Virgin Islands Environmental Council incorporated

The Virgin Islands Environmental Council was incorporated in July 2007 pursuant to the resolution of a general meeting called by the Fisherpersons and Concerned Citizens for the Protection of Beef Island (FCCPBI) in February 2007.

It was agreed by those present that a collective-vehicle should be formed in order to pool resources to do research and take action on issues affecting the BVI environment, particularly development-related issues. This vehicle was first announced as a coalition between the FCCPBI and BVI Heritage Conservation Group (BVIHCG).

The coalition staged a successful rally in the Palm Grove park in March of this year that raised awareness and educate the public about the threat posed to the Hans Creek Fisheries Protected Area by the Quorum Island (Ltd.) Beef Island Development Project and the problems posed by the Villa Paradiso Development Project to the beach at Smugglers Cove and the proposed national park in the Belmont Area.

VIEC was established under the BVI Business Companies Act 2000 (as amended) as a company limited by guarantee. It is an umbrella non-profit environmental organization whose objects include promoting environmental democracy, public participation, access to justice on environmental issues and the enforcement of environmental legislation. The directors of VIEC pro-tem are Dr. Quincy Lettsome and Mr. Richard Courtney DeCastro from the Fisherpersons and Concerned Citizens for the Protection of Beef Island.

The Environmental Council has three immediate tasks: (1) to support the efforts of its members to circulate petitions (to be submitted to the new premier on their first day in office) requesting reconsideration of planning approvals granted to the Beef Island and Smugglers Cove Developments; (2) to investigate the possibility of taking legal action in the public interest against a number of developments about which serious environmental and legal concerns have been raised including those at Beef Island, Smuggler’s Cove, Lambert Bay, Oil Nut Bay, White Bay, and Diamond Cay; (3) to raise public awareness of the unnecessary negative environmental impacts caused by developments with inadequate environmental controls, such as Scrub Island.

Membership in VIEC is open to any individual, group, or organization that wishes to support environmental protection in the public interest. Membership may obtained by contacting VIEC at viec@bvihcg.com and responding to the confirmatory email.

Further information maybe obtained by contacting one of its directors, or by emailing viec@bvihcg.com

Belmont/Smuggler's area Standpoint advertisement, August 8th, 2007

Press Release-Global Coral Alliance, July, 2007

GLOBAL CORAL REEF ALLIANCE
A non-profit organization for protection and sustainable management of coral reefs
___________________________________________

Global Coral Reef Alliance, 37 Pleasant Street, Cambridge, MA 02139,  USA
Telephone:          617-864-4226                                       617-864-0433  
E-mail:   goreau@bestweb.net                       Web site: http://www.globalcoral.org

RESTORING BRITISH VIRGIN ISLANDS ECOSYSTEMS AND FISHERIES

Thomas J. Goreau, PhD
President, Global Coral Reef Alliance
July 5 2007

1.         GENERAL ENVIRONMENTAL STRATEGY ISSUES

            The British Virgin Islands has long been known for its excellent snorkeling, so healthy coral reefs have been the major natural resource base for BVI’s tourism and boating economy as well as its fisheries. The health of BVI’s coral reefs have not been the result of wise management, but a series of lucky accidents: low population, low pollution levels from sewage and industry, low deforestation and erosion rates, and its location in the very northeastern Caribbean, flushed by clean Atlantic ocean waters.

            Nevertheless, despite these advantages, BVI’s reefs have declined severely, even if not as badly as most of the rest of the Caribbean. In 1979 almost all the elkhorn and staghorn corals, which made up the bulk of the shallow reefs, and were responsible for most of the fish habitat and shore protection, died from White Band Disease. While there has been more recovery of these crucial species than is seen elsewhere in the Caribbean, their amounts are still only a tiny fraction of what they were, and they are threatened by White Plague and White Pox diseases as well as recurrent White Band disease. Nutrients from inadequately treated sewage have caused algae blooms to overgrow and kill reefs near population centres. And a very large proportion of all of the corals (roughly a quarter to a half, depending on location) in BVI died in 2005 from extreme high regional temperatures caused by global climate change.

            Given the accelerating and unavoidable stresses to the reefs caused by climate change and new diseases, the last thing BVI should do is increase stress to the remaining coral reefs by allowing increased sedimentation and nutrients from uncontrolled and ecologically unsustainable “development” schemes that would help destroy the very natural beauty on which BVI’s economy is based. BVI’s national coral reef management strategy should be based on conserving all the good reef remaining, and actively restoring the degraded areas critical to fisheries and tourism.

At this time the Turks and Caicos Islands are the only country in the world to have a national strategy to address these issues (T. Goreau, 2006, Turks and Caicos Islands: Coral reef assessment and restoration and management strategy). TCI is the only place that requires all developers to build secondary sewage treatment plants and then to recycle all the wastewater on their own properties without discharge, in order to avoid polluting the coastal zone, and is the only country to adopt water quality standards specifically designed to protect coral reefs. They are the only country that not only enforces their environmental laws, they do so to higher standards than the letter of the law requires. That is because having survived slavery and economic abandonment, the people lived off the sea for hundreds of years, and even though they now have tourism and financial services, they know that these are fragile, could collapse at any moment due to political factors beyond their control, and they could be forced to survive from the sea again. So they have taken every possible step to preserve their reefs and fisheries, to prevent outside investors from destroying or damaging their resources, and started promoting active marine habitat restoration.

BVI should do the same, for their own long-term self-interest. Effective marine resource management requires not only effective laws but the will to enforce them, developing the means to identify locally-caused factors that could stress reefs before they are out of control and strategies to reduce them, while pushing the British Government, as their representative, to act much more forcefully on their behalf to reverse global climate change.

2.         WATER QUALITY ISSUES

            Water quality problems in BVI are visible in the form of high levels of algae that smother and kill corals, and are largely located where there are land-based sources of nutrients (nitrogen and phosphorus) entering the coastal zone, largely from inadequately treated sewage. These nutrients are fertilizers, and just as throwing fertilizer on an empty field yields bumper crops of weeds, releasing them into the coastal zone causes massive growth of algae and bacteria that overgrow and kill corals, and wipe out reef habitat and fisheries. In BVI there are few industrial or agricultural pollutants, so sewage is likely to be the major problem, although some sites down-current from offshore sites where deep, cold, nutrient-rich water is brought up by winds, waves, and ocean circulation can be naturally, but episodically, enriched in nutrients. Coral reefs are the most sensitive of all ecosystems to nutrients, and are smothered with weeds at levels that would affect no other aquatic ecosystem. Therefore they require the strongest water quality standards and the most effective recycling of nutrients on land (T, Goreau, 2003, Waste Nutrients: Impacts on coastal coral reefs and fisheries and abatement via land recycling, UN Expert Meeting on Waste Management in Small Island Developing Countries).

There is no systematic monitoring of nutrients in BVI, and therefore coastal managers do not know the amounts and sources of nutrients to the coastal zone, and are unable to devise strategies to reduce them at a time when growing population and mega-developments are greatly increasing sewage effluent loading  to the coastal zone. Because BVI is surrounded by clean open Atlantic waters, algae in coral reefs are generally very low by Caribbean standards except next to human population concentrations, but these areas are highly vulnerable to only very small increases in nutrients from existing or new sources. The pattern of spreading algae that degrade reefs has been seen all over the Caribbean, even in low lying, dry, sparsely populated islands such as the Turks and Caicos, Bahamas, Bonaire, and Cayman. While the bulk of these nutrient sources are from sewage, agricultural runoff can play a role locally, as do captive dolphin pens, turtle farms, fish hatcheries, and sediment loaded runoff from poorly designed roads and building sites.

No coral reef country in the world has mapped nutrient distributions in their coastal waters even though this is needed to identify the sources of nutrients triggering changes in reefs and fisheries, devise specific policy actions to reduce them, and to test if such steps are effective. Without doing so, the database needed for effective scientifically-sound management does not exist. While most Caribbean countries have already lost most of their coastal reefs, in BVI the problem is still in the early stages and might still be dealt with, before the damage to the reefs is irreversible, by treating existing wastes better and preventing new sources. The issue of boat anchorages and waste discharges also needs to be seriously addressed and anchorages need to be examined for signs of environmental impact. For example at boat anchorages in the Grenadines, which is along with BVI the major yachting center of the Caribbean, the bottom is covered with dense masses of algae indicative of sewage inputs, which are not found away from the anchorages. While much concern is raised about the damage to the corals by uncontrolled anchoring, the impacts of nutrients must also be considered.

BVI already possesses a critical element in setting up a national water quality assessment in the large collection of state of the art marine equipment that has been purchased for the H. Lavity Stoutt Community College, but which has never been set up. This is due to lack of personnel skilled in setting up and maintaining this equipment, and lack of a funded program that would use it. In some cases the equipment that was bought can only be used to analyze nutrients in samples that are collected in the field and brought back to the lab, but this causes numerous problems in interpretation because of sampling, storage, and analytical errors, and because the samples taken must be widely separated in space and time. It would have been far more useful to have gotten equipment that could be used for continuous real time measurements in the field from small boats, allowing nutrient maps to be prepared all around whole islands, identify every single nutrient source, and track each to its origin, while eliminating storage and sampling artifacts. But the personnel and long term monitoring environmental programs must be in place for this equipment to be effectively used. This is an issue that needs a comprehensive policy, strategy, and funding involving the College, the Government Department of Environment and Fisheries, and scientific researchers. 

Because much of this equipment would be primarily used for intensive field mapping at selected times of the year, it could be profitably used for regional programs in several places. This would fit with the original mandate of the Maritime Program to serve regional needs. An especially attractive route for funding from the British Government Overseas Development Assistance would be to create a regional program involving all the British Caribbean territories, which all face similar water quality problems and needs. The 2006 Turks and Caicos coral reef assessment, conducted by the author, reveals systematic patterns of excessive algae reflecting both human and natural nutrient sources, and calls for the development of precisely the same kind of nutrient mapping capability by the TCI Department of Environment and Coastal Resources. A similar but much briefer assessment of algae problems carried out by the author in 2005 for the Cayman Government Department of the Environment also revealed widespread algae problems related to nutrient sources from sewage, garbage dumps, golf courses, and in some cases, natural sources. Based on that study the Cayman DOE sought funds from the British Government to set up a “Regional Centre of Excellence in Water Quality Studies” and while it received some funds for this in 2006 follow through seems to have been stalled. The point is that the environmental agencies in both Turks and Caicos and Cayman have identified this lack of water quality monitoring capability as a serious obstacle to sound coastal zone management and have stated the desire to resolve it. BVI could collaborate with Turks and Caicos and Cayman, and in addition with Anguilla and Montserrat to develop tools that could be shared regionally and be more attractive for British, Canadian, or EU funding agencies. Such a program could logically use the H. Lavity Stoutt Community College Maritime Program facilities as a permanent laboratory base for the program, and add on instruments for field monitoring capabilities to be shared with other regional government environmental agencies.

3.         NEED FOR A NATIONAL REEF RESTORATION STRATEGY

            The quality and quantity of coral reefs with good snorkeling and diving has steadily declined in BVI. Many coral reefs near hotels that once had excellent snorkeling right in front of their beaches now have dead or nearly dead reefs. Long-term divers are all aware of the constant deterioration of the reefs, but most are secretive about it, since the success of tourism means selling the image of pristine reefs in paradise, a place where by definition nothing can be wrong. Since all BVI’s competitors are selling the same lie, no one can admit that their reefs are on a downward death spiral, because to be honest about this would be a self-inflicted wound from a commercial standpoint. Even though the general decline of reefs all around the world means that as BVI reefs decline, the decline in the reefs everywhere else are such that BVI’s reefs remain RELATIVELY better, even as they steadily become less and less.

In my view it is unwise for BVI to base its coral reef management strategy on self-deception for tourism public relations, because you can’t fool Mother Nature or what she will do to those who willingly or unwittingly squander their natural resources. An honest appraisal of the problems is critical to developing any will for active restoration. At this moment the Turks and Caicos Islands is the only country in the world with an official policy draft for a coral reef restoration policy, the rest are totally unaware of what is happening to their marine resources, in denial (Cayman hired Jean-Michel Cousteau to go to dive shows and say that “thanks to the hurricanes, Cayman reefs are now better than ever” when in fact they had been heavily damaged), in deliberate concealment (Bonaire is suppressing the long term photographic record showing continuous decline in coral cover because of fear that it would affect tourism). None of these responses will result in pro-active efforts to restore their damaged reefs which will decline even faster in the coming years as global warming and new diseases accelerate greatly.

            BVI should encourage or even require all shore front properties to restore the coral reefs in front of them. This would not only provide a resource for ecotourism, it would at the same time provide shore protection and habitat to restore the fisheries. An option for doing so is to use Biorock® technology which uses safe low voltage electrical currents to grow reef frameworks of any size or shape on which corals typically grow 3-5 times faster than normal, have 16-50 times greater survival from severe bleaching heat stroke, and which attracts dense populations of fish, especially juveniles. The Global Coral Reef Alliance, the developer of this technology, is ready to work with all serious partners to  assist in reef restoration efforts.

4.HANS CREEK AND BEEF ISLAND DEVELOPMENT

Hans Creek is one of the most important marine protected areas in BVI. The waters are remarkably clean and clear for a mangrove habitat, and the seagrasses are unusually lush and healthy, which makes it an unexcelled habitat for juvenile reef fish, lobster, and conch, fueling much of the fisheries in surrounding waters. A long-term study of Hans Creek by the International Centre for Living Aquatic Resource Management ( ICLARM) identified Hans Creek as one of the richest fish nurseries in the Caribbean. The few remaining mangroves in BVI need to be systematically protected from all development, but there appears to be no policy to do so, instead marinas, golf courses and hotels are being approved on mangrove habitat wherever developers wish. The proposed development of Beef Island would place a big boat marina in a shallow semi-dry salt pond, which would require massive excavation of fine mud right in front the channel through which almost all the water of the Hans Creek Marine Protected Area area circulates. The shallow channel would need to be blasted much deeper to allow mega-yachts to enter. All the mud from dredging and excavation right at its inflow point would kill off the fisheries nursery function of Hans Creek. Even worse, the golf course planned for the mangrove and dry forest area above it would provide a source of nutrients that would deliver the coup de grace. The figure shows that any development in this area is immediately upstream of Hans Creek and would unavoidably destroy it one of BVIs most important fisheries resources and should never be permitted. 

5.         SCRUB ISLAND DEVELOPMENT

            The ongoing development at Scrub Island has clearly failed to properly contain the sediment from construction, which is moving under, around, through, and over the silt curtains that were installed there. The passage between Scrub Island and Great Camanoe Island has very strong currents (in fact they are so strong that they need to be documented as a potential site for generating pollution-free renewable energy using vertical axis turbines, which would be a good use for the two excellent recording current meters now sitting unused at the College). This is directly threatening  a prime snorkeling and diving reef (Diamond Reef) immediately across the channel to the south, and a designated Marine protected area ( Cam Bay) just across the channel to the North.  It should be noted that the isthmus between Cam Bay and Lee Bay is  national park.  The fattached map  shows that the west end of Scrub Island, where the massive development is underway (red circle), is located where the currents (red arrows) will carry the sediments and damage the excellent reefs (shown in green) that are so close to it. These two reefs are some of BVIs major ecotourism resources, and is just astonishing that such a poorly executed development could be allowed to imperil them, and that such developments are allowed in general without serious independent environmental assessment or a national policy to protect all coral reefs from being impacted by development. These two reefs have some good  coral cover and even more important they are some of the few locations remaining anywhere in the Caribbean where healthy elkhorn and staghorn coral ( now on the endangered species list in the USVI) are making a comeback. Diamond Reef is furthermore the site of the major long-term coral reef monitoring program in BVI.

Press release Feb 14th, 2007 on coalition

The B.V.I Fisherperson’s Association and Concerned Individuals for the Protection of Beef Island has formed an alliance with the B.V.I Heritage Conservation Group ( bvihcg.com ) in order to oppose the proposed developments for Smugglers Cove and Beef Island, the latter of which has been approved pending minor alterations. This coalition stands against these projects as they are not in keeping with good governance and are not in the interest of the people of the British Virgin Islands.

From a legal standpoint, the Beef Island development is clearly a violation of the law, having a direct impact on Hans Creek, Beef Island, which was declared a Fisheries Protected Area under the Virgin Islands Fisheries Regulations, 2003 s. 51(5)(b) which states, "No person shall carry out any development activity whether terrestrial or otherwise, which may or is likely to adversely impact on a marine protected area…". Hans Creek’s ecological significance has been scientifically established, functioning as an important nursery where 90% of the fish (outside of Anegada) are spawned.

Both the Smugglers Cove and Beef Island developments present significant environmental, social, and cultural problems. There will be a significant loss of bio-diversity due to the destruction of areas that support a large resident and migratory population of land and water birds, some of which are already globally threatened and endangered; chemicals for the golf course will pollute surrounding areas; and there will be sedimentation from storm water runoff, in particular, due to the destruction of the 10 acre Bluff Bay Salt Pond during the construction phase of the inner marina and the creation of the hotel island.

Contrary to the official views espoused, jobs for B.V.Islanders during the Beef Island development will be limited, due to lack of training and certification in vocational trades. It has been acknowledged that most of the labour will be imported from overseas, possibly India or China, which are favored by the developer. This rising population will further strain social services requiring more teachers, doctors and nurses, etc. Statistics show that 45% of applicants for primary and secondary schools were turned away because the schools were full, between 2002 and 2005. In addition to these facts, it is recognized that the value of real estate will rise, leading to a lack of affordable housing. Inflation will also rise.

Both Beef Island and Smugglers Cove have historical ruins which will be impacted by these developments. The Smugglers Cove development in particular will greatly alter the local people’s recreational use of the beach, with densely populated villas encroaching on the beach.

This coalition is calling for a moratorium on all large development projects in the territory, as is now the case in Anguilla where many of the same developments have been undertaken. These areas should be designated as National Parks, preserved for the coming generations of B.V.Islanders and visitors. There has been growing opposition to these developments from within and without the B.V.I, and this coalition invites the public to participate in protest against these developments. Several members of our group have met with the Governor and Chief Minister. Despite our efforts the Beef Island development has been approved pending slight alterations, with the Smugglers Cove development heading in the same direction. And so, we will gather on March 5th at Long Bay, Beef Island for a Family Day, where we can learn more about the development’s impact on Beef Island and rally support; on March 12th we will be at Smugglers Cove beach for another Family Day rally. There will numerous other protests scheduled between March 5th and 12th. For more info you can email preserve_the_bvi@yahoo.com

Letter to the editor, BVI Beacon, Feb 13th, 2007

Dear Editor,

With the headline, "Residents voice Opposition to Smugglers", people expected and, indeed, are entitled to know why there is protest concerning the development at Smugglers Cove. With the islands-wide headlong rush to high-end development and resorts, it was assumed some development would eventually come to Smuggler’s Cove. Given the small size, shape, and narrowness of the site, expected were 10 or so individual upscale villas well-designed, evoking a small West Indian village, and showcasing the BVIs unique and recognized architectural style in an eco-friendly manner. Villas would be tucked away and landscaped on acre lots in keeping with the surrounding houses and set back far off the beach maintaining easy access and use by all. A 5 star boutique resort on the scale and size of Sugar Mill was touted, yet what has been proposed is much denser than other 5 star resorts in BVI:

Biras Creek has 34 guest units on 140 acres, and Little Dix Bay has around 100 guest units on nearly 500 acres. Instead of a small upscale boutique eco-friendly resort theyd been led to expect, the community was shocked into the reality that Government is encouraging private local land to be sold to a speculative outside developer and signing away the rights to historic Government owned land. Here are just some of the stated issues and concerns raised by the public at the meeting, the only public hearing scheduled on this important topic.

A development agreement was signed without input from the people. The resort is to take up more than half the (the full) length of the quiet well-used local family beach, leaving just a small part available to the public. Yacht charter guests, guests of other hotels, and villa rental visitors, these being the bread and butter of traditional BVI businesses, the many many local families enjoying family outings, and church groups holding baptismal services and prayer meetings can not possibly fit on the remaining small public side. Throw in the cruise ship passengers, who will be encouraged by the upgraded roads, and there won't be room to sit down much less swim.

The agreement includes a 250 Ft. private dock which will, by default, be built on or near coral, fragile yet rejuvenating from previous damage and bleaching. The dock will jut into the coral reef rich with juvenile fish. It should be noted that coral reefs act as buffers from erosive wave action. Any responsible boat captain will warn, as several did at the hearing, the north swells in Smugglers Cove are unpredictable and particularly fierce during storms and will make the dock dangerous.

This agreement covers two blocks of land: parcel 2 is the 11 acre site owned/leased by the Denniston estate; parcel 268 is the 1.3 acre site owned by Belmont Estates Limited (not Belmont Owners Association). As displayed on the drawings, the proposed dock is sited on parcel #2s pebbly beach. However, the development agreement clearly states twice [para 2.10 and para 4.5] the dock is to be located on parcel 268 not parcel 2, as shown on the picture circulated by the applicant. This places the dock at the very centre of the swimming beach !!!!

While the developer cherry-picked his comments, asserting the project will be environmentally safe, the fine print of the Environmental Impact Assessment survey(EIA) indicates otherwise and states clearly on page 19 there are serious environmental issues with erosion, runoff, pollution and contaminants, the contention the author himself backed up in person. Boats in this small cove will raise serious risk to swimmers, perhaps even eliminating Smugglers as the last public family swimming beach on Tortola. Due to its low level, land around Smugglers is a wetland with a very shallow water table. A sewage treatment facility located there, no matter how technologically advanced, will be subject to strong natural forces as will any individual septic systems. 10 foot waves and surges are not uncommon in Smugglers during violent storms and hurricanes. More frequent are sudden outbursts with rain accumulations of 10-20 inches over a period of hours or days. Even the best technology will be no match against the power of Mother Nature (water weighs 10 pounds per lbs per imperial gallon at zero force level), pummeling the land from the sea and/or hillside. In the best circumstances and with the best intensions, ongoing day-to-day maintenance of a high-tech facility will be problematic and dependent on special parts prone to failure and skilled proactive human intervention. It is not a matter of "IF" the sewage treatment facility and/or septic systems will fail. It is a matter of "WHEN". Could be the first year, maybe the 5th or 10th but it will fail.

As noted in the EIA, at 65 dB (A), each generator, even "installed in an acoustic enclosure" will create as much noise as a city bus or large truck gunning its engine to climb a hill. At this level with an acoustic enclosure, the noise level will significantly exceed the recognized standards for residential areas which are below 55 dB (A) during the day and 45 dB (A) during the night. Given the steep bowl shape of the surrounding hillside, any and all noise will be amplified and reverberate throughout the estate.

Water, electricity, trash, sewage, construction accidents, noise are all issues in this small crescent shaped rural area.

The EIA also notes "In addition to noise, workers and guests should be protected against air emissions .nitrogen oxide, sulfur dioxide, and particulate matter emissions are usually the areas of concern". Recent studies and papers authored by the leading international network of climate scientists has concluded for the first time that global warming is "unequivocal and that human activity is the main driver" (New York Times Feb 2, 2007). We should be promoting sustainable energy at resorts and developments.

Traffic through Long Bay and around Steele Point through the ferry dock would jump from around 20-50 cars to a minimum of 266 cars daily on country roads- an increase ranging from 532 % to 1,330 % at a minimum!!! It was noted the traffic study was done during August and September of 2006 the slowest off peak time of the year and did not include traffic generated by groups such as resorts visitors who are there to use the spa or restaurant but not staying onsite among others.

Consider what West End, the ferry dock area, Apple Bay, and Long Bay will be like during peak season. Access roads are to be widened over land owned and/or improved by Belongers and residents at their own expense, wiping out their improvements and creating dangerous traffic situations. And there still wont be enough road way or parking to handle the increase in traffic volumes safely. The consultant stated he anticipates "conflict between vehicles and pedestrians" as a crucial issue.

The dock will allow entry from other islands without clearing normal Immigration and Customs and will invite boat moorings, and possibly illegal landings.Boats which will pump sewage into the now clear and clean water of Smugglers.

The hotel is to have its own shuttle to the ferry and airport, discouraging taxis. Taxis proudly owned and operated by hard working BVI residents forcing them to find other lines of work or to work for others, possibly the developer himself or an outside concessionaire of his choosing. Someone whose permit andtrade license has been fast-tracked per agreement by Government.

The off island contractor was given permission to build "temporary" affordable accommodations and "related facilities" for its migrant workers on site or near on Parcel 267, (the salt pond and palm grove area). As discussed in detail below, this site is part of the 2005 plan by Town and Country Planning proposal for a park or conservation area, running from Smugglers Cove to Black Rock on Long Bay. This parcel is home to an important Pre-Columbian Indian archeological dig, part of Tortolas heritage. The 18th century ruins on the site of the first phase of development were built by the blood, sweat, tears, and lives of BVIs ancestors. Who knows what other historical evidence and heritage is there under the surface to be forever buried under the villas and resort.

Rather than representing the West Indies and more specifically the elegant architecture the BVI is proudly recognized for, these villas and the entire resort will copy, exactly, the Balinese architecture chosen by the developer to further his global brand image. And it will set a precedent for the future as it will be the first time in BVI history its doors will be open to a chain, welcoming it with concessions such as allowing them to speculate and build on historic sites. The "brand-use" of proposed thatched roofing is inappropriate in Smugglers wet climate and will become host to rats, bats and rot, as attested to by another local estate.

More alarming, the developer was given "first refusal" for future expansion of the Resort or the building of a new Resort and related facilities, from Smugglers to Long Bay. This will mean the developer would control the northwest corner of the island up to the (densely populated) Long Bay Resort including the end of that beach as well. All the villas and suites are for sale, meaning the entire resort is being built as a speculative real estate venture which will be handed over to managers. Work permits for the outside laborers are to be fast-tracked (within 14 days), along with non-belonger landowners and trade licenses raising the likelihood individuals from other countries with dubious personal histories and/or criminal records will prey upon the good people of the BVI. Meanwhile, some responsible residents have been waiting for 8 years for theirs. These development agreements look like a grab for land and licenses benefiting outside investors and speculators, leaving residents in the dust.

Access to the development proposal and development agreement, as well as the Environmental Impact survey [and impact] statement was limited and few had the opportunity to see and read it prior to the meeting. Much of information contained in it is vague and/or based on assumptions which may or may not be complete or valid, raising more concerns. Had the documentation been more widely available, the meeting been allowed to continue with more public comments read into the record and/or additional meetings scheduled, there is a sense even more questions and concerns would be raised.

And finally, according to management plans developed by Town and Country in 2001, the area including Smugglers Cove, Belmont Bay, the salt pond, Black Rock, and the palm grove to the end of Long Bay were slated to be become a park system complete with bathroom facilities, retreat house, nature trails, beach activities and used for historic preservation, scientific, educational, and recreational purposes. As late as 2005, this management plan was reviewed, updated, and revalidated, identifying a combined park system of recreational, cultural, educational, scientific as the best use of the site for current and future generations. What happened in one short year? Why the sudden change of intention and best use? Why the rush?

All of our environmental assets that were pending protection are now at red-alert since our present powers dont seem to think the proposed park system merits any consideration in their development agreements.

Once Smugglers Cove, one of Natures Little Secrets, is gone, it will be gone forever. While it is recognized there is room for some development, the island has been stricken by a fatal disease eating all coastlines and the last few "hidden secrets". Only a local doctor with a holistic vision can save it from becoming St. Thomas or Cancun. That is what members of the public who were given the opportunity to speak said during the meeting and why there is much community comment, discussion and concern about the development.

Signed,

BVI Islands Heritage Conservation Group: Noni Mandisa Georges, Deanna Trott-Rubaine