Mr Carlton Frederick, CEO
Planning and Development Authority
GNCA Building
Kirani James Boulevard
St George
Date as per email
Dear Mr Frederick
Application for full planning consent by Charis Group dated 6 January 2022 for land at Coral Cove
Further to representations made to you on 21 March 2022 and reproduced at http://www.coralcovegrenada.org/2022/03/31/why-planning-consent-should-be-refused/, and those by the L’Anse aux Epines Association, and those by various concerned community members, we write now to make what we hope will be helpful suggestions.
Firstly, we suggest that approval of this application should not be given whilst the decision on the outline planning consent (the AIP) remains under judicial review. If the court finds that the outline consent should not have been given then any approval of the full consent will be open to an immediate judicial review application.
Secondly, the application is not accompanied by a relevant Environmental Impact Assessment (EIA) when the Physical Planning and Development Control Act 23 of 2016 is crystal clear that it must be. The application is incomplete and cannot be decided legally until that is rectified. Completion of a satisfactory EIA (including meeting the standards of the terms of reference for an EIA issued by the Authority itself) is a significant undertaking and will take some considerable time.
Thirdly, our detailed representations to you of 21 March 2022 and reproduced at http://www.coralcovegrenada.org/2022/03/31/why-planning-consent-should-be-refused/ identify a number of issues where the application violates fundamentally the letter and the spirit of relevant legislation such that approval – even with conditions – would be open to a judicial review application.
Respectfully, we suggest that the positive and fair way forward from here is for the Authority to refuse consent (for reasons summarised above and because there has been no community consultation) whilst suggesting to the applicant that they now work with the community to come up with an acceptable and viable future for the site. We undertake to engage constructively in such work. As you know, we have offered this before to the developer but have been rejected and there has been no community consultation on this application or on the outline application that preceded it.
As this letter is being copied to various relevant governmental and statutory bodies, we take the opportunity to emphasise again that the 240-plus subscribers to the web site are not against tourism. We are against this development on this site: it is too big, too high, too brutal, not suitable for the harsh micro-climate, will cause irreparable damage to a residential neighbourhood, overload and damage the delicate residential road network, probably overload the utilities of water and power (no studies done but water is already a problem), cause biological contamination (plans assume a municipal sewerage connection that doesn’t exist), ride roughshod over a “critically endangered” and other “endangered” species, remove all natural vegetation habitat for native mammals and birds, and damage the ‘Pure Grenada’ tourism branding.
In working with the developer we would seek a smaller, environmentally sensitive, boutique hotel aimed at the rapidly growing eco-tourism market and based on marine activities and conservation.
Thank you for your attention as always.
Coral Cove Group: working for Grenada’s future
contact@coralcovegrenada.org