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Environmental Threats
and Challenges
Development:  Placencia Marina
Placencia Marina, revised

The developer of this 300 slip marina for which the National Environmental Advisory Committee (NEAC) recommended approval on 24 February 2010 is Placencia Marina, Ltd., a Belize limited liability corporation owned by Romas, Ltd., a British Virgin Isles company. One of the principals of the developer is Marco Caruso, who is also part owner of Copal Beach, The Placencia Hotel and Residences, the under-construction Placencia Airport on the northern end of the Peninsula and Rendezvous Caye.  Mr. Caruso also owns Rio Mayo Construction Company, which has constructed the Placencia Hotel and Residences, and is currently constructing Copal Beach Resort and the Rendezvous Caye resort.

The Placencia Marina will be built on 60 acres of fill off the northern coast of the Peninsula between The Placencia Hotel and Copal Beach.  As shown above, the Marina will include a 500-700 foot pier connecting it with the Peninsula, will accommodate boats of up to 200 feet in length, and will be surrounded by a solid breakwater with culverts, which the developer maintains will prevent the marina from causing erosion to beaches south of the marina.  The Marina will employ a maximum of 20 people.

NEAC recommended approval of the marina despite not receiving two studies that NEAC minutes state were critical to the decision by NEAC on whether to recommend approval of the marina. 

Incredibly, the minutes of NEAC meeting in which approval was recommended suggest requiring the developer to do the studies AFTER approval is granted, as part of the conditions of the Environmental Compliance Plan for the project.  This decision by NEAC essentially stands the EIA process on its head if NEAC can recommend approval of a project without necessary studies.  It further establishes a dangerous precedent for future projects which can argue that tests required by DOE can be done AFTER approval rather than before, based on the NEAC marina decision. 

On 16 February 2010, PCSD received a copy of a letter dated 12 February 2010 from Mr. Ismael Fabro, the Chief Environmental Officer of the Department of the Environment (DOE) under the People's United Party, to Mr. Martin Alegria, Fabro's successor under the United Democratic Party.

In his 12 February letter, Mr. Fabro asked DOE and the National Environmental Advisory Council (NEAC) to waive their requirement that bathymetry and modeling studies be performed before approval or disapproval of the Placencia Marina.

Mr. Fabro instead asked that DOE and NEAC require the bathymetry and modeling studies to be done AFTER approval, as a condition of the Environmental Compliance Plan for the Placencia Marina.

Fabro's reasons for making his request:

  • Getting the equipment to do the bathymetry and modeling into the country would take too long and the developer's investors would lose confidence through this delay; and

  • DOE had not required Ara Macao to perform bathymetry and modeling studies even though the marina was much larger (64 rather than 60 acres and 400 boat slips rather than 300 boat slips).  (Note:  Mr. Fabro was the Chief Executive Officer when Ara Macao went through its EIA process.)

Bathymetry studies have been required since the initial Terms of Reference for the original EIA in July 2009, but were not provided in the original EIA.  Two supplemental EIAs have been completed since the original EIA, one in December 2009 and one in February 2010.  The lack of bathymetry and modeling studies were specifically given as a reason for denial of the Marina EIA in the January 2010 minutes of NEAC - also forwarded anonymously to PCSD on 16 February 2010.

In the December 2009 EIA supplement, Mr. Fabro claimed that the bathymetry and modeling studies were impossible to perform for the proposed Marina site due to lack of necessary data.

PCSD's letter to DOE about Mr. Fabro's letter is provided below.

In addition to the issue of the bathymetry and modeling studies identified by NEAC, PCSD opposed Marina approval for several reasons, among them the following:

  • The inability of the Peninsula to support over 950 boat slips - 700 within 3 miles of each other - the second marina being the approved 400 slip Ara Macao marina.  The amount of boat traffic generated by this number of boats would overrun fishing grounds, greatly over-tax marine protected areas, destroy vitally important seagrass beds, coral and other marine habitat, and ruin the aesthetics that draw tourists to the Peninsula.

  • The cumulative impact of a 300-slip marina, approximately 500 hotel rooms, a casino and a golf course within a 5 mile area has not been assessed and is likely not sustainable for the area's infrastructure (particularly garbage, sewage, roads, police and fire protection and health care) and its eco-systems, specifically its effects on the Placencia Lagoon and the Caribbean Sea.

  • The environmental sustainability promised by the EIA and Supplemental EIA for the Marina relies solely on self-monitoring by the developer.  Given  developers' history of compliance with the terms of ECPs for other projects, predicating approval of this Marina on self monitoring is a disaster waiting to happen.  If the marina is approved, the developer should be required to pay a yearly fee for independent monitoring and testing in an amount sufficient to pay a top-quality firm for these services.  As usual, monitoring results are intended to be kept private and away from the eyes of the public, which is not only wrong, but can jeopardize the health and welfare of the public.

  • Section 9.2.2 of the Supplemental EIA states that   "[a]t a depth of 9-10 meters the upper layer consisted of very fine silt and showed for the presence of a few small shells (C of Plate 9.1)"

    Therefore, silt curtains will not effectively prevent siltation of areas outside of the area bounded by silt curtains, but will instead allow silt to disperse to other areas, endangering coral and seagrasses.

    As explained by the US Army Corps of Engineers, “[w]hile the curtain provides an enclosure where some of the fine-grained material may flocculate and/or settle, most of this fine-grained suspended material in the water column escapes with the flow of water and fluid mud under the curtain.  Whereas properly deployed and maintained silt curtains can effectively control the distribution of turbid water, they are not designed to contain or control fluid mud.” (Silt Curtains as a Dredging Project Management Practice, ERDC TN-DOER-E21 Sept.2005.

  • The February 2010 Supplemental EIA finally identified the Placencia Lagoon as the source of the 100,000 cubic yards of sand needed to fill the geo-tubes from which the Marina will be constructed.  Absolutely no studies were done on the effects this dredging will have on the Lagoon and the aquatic life in the Lagoon - not to mention that the location of the dredging was withheld for 6 months after the original EIA was submitted.  Further, the February 2010 supplemental EIA states that Mr. Caruso will dredge his "own property" in the Lagoon.  Private individuals cannot own under-water land in Belize. 
  • Submitted plans do not provide the exact position of the Marina.
  • The size of the Marina was miscalculated or misstated  – the EIA Addendum says the Marina is 34 acres, while it really covers about 60 acres when the breakwaters are included in the measurements.
  • Submitted plans and maps for the Marina were not done to proper Belize engineering standards because no Belize engineer was involved in the planning.
  • Soil at the Marina site was not tested, meaning the Marina might be unsafe and could subside (collapse).
  • The source and quantity of water for the Marina (and Copal Beach) was not determined, nor was the quality of the water tested to determine whether it’s fit for drinking.
  • The EIA and its Addendum are generic and not specific to the Marina; sections of the Marina EIA and Addendum are just copied from other EIAs.
  • Boating routes and navigation evaluation missing from submitted documents – especially with respect to the ability of the 200 foot boats to maneuver within the Marina.

In addition, the location of the proposed Marina appears to be right in the middle of a navigational channel. 

 

To no one's surprise, DOE approved the Marina and signed an environmental compliance plan on 6 April 2010.  And, the ECP did not follow the recommendations of NEAC, but instead authorizes construction of the pier as a "pilot project."

 

And, in addition to approving the Marina, the Marina ECP also approves:

  • A 50-room boutique hotel;

  • Fitness center

  • Casino

  • Commercial retail area

  • Parking area

  • Amenity areas for pools, bars, "etc."

  • Public utilities area along the Placencia Lagoon.

None of the above land based components were included in the Marina ECP.  Therefore, calculations of water usage, sewage and waste production and other similar factors in the ECP do not include the hotel, the casino and the other land-based components improved in the ECP.  Nor were public comments solicited for these land based components.

 
 

Peninsula Citizens for Sustainable Development
General Delivery
Placencia, Belize
 info@saveourpeninsula.org
 www.saveourpeninsula.org
011-501-610-4718