Pride and EPIC Objection to Great Salt Pond Ring Road.

SXM Pride - Thursday June 4th, 2009

Executive Council
Clem LaBega Square
Philipsburg, St. Maarten
Netherlands Antilles

RE: Objection to both the Construction Permit request (BP# 110/09) for the filling of a part of the Great Salt Pond for the construction of the Ring Road and the requested permit for the partial removal of limited portions of the Salt Pans for the construction of the Ring Road

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Honorable Executive Council members,

Environmental Protection In the Caribbean and St. Maarten Pride Foundation have taken notice of and have carefully reviewed the “Construction Permit request (BP# 110/09) for the filling of a part of the Great Salt Pond and the construction of the Ring Road” and associated documents. Based on the Foundations’ analysis of the abovementioned documents the Foundations are hereby jointly objecting to these requests for the following reasons:

The Great Salt Pond, played a prominent role in both Sint Maarten’s and the Kingdom of the Netherlands’ history due to its immense size and its central location, particularly in the wide scale Salt mining industry which started with the Dutch around 1631. Salt was collected from the Great Salt Pond and subsequently exported all over the world or locally used to conserve food. The last commercially significant salt reaping occurred in the 1940’s. Many Sint Maarteners are descendants of people who worked in the Great Salt Pond during and after slavery, a fact which makes the Pond an important aspect of the island’s and the Kingdom’s heritage

* The eastern side of the Great Salt Pond, an area called the Great Salt Pans (Grote zout-vlaktes/ pannen), has recently been identified and designated by the Executive Council of the Island Territory of St. Maarten as a monument (BC# 1172-08) the Great Salt Pans monument was officially registered in May of 2009; in doing so, government acknowledged the cultural/historical significance of the area and committed to protecting it.

* The construction of the Ring road/ link 3, as it is currently proposed, will destroy a large portion of the same area of the Great Salt Pond that Government only recently identified and designated as a monument (BC# 1172-08).

* The proposed plans will therefore demolish significant and rare physical evidence of our ancestors’ strenuous labour and St. Maarten’s history through the destruction of many of the few remaining rock walls and salt pans (Zout-vlaktes/ pannen), in particularly the eastern section of the pond. The removal of these historical artifacts would deprive St. Maarten of an important aspect of the island’s cultural identity.

* The Foundations are of the opinion that an undesirable precedent would be set if Government destroys large portions of an area which that same Government only just identified and designated as a monument based on its cultural/ historical significance.

Sint Maarten’s ponds (including parts of) the Great Salt Pond have been recommended for protection in reports such as The Ponds of Sint-Maarten, (Ecovision, 1996) and many other studies which concluded that the ponds are of ecological and environmental importance.

* The Great Salt Pond is of crucial importance for the survival of many species of birds, fish and other wetland life; It is an important feeding, breeding and nesting areas for numerous species of migratory and resident birds. Construction of the Ring road will have a devastating effect on the many species of birds, crabs and fish in the Great Salt Pond.
* BirdLife International (de Vogelbescherming) recently recognized the Great Salt Pond as one of the Caribbean’s “Important Bird Areas (IBA)”. IBAs are places of the highest global priority for bird and biodiversity conservation.

“Great Salt Pond IBA is in south-central St. Maarten, on the outskirts of the capital Philipsburg....This IBA is significant for its population of Laughing Gull (Larus atricilla). Up to 5.800 gulls congregate at the IBA prior to the breeding season. About 50 pairs of Black-necked Stilt (Himantopus mexicanus) breed .... within the IBA.”

(St. Maarten, Important Bird Areas In the Caribbean, Key sites for conservation, BirdLife International, 2008)

The area is also of importance for the:

o White-cheeked Pintail (Anas bahamensis) a regionally threatened species experiencing declining populations due to habitat restriction,
o Ruddy Duck (Oxyura jamaicensis) which is found on only four other Lesser Antillean islands due to habitat restriction,
o Caribbean Coot (Fulica caribaea) a regionally threatened species experiencing declining populations due to habitat restriction,
o St. Maarten’s national bird, the Brown Pelican (Pelecanus occidentalis), with up to 60 pairs known to breed in the Greater Great Bay Area.

* The Pond also serves as a natural cache for much of the run-off water from surrounding hills. Removing or even partially filling it will have drastic consequences for the surrounding areas as excess run-off water will lead to additional flooding of the already overburdened districts adjacent to the pond.

The Island Government appointed Lievense Consulting Engineers to carry-out an Environmental Impact Assessment (EIA) of the Ring road/ link 3.

* The Foundations have reviewed the abovementioned EIA and are of the opinion that the research and analysis conducted for the document is of poor quality, incomplete at best and does not meet commonly used Dutch or international standards/ formats for Environmental Impact Assessments. EPIC and St. Maarten Pride strongly recommend that a new EIA be carried out for the Ring road project, this and any future EIA must at a minimum include information on the following:

1. Description of the project and alternatives to be studied, with an explanation on how environmental considerations have already been integrated in the project design.
2. Legislative, regulatory and policy frameworks
3. Analysis of alternatives to proposed plans and reasons for rejection
4. Aspects likely to be significantly affected with current situation and trends (baseline)
5. Description of the likely significant effects (with a comparison of the studied alternatives)
6. Mitigation and enhancement measures, organized as an Environmental Management Plan
7. Analysis of social impacts.
8. Residual impacts
9. Non-technical summary
10. Analysis of possible Difficulties and uncertainties

* Lievense is involved in many of Government’s infrastructural projects. St. Maarten Pride and EPIC therefore question the objectivity of this Environmental Impact Assessment and insist on the production of a new EIA to be carried out by qualified and entirely independent consultants.

St. Maarten Pride and EPIC are in full favor of the development and implementation of sustainable solutions to St. Maarten’s traffic congestion challenges. Increasing road network capacity, by building a ring-road in the Great Salt Pond is however not an effective solution for St. Maarten’s traffic related challenges. With the number of vehicles on the island increasing by a significant percentage each year, as is presently the case, the Foundations’ estimate that the planned road network expansion will cease to meet traffic capacity needs in less than 5 years unless government takes measures to curb the increase of vehicles on the island and improve public transportation.

In addition to the aforementioned, research and experience in many countries shows that increased road capacity is very quickly filled with what researchers have dubbed “induced vehicle traffic”; people tend to abandon public transportation and carpools when additional road space is made available, through new road construction or linkages, thereby resulting in more cars on the road and subsequently more traffic congestion.

Much of the Island Government’s actions and projects aimed at the alleviation of traffic congestion have only focused on the expansion of road networks. Various government policy plans, government commissioned reports and independent studies have, however, identified the alarming number of vehicles on St. Maarten as the primary cause of traffic congestion.

The Tourism Master Plan of 2005, for instance, provides recommendations and specific proposals aimed at alleviating traffic congestion in the long-term including proposals on:

* Raising road or registration tax with excessively large cars more highly taxed,
* Introducing a regulated public transportation system with proper bus stops and related amenities,
* Regulating the car rental sector to limit the number of rental vehicles and the issuing of new car rental licenses.

St. Maarten’s traffic congestion issues will therefore not be alleviated by the expansion of the road network. Building new roads without taking additional measures to curb the increase of vehicles on the island is merely a very temporary measure and consequently an ineffective and unsustainable strategy for resolving the island’s traffic congestion challenges.

* The Foundations recommend that Government provides for an up-to-date independent study of St. Maarten’s traffic congestion challenges instead of indiscriminately expanding the Island’s Road Network as is currently the case.

In principle St. Maarten Pride Foundation and EPIC are against the entire Ring road project. Should government continue with the execution of this cosmetic solution to the island’s traffic congestion challenges, the Foundations urge government to at least preserve the entire now remaining eastern side of the pond. This preservation of the eastern end of the pond (the Great Salt Pans Monument) can be achieved through the improvement of the Soualiga road which runs from Philipsburg to Suckergarden through Pond Island as an alternative to the planned filling in and destruction of the “Great Salt Pans” monument.

Sincerely,

St. Maarten Pride Foundation
Environmental Protection in the Caribbean (EPIC)