–against proposed ‘NALCO’ development

Dear Editor,

WE the residents of Houston Gardens/Plantation Houston Estates and surrounding areas would like to request that the following issues be addressed by the Environmental and Social Impact Assessment (ESIA) for the NALCO CHAMPIONS GUYANA PROPOSED DEVELOPMENT.

We have been forced to take recourse to the press since two letters to the Environmental Protection Agency related to developments in the Houston area have received no response. The EPA Act 1996 has a clear legal requirement defined in Part II ESTABLISHMENT AND FUNCTIONS OF AGENCY, Section (n) (3) (a). The mandated requirement is for the EPA, “In the exercise of its functions the Agency shall compile and amend from time to time with the assistance of internationally recognised environmental groups a list of approved persons who have the qualifications and experience to carry out environmental impact assessments.”
We, the residents of Houston Gardens/Plantation Houston Estates and surrounding housing areas, would like the EPA to identify the internationally-recognised environmental group(s) which assisted it to compile the list of consultants, and which consultant on the list is being used to conduct this ESIA.

This ESIA must be undertaken by a party identified on the list prepared in accordance with this dictate of the EP ACT 1996. If no such list exists, the residents of Houston Gardens/Plantation Houston Estates and surrounding communities regard the entire process as being flawed and call on the EPA to abort the process and to halt the chemical plant development until such time as an appropriately qualified consultant is appointed in accordance with the EP Act 1996 to conduct the ESIA.

It is understood, from the Notice, that the intent is to handle chemicals at the site. The Material Safety Data Sheets must be made available for all chemicals to be stored on the site. A material breach has likely already occurred if chemicals are stored in the John Fernandes Inland Terminal, in proximity to existing residences with no evacuation plan and/or mechanism for warning residents of any releases to the environment that pose threats to both human health and the environment. Consequently, the residents of Houston Gardens/Plantation Houston Estates and surrounding communities demand that the ESIA define both the Direct and Indirect area of Influence of this project based on mathematical analyses of the consequences of the chemical storage and possible release, based on the initial and projected scale of this development. The definition of the Direct and Indirect Areas of influence must mandatorily incorporate public health and well-being, land and property values and other resources within these areas. The target population of all areas must be identified, in addition to costs associated with health care, loss of earnings and relocation costs in the event of a release to the environment. Please recognize that there are residential communities in the westerly, northerly and easterly directions of this proposed development.

The residents of Houston Gardens/Plantation Houston Estates and surrounding areas also request that an environmental cost/benefit analyses, as opposed to an economic cost-benefit analyses, be conducted for the proposed development. The analyses should identify the environmental costs and benefits of the proposed development. We have identified as major impacts the risks to the health and well-being of our families, the detrimental impact on the quality of our community life and the depreciation in the values of our homes. This project must only advance if is demonstrated that the environmental benefits to the residents of Houston Gardens/Plantation Houston Estates and other impacted communities exceed such environmental costs.

Part II, 4 (a) of the EP Act 1996 mandates “In performing its functions the Agency shall make use of current principles of environmental management, namely: a. the “polluter pays” principle: the polluter should bear the cost of measures to reduce pollution decided upon by public authorities, to ensure that the environment is in an acceptable state, and should compensate citizens for the harm they suffer from pollution. The residents of Houston Gardens/Plantation Houston Estates are therefore requesting that the developer identify appropriate relevant and applicable methods to compensate them for decreased property values occasioned by this development.

We understand that the Central Housing and Planning Authority and the Guyana Lands and Surveys Commission has zoned all lands in Houston Gardens/Plantation Houston Estates and surrounding areas as residential and/or agricultural. The ESIA shall include confirmation from the CHPA/GLSC whether the land identified for this and additional developments in the area of John Fernandes Inland Terminal have been altered to commercial/industrial use. Evidence must also be presented in the ESIA to confirm that residents of Houston Gardens/Plantation Houston Estates and surroundings were consulted if such a change was made. Our property transports clearly stipule that the Houston Gardens/Plantation Estates are strictly for residential purposes. It is inconceivable that the authorities responsible for regulating our country’s land use would so perilously place an activity such as chemicals handling, so close to the homes of citizens.

There are several canals, bordering our community, into which waste and stormwater from the John Fernandes Inland Terminal facility is discharged. At least one of these canals is blocked causing water to stagnate within close proximity to our homes. The risks of waste or contaminated runoff from the proposed development must be seriously assessed given the interaction with our community’s internal drainage. The ESIA must consequently include numerical surface water quality modeling to confirm no impacts on the surface water quality. There is a groundwater well located within 200 m of the proposed development. The ESIA must include a detailed description of structural geology and hydrogeology of the area to ensure no discharges to groundwater and a monitoring plan to confirm the conclusions of the ESIA.

The propensity for the chemicals to volatilize must be documented based on the Henry’s Law constant of the chemicals to be stored at the facility. We also demand that an appropriate, relevant and applicable approach be used to model the dispersion of any chemicals released to the environment. At a minimum, the model shall be developed based on atmospheric data compiled for the project location and must at a minimum consider both wet and dry deposition. A detailed risk assessment shall follow based on life expectancy of 80 years. Further, a risk assessment must be conducted to determine the risks to human health and the environment of chemical concentrations in air. You are no doubt aware of the presence of two schools within proximity of the proposed development, increasing the risk of potential harm to our very youngest citizens.

Our previous letters to you dated of July 2018 and June 2019, sent before your current Notice was posted, requested action from the EPA to address several threats to human health and the environment related to developments in the Houston Gardens/Plantation Houston Estates area. This proposed chemical plant catapults the need for action from the EPA into a sphere of indisputable urgency. It is also understood that there are other impending developments in this area. We are therefore requesting that the EPA conduct a Sectoral Environmental Assessment to examine the cumulative environmental, social and economic impacts on the residents of Houston Gardens/Plantation Houston Estates and surrounding areas of all developments planned by the current owners/lessors of the lands in this Houston area.

In closing, we the residents of Houston Gardens/Plantation Houston Estates, appeal to the EPA for a through, high-quality ESIA, in compliance with the principles enshrined in our Laws and in the spirit of citizenry protection from which it was born. We welcome any further opportunity to represent our views as the ESIA progresses and look forward to your responses to our letters.

Regards,

Residents of Houston Gardens/Plantation Houston Estates and Surrounding communities