Misunderstandings of the East/West Arterial Environmental Impact Assessment Recommendations

The National Conservation Council (NCC) understands that there is current discussion in the public and political realms regarding the recommendations made by the NCC’s Environmental Assessment Board (EAB), including that route B2 of the East/West Arterial is the better choice. The EAB recommendations were made in the best social, economic and environmental interests of the country, based on the best information available to and from the government for the East/West Arterial. If the reasons for the East/West arterial have changed from those initially advanced by the National Roads Authority (NRA) - from reducing travel time to opening up the Central Mangrove Wetland for development - then this brings into question the very proposal for the East/West arterial. None of the Critical Success Factors identified by the NRA, Ministry of Planning, Lands, Housing, Agriculture and Infrastructure (PLAHI) and their consultants at the outset of the project included opening up land for development. If the underlying reasonsfor the East/West arterial have indeed changed then the consideration for the road needs to change at a fundamental level to reflect that. Until that time the NCC stands by the recommendations of the Environmental Impact Assessment (EIA) and EAB and takes this opportunity to expand on certain facets of those recommendations. There have been suggestions that B3, the currently chosen route, though slightly longer, more costly, and less environmentally sensitive, may serve other national infrastructure goals. If such goals existed they would have, or should have, been incorporated by the NRA into the terms of reference for the EIA (and the road itself). We are unaware of any such national goals having been detailed, considered and established. In particular, claims that opening the Central Mangrove Wetland north of the proposed arterial would provide suitable land for low‑cost housing (or industrial and commercial development) are implausible, given the well‑documented depth of peat in that area. Indeed, this very factor was central to the EAB and NCC’s recommendation of Route B2, which would reduce both economic and environmental costs by requiring less peat removal than Route B3. Council would draw Cabinet’s attention to the longstanding community proposals for the Central Mangrove Wetland (especially north of the road corridor) to be insulated from loss to development, such as through purchase from willing landowners over time as a protected area under the NCA.
Concerns have also been raised by PLAHI & NRA regarding the data used in the EIA, including projections of future road use. It is important to emphasize that the EIA (and its Terms of Reference (TOR)) relied on information provided by the NRA and its consultants. If deficiencies existed, the NRA should have corrected them before accepting the EIA. Alternatively, if the underlying data itself were invalid, then the justification for the road project as a whole would be compromised - a far larger issue than route selection. For the record, we have seen no reason to question the NRA’s data, and suggestions that it is unreliable are troubling. Another concern raised retroactively is that Route B2 could disrupt one quarry’s operations. The EIA did consider potential impacts on existing and proposed developments along the routes, including existing and proposed quarries, agriculture and other economic interests, and no input was provided at the time (in the Terms of Reference or subsequently) to suggest that this quarry warranted special treatment. If information was incomplete (a point raised after the fact), then that would reflect a broader weakness in the road planning process, not in the EIA itself, and we question why it was not raised with the EAB when PLAHI became aware of the new information. It must be recognized that any route of any road will have economic and social disruptions and the preferred route B2 is an attempt to make the best recommendation weighing these and other impacts against benefits as much as possible. Attention has also been given to the proposed solar canopy, with claims that its tangible benefits were not weighed against the arterial’s intangible benefits (examples given include increased foreign investment, and confusingly, increasing climate resiliency) regardless of if the solar panels are installed. This sadly misrepresents the process. Both the EIA and the detailed Cost-Benefit Analysis (business case) are designed to evaluate tangible and intangible impacts together, ensuring that Government decisions are fully informed. The canopy’s quantified benefits are significant, while intangible benefits alone struggled to justify the project. The solar canopy would also align with actual established national priorities as set out in the National Climate Change Policy and National Energy Policy.
Much has been made of the EAB’s recommendation of Route B2, with critics suggesting that its economic and environmental advantages are too small to matter. Yet these benefits, though modest in percentage terms, are not immaterial. They were calculated on the same basis as the road’s overall benefits, precisely to identify the option that delivers the greatest value at the least cost. To dismiss them is not to undermine the EIA or the EAB’s recommendation, but to cast doubt on the rationale used for the road proposal itself. Finally, objections have been raised about the EIA’s treatment of time savings and transport patterns. Here again the EIA relied on the same data and analysis used by the NRA to plan the road. If that is flawed, the weakness lies in the assumptions underpinning the business case, not in the EIA. As Government considers the EIA’s findings we encourage equal attention to the business case which, per the Government’s standard business case process, should be updated with the EIA findings to ensure a sound basis for decision‑making. If opening up the Central Mangrove Wetland for development was a primary objective of the East/West Arterial this should have been stated clearly at the outset for both the business case and the Environmental Impact Assessment, instead of focusing on traffic alleviation, which analysis now shows it will not address to the extent that original proponents suggested. The EIA was conducted according to established procedures, using the NRA’s data, and with careful consideration of environmental, economic, and social impacts. It is based upon this independent analysis commissioned by and for, and accepted by the NRA, that the EAB and NCC advises Government to reconsider the route of the road, as B2 is the better option, especially when including the proposed solar canopy. The criticisms of the EIA actually imply deeper systemic issues - whether in data available to the NRA, road planning assumptions, or policy clarity - but they do not invalidate the EIA itself. We urge Government to recognize the EIA as a credible and essential tool in the decision‑making process, and to ensure that its findings are weighed carefully along with the updated business case in determining the future of the East/West Arterial.