In a joint submission to the Environmental Management Authority, 19 civil society organisations have challenged several conclusions of the Environmental Impact Assessment on the government’s proposed Toco Port Project. The organisations’ concerns were submitted to the EMA on May 22 following the groups’ internal review via webinar of the EIA which was out for public comment. The EIA was conducted by ERM West Inc, a US-based environmental engineering consulting firm.
In the detailed submission, the CSOs argued that the proposal for the Toco Port is inconsistent with the Vision 2030 National Development Strategy which places the environment at the centre of social and economic development. Citing “critical misrepresentations and shortcomings” in the EIA’s assessment of the biodiversity and eco-systems on the North-east coast of Trinidad and the wider Caribbean/Atlantic marine environment, they urged the EMA to apply the Precautionary Principle in the National Environmental Policy (NEP) in their deliberations on the granting of a Certificate of Environment Clearance to the Port project. The NEP requires the government to “adhere to the principle that if there are threats of serious irreversible damage to humans or the environment, lack of full scientific certainty will not be used as a reason for postponing social and environmental safeguards.”
The CSOs went on to challenge the selection of Toco for a port noting that the feasibility study on which it is based was done 32 years ago and that even then, the pros and cons of a port at Toco had been weighed without definitive recommendation. They declared that “Civil Society rejects development planning based on antiquated data.”
Noting that more recent studies contradict the idea of locating a port at Toco, the CSOs cited the ‘Vulnerability and Capacity Assessment Report Trinidad and Tobago (2019)’ conducted by the government with support from the European Union. That report projected a rise in sea-level and increases in extreme weather events and storm surges until 2100 and went on to identify the Sangre Grande/Toco/Matelot areas as “vulnerable to damage to access roads and major roads and transportation links like marinas, Ports, jetties and sea defences and offshore industrial, residential infrastructure, utilities, industrial facilities and plants.” In this context the NGOs queried the EIA’s assessment of the impact of climate change on Toco and the design of infrastructure.
The CSOs also expressed scepticism about the government’s stated purpose of the port for a ferry service saying a detailed review of its scale suggests it is “way oversized for that.” They went on to question whether it is in fact intended as a bunkering facility for refuelling oil and gas tankers, adding that it would not support such a project. “These facilities are already established in the South of Trinidad. It does not make ecological sense to extend such facilities into the relatively pristine Northern Range, where no other large fossil-based infrastructure exists.”
The CSOs also disputed the adequacy of the baseline studies used in the assessment noting that key elements of the baseline – Marine Ecological Surveys and drop camera surveys – were significantly hampered by low water clarity and high wave action during the period that the primary baseline studies were conducted.
On the issue of infrastructure the CSOs questioned the project’s mitigation plans for the projected traffic increase of 80-100 percent during the project’s construction phase and thereafter. Given the potential impact of additional heavy vehicles on the already deplorable road conditions, the CSOs expressed concern about the imoact on the residents.
Toco community’s water supply was also raised as a source of worry given the current shortage of freshwater and the potential worsening of the situation by the ratcheting up of demand by the proposed port. The CSOs contended that the mitigation plan for addressing this problem through negotiations with WASA and rain harvesting tanks does not take inti account climatic predictions of “severe water stress, reduction of rainfall and increased saltwater intrusion into nearshore aquifers.”
The CSOs raised concerns about the EIA’s waste disposal plan noting that the proposed waste management system focuses on non-hazardous waste and is not equipped to remove hydrocarbon, heavy metal, and other non-human waste that will be produced. They dismissed its stormwater plan as reactive and not proactive, with unrealistic sampling regimes.
Commenting on the socio-economic impact of the proposed port project on the area, the CSOs raised concerns about the proposed highway to facilitate the port noting that it will require the relocation of many residents along the roadside and in villages with a disruption of the subsistence and fishing economies on which their livelihoods depend. “The EIA does not give enough consideration of how these livelihoods will be sustained into the future,” said the submission.
The group of CSOs also criticised the absence of “planned opportunity, process or training” to help small businesses to capitalise on the assumed opportunity” and pointed out that while 90 percent of the workforce for land construction will be local, 60 percent of the higher-paid jobs requiring greater skills during the marine construction phase will be filled by non-nationals.
Addressing the question of whether the proposed Toco is worth the cost for Trinidad and Tobago, the CSOs pointed out the absence of a rigorous Cost-Benefit analysis noting that the assumptions rely on an analysis done 30 years ago. They insisted that the EIA be accompanied by current Cost-Benefit analyses and demanded evidence of the economic logic of the project. Further, given the value of the natural capital in the unspoilt North-eastern area of Trinidad, the CSOs queried the basis on which the EIA had assessed the loss of natural capital in determining the socio-economic impact.
In closing off their comment on the EIA, the CSOs questioned the value of any capital expenditure, during the COVID pandemic recovery and with a looming global recession, on investments that do not deliver broad-based economic, social and environmental benefits, adding: “At all times, but especially now, the spending of public funds on these mega-projects should be excessively interrogated – even if it takes time.”
Civil Society Signatories
- Acono Village Dynamic Action Committee
- Caura Eco Protectors
- Caura Valley Village Council
- Council of Presidents for the Environment
- Environment Tobago
- Fishermen and Friends of the Sea
- Fishing Pond Farmers Association
- Lloyd Best Institute of the West Indies
- Lopinot Tourism Association
- Maracas Valley Action Committee
- The Cropper Foundation