At the general meeting of the National Conservation Council held on 23 September the Council took note of the Benthic Habitat Characterisation Survey conducted by CSA Ocean Sciences Inc. dated 21 August 2015 that had been released to the public on the day of the Council meeting. The Council resolved to review the survey and issue its views, as it had previously done following the issue of the Environmental Advisory Board’s Review of the official Environmental Statement. The Council’s comments, which will be posted to the Council section of the DoE website shortly, follows:

THE NATIONAL CONSERVATION COUNCIL

Promoting and securing biological diversity and the sustainable use of natural resources in the Cayman Islands

2 October 2015

PROPOSED CRUISE BERTHING FACILITY

Observations and comments on the scientific basis and results of a second
Benthic Habitat Characterisation Survey conducted by CSA Ocean Sciences Inc.

CONCLUSIONS

Despite, unfortunately, utilising different methodologies, this second survey (BHCS) nonetheless confirms the original Environmental Impact Assessment (EIA) results in terms of the area of massive, high- biodiversity reef to be impacted. It also acknowledges that the success of coral relocation on the scale necessary for the reefs in GTH would be a very complex and costly task with limited chance of success, but offers no cost estimates.

Cost information obtained by the Council from the Florida Keys National Marine Sanctuary indicates that relocating 134,000 corals would cost well in excess of US$40 million.

Coral relocation will not achieve “no net loss” of coral in the direct impact zone and will not mitigate indirect impacts outside of the project footprint. No suitable recipient site, if relocation were to be attempted, has been identified and Council remains skeptical that one can be found. Coral translocation is, in fact, not mitigation for the in situ coral but a compensatory measure that should not be considered until mitigation in the form of avoidance or minimisation of the impact in situ has been completely ruled out. Until it can be satisfactorily shown that there is no option, other than a Cruise Berthing Facility in the form and location proposed, then mitigation has not properly been considered.

OBSERVATIONS AND ANALYSIS

 The survey confirms the extent of the higher diversity spur and groove coral reefs within the dredge footprint to be 2.8 ha. The survey estimates, but does not explain, coral cover on the lower diversity hard grounds / patch reefs to be lower than that estimated by the EIA.

 Actual ground-truthing of the EIA survey sites was not conducted and the methodology was significantly less able to accurately assess live coral. The significant differences in estimated biotic cover might be accounted for by the different levels of granularity in the sampling methods used. In the EIA area point counts of 2000 data points per EIA site were sampled, versus line intercept counts of 400 data points per BHCS site. It has been shown that more points are needed to characterise
reefs with lower cover and more homogenously distributed colonies. 50 random points per m2, as
used by the EIA (versus 10 linear points per m2 used in the second survey) are the minimum required to expect a reasonably, statistically, accurate assessment.1

As the survey did not actually ground-truth the same sites as the EIA there may also be random differences between the sites surveyed. It is not possible to assess whether the 10% higher non- biotic result found by the survey on the spur and groove reefs was a result of the orientation of the transects or a real difference in the sites sampled.

 Assuming that only hard and soft coral greater that 10 cm diameter and 25 cm tall are relocated the survey estimates a total of 133,800 organisms to be moved. This compares closely in scale with the
148,000 relocated in the 2009-10 Falmouth port project, which took eight months and 93 persons to complete, but failed. By 2013 the recipient reefs could not be distinguished from the control reefs that had not received any donor coral.2,3,4

 Two of the examples cited in the survey give results of reattachment of small numbers of coral at the immediate sites of groundings of small motor vessels (50-60ft) – one coral head and seven fragments in the first case and 400 fragments in the other.5,6 The third example reports 1,000 cached
fragments.7

BHCS size date implies that the majority of corals are small and easily moved. However, the spur
and groove formations are massive, biologically-cemented structures and contain large boulder corals
(Orbicella species complex), which, if the reefs are truly to be recreated elsewhere, must be moved as whole blocks.

 The contractor submitted credentials for expertise in small scale coral translocations in Florida; however no additional cost information was provided to supplement or inform the estimates provided by the EIS (US$5-35 million based on a range of per square meter costs from the literature).

The Florida Keys National Marine Sanctuary has provided the Council with the following information on cost of the 2001 M/V Connected restoration (noted above) which involved 20 manufactured cylindrical concrete “crowns” of diameter 0.9 – 1.2 meters diameter, cemented into the reef with rebar reinforcement to which 400 fragments of coral were re-attached: Restoration costs (conducted by a contractor): US$120,000; FKNMS response, assessment and monitoring costs: US$72,632.

The initial, broad conclusion that can be drawn is that if stabilization of 400 coral fragments at the original damage site cost $120,000, translocating 134,000 corals would cost in excess of $40 million. Other, non-exhaustive, considerations that would affect this calculation upwards would be (a) moving the coral to a remote translocation site, (b) the much larger size of the GTH spur and groove formations would increase the size and cost of manufacturing appropriate concrete anchoring substrates; (c) inflation since 2001; (d) cost of doing business in Cayman, e.g. labour availability/immigration costs for temporary permits, accommodation, boat fuel costs, etc.

 The M/V Connected restoration shows the high relative cost of assessment and monitoring. At
Falmouth the monitoring to 2013 alone was calculated to have cost US$12 million.8

 Regardless of any execution of a successful coral translocation, as the EIA pointed out, the environmental impact remains at significant –D and the reefs not directly impacted will be subject to lethal and sub-lethal sedimentation and turbidity during the dredging and construction phases.

 Council also notes that the survey did not adhere to the Terms of Reference which required analysis of aerial photography but did not call for side scan sonar characterization of subsurface geology. Nor were the Terms of Reference prepared or reviewed by the EIA Steering Group in accordance with original Cabinet guidance.

This commentary is not intended to endorse any other proposed or alternative cruise berthing facility in GTH
or elsewhere.

1 Pante, E. and P. Dustan (2012) Getting to the Point: Accuracy of Point Count in Monitoring Ecosystem Change. Journal of Marine
Biology. http://dx.doi.org/10.1155/2012/802875.

2 Kenny, I., A. Kramer, P.W. Kelly & T. Burbury (2012) Coral Relocation: A mitigation tool for dredging works in Jamaica. Proceedings of the 12th International Coral Reef Symposium, Cairns, Australia, 9-13 July 2012, 20A Restoration of coral reefs.

3 JET, Jamaica Environmental Trust (2011) Environmental Regulatory Failure. The National Environmental and Planning Agency
(NEPA) and the Cruise Ship Pier at Falmouth, Trelawny, Jamaica. Report.

4 C.L. Environmental Co. Ltd. (2013) Environmental Status of the Falmouth Cruise Ship Terminal, Trelawny, Jamaica. Final Report to the
Port Authority of Jamaica.

5 Franklin, E.C., J.H. Hudson, and J. Anderson. 2005. M/V WAVE WALKER. Coral reef restoration baseline monitoring report – 2004
Florida Keys National Marine Sanctuary, Monroe County, Florida. Marine Sanctuaries Conservation Series NMSP-0608. U.S. Department of Commerce, National Oceanic and Atmospheric Administration, National Marine Sanctuary Program, Silver Spring, MD. 15 pp.

6 Schittone, J., E.C. Franklin, J.H. Hudson, and J. Anderson. 2006. M/V CONNECTED Coral Reef Restoration Monitoring Report, Monitoring Events 2004-2005. Florida Keys National Marine Sanctuary Monroe County, Florida. Marine Sanctuaries Conservation Series NMSP-06-10. U.S. Department of Commerce, National Oceanic and Atmospheric Administration, National Marine Sanctuary Program, Silver Spring, MD. 25 pp.

7 National Coral Reef Institute. 2004. Hollywood Ocean Outfall Stony Coral Transplantation Monitoring Final Monitoring Event. Draft
Report. Nova Southeastern Oceanographic Center, Dania Beach, Florida. 14 pp.

8 Korbee D., A.P.J. Mol, J.P.M. van Tatenhove (2015) Ecological considerations in constructing marine infrastructure: the Falmouth cruise terminal development, Jamaica. Marine Policy (2015) 56: 23–32.

END

IMAGE: Baird