Supplemental EIA for Invaders Bay
c/o #34 Frederick Street, Port of Spain, Trinidad, West Indies Tel (868) 674-7911. Fax: (868) 355-7671. Cell: (868) 355-7671 Email: [email protected]
Supplemental EIA for Invaders Bay
Date: August 27th, 2019
Fishermen and Friends of the Sea (FFOS) have always been transparent in our correspondence with Government officials.
In light of increasing flood events in South Western Woodbrook, please find attached an open letter to the Honourable Minister of Planning and Development, Camille Robinson Regis requesting documented investigations by way of a supplemental Environmental Impact Assessment (EIA) to be conducted at Invaders Bay.
Sincerely, Gary Aboud Corporate Secretary
Fishermen and Friends of the Sea (FFOS) c/o #34 Frederick Street, Port of Spain, Trinidad and Tobago. 22nd August 2019
The Honourable Camille Robinson-Regis, MP Minister of Planning and Development Level 14 Eric Williams Financial Complex, Independence Square, Port of Spain.
Dear Minister Regis,
Re: Documented investigations by way of a “supplemental Environmental Impact Assessment (EIA)”
Since the removal of the Invaders Bay mangrove forest, every year south western Woodbrook has been plagued by flash flooding. On 21st August 2019, areas of Woodbrook South have once again flooded. We had forecasted this unprecedented event when in 1999, the mangrove forests at Invaders Bay were being bulldozed without the safe guards or considered mitigation of an Environmental Impact Assessment (EIA) summarized as the ‘long hard look’ of the Certificate of Environmental Clearance (CEC) process.
Given that this mangrove destruction was executed prior to passing of the Environmental Management Act in 2000, we respectfully appeal to your good office to call on the Environmental Management Authority (EMA) to require that high environmentally impacting projects which were approved prior to the CEC Rules being passed, and which have not yet been completed, or which additional phases have not commenced, such as this Invaders Bay should be required to conduct official documented investigation by way mof a supplemental EIA, to determine and mitigate the impact of further clearing and development.
We respectfully submit that had a proper EIA been conducted, the function of the mangrove forest and its role in curbing flooding in our Capital City would have been deliberated. Better valuations of the protective services of these coastal habitats would have ensured that they are recognized and when built development is considered, it would have acknowledged and mitigated risks to public safety. It is within the scope of the Government of the Republic of Trinidad and Tobago (GORTT) to adhere to all laws of our country. Despite the “No Net Loss” mangrove policy enshrined in our National Environmental Policy (NEP), which has a force of Law, our mangroves continue to be destroyed by legal and illegal, unregulated, unapproved built structures, in part because the economic value of their benefits and services is not appreciated or measured, nor is its importance synchronized with competing activities of private enterprises or Governmental ministries and agencies.
A 2017 study released by the Wealth Accounting and the Valuation of Ecosystem Services (WAVES) and led by the World Bank “quantitatively values the benefits provided by mangroves across the Philippines and finds that they reduce the damage from flooding to people and property by 25 percent annually”. Despite repetitive scientific assertions, wetlands and mangroves are not fully accounted for in public administration and management decisions and we humbly request that it should.
In early 2018 acclaimed engineering seismologist Dr. Illias Papadopoulos expressed his concerns that “Port of Spain is in grave danger”…..tall buildings can be “swallowed up into the ground”, simply “sinking” and “the land would move like water in the event of a major earthquake in a process called liquefaction”. This is one of the reasons why in 2000 FFOS campaigned on the consequences of bulldozing the Invaders Bay mangrove forest, including the human fatality risks of liquefaction and flooding.
In 2018, despite seismological warnings of quake disasters and obvious flash flooding, Urban Development Corporation of Trinidad and Tobago, (UDeCoTT) was gallantly inviting “expressions of interest” for development of 30.5 hectares of lands at Invaders Bay.
As we move towards built development, very little is being done or investigated to prevent or minimize the risks of liquefaction which Dr. Illias Papadopoulos has repeatedly warned us about. We are sure than any right-thinking person would agree that planning and development of the Invaders Bay has not taken into consideration the major environmental risks and impacts. If an Invaders Bay high rise sinks with fatalities who will be held accountable? We write to you with a great sense of urgency and concern.
We respectfully remind your good office of the myriad of ecosystem values and functions mangrove have in terms of coastline protection, adsorption of pollution, protection to inland coastal communities, reduction of damage to coastal infrastructure and its critical role in coastal stability, spawning and species survival. For a city that suffers from severe flash flooding, has decimated so much of its marine habitat, and where the average person in our capital has few windows to even see the sea, we appeal to your good office to consider saving the last small piece of standing and pristine mangrove, and if it must be removed, it should be done under the watchful guidance of science aptly described as the long hard look of the EIA.
We respectfully request a reply in writing within ten working days.
We Remain, Respectfully and Sincerely, In Sustainable and Inclusionary Development,
Gary Aboud Corporate Secretary