Land of Wood and Water, or Land of Concrete and Congestion? A Jamaican biologist comments on the proposed Mammee River Development Project

Wendy Lee, who attended the January 11 public meeting on the proposed Mammee River Development Project convened by China Harbour Engineering Company (CHEC), is a Jamaican citizen, a St. Ann resident, and a biologist and environmentalist with over 45 years of experience.

Biodiversity, simply put, means the huge variety of life on Planet Earth that we may or may not be aware of as we go about our daily lives: from large mammals and birds to tiny insects and plants, each has its role to play in its own particular ecosystem. As the World Wildlife Fund points out here:

Biodiversity supports everything in nature that we need to survive: food, clean water, medicine, and shelter.

World Wildlife Fund website

This development will be devastating to all the creatures that have made this land their home. It will destroy Jamaicans’ birthright, their natural and cultural heritage. Forever. And by the way, Nature cannot be moved around – it simply doesn’t work that way. Nor can things be fixed back the way they were before. Nature doesn’t work that way, either. Right?

We cannot say to endemic birds (which live nowhere else but Jamaica) and other species “OK, we’ve finished building. You can come back now!”

Please read these comments on the Environmental Impact Assessment (EIA) . The final section on “ABOUT THE EIA PROCESS, PUBLIC CONSULTATION, AND OUR RIGHTS” is very important. The Environmental Solutions Limited website is currently down (the company was contracted by CHEC to produce the EIA). Its Facebook page consists of several posts about earthquakes.

We are giving up another part of our natural and cultural birthright. Future generations of Jamaicans will no longer be able to enjoy it.

COMMENTS ON THE PROPOSED MAMMEE RIVER DEVELOPMENT PROJECT

Wendy A. Lee

30 January 2024

I submit these comments and questions on the proposed Mammee River Development Project in my capacity as a Jamaican citizen; a resident of St. Ann; a biologist and environmentalist with over 45 years of observing the flora and fauna of Jamaica, particularly birds, and documenting the environmental impacts of human activities on the natural environment of Jamaica. My concerns about this project go far beyond the impacts on biodiversity, but I will focus on this issue as it involves the destruction of our irreplaceable ecological heritage.

St. Ann is the largest parish in Jamaica. It has the most nature-based tourist attractions of any parish, the busiest cruise port and will soon surpass Montego Bay in the number of hotel rooms. It is astonishing to realise that St. Ann, arguably Jamaica’s most important tourism destination, does not have a single protected area of natural forest that is managed for the conservation of the natural landscape, as a refuge for wildlife, or a publicly accessible site for non-extractive recreation such as birdwatching.

Apart from the ecological disaster of mass tourism development, the many recently announced resort projects are on track to permanently destroy the existing and potential market for nature tourism in St. Ann. Already, lucrative birding tours routinely bypass St. Ann and stop only in the Cockpit Country and Portland, due to the lack of publicly available forested areas for wildlife viewing. Ocho Rios-based tourists must travel at least 1.5 hours in either direction to reach suitable areas to see forest-dependent birds, and yet the Roaring River forest is located right there and is filled with endemic birds and other wildlife.

WHAT IS AT STAKE?

The project site, 167 acres in the Roaring River watershed, is one of the last remaining areas of natural forest along the entire coast of St. Ann. The EIA established that the area is exceptionally rich in wildlife:

The EIA states that:

“With the presence of such differing habitats and environmental conditions, a variety of fauna were in turn identified from groups including avifauna, amphibians, reptiles, butterflies, moths and snails…

EIA on Roaring River development

and that:

“The high number of endemic forest species suggests that the forest is in good health.”

EIA, Roaring River development

Of all the places that should not be considered for housing development, it is this wildlife-rich, healthy forest that forms part of the Roaring River Watershed.

Fauna and flora identified on the site included:

• Birds – 51 species (15 endemic, of which 9 are “forest-dependent;” 29 resident, 5 migrant)

• Amphibians – 14 (11 endemic)

• Reptiles – 17 (11 endemic)

• Mammals – 10 bats

• Butterflies and Moths – 12 species (4 endemic)

• Snails – 17 species (2 endemic)

• Plants – 108 species (43 trees of which 5 are endemic; 16 shrubs, 28 herbs, 7 shrubby herbs, 10 epiphytes and climbers (2 endemic), and 4 ferns).

IMPACTS OF FOREST CLEARANCE ON BIODIVERSITY

These are some of the impacts described in the EIA (excerpts below are taken from pages 87-88 and the Executive Summary):

The proposed development will convert 102.6 acres out of 167 acres to houses, townhouses, apartments, roads, and supporting utilities, replacing forest with “mainly impermeable surface.”

“The construction associated with the proposed housing development will result in extensive removal of vegetation and excavating the land which will result in loss of habitat and greenery. Many species play key roles in the environment and all measures should be employed to reduce habitat disturbance.”

“Large tracts of existing flora are expected to be removed during construction. The overall biodiversity will decline, however there is the possibility of increased fruit trees…”

“No rare or endangered species have been identified…

“There is a risk to the destruction of previously undiscovered heritage sites.”

EIA, Roaring River development

My comments:

• Clearly, the physical impacts would be devastating to the forest and all its inhabitants. It is ridiculous to suggest that habitat disturbance could be reduced when obviously the habitat – this extremely rare and valuable area of healthy forest – is going to be obliterated.

• Introduced fruit trees are of negligible value compared to the value of a natural forest ecosystem.

• Just because species are not ‘officially’ endangered does not mean they are not important species. It is the ecosystem that merits protection, not just the rare or endangered species, and each species plays a role in the ecosystem.

• The EIA fails to note that there is a risk to previously undiscovered biodiversity. Having described the devastating impacts of this project on more than 102 acres of healthy forest, the EIA goes on to make these stunning false conclusions:

The development “will have minimal to moderate impact on the surrounding physical environment” and “…the existing fauna will migrate to the surrounding habitat.”

“Species occurring here are ubiquitous, and are therefore capable of surviving a large variety of habitats and can return to remaining habitats following construction.”

EIA, Roaring River development

Every ecologist knows that in an ecosystem, each plant or animal is dependent on a specific set of habitat conditions (their niche). If land is cleared, the forest and all its inhabitants will be destroyed. Adult birds might escape the bulldozers, but where would they go to? What could possibly be meant by “return to remaining habitats”?

The statements suggesting that animals would merely be displaced, to return later, are false and should not be accepted by NEPA/NRCA. In fact, these agencies need to stop accepting the proposed ‘temporary relocation’ of ‘rare’ species of flora and fauna as a mitigation measure; ecosystems that are destroyed cannot be replicated, and the impact is not ‘displacement’…

It is LOSS.

ALTERNATIVES

The EIA fails to identify any lower-impact alternatives to the planned project. All they offer is the ‘no-action’ alternative, which unbelievably they have tried to spin as a negative thing for the preservation of cultural heritage, citing the possibility that heritage sites might remain “unnoted.” They do not attempt to quantify the benefits of protecting the forest and its associated wildlife, which is a major omission of the EIA. Why is it all or nothing? Why isn’t there any suggestion of a lower-impact alternative?

We were told by the CHEC representative at the meeting held on January 11, 2024 that “the Government” told CHEC they “had to” do a high-end, luxury development on that land. Among the amenities planned for the undoubtedly wealthy residents of the proposed development are “a clubhouse with a pool, a gym, tennis courts, disability accessibility, parks, birdwatching and walking trails…”

I submit that as an alternative, they could turn the site into a tangible environmental and cultural asset by developing those amenities for both the people of Jamaica and tourists. Surely this would enhance tourism and provide multiple opportunities for local involvement, with a light environmental footprint?

In short, they could establish St. Ann’s first protected area for wildlife conservation, nature tourism (wildlife viewing) and non-extractive recreation, in conjunction with preserving the historical heritage of the Great House and environs.

A SHORT LIST OF MY OTHER CONCERNS ABOUT THIS PROJECT

FLOODING: Increased risk of flooding and siltation of the marine environment due to land clearance and resulting surface runoff.

WATER SUPPLY: With a total of 834 units adding 4,468 occupants, this would increase the local population by almost 50% (there are 11,639 other residents within 2 km of the site). This project would obviously put increased pressure on water supply for existing residents; 30% of the respondents from the surrounding population say their water supply is inadequate and another 45% say it is sometimes adequate.

MARINE WATER QUALITY: There are already disturbingly high faecal coliform levels off the nearby coast. This project poses a big risk of adding to the problem. It is significant that from the freshwater sample sites, contamination is only near the Great House (i.e. near human occupation).

MISREPRESENTATION OF THE PROJECT IN SURVEYS: The EIA states that the socio-economic surveys did not identify the high-income target market for the project, so “the characterisation of the proposed development as a solution to address a long-standing housing need is not applicable.” This omission should force the abandonment of the approval ratings for the project. In fact, several participants of the January 11 meeting inquired about the affordability of the houses and were told rather bluntly by the CHEC representative that the houses would not be affordable.

GARBAGE: The EIA states that waste collection will be handled by a private company contracted by the homeowners’ association, but gives no further details about this issue. How much garbage will be generated by the additional 4,468 residents? Will this additional garbage be taken to Haddon [nearest dump]? How many truckloads per week will be going through Fern Gully to Haddon? What are the energy costs/emissions/pollution impacts of all those trips? These are just a few of the concerns I have about garbage and its impacts.

TRAFFIC: How many more vehicles will be added to the already intolerable lines of traffic? Even with police officers present at every traffic light in the area, the current travel time from Ocho Rios to Runaway Bay on any weekday afternoon is 1.5 hours or more, without any special event happening. Adding just one vehicle per unit, represents 834 more vehicles in the area. This will cause increased travel time for all road users; increased chances of accidents; increased fuel consumption and emissions.

INCREASED DEMAND FOR SOCIAL SERVICES: What is the carrying capacity of the Ocho Rios area and northern St. Ann in general for social services such as health care/hospital services? Tax Administration and Motor Vehicle Licensing? Additional pressure would be placed on these services by some 4,500 new residents.

ABOUT THE EIA PROCESS, PUBLIC CONSULTATION, AND OUR RIGHTS

As each massive new construction project is launched, the Land of Wood and Water becomes increasingly the Land of Concrete and Congestion. When it comes to resort development, we are destroying the very natural assets that make Jamaica attractive as a tourism destination: the lush vegetation and all its dependent wildlife; the indigenous flora (to be largely replaced by non-native plants that do not support any indigenous fauna); the beautiful natural landscapes and coastal vistas (to be replaced by concrete skyscrapers behind hideous, high walls); the shoreline with its varied landforms and different vegetation types (replaced by fake beaches and groynes); and the once-vibrant coral reefs (now reduced to less than ten percent of live coral).

These are not just visual impacts, they have very real consequences for the quality of life of residents and the sustainability of tourism itself. It is difficult to quantify the loss of ecological services as land is cleared for construction, but impacts are both tangible (such as increasing ambient temperatures and surface runoff) and intangible (such as loss of scenic landscapes and seascapes).

At the same time, local people are increasingly excluded from enjoying their own natural resources – beaches, rivers, scenic natural areas – while facing intolerable levels of traffic congestion caused by tourism (such as on cruise ship days) and urbanisation of the lands between towns (a practice specifically discouraged by the St. Ann Parish Development Order).

The Environmental Impact Assessment process in Jamaica is completely inadequate to protect the environment and ensure

“the right to enjoy a healthy and productiveenvironment free from the threat of injury or damage from environmental abuse and degradation of the ecological heritage…

Charter of Fundamental Rights and Freedoms

If public consultation is offered (and this is not guaranteed, it is at the discretion of NEPA), participants are presented with a bewildering barrage of technical information and typically only allowed to ask a single question during the limited question and answer segment of the consultation (as happened on January 11). Satisfactory answers are rarely, if ever, given.

Since the 1990s, I have participated in the public consultation process for every new resort development, mining venture and major housing scheme in St. Ann where notice was given and provision made for public consultation. At no time has the question of cumulative impacts of coastal development ever been adequately addressed by the EIA process, nor have my questions on this subject ever been answered.

As far as I know, no resort development has ever been refused an Environmental Permit by the NRCA, nor have there been any major modifications required. Instead, clear breaches of the Environmental Permit have been “regularised”– such as the sewage treatment plant constructed for the Bahia Principe (the largest hotel in Jamaica), which was significantly different from the plant that had been approved by NRCA.

I note with concern the announcements from the tourism ministry about a series of massive new resort developments in St. Ann and elsewhere along the north coast of Jamaica. How can these projects be announced prior to a thorough assessment of their individual and cumulative impacts on the environment? Or is it the case (as people say) that they are all “done deals”?

Clearly, the EIA process is an expensive sham, for which developers pay in order to “go through the motions” of environmental responsibility. The approving agencies eagerly rubber-stamp the destruction while promising to ensure compliance with “conditions” designed to protect the environment. However, as everyone who follows the news knows, monitoring and enforcement are practically non-existent and certainly ineffectual.

I encourage the development decision-makers to recognise the special value of this area, the Roaring River forest, and provide for its conservation rather than approving its destruction. If this housing development is allowed to go ahead, the people of St. Ann will be deprived of their right to enjoy an important part of our ecological heritage.

A part of the Mammee River/Roaring River property to be developed by China Harbour Engineering Company. Is it a “done deal”?