A proposed change in use of the Comino Hotel bungalows from tourism to residential could have a “severe impact” on the island’s ecology, according to the project’s environmental impact assessment.

This is due to the potential increase in its permanent population, which now numbers just three people.

Though the likelihood of bungalow owners transferring to live permanently on the island is unknown, this would be of major significance. It would affect the local ecology through increased trampling over sensitive areas and additional noise and light pollution, the EIA states.

Without a coordinated effort to mitigate these, the integrity of important habitats and species could be affected, it adds.

Application PA/04777/20, by HV Hospitality Limited, proposes the redevelopment of the existing 100-guestroom Comino Hotel in San Niklaw Bay and the bungalows complex in Santa Marija Bay, which date back to the 1960s.

The proposed hotel would have 71 guest-rooms, with various amenities, while the Santa Marija Village, with its 21 “serviced” bungalows, would have a restaurant and a small general store.

The EIA says these bungalows will be for sale and prospective owners can opt to put their property in a rental pool, serviced by the hotel, and make use of its facilities.

EIA flags major concerns

Major negative impacts identified in the assessment by Adi Associates Environmental Consultants Ltd relate to the excavation of the site, the loss of habitat and potential damage from trampling by guests and residents. 

The bungalows could be sold to multiple owners – it is estimated they will be home to 130 residents – and, therefore, operate year-round, unlike the hotel.

This could significantly increase the risk of trampling of habitats, bring about additional lighting that is not ecologically responsible as well as introduce alien species in the private gardens.

To mitigate these effects, the EIA recommends conditions in the operational permits, such as no additional lighting by individual owners. While no invasive and alien species will be used, the potential for their introduction by individuals is a significant risk and the impact on the Natura 2000 site could be major, the report highlights.

Ecological value of virgin habitat is higher than that of restored habitat

The report also suggests the hotel provides information on the importance of habitats and encourages guests to use existing footpaths.

Subject to the issuing of permits, demolition and excavation works are anticipated to start in the first quarter of 2022, taking approximately 14 months at the hotel site and eight months at the village. Construction of the superstructure should commence in the first quarter of 2023, with the hotel and village opening together three years later, in April 2025.

The impact on geological resources is considered of major negative significance since the development involves the extraction of rock and soil from the site, the EIA states.

Loss of habitat at the hotel and village sites is being envisaged by the EIA because the hotel is being set back from the coast, while the village site has increased the number of buildings. This would result in extensive encroachment on the surrounding garigue if mitigation measures are not implemented.

'Irreversible' loss of habitats

The EIA report estimates an area of 15,983 square metres of different habitats will be lost to accommodate the development.

“The impact is irreversible since the ecological value of virgin habitat is higher than that of restored habitat,” it continues.

“While the development’s ecological restoration plan will result in a positive impact, the ecological value of restored areas will develop in the long-term and does not replace the loss of natural habitat in the short-term,” it notes.

Cultural heritage would be affected by the removal of two features by the bungalows that merit a Grade 2 level of protection, it states, suggesting the encroachment of the units towards the buffer area of the scheduled chapel be reduced.

Although the consultants consider the existing hotel and bungalows to merit a Grade 3 level of protection, the impact on the cultural landscape at the hotel site is considered neutral, with no cultural heritage features in the vicinity.

Positive impacts

On a positive note, the hotel is predicted to have positive impacts on the landscape in respect of the low-lying coast and built-up areas, according to the EIA.

It has identified a positive impact on terrestrial ecology as regards the removal of alien species on the site and the implementation of landscaping and restoration plans.

A total of 380 protected trees will be removed, 63 of which will be destroyed as they are not transplantable.

But the extensive landscaping plan, following construction, anticipates the planting of an additional 1,281 protected trees.