Quar­ry zones are "re­quired" by the Min­er­als Act of 2000. The Min­istry of En­er­gy en­gaged GWP Ltd, an Eng­lish com­pa­ny, to con­duct a Strate­gic En­vi­ron­men­tal Im­pact As­sess­ment Re­port (SEIA) to iden­ti­fy and rec­om­mend quar­ries (Min­ing Zones) across T&T.

Their work start­ed in Jan­u­ary 2013 and was due to be com­plet­ed at the end of Sep­tem­ber 2013. Fish­er­men and Friends of the Sea (FFOS) were in­vit­ed, along with oth­er pub­lic in­ter­est cit­i­zens and stake­hold­ers, to the first "pub­lic con­sul­ta­tion" in De­cem­ber 2013.... af­ter the re­port had been com­plet­ed. This was not a pub­lic con­sul­ta­tion. It was dic­ta­to­r­i­al, un­de­mo­c­ra­t­ic, and se­cre­tive:

1. There was no back­ground in­for­ma­tion pro­vid­ed be­fore­hand as to what was go­ing to be the sub­ject of the "pub­lic con­sul­ta­tion," even though FFOS wrote re­quest­ing same.

2. There was no open com­ment pe­ri­od to al­low at­ten­dees to voice their con­cerns.

3. The SEIA Re­port which formed the ba­sis of the en­tire "pub­lic con­sul­ta­tion" process was deemed to be too con­fi­den­tial to share with the at­ten­dees. Imag­ine you are be­ing asked to par­tic­i­pate in a "pub­lic con­sul­ta­tion" process and you are not per­mit­ted to view the doc­u­ment that is un­der­ly­ing the en­tire con­sul­ta­tion?

4. Many of the re­spons­es pro­vid­ed were vague.

5. At­ten­dees were warned not to try to get the SEIA Re­port even un­der the Free­dom of In­for­ma­tion Act, (FOIA) as this was clothed with Cab­i­net se­cre­cy. What can be so con­fi­den­tial in a re­port on quar­ry­ing zones in T&T?

6. There were no maps clear­ly show­ing the pro­posed min­ing zones.

7. There was a fail­ure to con­sult with the wider pub­lic to in­form the SEIA.

The na­tion's wa­ter se­cu­ri­ty is at stake. Should we not have had mean­ing­ful pub­lic con­sul­ta­tions dur­ing the study pe­ri­od?

Ac­cord­ing to the Min­istry of En­er­gy, the rec­om­men­da­tions of the SEIA will "al­low" the En­vi­ron­men­tal Man­age­ment Au­thor­i­ty to grant a "blan­ket" Cer­tifi­cate of En­vi­ron­men­tal Clear­ance (CEC) to all ex­ist­ing and pro­posed quar­ry ac­tiv­i­ties in each of the three dozen des­ig­nat­ed Min­ing Zones. This, ac­cord­ing to the Min­istry, will "sim­pli­fy the process" for the grant of quar­ry li­cences and pro­vide an "emerg­ing frame­work for bet­ter reg­u­la­tion of the in­dus­try".

FFOS ex­press­es its strongest dis­sat­is­fac­tion with how the Min­istry of En­er­gy has gone about con­duct­ing the SEIA. If what has been pro­posed is in­deed ap­pro­pri­ate and above board, why were the con­sul­ta­tions dur­ing the study not open to pub­lic par­tic­i­pa­tion? Now that the re­port has been fi­nalised, why not share it with the pub­lic?

The last sig­nif­i­cant study done on quar­ry­ing in the North­ern Range was the EMA's 2004 State of the En­vi­ron­ment Re­port (SER), pre­pared in col­lab­o­ra­tion with civic so­ci­ety or­gan­i­sa­tions, pri­vate in­di­vid­u­als, and em­ploy­ees of sev­er­al gov­ern­ment min­istries and agen­cies.

The SER fo­cused on the North­ern Range be­cause it is the source of 80 per cent of our drink­ing wa­ter. The SER not­ed that en­vi­ron­men­tal ef­fects of un­con­trolled quar­ry­ing were cre­at­ing "ma­jor prob­lems", that North­ern Range wa­ter­sheds were be­com­ing more de­grad­ed, and that there was "a de­clin­ing trend in fresh wa­ter qual­i­ty."Key among the SER's rec­om­men­da­tions were to give pri­or­i­ty to re­ha­bil­i­ta­tion and restora­tion and where pos­si­ble, to aban­don quar­ry sites to ar­rest ero­sion and run-off.

In stark con­trast to the SEIA, the EMA's 2004 SER sug­gest­ed that fur­ther quar­ry­ing in the North­ern Range be "dis­al­lowed" and if nec­es­sary, quar­ry ag­gre­gate was to be "im­port­ed." The SER al­so not­ed that the sit­u­a­tion in the North­ern Range could be helped if there was "a cham­pi­on of the is­sues at the po­lit­i­cal lev­el."We doubt that the cur­rent Min­is­ter of En­er­gy is the "cham­pi­on" we were wait­ing for.In the pub­lic in­ter­est, FFOS can find no good rea­son why the SEIA must be kept se­cret.

The na­tion's potable wa­ter, and the dan­gers of sil­ta­tion and flood­ing are not pri­vate, se­cre­tive mat­ters. In our re­spect­ful view a cost-ben­e­fit analy­sis, com­par­ing the cost of the im­por­ta­tion of ag­gre­gate ver­sus ex­pand­ing quar­ries in the North­ern Range, should be car­ried out be­fore the SEIA is fi­nalised or im­ple­ment­ed.

Based on the facts in hand, FFOS are op­posed to any "blan­ket" CECs be­ing is­sued. There is no sub­sti­tute for a trans­par­ent con­sul­ta­tive process where so­cial, en­vi­ron­men­tal and eco­nom­ic val­ues are con­sid­ered equal­ly.

The ab­sence of trans­paren­cy in con­duct­ing the SEIA is con­sis­tent with the Min­istry of En­er­gy's sup­port for un­reg­u­lat­ed seis­mic sur­veys, that is, with­out the con­duct of EIAs. The SEIA process ap­pears to be dri­ven sole­ly by big busi­ness in­ter­ests and is head­ed for a con­fronta­tion with the silent ma­jor­i­ty who val­ue potable fresh wa­ter over pri­vate short-term prof­it.

Gary Aboud, Sec­re­tary

Ter­rence bed­doe, Pres­i­dent

Fish­er­men and Friends of the Sea