UPDATE!!!!!!!!!!!!!!!!!!!

27 June 2007:  A phone call was received today from an independent contractor employed by Ara Macao asking (demanding?) that the historical information on this Website about Ara Macao be taken down because it is "misleading and inflammatory."  I have reviewed the information presented here, and all of it reports events as they occurred during the Ara Macao EIA approval process.  This entire process was a very significant one for the Placencia Peninsula and surrounding areas.  It occupied public debate for over an entire year, it brought Peninsula communities and people together, and ultimately has made everyone on the Peninsula much more aware of environmental and development issues.  It also raised issues that continue to need to be answered, such as the capacity and recharge rate of the aquifer that provides water to the people of the Peninsula.  For these reasons alone, the information provided here is important for the Peninsula, historically, environmentally, sociologically and economically. 

1 June 2007:  Justice Awich of the Belize Supreme Court denied PCSD's application to proceed with judicial review of the approval of Ara Macao by the Belize Department of the Environment.  Justice Awich also assessed legal costs against PCSD.  PCSD did not have the funds to appeal Justice Awich's ruling, although PCSD does believe that Justice Awich's ruling was in error.  A copy of the judicial decision will be made available when a digital copy can be obtained.

2 April 2007:  On Monday, 2 April 2007, the Peninsula Citizens for Sustainable Development (PCSD) filed a lawsuit asking the Belize Supreme Court to overturn the decision of the Belize Department of the Environment (DOE) approving the Ara Macao Resort and Marina development at the northern end of the Placencia Peninsula. PCSD also asked the court to grant an injunction to prevent Ara Macao Development Ltd. from proceeding with the development.

PCSD’s suit is based, in part, on DOE’s failure to comply with Belize’s environmental regulations.

PCSD also maintains that DOE unreasonably and irrationally approved the development because it did not have critical information about environmental issues such as downstream beach erosion, effect of the development on the Peninsula’s marine environment (such as lobster, conch and coral reefs), and whether Ara Macao and other new developments could quickly use up the water supply that provides Placencia, Seine Bight, Maya Beach, Independence and Big Creek with drinking water.

PCSD also argues that DOE’s approval failed to protect the public’s access and use of the 66’ public reserve on the beach surrounding the development, and that the development violates zoning for the area under the Mango Creek/Placencia Special Development Area, as recognized by Belize law.

A court date has been set for 20 April 2007 for judicial consideration of PCSD’s claim.

Donations to the Ara Macao litigation fund may be made by depositing funds into the PCSD account at Atlantic Bank, account number 100158838.

Donations may also be made by check made payable to the Peninsula Citizens for Sustainable Development, General Delivery, Placencia, Belize.

Money may also be wire transferred to PCSD, using the following wiring instructions:

Bank of New York
36-63 Main Street
New York, New York 11354
ABA#: 021000018

For credit to Atlantic Bank
Swift Code: IRVTUS3N
Atlantic Bank Account No: 8900545925

For further credit to
Peninsula Citizens for Sustainable Development, Atlantic Bank Account no. 100158838

Please note that if wiring from the US, this is NOT an international wire.  The funds are wired to Bank of New York which, in turn, transfers them to PCSD in Placencia.

The Peninsula Citizens for Sustainable Development is a Belize non-profit corporation and grass roots community organization of Placencia Peninsula residents concerned with the rapid, and often poorly planned and executed, development of the Peninsula. PCSD seeks to bring information about proposed developments to Peninsula residents to ensure that all developments are environmentally sustainable with respect to the fragile eco-systems of the Peninsula and its communities and cultures.

Please contact PCSD at 610-4718 or info@placenciadocuments.info for further information.

Peninsula Citizens for
Sustainable Development
Placencia, Belize

To:     Belize Department of the Environment
          Belize National Environmental Advisory Committee

Re:     Proposed Ara Macao Development, South Stann Creek, Belize

Date: 3 May 2006

A number of serious issues have been identified by professional and community reviews of the Environmental Impact Assessment (EIA) for the proposed Ara Macao (a/k/a Scarlet Macaw) development (the “Proposed Development”).

These issues include, but are not limited to:

• Legitimacy of Public Consultation and Solicitation of Comments on the Ara Macao Environmental Impact Assessment (“EIA”): On 17 March 2006, a Public Notice for Ara Macao Resort & Marina appeared in The Guardian newspaper. The notice stated that the EIA had been completed and submitted to the Department of the Environment (“DOE”) and that the EIA would be reviewed by the National Environmental Appraisal Committee (“NEAC”) before a final decision was made by DOE. The notice also invited the General Public to review the EIA and submit comments.
  
  On Sunday, 23 April 2006, a Public Consultation Notice for Ara Macao Resort and Marina was published in the Amandala and other papers. This notice stated that the EIA had been completed and that a Public Consultation on the EIA would be held on Wednesday, May 3, 2006 at 6:30 pm in Seine Bight Village.
  
  On 20 April 2006, Mr. James R. Joslyn, a US citizen, spoke with Mr. Vince Minnitti who is employed by the developer as its Director of Financial Services. As part of a discussion between Mr. Joslyn and Mr. Minnitti, Mr. Minnitti informed Mr. Joslyn that:
   

  • The developer had met with all members of Cabinet, who asked them to drill two wells, among a few other requests, none of which were “deal breakers,” according to Mr. Minnitti. In fact, Mr. Minnitti stated that the developer was surprised that the Ministers had not asked about issues such as beach erosion, which they were prepared to answer. Mr. Minnitti also stated that the EIA was approved after the developer complied with the Ministers’ requests.

  • There would be no environmental meeting in Seine Bight because the people of Seine Bight did not want a public meeting. There would be a meeting in Placencia on 3 May 2006, but strictly as a public relations gambit because the Belizean government had already approved the EIA.

  In May 2005, the Placencia Road Upgrade Environmental Assessment by Beca International Consultants Ltd. (the “Road EIA”) was delivered to the Chief Executive Officer of the Ministry of Works and Transport of the Government of Belize. Photograph 2.10 on page 23 of the Road EIA shows the alignment of the existing Placencia Road approaching the Placencia Lagoon, with accompanying text describing the existing Placencia Road as passing through “lowland savanna, wetlands and mangrove forest” located on the site of the Proposed Development. The Road EIA then goes on to state that “an area within this zone has recently obtained environmental clearance for a tourism and housing project with amenities such as a golf course and trails.” (see Road EIA, p. 23)

  The date of the Road EIA clearly pre-dates the submittal of the EIA by the developers by almost an entire year! Mr. Minnitti’s statements to Mr. Joslyn concerning existing approval of the Proposed Development pre-dates tonight’s public consultation by over two weeks.

  Based on these facts, the environmental review process for the proposed development, at best, lacks legitimacy, and, at worst, constitutes a fraud upon the people of Belize. These facts also call into question the legitimacy of the environmental review process for every development in the country, not just the Proposed Development.

  Further, these facts demonstrate an utter disregard for the health and welfare of all residents of the Peninsula, and disdain for its communities and cultures, and their right to have a say in their future.

  We ask for an immediate explanation from DOE, the Government of Belize and the developer.
   

• Road EIA: The EIA conflicts with the Placencia Road Upgrade planned by the Government of Belize under the Ministry of Works and Transport. As presented in the Road EIA, that portion of the Placencia Road which passes through the Proposed Development is built in environmentally sensitive wetlands. Therefore, the Government of Belize in its Road EIA recommends disturbing these wetlands as little as possible to avoid any adverse effects resulting on the wetland areas outside the existing [road] formation. (Road EIA, Section 6.3.1.d., page 77)
   

• Terms of Reference: The EIA fails to comply with the Terms of Reference (“TOR”) developed by DOE. The failure of the EIA to comply with the TOR includes failure to:
   

  • Provide information on the overall management structure of the Proposed Development

  • Establish seasonal water resource variations

  • Test temperature, DO and pH in the field rather than in a lab

  • Establish a sustainable safe, maximum yield for the confined, pressurized aquifer

  • Provide an inventory of deep wells in the same aquifer

  • Provide an adequate pre or post EIA monitoring program for the groundwater aquifer

  • Provide a separation of gray and black waters

  • Determine the nature and volume for the run-off of fertilized water from the golf-course

  • Provide dimensions to scale of all marina related structures (both land and marine based) and text justifying the size and scope of the marina

  • Provide restrictive covenants for the subdivision landowners.

  No excuse is acceptable for failure to comply with the regulatory requirements of the TOR.
   

• Electrical Capacity: The EIA fails to address the lack of available electrical capacity for the Proposed Development.
  
  According to BEL, the developer’s use of electric transmission lines near the property, including the line from Riversdale, is impossible because the lines have no available capacity.

  Instead, the developer will need to order and install a 115kv substation to service the Proposed Development. Completion of the design and build of this substation will require at least 3 years.

  BEL indicates that the developer has not contacted BEL about its electrical demands, which will equal the electrical demand of the entire Belize City metropolitan area. This lack of planning for something as basic as electric power is indicative of how this project has been put together. If the developer plans to use an alternative form of power, the EIA should have addressed this issue. Query: How does the developer plan to construct a development of this magnitude without electricity? (See Summary of Information Provided by Mr. Jose Marino, 2 May 2006)
   

• Lobster Fishery: The EIA provides inaccurate information with respect to the lobster fishery adjacent to the Proposed Development. This lobster fishery provides a significant annual income to a number of lobster fishermen in Riversdale, and the EIA fails to address in any way the effects of the Proposed Development on the fishery or the fishermen (such as from dredging and reclamation activities), or mitigation of these effects.
  
  Instead, the EIA merely states that “traditional users of the area are mainly fishermen who use the main channel for fishing and boats traveling from Seine Bight to Placencia. There is no foreseen threat to users since homeowners are expected to be retirees and business persons with little interest in fishing, except for recreation purposes and for small scale consumption.” This statement is indicative of the lack of attention to potential effects on local communities and their livelihoods throughout the entire EIA. (See Letter from Riversdale Fishermen Attesting to Health of Lobster Fishery Adjacent to Proposed Development)
   

• Siltation/Sediment Plume: The EIA inaccurately reports the composition of sand in the natural channel in front of Proposed Development. Independent testing found that the percentage of mud/silt in this channel is at least 22%, and not 17% as reported in the EIA. A mud/silt composition of 22% makes siltation curtains ineffective to control fine sediments threatening corals, grass beds, fish, other marine life, and southern beaches, and more appropriate measures must be proposed by the developer. (See Review of EIA for Coral Reef Impacts for Ara Macao Resort and Marina, April 30 2006 by Todd R. Barber, Reef Ball Foundation, p. 61)
  
  In addition, high silt and peat content as indicated by reported borings necessitate filters and “silt-ponds“ (e.g., settlement ponds) to control the silt and turbidity of reclamation discharge. The EIA for the Proposed Development completely fails to address the need for settlement ponds in this context. (See Comments of Dr. Thomas Williams, University of California at Berkeley, pp 8-9)
  
  (Note: the amount of peat and silt that will be deposited in the sediment ponds will make the settlement ponds completely un-useable for building.) In addition to marine life destruction, improper siltation and sediment control can destroy businesses and livelihoods in adjacent areas by destroying lobster, conch and grass beds, and by making the area unattractive for divers, snorkelers, anglers, kayakers and beach and nature enthusiasts.
  
  The EIA includes no discussion of a Predictive Monitoring Program which seeks to prevent harmful effects of siltation rather than mitigate the impact once the harmful siltation has already occurred.  Predictive Monitoring
   

• Shore Erosion/Sand Starvation: The EIA does not include sufficient information and analysis of the real threat of downstream shore erosion and sand starvation of beach properties, including possible accretion of sand over coral reef adjacent to the Proposed Development. Instead, the EIA attempts to ignore or minimize both of these issues. However, the effects of jetties, breakwaters and groins are clearly evident along the coast.
  
  Further, the developer’s engineers, Shabica and Associates, recognize the issue of sand starvation of downstream beaches in the annexes, but offer only an ineffective and unrealistic solution to the problem – that of perpetual maintenance dredging, filling and physical movement of sand. (EIA Annex, p. 88) Further, pictures presented by Shabica and Associates in the Annex as evidence of lack of erosion downstream from existing structures actually do show evidence of erosion – that of lost older trees. (EIA Annex, p. 80).
  
  In addition, as noted by Barber, “sand by passing cannot guarantee the lack of downstream erosion to the south, nor can it guarantee that sands do no over-accrete to the north . . . [and] a very real possibility [exists] that sand will try to by pass the channels offshore and this sand may or may not make it back to shore south of the structures. If it does not make it back to shore, erosion will be the result. Either way, this sand may flow over natural reefs offshore, killing them. Additionally, the sand that accretes to the north may back up sufficiently to cover the natural reefs.” (Barber, p. 66)
  
  Finally, the developer contends that its coastal works will reduce sedimentation of coral reefs by covering eroding areas with coarse sands and that the coarse sands will lead to reef recovery. However, as also noted by Barber, “the eroding beach sands all contain less than 2% of silt (sieve smaller than #100). So, at best, any gains will be offset by the perpetual dredging activities. Claims that the development will aid in the recovery of the reefs due to reduced sedimentation (as presented) are unfounded.” (Barber, p. 69)
  
  Barber recommends an independent evaluation of the down stream erosion potential, upstream over accretion possibility and offshore sand transport over reefs by Dr. Lee Harris of The Florida Institute of Technology who is a renowned expert on the effect of coastal structures. Dr. Harris can be reached at lharris@fit.edu. (Barber, p. 68)
   

• Water Quality and Quantity: The EIA uses inadequate estimates of the quantity of water that will be required to operate the Proposed Development. In addition, the EIA well water quantity and quality test results are suspect.

  • Water Quantity: The EIA assumes that each resident and guest at the Proposed Development will use an average of 34 gallons of water per day, without differentiating among guests, employees and residents. The EIA instead estimates water usage by facility, without breaking out the number of employees, residents and guests in each facility, making it impossible to perform intelligible calculations based on actual likely water usage.
    
    However, even ignoring this flaw, it is clear that water usage is grossly underestimated. For example, the highest water usage of 47.5 gallons per day is estimated for the golf course houses, which are the only units likely to actually house resort residents as opposed to guests. Instead of 47.5 gallons per day, these residents are more likely to use 80-100 gallons a day, which is the average water usage for residents in the US. (Note: even the EIA approved for the Coco Plum development on the Peninsula uses an estimate of 75 gallons per day per person. See also, Comments by Mark Chernaik, Ph.D, Mercedes Lu, Q.F., May 2006
    
    In addition, an almost 80% underestimation of the quantity of water needed by the Proposed Development results from the developer’s use of an average daily water consumption of 34 gallons per day instead of 150 to 179 gallons of water per day for the 5,810 tourists in the condos, villas, golf course and club house units, hotel, casino, bars and restaurants. (See page 3, Environment and Tourism: Examining the Relationship between Tourism and the Environment in Barbados and St. Lucia, reporting that in St. Lucia, the average resident uses on average of 50 gallons per person each day, while hotel residents use up to 150 gallons per person daily. Also, Barbadians use 73 gallons per person daily and the average tourist 179 gallons per person per day.)
    
    Further, the amount of water needed for employees cannot be based on occupancy rates since a certain number of full-time employees will be working and living at the resort regardless of tourist occupancy.
    
    (Again, it is impossible to determine accurately how many guests, tourists, residents and employees will be at the resort on a daily basis since the EIA fails to differentiate among these groups in its occupancy information. For example, Table 5.1 of the EIA reports that 5,648 people can occupy the Reception and Commercial Areas at full occupancy, but doesn’t tell us who these people are or what they will be doing.)
     

  • Adequacy of Aquifer: The adequacy of the aquifer the developer proposes to use to provide drinking water should have been tested using an aquifer test rather than a “well” or pump test. This involves pumping for four to ten days at a rate of at least equivalent to the project supply requirement at capacity. As no other deep boring information is available, no confirmation of the adequacy of Wells 1 or 2 is possible from the information in the EIA, especially given the gross underestimation of water quantity required by the resort as discussed above. (See Williams p. 5)
    
    Further, the ground province of the southern Belize coast and cayes is thought to be almost lacking groundwater resources. “A persistent perched water-table aquifer exists in the extensive sand beaches all along the coast and similar aquifers exist on the larger cayes, but the amount of fresh water in them is not large . . .”
     

  • Quality of Well Water: The well water testing results may be too good, especially in terms of the TDS and conductivity results for ground water. Further, the pH of the water is acidic (which is not specifically mentioned in the text of EIA, only in the water quality testing tables), requiring special handling in terms of pipes and conduits. In addition, treatment over and above the proposed addition of chlorine is necessary before this water can be used as drinking water. (See Williams, pp 5-6)
     

  • Wastewater/Sewage: The gross underestimation of water quantity needed for the Proposed Development clearly means that the amount of wastewater/sewage has also been grossly underestimated. In addition, the EIA does not address the quantity of waste water and sewage from 400 boats in addition to those generated on land (as required by the TOR). (See Williams, p. 7)
    
    The BESST units chosen by the developer to treat wastewater/sewage are definitely able to treat water and sewage to standards at or above those required by Belize law. However, if the BESST units are overloaded by actual flows 10-50% above what has been estimated in the EIA, the treated effluent may contain higher levels of pathogens than permitted by Belize law, resulting in potentially serious health hazards for local communities, employees and residents and guests at the Proposed Development. (See Williams, p. 7)
     

  • Water Quality Monitoring: The EIA includes an extremely ineffective water quality monitoring plan for coral reefs which sets critical levels for phosphate at 100 times those acceptable for coral reefs and nitrate levels at 10 times higher than those acceptable for coral reefs. (See Barber, p. 55)
    
    Also, no baseline for monitoring has been established, especially in the Placencia Lagoon, because only one site in the Lagoon was initially tested by the developer (a site not near the Proposed Development) and is not included in the list of sites to be monitored in Figure 20-1 of the EIA. Further, water quality monitoring is only mandated for a period of 4 years, a period which could very well expire before the Proposed Development is fully completed.
     

  • Cumulative Impacts: The EIA completely disregards and fails to address the serious environmental and social/economic effects of all proposed developments in the Placencia Peninsula area.
    
    These developments will bring the resident and guest population of the Peninsula to well over 22,000 persons within 4 years if the Proposed Development is approved. The resident population of the Peninsula is currently under 2,000, and its education, healthcare, police and fire protection resources are already stretched to the breaking point.
    
    The EIA completely fails to recognize or address problems local communities will encounter in attempting to educate, house and protect the hundreds of additional people the Proposed Development and others will bring to the Peninsula. (As an example of the developer’s complete disregard for local communities, the EIA answers the question of the need for increased security by stating that it will provide its own security within the boundaries of the Proposed Development, completely ignoring the increased security problems it will cause for area communities.)
    
    Belize law requires NEAC to consider the cumulative effects of all proposed developments in the area of the Proposed Development. However, the EIA merely (and inadequately) states in Section 18.2 that “the determination of potential cumulative impacts, as required by the TOR, is difficult to quantify since data is limited due to the fact that all projects have not been subjected to the environmental clearance process.”
    
    How can NEAC intelligently assess cumulative impacts when the EIA provides no substantive information about those impacts? The EIA could have reported on the number of developments slated to come on-line on the Peninsula in the next 2 or 3 years, which is information readily and easily obtainable from a basic search on Google using the search terms “Belize real estate.” Internet information on the size of these developments is also readily obtainable, as are permits issued by DOE. Had the developer gone to the trouble to obtain this information, projections could have been made for items such as estimated increase in population, solid waste and waste water generation, water consumption, electrical consumption, demands on infrastructure and educational, health and security factors. Further, if the developer cannot obtain this information from DOE, something must be very wrong with the EIA process in southern Belize.
     

  • Marina Flushing: The EIA’s conclusion that “successful” flushing of the marina can occur in 2-3 days is suspect given the small, less than .5 meter maximum normal tides, and the fact that the water quality model for the marina uses a clean and clear channel without boats, while the successful project anticipates 307 boats up to 30+m length which will severely reduce the turnover/flushing of the lagoon/marina. (See Williams, p. 9)
     

  • Solid Waste Management: The EIA fails to provide any analysis of the Placencia dump and grossly underestimates the amount of solid waste that will be generated by the Proposed Development.
     

    • Placencia Dump: The EIA fails to answer questions related to: (a) whether the Placencia dump has the capacity to absorb up to 1.7 million pounds per month of additional garbage that will be produced by the Proposed Development at capacity, (b) the financial ability of Placencia Village to acquire necessary equipment, employees and management expertise to professionally manage the dump given the complete lack of taxing power of the Placencia Village Council to raise revenue for the dump, and (c) the amount of leaching that may occur at the dump with this amount of additional garbage, how that leaching can be mitigated, and the effects on the environment of surrounding communities if leaching problems are not addressed.
      
      The developer must assure that the location used for solid waste disposal is a properly managed and funded land fill, and not a mere waste dump. This includes separate (and safe) disposal of hazardous chemicals and substances under an approved hazardous waste management plan (not included in the EIA), environmental protections such as liners to control leaching, segregation of garbage and a viable recycling plan.
      
      The Road EIA describes the Placencia dump as a “visual and ecological blight on the landscape . . . [that] is unnecessarily large in area. There appears to have been little attempt to manage its use and operation or contain the dump and the site is badly in need of some form of rehabilitation work.” (See Road EIA, p. 33)
       

    • Solid Waste Estimates: The EIA solid waste projections are based on 3 pounds of garbage per day per person for residents, guests and employees. The developer selected this number based on the average of the amount of garbage generated in Belize metropolitan areas, apparently excluding San Pedro where the average daily amount of garbage per person is 4.8 pounds per day. The amount of garbage produced by San Pedro is a much more accurate number for residents and guests of the Proposed Development, who will primarily be from North America and possibly Europe, where the average amount of residential garbage produced per day is 4.5 pounds. (Department of Environment Quality for the State of Oregon)
      
      Further, tourists produce even more solid waste per day than residents because they have no stake in the sustainability of the country as would longer-term residents. And, guests visiting the resort on a day basis have even less of a stake than overnight guests. One hotel and casino in California with 781 hotel rooms reported solid waste generated per day at 11 tons or 22,000 pounds – or over 28 pounds of garbage per day per hotel room.
      
      Based on this report, the Proposed Development will have 1,041 rooms, generating 29,148 pounds of garbage per day, or over 7 pounds per day per guest based on the occupancy numbers in the Proposed Development for the condos, villas and hotel. Clearly, solid waste estimates provided by the EIA are seriously underestimated, further increasing the need for a professionally managed solid waste management facility, and not a waste dump about which no information has been provided by the developer. (The developer also seeks to hide the fact that it will produce a minimum of 6 times the solid waste produced by the local Seine Bight and Placencia communities by including Dangriga in its solid waste calculations.)
       

    • Wetlands: The EIA completely fails to recognize or address significant destruction of wetlands by the marina, the golf course and diversion of the Placencia Road. Wetlands are among the most valuable and productive ecosystems on earth and provide biodiversity conservation, nursery and breeding grounds, improved water quality, flood mitigation, groundwater recharge, foreshore protection, recreation, aesthetic values and uniqueness for communities on the Peninsula.
      
      As recognized in Section 2.8.2 of the Road EIA, the Proposed Development is located in the Mango Creek and Placencia Special Development Area (SDA). The report for the SDA was approved in 1997, and included the objective of protection of wetlands within the SDA. Further, that portion of the Proposed Development in which the golf course, a portion of the marina and the road diversion are located is within an area designated by the SDA as a Protection Reserve II. The land use zoning established by the SDA report is still effective.
      
      Further, the Road EIA recognizes the sensitive nature of the wetlands environment located at the Proposed Development and adopted “a reduced design speed of 80 kph in order to avoid excess widening into the surrounding wetland. The construction area will be contained totally within the existing surface area. The completed design will provide a seal width of 7 metres, resulting from a reduction in the shoulder width. This avoids any new adverse effects resulting from the disturbance of wetlands areas outside the existing formations.” (See Road EIA, p. 77)
       

    • Surrounding Communities: As mentioned in the previous section on Cumulative Impacts, the EIA fails to adequately assess the social and economic effects on surrounding communities, including police and fire protection, healthcare, education, and significant price increases for commodities and land. For example:
       

      • Police Protection: The Peninsula’s very tiny police force of 4-6 officers and constables is already overwhelmed by existing crime, and lacks basic tools necessary to do its job, such as vehicles, radios, telephones – even office supplies and computer equipment. If the Peninsula’s police force can’t deal with existing crime, how will they cope with the large numbers of construction workers who will be needed to construct the development, and the hundreds of employees who will be housed somewhere in the area after completion?

      • Fire Protection: Fire protection does not currently exist at all in the area.
        o Healthcare: One nurse and one Cuban doctor currently provide all the available medical care for the entire Peninsula. It is laughable to assume that two people can possibly provide the medical care that will be needed by the employees and families of the Proposed Development – not to mention all the medical supplies that someone must purchase, pay for, and store.

      • Education: The schools in Seine Bight and Placencia are already overcrowded, and Santa Cruz doesn’t even have a school to educate its children. School attendance is mandatory in Belize. But, who will provide this education when there are already too many students for the existing schools? How will the Government of Belize find the funds to construct a new school at Santa Cruz, expand the existing schools in Seine Bight and Placencia and pay the additional teachers that will result from the developer’s project – without any financial impact or responsibility for that impact on the developer?
        
        The developer is asking for permission to use an enormous amount of the public’s natural resources for its own potentially enormous private gain. A just and equitable amount of that enormous private gain should be available to compensate local communities for these resources and to pay for the tremendous burdens imposed on them in order for the developer to realize its enormous profits.
        
        However, the developer’s lack of concern for the potential impacts of this size of a development are amply demonstrated by mitigation measures detailed in pages 13-11 and 13-12 of the EIA which completely fail to recognize or respond to issues related to the impact of the Proposed Development on local communities. In addition, in response to the potential impact of the location and size of the Proposed Development, the developer states that the Proposed Development is “low impact and low density” compared to other urban developments and that the residual impact of the size and location of the development is of low magnitude! When did a 20 mile peninsula with a population of under 2000 become an urban area? (See, EIA Table 13.6)
         

      • Economic Impact on Local Communities/Local Employment: As has been amply demonstrated throughout the world at enclave developments similar to the Proposed Development, and by the cruise ship industry in our own backyard, large scale tour operators from the well established and well connected elites are favored by large scale developments such as the proposed Ara Macao.
        
        We have all watched as the skiffs which originally carried cruise ship passengers a few at a time to snorkeling sites were replaced by large catamarans carrying hundreds of people. We have all seen the hair braiders, local craftsmen and other local vendors pushed beyond the iron gates of the Tourist Village, where signs warn tourists that they leave the safety of the Tourist Village sanctum at their own risk. The simple fact of the matter is that large scale operations want to control all aspects of their guests’ tourist experience so that they can reap most, if not all, of the financial rewards from that experience. Large scale developments such as Ara Macao want their guests to eat at resort restaurants, drink at resort bars, take resort tours and buy resort souvenirs. They do not want competition from local tour guides, local restaurants, local bars, or local craftsmen.
        
        Further, local entrepreneurs and small investors do not have the liquidity or access to affordable capital to finance luxury fishing boats, climate controlled coaches, custom-designed furnishings and other capital items necessary to compete against well-capitalized resorts such as the Proposed Development, most of which also enjoy substantial development concessions, allowing them to import much of their operating inventories duty free. Instead, most of these local entrepreneurs and small investors have invested their life savings, the only capital to which they have access in addition to their own labor – both of which have earned Belize the reputation as a prime eco-tourism destination that it enjoys today.
        
        The EIA fails to recognize this issue of marginalization of local independent businesses and investors, or to offer any mitigation for the effects of this marginalization other than to hold out the carrot of “increased employment.” However, many of the people who currently own and operate their own businesses have no desire to be forced to become an employee of a development so out of scale and character with their culture and environment. But, even if they do, the EIA fails to provide any details of the kind of employment they might find at the Proposed Development. Are the jobs that will be provided temporary or seasonal, full-time or part-time, salaried or hourly, skilled or unskilled? For example, will an experienced and skilled fly fishing guide be a permanent employee, on-call, seasonal/temporary? Will he receive private health care benefits, a pension, a paid vacation every year? Will he be required to live at the Proposed Development, or expected to commute? Can he afford to commute, and if he is required to live at the Proposed Development, where will his family live? Will he earn as much money for his family as he does now with his own boat, his own gear and his own livelihood?
        
        How will managerial and skilled employees be recruited? From where will they be recruited? If there are no skills available on the Peninsula, will training and educational programs be made available so that these jobs may eventually be filled by local residents? How will the free movement of workers under CARICOM impact on the employment opportunities available to Peninsula residents?
        
        Again, the EIA abysmally fails to recognize or address any of these employment related issues or impacts on local communities.
         

      • Casino: The EIA fails to address the direct and indirect labor requirements of the proposed casino or to provide necessary operational information about the proposed casino and night club, such as number of seats in the proposed casino, casino floor space, size of night club, and other services in the facility such as restaurants, number of bars, and the source of casino and nightclub patrons.
         

        • Casino Labor Requirements: Direct and indirect labor requirements for a casino far exceed the levels indicated in the EIA and will generally require much higher levels of experience and skills than can be met by general training. The EIA does not address the source of these employees, wage scales, the need for advanced training in order to hire Belizeans and the effect of the CARICOM free movement of labor, which may result in most mid to upper level management positions in the casino being filled by Caribbean nationals and not Belizeans.

        • Casino Operational Information: Operational information is necessary to evaluate water capacity, sufficiency of solid waste management (as discussed above), waste water treatment capacity and management, and financial viability of the Proposed Development. Also, Table 5.1 of the EIA calculates occupancy of the casino at 1,000 persons in addition to the number of guests, residents and employees in the hotel, villas, condos, and golf course homes. Since information such as number of seats and floor space of the casino is not provided, it is impossible to determine the population base that will be needed to support the casino. However, assuming 500 seats (or half the reported capacity of the casino) a population base of approximately 18,000 people is necessary to make the casino economically viable. The EIA does not discuss where this population base will come from, strengthening local suspicions that one of the primary purposes of the Proposed Development is as a cruise ship destination as discussed below in the section on Undisclosed Uses of Proposed Development Facilities. In any event, operational information is necessary in order to adequately evaluate carrying capacity.
           

      • Golf Course: The EIA is wholly lacking in any specific details about the golf course other than the location of the club house, the acreage and the grass that will be used as turf.
        
        Significantly, it fails to address the nature and volume of the expected run-off of fertilized water from the golf-courses as required by TOR, or to provide details about the pesticides and insecticides that will be actually used on the golf course. The list of pesticides that may be used on the golf course is merely a list of all pesticides and insecticides authorized for use in Belize.
        
        Section 1.04 of the TOR requires information on pesticides that will be used, not any and all pesticides that might be used. Therefore, the EIA also does not comply with Section 1.04 of the TOR. This is not a mere niggling matter because neither DOE nor NEAC can evaluate the impact of pesticides that will be used on the golf courses without knowing what those pesticides are – or what pests they are intended to destroy. Further, no mention is made of any specific controls to reduce the use of pesticides and insecticides such as Integrated Pest Management, or specific grasses that are not prone to significant damage from tropical insects.
        
        Also, as with other EIA sections dealing with water use, we suspect that the amount of water that will be required for the golf courses has been significantly underestimated since UNESCO reports that 18-hole golf courses situated in the tropics can use up to 575,000 gallons of water per day.
        
        Further, the EIA did not include the water required for the golf course in its calculation of water demand of the project. The Executive Summary mentions it is expected that some 325,000 gallons of water per day at full operation, equivalent to 1,23 cubic meters per day or 450,000 cubic meters per year, which is only half of the water required to irrigate the golf course, which could be even higher considering the high evaporation rate in the weather conditions of Belize. (see Chernaik, p. 3)
        
        However, it is impossible to adequately assess the water use issue because the EIA includes so few details about the golf course that are essential to an assessment of water use, including course layout, irrigation system design and control, fertilization program, pest management, and mowing. What we do know is that the EIA describes Bermuda grass as the preferred turf grass rather than other more environmentally friendly grasses such as Seashore paspalum (Paspalum vaginatum) which has relatively low fertiliser requirements, (up to 50% of that needed by hybrid Bermudagrass), and will tolerate salt water and other alternative irrigation sources, e.g. recycled water.
        
        In addition, we are uncertain of the relevancy of the EIA’s almost verbatim (and without citation) publication of The General Description of Construction Line Items from the American Society for Golf Course Architects from the Society’s Website and which consumes about one-half of Section 16 of the EIA).
        
        Finally, no mention is made in the EIA of seeking certification as an environmentally sound golf course by the Audubon Cooperative Sanctuary for Golf Courses certification program. (http://turf.lib.msu.edu/2000s/2002/020925.pdf and www.audubonintl.org/programs/acss/CACS%20List%20by%20State.pdf).
        
        The proposed golf courses present such a significant threat to the fragile wetlands and Lagoon environments that a separate EIA should be required for the golf courses.
         

      • Economic and Financial Viability/Project Abandonment: The EIA fails to include any information about the economic viability of the Proposed Development with respect to the financial ability of the developer to: (a) complete the project if approved; (b) comply with significant ongoing monitoring requirements given the serious environmental impacts that will result if problems are not identified as soon as they develop; (c) continue maintenance dredging and beach sand filling in perpetuity (as long as groins and channel remain); (d) attract the necessary number of visitors for economic viability of the proposed casino and golf course; or (e) provide a fund for closure of the project and mitigation of negative environmental impacts (such as removal of the breakwater jetties) if the project is abandoned.
         

      • Development Schedule: The EIA fails to include adequate information on the development schedule for the Proposed Development in terms of which buildings will be completed first and when infrastructure will be completed. Lack of detailed information on the development schedule for the Proposed Development means that DOE cannot be sure that Phase I is complete before giving approval to the developer to start Phase II. This lack of information also raises suspicions that the developer does not intend to actually develop the project, but instead intends to immediately sell the property once its value has been substantially increased by an approved development plan. This lack of detailed information also raises the suspicion that the developer did not believe that its full proposed development plan would be approved, which resulted in the developer asking for approval of a much more intensive development in the hope of getting what it really wants.
         

      • Project Financials: The EIA fails to provide any information about whether project financials are based on the same assumptions as those used in the EIA. This information is necessary to fully assess whether the projections provided in the EIA to the Belize government are realistic ones, or were developed solely for the purpose of obtaining development approval.
         

      • Undisclosed Uses of Development Facilities: The sheer size and scope of the project in relation to the population of southern Belize, including all new developments on the Peninsula, has created a very strong local suspicion that one of the primary purposes of the Proposed Development is to provide a cruise ship passenger destination for cruise ships docking at Big Creek or other proposed cruise ship ports in the region. The EIA deliberately avoids addressing the issue of the permanent and temporary population base necessary for a development of this size. If suspicions are correct, the EIA must be completely reworked to include assessments of the wide-reaching effects of large numbers of day visitors from cruise ships, including, as illustration, but not as a limitation, water, solid waste management, sewage and local employment. In any case, the EIA must address the issue of day visitors with respect to all of the issues discussed above, including water consumption, garbage, waste water, and impact infrastructure.
        
        More information on the above issues is provided in the enclosed documents, which include:
         

      • EIA Review for Coral Reef Impacts, Todd Barber, Chairman, Reef Ball Foundation

      • Comments of Dr. Thomas Williams, University of California, Berkeley (also attached as Appendix I to the enclosed EIA Review by Todd Barber)

      • Comments on the Environmental Impact Assessment (EIA) for the Proposed Ara Macao Development, South Stann Creek, Belize, by Mark Chernaik, Ph.D, Mercedes Lu, Q.F. May 2006

      • Statement of Lobster Fishermen from Riversdale

      • Report on Investigation into Availability of Electrical Supply to the Proposed Development, including information provided in a phone interview with Mr. Jose Moreno, Planning and Engineering Dept., BEL, 2 May 2006. Tel 227-0954

      • Mango Creek Special Development Area Map

      As demonstrated by the issues identified above and in the enclosed documentation, the amount of missing, inadequate and inaccurate information provided in the EIA for the Proposed Development is staggering.
      
      Also, please note that the list of issues identified above is not an all-inclusive list, but rather represents some of the most serious problems of the EIA identified by the community and its consultants. Other very serious issues also need to be adequately addressed by the EIA, including, but not limited to:

      • The amount and effect of fertilizers, insecticides and pesticides that will be drained or leached into the Placencia Lagoon through the 15’ wide, 6’ deep and 9,504 feet long drainage “ditch” the developer proposes to dig to channel untreated drainage from the road and the golf courses into the Lagoon

      • The establishment of an adequate water quality baseline so that a meaningful environmental monitoring program can be implemented

      • The possibility of saltwater intrusion into the ground water from over-pumping of well water for the aquifer (see Chernaik, p.4)

      • Hurricane evacuation and/or shelter for residents of the Proposed Development, and hurricane evacuation of residents living south of the Proposed Development

      • Disposal of sludge from the waste water treatment facilities (which is not addressed in the EIA)

      • Possible contamination of dredged soils from banana and shrimp farm operations making the dredged soils unsuitable for use as fill

      • Potential breach from Caribbean to Lagoon and impacts of such a breach

      • Impacts on coral reef from land-based activities

      Consequently, the EIA for the Proposed Development does not provide a rational basis on which to make an informed decision about the Proposed Development. Therefore, NEAC must deny the Proposed Development based on this EIA. If the developer still desires to proceed, it must submit a new or substantially revised EIA that adequately and reasonably addresses all relevant issues, including, but not limited to, those outlined above.
      
      Therefore, we respectfully urge NEAC to recommend denial of the Proposed Development until the developers comply with the laws of Belize regulating the environmental and social/economic impacts of their Proposed Development on our environment and our communities.
      
      cc:     BACONGO
                Placencia Village Council
                Seine Bight Village Council
                Independence Village Council
                Ministry of Natural Resources and the Environment
                Belize Tourism Industry Association – Placencia Chapter
                Belize Tourism Industry Association (national office)
                Belize Eco-Tourism Association
                Belize Audubon Society
                Friends of Nature
                Belize Zoo
                TIDE
                BELPO