So, what is being argued in the submitted representations?

Firstly, “the plans run counter to S.L. 549.44, due to the application consisting of te intensification of urban development and commercial use and activity which is not directly connected with or necessary to the management of the protected site”.

Secondly, the proposed plans are said to breach a total of four policies within the Local Plans, as explained below. 

GZ-COMI-1: “In view of its status as a Natura 2000 Site and Special Area of Conservation (International Importance) and as a Nature Reserve and pending its formal scheduling as an Area of Ecological Importance and a Site of Scientific Importance, the entire island of Comino, together with its associated minor islets, shall be afforded the same level of protection as scheduled property in line with the protective bands referred to in the Natural Protective Inventory.”

GZ-COMI-2: “In the light of the provisions of policy GZ-COMI-1 and in view of its status as a Rural Conservation Area, Comino shall continue to be protected from urban-related development.”

GZ-Ghjn-8: “In line with the requirement to maintain the ecological equilibrium on Comino, PA shall require the removal of clutter around the hotel at il-Bajja ta’ San Niklaw and the tourist complex at il-Bajja ta’ Santa Marija as well as the general rehabilitation of these areas.”

“The creation of a residential village will intensify the use of Comino and change its topography forever and is in breach of GZ-COMI-2 and GZ-Għjn -8.”

GZ-DARK-1: “It should be noted that part of the islet of Comino indicated in MAP 13.8 is designated as Dark Sky Heritage Areas. According to policy GZ-DARK-1 the installation of lighting which is not related to aerial or maritime navigation shall be strongly discouraged in these areas.”

Finally, it is also said to breach several objectives of the Strategic Plan for the Environment and Development (SPED).

Thematic Objective 8: “To safeguard and enhance biodiversity, cultural heritage, geology and geomorphology…”

Rural Objective 2: “To ensure that existing rural recreational resources are protected, enhanced, and accessible and to facilitate the provision of new recreational facilities which enhance the public’s rural experience in a manner that does not have an unacceptable adverse impact on protected areas, species and areas of high landscape sensitivity.”

Rural Objective 4: “To protect and enhance the positive qualities of the landscape and the traditional components of the rural landscape.”

Gozo Objective 1: “To ensure that the social and employment needs of Gozo are met and to protect the distinctiveness of Gozo’s settlements, cultural and natural environment to support the implementation of EcoGozo’s initiative by making better use of previously developed land on Comino for tourism and recreation-related uses.”

It is also important to note that “the appeal against the EIA’s findings has not yet been decided, therefore rendering the PA’s consideration of this application premature”.

Just a few days ago, the developers behind the plans said that the company “is committed to producing a world-class sustainable tourism product that respects the environment and stands up to close scrutiny”.

“In planning the project, the company engaged with all local authorities and stakeholders, including NGOs, to ensure that the hotel’s redevelopment is carried out in a sensitive and sensible manner.”

“HV Hospitality remains committed to engaging with all stakeholders and will continue to participate in the planning process fairly, transparently and with full respect for its obligations to respect and uphold Comino’s Natura 2000 status,” it ended.

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