With the 30-day period for objecting to the EPA’s decision not to require an Environmental Impact Assessment (EIA) for the new Demerara Harbour Bridge having ended on Wednesday, geologist Simone Mangal-Joly has submitted that the agency lacks adequate information to arrive at such a conclusion.
In a letter dated December 20 to head of the Environmental Assessment Board (EAB) Omkar Lochan, Mangal-Joly objected to the waiving of the EIA on two major grounds.
She contended that the Environmental Protection Agency’s (EPA) conclusion that the environmental impacts would not be significant is irrational since the design for the bridge is non-existent.
In early November, the Irfaan Ali government announced the selection of China State Construction Engineering Corporation (CSCEC) to build the bridge for US$256,638,289. In its tender document, CSCEC submitted the cost based on the Design, Build and Finance (DBF) option, or Design, Build, Finance, Operate and Maintain (DBFOM).
That means that CSCEC would be responsible for designing the bridge based on the government’s specifications. It is on that ground that several environmentalists and other professionals are continuously objecting to the EPA’s decision to not require an EIA.
“The reasons that the Agency published to justify its waiver of an EIA are in fact persuasive arguments for why potential impacts cannot be addressed outside of the statutory EIA process. These reasons illustrate that the EPA is in no position at this time to decide on the significance of impacts and to identify directly affected parties that must be engaged in the impact assessment process,” Mangal-Joly submitted in her objection to the EAB, which adjudicates appeals against EPA decisions.
She argued that the EPA’s actions in processing the Ministry of Public Work’s application for Environmental Authorisation are procedurally incorrect. The environmentalist further accused the EPA of “subverting the very laws the EPA was created to implement and uphold.”
Both the EPA and the Ministry, according to Mangal-Joly, have admitted to engaging stakeholders outside of the statutory democratic process specified in the Environmental Protection Act.
“You would note that this is not taking place in addition to the EPA having already fulfilled those statutory requirements. This has been taking place ahead of, and in lieu of, the statutory process, including this 30-day public comment period and potential EAB hearing.
“The Environmental Management Planning process that the EPA has conjured is based on arbitrary rules of community engagement set by itself and the Ministry of Public Works that deprive stakeholders of the transparent, accountable, and comprehensive process laid out for impact assessments in the Environmental Protection Act,” she said.
Initially, the EPA had indicated that an EIA would be required for the project but that decision was subsequently rescinded. Mangal-Joly reminded that the EPA admitted to breaking the law when it failed to list reasons for the waiving of the EIA following her objections.
Further, an earlier process for the approval of the new bridge was aborted by the EPA at the appeals stage before the EAB after it came in for severe flak from environmentalists and civil society activists for not providing reasons why an EIA was not required.
Indulged
“The EAB indulged the EPA by accepting that the application was withdrawn, thus permitting the EPA to circle back to the same decision, still without credible technical reasons and still acting outside of the law. There is a pattern of conduct here that cannot be ignored in the EAB’s consideration of this matter,” she said.
On November 23, the EPA launched a fresh process for the approval of the new bridge over the Demerara River and stuck to its controversial opinion that an EIA is not required even though protected mangroves will have to be removed. The EPA, as of recent, has made it a trend not to require EIAs for projects with obvious environmental impacts. It has been continuously called out by environmentalists and activists.
Based on the project summary, the replacement of the 43-year-old existing floating bridge is critical for a number of reasons ranging from it exceeding its lifespan to costly and regular maintenance. The project summary also indicates that there is an increased vulnerability to disruptive incidents on the bridge and it limits the capacity for travellers owing to the long and slow retraction process.
“The overall significance of environmental impacts of this project are considered to be low to medium and manageable from a technical, social and financial point of view. The overall social impact of the project will be positive. Therefore this proposed project is exempt from the conduct of an Environmental Impact Assessment (EIA), as set out in section 11(2) of the Environmental Protection Act, Cap. 20:05, Laws of Guyana. While the EPA has exempted this project from the requirement of an EIA, it is recommended that an Environmental Social and Management Plan (ESMP) be prepared for this project,” EPA had said as part of its reasoning.
The new bridge is expected to land in the vicinity of Nandy Park on the eastern side of the Demerara River and at La Grange/Meer-Zorgen on the West Bank. Based on the information provided, the bridge is expected to land some 700 metres inland from the eastern bank of the river and will be elevated 50 meters at the beginning of the channel – which is closer to the east bank. The descent is slated to be at a rate of 5 degrees.
The Scope of Works in the design/build contract included the complete design and construction of a two-lane dual (four-lane) carriageway, hybrid cable-stayed centre-span bridge with concrete box/T-beam girder approach bridge structures, and must include bridge collision protection, a navigation span to accommodate Handymax vessel navigation aids, lighting, signage, and all other ancillary works, an access road with a minimum of 50 meters up to abutments, toll-collection buildings and ancillary buildings on the West Bank of the Demerara River.
Mangal-Joly, who holds a BA in Geology & Third World Development Studies from Smith College, USA, a Master’s in Natural Resources and Environmental Management with sub-specialisation in Social Ecology from Yale University, USA, and has completed three years of graduate field research on the Environmental Impact Assessments in natural gas and downstream developments towards a PhD in Economic Anthropology at University College London has previously stated that the hydrology of the Demerara River stands to be affected.
The complete bridge project would have to be comprised of approach roads which must be built or rerouted in the communities to feed traffic to the bridge. Then there is the bridge approach, which is a type of ramp that leads up to the bridge and the upper structure one would drive over to get to the other side. At both ends of a bridge are abutments, which are the parts that straddle the land and river and in between these in the river are piers, or big and wide posts that support the upper structure of a bridge.
Mangal-Joly contends that the number of piers will affect the river’s hydrology while urging the EPA to conduct hydrological and hydraulic studies to determine the likely impacts. For that to happen, she said that the design of the bridge is essential.
