The Environment and Resources Authority has greenlit preliminary environmental works for the controversial Six Senses Comino resort, a decision environmental groups are calling a betrayal that could set a dangerous precedent for development on Malta's protected islands. The permit, approved on August 7, 2025, authorizes site preparation and the removal of nearly 2,000 trees—all while a legal challenge to the underlying hotel permit remains unresolved in court.
Why This Matters:
• Irreversible impact: Tree removal begins before August 19, 2025, when the court will hear the main development appeal, potentially causing permanent damage to protected garigue habitat.
• Legal grey zone: The ERA has approved works tied to a 71-room hotel, 16 villas, and 44 swimming pools that environmental groups are still fighting in tribunal.
• Public mobilization: Moviment Graffitti and eight other environmental organizations are urging residents to prepare for direct action to save the island's protected status.
• Public access concerns: Residents and day-trippers who regularly visit Comino face uncertainty about future access to parts of the island, as the development would significantly alter the landscape around the popular Blue Lagoon area and restrict movement across the site.
A Coalition Prepares for Battle
Moviment Graffitti has launched a public mailing list and called for mass mobilization, warning that Comino's designation as a Natura 2000 site and bird sanctuary is under existential threat. The group is joined by a coalition including BirdLife Malta, Din l-Art Ħelwa, Friends of the Earth Malta, Nature Trust – FEE Malta, the Ramblers Association, and several others who have collectively funded ongoing legal proceedings.
HV Hospitality, part of the Hili Group—a developer with a track record of major projects across Malta—is leading the resort development, a factor that concerns residents already familiar with the company's previous investments on the islands.
The coalition's strategy hinges on three pillars: escalating their tribunal challenge, demanding transparency through Freedom of Information requests on land deals related to the island, and organizing public protests. Their messaging emphasizes that ERA's approval of preliminary works while the main permit faces appeal undermines the entire legal safeguarding process.
Momentum and Moviment Azzjoni Soċjali have also publicly condemned the decision, amplifying pressure on both ERA and the Planning Authority to halt works until the court delivers its verdict.
The Numbers Behind the Controversy
Developer HV Hospitality argues that approximately 1,900 of the 2,500 existing trees and shrubs are alien or invasive species whose removal would actually benefit Comino's native ecosystem. Under their plan, roughly 550 of the 600 native and protected specimens would be transplanted, with only 50 permanently removed. For each lost native tree, the company pledges to plant ten replacements—totaling an estimated 500 new trees—and ultimately introduce around 55,000 new trees and plants across the site.
The company also commits to restoring more than 8,200 square meters of previously developed land back to its natural state, a figure it presents as a net environmental gain.
Environmental groups dispute this calculus. They point out that the project will result in an irreversible loss of 15,983 square meters of mixed habitats, including crucial garigue—a Mediterranean shrubland ecosystem that supports species found nowhere else in the Maltese archipelago. Transplantation success rates for mature African tamarisks, mastic trees, and dwarf fan palms are uncertain, and the temporary disturbance from heavy machinery alone can fragment habitats and displace wildlife.
The 33 Aleppo pines and 21 cypress trees slated for removal, though not strictly native, provide shelter and nesting sites for migratory birds, including the endangered Yelkouan Shearwater and Cory's Shearwater. Conservationists warn that even short-term disruptions—noise, dust, vibration—can drive away breeding populations during critical nesting periods.
What This Means for Protected Habitats
Comino's ecological value extends far beyond tree counts. The island serves as a critical stopover and refueling site for migratory birds, including bee-eaters, hoopoes, harrier species, and ground-nesting Short-toed Larks. Its garigue plateau is also home to Spectacled Warblers and the Blue Rock Thrush, Malta's national bird.
Reptiles such as the Maltese Wall Lizard, Mediterranean Chameleon, and Moorish Gecko rely on undisturbed garigue for shelter and foraging. Native flora—Mediterranean Thyme, Maltese Spurge, Judas Tree, and Chaste Tree—provide nectar for pollinators during the dry summer months when other food sources are scarce. The loss of these flowering plants would ripple through the food chain, impacting insect populations and, by extension, insectivorous birds and reptiles.
Soil erosion is another concern. Tree roots anchor the thin soil layer over Comino's rocky terrain; removing them exposes the ground to runoff during heavy rains, potentially altering the island's hydro-ecology and affecting even rare species like the Maltese Freshwater Crab, which depends on stable water flows.
The Legal Tangle
ERA's decision has intensified scrutiny of Malta's environmental permitting process. Notably, the NGO representative on the ERA board voted against the permit, requesting a postponement until the ongoing court appeal was resolved. That objection was overruled by the board majority.
This is the second tree removal permit ERA has issued for the site. A previous permit in February was revoked by the Environment and Planning Review Tribunal due to inadequate public consultation, a ruling environmental groups cite as evidence that the current permit may also be legally vulnerable.
Under Malta's Environment Protection Act, aggrieved parties—including environmental NGOs without direct juridical interest—can appeal ERA decisions to the EPRT within 30 days. The tribunal has the authority to suspend actions that could cause irreversible environmental damage while the appeal is pending. A 2022 Court of Appeal decision broadened NGO standing in cases involving Environmental Impact Assessments, a precedent the coalition plans to invoke.
The next hearing on the main development permit is scheduled for August 19, 2025, just 12 days after ERA's controversial approval. Environmental groups argue that allowing site preparation to proceed before that hearing undermines the purpose of the court challenge, potentially rendering any future ruling moot if trees are already gone and habitats destroyed.
A Test of Malta's Environmental Priorities
The Comino dispute is the latest flashpoint in a broader debate over how Malta balances economic development with its obligations under European environmental law. The island's protected status—Natura 2000 site, bird sanctuary, nature reserve—is enshrined in both domestic and EU regulations. Critics contend that commercial interests have repeatedly trumped conservation mandates, eroding public trust in regulatory institutions.
ERA's mandate is to safeguard Malta's natural environment. Yet environmental groups accuse the authority of prioritizing developer interests, noting that the agency's decision to approve preliminary works mirrors a pattern seen in other contentious projects where permits were issued despite incomplete environmental reviews or pending litigation.
Moviment Graffitti's call to "prepare to fight" reflects a shift from procedural challenges to mass public engagement. The organization has begun compiling a registry of supporters willing to participate in direct action—whether protests, awareness campaigns, or physical presence on Comino to obstruct machinery if works begin before the court rules.
What Happens Next
The legal challenge to the main development permit will proceed on August 19, 2025, before the tribunal. If the coalition succeeds in having that permit revoked, the preliminary works permit approved by ERA could also become moot, though the environmental damage would already be done.
Environmental groups are also exploring a separate appeal to the Information and Data Protection Commissioner to force publication of a visitor Carrying Capacity Assessment for Comino, a document they argue is required under the 2014 Comino Management Plan but which ERA has refused to release.
Meanwhile, the developer is expected to move quickly to begin site preparation, banking on the assumption that once works are underway, courts will be reluctant to order a halt. The coalition's ability to mobilize public pressure—and possibly secure an interim suspension order from the tribunal—will determine whether they can delay or block that timeline.
For residents and environmental advocates, the stakes are clear: Comino is a litmus test for whether Malta's regulatory framework can genuinely protect its most vulnerable ecosystems, or whether protected status has become a formality that yields to commercial ambition. The coming weeks will reveal whether the island's legal safeguards hold—or crumble under pressure.
