Hili Ventures recently shared more information to address the massive public rejection of its Comino project. Hili says the project will “positively impact Malta’s tourism industry and the environment, while preserving the unique character of Comino”.

These often-conflicting objectives would somehow be achieved through design quality, reducing the land used and other ‘sustainable practices’. However, the project will have a disastrous impact on the serene bay of Santa Marija, where Hili will conduct vast excavation, uproot protected native plants and greatly increase buildings footprint to create a Comino Village. The project must be stopped as it has nothing to do with conservation.

Hili’s plans are based on the reconstruction of the hotel at San Niklaw Bay and the bungalows at Santa Marija Bay. The amount of disturbed land will be reduced by 11 per cent – this claim is factually correct as the reduction will mostly be achieved by getting rid of the hotel tennis courts at San Niklaw Bay. But it’s extremely misleading when you start to specifically look at Santa Marija Bay where a sprawling built-up area would emerge.

Hili’s proposal for Santa Marija Bay is brutal: increasing the number of villas from the 13 existing to 19 new units with pools, plus amenities and a restaurant. It will result in a massive 49 per cent increase of the ground floor area. The amount of land disturbed will also increase by 12 per cent. Around 380 protected trees, fauna and garrigue will make space for more buildings.

All this doesn’t even meet the Malta Developers Association’s recommendation that “changes to existing legal buildings for sites that fall in Natura 2000 zones shouldn’t allow enlargement of footprint or of building volume when redeveloping such sensitive sites”.

Hili’s project will create a village at Santa Marija Bay, complete with its own restaurant, shop, bar, new pier and ‘Village Clubhouse’. Hili disagrees with eNGOs referring to a “village”. But, ironically, their own supporting documents for the development application repeatedly refer to a “village” and plans clearly show a formal urban layout for the village completely foreign to a natural setting. New landscaped village streets within a protected Natura 2000 area are totally unacceptable.

It is generally agreed that Hili is proposing high quality standards for the site on paper. However, it can’t be an excuse to vastly increase the building density and introduce some features that are contrary to genuine nature conservation. For instance, swimming pools shouldn’t be built in ODZ, yet, Hili and their architect have no issue applying for 19 of them for their village on Natura 2000 site!

The original bungalows didn’t have their own pools. Hili proposes that each new bungalow will come with its own pool. As one NGO activist rightly pointed out: “There is a bay right there, yet, they want to have a pool in every villa. Can you explain how this is sustainable?” And if we carry on looking at inconsistencies with their nature-loving claims, we need to ask why they think that a new pier in a marine protected area has anything to do with good conservation practices.

The urbanisation of Comino must be avoided at all costs- Stéphane Croce

In fact, the new pier would offer an additional disembarkation point for day trippers, turning Santa Marija into another Blue Lagoon. Is it what Hili means by revitalisation of Comino?

Finally, one can only wonder why each bungalow would need 30-40m² of basement storage space if it’s just to store few pieces of expensive luggage for short term stays by residents. These large basements serve no purpose in terms of sustainability. They must be eliminated with the additional benefit of minimising excavation on site.

Hili and their Six Senses partner claim that they will enhance the natural habitat. A new water treatment facility is proposed but could they seriously say they could operate without one and just dump untreated water at sea like in the old days? They want to replant local species. But the garrigue on the site is already in relatively good condition.

So, given Comino’s habitat, the minimal soil cover and the fact that many important endemic and indigenous flora, fauna and endangered pollinators are omitted from rehabilitation plans, the likelihood of recreating a garrigue of the same quality is slim once you destroy it. And, as far as using a “plastic free” claim to justify green credentials, it just feels like it is a marketing spin.

Prime Minister Robert Abela recently stressed the need to protect untouched land on Comino.

Legislation and policies are in place, so the Planning Authority has a duty to protect the site. The principle of an increased building footprint in a Natura 2000 area must be rejected now or nothing will stop further encroachment on the Comino natural habitat in the future.

Also, the urbanisation of Comino must be avoided at all costs. The possibility of permanent residency at the new ‘village’ must also be eliminated and no loopholes allowed. If Hili’s plans get the go ahead, it would radically change the island. It can’t follow the path of Malta and must be spared the cancer of development.

Comino is practically uninhabited and still undeveloped. It’s the unique character of the island. We must keep it that way.

Stéphane Croce is a former council member of Din l-Art Ħelwa.