A letter sent by TNC’s country director, Julianne Stockbridge, to the CEO of the Ministry of Sustainable Development and Chairman of the NEAC, Kenrick Williams, points to four major reasons for the Blue Bond facilitator’s call for GoB to hit the brakes on Waterloo’s proposed Port of Belize development.

by Marco Lopez 

BELIZE CITY, Wed. Oct. 5, 2022 

The Nature Conservancy (TNC), which secured the financing for Belize’s Blue Bond, thus making it possible for the country to retire the Superbond, and which co-created a framework for the generation of cash flow for conservation through 2040, has written a letter to the Government of Belize suggesting that GoB defer the consideration of Waterloo’s proposal for construction of a cruise terminal at the Port of Belize until certain major concerns are addressed, and until the development of a Marine Spatial Plan is completed. TNC is the world’s leading conservation organization and, as just mentioned, entered an agreement with the government that required the country to commit to protecting our coral reefs, mangroves, and fish-spawning sites and approximately 30% of Belize’s marine areas.

The proposed Cargo Expansion and Cruise Port Terminal and Village by Waterloo Investment Holdings at the Port of Belize has been actively opposed by members of the conservation community. According to Janelle Chanona, Vice President of Oceana Belize, a joint letter which was sent a few weeks ago by a coalition of conservation organizations to the Prime Minister to urge the government to put a pause on all ongoing EIAs (environmental impact assessments) in line with a commitment made by the Government of Belize under the Blue Bond Agreement had not included a signature from The Nature Conservancy for one reason: the process was done very quickly, and several groups which likely would have wanted to sign onto the document had not gotten the chance to be a part of the process.

On September 30, however, TNC’s Belize program director, Julianne Stockbridge, clearly stated the organization’s position in a letter sent to the CEO of the Ministry of Sustainable Development, Climate Change, and Disaster Risk Management, Kenrick Williams, who is also the Chairman of the National Environmental Appraisal Committee (NEAC). In that letter, TNC presented its comments on the ESIA submitted by Waterloo in August 2022 and outlined four major concerns about that ongoing process, after which it offered suggestions on a way forward. 

Firstly, the organization recommends that an ESIA be submitted for each of the two projects that are part of the proposed development— the cargo expansion project and the cruise terminal project— separately, and the reason for that separation, it said, is to ensure that each ESIA addresses “ALL [emphasis ours] potential impacts”. The underlying suggestion in the TNC’s comments is that it is not possible to address all these impacts in one overall document “due to the differences in the scope, objectives and potential social, economic and environmental impacts of the proposed Port of Belize Cargo Expansion (PoBCE) and Port Cruise Terminal (PCT) developments.” The TNC Belize program director thus recommends that these be “presented as two separate project proposals, each with their own ESIAs”.

Notably, environmental officer of the Department of Environment, Kenrick Gordon had said, during the public consultation on Waterloo’s ESIA that was held at the Belize Best Western Biltmore Plaza on September 1, that “in terms of the presentation of the cruise port itself, and the cargo port itself, that has to come to the department in a whole. If they were to present just one project, we would consider it as a piecemeal approach; the department doesn’t look at a project on the piecemeal approach; it has to be considered holistically”. However, the TNC Belize program director, in a portion of her comments that outlines a second area of concern, pointed out major shortfalls in the blanket ESIA being considered by the department. One of those deficits is that the document does not address the Outstanding Universal Value of our World Heritage Site, the Belize Barrier Reef Reserve System – a requirement that was included in the 2020 amendment of the EIA regulations. The Outstanding Universal Value is defined by UNESCO as having cultural and/ or natural significance which is so exceptional as to transcend national boundaries and to be of common importance for present and future generations of all humanity.

This was pointed out by attorney Sharon Pitts during her presentation at the public consultation, when she asked the panel how the reef would be “present-proofed and future-proofed” by those persons/entities which are implementing this project. She outlined that a no-action alternative would be the only viable solution, and that position was echoed by TNC in its written submission as a third major point. Stockbridge noted that a no-action alternative is not included in the project proposal/ESIA, and points to that shortfall as something that must be rectified . 

“The ESIA needs a no-action alternative, a key requirement of the approved ESIA Terms of Reference. The current ESIA does not include this alternative. The no-action alternative should establish the social, economic, and environmental baseline of the existing Fort Street Tourism Village and the under construction Port Coral cruise terminals, then show the incremental impact of the POBCE and PCT projects. This is a major failing of the ESIA and must be rectified,” TNC’s letter states. 

In the 2022 ESIA, Waterloo’s consultants attempt to justify their exclusion of the no-action alternative by stating that, “The no action alternative only becomes a viable option where it is determined that a project’s environmental and social impacts would far outweigh any net economic and social benefits.” Because the project is not considered in the ESIA in the context of two other proposed port developments (by Stake Bank Enterprise Ltd. and Portico Enterprises Limited), it is not possible for the ESIA submitted by Waterloo to give an accurate picture of net jobs created, in light of other jobs that might be lost due to the Waterloo project, nor the environmental risks due to harm to our marine ecosystem as a result of the presence of two or three port developments within such a small area.

TNC makes note of this while outlining the fourth and final point in its letter to CEO Williams: “The cumulative impact of the existing cruise port developments nearby should be taken into consideration for the calculations of overall impacts to the environment and socio-economic values of ports. The proposed development of two new ports is within an 8-mile radius of [two] other cruise port developments. It’s not clear what the cumulative economic, social, and/or ecological impacts are if all these developments were in operation,” the letter states.

After laying out these key observations in the letter to Williams, the TNC Belize program director suggests to the government and the NEAC that instead of granting environmental clearance to the Waterloo project at this time, it should defer such a decision until “a more in-depth assessment is completed that addresses these and other concerns”.

The organization then points to a larger picture— the need for an overall mapping of Belize’s marine areas and an overall vision or strategy that could guide critical development decisions that might affect the country for decades to come. It goes on to present what it calls a “tangible and timely solution” : accessing key information on “what human activities can occur in the ocean and where” through a Marine Spatial Plan process that the Coastal Zone Management Authority and Institute (CZMAI) is starting in October 2022 — this month. The TNC noted that it is a “public, participatory process with ecological, social and economic objectives that is based on science, information and local knowledge”. It went on to say that such a process “can be used to decide the best locations” for “industrial and large commercial developments such as cruise and cargo ports.”

“A national Marine Spatial Plan will facilitate decisions on a coordinated way forward… and will be inclusive of all major coastal and marine developments, including the other cruise port developments,” the letter points out.

This is in line with the need for the creation of a national strategy for port development.

The creation of the MSP is one of the principal commitments under the Conservation Funding Agreement, and a call to the public has been made to select a name for the marine spatial plan. “This Belize MSP will provide government, local communities, and marine sectors with a transparent, equitable, and participatory process for ensuring that Belize will continue to receive the benefits and services that a healthy ocean can provide,” a post on the TNC Facebook page states. 

In the comments submitted to CEO Williams, the TNC Belize program director makes one final, critical point: that having a completed MSP could be of aid to the country when it is seeking financing. “An MSP can be an important asset for Belize when applying for large grants or loans, as it demonstrates that there is an integrated plan for the coastal and marine waters for uses and activities,” TNC’s letter states.

“The zoning plan provides a level of business certainty for economic development and secures marine space,” the letter goes on to say.

The TNC Director concludes the comments sent to CEO Williams by stating, “We urge you to consider this as a solution on how to proceed for expanding ports in the country, not only for the Port of Belize ESIA but with all other ESIAs and major developments in marine and coastal areas that are on the horizon.”

As mentioned, the Blue Bond financing arrangement between TNC and the Government of Belize represented the world’s largest debt restructuring for marine conservation to date.