Letter to Physical Planning re: development plans to remove reef at Indian Bay

Ms. Dornet Hull Secretary Physical Planning and Development Board Kingstown St. Vincent

Re. Development Plans to Remove Reef at Indian Bay

Dear Madam Secretary,

In response to the Public Notice by the Physical Planning and Development Board published in the News Newspaper on July 2nd, 2021 (pg. 22) in respect of the proposal by one Rafique Dunbar on behalf of Syre Holdings Inc. – the owners of La Vue Boutique Hotel, [formerly]known as the Grand View Beach Hotel – “To remove Coral Reef at Great Head Bay”, I wish to first bring to your attention the fact that reference to the location of the development project is misleading as the application and its supporting documents and photographs clearly identifies the proposed development area to be located at Indian Bay Beach and not Great Head Bay as is intimated in the Public Notice. That noted, I am hereby registering my concerns to the proposed development project at Indian Bay, which seeks to (a) remove an area of dead coral along the beach front covering an area that is 350’ along the coast and 50’ to 60’ seaward, approximately 17,500 sq. ft. in size; (b) placement of an artificial reef at about 100’ to 150’ from the shore; and (c) placement of imported sand to increase the width of the beach in the demarcated area.

1. The Development area (Fig.1) is located within the confines of the South Coast Marine Conservation Area, which has legal instruments of marine protection established by the Fisheries Act of 1986 and of 1987 (Fig. 2). This marine protected area is located between Latitudes 13º 07.2’ N and 13º 08’ N and Longitudes 61º11.9’ W and 61º13’ W1. Marine Protected Areas are defined by the World Conservation Union (IUCN) as “parts of intertidal and subtidal environments together with their overlying waters, flora, fauna and other features, that have been reserved and protected by law and other effective means” (IUCN-WCPA, 2008).

1 Map of St. Vincent which details the location of the South Coast Marine Conservation Area. Sourced at: http://www.charim.net/sites/default/files/handbook/maps/SAINT_VICENT/SVG%20Topographic%20Map.pdf

2. The supporting document to the aforementioned Application, namely the Environmental Impact Assessment (EIA) is highly misleading, inaccurate, and lacking in substance. An Environmental Impact Assessment is “a tool used to identify the environmental, social and economic impacts of a project prior to decision-making. It aims to predict environmental impacts at an early stage in project planning and design…” (UNEP).

(i) While the EIA claims the reef to be dead, the document fails to produce scientific evidence to this effect and the author admits that no scientific evaluation of the reef and other marine life in the area has been conducted. Scientific evaluation of marine life is central to informing an Environmental Impact Assessment for a project of this nature. Contrary to statements made in the document – that “little flora and fauna”, a “handful of white sea eggs” and “lots of algae blooms” were observed – photographic evidence (Fig. 3) provided by Visual Artist and Photographer, Nadia Huggins, clearly indicates that the reef at Indian Bay.is very much alive and well (extracts of photo diary attached).

(ii) The EIA states that water quality testing was not done. Again, water quality testing results is an integral part of information gathering used to inform an EIA of this nature, since the quality and condition of the water is central to the existence of marine life in that it provides the environment in which reef and other marine animals can thrive. In terms of Environmental Management, water quality testing is an essential tool used to monitor and evaluate the health of the marine environment. The most recent results of water quality testing conducted at Indian Bay in 2014 actually showed better results than other parts of the South Coast Conservation Area where the density of tourism activity is much greater.

2 OAS (2014) South Coast Marine Park Project St. Vincent and the Grenadines, Final Report [pages 33&34]. Sourced at: http://www.oas.org/en/sedi/dsd/Biodiversity/ReefFix/SVG%20South%20Coast%20Final%20Report.pdf

(iii) No mention was made in the document that suggests consultations were ever held with the members of the Indian Bay/Villa community and/or users of the beach and marine area. Once more the EIA failed to address one of the most basic components to developing and informing an EIA relevant to the proposed development.

(iv) The document cites only one piece of legislation to be of relevance in consideration of this application – that being the Town and Country Planning Act of 1992 – when in fact there are several laws which govern the protection of the marine environment. The following are some other pieces of legislation which may apply to this application:

The Beach Protection Act, No. 10 of 198. Among its aims are to “protect the beaches and to prohibit the removal of sand, corals, stones, shingles and other material from the shores of St. Vincent and the Grenadines and sea beds adjoining.”

Wildlife Protection Act, No. 16 of 1987. The purpose of this act is “for the protection of wildlife and matters connected therewith and incidental thereto”. Section 1 of this act defines wildlife as “any species of mammals, birds and their eggs, frogs and their eggs, reptiles, fishes and their fry, and crustations”.

Fisheries Act, No. 8 of 1986 Established powers of governance over all fisheries, including regulations to protect endangered species, and the establishment of marine conservation areas.

Environmental Health Services Act, No. 14 of 1991. Under Section 3(1) of this Act, the Minister has responsibility to promote and protect public health by ensuring the conservation and maintenance of the environment. Section 3(2) elaborates further by stating that the Minister is specifically responsible for regulating, monitoring and controlling both the actual and likely contamination of the environment from any source.

3. Removal of coral along the Indian Bay Beach is in contravention of the Beach Protection Act cited above where it relates to removal of coral. It also goes against the grain of the intentions of the South Coast Marine Conservation Area to protect and conserve the marine environment in the area. Although the EIA does not indicate the method of extraction, removal of reef should never be an option given its contribution to ecosystem services and beach protection. Further, any such act of removal can be expected to generate a significant amount of sediment that will smother and destroy existing reef and create unfavourable conditions for other marine organisms located outside the development area.

4. The placement of an artificial reef at about 100’ to 150’ from the shore might seem like a plausible means of sea defence by abating wave action before it reaches the shore, however details of this operation are still very vague and environmental impact and mitigation measures are non-existent in the EIA document. Absent also are the relevant bathymeter surveys and drawings to show the placement of the proposed artificial reef.

5. Placement of imported sand to increase the width of the beach in the demarcated area is also likely to generate a significant amount of sediment that will most certainly smother and destroy existing reef, and create unfavourable conditions for marine life outside of the development area. Further, imported sand is likely to introduce species that can threaten the survival of indigenous species and cause disruption to the ecology of the area. Imported species when displaced from their origins tend to over proliferate since they are no longer controlled by natural predators that exist in their place of origin. This can present a serious threat to native species existing at Indian Bay and other areas of migration.

Indian Bay Beach and the surrounding marine environment is a public space that is of great natural and recreational value to the nearby communities, visitors to the area, and the Vincentian population in general. It forms part of an important economic zone due to its aesthetic attributes and contribution to the Tourism Industry, to both local operators and to the nation. It contributes significantly to the health and wellbeing of the local community and visitors alike and enhances the quality of life for many Vincentians. It is also an important contributor to fisheries in the area.

In view of the foregoing, I would strongly recommend that the Board disqualify the existing Environmental Impact Assessment that is currently on file, and to consider instead adopting the photographic material and data provided by Nadia Huggins as supporting evidence of the condition of the reef and marine life in the area. Ms. Huggins is a highly credible individual who has been interacting with this area throughout her childhood and over her career as a visual artist and photographer. The Indian Bay marine environment has been the subject of a great deal of her visual art and photography that has achieved much acclaim regionally and internationally. Alternatively, the Board can seek to be provided with an EIA developed and prepared by a reputable environmental agency.

Consideration must also be given to maintaining and improving the integrity of the reef and beach in keeping with our nation’s commitment to mitigating the impacts of climate change and preserving the environmental integrity of the area. This, along with the special status as a conservation area is enough reason to reject this application. No entity should be allowed to embark upon such an invasive and intrusive development so as to cause damage to the reef and disrupt thriving marine ecosystems that exist there, hence I strenuously oppose any such development.

I would further recommend that the developers be restricted to approved development within the confines of their property boundaries, and that measures are taken to ensure proper filtration of sewerage and grey water from their business establishment to prevent further contamination of the surrounding marine environment. They should also be guided in terms of maintaining high standards of corporate responsibility and respect for the community and environment they are now a part of.
I remain. Sincerely yours,

G. Marlon Mills

Figure 1 – Nadia Huggins. Illustration of the development area.
Figure 2 – Department of Fisheries, St. Vincent and the Grenadines. Marine Conservation Areas
Figure 3(a) Nadia Huggins, photo diary. Reef at Indian Bay
Figure 3(b) Nadia Huggins, photo diary. Reef at Indian Bay
Figure 3(c) Nadia Huggins, photo diary. Reef at Indian Bay
Figure 3(d) Nadia Huggins, photo diary. Reef at Indian Bay
Figure 3(e) Nadia Huggins, photo diary. Reef at Indian Bay
Figure 3(f) Nadia Huggins, photo diary. Reef at Indian Bay
Figure 3(g) Nadia Huggins, photo diary. Reef at Indian Bay
Figure 3(h) Nadia Huggins, photo diary. Reef at Indian Bay