The proposed new piers at Dockyard will require extensive dredging in the dockyard area itself.

The project calls for the construction of a large landfill adjacent to the new piers to accommodate the transportation needs of cruise ship passengers.

The construction already underway of the double berth pier presents the double threat of sediment displacement due to disruption of the seabed, and the likelihood of toxic substances leaching into the sea water.

It is possible that sediment stirred up by construction-related work will blanket and smother fragile marine reef communities in the vicinity.

Once the dock comes into use, mega ships using their thrusters to dock at the new pier could displace considerable sediment, as could large ferries, water taxis and water sport boats.

It would have been important before this project began, for the Government and the public to have been informed through a formal study of the potential social, economic and environmental impacts of all aspects of the proposal including those from sediment displacement and resettlement throughout the dockyard basin and beyond.

It was, however, in 2007, after the project had already begun, that an Environmental Impact Statement (EIS) was prepared for the Ministry of Tourism and Transport by Bermuda Water Consultants Limited (BWC).

BWC consulted various Government departments, statutory bodies and several of the firms contracted for the project.

The resulting document reportedly lacked statistical data and the rigorous study required for such a significant and extensive project.

It should have been the subject of an EIS Audit. BWC was also commissioned earlier this year to perform a 'scoping' exercise – a step that sets the scope of the project, and should have preceded the EIS.

An an example of an area where rigour is required, there is a reference to the probable need for as much as 139,000 cubic yards 'foreign fill' material for the construction of the 64,800 square feet transportation area adjacent to the new piers.

Where would this foreign fill originate and what are the risks in the introduction of foreign bacteria and mineral content to our marine environment?

BWC does acknowledge that 'the import into Bermuda of overseas soils and rubble does pose a potential threat to the local environment…' but does not instruct on the studies or safeguards that should be applied.

More troublesome than the pier construction is the issue of the shipping channels.

When these mega ships approach Bermuda, in order to arrive at Dockyard they have to travel the entire length of our north shore – from East to West.

At the present time, the Panamax ships use the north channel.

We know that the west end of the north channel is narrow, with coral reefs on either side.

The BWC reports that they 'require daylight and local knowledge for steering a ship through them'.

If one looks at the reef chart, one can see that not only are the passages narrow, there is a sharp and almost right-angled turn ships have to negotiate in their final approach to Dockyard.

What plans are in store for the reefs lining these particular passages so as to enable a ship one-quarter of a mile in length, to navigate its way to the new piers in Dockyard?

We note this wording in BWC documents: "Future considerations may require some widening and deepening of the channels. This is a development process which may require dredging of seabed and removal of portions of the reef in selected areas of the North Channel."

Will access for these mega ships indeed require deepening and widening the channels?

Are we planning to blast the reefs to make way for mega cruise ships?

And exactly which portions of reef may be 'selected'? How will this impact the reef communities, sea grass beds and marine environment generally along the entire north shore?

We understand that when a portion of a reef is destroyed there is inevitably reef damage and/or destruction in adjacent areas.

An independent and rigorous Environmental Impact Assessment would enable us to know the facts from bona fide marine scientists.

They would also apprise us of the overall risks, allowing for informed decisions affecting Bermuda's northern reef communities.

We know, to a limited extent, how sediment plumes from smaller cruise ships have over the years affected sea grass beds, adjacent reef structures, fish and marine communities generally.

We would be derelict not to seek to know more before we commit ourselves to bigger and potentially more damaging ships.

Ship groundings present another potential problem. Though rare, groundings have in the past caused irreparable damage to the reef communities.

The National Trust in its 2006 review of tourism policy titled Cruise Ships and Sustainability in Bermuda notes that Bermuda's 'local resources would probably be insufficient for freeing a post-Panamax ship' should an accident occur.

Should Bermuda prepare for that eventuality? How much would such preparation cost? And if we were not prepared, how much collateral damage could occur while we waited for international assistance?

There are further questions about things like the effects of the greater propwash from larger ships; compliance with planning regulations and the risks of developing a dependency on cruise ship trade.

Unfortunately, without independent and rigorous environmental impact studies, neither we nor the Government will know the full range of consequences from this project, and its underlying policies, until after it has been completed; and then it may be too late.

With the Government requesting a Special Development Order (SDO), which would enable the project to circumvent scrutiny and bypass planning regulations and safeguards, we feel there is an even more urgent need for a comprehensive Environmental Impact Assessment to be conducted by a reputable and independent outfit, selected with the full agreement of all stakeholders.

Anything less is to sell Bermuda short and risk unforeseen and unintended consequences to our transportation infrastructure, our economy and our environment.