KINGSTON, Jamaica — Environment watchdog group Jamaica Environment Trust (JET) has penned an “open letter” to Minister of Transport and Works, Dr Omar Davies, posing numerous questions regarding Government’s decision to allow the construction of a deep water pier and other block-and-steel development in the Portland Bight Protected Area.

JET’s unedited letter to Davies:

Dear Minister Davies,

We have read your statement to Parliament on February 25, 2014 on the proposal for China Harbour Engineering Company (CHEC) to construct a port and industrial park in the Portland Bight Protected Area, in the vicinity of the Goat Islands.  We have the following questions and observations:

 1) The Jamaican public still does not know what due diligence was done to select this site, what other sites were considered and the reasons for rejection.  Since this project was first announced in August 2013, various experts, including, a past President of the Jamaica Institute of Engineers have called into question the suitability of this location and suggested alternative sites. Has the Government asked CHEC to consider other sites for the proposed port? Is it that CHEC is only interested in the Goat Islands for the construction of the port?  

2) There has still been no response from the Government of Jamaica (GOJ) to the errors contained in the Environmental Management Scoping Study (EMSR), which were identified in November 2013 by eight agencies and two scientists from the University of the West Indies.  It appears that despite these errors, you continue to rely on this flawed study.  In brief the errors and omissions of the EMSR were – cursory literature review, scant field observations, inadequate consultation with critical stakeholders, inaccuracies in descriptions of the rare, threatened and endangered species, a too narrow concentration on the Goat Islands themselves (we now know that a large proportion of this development will be on the mainland, so this omission is especially serious) and proposal of mitigation measures that are not feasible.  

3) The details of the project as laid out in your presentation confirm the environmentally devastating nature of this port for the coast of a protected area, including the construction of a coal fired coal plant.  The serious public health impacts of coal as a source of energy are extremely well documented.  It is ironic that the GOJ would consider this in view of its emphasis on the threat presented to Jamaica by climate change and its establishment of a Ministry of Climate Change.

4)  We note the emphasis on the Environmental Impact Assessment (EIA) process, but much is going to depend on the quality of the EIA, the amount of time that is allowed for this to be properly done, and in the event of approval, the resources and political will to monitor and enforce permit conditions.  The issues of alternatives and cumulative impacts are generally weak in Jamaican EIAs and it is these issues which are of critical importance in this case. 

5) Despite your assurances to the contrary, public consultation and transparency remain inadequate.  The Government has denied all of the requests that the Jamaica Environment Trust (JET) has made under the Access to Information Act. To be more specific, our request for the Memorandum of Understanding (MOU) between the Port Authority and CHEC and the proposals and draft agreement proposed by CHEC have been exempted from disclosure on the grounds that the logistics hub initiative is a central plank to Jamaica’s growth strategy and that the Government’s growth strategy influences the monetary policy. In your previous statement to Parliament on September 10, 2013 you stated, “We invite those who have already taken a position in opposition to the project to place in the public domain some alternatives which would simultaneously protect the natural environment and assist the population.”  The documents denied to us likely contain information that would allow us and other interested stakeholders to propose suitable alternatives to Goat Islands.

6)  You state that you have met with all the environmental protection agencies. We do not know to which agencies you refer. You have not included JET in these consultations.  In addition we can say with certainty that the communities in proximity to the Old Harbour and Goat Islands aspects of this project are still clamouring for more detailed information.  

7)  The net benefits to Jamaica of this project remain poorly articulated.  If we are going to destroy a significant natural area protected under four different Jamaican laws and two international conventions, it should not be for crumbs.

8)  We note the existence of an Initial Framework Agreement (IFA) between CHEC and the GOJ and, notwithstanding the response that we received from the Port Authority to our request for a copy of the MOU, we will be requesting a copy of the IFA under the Access to Information Act in the usual manner.

 We remain committed to economic development for all Jamaicans that is both equitable and sustainable.