Comino: beyond ecological compensation

Comino is a small Mediterranean island already under intense tourism pressure. Its ecological value depends on a mosaic of garrigue, rocky habitats, scrub, cliffs and coastal ecosystems. Malta’s own Natura 2000 Management Plan recognises these habitats and the pressures placed upon them by tourism. It specifically calls for a tourism carrying-capacity assessment and for further development to be carefully regulated[1]. Against this background, the proposed redevelopment of the existing tourist complex remains controversial and legally unresolved. In May 2026, the Court of Appeal overturned the Tribunal decision that had upheld the planning permit and sent the case back for reconsideration[2]. Meanwhile, ERA has approved environmental interventions connected with the project. According to the authority, 678 trees and shrubs would be removed, including 54 protected trees. Another 348 specimens would be transplanted, 341 of which are protected, while the developer would be required to plant 540 indigenous trees as compensation[3][7]. Yet these figures require important qualification. The ERA report does not specify that the 540 compensatory trees will be mature specimens, meaning that they may be planted as saplings. Nor does it establish an expected survival rate for the 348 transplanted specimens, although failed transplants must be replaced under the permit’s compensation mechanism[7]. The 540 new trees therefore cannot be understood as an immediate one-for-one ecological replacement for the established vegetation being removed[7].

At first sight, 540 new trees may sound like a strong environmental measure. But ecology does not work through simple arithmetic. Planting trees cannot simply replace an established habitat, its soils, ecological continuity, species interactions and microhabitats.

More trees do not automatically mean more biodiversity.

The real issue, therefore, is not whether the removal of trees can be compensated by planting 540 new ones. It is the wider logic of ecological compensation as a licence to transform. Compensation and restoration can genuinely help ecosystems. The problem begins when they change the question from:

“Should this transformation happen at all?”

to:

“How much compensation is required for it to happen?”

The economic project then becomes the starting point, while ecology is asked to adapt around it. A genuinely ecological approach would reverse this logic: begin with the limits of the ecosystem, and then ask what kind and scale of economic activity can take place within those limits. This tension is also visible in the way the project has been presented institutionally. In 2025, the European Urban Initiative described the redevelopment as “A Model of Sustainable Island Tourism”, highlighting green roofs, native landscaping, a coastal buffer zone and other environmental measures.[4] Such measures may reduce impacts. But making a development less damaging is not the same as demonstrating that it is ecologically compatible with the place in which it occurs. This distinction is reinforced by the European Commission’s 2026 guidance on Natura 2000 and sustainable tourism, which stresses the need to assess tourism pressures, cumulative impacts and carrying capacity in relation to a site’s conservation objectives[5]. This is particularly relevant to Comino. Its own Natura 2000 Management Plan already calls for a tourism carrying-capacity assessment, while environmental NGOs have spent years seeking access to that assessment.[1][6] Carrying capacity is not simply a maximum number of visitors. It concerns how much tourism pressure, in its intensity, distribution and cumulative effects, an ecosystem can sustain without undermining its conservation objectives[5].

The issue is also social.

An ecosystem is not simply a collection of natural assets. It is an interlinked biocultural heritage, made of habitats, species, landscapes, ecological processes and human relationships with place. It belongs to a community larger than the market: to present and future generations, and to the non-human life that depends on it. An exclusive tourism development works according to a different logic. Its financial benefits are concentrated, while many of its costs remain collective.

What is common is transformed to generate private value; what is lost remains a public loss.

Habitat degradation, pressure on resources, disturbance and landscape transformation do not stop at the boundaries of a development site. They are absorbed by the island, by society and, eventually, by future generations. This is the deeper contradiction behind the language of compensation. Nature is treated as if its different elements could be priced, replaced and rearranged around an economic project: remove here, plant there, compensate elsewhere.

But some things cannot be exchanged in this way.

An established habitat is not interchangeable with a collection of newly planted trees. Ecological continuity is not interchangeable with compensation. And an island is not simply a surface on which economic value can be maximised. How far such a place can be transformed is therefore both an ecological question and a social one: who gets to transform what is shared, for whose benefit, and at whose cost?

[1] ERA, Kemmuna u l-Gżejjer ta’ Madwarha Natura 2000 Management Plan.

[2] Court of Appeal decision, May 2026; reported by Times of Malta, “Court sends PA permit for Comino development back for review.”

[3] ERA decision on environmental interventions, August 2026; figures reported by Times of Malta on the removal, transplantation and replacement of trees and shrubs.

[4] European Urban Initiative, “Comino Redevelopment Project Approved: A Model of Sustainable Island Tourism,” 19 September 2025.

[5] European Commission, Directorate-General for Environment, Natura 2000 and sustainable tourism, 2026; European Commission, “Natura 2000 Network offers sustainable tourism opportunities,” 14 July 2026.

[6] BirdLife Malta and other environmental NGOs, documentation concerning the Comino tourism carrying-capacity assessment and attempts to obtain its publication.

[7] James Debono, “Fact-check: What the Comino hotel project means for the island’s trees,” MaltaToday, 8 August 2026.