Edison Baird, MA
Sandy Ground
Anguilla, BWI
AI 2640
Hon. Mark Simmonds, MP
Parliamentary Under Secretary
Foreign and Commonwealth Affairs
Minister responsible for the Overseas Territories
28th October, 2013
Dear Sir
I write on behalf of the people of the Road North Constituency ( in particular, and the people of Anguilla in general) to request financial assistance from the British Government for the purpose of reviewing the Environmental Impact Assessment (EIA) carried out in respect of the proposed Salt Works Project at the Road Bay Salt Pond.
In the interest of objectivity and transparency, I am also requesting that the British Government select a professional and competent company to conduct the review of the EIA, which is entitled Environmental Impact Assessment: Proposed Salt Pond Conversion, Road Bay, Anguilla, BWI.
The EIA, which was done in August 2013 by Ocean Earth Technologies, is a large, heavy document weighing approximately 8.20lbs, and is written in very technical language. These factors render it almost inaccessible to the average citizen who is not only likely to experience difficulty understanding it, but will be challenged to hold it steady as he/she seeks optimal alignment when reading.
The content of the EIA also has a number of significant shortcomings, which I consider too obvious to ignore. It fails, for example, to highlight the fact that the Salt Pond is an internationally designated Important Bird Area (IBA). It has not accorded importance to the Pond being an important way station for birds travelling back and forth from North to South America in response to the seasonal changes of winter and summer. No mention at all is made of the resulting negative impact that the industrialization of the Pond can have on this important bird cycle. Additionally, the EIA does not mention that the Pond becomes a habitat for more than 1000 water birds as a result of the migratory cycle. It might be useful for you to know that the Pond is habitat to the Least Terns bird species of global significance. Nowhere is this captured in the document. The EIA has also failed to mention that these birds are also protected by the Biodiversity and Heritage Act 2009. This Act, among other things, provides protection for wild and endangered birds. Suffice it to say, the entire salt pond is really a habitat for birds protected by law.
An abundance of information is available to any diligent researcher on bird life in the Road Salt Pond. Every month, for the last eight years, The Anguilla National Trust has counted the number of birds, residing, so to speak, at this pond. The EIA, however, only reflects statistics for 2008 and a few months in 2013.
The EIA also dangerously falls to the ground in another critical area. It calls for the removal of mud from the canal that runs parallel to the houses that border it. The removal of the mud by dredging would release hydrogen sulphide, a foul smelling and poisoning gas. The Occupational
Safety and Health Administration (OSHA), is an agency of the United States Department of Labor. According to OSHA:
Hydrogen Sulfide (also known as H2S, sewer gas, swamp gas, stink damp and sour damp) is a colorless gas known for its pungent “rotten egg” odor at low concentrations. It is extremely flammable and highly toxic…The health effects of hydrogen sulfide depend on how much H2S a worker breathes and for how long. However, many effects are seen even at low concentrations. Effects ranging from mild, headaches or eye irritation, to very serious unconsciousness and death.
This obnoxious and poisonous gas would undoubtedly pose a threat to the health of residents and other individuals. The village would be closed as a place of commerce and tourism as the gas permeates homes, shops, restaurants and other businesses. Any attempt therefore to dredge the Pond, or any attempt on part of the Government to illegally and forcefully remove the villagers to accommodate it, would lead to a raft of lawsuits. The latter would place a heavy and debilitating burden on the stooped taxpayer.
The EIA, too, does not adequately address the issue of flooding. The Road Salt Pond is really a natural flood storage area. If it breaks its banks, it would undoubtedly flood the village as was the case in 1999 during the passage of Hurricane Lenny. The horror that resulted in the village as a result of the sand bar being breached by Lenny was captured in a flood study entitled Department for International Development Drainage Study Final Report, August 2000, and done by Hallcrow Water, a British company:
If the Sand Bar is overtopped, then a breach would normally form and the rapid release of water from the pond pose a significant risk to life for any inhabitants living at the position of the breach. The breach channel formed during Lenny (1999) occurred away from residential properties, but there is no guarantee that the inhabitants would be so lucky in the course of the next hurricane.
Anguilla, like any other country, must learn from its past in order to avoid repeating mistakes. Our experiences with past EIAs should serve to inform how we tackle similar occurrences going forward. In the early 1990s, an American company, Beal Aerospace, sought to lease Sombrero Island to use as a platform to launch rockets into space for the carriage of satellites. Before this was done, IFC Kaiser International carried out an EIA. The study concluded that it was safe to launch rockets from Sombrero, as the launching pose no threat to bird and marine life and the environment in general.
However, a number of Anguillians challenged the conclusion of the study, contending that it negatively impacted bird life, fishing and the marine environment. Owing to the public outcry, the British Government decided to finance a review of the EIA. The Anguillian newspaper, dated 28th May, 1999, reported, in part, at that time that, “while Beal has reportedly received approval from the Anguilla Government, an environmental impact study by the British Government has not been completed.”
The completion of the study showed the EIA by IFC Kaiser to be so seriously flawed that it amounted to a death blow to the Beal Aerospace Project. IFC Kaiser EIA, like the present EIA of the Road Salt Pond, was also written in very technical language. The review of the EIA, however, was explained to the Government and people of Anguilla in language that was readily understood by the average citizen.
I strongly feel that the government of Anguilla must not be permitted to play Russian Roulette with the lives of the people of Sandy Ground. After all, it is only right that we be afforded maximum protection from death.
Against the above background, I once again reiterate the need for financial assistance from the British Government for a review of the EIA. I believe that my humble request is reasonably justified.
I look forward, on behalf of my people, to a favourable and speedy response.
Yours sincerely,
Edison Baird, MA
Elected Representative,
Road North Constituency, #5
The Anguilla House of Assembly
cc: Christina Scott, HE The Governor
Dr. Peter Haynes, Director of the Overseas Territories
Joan Walley, Chair, Environmental Audit Committee, House of Commons
James Millet, RSPB
Grace Vanterpool, Interim Chair, ASPIRE
Vincent Proctor, Secretary Land Development Control Committee
The Anguilla National Trust
The Press
(Published without editing by The Anguillian newspaper.)