No Waterpark At Graeme Hall

NO SPLASH AT GRAEME HALL

(Why building the Caribbean Splash Water Park at Graeme Hall is a bad idea)

TABLE OF CONTENTS

1. Executive Summary

2. Is a Water Park a good idea for Barbados?

3. Why the proposed location in the Graeme Hall Watershed is a bad idea.

4. Drawbacks and omissions of studies to date.

A. The Impact Study is incomplete.
B. Failure to recognize that a watershed is an interdependent zone. (Failure to acknowledge that toxic waste flows downhill)
C. Failure to deal with or ignoring the treatment and dispersal of toxic waste
D. Failure to discuss medical, health, and emergency management issues
E. Failure to discuss Barbados’ agreements to conform with all international environmental standards, treaties and agreements?
F. Failure to consult with downstream and adjacent neighbors
G. Omissions and Inconsistencies which Tend to Mislead
H. There is no plan to cope with the mess if Splash fails

I. South Coast Sewerage Project emergency analysis

J. A Petting Zoo?

5. Why not other locations?

1. EXECUTIVE SUMMARY

Q. Is a Water Park for Barbados a good idea?

A. Yes. It will provide entertainment for tourists and Barbadians, as well as jobs.

Q. Is the proposed location for Caribbean Splash in the Graeme Hall area a good choice?

A. No. It is all wrong.

– Valuable agricultural land will be lost
– It will cause traffic problems
– It is too noisy
– There is not enough water
– It will destroy housing values
– the chemicals involved are toxic
– there is no plan for if it fails
– It is contrary to the Graeme Hall National Park Watershed Management Plan, and conflicts with many other scientific studies performed over the past 30 years.

Water parks are busy, noisy, and incompatible with preservation of Barbados’ most important wetland and bird sanctuary. The proposed location for Caribbean Splash is upstream from residential housing and Graeme Hall Nature Sanctuary. These will, in time, be harmed by the toxic chemicals (brine and chlorine) from the water park.

Q. Are there other locations which will better serve the needs of Barbados and Caribbean Splash with minimum negative impact.

A. Yes. There are better locations.
2. Is a Water Park for Barbados a good idea?

Yes. A water park for Barbados, if located, built and operated responsibly, would be enjoyed by many Barbadians and tourists. There are over 900 water parks in the United States alone serving millions of people every year. Proprietary water park technologies have further evolved beyond slides and wave machines such as those at Disneyland’s Typhoon Lagoon in Orlando, Florida, to include stationary surf waves and moving reef waves by companies such as Waveloch, Inc. in California. The latter technologies are found at many of the most sophisticated water/surf parks around the world, including the United States, Canada, Europe, South Africa, and elsewhere.

Caribbean Splash will create training and employment opportunities for dozens of Bajans. The challenge will be to differentiate this park from the many that are located around the world in such a way that more tourists will visit Barbados.

3. Why the proposed location in the Graeme Hall Watershed is a bad idea.

Is the proposed location for Caribbean Splash in the Graeme Hall area near the Graeme Hall Environmental Heritage Site a good choice?

No. While the idea of a well-designed, well-managed water park in Barbados is a good idea, the proposed location within the Graeme Hall Watershed and near the Graeme Hall Environmental Heritage Site is not.

The proposal prepared by Coastal Engineering for Caribbean Splash is preliminary and void of crucial data which would show that a water park will cause insurmountable and irreversible problems if it is located in the Graeme Hall Watershed.

The Graeme Hall National Park Watershed Management Plan makes it clear that in the short run there is no logic to adding any more development in the Graeme Hall Watershed until further studies are done. And what is already known makes it clear that in the long run the Watershed cannot accommodate a water park.

A water park in the Graeme Hall Watershed will cause the following problems which the Coastal Engineering Study does not address properly or at all

– Valuable agricultural land will be lost. This is contrary to government policy which seeks to preserve agricultural lands so that Barbados can become more reliant on producing it own food.
– It will cause traffic problems by adding to existing congestions. If no roads are to be added things will only get worse.
– It is too noisy. It promises to double the noise level in the community for 12 hours a day.
– There is not enough water. Barbados is already short of water yet this water park promises to consume more. If this amount of water is available it would be better to use it to sustain residential housing growth.
– Noise, additional traffic, and added crime potential will destroy housing values.
– The chemicals involved are toxic. Chlorine and brine will kill wildlife and vegetation downstream. No matter what is promised we all know accidents happen and these chemicals will end up in the soil and in the Graeme Hall Wetlands, killing fish, birds, and plants.
– The Coastal Engineering proposal does not mention economic failure of the proposed project. If the water park fails, who is responsible for removing the eyesore? There is no plan for this which means that Barbados will be left with a highly visible, environmentally unsafe, wreck on land which is owned by the Government. The Government will be left to deal with the mess.
– It fails to deal with important issues which still have to be studied. These are discussed in the Graeme Watershed Management Plan.

The Graeme Hall Environmental Heritage Site is a national legacy and encompasses the last significant wetland and migratory bird site in Barbados. The majority of the lands within the Site are owned by the Government of Barbados, with a smaller portion (35 acres) owned by the Graeme Hall Nature Sanctuary.

The Government of Barbados and Graeme Hall Nature Sanctuary have worked long and hard to achieve a special environmental status for the Sanctuary and part of the wetlands that surround it so that this important area will be preserved for use and enjoyment by future generations.

This was manifested recently when the government of Barbados concluded treaty negotiations to include 33 hectares of wetlands in Graeme Hall as an internationally designated wetland (RAMSAR designation) which means it is recognized under the Convention on Wetlands. The Graeme Hall area is respected around the world as an important area that should be left to be developed in an environmentally sound way so that its unique characteristics can be enhanced and protected.

Developments adjacent to the Environmental Site and its buffer, as defined by the ARA Study and supported by other studies conducted over the past 35 years, directly affect the health and welfare of the Graeme Hall Environmental Heritage Site. Shared by agriculture and low-density residential development, area is a prime example of why the area around a sensitive natural habitat must be zoned and maintained at low densities to minimize polluted runoff, noise generation, traffic and other disturbances.

In fact, the Environmental Heritage Site is already showing major signs of significant stress from polluted urban runoff, with water quality readings confirming an ongoing polluted main lake and waterbody system.

The Government of Barbados and the Graeme Hall Nature Sanctuary share a dilemma within the 117-acre Graeme Hall Swamp Environmental Heritage Site, its Buffer Area, and the sensitive upland lands near the ABC Highway: These combined lands are located at the lowest point of the Graeme Hall Watershed, and they do not readily drain to the sea. This means that the effects of pollution are cumulative within the Site – and are compounded by already limited freshwater aquifer supplies, as well as polluted stormwater, agricultural fertilizer, pesticides, emergency sewage dumps from the South Coast Sewage Plant, and other illegal wastewater and grease trap overflows.

All of these, singly and combined, threaten the survival of the Graeme Hall Environmental Heritage Site.

The proposed development should be implemented in a more commercial area that is not within or adjacent to a sensitive environmental site or near residential neighborhoods.

4. Drawbacks and omissions of studies to date.

A. The Impact Study is incomplete.

Caribbean Splash Inc. hired Coastal & Environmental Engineering Solutions, Inc. (Coastal Engineering) to prepare an Environmental and Social Impact Assessment (Impact Study) for the proposed location. Unfortunately this impact study is deficient in many respects. Not only is it based on incorrect or incomplete assumptions but it also fails to take into account a number of important factors. The conclusions it draws are not based on accepted scientific research and are in many aspects simply wishful thinking.

Coastal Engineering first prepared an Impact Study in October 2005. It states that it then circulated this study to all relevant government departments for comment and then prepared a Supplementary Study dated March 2006. Both the Impact Study and Supplementary Study have not yet been published in the public domain. Instead, a copy of each has been filed with the Barbados Library System to be reviewed under strict conditions where no one is allowed to have copies but rather must read the original in the library. No copies have been published and in fact Coastal Engineering have stated that the filed copies are neither complete nor final. This curious procedure has made it difficult to fully analyze these studies however it is clear that the project has not been fully thought through and further study and analysis is required.

What follows is therefore a critique which is hampered by limited access to what is acknowledged to be an incomplete study. A more complete analysis will be achieved if and when these deficiencies are rectified and a comprehensive study is published and made available to the general public.

B. Failure to recognize that a watershed is an interdependent zone. (Failure to acknowledge that toxic waste flows downhill)

The Impact Study claims that the boundary of the Graeme Hall Swamp Environmental Heritage Site is 750 metres to the southwest of the Caribbean Splash site and concludes that the sensitive Graeme Hall wetland is NOT an “environmental component of concern?”

This position stated in the Coastal Engineering Impact Study ignores that a watershed is like a sink. Everything in it flows downhill and, in the case of the Graeme Hall Watershed, ends up in the Graeme Hall Wetlands, which is th lowest point in the watershed. If this comment in the Impact Study is designed to eliminate or reduce public perceptions that the proposed location for the water park may negatively impact the Graeme Hall wetland it is misleading. This topic will be discussed below under the heading ‘Omissions and Inconsistencies which Tend to Mislead’ and is all the more of a concern if it was intentional in that an important and fundamental fact is being trivialized.

The truth is that the proposed the water park would be located within the sensitive Graeme Hall Watershed, and adjacent to the Graeme Hall Swamp Management Buffer Zone, which is in turn directly adjacent to the Environmental Heritage Site. The Buffer Zone includes Ministry of Agriculture lands.

The Graeme Hall Swamp Management Buffer Zone is illustrated in the 1997 ARA Barbados Tourism Development Programme, Subprogramme C, Part 1, Figure 2-1, and Part 2, page 11-1-3.

Incidentally, the US $800,000 ARA Study was funded in large part by the Inter-American Development Bank, and is the most comprehensive text produced to date concerning preservation, development and management of the Graeme Hall Swamp area, including buffers.

In addition, the ARA Study was brought to the attention of the CEES consultants during their survey period. The ARA Study is not in their list of EIA reference documents.

C. Failure to deal with or ignoring the treatment and dispersal of toxic waste

As discussed below the only realistic supply of the 47,000 gallons of non potable water that is required to operate the water park (which is in addition to the 75,000 gallons of potable water) is to construct a desalination plant on the premises designed to treat 94,000 gallons of salt water. After treatment of the water that means there will be the need to dispose of 47,000 gallons of brine per day. The Impact Study acknowledges that the Barbados Water Authority will not or cannot deal with 47,000 gallons of brine in that location and therefore plans to dump the brine into a brine well within the Graeme Hall Swamp Management Buffer Zone.

Brine is a toxic waste product. It will kill plants in the Graeme Hall Watershed and severely alter the ecosystem and result in death to many of the species of flora and fauna that are unique in Barbados. (additional information about the specific toxicity of brine is available)

The Impact study is almost silent on the issue of the deleterious effects and dangers of creation and disposal of brine immediately upstream of a closed wetland. The sensitive hydrology in the Graeme Hall Watershed is understood at least to the extent that it is known that 17,155,000 (17.155 million) gallons of brine being dumped into the sensitive watershed will be fatal to its continued existence and the efforts to ensure its legacy for future generations of Barbadians. There is no doubt that fresh groundwater can be affected by subterranean pumping of both saltwater and freshwater, and while the Coastal Zone Management Unit is actively studying the hydrology of the Watershed under the Graeme Hall Environmental Stewardship Programme, much more scientific assessment is needed to ensure that the area will not be poisoned or ruined.

The Impact Study fails completely in its analysis in this area. It offers nothing in the way of scientific evidence to support its claim that pumping 94,000 gallons per day of seawater will not affect sensitive environmental areas, or affect irrigation wells located on Ministry of Agriculture lands. The Impact Study tries to overcome this glaring deficiency by engaging in a discussion of available capacity, but there is no discussion about how extraction of seawater from below the existing brackish and freshwater lenses will affect the environmental integrity of the Watershed, and the wetland nor is there any evidence to support its assertions.

There is no scientific or environmental protocol for dumping brine discharge into a wetland aquifer, or a wetland that is a relatively closed site, without positive daily interactive estuarine flushing action with the sea. All contaminated discharges into the Graeme Hall Watershed, both above and below ground, ultimately flow into the Graeme Hall Environmental Heritage Site and the wetland. Based on initial hydrology studies articulated in the 1997 ARA Barbados Tourism Development Programme, Subprogramme C, surface and subterranean stormwater and other flows originate at the higher agricultural uplands and the freshwater springs and flow to the main lake located on Graeme Hall Nature Sanctuary property, before flowing out to sea via the bisecting canal.

Granting permission for an additional pollution sourcepoint, such as brine, upstream of the Environmental Heritage Site, is inappropriate and inconsistent with maintaining a healthy wetland. According to the Journal of Contemporary Water Research and Education (2005), the environmental issues of desalination are significant. For example, if the sourcepoint of groundwater for a proposed desalination plant contains “low levels of dissolved oxygen and high levels of other gases such as carbon dioxide and hydrogen sulfide (will) contribute to the toxicity of (brine) concentrate….This fact somewhat validates the hypothesis that groundwater characteristic may influence the ion toxicity of (brine) toxicity from desalination plants.” (Toumos, Virginia Polytechnic Institute and State University)
These contaminants accumulate over time. In fact, the main 10-acre lake at the Graeme Hall Nature Sanctuary is the lowest point in the Graeme Hall Watershed, and already shows significant accumulations of pollutants from surrounding communities. From water quality testing done by the University of the West Indies and others on waterbodies within the Graeme Hall Environmental Heritage Site, pollutants include abnormally high levels of faecal coliforms from human sewage from surrounding communities and the South Coast Sewage Treatment Plant, high nitrogen from fertilizer and other runoff, corresponding low oxygen concentrations, high turbidity, and concentrations of carbon dioxide and hydrogen sulfide.

D. Failure to fully disclose medical, health, and emergency management issues
There are over 900 water parks in the United States. On average, 15,000 people are rescued each year in water attractions, 10,000 of those are under 12 years of age. While deaths are rare in water parks, water-borne diseases and infections are a concern. In particular, Cryptosporidium resists chlorine treatment and can cause severe diarrhea, and there have been large scale outbreaks of water borne illnesses in various water parks internationally.
The Impact Study fails to deal with the establishment of an infrastructure to deal with the realities that there can be serious medical and health related problems resulting from the Operation of a Waterpark and that facilities and emergency actions plans must be set up at the outset, even during the construction phase.

Will there be an increased requirement for government-funded police response teams?

Yes. Informal discussions with police personnel indicate that they would expect a significant increase in patrols required for the proposed water park given the anticipated volume of young people, and the fact that it would be a natural gathering place causing potential increased impacts on adjoining residential neighborhoods. No increase in police or health response team budgets are anticipated to accommodate the Caribbean Splash proposal.

E. Failure to discuss Barbados’ agreements to conform with all international environmental standards, treaties and agreements?

Barbados has signed a number of treaties and agreements and it will require that Caribbean Splash’s proposal comply with all of them. However this is not discussed and a preliminary analysis indicates that what is set out in the Impact Study and the problems with the proposed location will fun afoul of many of their provisions.

Any proposed desalination discharges and contaminated wastewater discharges that bypass the South Coast Sewage sanitary sewer system and enter the Graeme Hall Swamp Management Unit and Environmental Heritage Site could result in violations of terms and conditions of international environmental Conventions to which the Government of Barbados is a party, specifically the Convention on Wetlands, Convention on Biological Diversity, and the Environmental Terms of Reference specified by the Inter-American Development Bank.

The Government of Barbados is under particular pressure to ensure that it protect and manage its freshwater supplies. According to the Inter-American Development Bank, Barbados is within the top fifteen countries worldwide with the scarcest freshwater supplies. Additional inland pumping of either freshwater or seawater for desalination is particularly critical to the stability of the aquifer underlying the Graeme Hall Environmental Heritage Site.

F. Failure to consult with downstream and adjacent neighbors

A recent outcry demonstrates that the so called survey carried out by Coastal Engineering was flawed and misleading. There is little, if any, public support in the Graeme Hall area for the Caribbean Splash project.

Has Graeme Hall Nature Sanctuary, Inc. given permission to the Barbados Water Authority or any other Watershed occupant to dump emergency sewage or other contaminates into its main lake?

No. Fresh water and a natural healthy ecosystem are the primary reasons why the Sanctuary stays in business. Cumulative and periodic contamination of the Sanctuary damages not only the ecosystem, but damages business as well.

Under the terms of the Marine Pollution Control Act, the last private landowner to hold and discharge polluted waters to sea is liable for said pollution. Even though the Sanctuary is not a pollution sourcepoint, added pollution from the water park could incur additional liability on the Sanctuary.

G. Omissions and Inconsistencies which Tend to Mislead

a) 1997 ARA Barbados Tourism Development Programme (The ARA study) is not referenced or discussed anywhere in the Impact Study.

b) Government studies and opinions have been ignored.

The Ministry of Energy and Environment, as well as the Ministry of Agriculture and Rural Development, have formally objected to the proposed Caribbean Splash, Inc. water park location at Graeme Hall, and have found the Environmental Impact Assessment for the project to be unacceptable. Specific objections from the Environmental Impact Committee, consisting of the Environmental Unit, Coastal Zone Management Unit and the Environmental Protection Department, were filed on January 12, 2006.

c) Noise issues are glossed over in the Impact Study by the simple device of speaking only of decibel levels. Noise is an important consideration emanating from the day to day operation of a Water Park. The Impact Study fails to tell the reader that the noise levels will be at least double existing levels.

Noise is a factor, and while the EIA claims that decibel ratings from the development would be “only” 1-3 decibels above existing ambient noise levels, it should be noted that this statement can confuse those who are not familiar with such measurements. While the EIA provides clear information about current (ambient) and projected decibel readings, the Report does not articulate, in simplified and lay terms, the real meaning of sound levels.

Example: Decibel readings are a logarithmic, or relative, function – for example, a noise level of 100 decibels is twice the volume as 97 decibels.

In addition the Impact Study fails to deal with the reality that noise reduction measures at the proposed Water Park would be inadequate.

The Impact Study claims that vegetation will provide further attenuation of sound is also misleading – there is no significant reduction in noise unless vegetation is at least 100 feet deep, and over six feet tall. (In fact, 100 feet of thick vegetation will reduce sound only by approximately 0.5 decibel.)

To be truly effective, outdoor sound barriers or berms are constructed of earth or concrete, and must be high enough to be above the centre of the noise source. The acoustical treatments proposed within the Impact Study are rudimentary at best, do not follow acoustic mitigation best practices design criteria, and do not specifically pre-empt the variety of acoustical source points within the complex itself.

This is a common failure of many developments close to sensitive residential and environmental areas, because planned acoustical mitigation can be costly to a developer.

How much water will the Caribbean Splash water park use, and where will they get it?

The estimated daily amount of water needed to run the water park, both POTABLE and NON-POTABLE feed water, is 169,000 gallons per day, of which 47,000 gallons would be immediately discharged as brine.

A comparison can be made to understand how much potable water will be needed. Based on an average household consumption rate of 258 gallons per day, the Caribbean Splash operation would use the same amount of freshwater as 472 single-family homes.

The Barbados Water Authority has allegedly agreed to provide the potable water requirement for this project and they made this determination knowing the demand for sanitary Barbados Water Authority water: 15 gallons per day x 5000 people = 75,000 gallons per day of POTABLE water for drinking, food service, sanitary and shower facilities, and maintenance. (page 23, CEES EIA, and page 13, Addendum). Since BWA does not now supply all the potable water that is needed for use in Barbados there is no explanation of where this extra water will come from.

In addition, the water park will need substantial amounts of NON-POTABLE water for all of its water slides, pools and other attractions. It would be most profitable for the Caribbean Splash operation to obtain this water from freshwater wells within the Graeme Hall Watershed because it would need minimal water treatment, or no treatment if it is used for irrigation. However, there is some doubt as to whether Barbados Water Authority would allow draws from freshwater wells. The next question deals with the EIA assessment of freshwater wells.

Although it is not discussed it is expected that the most likely, option for Caribbean Splash to obtain the needed 47,000 gallons per day of non potable water to run the attractions is to develop a desalination plant using seawater obtained from on site wells. In the desalination process, approximately 50% of the pumped volume will be lost as brine.

This means that water park attractions will require 94,000 gallons per day of NON-POTABLE water from a saltwater well.

The test of well no. 3 mentioned in the Impact Study was primitive in scope, as it did not offer any basic specifications regarding average or seasonal flow rates, or existing pump specifications. However, both scientific and anecdotal evidence from spring activity in the Environmental Heritage Site however, which is lower and wetter than the area of Well No. 3, indicates periodically low freshwater supplies due to drought.

Low levels at the main lake happen regularly, whether induced by lack of rainfall drainage or by low freshwater replenishment from the natural aquifer. Further degradation of freshwater supplies by the proposed water park from Ministry of Agriculture wells will likely cause substantial increased stress to the Environmental Heritage Site, and the Graeme Hall Nature Sanctuary.

The Caribbean Splash EIA proposes a brine well or disposal to the South Coast Sewage Plant to dispose of brine concentrate. Is there any specific scientific or mechanical information to support this option?
No. The reasons for this lack of information are not known, however, it appears that the underlying assumption of the CEES EIA was that the Barbados Water Authority would allow brine dumping into a brine well.

Curiously, there is no comprehensive discussion in the EIA in regard to direct injection of brine wastewater into the South Coast Sewerage treated sewage discharge line leading to the outfall at Needham’s Point, nor is there a comprehensive discussion regarding deep well injection technology, or brine well impact on wetland salinity, or onsite solar tray treatment of brine water.

Why does the Caribbean Splash EIA, and subsequent responses from the Barbados Water Authority, claim that they cannot provide wastewater solutions based on volumes and the potential characteristics of that wastewater until after final designs for the project have been prepared?

Isn’t this information essential to the preparation and resolution of an environmental impact assessment?

It is essential and appropriate for an environmental impact assessment report to provide probable engineering estimates of wastewater volumes for this type of endeavour, and to address specific capacities of sanitary sewerage availability.

Not only does this information help make an environmental impact assessment relevant and useful in formulating designs, it also enables government agencies and stakeholders to accurately assess the project.

In fact, much of the information already exists about the project layout and Capacity Matrix (Table 3.1), projected water use and associated discharge mechanisms, based on expected visitor volume, water sourcepoints, and related discharge mechanisms. But the EIA consultant does not bring these relevant factors together into a comprehensive summary of probable engineering estimates associated with water use and discharge.

Example: The Caribbean Splash EIA states that “Wastewater volumes are expected to be 90% of the potable water demand figures plus that from cleaning and spillage (of non-potable water) from the slides.” The latter can be calculated based on rule-of-thumb from the water park industry, as are common rule-of-thumb supply and waste values for sanitary bathroom stations, showers, food service, drinking water, irrigation and stormwater runoff.

From a conceptual standpoint, the Barbados Water Authority also has enough information at hand to make a preliminary determination of available South Coast Sewerage capacity for the water park.

It is probable that the Barbados Water Authority would prefer to minimize discharges into the sanitary sewerage system, especially given the fact that when the South Coast Sewerage facility was originally designed, brine and large-volume sanitary wastewater from a water park was not part of the original calculation of expected future capacity.

H. There is no plan to cope with the mess if it fails

This is a glaring flaw in the Impact Study. Coastal Engineering’s study completely ignores the reality that the Caribbean Splash project might lose money and eventually fail. While we are not in the business of challenging its financial assumptions no one can deny that failure is a possibility.

If it fails, the Caribbean Splash Inc. will be bankrupt. The water park will stop operating leaving behind all of the structures which have been built. Toxic chemicals on the site will be abandoned and no one will be there to contain them and ensure that they are properly disposed of so they will eventually leak into the Watershed while they destroy the underlying agricultural land.

We can’t rely on the Government to clean up the mess, dismantle the park, and safely dispose of the chlorine supplies and brine by products being produced by the desalinization processes. In fact the Government cannot protect the Watershed because it does not have environmental safety laws in place which it might otherwise enforce to require the owners, directors, and officers of Caribbean Splash Inc. to carry out the clean-up. The Government has no expertise to do it. It does not have trained personnel nor resources to undertake such a large endeavour and therefore the agricultural lands will be lost forever under a mass of eroding structures and environmental problems.

I. Adoption of South Coast Sewerage Project emergency analysis

The Caribbean Splash proposal notes that “the lake at Graeme Hall has been earmarked as the overflow site in the event of an emergency at the South Coast Sewerage Project.”
Does this justify dumping or directing of additional wastewater by Caribbean Splash, via the surface or underground, into the Graeme Hall Environmental Heritage Site?

There is no justification to direct or dump additional wastewater into the Site.

The Impact Study attempts to piggy back on an emergency plan that is set up in the event of catastrophic failure of the South Coast Sewerage Plant operations to justify the future viability of Caribbean Splash. This is a non-sequitur.

Emergency and other contaminated discharges into the Site would be in direct violation of the Environmental Terms of Reference within the Inter-American Development Bank agreement associated with the South Coast Sewerage Project, and could violate the terms of the Convention on Biological Diversity.

Of particular importance, the Inter-American Development Bank agreement specifies that South Coast Sewage emergency operations should utilize the Bank-approved Emergency Discharge Canal.

This emergency outfall had been specifically designed and built in accordance with Bank-financed studies in the 1980’s and early 1990’s that recommended emergency discharges to the sea, rather than the Environmental Heritage Site, since the effects of sewage dumping in the Heritage Site are considered to be long-term and cumulatively detrimental to the wetland. Compounding the accumulation is the fact that there is little natural flushing or cleansing action within the Environmental Heritage Site ecosystem.

It should also be noted that future dumping of contaminates into the protected wetland could conflict with future Inter-American Development Bank applications for credit, under the new Environmental Terms of Reference developed in 2005 which require a review of past environmental compliance of the applicant.

Bank financing of the South Coast Sewerage Project was, and is, contingent on appropriate operation of the sewage treatment system in accordance with local and multi-lateral agreements such as the United Nations Convention on Biological Diversity (Barbados signed this Convention in 1993), and in accordance with measurable environmental standards such as the numeric limits contained in “The Pollution Prevention and Abatement Handbook, Part III.”

J. A Petting Zoo?

Why would the Caribbean Splash EIA suggest that the developer intends to build a building for the Ministry of Agriculture for an Interpretive Centre and Petting Zoo?
This representation in the EIA is indeed confusing in regard to the true mission and intent of a recreational water park, and perhaps patronizing to the needs and objectives of the Graeme Hall Swamp Environmental Heritage Site. In any case, it seems that this “intention” by the developer does not represent a thorough understanding of what an effective Interpretive Centre requires, nor is there here is a substantive reference to who will pay for operations of this Centre, or what the visitor volume will be, or whether the Ministry of Agriculture even wants a new building or the added operational expense.

The proposed water park is not a place where people would likely choose to become educated about the environment. At the same time, less than 700 meters away at the Graeme Hall Nature Sanctuary, is one of the finest environmental education facilities in the Caribbean. The Sanctuary spends hundreds of thousands of dollars every year for complimentary educational tours, new interpretive exhibits, and formal education syllabus materials for schoolchildren and adults. At the same time, the Sanctuary exhibits a large collection of birds in two aviaries which are among the largest in the Western Hemisphere, and which contain appropriate interpretives.

Perhaps the Caribbean Splash EIA should have acknowledged forthrightly that water parks are not designed to be centres for environmental awareness programmes, and that the water park Application should focus on the development intent at hand, rather than trying to be something it is not.

5. Why not other locations

The Coastal Engineering proposal states that that it has thoroughly investigated other locations and rejected them. Yet the results of these investigations have never been published. Proper investigations will show that there are better locations in Barbados. Ocean Park want a water park adjacent to their area as the two businesses have the same theme and are natural neighbours. Other areas in Barbados are preferable and yet we are prevented from seeing the studies.