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Review of the Bahia Principe Hotel Resort Development EIA Report

Development for Pear Tree Bottom, St. Ann, Jamaica

Shonnette Lowman, ID # 0601242. Bachelor of Science in Construction

Management 2010-2011, Faculty of the Built Environment, University of Technology,

Jamaica.

Craig Williamson, ID # 0703982. Bachelor of Science in Construction Management

2010-2011, Faculty of the Built Environment, University of Technology, Jamaica

Michael Mitchell, ID # 0505911. Bachelor of Science in Construction Management

2010-2011, Faculty of the Built Environment, University of Technology, Jamaica.

Kathena Moultan, ID # 0600966. Bachelor of Science in Construction

Management 2010-2011, Faculty of the Built Environment, University of Technology,

Jamaica.

Donald k.Gayle, ID # 1006442. Bachelor of Science in Construction Management

2010-2011, Faculty of the Built Environment, University of Technology, Jamaica.

Patrick A. Reid, ID # 9612298. Bachelor of Science in Construction Management

2010-2011, Faculty of the Built Environment, University of Technology, Jamaica.

Kerry-Ann Wedderburn, ID # 0503304. Bachelor of Science in Construction

Management 2010-2011, Faculty of the Built Environment, University of Technology,

Jamaica.

Introduction
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In carrying out this Environmental Impact Assessment (EIA) report review we

aim to investigate how credible and sufficient the information submitted in the report is.

It is also our objective to make a decision as to the satisfactory performance of the

Bahia Principe Hotel Resort Development EIA Report (Bahia EIA Report). The

approach taken to the EIA report review is the one outlined in the National Environment

and Planning Agency (NEPA) Draft EIA Report Review Manual, and is an adaptation of

the Lee & Colley (1990) Review Criteria for Environmental Statements. This Lee &

Colley (1990) approach has helped us greatly to assess the quality and completeness

of the information presented in the Bahia EIA Report and we were quite able to easily

make an overall judgment of the suitability of this report as a planning document.

The tools for conducting an EIA report review as outlined in section 2 of the

NEPA EIA Report Review Manual proved to be quite helpful in allowing us to meet our

objective. In strategizing, we did not embark upon a process of trying to contradict or

object to the truthfulness of the findings of the report. Instead, our group tried to

identify the baseline assessment, strengths and weaknesses, omissions inaccurate

supporting data or even errors in the report. It is the appropriateness and quality of the

report and not the volume of information provided that was given our thorough scrutiny.

This approach greatly enhanced the quality of the decision making process and thus

our final decision.

Project Description

The following project description was extracted from the EIA report in question:

“The Client, Hoteles Jamaica Piñero (HOJAPI), intends to build a 1,918-

room resort development (three hotels) on 34 hectares (80 acres) of

coastal land, part of 80 ha (198 ac) of tract of land at Pear Tree Bottom,
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just west of Runaway Bay, St. Ann (Figure 1.1). The development site lies

immediately north of the North Coast Highway. The project is to be carried

out in three phases, each involving the construction of a hotel. This

document presents the Environmental Impact Assessment (EIA) of the

proposed resort”.

Baseline Assessment

According to the NEPA Draft EIA Report Review Manual; Section 1: page 11,

review category 1.3 and review sub-categories 1.3.1 to 1.3.2; “baseline conditions

requires presenting a description of the affected environment as it is currently

and as it could be expected to develop if the project were not to proceed”.

After analyzing the Bahia EIA Report our group concluded that a baseline

assessment was not included in the report. ‘The probable future state of the

environment in the absence of the project, taking into account natural fluctuations and

human activities’, was not addressed by the Bahia EIA Report. This act is in total

violation of Task 2 of the Terms of Reference provided by NEPA.

A very large volume of data outlining the existing environmental and project area

conditions were presented from page 16 to page 76 of the Bahia EIA report. This

project area description, although spanning sixty (60) pages, failed to deliver a baseline

assessment. Under Section 3.8.3 Beach - on page 48, the report mentioned that

“illegal sand mining has been reported from Pear Tree Bay in the past. Evidence of

further sand removal was observed (Plate 3.8.3.1) during a site visit on 2 February

2005”. However the report failed to assess the probable future state of the

environment on this beach in the absence of the project.

Plate 3.8.3.1 Sand stealing from beach at Pear Tree Bay.

Strengths and Weaknesses of the Bahia EIA Report

The Bahia EIA Report was evaluated using the review criteria as outlined on

pages 11 to 17 of the NEPA Draft EIA Report Review Manual. The report was found to

be strong in certain Review Areas, Review Categories and Review Sub-categories. The

report was deemed to be strong in the following significant sections:

a) 1.1.1 – The regulations, standards and guidelines applicable to the

project were referred to and reference to applicable regulations and

guidelines were made in the report.

b) 2.1 to 2.3.1, except 2.1.2 – Key environmental and socio-economic

impacts were identified and evaluated. A systematic methodology; that

of a very exhaustive matrix, was used. A list was compiled including all

the direct and indirect effects, cumulative, short, medium or long term

effects, permanent, temporary, positive or negative effects on the project.

The report was deemed to be very weak in the following significant sections:
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a) 1.2.1 – The purposes and objectives of the development were not

explained. The Executive Summary outlines what the developer intends

to build but does not adequately explain neither the purposes nor the

objectives of the development. The Introduction is likewise lacking, it only

states the purpose of the EIA Report. It is significant to note however

that the Terms of Reference provided by NEPA did not out-rightly

require this explanation.

b) 2.5.2 – The impacts of the proposed project on the socio-economic

environment were not adequately analyzed. It is significant to note

however that the Terms of Reference provided by NEPA did not out-

rightly require this explanation.

c) 3.1.1 – No alternative sites were considered in the EIA Report. This very

important task was not attempted whereas the Terms of Reference

required a detailed discussion on the main environmental advantages and

disadvantages of these alternative sites. Only an “adjunct” to the land use

was mentioned on page 106 of the EIA Report.

d) 6.1.1 to 6.1.2 – As far as the documents that we have consulted showed,

the involvement and visions of Non-Governmental Organizations (NGOs)

and citizens within the communities were totally neglected. No mention of

community input or of NGOs was found in the Bahia EIA Report despite

the fact that this was specifically required under Task 8 in the Terms

of Reference.
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Evaluation Criteria

The evaluation criteria that were employed were those found on pages 11 to 17

of the NEPA Draft EIA Report Review Manual. The process of review was conducted

in a four (4) step approach as outlined on page 3 of the said manual, namely;

1) Determine the compliance of the report with the Terms of Reference

2) Identify the deficiencies, if any, in the EIA report using the review criteria

and a review of any comparable EIA reports and their reviews

3) Focus on any crucial shortcomings observed in the EIA report and

determine which shortcomings are so crucial that they directly influence

the decision

4) Recommend how or when any serious shortcomings should be remedied

to assist decision-making and improve its implementation.

After following the four (4) step approach as outlined above it was concluded

that the Bahia EIA Report displayed crucial shortcomings in certain very important

aspects of the following review areas:

 1.0 – Description of the development, the local environment and

the baseline conditions.

 2.0 – Identification and evaluation of key environmental and socio-

economic impacts

 3.0 - Alternatives

 6.0 – Public / Community Involvement

The four above-mentioned shortcomings were so crucial that they directly

influenced the decision. Reviewers’ comments on specific review categories and

review sub-categories are inserted in the collection sheets found on pages 23 to 33 of

the NEPA Draft EIA Report Review Manual.

It may be noteworthy to note that our findings suggest that the Terms of

Reference provided by NEPA were not in the best interest of protecting the

environment nor enhancing community visions. Certain crucial environmental concerns

were not directly mentioned in the terms of reference.

Decision and Recommendations

Based on the findings of our evaluation we hereby assign the assessment

symbol ‘E’ to the Bahia EIA Report. It is in our opinion that the work was not

satisfactory whereby very crucial tasks were either poorly done or not attempted at all.

The report performed unsatisfactorily both with respect to the minimum requirements

and the broad compliance areas.

It is hereby recommended that Remedial Option 1 be embarked upon in order to

remedy the crucial shortcomings. The following wording of Remedial Option 1 was

extracted from the NEPA Draft EIA Report Review Manual, page 20;

“The shortcomings of the EIA report are so serious that they require

immediate remedy in the form of a supplement to the EIA report or a new EIA

being undertaken by a different more competent team”.

Additional information forming the supplement or the new EIA must be collected

using the same on-site study team approach plus any additional information which may

be available in local archives or internationally. The acquired information should be

presented in the same format that is now employed in the existing

Conclusion

The approach taken to the EIA report review, as outlined in the National

Environment and Planning Agency (NEPA) Draft EIA Report Review Manual, is an

excellent approach to use in evaluating EIA reports. It effectively facilitates quality

assessment and also completeness assessment of the information presented in EIA

reports.

The tools for conducting an EIA report review as outlined in section 2 of the

NEPA EIA Report Review Manual helped us to identify very crucial tasks that were

either poorly done or not attempted at all. We were aptly equipped to conclude that the

work presented in the Bahia EIA Report was unsatisfactory.

The Terms of Reference provided by NEPA were not in the best interest of

protecting the environment nor enhancing community visions. Certain crucial

environmental concerns were not directly mentioned in the terms of reference. What

was required in the terms of reference was way below the standards that NEPA

professes to uphold. We are convinced that NEPA was ‘in bed with the developers’.

Even when certain crucial tasks were clearly outlined in the Terms of Reference no

attempt was made to addressee these in the EIA report.

The shortcomings of the present EIA report are partly due to the inconsistencies

in NEPA’s standards. These shortcomings are so serious that they require immediate

remedy in the form of a supplement to the EIA report or a new EIA being undertaken by

a different more competent team.

References

Draft EIA Report Manual, (2004). National Environment and Planning Agency
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Environmental Impact Assessment (2005) Bahia Principe Hotel Resort Development,

Pear Tree Bottom. St Ann, Jamaica Retrieved From:

http://www.environmentalsolutions.com/bahia_principe-runawaybay Retrieved

On: February 18,2011.