The National Conservation Council is deeply concerned that proposed amendments to the National Conservation Act pose serious and irreversible impacts to the long-term health of Cayman’s natural environment by weakening the strength of the Act and therefore the capacity of the NCC and DoE to effectively administer its provisions. The proposed redefinition of “alien species” to exclude any species which has been in the Cayman Islands for 100 years or more is not only at odds with the globally accepted scientific understanding of the term but would also undermine current laws and very quickly unravel decades of dedicated conservation work. It is accepted by the global scientific community that alien (or non-native) species are animals, plants or other organisms introduced by humans, either intentionally or accidentally, into areas outside their natural range (i.e. the total geographic area where that species occurs naturally without human help) (see IUCN website link to definition). To redefine otherwise would therefore be unscientific and cause a significant and concerning shift in environmental policy in contravention of best global practices. Such a decision would have serious consequences for the management of introduced species in the Cayman Islands. Under this proposed definition, any plant or animal that has lived in the Cayman Islands for 100 years would be treated as a “natural” part of our islands’ ecosystems and therefore afforded protections to live in the wild that were never intended under the National Conservation Act. Enabling non-native species to live unmanaged in the wild would place unnatural pressures on species and habitats that evolved in our islands over millennia without such influences. A species does not become native simply because it was introduced a long time ago. This proposal effectively treats farm animals, pets and even pests, as part of our natural ecosystem. It would be scientifically invalid to treat domesticated animals such as chickens, cows, goats, cats, dogs, and even rats, as well as numerous introduced plants, as if they are native and belong in the wild. Not all alien species are invasive or require management, but maintaining the distinction between native and introduced species is essential so that those which do cause ecological harm can be appropriately managed. Island ecosystems are particularly vulnerable to introduced species because many native plants and animals evolved in isolation without the predators, competitors and diseases introduced species may bring. Cayman is home to species found nowhere else on Earth, making effective management of harmful introduced species especially important.
For example, our endemic Blue and Rock iguana hatchlings do not recognise a cat as a threat until it is too late because they are not born with this instinct. Green iguanas, which are native species elsewhere in the region, defoliate our native landscapes, predate on native species and lay 2-3 times as many eggs per nest compared to our native rock iguanas. Retaining the status of species like these as introduced species, not native to the ecology of our islands, and which therefore require specific rules for managing their populations and movements is critical to preserving the integrity of our islands’ natural environment – the actual purpose of the National Conservation Act, the Department of Environment and indeed, the National Conservation Council. The Bill also proposes making any delegation of the National Conservation Council’s powers subject to Cabinet approval. Such an added layer of bureaucracy would inevitably slow environmental reviews and create bottlenecks for both the Department of Environment and the Council as well as any other departments relying on their timely decisions. It is unclear what practical benefit this additional approval requirement would provide as the functions concerned are scientific and technical matters delegated to qualified Government experts. The National Conservation Council’s delegation to the Department of Environment is already in writing and gazetted. The delegation is for scientific and technical functions which are best accomplished by the scientific experts employed and entrusted by the Government of our islands. The Council’s role is to provide robust oversight of those delegated functions and high-level policy guidance. Further, recommendations coming out of the recent Cayman Forward forum included having the Central Planning Authority delegate more of its technical planning work to qualified planners in the Department of Planning. This proposal appears to be at odds with what was generally accepted as best practice by the public and private sector representatives attending the forum. Protecting Cayman’s unique biodiversity requires strong, streamlined, and evidence-based conservation frameworks - these proposed amendments undermine the integrity of this fundamental objective and raise serious concerns for the future of conservation in the Cayman Islands. The National Conservation Council remains committed to protecting and sustainably managing Cayman’s natural environment and resources for the enduring benefit of our unique biodiversity and our people.