Verifiable Administrative Investigation

Atri’s new school: we lined up the records.

Two worksites, three investigative chapters, €5.88 million in cumulative funding: from the 2023 tender to the 2026 completion certificate. A chronological reconstruction from resolutions, CUP codes, determinations, tender minutes and teaching standards.

Method: Official documentation and on-site checks
Monitored CUPs: B38E18000020002 / B33C25002520001 / B39J22004040002
Updated: September 2026

7 September is the scheduled inauguration of the new Mambelli-Barnabei school complex on Viale Umberto I, built on the site of the demolished former OMNI/INPS building. The administrative story, however, is not one worksite but two: the new timber structure on Viale Umberto I, and the complete demolition of the old Mambelli school on Via Finocchi to make way for parking and slope works.

We do not extract personal accusations or summary judgments. We extract precise questions, anchored line by line to the figures and resolutions of the Municipality of Atri. This reconstruction is divided into three chapters: from today's worksite back to the 2023 tender, and from there to the design competition that shaped the project from the very start.

In this investigation

  1. Chapter I — The questions came on their own: the economic framework, the 2026 progress payments and the mystery of the roof
  2. Chapter II — Back to the beginning: the August 2023 tender, the OS32 subcontract, the Heritage Authority's changes and the €565,000 multi-storey car park
  3. Chapter III — The questions were already in the FAQ: the 2023 design competition and the S1 planning-sheet problem
Chapter I

1. The dual funding channel: PNRR and GSE Conto Termico

The school was financed and contracted from the outset to near-zero energy standards (nZEB, class A4, photovoltaics and mechanical ventilation). A few months later, a second non-repayable funding channel was nonetheless acquired:

Funding channel CUP / Instrument Total amount Works contractor
PNRR Mission 4 CUP B38E18000020002 € 5,116,110.52 Ubaldi Costruzioni S.p.A.
Conto Termico 2.0 CUP B33C25002520001 € 766,360.40 Ubaldi Costruzioni S.p.A.
Cumulative economic framework (Det. 821/2026) € 5,882,470.92

Accounting question 01

If in July 2025 (NiiProgetti technical sheet ID 511703) the school was already designed as nZEB, class A4, with a heat pump and rooftop photovoltaics, which distinct and additional works were financed with the further €766,360 from GSE to turn that same building into an nZEB?

2. Timeline, progress payments, and the unanswered question of the roof

Piecing together payments scattered across separate acts produces a single timeline of what was paid to Ubaldi Costruzioni S.p.A. across the two worksites, PNRR and Conto Termico:

Date Act / Event Amount
202520% contractual advance (PNRR)€ 899,648.30 incl. VAT
2025Executive design share (integrated contract)€ 125,207.33 incl. VAT and charges
By 2 December 20251st PNRR progress payment€ 619,923.74 incl. VAT
12 June 2026Urgent handover of Conto Termico works (contract € 573,629.54 + VAT)
3 July 2026 (Det. 649)1st Conto Termico progress payment — 79.1% of the contract 21 days after handover€ 453,982.54 + VAT
7 July 20265th PNRR progress payment€ 375,215.07 incl. VAT
27 July 2026Certificate of completion of works (recorded by Det. 820 of 18/08)
12 August 2026Mayor's video on the roof: no photovoltaic module visible
18 August 2026 (Det. 820 + 821)6th PNRR progress payment + 1st Conto Termico progress payment, same day€ 1,028,630.97

Determination no. 649 of 3 July does not specify which works make up the € 453,982.54 accounted for just three weeks after handover. The completion certificate of 27 July, cited by Determination no. 820 of 18 August, is not publicly available online: we know it exists, we don't know what it attests to — remaining works, prescriptions, deadlines for completion.

On 12 August the Mayor publishes a video shot on the school's flat roof: parapet, gravel and surrounding buildings are visible, but across a wide filmed area no photovoltaic modules nor their mounting structures are visible — despite the rooftop photovoltaic system already being described in the July 2025 NiiProgetti technical sheet. Was the photovoltaic system among the works certified as completed on 27 July? If so, the 12 August images need explaining; if not, it should be stated what was still left to finish.

As of this check, Ubaldi Costruzioni S.p.A. itself still classifies the project on its own website among "works in progress" — this may be an outdated page, but the fact remains that this is what it says today.

Chapter II

3. Back to the beginning: the August 2023 tender

To understand how today's worksite came about, we need to go back to the project put out to tender three years earlier. Checking the regional PNRR programme for school buildings, Atri's project ranks second by amount in Abruzzo among those included in that programme, surpassed only by a Province of Chieti project worth just over €6 million: for the municipal coffers this is not an ordinary figure, comparable in historical scale to only a few other public works in Atri (such as the Centro Turistico Integrato with its ice rink, which cost 9 billion old lire, albeit over a much larger area).

Tender procedure timeline (€ 4,240,922.06 estimated contract value, integrated contract)

  • 9 August 2023: the tender base project is approved. 11 August: the contracting determination.
  • 14 August 2023 (Ferragosto): invitation letters sent to 10 economic operators on the ASMECOMM platform. Bid deadline: 18:00 on 31 August.
  • The tender rules expressly allow the contract to be awarded even with a single valid bid, provided it is adequate and convenient, and the procedure starts while some opinions still needed to approve the executive project are pending — already contemplating the possibility of later changes.
  • 22 August 2023: an operator holding only the OG1 VIII qualification asks whether it may take part by fully subcontracting the separable OS32 category (timber structures, € 511,817.10 out of € 3,364,976.83 of OG1).
  • 25 August 2023: an operator reports being unable to generate the PASSOE or pay the ANAC contribution because the CIG (tender ID) has not been finalised.
  • 28 August 2023, 12:31: the Municipality announces the problem is resolved, also correcting a typo in the CIG in the invitation letter — but the deadline for clarifications had already expired at 10:00 that same morning, and just over three days remained to submit a bid.
  • Outcome: of the 10 operators invited, only one submitted a bid. Ubaldi Costruzioni S.p.A. is awarded the contract with a 0.50% discount on the works and 0.50% on the design — € 15,379.86 off, "roughly a coffee's worth per Atri resident".
  • 13 September 2023: formal award. The determination cites four committee meeting minutes, including the closed session of 6 September 2023: the minutes and the technical bid exist, but are not available in the public area of the tender consulted.

The project put out to tender was not just the school building: it also included the demolition of the old Mambelli-Barnabei and the former INPS building, an underground car park, an underground connection, the gym's roof and systems, and the redevelopment of Largo Cherubini. The award mechanism weighted price at only 20 points out of 100: 70 went to the technical bid (up to 15 points for heat pumps and mechanical ventilation, up to 10 for photovoltaics, plus home automation and thermal/acoustic comfort), 5 to design price, 5 to time. Without the winning bidder's technical bid, we don't know what was actually proposed and rewarded with those 70 points.

The subcontract and a coincidence of dates

The only bid submitted came from a company holding OG1 VIII. On the worksite sign, among the subcontractors, appears My House Legno S.r.l., a specialist in X-LAM timber structures — likely assigned the OS32 category that was the subject of the 22 August query. My House Legno's currently published SOA certification was issued in February 2025, but it lists the issue date of the original certification as 3 August 2023: eleven days before the invitations for the Atri tender were sent. The current document does not reveal which categories that first certification covered — the SOA actually valid in August 2023 needs to be retrieved.

A side note, without conflating separate tenders: My House Legno and Acotec Costruzioni Tecnologiche S.r.l. also appear together in Atri's other PNRR school worksite, the new Fontanelle nursery school (awarded for € 499,385.45 + VAT with a 3.13% discount, contract signed 18 December 2024). These are two separate tenders and two different contractual roles: for now we simply note that the same two names recur in both worksites.

4. After the award, the project changes

On 27 October 2023 the RUP (person responsible for the procedure) asks the designers to rework the executive project, citing the area's archaeological risk and the schedule imposed by the funding. On 8 November a meeting is held with the Heritage Authority (Soprintendenza), which does not halt the project but triggers a preventive-protection procedure (an archaeologist present during excavation). The Administration decides to reduce the excavation areas: Largo Cherubini is removed from the most invasive works and the underground car park and underground connection to the former Bargiglione gym disappear. Added to this, after protests and public debate, is the decision to preserve the large Cedar of Lebanon, whose root system requires a further redesign of the area.

Between November 2023 and January 2024, new solutions are developed and accepted in October 2024; the executive project is submitted in November 2024, but on 27 February 2025 the Ministry requests further additions (including explanations of the parametric cost); a new version follows in March 2025 and finally the executive project is approved on 5 June 2025 — almost two years after the tender, with a project that no longer matches the one from August 2023.

Three timelines that don't add up

The contract record shows signing on 7 December 2023, start on 30 November 2023, and a deadline of 29 May 2025 — but the executive project following that rework is approved on 5 June 2025, after that contractual deadline. The PNRR concession agreement instead set: award by 15 September 2023, start of works by 31 December 2023, completion of works by 31 March 2026, testing by 30 June 2026 (a date still appearing in the Municipality's 2025 PIAO next to the Mambelli-Barnabei CUP). The dates we know today are different: 27 July 2026 for the completion certificate and, according to what was communicated to council members, 31 August 2026 for the completion of the works. What's needed are the records — extensions, suspensions, resumptions, deferrals, ministerial changes — that reconcile these three timelines.

In the final executive project, the intervention is split into two phases: the first, funded by PNRR, keeps the school and the directly connected works; the second covers the external landscaping and Piazza Cherubini, to be carried out with other municipal funds or other public funding.

5. The tree count, with the project's own numbers

The executive project indicates 23 tree specimens to be removed and 8 new specimens to be planted in the works area (among them, Acer Negundo Argenteovariegatum specimens along Viale Umberto I and three Prunus Cerasifera Pissardii in the Largo Cherubini car park). The Cedar of Lebanon is preserved. The report further specifies that, keeping the felling at 23, once on-site plantings are accounted for another 35 specimens would remain to be planted at the Municipality's expense in other public areas.

The question thus becomes a concrete check: how many of the 23 planned removals were actually carried out, how many of the 8 new plantings were actually put in the ground, and where have or will the further 35 specimens at the Municipality's expense be placed?

6. A worksite arrives in front of the high school

On Via Finocchi the old Mambelli school has been demolished: today a large open area is visible, with works on the slopes and materials for the new car-park layout. School activities at the adjacent secondary schools have already resumed, and in front of the high school's entrance numerous pallets of concrete blocks have been stacked, with cracking and visible deterioration of the pavement under and near the storage area. Has the area's suitability to bear that load, the stability of the pallets, and the safe separation between the worksite and the paths used by students, staff and anyone accessing the school been verified? There is no need to wait for the final inspection here: the school next to the worksite is already in use.

7. The €565,000 multi-storey car park: a separate project, the same area?

Within the same urban transformation around the school appears a project with its own CUP and funding. Determination no. 862 of 27 August 2026 concerns "Sistemazione delle aree di parcheggio e trasformazione in zone di scambio intermodale con sistemi di mobilità sostenibile" [Reorganisation of parking areas and their transformation into intermodal interchange zones with sustainable mobility systems] in the Municipality of Atri — CUP B39J22004040002, total amount € 565,000. In the act's own financial framework, the commitment is described more directly as "construction of a multi-storey car park".

ItemAmount
Abruzzo Region contribution€ 131,903.40 (in the final ruling: € 132,903.40)
Financed through another public project€ 432,096.60
Works financed by the regional contribution€ 91,197.93
Works financed with other funds€ 354,177.54
Sums at the contracting authority's disposal€ 119,624.53

The main works were awarded for € 90,970.96 plus VAT, handed over on 11 November 2025 and completed on 30 December 2025; the final account and the certificate of proper execution were approved on 27 February 2026. The determination thus confirms a publicly funded, awarded and formally concluded public project — but a separate one from the school: the new Mambelli-Barnabei on Viale Umberto I has CUP B38E18000020002 (PNRR), while this multi-storey car park, linked to the former Mambelli site on Via Finocchi, has CUP B39J22004040002. The Via Finocchi worksite photographs show precisely this area.

The determination does not expressly state the plot's surface area, the number of levels, the number of parking spaces, nor the total area actually built.

Two inconsistencies in the text of the act

The determination's subject line shows CIG B8F005AC7E, while the operative section shows CIG BCC9B481BA. The regional contribution is also not reported consistently throughout the document: € 131,903.40 in the narrative section, € 132,903.40 in the final ruling. These are not enough on their own to suggest irregularity, but they make it necessary to read the executive project and the full economic framework.

The main question: is the € 565,000 multi-storey car park a project entirely separate from the new school, or does it include works, areas or arrangements already planned in other projects — including the underground car park removed from the school's executive project after the Heritage Authority's intervention? Answering this requires the site plan, the bill of quantities, the economic framework, a precise indication of the areas involved, the executive project, and the official number of parking spaces.

8. Teaching: music track (DI 176/2022) and specialist spaces

Beyond the disappearance of the two-level underground car park and the gym (originally planned on the former Bargiglione site), the new building must meet the pedagogical and regulatory criteria of public school construction:

Teaching standards to verify

  • Interministerial Decree 1 July 2022, no. 176: Atri's lower secondary school has a music specialisation. The rules require dedicated rooms for individual lessons (piano, violin, guitar, flute) and a soundproofed, enlarged classroom for ensemble music and orchestra rehearsals with fixed music stands.
  • Existing laboratories: Have the Science classroom and the IT classroom (previously funded by ministerial calls) been relocated with compliant floor areas?
  • Inclusion and SEN: Have dedicated spaces been provided for regulation/decompression and support for pupils with special educational needs and severe disability, or is teaching compressed into the 9 core classrooms alone?

Matches in the Register

Some of the acts and codes cited in this dossier are already in the Records Register, each with a link to the official document. Here is where to find them:

Mambelli-Barnabei school — CUP B38E18000020002

Multi-storey car park — CUP B39J22004040002

Not yet in the Register: CIG B8F005AC7E, CUP B33C25002520001 and determinations 649, 820, 821 and 862/2026 do not yet appear with a public record; they are among the documents still to be obtained, listed below.

The public documents needed

To move from doubts to objective checks, controversy is not what's needed. What's needed are administrative documents that the law treats as disclosable:

A question for the council members

Majority and opposition council members have the tools of their mandate to obtain these records, verify them, and formally request explanations. The dates, CUPs, amounts and determinations are identified in this dossier: whoever believes a simple explanation exists can obtain the documents and make it public; whoever believes there is something worth looking into further can turn these questions into a formal council question. There's no need to pick a thesis before seeing the papers: what's needed is to ask for the papers.

Chapter III

9. The design competition: the questions were already in the FAQ

Before the 2023 tender there is an earlier step, where the Municipality defined the project, identified the site and set the objectives for the designers: the design competition. With City Council resolution no. 30 of 14 February 2023, the Design Guidance Document (DIP) is approved for a two-stage competition for the new lower secondary school.

The project outlined by the DIP was already broader than simply building a school: it included demolishing the Mambelli-Barnabei on Via Finocchi, making the area safe and levelling it, building car parks, and relocating the school to the former INPS site opposite the Istituto Comprensivo. The new school had to have at least 9 classrooms plus services, meet school-building standards, and include physical-education spaces — as well as a gym (or at least a room for physical activity) in the area behind the Istituto, where the old Bargiglione gym once stood. The economic framework set a maximum sum of € 5,116,110.52, increasable only for the costs of demolishing and disposing of the former INPS building.

The competition is published on 17 February 2023. Six competitors take part in the first stage, two make it to the second: Officina Tecnica S.r.l. wins with 75.583 points out of 100; second is the Buzzelli–Angelucci–Tupone group, with 69.334 points.

The surface-area problem

The area lies in the historic-centre zone, governed by Project Sheet S1 of the Detailed Plan: an existing covered surface of about 345 sqm, no increase allowed to the covered surface (only to the usable floor area), maximum height 8 metres. One competitor does the math in the tender queries:

  • 9 classrooms × 225 pupils × 9.61 sqm/pupil (standard) = 2,162.25 sqm minimum gross floor area required.
  • Minus about 700 sqm for the physical-education space = ~1,462.25 sqm needed for the school and its services.
  • With 345 sqm of covered surface over three storeys, only about 1,035 sqm total is achievable.
  • Shortfall: about 427 sqm.

Asked how to reconcile the project with Sheet S1, the Municipality replies in the FAQ: "As already indicated in the DIP, it is possible to propose variants to the project sheet." Asked what "modest variants" should be understood to mean, it replies that deviating from the Sheet's indications is allowed to the extent necessary to meet school-building standards. But a designer can propose a solution within the competition — they cannot unilaterally amend a planning regulation: a genuine variant to the PRG or the Detailed Plan would normally require passage through the City Council, publication of the records, the possibility of objections, and final approval.

The passage through the City Council

According to what a council member privately reported, this passage through the Council was never carried out — information still to be verified in the records. If confirmed, it would be decisive: if Sheet S1 banned an increase in covered surface and the building was authorised or built beyond that limit without a validly approved variant, this would raise a planning/building compliance issue to be ascertained. It cannot yet be said that the school is unlawful: the act that would have amended or waived the Sheet, and who approved it, still needs to be found.

Two more passages from the FAQ are worth recording. Several competitors point out that the site survey (including elevation data) is missing from the tender materials and ask for an extension to properly prepare their proposals: the Municipality replies that the survey was not available and that all checks were left to the candidates, and denies the extension ("No extensions can be granted for this procedure"), while still requiring a technical report, drawings, a bill of quantities, an economic framework, a schedule, and a management/maintenance assessment. On the number of parking spaces, the answer is that "none has been set", leaving the choice to the designer's judgment. On the gym, finally, the political section of the DIP speaks of a "school gym" while the technical section speaks of a "room for physical activity" — a terminological difference that does not clarify what structure was actually meant to be built, and which today translates into the fact that gym not having been built in the announced form.

What's still to be compared

  1. What surface area was planned for the school and how the limits of Sheet S1 were meant to be respected
  2. Whether a genuine planning variant was approved, and by whom
  3. Whether the gym was present in the winning project, and in what form
  4. What parking had been designed
  5. Whether deep excavation or underground connections were planned, and when they were removed
  6. Which works from the feasibility project were eliminated or changed, and where the related funds ended up

A question for the five opposition council members

The questions in this chapter were not invented after the works began: they were raised in 2023 by the very professionals asked to design the school, and they already covered all the main issues — surface area, height, school standards, planning law, the variant, surveys, parking and the gym. Were you aware of the contents of the Design Guidance Document, the competition FAQ, and the issues concerning Sheet S1? If so, since when were you aware, and what steps did you take?

For now we remain waiting for the final testing certificate. Once it is available, this dossier will return to the subject to complete the comparison between the original project, the changes made, and the work actually built.