Comino hotel and bungalows project approved

The Planning Authority has approved the construction of a 140-bed hotel in San Niklaw Bay and 16 individual serviced bungalows at Santa Marija Bay area instead of the existing hotel and disused 13 bungalows. 

The development also includes 44 swimming pools, 17 of which located in the Santa Marija bay area. 

The project was approved by eight votes against one, with the only board member voting against being the Għajnsielem local council. The decision was met by online disapproval of several participants, some of which blamed the board for ruining Comino for future generations.

The project proposed by Hili Ventures involves a 966sq.m increase in the total floor area of built-up structures in the area. It also emerged that a brand new application still has to be filed for the construction of a sewage treatment plant catering for both the new development and other users in Comino.

Photomontage presented by the developer of showing an aerial view of the redeveloped Comino Hotel

The existing hotel and bungalows were developed in the 1970s long before the island was granted protection as a Natura 2000 site.

Two jetties for visiting boats will also be developed in the middle of Santa Marija bay and San Niklaw bay.

At the start of the meeting Marie Claire Gatt from Moviment Graffitti requested that the meeting is postponed in view of new plans were filed yesterday and objectors needed time to analyse the documents. The law requires a 15-day interval between the submission of plans.

PA CEO Johann Buttigieg said the board had no option either to postpone the decision or to discard the new plans, while noting that the plans themselves do not include any changes to already submitted plans and involved a change in labelling.

Photomontage presented by the developer of the bungalows as seen from Santa Marija Bay

Ian Stafrace on behalf of the developers chose to retract the new plans. The board agreed to proceed with the meeting.

Lucienne Haber, the executive secretary on behalf of the Għajnsielem Local Council voted against the project insisting that the project did not respect the integrity of the Natura 2000 site in terms of light pollution and building density, also noticing the absence of a sewage treatment in the plans. 

Developers insist project is an improvement on existing situation

In their presentation, HV Hospitality’s architect Antonio Belvedere and engineer Andrew Forte emphasised that the project will represent an improvement on the present situation and one which blends better with the natural environment.

“The fundamental question we faced is what would be an appropriate way of rebuilding an already developed site and make it blend better with the surrounding environment and our starting point was that this is a Natura 2000 site and our first priority was to respect the shore line and pushing back the existing buildings from it,” Belvedere said.

He referred to existing tennis courts which will be removed.

As regards the bungalows, he insisted that the design of the bungalows will break up the massing of the existing ones, creating voids in between buildings.

The Planning Authority Planning Directorate recommended approval of the project insisting that the project is in line of the local plan as it is restricted to the site of the existing hotel and bungalows. 

According to the case officer report, the bungalow site currently occupies an area of approximately 16,165sq.m including sports facilities.

The existing gross floor area for the bungalows is 3,822sq.m.

The proposed bungalows will be spread over 15,075sq.m of existing disturbed land.

But the proposed gross floor area for the bungalow site will increase to 4,788sq.m - an increase of 966sq.m over the present situation.

Overall, when the hotel area is also included, the gross floor area will increase by 2,360sq.m for both the hotel and bungalow sites. But 8,244sq.m of disturbed land, most of which is unbuilt but used as tennis courts, will be restored back to landscape.

The developers claimed that the hotel and bungalows will attract 44 less guests than the existing structures, but admitted that the number does not include other visitors to the facility.

No divine right to redevelop a Natura 2000 site

Marie Claire Gatt, an ornithologist and Moviment Graffitti activist insisted that the fact that the site is already developed does not entitle developers to redevelop it.

“Comino is a nature reserve protected at the highest level, and no developer has any God given right to develop the site simply because it was developed in the past before Comino was recognised as a Natura 2000 site,” she said.

She also referred to the recently approved nature restoration regulations by the European Union, which are aimed at restoring protected areas back to nature not to rebuild them. “Rebuilding a hotel and villas on a Natura 2000 is not in line with the whole idea of nature restoration”

She also shot down the claim made by the project architect that disturbed areas will be restored back to nature simply because this land is already being reclaimed by nature and includes land used for sports facilities, which presently includes no buildings.

She also referred to 17 pools next to Santa Marija Bay and 44 pools in the entirety of the project - all in a Natura 2000 site - questioning how sustainable a project with so many pools can be not just in terms of aesthetics but also in terms of water use.

She accused sixth senses of greenwashing, mentioning the development of a hotel in Ibiza which contradicted the promises made before approval. “We do not trust the goodwill of companies on development which should not be there in the first place.”

She also noted that the project will give nothing back to the public as most open spaces will still consist in private spaces.

Joseph Caruana on behalf of Wirt Ghawdex referred to increased light pollution in a dark sky heritage area and a Natura 2000 site where there should be no lights at all.

Nicholas Barbara from Birdlife questioned the claim that the hotel will be downsized simply because the number of rooms will be decreased. “The question is how many people it will attract including those visiting the spa, restaurant visitors and people visiting the hotel by boat facilitated by new jetties.”

He also expressed concern on activities in bungalows with separate pools and amenities occupied throughout the year.

Project approved in absence of a carrying capacity for Comino

Analise Falzon from Friends of the Earth Malta insisted that a carrying capacity should be established for Comino before any new project is approved.

A management plan for the Natura 2000 site dictates that the island’s carrying capacity should be established but the government has procrastinated on this obligation established five years ago. “You cannot go ahead with a hotel development before establishing the carrying capacity of the island as required by the policy regulating the Natura 2000 site.”

This point was emphasised by all other speakers and nobody rebutted this pertinent argument.

She also noted that most disturbed areas in the bungalow area are regenerating on their own and do not require any restoration.

A public deed will be signed to ensure that the bungalows will not be serviced by the hotel and will not become separate residential units.