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Letter of opposition to the application to remove a reef at Villa

Letter of opposition to the application to remove a reef at Villa
Ms. Louise Mitchell

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Ms Dornet Hull

Secretary to the Physical Planning and Development Board and Town Planner Physical Planning and Development Board


St. Vincent and the Grenadines


July 7th 2021


Dear Ms Hull,

Opposition to the Application by Raffique Dunbar to remove a reef at Villa

I write to express my strong objection to the Application published in the newspapers on July 2 2021, submitted by Mr Raffique Dunbar to remove a reef at Greathead Bay, Villa, supported by a document entitled “EIA, Prepared on behalf of SVRE Holdings Inc. for the La Vue Boutique Hotel and Beach Club Beach Restoration, “by Krystle Francis, Environmental Engineer.

While the advertisement stated that the relevant reef is located at Greathead Bay, all of the information on the application supports  the fact that the relevant reef  that the said Mr Dunbar wishes to remove is located in Indian Bay, directly in front of the building that was  formerly  called  the Grand View_ Grill and extending eastward  along that said beach. Accordingly, in the balance of this letter I shall refer to the beach as the Indian Bay beach and the reef as the Indian Bay Reef. In fact I have been advised that a correction  has been made to the title of the application  to: “For the removal of dead coral and replacement of artificial reef at Villa.”

The application seeks to do the following things:

  1. Extract a “dead/ dying” coral reef 350 feet along the coast and 50 – 60 feet outwards into the sea, a total area of 17,500 square feet
  2. The placement of a new artificial reef at about 100-150 feet from the shore (using concrete x blocks, the surface area of which will exceed that of the extracted coral)
  3. The placement of imported sand to increase beach width (“beach nourishment”)

Firstly I take issue with the labelling of the reef sections as “dead” in support of their removal by the developers. Obviously, a proper assessment of the reef must be conducted by a trained professional. Such an assessment would include, but not be limited to, the analysis and description of the reef sections in the entire area around the development and cannot be thought to be sufficiently accomplished by the incorporation of a few photographs taken from the beach.

The “EIA” done by Ms Francis considers the environmental impact during construction. No real attempt was made to model the ongoing impact of the development to the surrounding reefs once construction is complete and the 17500 sq ft area is being used as proposed.

The mitigating strategies suggested for the protection of the environment during construction are woefully inadequate and place all the responsibility on the as yet unnamed contractor. Specifically, the statement that the work would be paused upon the entrance into the work area of any “marine animal” is laughable. On this basis the work can never commence given the abundance of marine life in the stated area.

I oppose this application on the following grounds:

  1. The said area of the Indian Bay Reef is not dead. Evidence of the fact that it is very much alive is set out below.
  2. Living coral reefs provide spawning, nursery, refuge and feeding areas for a large variety of organisms, in short, they support biodiversity of sea life. They protect coastlines from storms and erosion (even more important with rising sea levels due to climate change) and offer opportunities for recreation (both for Vincentians and tourists alike). This coral reef protects the entire Indian Bay beach.
  3. The removal of the targeted area of coral reef will not only kill the reef being removed but will do severe damage to the surrounding coral reef and sea life.
  1. The placement of a new artificial reef at about 100-150 feet from the shore will disrupt the entire eco-system and flow of ocean currents in the area, causing unknown damage to the beach both nearby and further along the coastline.
  2. The placement of a new artificial reef (itself a misnomer), will be aesthetically unpleasing to the eyes and damaging to the souls like mine who go to Indian Bay to connect with our natural heritage.
  3. The placement of imported sand will destroy the natural habitat of the existing beach and disturb all of the organisms that live on the present beach.
  4. There is always also a risk that imported sand could contain undetected invasive organisms, a risk which cannot be 100% mitigated.
  5. There is a possibility that hawksbill turtles nest on the Indian Bay Beach and the imposition of new imported sand could be a threat to possible turtle nesting.
  6. The proposed overall effect of the removal of one section of the Indian Bay Reef, the placement of imported sand on one area of Indian Bay beach and the placement of concrete x blocks out to sea will create a SEPARATE AND DISTINCT LOOKING BEACH THAT WILL IN EFFECT OPERATE TO SEGREGATE THE LOCAL COMMUNITY FROM WHAT WOULD THEN APPEAR TO BE AN EXCLUSIVE SPACE OF THE HOTEL COMPOUND. Despite the absence of a physcial barrier wall, the changed look and feel of the beach will instill a feeling of separateness. I feel that this separation would serve to displace Vincentians from their natural heritage. This would create an effect similar to the segregation that happened at Buccama, which should not be repeated. The rights of Vincentians to beach access should be safeguarded.
  7. In the context of climate change risk mitigation, this type of destruction of nature’s natural barrier of protection of the beach and land is untenable.
  8. No proper Environmental Impact Assessment has been conducted. The “EIA” on file has no photographic or other proper descriptive evidence on the status of the coral reef. It contains only 3 sentences about the “coastal waters” which contain some falsities and demonstrate that the author of the “EIA” did not do any underwater collection of data.
  9. This area falls within the existing Conservation Area that was legally declared as such by virtue of The Eleventh Schedule of the Fisheries Act, Cap 59 of the Laws of St. Vincent and the Grenadines 2009 and is described in the said law as follows:


Saint Vincent

The south coast of Saint Vincent, including Indian Bay, Calliaqua Bay, and Blue Lagoon, between the latitudes 13°07.2′ N and 13°08’N and between longitudes 61 °11.9W’ and 61°13’W.


  1. To support this application is against Government policy. The Conservation Area has been earmarked by the National Parks Rivers and Beaches Authority to receive enhanced protection by its proposed declaration as a Marine Protected Area under the National Parks Act. In preparation for such declaration, near to half a million Eastern Caribbean Dollars has been invested in the preparation of such declaration, including the Management Plan, community consultations and baseline studies and the like. The area is now being zoned by the Fisheries Department in collaboration with National Parks for differing usage within the proposed marine park. The removal of live coral reef from this area is against this government policy of enhanced protection for this area, which was highlighted as a goal of the Government in the speech delivered by the Hon. Camillo Gonsalves at the launch of the SVG Conservation Fund at Paradise Beach Hotel on February 27th 2019.

I quote: ”We are a small country and every developmental decision that we make has an ecological implication. We have to try to develop this country while not make decisions like blowing a hole in the reef that make sense in the short term but has lasting environmental and ecological implications in the long term.” “This [south coast] is an area under threat… we are in crisis in terms of the protection of sanctity of our environment and our ecosystems.. We must realise that now is the time for urgent action.” I echo the sentiments of the Honourable Minister of Finance.

  1. The application runs contrary to UN Sustainable Development Goal No 14, Develop Life Below

Existing Sea Life at the Indian Bay Reef – all images below of coral reef are from the area proposed for Removal.

These photographs were taken by Nadia Huggins, in collaboration with Stephan Hornsey and myself who accompanied her around 3 pm on July 4th 2021. They were all taken within 30 feet of the shore line and directly in front of the former Grand View Grill.

ElkHorn Coral

Letter of opposition to the application to remove a reef at Villa
The Elkhorn coral can be seen directly in front of the Grand Vue development.

Elkhorn coral is listed as Critically Endangered by the International Union for the Conservation of Nature (IUCN 3.1), it is an important reef building coral in the Caribbean. It is becoming increasingly rare.

Letter of opposition to the application to remove a reef at Villa
Elkhorn Coral

It is present on the Indian Bay Reef.


Letter of opposition to the application to remove a reef at Villa
Brain Coral on Indian Bay Reef

Brain         coral is         a common         name given         to          various corals in the families Mussidae and Merulinidae,      so      called      due       to       their generally spheroid shape and grooved surface which resembles a brain. Each head of coral is formed by a colony of genetically identical polyps which secrete a hard skeleton of calcium carbonate; this makes them important coral reef builders like other stony corals in the order Scleractinia. Brain corals are found in shallow warm water coral reefs in all the world’s oceans. They are part of the phylum Cnidaria, in a class called Anthozoa or “flower animals”. The lifespan of the largest brain corals is 900 years. Colonies can grow as large as 1.8 m (6 ft) or more in height. This particular brain coral is home to many fish, including a juvenile parrot fish seen on July 4th 2021 during the site inspection.


Golfball coral

Letter of opposition to the application to remove a reef at Villa
Golf Ball coral at Indian Bay Beach

Favia jragum (Golfball Coral) is a species of cnidarians in the family Faviidae. They are listed in cites appendix ii. Golfball Coral form marine reefs. Dead Golfball Coral form shallow marine sediments.


Star Coral

Mountainous star coral is native to the Caribbean Sea and the Gulf of Mexico. Its color is usually pale brown but may be deep brown with fluorescent green highlights. Mountainous star coral is listed as threatened under the Endangered Species Act (USA law).

Letter of opposition to the application to remove a reef at Villa
Star Coral at Indian Bay Beach

NOAA Fisheries is committed to conserving and protecting mountainous star coral.

Protected Status. By the ESA it is listed as Threatened Throughout Its Range. By CITES Appendix II Throughout Its Range. By SPAW Annex II Throughout the Wider Caribbean Region.

SVG is party to CITES and the SPAW Protocol. CITES (the Convention on International Trade in Endangered Species of Wild Fauna and Flora) is an international agreement between governments. Its aim is to ensure that international trade in specimens of wild animals and plants does not threaten the survival of the species. SVG signed CITES in 1988. The Spaw Protocol of the Cartagena Convention, is another treaty which SVG signed onto in 1991. The Protocol for Specially Protected Areas and Wildlife-commonly referred to as the SPAW Protocol-is part of the Convention for the Protection and Development of the Marine Environment of the Wider Caribbean Region (the Cartagena Convention). Under the SPAW Protocol, nations in the wider Caribbean region work together to conserve and manage threatened and endangered species.

Fire Coral

Fire corals are listed on Appendix II of the Convention on International Trade in Endangered Species (CITES).

Letter of opposition to the application to remove a reef at Villa
Fire Coral at Indian Bay Beach

Fire corals (Miiiepora) are a genus of colonial marine organisms that exhibit physical characteristics similar to that of coral.

Sea Grass

A    vital    part    of    the    marine ecosystem due    to     their     productivity level, seagrasses provide food, habitat, and nursery areas for numerous vertebrate and invertebrate species. … Seagrasses perform numerous functions: Stabilizing the sea bottom.

Letter of opposition to the application to remove a reef at Villa
Sea Grass at Indian Bay Beach

Providing food and habitat for other marine organisms, in particular hawksbill and green sea turtles which are found in these waters on the South Coast. Sea grass also serves a role in improving water quality.



Artificial Reef?

Letter of opposition to the application to remove a reef at Villa
Artificial Reef

What will this “artificial reef’ look like, if constructed. It will look nothing like a reef. An example of a tetrapod where the concrete X es similar to that mentioned in the “EIA” is below. There will be nothing reef like about it.



For   all the  reasons outlined  above, I  request that planning permission  be denied  to the applicant. I trust that the Board will act swiftly to reject this application and in so doing save Vincentians the trauma of further loss of their natural heritage.

I personally invited the individuals behind this proposed scheme to instead invest in coral restoration. It is time for restoration of our coral reefs, not further destruction.


Yours truly

S Louise Mitchell

I endorse this letter

Nadia Huggins


CC: Ms Barbara Soso, Chairman of the Planning and Development Board

Mr Andrew Wilson, Executive Director, National Parks Rivers and Beaches Authority

Mr Gideon Nash, Chairman of National Parks Rivers and Beaches Authority

Hon.    Saboto    Caesar,    Minister    of    Agriculture,   Forestry,    Fisheries,    Rural Transformation, Labour and Industry

Hon. Carlos James, Minister of Tourism, Sustainable Development, Civil Aviation and Culture

Mr Anthony Theobalds, Chairperson SVG National Trust Hon. Prime Minister, Dr the Hon Ralph E Gonsalves

Mrs Janeel Miller- Findlay, Director, Sustainable Development Unit, Ministry of Tourism, Civil Aviation, Sustainable Development and Culture

Mr Michael John, Chairman SVG Conservation Fund