[Coral-List] Discovery Land Project

[William Allison]

Dear Todd,

Your seem to register surprise that a developer would attempt to avoid an
EIA or would interfere with performance of one. This seems naïve but perhaps
that is not what you meant to say. At any rate, it seems that in the vast
majority of cases EIAs are treated as costs avoided where possible and
minimized when unavoidable, so EIAs tend to be minimalist exercises or
merely flam. Incidentally, this is often a mistake because irreparable
damage may be done to coral reef environments, damage that causes chronic
problems (coastal erosion, algal blooms, loss of amenities requiring
restoration, etc) that bleed the developer or subsequent proprietor of
palliative funds forever.

Your proposal that government pay for the EIA and recoup the costs in taxes
from the development seems to bias the EIA in favour of the development.
Perhaps the responsibilities should be divided such that the developer pays
the cost of immediate baseline and potential impact study and monitoring and
the government is responsible for the more general baseline and monitoring
essential for comparison and control. A possible way to keep the immediate
study arms' length would be for the developer to pay a predetermined fee to
government as partial payment for the right to develop the location. A
general tax could contribute to ongoing monitoring etc - specific and
general. Due diligence would be required to guard against the regulators
being captured by the regulated (e.g., in an extreme example of a structure
conducive to this, the developer pays private companies staffed by
moonlighting government employees to do the EIA). In line with the arm's
length requirement and strictly from a structural perspective, Mike's
concern about having a company marketing artificial reefs intervening on
behalf of the environment is understandable.

Sincerely,
Bill



 

>I am not sure 
> I understand who a developer could reject this or how a developer should
> even be involved in baseline data and on-going monitoring....that should be
> something the governmental agencies do or other independent scientific or
> NGO organizations do...as you stated it needs to be at arms length and I
> don't think that the developer can reject anyone doing science in the water
> near their development.

> From: "Todd Barber" <reefball at reefball.com>
> Date: Wed, 15 Mar 2006 15:09:56 -0500
> To: "Michael Risk" <riskmj at univmail.cis.mcmaster.ca>,
> <coral-list at aoml.noaa.gov>
> Subject: Re: [Coral-List] Discovery Land Project
> Resent-From: AOML.Coral-List at noaa.gov
> Resent-Date: Wed, 15 Mar 2006 14:55:24 -0500 (EST)
> 
> Hi Michael,
> 
> First, it should be known that I have never suggested Reef Balls for Guana
> Cay.  I have simply offered to interviene between those interested in
> preserving coral reefs and the developer to get a better outcome for the
> reef.  And in fact, the Reef Ball Foundation would ALWAYS prefer to save a
> natural reef rather than having to resort to building an artificial one.
> 
> But help me out here, it seems we have a Developer that is willing to
> consider options to make the development have less impact on the reef and we
> seem to have several scientists that can suggest "low impact" technologies
> that might be appropriate.  (And it actually appears from my investigation
> that the Developer is trying to incorporate as many low impact features as
> they can).  We have you saying we need an independent (non-developer
> sponsored) baseline and monitoring program which I agree with.  Seems to me
> like everyone is in agreement on what to do to move forward.  I must be
> missing something.
> 
> You mentioned the developer "rejected" baseline & monitoring. I am not sure
> I understand who a developer could reject this or how a developer should
> even be involved in baseline data and on-going monitoring....that should be
> something the governmental agencies do or other independent scientific or
> NGO organizations do...as you stated it needs to be at arms length and I
> don't think that the developer can reject anyone doing science in the water
> near their development.  It is a public policy issue if this information
> needs to be gathered.  Certainly it is not done for every development....
> for example, did you do a baseline and on-going monitoring on the impact to,
> for example, bird nesting impacts when you built your home?  Sometimes
> government would say it was important to do so (in the event your house was
> being developed on a historical bird nesting location) and sometimes they
> would say it was not necessary.  In the case of Guana Cay, I would say,
> "yes" we need to baseline and monitor the coral reefs around Guana Cay
> because the development is significant and the coral reef is important.  So,
> the government should bear that expense.  It should be able to more than pay
> for the studies with the increased tax revenues generated by the
> development.
> 
> My point in all of this is that as activists, if we are going to cry out
> against development, we need to have alternatives, suggestions, and action
> plans to help guide the development to minimize the negative impacts.  Even
> if faced with the complete halt of development we don't necessary achieve
> victory and save the reef because the developer will just move to another
> island with less resistance.  That's why we need to give them assistance,
> not necessarily resistance.
> 
> I'll give you an example from my own life.  I have always known since I was
> young that the cars I drove contributes to coral reef's decline.  Did I
> drive a solar car? No, it was not practical.  But two years ago they came
> out with Hybrid cars.  So, now both of my cars are hybrids.  Science
> provided me with a reasonable alternative...cost me a bit more but I know it
> is better for the reefs.  I think developers will do the same as science
> offers then alternatives.
> 
> Is there a way to use this opportunity of an open dialog with the developer
> to accomplish something positive?
> 
> 
> Thanks,
> 
> Todd Barber
> Chairman Reef Ball Foundation, Inc.
> 3305 Edwards Court
> Greenville, NC 27858
> reefball at reefball.com
> 
> http://www.artificialreefs.org
> http://www.reefball.org
> http://www.reefball.com
> 
> Direct: 252-353-9094
> mobile: 941-720-7549
> Fax 425-963-4119
> 
> Personal Space: http://www.myspace/reefball
> Group Space http://groups.myspace.com/reefballfoundation
> Skype & MSN For Voice or Video Conferences:
> Available upon request
> 
> Atlanta/Athens Office
> 890 Hill Street
> Athens, GA 30606 USA
> 770-752-0202
> (Our headquarters...not where I work see above)
> 
> 
> ----- Original Message -----
> From: "Michael Risk" <riskmj at univmail.cis.mcmaster.ca>
> To: "Todd Barber" <reefball at reefball.com>; <coral-list at aoml.noaa.gov>
> Sent: Wednesday, March 15, 2006 1:44 PM
> Subject: Re: [Coral-List] Discovery Land Project
> 
> 
>> Hello Todd.
>> 
>> My involvement with the Guana Cay situation has been restricted to the
>> writing of a short initial report, which was commissioned by the
>> present inhabitants. I have no involvement at present. Nonetheless, I
>> want my position on your actions to be crystal-clear to the -list:
>> 
>> I am opposed to the use of Reef Balls or indeed any similar artificial
>> reef structures in this case. There is no need for them when the reef
>> is healthy. In fact, if you want to be of real use, try to ensure that
>> Reef Balls are never needed on Guana.
>> 
>> What would help is what the "eco-friendly" developer has already
>> rejected. In this case, AND ALL SUCH CASES, there must be the following
>> ingredients:
>> 
>> 1. necessary and sufficient baseline data on fish, invertebrates, and
>> nutrients. These data must be taken by qualified people, and at a
>> research-grade level with proper QA/QC protocols.
>> 
>> 2. there must be a long-term monitoring program established, carried
>> out by an arms'-length agency (ie, NOT hired by and reporting to the
>> developer).
>> 
>> 3. all data must be distributed freely and archived in several
>> locations.
>> 
>> None of the above conditions have been met.
>> 
>> Mike 
> 
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