Comino deserves 'highest level' of protection, students and NGOs say

Comino deserves the highest level of environmental protection, a coalition of student organisations, student representatives and NGOs has said.

This comes after the Environment and Resources Authority (ERA) approved a decision on Friday 7 August that the group says allows excavation works and the uprooting of 678 trees in connection with a private development on the island.

The development, covered by permit EP 1472/22, would see the construction of 16 holiday villas, 44 swimming pools and a 140-bed hotel within the Comino Hotel Complex at il-Bajja ta' San Niklaw, as well as works at the Comino Bungalows Area at il-Bajja ta' Santa Marija, under planning application PA/04777/20.

The coalition points to Comino's legal designations in making its case. Comino and its surrounding islets are designated as a Special Area of Conservation under the EU Habitats Directive and as a Special Protection Area under the EU Birds Directive, forming part of the Natura 2000 network. 

Various parts of the island are also designated as Areas of Ecological Importance, Sites of Scientific Importance, Tree Protection Areas, Bird Sanctuaries, and a Nature Reserve.

According to the coalition, of the trees marked for uprooting, 468 are Oleanders, 125 are Mexican Fan Palms and 31 are Canary Island Date Palms, all non-endemic and unprotected under the Trees and Woodlands Protection Regulations. 

The group says the decision also covers 33 protected Aleppo Pines and 21 Cypress Trees. 

The signatories argue that removing mature trees on such a scale raises environmental concerns regardless of protected status, as established vegetation provides shade, stabilises soil and reduces water runoff, all of which they say matter given the state of Comino's biodiversity and the seasonal pressure of tourism.

The coalition says that, as compensation, 540 indigenous saplings are due to be planted to offset the removal of 54 protected mature specimens, alongside further replacements for any of the 348 trees earmarked for transplantation that fail to survive. 

The signatories say this remains insufficient to offset the benefits provided by established vegetation, and that compensatory planting should only be considered a last resort, since it leaves a significant gap in time before any ecological benefits can be felt.

The statement also raises concern over the wider impact of the project. While acknowledging the adverse effects identified in the Environmental Impact Assessment, including construction and demolition-related noise, vibrations and waste, as well as increased infrastructure demand once the development is operational, the signatories say the project sets a dangerous agenda for the urbanisation of Comino and the expansion of tourism there. 

They note that this is particularly concerning given the number of tourists who already visit the island, and that Comino's Carrying Capacity Study remains withheld from the public.

A further concern raised in the statement concerns the project's planning and legal basis, particularly its compliance with the Local Plan and the protections afforded to Comino as a Natura 2000 site and Special Area of Conservation. 

The coalition say the development also raises questions over its compatibility with the Planning Objectives of the Comino Management Plan, as well as rural development and design policies intended to safeguard such sites. 

They note that these concerns have already been raised regarding the project, with environmental NGOs currently challenging the Planning Authority’s permit in court.

They say they support Moviment Graffitti and urge the ERA board to reconsider its decision. They are also calling into question the position taken by the Minister for Energy, the Environment and the Regeneration of the Grand Harbour, Miriam Dalli, on the matter. 

They argue that economic activity on Comino, particularly tourism, should be supported through small-scale infrastructure and should prioritise the restoration of existing buildings over large-scale development, adding that any intervention affecting Comino and its flora must be carried out in good faith and in line with the Management Plan's Vision Statement and all applicable legislation and policies.

The statement has been endorsed: The Association of Students of Commercial Studies, Betapsi Malta, the Classics & Archaeology Students' Association, the Criminology Students' Association, the Department of English Students Association, the Malta Law Students' Society, Għaqda Studenti tat-Teoloġija, Għaqda tal-Malti, the Gozo University Group, the History of Art and Fine Arts Students' Association, the Junior Chamber of Advocates, the Kunsill Nazzjonali taż-Żgħażagħ, the Kunsill Studenti Universitarji, the Malta Association of Dental Students, the Malta Health Students' Association, the Malta International Relations Students Association, the Malta Medical Students' Association, the Media & Knowledge Sciences Association, the Pharmacology and Clinical Therapeutics Students' Society, the Science Students' Society, the Society for Architecture & Civil Engineering Students, Studenti Demokristjani Maltin, Studenti Graffitti, Students for Liberty Malta, the University Engineering Students' Association and Young European Federalists Malta.

It has also been signed by five University of Malta Senate student representatives, two University Council student representatives, and two student faculty board representatives each from the Faculty of Medicine and Surgery and the Faculty of Laws.

The following NGOs also endorsed the statement: the Astronomical Society of Malta, FAA Flimkien għal Ambjent Aħjar, GreenHouse, the Grow 10 Trees Project, Il-Kollettiv, the Malta Environment Foundation, Malta Youth in Agriculture, the Malta Chamber of Scientists, the Foundation for the Conservation of the Maltese Honey Bee, Wild for Orchids Community Malta and Wirt Għawdex