Student organisations and environmental NGOs have expressed deep concern over a decision by the Environment and Resources Authority (ERA) Board to allow excavation works and the uprooting of hundreds of trees as part of a major development proposed for Comino.

The statement, issued by the Earth Systems Association together with 26 other student organisations, 11 student representatives and 11 NGOs, criticised the ERA Board's decision of 7 August concerning development permit EP 1472/22.

The project, linked to planning application PA/04777/20, proposes 16 holiday villas, 44 swimming pools and a 140-bed hotel within the existing Comino Hotel Complex at St Nicholas Bay and the Comino Bungalows Area at Santa Marija Bay.

The groups argued that the scale of the intervention is particularly concerning given Comino's environmental status. The island and its surrounding islets form part of the Natura 2000 network and are protected as a Special Area of Conservation under the EU Habitats Directive and as a Special Protection Area under the EU Birds Directive.

Various parts of Comino also carry additional designations, including Areas of Ecological Importance, Sites of Scientific Importance, Tree Protection Areas, Bird Sanctuaries and a Nature Reserve.

Concerns over removal of 678 trees

A central concern raised by the organisations is the planned removal of 678 trees. These include 468 oleanders, 125 Mexican fan palms and 31 Canary Island date palms, which are not endemic and are not protected under the Trees and Woodlands Protection Regulations.

However, the groups said that removing vegetation on such a large scale could nevertheless have significant environmental consequences. The plans also involve the removal of 33 protected Aleppo pines and 21 cypress trees.

According to the statement, mature trees play an important role in providing shade, stabilising soil and reducing water runoff, functions that the groups consider particularly important on an island already facing biodiversity degradation and significant seasonal pressure from visitors.

The project proposes planting 540 indigenous saplings as compensation for the removal of 54 protected mature specimens. Additional planting would be undertaken to replace trees intended for transplantation if they fail to survive.

The organisations argue that such measures cannot immediately compensate for the ecological benefits provided by established mature vegetation, and maintain that compensatory planting should be considered only as a last resort.

Fears over tourism and Comino's future

The groups also warned that the project could establish a precedent for further urbanisation and tourism expansion on Comino.

While acknowledging that the Environmental Impact Assessment identified adverse effects associated with the development, including construction and demolition noise, vibrations, waste and increased infrastructure demand, they argued that the wider implications of the project require greater consideration.

Particular concern was expressed over the number of tourists already visiting Comino and the fact that the island's Carrying Capacity Study has not been made publicly available.

The organisations said that approving a large-scale tourism project in this context could contribute to increasing pressure on the island's natural environment and infrastructure.

Planning and legal concerns

The statement further questioned whether the proposed development is compatible with the planning and legal protections applying to Comino.

Among the issues raised are the project's compliance with the Local Plan, its compatibility with Comino's status as a Natura 2000 site and Special Area of Conservation, and its consistency with the Planning Objectives of the Comino Management Plan.

The groups also pointed to concerns surrounding rural development and design policies intended to protect environmentally sensitive sites.

They noted that environmental NGOs are already challenging the planning permit in court, adding another layer of legal uncertainty surrounding the project.

Calls for reconsideration

The student organisations, representatives and NGOs said they support the position taken by Moviment Graffitti and called on the ERA Board to reconsider its decision.

They also questioned the position of Energy, Environment and Regeneration of the Grand Harbour Minister Miriam Dalli on the matter.

The organisations argued that economic activity on Comino, particularly tourism, should be based on small-scale infrastructure and should prioritise the restoration of existing buildings rather than large-scale new development.

They further called for any intervention affecting Comino's landscape and vegetation to be undertaken in accordance with the island's Management Plan, its vision for the area and all applicable environmental legislation and planning policies.