Adhesion to the Statement: Runway Extension Project at Gran Roque — Los Roques Archipelago National Park
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STATEMENT: PROJECT FOR THE EXTENSION OF THE RUNWAY AT CAYO GRAN ROQUE, LOS ROQUES ARCHIPELAGO NATIONAL PARK
Los Roques Archipelago National Park (Parque Nacional Archipiélago Los Roques, PNALR) was created in 1972 with the objective of protecting a complex marine ecological system of 221,120 hectares, made up of coral islands and rocky islets, coral reefs, lagoons, mangroves, and a wide variety of seabeds at varying depths, including the open sea adjacent to the archipelago. This is the first marine park created in our country and one of the first in the Caribbean region. Any activity to be carried out within the park must take into account the following considerations:
- The PNALR is unique in its kind in the Southern Caribbean, due to its great biological diversity and the extension of its two large coral barriers (east and south) and fringing reefs around many of its keys. Within the park’s area, coral reef, mangrove, and seagrass meadow ecosystems converge, offering shelter, food, and breeding sites for numerous marine species — among them many of environmental conservation interest, some classified as endangered (e.g., sea turtles), or protected by partial or total bans (e.g., lobster, conch, and sharks), as well as many other species of fish and invertebrates of commercial interest that represent the food and economic livelihood of the park’s resident populations.
- The PNALR has been included since 1996 in the list of wetlands protected by the RAMSAR Convention (Convention on Wetlands of International Importance, especially as Waterfowl Habitat), by virtue of its importance as a nesting site for seabirds and migratory birds.
- The fundamental instrument for the protection and administration of the PNALR is the “Plan de Ordenamiento y Reglamento de Uso (PORU) del PNALR” (Management Plan and Use Regulations of the PNALR), discussed in Public Consultation in 1990 and in force since January 1991. The PORU “establishes the guidelines, policies, and criteria that make up the Management Plan of the Los Roques Archipelago National Park, as well as the criteria for assigning uses, their zoning, and the rules that will develop such uses and regulate the execution of activities that may be carried out, both by the public and the private sector.”
- On November 1, 2011, by presidential decree No. 8,549, Official Gazette 39,797, with the rank, value, and force of law, the creation of the Territorio Insular Francisco de Miranda (TIFM) was enacted. This territory includes, among others, the Los Roques archipelago and designates, in its Article 6, the island of Gran Roque as the seat of government of the TIFM. The creation of the TIFM and the designation of Gran Roque island as the seat of government of this territory created a conflict of jurisdiction and interests between the development needs of the TIFM’s capital and those of conservation inherent to a national park such as the Los Roques Archipelago. For this reason, we believe it is necessary to apply the utmost environmental considerations to the actions proposed by the TIFM, so that they can be carried out in accordance with the sustainable development objectives consistent with the PNALR designation.
In this regard, information received from Gran Roque indicates the start of works to extend the runway at Gran Roque, by filling the sea with debris from the service area. This information has been verified through the review of satellite images.
Taking into account that:
According to the SATIM (Servicio de Administración Tributaria Insular Miranda), visitor statistics for the PNALR indicate that the maximum number of visitors was reached in 1998, with 63,778 tourists, and between 2013 and 2015 with an average of 45,000. By 2017, the figure had dropped to 29,474 tourists, 53% less than in 1998, and unofficial sources indicate that in 2018 the number of visitors barely exceeded 20,000. Several airlines (AEROTUY, SOL DE AMÉRICA, CHAPI AIR, TRANSAVEN) operated during those years of high influx to Los Roques, using aircraft such as the 37-passenger Dash, the 18-passenger Britten-Norman Trislander, the 18–20-passenger Dornier and the Let L-410 with 17 seats or the 18–20-passenger DHC Twin Otter. With these airlines, between 45,000 and 60,000 passengers were transported using the current runway. Currently, at least 4–5 airlines fly to Los Roques with LT 410 aircraft with 17 seats (AEROCARIBE), TURBOPROP JETSTREAM with 18 seats (SASCA), Grand CARAVAN 208 B (CONVIASA and AEROCARIBE). All of them land perfectly on the current runway, and their capacities are similar to those of the airlines of 10–15 years ago.
The extension of the Gran Roque runway at its northern end contemplates an increase in length of approximately 300 meters. Currently, this end borders directly with the sea in a small bay located to the northeast of that key. Such an increase in length is therefore only possible by filling that bay. Modifying the geomorphology of Gran Roque key through landfilling represents an action contrary to the principles of National Parks and to the uses permitted in the PORU.
The area where this work is intended to be carried out belongs to the zoning of “Managed Natural Environment” (“Ambiente Natural Manejado”) stipulated in Article 12 of the PORU, where only the following is permitted under Article 27: “The construction of rustic infrastructure necessary for the execution of recreation, tourism, and environmental stewardship activities, such as: visitor centers, refuges, viewpoints, picnic areas, piers, cafeterias, restaurants, restrooms, tourist camps, ranger stations, and similar works.”
The use of solid waste that has accumulated for years in the service area of Gran Roque as fill material to extend the runway, in addition to being inappropriate for this type of work, contravenes laws and legal regulations that govern this type of activity in marine environments and in National Parks. The PORU of the PNALR clearly establishes the management of such waste, in its Articles 73 and 74, which state that “the competent public agencies and tourism operators are responsible for collecting, sorting, and transporting to the mainland for final disposal all the solid waste generated by residents and that generated by their tourism operations, respectively.”
The area to be modified by the runway extension hosts mangrove ecosystems and seagrass meadows, both protected by national laws and by the PORU of the PNALR. These ecosystems will inevitably be impacted by this construction in the short, medium, and long term. Additionally, this construction would destroy the only hawksbill sea turtle (Eretmochelys imbricata) nesting beach on Gran Roque key, an endangered species.
The extension of the runway represents an unnatural physical barrier that will permanently alter existing current patterns (direction and energy of the marine front), affecting mangrove communities and turtle spawning, among other disturbances that will impact the park’s natural resources. For example, the accumulation of sand resulting from the debris barrier that will flank the runway extension will contribute to the gradual disappearance of the seagrasses currently occupying that area.
The extension of the runway in this area will produce a change in the local sedimentation pattern that will not only alter the physiognomy (geophysics) of that area of Cayo de Gran Roque (CGR), but will also affect the flow of water produced by the currents, waves, and tides that reach that area and feed the mangrove-covered lagoon located in the northeastern part of that key. Additionally, sandy beaches may decrease or disappear, or new ones may form where none currently exist — with consequences similar to those that have occurred along our coasts when breakwaters or jetties have been built without the necessary studies of currents, tides, sediment transport, and especially the Environmental Impact Studies (EIA) established in Article 129 of our National Constitution.
This work is being carried out without the corresponding Environmental and Sociocultural Impact Study, as required by Article 129 of the Constitution of the Republic. This work is an activity that is obviously causing damage to the ecosystem, and therefore the ESIA is mandatory, as expressly indicated by the current Decree 1257 (Norms on Environmental Evaluation of Activities Susceptible to Degrading the Environment), whose Article 6 expressly establishes the obligation to carry out a prior Environmental Impact Study for “public and private airport projects.” Moreover, the Ley Penal del Ambiente (2012) clearly states in its Article 43 that “the public official who grants permits or authorizations without requiring, evaluating, and approving the environmental and sociocultural impact study or other environmental evaluations in the activities for which the norms on the matter require it, shall be punished with arrest from three months to one year. The penalty shall carry disqualification from holding public office or employment for up to two years after serving the principal penalty.” In this regard, this work is being carried out not only in violation of an administrative regulation, but also merits a criminal penalty for the officials who have allowed it.
In view of the foregoing, the undersigned — all professional biologists, oceanographers, environmental engineers, environmental managers, and citizens interested in the protection of our country’s natural resources, and in particular, the resources of the PNALR — request that the competent authorities immediately halt the runway extension works at Gran Roque, and that representatives of this key’s community be called together with the other actors directly or indirectly linked to the PNALR, to inform them of the implications of carrying out this extension and to analyze the options for its proceeding, within the legal limitations applicable to the PNALR, and in particular, to the coastal and marine environment of Gran Roque.