Din l-Art Ħelwa categorically rejects the approval of the environmental impact assessment (EIA) for a Comino hotel and bungalows by the ERA board on July 17.
The current plans for a luxury hotel and a new village of 19 bungalows is another nail in the coffin for the last relatively unspoiled nature area in our archipelago. Where will the destruction and the commercialisation of Malta’s natural environment stop?
Din l-Art Ħelwa and several other NGOs strongly objected to the proposed EIA but, as expected, our objections were simply brushed aside.
Let us be clear: the proposed project is not about the conservation and protection of Comino, a unique and important Natura 2000 site that we have an obligation to preserve for future generations but more about the destruction and commercialisation of an island that is one of the last remaining pristine natural habitats of the Maltese islands.
We oppose a new village in Comino.
Din l-Art Ħelwa is very concerned about the environmental and visual impact of the proposal. The introduction of a new residential town (with restaurant and convenience store) at the bay of Santa Marija has effectively been given the green light, on the essentially uninhabited island of Comino, with the existing relatively low-key structures being replaced by a sprawling settlement of 19 bungalows (with the possibility of private ownership and permanent residency).
In addition, ancillary facilities such as a new pontoon and the redevelopment of the existing hotel (of architectural merit in its own right) into a luxury hotel are being considered. The proposed hotel complex would be set back from the coast and will extend further into the Natura 2000 site. The development is completely alien to the natural setting.
Din l-Art Ħelwa will continue to work with other NGOs to ensure that Comino is protected against rampant commercialisation and urbanisation- Stéphane Croce
The 19 bungalows would sprawl further into the Natura 2000 site as the built footprint and extent of disturbed land have increased significantly. The proposed change in the landscape of this Nature 2000 site to a formalised urban settlement is completely unacceptable.
The development of a sprawling residential village on the essentially uninhabited island of Comino is an alarming proposal for the nation’s last unspoiled nature paradise. The repercussions are likely to include densification of development, loss of habitat, noise, light pollution, littering and additional vehicle activity traffic, which will negatively impact the site but will also have far-reaching consequences on the whole island.
We oppose the loss of protected habitat for commercial ventures.
The proposed disfigurement of this Natura 2000 site through rock-cutting and excavation is of great concern. Furthermore, the project would lead to the loss of 380 protected trees. On a site designated as a special area of conservation and a rural conservation area, the loss of protected trees cannot be justified through the planting of replacement saplings.
Such an approach would render the designation of trees as protected and sites as conservation areas completely meaningless. The EIA’s conclusion that the loss of trees would be a minor loss, simply because of the proposed planting of new trees, is completely unacceptable.
The EIA is playing down the severity of the matter by stating that the impact would be mitigated through the transplantation of existing trees. For a tree to be transplanted to another site, the receiving site has to be prepared to accommodate the tree’s roots. Given that Comino is mainly a garrigue habitat (with sporadic minimal soil cover) the likelihood of this being successful is minimal.
In addition, the species listed in the landscaping scheme omits many important species that are found in garrigue habitats, with only trees being proposed for landscaping.
We oppose a weak set of mitigation measures.
The ERA board voted to approve the EIA as long as a number of conditions are met. We believe these conditions to be totally insufficient to protect Comino and prevent the project from having a severe impact on the island’s unique ecology. Din l-Art Ħelwa considers the mitigation measures proposed to be poorly considered and will not lead to the desired improvement necessary to mitigate the detrimental impact on the environment that the proposal, as presented, will have on this Natura 2000 site.
The mitigation measures proposed are ineffective.
The proposal for the creation of a Comino village, which is contrary to the protection and conservation of this site, is not adequately highlighted as a major environmental concern that should be prevented. The EIA fails to adequately address the serious detrimental impact that the proposed increase in development density, and intensification of use, will have on this Natura 2000 site. The footprint must be extensively reduced and the possibility of any form of temporary or permanent residency must be eliminated.
Din l-Art Ħelwa will continue to work in partnership with other environmental NGOs to ensure that Comino is protected against rampant commercialisation and urbanisation and in order to ensure that all legal measures are put in place to ensure the future conservation of Comino’s natural environment.
Stéphane Croce is a council member of Din l-Art Ħelwa.