We, citizens of the Commonwealth of Dominica, are writing to express our grave concerns about the announced construction of a yacht marina in the Cabrits National Park. This development, revealed during the groundbreaking ceremony on May 25, 2024, poses significant environmental risks and potential breaches of law, which we believe warrant urgent reconsideration. To be clear, we are not ideologically opposed to a marina, but firmly believe, if one is to be built, it should be done in a less environmentally sensitive area. Utilizing technology of the 21st century, Dominica could lead the way as a staging ground for an environmentally sound marina if we so choose.

Over the years, Dominica has done an exemplary job of positioning itself not just as the Nature Isle of the Caribbean, but also as a beacon of light in the fight against climate change by setting the laudable goal of becoming the first climate-resilient nation in the world. As a result, Dominica's reputation as a progressive, eco-conscious nation has gained global recognition with numerous international publications highlighting Dominica's climate change initiatives. Additionally, Dominica frequently tops the list of the best travel destinations with Dominica's eco-friendly hotels, bolstered by the Citizenship By Investment program, regularly feature at the top of luxury eco-resort rankings in prestigious publications like Forbes and Travel + Leisure.

Recently in November 2023, aligning with our commitment to protect 30% of our land and ocean by 2030, the government announced the creation of the impressive 788 square kilometre marine park area to protect the endangered sperm whales - the first sperm whale reserve in the world, garnering worldwide press attention, including coverage from the National Geographic Society and CBS, among others.

Considering the huge strides made over the years, we believe that the building of a marina in Cabrits National Park has the potential to seriously undo this important work, imperiling Dominica’s reputation as a leader in the fight against climate change, its brand as an eco-conscious tourist destination, as well as having negative consequences for the environment and surrounding population. It is also part of an alarming trend of giving away national park land (which is our shared heritage) to private investors.

The following are our main concerns:

Impact on Livelihoods & Environment

1. Flood Control and Water Filtration:

○ Wetlands play a vital role in flood control, particularly in buffering coastal areas
against storm surges and hurricanes. Wetlands are known to reduce the peak water flow in floods by as much as 60%, reducing the risk of damage to infrastructure and homes. The destruction of the Cabrits Wetlands increases the

 vulnerability of Portsmouth to climate change and natural disaster impacts. Backfilling of swampland in Glanvillia has already increased flooding in the town of Portsmouth.

2. Impact on Fishing Industry & Eco Tourism:

○ Wetlands filter silt-laden runoff, maintaining the clarity and health of nearby
marine environments. The construction of a marina threatens this natural filtration system, endangering marine life and coral reefs, which are already disappearing due to warming seas, pollution, and unsustainable development.

○ The Cabrits Wetlands and surrounding terrestrial and marine areas support diverse wildlife and act as a nesting ground for many species of fish, crabs, and numerous other terrestrial and marine species critical to the fishing and hunting industries. The destruction of this ecosystem will adversely impact the Fishing Industry and the livelihood of the fishers in the north. The Tourism Industry will also be impacted due to the destruction of picturesque diving sites due to siltation of the marine component of the Cabrits National Park. Human health and safety, both of which are vital to the local economy, will also be impacted. We have already witnessed some of these impacts with the introduction of the Cuban Treefrog.

3. Carbon Sequestration:

○ Coastal wetlands like the Cabrits Wetlands are crucial carbon sinks, absorbing and storing significant amounts of carbon dioxide. Wetlands store between 20-30% of the world’s soil carbon despite covering only 5-8% of the land surface. Disrupting these ecosystems releases stored carbon, exacerbating climate change, and directly contradicts our commitment to becoming a climate-resilient nation.

○ The Park is home to 10 species of crabs including 162 species of birds, 18 species of mammals, 4 endemic snakes, 1 endemic frog, over 10 species of crabs (the protection of which is critical for the continuation of our hunting season), all of which will be under threat with the building of this marina.

Cultural and Historical Heritage

1. Cultural Importance:

○ The Cabrits National Park and its wetlands are integral to the cultural identity of
the local communities, representing a connection to our natural and historical heritage.

 ○ Preserving the park aligns with Dominica’s ethos as the “Nature Isle of the Caribbean,” showcasing our commitment to environmental stewardship and cultural preservation.

Environmental and Legal Concerns

1. Critical Ecosystem and Legal Protections:

○ The Cabrits National Park, established in 1986, encompasses 1,313 acres of
protected tropical forests, coral reefs, and wetlands, including the vital Cabrits
Wetlands.
○ According to the Physical Planning Act, an Environmental Impact Assessment
(EIA) is required for any development within sensitive environmental areas. There is no evidence that an EIA has been completed or made available to stakeholders, nor that plans for the marina have been submitted to the Physical Planning Division for consideration.

2. International Commitments:

○ Dominica ratified the United Nations Convention on Biological Diversity (CBD) in
1994, committing to the conservation and sustainable use of biological resources.
○ The recent ratification of the Escazú Agreement in April 2024 mandates public access to information, participation in environmental decision-making, and justice in environmental matters. The current marina project appears to lack
transparency and stakeholder engagement as required by these commitments.

Feasibility Concern

1. In addition to a lack of an Environmental Impact Assessment, the plan also lacks a geological assessment. Since 2000, multiple investors have visited the site, yet declined to build due to the excavation costs - solid ignimbrite rock deposits from Morne Aux Diables volcano and blocky basalt from Cabrits volcano will result in unexpected difficulties, extra costs, and environmental impact. In addition, due to the nature of the area, the site will continue to fill with silt.

Call to Action

Given Dominica’s commitment to becoming the first climate-resilient nation in the world, the construction of a marina within a Protected Area stands in stark contradiction to this goal. We call on Dominicans to petition the government to:

● Halt the marina project within the Cabrits Wetlands and explore alternative locations that do not threaten crucial environmental resources.

 ● Ensure compliance with national and international environmental laws, including conducting a thorough and transparent EIA with full public participation.

● Prioritise sustainable development that balances economic opportunities with the preservation of Dominica’s natural, historical, and cultural heritage.
Dominica’s reputation as the “Nature Isle of the Caribbean” and a leader in climate resilience depends on protecting our unique and irreplaceable natural environments .Together we must create a future that will consider the long-term impacts on our environment, economy, health, livelihoods, and global standing.

ESCAZU AGREEMENT SUMMARY

Objectives:

● Ensure Access to Environmental Information:
○ Public access to accurate, timely, and comprehensive environmental information.

● Promote Public Participation:
○ Involvement of the public in environmental decision-making processes.

● Provide Access to Justice:
○ Facilitate access to legal and administrative proceedings related to environmental
matters.

● Strengthen Environmental Rights:
○ Protect the rights of environmental defenders and ensure the protection of human rights in environmental contexts.

Key Provisions:

 ● Right to Environmental Information:
○ Obligation for governments to provide public access to environmental
information.

● Public Participation:
○ Mechanisms for public involvement in environmental decision-making, including consultations and public hearings.

● Access to Justice:
○ Legal frameworks to challenge environmental decisions and seek remedy for environmental harm.

● Protection of Environmental Defenders:
○ Measures to safeguard individuals and groups defending environmental and human rights.

Geographic Scope:
● Latin America and the Caribbean:
○ Specifically targets countries in these regions, enhancing regional cooperation
and addressing shared environmental challenges.

Significance:
● First of Its Kind:
○ First legally binding regional agreement in Latin America and the Caribbean
focused on environmental democracy. ● Human Rights and Environmental Link:
○ Emphasizes the interconnection between human rights and environmental protection, aiming to empower vulnerable communities.