The general spatial plan for the reconstruction and revitalization of the abandoned settlement of Trozena is being put under the microscope of the Environmental Authority, as based on evidence that has been submitted to the competent authority, arbitrary interventions and illegal works are found in the area where the proposed project is located.
In fact, the interventions were implemented before a Special Ecological Assessment Study was even submitted and examined, which is required under the current legislation, as the proposed project falls entirely within the area of the Natura 2000 network Ha-Potami Special Protection Area.
According to cadastral maps and satellite surveys submitted to the competent authorities, it appears that very serious and large-scale earthworks have already been carried out in the area.
The interventions are recorded both within a defined development limit, namely the Residential Urban Planning Zone (H1), and outside the defined development limit, namely the Nature Protection Urban Planning Zone (Z1), the Water Protection Urban Planning Zone (Z3), as well as the Water Protection Urban Planning Zone and the Protected Landscape Urban Planning Regime (Z3-PT), which includes the Trozena – Gerovasa Gorge. The interventions appear to have been carried out between December 2023 and May 2025, during the essential time of the preparation of the Special Ecological Assessment Study for the proposed project.
It is noted that relevant applications for planning permits for the reconstruction of existing and the construction of new residential units, as well as the construction and operation of a winery, a restaurant, offices and reception areas, parking spaces, camping sites, supporting infrastructure (EAC substation and biological wastewater treatment plant) and an access road have already been submitted and are pending for examination by the Limassol District Local Government Organization.
The Ad-hoc Committee for the Special Ecological Assessment examined the relevant Study at a meeting held on 10/2/2026, during which the members requested the submission of additional and clarifying data concerning, among other things, the implementation of earthworks, the cutting of trees and the removal of vegetation in the plots of the proposed project.
Based on the new data, the Department of Environment is now called upon to make critical decisions. At the heart of the examination is whether the Environmental Authority intends to continue the evaluation of a proposed project that appears to violate fundamental provisions and legal procedures of European and Cypriot environmental protection law.
The case law of the Court of Justice of the European Union is clear that Member States must ensure that the environmental impact assessment is carried out before any permit is granted, in order to avoid causing pollution and nuisance and not to combat their consequences after the fact. In addition, a specific legalisation regime that would encourage developers to ignore the common environmental impact assessment and specific ecological assessment procedure is not allowed.
The case law of the Courts of the Republic of Cyprus is also clear that the submission of an application for planning permission presupposes that any works under this application constitute development. Therefore, the commencement of any preparatory (earthmoving) and construction (construction) works without any approval and permit, while the relevant applications and studies are being examined, constitutes a parallel approval and disapproval of an institutional process, a practice that is not accepted in administrative law.
Questions to the Department of Environment
The following questions have already been submitted to the Deputy Director of the Department of Environment:
1. Whether the Department of Environment carried out an on-site visit to the area where the proposed project is located after the meeting of the Ad-hoc Committee for the Special Ecological Assessment held on 10/2/2026, when the arbitrary interventions were identified and highlighted.
2. If the implementation of any preparatory (earthmoving) and/or construction (building) works has been ascertained in the plots of the proposed project.
3. Whether the Department of Environment, the Game and Fauna Service and/or the Limassol District Authority have taken any measures to comply with and enforce the environmental, urban planning and building legislation.
4. Whether the Department of Environment intends to continue the examination of the proposed project, taking into account the applicable legislation, the relevant case law of the Courts of the European Union and the Republic of Cyprus, as well as relevant Opinions of the Legal Service.
5. If the Department of Environment has prepared and submitted a relevant fact report to the Legal Service, requesting a legal opinion on the above issues.
The case of Trozena is expected to be a crash test for the will and determination of the co-competent authorities to take substantial measures to deal with practices that attempt to create a fait accompli on the ground, at the expense of nature and without following the legal procedures.
