Plans to create a complex of villas at Santa Marija Bay in Comino as part of the proposed Comino Hotel redevelopment have received strong opposition from the public after a call to action from environmental groups.

In a statement on Friday, environmental organisations said the Planning Authority is still processing more than 13,500 individual objections from concerned citizens, mostly submitted through a custom online form.

This was a record number of objections submitted for a project proposal within a single representation period.

"This level of public anger makes it difficult to see how the PA could possibly approve this destructive scheme being proposed by Hili Group," the groups said.

They said that despite claims by the developers that the proposed plans would take up less land overall, the developers’ own figures showed how the footprint is significantly larger for the “village” in Santa Marija Bay.

The project, they argued, would destroy intact garigue to push the facility farther from the coast and erect buildings further into the bay in the place of abandoned sports courts.

The visual impact, the environmental groups insisted, is evident from the renders, also produced by the developers themselves. 

They said it took very little imagination to foresee the greater congestion and disturbance expected, both on land and at sea, if the bay is effectively transformed into a high-end holiday resort, complete with pontoon.

“If the PA grants permission for this project, it would come to the detriment of a public seeking a peaceful escape - a necessity under serious threat on the Maltese Islands - and the health of our natural environment.

“Comino is a rural conservation area, a nature reserve, a bird sanctuary, a special area of conservation and a special protection area in the Natura 2000 network, an important bird area of international and EU importance, and a dark sky heritage site, home to many nationally and internationally protected habitats and species.”

Five organisations are currently appealing ERA's approval of the proposal.

They are BirdLife Malta, Din l-Art Ħelwa, Friends of the Earth Malta, Moviment Graffitti, and Nature Trust - FEE Malta.

Together, they are slamming “the superficial assessment of the private project on a prized nature reserve in favour of the commercial interests of a few catering for the wealthy”. Ramblers Malta and Flimkien għal Ambjent Aħjar are also vociferously opposing the project.

“Backed by the resounding public outrage, we appeal to Hili Ventures to withdraw all plans for Santa Marija Bay and to abandon the idea of sale of any part of the complex to third parties.

“Ultimately, the most sustainable construction for the island of Comino is no construction at all,” the organisations insisted.

Bungalows ‘an important example of modernism’

An architectural heritage practitioner has made a case for the preservation of the Comino Hotel bungalows, saying they constitute an “important example of regional modernism”.

In his representation to PA 04777/20 to demolish and rebuild the hotel and bungalows at Santa Marija and San Niklaw Bays, Edward Said says “fewer and fewer specimen (of this modernist architecture) survive on the mainland”.

“Now is the time to cater for its assessment, preservation and integration,” he adds.

Said was the first to submit an objection at the end of last year, following which the flood gates of disapproval opened, drowning the defunct Comino Hotel’s redevelopment plans in a sea of thousands of representations.

Plans were first unveiled in 2020 but opposition remained muted until recently, when activists and NGOs rallied support to oppose the project.

They argue that the “monstrous” development would be incompatible with the special protection afforded to Comino as a rural conservation area, a nature reserve and a Natura 2000 site.Although the hotel’s redevelopment could be considered “understandable and necessary”, Said feels that, as a student of Maltese architecture with a particular interest in the modernist expression, he had to highlight the existence of buildings that merited recognition and, at least in part, preservation.

Referring specifically to the bungalow complex on Santa Marija Bay, he noted a clear distinction in the kind and quality of architecture between the two phases of the building.

The earlier, dating back to the early 1960s, was more sensitive to landscape, inclusion of vernacular idiom and the application of modernist elements, while in later years, the hotel was repurposed, with the addition of maisonette-type units.

“The overall massing, humble yet embracing, and the now mature soft landscaping, gives an impression of a simple Maltese village, when viewed from a distance at least,” Said pointed out in his letter to the Planning Authority chairman and the Superintendence of Cultural Heritage.

He listed features such as “fins, rusticated feature walls, slit windows, vertical and horizontal brise soleil screens, panelling, subtle projections, tenuous cantilevers, and a balanced blend of limestone and concrete planes, fenestrated with sleek steel Crittall-Hope windows”. 

Said also highlighted the curved Nautico Bar verandah, with its American-style art deco steel aperture and fitted ‘showroom-type’ openings with angled canopies, in his appeal for preservation.