Comino represents the last frontier to many Maltese, epitomising the last vestige of wilderness on these largely gentrified islands. So much so that the number of campers who seek to get away from the maddening crowd by living it rough on the islet has swollen in recent years.
As far as local jurisdictions are concerned, Comino is ‘annexed’ to Gozo, given that it is directly administered by the Ministry of Gozo. It comes as no surprise therefore that the ministry was behind the latest unilateral move to scarify the islet by summoning heavy machinery in order to formalise the main dust-beaten track on the islet as well as the access road to the Blue Lagoon.
The Ministry of Gozo had applied in August 2018, through PA 07028/18, to get the green light for the innocuous sounding ‘Resurfacing of existing surface road towards Blue Lagoon’. No decision on such an application had been taken to date, although the case officer was recommending refusal, mainly on the grounds that “the applicant had failed to provide the requested information within the stipulated time frame... to enable a complete assessment in terms of environmental and landscape requirements”.
This recommendation might have forced the ministry’s hand by initiating works in blatant disregard to the fact that no permits were in hand, despite the public assurance by the same ministry that all permits from the relevant authorities had been obtained. The timeline of the faux pax on Comino is vaguely reminiscent of the unauthorised (initially) works by Infrastructure Malta within Wied Qirda in Żebbuġ, which were only ‘sanitised’ through a convoluted revision of method statements by IM.
A slew of environmental NGOs, most notably Friends of the Earth and Birdlife Malta, have flagged the incursion on Comino, calling upon the ERA, as the local custodian of Natura 2000 sites, to embark on urgent action to stall the works. Comino in fact, should, at least on paper, be safeguarded through a plethora of environmental legislation and policies, being designated a Natura 2000 (MT0000017) site by virtue of both the Habitats and the Birds Directives and as a proposed Area of Ecological Importance and Site of Scientific Importance, besides supposedly enjoying refuge under a welter of SPED and Gozo and Comino Local Plan policies.
Concerning the latter, policy GZ-GHJN-11 is especially relevant to the current context in that it stipulates that “Consolidation of the existing routes on Comino through a method which reduces surface wear but at the same time having a surface which resembles a pedestrian country-path will be promoted. Limited inconspicuous signage (not pole mounted) may be permitted at the route intersections. Artificial illumination of the pedestrian and vehicular routes on Comino shall be prohibited”.
I wonder if those who authorised these roughshod works on Comino within the ministry are actually aware of these policies or even of the sheer ecological importance of the site to which they decided to transport their hardware.
Comino epitomises the last vestige of wilderness on these largely gentrified islands- Alan Deidun
Two submissions by ‘statutory consultees’ (i.e. public entities which need to be consulted in such circumstances) included within the case officer’s report which catch the eye are the ones by the Environment and Resources Authority (ERA) and by the Superintendence for Cultural Heritage (SCH). The ERA opined that: “... the proposal is located in an area which is exceptionally sensitive in terms of scenic/landscape, geological, geomorphological and ecological (Natura 2000) aspects. In this regard, the project needs to be set in the context of a holistic environmentally- oriented management plan. Any proposed interventions are to be reasonably minimalistic and are not to significantly alter the sensitive environment and landscape of the site”.
The SCH’s submission was perhaps even more explicit, expounding that: “The Superintendence did not object in principle to appropriate resurfacing of the existing road, and noted the removal of the initially proposed offshore mooring, which would inevitable impact negatively on views of the area.
“Nevertheless, the application still proposes considerable intensification and formalisation of the area, even through the creation of embankments and retaining walls. The works as proposed would impact on the scenic context and promote vehicular traffic, with incrementally increasing impact on the landscape. The applicant was urged to lessen the scope of proposed works, preserving the singular scenic value of the site.”
This submission reflects the general sentiment out there... environmental concerns should not be seen as a spoke in the wheels of essential infrastructural works but rather as a reality check given the sensitivity of the natural heritage at Comino.
The sobering part of it all is that the die has largely been cast in that the existing track has been widened already, trenches have been excavated and most of the heavy-handed interventions have been executed, such that it is virtually impossible to restore ecologically the scarred areas in the short term. Presenting detractors with a fait accompli is in fact one of the oldest tricks in the book resorted to by perpetrators of unauthorised infrastructure works as the authorities would be faced with the Hobson’s choice between endorsing half-baked projects or else sanctioning the fully-fledged intervention.
Besides stalling such unauthorised works, the Planning Authority should bring the Ministry of Gozo to heel by submitting a fresh method statement for a downsized footprint of works for it to even contemplate the issuance of the relevant permit.
Daily hefty fines should be applied once the 15-day grace period has expired. The monies accrued from such a contravention would go towards the funding of ecological restoration works on site, such as the consolidation of loose sediment to avoid further aeolian transport and the regular obviation of any ruderal/opportunistic species which establish themselves along the path’s boundary.