Environmental due diligence

By Peter Espeut

Speaking at a Jamaica House press conference on September 11, 2013, Transport Minister Dr Omar Davies told journalists that the scoping study by Conrad Douglas & Associates (CD&A) would be used to inform how the Port Authority and the Chinese investors would proceed on the logistics hub project. The Gleaner reports: "He says a Cabinet decision will be made shortly after the completion of the study on the use of the Goat Islands".

To take such a decision based on the results of the scoping study completed last month would be a mistake of immense proportions!

Even before the Table of Contents page, CD&A lodge a caveat on their own report: "This scoping project is not an Environmental Impact Assessment (EIA) nor an Environmental Impact Statement (EIS)".

Speaking at a symposium put on by the University of the West Indies and the Caribbean Maritime Institute last Saturday (November 9) 'The Logistics Hub: The Economy vs The Environment', Conrad Douglas himself, in no way hostile to the Government, said that, since the design and the intended plan for the islands have not yet been presented, assessments about the environmental impact were useless at this time.

The Gleaner of November 11 quotes Douglas: "Because you don't know the horizontal and vertical profile of the project; because you don't know what the project entails and where it will be, you cannot proceed to make statements about the environmental impact". Douglas noted that a comprehensive environmental impact assessment must be done on the Goat Islands to determine its suitability.

If Cabinet uses the CD&A scoping study to take a decision on the use of the Goat Islands, it would have done so in ignorance of the possible negative impacts of the hub on the sensitive environment. And this out of the mouth of Conrad Douglas himself! It would be grossly irresponsible of the Cabinet to take such a decision before the results of the EIA are known.

CD&A report

But I go further. CD&A highlight a second caveat on their own report: "In preparing this report CD&A did not see any plans nor (sic) designs for the Transshipment Port and Logistics Hub under discussion" (page 3). Yet, one of the stated outputs of the study is, "Preparation of a Proposed Draft Terms of Reference for conducting an Environmental Impact Assessment" (page 1). I put it to you that, since CD&A have not seen any plans or designs for the logistics hub, they are not even in a position to prepare draft terms of reference for conducting an EIA!

In his statement to Parliament on Tuesday, September 10, 2013, Davies advised the country that, "The Cabinet on April 21, 2013 approved an addendum to the existing MOU to allow the investors to undertake the necessary feasibility studies/due diligence of the project to facilitate the refinement of a final proposal that would be submitted to the Government of Jamaica. The period of assessment is one year and is expected to be completed by the end of April 2014".

This clearly states that not even the Government of Jamaica has seen the final plans/designs for the logistics hub, and therefore, the Cabinet is in no position to take any decision on whether the Goat Islands within the Portland Bight Protected Area are a suitable location or even the best location for what the Chinese will propose.

Terms of reference

The appropriate time to prepare the terms of reference for conducting the EIA is May 2014. A proper EIA should take one year, so that the earliest the Cabinet would be able to take a decision would be June 2015.

There is a heresy often heard: that the approval of project proposals should be quick, and that project turn-around time should be no more than three months. To be done correctly, assessments of environmental and archaeological impact take time. Advocates of hurry-up development in both the government and the private sector are not advocates for sustainable development. When Jamaica signed on to the Rio Declaration in 1992, we undertook to conduct education for both the Government and the private sector in sustainable development. We have clearly failed!

Speaking to a huge gathering of business interests at the Economic Reform Programme Stakeholders Conference at the Jamaica Conference Centre on September 12, 2013, Prime Minister Simpson Miller jousted with windmills: "If we were not strong and took the right position, we would never have had the Norman Manley International Airport or the Sangster International Airport, Newport West, the National Stadium or a number of housing schemes". Palisadoes Airport in 1937, and the Chatham Airfield in MoBay in 1945, were both built as military airfields before she was born. And I am not sure residents of the flood-prone Nightingale Grove and Kennedy Grove appreciate the strength of the Government in pushing through their housing schemes without proper environmental due diligence.

Peter Espeut is a sociologist and an environmentalist. Email feedback to columns@gleanerjm.com.