Comino

Summary

Comino — a 3.5 km², almost-uninhabited island — has generated 67 PA applications since 1993. The data reveals decades-long sagas: a hotel redevelopment that took 27 years before the original application was withdrawn and a replacement approved (now under appeal); a decade-long sunbed war where the same operators were refused, overturned, refused again, and eventually approved; competing ferry ticket booth battles across multiple harbours; a proposal to scuttle a naval patrol boat as a dive site; tuna farm revocations in the Comino Channel; and even an ex-tipping-site-turned-campsite. Every square metre of this tiny island is contested.

Hearing-level findings draw on 69,254 board minute entries (~third of decided cases). See methodology for coverage details.

Key findings

The Comino Hotel: a 27-year saga

The island's only significant building has been the subject of a planning marathon spanning three decades:

The hotel can't even get a satellite dish without drama: three applications refused on the same day in 2000.

The PA/04325/98 case — filed in July 1998 and withdrawn in April 2025 — is one of the longest-lived applications in the entire database: 26 years, 9 months from filing to resolution.

The Blue Lagoon sunbed wars

Two operators — Mr Coronato Portelli (Blue Lagoon) and Mr John Baptist Spiteri (Cominotto Beach) — waged a parallel decade-long campaign to hire sunbeds. Their applications moved in lockstep:

The pattern: PA applications consistently refused (2001–2005), with one brief victory via reconsideration in 2002. After a 7-year gap, the operation re-emerged in 2012 under a different applicant name (Raymond Azzopardi) and via the DN (development notification) route — which bypasses the full planning board. Approved both times. The same activity, refused for a decade as PA, sailed through as DN.

Portelli alone filed at least 5 applications over 7 years for the identical activity: "hiring of sunbeds and umbrellas."

The ferry ticket booth battles

Multiple operators have fought for decades over the right to sell Comino ferry tickets at harbours on both Malta and Gozo:

At least 3 competing operators (Comino Ferries, Blue Lagoon Ferries, Excel Comino Cruises) have fought over ticket booth permissions across 3 harbours over 20+ years. The pattern of refused-then-approved-then-refused-again suggests the planning system being used as a commercial battleground.

The scuttled patrol boat (twice)

PA/06280/06 — Mr Martin Vella, on behalf of the Malta Marine Foundation, proposed "scuttling of vessel (Patrol Boat P31) at L-Imnieri, East Comino" as a diving attraction. Withdrawn.

PA/05517/08 — Same applicant, same vessel, different location: "Site on Sea-Bed" off West Comino. Approved. It took two attempts to find an acceptable spot to sink a boat.

Tuna farm revocation in the Comino Channel

PA/01741/01 — "To substitute part of the breeding of sea bream with tuna" in the South Comino Channel. Filed 2001, eventually revoked in 2016 after an extraordinary full Planning Board session. The board minutes reveal:

• 81 public objections, 0 in favour
• A dramatic hearing where fish farm operators admitted to illegal cages but argued revocation would "destroy the tuna fish farming industry"
• Operators claimed extra cages were needed for EU traceability rules
• The Board unanimously revoked the permission (11-0), along with 9 other fish farm permits across four separate votes (10 permits revoked in total)
• Dr Robert Abela (now Prime Minister) participated, stating "the fish farms as existing today are already illegal"

For PA/01741/01, the board minutes capture the deferred-then-revoked sequence: a hearing on 5 September 2016 deferred the decision after operators committed to a method statement; on 22 September 2016 the board revoked PA/01741/01 along with the nine other permits.

The campsite on a former dump

PA/02126/19 — Mr Herman Galea proposed "temporary change of use of ex-tipping site to campsite (approximate mid May to mid September)." Approved. The same Mr Galea also applied to build public conveniences (PA/09167/19, approved) and install information boards (PA/04570/22, PA/04571/22, both approved) — emerging as a key figure in Comino's recent transformation from abandoned island to managed visitor destination.

Heritage restoration

Amid the commercial battles, conservation efforts appear:

• PA/00233/00 — Restoration of Santa Marija Tower by Din l-Art Helwa (heritage NGO). Approved.
• PA/00422/02 — Sanctioning additions to the tower restoration. Approved.
• PA/00599/14 — Installing safety railings on the tower staircase. Approved.
• PA/02212/23 — Second round of tower restoration, 23 years after the first. Approved.
• PA/03710/15 — Restoration of Santa Marija Battery. Approved.

Infrastructure: fibre optic and walkways

• PA/07018/16 — Enemalta proposed trenching for a fibre optic cable to Comino. Dismissed (non-compliance with requirements).
• PA/03917/23 — Same fibre optic trench, refiled 7 years later. Approved.
• PA/04832/09 — Transport Malta: demountable pier at Blue Lagoon. Approved.
• PA/09966/19 — Demolition and reconstruction of Comino Jetty at Ramla tal-Bir. Approved.
• PA/04833/20 — Infrastructure Malta: extend pier at Blue Lagoon, remove "makeshift concrete walkways" to restore shoreline. Withdrawn.
• DN/00742/25 & DN/00097/26 — Malta Tourism Authority: temporary timber pathways for accessibility. Approved.

The filming track

PA/01996/93 — The earliest Comino application in the database. CIBY 2000 (a French film production company) applied to "construct temporary track for filming purposes" at Comino Tower. Refused, then overturned on reconsideration. This was likely for the 1990s era of Malta's film industry boom.

The numbers

Of the 67 PA applications on Comino island itself (excluding addresses on "Triq Kemmuna" in Għajnsielem town):

Refusal rate: 44% (21 refused of 48 decided) — three times Malta's overall rate of ~14%. Comino's ODZ (Outside Development Zone) status and environmental sensitivity make the planning authority significantly more resistant. Yet the same applicants file again and again, sometimes winning on the second, third, or fifth attempt.

Notable cases

PA/04777/20 — San Niklaw Bay, Comino. HV Hospitality proposed demolishing the entire existing hotel and bungalows complex to build a 140-bed luxury hotel with spa, pools, restaurants, and 16 serviced bungalows. After 5 years of assessment, it was approved in April 2025 — but immediately appealed (PAB/00234/25). This single application would transform the character of an almost-uninhabited island, yet the planning system treated it as a routine Class 3B hotel application.

PA/01741/01 — South Comino Channel. A tuna farm substitution permit filed in 2001 was eventually revoked in 2016 after 81 public objections and zero letters of support. The board hearing became a national moment: operators admitted to illegal cages, future Prime Minister Dr Robert Abela declared the farms "already illegal," and the board voted 11-0 to revoke — along with 9 other fish farm permits across four separate votes (10 permits revoked in total). It took 15 years to undo a single permit.

PA/00563/14 — Former Bakery, Comino. Friends of the Earth Malta applied to restore dilapidated buildings and convert them into an interpretation centre with lodging facilities. Approved. This rare conservation-led application stands in contrast to the commercial battles elsewhere on the island, showing what community-driven planning on Comino could look like.

Why this matters

Comino is a microcosm of Malta's planning tensions compressed into 3.5 km². An almost-uninhabited island has generated 67 PA applications because every one of them touches on environment vs. commerce, heritage vs. tourism, public space vs. private profit. The Blue Lagoon sunbed wars show how the same operators can be refused for a decade then approved via a different route. The hotel saga — 27 years from first application to withdrawal — is among the longest in Malta's planning history. The tuna farm revocation hearing, where future Prime Minister Dr Robert Abela participated, became a national reckoning over environmental enforcement. And the ferry ticket booth battles show the planning system used as a proxy war between competing commercial interests.

International context

In England, development on protected land equivalent to Comino's status — such as Green Belt or Areas of Outstanding Natural Beauty — faces approval rates of roughly 20% for inappropriate development. Comino's 44% refusal rate is three times Malta's average but still means 56% of decided applications on this ecologically sensitive, near-uninhabited island succeed. No comparable English site — a protected, almost-uninhabited island — would see a majority of development proposals approved.

Comino's planning battles also raise questions that extend beyond the island. The pattern of the same applicants filing repeatedly until they succeed, or switching from PA to DN routes to bypass the full board, suggests a system where persistence is rewarded more than policy is enforced. The hotel redevelopment now under appeal will test whether environmental and heritage protections can hold against large-scale commercial pressure on one of the Mediterranean's last semi-wild islands. Meanwhile, Herman Galea's cluster of eco-tourism approvals (campsite, toilets, information boards) hints at a possible alternative model — but without a coherent Comino management plan, even well-intentioned projects risk being piecemeal. The fundamental question remains: who decides what happens to an island that belongs to everyone and no one?

Media sources

• "Comino hotel and bungalows project approved" — MaltaToday, 24 April 2025. Confirms the PA approved the 140-bed hotel and 16 bungalows (8-1 vote), with environmental groups objecting to the lack of a carrying capacity assessment for the Natura 2000 site.
• "Tourism Minister bans sunbeds on Blue Lagoon's sandy beach, limits them to quay" — The Malta Independent, 13 June 2022. Corroborates the long-running sunbed wars, with the Tourism Minister finally banning sunbeds from the sandy beach after activist protests.
• "Graffitti versus Comino profiteers: activists claim public shoreline in direct action" — MaltaToday, 11 June 2022. Documents Moviment Graffitti activists physically removing deckchairs from Comino, corroborating the decade-long commercial battle over the Blue Lagoon.
• "Don't yield to fish farm blackmail, green NGOs warn" — MaltaToday, 15 September 2016. Confirms the fish farm revocation drama in the Comino Channel, with operators warning of a euro150 million industry collapse and NGOs calling it "blackmail."
• "Planning Authority approves Comino hotel and bungalows" — Times of Malta, 24 April 2025. Confirms the approval of HV Hospitality's 140-bed hotel and 16 bungalows (PA/4777/20), with over 10,000 objections filed against the project and only Għajnsielem Local Council voting against -- corroborating the decades-long Comino hotel saga.