Arguments on the Draft SDO
Our Planning consultant has examined the draft SDO and provides the following points that can be used to craft an objection. The letters refer to sections of the draft SDO as published.
The Minister of the Environment has published the Draft Special Development Order (SDO). The SDO is incomplete. In simple terms, the Minister of the Environment, who is supposed to protect our fragile environment, has produced an SDO that facilitates development instead of protecting our environment and natural resources. Specifically:
The SDO should only be for In Principle Approval, since all the conditions of approval impact on ability of this site to be developed:
(a) The Architectural Advisory Panel should have been consulted before approval. I can recall that many birds were killed flying into reflective glass when it was first introduced into city buildings. Will this be the case for these buildings?
(c) If Bermuda has a housing problem why give final approval for a major hotel development before the housing of hundreds of staff has been resolved?
(j) Bermuda already has problems with the stress on our electricity provider. This should be addressed before Planning approval is granted.
(l) An Environmental Impact Statement (EIS) determines the feasibility of a development. Why give approval and then ask, after the fact, to be satisfied as to the impact on our natural environment? And who will rescind the approval (worth millions of dollars) if the EIS confirms that this development will be detrimental?
(m) If the Ministry of the Environment has not discussed a Woodland Management Scheme with the Applicants, then how was the impact on Woodlands determined in order to give approval for development? And as the Draft SDO does not specifically say if or when a Woodland Management scheme has to be submitted, are the Developers relieved from that essential step?
(n) There is already a valid Section 34 Agreement in force on this site that protects natural features. Why would the Minister give final approval for development that is in conflict with that Agreement before it is rescinded, and then ask for another Section 34 Agreement that suits development and the Developers?
(o) Anyone who knows about Bermuda’s Planning and Development regulations knows that land can be zoned for one thing but used for something else. The draft SDO does not protect the agricultural land, it only maintains the zoning and, in any case that already falls within the Ministry’s power, even without the SDO. (One has to question whether this was included to mislead the public into believing the agricultural land would be preserved for traditional agricultural uses.)
(p) Once again, if the Minister is not sure of the impact of the development on our coastline, then why give final approval?
We note that no reference has been made as to whether the hotel is to be commenced prior to the 42 residential units. This raises the suspicion that, with this questionable SDO, Bermuda will be faced with more high-end homes built for the overseas market, with the hotel development rights left sitting in abeyance whilst the developers wait to sell it to the highest bidder.
PLEASE NOTE: Letters of objection to the draft Southlands Resort Development (Warwick Parish) Special Development Order 2007 may be sent in writing to the Permanent Secretary, Ministry of Environment, Telecommunications and E-Commerce, 3rd Floor, Government Administration Building, 30 Parliament Street, Hamilton, HM12, or by email to psimmons@gov.bm, and should reach the Ministry by 5:00pm Friday, March 23rd, 2007.