Dear Dr. Rhianna Neely-Murphy,

On April 26, Deputy Prime Minister (DPM) and Minister of Tourism, Investments and Aviation Chester Cooper issued this public statement regarding the public concerns being expressed about the environmental impact of Royal Caribbean's proposed private beach development on Paradise Island:

"If there's a suggestion from anybody in the public, DEPP will consider those adjustments and will ensure that they are addressed in the best interest of the Bahamian people. We are all Bahamians. We all love our country. We all want the best for our country, and I hear some environmental pundits who may have some expertise in the area making their commentary publicly. I would invite them to send their suggestions to DEPP, so they can be properly considered and the responses can be measured and deliberate in ensuring that we address the issues."

Following up on Cooper's welcome remarks and invitation, we would like to share a number of concerns regarding the proposed "Royal Beach Club" project that require Department of Environmental Planning and Protection (DEPP) investigation and vigilance.

As Bahamian citizens and environmentalists, we are counting on you to fulfill your mandate to protect our nation's precious natural resources and unique environment by demanding detailed answers from Royal Caribbean - in as transparent a manner as possible - regarding its plans and promises.

From what the cruise line has revealed publicly, we fear that if the project receives your approval, the full transition and complete decimation of this small, fragile strip of Paradise Island land will be inevitable and irreversible.

We therefore ask that in performing your duties, you consider the following:

1. Has Royal Caribbean adequately mapped the coral reef on the north seabed and proposed steps to prevent or mitigate its destruction during construction and after? Have they shared with you how they intend to monitor its health over time? And what would the DEPP's response be if the damage we suspect will happen is detected?

2. How does Royal Caribbean intend to prevent catastrophic erosion on its site once significant amounts of natural grass and other plant life on the site are destroyed by construction activity and the intended long-term use?

3. Royal Caribbean has promised to build no over-the-water structures. But where will the required over-the-water docks be built to handle the intense daily water taxi activity?

4. Has Royal Caribbean submitted detailed construction plans, not just renderings, so that the DEPP can properly assess the proposed project's environmental impact? Royal Caribbean representatives have estimated that those plans will not be available until the end of 2023. No environmental approvals would be appropriate without review of the final plans.

5. Has a recent survey of plant and animal species on the site been conducted? Studies from 2021 are not valid; a current, comprehensive survey is required. What has Royal Caribbean said will be the short- and long-term fate of the site's current inhabitants?

6. How did Royal Caribbean determine that its estimated daily use of the site by 2,750 to 3,000 visitors is acceptable? Was it based at all on an analysis of the capacity of this narrow, fragile strip of land to hold up under such density and intensity of use? On 17 acres, that's 176 people per acre.

a. Given the requirement to dedicate land for the site's power plant, waste treatment facilities, buildings, restaurant areas, performance stages and other structures, the density of people-per-acre will be even greater. Does this comport with DEPP best practices and established standards?

7. We would like greater detail about the intended waste treatment plan Royal Caribbean has promised. Where on the site will its solid and liquid waste treatment facilities be? What levels of odor and sound will they emit? How close to the water will they be? How will it be powered until the promised net-zero carbon footprint is achieved? Which Bahamian partner have they selected to build and manage the facility?

8. Has Royal Caribbean analyzed the level and reach of noise pollution from on-site activities, jet skis and other uses?

9. Has Royal Caribbean shared with you any plans to provide emergency and life safety services on their site? Do they have a fire prevention and response plan that is sensitive to the environment and has been reviewed by the appropriate agencies and authorities?

10. Has Royal Caribbean developed and submitted an evacuation plan? Do they have a plan to secure the site and its structures to survive storms?

11. Could you share with the public any record of DEPP actions or fines against Royal Caribbean for environmental infractions in The Bahamas?

12. Royal Caribbean has made a pledge to achieve net-zero carbon emissions on its site by 2030. It has also stated that it will generate its own energy.

a. If Royal Caribbean is proposing to use solar power, where will a solar panel field large enough to provide the required amount of energy for the company's intended uses be located on the restricted 17-acre site?

b. If diesel generators are to be used prior to solar conversion, how does Royal Caribbean intend to mitigate the anticipated levels of air and sound pollution?

c. Does Royal Caribbean's net-zero carbon pledge include the anticipated impact of intense private water taxi traffic they intend to introduce to transport thousands of staff and visitors across the harbor every day?

d. And has Royal Caribbean agreed that not meeting the 2030 pledge would trigger meaningful penalties?

13. And as we have stated publicly, Royal Caribbean needs to respond to our previously stated requests for:

a. Online public access to all documents related to the beach project submitted to the government by Royal Caribbean, inclusive of the cultural and environmental impact assessments and management plans;

b. Responses and mitigation plans related to the beach project submitted to the government by Royal Caribbean;

c. Open in-person and online town halls at which members of the public will be permitted ample time to express their views, and a commitment to making transcripts available online;

d. Royal Caribbean written responses to numerous unanswered questions previously posed by The Bahamas' business and environmental communities regarding the impact of its proposed project; and

e. Publishing as soon as possible of an environmental review timetable, including a schedule of town halls and public comment period.

While this is not a comprehensive list of our questions and concerns, it does demonstrate the inadequacy of Royal Caribbean's public pronouncements and the absence of public disclosure, to date.

Thank you for your consideration and please know that we are available for consultation if you would find it helpful. We appreciate the critical role you play in protecting our environment and will continue to add our voices to the groundswell of Bahamians calling for transparency, public comment and due diligence.

Respectfully submitted,

— Joseph Darville

Executive chairman, Save the Bays

— Eric Carey

Bahamian environmentalist and former executive director of the Bahamas National Trust

— Sam Duncombe

Executive director, reEarth

— Rashema Ingraham

Executive director, Waterkeepers

— Casuarina McKinney

Executive director, Bahamas Reef Environment Educational Foundation

— Gail Woon

President, Earthcare

The post A letter to the director of DEPP  appeared first on The Nassau Guardian.

The post A letter to the director of DEPP  appeared first on The Nassau Guardian.

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