The Environment Department is facing a critical decision over a proposed development plan for the abandoned village of Trozena after cadastral maps and satellite surveys revealed large-scale illegal earthworks inside a Natura 2000 Special Protection Area.
The works were carried out before the developer submitted the Special Ecological Assessment required by law — and, according to evidence placed before the authorities, took place between December 2023 and May 2025, during the very period the assessment was being prepared.
The proposed project falls entirely within the Cha-Potami Special Protection Area of the Natura 2000 network.
The earthworks have been recorded across multiple protected planning zones: the Nature Protection Zone (Z1), the Water Protection Zone (Z3), and the Water Protection and Protected Landscape Zone (Z3-PT), which includes the Trozena–Gerovasa Gorge, as well as within the designated Residential Zone (H1).
The applications cover the reconstruction of existing buildings and the construction of new residential units, a winery, a restaurant, offices and reception areas, parking facilities, camping areas, supporting infrastructure including an EAC substation and a biological sewage treatment station, and an access road.
The Ad-hoc Committee for the Special Ecological Assessment examined the study at a session on February 10, 2026, at which members requested supplementary and clarifying information relating to, among other things, the earthworks carried out, tree felling, and the removal of vegetation on the plots where the project is to be located.
EU Court of Justice case law establishes that member states must ensure environmental impact assessments are completed before any permits are granted, so as to prevent pollution and disturbance rather than address their consequences after the fact.
It further prohibits special legitimisation arrangements that would encourage project owners to bypass standard environmental impact and special ecological assessment procedures.
Cyprus court case law holds that the submission of a planning permit application presupposes that any works carried out under that application constitute development.
Accordingly, beginning preparatory earthworks or construction works without any approval or permit, while the relevant applications and studies are still under examination, amounts to simultaneously endorsing and undermining an institutional process — a practice that is not acceptable under administrative law.
Five questions have been submitted to the Deputy Director of the Environment Department:
- Whether the Environment Department carried out a site visit to the project area after the Ad-hoc Committee session of February 10, 2026, at which the unauthorised interventions were identified.
- Whether any preparatory earthworks or construction works were confirmed on the plots designated for the proposed project.
- Whether the Environment Department, the Game and Fauna Service, or the Limassol DLGO took any compliance or enforcement measures under environmental, planning, or building legislation.
- Whether the Environment Department intends to continue examining the proposed project, taking into substantive account the applicable legislation, relevant EU and Cyprus court case law, and related Law Office opinions.
- Whether the Environment Department has prepared and submitted a factual report to the Law Office requesting a legal opinion on the above matters.
The case is being watched as a test of whether the competent authorities will take meaningful action against attempts to create facts on the ground at the expense of protected nature and without following due process.
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