04 December, 2007

Dolphin Relocation

EIS Reports. I have been reading the two Environmental Impact Statements provided by Dolphin Fantaseas to the Planning Department. These reports are intended to be independent, objective, expert reports prepared by environmental specialists. They are meant to assist the Planning Department in making its recommendation to government whether a particular project should be permitted as proposed. In this case, the proposal is for government to lease to the dolphinarium owners the sandy ground spit at Blowing Point just to the West of Ferryboat Inn. They will construct restaurants and other facilities on land, and pens for displaying the dolphins in the sea. The reports were supposed to advise government on the impact, among other things, of the food and feces nutrients on the surrounding sea used by swimmers, plants, and fish. They were also supposed to indicate whether the dolphins will survive the diesel and gasoline in the sea from the ferryboats and other vessels using the dock just a few yards up-current.

In the case of the report titled, “Appendix B Socioeconomic Report”, I was not able to get past the first page. Here is an extract from page 1.

The number of grammatical, spelling, and punctuation mistakes present in the short paragraph above beggars description. I challenge any adult to read the 49 pages with any degree of comprehension. I challenge any secondary school student to read the paragraph and not burst out laughing aloud.

If this is the quality of the reports presented by the dolphin prison keepers, I cannot understand how government will be able to come to an informed decision.

Anyone wanting to read a copy of the reports just email me and I will send them to you.

I am awaiting expert comments on the substance of the reports. I shall report to you in due course.


  1. It is a West Indian disease, showing off how many big words we know. It says "I don't care if you understand me, as long as you're impressed with how smart I am."

    It was Albert Einstein who said, "If you are out to describe the truth, leave elegance to the tailor."

  2. This Socioeconomic Report was done by a company called "Young's Consulting," but is being referred to by local insideras as "The Hoyoung Report."

    "I recognise the spelling," commented a former teacher.

  3. DOn, please let me know whose name is attached to the report. This is why middle management and higher ups need to be place on term contracts.

    We want only Anguillians to do things but sometimes asking for expert consult can help us. I hope governement gets back all the money paid for this substandard report. And those in the civil service who allowed this to be made public should resign immediately.

    We can do better Anguilla.

    80 % of Anguillians between the ages of 18-45 never read for pleasure. Just listen to the Talk Shows and the grammar mistakes are excruciating.

  4. The author of the report is Young's Consultancy Services, South Hill, Anguilla. The owner of this alleged company is not identified. Is this company registered with the Companies Registry? Is it lawful to do business in Anguilla using an unregistered company name? No other address is given, nor a telephone number or email address. There is no such company in the telephone directory, nor any Youngs listed in South Hill.

    There is one Young's Consultancy found on Google. It appears to be an employment or recruitment agency. It is perhaps of interest that it is located in Slough:

    Young's Consultancy
    Tel: 01753 681182
    Lakeside Industrial Estate,
    Colnbrook By Pass,
    Slough, Berkshire, SL3 0EL

  5. Is there a branch of Ernest and Young in Anguilla? And who is the local rep. Find out, so the government can get their money back for thi hack job. I am not there to investigate.


    "A Sandy Ground alternative was considered but construction was halted based on Government input." This is an interesting way to explain that they started construction illegally, partially on public property, without a lease on the Crown land and without an alien land holding license, using what the Chief Minister said were Mexican workers without work permits, and when they were caught, the Chief Minister ordered them to stop work and remove what they had built.

    This sort of deceptive and misleading explanation of what happened in Sandy Ground reveals the bias of the "independent" consultant and calls into question the validity of the entire Environmental Impact exercise.


    The EIS states that the project site is currently undeveloped, and has a beach access road. If my understanding of the location is correct, it is the parking area for Sandy Point, for the people of Blowing Point and other visitors. The developer promises "public access" to the beach, but makes no mention of parking. I must conclude that where we can presently drive, in the future we must walk, as DD intends to privatise our parking lot.

    Many of us will not choose to spend our weekends on a beach that annually attracts 25,000 foreign day trippers. Especially if we have to walk there. Thus, although we will continue to have the legal right to use most of the beach and some of the tidal waters, the real, practical effect of the DD proposal is that Sandy Point will be theirs, not ours.

  8. The EIS states that the existing facility was closed "due to land redevelopment by another party." This is an imaginative description of the facts.

    Dolphin Discovery (DD) owned the existing facility. Viceroy purchased all of the surrounding property and made them an offer for theirs. DD had every right to stay there forever, although Hubert has stated incorrectly that they have been "pushed out" and it should be the obligation of a caring government to protect businesses from large investors. DD chose to sell. They took Viceroy's money and gave Viceroy their land and buildings. Their right to start a new facility in Anguilla is no different from any other foreign investor. Their attempt to seem like a victim of redevelopment is deceptive and misleading.

  9. This deception also brings into question the objectivity of the consultants who did the report. An EIS is supposed to be an unbiased assessment of the environmental consequences, good or bad, of a development proposal. A proper EIS is supposed to be a report to our Planning Department, paid for but not influenced by the developer. As revealed on the cover of the report, the consultant apparently believes their client is Dolphin Discovery, not the Government of Anguilla.

    It is thus understandable that the entire report reads like a sales document that might be more appropriately entitled, "Why Dolphin Discovery Should Be Allowed To Move to Blowing Point." The entire premise is inappropriate. Calling this an EIS is a farce. A poster asked previously if someone at Planning had been paid off. If they accept a sales document as an EIS, one must wonder what's really going on down there.

  10. I have read the EIS. It claims that "Future expansion will be done through captive breeding and transfer from other facilities." This statement is an attempt to convince us that no dolphins will be captured from the freedom they enjoy in the seas. "Other facilities," however, include the National Aquarium in Havana, Cuba, where Dr. Graham Simpson illegally purchased (and was fined by US Homeland Security) the original Anguilla dolphins. All Havana dolphins are captured in the wild.

    Accordingly, saying that new dolphins will be transferred from other facilities is deceptive and misleading.

  11. ATM did the EIS. If we enter the following at Google: "applied technology & management" dolphin

    we learn that the consultant has also done reports for Marineland somewhere, and the failed Dolphin Quest proposal in Bermuda.

    Perhaps you will find others on their website. They seem to be the procurors for the dolphin prisonistas.

  12. The report states that a "minimal amount" of fecal coliform bacteria will be produced in "dolphin waste," will be flushed out of the proposed pen and "should have a minimal impact" on the health of recreational bathers.

    Under similar conditions at the earlier proposed located at Sandy Ground, Edison Baird stated that this waste would affect those swimming in Road Bay "and many people will die."


    The EIS admits that "the additional nitrogen from dolphin wastes may increase algae production within the proposed project's area of influence, particularly downstream of the site". Although algae is the primary cause of the dying of reefs, the EIS passes off this threat as "minimal" and "not significant". The claim is made that "a water quality monitoring program will ensure the maintenance of water quality".

    It should be obvious that monitoring water quality will not change the quality of the water if it identifies a problem. The EIS offers no solution should that occur.

    In a 2003 study on how waste nutrients impact coral reefs: http://tinyurl.com/ypg6x5 Dr. Thomas J. Goreau documented the manner in which the types of algae that enjoy waste nutrients gets more dense as one approaches captive dolphin facilities from the down-current side, yet are absent from the up-current side. He believes that captive dolphin facilities are killing reefs in the Caribbean. The EIS does not contest Dr. Goreau's findings; they simply ignore him.

  14. The EIS says there will be job opportunities for Anguillians. Anguilla already has thousands more job opportunities than we have Anguillians to fill them. In fact, these excess "opportunities" have caused a housing crisis, people are homeless and living in goat pens, foreign workers are everywhere, inflation is fed by an overheated economy, the schools are stuffed full and if they ever get the National Health Fund going we will have to pay for complete medical care for all these people, with no deductions and no limitations.

    It is time we stopped listening to people going on about the lost jobs at the dolphin facility and turned our brains back on. Our employment cup runneth over and refusing to allow the dolphin facility a new license is not a problem; it is part of the solution.

  15. The EIS says DD will draft a written operations manual. This means either that they have one at the existing facility but will trash it and write a new one, or that they have been operating for ten years and haven't had one.

    By the way, their grand opening at Meads Bay was on 15 May 2001, which is 6-1/2 years ago. Why are they claiming to have operated for ten years?

  16. The bird and tortoise cages will have sand floors. I believe the existing cages have sand floors. Unconfirmed information reaches me that this sand is the result of illegal sand mining at a nearby source, and that the used sand, complete with the considerable by-product of caged birds, is illegally dumped somewhere. Is this true?

  17. I found the part about sewage disposal intresting. The EIS states that sewage will be transported to a sewage treatment plant. The only sewage treatment plants I know of in Anguilla are found at hotels, and a few commercial establishments and government institutions. Which hotel, commercial establishment or government institution is going to process DD's annual 36,000 gallons of sewage? This is a lot of ---t.

  18. The part on sewage analysis is pure rubbish. The EIS says that a local licensed contractor will perform any required analysis of the raw sewage. What sort of "analysis" do they anticipate being required, who will require it, what will they do with it and who has the knowledge and equipment required to analyse it?

  19. I was more interested in the indications of drug abuse at the dolphinarium.

    One of the "specialised materials" to be used at this facility is VALIUM, a sedative. Valium has the potential for abuse and may cause dependence/addiction. A number of Valium abusers also abuse other illicit drugs. Valium is usually a secondary drug of abuse, used mainly to potentiate the “high” obtained from other drugs. However, even legitimate and therapeutic usage of Valium is associated with an inherent risk of addiction and physical/psychological dependence.

    Withdrawal symptoms of Valium include convulsions, tremor, abdominal and muscle cramps, vomiting and sweating. In the U.S., Valium is a Schedule IV controlled drug under the Federal Controlled Substances Act.

    How many people will have access to this and other drugs and what provisions have been made to keep them finding their way into the hands of unregulated purveyors who work the streets of Anguilla?

    MEGACE (megestrol acetate) is indicated for the treatment of anorexia (loss of apetite) and cachexia (loss of body weight that may occur in patients with cancer, AIDS, or other chronic disease). So if the poor dolphins don't eat their dead fish, they are drugged to make them hungry?

  20. so...now we have identified many, many problems with the EIA. What's the next step? Where do we go? How can we make these comments on the EIA? Who is willing to stand up and give their comments? What is the protocol for commenting to the planning department. I seem to remember, years ago, that these proposals were announced on the radio and comments were encouraged.

    I love this site, but what happens next? Don has brought it to our attention and we obviously have thoughts, ideas and comments - where do we go now?

  21. The people of Blowing Point say that they will not permit any dolphins to be relocated to the sea/beach at Sandy Point. So, what use is the EIS?

  22. On page 5-14 it is revealed that there will be about 24 construction workers, of which about half will live on the site.

    Do I understand that there are rental villas adjoining this site and that visitors will spend large amounts of money to come here and rent them so they can experience the peace and tranquility of our island?

  23. One of the primary reasons advanced for keeping the dolphin facility in Anguilla was the work it provides for taxi drivers.

    It is thus surprising to learn from the EIS that "the facility", meaning DD, "will provide bus service from the airport".

  24. I have read the EIS. I noted that representations are made regarding standards and procedures that will be upheld during the construction phase.

    It should be noted that none of these were evident during the illegal and aborted construction at Sandy Ground.

    How seriously can we take this claim?

  25. I read with amusement the promises about the many and various parameters that will be monitored on a continuing basis. The Government of Anguilla has no systems in place to enforce such commitments. While the Director of the Department of Fisheries and Marine Resources is a qualified marine biologist, the Department is already overextended with other duties and it is questionable whether they should be tasked with the supervision of private, for-profit enterprises. It thus seems we may be depending on DD to monitor themselves.

    In view of their prior actions, and statements in this report and elsewhere which I consider to be deceptive and misleading, this may be unwise.

  26. Sand floors for the tortoises?

    On the web, I found this:

    "In outdoor pens in areas of high sand content, food should not be placed directly on sandy soil. Sand can build up in the tortoises GI tract leading to possible impaction and even death. A completely separate sand-free area in the habitat should be utilized to feed."


    The pen full of tortoises at the old site was all sand. So they aren't even taking care of the tortoises _today_, and are proposing sand floors for the future site.

    A bunch of Steve Irwins, these people are not. They may try to pass themselves off as caring for the animals, but I don't see any evidence of that.

  27. Interesting comments being posted, however, I must ask, where is the local representative in all this? Why isn’t Hubert making any noise, hell, he whines and complains and opposes everything else. Perhaps, is it because it does not directly affect his Southhill folks, he doesn’t care? This type of attitude is despicable and as a representative and an Anguillian he should be ashamed.

    DD is out to damage our lively hood by destroying our reefs and beaches with their filth. The containment of the dolphins in pens was bad enough but to put them out in the sea on our beaches and dispose that quantity of sewage will be disastrous. How can Gov't sit by idly and not voice concern or opposition to this developmnet plan? We need to protest Gov't action and let it be know that it is not acceptable, especially residents of Blowing Point. Enough is enough and its time we make a stand before our communities are overburdened by some health epidemic. Who knows what health crisis will spin off from this move? Can we really afford to take that risk in the interest of financial gain? Its better to be one job short then a thousand sick, dying or dead.

    Our leaders have to think in terms of what’s best for all Anguillians and not what’s best for their financial gain. If they cannot do that, then we have to show them by demonstrating with conviction the will of the people. If we remain mute we are just as bad as these corrupt officials. What are we waiting for? our parents, children, our families or us to succumb to some ailment that overpowers the resources of our small healthcare system? It is our job and duty to be proactive and work to prevent such disasters from occurring. Let these crazy DD folks konw that we are aware of the serious ramification of their enterprise and that we will not allow them to put any Anguillian live at risk. One dead Anguillian as a result of their scheme is one Anguillian too many. Our means of support has been by our seas so why would we allow someone to toxify the very waters that help sustain our very exsistence? If we lose our fishing industry and our beaches form their dumping of sewage what do we have left. If our visitors cannot swim and use our coastal beaches where is the attraction for them to come here? We are on the brink of creating a cascading or dominoe effect here with our careless, selfish and greedy actions.

    Wake up my people, wake up and open your eyes to the plight that is before you. Like the Pharohs and the children of Israel who did not listen to the warnings told to them, we are most likely to become victims of our own hardened hearts, and greed.

    I'm not trying to preach to the choir here but merely a messenger stating my observations and pending calamities if we do not change our destructive ways.

  28. The people of Blowing Point say that they will not permit any dolphins to be relocated to the sea/beach at Sandy Point. So, what use is the EIS?

  29. o...now we have identified many, many problems with the EIA. What's the next step? Where do we go? How can we make these comments on the EIA? Who is willing to stand up and give their comments? What is the protocol for commenting to the planning department. I seem to remember, years ago, that these proposals were announced on the radio and comments were encouraged.

    I love this site, but what happens next? Don has brought it to our attention and we obviously have thoughts, ideas and comments - where do we go now?

  30. Keep going! Damning this report is very important. This so-called EIS is an insult to the intelligence and respect due to our politicians and senior civil servants; it assumes that the readers have none.

  31. One thing which Don mentioned is also important - what about the currents taking the diesel and gasoline fuels from the ferry boats (less than 600 yards away) to the dolphin enclosure? Won't the dolphins get a mouthful of that? Will it get on their skin? Will it get on the swimmers' skins? If Government approves this venture in this location and a tourist gets ill or worse because s/he develops a reaction, will the government have a liability? (Think in terms of 'Health & Safety Act') Is this the kind of contingent liability which the Brits are seeking to minimize?

    Also - remind me - I think that a few years ago the spit at Blowing Point, and the area around it, was set aside by the government for something – like a special area. It certainly wasn't for anything like a dolphinarium. It might not have been a National park type move, but it was something like that - the gist was that they wanted to protect it. It was being accorded a similar reverential status that the Cove has got.

  32. I am sure many of persons remembered the hostile treatment that was received when a few right thinking Anguillians tried to stop Dolphin tourism from coming to Anguilla. Taxi drivers and politician mouths were the loudest. For those who want a refresher on how Anguilla was viewed in the international press, just click on the link.

    Ferocious Anguiillians Demand Dolphins Stay

    I do hope the EIA also examined the issue of public health safety. Dolphins are known to carry diseases that can infect humans. Can we ensure that the proiper testing facilities can accomodate such a facility so close to a public beach?

    Ras B of Heart Beat Radio was the only one in the media willing to hear the opposing view.

  33. They are treating us like backwater beggars who will grab at any scrap -crap- they throw at us.I know that we are a better people than that and we have to get up off our lazy behinds and actually do something about DD trying to railroad us into accepting their sorry proposals.We must force Gov't to carry out our wishes without bias.Where is the democracy in all this?It appears as if Gov't has already sanctioned the project but is keeping it secret.Well surprise surprise it really shouldn't come as a shock they have done some shady things before.
    Our only hope is to force Gov't action ,make them know that the people of Anguilla has spoken and they must be compelled to act against DD and their project of destruction.

  34. The first 5 posters were critical of and asking questions about the author of the Socioeconomic Report and who was behind it as well as whether the company was registered.

    I asked a friend who has access to the online registry system and she tells me that there is a "Yopung & Clever Consulting Ltd." She says this is an IBC and therefore should not be dealing with Anguillians.

    Of more interest is a company called YOUNG'S BROKERAGE & ENTERPRISE LTD whose Registered Office is "Private International Trust Corporation" who are now located at Auckland House with the Lake Kentish law firm in The Farrington. The 2007 Annual Return shows:
    06. The Directors of the company as on 01-Jan-2007 are

    Name Nationality Appt. Date Lana Hoyoung Anguillian 14-Feb-2006
    Leroy Hoyoung Anguillian14-Feb-2006
    Lavau Hoyoung Anguillian14-Feb-2006
    Name, Address & Mailing Address
    Lana Hoyoung,
    Seaview Cottage No.2
    South Hill, Anguilla
    P.O. Box 1395
    The Valley, Anguilla

    Leroy Hoyoung
    South Hill, Anguilla
    P.O. Box 1395
    The Valley, Anguilla

    Lavau Hoyoung
    South Hill, Anguilla
    P.O. Box 1395
    The Valley, Anguilla

    07. There are no Officers for the company as on 01-Jan-2007

    08. There are no Shareholders for the company as on 01-Jan-2007

    09. There are no Guarantors for the company as on 01-Jan-2007

    10. Are Shares Distributed to the Public ? NO

    11. Does the company maintain a physical presence, office, or staff in Anguilla, or engage in any money generating activities in Anguilla ?
    12. Business Company License
    13. Business Name
    Young's Brokerage & Enterprise Ltd.

    Filing Date 03-Aug-2007

    I had to reformat the above a bit in the hope it would display and be legible here. I can send the Word version of the Annual Return to Don if it does not display well and then Don can forward it if he wishes.

    So it seems as if the business did not have a business licence as at 3 August 2007. It might have one now; only the licence holder, anyone who visits the office and the Ministry of Finance would know. However the licence which was pending as per the annual return is in a different name to that which appears on the report. Maybe out of embarrassment.

  35. Anonymous poster at December 05, 2007 5:44 PM ( thank you, that info was most helpful)
    God Bless the bloggers and may more sprout up to keep government and others on their toes. Those who cannot perform must be removed from the system. It just goes to show when we put our minds together we can get to the bottom of all this shady crap going on in Anguilla.

    This is a sad state of affairs that an EIA can be so bias. Why are Anguillians putting money first before what's right for the island? Who paid to have this EIA done? How was the offer given to this company? Was it publicise? And is there a similar report done by the Planning or Environment departments? What are the established criteria for conducting EIAs in Anguilla? What qualfications or certifications are necessary to handle EIAs for government or private companies? Can anyway declare themself to be consultants in Anguilla?

    I hope the media can pick up this thread and get a response from the author/s of this EIA.

  36. Was this really written by Lana? The English is appalling. Didn’t anyone every check over it? She now calls herself Dr Lana Hoyoung—I wonder what she studied, certainly not English!


    According to the Executive Summary, there is to be a "Construction Phased" [sic] and a "Phase Two" which "may be done through rent or construction physical premises for restaurant, boutiques, bird and turtle sanctuaries." This is in direct conflict with the main part of the EIS which does not mention phased construction.

    As both versions cannot be true, one must be false. It is difficult to know how to respond to such a situation without reliable facts.

    It is also difficult to understand the strange English dialect used in this report, and which I have never encountered in my travels throughout the English speaking world, but I think they're saying they might rent the restaurant, some unstated number of boutiques and the various "sanctuaries" and place them on the Sandy Point property. This is difficult to envision. Perhaps the plan is to have a rented food truck.

    Although the EIS speaks of a high class facility, the image I'm getting sounds more like the "Coney Island" travelling circus that was brought in several years ago to commemorate the anniversary of the birth of Our Saviour.

  38. The Executive Summary lists only two negative effects: those voiced by those who oppose animal captivity and those who don't wish to see Anguilla impacted by tourists "at the lower end".

    I agree with the writer that captive dolphin facilities attract the lowest of the low end Caribbean tourist. I'm pleased that there is no argument about this fact.

    In light of the very serious environmental and other problems I have commented on previously, and the fact that the people of Blowing Point have made it abundantly clear, according to their elected representative, that they do not want and will not allow this facility at Sandy Point and will not cede to foreign investors the beach they have enjoyed for countless generations, it is an insult to the intelligence of the Government and people of Anguilla to claim there are only two possible objections.


    It is suggested that a "Dolphin Discovery Evacuation Plan" be developed to meet "the Standard" to be set by Disaster Management.

    What sort of disaster is anticipated and who would be evacuated? Does this have to do with hurricanes? Earthquakes? Tsunamis? Jet planes crashing to the ground by Sandy Point? A flood in the Blowing Point River Delta? The rising of a volcano as happened just outside of Plymouth, Montserrat 12 years ago? What "Standard" has Disaster Management devised? Is it specific to the proposed site or does it apply to all of us? If a volcano erupts by Sandy Point, are we such Bobo Johnnies that we must read some government directive in order to know whether to run east or west?

    This "Evacuation Plan" is put forth as a mitigation measure for some undefined issue or impact that may arise at the project site. This seems to be a solution in search of a problem.


    I read with some amazement their comment on the proposed relocation to Sandy Ground. It is described as having "met with planning approval but due to miss guided information political and land/lease discrepancy the project was not allowed to be built in Sandy Ground."

    Translation: "miss guided information": According to the Chief Minister, the approval from Planning contained the clear condition that an alien land holding license had to be obtained. Either this was "miss guided information" or DD's understanding of it was "miss guided", it is unclear.

    Translation: "land/lease discrepancy": DD started construction on a public beach without a lease on the public land they were building on. This is trivialised as a "discrepancy", or minor technical problem. What are we to think about a company that boldly moves ahead and misappropriates a public beach with neither lease nor license? What are we to think about an Anguillian who excuses such an abomination as a mere "discrepancy"?

    Raise your hand if you think this Anguillian has submitted an objective, unbiased report.

  41. "The project is to be located in the sea with facilities such as restaurant on part of the land area that was specifically bought to develop a National Park to preserve it [sic] cultural heritage."

    The statement speaks for itself.

  42. NOISE
    Persons say "that their dwellings will be devalued due to the noisy sounds made by the animals and the equipment such as generators used to operate the facility."

    Dolphins are as quiet as fish. The Electricity Ordinance prohibits the use of generators when Anglec power is available. The noise seems more likely to come from the exotic birds, 25,000 people, their screaming children and their buses and other vehicles.

    The proposal to relocate the project to this area "has given the impression that Public access and use of the beach would be lost."

    I'm glad we all understand this.

    The socio-psychocological gobble-de-gook in this Report is offensive. You read stuff like, "Often Children are further at risk when migrants often have convenient or temporary to meet their sexual needs (Marshow has classified sex as a basic need of all living organisms). Added to this economic need also lend itself for unacceptable behaviour such as prostitution in which boys and girls to indulge in."

    Assuming you can follow what this illiterate nonsense means, Abraham Maslow, the American psychologist (1908-1970) said something like that. I will try to comment on the rest if I'm able to translate it into English. I think the writer is suggesting that swimming with dolphins will relieve the need for such behaviour.

    The report continues for many pages about the moral and ethical conduct of "migrants" and the danger they represent to our community. It is difficult to differentiate xenophobic hostility from thinly disguised race hatred.

    The author seems to be suggesting that the relocation of the dolphin facility will cause or contribute to various sexual events, the nature of which are concealed behind the flowery but vague language. To mitigate these social effects, the writer suggests that the government, not DD, "implement the CRC Convention so that all children born on Anguilla has their right to citizenship", and that "migrant workers be able to communicate in basic English." Her reasoning is more difficult to follow than her English.

    Mitigation measures are usually those imposed on a developer who causes or contributes to social or environmental impacts. This report attempts to shift responsibility onto government, the community, and even Anglec:

  46. Concern has been expressed that "Visitors will strung [sic] the beach and walk to the facility instead of taking a taxi." This problem will be mitigated by eliminating taxis altogether and use the "transportation contract agreement with the two Bus operators" and "Government outlines the path of access to the Sandy Point Beach."

    I find it difficult to understand the last part or how it would work. Perhaps people will be misdirected somewhere, forcing them to hire a taxi before they collapse from heat and thirst.

  47. “Guards will be in place to ensure the safety of beach goers during the construction period”.

    Right. And pigs will fly.

    At the end of the last page it is revealed that a plan must be put in place to evacuate the dolphins in the event of a hurricane. No suggestions are made on how this might be accomplished, who will do it, what equipment will be required, where the dolphins will be transferred or what will be done should the dolphins fail to cooperate.

    Respectfully submitted,

    Miss Guided

  49. In May of this year a paper was presented in Grenada at a United Nations conference for the eradication of colonialism in by Dr. Lana W. Connor Hoyoung, who stated that decolonization "remains inclusive of us all people, who are trapped in servitude, continue to be controlled and have decisions imposed upon us." Her words are pure Hubert, but without his ability to speak English.


    "To sight one instance" she alleges that Permanent Secretaries who run everything are answerable to the Governor, and thus the Permanent Secretaries are effectively the tools of the evil British in controlling Government and oppressing women. "The UK Government is tightening its grasp on the people of Anguilla" and "we are in the Rigours of Colonialism, a people deprived of a voice and a culture."

    But "our people is awakening." Primary among Dr. Hoyoung's oppressors is "the Mitchell's Commission that have set about to draft and make recommendations the constitution. The processes that are not propelled by the people but rather is interpreted as imposed upon them. We reject any false semblance of involvement of us women to make it appear gender equitable by appointing any woman on a committee.

    In her recent review of the dolphin relocation she states that it would bring Anguilla economic rewards and benefits beyond measure, but in Grenada she stated that we are having an economic boom but "only a little is really trickling down to the masses." She revealed that the economic boom amounts to trickery by the UK to deprive us of the vision and goals of the Revolution, a "land marked event".

  50. Today in Anguilla, money is king and everything is for sale. Some of us who are too old to sell our bodies will sell our integrity.

    Eric Reid, in his farewell address before the last election, warned us of "people who become community minded only to ensure their own personal gain."

    See it dey.

  51. Thank you for these excellent comments.

    I wonder if Nat Hodge, Teacher George or Brenda Carty read this blog and the comments. If so, whether they will post Don's article and the comments on it?

    If they don't, I'll bet that they won't be averse to receiving them as a paid advertisement.

  52. Teacher George is in favour of having a mix of low and high end tourism that has failed everywhere else. He is in favour of cruse ships, unlimited development and unlimited importation of foreign workers. He supports anything legal that brings in money, including the dolphin sideshow.

    Dolphin psychologist Brenda Carty, after the original dolphins were captured in Cuban waters and brought to Anguilla in boxes, commented on "the happy dolphins." She is an otherwise sensitive and intelligent person.

    My opinion of Nat Hodge as a crusading editor is extremely low, but I must commend him for printing this anonymous letter recently:

    "Letter to The Editor Mr. Nat Hodge The Anguillian Newspaper The Valley Anguilla

    "Dear Sir,

    "When did the Dollar Sign replace the Dolphin as our National Emblem? This year we celebrated the 40th anniversary of the Anguilla Revolution. It is so ironic that as we waved our flags celebrating our heroes and heroines of the Revolution and the economic progress of our proud nation, the Planning Board would allow the dolphins, our national symbol, to remain in captivity and furthermore, allow the owners of this dolphin facility to pollute our waters and obstruct our beaches. It is just a myth, a FANTASY, created by large foreign owned corporations that dolphins thrive in captivity and enjoy performing tricks for selfish humans with more money than morals."

  53. Does anyone know where Dr. Hoyoung was awarded her degree?

  54. In the USA, they dicuss anonymous bloggers all the time and remark on the various comments. In Anguilla, we don't have any journalist to elevate the discussion to bloggers. They would want to know who the posters are, where they live and who their parents are.

    At least they know who the owner of the blog is, so why not disucss this serious topic on air.

  55. Steve Donahue has kindly posted the EIS and Hoyoung Appendix at:

    Dolphin EIS

  56. Everyone may not be aware that the annual meeting of the Anguilla National Trust is tonight, Thursday, 6 December - Paradise Cove Meeting Room, 6:00 PM - Refreshments served following meeting.

    All are welcome, both members and those who care about what kind of Anguilla we leave to those who come after us.

  57. "Does anyone know where Dr. Hoyoung was awarded her degree?"

    Considering that a bona fide degree implies that she would have needed to have graduated and then done more time on top of that, I can only wonder if it is the same place where Carlton Pickering got his degree.

  58. Is there an Environment Impact Assessment Act/ Ordinance in Anguilla? And do we have an Environment Impact Assessment Review Committee? We need to stop this nonsense right now.

    The inconsistenecy in English(UK) and English (USA) is annoying. Where did this person graduate. I am so embarass this thing is online. It is bloated with content and no substantive objective relevance. Also the document is bordering on plagiarsim with sources not properly cited.

    I would suggest Dr. Hoyoung recall this document and enroll in Preparing and Environment Impact Assessment report 101 class.

    Sadly, I could not read the entire monstrosity. Much bigger projects in the developed world with populations in the millions have shorter assessment reports.

  59. Here is the link to ATM website:

    Applied Technology and Management

    Can anyone verify if anyone from the company ever set foot on Anguilla? Is this a remote assessment report?

    I do hope the Talk Shows can have on 2 or 3 experts so persons can call in and ask questions.

  60. If Lana Hoyoung is indeed the author of this clumsily written EIA which is clearly crafted to hoodwink the the unassuming government authorities, then Lana should be tarred and feathered! I can't for a moment comprehend that someone from Blowing Point would wish to assist in seeing one of Anguilla's last remaining pristine beach areas sacrificed to satisfy the the whims of a bunch of money hungry prospectors.

    Sandy Point for me, and I'm certain for all other Anguillans who appreciate nature, is very special. This emerged reef or spit with its turquoise water and dazzling little beach is part of our natural heritage which should and must be preserved. Sandy Point must remain unspoilt and untouched by the clutter of man-made influences and preserved for the enjoyment of all.

    While travelling on the ferry from St. Marrten one evening, I fixed my gaze on a bent, solitary figure silhouetted againts the sinking sun foraging on the Sandy Point spit. The timeless image conjoured in my mind a picture of how our ancestors of over five centuries past survived using their God given resource-the sea.

    Let us seek to protect this little gem called Sandy Point for the enjoment of future generations.

  61. Well I should say that it seems as if Anguillians are agin getting suckered into a false sense of security by placing their trust in the dollar. These investors beleive that flashing around dollars to a small third world country will compensate for its lack of wealth and coerce them into doing their bidding. Alas, they have discovered that not all Anguillians are for sale. Our history is filled with struggles and hardships as we worked to better our living conditions here at home. We have sacrificed a great deal to achieve what we have today and are proud of our accomplishments. It is therefore distressing to see that some people have forgotten all of that. Once we were shunned by most other carribean islands as backward and worhtless. Despite this we worked hard to make our island a beacon of the region worthy of world recognition. Our purity and humility have sustained us thus far and now it seems we are becoming more arrogant as our wealth and standard of living has increased. We appear to be acting on whims and without any serious deliberation to the impact of the various projects undertaken.

    If we have survived so far without all these grand developments, why is it that we are so willing to sell our selves short and not conduct the necessary EIS before approving them? Our space is small and precious and so are our beaches. If we fail to do the necessary EIS we will surely lose that glorified status and again sink to the lower echelons of society where we have worked so long and hard to climb out of. Arrogance and greed are the culprits that are crippling our island today. Why do we crave such wealth at the expense of our birthplace? The dolphin which is celebrated on our flag is being exploited and we are not even concerned but we are about the turtle dove. What is the significance of the dolphin on our flag? Why are we trying so hard to poison and destroy our seawaters and beaches? Many a fortune was made by our fishing industry but we seem not to care anymore because the hotelier and other are now interested in us. Who wants to fish when we can work in a hotel etc. I hope we never live to regret these decisions our political officials are making. We really need a reality check people and stop all this crazy nonsense.

  62. Could someone post, or point me to, the URL for the full Environmental Impact Statement? Please forgive my ignorance if it is on this blog entry already.


  63. I found the answer to my own question. Here is the URL for the EIS:


  64. Lets be clear, the Environment Impact Assessment was done by Applied Technology Management (ATM):

    Applied Technology and Management

    The Social and Cultural Impact Assessment was done by Young Consultancy:

    Hoyoung Socio-Cultural Impact Assessment

    Just click the links and view.

  65. Correction

    Environement Impact Assessment

    Environment Impact Assessment

    The Social and Cultural Impact Assessment was done by Young Consultancy:

    Hoyoung Socio-Cultural Impact Assessment

  66. And let's be clear, when two entities work together to defraud others, that is called a criminal conspiracy.

    I'm not saying that's necessarily happening in the present case. I have formed my own opinion about that, which I'm keeping to myself.

    You are welcome to decide for yourself. We do not make statements on this blog that are potentially libellous. We cannot be sued for what we think.

  67. When young, fragile and hungry few came to my side,
    As I cried where were you to comfort and wipe my tears?
    I rebelled, you rebuked as foolish pride,
    I was cautious, for you it was unwarranted fears.
    I struggled, where was your guidance,
    I needed you, you snickered and sneered.
    On my own I blossomed, you claimed covert governance.
    Now tides have turned, you proclaim you cared.
    A portion of wealth, yes that seek you,
    Colonialism, a hole in my heart doth burn,
    But alas, you claim we no longer can do.
    To submit, I'd rather to the earth return.
    Freedom , like a cool sea breeze,
    Flows unabated where ever it choose.
    So, never again will I bend at the knees,
    For a free spirit hath too much to loose.

    This is by an unknown author

    It so appropriate that I post this. Anguilla seems to be preyed upon by vultures who are bent on tarnishing its pristine image. They appear to want us to return to "a desolate and barren state". We should be proud of our country and work hard at preserving what we have. Our culture, heritage and values. Change will come and we welcome it, but do we have to sacrifice our very souls for it? We were rebuilt on the pride we had in ourselves to be hard working and honest people. We struggled but we maintained and created a robust economy and a higher standard of living for all Anguillians. Those who have left are now returning and others from the region are longing to get to our shores. However, if we continue down the road we seems to be heading all this prosperity could easily vanish. What will we have after its all gone? We surely do not want to return to drinking sugar water and butter bread when we can retain our ability to experience the finer things in life. Yes, this is a little extreme but it is just an example of how our future might be if we are not careful.

    Arrogance, greed, pride and just plain stupidity or ignorance will destroy any country, all the great empires fell because of it.

  68. Where is the description of qualifications of those who produced the report?

  69. Description of qualifications? The main "researcher" doesn't even reveal her name!

  70. Appendix 1 (Young Consulting)

    This appendix was essentially illiterate and therefore difficult to read. Perhaps English is not the first language of the author, but the failure to have the document proofread and the English corrected is remarkable.

    All opposing views or positions are characterized as misguided or otherwise unsubstantiated, including, for example, regarding potential impacts from increased vessel traffic (see below). However, increased traffic will without doubt have a negative impact on the environment, even if this impact is negligible, minor and/or mitigated. The appendix suggests that this increased traffic will have no impact, which is unrealistic. This type of bias appears throughout the document, decreasing or even eliminating its value as an objective analysis of impacts.

    In general, this document does not analyze anything with sufficient rigor or depth – its standards do not approach even those of a relatively minor environmental assessment (let alone a detailed environmental impact statement) in the United States. It is not in fact an objective analysis of impacts at all, but rather a (shallow) supportive statement from someone who is clearly completely biased in favor of allowing Dolphin Discovery to move to Sandy Point.

    Specific concerns:
    p. 10, 1.2.1 – describes increased traffic (ferries, etc.) only in terms of taxes and revenues – there is no indication of possible environmental impacts of this increased traffic.

    p. 11, 1.2.1 – states that “The employment also affords Anguillians to do some specialized skills such as Marine Mammals training, Photography, Plumbing, Electricians, and Divers and to be part of middle management” [sic]. Are any locals in fact employed as trainers at this facility? In many Caribbean dolphinariums, the trainers are non-nationals. As for plumbers and electricians, their opportunities for employment are hardly dependent on this facility. This is an overblown assertion that offers no hard data for support (how many locals are employed at Dolphin Discovery? What are they employed to do? A table or list should be provided, rather than unsupported and unquantified assertions like this).

    p. 11, 1.2.2 – states that other locations were “unsuitable.” The EIS needs to describe how the other locations are unsuitable or in some way explain or provide support for what are otherwise unsubstantiated assertions. An EIS is not supposed to be a litany of didactic assertions, but rather a detailed description of impacts and/or options, including references, data, and other support for the conclusions drawn.

    p. 13, 2.2 Fact Finding – this section in general describes “research” that uses methods that struck me as the sort a journalist might use to write an “investigative” article (interviews, review of subjective documents as opposed to technical reports, etc.), but are not sufficient for true analysis or evaluation. Journalists report facts and ideally leave conclusions to the reader – an EIS should evaluate facts and actively draw conclusions. This section struck me as (mis)using reporting methods in what the author calls an evaluation but is really just selective identification of facts that will support a pre-determined outcome.

    p. 14 (bullets) – this list of bullet points has no references. It appears to be a list of the perceptions of the author on what the concerns are. There is no way to confirm that this list accurately reflects the concerns actually being expressed by stakeholders. I note this because one bullet, about sharks, isn’t even true. There are no published papers of which I am aware regarding “sharks following dolphins” – dolphins in fact are effective at repelling sharks, so there is no reason to assume sharks would “follow” dolphins (whatever that means).

    p. 15, 2.2.2 – the first paragraph of this section makes little sense – a growth (rate?) of 18.5% is given, then a growth rate of 1.77% is given. A reference is made to U.S. Census Bureau data – but what the U.S. Census Bureau has to do with Anguilla is not made clear.

    p. 16, 2.2.2 – states that “many of the [Dolphin Discovery] staff is locals or residents living on the island.” This is the kind of general, qualitative (and unsubstantiated) statement that is found throughout this document. Exactly how many staff members are locals? (“Many” seems an exaggeration when the total staff numbers at Dolphin Discovery cannot be very high.) Which jobs at Dolphin Discovery do these locals hold?

    p. 17, 2.2.3 – this description of the local community into which Dolphin Discovery seeks to build comes across more as an argument against building a dolphinarium there than one for it. A community that is apparently rapidly expanding, that may very well soon overtax its existing infrastructure, that has drug and alcohol problems and so on is not a community into which a facility housing highly specialized (and non-native) wildlife should be introduced. Such a facility has an obligation to keep its animals safe from harm (including from local vandals) and must deal with a large daily traffic in tourists (transients). A rapidly expanding community with potential infrastructure shortfalls and even some social ills (however small – and this description suggests these social ills are not small and are in fact expanding) is not an ideal location for such a facility.

    p. 20, 2.2.5 – the description of the 20-year development plan seems singularly unsuitable for an area neighboring a sea-pen dolphinarium. A “5 Star Terminal Destination” would be an incompatible neighbor for a sea-pen dolphinarium (land-based tanks would be better, but this is not apparently an option at this new location) – the noise alone would be a stress factor, but the potential for petroleum discharges and other pollution to affect the dolphins in sea pens would be significant. A similar plan to build a dolphinarium near the cruise ship ferry docks in St. Maarten was abandoned, due in part to the many problems associated with locating a dolphin sea pen so close to docks hosting such large vessels.

    The literature on the impacts of chemical pollution and noise on cetaceans (whales and dolphins) is growing every year – a review of this literature is done each year by the International Whaling Commission’s Scientific Committee and in a separate email I will send these reviews (known as the State of the Cetacean Environment Reports) from the last two years. There are many other science papers published on pollution and noise impacts on cetaceans – the IWC reports offer a key sampling of the most recent.

    p. 22, 2.2.6 – here again (the first mention was earlier in the document) the appendix notes that a national park is being considered for the area where the dolphinarium is proposed to be built, where national customs and traditional activities can be practiced. However, there is nothing “Anguillan” or traditional about a dolphinarium. A dolphinarium is in fact singularly generic or cosmopolitan, found all over the world (with varying levels of expertise involved in the care and maintenance of the dolphins, from substantial to virtually none at all) and nowhere particularly reflective of local culture or practices – Anguilla has no particular history with dolphins, not even hunting them.

    p. 24, 2.2.6, Table 2.6 – the fact that Blowing Point is the largest port of entry for Anguilla is, as above, an argument against situating a dolphinarium nearby, not for it. The greater the vessel traffic in and out of this port, the less appropriate from an animal welfare perspective it is to locate a sea-pen dolphinarium next door.

    p. 26 – it is phrases such as “It is therefore obvious” that Dolphin Discovery would remain a major tourist attraction that suggest the author of this appendix was highly biased. This “leaping to conclusions” in which the author indulges reduces the value of this document as a tool in evaluating the impacts of the proposed dolphinarium relocation. For example, it is not obvious at all that Dolphin Discovery will remain a major tourist attraction, at least not based on the information to which the author is referring (the expansion of a local airport). There is absolutely no logical connection between an airport expansion and the popularity of a particular tourist attraction. The airport expansion might facilitate traffic to and from a popular attraction, but in and of itself cannot maintain or increase the popularity of a particular attraction.

    p. 27, 2.2.6(g) Disaster and disaster management – this section has no useful information, other than to tell the reader that a disaster plan exists that has been approved by the “Department of Disaster” (is this a government agency?). What does this plan contain? How can one get a copy to evaluate it? Did the author of the appendix evaluate it or simply consider its existence evidence of effectiveness? Just because it exists and was approved by the Department of Disaster (the staff of which presumably has no expertise in dolphin transport or husbandry and therefore could not offer any substantive critique of the plan) doesn’t mean it’s an adequate plan.

    p. 28, 3.1 – this paragraph purports to describe the methodology of this part of the analysis, but all it says is that the author conducted research. That’s like defining brain surgery as “surgery on the brain.” Describing one’s methods as research does not describe the methodology! What kind of research was done and how was it done?

    p. 28, 3.2 – the author implies here that, because Dolphin Discovery has been operating at another location for seven years, obviously there have been no problems (in this section, the author is referring specifically to public health). This is not in fact obvious at all! On what is the author basing this conclusion? Existence and persistence of a business alone do not de facto mean there have been no problems (witness many instances where, for example, factories operated for years while steadily polluting the environment and causing serious health problems for residents, in some cases before the problems were identified and in many cases long after the problems were identified!). The author must provide or refer to evidence that there have been no problems during the 7-year-long operation of Dolphin Discovery at its other location.

    p. 29, 3.2(b) Recommendations – the bullet point list recommends that Dolphin Discovery have an “approved” hurricane contingency plan on file, when it should say that there should be an effective or even adequate hurricane contingency plan on file. Approval does not automatically mean adequacy, especially if the agency approving the plan has no expertise on which to draw regarding dolphin transport or husbandry.

    p. 31, 3.4 – I have no expertise in societal development, but this entire discussion on crime and “deviancy” strikes me as bigoted and unsubstantiated. Where are the author’s sources and citations for this diatribe on “migrant worker” sexual deviancy, etc.?

    (Continuing on p. 32) – as for the idea that the dolphinarium and swimming with the dolphins would in ANY way relieve the social stressors to which Anguilla is apparently now subject, thus presumably leading to decreased crime, drug use, and so on – this idea is so insulting to any normal intelligence that I can’t even articulate a response other than to say it is patently ABSURD. Even assuming that somehow swimming with dolphins would in any way alleviate the impulse to sexual deviancy or in any way address such social ills as prostitution (!!!), how many locals or residents will actually swim with these dolphins? This is a tourist attraction – will the locals most subject to the crimes at issue even be able to afford the entrance fee?

    This section is absolutely ludicrous.

    p. 33, 3.5 – the mitigation measures described for potential concerns regarding electricity and water supply are not in fact mitigation – they are the objectives of the mitigation. The goal is to ensure that there is adequate electricity and potable water – this goal will not be met by…ensuring that there is adequate electricity and potable water (!). Once again, the appendix fails to describe in detail how adequate electricity and water will be ensured.

    p. 33, Recommendations – once again, the author of this document shows a strong bias in favor of a pre-determined conclusion. This document is not an objective evaluation of impacts – it is a lobbying document from someone who supports the permit applicant.

    p. 34, 3.6.1 – this is the obvious place to discuss potential impacts from pile driving, an activity known to introduce considerable energy and noise into the marine environment (see IWC “State of the Cetacean Environment Reports”). Yet there is nothing here on this subject, an unacceptable omission.

    p. 34, 3.6.2(a) – this section makes a number of inappropriately subjective comments about the “luster” of the animal displays, once again showing bias. That aside, the claims that there have been economic benefits to the local community must be substantiated. It may seem a given that a business operating for seven years (and wanting to stay in business) will have economically benefited the surrounding community, but an EIS cannot simply state “the obvious.” It is meant to provide hard evidence for claims and conclusions and detailed evaluation of this evidence that convincingly leads to the claims and conclusions. Simply stating something does not make it a fact. Where is the evidence for the economic benefit to the local community – the tax revenue reports, the revenue amount for various businesses, etc.? Dolphin Discovery is a company based in Mexico – it is equally plausible to claim that the majority of the revenue has gone to the company’s headquarters in Mexico and has benefited Anguilla not at all. Evidence is needed for either claim.

    p. 35, 3.6.2(b) – the author makes another claim without substantiation – where is the evidence that much of the increased tourist traffic to Anguilla can be “contributed” (the author means “attributed”) to Dolphin Discovery?

    p. 35, Table 8 – perhaps I’m missing something, but this table actually seems to show that from 2005 to 2006, substantially greater numbers of people came to the island because they were on cruises and substantially fewer came to the island to swim with dolphins. If the implication is that the cruise ship passengers were also swimming with the dolphins (and the number in the table under “swim” was merely reflective of those tourists who came to the island by other means, such as the ferry, specifically to swim with dolphins), then that is not clear from the table.

    p. 36, 3.7 – there is no discussion here about the potential impacts to water quality and coral reef health from the proximity of a dolphin sea pen enclosure. Research conducted on a coral reef near a sea-pen dolphinarium (see http://globalcoral.org/Dolphin%20enclosures%20and%20algae%20distributions%20at%20Chankanaab,%20Co.htm) has shown that dolphin waste can have negative impacts on nearby corals. This needs to be discussed in the EIS. What kind of current/water flow exists in this area? What are the tides like? It is inadvisable to allow human swimmers in or near dolphin sea pens that are not adequately flushed by natural currents and tides.

    p. 37, 3.9.1(b) – this is the first mention of the size of the staff at Dolphin Discovery and the number of staff members who are locals. See comment above on this point. While this is an improvement on the completely unsubstantiated statements earlier in the document, this section still does not say what the locals are employed to do (are they cleaning crew or food servers? Are the non-locals the trainers?).

    p. 38, 3.9.1(c) – again, this is an improvement on the earlier vague assertions, but it is still an incomplete description of the employment situation at Dolphin Discovery. With only 45 employees, a table with all the jobs and whether the holder is a local or non-local could easily be provided – it would be far preferable to subjective statements such as “There are also Anguillians employed in the Management level of the company such as Human Resource Manager” (does this mean that exactly one Anguillan is employed at the management level? If it is more than one, what other management job(s) is/are filled by an Anguillan?).

    p. 41, 3.9.6 – there is no description or evaluation in this document of the education programs offered by Dolphin Discovery. The author appears to accept without question that Dolphin Discovery is providing an educational service to local children – this is clearly biased. The “conventional wisdom” that dolphinariums are automatically educational is unsubstantiated for the most part – I am aware of only one systematic study (done in Europe) on the quality of a dolphinarium’s education program and in that case, while information retention among schoolchildren was initially higher in those who took a course at a dolphinarium versus those who took the same course in a classroom, the difference disappeared within three months (this study was not published in a peer-reviewed publication so I can’t offer you a citation – it was presented at a European Cetacean Society conference in 2004). The other “support” for this conventional wisdom comes from opinion polls, which are not surveys that measure actual information transfer but merely summaries of public opinion. People might think something is educational, but whether it is or not can only be measured by objective examination. The dolphinarium industry has never conducted such objection examinations of their education programs – or if they have, they’ve never published them!

    p. 42, 3.9.9 – a bullet point mentions concerns about pollution affecting the dolphins’ well-being; however, the document does not offer any response to this concern. An EIS cannot simply note the concerns – it must address and evaluate them!

    p. 43, 3.9.9 – a “random survey” of 120 people is mentioned. There is no description of who conducted the survey, what the questions were, what methodology assured randomness, why the number 120 was chosen (was this sufficient for statistical significance?), what the standard error was, etc. It cannot be determined if this survey was even as rigorous as a standard opinion poll conducted by a professional polling company – simply asking the first 120 people one encounters on a street will not accurately reflect public opinion (all sorts of bias can be introduced with this sort of “random” methodology!). More detail is needed on methodology to ensure that these survey results are valid and acceptable for consideration in any decision-making process.

    p. 46, 3.9.9 Disaster management risk (I think it’s supposed to be “Disaster Risk Management”) – this section is fluff. There is no substance – merely a list of things that should happen (without any justification).

    The reference list seems thin and inadequate.

    In general, this document is insubstantial and shallow.

    Naomi A Rose

  71. Dr. Naomi Rose is a Marine Animal Scientist with the Humane Society of the U.S. She is also preparing a response to the main Environmental Impact Study.


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