REVIEW OF THE ENVIRONMENTAL IMPACT ASSESSMENT
done by Environmental Solutions Limited of the proposed Bahia Principe Hotel Resort Development Pear Tree Bottom, St. Ann Jamaica
Respectfully submitted by:
JAMAICA ENVIRONMENT TRUST and NORTHERN JAMAICA CONSERVATION ASSOCIATION
Supported by (in alphabetical order):
Carter Center (Jamaica)
Coalition for Community Participation in Governance
Countrystyle Community Tourism Network
Cranbrook Flower Forest
Friedrich Ebert Stiftung
Friends of the Sea
Friends of Conservation (UK)
Hotel Mockingbird Hill
International School of Jamaica
Jamaica Environment Trust
Jamaican Caves Organisation
Marcus y Bob Community League (Discovery Bay)
Montego Bay Marine Park
Mount Pleasant Residents’ Association (Runaway Bay)
Northern Jamaica Conservation Association
Ocho Rios Nature Preserve Trust
Residents of Queen’s Crescent (Discovery Bay)
Runaway Bay Craft Vendor’s Association
Seven Oaks Sanctuary for Wildlife
Sturge Town Community Development Council
Tourism Protection Committee of St. Ann / St. Mary
United African Improvement Association (Discovery Bay)
and many individuals, whose names are appended to this document.
From as early as 1992, St. Ann Environment Protection Association (STAEPA) and other groups had begun to voice their concerns about the proposed development of the coastal area of Pear Tree Bottom in St. Ann. Below is a list of concerns about the possible environmental and social impacts of the development sent in 1993 by STAEPA to the Natural Resources Conservation Authority and the developers of the proposed Pear Tree Bay hotel project near Runaway Bay in St. Ann, on behalf of STAEPA and local residents:
- Very special area and beautiful area, recommended for protection in JCDT’s plan for a system of parks and protected areas
- Forested hillside, sloping to freshwater marsh, mangroves, sandy bays interspersed with rocky shoreline; coral reefs “spectacular” – buttress formations; outstanding scenery
- Habitat for wide variety of birds, endangered Jamaican boa, sea turtle nesting beach
- Plans include a large, beachfront hotel and villas, details uncertain
- Extensive coastal modifications already underway include construction of 5 large groynes, dredging the shallow back-reef area to provide swimming areas, and creation of artificial beaches with crushed marl
- High density development will affect the entire nature of the area
- The clearing of natural forest cover will lead to increased surface run-off, soil erosion, and siltation of the nearshore marine environment
- Deforestation associated with the construction of roads has already led to loss of wildlife habitat, particularly for birds and the endangered Jamaican boa
- The clearing of the seafloor from shore to the back-reef will destroy this shallow, protected environment; this area does not consist merely of coral rubble, but supports a variety of life, in particular the mollusks and other invertebrates
- The construction of groynes and other alterations to the coastline have already proven a deterrent to nesting of the endangered hawksbill sea turtles for which this area is an important nesting site
- Bypass road is affecting the wetlands, as three culverts are not enough to ensure free flow and drainage is impeded (according to North Coast Highway Project scientists) which will affect health of wetlands
- Uncertainty about the capacity of the developers to effectively manage sewage and wastewater effluent as well as solid waste generated by development.
- Jamaica’s north coast is suffering from the effects of intensive development with inadequate infrastructure, implemented with little or no consultation with communities affected
- Local people are being and will be excluded from amenities which include access to the beach and river at Pear Tree Bottom, a popular and traditional recreation spot; this creates frustration and hostility towards developers and tourists
- The traveling public is denied views one of the most picturesque coastal areas on the entire island, and one of the few remaining places on north coast where construction has not obliterated a view of the sea; although economic values of these amenities are not easily quantified, they nevertheless exist.
- Fishermen are being displaced
- The development will need large numbers of workers for whom there is insufficient housing, vendors for whom there is no craft market or designated vending area
The concerns expressed above were presented to the developers, Tankweld Ltd., on a number of occasions between 1992 and 1995, including at a meeting of the St. Ann Chamber of Commerce (November 11, 1992), at a public hearing for the project at Hotel Ambiance, and a community meeting specially hosted by STAEPA to discuss the project with the developers.
Now in 2005, many groups and individuals are deeply concerned about the proposed development of the Bahia Principe Resort at Pear Tree Bottom. We have reviewed the EIA and sought input from a wide range of people, both those from the immediate vicinity and islandwide. We have also received input from Jamaicans no longer resident in the island and from tourists.
We submit below our findings in the following format:
1. Significance and values of the Pear Tree Bottom area
2. Community perspective and vision for the development of Pear Tree Bottom
3. ‘Material concerns’ about the proposed Bahia Principe resort development
4. Comments on the development process
5. Comments on the EIA process
6. Recommendations for NEPA and the developers
SIGNIFICANCE AND VALUES OF PEAR TREE BOTTOM
What is the significance of this area?
The EIA for the Bahia Principe Hotel says:-
“The Pear Tree Bottom wetland is a unique feature on the north coast of Jamaica; no other wetland of equivalent size and with the same mix of physical and vegetation characteristics has been described from this coast.” (Bacon & Alleng (1991), quoted on p. 39 of the EIA.)
“…one of the best coral reef dive sites in Jamaica.” (p. 102, EIA).
“The wetland plays an important role as a nursery for fish and estuarine species and this highlights the need to protect the integrity of the swamp.” (p. 42, EIA)
We, the undersigned, think that the coastal ecosystem at Pear Tree Bottom is of local, national and international importance as a unique and significant example of Jamaica’s natural heritage, as a research site for marine and coastal ecology, as wildlife habitat, as a traditional fishing beach for a small local population, and as a quiet place of refuge and relaxation for local residents and visitors alike.
The significance of this special natural area can not be underestimated, especially in light of the collective impacts of the North Coast highway and other developments planned and in progress on the north coast of Jamaica.
With its forested hillsides sloping to a freshwater marsh; the river, mangroves, and sandy bays interspersed with rocky shoreline; seagrass beds and spectacular coral reefs, Pear Tree Bottom provides the following ecosystem services:
Wildlife habitat: Dry limestone forest is home to a multitude of indigenous and endemic wildlife, including several species of birds (all protected by law), endangered Jamaican boas/yellow snakes (also a protected species), and countless species of invertebrates and plants, including many endemic and indigenous coastal species. The wetland and estuary are the habitat for a rich and diverse fauna, including native and migratory birds and aquatic species. The seagrass beds are nurseries for fishes, lobsters and other marine species. The beach is a well-known nesting beach for at least two species of critically endangered sea turtles, Green and Hawksbill.
Research and education: The coral reef reefs at Pear Tree Bottom, with their spectacular buttress formations, are of international importance as a research site and the place where sclerosponges were first discovered in the 1980s, in underwater caves just offshore. Scientists working from the nearby Discovery Bay Marine Laboratory have studied and documented the biology and ecology of the Pear Tree Bottom reefs continuously for almost 40 years.
Health and wellbeing: Generations of Jamaicans have used and enjoyed the beach at Pear Tree Bottom to improve their quality of life – for recreation, relaxation and meditation, exercise, appreciation of nature (e.g. bird-watching), and fishing. It was designated a Public Bathing Beach on the St. Ann Coast Development Order of 1963 and is one of the few remaining beaches on the north coast where ordinary Jamaicans can go to quietly enjoy nature, in contrast to a commercially-developed recreational beach or an all-inclusive hotel.
Flood and storm surge protection/pollution control: The forest and wetland help to reduce runoff and increase rainfall capture, reducing the risk of flooding in nearby coastal areas. The wetland helps to filter the run-off, while the coral reefs and rocky shore help to reduce vulnerability to storm surges.
Improvement of air quality/carbon sink: Vegetation of the forest and wetland filters air pollution from motor vehicles and absorbs carbon dioxide (1 hectare of woodland can absorb emissions equivalent to 100 family cars). The forest also attenuates noise.
Shade and cooling: A single large tree can be equivalent to five room air conditioners and will supply enough oxygen for ten people. The forest at Pear Tree Bottom literally provides ‘a breath of fresh air’ for Runaway Bay and environs.
COMMUNITY PERSPECTIVE AND VISION
From the responses gathered over the past 13 years, the collective vision of the local community and the wider community of Jamaicans for Pear Tree Bottom includes the following elements and recommendations:
1. Declare the area a National Nature Reserve / Wilderness Area and manage the area for biodiversity and ecological protection, scientific research and education. This is a category of protected area reserved for ‘lands or waters with unique biodiversity or other ecological values’ and there can be no doubt that with its dry limestone forest, river, wetlands, mangroves, estuary, seagrass beds, and spectacular coral reefs, Pear Tree Bottom qualifies in all respects. There is no area of Jamaica’s north coast that is protected and managed as a nature reserve, where people can safely go to experience and enjoy a natural, unspoiled beach.
2. Maintain the beachfront as scenic natural coastline, with minimal alterations to shoreline except restoration. Replace the existing coast road with a public bicycle trail and footpaths, while ensuring effective monitoring and site management so that the use of the area by the public is compatible with the objectives of the Nature Reserve, as noted above. Provision should be made for the few local fishermen who traditionally have used this beach to store and launch their boats. Further expansion of fishing activities to newcomers need not be allowed, and fishing does not have to take place in near-shore waters of the bay. In our experience, fishermen are receptive to the concept of marine protected areas as fish nurseries.
3. Any resort development proposed for this area should be designed and operated as a first-class ecotourism resort in order to protect its natural assets and maximise their environmental and economic values over the long term. The resort should be low impact, ecologically sensitive, and community-oriented, providing a high quality visitor experience with opportunities for interaction with local people. Jamaica already has numerous large hotels catering to mass tourism (and more planned), with significant environmental and social costs. Pear Tree Bottom can provide at least as much economic benefit to both local and foreign investors by attracting ‘premium’ tourists who are willing to pay top dollar for a visit to a more natural and unspoiled destination.
4. The resort should be integrated with the local communities and not run as an all-inclusive resort . The people of Runaway Bay and environs are totally opposed to being excluded from access to this beautiful strip of coast which has been enjoyed and used by local people for generations. A community-oriented ecotourism resort would provide a far greater range of spin-offs to local communities in the form of employment, support for local businesses and products, for example, organic agricultural produce, art, crafts, and the growing number of eco/cultural/heritage tours in the region. The resort could provide facilities for craft vendors and other tourism-related services in a designated commercial area to the east of the hotel complex. And it could cater to Jamaicans – ‘dry land tourists’ – who have few affordable options for vacations due to the dominance of all-inclusive hotels on the north coast.
3. A resort at Pear Tree Bottom should promote the unique values of this special area and Jamaica itself. St. Ann is rich in history and culture, with many world-renowned sites such as Dunn’s River, Seville, Nine Miles, Green Grotto Caves and emerging events and attractions of community tourism such as in Sturge Town and Walkerswood. There are excellent opportunities for bird-watching, botanical tours, SCUBA diving, and other forms of nature / adventure tourism.
COMMENTS ON THE ENVIRONMENTAL IMPACT ASSESSMENT
Number of protected species: The EIA states that the “…the dry limestone forest is home to two endemic and protected species in Jamaica, the Yellow Snake or Jamaican Boa and the Yellow-billed Parrot” (Executive Summary, p. 4).
All indigenous and migrant birds are protected under the Wildlife Protection Act, so the number of protected species in the forest is not just two, as the EIA concludes, but is the total number of bird species in the area, plus the yellow snakes.
Insufficient field assessment: “… field investigations undertaken on 15 February 2005. Seven representative sites or stations were visited; five on the proposed resort site north of the main road and two stations south of the main road on lands also owned by the developer… Birds were recorded by sight and by sound for half-an-hour at each station.” (p. 7).
Apparently, the field assessment involved a total of 3.5 hours of birding, on one visit, in daylight (we assume). How were the sampling stations chosen? Only one of the six stations was in a fairly well vegetated area (Station 2). Four of the five stations on the project site had little or no vegetation (two being roadways, Stations 5 and 6). No sampling stations were located in the wetlands.
The fact is that there are a great many more species of birds at Pear Tree Bottom than can be determined in one or two visits of a few hours. For example, nocturnal birds and seasonal variations in bird populations have been missed. Nocturnal birds (potoos and patoos) are undoubtedly present in the forest, as they are heard calling at night at Seven Oaks, only a couple miles away.
The EIA mentions “the possibility that the wetland is being used as a wintering stop-over” (p. 42). This should have been established conclusively. During the colder months, a variety of seabirds can be seen in the area, wading in the shallows, hovering over the reef or feeding on the beach. The EIA should properly assess the importance of this site for migrant bird populations as well as year-round residents.
Importance of this forest: The EIA does not state what proportion of remaining dry limestone forest in St. Ann this area represents. It also does not assess the dispersal ranges for the bird species that live in the forest at Pear Tree Bottom, that feed in the estuary, that roost in the mangroves. The EIA should assess how wide an area the forest influences as a wildlife “reservoir.”
We urge NEPA and the developers not to underestimate the importance of this forest, especially in light of the cumulative impacts of the highway and other coastal development.
“The section of forest north of the highway is degraded and impacted by human activity.” (p. 29).
What the EIA calls ‘degraded dry limestone forest’ has been degraded by the activities of the previous developers, who caused the road to be moved cutting right through the fairly undisturbed forest at the time.
Also, despite the sparse vegetation of the mangrove scrub at Station 4, the importance of this area is in how it used by wildlife. In the early evening, this is an important congregation area and roosting site for many birds.
Replanting: Replanting and landscaping can in no way be compared to or called “part restoration of lost habitat” (p. 5). Typically, flora and fauna that would be removed would be replaced by a totally different habitat, otherwise why not keep the original vegetation of the site? Some of the endemics are quite difficult to propagate, although they seem hardy growing wild in their own environment.
“The EIA should speak to the endemics and other specific trees and plant materials which should be retained. If a landscape plan is not submitted then you will never know which ones will be retained… [NJCA] should insist that NEPA require a Landscape plan…to be submitted.”
Bats: The EIA does not assess the bat population. Bats play an important role in pollination and seed dispersal in Jamaican forests as well as domestic fruit orchards.
Reptiles: The EIA states, “Information on endangered reptiles was gathered from the Seven Oaks Sanctuary for Wildlife in St. Ann,” (operated by NJCA).
Jamaican boas: The discussion between SOS-Wildlife and Environmental Solutions Ltd. was mainly about one species, the Jamaican boa, of which several individuals have been rescued from Pear Tree Bottom. In fact, most of the yellow snakes received by Seven Oaks Sanctuary for Wildlife have come from this area and we believe that the forest at Pear Tree Bottom is an extremely important habitat for the endangered yellow snake.
The mitigation guidelines for yellow snakes as stated in the EIA are as follows: “All construction workers and persons on site must be given specific instructions not to harm snakes but allow the animals to retreat into the forest. Alternatively they may be captured for safe keeping by the Seven Oaks Sanctuary for Wildlife in St. Ann. All sightings should be reported to the project manager and ultimately to NEPA. It may be prudent to offer a substantial reward for every snake recovered unharmed.” (p. 88)
Except for the first sentence, these guidelines are insufficient. Yellow snakes belong in their habitat. We do not recommend the encouragement of people to “recover” snakes for a “substantial reward.” SOS-Wildlife does not have the space or capacity to become a holding facility for the population of yellow snakes that will be displaced by this project. Apart from a few demonstration specimens and possibly a breeding pair, SOS-Wildlife’s goal for snakes is rescue, rehabilitation if necessary, and then release into suitable habitat.
Sea turtles: Local people know that the beach at Pear Tree Bottom is a sea turtle nesting beach. NJCA has been called to rescue one large female turtle which had come to lay eggs and been captured by the workmen at the Tankweld site, and recently another was slaughtered by construction workers at a small hotel site nearby. Construction workers were also responsible for nearly beating to death one of the yellow snakes currently at SOS-Wildlife.
Pear Tree Bottom and the beaches at Llandovery and Seville are among the few turtle nesting beaches left in St. Ann. No hotels, no lights, lots of sand.
Other reptiles: SOS-Wildlife has no information about other reptiles such as lizards or the endemic freshwater turtle, which may or may not occur in the area.
Heavy footprint of project: We note with alarm that an astounding 23.5% of the project’s land area is to be covered by impervious surface!
“It is estimated that approximately 8 ha (19.7ac) or 23.5% of the land area will become covered by impervious surface.” (p. 77).
As planned, “The buildings will be a maximum of six stories high in Phases 1 & 2 and seven stories high in Phase 3,” which would be “The westernmost hotel adjacent to the small area of wetland.” (P. 77)
WE FEEL THAT SUCH A LARGE HOTEL COMPLEX IS COMPLETELY INAPPROPRIATE FOR THIS SCENIC AND ECOLOGICALLY SENSITIVE AREA. APPROVAL SHOULD BE REFUSED FOR THE THIRD BLOCK ON THE WESTERN SIDE, AS IT WILL IRREVERSIBLY DESTROY THE AESTHETIC VALUE OF THE COASTLINE AND SEVERELY AFFECT THE WILDLIFE IN THE ADJACENT WETLANDS/ESTUARY.
We are also very worried about the statement, “At present there are no definite plans for utilization of the rest of the property south of the highway.” (p. 77)
We have heard rumours of a golf course in the future – could this possibly be one of the plans? If so, it would mean the demise of the entire complex of linked ecosystems, and probably loads of fertilizers and pesticides going into the bay. The rocky limestone is entirely unsuited to the maintenance of anything resembling a lawn. We totally oppose the practice of granting separate permits for such developments – NEPA should insist on all aspects of the development being described at the outset. In the event that there are genuinely no future plans, the EIA should state what land use is appropriate for the unused portion of the site.
The wetlands/mangroves" Plans for the management of the wetlands were not clearly stated in the EIA, other than to say that “the marsh will be incorporated as a special feature in the landscape design” (p. 93). The EIA should assess potentially damaging impacts of the project and set out both preventative and restorative measures. The EIA should specifically address how the wetlands and estuary will be maintained, state the size of the wetland and what measures will be undertaken to ensure its protection. The wetland should be identified on a map and pictures provided.
Bulrushes are blamed for restricting water flow (p. 39), yet no mention is made of the road constructed in 1995 by Tankweld, which has visibly contributed to the drying out of the wetland. At the public hearing for the Tankweld development, some time in 1994, Dr. Jeremy Woodley, Head of the DBML at the time, challenged the estimates put forward by the EIA for surface flow, and suggested that the new road did not have adequate provision to allow the water to flow freely through the wetland. Ten years later, his predictions have come true, but the connection is still not being made to the real cause – the road.
The EIA does not refer to NEPA’s draft wetland policy.
Marine life: In terms of the marine evaluation, the EIA states:
“This section relies much on the descriptions of these habitats presented in Harvey (1993) but there has been verbal confirmation that the current status of the reef is not much changed.” (p. 44)
A thorough study and appraisal of Pear Tree Bottom’s prime assets – coral reefs – should have been conducted.
Marine pollution/coral reef impacts:
The EIA states: “The discharge of sewage from the proposed development into the surface waters should not be allowed as the algae growth present on the reef could proliferate with any increase in nutrient levels.” (p. 66)
The EIA does not definitively state how the sewage will be treated. The environmental impacts cannot be properly assessed unless the precise method for sewage treatment is known. In order to prevent the kind of nutrient overload that has severely degraded reefs all over the north coast, a tertiary sewage treatment system is essential.
Groynes and coastal engineering: The groynes were constructed sometime after 1994, not in the mid-1980s. The seafloor inside the groynes is ecologically barren compared to what it was like prior to the complete destruction of the original inshore area.
The EIA assumes that debris on the reef crest was “thrown up by past hurricanes” (p. 4). Much of the debris actually came from excavation of inshore waters by Tankweld to construct the groynes. The coastline on the eastern side of the property has been marred by the ugly groynes put in by Tankweld. We are not sure what physical impacts these large structures are having on other beaches as sand migrates down the coast.
Regarding the “deepening of the back reef” (p. 101) the EIA states that the developers will be seeking to excavate a channel on the western side of the bay, which is presently covered with sea grasses. Tankweld did this already in the mid-nineties, and within a few years the part that was dredged to form a swimming area had totally silted up. So, in November 2003, Tankweld again dredged the western inshore area, causing major turbidity and sediment suspension. Is this going to be an on going requirement for this hotel?
The mitigation measures outlined below are unrealistic and unattainable: “Based on the appropriate study and assessment prepare a plan for deepening the area that would respect the habitat value of the back reef lagoon, improve its habitat function, and avoid the adverse ecological impacts related to sediment suspension and turbidity.” (p. 90)
This is unclear. Who will the habitat be improved for? Certainly not for the creatures that inhabit the seagrass beds, or the turtles that seek a shallow, sloping beach, or the corals downstream that will be hit by the unavoidable sediment suspension from the dredging.
The destruction of the seagrass beds should not be permitted. We are aware that many hotels in Jamaica have been allowed to destroy sea grasses on the understanding that they are replanted elsewhere. Has any assessment of the success of these measures been undertaken?
The EIA warns about damage during the operational phase from “misuse of coral reefs – severe damage to corals due to recreational boat anchoring, marine souvenir collecting, and careless diving technique.” (p. 5) However, It fails to mention the impacts of oil, gas and noise from motor boats and jet-skis on the marine environment.
Community studies: It is unclear from the EIA what the sociological assessment investigated and what the results were. How were the communities selected and defined?
The EIA says, “three were fishing beaches, and six were residential” (P. 21), but the names of the communities read like a list of hotels, with a few squatter communities thrown in.
Please clarify what is meant by the following (p. 14) regarding the Parish Development Order, 2000:
“It also confirms the realignment of the boundary on the Pear Tree property between the resort use area and the conservation area as being the old Parish Council road.”
Language: Some of the statements in the EIA are vague, unclear and/or unenforceable, such as :-
“The proposed resort development project must endeavour to ensure that onsite and shoreline construction activities do not threaten or harm the fringing coral reef and back-reef habitats adjacent to the site.” (p. 15).
“Equally important will be the project’s contribution to the new momentum given the physical planning process, since it is the cumulative impacts of this process that will ultimately determine the sustainability of development along the North Coast.” (p. 62)
Many of the mitigation guidelines use the phrase, “should be guided by” (pp. 86-87). This is not strong enough; they must adhere to the conditions.
Rainfall: Rainfall figures are out of date. Current figures are available for Runaway Bay since 1999 (NJCA is a Rainfall Observer) and should be compared with older figures.
Economic concerns: We do not agree that “In national economic terms, this is the best value-added land use option available in the context of given opportunities.” (p. 62)
There is no indication of the long-term sustainability of the mass tourism option. Indeed, there is ample evidence of, and demand for, alternative forms of tourism.
The EIA states, definitively: “Loss of options is the trade off for tourism benefits” (p. 5)
This statement does not give a clear picture of what those options are – they encompass a wide range of environmental, social, aesthetic and economic benefits, the value of which has not been properly assessed and compared with the present plans.
High-density, high-impact development means irretrievable lost opportunities for wildlife and nature tourism, which would be linked to community benefits for the surrounding areas, as well as tangible and intangible ecological services and benefits. To use this area for mass tourism would be an irresponsible waste of our natural resources.
Furthermore, if this development were done in harmony with the environment and sensitive to the needs of the people of the area, we would not have to lose the ecological or ecotourism benefits of this special area, while still deriving economic benefits for ourselves and Jamaica.
The EIA mentions a ‘tourism corridor’ (p. 61). Along with this we should be putting in place a ‘conservation corridor’ to ensure that our native species and natural habitats are not reduced to small fragments in a concrete landscape.
Before raising the expectations of local people and others who might be attracted to the area, secondary and tertiary spin-off services must be carefully evaluated and facilitated by: (e.g.) HEART Trust, Parish Council, NWA, JAS, RADA, SDC, TPDCo., Community Tourism interests, Chamber of Commerce, service clubs, manufacturers, processors, business, labour unions, and community-based organisations. We need higher level employment opportunities, not just minimum wage employment.
The cultural values of livelihoods must not be overlooked, particularly the local artisanal fishing industry. The EIA says, “Fisheries in the area have relatively little to contribute to the project but stand to benefit if the hotel creates an indirect and additional demand for fresh fish.” (p. 64)
This point is irrelevant, since the demand for fresh fish currently outstrips the local supply due to long-standing degradation of Jamaica’s inshore fisheries. On the other hand, the destruction of a very important fish nursery would have significant long-term impacts on subsistence fishing along the coast. And fishing is an integral part of our coastal culture, despite the problems with over-fishing. We on the north coast should follow the example of Treasure Beach, which has successfully integrated fishing with tourism opportunities.
In preparing for the start of work, there should be a collaborative effort to implement a community outreach programme for nearby communities – Runaway Bay, Discovery Bay, Salem, Mt. Olivet, Dunbarton, Queenhythe, Thickets, Farm Town – so as to provide a recruitment centre for jobs, coordinate transportation, help with infrastructure to avoid squatting.
Employment for locals and community-based services should have priority over external entities. Foreign companies should be encouraged to form partnerships with local companies. Franchises of transport and other services must be handled carefully so as to minimise conflicts.
Social and infrastructure concerns: There is unanimous agreement among local stakeholders that the hotel at Pear Tree Bottom needs to be considerably smaller than proposed. The carrying capacity of the area cannot sustain a new development of the size planned for the Bahia Principe. The physical and social infrastructure is inadequate even now, without a 1,900-room hotel and its work force in the area. Respondents submitted a wide range of concerns about the impact of such a large development:
§ There is limited space for urban expansion and not enough affordable housing. Squatter communities are growing in areas adjacent to Cardiff Hall, Mount Edgecombe, Belair and in the hills south of Pear Tree Bottom. The EIA recognises this as the most critical environmental issue, but leaves the ball in the Government’s court: “It is the responsibility of the Government to provide the planning solutions.” (p. 70)
§ With respect to electricity supply, the EIA says, “The total estimated demand for electricity is 1.8 MW. It is currently proposed to purchase that supply from the Jamaica Public Service Co. Ltd. However, the possibility of co-generation will be considered.” (p. 83). Electricity supply for the area is already erratic, with frequent power cuts and low voltage.
§ There are no land lines available from Cable and Wireless in this exchange.
§ The fire services are in need of equipment and trucks, which are not forthcoming any time soon. How could they possibly cope with a fire in a 7-storey building?
§ All the non-biodegradable garbage produced by the hotel and its work force would have to be trucked through Fern Gully daily (or perhaps not, if it were dumped in some out-of-the-way gully or corner of the forest by unscrupulous contractors, which happens frequently).
§ Crime and violence are escalating in the area, fuelled primarily by the illegal drug trade (one of tourism’s unwanted spin-offs). The Runaway Bay Police Station is understaffed and often without a vehicle to respond to reports of crime.
§ There are not enough schools or suitable school sites available on the north coast. Our children have to travel long distances in overcrowded buses on pothole-riddled roads to reach schools in the interior towns and villages. The all-age and high schools are already on double shift, some of them accommodating over 2,500 students.
§ We worry about the impact of the resort on local water supplies. The EIA states, “Conditions designed to prevent over-pumping and salinisation of the supply are attached to the permit. Should pumping tests prove that this supply is not reliable then the options of opening a new well or installing a reverse osmosis plant will be considered.” (p. 81) .
The water supply plan is vague, unenforceable, and inconclusive. A development of this size should not be approved without concrete evidence of a sustainable water supply.
COMMENTS ON THE DEVELOPMENT PROCESS
Lack of information and opportunities for local involvement
Local stakeholders have repeatedly requested information on this development since August 2003. The St. Ann Parish Development Committee on which NJCA sits has repeatedly requested information on this project from the developers, JAMPRO, the Ministry of Development and the Minister himself, Dr. the Hon Paul Robertson – all to no avail. Planning should precede development, but it appears to be happening the other way around.
In October 2003, Mr. James Walsh, the Chairman of the St. Ann PDC, said that he “had written to the Ministry of Land and Environment pointing out the concerns of the PDC; that the Committee noted with interest that there was a proposal to construct an 1,800 room hotel on lands at Pear Tree Bay, and that persons in the area would like to have an input in the decision making of the parish.” (St. Ann PDC Minutes 09 04).
The PDC Minutes of June 2004 confirm the lack of response from either the applicant or the government:
It was not until September 2004 that the Secretary/Manager of the St. Ann Parish Council, Mrs. Dorothy Delgado, was able to report that an ‘Outline’ application for the development had been received by the Council (St. Ann PDC Minutes 09 04).
Ironically, in March 2005, NEPA asked us to respond to the EIA as soon as possible “so that a timely response can be made to the applicant.”
Disregard for planning and development application requirements
We submit that the Ministry of Development (is that its name?) appears to be disregarding the planning and approval process. From the statements made by the Minister in the 2004-2005 Sectoral Debate Presentation on May 11, 2004, it seems that we, the local stakeholders, are being invited to comment after the fact on one of the many large resort developments for which the Minister of Development has undertaken to “expedite the processing of their approvals” in order to “realize these investments in the shortest possible time” and “ensure that the projects are not delayed by bureaucratic humbug”.
Pattern of violations of permit conditions / lack of compliance
We are worried that in the case of at least two other Bahia Principe resorts built and operated by this developer, local residents in other parts of the world reported serious environmental problems and breaches of permits and regulations, despite the developer’s claims of environmental responsibility.
Given the huge scale of this project and the irreversible damage that it could cause, we need to proceed with extra caution. We do not want to lose our fragile and irreplaceable natural assets like what is happening in the Yucatan, where large areas of wetlands were destroyed by this “totally ecological” company.
In December 2002 the City Council of Adeje, Tenerife fined the Hotel Bahia Principe 6,000 Euros after finding the hotel “unrelenting in its nuisances,” which included constant loud noise and emissions from its generating plant. The citizen’s group that brought the case called them “a company that never tried to fix the problem for its neighbours who complained.”
Based on the precedent already set in the application process and examples of other recent developments along this coast and elsewhere, there is a strong probability that there will be environmental breaches, and that NEPA will not be able to adequately monitor this project and enforce permit conditions. For example, the Development Order makes it illegal for any road construction for a subdivision to take place before approval is granted. The previous developers were in violation of the order, and were never stopped.
COMMENTS ON THE EIA PROCESS
Our recommendations to avoid major problems with the communities / stakeholders and overall failure of the EIA process are as follows:
1. The Ministry of Industry and Tourism should facilitate development of a Strategic Environmental Assessment for the policy/plan/development order that is encouraging large scale tourism zonation in the coastal area of St. Ann. We are being faced with some pretty major social impact and marine conservation issues, as well as scarce shared resources managed by municipal authorities (water supply, solid waste disposal, sewage disposal, road maintenance etc.).
2. The National Environment and Planning Agency needs to revise the EIA scoping process (Terms of Reference). Presently, the consultants to the proponents submit a draft TOR for approval. This is reviewed at NEPA and recommendations made there for its finalization before approval is granted. TORs are placed on the website for comment but very few impacted parties may have web access. Samples of TORs reviewed tended to very generic. There should be:
(a) A standardized format with a clear statement of the purpose of each section.
(b) Establishment of a "statute of limitations" for environmental data - obviously different types may have different periods of validity (geological information versus water quality). Pollutants (in air, water, soil/sediment, noise, light etc) need to be fairly up to date, as would be biological and socio-economic communities. Of course the relative importance of the baseline would vary with the area and project as well.
(c) An attempt should be made to identify the major environmental issues that would be pertinent in the proposed development area. This can be done by having a community presentation made of the project plan prior to the start-up of the study so that stakeholders can have input to the TORs very early on. This also minimizes later conflicts or omissions. At this stage it also helps the consultant budget the project properly because they have a better idea of what new environmental surveys are needed.
(d) Standards for the EIA - particularly with respect to how impacts should be assessed. Many EIA reports identify impacts but do not assess them. Standards are also needed for the descriptions of monitoring plans and mitigation measures to ensure clarity and feasibility of the steps to be taken.
RECOMMENDATIONS FOR NEPA AND THE DEVELOPERS
Local community- and interest groups should not be perceived as anti-development; they wish to contribute to sustainable development in their communities and to have good relationships with the investors and owners of new resorts. However, they must be provided with information about the proposed development and their input actively sought for the development plans.
We are not asking for this project to be refused outright, but we must know, by thorough study and research, exactly how it will affect the site; we must have a say in determining what impacts are acceptable and what are not, and what the developer must do in terms of identifying and if necessary, providing, the support for the preservation of specific natural areas and the additional community infrastructure required for the sustainability of the project itself. And the authorities must enforce the stipulations without fear or favour.
We therefore recommend the following approach to the development of Pear Tree Bottom:
1. Community vision and involvement: Implement the general recommendations in the section on Community Perspective and Vision and the specific recommendations throughout this submission. Include local tourism products and services supplemented by imports, and not vice versa. We believe that NGOs and community-based organisations have an important role to play in facilitating development that is truly sustainable and beneficial to all.
2. Scale : Reduce the size of the resort by at least two-thirds and confine its ‘footprint’ to the parts of the property that have already been cleared by Tankweld or earlier habitations. Reduce the height of the hotel buildings to three storeys, maximum, and do not approve construction of the third block, adjacent to the wetlands.
3. Setback: Increase the set-back to 100 meters from the shore and restore the coastal area with walking trails and bicycle paths. Offer managed public access to trails and the beach, which should be kept as natural as possible.
4. Speed: The development should be done over a much longer timeframe and in concert with adequate local infrastructure, some of which the developers should be required to support (e.g. worker housing, tertiary sewage treatment, fire services, water supply for surrounding communities, power supply, waste management).
5. Environment: Expressly prohibit harmful practices, such as dredging, the removal of seagrass beds or mangroves, dumping of solid waste or construction material and rigidly enforce those prohibitions.
6. Conservation and Education: The resort must also support local conservation efforts – environmental education, wildlife rescue and rehabilitation, coral reef monitoring and restoration, cultural preservation, and community outreach programmes to encourage sustainable tourism initiatives, to name a few areas.
7. Carrying Capacity: All coastal resort development must be based on adequate assessment of Carrying Capacity of the area’s resources – human, physical, environmental, social, and economic.
8. Cumulative Impacts: All coastal resort development must only be approved following a thorough evaluation of cumulative impacts.
April 28, 2005