Comino development: why the plans should be withdrawn

March 22, 2023 1:20 pm

Comino is a small uninhabited island of 3.5 km2 located between Malta and Gozo. It is home to many species of birds. Unfortunately, Comino has become the centre of a debate between developers and environmentalists. The Comino Hotel project is at the heart of the debate. It threatens to destroy a fragile and protected ecosystem. The project risks irreparably damaging the island’s biodiversity and wiping out endangered species for good.

A disproportionate project

Comino project before after
Before and after… what the Hili Group’s project will do to Comino

According to the developers, the proposed development seeks to rebuild the 1960s hotel and bungalows after many years of disrepair. The new development, according to Hili Group’s hospitality subsidiary, HV Hospitality, would create a “Zero-Net-Carbon” and “higher tier of hospitality” consisting of a 71-suite hotel and 19 serviced bungalows on a building gross floor area of circa 5,211m2. The developers are claiming that the overall footprint of the new development would be smaller than the existing site. They also claim that the project would be less bulky than the existing site (source).

However, this is not true. According to the Times of Malta’s fact-checking service, the project will consist of more built-up area than the existing site, with the gross floor area set to increase by a total of 3,264 square meters, a 33% increase from the existing site. This means that the project will be more extensive in terms of area than the previous one. Apart from this, the development will replace the derelict bungalows at Santa Marija Bay by a larger complex of 19 villas complete with a convenience store and amenities.

But how can nature ever benefit from such a project? Is it fair to claim it will be carbon-neutral when it will change Comino – an island so far unspoilt by buildings – for ever? And when a recent study by MHRA found that there are more hotels than needed in Malta?

Why is the island of Comino in danger?

For BirdLife Malta, the construction of an upscale hotel and bungalows in Comino would cause significant damage to natural habitats, disrupt wildlife and cause light pollution that could harm or even kill migratory birds.

Let’s remember, Comino forms part of the Natura 2000 network of protected sites – a sensitive area. This means that for the European Union, Comino is a natural site with great heritage value, for the exceptional flora and fauna it is home to. It is also an important breeding ground for many species of birds, including the Yelkouan Shearwater, which we are strongly protecting through our LIFE PanPuffinus! project.

Joint ENGO press conference Hili Ventures offices Malta Comino Project
Joint ENGO press conference held in front of the Hili Ventures offices in Marsa earlier this month (Photo by Moviment Graffitti)

Apart from this important status, Comino is also designated as a a Rural Conservation Area, a Nature Reserve, a Special Area of Conservation, and Special Protection Area (within the Natura 2000 network), an Important Bird Area (IBA) of International and EU Importance, a Bird Sanctuary, and a Dark Sky Heritage site.

Starting from this principle, do we really need to justify why the island of Comino is threatened?

Together with other local ENGOs, we are strongly opposed to this project, which will have a devastating impact on the natural and cultural heritage of the island. The project threatens to increase the number of people on the island, and this will bring with it more noise, more light pollution, and more disturbance, especially at Santa Marija Bay.

The project goes against the spirit of Comino as a nature reserve, and we are unaware of the effects of tourism on the wildlife. Furthermore, the project would lead to a commercialization of the island for the benefit of investors, transforming it into a playground for tourists and an impediment to the rights of the Maltese population.

The promoters try to justify the project by saying that it would be good for revitalizing the island’s tourism industry. However, we would like to point out the high cost of the construction (estimated at €120 million according to the promoter), which in no way justifies the destruction of this priceless natural heritage.

comino development hotel
The hotel built in the 60s and now abandoned (Photo by Nik Barbara)

An unpopular project rejected by locals

Moviment Graffitti protest on 11 June 2022 (Photo by Moviment Graffitti)

Moviment Graffitti launched a petition a few months ago to protest against this project. The result was overwhelming: a record 13,500 objections submitted to the Planning Authority. This makes this project one of the most unpopular in Malta’s history. Environmental protection organizations have organized demonstrations and press conferences to demand the withdrawal of the application. However the Hili Group seems determined to go ahead with this controversial project without taking into consideration the many objections and protests.

“Plans to create a complex of villas disfiguring Santa Marija Bay on the island of Comino as part of the proposed Comino Hotel redevelopment have received strong opposition from the public after a call to action from environmental groups. (…) This level of public anger makes it difficult to see how the PA could possibly approve this destructive scheme being proposed by Hili Group,”

ENGO Moviment Graffitti

At the time of writing this blog, plans for the project still stand, with the Environment & Resources Authority (ERA) having given its approval of the Environment Impact Assessment (EIA), and the Planning Authority evaluating the application to be able to take a final decision in regard to the permit.

We would like to sincerely thank Moviment Graffitti, Din l-Art Ħelwa, Flimkien għal Ambjent Aħjar, Friends of the Earth Malta, Nature Trust – FEE Malta, and Ramblers Association Malta for joining us and the general public in this fight. All above-mentioned ENGOs have appealed ERA’s disgraceful approval of the Environemt Impact Assessment (EIA) before the Planning Tribunal (EPRT). We will fight until the end to defend Comino’s pristine state and the rights of 13,500 Maltese citizens who signed the petition against any development on Comino! Our call is for the plans to be withdrawn immediately.

By Antoine Monnier, BirdLife Malta Communication Assistant
Antoine Monnier is an Erasmus+ volunteer following a European Solidarity Corps programme