On August 9th, 2009, the West End Development Corporation (WEDCo) was granted 61 acres of additional land by the Bermuda Government, primarily in the form of rent-free sea bed between the South Basin and Ireland Island South. Following the grant, the development of a multi-phased marina project, including nine acres of land reclamation and approximately 200 slips as well as support and club facilities, was approved by Cabinet on October 29th, 2009. As both a large-scale marina and reclamation project in a sensitive environmental area, a thorough Environmental Impact Assessment (EIA) is required under Environment Charter with the resulting Environmental Impact Statement (EIS) to be submitted as part of the planning application.It is our understanding that Bermuda Water Consultants (BWC), the same firm that was contracted to conduct the Dockyard cruise pier EIA, has been hired to produce an EIA for the proposed Cross Island Marina. This is a highly questionable decision as, not only was this firm never made to account for their previously inadequate attempt at an EIA for the Dockyard cruise pier and the substantial unnecessary costs to taxpayers that resulted, but it would appear that they are now being rewarded with a contract for similar work. Given the considerable environmental sensitivity of the area proposed for the Cross Island Marina, we anticipate that an appropriate EIA would provide indisputable evidence that the land reclamation and marina construction proposed should not take place at this site.Cross Island Marina –A Potential “Ecological Disaster”In a 2009 mapping study by the Department of Conservation Services, the Dockyard marine area, including the South Basin, was identified as having a species richness of between nine and ten on a scale of one to eleven. Only one section of the Island’s entire coastal region was found to be more environmentally sensitive. The environmental community has several important concerns regarding the proposed Cross Island Marina development, all of which would need to be scrutinised and addressed in a credible EIA and resulting EIS document. The three primary issues are as follows:Sea GrassDockyard’s South Basin contains all three types of local sea grass, in what is a healthy sea grass environment. This is important economically and environmentally for several reasons. Firstly, sea grass provides a nursery habitat for a number of commercially important species, such as juvenile groupers and spiny lobsters, as well as protected species, like seahorses and juvenile conch. In addition, the canopy of a sea grass meadow acts as a water filter, trapping particles and dissolved materials. This is an important function as it helps to maintain the high water clarity that enables Bermuda’s coral reef communities to thrive. In this way, sea grass helps to preserve two of Bermuda’s most significant tourist attractions: our clear waters and our coral reefs. Without the existence of such sea grass beds, sedimentation would likely increase with further negative effects for marine life.Another function of sea grass is to provide a foraging ground for juvenile green turtles, whose diet consists primarily of sea grass. In 2009, samplings of Bermuda’s turtle population were carried out at Stock’s Harbour in St. George’s and Dockyard’s South Basin as part of the ongoing Bermuda Turtle Project. Both samplings yielded a greater number of turtles than the Project’s average site sampling and, notably, Dockyard appeared to have more than double the average number of resident green turtles than other study locations frequented by the Bermuda Turtle Project. The construction of a marina at this location would not only destroy an important food source for green turtles, but would almost certainly increase the number of collisions between sea turtles and marine craft, which has been found to be a notable cause of turtle injury and mortality in Bermuda.In October of this year, plans for a marina at Stock’s Harbour were rejected primarily due to concerns over the destruction of sea grass habitats. Not only have the sea grass beds in Dockyard been found to be denser and more ecologically rich than those at Stock’s Harbour, but the proposed Dockyard development covers a much larger area of sea grass than the Stock’s Harbour plan. Based on the precedent set by the Stock’s Harbour decision alone, the plans for the Cross Island Marina should be rejected.Bird RoostingThe south jetty attached to Cross Island serves an important function as a roosting site for wintering gulls, shorebirds and terns. Predator-free roosting sites for gulls and shorebirds are rare in Bermuda and the Dockyard south jetty has traditionally been by far the most important for over a century. Most winters, up to 200+ gulls of nine species, 5+ terns of three species, and over 100 shorebirds of 4+ species use the jetty as both a day and night roost. As such, it has become an important location for visiting, as well as local, naturalists and bird watchers, which form a small but significant component of our ecotourism.The proposed Cross Island development connects both Cross Island and the south jetty to the mainland, as well as infilling a substantial marine habitat area on the inwards side of the jetty arm. Once connected to the mainland and developed in the manner proposed, this area will no longer be able to serve its key roosting function or act as a potential nesting site for terns. The Common tern nesting population is endangered in Bermuda, having ranged between six and thirty pairs over the past seventy years, and safe nesting islets are in short supply. As a result, retaining and enhancing the nesting potential of the jetty could be important to the conservation of the species locally.The only practical mitigation to preserve the area’s roost site and tern nesting potential might be to wall off the eastern half of the jetty against human access and predators such as dogs and cats. That portion of the jetty might then be upgraded in other ways to serve a nature reserve function. Any properly conducted EIA would address these issues and consult with local naturalists and NGOs, such as David Wingate and the Audobon Society, regarding suitable barrier design and location if any development here is to go ahead.Coral ReefsIn addition to the destruction of sea grass leading to reduced water clarity with consequent negative effects for the health of the island’s coral reefs, the proposed area of landfill looks to be sited directly on top of a reef cluster. As all corals are protected in Bermuda, this should pose a serious impediment to the proposal going ahead.Clearly, there are many relevant areas of concern that will need to be addressed prior to any work being undertaken in this area. Furthermore, given the extreme and significant environmental sensitivity of the area, we anticipate that an appropriate EIA would provide indisputable, documented evidence that the proposed land reclamation and marina construction should not take place at this site.Recommendations for EIA in BermudaWhile EIAs have been mandated for projects such as this by the Environment Charter for almost ten years now, Bermuda has yet to get the process right. As noted by the Department of Planning, the EIA process should form an integral part of a project’s planning and design stage and should not be regarded merely as a requirement for obtaining planning approval. The importance of a reliable procedure becoming firmly established is becoming increasingly apparent. Importantly, SDOs and retroactive planning approvals often make a mockery of the planning process, which is intended to protect Bermuda’s environment, economy and people.The Bermuda Environmental and Sustainability Taskforce (BEST) commends the production of the Department of Planning (DOP) Guidance Document (GN106) on Environmental Impact Assessments and Environmental Impact Statements. It is now the responsibility of the Government, led by the Department of Planning, to ensure that this framework is adhered to and to demand compliance to an appropriate standard. This should begin with widespread inclusion of stakeholders during the initial consultation, screening and scoping stages, independent review of the EIA/EIS, and further consultation during the final appraisal stage. Notably, the Government should be leading by example and, to ensure transparency and robustness of the system, all scoping documents should be made public once submitted.Without standards, and review of work to ensure compliance with these standards, EIAs are of questionable worth. Moreover, no competent environmental assessment body can compete in terms of price with an organization that is willing to cut corners and produce incomplete work. All planners in Bermuda are members of professional bodies that require them to produce comprehensive and defendable submissions. Such bodies allow members to submit reports for professional review and critique, which should be done in cases where reports are of a technical nature such that planners are not qualified to provide an informed assessment of the quality of the information.The requirement for independent verification of the standard of submitted work is essential for the health of the EIA process and for the development of a competent environmental consulting sector in Bermuda. The mechanisms for this are already in place and, given recent experience and further potential for costly and detrimental environmental effects where proper EIAs are not conducted, tough sanctions should be imposed on responsible parties where standards are not met.ConclusionsWithout a suitable EIA, the potential exists that the construction of the Cross Island Marina will lead to significant environmental damage and further waste of public funds. As a result, the proposal should undoubtedly be subjected to a reputable, independent and adequately budgeted EIA/EIS process, at the very least in order to meet Bermuda’s obligations as a signatory of the UK Environment Charter.One of the requirements of the EIA/EIS process is to offer an explanation of the main alternative options considered, including alternative site locations and a comparison of the potential environmental effects. It is our understanding that this was not done as part of the initial scoping document for the marina, despite that several more suitable locations exist in terms of both environmental sensitivity and natural shelter. Locations such as St. George’s Harbour or Morgan’s Point, for example, have already suffered negative environmental effects as a result of development and consequently have relatively low current species richness ratings of between three and six, or less than half that of Dockyard’s South Basin.These are also likely to be more viable options for the type of mega yacht community proposed given the potential conflict between, and differing demands of, cruise ship passengers and mega yacht owners. Additionally, one must question the attraction of the Cross Island site for wealthy mega yacht owners given the 100 low income housing units proposed as part of the same development. Finally, WEDCo should not be allowed to commence any major development until all conditions of prior planning approvals have been acceptably fulfilled. This includes providing evidence that the Dockyard cruise pier Interim Monitoring Programme meets all DAB stipulations and waiting until a suitable Long-term Monitoring Programme is in effect.Reputable, independent and adequately budgeted environmental assessments are key to maximizing the benefits of the planning process and resulting developments. Given the multiple economic, social and environmental benefits afforded, a properly scoped and evaluated EIA, including full stakeholder consultation, should be a standard ingredient for any major project, whether terrestrial or marine.Along with firmly establishing a transparent, thorough and independently reviewed EIA process, the appropriateness of SDOs and retroactive planning applications should also be both seriously considered and firmly resisted. The Bermuda Environment and Sustainability Taskforce (BEST) has previously called for mandatory rather than discretionary Environmental Impact Assessments for projects such as this. BEST plans to hold workshops for stakeholders and the public on both EIAs and SDOs in the near future.