Mr. Luther Rennie
Sandy Island Oyster Bed Marine Protected Area
October 27th, 2013
Dear Mr. Rennie,
Re Sundays with George Grant, October 27th, : Tyrell Bay Marina Development
Greetings from Citizens in Defence of Grenada’s Lands and Heritage! We write to you as citizens who take a keen interest in and advocate on issues of national governance, sustainable development and environmental protection.
Today, we had the opportunity to listen to the above-referenced programme aired live from Hillsborough, Carriacou. Of particular interest was the discussion which featured yourself and Mr. Orlon Jules of the Mangrove Oyster Bed Protection Community. What a pity that the representatives of the government and of the developers did not avail themselves of the opportunity for public engagement on this project!
It was noted, Mr. Rennie, that you introduced yourself as neither a representative of the government nor of the developer. While you may not have represented either the government or the developer, you are the Chairperson of the Management Committee of the Sandy Island Oyster Bay Marine Protected Area. So your contribution to the discussion on the controversial marina development would be very significant.
We understood you to say the following:
The marina project was intended to boost the economy and address problems of high unemployment.
You have engaged the developers – you have preliminary questions(??) and they have promised to mitigate the damage.
One has to judge whether or not there is significant damage.
Local people are not innocent. They are polluting the oyster bed area. They are also cutting down trees to make fish pots.
The developers have given assurances: – they have promised to do training for at risk persons and there will be jobs.
The developers have already spent $5million on the marina.
Both the marina and the oyster bed can exist.
The developer had already demonstrated good corporate citizenship by the removal of wreck.
The marina represents less than ½ of one (1) percent of the MPA.
Mr. Orlon Jules’ principal concerns were:
the impact on the livelihoods of fishermen and other community persons of the removal of the mangroves and the dredging on the area and the decline in fish stock and oysters – the fish stock was reduced and he claimed that 99 percent of the oyster population had been destroyed.
Mitigation measures, e.g. silt traps, were not being used in the dredging as evidenced by the heavy silt plumes in the area.
The lack of response from government to come to the table and discuss with the concerns of the community.
Information on the Environmental Impact Assessment and Environmental Management Plan was unavailable.
Community persons were threatened with fines for fishing in the MPA while it was being destroyed by a developer.
The developer was also encroaching on privately owned lands in the SIOBMPA.
In response to Mr. Jules’ concerns:-
You suggested that Mr. Jules was speaking from his head and that he lacked scientific data and facts and figures to support his concerns.
You recommended a marriage of the marina and the oyster beds.
You advised that the developer had promised to be on radio next week to inform the community about the marina development.
Mr. Rennie, given that you are the Chairman of the Management Committee of the Sandy Island Oyster Bed MPA, your response was somewhat baffling.
Not once did you appear to represent the interests of the Sandy Island Oyster Bed MPA.
Rather than acknowledging the concerns of Mr. Jules re the impact of the removal of mangroves and the dredging, you appeared to sneer at his concerns with your requests for scientific data/ facts and figures and information about the contribution of the oyster beds to the Gross Domestic Product of Carriacou.
Permit us the following comments and observations:-
Rationale for MPAs:
*Protecting Species and Livelihoods: As Chairman of the Management Committee of the SIOBMPA, you ought to be aware, Mr. Rennie, that the primary reason for creating MPAs is to protect species and protect the livelihoods of the persons and communities that depend on those species for a livelihood. A resource may contribute to subsistence.
You also ought to know that a resource’s contribution to livelihoods may not necessarily be reflected in the GDP. This does not make it any less important. It contributes to the resilience and coping strategies of the community and users. And it is the duty of the Management Committee to ensure that this is understood and appreciated by all and sundry.
*Unique Ecosystems: MPAs are also created to protect unique ecosystems as part of the heritage of a country. And in this regard, the Oyster Bed is unique. It is one of two such ecosystems in the region. So the Oyster Bed is part of the unique natural heritage of Carriacou.
Co-management: The fact that there is a management committee of which you are Chair suggests that in the creation of the MPA the principle of co-management was taken on board. The management was not only restricted to government officers and technical persons.
*Respect for Local Knowledge: The principle of co-management acknowledges that the users and community have valuable local knowledge and have a part to play in the management of the resource. One does not have to be a scientist to note plumes and turbidity and to know that this is inimical to fish life and to the reefs in the area.
Mr. Jules shared his observations and knowledge as the fifth generation of fisherfolk who have made a living from the resources of the Mangrove and Oyster Bed. But Mr. Jules is not just a fisherman. He is a qualified and experienced civil engineer who has served in Grenada and abroad. He would have written the TORs for many EIAs or reviewed several during the course of his work.
Mitigation Measures: As Chairman of the SIOBMPA, you have a REGULATORY function re the protection of the MPA. How can the developers be operating without mitigation measures and your committee accepts that they “have promised to mitigate”? What are YOU, who apparently appreciates “scientific data” doing about “judging whether or not there is any significant damage”?
What has promises “to train” and “removal of a wreck” got to do with it: Mr. Rennie, you sought to deflect Mr. Jules’ concern re the destruction of mangroves on privately owned lands by suggesting that Mr. Jules should not mix legal issues and degradation of the mangroves. Permit us to observe Mr. Rennie that the same could be said to you – why are you confounding the concerns of the destruction of livelihoods by removal of the mangrove and the dredging with promises “to train” and “removal of a wreck”?
Environmental Impact Assessment:
Mr. Rennie you wrapped up the discussion by categorically recommending a “marriage of the marina and oyster bed”. On what SCIENTIFIC BASIS are you making such a recommendation? What has been the source of your scientific facts and figures that informs this recommendation? Do you have access to the Environmental Impact Assessment?
Approval of Project: Can you comment on the approval process for this project Mr. Rennie? Was this project ever approved and if yes, by whom? Was it approved by the Physical Planning Unit/Land Development Control Authority?
On today’s programme, while you did indicate that you were neither representing the government or the developer, most persons listening would have concluded that the developer’s interests were well represented by you. This therefore leads to the question – whose interests do you represent on the SIOBMPA? Are you representing an organisation called the Carriacou Environmental Committee?
Carriacou Environmental Committee:
It is interesting that the EIA of April 2002, makes the following reference to the Carriacou Environmental Committee:-
“The developers have agreed to enter into an MOU with the Carriacou Environmental Committee so they can be part of an ongoing monitoring process. We believe this to be important as the marina is within an area designated by government as a marine park.”
“…An office will be set aside in the facility to be used by the Carricou Environmental Committee to monitor and organise tours of the lagoon and adjacent protected marinas”
Does the Carriacou Environmental Committee have any arrangements with the developer? If you are representing the Carriacou Environmental Committee, then it is reasonable to ask whether or not there is a conflict of interests between the public interest as Chair of the SIOBMPA and the interests of the Carriacou Environmental Committee?
Thank you for the opportunity to offer these comments and queries on your contribution the SWGG programme today.