Stephon Nicholas

To­ba­go Cor­re­spon­dent

Less than two months be­fore the En­vi­ron­men­tal Man­age­ment Au­thor­i­ty (EMA) grant­ed a Cer­tifi­cate of En­vi­ron­men­tal Clear­ance (CEC) to Su­pe­ri­or Ho­tels Ltd for a ma­jor project at Rocky Point, To­ba­go, two ex­perts con­sult­ed by the EMA deemed the 200-room ho­tel and re­sort “fun­da­men­tal­ly in­com­pat­i­ble” with the site.

Ma­rine sci­en­tist Dr An­jani Ganase, writ­ing on be­half of the In­sti­tute of Ma­rine Af­fairs (IMA), rec­om­mend­ed a re­jec­tion of the ap­pli­ca­tion, while Dr Michelle Caz­abon-Man­nette, tech­ni­cal ad­vi­sor at Save our Sea (SOS) Tur­tles To­ba­go, ad­vised the EMA to con­sid­er re­fus­ing the CEC based on the sig­nif­i­cant vul­ner­a­bil­i­ty of the area.

Their com­ments fol­lowed a com­pre­hen­sive re­view of the re­vised en­vi­ron­men­tal im­pact as­sess­ment (EIA) and re­spons­es to the Re­view and As­sess­ment Re­port (RAR).

The con­cerns of the IMA and SOS mir­ror that of the Rocky Point Foun­da­tion, who were al­so among the stake­hold­ers con­sult­ed by the EMA.

On May 1, the EMA an­nounced it had giv­en the green light for the Mar­riott-brand­ed de­vel­op­ment, which in­cludes bun­ga­lows and pri­vate res­i­dences, on 11.99 hectares.

How­ev­er, Rocky Point Foun­da­tion founder Du­ane Ken­ny has ex­pressed dis­ap­point­ment with the EMA’s de­ci­sion, ar­gu­ing in a May 11 Guardian Me­dia re­port that the terms of the CEC are not strin­gent enough to ad­e­quate­ly pro­tect an al­ready frag­ile reef and ecosys­tem. Ken­ny said he was par­tic­u­lar­ly con­cerned about the runoff from a project of this scale and al­so the im­pact on the tur­tles nest­ing there.

He added, “That lo­ca­tion is one of the gems of To­ba­go...we find that is way too much con­crete for that site.” 

In a me­dia re­lease the same day, the EMA de­fend­ed it­self, say­ing it con­duct­ed “an ex­ten­sive, sci­ence-dri­ven re­view process” be­fore is­su­ing the CEC. It said the process in­clud­ed tech­ni­cal as­sess­ments, stake­hold­er in­put and con­sul­ta­tions with mul­ti­ple agen­cies, ex­am­in­ing fac­tors such as ma­rine ecol­o­gy, drainage, cli­mate re­silience and so­cio-eco­nom­ic im­pact.

The au­thor­i­ty said it al­so strength­ened sev­er­al mea­sures be­yond those pro­posed in the En­vi­ron­men­tal Im­pact As­sess­ment.

The EMA em­pha­sised that ap­proval was on­ly the first step in the process, not­ing that on­go­ing mon­i­tor­ing, re­port­ing and en­force­ment mea­sures will be put in place to en­sure com­pli­ance.

It main­tains the project bal­ances en­vi­ron­men­tal pro­tec­tion with sus­tain­able de­vel­op­ment and says it re­mains open to pub­lic en­gage­ment on the mat­ter.

How­ev­er, Guardian Me­dia re­ceived copies of var­i­ous sub­mis­sions to the EMA’s CEC Unit where sev­er­al red flags were raised.

Ganase, a reef ecol­o­gist with the IMA, said the ap­pli­cant has “con­sis­tent­ly re­fused to ad­just the project’s scale, de­sign, or mit­i­ga­tion strate­gies, demon­strat­ing a pro­found lack of un­der­stand­ing re­gard­ing the sever­i­ty of the im­pacts on the sen­si­tive ma­rine en­vi­ron­ment.”

Var­i­ous stake­hold­ers told the EMA that the ap­pli­cant showed no jus­ti­fi­ca­tion for a de­vel­op­ment of that mag­ni­tude oth­er than the deed of lease, adding that green­er, low­er-im­pact al­ter­na­tives were not be­ing con­sid­ered.

Ganase added that Su­pe­ri­or Ho­tels “fails to recog­nise the ex­ist­ing poli­cies, in­ter­na­tion­al con­ven­tions and best prac­tices to guide the way for­ward for sus­tain­able de­vel­op­ment that con­sid­ers life be­low wa­ter (a Unit­ed Na­tions sus­tain­able de­vel­op­ment goal).”

She said her po­si­tion was sup­port­ed by over 50 years of sci­en­tif­ic re­search which show that large-scale coastal con­struc­tion leads to habi­tat de­struc­tion, bio­di­ver­si­ty loss, sed­i­men­ta­tion and nu­tri­ent-dri­ven reef col­lapse.

Ad­dress­ing the specifics, the IMA said the project lacks sci­ence to sup­port cur­rent de­sign and mit­i­ga­tion strate­gies. It said the im­pact of stormwa­ter dis­charge and sur­face runoff di­rect­ly on to the reef and the vicin­i­ty of the nest­ing beach re­mains un­ad­dressed. 

“The EMA re­quires the use of mod­els and sci­en­tif­ic sup­port­ing in­for­ma­tion to prove that run off/dis­charge will not im­pact the ma­rine en­vi­ron­ment, but the ap­pli­cant does not pro­vide any hy­dro­dy­nam­ic mod­el/ sed­i­ment plume mod­el that con­sid­ers peak flow, sea­son­al­i­ty nor eco­log­i­cal sen­si­tiv­i­ty.”

In­stead, Ganase said Su­pe­ri­or Ho­tels pro­vid­ed “ar­bi­trary di­lu­tion rates, but no quan­ti­ta­tive in­for­ma­tion” to in­form mod­el out­puts.

The IMA al­so crit­i­cised some of the mit­i­ga­tion meth­ods which made its way in­to the CEC. On the pro­vi­sion to halt earth­works dur­ing in­tense rain­fall to pre­vent de­bris flow­ing in­to the sea, the IMA said this was re­ac­tive and im­prac­ti­cal, and does noth­ing to sta­bilise ex­posed sed­i­ment. 

The IMA said the cu­mu­la­tive im­pact of stres­sors was al­so be­ing ig­nored, as the reef ecosys­tem is al­ready weak­ened by ma­rine heat­wave. It said the ecosys­tems will have a re­duced ca­pac­i­ty to as­sim­i­late to ad­di­tion­al is­sue re­lat­ed to ho­tel con­struc­tion, and reef degra­da­tion is a re­al pos­si­bil­i­ty.

The IMA al­so com­plained about non-com­pli­ance and with­hold­ing of crit­i­cal in­for­ma­tion by the ap­pli­cant, not­ing this af­fects the EMA be­ing able to scop­ing works fea­si­bly.

Save our Sea Tur­tles: CEC grant­ed quick­ly

Mean­while, Caz­abon-Man­nette told Guardian Me­dia she was sur­prised the CEC ap­proval came so soon.

Caz­abon-Man­nette, who holds a PhD in En­vi­ron­men­tal Bi­ol­o­gy, has worked in EIA prac­tice lo­cal­ly for the last 15 years.

She said, “What re­al­ly sur­prised me was how quick­ly it was grant­ed with no fol­low-up to that first RAR.”

Caz­abon-Man­nette said for ma­jor projects over the last few years, the EMA held sev­er­al rounds of re­view and pushed the ap­pli­cant for more in­for­ma­tion.

“For the Cu­mu­to High­way sec­ond phase, they re­quired quite ex­ten­sive flood­ing mod­el­ling, be­cause that was a ma­jor con­cern that was raised — but this sen­si­tive site you ac­cept­ing no mod­el­ling.”

How­ev­er, Caz­abon-Man­nette said she was pleased that the EMA did not ac­cept the pro­posed 3.5-me­tre coastal set­back for the project, in­stead en­forc­ing a 30-me­tre set­back in the CEC.

Still, she said the terms of the CEC did not meet the stan­dard re­quired to mit­i­gate the po­ten­tial en­vi­ron­men­tal harm.

“I feel like the de­ci­sion was not ful­ly sci­ence-based. It could be said they ig­nored the sci­en­tists who were part of their com­mit­tee and they did not ask for more sci­ence. They ac­cept­ed very vague in­for­ma­tion from the ap­pli­cant.”

SOS said the project is al­so not in line with the To­ba­go Tourism Agency’s “un­spoilt, un­touched, undis­cov­ered” slo­gan.

Caz­abon-Man­nette said she planned to write To­ba­go House of As­sem­b­ley Chief Sec­re­tary Far­ley Au­gus­tine to in­form him of her con­cerns.

At a me­dia con­fer­ence on Thurs­day, Au­gus­tine said he would sup­port the de­vel­op­ment once four con­di­tions are met: THA in­volve­ment, en­vi­ron­men­tal­ly safe, preser­va­tion of his­tor­i­cal as­pects of the site, and pub­lic ac­cess to the beach.

He said if there is ev­i­dence the de­vel­op­er is not ad­her­ing to these con­di­tions then his of­fice should be con­tact­ed im­me­di­ate­ly.