The revised plan for Comino is still bad news

Hili Ventures has announced its new plan for the old Comino Hotel and bungalows under the eye-catching claim of a “total reduced footprint equivalent to 32 tennis courts”.

The developer is also saying that it has reduced the number of villas as a response to public feedback. Has a good compromise finally been reached?

In fact, Santa Marija Bay will still end up with a higher number of villas than the original resort and 16 swimming pools being dug there.

The project still presents the same fundamental problems: large villas and a hotel that will still result in an increase of building density, extensive excavation in a protected area and the developer leaving the door open for the sale of the villas and the urbanisation of Comino in the future.

For this redevelopment project to go-ahead on a Natura 2000 site, the authorities must set strict conditions to limit its impact: no increase in footprint and buildings volume, no sale of villas and limit excavations to a minimum.

Only then could Hili claim to have Comino’s natural environment in mind.

Because what Hili doesn’t talk about in its latest PR campaign is the massive increase of total floor area of buildings on the site: up 23 per cent for the hotel and villas combined. The plans for Santa Marija Bay are like the previous one in terms of design and layout. The main change is a reduced number of units from 19 to 16, an increase of three when compared to today. So, it will still result in a massive 25 per cent increase of gross floor area on this quiet bay alone.

In fact, this increase in density does not 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”. These sensible industry guidelines must be applied to Hili’s Comino project as a start.

Furthermore, the proposed design of the villas has kept all the problematic features. It is understood by most that it is against planning rules to have swimming pools built in ODZ or, at least, that is the rule for most of us. Yet, Hili and their architect have no issue applying for 16 of them on a Natura 2000 site. Nice move on an island rather deprived of natural water resources.

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?”

Also, each villa will still have large basement space: an unexplainable feature for buildings allegedly aimed at short-term luxury rental market. Their construction will require extensive excavation on Comino. Never a good nature conservation practice, so basements and pools must go.

After attempting to spin a “plastic-free” concept, Hili now talks about getting top “green” construction certification. But has it got any relevance with Comino’s habitat protection? When it comes to nature conservation, the overview of the outcomes of the environmental impact assessment (EIA) for Hili’s project was pretty damning.

The report identified significant impacts, ranging from geo-environment (arising from the excavation of the site), terrestrial ecology (habitat loss), potential damage from trampling by guests and residents, damage to marine ecology, and changes to the view and landscape.

Santa Marija Bay will still end up with a higher number of villas than the original resort and 16 swimming pools- Stephane Croce

Yet, the Environment and Resources Authority (ERA) board signed off the environment permit despite Comino being designated a special area of conservation. This has prompted a strong legal challenge by NGOs.

Some mitigation measures are proposed by Hili but the fundamental risk of damage to the natural habitat cannot be minimised and buried under a “green” label that has limited relevance to natural habitat protection.

Finally, what will happen once the 16 villas at Santa Marija Bay are built? Originally, Hili referred to the possible sale of the villas. Hili says that the plans have changed, been downsized and that the villas will no longer be sold. However, the developer is still refusing to drop its rights to sell them. So, will Hili apply to build more villas in the future? Will they sell the villas one day?

One can only speculate but the risk for future additional development phases in Santa Marija can’t be ignored. If we don’t want the villas to mushroom in few years and a ‘Comino Village’ to emerge, their sale must be banned by the authorities now.

Looking beyond Comino, once the precedent of the approval of a redevelopment project on a Natura 2000 site with an increased footprint or building volumes is set by the Planning Authority, then all Natura 2000 sites in Malta will be under redevelopment threat (just think what it could mean for Ta’ Ċenċ area, for instance).

It must not be allowed to happen.

It is worrying that it was reported that the NGOs were told by Robert Abela in June that he could find little wrong in the proposed Comino project. Comino is already a victim of the tourism industry and a laissez-faire attitude and now faces additional risks of overdevelopment.

So the public must insist that the authorities set strict safeguarding conditions to allow this project to go ahead on a Natura 2000 site.

There must be no increase in footprint, no increase in floor area and building volume, restricted excavation and a total ban on the sale of the villas through strict legal means.

Stéphane Croce

Unless this is done, Comino and all Natura 2000 sites in Malta will become the new playing grounds for the developers. Plus ça change!

Stéphane Croce is an environmentalist.