Environmental NGOs to challenge ERA’s refusal to publish Carrying Capacity Assessment for Comino

May 25, 2024 8:55 am

Seven environmental NGOs shall be supporting an appeal against a decision by the Environment and Resources Authority (ERA) to not publish a visitor Carrying Capacity Assessment for the island of Comino, despite repeated attempts to release this document publicly. The need to carry out such an assessment featured as a requirement from Comino’s Management Plan for the island which was finalised in 2014, which management plan had set a number of targets and priorities aimed at preserving and restoring the island’s biodiversity.

Initial requests for the study’s release by BirdLife Malta representatives were denied by ERA, prompting BirdLife Malta to file a Freedom of Information (FOI) request last October 2023. ERA sought an extension to respond, eventually stating in December that the document could not be released since this was a reserved matter requested by the Cabinet of Ministers. BirdLife Malta escalated the issue by filing a FOI complaint, leading to an investigation by the Information and Data Protection Commissioner (IDPC). The IDPC’s investigation concluded that a note from the Cabinet’s Secretary stated that this was requested by Cabinet, and that the document was lawfully exempt from being released.

ERA continues to block publication of this important study, as impunity of commercial operators persists on the island for another summer

In response, BirdLife Malta and six other ENGOs will be filing an appeal in front of the IDPC Tribunal, arguing that the visitor Carrying Capacity Study is not a Cabinet prerogative, but a requirement of the 2014 Comino Management Plan commissioned by ERA itself, which is meant to guide policy-making and conservation measures for the preservation of the island.

Photo taken on 23rd May 2024 by BirdLife Malta showing a new vendor/kiosk camped at Santa Marija Bay on Comino without ERA permits

The ENGOs condemn ERA’s refusal to release this critical documentation. The intervention of Cabinet’s Secretary to support such a block suggests a reluctance to address the mass tourism issue on Comino which is causing significant environmental impacts while generating profit for service providers, operating legally and illegally.

Santa Marija Bay, in fact, has over the past days seen the setting up of another beach kiosk without any relevant permits issued by ERA to authorise such activities within the Natura 2000 site. On the other hand, ERA has in the past days authorised kiosk operators to camp at the back of Santa Marija Bay until the end of September 2024, despite the setting up of a dedicated camp site for the public on another part of the island. Last year, in April 2023, sunbeds appeared in a new area on Comino, away from the usual concessions granted at the Blue Lagoon, adding encroachment of commercial activities on the protected Natura 2000 site.

Photo taken on 21st April 2024 by BirdLife Malta showing eight kiosks and vendors already lining up the access way to Comino from Blue Lagoon ahead of the start of peak tourist season

Meanwhile, proposals for rebuilding of the Comino Hotel are still under review, with environmental NGOs challenging the Environmental Impact Assessment (EIA) carried out to determine the hotel’s impact on the Natura 2000 site. Amongst the various flaws challenged by the NGOs, the impact assessment did not outline the number of extra visitors to the island a renewed hotel and its facilities would generate on top of the already tourist-packed island during the summer months.

We are appealing to government to shy away from commercial operators’ interests and come clean on the island’s limitations to support sustainable tourism, giving priority to nature protection over an ever-increasing exploitation of the island for profit. Comino’s future as a pristine island to be enjoyed by all, now and in the future, depends on a long-term strategy at safeguarding the island, with adequate planning and enforcement aimed at maintaining sustainability and not at fattening the pockets of selected operators at the expense of our natural heritage. We also want to warn against the commercialisation of Santa Marija Bay which would eventually replicate what is happening at Blue Lagoon.

Environmental organisations:
BirdLife Malta
Moviment Graffitti
Flimkien għal Ambjent Aħjar
Din l-Art Ħelwa
Friends of the Earth Malta
Nature Trust-FEE Malta
Ramblers’ Association of Malta

Read the Maltese version of the press release here.

Deckchairs and umbrellas encroaching on a new area north of the Blue Lagoon by one of the operators in May 2023. Despite complaints by NGOs, operator is still utilising this area even during this summer