A fact sheet issued by Hili Ventures, the developers behind the proposal to redevelop a hotel and bungalow complex on Comino, claimed that “the total land area of the new Comino Hotel & Bungalows will be reduced by 5,122 square metres when compared to the existing development”. 

The developers were responding to a statement released by a group of seven environmental organisations saying that the development would include the replacement of the nine derelict bungalows at Santa Marija Bay by a larger complex of 19 villas complete with a convenience store and amenities.

Following this statement, thousands of objections to the project were submitted by the public, many of them objecting to the size of the development and the potential loss of the modernist features in the current complex. 

NGOs, in turn, accused the developers of masking the scale of the project.

The Malta Developers Association also released a statement indicating concern over such projects within Natura 2000 sites, saying “no enlargement of footprint or of building volume should be allowed when redeveloping such sensitive sites”.

Is the overall footprint of the new development smaller?


Plans submitted to the Planning Authority show that the overall footprint of the new development is smaller than the existing site. The footprint of the hotel in San Niklaw Bay will be reduced by over 7,000 square metres, from 29,649 square metres to 22,495 square metres.

Meanwhile, that of the bungalows in Santa Marija Bay will grow from 16,165 metres square to 18,197 square metres, an increase of just over 2,000 square metres. 

In total, the overall footprint of the new development will be 5,122 square metres smaller than the existing site, a decrease of 11%.

Does this mean that the site will be less built-up? 


Although the overall footprint will be smaller, the project will consist of more built-up area than the existing site. 

The project’s development plans show that the gross floor area, which the Planning Authority defines as “the total area of the whole unit measured from the external face of the development’s walls”, is set to increase by a total of 3,264 square metres, 33% more than the existing site. 

The gross floor area is a widely used tool to measure the size of built structures. It calculates all the floor space in a building across multiple floors, as well as outdoor areas that are structurally connected to the building, such as balconies and terraces. It does not include outdoor spaces that are not structurally connected to the building, such as gardens and open spaces. 

Although the hotel’s overall footprint will be over 7,000 square metres smaller, the gross floor area will increase by 1,394 square metres, or 23% (from 6,123 to 7,517 square metres), while that of the bungalows will grow by 1,870 square metres, or 49% (from 3,822 to 5,692 square metres). This suggests that the sites will be more densely built and that building volume is set to increase.

How will the new development look?

Several images comparing the existing and proposed project, submitted as part of the planning application to demonstrate the visual impact of the development, also suggest that the land will be more densely built. 

A comparison of the current and proposed hotel shows how the new structure will be generally wider and higher than the existing hotel.

The current hotel.The proposed hotel.

Side-by-side photos of the bungalow complex, meanwhile, suggest that the building density of the area will increase.

The existing bungalow complex.The proposed bungalow complex

What do architects say?

Independent architects who spoke to Times of Malta confirmed that the development plans indicate that the overall footprint will be reduced, but the building volume is to increase, in part because certain structures will have more floors than the existing buildings while others will be built over a wider footprint.

The project’s architects admit that the bungalow complex will result in “a greater and displaced built footprint compared to the existing development” but argue that this is necessary as certain existing bungalows will be reduced in height and development will be set back from the coastline, unlike the current bungalows.

They plan to adopt an architectural technique referred to as fragmented architecture, where each room in a bungalow is separated by a 1m connecting space. They argue that “even though fragmenting the solid buildings intrinsically implies occupying more floor space, the less intense utilisation of the space will result in a less dense and quieter occupancy”.

The proposed bungalow complex footprint overlaid on the existing footprint. Source: Belvedere ArchitectureThe proposed bungalow complex footprint overlaid on the existing footprint. Source: Belvedere Architecture

When contacted for comment, Hili Ventures said: “To meet today’s MTA hotel standards for a five-star hotel, we had to find a way of increasing the usable floor space while reducing the footprint, and in some cases even the height of the buildings (some of the existing bungalows are two storeys and we are proposing to reduce them to one).

"Our architects achieved this by making use of good design and bringing the building units closer to each other. The architectural style adopted enhances the integration of the bungalows into the landscape and allows the natural terrain to flow around the fragmented architecture. 

"We have also succeeded in creating a business model that requires fewer guests than the previous hotel, meaning we did not only reduce the height and the extent of the buildings, but also the intensity of the overall development. According to the Local Plan, the redevelopment of the site is ‘encouraged’ but should not increase height, extent or intensity. Our proposal meets those requirements while also creating a sustainable project.”


Although the developers are correct in saying that the overall footprint of the project will be reduced by 5,122 square metres, this alone is not enough to describe the scale of the project. The development’s floor space will increase by a third compared to the current site, indicating that the overall extent of built structures will increase.

This claim is therefore misleading, as although the claim may, in itself, be partly or entirely true, it is presented in a manner that is not representative of the facts within a broader context.

The Times of Malta fact-checking service forms part of the Mediterranean Digital Media Observatory (MedDMO) and the European Digital Media Observatory (EDMO), an independent observatory with hubs across all 27 EU member states that is funded by the EU’s Digital Europe programme. Fact-checks are based on our code of principles

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