With reference to the Ministry of Cultural Heritage and Activities and Tourism (MIBACT)'s decision to initiate a procedure to declare the former Tor Di Valle hippodrome as a site of "particularly important interest", the proponents of the Stadio della Roma – Tor di Valle project wish to make the following observations.
Ever since the preliminary project was submitted to the Municipality in May 2014 and reviewed by the relevant public authorities, the project has envisaged that the old hippodrome would be demolished, due to its dilapidated state, and replaced by the new stadium.
During the external Conferenza dei Servizi called by the Municipality in accordance with the stadium law to examine the preliminary project on 28 July 2014, the Regional Office for Cultural and Landscape Heritage requested only that:
- a) with regards to archaeological aspects, preliminary surveys be carried out;
- b) with regards to environmental aspects, buffer zones relating to the River Tiber and Valle dei Casali and Tenuta dei Massimi nature reserves be maintained; existing trees be protected and provisions made for their replacement; existing farmhouses be restored.
Subsequent memorandums released by various MiBACT branch offices make reference to the same points.
Particularly relevant is the opinion expressed by the Architectural and Landscape Heritage Superintendency in a memorandum dated 18 November 2014, which requested that “particular attention must be paid […] to specifying replacement criteria in relation to the demolition of the hippodrome and all of its architectural elements and related structures.”
After the proposal was declared to be “of public interest” by the Comune (A.C. 132/2014), the final project was presented to Lazio Regione.
During the decision-making Conferenza di Servizi the Archaeology, Fine Arts and Landscape Superintendency raised two main issues, principally regarding:
- a) the compatibility of the private high-rise constructions (the three towers) with the surrounding views;
- b) the carrying out of archaeological surveys, specifying that costs should be covered by the proponent.
During the Environmental Assessment Procedure (VIA) of 6 February 2017, the above-mentioned Superintendency, while making reference to the “value” of the hippodrome, did not express any views contrary to its demolition, but instead continued to cite concerns relating to other matters, such as the surrounding views and preliminary archaeological surveys.
These documents confirm not only that the procedure for placing cultural restrictions on the hippodrome was never mentioned previously, but also that it is in contrast with the assessments and opinions given at both the preliminary and final Conferenze di Servizi regarding a project that envisages the demolition of the hippodrome and the construction of a new stadium in its place.
The stands of the former Tor di Valle hippodrome are recognised by all parties as unequivocally unstable and dangerous structures, parts of which are covered in asbestos. They have been completely neglected for years, forgotten about even by the Superintendency itself, which has never undertaken any action to protect the area before we began working on this project.
The institutions have been aware of the situation for many years and gave the green light to the Stadio della Roma – Tor di Valle project in the knowledge that these structures, due to their state of disrepair, would inevitably be removed.
We are nevertheless willing to redevelop and retain a section of the stands in a dedicated area – once they have been restored and secured – in order to preserve their historical memory, as suggested by the Superintendency.
However, we would like to place on record that we find the timing of this issuing of an opinion by the Superintendency particularly odd, and we will pursue all possible actions to protect our project, the investors and public shareholders of AS Roma, and of course the fans, who find such untimely and seemingly hostile actions hard to comprehend.