Millions in EU funds designated for enhancement and restoration of ecosystems in farmland were used in Gozo to rebuild stretches of “rubble walls” backed by blocks of limestone and cement, and only superficially clad by unhewn rubble stones, a journalistic investigation can report.
The investigation has also found that these walls do not adhere to the definition and protection afforded to rubble walls in law, and diminish rather than enhance biodiversity.

The funds were granted to the EcoGozo Directorate, which is tasked with steering Gozo towards sustainability and protecting nature. They came from the European Agricultural Fund for Rural Development (EAFRD). The directorate, within the Ministry for Gozo, received three grants: just over €10 million for “Gozo’s valleys”, €2.3 million for Ramla Valley, and €371,000 for Marsalforn Valley.
Each of the funds was for the construction or restoration of rubble walls, awarded under Measure 4.4 – one of 4 measures under the title of Restoring, Preserving and Enhancing Ecosystems in farmland areas.
The project description for the grant of €10 million was for “rehabilitation of Gozo’s valleys to enhance their rain capturing and soil retention capabilities” and the works involved “building and restoring dry stone and rubble walls.”
The walls were mostly built along roads that skirt valleys, some of them being main roads between towns or villages. At least one road was on a plateau – the road that leads to San Raflu from the fringes of Kercem. Walls along that stretch can hardly be described as having a priority when it comes to soil retention in Gozo as the fields are on a plateau and level of that road only marginally lower than level of fields. In another two cases, the fields were at a lower level than the road, and as such there could be neither soil erosion nor “soil retention.”

In a bid to check all the roads, I asked Anthony Camilleri, the director general of the Funds and Programmes Division within the Maltese government, for a list of the locations or roads where this work was taking place. Camilleri twice said he needed more time to reply, but then he never sent me the list despite reminders and the passage of months.
So – I used information from sources, press releases, and Facebook posts of the Minister for Gozo, Clint Camilleri, to locate the roads where the walls had been or were being built.
According to a source at the Ministry of Gozo, the walls along a largely flat stretch of the road from Rabat to Nadur, at Ta’ Xhajma, were also rebuilt from these funds even though the level of the road is slightly higher than the level of the fields beyond, and as such there is no soil for the walls to retain. In that case, the walls are behind a strip of greenery that serves to separate road from fields – which, as already pointed out, are at lower level than road – and those works can be described as infrastructural improvement – a more aesthetic, newer and higher wall than the one that existed. Similarly, a stretch of the arterial road between Rabat and Xaghra can be more fittingly described as infrastructural work.

When the work neared its completion, two years ago, the Minister for Gozo in a press release boasted that more than 30km of walls had been built.

Two years later, many stretches of these walls remain visibly devoid of flora and fauna. In normal rubble walls, with soil filling the cavities of the wall and some moisture remaining within the wall as the surrounding fields bake dry in summer, various species of flora and fauna find refuge in the wall. Other shrubs grow at the base of the walls, creating micro-habitats and a micro-climate – and a habitat protected in law. But in significant stretches of the walls built with EU funds in Gozo in recent years, little soil, if any, can fill the cavities and the walls remain relatively barren of wildlife. This is because the backing is of cement and blocks of limestone, or cement that has been poured as infill in some areas, or in some other areas walls constructed of broken limestone sourced from building demolitions. (For full description of rubble walls as habitat, see box below).

Destruction of protected trees and damage to valley
At a stretch of 2km at Ramla Valley, funded by €2,234,700 of rural funds for “building and restoration of dry stone and rubble walls”, the works tore up the valley in breach of planning permit conditions and environmental regulations.
Ramla Valley is one of the strongholds of chaste trees, which only occur in various valleys in Gozo within the Maltese Islands. The works, which involved excavation by mechanical excavators, destroyed at least two large chaste trees.

This led to the Environment and Resources Authority (ERA) to issue a fine to EcoGozo Directorate that was, according to a source, between €10,000 and €20,000.
The works were also radically different than described when the Ministry for Gozo had applied for a planning permit. ERA was initially opposed to the works, but then it dropped its opposition to the planning permit after the project architect, Godwin Sultana, drafted a Comprehensive Method Statement.
The works, according to the method statement, were intended “to repair existing walls which are structurally sound by traditional means in order to maintain its [the wall’s] integrity” and to “replace unsound walls with traditional rubble walls characteristic of the rural environment.”
“The project,” wrote the architect, “seeks only to work within the footprint of the existing walls maintaining existing dimensions.”
The method statement further specified that the walls would be “built from different sizes of limestone blocks (tal-Franka or tal-Qawwi), roughly fitted together with minimal clearance between adjacent stones and no use of mortar.” Moreover, “structurally unsound” stretches of walls would be “carefully dismantled” using “equipment” that is normally employed in “minor excavation works, minor concrete works, and masonry works.”
The works were contracted to Little Rock Quarry Limited, whose owners have other companies that are involved in road building (such as Road Construction Company Limited) and quarrying, as well as property development (via a company called Road Construction Properties Limited). The works involved diggers, excavators, trucks and cranes, and they were carried out mostly by labourers from southeast Europe – Albanians, according to a source.

Rather than having works “carefully managed to ensure that disruption to the surrounding areas is avoided,” as promised in the method statement, the existing walls were bulldozed and soil and substrate dug up at the sides of the valleys to make room for thick walls – much thicker than what existed before – built of globigerina blocks of limestone. The rough unhewn ‘rubble’ stones were then set at the outer level, merely as cladding, with cement inbetween the blocks of limestone and the unhewn stones, presumably to fix or anchor the ‘rubble stone’ cladding.

Works were halted when I sent queries to the Planning Authority and ERA (Environment and Resources Authority). That is when ERA fined EcoGozo – the entity that was formed to protect nature in Gozo.
The works then resumed a few months later. And in response to further questions, the Planning Authority told me that the resumption of work consisted of “remedial works” whose purpose was to “shore up collapsing walls and clear any loose debris from the valley system following this year’s storm.” These urgent works, it said, had to be carried out “to avoid danger to public and the free flow of storm water.”

Works dragged on, and the second wall, between the road and valley, was only in recent months.
I asked Anthony Camilleri, director general of the Funds and Programme Division, if the Managing Authority, the entity within the Maltese government that manages EU funding, would withdraw the funding on the basis that the “rubble walls” were in breach of regulations on rubble walls, in breach of the Planning Authority permit conditions, and ostensibly did more damage than good to biodiversity.
He wrote that EU funding “is possible only when projects being supported are in line with all the pertinent regulatory obligations,” and that the Managing Authority is “liaising with the authorities responsible for planning and environment obligations.”
But he declined to reply definitively to a question on whether funding for the Ramla Valley works had been withdrawn.
More cement and demolition waste
In one of his Facebook posts about the construction of the EU-funded rubble walls, Gozo Minister Clint Camilleri wrote about “strengthening traditional infrastructure for soil retention” as well as the “added value” of attractive rural roads that “complements the natural beauty of some of the most attractive countryside walks.”
In law – specifically, the Rubble Walls and Rural Structures (Conservation and Management) Regulations of 1998 – rubble walls are declared as “protected” due to “their historical and architectural importance, their exceptional beauty, their affording a habitat for flora and fauna, and their vital importance in the conservation of the soil and of water.”
The law defines rubble walls as “a dry stone wall, built in loose unhewn or rough-dressed stones which stands by gravity and friction without the use of mortar.”
That means that significant stretches of the more than 30km of rubble walls built from the EU’s rural development funds, which has the overarching aim of enhancing biodiversity, were not built in conformity with the law.

Aside from the walls in Ramla Valley mentioned above, I found other stretches of walls that were backed by cement or globigerina limestone. These included wall along the road that runs along Ta Zejta Valley, as well as the road from Rabat to Kercem. I did not manage to visit all walls during the construction stage, and as such it is not possible to be sure of all the ones, or which ones, that were backed with stones or cement, and only clad with unhewn stones.


I did find stretches entirely built from rubble stones, and my estimation is that some, not most, walls were backed by a layer of cement and globigerina limestone.

However, I also saw other things: in two areas in which the walls were built entirely from rubble – or unhewn stone – cement was poured into the core of the walls to give the stones anchorage, and the wall strength and durability. This is also in breach of law, and such walls end up having cement – not soil – fill some or most of their cavities, thus impeding the formation of micro-habitats within the wall.
In another stretch, at the west of Gozo, a significant amount of the material that was being used to construct the ‘rubble walls’ was demolition waste. This is a deviation from traditional, classical rubble walls, which are constructed of a mixture of stones, upper coralline limestone mostly but also some globigerina limestone. Such walls also make poor habitats for flora and fauna.

In fields, such stones tend to be found within the soil, and rubble walls traditionally served three purposes: the clearing of stones mixed within the soil for better soil management, division of land-holdings and, on slopes, preventing soil erosion.
I also saw a few stretches of walls apparently funded by the EU’s rural funds to be constructed mostly of roughly broken globigerina limestone. The provenance of such limestone is demolitions of houses and buildings, with limestone blocks then further broken before being used to construct the EcoGozo’s “rubble walls.”
The use of such limestone reached its greatest prevalence at Ta’ Xhajma, part of the road between Rabat and Nadur. A source told this journalist that the walls on that road were also funded by the same €10 million grant of EU rural development funds, but this could not be independently verified. (As already pointed out, the director general of the entity in charge of EU funds in Malta, Anthony Camilleri, failed to provide a list of roads where rubble walls were built.)

Funding of fake rubble walls a missed opportunity
The grant of €10 million (precisely it was €10,091,000) as well as the separate grant for €2.2 million for building or restoring rubble walls awarded to the Ministry for Gozo were by far the largest grants awarded under Measure 4.4 in the 2014-2020 allocation of rural development funds.
The third largest grant, of over €700,000, was awarded to the Ministry for the Environment for the restoration and construction of rubble walls at Wied Ghajn Rihana.
All the rest were grants of less than €150,000 – this was the cap for individual landholders – and a significant number of grants were awarded to Local Councils, also for the construction of rubble walls along rural streets.

Only a small number of grants were awarded to farmers in Gozo. The largest individual recipient in Gozo was Daniel Refalo, of DTX Holdings, a developer who is a partner in Excel Investments Limited, a company whose majority shareholder is property magnate Joseph Portelli. Excel has carried out numerous developments in Gozo, and Malta to a lesser extent.
Refalo got two grants, one of €150,000 to construct rubble walls and the second of €149,438, granted as “support for investments in agricultural holdings.” Refalo has planted trees and vines, fashioned two ponds, and constructed rubble walls, on terraced fields at a hillside in Xaghra.
In many hillsides in Gozo, rubble walls that once existed along terraced fields are mostly in a crumbled or collapsed state.
I spoke to various farmers about the rural development funds to gauge their interest, and all of them told me they were not aware that, as individual farmers or landholders, they could procure funds to restore rubble walls in their fields.
In this sense, with farmers not aware of these funds and rubble walls throughout Gozo’s hillsides increasingly in a collapsed state, the allocation of millions to the Ministry for Gozo for buildings infrastructural walls along roads – a significant part of them “rubble walls” in appearance only, fake rubble walls – represents a lost opportunity to tackle soil loss on Gozo’s hillsides and restore walls that constitute a habitat.
This article was supported by S-Info and funded by the European Union. Views and opinions expressed are however those of the author only and do not necessarily reflect those of the European Union or the European Education and Culture Executive Agency (EACEA). Neither the European Union nor EACEA can be held responsible for them.
The environmental NGO Flimkien Ghal Ambjent Ahjar collaborated with the author on the S-Info project.

