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ENVIRONMENTAL MANAGEMENT AUTHORITY

NOTICE OF THE FINAL ACTION FOR THE 2018

NATIONAL ENVIRONMENTAL POLICY (NEP) OF

TRINIDAD AND TOBAGO

{Monday 7th January, 2019 to Monday 25th February, 2019}

TABLE OF CONTENTS

1.0 ADMINISTRATIVE RECORD…………………………………………………………….1 1.1 Description of The Final Action…………………………………………………...1 1.2 Major Environmental/Development Issues………………………………………1 1.3 Reasons for Proposed Activity…………………………………………………….3 ATTACHMENT 1 – OVERVIEW OF THE DEVELOPMENT PROCESS ATTACHMENT 2 – LIST OF LEGISLATION, POLICIES AND PLANS REVIEWED ATTACHMENT 3 – LIST OF STAKEHOLDERS FORMALLY ENGAGED ATTACHMENT 4 – EXECUTIVE SUMMARY OF THE 2016 NATIONAL ENVIRONMENTAL LITERACY SURVEY ATTACHMENT 5 – OVERVIEW OF THE EXPERT REVIEW PANEL ATTACHMENT 6 – 2018 NATIONAL ENVIORNMENTAL POLICY ATTACHMENT 7 – RESPONSE TO PUBLIC COMMENTS AND BASIS OF THE FINAL ACTION

1.0 ADMINISTRATIVE RECORD 1.1 Description of The Final Action This 2018 NEP was prepared by the Board of Directors of the EMA (“the Board”) after

consideration of policy recommendations received from the Minister with the responsibility

for the environment, governmental entities, non-governmental entities, private sector and

the public.

This policy provides the framework within which all individuals, groups and agencies, whether private or public, will operate. The policy statements have their basis in universally recognised environmental principles that recognise the linkages and interrelationships among humans, other life forms and non-living things; the cyclical pattern of nature; and the fact that human health, societal well-being and economic growth are dependent on health ecological systems. The policy also strengthens the connection national, regional and international policies and goals. This 2018 NEP is therefore expected to provide a more enlightened approach to our use of natural resources for sustainable development. After several iterations of the document informed by stakeholder feedback (See Section 4.1) a final version was submitted by the Board to the Minister for her approval. The document was approved by Cabinet on 25th October, 2018 and subsequently laid in Parliament on 2nd November, 2018. 1.2 Major Environmental/Development Issues The challenges to environmental management in Trinidad and Tobago since the establishment of the previous NEP remain largely the same. However, there have been notable changes in the country’s developmental context, international relations and global thought on environmental management that call for an updated framework. The most substantial shift is with regards to the national approach to sustainable development and all of its facets. The Government of the Republic of Trinidad and Tobago (GORTT) recognises that the environment is intimately connected to poverty, economic growth, human health and well-being, disaster risk reduction, gender equality, peace and justice. Therefore, this revised policy goes beyond traditional environmental issues (e.g., pollution and conservation) to address issues that exist at the interface between the environment and society, and/or environment and economy. The 2018 NEP reflects and strengthens the environmental pillar of Trinidad and Tobago’s sustainable development thrusts by harmonising the national framework with regional and international sustainable development agendas, such as, the United Nations Sustainable Development Goals (SDGs).

The 2018 NEP presents a vision for the environment, as well as, six (6) priority areas/pathways for achieving this vision. Each priority area presents several policy statements to address key national issues. It also presents enabling actions that are pre-requisites for making progress in the priority areas, and a framework for implementing and monitoring the progress of the policy. All of these elements were developed through a robust process that involved a public consultation with a wide-cross section of stakeholders and literature review. The environmental/developmental issues addressed by the policy are: 1. Protecting environmental and human health through pollution control

This priority area focuses on the quality of the environment by addressing freshwater and marine pollution; air pollution from open burning, mobile sources, ozone depleting substances, land use change, commercial and industrial activities; noise pollution on land, offshore and underwater; solid and hazardous waste; and solid waste recycling, recovery and reuse.

2. Sustainably managing natural assets

This priority area focuses on the quantity and management of the environment. It specifically speaks to water resources, soil/land, biodiversity (inclusive of invasive alien species), coastal and marine areas, fisheries, agriculture, and mineral and hydrocarbon resources.

3. Improving the local environment The public and stakeholders strongly believed that a progressive environmental policy would seek to address everyday life, in Trinidad and Tobago, as settlements and development strongly impact the environment and vice versa. This priority area addresses planning and human settlements; green architecture and infrastructure; heritage, cultural and archaeological sites; national festivals and events management; and mass transit solutions.

4. Evolving a greener economy This priority area recognizes that the integration of environmental considerations into the way business is conducted reduces economic vulnerability and drives economic growth through the reduction of inefficiencies and waste, creation of jobs and development of new markets. This section of the document outlines the means of economic transformation and providing the financial support system for achieving the 2018 NEP’s policy statements.

5. Fostering an environmentally responsible society This priority area seeks to empower stakeholders and the general public to become stewards of the environment. It covers areas, such as, availability of information, and public access to information; communication, awareness and public participation; research; and access to, and implementation of environmental justice.

6. Addressing climate change and environmental disasters

Climate change has become near-universally recognised as an urgent and possibly irreversible threat to societies and the planet. This priority area addresses this threat and environmental disasters, in general, by speaking to climate change mitigation; energy efficiency and energy conservation; renewable energy; climate change adaptation; and comprehensive environmental disaster management.

1.3 Reasons for the Proposed Activity Legal Obligation The revision of the 2006 NEP pursuant to Section 18 of the EM Act and the submission of this Notice of Final Action are in accordance with Section 29 of that Act. Broad Based Public Participation This process of public comment will serve to incorporate the views of the widest cross section of the population. This is essential because the NEP will impinge on the actions of every individual and group in society Constituency Building The involvement of a wide public in the formulation of this policy serves to build the commitment required from all groups and individuals for translating the policy goal into effective action at all levels.

ATTACHMENT 1 – OVERVIEW OF DEVELOPMENT PROCESS

The development of the 2018 NEP occurred over the period September 2016 – November 2018. This process entailed: 1. A 2016 nation-wide environmental awareness/ literacy survey conducted by the

EMA towards revising the NEP which targeted nine hundred and eighty-four (984) households across all regional corporations and counties of Trinidad and Tobago; six thousand one hundred and twenty (6120) Secondary School Students (Forms 3 – 6) across Trinidad and Tobago and forty-five (45) senior officials representatives of nine (9) industrial sectors;

2. A 2016 stakeholder questionnaire survey conducted by the EMA targeting two

hundred and twelve (212) stakeholders across public, private and non-governmental spheres to gather initial feedback and perceptions of the 2006 NEP;

3. Thirteen (13) thematic focus group meetings hosted by the EMA across Trinidad and Tobago in 2016, each containing fifteen (15) stakeholders from those group’s thematic areas. The thematic groups were: Government Agencies, Ministries and State-Owned Agencies; Municipal Corporations, Local Government and Rural Development; Regional and International Agencies; Education and Research Institutions; Environmental NGOs; Environmental CBOs; Extractive Industry; Agriculture, Forestry, Fisheries and Wildlife; Business and Manufacturing; and Tourism, Maritime and Other Emerging Sectors.

4. A 2016 literature review and GAP Analysis report was commissioned by the EMA

to review over one hundred (100) documents consisting of national policies, laws and reports, regional policies and international policies with a direct bearing on the environmental governance of Trinidad and Tobago.

5. Comments and revisions from staff of the EMA; an expert review panel consisting

of distinguished persons in the realms of Energy, Climate Change and Sustainable Development; and the consultants contracted to lead the revision of the NEP.

6. Nine (9) public consultations held at Trinidad and Tobago over the period February

– May 2017 in the following areas: Arouca, Chaguanas, Port of Spain, Sangre Grande, Vessigny, San Fernando, Mayaro, Argyle and Scarborough.

7. Written submissions received via mail or electronically by the EMA from the public. 8. A formal Public Comment period on the draft revised NEP over the period October

2017 – December 2017 in which the document was placed online and at 19 locations across Trinidad and Tobago for public viewing.

9. Post-Public Comment feedback from various stakeholders and the Ministry of Planning and Development over the period January 2018 – March 2018.

10. Review by the Minister of Planning and Development, and Cabinet over the period

March 2018 – October 2018.

The feedback received resulted in several interim drafts that were gradually refined into the final version contained within this Administrative Record. Figure 1 showing an Overview of the 2018 NEP Development

ATTACHMENT 2 – LIST OF LEGISLATION, POLICIES AND PLANS REVIEWED FOR THE PREPARATION OF THE 2018 NEP

Environmental Policies, Plans and Agreements (Trinidad and Tobago)

National Waste Recycling Policy, 2015

National Policy and Programmes on Wetland Conservation for Trinidad and Tobago, 2002

National Biodiversity Strategy and Action Plan

National Forest Policy, 2011

National Protected Areas Policy, 2011

National Climate Change Policy, 2011

National Wildlife Policy 2013

National Tourism Policy

National Quality Policy (Draft) , 2017

Integrated Solid Waste/Resource Management Policy (Draft), 2012

National Development Strategy (Vision 2030), 2016 - 2030

Draft Yachting Policy, 2016 – 2021

Northern Range Hillside Development Policy

National Action Programme (NAP) to Combat Land Degradation

Integrated Coastal Zone Management (ICZM) Policy (Draft)

Quarry Policy White Paper 2007

Ecotourism Policy (Draft)

Strategy for Reduction Of Carbon Emissions In Trinidad And Tobago, 2040.

Civil Aviation Action Plan on Emissions Reduction for Trinidad and Tobago (APERTT)

Arima Borough Corporation Spatial Development Plan

Chaguanas Borough Corporation Spatial Development Plan

Couva Tabaquite Talparo Spatial Development Plan

Diego Martin Regional Corporation Spatial Development Plan

Mayaro Rio Claro Regional Corporation Spatial Development Plan

Penal Debe Regional Corporation Spatial Development Plan

Point Fortin Borough Corporation Spatial Development Plan

Port of Spain City Corporation Spatial Development Plan

Princes Town Regional Corporation Spatial Development Plan

San Fernando City Corporation Spatial Development Plan

San Juan Laventille Regional Corporation Spatial Development Plan

Sangre Grande Regional Corporation Spatial Development Plan

Siparia Regional Corporation Spatial Development Plan

Tunapuna Piarco Regional Corporation Spatial Development Plan

Legislation

Environmental Management Act, Chapter 35:05

Certificate of Environmental Clearance Rules, 2001

Environmentally Sensitive Area Rules, 2001

Environmentally Sensitive Species Rules, 2001

Water Pollution Rules, 2001 (with 2006 Amendments)

Air Pollution Rules, 2014

Noise Pollution Control Rules, 2001

Water and Sewerage Act, Chapter 54:40

Water Works and Water Conservation Act, Chapter 54:41

Forests Act, 1916 (Includes Amendments up to 1999), Chapter 66:01

Conservation of Wildlife Act, Chapter 67:01

Minerals Act, Chapter 61:03

The Occupational Safety and Health (OSH) Act, 2004 (with 2006 Amendments), Chapter 88:08

The Litter Act (Act 27 of 1973), Chapter 30:52

The Summary Offences Act, Chapter 11:02

The Fisheries Act, Chapter 67:51

Town and Country Planning Act, Chapter 35:01.

Marine Areas Preservation Act, Chapter 37.02

State Lands Act, Chapter 57.01

National Trust Act, Chapter 40.53

Municipal Corporation Act, Chapter 25.04

Planning and Facilitation of Development Act No. 10 2014

Waste Management Rules, 2014 (Draft)

Environmental Policies from Other Jurisdictions

Nigeria National Policy on the Environment

National Environmental Policy Kenya, 2012

Environmental Sustainable Policy, Australia, 2014

Environmental Policy Guyana, 1996

Barbados Sustainable Development Policy, 2004

National Environmental Policy, India, 2006

Jamaica National Environmental Action Plan 1999-2002

Anguilla National Environmental Strategy and Action Plan 2005-2009 Other International Agreements

Paris Climate Change Agreement 2016

Ramsar Convention on Wetlands, 1971

United Nations 2030 Agenda for Sustainable Development

Convention on Nature Protection and Wildlife Preservation in the Western Hemisphere.

Convention on International Trade In Endangered Species of Wild Fauna and Flora.

Convention on Fishing and Conservation of the Living Resources of the High Seas

International Plant Protection Convention

Geneva Convention on the Continental Shelf

Geneva Convention on the High Seas

Convention on the Territorial Sea and the Contiguous Zone

United Nations Convention on the Law of the Sea- Montego Bay

Cartagena Convention Oil Spill Protocol (Protection and Development of the Marine Environment of the Wider Caribbean)

Cartagena Convention LBS Protocol (Concerning Pollution from Land Based Sources and Activities)

International Tropical Timber Agreement

Montreal Protocol on Substances that Deplete the Ozone Layer as amended in London 1990, Copenhagen 1992, Vienna 1995, Montreal 1997, Beijing 1999

Vienna Convention For the Protection of the Ozone Layer

Basel Convention on the control of Transboundary Movement of Hazardous Wastes and their disposal

United Nations Framework Convention on Climate Change

Kyoto Protocol To The United Nations Framework Convention On Climate Change

United Nations Framework Convention on the Conservation of Biological Diversity and its Cartagena Protocol on Biosafety.

Lome IV Convention (Article 39) Annex II. Control of Hazardous Wastes as defined in Annexes I and II

Stockholm Convention on Persistent Organic Pollutants

Rotterdam Convention

Revised Treaty of Chaguaramas establishing the Caribbean Community including the CARICOM single Market and Economy

CARICOM Draft Environmental and Natural Resources Policy Other Documents

State of the Environment Reports, 2006-2015

Report on Complaints Database 2014-2016

Report on iCare recycling programme 2015-2016

Information on proposed Environmentally Sensitive Areas (ESA) and Environmentally Sensitive Species (ESSs)

ATTACHMENT 3 – LIST OF STAKEHOLDERS FORMALLY ENGAGED

Government Agencies

Ministry of Agriculture, Land and Fisheries o Forestry Division o Fisheries Division o Horticultural Division o Commissioner of State Lands

Ministry of Planning and Development o Environmental Policy and Planning Division o Town and Country Planning Division o Green Fund Executing Unit o Central Statistical Office o National Transformation Unit o Economic Development Advisory Board

Ministry of Works and Transport o Bridges, Landslips and Traffic Management (BLT) Programme Implementation Unit o Coastal Protection Unit (CPU) o Drainage Division o Maritime Services Division

Ministry of Public Utilities o Trinidad and Tobago Meteorological Services o Water and Sewerage Authority o Water Resources Agency o Trinidad and Tobago Electricity Commission

Ministry of National Security o Trinidad and Tobago Police Service o Trinidad and Tobago Fire Service o Trinidad and Tobago Coast Guard

Ministry of Health

Ministry of Finance

Ministry of Energy and Energy Industries o Energy Research and Planning Division o Minerals Division o Resource Management Division

Ministry of Education

Ministry of Rural Development and Local Government

Ministry of Tourism

Ministry of Foreign and CARICOM Affairs

Ministry of Social Development and Family Services

Ministry of Housing and Urban Development

Ministry of Labour and Small Enterprise Development

Ministry of Community Development, Culture and the Arts

Ministry of Trade and Industry

Tourism Development Company (TDC)

Office of Disaster Preparedness and Management (ODPM)

Institute of Marine Affairs (IMA)

Trinidad and Tobago Civil Aviation Authority

Port Authority of Trinidad and Tobago (PATT)

Tobago House of Assembly: Division of Agriculture, Marine Affairs, Marketing and Environment

Tobago House of Assembly: Division of Infrastructure and Public Utilities

Tobago House of Assembly: Division of Tourism and Transportation

Tobago House of Assembly: Division of Planning and Development

Tobago House of Assembly: Division of Health and Social Services

Tobago House of Assembly: Division of Education, Youth Affairs and Sport

Tobago House of Assembly: Division of Finance and Enterprise Development

Tobago House of Assembly: Department of Natural Resources and the Environment

Tobago House of Assembly: Department of Marine Resources and Fisheries Disaster Management Agencies

Caribbean Disaster Emergency Management Agency (CDEMA)

Tobago Emergency Management Agency (TEMA)

Diego Martin Regional Corporation

Port of Spain City Corporation

San Juan/Laventille Regional Corporation

Tunapuna/Piarco Regional Corporation

Arima Borough Corporation

Sangre Grande Regional Corporation

Chaguanas Borough Corporation

Couva/Tabaquite/Talparo Regional Corporation

San Fernando City Corporation

Princes Town Regional Corporation

Penal/Debe Regional Corporation

Siparia Regional Corporation

Point Fortin Regional Corporation

Mayaro/Rio Claro Regional Corporation

Trinidad and Tobago Emergency Mutual Aid Scheme (TTEMAS)

Regional and International Agencies based in Trinidad and Tobago

Basel Convention Regional Centre

United Nations Development Programme (UNDP)

Inter-American Development Bank (IDB)

Caribbean Public Health Agency (CARPHA)

Caribbean Agricultural Research & Development Institute (CARDI)

Caribbean Natural Resources Institute (CANARI)

Caribbean Meteorological Organisation

International Federation for Red Cross Red Crescent Societies

Global Environment Facility's Small Grants Programme (GEF-SGP)

Delegation of the European Union to Trinidad and Tobago

Caribbean Disaster Emergency Management Agency (CDEMA)

Pan-American Health Organisation/World Health Organisation (PAHO/WHO)

Association of Caribbean States (ACS)

Organisation of American States (OAS)

United Nations Development Programme (UNDP)

United Nations Economic Commission for Latin America and the Caribbean (UN/ECLAC)

United Nations Information Centre (UNIC)

United Nations Educational, Scientific and Cultural Organisation (UNESCO)

Inter-American Institute for Co-operation on Agriculture (IICA) Universities

University of the West Indies (UWI) St Augustine Campus

University of Trinidad and Tobago (UTT)

University of the Southern Caribbean

College of Science, Technology and Applied Arts of Trinidad and Tobago (COSTAATT)

Cipriani College of Labour and Cooperative Studies (CCLCS)

Arthur Lok Jack Graduate School of Business (ALJGSB)

Academy of Tertiary Studies

School of Higher Education

Inter-American Institute for Co-operation on Agriculture (IICA)

College of Health, Environmental and Safety Studies (CHESS)

School of Business and Computer Science (SBCS)

Academy of Tertiary Studies (ATS)

School of Accounting and Management (SAM)

SITAL College Environmental Non-Governmental Organizations

Nature Seekers

Environment Tobago

Buccoo Reef Trust

Turtle Village Trust

Zoological Society of T&T

Pointe-a-Pierre Wild Fowl Trust

Council of Presidents of the Environment (COPE) o Asa Wright Nature Centre o Pointe a Pierre Wild Fowl Trust o Blanchisseuse Forest Conservation Trust (BEAT) o Caribbean Forest Conservation Association o Citizens for Conservation o Centre for the Rescue of Endangered Species of Trinidad and Tobago

Environment Tobago o Fondes Amandes Reforestation Project o Friends of Botanic Gardens of Trinidad and Tobago o Horticultural Society of Trinidad and Tobago o Stakeholders Against the Destruction of Toco (SAD) o Trinidad and Tobago Field Naturalist Club (TTFNC) o Trinidad and Tobago Game Fishing Association o Trinidad and Tobago Orchid Society o Trinidad and Tobago Zoological Society o Wildlife Ophanage and Rehabilitation Centre o Pawi Study Group o The UWI Biological Society

Trinidad and Tobago Field Naturalists' Club (TTFNC)

The Cropper Foundation

El Socorro Centre for Wildlife Conservation

Asa Wright Nature Centre and Lodge

Wildlife Orphanage and Rehabilitation Center (WORC)

Fishermen and Friends Of the Sea (FFOS)

Manatee Conservation Trust

Secure A Vibrant Environment (SAVE) Foundation

Trinidad and Tobago Green Building Council

The Greenlight Network

Sustain T&T

Papa Bois Conservation

Trinidad and Tobago EcoWarriors

The Trust for Sustainable Livelihoods

Tobago Wildlife and Environmental Protection Group (TWEPG)

Speyside Eco-Marine Park Rangers (SEMPR)

Save Our Sea Turtles (SOS)

Caribbean Youth Environmental Network (CYEN) Community-based Organizations

Community-based Environmental Protection and Enhancement Programme (CEPEP)

Nariva Environment Trust

Fishing Pond Turtle Conservation Group

Save Our Sea Turtles

North East Sea Turtles

Grande Riviere Nature Tour Guides Association

Environmental Research Institute Charlotteville (ERIC)

Cedros Harmony Community (CEDHRAM)

Protectors of the Environment (POE)

South East Fishing Association

All Tobago Fisherfolk Association

The Trinidad and Tobago Unified Fisherfolk

South Eastern Hunters Association

San Souci Wildlife and Tourism Development Organisation

Balandra Nature Lovers Association

Association of Village and Community Councils

Agricultural Society of Trinidad and Tobago

Confederation of Hunters Association for Conservation (CHACCTT)

Trinidad and Tobago Assembly of Hunting Association (TTAHA)

Trinidad and Tobago Network of Rural Women Producers

Private Sector Organizations

Trinidad and Tobago Manufacturers Association (TTMA)

Trinidad and Tobago Chamber of Industry and Commerce

Trinidad and Tobago Emergency Mutual Aid Scheme (TTEMAS)

Chaguanas Chamber of Industry and Commerce

The South Chamber of Commerce

British Caribbean Chamber of Commerce

European Business Chamber in Trinidad and Tobago (EUROCHAMTT)

Couva / Point Lisas Chamber of Commerce

Point. Fortin Chamber of Commerce

South Trinidad Chamber of Industry and Commerce

Trinidad and Tobago Manufacturers’ Association

Energy Chamber of Trinidad and Tobago

American Chamber of Commerce of Trinidad and Tobago (AMCHAM T&T)

Tobago Chamber of Commerce

Quarry Association of Trinidad and Tobago

Bankers Association of Trinidad and Tobago (BATT)

Trinidad and Tobago Creative Industries Company Limited (Create TT)

Yacht Services Association of Trinidad and Tobago

Association of Upstream Operators (AUOTT)

Trinidad and Tobago Extractive Industries Transparency Initiative Secretariat

Trinidad and Tobago Agri-Business Association (TTABA) State-Owned Companies

La Brea Industrial Development Company Limited (LABIDCO)

Point Lisas Industrial Port Development Corporation Limited (PLIPDECO)

National Insurance Board of Trinidad and Tobago (NIBTT)

The National Institute of Higher Education, Research, Science and Technology (NIHERST)

Trinidad and Tobago Solid Waste Management Company (SWMCOL)

National Infrastructure Development Company Limited (NIDCO)

Chaguaramas Development Authority (CDA)

Urban Development Corporation of Trinidad and Tobago (UDeCOTT)

Evolving Tecknologies and Enterprise Development Company Limited (eTecK)

Trinidad and Tobago Bureau of Standards ( TTBS)

National Agricultural Marketing and Development Corporation (NAMDEVCO)

Cocoa Development Company of Trinidad and Tobago Limited

Seafood Industry Development Company

Trinidad and Tobago Hospitality and Tourism Institute (TTHTI)

Seafood Industry Development Company

Cocoa Development Company of Trinidad and Tobago Limited

Caribbean Industrial Research Institute (CARIRI)

Trinidad and Tobago Creative Industries Company Limited (Create TT)

Agricultural Development Bank (ADB)

Food and Agriculture Organisation (FAO)

ATTACHMENT 4 – EXECUTIVE SUMMARY OF THE 2016 NATIONAL ENVIRONMENTAL LITERACY SURVEY

The National Environmental Literacy/Awareness Survey was commissioned by the Environmental Management Authority (EMA) to assess current trends in environmental knowledge, attitudes and practices, in Trinidad and Tobago, within the new social media paradigm. The levels of literacy and awareness are related to the EMA’s Educational Programmes, Outreach, Brand and Organisational Notoriety through its policy implementation activities across our twin-island state. Therefore, the survey can be used as a barometer to gauge and inform the effectiveness of the EMA’s public educational and awareness programmes, and provide the required adjustments for increased levels of environmental Awareness and Literacy. Specifically, the survey was intended to capture the nation’s knowledge about the environment relative to: environmental threats; household activities that enhance sustainability and behaviours that promote a healthy co-existence with the natural environment. The survey implementation process consisted of four (4) distinct phases and was designed to incorporate lessons from previous surveys, as well as, measure the relative changes in knowledge and awareness status, over the respective national survey periods. The four (4) phases of this design included: 1. Survey Planning and Research – EMA Requirements 2. Survey and Questionnaire Design – Survey Protocols 3. Survey Implementation - Enumerator Training and Preparation 4. Data Analysis and Report – Summary of Results and Recommendations Survey Planning entailed the defining of the survey population, sample size and objectives to be derived across defined groups relative to overall environmental Knowledge, Attitudes and Practices. Survey Design consisted of selecting the appropriate survey instrument for the selected populations along with the plan of analysis and required protocols for disseminating the respective survey instruments. This included customisation of the instrument based on the mode of implementation i.e. phone, electronic or in person questionnaires. As part of the survey design, three (3) scales for measuring environmental literacy were derived. Selected questions in each of the survey categories were weighted on a positive/negative environmental scale and converted to a numerical Environmental Index. Three (3) separate indices were developed; one each for Knowledge, Attitudes and Practices. These indices were subsequently converted to percentages for reporting on environmental disposition for the respective categories. For example, the possible score ranges for the Household Survey were as follows: • Knowledge: 0 – 31 • Attitudes: 0 – 34 • Practices: 0 – 35

The relative score, attained in each of these categories, is associated with the relative environmental proficiency of survey respondents. Survey Implementation: In person interviews were conducted in forty-one (41) electoral districts, across Trinidad and Tobago. A small percentage (1.4%) of surveys were also collected electronically via email (email response rate 14%). Hardcopy responses were entered into the survey software for analysis, where quality control checks for completeness of the responses were performed. Data Analysis and Reporting was conducted in three (3) phases: presentation of results, environmental literacy score development and comparative analysis. The results were enhanced through infographic presentations and Geographic Information System maps (GIS). Environmental Literacy Scores were derived by attributing scores based on responses given for each KAP Component. The combined sum of these KAP components was evaluated to generate a Composite Score to measure Environmental Literacy for each respondent. The respondents were grouped according to selected demographic profiles. Subsequently, the average scores were calculated, for the various demographic groups, and represented as percentages. This National Environmental Literacy/Awareness Survey Report details the assessment of environmental literacy and awareness among citizens of Trinidad and Tobago. The results constitute an integral part of the review and update of the National Environmental Policy (NEP). The survey was launched on June 8, 2016 and was executed over a period of six (6) months. The survey targeted three (3) primary demographic profiles; Households, Schools (Forms 3 – 6), and Businesses/Industry. Industry respondents were found to have the highest levels of environmental literacy (63%) followed by Household respondents fifty-six percent (56%) and students fifty-one percent (51%). Pro-environment tendencies between the three (3) demographics showed a similar trend (Illustrated in the Infographic Below).

Household Survey Summary The national household survey component reflected an environmentally friendly population, willing to engage in activities that preserve and sustain our environmental heritage. This was demonstrated in a relatively high Attitude score of seventy-three percent (73%). The national population was significantly less engaged in pro-environment activities such as planting trees, recycling, composting and positive recreational interaction with the environment. Relative scores in these categories were significantly lower, with a household score of fifty percent (50%) in the “Practices” component. These low environmental activity scores seem to be inconsistent with the overall positive disposition towards the environment and may require increased organisation at the community level to increase awareness of the possibilities for environmentally friendly recreational activities and economic/entrepreneurial environmental opportunities. Citizen knowledge on environmental subjects was the lowest scoring component with forty-three percent (43%). The overall Environmental Literacy Score for national households of Trinidad and Tobago is fifty-six percent (56%). This score is intended to serve as a benchmark for future environmental literacy Knowledge, Attitude and Practise (KAP) surveys.

Secondary School Summary The scores derived from the school survey indicate a pro-environment disposition with an Attitude score of sixty-three percent (63%). Students, however, were found to be less willing to engage in environmentally friendly activities including activities attributed to the conservation of water and recycling. This is note-worthy since younger generations have experienced more targeted pro-environmental awareness advertising than their older citizen counterparts. Additionally, the positive Attitude scores did not translate to high engagement levels in environmental conservation. The overall Environmental Literacy score for secondary schools in Trinidad and Tobago is fifty-one percent (51%). Knowledge and Practice scores were forty-two (42%) and forty-seven (47%) percent, respectively. These relatively lower scores among students suggests the need for increased involvement and awareness of environmental programmes within schools to encourage continued student participation in activities geared towards enhancing their natural environments. These activities may include clean-ups, planting trees, field trips and environmental innovation competitions to increase awareness and explore career and business opportunities in the environmental sector. The results also indicated that not much movement in environmental maturity is realised as students matriculate from Forms 3 through Form 6. This may require a closer look at the environmental curriculum for secondary schools.

Industry Summary Environmental Literacy was measured across various sectors including oil and gas, manufacturing, services and agriculture. The scores were highest among industry respondents compared to national households and school respondents, with an environmental literacy level of sixty-three percent (63%).

As evidenced by an Attitude score of eighty-two percent (82%), organisations were found to be very willing to engage in environmentally friendly activities including water conservation and recycling. But, they were significantly more reserved when asked to engage in green initiatives for communities and employees. Increased engagement in green activities can be addressed by raising awareness of the social linkages between corporate citizenship, employee well-being and productivity. The Practice score for Industry is currently at fifty-five percent (55%) and Knowledge scores were on average fifty-our percent (54%). The Services Sector has the lowest recorded Environmental Literacy rate sixty percent (60%) underscored the need for a more targeted approach to the promotion of environmental awareness programmes. The Services Sector included property development and waste management companies, utilities, vehicle maintenance services and financial organisations.

ATTACHMENT 5 – OVERVIEW OF THE EXPERT REVIEW PANEL (ERP)

Rationale These local experts will give advice on policy formulation, strategy and programme implementation and monitoring, as it relates to the revision of the 2006 NEP. The services of this ERP will bring expert independent perspectives external to the EMA. The panel will also provide high level peer review of the Consultant’s outputs at key points in this project.

Scope of work of the Panel of Experts

The role of the ERP is not to duplicate the functions of the consultant contracted by the EMA to

revise the 2006 NEP, but rather to:

Provide the scientific and/or technical knowledge and judgement necessary to assist with the development of a revised NEP for Trinidad and Tobago;

Enrich the Consultant’s work through additional relevant information and draw attention to points needing closer consideration or further reflection;

Assist the EMA with the review of the various outputs from the Consultant as defined in the Consultant’s Terms of Reference; and identify any concerns or issues associated with these documents including objectives, strategies, best practices and implementation;

Provide on an ad hoc basis, guidance and advisory input, where needed, in areas related to their speciality.

Experts Selected

Professor John Agard – Environment and sustainability, including mainstreaming of biodiversity, ecosystem services conservation and climate change issues, into the national agenda;

Dr. Carol James – Environmental policy, including work with non-governmental and community based organisations towards people-centred environmental management;

Dr. Thackwray Driver – Integrating private sector/industry perspectives into the national environmental agenda.

ATTACHMENT 6 – 2018 NATIONAL ENVIRONMENTAL POLICY

FIRST REVISED DRAFT: FEBRUARY 06, 2017

LAID IN PARLIAMENT: NOVEMBER 2, 2018

NATIONAL ENVIRONMENTAL

POLICY

REPUBLIC OF TRINIDAD AND TOBAGO

i

Wise use of the environment is compatible with economic and social development. It is the cornerstone for ensuring that the needs and interests of present and future generations are met. A healthy and sustainably managed environment enables foreign investment, job creation, and an improved standard of living. More so, maintaining a healthy environment is central to our health and well-being, security, and enjoyment of property. This National Environmental Policy (NEP) articulates the priorities determined by the people of Trinidad and Tobago as critical to achieving environmental sustainability and ultimately, sustainable development. Its success depends on everyone understanding their roles and responsibilities regarding the environment while in pursuit of their interests. The relevance of this NEP to a person largely depends on his/her context but it is envisioned that:

For government entities, public officials and decision-makers, this NEP will serve as the primary declaration regarding Trinidad and Tobago’s policy direction as it relates to the environmental pillar of sustainable development. As such, the principles contained within will be applied to the development, revision and/or execution of all sectoral policies and work programmes to ensure policy integration at all levels. Furthermore, government entities and decision-makers will use the reach of their powers to apply or support the undertaking of policy actions, or works complementary to the policy actions herein.

For entrepreneurs, industry and commerce, this NEP will be interpreted as a clear commitment by the Government of the Republic of Trinidad and Tobago (GoRTT) to a greener development trajectory. As such, the policy actions contained should be used as a source of economic opportunities that can also yield social and environmental value. Furthermore, it sets out clear tools and anticipated roles of the business and commerce sectors for sound environmental management in Trinidad and Tobago.

For law enforcement, the judiciary and Alternative Dispute Resolution (ADR) practitioners, this NEP can be used as a tool to effectively guide the resolution of environmental disputes. The principles herein will be used to inform interpretation of matters before the court pertaining, in whole or in part, to development activities and environmental management. ADR mechanisms used to remedy environmental conflicts should, where practicable, ensure that precipitating outcomes do not conflict with the principles and policy actions of this NEP.

For Community-based Organisations and Non-Governmental Organisations, this NEP will serve as a map of the various stakeholders and their anticipated roles regarding environmental management. As such, this document serves as a guide for developing strategic plans and programmes for promoting and achieving sustainable development. It also serves as a measuring stick for the performance of all public, private and non-governmental stakeholder groups in this context.

For members of the public, this NEP spells out the changes the GoRTT will undertake to ensure an improved quality of life for current and future generations of citizens. It also supports the important role of citizens in environmental management and sustainable development.

Furthermore, it is hoped that this NEP will serve as a focal point for dialogue and partnerships between groups across all sectors and strata of society. The GoRTT remains committed to adopting policies and measures that foster an enabling environment in which all stakeholders can actively contribute to the environmental sustainability of Trinidad and Tobago.

Foreword: This NEP and You

ii

1.0 INTRODUCTION AND CONTEXT ............................................................................................ 1 1.01 Introduction ..................................................................................................................................................... 1 1.02 The Need for a Modern National Environmental Policy ........................................................................... 3 1.03 Drafting Process of this NEP ....................................................................................................................... 4 1.04 Our Vision for the Environment ................................................................................................................... 6 1.05 Environmental Governance Principles of Trinidad and Tobago ............................................................. 6

2.0 ENVIRONMENTAL PRIORITIES FOR TRINIDAD AND TOBAGO ............................. 12

PRIORITY 1: Protecting Environmental and Human Health through Pollution Control ..................... 12 2.01 Water Pollution ............................................................................................................................................. 12 2.02 Air Pollution ................................................................................................................................................... 13 2.03 Noise Pollution ............................................................................................................................................. 15 2.04 Solid and Hazardous Wastes ..................................................................................................................... 16 2.05 Light Pollution ............................................................................................................................................... 18

PRIORITY 2: Sustainably Managing Natural Assets ................................................................................. 20 2.06 Water Resource Management ................................................................................................................... 20 2.07 Soil / Land Management ............................................................................................................................. 21 2.08 Biodiversity Management ........................................................................................................................... 21 2.09 Coastal and Marine Area Management .................................................................................................... 24 2.10 Fisheries Management ............................................................................................................................... 24 2.11 Agriculture Management............................................................................................................................. 25 2.12 Mineral and Hydrocarbon Resource Management ................................................................................. 26

PRIORITY 3: Improving the Local Environment ......................................................................................... 27 2.13 Planning and Human Settlements ............................................................................................................. 27 2.14 Green Architecture and Infrastructure ...................................................................................................... 28 2.15 Heritage, Cultural and Archaeological Sites ............................................................................................ 28 2.16 National Festival and Events Management ............................................................................................. 29 2.17 Mass Transit Solutions ................................................................................................................................ 29

PRIORITY 4: Evolving a Greener Economy ................................................................................................ 30 2.18 Economic Transformation ........................................................................................................................... 30

PRIORITY 5: Fostering an Environmentally Responsible Society.......................................................... 32 2.19 Availability of and Public Access to Information ...................................................................................... 32 2.20 Communication, Education and Public Participation .............................................................................. 32 2.21 Research ....................................................................................................................................................... 33 2.22 Access to and Implementation of Environmental Justice ...................................................................... 33

PRIORITY 6: Addressing Climate Change and Environmental and Natural Disasters ....................... 35 2.23 Climate Change Mitigation and Adaptation ............................................................................................. 35 2.24 Comprehensive Environmental and Natural Disaster Management .................................................... 38

TABLE OF CONTENTS

iii

3.0 IMPLEMENTING AND ACHIEVING POLICY ACTIONS ................................................. 41 3.01 Critical Success Factors ............................................................................................................................. 41 3.02 Implementation and Mainstreaming Framework ..................................................................................... 42

4.0 MONITORING AND EVALUATION .......................................................................................................... 44 4.01 Monitoring and Evaluation of the NEP and Action Plan ......................................................................... 45 4.02 Revision of the NEP and Action Plan ....................................................................................................... 45

ANNEX I: INTERNATIONAL TREATIES AND CONVENTIONS RELATED TO THE ENVIRONMENT ... 47

ANNEX Ii: ENVIRONMENTAL POLICIES (TRINIDAD AND TOBAGO) ..................................................... 55

ANNEX III: FRAMEWORK FOR THE NEP ACTION PLAN.......................................................................... 56

ANNEX IV: THE SUSTAINABLE DEVELOPMENT GOALS ........................................................................ 59

iv

LIST OF ACRONYMS ADR Alternative Dispute Resolution

AF Adaptation Fund

CARICOM Caribbean Community

CBD Convention on Biological Diversity

CDM Clean Development Mechanism

CITES Convention on International Trade in Endangered Species of Wild Fauna and Flora

CSME Caribbean Single Market Economy

EMA Environmental Management Authority

EPR Extended Producer Responsibility

FAO Food and Agriculture Organization

GCF Green Climate Fund

GDP Gross Domestic Product

GoRTT Government of the Republic of Trinidad and Tobago

GHG Greenhouse Gas

GIS Geographical Information Systems

HCFC Hydrochlorofluorocarbon

IAS Invasive Alien Species

ICZM Integrated Coastal Zone Management

LDCF Least Developed Countries Fund

LEDS Low Emission Development Strategies

LMO Living Modified Organism

MEA Multilateral Environmental Agreement

NAMA Nationally Appropriate Mitigation Action

NAP National Action Programme

NCSD National Council for Sustainable Development

NDC Nationally Determined Contribution

NEP National Environmental Policy

NGO Non-Governmental Organisation

ODS Ozone Depleting Substance

POP Persistent Organic Pollutant

REDD+ Reducing Emissions from Deforestation and Forest Degradation

SCCF Special Climate Change Fund

SDG Sustainable Development Goal

SIDS Small Island Developing States

SLM Sustainable Land Management

SPAW Specially Protected Areas and Wildlife

ToC Theory of Change

T&T Trinidad and Tobago

UN United Nations

UNCCD United Nations Convention to Combat Desertification

UNDP United Nations Development Programme

UNFCCC United Nations Framework Convention on Climate Change

WEEE Waste Electrical and Electronic Equipment

http://unfccc.int/cooperation_and_support/financial_mechanism/adaptation_fund/items/3659.php

http://unfccc.int/cooperation_and_support/financial_mechanism/least_developed_country_fund/items/4723.php

http://unfccc.int/cooperation_and_support/financial_mechanism/special_climate_change_fund/items/3657.php

1 National Environmental Policy (2018)

1.0 INTRODUCTION AND CONTEXT

1.01 Introduction

The environment encompasses the air, water, land, biodiversity, human beings and all interactions between them. It provides the foundation for societal well-being, economic prosperity and political stability. This pivotal role in the society and economy stems from the various benefits derived from ecosystems, including but not limited to:

1. Provision of natural resources that form the basis of economic activity such as food, water, energy, non-food plant and animal products, ornamental items, genetic resources, minerals and raw materials;

2. Regulation of critical life processes such as air and water purification, pest and disease

control, climate regulation and waste decomposition;

3. Non-material benefits such as cultural, religious, spiritual, aesthetic and recreational experiences; and

4. Supporting services which sustain the other ecosystem services such as nutrient cycling

and soil formation. The GoRTT recognises the inextricable relationships between environmental sustainability and:

1. Poverty and hunger reduction - The most economically-challenged often depend directly on ecosystem services for nourishment and financial gain and they suffer most when ecosystems are degraded.

2. Economic prosperity - All economies are built upon the material resources or non-

material services provided by the environment which when used unsustainably, undermine economic growth.

3. Human health and well-being - Poorly managed human-environment interactions (water

pollution, air pollution, noise pollution, waste management, and climate change) directly influence levels of disease, morbidity and mortality resulting in mental and emotional suffering.

4. Disaster risk-reduction and post-disaster recovery - Ecosystems (such as wetlands,

forests and coral reefs) buffer human settlements against extreme weather events (such as tropical storms, hurricanes, droughts) and disasters (such as flooding and landslides) through their capacity to absorb water, control erosion, reduce wind-speeds, sequester greenhouse gases and absorb pollutants. As ecosystems are degraded, the vulnerability of human settlements is increased.

5. Peace and Justice - Scarcity of natural resources, mismanagement of common-pool

resources and the inequitable sharing of benefits derived from ecosystems are recognised drivers of non-violent and violent conflicts between stakeholders, within and between nations. Where these conflicts arise, marginalised groups (such as indigenous peoples, rural poor, children, youth, women, sick, disabled and the elderly) tend to suffer most.

1.01 Introduction


6. Gender equality - Socially constructed roles and existing inequalities disproportionately affect women more than men. Often, rural women are disproportionately dependent on ecosystem services yet are insufficiently involved in environmental decision-making, management and land ownership. As ecosystem services decline, the rights and opportunities of women are disproportionately affected. This simultaneously reinforces the drivers of poverty and conflict towards further environmental decline.

Thus, the GoRTT considers it a priority responsibility to judiciously manage the interactions between its citizens and the environment with aims of safeguarding human health, peace, prosperity and social justice, while yielding optimum sustainable benefits for present and future generations. The GoRTT remains steadfast on guiding the country along a sustainable development pathway that is aligned with the regional and global sustainability agenda as well as supported by leading edge environmental policies, practices and programmes that responsibly manage all aspects of the environment. To this end, the GoRTT is party to several Multilateral Environmental Agreements (MEAs) and shall fulfil all commitments agreed to by signing these agreements. This NEP reflects and strengthens the environmental pillar of Trinidad and Tobago’s sustainable development thrust – focusing on sustainable management of the country’s environmental assets rather than on the narrower concept of environmental protection, which tends to bring into conflict the environment and development. This NEP integrates the learning from the earlier versions (1998 and 2006), contemporary thinking on environmental issues and Trinidad and Tobago’s present-day context to:

a. Provide direction to public, private, non-governmental and other national actors regarding environmental sustainability;

b. Clearly articulate national environmental commitments and objectives in a transparent

manner; and

c. Provide a rational, practical and comprehensive framework for addressing the salient threats to environmental sustainability.

The NEP provides the overarching framework for environmental management. Subsequent national and sectoral policies with bearing on environmental or natural resource management; detailed procedures on environmental management; and concrete actions towards environmental sustainability in Trinidad and Tobago will therefore be grounded in the principles and broader approaches embodied in this NEP. Although the responsibility for monitoring the implementation and effectiveness of the NEP resides with the Environmental Management Authority (EMA), the achievement of policy actions will be driven by the action of each citizen across the public, private, governmental, and non-governmental sectors. All stakeholders therefore have a critical role in ensuring a sustainable future for Trinidad and Tobago. Chapter 1 of this NEP establishes the context within which it is to be used. Chapter 2 details six nationally appropriate environmental priority areas to be pursued by Trinidad and Tobago. Chapter 3 describes the facilitative actions required to achieve the six priority goals while Chapter 4 establishes the framework for monitoring and evaluating the policy.


1.02 The Need for a Modern National Environmental Policy

The GoRTT recognises that since 2006, there have been significant changes to the prevailing environmental issues and responses to these issues at the supranational and national scales. At the supranational scale… Anthropogenic contributions to climate change is near universally accepted and the adverse impacts of climate change are recognised as real, increasingly severe, and disproportionately distributed. Other phenomena, such as increasing aquatic and terrestrial contamination of engineered nanoparticles remain poorly understood and their burgeoning throughout the world promises a new era of environmental issues in decades to come1. Similarly, advances in technology offer novel opportunities for environmental conservation2. Small Island Developing States (SIDS), such as Trinidad and Tobago, are particularly vulnerable to global-scale threats due to their size, geography, and open economy. Additionally, they are constrained in the adoption of cutting edge responses due to their weak institutional capacity, high cost of infrastructure and unique socio-political milieu. In the past decade, there have also been changes in the collective response to environmental issues. Environmental law principles which guide humankind’s collective response to environmental issues have been advanced, refined and firmly planted into the corpus of international law. These principles also underpin several recently established MEAs adopted by the GoRTT in pursuit of integrating environmental development with economic and social development. These include the United Nations 2030 Agenda for Sustainable Development and the Paris Agreement to the United Nations Framework Convention on Climate Change (UNFCCC). Additionally, the Revised Treaty of Chaguaramas Establishing the Caribbean Community (CARICOM) including the Caribbean Single Market Economy (CSME), enjoins Trinidad and Tobago to several regional policies developed by CARICOM to achieve sustainable development. Since 2006, established regional policies have included the CARICOM Common Environmental and Natural Resource Policy, CARICOM Common Agricultural Policy, CARICOM Common Fisheries Policy, and CARICOM Regional Framework for Achieving Development Resilient to Climate Change. A modern NEP is needed to:

1. Provide a flexible and adaptive framework for proactively addressing realised and forecasted global environmental threats and facilitating the most modern responses to these threats in a manner respectful of the country’s unique context.

2. Formally codify contemporary environmental law principles into our national context, and to integrate Trinidad and Tobago’s environmental efforts with the collective regional and global strategies for sustainable development.

1 Sutherland, W. J., et al. (2015). A Horizon Scan of Global Conservation Issues for 2016. Trends in Ecology & Evolution, 29 (1), 15-22 2 Sutherland, W. J., et al. (2017). A Horizon Scan of Global Conservation Issues for 2017. Trends in Ecology & Evolution, 32 (1), 31-40

1.02 The Need for a Modern National Environmental Policy


At the national scale… Trinidad and Tobago is perceived to be progressively above average with respect to environmental management; moving from the 90th position to the 62nd position among 180 countries measured on the Yale Environmental Performance Index over the period 2006 - 2016. In the decade following the 2006 NEP, several environmental policy instruments have been established including, but not limited to, national policies for forests, wildlife, protected areas, recycling, and climate change; a green tax levy and a national green fund; and the enactment of Water Pollution and Air Pollution Rules. Yet despite these policy responses, periodic assessments taken over the past decade indicate that the country’s ecosystems and natural resources remain encumbered by the impacts of urban expansion and industrial development. Furthermore, a precise measurement of trends in the state of the environment of Trinidad and Tobago has been difficult to attain due to institutional constraints and gaps in the 2006 NEP regarding monitoring and reporting on indicators. A review of the EMA’s Complaints Database revealed that for the period 2014 – 2016 complaints related to development activities comprised the majority (28%) followed closely by noise from events and recreational venues (26%); air quality due to open burning, odours and dust (15%); and petrochemical spills and releases (8%). This stands in contrast to the characterisation of complaints in 2006 which were predominantly centred on agricultural practices, construction activities and small-scale commercial endeavours. A modern NEP is therefore needed to:

1. Address the limitations of previous versions so that it includes the suite of contemporary national policies and laws; establishes a framework for effective mobilisation of resources and capacity building of institutions; and strengthens the mechanisms for monitoring and evaluation.

2. Bring focus to the current environmental issues encountered by the citizens of Trinidad and Tobago, and detail proactive and corrective actions to be undertaken by government entities, private sector, non-governmental organisations and the public.

1.03 Drafting Process of this NEP

In consideration of the burgeoning threats to environmental sustainability at all levels, the GoRTT sought unprecedented action to develop a robust, inclusive and comprehensive environmental policy. While a process for revising the NEP is provided for under Section 18 of the Environmental Management Act, Chapter 35:05 (EM Act), the drafting of this NEP utilised stakeholder engagement strategies inclusive of, but far exceeding, the statutory process defined in the Act. The development of this policy was executed in three distinct phases with several sub-activities conducted within each phase. During Phase 1, an initial draft NEP was formulated based on feedback received from:

1.03 Drafting Process of this NEP


1. A 2016 nationwide environmental awareness/ literacy survey.

2. A 2016 stakeholder questionnaire survey.

3. Thirteen (13) thematic focus group meetings hosted by the EMA across Trinidad and Tobago in 2016 with representatives from public, private governmental, and non-governmental sectors.

4. A 2016 literature review and environmental Gap Analysis Report.

5. Staff of the EMA; an expert review panel consisting of distinguished persons in the realms

of energy, climate change and sustainable development policy; and consultants contracted to lead the revision of the NEP.

During Phase 2, the initial draft was made available electronically on the EMA’s website and a two-month mass engagement campaign was undertaken. Nine public consultations were held across Trinidad and Tobago. These events and feedback options were heavily advertised through social media, radio, mobile speaker announcements, text-message alerts and EMA mailing lists. Written and verbal comments received were used to produce the second draft NEP. During Phase 3, the public comment process described under Section 28 of the EM Act was undertaken to produce further iterations, and ultimately, the final draft NEP. Thus, this NEP stands as a testament to inclusive governance; a policy made for the people of Trinidad and Tobago, by the people of Trinidad and Tobago. The final product represents the concerns, knowledge and solutions derived from unparalleled collaboration aimed at elevating

environmental consciousness and advancing sustainable development in Trinidad and Tobago.


1.04 Our Vision for the Environment

We, the people of Trinidad and Tobago aspire to make our country a place where we can enjoy a high quality of life within a safe and healthy environment where natural resources are safeguarded and used sustainably. We envisage a country where food security is achieved through sustainable agricultural practices. Our desire is for our villages, towns and cities to benefit from green architecture and infrastructure, increased energy efficiency, and are powered by renewable resources. We foresee a future where all stakeholders from individual citizens to political and non-political, formal and informal groups are actively involved in the management of their national and local environments based on strong environmental ethics. The Government of the Republic of Trinidad and Tobago envisions a country in which all stakeholders take an active role in protecting the environment and assume individual responsibility for maintaining and enhancing the quality of the environment.

1.05 Environmental Governance Principles of Trinidad and Tobago

Environmental challenges are usually difficult and complex, for which easy solutions may not exist and suitable responses may sometimes be constrained by the limitations of the legislative and institutional structures. The unwavering pursuit of environmental sustainability within an ever-changing socio-economic paradigm requires clear, yet adaptable guidance. Hence, the GoRTT commits that all environmental, or environment-related laws, policies, programmes, actions and institutions shall be guided by the following principles and concepts: Sustainable Development, Integration and Interdependence

Sustainable development, defined in the Brundtland Report as “development that meets the

needs of the present without compromising the ability of future generations to meet their own

needs”3, is recognised as the overarching model for improving the quality of life for the citizens of

Trinidad and Tobago. It is understood that economic development, social development and

environmental management are interdependent, indivisible and mutually reinforcing components

of sustainable development. Moreover, the attainment of peace and sustainability can only be

done when environmental concerns are integrated across all spheres, at the policy, planning,

programme and project levels. Thus, development and the pursuit of peace, justice and strong

institutions in Trinidad and Tobago must be done in a manner that strives to balance social,

economic and environmental considerations.

3 World Commission on Environment and Development. (1987) Our common future. Oxford: Oxford University Press

1.04 Our Vision for the Environment

1.05 Environmental Governance Principles of Trinidad and Tobago


Inter-Generational and Intra-Generational Equity

Equity is the cornerstone of achieving sustainable development. It is recognised that all citizens of Trinidad and Tobago within the current generation have the right of fair access to their generation’s entitlement of natural resources. In addition, future generations are entitled to enjoy a fair level of the common patrimony. Thus, each generation has the duty of ensuring that pursuit of development does not impede the ability of each citizen, or successive generations of citizens, from meeting their needs. In addition, the GoRTT assumes responsibility for fairly allocating and regulating scarce resources to ensure that all benefits and burdens are equitably shared amongst all members of society.

Precautionary Principle

The finite nature of the earth’s systems and processes dictate that there are limits to the amount

of human activity tolerable before there is a risk of abrupt and irreversible environmental

changes. The GoRTT will adhere to the principle that if there are threats of serious irreversible

damage to humans or the environment, lack of full scientific certainty will not be used as a

reason for postponing social and environmental safeguards. Furthermore, the GoRTT affirms:

1. Scientific uncertainty will not be used as a reason not to act in respect to environmental

concerns;

2. Action will affirmatively be taken with respect to environmental concerns;

3. Those engaging in potentially damaging activities will shoulder the burden of

establishing the absence of significant environmental harm; and

4. It may restrict imports based on a standard involving less than full scientific certainty of

environmental harm.

Responsibility to Avoid Transboundary Harm

The exercise of Trinidad and Tobago’s sovereign right to exploit its natural resources in

accordance with its environmental and developmental policies shall not cause damage to the

environment or impact human health of neighbouring States or areas beyond the limits of its

national jurisdiction. As such, the GoRTT and entities operating within the boundaries of Trinidad

and Tobago accept the responsibility to prevent damage to neighbouring environments.

Prevention

The concept of prevention of environmental harm, irrespective of whether there is transboundary

harm, is a well-established concept for economic and ecological reasons. Often environmental

ills create irreversible ecological or human health impacts, or where remedies exist the costs are

prohibitive. Thus, comprehensive prior assessment of environmental harm and measures to

avoid/mitigate significant environmental or human health impacts shall be utilised whenever there

exists a risk of environmental damage.


Polluter Pays Principle

The cost of preventing pollution, minimising environmental damage due to pollution, and/or

compensation for damages due to pollution, shall be borne by those responsible for the pollution.

This principle may be applied through command-and-control measures (E.g. Pollution Standards)

or market-based measures (E.g. Taxes). Important elements of the application of this principle

using pollution standards are:

a) Charges are levied as:

i. An application or processing fee proportional to the cost of processing a license or

permit; and

ii. A licence or permit operating fee proportional to: (1) the quantities/concentration/

amount of pollutants which the holder is permitted to generate, or (2) to the best

approximate of the total cost to society due to polluting activities undertaken;

b) Charges are levied for compensation and damages associated with pollution of the

environment; and

c) Money collected will be used to correct environmental damages and improve pollution

management.

Transparency, Public Participation and Access to Information and Remedies Public participation is critical to sustainable development and is a prerequisite for responsive, transparent and accountable governmental entities and civil society organisations. It is also acknowledged that meaningful public participation can only be attained where there are transparent public processes, and access to appropriate, timely and comprehensible information concerning the environment held by public authorities. Such information must be made widely available without imposing undue financial burdens on the applicant and with adequate protection of privacy and business confidentiality. Consequently, all governmental entities of Trinidad and Tobago shall, in accordance with Principle 10 of the Rio Declaration, facilitate and encourage public awareness and participation in environmental and developmental matters by making information widely available, and ensuring effective access to judicial and administrative proceedings, including redress and remedy. Co-operation and Common but Differentiated Responsibilities The GoRTT as well as all sub-national and trans-national entities operating within its boundaries shall, in the spirit of global partnership, co-operate towards the conservation, protection and restoration of the Earth’s ecosystem integrity. Given that different actors contribute differently to environmental problems in the pursuit of sustainable development, all actors bear common but differentiated responsibilities for addressing environmental challenges proportional to their contribution.


Rights of Indigenous Peoples and Local Communities

Indigenous peoples and local communities shall have a right to participate in the decision-making

process, and share in managing the resources upon which their cultural identity and livelihoods

depend. All development activities shall recognise and include safeguards to respect, preserve

and maintain the identity, culture and interest of indigenous peoples and local communities likely

to be impacted. The traditional knowledge, innovations and practices of indigenous and local

communities shall be respected and promoted for wider application given the free, prior and

informed consent of the holders of those knowledge systems. Benefits arising from the utilisation

of such knowledge, innovations and practices shall be equitably shared among holders of those

knowledge systems.

Common Heritage and Common Concern of Humankind The GoRTT recognises that the management of the climate system and biodiversity of the Earth are common concerns for humankind. Moreover, resources of outer space, celestial bodies, the sea-bed, ocean floor and subsoil thereof beyond the limits of national jurisdiction are considered the common heritage of humankind. The GoRTT, sub-national actors, and transnational organisations within its boundaries shall share responsibility for addressing common concerns, minimising harm to issues of common concern and safeguarding the common heritage of humankind. Good Governance It is recognised that sustainable development can only be achieved where public, private and non-governmental institutions are transparent, accountable and honest in their governance of human, financial, environmental and natural resources. Good governance is a function of mutual trust and reciprocal relations between governmental agencies, civil society, and non-state actors including businesses and NGOs. This must be based on the fulfilment of constitutional, legislative and executive functions and the acceptance of authority, probity, transparency and accountability. It necessitates that appropriate institutions, institutional relationships and common targets are established and supported. In the pursuit of good governance, the GoRTT reaffirms its responsibility to respect the health and well-being of all citizens. Furthermore, the GoRTT, all sub-national actors and international actors operating within the State’s boundaries shall adopt/maintain, where appropriate, the features of good governance required to galvanise environmental sustainability, including but not limited to:

1. Internal democratic and transparent decision-making procedures and financial

accountability;

2. Effective measures to combat official or other corruption;

3. Respect for due process and observance of the rule of law;

4. Protection of human rights as enshrined in the Constitution;

5. Transparent and non-corrupt public procurement procedures;

6. Meaningful participation of women at all levels of decision-making;

7. Meaningful engagement and involvement of Trinidad and Tobago’s youth;

8. Respect for all forms of knowledge systems inclusive of traditional knowledge held by

indigenous and local communities;


9. Equitable representation and meaningful participation of the poor and other marginalised

groups in decision-making;

10. A culture of accountability in their responsibilities pertaining to the development and

implementation of environmental and development policies, laws and policy instruments;

11. Effective process to redress past and present environmental justice;

12. Corporate social responsibility and socially responsible investments towards the equitable

distribution of wealth and benefits within communities;

13. The right of workers to refuse work that is injurious to human health or the environment;

and

14. The right of every citizen to expose any environmental or health hazard without fear of

reprisal.


The goal of this NEP is to improve and maintain a high level of environmental quality for current and future generations while ensuring that the health, interests and development of the people of Trinidad and Tobago are not compromised. This chapter details the six environmental priorities identified through extensive stakeholder consultation as being critical to achieving sustainable development. These priorities are:

Protecting Environmental and Human Health through Pollution Control;

Sustainably Managing Natural Assets;

Improving the Local Environment;

Evolving a Greener Economy;

Fostering an Environmentally-Responsible Society; and

Addressing Climate Change and Environmental and Natural Disasters. The concerns described in Section 1.02 must be given increased priority, in recognition that long-term economic growth, social transformation, poverty reduction and environmental sustainability are inter-linked. These priorities are also aligned with the United Nations 2030 Sustainable Development Agenda that will be described in the sections below. The discussion of each priority will identify the significance of each issue, link the issue to the Sustainable Development Goals (SDGs) (see Annex IV) and list policy actions to address each issue.

2 ENVIRONMENTAL PRIORITIES FOR TRINIDAD AND TOBAGO


2.0 ENVIRONMENTAL PRIORITIES FOR TRINIDAD AND TOBAGO PRIORITY 1: Protecting Environmental and Human Health through Pollution Control The production and consumption of goods and services invariably yield by-products that, if improperly managed, negatively impact the environment, human health, and the economy. Therefore, managing pollution is a critical priority for the GoRTT while pursuing its development agenda. This section highlights the core commitments of the GoRTT for addressing pollution so that Trinidad and Tobago maintains a healthy environment suitable for all human uses and maintaining ecosystem functions.

2.01 Water Pollution

The GoRTT recognises that the quality of water determines its suitability for drinking, recreation, commercial and industrial use, and sustaining aquatic ecosystems. The quality of water is impaired by social and economic activity that introduce biological, chemical and physical pollution. Safeguarding water quality is a national imperative. To this end, the GoRTT reaffirms its commitment to the Convention for the Protection and Development of the Marine Environment of the Wider Caribbean Area, the Land-Based Sources Protocol of the Cartagena Convention, International Convention for the Prevention of Pollution from Ships (MARPOL), and SDGs 6, 12 and 14 which speak to water quality management. Accordingly, the GoRTT will:

a) Manage the water resources of the country for long-term sustainability by ensuring that the water quality in any area does not fall below that which is required to protect the uses of the water by humans;

b) Manage the water resources in the country such that water quality in any area does not fall below that necessary to avoid diminishing the quality of the environment by preventing the discharging or depositing of pollutants in waters which may cause any of the following:

i. Loss of native aquatic vegetation; ii. A reduction in numbers of any native species of aquatic animal or insect; iii. An increase in the numbers of any non-native species of aquatic animal or insect; iv. A reduction in numbers of aquatic organisms necessary for a healthy aquatic

ecosystem; v. An increase in algal or aquatic plant growth; vi. The water to become toxic to vegetation on land; vii. The water to become harmful or offensive to humans, livestock, or native animals;

and viii. An increase in turbidity or sediment levels.

c) Ensure that waters designated as protected or significant to species protected by law are maintained in a pristine state;

d) Establish ambient water quality guidelines consistent with use as well as standards and limits on concentrations of substances in point source discharges;

e) Ensure that for waters with multiple uses, the water quality criteria support the most sensitive use;

PRIORITY 1: Protecting Environmental and

Human Health through Pollution Control


f) Amend existing legislation or develop new legislation, as appropriate, to enable the comprehensive protection of water bodies from point source and non-point source pollution;

g) Encourage the sustainable management of water bodies by way of cleaner technologies, and cost-effective and reasonable environmental management practices;

h) Limit, as far as practicably possible, point source discharge of pollution into near-shore or fresh surface waters;

i) Empower agencies with the responsibility for water quality, and water pollution management to fully undertake their mandate by providing financial, technical and institutional capacity building;

j) Encourage partnerships between governmental entities, private sector and non-governmental organisations towards the monitoring and mitigation of water pollution;

k) Ensure abstracted drinking water is given adequate treatment and meets national standards prior to distribution to the public;

l) Ensure that for waters whose existing quality is less than the quality specified in the established ambient water quality guidelines and standards shall be made to comply with these, wherever possible;

m) Protect existing or planned ground and surface water sources of public drinking water from direct or indirect contact with sewage or other waste;

n) Ensure that there is not direct or indirect discharges of hazardous substances into surface water and ground water aquifers;

o) Ensure that sewage, waste water and produced water receive the degree of treatment necessary to protect the quality of waters of Trinidad and Tobago prior to being discharged;

p) Ensure that in cases where the water quality falls below that which is necessary to protect human health, the person responsible for the pollution shall pay any cost necessary to inform the public of the risk involved, and restore quality in order to protect human health; and

q) Develop guidelines and policies, as appropriate, to reduce impacts to water quality due to the activities of marinas, boatyards, and/or vessels.

2.02 Air Pollution

Air emissions in Trinidad and Tobago come from a wide range of sources, representing diverse economic activities and personal lifestyles. Given that our atmosphere is all pervasive, contaminated air affects everyone’s health as well as that of plants, animals and non-living components of the environment. Furthermore, certain pollutants may impact the ozone layer and the greenhouse effect, undermining global environmental sustainability. Thus, to abate the threats of air pollution, in alignment with SDG 3, SDG13, and the objectives of the Vienna Convention for the Protection of the Ozone Layer, Stockholm Convention on Persistent Organic Pollutants and the United Nations Framework Convention on Climate Change, the GoRTT will undertake proactive measures to address the sources and forms of air pollution within its national boundaries.


Open Burning It is Government’s policy that open burning of waste without consent from designated national authorities governing waste management is strictly prohibited. Nevertheless, the GoRTT recognises that open burning and agricultural fires persist throughout the year, and commits that it will:

a) Empower agencies with responsibility for the management of agricultural or other waste, or for fire management to detect and respond to incidents of open burning;

b) Amend or develop additional policies and legislation, as appropriate, to improve the regulation of open burning and agricultural fires; and

c) Undertake sensitisation campaigns regarding the national policy and laws regarding open burning, and the impacts of open burning on human health and the environment. Air Emissions from Land-Use Change, Commercial and Industrial Activities

Trinidad and Tobago is one of the most industrialised countries in CARICOM. To address the air pollution emitted by land-use changes, commercial activity or industrial processes, the GoRTT will:

d) Prevent avoidable emissions to the atmosphere and, where emissions are unavoidable, take all reasonable and practicable measures to minimise their impact on ambient air quality;

e) Encourage the utilisation technologies and techniques that minimise emissions, including odours, from land-use changes, commercial activities, and industrial processes;

f) Mobilise resources, and seek global partnerships to secure resources, for the development of a national network of ambient air quality monitoring stations to provide accurate, real-time assessments of ambient air quality throughout Trinidad and Tobago;

g) Empower government entities and non-governmental institutions to effectively monitor point source emissions by means of enhanced technical, financial and human-resource capacity development;

h) Amend or develop additional policies and legislation, as appropriate, to improve the regulation of air pollutants arising from land-use changes, commercial activities, and industrial processes; and

i) Encourage the use of cleaner fuels as inputs into commercial and industrial activities. Air Emissions from Motor Vehicles, Vessels and Aircraft

Mobile sources powered by combustion engines represent a growing source of emissions in Trinidad and Tobago. In response, the GoRTT will:

j) Amend or develop additional policies, legislation, standards, or regulations, as appropriate, to reduce emissions related to mobile sources including but, not limited to, motor vehicles, vessels and aircraft;

k) Amend or develop additional policies legislation, standards, or regulations, as appropriate, to ensure timely vehicular maintenance and avoidance of ‘black smoke’;

l) Encourage the public to utilise mass transit systems; m) Ensure the development, access to, and use of cleaner and/or alternative forms of fuel for

vehicles, vessels and aircraft;


n) Empower government entities to better undertake their mandates with respect to the control of air pollution from mobile sources by way of enhanced technical, financial and human-resource capacity development; and

o) Implement cost-effective measures to minimize vehicular traffic congestion, particularly in major urban centers.

Ozone Depleting Substances (ODS) Substances that deplete the ozone layer continue to be used in air conditioning and refrigeration, fumigation, and foam blowing. Although Trinidad and Tobago has successfully phased out the import of some ozone depleting substances (ODS) such as chlorofluorocarbons, halons and carbon tetrachloride, efforts are still required to phase out additional substances found to be damaging to the ozone layer as well as those substances used as alternatives that contribute to global warming. To this end, the GoRTT will:

p) Amend or develop legislation as appropriate, to give effect to Trinidad and Tobago’s obligations under MEAs related to ozone depleting substances, as well as alternatives to these substances;

q) Implement a system to control the import and export of all ozone depleting substances and their alternatives;

r) Develop and implement standards and guidelines as appropriate, for relevant sectors that utilise ozone depleting substances, as well as alternatives to these substances;

s) Ensure that all developmental activities utilize ozone friendly technologies; t) Ensure that climate and energy efficient considerations are taken into account when

choosing ODS alternatives; u) Ensure that refrigerant used in air conditioning and refrigeration equipment are recovered

(if practical) for destruction, recycling or reclamation during servicing and maintenance of equipment prior to equipment dismantling for disposal;

v) Develop incentive and disincentive mechanisms towards reduction or use of ozone depleting substances and promotion of alternatives; and

w) Encourage the meaningful participation of all stakeholders in the monitoring of ozone depleting substances and promote their alternatives.

2.03 Noise Pollution

It is Government’s policy that noise, from all sources, will be managed to ensure that the health and well-being of all citizens will be respected. Additionally, noise generated on land and at sea, shall be managed to avoid significant impact to biodiversity, human health and community peace. To these ends, the GoRTT will:

a) Amend existing legislation or develop new legislation and standards, as appropriate, to ensure that all sources and types of noise are appropriately managed to minimise nuisance, and danger to the health and welfare of sensitive receptors;

b) Revise spatial and temporal zones for the management of noise, taking into consideration sensitive species and sensitive receptors, and establish noise management plans for each zone;

c) Empower government entities to better undertake their mandates with respect to the control of noise pollution from all sources by way of enhanced technical, financial and human-resource capacity development;


d) Encourage the responsible management of noise from all sources through education and awareness programmes with an emphasis on sources neighbouring sensitive communities and environmental receptors;

e) Develop incentive and disincentive programmes towards the responsible management of noise from all sources with an emphasis on sources neighbouring sensitive communities and environmental receptors;

f) Develop national regulations, standards and guidelines for managing human-induced noise in the marine environment with an aim to prevent acute and chronic impacts to marine species; and

g) Encourage the use of noise-quieting technology, and the use of spatial or temporal exclusion of noise to minimise contact with marine life.

2.04 Solid and Hazardous Wastes

Solid Wastes

The GoRTT recognises major drivers of solid waste generation to be unsustainable consumption patterns and the inefficient use of resources in the production of goods and services. Thus, in keeping with SDG 12 which aims to ensure sustainable consumption and production patterns through the environmentally sound management of all wastes, the GoRTT’s policy will be to give priority in the order of prevention, reduction, reuse, recycling and energy recovery whilst recognising that the timeframe for establishment of systems to undertake such actions will require that waste be disposed of in a manner that does not negatively impact on human health and the environment. To this end, the GoRTT will:

a) Harmonise national policies that relate to waste management including, but not limited to the National Waste Recycling Policy and the Integrated Solid Waste/Resource Management Policy;

b) Amend existing legislation or develop new legislation, policies or programmes, as appropriate, to:

i. Facilitate action towards the objectives of the United Nations’ 10-year Framework of Programmes on Sustainable Consumption and Production Patterns;

ii. Facilitate the proper handling, storage and disposal of waste; iii. Facilitate the reduction of food waste at the retail and consumer levels, and reduce

food losses along the production and supply chains, including post-harvest losses; iv. Combat marine litter, inclusive of marine debris and micro-plastics, in accordance

with the most current resolutions of the United Nations Environment Assembly; and

v. Promote closed-loop production of goods to minimise the overall waste load. c) Promote the concept of Extended Producer Responsibility (EPR) whereby

manufacturers/generators play a role in the treatment and disposal of products at the end-of-life;

d) Facilitate the management of emerging waste streams; e) Ensure that waste is recovered or disposed of without using processes or methods that

can endanger human health, cause significant harm to the environment, and/or significant nuisance through noise, odour or loss of aesthetic appeal;

f) Encourage the private sector to phase-out the import, manufacture and use of synthetic, non-biodegradable materials such as polystyrene and plastics through market-based economic instruments;


g) Encourage the public, private and non-governmental sectors, especially large and transnational companies, to adopt sustainable practices and integrate sustainability into their operations and reporting cycle;

h) Encourage and support partnership with regional and international organisations to support technical and institutional capacity development of sustainable patterns of consumption and production;

i) Encourage and support partnership with educational institutions, non-governmental organisations and the private sector to undertake research and programmes to improve waste management; and

j) Empower governmental entities to better undertake their mandates with respect to the management of solid waste by way of enhanced technical, financial and human-resource capacity development.

Recycling, Recovery and Reuse The GoRTT believes that efforts to recycle (including up-cycling), recover materials, and reuse discarded products will provide co-benefits beyond environmental sustainability. These include (i) delaying or avoiding new waste disposal infrastructure to meet growing waste generation, (ii) development of new local industries, (iii) access to new international markets, and (iv) divert waste from landfills. Thus, it is Government’s policy to mainstream the minimisation of waste and practice of recycling, recovery and reuse into the culture of Trinidad and Tobago. Accordingly, the GoRTT will:

k) Amend existing legislation or develop new legislation, as appropriate, to facilitate the efficient coordination and implementation of a national waste recycling system;

l) Support non-governmental organisations, private sector, and/or community-based efforts to prevent, reduce, reuse, recover, or recycle waste, including the use of waste as an energy source;

m) Encourage and support the development of market-based economic instruments for the prevention, reduction, reuse and recycling of waste, including the use of waste as an energy source; and

n) Collaborate with non-governmental organisations, community-based organisations, the private sector and other governmental entities to build sustainable public education and awareness campaigns that highlight the consequences of improper waste disposal and encourage the prevention, reduction, reuse and recycling of waste.

Hazardous Substances and Wastes

The GoRTT will continue to take decisive action regarding the generation, handling, use, transboundary movement, treatment, storage and disposal of hazardous substances and hazardous wastes. As a responsible global citizen, the GoRTT stands with the international community in the collective effort to address, among others, Persistent Organic Pollutants (POPs), Waste Electrical and Electronic Equipment (WEEE), pesticides, toxic chemicals, waste oils, and radioactive materials. Accordingly, the GoRTT will:

o) Amend existing legislation or develop new legislation, as appropriate, to give effect to the enforcement of MEAs on hazardous substances and hazardous waste including, but not limited to: the Basel Convention on the Control of Transboundary Movement of Hazardous Waste and their Disposal, the Stockholm Convention on Persistent Organic Pollutants,


and the Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade;

p) Monitor implementation of Chemical and Waste related MEAs to ensure adherence of all national obligations;

q) Enforce existing legislation and as required, amend existing legislation or develop new legislation to ensure the proper handling, transport, treatment, storage and disposal of hazardous substances and hazardous waste through permitting and licensing systems;

r) Further develop and maintain lists and inventories of hazardous waste; s) Prevent the import of hazardous waste if there is reason to believe that the waste in

question will not be managed in an environmentally sound manner and thereby pose a threat to human health and the environment;

t) Strengthen enforcement of the ban on open burning of hazardous substances and hazardous waste;

u) Empower governmental entities to better undertake their mandates with respect to the management of hazardous waste and hazardous substances by way of enhanced technical, financial and human-resource capacity development;

v) Encourage access to technical assistance, technology transfer, training and capacity-building opportunities and other resources established under the Chemical and Waste related MEAs including the strengthening of partnerships with the Basel Convention Regional Centre for Training and Technology Transfer for the Caribbean region, and similar regional and international entities; and

w) Explore market-based mechanisms, regulations and alternative incentives for the replacement of toxic and persistent industrial and agricultural chemicals with less toxic and biodegradable alternatives.

Furthermore, it is Government’s policy that:

x) Manufacturers and distributors will ensure that they supply materials and substances which are approved for local use by the relevant regulatory authorities concerned, which includes, but is not limited to, the Pesticides and Toxic Chemicals Control Board and the Trinidad and Tobago Bureau of Standards; and

y) The consent of the Environmental Management Authority be sought for the transboundary movement (export, import and transit) of hazardous waste and other waste controlled under the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal.

2.05 Light Pollution

Photopollution is caused by the inappropriate, or excessive, use of artificial light for lighting or advertising in the night environment. The GoRTT recognises that the inefficient use of artificial light negatively impacts local amenity, the national carbon footprint, intrinsically dark landscapes and nature conservation. It also acknowledges that the adverse impacts of artificial light to nocturnal pollinators threatens agricultural productivity and ecosystems. It is government’s policy that sky glow, light trespass, light clutter, over-lighting and glare from outdoor sources of artificial light will be judiciously managed. To this end, the GoRTT will:

a) Amend existing legislation or develop new legislation and standards, as appropriate, to ensure that all sources and types of artificial light are appropriately managed to minimise nuisance, aesthetic impact, and danger to the health and welfare of sensitive receptors which include, but are not limited to, vulnerable members of society, intrinsically dark landscapes and nocturnal species;


b) Ensure, through existing environmental/planning legislation and processes, that development involving outdoor lighting schemes:

i. Uses the minimum amount of lighting required for security or work purposes; ii. Minimises light spillage and glare, particularly in areas of open countryside or on

the edge of settlements; and iii. Minimises impact to local amenity, road safety or to sites of conservation value.

c) Develop incentive and disincentive programmes towards the responsible management of artificial light with an emphasis on sources neighbouring sensitive communities, intrinsically dark landscapes, or environmentally sensitive areas;

d) Retrofit all state-owned outdoor lighting fixtures (including street lights) with appropriate shields and energy efficient bulbs;

e) Encourage private-sector entities to retro-fit outdoor lighting fixtures (including street lights) with appropriate shields and energy-efficient bulbs.

f) Encourage the responsible management of artificial light from all sources through education and awareness programmes with an emphasis on sources neighbouring sensitive communities and environmental receptors; and

g) Empower government entities to better undertake their mandates with respect to the control of light pollution from artificial sources by way of enhanced technical, financial and human-resource capacity development.

20 National Environmental Policy

PRIORITY 2: Sustainably Managing Natural Assets Trinidad and Tobago is enriched with an abundance of ecosystems and natural resources which provide the foundation of economic activity and social well-being. As such, the management and wise use of these finite, natural assets are of paramount importance. This section highlights the GoRTT’s commitments to sustainably managing the quality and quantity of the country’s natural assets.

2.06 Water Resource Management

Trinidad and Tobago produces potable water from a system of wells, from surface impoundments, from river extraction and more recently from desalination. However, continuous access to potable water by all citizens is constrained by climate variability and infrastructure capacity. With these water supply systems, several pieces of laws and policies were prepared to regulate the abstraction of water, protect water supplies from pollution and manage use of water in an efficient and effective manner. In keeping with SDGs 3 and 6, which aim to ensuring healthy lives and the availability and sustainable management of water and sanitation for all, respectively, the GoRTT will:

a) Pursue an integrated water resource management approach in accordance with the national Integrated Water Resource Management Policy to ensure optimal protection of and use of the country’s water resources;

b) Expand opportunities for private sector, non-governmental, and public participation and collaboration in the development and implementation of water management programmes;

c) Increase administrative effectiveness by the elimination of fragmentation and duplication in responsibilities and consolidating programmes wherever possible;

d) Minimise potable water losses in transmission and distribution systems; e) Encourage water conservation through recycling and waste water reuse, especially during

the Dry Season; f) Encourage water-use efficiency across all economic sectors; g) Protect and restore water-related ecosystems, including mountains, forests, wetlands,

rivers, aquifers and lakes; h) Encourage the use of advanced technology systems such as desalination, waste water

reuse, storm water reuse, and rainwater harvesting to supplement fresh water demand where it is economically, technically and environmentally feasible;

i) Ensure that environmental authorisation for applications that involve the construction of waste water storage lagoons adhere to the appropriate setbacks by the national planning agency and other regulatory bodies, and are considerate of:

i. Known flood plains or any flood plain that is subject to flooding that occurs, on average, more often than once every 100 years;

ii. Bodies of water in environmentally sensitive areas or areas that support environmentally sensitive species;

iii. Public roads or road reserves; iv. Banks of water courses;

PRIORITY 2: Sustainably Managing Natural Assets


v. Residences built in the vicinity; vi. The high-water mark; and vii. Areas where the base of the lagoon would be below a seasonal water table.

j) Review and, if necessary update legislation on management of water resources; k) Encourage educational campaigns and research into water management strategies; and l) Utilise market-based measures and other policy instruments to achieve these water

management objectives.

2.07 Soil / Land Management

The GoRTT recognises that land and soil are finite resources that provide critical supporting and regulatory ecosystem functions including, but not limited to: the growth of crops, regulation of water quality and quantity, carbon sequestration, biodiversity conservation and provision of space for human settlement. The availability of land and soil resources to support rapid population growth is limited. Therefore, their management is important to ensure that the needs for both the human and natural environments are met. In recognising this, Trinidad and Tobago has become a partner of the Global Soil Partnership to improve governance of soil resources. Furthermore, in continued efforts to uphold SDGs 2, 3 and 15, which aim to promote sustainable agriculture, promote well-being for all at all ages and reverse land degradation, respectively, the GoRTT will:

a) Mobilise resources for the implementation of the National Action Program to Combat Land Degradation in Trinidad and Tobago to ensure that critical issues regarding land degradation are identified, corrected, mitigated or eliminated;

b) Amend existing legislation or develop new legislation, as appropriate, to improve soil/land conservation, fertility, and management;

c) Empower government entities to better undertake their mandates with respect to the conservation and management of soil/land by way of enhanced technical, financial and human-resource capacity development;

d) Encourage educational institutions, non-governmental organisations and private sector entities to engage in research regarding soil conservation, and soil fertility augmentation; and

e) Continue efforts to prevent soil loss through the development and implementation of programs to afforest, reforest, or otherwise re-vegetate slopes vulnerable to erosion.

2.08 Biodiversity Management

Trinidad and Tobago has some of the highest levels of biodiversity globally, being home to a diverse array of ecosystems and native species. The GoRTT recognises its responsibility to be diligent stewards of all forms of life based on intrinsic value. Further, it recognises that halting the loss and degradation of biodiversity will yield compounded benefits to biodiversity-related industries, such as ecotourism, and the general well-being of all citizens. Thus, in continuing its efforts to achieve SDG 14 and 15, which aim to protect, restore and promote the sustainable use of biological resources and halt biodiversity loss, the GoRTT, will:


a) Amend existing legislation or develop new legislation, as appropriate, to: i. Facilitate action towards the objectives of MEAs related to biodiversity

conservation including, but not limited to the: Convention on Biological Diversity and its precipitating Protocols, Convention for the Protection and Development of the Marine Environment of the Wider Caribbean Area and its precipitating Protocols, Convention on International Trade in Endangered Species of Wild Fauna and Flora, Ramsar Convention on Wetlands and United Nations Convention on the Law of the Sea; and

ii. Facilitate the coordination and management of a system to govern forest, protected areas and wildlife in accordance with the National Forest Policy, National Protected Areas Policy and National Wildlife Policy.

b) Periodically update the National Biodiversity Strategy and Action Plan and National

Biodiversity Targets to ensure harmonisation with national development policy,

biodiversity-related MEAs and regional efforts at biodiversity conservation including but

not limited to the: CARICOM Biodiversity Strategy, CARICOM Environmental and Natural

Resources Action Plan, and the Specially Protected Areas and Wildlife Protocol to the

Cartagena Convention;

c) Mainstream the National Biodiversity Strategy and Action Plan across all economic

sectors, and biodiversity issues into all national and sectoral policies, plans and

programmes;

d) Continue the conservation of biodiversity through the development and implementation of

programmes to address drivers of biodiversity loss including, but not limited to:

deforestation, fires, erosion, illegal development activity, illegal exotic pet trade, invasive

species and over-hunting;

e) Conserve representative examples of all terrestrial and marine ecosystems through their

designation, and effective management of protected areas under national legislation;

f) Maintain total areas of land zoned for forest reserves and prevent conversion of lands

best-suited for forest to other land use types;

g) Ensure sustainable use of forest including extraction of timber and wild meat;

h) Continue the protection and in-situ conservation of threatened, vulnerable, rare or endangered species through the designation, and effective management, of protected areas under national legislation;

i) Encourage the meaningful participation of non-governmental organisations and

community-groups, especially those involving youth, in the conservation, management,

monitoring and evaluation of biodiversity;

j) Encourage through market-based mechanisms and alternative incentive programmes the conservation, and wise use of biodiversity;

k) Establish mechanisms to ensure the equitable sharing of benefits arising from the

conservation or utilisation of biodiversity, and/or intellectual property associated with the

conservation or utilisation of biodiversity;

l) Continue the ex-situ conservation of biodiversity and genetic resources, as a complement

to in-situ conservation programmes;

m) Support global partnerships that enhance opportunities and build capacity in local

educational institutions towards biodiversity research, conservation and outreach;

n) Encourage the economic and social valuation of ecosystem services to inform

conservation and ecosystem management efforts;


o) Undertake, in collaboration with non-governmental organisations, private sector and community groups sustained public education and awareness campaigns that encourage the conservation, and wise use of biodiversity; and

p) Empower governmental entities to better undertake their mandates with respect to the management of biodiversity by way of enhanced technical, financial and human-resource capacity development.

Invasive Alien Species (IAS) Management

The GoRTT recognises that Trinidad and Tobago is vulnerable to the impact of invasive alien species (IAS) by nature of being a SIDS. Furthermore, its vulnerability will be increased as it pursues measures to enhance trade, sectoral growth in the maritime services and tourism sectors, and the regional and international movement of people. To mitigate the risk IAS pose to biodiversity, biodiversity-based economies and human-health, the Government remains committed to regional and international efforts aimed at controlling the spread of invasive species through prevention, early detection and control – with eradication sought as a last resort. Accordingly, the GoRTT will:

q) Amend existing legislation or develop new legislation, as appropriate, to give effect to Trinidad and Tobago’s MEA obligations related to IAS;

r) Finalise a national strategy and action plan for addressing IAS which includes: i. Coherence with national, regional and international efforts at managing IAS; ii. Strategies for preventing the introduction of IAS; iii. Strengthening of the national surveillance system for IAS; iv. Strategies for mitigating the spread and impacts of IAS; v. Strategies for restoring species and ecosystems impacted by IAS; and vi. Strategies for mobilising national, bilateral and multilateral resources for

implementation of the national strategy and action plan. s) Ensure the effective implementation of programmes and projects that give effect to the

national strategies for addressing IAS, including but not limited to the National Strategy for Ballast Water Management for Trinidad and Tobago;

t) Maintain a catalogue of existing flora and fauna to properly identify species that are indigenous to Trinidad and Tobago and species that have been introduced and have either become naturalised or invasive;

u) Foster partnerships between national, regional and international organisations with an aim to undertaking national, regional and sub-regional efforts addressing IAS;

v) Encourage the meaningful participation of private sector, governmental entities, non-governmental organisations and the public in the management of IAS; and

w) Empower government entities, by way of enhanced technical, financial and human-resource capacity development, to better undertake their mandates with respect to the management of IAS in accordance with MEAs, including but not limited to, the Convention on Biological Diversity, International Plant Protection Convention, World Trade Organization Sanitary and Phytosanitary Measures, Organization des Epizooties, International Convention for the Control and Management of Ships’ Ballast Water and Sediments, and International Maritime Organization standard.


2.09 Coastal and Marine Area Management

The GoRTT acknowledges that, as a SIDS, management of the coastal and marine area is critical as they form the nexus of human settlement, economic activity and some of the most productive ecosystems in the world. Coastal resources such as beaches, sea-grass beds, mangrove forests and coral reefs contribute to the national Gross Domestic Product (GDP), protect coastal communities and provide non-material benefits to the people of Trinidad and Tobago. However, these areas remain highly vulnerable to the projected impacts of climate change, natural disasters and unsustainable development. Therefore, the GoRTT is committed to sustainably managing these resources in keeping with integrated coastal zone management principles and philosophies. It is Government’s policy that there will be no net loss of wetlands and their function on publicly owned wetlands and waters. In its continued efforts to uphold SDG 14, which aims to conserve and sustainably use the oceans, seas and marine resources, the GoRTT will:

a) Conserve representative examples of all coastal and marine ecosystems by including them in a system of protected areas;

b) Establish an Integrated Coastal Zone Management Policy, Strategies and Action Plan to guide management and restoration of the coastal zone;

c) Amend existing legislation or develop new legislation, as appropriate, to establish and enforce building set-backs from shorelines and coastal wetlands;

d) Mobilise resources to enable the activities prescribed in the National Wetlands Policy; e) Empower government entities to better undertake their mandates with respect to the

management of the coastal zone by way of enhanced technical, financial and human-resource capacity development;

f) Develop capacity in Government agencies towards the development and use of marine spatial planning to better manage ocean space;

g) Encourage educational institutions, non-governmental organisations and private sector entities to engage in research regarding coastal ecosystems and their use; and

h) Implement regulations, incentive schemes and/or awareness programmes to encourage the wise use of privately-owned wetlands.

2.10 Fisheries Management

Fisheries resources exploited in Trinidad and Tobago include finfish, shrimp, lobster, crab and shellfish (oysters, conch, mussels, and chip chip). The sustainable management of these resources is hampered by a number of factors including outdated legislation; an open access regime, high by-catch discards, illegal fishing, fishing subsidies, inadequate monitoring and enforcement of regulations and the lack of accurate data on fisheries. The development of the fisheries sector, inclusive of ornamental fish trade and aquaculture, has an important role to play in long term food security, employment and economic development. It is also recognised that for many coastal communities that depend on fisheries and marine resources, a thriving fishery is a core component to their livelihoods, traditions, and cultural identity. Government’s policy is therefore that all fisheries will be managed in a sustainable manner. Accordingly, in keeping with SDGs 12 and 14, the GoRTT will:

a) Develop a National Fisheries and Aquaculture Sector Policy aligned with internationally accepted principles, guidelines and the CARICOM Common Fisheries Policy, to guide the strategic development and growth of this sector;


b) Review and amend existing legislation, regulations and guidelines, as appropriate, to improve data collection and facilitate the implementation of appropriate technical measures for sustainable fisheries management;

c) Develop and execute, in collaboration with national stakeholders, programmes to give effect to the CARICOM Common Fisheries Policy;

d) Promote participatory governance by strengthening the capacity of coastal communities for community-based management of fisheries resources;

e) Utilise market-based and alternative incentive programmes to integrate more sustainable practices into the fisheries sector;

f) Encourage the development of the aquaculture sub-sector; g) Mobilise resources, or seek global partnership for the mobilisation of resources, towards

pollution prevention and coastal ecosystem protection measures likely to safeguard critical fish stocks;

h) Empower government entities to better undertake their mandates with respect to the management of fisheries and aquaculture by way of enhanced technical, financial and human-resource capacity development;

i) Encourage educational institutions, non-governmental organisations and private sector entities to engage in research relevant to fisheries and aquaculture; and

j) Encourage the use of ecosystem based approaches for enhancing the resilience of the fisheries sector to the effects of climate change, pests and diseases.

2.11 Agriculture Management

Agricultural food systems can contribute to water, soil and biodiversity conservation in addition to other nationally significant benefits that include, but are not limited to (i) enhanced food security, (ii) increased food sovereignty, (iii) wealth creation among rural communities, (iv) economic growth and diversification, and (v) significant reductions in food import expenditure. Thus, the growth of a sustainable agricultural sector is of national importance. The GoRTT also acknowledges that the agricultural sector is among the most dependent on the quality of the environment, and most vulnerable to environmental catastrophe. Accordingly, the GoRTT will:

a) Ensure that lands best suited for crop production are prioritised for agricultural purposes; b) Encourage, by way of market-based mechanisms, standards or alternative incentives,

sustainable agricultural practices, agricultural processing and food production; c) Encourage partnerships at the national, regional and international scale to develop a

sustainable food production system that: i. Increases productivity and production; ii. Increases resilience to the impacts of climate change; iii. Maintains ecosystems; and iv. Improves the land and quality of soil.

d) Empower government entities to better undertake their mandates with respect to the development of a sustainable food production system by way of enhanced technical, financial and human-resource capacity development;

e) Undertake, in collaboration with stakeholders, programmes towards the objectives of the CARICOM Common Agriculture Policy;

f) Empower small-scale food producers, particularly women, indigenous peoples, and family farmers, through improving secure and equal access to: land, other productive resources and inputs, knowledge, financial services, markets, and opportunities for value addition and non-farm employment; and


g) Undertake, in collaboration with non-governmental organisations, private sector and community groups sustained public education and awareness campaigns that encourage sustainable agricultural practices, and the consumption of locally-produced agricultural goods.

2.12 Mineral and Hydrocarbon Resource Management

The GoRTT recognises the need to diversify the economy from its reliance on finite hydrocarbon resources. However, the prudent use of these resources remains a critical component for economic growth and social development in Trinidad and Tobago. Acknowledging that the exploration, extraction and processing of non-renewable resources in the form of minerals (e.g. sand, asphalt, and gravel) or hydrocarbons (e.g. petroleum or natural gas) can potentially negatively impact society and the environment, the Government’s policy is that these activities shall be undertaken in a manner as to minimise the impacts to human health, livelihoods, cultural assets and the environment. In this regard, the GoRTT will:

a) Encourage and support research and academic institutions, non-governmental and governmental organisations and private sector entities in undertaking a systematic assessment into the true cost of mineral and hydrocarbon exploitation for the purposes of selecting ventures that are most socially, environmentally and economically sustainable;

b) Strengthen existent, or develop new institutional and regulatory regimes, as appropriate, to support the wise use of primary energy resources for sustainable development based on Full Cost Accounting Practices that will support the establishment of fees/funding consistent with the Polluter Pays Principle;

c) Utilise Environmental Impact Assessments (EIAs), and cost-benefit analysis to: i. Inform the decision-making process regarding projects that may have significant

environmental impacts or where there is great uncertainty regarding potential impacts; and

ii. Inform mitigation measures for projects that receive approval. d) Ensure that all stakeholders likely to be impacted by the exploitation of minerals and

hydrocarbon resources have meaningful participation in the process of developing social and environmental safeguards;

e) Ensure all extractive projects employ the best available technologies and mitigation strategies not exceeding excessive cost that have been historically effective at minimising environmental impact in Trinidad and Tobago or similar jurisdictions;

f) Ensure the use of progressive rehabilitation at mining sites; g) Amend existing legislation or develop new legislation, as appropriate, to:

i. Modernise fiduciary instruments and fees associated with site rehabilitation; and ii. Mainstream the use of asset integrity management systems in extractive

industries. h) Empower government entities to better undertake their mandates with respect to the

regulation, monitoring and evaluation of mineral and hydrocarbon exploitation projects by way of enhanced technical, financial and human-resource capacity development; and

i) Ensure that industries responsible for environmental disasters or significant impact to human health bear the complete cost of reconciliatory action, rehabilitation and restoration.


PRIORITY 3: Improving the Local Environment The importance of ensuring that urban and rural communities live within cities, towns and villages that meet their needs and provide a safe environment must not be minimised, as settlement features can impact the environment, human health, and the economy. Communities must be safe, inclusive, and resilient; maintain their distinct cultural flair; and enhance human health and well-being. Thus, this section features the GoRTT’s commitment to strategically-planned settlement patterns and design, as well as sustainable and resilient infrastructure.

2.13 Planning and Human Settlements

The GoRTT believes that modern and sustainably planned human settlement is essential for achieving environmental sustainability. Moreover, properly designed and managed human settlements reduce the vulnerability of the community to social and environmental threats. Thus, in keeping with SDG 11, the GoRTT will:

a) Take urgent action, as appropriate, to address and monitor unplanned, unregulated, and illegal settlement of state lands, particularly in areas of high environmental sensitivity, historical or cultural significance;

b) Empower government entities with the responsibility for planning and development to effectively implement their mandate through the provision of additional financial, technical and institutional capacity-building;

c) Ensure meaningful participation of private sector, non-governmental entities and the public in planning and development of human settlements;

d) Revise, as appropriate, and enforce guidelines on land use and human settlement as to minimise the impact of economic activity on human health and comfort;

e) Review and amend, as appropriate, legislation to promote sustainable human settlement planning;

f) Ensure that all planned human settlements are designed to: i. Incorporate ‘green spaces’, with particular emphasis on areas of high hydrological

significance; ii. Include community spaces that encourage healthy lifestyles; iii. Minimise the fragmentation of forests and enhance the connectivity of parks,

forests and green spaces; and iv. Withstand and alleviate the impacts of natural disasters and climate change.

g) Ensure that all planned human settlements, as far as practicably possible, are not: i. Placed on hillsides, within flood plains, or other areas highly vulnerable to natural

disaster; ii. Placed within environmentally sensitive areas where development may threaten

environmentally sensitive or endangered species; iii. Placed within hydrological significant areas where development may threaten the

quality or quantity of critical water supplies; iv. Placed on land determined to be best suited for agricultural production.

PRIORITY 3: Improving the Local Environment


2.14 Green Architecture and Infrastructure

It is Government’s policy that all its buildings and development projects will minimise, as far as practicably possible, its carbon and ecological footprint. The operations of governmental agencies will be in accordance with the national Green Government Policy. Promoting green architecture and infrastructure will be used as a key strategy for sustainable development. It will lead to reductions in the environmental impacts associated with Trinidad and Tobago’s built environment while providing economic, ecological and social benefits. This sustainable and resource efficient development process is in keeping with Government’s development plans as well as SDG 9, which seeks to build resilient infrastructure. Measures to encourage green architecture and infrastructure into Trinidad and Tobago’s built environment include:

a) Establish national building codes, aligned to regional standards and international best practice, and which emphasise energy efficiency and climate resilience;

b) Enhance or develop additional incentive programmes, as appropriate, that promote green architecture and infrastructure;

c) Encourage private sector entities and the public to utilise infrastructure designs that minimise, as far as practicably possible, the ecological footprint and carbon footprint of development;

d) Support the development of non-governmental and private sector specialisation and expertise in the areas of green architecture and design suitable for the Caribbean environment; and

e) Encourage educational institutions, non-governmental organisations and private sector entities to engage in research relevant to green architecture and green infrastructure.

2.15 Heritage, Cultural and Archaeological Sites

SDG 11 aims to make cities and human settlements inclusive, safe, resilient and sustainable by strengthening efforts to protect and safeguard the world’s cultural and natural heritage. Heritage sites may include natural or built monuments or sceneries that offer outstanding beauty, in addition to material and non-material ecosystem services. Local sites of historical, cultural or natural significance need to be identified and listed before they are destroyed or eliminated. In keeping with this goal, the GoRTT believes a sustainable approach is necessary for the protection and enhancement of the historic environment. It will improve well-being and create vibrant communities, while sustaining local economies, particularly through tourism. To sustainably manage Trinidad and Tobago’s historic sites, the GoRTT will:

a) Amend or develop additional policies and legislation and standards, as appropriate, to enhance the number and management of heritage, cultural, and archaeological sites;

b) Consider the protection of heritage, cultural, and archaeological sites as priority in national planning and development permitting processes;

c) Empower government entities, non-governmental organisations and private sector entities to undertake actions, as appropriate, for the conservation and preservation of heritage, cultural and archaeological sites;

d) Improve the quality of heritage, cultural and archaeological sites with an aim of achieving World Heritage status;

e) Develop and promote Trinidad and Tobago’s heritage, cultural and archaeological sites as tourist attractions; and


f) Utilise market-based and alternative incentive programmes to ensure the maintenance and preservation of privately owned heritage sites.

2.16 National Festival and Events Management

Improving the quality of human settlements also entails adjusting the use of human settlements to ensure the maintenance of environmental integrity and human health. Trinidad and Tobago is a multicultural society with many celebrations. The execution of these events is often characterised by large volumes of solid waste, water contamination and frequent complaints about excessive noise. It is the GoRTT’s policy that all national events will be conducted in a manner that ensures minimal impact to human health and the environment while respecting the well-being of all citizens. Additionally, the GoRTT will:

a) Develop a national policy to guide the promotion, execution and management of national festivals and events that is inclusive of environmental and human health;

b) Amend or develop additional policies, legislation and standards, as appropriate, to address events and festivals which may negatively impact human health and the environment; and

c) Encourage environmentally responsible behaviour and practices in the management of national festivals and events.

2.17 Mass Transit Solutions

The GoRTT recognises that a safe, affordable, accessible and sustainable transport system has an important role in addressing environmental sustainability. The mainstreaming of mass transit solutions can profoundly shape and improve the quality of human settlements, yielding multiple benefits including (i) reduced localised air pollution and greenhouse gas emissions, (ii) reduction in accidents and accident-related deaths and injuries, and (iii) improved productivity and quality of life of citizens, due to reduced commute times. In keeping with SDG 11, the GoRTT will:

a) Collaborate with private and non-governmental institutions, at the national, regional and international scales to advance mass transit systems;

b) Amend existing legislation or develop new legislation, as appropriate, to enable the utilisation of mass transit systems;

c) Ensure that development planning and development approvals consider favourable efforts to incorporate mass transit systems;

d) Improve transport infrastructure with an aim of encouraging mass transit; and e) Encourage the use of mass transit solutions including public transportation, and car-

pooling through various policy instruments.


PRIORITY 4: Evolving a Greener Economy

2.18 Economic Transformation

The GoRTT recognises that the growth of a greener economy shares parity with environmental conservation and fosters an environmentally responsible society. Integrating environmental considerations into the way business is conducted reduces economic vulnerability and drives economic growth. Greening the economy is therefore a means to strengthen the country’s economic performance through the introduction of new value added economic activities, increased efficiency across all sectors, reduction of waste, and the generation of green jobs. Towards this end, the GoRTT will:

a) Mainstream the policy targets of this NEP and Action Plan into codes of conduct, voluntary agreements and codes of practice;

b) Develop responsive and accessible financial support programmes for the private and non-governmental sector;

c) Improve the national system of market-based economic instruments through measures that include, but are not limited to:

i. Phasing out perverse economic incentives which result in unintentional impacts to the environment;

ii. Internalising the negative environmental externalities in the production of goods and services by way of taxes and levies;

iii. Developing markets based on the trading of pollution/emission licenses or credits; iv. Providing conditional payments for the voluntary protection of ecosystems and

their services; v. Developing deposit-refund systems that reward behaviours that abate pollution;

and vi. Developing subsidies and tax-breaks for environmentally responsible behaviours.

d) Enhance the existing legislation and body of standards for goods, services and activities in Trinidad and Tobago;

e) Invest in human resources through education and skills training to facilitate the shift from ‘brown’ to ‘green’ jobs;

f) Develop incentives to attract foreign direct investment as well as investment from the Caribbean diaspora;

g) Encourage the growth and development of a circular economy in which waste is revalued and resources are recirculated locally as much as possible;

h) Support the growth and development of alternative economies compatible with a greener economy including but not limited to:

i. A “Blue Economy” based on the sustainable use of ocean resources; and ii. A “Silver Economy” based on leveraging ageing populations and their needs to

stimulate sustainable economic growth.

PRIORITY 4: Evolving a Greener Economy


To catalyse the growth of a greener economy, the GoRTT further commits to harmonising the regulations of the national environmental fund4 with this NEP by 2020 to enable the timely financial support of activities related to the NEP policy statements and strategic priorities identified in the Action Plan. Special emphasis will be given to programmes and projects that advance low-emissions development and enhance community resilience to natural disasters. Additional focus will be on those projects where private capital can be raised, with additional public financial support. The revitalized economy will generate economic prosperity across Trinidad and Tobago, especially in communities where income is generated through the direct or facilitated use of the environment. Whereas government’s actions will create the enabling environment for economic transformation, the private sector will be the innovator and leader for creating socially-just and environmentally responsible employment opportunities. The GORTT will:

i) Ensure that multi-national corporations operating in rural and/or coastal communities to

exercise corporate-social responsibility through: i. The provision of employment opportunities for suitably qualified members of the

community; and ii. The provision of training, internship or mentoring opportunities aimed at improving

the skills and qualifications of members of the community for future employment or entrepreneurship.

j) Support entrepreneurial efforts aimed to address environmental issues, or foster economic prosperity in an environmentally responsible manner.

4 The Green Fund established under the Finance Act 2000 through the Miscellaneous Taxes Act, Chapter 77:01 (as amended) and as regulated by Green Fund Regulations, 2007 and the Green Fund (Amendment) Regulations 2011


PRIORITY 5: Fostering an Environmentally Responsible Society The National Environmental Literacy Survey5 conducted in 2016 revealed that the people of Trinidad and Tobago generally hold above average pro-environmental attitudes. However, these attitudes were neither matched by their degree of environmental knowledge nor lifestyle practices. To achieve a society in which all people take an active role in protecting, maintaining and enhancing the quality of the environment, the GoRTT will create enabling conditions for the growth and normalisation of environmental attitudes, knowledge and practices. Such action is in line with SDGs 4 and 16 which emphasise the need to acquire knowledge and skills to promote sustainable development. The following sections highlight the need for information to be accessible to the public; the importance of sustained public education and awareness campaigns; the need for research; and a framework for how citizens can access environmental justice.

2.19 Availability of and Public Access to Information

GoRTT’s policy is that public authorities holding information on the environment must make it available to anyone requesting it, subject to certain exclusions. Reasons for exclusion must be in accordance with the provisions of the Freedom of Information Act Chap. 22:02 or parent/primary legislation of the public authority. In keeping with the environmental principles enshrined in this policy, the GoRTT will:

a) Increase the capacity of government and non-governmental entities to maintain and provide accurate and legible environmental information of interest to the public via physical and digital media;

b) Promote mechanisms for accessing environmental information, data and processes used to inform decisions with bearing on development activity; and

c) Empower public and non-governmental organisations to utilise the provisions under the Freedom of Information Act Chap 22:02 to access environmental information.

2.20 Communication, Education and Public Participation

The GoRTT recognises that empowering individuals to undertake environmentally responsible behaviour also requires systemic reinforcement of pro-environmental behaviours and knowledge. This entails continuous environmental education and public participation in environmental decision-making. It is the Government’s policy that all environmental education in Trinidad and Tobago is in keeping with the goals, objectives and characterisations contained in the Belgrade Charter (1975), the Tbilisi Declaration (1977) and Chapter 36 or Agenda 21 (1992). To this end, and in keeping with SDG 4, the GoRTT will:

a) Continue to introduce environmental education from pre-school school age to adulthood, for both formal and informal sectors, with the goal of providing knowledge of both local and global environmental issues as well as the skills required to enable effective public participation, decision-making and action;

5 EMA (2016) National Environmental Literacy Survey

PRIORITY 5: Fostering an Environmentally

Responsible Society


b) Further the integration of sustainable development concepts and the principles of this NEP into all education programmes and curricula;

c) Mobilise resources and encourage partnerships among national, regional and international entities towards building public awareness and behavioural change;

d) Coordinate environmental education and awareness programmes initiated by the public, private and non-governmental sectors at the national level;

e) Empower public agencies to undertake environmental communication, awareness and education programmes based on local environmental issues in a manner appropriate for the target community;

f) Support the development and promotion of mechanisms that provide viable solutions to environmental problems in communities;

g) Ensure that mechanisms established for meaningful participation in decision-making regarding environmental and/or development issues are appropriately promoted, and made available to the public; and

h) Ensure that all efforts at education, awareness-building and meaningful participation in decision-making regarding environmental and/or development issues encourage and facilitate the inclusion of marginalised groups such as indigenous peoples, the rural poor, children, youth, women, sick, disabled and elderly.

2.21 Research

Scientifically-sound research and local knowledge will underpin environmental decision-making in Trinidad and Tobago and support the achievement of this NEP’s policy statements. Furthermore, the GoRTT recognises that participation in the generation and advancement of scientific and socio-ecological research provides a significant opportunity for fostering environmental stewardship and responsibility among individuals. Thus, in keeping with SDG 9, the GoRTT will:

a) Through inter-agency collaboration, develop a framework for research opportunities in areas identified as a priority for progressing this NEP and attendant Action Plan;

b) Encourage, by way of funding mechanisms, government, private and non-governmental entities to engage in projects that incorporate ‘citizen science’ and public participatory methods of gathering data; and

c) Establish a knowledge management platform to maintain and disseminate updates on research activities between government, private and non-governmental entities to minimise duplication of effort.

2.22 Access to and Implementation of Environmental Justice

The GoRTT understands that the meaningful involvement of all persons in the development, implementation and enforcement of environmental laws and policies fosters a society of environmental stewards. More so, providing access to effective redress for environmental disputes and issues empowers individuals to take personal responsibility for an environmentally sustainable future. Accordingly, the GoRTT will:

a) Encourage public participation in the development, implementation and enforcement of environmental laws, regulations, policies, management plans and programmes as far as practicably possible;


b) Empower government entities with responsibility for the environment to adopt proactive measures for discovering and responding to environmental issues in a timely manner;

c) Support the development of ADR mechanisms for addressing environmental and natural resource conflicts;

d) Amend or develop new legislation, as appropriate, to facilitate expedient civil action on environmental issues;

e) Empower community groups and non-governmental organisations to seek redress through litigative or ADR mechanisms;

f) Support education and awareness campaigns that promote avenues for environmental redress and remedies;

g) Encourage the mainstreaming of environmental laws, regulations and policies among all stakeholders with critical roles in dispensing environmental justice including but not limited to, the police service and the judiciary;

h) Amend or develop new legislation, as appropriate, to establish courts dedicated to addressing environmental issues across Trinidad and Tobago; and

i) Revise, as appropriate, environmental regulations to maintain effective financial disincentives and mechanisms for appropriate financial compensation for environmental losses.


PRIORITY 6: Addressing Climate Change and Environmental and Natural Disasters Climate Change presents urgent threats to ecosystems and built environments with likely irreparable damage to societies and the planet. Small Island Developing States (SIDS), such as Trinidad and Tobago, are among those most vulnerable to the effects of climate change due to their unique political, social and cultural milieu; character, geography, size and state of economic development6. The effects of climate change include shifts in climate variability towards higher average daily and nightly temperatures, reduced rainfall volumes and increased rainfall intensity; more frequent and intense extreme weather events such as droughts, floods and tropical storms; and increased ocean acidification, sea level rise, and distribution of disease-carrying vectors7. These effects may exacerbate human-made disasters, or result in increased incidence of natural disasters with detrimental impact across all sectors and strata of society. The economic cost of damage to society is conservatively estimated to be in the magnitude of billions of USD towards the end of the 21st century for Trinidad and Tobago8. In keeping with the provisions of SDG 13 as well as the United Nations Framework Convention on Climate Change (UNFCCC) and its instruments including the Paris Agreement and the Kyoto Protocol, Trinidad and Tobago remains committed to urgently addressing the drivers and impacts of climate change. This section details the GoRTT’s commitments towards climate change mitigation, adaptation as well as managing climate risks. It also details the GoRTT’s planned initiatives towards comprehensive environmental and natural disaster management.

2.23 Climate Change Mitigation and Adaptation

Climate Change Mitigation Greenhouse gas (GHG) emissions produced from human activity is recognised by the GoRTT as the dominant driver of global climate change. Thus, the GoRTT is committed to reducing the country’s GHG emissions through source reduction, avoidance and improved sequestration of GHGs. In its Nationally Determined Contributions (NDC) under the Paris Agreement, the GoRTT has committed itself to:

i. An overall reduction of emissions from the industrial, power generation and transport sectors by 15% of cumulative emissions by 2030 relative to a business-as-usual baseline, conditional on external financial support; and

ii. An unconditional reduction of cumulative emissions from the public transportation sector by 30% baseline by December 31st, 2030 relative to a business-as-usual baseline, and

6 Everest-Phillip, M. 2014. “Small, So Simple? Complexity in Small Island Developing States” UNDP Global Centre for Public Service Excellence 7 IPCC. 2014. “Climate Change 2014: Impacts, Adaptation and Vulnerability” IPCC, Geneva, Switzerland 8 Bueno, R., C. Herzfeld, E.A. Stanton and F. Ackerman. 2008. “The Caribbean and Climate Change: The Cost of Inaction” Global Development and Environment Institute, Tufts University.

Priority 6: Addressing Climate

Change and Environmental and Natural Disasters


which forms part of the overall emissions reductions from the three sectors.

Towards achieving current and future commitments to the Paris Agreement, and the reduction, avoidance or sequestration of emissions across all sectors, the GoRTT will:

a) Conduct regular inventories of GHGs; b) Cooperate with relevant local, regional and international agencies to implement

technologies that will sequester, reduce, prevent or control man-made emissions of GHGs across all sectors;

c) Conserve and enhance natural ecosystems that serve as sinks or reservoirs of GHGs such as forests, coastal and marine wetland ecosystems;

d) Utilise mechanisms under the UNFCCC including, but not limited to: Low Emission Development Strategies (LEDS), Nationally Appropriate Mitigation Actions (NAMA), Clean Development Mechanism (CDM), REDD+ and market mechanisms;

e) Establish and strengthen the institutional arrangements, including the designation of focal points, national authorities, and other entities, for the purpose of utilising financial mechanisms related to climate change including, but not limited to the: Special Climate Change Fund (SCCF), the Green Climate Fund (GCF), and the Adaptation Fund (AF);

f) Mobilise resources, and seek global partnerships to secure resources, to support the implementation of the mitigation measures contained in the:

i. National Strategy for the Reduction of Carbon Emissions in Trinidad and Tobago, 2040;

ii. National Climate Change Policy and other national policies related to climate change; and

iii. Nationally Determined Contributions under the Paris Agreement g) Amend existing legislation or develop new legislation, as appropriate, to give effect to

Trinidad and Tobago’s commitments under MEAs related to climate change; h) Explore market-based mechanisms that give effect to Trinidad and Tobago’s

commitments under MEAs related to climate change; i) Establish a national monitoring, reporting and verification system for GHG emission

inventorying, reduction, avoidance or sequestration; and j) Support institutional capacity building in the public, private and non-governmental sector

towards emissions reductions, monitoring, verification and reporting. Energy Efficiency and Energy Conservation The GoRTT is cognisant that pursuing energy efficiency and energy conservation will aid in the reduction of the country’s carbon footprint while simultaneously yielding additional social and economic benefits. These include: (i) delaying or avoiding new energy generation infrastructure to match growing demand; (ii) increased fuel availability for industrial use; (iii) enhanced energy security for all; (iv) significant macro-economic savings in the amount required for household energy subsidies. As such, in alignment with SDG 7 (affordable, reliable, sustainable and modern energy for all), the GoRTT is committed to improving supply-side and demand-side energy efficiency and energy conservation. The GoRTT will:

k) Create an enabling fiscal, legislative and institutional environment that encourages and supports the use of cogeneration systems with an emphasis on the power generation sector;

l) Develop a regulatory framework to promote energy efficiency in buildings, equipment and appliances, that is aligned with regional and international standards and best practice;



http://unfccc.int/cooperation_and_support/financial_mechanism/adaptation_fund/items/3659.php


m) Strengthen the capacity of public, private and non-governmental actors to undertake energy efficiency interventions including, but not limited to, energy audits, energy-efficient design, and other energy services;

n) Strengthen existing or further develop, as appropriate, appropriate financial and market-based mechanisms to encourage energy efficiency and energy conservation across all sectors;

o) Continue to develop and implement demand-side management programmes to encourage energy efficiency and energy conservation practices in the residential, commercial and industrial sectors; and

p) Adjust, as appropriate, electricity tariffs and pricing mechanisms to encourage more efficient and responsible consumption of energy.

Renewable Energy The GoRTT recognises the importance of utilising low-emission and zero-emission technologies to close the gap between energy supply and demand. Therefore, the GoRTT has set a target of 10% power generation from renewable sources of energy by 2021 to catalyse the transition to a low-emission development pathway. In alignment with SDG 7, the Government will achieve this target through actions including, but not limited to:

q) Revise existing legislation or develop new legislation and policies, as appropriate, to facilitate the deployment and integration of renewable energy technology into the residential, commercial and industrial sectors;

r) Strengthen existing or further develop financial and market-based mechanisms, as appropriate, to encourage the use of renewable energy across all sectors;

s) Partner with local, regional and international entities to create an enabling environment for investment into renewable energy research, support services, and projects, including feasibility studies;

t) Develop and implement programmes aimed at enhancing public awareness and education on renewable energy;

u) Develop and implement, as appropriate, capacity building programmes in collaboration with private and non-governmental actors to enhance renewable energy integration and deployment; and

v) Develop and adopt, as appropriate, standards and codes for the buildings sector in order to enable the development and integration of renewable energy technologies, and are harmonised with international and regional standards, codes and best practice.

Climate Change Adaptation The GoRTT acknowledges that projected global climate change will have adverse impact son physical, biophysical and socio-economic sectors in Trinidad and Tobago. Accordingly, and in accordance with SDG 13, the GoRTT will:

w) Mobilise resources, and seek global partnerships to secure resources, for the implementation of the adaptation measures contained in the National Climate Change Policy and other national policies related to climate change adaptation and resilience building;


x) Conduct assessments of the climate risk and/or vulnerability of communities and/or sectors to the impacts of climate change, including the development of GIS-based climate risk maps;

y) Establish early warning systems for climate risks in vulnerable sectors; z) Revise existing legislation, or develop new legislation, standards, codes and policies, as

appropriate, to ensure that climate change vulnerability and adaptation are integrated into national and sectoral development planning to enhance and maintain climate resilience;

aa) Maintain and enhance, as appropriate, ecosystems that provide climate resilience services that minimize the adverse impacts of climate change and/or which minimise climate risk;

bb) Strengthen institutional arrangements within and among public, private and non-governmental sectors for conducting systematic observations, vulnerability assessments, research and climate modelling;

cc) Support community-based adaptation and resilience building efforts led by governmental entities, private sector and/or non-governmental organisations; and

dd) Encourage the use of infrastructure designs and land use plans that include elements to adapt to the effects of climate change such as enhanced storm water conveyance and detention capacity.

2.24 Comprehensive Environmental and Natural Disaster Management

Environmental disasters encompass both human impact on the environment and the environment’s impact on humans. Human health, the environment and the economy can be impacted by unintended human activity, such as, industrial accidents, spills and releases. Additionally, human health and environmental quality can also be severely impacted by natural occurrences, such as hurricanes, drought and earthquakes. Over a 25-year period, disasters in the Caribbean region claimed more than 240,000 lives and inflicted more than US$39 billion in damage9. In keeping with the Sendai Framework for Disaster Risk Reduction 2015 – 2030, and the Revised Treaty of Chaguaramas Establishing the CARICOM and the CSME, the GoRTT is committed to collaborating, at all scales, to ensure that environmental disasters are comprehensively managed through prevention and mitigation, preparedness, response, recovery, and rehabilitation. Accordingly, the GoRTT will:

a) Mobilise resources to strengthen national institutions and institutional arrangements among national and regional actors to give effect to the directives and strategies contained in national policies, laws and plans aimed at disaster risk reduction and emergency response which include, but are not limited to the: i. Comprehensive Disaster Management Policy Framework ii. Critical Infrastructure Policy Framework iii. National Climate Change Policy iv. Hazard Mitigation Policy v. National Relief Policy vi. Shelter Management Policy vii. Volunteer Policy viii. Disasters Measures Act Chap. 16:50

9 UN ECLAC. (2015) The Caribbean and the Post-2015 Sustainable Development Agenda


b) Increase administrative effectiveness by the elimination of fragmentation and duplication in emergency response responsibilities, updating legislation governing disaster management, and consolidating policies and programmes wherever possible;

c) Further strengthen measures to prevent the occurrence of environmental incidents including but not limited to: fail-safe systems, environmental management systems, GIS-based resource inventories, early-warning systems, inspection and maintenance programmes, and operating procedures;

d) Update existing or develop, as appropriate, new local, bi-lateral, and multi-lateral plans for pre-emergency contingency plans with clearly identified roles and responsibilities of the required public, private and non-governmental inputs of the State(s) involved;

e) Conduct periodical assessment of hazards, risks and vulnerability, using methodologies appropriate for SIDS with an aim to estimate emergency response demands;

f) Enhance the framework for accessing local and international funds for, inter alia, the establishment and maintenance of early warning systems, emergency response systems, and programmes for infrastructural rehabilitation and environmental remediation;

g) Further develop post-emergency response systems including containment of hydrocarbon and chemical spills or discharges, and remediation of contaminated and/or disturbed sites;

h) Support government, private, and non-governmental efforts to enhance community resilience and preparedness for environmental disasters;

i) Revise existing, or develop new, legislation or regulations, as appropriate, to ensure entities responsible for man-made environmental disasters bear the cost of compensation for loss and damages, as well as the cost of any restoration or remediation works; and

j) Enhance ecosystem-based measures to alleviate the impacts of natural disasters and climate change including, but not limited to the establishment, conservation and/or restoration of forests and coastal ecosystems.


3 IMPLEMENTING AND ACHIEVING

POLICY ACTIONS


3.0 IMPLEMENTING AND ACHIEVING POLICY ACTIONS

3.01 Critical Success Factors

Several challenges have limited the successful implementation of previous environmental policies. The GoRTT recognises that these barriers must be surmounted to ensure environmental sustainability is achieved. Thus, the GoRTT commits to: Strengthening mechanisms for compliance with the NEP and environmental legislation For environmental sustainability to be achieved, the environmental governance principles of Trinidad and Tobago need to be internalised by all interest groups. Furthermore, there needs to be improved compliance with existing legislation pertaining to development and environment. Towards this goal, the GoRTT shall:

a. Empower regulators and government agencies to undertake programmes geared towards proactive outreach for voluntary compliance with the NEP and environmental legislation;

b. Enhance the capacity of government organisations to operationalise this NEP and undertake works related to the Action Plan;

c. Support projects and programmes led by private sector and non-governmental organisations that are geared towards environmental education and compliance with environmental legislation; and

d. Formalise the National Environmental Code within one year of this NEP coming into effect. Strengthening institutional arrangements and collaboration among stakeholders There are many stakeholders with roles to play in environmental management and sustainable development. Effective implementation of the NEP requires the cooperation of all agencies and interest groups. To this end, the GoRTT will:

e. Ensure that all government entities are conducting operations in accordance with the NEP and National Environmental Code;

f. Enhance the existing coordination and collaboration framework with the establishment of a multi-sectoral oversight committee; and

g. Empower government organisations to engage in meaningful collaboration with non-governmental and private sector organisations towards sustainability.

Building the capacity of stakeholders towards enhancing environmental resilience The GoRTT acknowledges that there may be challenges with respect to institutional capacity for achieving policy objectives. The GoRTT therefore makes the commitment to:

h. Provide resources for improving the financial, institutional and technological capacities of

stakeholder organisations. Improving national environmental data / information management Timely access to accurate environmental information is a pre-requisite to sound planning and decision-making. Effective data management is therefore critical for the implementation of this NEP. The GoRTT shall therefore:

i. Establish a suite of baseline indicators aligned with the SDGs to be monitored; j. Empower government organisations and other stakeholders to collect and report on

environmental indicators to the EMA; and

3.01 Critical Success Factors


k. Establish a National Environmental Information Management System that serves as a clearing house for all forms of environmental information.

Mobilising resources for the implementation, monitoring and evaluation of this NEP The GoRTT will:

l. Ensure that the NEP and Action Plan are considered in the determination of budgetary allocations;

m. Enhance the framework for stakeholders to access new and existing sources of funding to aid in achieving policy objectives; and

n. Take all appropriate actions towards securing bi-lateral and multilateral funding to support the implementation, monitoring and evaluation of this NEP.

Participating in cross boundary strategies & global partnerships Global sustainability depends on a firm alliance among all countries and collective effort in addressing pressing environmental issues. The GoRTT shall continue to:

o. Subscribe to, and enforce, regional and international environmental treaties aimed at advancing environmental sustainability in the region and globally;

p. Contribute to the development of future treaties and programmes that promote the ethics of care for shared resources and the common concern of humankind; and

q. Participate in multi-country programmes that enhance environmental sustainability and comprehensive environmental disaster management at the regional and global scale.

3.02 Implementation and Mainstreaming Framework

Implementation It is envisioned that the implementation of this NEP will be achieved through a combination of top-down and bottom-up efforts, across all sectors driven by governmental, non-governmental and private sector organisations. To this end, an NEP Action Plan will be developed by the EMA, in collaboration with key interest groups, within one year of this NEP coming into effect. This Action Plan will give effect to the policy statements contained within this NEP and will identify discrete time frames, responsible and supporting agencies, monitoring indicators and targets. The Action Plan will serve as the pathway to an environmentally sustainable future for Trinidad and Tobago; reflect strategic efforts for integrating sustainable development into sectoral development and poverty alleviation, and contribute to the transformation of the unsustainable trajectory of global development through nationally appropriate effort. To further the implementation of this policy, a National Council for Sustainable Development (NCSD) will be established within one year of this NEP coming into effect. The NCSD will provide a forum for Government, business and civil society to have ongoing oversight with advisory functions to the Action Plan. The composition of the NCSD will, at all times, also reflect the tenets of the principle of Good Governance; ensuring, inter alia, the meaningful involvement of women

3.02 Implementation and Mainstreaming Framework


and youth. It is envisioned that members of the NCSD will utilise the auspices of their respective positions to facilitate the implementation of the NEP into their sectors. Mainstreaming & Coordination The EMA is vested with the responsibility for coordinating the mainstreaming of the NEP across all sectoral activity. To this end, the EMA will have the responsibility for:

i. Serving as the Secretariat to the NCSD; ii. Coordinating and supporting the mainstreaming of the NEP into the work plans of all

divisions of government agencies; iii. Leading the public education and awareness programmes on the NEP and Action Plan;

and iv. Providing technical and other support to actors with assigned responsibilities under the

Action Plan.


4. MONITORING AND

EVALUATION


4.01 Monitoring and Evaluation of the NEP and Action Plan The Action Plan will provide performance indicators, for the short, medium and long-term action items, which are necessary for the achievement of the policy statements contained within the NEP. It will also identify the lead and supporting agencies responsible for tracking and reporting performance metrics. To ensure that continuous progress is being made towards environmental sustainability, this NEP and attendant Action Plan will be monitored and evaluated by the EMA as prescribed under the EM Act. Annual reporting of the overall progress made shall be done via the Assessment of the State of the Environment Reports. Through the assessment of the barriers, constraints and degree of progress made towards policy statements, the strategies and actions can be modified to suit evolving needs and conditions.

4.02 Revision of the NEP and Action Plan

To maintain relevance and cohesion with an ever-changing national and supranational context, this NEP shall be reviewed and revised as appropriate, but not exceeding 10 years. The process of undertaking this revision shall, at the minimum, entail the process as prescribed under Section 18 of the EM Act. The NCSD shall review the Action Plan at a frequency determined as appropriate, but not exceeding two years. Revision of the document will be made to ensure that action items are aligned with national obligations and the socio-economic context of the time.

4. MONITORING

AND EVALUATION


ANNEXES


ANNEX I: INTERNATIONAL TREATIES AND CONVENTIONS RELATED TO THE ENVIRONMENT

NAME OF TREATY/

CONVENTION FOCAL POINTS REPORTING REQUIREMENTS/ COMMITMENTS

Biodiversity

The United Nations Convention on the Conservation of Biological Diversity (1975)

Permanent Secretary of the Ministry of Planning

and Development

Article 6 requires each Party develop strategies, plans or programmes for the conservation and sustainable use of biological diversity by using the guiding principles of the CBD - conserve biodiversity, promote sustainable use, and share benefits arising from genetic resources.

Article 18 requires Parties to promote international technical and scientific cooperation in the field of conservation and sustainable use of biological diversity, where necessary, through the appropriate international and national institutions.

Article 26 requires Parties to report on their biodiversity goals.

Cartagena Protocol on Biosafety (2003) to the UN Convention on Biological Diversity

Permanent Secretary of Ministry of the Attorney

General and Legal Affairs

Develop a National Biosafety Framework.

Each Party shall monitor the implementation of its obligations and report to the Convention on the measures that it has taken to implement the Protocol.

Facilitate the exchange of scientific, technical, environmental and legal information on and experience with Living Modified Organisms (LMOs).

Protocol Concerning Specially Protected Areas and Wildlife (SPAW Protocol) (1990) to the Cartagena Convention


and Development

Significantly increase the number, and improve the management of, national protected areas in the wider Caribbean region, including support to national and regional conservation management strategies and plans

Support the conservation of threatened and endangered species and sustainable use of natural resources to prevent them from becoming threatened or endangered

Develop strong regional capability for the coordination of information exchange, training and assistance, in support of national biodiversity conservation efforts

Coordinate activities, and develop strategies, with the Secretariat to the CBD, as well as other biodiversity-related treaties and initiatives, e.g. CITES and the Ramsar Convention.

Environmentally Sensitive Areas


NAME OF TREATY/ CONVENTION

FOCAL POINTS REPORTING REQUIREMENTS/ COMMITMENTS

Convention on Nature Protection and Wildlife Preservation in the Western Hemisphere (1942)

Permanent Secretary of Ministry of Agriculture, Land and Fisheries,

Forestry Division

Promote research and field study to further the objectives of the Convention.

Impose controls on trade in protected fauna and flora and any part thereof through a system of trade certificates.

Environmentally Sensitive Species

Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) (1973)

Permanent Secretary of the Ministry of

Agriculture, Land and Fisheries, not the Forestry Division.

Prohibit trade in specimens in violation of the Convention.

Designate one or more scientific authorities to advise on the issue of permits and one or more management authorities to grant permits and certificates.

Coastal and Marine Areas

Convention on Fishing and Conservation of the Living Resources of the High Seas (1958)

To be identified Adopt, or cooperate with other States in adopting, measures necessary for the conservation of the living resources of the high seas.

Convention for the Protection and Development of the Marine Environment of the Wider Caribbean Area (1983) [“Cartagena Convention”]


and Development

Requires the individual or joint undertaking of appropriate measures to reduce and control pollution of the Convention Area, and ensure sound environmental management of the wider Caribbean region. It speaks specifically to taking action to reduce marine pollution from: ships, dumping of wastes at sea, land-based sources, and sea-bed activities. It also requires action on airborne pollution and biodiversity protection.

Geneva Convention on the Continental Shelf (1958)

Permanent Secretary of Ministry of Foreign and

CARICOM Affairs

Exploration or exploitation of the continental shelf must not cause unjustifiable interference with navigation, fishing or the conservation of the living resources of the sea, or with oceanographic or other scientific research.

Convention on the High Seas (1958)

Draw up regulations to prevent pollution of the seas by the discharge of oil from ships or pipelines resulting from the exploitation and exploration of the seabed and its subsoil, as well as pollution from radioactive wastes.

Convention on the Territorial Sea and Contiguous Zone (1958)

Define limits of the territorial sea and contiguous zone.




United Nations Convention on the Law of the Sea- Montego Bay (1982)

General obligations for safeguarding the marine environment and protecting freedom of scientific research on the high seas.

Legal regime for controlling mineral resource exploitation in deep seabed areas beyond national jurisdiction.

Land Management

United Nations Convention to Combat Desertification (UNCCD) (1994)


and Development

Cooperate in implementing the convention at all levels particularly the areas of collection, analysis and exchange of information, research, technology transfer, capacity building and awareness building, the promotion of an integrated approach in developing national strategies for combatting desertification, and assistance in ensuring that adequate financial resources are available to programmes to combat desertification and mitigate the effects of drought.

Prepare National Action Programmes (NAPs) for addressing land degradation.

Harmonise NAPs with the Convention’s 10-year strategy such that Sustainable Land Management (SLM) concepts and principles are integrated into the national development agenda, and into the public consciousness.

Report on measures undertaken to implement the NAPs and achieve the objectives of the Convention.

Forests

International Tropical Timber Agreement (2006)

Permanent Secretary of Forestry Division,

Ministry of Agriculture, Land and Fisheries

Undertake to accept and carry out the decisions of the International Tropical Timber Council and refrain from implementing measures that would have the effect of limiting or running counter to such decisions.

International Plant Protection Convention (1951)

Permanent Secretary of Ministry of Agriculture Land and Fisheries

Make provision for an official plant protection organisation for inspection, disinfection and the issuing of certificates relating to physiosanitary condition of plants and plant products.

Reports of outbreaks and existence of pests, import requirements, methods of control, to be made to the FAO.

Wetlands




Ramsar Convention on Wetlands (1971)

National Wetland Committee under Forestry Division

Work towards the wise use of all wetlands.

Designate suitable wetlands for the List of Wetlands of International Importance (the “Ramsar List”) and ensure their effective management.

Cooperate internationally on transboundary wetlands, shared wetland systems and shared species.

Ozone Depleting Substances

Vienna Convention Protection of the Ozone Layer (1985)

National Ozone Unit, Environmental Policy

and Planning Division, Ministry of Planning and

Development

Cooperate in research concerning substances and processes that modify the ozone layer on human health and environmental effects of such modifications, on alternative substances and technologies and in the systematic observation of the state of the ozone layer.

Cooperate in controlling activities that cause adverse effects through modification of the ozone layer, and, particularly, in the development of protocols for such purposes.

Exchange scientific, technical, socio-economic, commercial and legal information relevant to the Convention, and cooperate in the development and transfer of technology and knowledge.

Montreal Protocol on Substances that Deplete the Ozone Layer (1987) to the Vienna Convention

Permanent Secretary of Ministry of Planning and

Development

Implement a Phase out Schedule for Ozone Depleting Substances (ODS), with the complete phase out of Hydrochlorofluorocarbons (HCFCs) by 2030.

Greenhouse Gases

Paris Climate Change Agreement (2016)


Development

Establish binding commitments to make Nationally Determined Contributions (NDCs), and to pursue domestic measures aimed at achieving them.

Regularly report on emissions and the progress made in implementing and achieving NDCs, and undergo international review.

Submit new NDCs every 5 years, with the clear expectation that they will be more ambitious than the previous submission.




United Nations Framework Convention on Climate Change (UNFCCC) (1994)


Development

Develop an inventory of greenhouse gas emissions.

Develop a Programme of Action containing measures to mitigate the effects of climate change.

Promote and cooperate in the development, application and diffusion of technologies.

Promote sustainable management.

Cooperate in preparing for adaptation to the impacts of climate change.

Employ appropriate methods to minimise adverse effects.

Promote and cooperate in scientific, technological, technical, socio-economic and other research.

Promote and cooperate in the full, open and prompt exchange of relevant scientific, technological, technical, socio-economic and legal information.

Promote and cooperate in education, training and public awareness.

Kyoto Protocol (2005) Permanent Secretary of Ministry of Planning and

Development

Monitor actual emissions and keep records of any trades - Create a Registry System that tracks and records transactions under the mechanisms of the Kyoto Protocol.

Reporting via the submission of annual emission inventories and national reports.

Formulate cost-effective national programmes to improve the quality of local emission factors, activity data and/or models which reflect the socio-economic conditions for the preparation and periodic updating of national inventories of anthropogenic emissions by sources and removals by sinks of greenhouse gases.

Formulate, implement, publish and regularly update national programmes containing measures to mitigate climate change and measures to facilitate adequate adaptation to climate change.




Hazardous Waste

Basel Convention on the Control of Transboundary Movement of Hazardous Wastes and their Disposal (1992)

Permanent Secretary of Ministry of Planning and Development

(Focal Point) Managing Director of

the Environmental Management Authority (Competent Authority)

Prohibit the export or import of hazardous and other wastes in or out of a State which is not Party to the Convention, unless a bilateral, multilateral or regional agreement for the movement of waste is made between Parties and Non-parties.

Prohibit the export of hazardous and other wastes if the State of Import does not consent in writing to the specific import.

Ensure that information on the effects of a proposed transboundary movement on human health and the environment is clearly stated and provided to the States concerned.

Limit the generation of hazardous and other wastes to a minimum, taking into the into account social, technological and economic aspects.

Ensure necessary steps are taken by persons involved in the management of hazardous and other wastes to prevent pollution, if such pollution occurs, ensure the necessary steps are taken to reduce the consequences thereof for human health and the environment.

Limit the transboundary movement of hazardous and other wastes to minimum consistent with the environmentally safe and efficient management of such wastes, and ensure any planned movements of wastes will have no adverse effect on human health and environment.

Prevent the import of hazardous and other wastes if believed that the waste will not be managed in an environmentally safe manner.

Report any accidents which have occurred.

Submit yearly reports.

Ensure that hazardous and other wastes subject to a transboundary movement are packaged, labelled, and transported in conformity with generally accepted and recognized international rules and standards and recognized practices in the field of packaging, labelling, and transport.




Hazardous Substances and Spills

Oil Spills Protocol (1983) to the Cartagena Convention

Director of the Institute of Marine Affairs

Undertake to exchange information regarding competent national authorities for combating pollution and on laws, institutions and procedures aimed at combating marine pollution by oil.

Take appropriate measures to combat pollution, inform other States of the measures taken or intended, assess the nature and extent of the marine emergency and determine the necessary and appropriate action to be taken.

Protocol Concerning Pollution from Land Based Sources and Activities (1999) to the Cartagena Convention

Director of the Institute of Marine Affairs

Adopt measures with a view to preventing, reducing and controlling pollution from land-based sources and activities, through the development and implementation of national and/or sub regional or regional plans and programmes.

Monitor and assess the effectiveness of the measures taken to implement the Protocol, develop environmental impact assessments, develop information systems and networks for the exchange of information, and consult each other when pollution from land-based sources and activities originating from any Party is likely to affect adversely the coastal or marine environment of one or more other Party.

Submit reports containing information on measures adopted, results obtained and any difficulties experienced in the implementation of this Protocol.

Lome IV Convention Control of Hazardous Wastes (1989)

To be identified Prohibit all direct or indirect export and import of hazardous and radioactive waste.

Provide technical information on pesticides and other chemical products, with a view to helping develop or reinforce suitable and safe use of these products.




Stockholm Convention on Persistent Organic Pollutants (2004)


Development

Article 15 requires Parties to report on measures taken to implement provisions of the measures and the effectiveness of those measures (schedule of reporting).

Article 3 requires that each Party take legal and administrative measures necessary to restrict the production and use of the chemicals listed in Annex B.

Article 4 sets up a register of specific exemptions. The only exemption invoked by T&T relates to the importation of Mirex-S, when this is de-registered, this exemption will no longer be used by T&T.

Article 5 requires Parties to undertake measures to reduce or eliminate the releases of POPs from unintentional production.

Article 6 requires that Parties take appropriate measures to ensure that POPs materials are handled, collected, transported and stored in an environmentally sound manner; and disposed of in such a way that the POPs Content is destroyed or irreversibly transformed

Article 9 requires each Party to facilitate or undertake the exchange of information with the Secretariat and other Parties.

Article 10 seeks to encourage education and public awareness.

Article 16 requires a periodic review of the Convention to ensure its effectiveness.

Rotterdam Convention for Certain Hazardous Chemicals and Pesticides in International Trade (1998)


Development

Notification of regulatory actions taken to ban or severely restrict a chemical.

Summaries of proposals of severely hazardous pesticide formulations.

Export notifications.

Information to accompany export (labelling, safety data sheets).

Sustainable Development

United Nations 2030 Agenda for Sustainable Development (2015)


Development and UNDP TT

Develop ambitious national responses to the overall implementation of the Agenda.

Conduct regular and inclusive reviews of progress at the national and subnational levels which are country-led and country driven.

National Environmental Policy 55

ANNEX Ii: ENVIRONMENTAL POLICIES (TRINIDAD AND TOBAGO)

FINAL POLICIES

National Waste Recycling Policy (2015)

National Policy and Programmes on Wetland Conservation for Trinidad and Tobago (2002)

National Forest Policy (2011)

National Protected Areas Policy (2011)

National Climate Change Policy (2011)

National Policy on Imported Used Goods (2015) National Wildlife Policy (2013)

National Tourism Policy (2010)

Northern Range Hillside Development Policy

National Integrated Water Resources Management Policy (2005)

Municipal Waste Policy (2008)

Green Government Policy (2011)

National Minerals Policy White Paper (2015)

Yachting Policy (2016 – 2021)

Integrated Solid Waste/Resource Management Policy (2012)

DRAFT POLICIES

Integrated Coastal Zone Management (ICZM) Policy (Draft)

Ecotourism Policy (Draft)

Renewable Energy Policy (Draft)

Green Enterprise Development Policy for Micro And Small Enterprises And Cooperatives (Draft)

Comprehensive Disaster Management Policy (Framework) (Draft)

Critical Facilities Protection Policy Framework for Trinidad and Tobago (2010) (Draft)

Hazard Mitigation Policy (Draft)

National Relief Policy (Draft)

Shelter Management Policy (2012) (Draft)

Volunteer Policy (Draft)


ANNEX III: FRAMEWORK FOR THE NEP ACTION PLAN

It is envisioned that the NEP Action Plan will consist of two major parts:

i. Strategic Approach ii. Implementation Plan

STRATEGIC APPROACH

This part of the NEP Action Plan will comprise the following:

1) Identification of Stakeholders & Donor Entities

a) For each priority area of the NEP a list of potential stakeholders will be identified based

on their interest, rights, or responsibility in that area.

b) For each Priority Area of the NEP a list of potential domestic, bi-lateral or multi-lateral funding sources will be identified.

2) Strategic Focus of the Action Plan a) This section of the NEP Action Plan will identify the specific policy statements of the NEP

that require priority focus in the short term, medium term and long term.

b) The prioritisation of policy statements will be done in consideration of: i. Discrete timeframes stated in the NEP for achievement of policy statement; ii. Potential to create an enabling context for achievement of future policy statements; iii. Alignment with objectives of the GoRTT’s national development strategy for the

period in which the NEP Action Plan is developed; iv. Environmental, social and economic issues identified as requiring critical attention

through national surveys/consultation; and v. Potential to achieve obligations to any regional/ international agreements to which

Trinidad and Tobago is a part.

c) The selection of focus areas will be determined by the EMA under the oversight of the NCSD.

IMPLEMENTATION PLAN The development of this portion of the NEP Action Plan requires extensive stakeholder collaboration. This part of the NEP Action plan will contain, at a minimum, the following:

1) Strategic Actions

a) Potential actions may be drawn from:

i. Consultation with stakeholders who have an interest, responsibility or technical expertise in the focus area;

ii. Identification of actions listed as priority in the Government’s national development strategy for the period in which the Action Plan is being developed;


iii. The outputs of national studies, consultations and surveys related to environmental management and sustainable development.

b) Working groups, comprised of stakeholders from the public, private and non-governmental sectors, will be established to determine, implement and monitor actions towards strategically identified policy statements.

c) Strategic actions towards the achievement of the policy statements of the NEP Action Plan will be determined in consideration of:

i. An evaluation of the likelihood of success using a “Theory of Change” (ToC) approach;

ii. Alignment with sectoral and national implementation plans; iii. Alignment with national and supra-national target; and iv. Linkages with other policy statements contained within the NEP.

2) Resource Needs

a) This section will identify the various inputs required to undertake each determined

action. As far as possible, cost for conducting actions will be estimated.

3) Financial Support Plan a) Sources of financial support will be identified.

b) Responsible entity/entities for pursuing this support will be identified.

4) Leading and Supporting Entity/Entities

a) A lead entity will be identified as having the primary responsibility for executing the

selected action. This entity will also have the responsibility of monitoring and reporting the progress of the action to the EMA.

b) The lead entity will be determined by considering: i. Legislative mandate granting responsibility for the undertaking of such tasks; ii. In the absence of legislated mandate, the technical capacity to undertake the

tasks.

c) Entities which may provide technical support, data, human resources, or inputs necessary as ‘needs’ etc. will also be identified as supporting entities.

5) Outputs and Targets a) Direct outputs from the actions will be identified along with estimated timeframes for the

achievement of these outputs.

6) Indicators of Success a) Indicators will be developed to reflect the outcome of the direct outputs.

b) Indicators selected will be:

i. Specific, measurable, achievable, realistic and time-bound.


ii. Aligned with nationally determined indicators for monitoring the environment and development as far as practicably possible.

c) The entity/entities responsible for monitoring these indicators will also be identified.

7) Monitoring and Evaluation Schedule a) Monitoring will be done throughout the project in accordance with the National

Monitoring and Evaluation Policy of Trinidad and Tobago to ensure that potential barriers are addressed in a timely manner.

b) Lead agencies will be required to keep track of the progress of the actions for which they are responsible and report to the EMA/ working groups established for implementation.

c) Post-deliverable evaluation will be done by comparing the status of indicators. This section will contain a schedule for conducting this evaluation.

d) Evaluation will also entail the updating of the ToC model at the mid-term and end of the NEP Action Plan. These reconstructed models will show changes in the assumptions and drivers over time – enabling effective decision-making regarding implementation and future iterations of the NEP Action Plans.

8) Risk Assessment and Management a) This section will identify, for each strategic action, perceived risks to the success of the

strategic action. These risks may include, but are not limited to: critical assumptions, conditional resources, or potential changes to the social or economic dimensions surrounding the action that may delay or halt progress.

b) This section will also contain a description of measures that will be taken to minimise risks to the successful achievement of strategic actions.


ANNEX IV: THE SUSTAINABLE DEVELOPMENT GOALS

United Nations Sustainable Development Goals10

10 United Nations, (2017). Sustainable Development Goals. Retrieved on 10 August, 2017 from: .http://www.un.org/sustainabledevelopment/sustainable-development-goals/

http://www.un.org/sustainabledevelopment/sustainable-development-goals/

ATTACHMENT 7 – RESPONSE TO PUBLIC COMMENTS AND BASIS OF FINAL ACTION

Comment Approach Rationale/Response

Good strides. Could go a bit further in advocating socio-economic requirements, aligned with environmental regulations. E.g. 20% local labour content - from the community that would be directly impacted by companies drilling within 50 miles from the nearest coastline. If an energy company would be drilling exploration wells, it may have a regulatory EMA requirement to complete public consultations as part of the CEC process in Guayaguyare. Therefore, the company should be required to also employ 20% of its labour workforce by residents of Guayaguayare. This should be the same for other communities - La Brea, Point Lisas, Point Fortin etc. There are direct and indirect benefits to integrating this socio-economic policy, which would result in fewer roadblocks / protests, and greater community development.

Add to the Priority Area 4 the following: The revitalized economy will generate economic prosperity across Trinidad and Tobago, but especially in communities where income is generated through the direct or facilitated use of the environment. Whereas government’s actions will create the enabling environment for economic transformation, the private sector will be the innovators and leaders for creating socially-just and environmentally responsible employment opportunities. The GORTT will: g) Ensure multi-national corporations operating in rural and/or coastal communities exercise corporate-social responsibility through: a. The provision of employment opportunities for suitably qualified members of the community; b. The provision of training, internship or mentoring opportunities aimed at improving the skills and qualifications of members of the community for future employment or entrepreneurship; h) Support entrepreneurial efforts aimed to address environmental issues, or foster economic prosperity in an environmentally responsible manner.

The NEP cannot be so prescriptive as to define a specific percentage of community members that a company must employ. Communities may have varying degrees of suitably qualified persons to employ and prescribing a rigid percentile may be impractical. Ultimately, employment opportunities created should not be restricted to basic manual labour but enable sustained economic prosperity. Note as well that the current "Local Content and Local Participation Policy and Framework" provides guidance to ensure that all energy projects include opportunities for the envelopment the expertise of nationals and the maximization of the level of local content and local participation.


I mostly interested in the noise pollution act... You see the street that I resided is in close proximity of the road. I have notice that your policy mention hardly any thing about noise pollution done by neighbours and parked motor vehicle...My problem is:in my area these neighbours would play there music as loud as a carnival truck for hours upon hours..or let their friends play their music from there vehicle...Sometimes this annoyance would go into the wee hours of the morning. When I go try to tell them to turn it down,they would "cuss up meh ass" as we trini would say.If you call the police,it's either they don't have a vehicle or when they do come by these idiots would turn down the music and pretend they were not playing loud and as soon the police leave it's up again. Do you know wats it's like to be asleep and during the course of the around 9-10 pm you are awaken by LOUD music continuing until morning....When the weekend is here,from Friday straight until Sunday night is loud music after loud music.There are people who are ill,there are people who have babies from birth to 4/5 year old,there are people who got business,there are people who just simply want peace and quiet to relax after a long stressful day at work,old and young people who cannot voice their frustration because of the crime situation.I am positively sure this problem occurs throughout Trinidad and people are afraid to speak up..I am sure you all can come up with some type of law that protect we the citizens..

Feedback noted. However, no modification to the text will be made since the feedback is better suited for consideration during the preparation of the NEP Action Plan.

The crux of this comment is covered under Section 2.03(a) which reads "a) Amend existing legislation or develop new legislation and standards, as necessary, to ensure that all sources and types of noise are appropriately managed to minimise nuisance, and danger to the health and welfare of sensitive receptors". Through the development of the Action Plan to address noise, specific measures will be assessed and incorporated. The suggestions of this comment - better enforcement by police, public education, campaigns specific to noisy vehicles - will be considered by the action plan. Note that the NEP Action plan will be executed by a range of stakeholders. In the case of addressing noise, by multiple stakeholders who share responsibility over noise pollution management including but not limited to the Trinidad and Tobago policy service, regional corporations and private sector entities.

It is a great initiative and we do hope the Policy is approved and passed.

Feedback noted. However, no modification to the text will be made since comment does not highlight an area in need of improvement.

General Comment.


Dear EMA, It is encouraging to see GoRTT producing this policy document and I hope that it will be followed with the enthusiasm, resources and commitment required for a successful 3-pillar sustainable future for T&T. There is much to be done and no time to waste as you will need to prove your credibility by walking the walk. I read a lot of lip service in this report and see a completely different reality, with so many examples where these sustainability principles should have already been urgently deployed. What specific sustainability targets are GoRTT setting (besides Paris) ? You should lead by example, by setting about improving the sustainability credentials of the GoRTT estate – all assets, buildings, transport, land, people etc I like the concept of a National Environmental Code – this will require much field research in order to establish baselines and set realistic targets over a suitable timetable.

Feedback noted. However, no modification to the text will be made since comment does not highlightan area in need of improvement.

General comments consisting of endorsements, suggestions and questions. Regarding the suggestion of 'leading by example', the NEP speaks to this under Section 2.13 which says "It is Government’s policy that all its buildings and development projects will minimise as far as practicably possible, its carbon and ecological footprint". Regarding the suggestion of engineering institutions taking the lead on the NEIMS, this will be considered in the production of the NEP Action Plan. Regarding questions: "What sustainability targets are the government setting (besides Paris)?" - Targets, as well as a monitoring and evaluation framework for the UN SDGs, are being developed by the GORTT concurrent with the development of this policy. At this tiem, it is premature for the NEP to incorporate targets that have not already received Cabinet approval. "When will you quantify the resources and mechanisms which GoRTT is committing and over what period? What other funding streams have been secured? Presumably deferred to the NEP Action Plan?" - Yes, these will be detailed in the NEP Action Plan as described in Annex III "There are lots of good intentions in this framework, most of which are expected in a


decent environmental policy document. Presumably most of it was borrowed?" - No, this policy is unique to Trinidad and Tobago.

What specific sustainability targets are GoRTT setting (besides Paris) ?


No, this policy framework is unique to Trinidad and Tobago. The content of this document was derived from an extremely robust consultation process with the public and other stakeholders. The formulation of this policy would have also benefited from a Gap Analysis and Literature Review that included national reports and foreign policies.


I also like the proposal for a National Environmental Information Management System – perhaps the engineering institutions can own this.


When will you quantify the resources and mechanisms which GoRTT is committing and over what period? What other funding streams have been secured? Presumably deferred to the NEP Action Plan?


There are lots of good intentions in this framework, most of which are expected in a decent environmental policy document. Presumably most of it was borrowed?



Light Pollution is not addressed in this draft. Light pollution can compromise health and damage eco systems. It disrupts circadian rhythm in humans and migratory patterns of birds, among many other impacts. Of particular concern is light pollution along sensitive coastal areas that can affect nesting turtles. Light pollution can be combatted by using proper shielding on exterior lighting (including streetlights). This would allow lower wattage bulbs to be used resulting in significant energy cost savings over time– this means that reducing light pollution pays for itself and results in net savings over time. Please refer to the International Dark-Sky Association (darksky.org) for more information, or contact the Caribbean Institute of Astronomy.

Insert a New Section Under Priority Area 1, "Section 2.05 - Light Pollution" and include the following: Photopollution is caused by the inappropriate, or excessive, use of artificial light for lighting or advertising in the night environment. The GoRTT recognizes that the inefficient use of artificial light negatively impacts for local amenity, the national carbon footprint, intrinsically dark landscapes and nature conservation. It is government’s policy that sky glow, light trespass, light clutter, over-lighting and glare from outdoor sources of artificial light will be judiciously managed. To this end, the GoRTT will: a) Amend existing legislation or develop new legislation and standards, as necessary, to ensure that all sources and types of artificial light are appropriately managed to minimise nuisance, aesthetic impact, and danger to the health and welfare of sensitive receptors; b) Ensure, through existing environmental/planning legislation and processes, that development involving outdoor lighting schemes: a. Uses the minimum amount of lighting required for security or work purposes; b. Minimizes light spillage and glare, particularly in areas of open countryside or on the edge of settlements. c. Minimizes impact to local amenity, road

Light Pollution was unintentionally overlooked in the development of the draft NEP. Light Pollution or photopollution comprises of several facets, including: sky glow, light trespass, light clutter, over-lighting and glare. There is no existing national policy on light pollution, however, some regulatory tools may be used to regulate light pollution. Insertion of a new section would enable national management of outdoor lighting, inclusive of light-emitting screens for advertising.


safety or to sites of conservation value. c) Retrofit all public outdoor lighting fixtures (including street lights) with appropriate shields and energy efficient bulbs. d) Empower government entities to better undertake their mandates with respect to the control of light pollution from artificial sources by way of enhanced technical, financial and human-resource capacity development; e) Encourage the responsible management of artificial light from all sources through education and awareness programmes with an emphasis on sources neighbouring sensitive communities and environmental receptors; f) Develop incentive and disincentive programmes towards the responsible management of artificial light with an emphasis on sources neighbouring intrinsically dark landscapes, or environmentally sensitive areas.


I just want to submit an issue regarding the light pollution in Trinidad and Tobago because as a person who does astronomy this affects us and also is every harmful to our bodies thank you

Light Pollution will now be addressed under a new Section 2.05, "Light Pollution".


In the "Priority 1: Protecting Environmental and Human Health through Pollution Control" section; I noticed a lack of attention given to "Light Pollution". While it is understandable that in our current social climate with the presence of crime, addressing light pollution can be tricky, it should not be left out. Excessive light pollution has many negative effects on humans and various animal species. It is also a large source of energy wastage. Light pollution control does not have to result in less lighting but rather more efficient lighting so that energy as well as the environment can be protected.



I will submit my comments on a separate document. Feedback noted. However, no modification to the text will be made since comment does not highlightan area in need of improvement.

General Comment


General – This is a great document overall, well done to the team that created it. Please accept my comments as constructive input. I hope it is given the teeth it deserves and does not just end up being an academic exercise. Great work! 1.04 Vision should include a statement that environmental protection is part of our legislation and a priority to the government thought processes and legislative and executive agenda. While this is covered in other parts of the document, it should feature in the vision. 1.05 Good Governance – Good governance also relies on the appropriate organizational structures being setup (e.g. A Ministry of the Environment), and measurements and targets that are binding (for all of government). Good governance should also drive alignment, the environment cannot be a silo that is opposed to the other directions of government (economic, legal, resources etc) 2.04 Recycling, Recovery and Reuse – (j) Glad to see the use of market-based mechanisms. I think this should be a heading on its own (maybe this is what 2.17 is about?). Alignment of environmental interests with economic interests would provide the largest driver for environmental sustainability (in my opinion). Closed cycle markets for waste should be a policy of the government (e.g. Plastic Market). This would drive market forces to collect and reuse waste. Collectors could then sell ‘credits’ to polluters creating a closed cycle.

Suggestion for: 1.04 (Vision) - No amendment made. 1.05 (Good Governance) - Insert "It necessitates that appropriate institutions, institutional relationships and common targets are established and supported." before "In the pursuit of good governance,..." 2.04(j) - No amendment made. 2.22 (Renewable Energy/ Energy Efficiency) - No amendment made 3.01 (Data Collection) - No Amendment made

1.04 (Vision). A vision, as an aspirational target is meant to capture our ideal situation. The current vision states "We foresee a future where all stakeholders from individual citizens to political and non-political, formal and informal groups are actively involved in the management of their national and local environments based on strong environmental ethics". Note here, that we aspire to be a country in which persons protect and manage the environment based on personal ethos instead of doing so because it is the law. 1.05 (Good Governance) - Governance refers to the process of decision-making and the process of decision implementation. As such, the suggested idea should be incorporated into the text. Note that with respect to institutional relationships and the 'breaking of silos', the NEP provides defined policy statements in Section 3.01 "Critical Success Factors". 2.04(j) - The fleshing out of the appropriate market-based mechanisms for solid waste will be determined during the creation of the NEP Action Plan. 2.22 (Renewable Energy and Renewable Energy) - Previous iterations of the draft NEP had these two issues as stand-alone Sections under Priority Area 3 (Improving the Local Environment). This separation of RE/EE and


2.05 Water Resources - (h) Completely support the use of Rainwater Harvesting, great inclusion! 2.22 I think electricity generation should not be buried in this section. I think it should be a section on its own as it is a significant part the environmental footprint. There should be a more aggressive approach to introducing renewables. This should be aligned to saving Natural Gas for export or downstream uses. 3.01 Improving national environmental data / information management – Transparency of collected information (to the public) is important to keep the government accountable and honest. Please feel free to contact me if you have any questions about my comments – [email protected]

Climate Change across two Priority Areas was criticised as being 'scattered' and enabling redundancy. It was agreed that two topics be harmonized for cohesive reading. The RE Target of 10% by 2021 was set by the government, and thus must be used in the NEP. This number cannot be adjusted without greater public stakeholder and government approval. 3.01 (Data Collection) - It is agreed that data collected must be made transparent to the public. This Section deals with the data management infrastructure side of the equation. Transparency and Access to information is already addressed under Section 2.18.


23rd November, 2017 Comment on the August 2017 draft of the National Environmental Policy by Cathal Healy-Singh (Environmental Engineer) Fossil Energy and the National Environmental Policy (NEP) The Environmental Management Authority of Trinidad and Tobago has prepared the final draft of the 2017 National Environmental Policy (NEP). This is the 3rd iteration of national policy development. The first NEP was published in 1998 according to Section 18 of the Environmental Management Act (1995). The time had apparently finally come for environmental management to be more meaningfully integrated into national development strategy. Environmental concerns were going to have a more central place in the national decision making process. Among other concerns, the 1998 NEP recognized that T&T suffered from environmental problems associated with production of petroleum products, nitrogen, ammonia, urea and fertilizer in addition to rum, paint and wood products, and acknowledged that resource exploitation had been characterized by the search for short-term economic gain with little attention paid to long-term sustainability. The benefits and costs of resource use and environmental conservation were going to be shared fairly among different communities, between the affluent and the poor. Development was to be “conservation-based”. Renewable resources like soil, wild and domesticated organisms, forests, agricultural lands and marine and freshwater ecosystems were to be used sustainably. Non-renewable

Replace Section 2.11(a) with: a) Encourage educational institutions, non-governmental organisations and private sector entities to engage in research into the true cost of mineral and hydrocarbon exploitation for the purposes of selecting ventures that are most socially, environmentally and economically sustainable; b) Utilise Environmental Impact Assessments (EIAs) and cost-benefit analysis to: i. Inform the decision-making process regarding projects that may have significant environmental impacts or where there is great uncertainty regarding potential impacts; and ii. Inform mitigation measures for projects that receive approval.

The government of the Republic of Trinidad and Tobago is committed to the sustainable use of its mineral and hydrocarbon resources for the economic growth of the country. Section 2.04 notes that "It is government's policy to mainstream the minimization of waste and practice of recycling, recovery and reuse into the culture of Trinidad and Tobago". Given that recycling is only one method of deriving value from waste products and that all waste may not be of a quality to be recycled, the adoption of a policy for 'all' waste to be recycled is considered to be impractical. The GORTT encourages research and private sector institutions to undertake this type of assessment to guide future energy sector ventures. The Environmental Impact Assessment process, by nature, can be used to account for the environmental and social cost of mineral and hydrocarbon resources. In Trinidad and Tobago, the EIA process is tied to the CEC process and as such, can be used to halt unsustainable projects as well as mitigate the impact of approved projects.


resources like oil, gas and minerals were to be conserved and optimally used to obtain the best possible benefits to all citizens and without impairing the value of other resources. With regards mineral resources the 1998 NEP sought to establish and enforce standards for the methods and rates of extraction, including rehabilitation of mined areas. Wastage of oil and gas was to be discouraged. The 1998 NEP also contained an ‘energy clause’ encouraging the use of energy recovery and “environmentally friendly” energy sources such as natural gas. Regular inventories of Greenhouse gases such as carbon dioxide, nitrous oxide and methane were to be conducted. By 2006, the 2nd iteration of environmental policy recognized that development of the petroleum and petrochemical sector has expanded to the extent that Trinidad and Tobago was then the largest supplier of LNG to the United States and the number one exporter of ammonia in the world. These developments had given the country global recognition and attention. The Government was therefore “duty bound” to ensure that Trinidad and Tobago found the right balance between economic development and environmental conservation. The 2006 NEP also contained an energy clause this time more specific. It acknowledged direct macro-economic implications to the country in the form of over-dependence on the exploitation of scarce fossil energy resources, with market regimes outside the influence of the Trinidad & Tobago Energy System. These could lead to reduced energy security for Trinidad & Tobago. Government would


support initiatives to assess the true costs of exploiting fossil energy resources and develop strategies for accounting for these costs in its decision-making process by “providing the required political, administrative and technical support to enable a systematic assessment of the external costs and benefits of exploiting fossil energy resources, including the comparison of costs associated with the various uses to which these energies are applied (e.g. direct export as LNG, petrochemicals processing, electricity generation)”. These assessments were to be used to determine those uses that contribute to development that is economically, socially and environmentally sustainable. Another initiative was to strengthen existent, or develop and implement appropriate, institutional and regulatory regimes to support exploitation of the primary energy resources for sustainable development, and to pursue research to develop a framework to support Full Cost Accounting Practices that will support the establishment of fees/funding consistent with the Polluter Pays Principle In 2017, the NEP went through a 3rd iteration. It was crafted by local consultants who enjoy the lion’s share of contracts seeking environmental clearance certification on behalf of developers. Their February draft put out for public consultation contained no energy clause despite mentioning “energy” 98 times. It is a glossy document very different from the first two, full of colour pictures. At a public consultation I questioned why the energy clause was dropped and urged that it be included, especially the policy commitment to “provide the required political, administrative and technical support to enable a systematic assessment of


the external costs and benefits of exploiting fossil energy resources, including the comparison of costs associated with the various uses to which these energies are applied (e.g. direct export as LNG, petrochemicals processing, electricity generation). These assessments were to be used to determine those uses that contribute to development that is economically, socially and environmentally sustainable”. I was assured that the policy “belonged to the people” and my comment would be taken into consideration. The August 2017 version of the NEP includes all public comments and inputs from “specialists” and distinguished persons, as well as EMA staff. The number of times “energy” was mentioned reduced to 62. In a section called “Mineral and Hydrocarbon Resources” the latest version of our NEP is to “utilize Environmental Impact Assessments (EIAs) and cost-benefit analysis to inform the approval, and/or mitigation measures required of projects that may have significant environmental impacts or where there is great uncertainty regarding potential impacts and to ensure that all stakeholders likely to be impacted by the exploitation of minerals and hydrocarbon resources have meaningful participation in the process of developing social and environmental safeguards.” It is my considered opinion that the EMA and their distinguished advisers are heading in the wrong direction with regards to the environmental implications of finite energy exploitation.


What is the basis for abandoning strategies and systematic assessments to account for the true costs associated with exploiting fossil resources? I strongly urge the wording of the 2006 NEP to be retained (as quoted above). What is presented in the August 2017 version of the NEP is a watering down of the 2006 NEP with regards to the social and ecological implications of using fossil fuels. This does not seem like a striking a balance between conservation and exploitation. Furthermore, although the 2006 Policy has never been followed with regards fossil exploitation, what the 2017 policy will do is make sure there will never be a national appreciation far less consideration of the true cost of fossil exploitation. Finally, the most recent national environmental literacy rates have been published by the EMA. Alarmingly, only 2% of the national population is aware that a National Environmental Policy exists. If the policy is weakened and the population becomes aware of this in the face of mounting problems and diminishing oil/gas supplies I predict awareness will drop even lower because of apathy and a lack of confidence in the wisdom and indeed autonomy of the EMA. END


-Need for reforestation of wetlands to help secure fish populations, and aid in purifying run-off water.-Reforestation of hilly areas to aid with land retention and flood prevention (vetiver grass).-Make use of reforestation to aid in Water Resource Management.-National Recycling Policy should insist that all waste must be recycled when possible.-Increase in the manpower of the EMA to carryout the new NEP.-Will there be any restructuring of the EMA to help fulfil the mandates within the NEP?-For the Convention on Fishing and Conservation of the Living Resources of the High Seas (1958), the Focal Point might be the Institute of Marine Affairs (IMA).-Perhaps a Ministry of the Environment should be considered as the body with responsibility of all the treaties and conventions, to allow for easier flow of information and oversight.

Insert in Section 2.06 (Soil/Land Management) the following:e) Continue efforts to prevent soil loss through the development and implementation of programs to afforest, reforest, or otherwise re-vegetate slopes vulnerable to erosion.

The NEP is intended to provide a broad framework for actions to be developed rather than propose specific actions which may or may not be suitable as time goes on. Reforestation is a specific cross cutting response that can address many of the topics/sections of the document such as water pollution, water recharge, soil management, biodiversity loss and carbon sequestration. It was anticipated that reforestation would be adopted as a specific measure in the NEP Action Plan under policy actions such as: 2.05(g) "g) Protect and restore water-related ecosystems, including mountains, forests, wetlands, rivers, aquifers and lakes;" 2.07(d) "Continue the conservation of biodiversity through the development and implementation of programmes to address drivers of biodiversity loss including, but not limited to: deforestation, fires, erosion, illegal development activity, illegal exotic pet trade, invasive species and over-hunting;" or 2.22(c) "c) Conserve and enhance natural ecosystems that serve as sinks or reservoirs of GHGs such as forests, coastal and marine wetland ecosystems." An additional point on reforestation and afforestation would be added to Section 2.06The NEP cannot re-write what is contained in the National Waste Recycling Policy. Section 2.04 notes "it is Government’s policy to mainstream the minimisation of waste and practice of recycling, recovery and reuse


into the culture of Trinidad and Tobago. " Recycling is only one means of gaining value from waste; others include reuse or waste-to-energy. While the government supports recycling it does not want to limit it's value-adding options strictly to recycling. As such, it cannot strictly advocate that "all" waste be recycled. The empowerment of the EMA to see this NEP through is covered under the Chapter on Critical Success Factors, specifically policy actions 3.01(a) and 3.01(b). These actions provide the broad framework for action, and specific measures will be determined during the formulation of the NEP Action Plan in consultation with relevant stakeholders.


Noise pollution needs to receive greater attention. Trinidad and Tobago have devolved into a situation where the noise pollution is so common that people are oblivious as to how bad it is. I was disappointed to see only a mere paragraph dedicated to noise pollution in the NEP. I had hoped by now, that greater recognition was had for the seriousness of the problem. I noticed that the NEP talked about different zones. However, treating with noise pollution in zones is not realistic. There is no area in the country that can be fully classified as totally commercial or residential. Businesses are always surrounded by residential properties. Legislation needs to be better written with more severe penalties. The use of a decibel measure is simply not a good enough system. No person should be allowed to play music that can be heard beyond the extent of their personal property; this includes businesses, homes or cars. It is a matter of them not having the right to encroach on another person’s personal property. We would not allow someone to store their belongings on another’s property, and sound waves or noise is no different. Why allow it to trespass into another person’s personal property. The policing of noise pollution also needs to be taken away from the police and put into the hands of the EMA totally. A large part of the problem is that the police are unwilling to treat with noise pollution seriously. It is not realistic to wait on them to get themselves in order to deal with this problem. Therefore, in order to address the situation in a timely manner, the police need to be removed from the


It is recognised that noise pollution is a serious problem nationally. The first iteration of the NEP Action Plan will make as it's number 1 priority, the addressing of noise pollution. The policy actions proposed in Section 2.03 cover the spectrum of potential responses including but not limited to legislative review, technological intervention, market-based mechanisms and education. The reference to 'zones' in the NEP applies not only to spatial zones, but temporal (time bound) zones as well. The management of noise levels relative to time of day is a well established and important technique used throughout the world.


equation and the monitoring and penalties should be implemented by a group where there is more direct management. The approach so far to noise pollution has been too soft; warnings are simply not enough. The perpetrators are always fully aware of their actions, they just do not care. Severe penalties must be applied to dissuade people from engaging in this behaviour. The penalties need to be applied to the owners of the property. It is easier to fine the owner where the activity is taking place than to try and find a DJ who may conveniently disappear. Owners are ultimately responsible for what happens on their property, whether that property is a business, a vehicle or a private home. The current method of monitoring noise pollution is not adequate, as it relies on measuring the noise above a particular decibel level. However, it does not take into consideration that even noise that may be below the threshold can still be a nuisance if it takes place on a regular basis. Further, many instances of noise pollution cannot be predicted, so giving an estimate of when the noise pollution may occur in the future, so that the authorities can visit and take measurements, is not an effective way of dealing with the problem. A dedicated noise pollution unit needs to be formed, that can accept reports and immediately go on site to verify the report. If music can be heard beyond the premises, then a fine should be applied to the owner of that address. This fine can then be tied to the property in such a way, that if


the owner fails to pay, there is jail time attached. Educating the public through the school system is also a good idea. It is better to get them informed and conscious of their actions at a young age. I would like to suggest that the effects of loud music on hearing also be stressed. It concerns me that this is not considered by these noise makers. Even more frustrating, is the impact on those who are simply caught up in the bad actions of others. The issue with relying on education to resolve the problem is that it can only pay off in the very long term. So while it is an important part of the solution, the more stringent measures and penalties described earlier must also be implemented to change behaviour in the more immediate future.


I think the section relating to noise pollution is very wishy washy and not well thought out. In your last development policy (2005/6) you mentioned that most of the complaints to the EMA were about noise pollution. I am sure that nothing has changed since you have not made enough steps towards educating the public or moreover putting anything in place to curb the noise pollution. Complaints abound, and you respond with excuses, including lack of staff. The police are not even interested in noise pollution. This 2017 draft is less specific than the previous one and will evoke even less interest and even less of a response. May I quote the Privy Council and state you need to give the issue adequate consideration and re-draft the sections with more concrete measures to curb the noise pollution that is plaguing the entire country and disrupting the lives of people living in St James (like myself) who cannot spend one single night without listening to the noise of casinos, wedding event spaces, clubs and bars and who cannot spend a single day without the noise coming from neighbouring garages. These measures in this proposal are weak and will be ineffective. Your organization needs to do better.

Feedback noted. However, no modification to the text will be made in consideration of the detailed rationale provided to support this decision.

The emphasis that noise pollution is of great concern is noted. The first iteration of the NEP Action Plan will make as its top priority the addressing of noise pollution. It is in the NEP Action Plan where "more concrete measures" would be established. THE NEP is to provide the guiding framework. The 2006 NEP had only ONE policy measure as it relates to noise, i.e. "developing a framework for the abatement of all noise that is prejudicial to health or nuisance" and proceeded to describe what would be included that framework. This measure was achieved in the creation of the Noise Pollution Control Rules in 2001. The measures listed in the draft revised NEP are much broader and include, among others, the amendment and updating of legislation (such as the NPCR, 2001).


No Comment received.


Recycling should be made mandatory in all institutions (government offices, schools, hospitals, office buildings, and businesses) as the amount of waste (especially plastic) is tremendous. Another point is the need for more of the recycling drop off bins, there are too few of these and people don't even know they exist. You have to make recycling a law in order for people to comply as people only do what is convenient and what is enforced.

Insert "The operations of governmental agencies will be in accordance with the national Green Government Policy (2011). " after the sentence, "It is Government’s policy that all its buildings and development projects will minimise as far as practicably possible, its carbon and ecological footprint." in Section 2.13 (Green Architecture and Infrastructure).

It is the government's intention that recycling seen as a business venture driven by the private sector and market forces. Consequently, the NEP advocates that the government creates the enabling environment to facilitate growth in the recycling industry. Recycling will only be sustainable when actors (private, non-governmental) are allowed to take the lead. As such, it cannot be made 'mandatory' - at least not at this time where the infrastructure is still developing. With regards to government showing leadership in recycling and waste management, the policy statement in Section 2.13 "It is Government’s policy that all its buildings and development projects will minimise as far as practicably possible, its carbon and ecological footprint." dictates that government institutions strive to reduce waste. An additional sentence will be added for emphasis.

Regarding air quality and waste management, it is imperative that heavy advertising and campaigns be launched explaining the effects on our health.

Feedback noted. However, no modification to the text will be made since this topic/suggestion is already captured under an existing policy statement(s).

Education campaigns related to air pollution and open burning is covered under 2.02(c ) "Undertake sensitisation campaigns regarding the national policy and laws regarding open burning, and the impacts of open burning on human health and the environment". The structure of these campaigns (social media, etc.) will be determined during the formulation of the NEP Action Plan. Section 2.19 speaks specifically about education campaigns


targeting youth, and measures for monitoring the environment are proposed in Section 3.01.

Short and impactful messages via social media, and in the areas particularly known for lack of environmental concern should be targeted. Maybe a short video (for example) showing someone burning bush, and then explain that their actions are harming them (poor air quality, carcinogenic fumes), their loved ones, and their community - a healthy person is a happy and productive citizen.

Feedback noted. However, no modification to the text will be made since the feedbacdk is better suited for consideration during the preparation of the NEP Action Plan.

Proper monitoring and consequences are the only way we will learn. It's no small feat as it seems we have a culture which lacks environmental consciousness, but if possible an environmental tax should be implemented for littering and burning of bush. It's difficult to change a mindset but small movements in the right direction is all we can ask for. Focus on the youth as they will educate their parents, maybe an Environmental Warrior App which tracks our carbon footprint? of course incentives should be intertwined with teaching elements.


Our beautiful islands have so much potential to be pioneers of the Caribbean. Wouldn't it be lovely for us to be seen as an Eco tourist destination, having exchange programmes with other like-minded islands and countries sharing best practices?



Thanks for allowing us citizens an opportunity to share our thoughts and for all the work you do.



Amendment to pg 14 Ozone Depleting Substances that deplete the ozone layer continue to be used in air conditioning and refrigeration, fumigation, and foam blowing. Although Trinidad and Tobago has successfully phased out the import of some ozone depleting substances such as chlorofluorocarbons, halons and carbon tetrachloride, efforts are still required to phase out additional substances found to be damaging to the ozone layer as well as those substances used as alternatives that contribute to global warming. To this end, the GoRTT will: a) Amend or develop legislation as necessary, to give effect to Trinidad and Tobago’s obligations under MEAs related to ozone depleting substances, as well as alternatives to these substances; b) Implement a system to control the import and export of all ozone depleting substances and their alternatives; c) Develop and implement standards and guidelines as necessary, for relevant sectors that utilize ozone depleting substances, as well as alternatives to these substances;d) Ensure that all developmental activities utilize ozone friendly technologies;e) Ensure that climate and energy efficient considerations are taken into account when choosing ODS alternatives;f) Ensure that refrigerant used in air conditioning and refrigeration equipment are recovered if practical for destruction, recycling or reclamation during servicing and maintenance of equipment prior to equipment dismantling for disposal; g) Develop incentive and disincentive mechanisms towards reduction or use of ozone depleting substances and promotion of alternatives; andh) Encourage the meaningful participation of all stakeholders in the monitoring of ozone depleting substances and promotion their alternatives.

Replace 2.02 (o) through 2.02 (r ) with:o) Amend or develop legislation as necessary, to give effect to Trinidad and Tobago’s obligations under MEAs related to ozone depleting substances, as well as alternatives to these substances; p) Implement a system to control the import and export of all ozone depleting substances and their alternatives; q) Develop and implement standards and guidelines as necessary, for relevant sectors that utilize ozone depleting substances, as well as alternatives to these substances;r) Ensure that all developmental activities utilize ozone friendly technologies;s) Ensure that climate and energy efficient considerations are taken into account when choosing ODS alternatives;t) Ensure that refrigerant used in air conditioning and refrigeration equipment are recovered if practical for destruction, recycling or reclamation during servicing and maintenance of equipment prior to equipment dismantling for disposal; u) Develop incentive and disincentive mechanisms towards reduction or use of ozone depleting substances and promotion of alternatives; andv) Encourage the meaningful participation of all stakeholders in the monitoring of ozone depleting substances and promotion their alternatives.

Proposed amendments received from Dr. Marissa Gowrie, 2017 winner of the United Nations Environment Programme (UNEP) Policy and Implementation Leadership award for her work regarding O-zone Depleting substances. The list of policy actions is more comprehensive than the previous list and is consistent with the language of the document.


It's a well crafted document, however the issue of light pollution and light trespass would be a valuable inclusion.



Having a BSc in ENRM, I am pleased to see that there are changes being made toward a reduce, reuse, recycle mentality and culture. I hope that the policy can be effectively enforced and that we as a people can be a benefit to the environment as much as it is to us.


Recycling will be considered as an urgent priority in the development of the NEP Action Plan.

I think that efforts like these are long overdue and it is great that there is finally some persistent effort for this type of initiative.


The Draft Revised NEP now has included in Section 4.02 provisions for more consistent revision of both the Policy and associated NEP Action Plan.

A review of the NEP coming 10 years after its implementation is a woefully inadequate solution. There should be a review at minimum at 2 years, then at 5 years on as the policy matures. This is an age of environmental flux with major changes required for sustainability against the threat of global warming. We need to be more agile. A ten year period is kicking the can down the road hoping you won't have to pick it up.

Replace the first sentence of Section 4.02 with "To maintain relevance and cohesion with an ever-changing national and supranational context, this NEP shall be reviewed and revised as necessary, but not exceeding 10 years. "

It was previously believed that the broader social, economic and environmental context of Trinidad and Tobago would not change significantly within a decadal time frame. However, it is agreed that the room for revision should be given for shorter time frames but not exceeding 10 years. The Action Plan, which contains the more concrete and precise actions will be revised at a much shorter frequency.


enforcement of the policy must be rigorously implemented other wise these are just words.

Feedback noted. However, no modification to the text will be made since this topic/suggestion is already captured under an existing policy statement(s)

The importance of monitoring and enforcing the policy is noted. Chapter's 3 and 4 address these issues.


No Comment received.

The ideas of the draft are in fact everything we should be concerned about and how to have a better developed country. However, I often have issues with the limited amount of recycle bins placed in public areas. We keep hovering over the issue of the excessive amount of waste materials but yet, we aren't providing enough to try to solve this issue.


Recycling will be considered as an urgent priority in the development of the NEP Action Plan.

I would like the use of Styrofoam to be banned completely and the use of plastics limited. I am a secondary school teacher and maybe we can introduce recycling nationwide in schools

Feedback noted. However, no modification to the text since this topic/suggestion is already captured under an exisitng policy statement(s).

Recycling will be considered as an urgent priority in the development of the NEP Action Plan. Recommendations for a national recycling program involving schools will be made as it would be consistent with the declaration in 2.04 that "it is Government’s policy to mainstream the minimisation of waste and practice of recycling, recovery and reuse into the culture of Trinidad and Tobago". The addressing of Styrofoam and plastics is covered under action 2.04(d) "Phase-out the manufacturing and importation of synthetic, nonbiodegradable packaging material such as polystyrene and non-recyclable plastics through environmental policy instruments". Given that Styrofoam and plastics are deeply intertwined with many


facets of the local economy, a sudden ban on non-biodegradable materials may have significant unintended social and economic consequences. Thus it is believed that a gradual replacement of non-biodegradable packaging with biodegradable ones would better serve the interest of sustainable development.

Well Done! In absence of the Integrated Coastal Zone Management Policy the NEP should include an amendment to existing legislation or develop new legislation, that enforces mandatory guidelines for bathing water just as there is quality standards for drinking water since (bathing and drinking water are very much related) in order to safeguard public health and protect the aquatic environment in coastal and inland areas from pollution


The development of standards for bathing water, will be encompassed in standards for ambient water quality which may be addressed in the NEP Action Plan. The NEP provides for the development of bathing water standards under the following actions: 2.01 (d) "d) Ensure that for waters with multiple uses, the water quality criteria support the most sensitive use" 2.01 (k) "Establish ambient water quality guidelines consistent with use as well as standards and limits on concentrations of substances in point source discharges;" 2.02 (l) Ensure that for waters whose existing


quality is less than the quality specified in the established ambient water quality guidelines and standards shall be made to comply with these, wherever possible.

I believe there is much good intended by this draft NEP and there are several things i would like to comment on. However, the most pressing concern i have is the infrastructure for enforcement of these policies. As i have noted that within the revised Air pollution act and Noise pollution, there has been very little enforcement that is observable by the common citizen. Even if one were to argue that enforcement is ongoing / has been ongoing where is the evidence? Please make your plans for this issue clear to the public.


The implementation of this policy is not the sole responsibility of any one organisation, but requires effort from public, private and non-governmental actors. The process for coordination and implementation is detailed in Section 3.02. The specific actions to be taken regarding air and noise pollution will be detailed in the NEP Action Plan, which will be made publicly available - consistent with the principles of the draft revised NEP and guidance of Annex III.

Time enough Feedback noted. However, no modification to the text will be made since comment does not highlightan area in need of improvement.

General Comment. The Draft Revised NEP now has included in Section 4.02 provisions for more consistent revision of both the Policy and associated NEP Action Plan.


Nothing on reforestation Insert in Section 2.06 (Soil/Land Management) the following:e) Continue efforts to prevent soil loss through the development and implementation of programs to afforest, reforest, or otherwise re-vegetate slopes vulnerable to erosion.

The NEP is intended to provide a broad framework for actions to be developed rather than propose specific actions which may or may not be suitable as time goes on. Reforestation is a specific cross cutting response that can address many of the topics/sections of the document such as water pollution, water recharge, soil management, biodiversity loss and carbon sequestration. It was anticipated that reforestation would be adopted as a specific measure in the NEP Action Plan under policy actions such as: 2.05(g) "g) Protect and restore water-related ecosystems, including mountains, forests, wetlands, rivers, aquifers and lakes;" 2.07(d) "Continue the conservation of biodiversity through the development and implementation of programmes to address drivers of biodiversity loss including, but not limited to: deforestation, fires, erosion, illegal development activity, illegal exotic pet trade, invasive species and over-hunting;" or 2.22(c) "c) Conserve and enhance natural ecosystems that serve as sinks or reservoirs of GHGs such as forests, coastal and marine wetland ecosystems." An additional point on reforestation and afforestation would be added to Section 2.06


Didn't see anything on preventing squatting and squatting related deforestation...EMA needs to work with housing ministry to prevent and relocate squatters.... especially in areas that are in need of reforestation....


"Squatting" may encompass unplanned, unregulated, or illegal settlement. Section 2.12 addresses these issues. Specifically, the government reaffirms its commitment via action 2.12 (a) to "Take urgent action, as appropriate, to address unplanned, unregulated, and illegal settlement of state lands, particularly in areas of high environmental sensitivity, historical or cultural significance". Addressing and reversing the environmental impacts of unplanned settlement of areas of high conservation value or forested land is captured under actions 2.07 (d) "Continue the conservation of biodiversity through the development and implementation of programmes to address drivers of biodiversity loss including, but not limited to: deforestation, fires, erosion, illegal development activity, illegal exotic pet trade, invasive species and over-hunting" and 2.07 (f) "Maintain total areas of land zoned for forest reserves and prevent conversion of lands best-suited for forest to other land use types"


Updates may be required to additional policies referenced in the NEP, including the National Forest Policy and others. Storm water Management may need to be emphasized, due increased rainfall events causing tremendous amounts of flooding and overflow of water courses and low lying areas.

Replace 2.05 (h) with h) Encourage the use of advanced technology systems such as desalination, waste water reuse, storm water reuse, and rainwater harvesting to supplement fresh water demand where it is economically, technically and environmentally feasible Insert the following as 2.22 (aa) aa) Encourage the use of infrastructure designs and land use plans that include elements to address the effects of climate change such as enhanced storm water conveyance and detention capacity.

Storm Water management is a cross-cutting technique that addresses several topics/sections of the draft NEP including, but not limited to: water pollution, soil/land management, water resource management, green infrastructure and climate change mitigation. Statements will be included.


Thank you for the opportunity to comment on the draft NEP. In general, I find the document very well written, easy to understand, and accurately addressing key issues. I have some specific comments/additions that you may wish to take into consideration. Section 2.01 - The section should distinguish between measures that are applicable to freshwater, seawater, or both. It seems that most points are geared towards freshwater contamination, but seawater contamination also needs to be considered since it affects marine ecosystems and human access to seafood as well as recreational resources. Most points address water quality, what about water conservation, particularly during the dry season? Section 2.03 – Very thorough range of solid waste management measures – I like the emphasis on prevention/reduction as first steps before recycling/recovery. However, I would suggest that these are very traditional approaches, and T&T might consider taking on a more proactive and progressive approach. - A critical starting point and missing piece of information for any solid waste management plan to work is proper characterization of the solid waste streams, which has never (to my fairly sophisticated knowledge) been done. We need to understand what materials are being discarded and entering the landfills, as well as what materials are being pulled out as valuable by waste pickers in the landfills, in order to develop appropriate source reduction and management strategies. As such regular monitoring/auditing/characterization of the solid waste streams should be conducted on the islands.

Insert the following statement into Section 2.04 under the sub-header of "Recycling, Recovery and Reuse" "j) Support non-governmental organisations, private sector, and/or community-based efforts to prevent, reduce, reuse, recover, or recycle waste, including the use of waste as an energy source" Insert the following into Section 2.07: "Encourage the economic and social valuation of ecosystem services to inform conservation and ecosystem management efforts." Insert the following in Section 2.17: "g) Encouraging the growth and development of a circular economy in which waste is revalued and resources are recirculated locally as much as possible." Adjust the text of 2.22 (f) to read as: f) Mobilise resources, and seek global partnerships to secure resources, to support the implementation of the mitigation measures contained in the:

Section 2.01 - Water Pollution Section 2.01 - Water Pollution The distinction between freshwater pollution and marine pollution was deemed unnecessary as previous attempts to distinguish them resulted in redundancy in policy statements. The policy statements in section 2.01 largely apply to both freshwater and sea water systems. Water conservation, is addressed under Section 2.05. No amendments to the text is proposed. Section 2.03 - Solid and Hazardous Wastes Characterization studies of waste streams in Trinidad and Tobago have been done periodically. The most robust was the Characterization and Centroid Study of 2010, and more recently, with the on-going development of the Waste Rules under the EM Act, a study in 2015. The 2011 Assessment of the State of the Environment Report on Solid and Hazardous Waste in Trinidad and Tobago, along with other studies related to waste has formed the basis of the policy statements contained in this section. Additional studies are captured under 2.03 (g) "Support educational institutions, non-governmental organisations and private sector companies to undertake research and programmes relevant to waste management".


- Encourage opportunities for separate recovery and management of organic waste, non-hazardous industrial waste, hazardous industrial waste as well as municipal solid waste in order to identify and support business opportunities for utilizing these materials in the economy. For example, encouraging composting for example would greatly reduce the need to produce and important fossil-derived/synthetic fertilizers. - Points (j) an (k) emphasize energy recovery from waste materials, but a separate item should be added about recycling these materials into new products. Energy recovery is typically lower value than recovering the value of the materials - The important role of people who recover waste needs to be recognized, appropriately compensated and adequately protected from the dangers posed in their activities. I think you have recognized the latter in the draft policy, but not the former, which can perpetuate the marginalization of these people. - A special note should be made of planning for waste generated during floods and other natural disasters such as hurricanes, as the large volume of materials generated in the short time frame can overwhelm conventional collection and management systems. I strongly support the measures for (2.07) conservation of biodiversity, (2.08) coastal and marine management, (2.09) fisheries and (2.10) agriculture as these are important interfaces between humans and the environment. Having direct community engagement for those directly involved in these industries is critical for maintaining the integrity of these resources by providing sustainable livelihoods for

i. National Strategy for the Reduction of Carbon Emissions in Trinidad and Tobago, 2040; ii. National Climate Change Policy and other national policies related to climate change;

Government support of efforts to recapture and revalue waste will be explicitly stated as a policy statement. Items 2.03 (j) and 2.03 (k) do not emphasize waste-to-energy but rather, lists it as an option for alternative waste disposal along with recycling, and other efforts higher on the waste management hierarchy. No amendments to text made. The issue of compensation of any individual or groups is too narrow for inclusion into the draft policy document. An assessment of the challenges and appropriate methods to address these challenges will be done in the formulation of the NEP Action Plan. Enhancing capacity of the waste management system to receive and dispose of demolition waste, or debris from natural disasters is captured under 2.04 (h) "h) Empower governmental entities to better undertake their mandates with respect to the management of solid waste by way of enhanced technical, financial and human-resource capacity development". 2.07 - Biodiversity The point on social and economic valuation of ecosystem services is well received and will be included.


persons in these communities. We might also consider how to conduct ECONOMIC and SOCIAL VALUATION of the ECOSYSTEM SERVICES provided at these interfaces and determine whether there are particular groups (including local business and local/foreign tourists) that may be willing to pay premiums for access to these services. I heartily support points 2.15 – national festivals and events and 2.16 – mass transit options as these are highly relevant to the quality of life of citizens. 2.17 Economic transition – the term “circular economy” is increasingly being used to emphasize the shift away from a linear model of “take, use, waste” resources into one that is regenerative, cycling resources as much as possible, while improving environmental quality and societal benefits. For an island economy, circular economy is even more meaningful as it suggests the need for self-sufficiency and resilience, by circulating resources locally, reducing dependence on imports. A completely circular island economy is not possible in the modern era of global trade, but by reducing dependence on resources that can currently imported, but which are available and could be produced locally for feeding into the local economy, could certainly help the island reduce its trade deficit, generate employment and reduce the carbon/ecological footprint of imports. 2.22 Climate Change mitigation and adaptation strategies should be a top priority. Coordination of efforts across different public sector ministries and agencies, private sector and community based groups is essential. In most

Section 2.03 - Solid and Hazardous Wastes Characterization studies of waste streams in Trinidad and Tobago have been done periodically. The most robust was the Characterization and Centroid Study of 2010, and more recently, with the on-going development of the Waste Rules under the EM Act, a study in 2015. The 2011 Assessment of the State of the Environment Report on Solid and Hazardous Waste in Trinidad and Tobago, along with other studies related to waste has formed the basis of the policy statements contained in this section. Additional studies is captured under 2.03 (g) "Support educational institutions, non-governmental organisations and private sector companies to undertake research and programmes relevant to waste management". Government support of efforts to recapture and revalue waste will be explicitly stated as a policy statement. Items 2.03 (j) and 2.03 (k) do not emphasize waste-to-energy but rather, lists it as an option for alternative waste disposal along with recycling, and other efforts higher on the waste management hierarchy. No amendments to text made.


countries prioritization of GHG reductions through energy efficiency in buildings and transportation tackles much of their emissions, but in T&T where the economy is still cantered around fossil fuels, attention has to be put on the petrochemical sector in order for mitigation to achieve significant reductions. Is there work in carbon capture and storage? The implementation plan sounds just about right – financial and legal instruments to ensure that the agencies have the power to enforce the items laid out in the plan. Regarding monitoring and evaluation, my only suggestion is there ought to be an independent audit/evaluation by a third party, such as university or Caribbean-based agency, to prevent conflicts of interest.

There is no data to suggest that persons involved in waste recovery/collection are not adequately compensated. On the contrary, waste recovery is, at present, largely informal sector driven by the market. No amendments to text proposed. Enhancing capacity of the waste management system to receive and dispose of demolition waste, or debris from natural disasters is captured under 2.04 (h) "h) Empower governmental entities to better undertake their mandates with respect to the management of solid waste by way of enhanced technical, financial and human-resource capacity development". 2.07 - Biodiversity The point on social and economic valuation of ecosystem services is well received and will be included. 2.17 - Economic Transformation The point on the circular economy is well received and will be included. 2.22 - Climate Change Mitigation and Adaptation.


Addressing climate change will be a top priority in the development of the NEP Action Plan. Climate change mitigation options inclusive of carbon capture and storage, are prescribed in the "National Strategy for the Reduction of Carbon Emissions in Trinidad and Tobago, 2040" and "National Climate Change Policy". The NEP will not duplicate the policy statements contained in those documents, but rather, endorses the pursuit of measures listed in those policies. Notwithstanding, a minor amendment will be made to 2.22 (f) to emphasize the point. Section 4.01 - Monitoring and Evaluation The responsibility of monitoring and evaluating the NEP shall remain vested with the EMA as the governmental entity with the responsibility for coordinating environmental efforts and reporting on the state of the environment. Neither the text of Section 4.01, nor the text of Annex III, however, precludes the EMA from seeking 3rd party support in evaluation. No amendments proposed.


The government needs to implement domestic laws to protect the ramsay sites in accordance with ramsay rules. There needs to be rules for farmers to ensure they follow best practices. The use too much pesticide and herbicide which pollutes the soil and groundwater and runs off into seas. Additionally, they kill pollinators. Their actions put our food security from land send sea at risk. The government needs to carryout their obligations to the Paris agreement. They need to show up to the conference of parties meetings, which have not attended for the past two years. They need to put in place laws which will allow implementation of green technology and they need to move away from oil. The government needs to implement recycling efforts and make it accessible to the public. They need to support private efforts by companies to recycle. There needs to stricter punitive actions against industrial pollution.


Conservation in keeping with the Ramsar Convention will be achieved via the provisions of 2.07 (a)(i) "i. Facilitate action towards the objectives of MEAs related to biodiversity conservation including, but not limited to the: Convention on Biological Diversity and its precipitating Protocols, Convention for the Protection and Development of the Marine Environment of the Wider Caribbean Area and its precipitating Protocols, Convention on International Trade in Endangered Species of Wild Fauna and Flora, and Ramsar Convention on Wetlands" Previous iterations of the NEP specifically mentioned farmers as sources of non-point pollution. However, recognising that farmers are not the only source of non-point pollution, the language was adjusted to not isolate farmers and address non-point sources more generally under Section 2.01. Recycling is addressed under Section 2.04 and the measures contained under Section 2.22 are harmonized with the provisions of the UNFCCC and the Paris Agreement


Well I think I am part of a small group of educated youth and not even youth but most of our population is unaware of the effects now and the future of their actions and others actions and other alternatives , better alternatives I think it would be great to invoke the youth .many of us are willing to do something but have no help or direction as the way to go about things and the youth have the drive and can amass a greater number of people to join us as we call and dew on our relatives and parents and bring about a new fresh better image to the country. Many youth want to help in any way we can for our country , we just need the proper guidance

*Amend Section 1.01 (Introduction), item re: "Peace and Justice" to read:Scarcity of natural resources, mismanagement of common-pool resources and the inequitable sharing of benefits derived from ecosystems are recognised drivers of non-violent and violent conflicts between stakeholders, within and between nations. Where these conflicts arise, marginalised groups (such as indigenous peoples, rural poor, children, youth, women, sick, disabled and the elderly) tend to suffer most. *Insert in Section 1.05 (Good Governance) the following:7. Meaningful engagement and involvement of Trinidad and Tobago’s youth;*Replace 2.19 (h) with the following:h) Ensure that all efforts at education, awareness-building and meaningful participation in decision-making regarding environmental and/or development issues encourage and facilitate the inclusion of marginalised groups such as indigenous peoples, the rural poor, children, youth, women, sick, disabled and elderly.*Replace the 2nd paragraph of 3.02 (Implementation) with the following:To further the implementation of this policy, a National Council for Sustainable Development (NCSD) will be established. The NCSD will provide a forum for Government, business and civil society to have ongoing oversight with advisory functions to the Action Plan. The composition of the NCSD will, at all times, also reflect the tenants of the principle of Good Governance; ensuring, inter alia, the

The young people of Trinidad and Tobago, as individuals or as part of youth groups, have a critical role in the success of this NEP. They are to be actively involved in the decision-making and guidance of the policy. Amendments to emphasize the importance of youth involvement have been made to the Principle of Good Governance, the Chapter on Implementation of the NEP, and other policy areas.


meaningful involvement of women and youth. It is envisioned that members of the NCSD will utilise the auspices of their respective positions to facilitate the implementation of the NEP into their sectors.


Just never give up. U r doing a great job. Trying at least is the best option. Keep going and u will get there. Just keep trying. Wish i could help. VERY WELL DONE!

Feedback noted. However, no modification to the text will be made since comment does not highlight an area in need of improvement.this topic/suggestion is already captured under an exisitng policy statement(s).

General Comment.

Excellent and well thought out, Trinidad needs this urgently. Feedback noted. However, no modification to the text will be made since comment does not highlight an area in need of improvement.this topic/suggestion is already captured under an existing policy statement(s).

General Comment.

I would like to see more on climate change included in the draft. Include the need for mitigation and adaptation measures as well as the need for a collaborative effort. People in T&T are unaware and sceptical about climate change regardless of all the evidence worldwide.


The position of the GORTT on the topic of climate change is one of certainty. Priority Area 6 is "Addressing Climate Change and Environmental Disasters". Section 2.22 speaks heavily on climate change adaptation and mitigation.

Good effort however more needs to be done to create a public awareness campaign and proper enforcement/prosecution to act as a deterrent to offenders.


Public Awareness and enhancing the capacity for enforcement is advocated for across all topics of the NEP. Notwithstanding, Section 2.19 gives specific focus to public education and awareness, and Section 3.01 addresses enforcement.

I think consideration should be given to promoting the use of renewable energy and electric cars. Relying on electricity produced using oil and gas is increasingly contributing to climate change. Taxes on importing electric vehicles and solar equipment should be reduced to encourage this. In addition, the gases released in the atmosphere at Point Lisas and Point-a-Pierre is of serious concern and air quality testing should be monitored and broadcasted to the public. Air pollution from industrial sources is addressed


Advancing the penetration of renewable energy will be a major focus of the NEP Action Plan as the GORTT has made a time-bound commitment. RE and EE measures are provided for under Section 2.22.


under Section 2.02. The NEP Action Plan will assess and determine the specific measures towards the policy actions for these subject areas.

1) Noise from Carnival was mentioned. However no inclusion of noise from fireworks and/or scratch bombs when used at celebrations. This poses a serious threat to human beings as well as make animals frantic often being killed or found missing from homes. For example in Japan, they use fireworks at celebrations and it makes no noise when emitted. 2) Could there be some sensitization included around carbon footprint. One initiative seen recently was introduction of hybrid vehicles. However, citizens still use different modes of transport to and from our destinations and may be unaware of contribution of CO 2 to the environment. In addition, as electricity rates increase, having an understanding of how the household contributes to the carbon footprint can assist in tackling climate change. 3) Apart from moving away from the use of Styrofoam products, there is also a large extent of use of plastic products which is harmful to the environment as it is non biodegradable. We need to look into finding ways to introduce biodegradable plastic. 4) Having been abroad and seeing the emphasis and discipline placed into the environment is amazing. In some countries it starts in the home where there are recycling bins (glass, aluminium cans, paper, cardboard). A garbage truck designed with compartments comprising of the aforementioned collects


Noise from fireworks can be captured under 2.03 (a) "Amend existing legislation or develop new legislation and standards, as necessary, to ensure that all sources and types of noise are appropriately managed to minimise nuisance, and danger to the health and welfare of sensitive receptors". Understanding that noise is the most pressing concern of the public, particularly from recreational events and fireworks, emphasis will be placed on addressing this measure in the NEP Action Plan. Measures to address climate change is addressed under Priority Area 6. Specific emphasis on carbon footprint and other topics for public education will be considered when developing the NEP Action Plan. Non-biodegradable materials is addressed under Section 2.04 (d) "Phase-out the manufacturing and importation of synthetic, non-biodegradable packaging material such as polystyrene and non-recyclable plastics


the refuse from homes and carries it to the landfill site. (This can be a long term goal). Placing recycling bins strategically into areas can encourage citizens to contribute to waste reduction through the recycling program.

through environmental policy instruments;" The introduction of more environmentally friendly products such as bio-degradable plastics, is captured under 2.04 (e) "Encourage private sector, especially large and transnational companies, to adopt sustainable practices and integrate sustainability into their reporting cycle;"


P.15. 2.04: Suggest the following "Thus, in keeping with SDG 12 which aims to ensure sustainable consumption and production patterns through the environmentally sound management of all wastes, the GoRTT’s policy will be based on, in priority order, the philosophy of prevention, reduction, reuse, recycling, energy recovery and disposal, with disposal considered as the least favoured option". P.15, a: Suggest to remove the identified policies. This allows for additional waste policies to be created and considered without restricting the NEP to these two policies. P.16, b(ii) and (iii): Suggest to remove b(iii) as food waste is a type of waste which can be addressed in b(ii). If the GORTT insists on specifically mentioning food waste, then suggest to add at the end of b(ii), "including food waste". P.16, c: Suggest to remove (c) and merge with b(ii), for example, "Facilitate the proper handling, storage and disposal of waste using processes and methods which will reduce harm to humans and the environment." P.16, d: Suggest "Phase-out the import, manufacture and use of synthetic, non-biodegradable materials such as polystyrene and plastics through market-based environmental policy instruments." P.16, e: This is tied to (b)(ii) and (d) above and assumes that only the private sector should adopt sustainable practices which public sector companies (Petrotrin, NGC, WASA, TTEC) are likely to be just as culpable in not implementing same. P.16, f: Suggest "Encourage and support partnership with regional and international organisations to support technical and institutional capacity development of sustainable patterns of consumption and production".

2.04 - Solid and Hazardous Waste Replace "Thus, in keeping with SDG 12 which aims to ensure sustainable consumption and production patterns through the minimisation and environmentally sound management of all wastes, the GoRTT’s policy on solid waste will be based on the philosophy of ‘prevent, reduce, reuse and recycling’’ with ‘energy recovery’ and ‘disposal’ considered only as last resort responses" with the text proposed, "Thus, in keeping with SDG 12 which aims to ensure sustainable consumption and production patterns through the environmentally sound management of all wastes, the GoRTT’s policy will be based on, in priority order, the philosophy of prevention, reduction, reuse, recycling, energy recovery and disposal, with disposal considered as the least favoured option." 2.04 (a) Amend text to read: a) Harmonise national policies that relate to waste management including, but not limited to the National Waste Recycling Policy and the Integrated Solid Waste/Resource Management Policy. 2.04 (d) Amend text to read: d) Phase-out the import, manufacture and use of

P.15. 2.04: Suggest the following "Thus, in keeping with SDG 12 which aims to ensure sustainable consumption and production patterns through the environmentally sound management of all wastes, the GoRTT’s policy will be based on, in priority order, the philosophy of prevention, reduction, reuse, recycling, energy recovery and disposal, with disposal considered as the least favoured option". Response: Text will be amended as proposed. P.15, a: Suggest to remove the identified policies. This allows for additional waste policies to be created and considered without restricting the NEP to these two policies. Response: The identification of the two policies does not prohibit the creation of a new policy. All policies governing solid waste must be harmonized. It is important that these two policies are specifically named as elements of them contradict one another and so, it is imperative that they be rationalized. The text will be amended to ensure that harmonization is not limited to these two documents. P.16, b(ii) and (iii): Suggest to remove b(iii) as food waste is a type of waste which can be addressed in b(ii). If the GORTT insists on specifically mentioning food waste, then suggest to add at the end of b(ii), "including


P.16, g: Suggest "Encourage and support partnership with educational institutions, non-governmental organisations and the private sector to undertake research and programmes to improve waste management". P.16, h: This is tied to (f) and (g) as governmental entities are presently supported by capacity building opportunities afforded by regional and international organizations. Suggest to remove and add "governmental entities" to the list in (g) above. P.16, i: Suggest to remove the policy identified and end the sentence at "system". P.16, j: Suggest to merge (j) and (d) or replace with "Encourage and support the development of market-based environmental policy instruments for the prevention, reduction, reuse and recycling of waste, including the use of waste as an energy source." P.16, k: This seems the same as (f) and (g). Suggest to merge with (f) or (g) or replace with "Collaborate with non-governmental organisations, community-based organisations, the private sector and other governmental entities to build sustainable public education and awareness campaigns that encourage the prevention, reduction, reuse and recycling of waste." P.17: Hazardous Substances and Wastes: Note that the MOH is currently the primary legislator for pesticides and toxic chemicals (under the P&TC Act) and radioactive materials (MOH currently developing an Act and Regulations to manage same). Suggest to amend this paragraph to "The GoRTT will continue to take decisive action regarding the manufacture, handling, use, transboundary movement, treatment and disposal of hazardous substances and hazardous

synthetic, non-biodegradable materials such as polystyrene and plastics through market-based environmental policy instruments 2.04(e) Amend text to read: e) Encourage the public, private and non-governmental sectors, especially large and transnational companies, to adopt sustainable practices and integrate sustainability into their reporting cycle. 2.04(f) Amend Text to read: f) Encourage and support partnership with regional and international organisations to support technical and institutional capacity development of sustainable patterns of consumption and production 2.04(g) Amend Text to read: Encourage and support partnership with educational institutions, non-governmental organisations and the private sector to undertake research and programmes to improve waste management; and 2.04(i) Amend text to read: i) Amend existing legislation or develop new legislation, as necessary, to facilitate the efficient

food waste". Response: It is recognised that the provision of b(ii) also captures food waste along with all other forms of waste. Policy statement b(iii) goes beyond handling, storage and disposal to speak about reducing food waste from production and consumption. Statement b(ii) speaks to the management of all waste, regardless of volume, while b(iii) speaks specifically to reduction in food waste volumes throughout the life cycle of food. As such, they should remain distinctly different statements. No change made. P.16, c: Suggest to remove (c) and merge with b(ii), for example, "Facilitate the proper handling, storage and disposal of waste using processes and methods which will reduce harm to humans and the environment." Response: 2.04 (b) speaks to management of waste (handling, storage and disposal) through legislative creation or amendment, while 2.04 (c ) provides a broad commitment that waste recovery and/or handling would not impact amenity or human and environmental health. Statement 2.04 (c ) allows for non-legislative methods to be used such as market-based measures, moral suasion tools or otherwise. It also provides the basis of taking action to preserve health in the absence of legislation. As such, merging of text is not recommended. No changes made.


wastes. The GoRTT will accordingly..." P.17, l(a): Suggest to name this (l) and state "Amend existing legislation or develop new legislation, as necessary, to give effect to the Multilateral Environmental Agreements (MEAs) on hazardous substances and wastes of which Trinidad and Tobago is a Party, including, but not limited to, the..." P.17, l(b): Suggest to name this (m) and state "Enforce existing legislation and as required, amend existing legislation or develop new legislation to ensure the proper handling, transport, treatment and disposal of hazardous substances and hazardous waste through permitting and licensing systems". A reminder on the note above on the MOH jurisdiction on radioactive materials and toxic chemicals. However, if it is a responsibility of the GORTT, then it should be clear to the reader that the EMA is not the only regulatory body with authority over the management of these hazardous substances. P.17, m: Suggest to remove. This should be innate to the legislation amended or developed in (l). This data will become accessible if the EMA specifically requests same in its permits, that is, ask the permit holder to record and collate the data in a format defined by the EMA. P.17, n: This is tied to l(a) as import is an aspect of the Basel Convention. If there is a company in Trinidad who can treat the waste in an environmentally sound manner, then it will be unfair to that company to prohibit import. Suggest to remove as it is an element of l(a) or replace with "Prevent the import of hazardous waste if there is reason to believe that the waste in question will not be managed in an environmentally sound manner." This allows room for

coordination and implementation of a national waste recycling system. 2.04(j) Amend text to read: j) Encourage and support the development of market-based environmental policy instruments for the prevention, reduction, reuse and recycling of waste, including the use of waste as an energy source 2.04(k) Amend text to read: Collaborate with non-governmental organisations, community-based organisations, the private sector and other governmental entities to build sustainable public education and awareness campaigns that encourage the prevention, reduction, reuse and recycling of waste. 2.04(l) Replace text with: l) Amend existing legislation or develop new legislation, as necessary, to give effect to the enforcement of MEAs on hazardous substances and hazardous waste including, but not limited to: the Basel Convention on the Control of Transboundary Movement of Hazardous Waste and their Disposal, the Stockholm Convention on Persistent Organic Pollutants, and the Rotterdam Convention on the Prior Informed

P.16, d: Suggest "Phase-out the import, manufacture and use of synthetic, non-biodegradable materials such as polystyrene and plastics through market-based environmental policy instruments." Response: Text amended as proposed. P.16, e: This is tied to (b)(ii) and (d) above and assumes that only the private sector should adopt sustainable practices which public sector companies (Petrotrin, NGC, WASA, TTEC) are likely to be just as culpable in not implementing same. Response: Whereas b(ii) advocates for legislation to be passed/amended to support this effort, 2.04(e) is not contingent on legislation. As such, it shall remain its own distinct policy statement. The point regarding public sector companies is well received and the text will be adjusted appropriately. P.16, f: Suggest "Encourage and support partnership with regional and international organisations to support technical and institutional capacity development of sustainable patterns of consumption and production". Response: Text amended as proposed. P.16, g: Suggest "Encourage and support partnership with educational institutions, non-


approval of an importer who has good practices and room for the EMA to object. A bilateral or multilateral agreement is an arrangement which should be addressed by CARICOM as T&T is viewed as 'developed' when it comes to hazardous waste management, especially wastes from oil and gas developments. P.17, o: Suggest to remove "prohibition" as there is no prohibition on this as of date. Suggest "Strengthen enforcement on the open burning of hazardous substances and hazardous waste". P.17, p: Re-word this section using suggestions above for (f) and (g). P.17, q: This is an activity which the PTCI can address and is tied to (j). Suggest to reword. P.17, r: This is tied to (p) and is a requirement for licences to import (safety data sheets). The public may also ask the EMA to define "adequate safety and toxicity testing". Suggest to remove or replace with "Manufacturers and distributors will ensure that they supply materials and substances which are approved for local use by the relevant regulatory authorities concerned, which includes, but is not limited to, the Pesticides and Toxic Chemicals Control Board and the Trinidad and Tobago Bureau of Standards". P.17, s: Suggest to remove. The NEP should not repeat what is already required in existing law. This statement is reflected in amended (r) above. P.17, t. Suggest to remove. There is a view that policy is not law and so this statement has no effect unless there is a requirement in domestic law which is l(a) above. At present, a CEC may include this requirement and the Ministry of Trade and Industry has this requirement for used lead acid

Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade 2.04(l)(b) This is to be elevated to become the new 2.04 (m). Text shall be adjusted to read: m) Enforce existing legislation and as required, amend existing legislation or develop new legislation to ensure the proper handling, transport, treatment and disposal of hazardous substances and hazardous waste through permitting and licensing systems 2.04(n) Amend text to read: Prevent the import of hazardous waste if there is reason to believe that the waste in question will not be managed in an environmentally sound manner. 2.04(o) Amend text to read: Strengthen enforcement on the open burning of hazardous substances and hazardous waste 2.04(r) Amend text to read: Manufacturers and distributors will ensure that they supply materials and substances which are approved for local use by the relevant regulatory authorities concerned, which includes, but is not limited to, the Pesticides and Toxic Chemicals

governmental organisations and the private sector to undertake research and programmes to improve waste management". Response: Text amended as proposed. P.16, h: This is tied to (f) and (g) as governmental entities are presently supported by capacity building opportunities afforded by regional and international organizations. Suggest to remove and add "governmental entities" to the list in (g) above. Response: It is recognised that 2.04(h) can encompass both (f) and (g). However, (h) is broader and affirms the government's commitment to empowering and building capacity of governmental entities while (f) and (g) only commits the government to 'encouraging partnerships' for building capacity. As such, (h) cannot be removed. No changes made. P.16, i: Suggest to remove the policy identified and end the sentence at "system". Response: Text amended as proposed. It is possible that the harmonization of policies as declared in 2.04(a) may render the policy defunct and as such, (i) should not be bounded to it. P.16, j: Suggest to merge (j) and (d) or replace with "Encourage and support the development of market-based environmental policy


batteries (Export Licence). P.17, u, v, w: Suggest to remove as Government has to provide for same in legislation as stated in l(b). P.17, x, y: This is a requirement under the OSH Act. Suggest to remove.

Control Board and the Trinidad and Tobago Bureau of Standards 2.04(s) Delete. 2.04(u, v, w, x, y) Delete.

instruments for the prevention, reduction, reuse and recycling of waste, including the use of waste as an energy source." Response: Amended as proposed. P.16, k: This seems the same as (f) and (g). Suggest to merge with (f) or (g) or replace with "Collaborate with non-governmental organisations, community-based organisations, the private sector and other governmental entities to build sustainable public education and awareness campaigns that encourage the prevention, reduction, reuse and recycling of waste." Response: Amended as proposed. P.17: Hazardous Substances and Wastes: Note that the MOH is currently the primary legislator for pesticides and toxic chemicals (under the P&TC Act) and radioactive materials (MOH currently developing an Act and Regulations to manage same). Suggest to amend this paragraph to "The GoRTT will continue to take decisive action regarding the manufacture, handling, use, transboundary movement, treatment and disposal of hazardous substances and hazardous wastes. The GoRTT will accordingly..." Response: The MOH being the primary legislator for pesticides and toxic chemicals, does not negate the government's commitment


to MEAs related to hazardous waste. As such, the statement should be removed. No change made. MOH will be included in the development of the NEP Action Plan for addressing hazardous waste. P.17, l(a): Suggest to name this (l) and state "Amend existing legislation or develop new legislation, as necessary, to give effect to the Multilateral Environmental Agreements (MEAs) on hazardous substances and wastes of which Trinidad and Tobago is a Party, including, but not limited to, the..." Response: Amendment made as proposed P.17, l(b): Suggest to name this (m) and state "Enforce existing legislation and as required, amend existing legislation or develop new legislation to ensure the proper handling, transport, treatment and disposal of hazardous substances and hazardous waste through permitting and licensing systems". A reminder on the note above on the MOH jurisdiction on radioactive materials and toxic chemicals. However, if it is a responsibility of the GORTT, then it should be clear to the reader that the EMA is not the only regulatory body with authority over the management of these hazardous substances. Response: Amendment made as proposed. P.17, m: Suggest to remove. This should be


innate to the legislation amended or developed in (l). This data will become accessible if the EMA specifically requests same in its permits, that is, ask the permit holder to record and collate the data in a format defined by the EMA. Response: While it is recognised that this will be innate to legislation developed under statement (l), it is believed that this should statement should remain to provide intermediate coverage until such legislation is developed. No change made. P.17, n: This is tied to l(a) as import is an aspect of the Basel Convention. If there is a company in Trinidad who can treat the waste in an environmentally sound manner, then it will be unfair to that company to prohibit import. Suggest to remove as it is an element of l(a) or replace with "Prevent the import of hazardous waste if there is reason to believe that the waste in question will not be managed in an environmentally sound manner." This allows room for approval of an importer who has good practices and room for the EMA to object. A bilateral or multilateral agreement is an arrangement which should be addressed by CARICOM as T&T is viewed as 'developed' when it comes to hazardous waste management, especially wastes from oil and gas developments. Response: Amendment made as proposed.


P.17, o: Suggest to remove "prohibition" as there is no prohibition on this as of date. Suggest "Strengthen enforcement on the open burning of hazardous substances and hazardous waste". Response: Amended as proposed. P.17, p: Re-word this section using suggestions above for (f) and (g). Response: This is similar to (h) in that it is broad to reaffirm the government's commitment to empowering their agencies. No changes made. P.17, q: This is an activity which the PTCI can address and is tied to (j). Suggest to reword. Response: The PTCI will be included in the development of the NEP Action Plan for this measure. No changes made. P.17, r: This is tied to (p) and is a requirement for licences to import (safety data sheets). The public may also ask the EMA to define "adequate safety and toxicity testing". Suggest to remove or replace with "Manufacturers and distributors will ensure that they supply materials and substances which are approved for local use by the relevant regulatory authorities concerned, which includes, but is not limited to, the Pesticides and Toxic Chemicals Control Board and the Trinidad and


Tobago Bureau of Standards". Response: Amended as proposed. P.17, s: Suggest to remove. The NEP should not repeat what is already required in existing law. This statement is reflected in amended (r) above. Response: Removed as suggested given the changes made to (r). P.17, t. Suggest to remove. There is a view that policy is not law and so this statement has no effect unless there is a requirement in domestic law which is l(a) above. At present, a CEC may include this requirement and the Ministry of Trade and Industry has this requirement for used lead acid batteries (Export Licence). Response: Notwithstanding the non-enforceable nature of a policy, it is believed that this be retained as an interim measure until legislation is passed. No change made. P.17, u, v, w: Suggest to remove as Government has to provide for same in legislation as stated in l(b). Response: Removed as proposed. P.17, x, y: This is a requirement under the OSH Act. Suggest to remove. Response: Removed as proposed.


Mention should be made to the fact that the NEP relates to 12 of the 17 SDGs as follows:SDGs:• Water Pollution (Section 2.01) linked to SDGs 6 and 12• Air Pollution (Section 2.02) linked to SDG 3• Solid and Hazardous Wastes (Section 2.04) linked to SDG 12• Water Resource Management (2.05) linked to SDGs 3 and 6• Soil / Land Management (2.06) linked to SDGs 2, 3 and 15• Biodiversity Management (2.07) linked to SDG 15• Coastal and Marine Area Management (Section 2.08) linked to SDG 14• Fisheries Management (2.09) linked to SDGs 12 and 14• Planning and Human Settlements (2.12) linked to SDG 11• Green Architecture and Infrastructure (2.13) linked to SDG 9• Heritage, Cultural and Archaeological Sites (2.14) linked to SDG 11• Mass Transit Solutions (2.16) linked to SDG 11• To achieve a society in which all people take an active role in protecting, maintaining and enhancing the quality of the environment, the GoRTT will create enabling conditions for the growth and normalisation of environmental attitudes, knowledge and practices. Such action is in line with SDGs 4 and 16 which emphasise the need to acquire knowledge and skills to promote sustainable development• Communication, Awareness and Public Participation (2.19) linked to SDG 4• Research (2.20) linked to SDG 9• Climate Change Mitigation and Adaptation (2.22) linked to SDG 13o Energy Efficiency and Energy Conservation linked to SDG 7o Renewable Energy linked to SDG 7Review periodA review period of 10 years is prescribed for the NEP but 2 years for the Action Plan as follows:"To maintain relevance and cohesion with an ever-changing national and supranational context, this NEP shall be reviewed and revised every 10 years. The process of undertaking this revision shall, at the minimum, entail the


All sections highlighted clearly show state their connection to the SDGs


process as prescribed under Section 18 of the EM Act.The NCSD shall review the Action Plan at a frequency determined as necessary, but not exceeding two years. Revision of the document will be made to ensure that action items are aligned with national obligations and the socio-economic context of the time."It is suggested that either the review period of the NEP be as early as five years but not exceeding 10 years or the review period of the Action plan be increased. This would allow continued alignment to be possible between the strategic level focus of the policy and the implementation focus of the Action plan. NEP’s Action Plan• NEP’s framework is meant to be aligned with sectoral and national implementation plans. This means that it is dynamic and subject to change based on the national directives at a point in time. It is suggested that the action plan receive national approval like the policy such that it remains an independent guiding framework. Obligations under International Conventions• The reporting requirements and commitments of the international Conventions (Appendix 1) are not always clear e.g. under the UNFCCC, reference is made to “Promote sustainable management” and “employ appropriate methods to minimise adverse effects” which make leaves the question “of what?”Alignment with CEC:The NEP's provisions should seek to be reflected in the CEC rules, if not currently then as a matter of urgency


First of all, Id like to say that Im thrilled to see growth . much has happened since 2009. This revision is necessary. I live outside T&T & will visiting to intern at a local herb store. When I first visited a couple years agoI was in complete ahock at peoples lack of desire to throw away trash. I cried for the beaches and marine animals. Now big business oil money is definitely thriving. This NEP and those who actively seek to follow thru will be the nations saving grace.


General Comment.

Innovative development that would help contribute to sustainable environmental development of Trinidad and Tobago.


General Comment.

There needs to be enforceable noise pollution regulations for fireworks use and other explosives in residential areas. A law that is vague difficult to hold persons to account is useless. We need active community policing at key times of night on Divali, independence and New Years. Also the cruelty to animals is a symptom of the other pervasive violence in our society. Cruelty to animals needs to be clearly defined, and harsher penalties. Smaller hunting periods, we have perhaps the longest hunting period in the world, and hand in hand with that is the employment of game wardens and number restrictions for animals hunted


The NEP Action Plan will consider as a matter of priority addressing noise from festivals, and in particular fireworks in residential areas. The adjustment to hunting seasons is a specific measure suitable for the NEP Action Plan. Such a measure will have to be discussed with relevant stakeholders. The NEP does provide for such action under 2.07 (d) "Continue the conservation of biodiversity through the development and implementation of programmes to address drivers of biodiversity loss including, but not limited to: deforestation, fires, erosion, illegal development activity, illegal exotic pet trade, invasive species and over-hunting" and 2.07 (g) "Ensure sustainable use of forest including extraction of timber and wild meat;"


I sent comments to email address provided Feedback noted. However, no modification to the text will be made since comment does not highlight an area in need of improvement.

General Comment. Mr. Healy-Singh's email was received and reviewed.

It touches on many of the critical issues, which is encouraging. But much of the language and coverage feels vague, weak, and non-committal so as not to give confidence that any concrete progress will be made on this in the short to medium term. But we live in hope.


The language of the NEP is intentionally broad to ensure that


Generally, a more systematic and holistic update to the 2006 version. The following are suggestions for your consideration: * Add a review period for this Policy (e.g. every 5 years or as a major need changes).* Page 1:1.01 - Shouldn't the 'environment' also include the sea floor up to some depth as well as a defined boundary for air (how many km from the water/land surface will be considered)?*1.01 The foundation is very anthropocentric. Please consider adding that the foundation is for respect to all life - which will then consider the needs of our endangered species; over-hunting by illegal human predators.* Please consider ALL forms of waste management, not just hazardous waste.*Page 2:Please consider modifying "Gender" Equality to "Equality for all Minority Groups " to include women, children, LGBT, Amerindian descendants, special needs persons etc.*With regards to fulfilling commitments of MEAs, how come Trinidad & Tobago has not yet ratified the Paris Climate Change Agreement 2015? Is the statement then true -"To this end, the GoRTT is party to several Multilateral Environmental Agreements (MEAs) and shall fulfil all commitments agreed to by signing these agreements." ?*Page 6 The GoRTT is spelt out even though it was abbreviated earlier. Please amend to abbreviation.* Page 7:With regards to the Section on the Precautionary Principle, there seems to be conflict on what the GORTT is committing to and what is actually happening in the country presently, for example, the proposed Toco highway, proposed Manzanilla Highway, following the heels of the Point Fortin Highway; clearing of the mangrove to build Movie Towne after it was reported in Parliament of the nesting of the national bird, the Scarlet Ibis, in the area;

Replace the first sentence of Section 4.02 with "To maintain relevance and cohesion with an ever-changing national and supranational context, this NEP shall be reviewed and revised as necessary, but not exceeding 10 years. " Amend the text of 1.01 under the heading of human health and well-being to read "Poorly managed human-environment interactions (water pollution, air pollution, noise pollution, waste management, and climate change) directly influence levels of disease, morbidity and mortality resulting in mental and emotional suffering."Replace the text of 2.23 (d) to read as "Update existing or develop, as necessary, new local, bi-lateral, and multi-lateral plans for pre-emergency contingency plans with clearly identified roles and responsibilities of the required public, private and non-governmental inputs of the State(s) involved;"

It is believed that a review of this policy every 5 years would be impractical both from the perspectives that (1) the revision process takes 1.5 - 2 years, if done as comprehensively as the 2018 revision and (2) the national and supra-national context of this NEP is unlikely to change significantly every 5 years. Notwithstanding, it is recognizes that a time period shorter than 10 years may be needed and as such, the text will be amended so that the review period shall remain as necessary but not for a period exceeding 10 years. 1.01 - IntroductionYes, the "environment" as defined by the Environmental Management Act Chap. 35:05 includes the sea and sea bed (sea floor) as well as the atmosphere above the earth. The NEP is developed in accordance with the provisions of the EM Act and for technical/legal debate, the definition as stated in the EM Act would be used. The intention of the Introduction section of the NEP is to quickly give the average person some context. As such, more technical definitions of environment which were used in previous iterations of the document were replaced with this general, simpler definition. This will be maintained.It is not contested that all forms of life are to be respected. The intrinsic value of biodiversity is recognized and Section 2.07 makes policy statements related to conservation and resource over-exploitation. The intention of the Introduction is to quickly inform the reader of


continued use of Turtle Beach, Tobago for business events (like fetes, beach football etc) when this a known nesting area for endangered sea-turtles in Tobago (and we know that hatchlings can emerge long after the official turtle nesting season has ended) etc. If what is written in this Section is the way forward, then can decisions please be made to reflect this policy AT ALL TIMES?*Page 24. (g)"Ensure that industries that are LEGALLY responsible..." Please add another clause to include who will be responsible for mystery damages (e.g. October 2017 Chaguaramas oil spill).*Page 35 (d) Please add multi-lateral plans to include the entire Caribbean. In 2000, there was MEEI discussion to develop a multi-lateral Oil Spill Contingency Plan in addition to updating the National Oil Spill Contingency Plan and Bi-lateral Plan between Trinidad and Tobago and Venezuela. REMPEITEC had offered to assist. Between then and now, oil spill trajectory models developed by some oil and gas operators show that there is possibility of oil spills from Trinidad and Tobago impacting islands such as Grenada, Barbados and St. Lucia IF absolutely nothing is done to control the spread of the oil. Even though measures are in place to respond locally, plans need to be developed with the other islands to clearly identify how these types of incidents are dealt with.*Page 35/36 What about response systems for global outbreaks(e.g. SARS) , pandemic incidents, world warfare, nuclear disasters, diseases that wipe out local populations of specific species etc? *Page 36 (i) "entities PROVEN responsible...."*What timeline is being considered to implement the required infrastructure (budget, people, training, tools, spaces, transport, communication plans and tools etc.) once this NEP is passed? *What are the

the importance of the environment to them and thus, the anthropocentric focus of the opening paragraph. This will be maintained.It is agreed that all form of waste, not only hazardous, can impact the health and well being of people. Amended as Suggested. The data for gender inequality with regards to environmental sustainability is robust. Rural women in particular work intimately with the environment daily but are disproportionately granted ownership of land, revenues from resource use, or access to decision-making world wide. The importance of addressing this issue is reflected in Gender Equality being its own Sustainable Development Goal (SDG 5). The relationship between environmental sustainability and the rights of other groups such as LGBTQIA remains largely unassessed. Disenfranchised groups are highlight as being more vulnerable in the paragraph preceding, and the rights of indigenous peoples and all marginalized groups are advocated for in the Principles of the NEP. The text on 'gender equality' will be maintained. Ratification of an international treaty may take some time, so the present day status of a treaty's ratification is not a reliable indicator for measuring the government's commitment to fulfilling its obligations. The text will be maintained. Section 1.04 - Our Vision for the Environment1.05 - Environmental Governance PrinciplesThe Precautionary


consequences for non-compliance to this Policy? For the GoRTT? For business sector? For the research sector? For NGOs? For citizens? For visitors?*Please give credit to the photographers to whom the photographs used in this NEP Draft belong.

Principle is a long-standing principle in Trinidad and Tobago. It is expected that all actions - past, present and future - inclusive of the ones highlighted would be done in accordance with this principle. Judgements as to whether previous or on-going development is in keeping with this principle are to be made by a court of law. No amendment to text proposed. Section 2.11 - Mineral and Hydrocarbon ResourcesThe text quoted by the commenter is not reflective of the text in the 3rd draft Revised NEP placed for public comment over the period October 9th - December 15th. The current text holds all entities that are responsible for spills accountable for their actions. No amendment to the text necessary. Section 2.23 - Comprehensive Environmental Disaster ManagementThe suggestion for multi-lateral plans to be included in regarding 2.23 (d) will be adopted. Global health epidemics and pandemics caused by illegal species trade can be addressed under some of the provisions of 2.08. With respect to other epidemics such as SARS and global warfare; issues such as those are beyond the remit of the NEP. The proposed amendment to 2.23(i) is unnecessary as it is implicitly understood that 'entities responsible' are those which are proven to be responsible. *What timeline is being considered to implement the required infrastructure (budget, people, training, tools, spaces, transport, communication plans and


tools etc.) once this NEP is passed? Answer: Section 3.02 provides a time frame of one year from the passing of the NEP to begin implementation via the development of the NEP Action Plan and establishment of the NCSD. *What are the consequences for non-compliance to this Policy? For the GoRTT? For business sector? For the research sector? For NGOs? For citizens? For visitors?Answer: There is no penalty for non-compliance with the NEP. The policy provides a broad framework for what needs to be done. Legislation is the tool that contains consequences. The failure of stakeholders, inclusive of the government, to comply with the Principles of the NEP, however, may have consequences if challenged in court. *Please give credit to the photographers to whom the photographs used in this NEP Draft belong.Answer: All credit will be given. The photographs used in this draft will not be the photos used in the final publication.


There should be greater focus on development, updating, implementation and enforcement of environmental legislation, in particular waste management legislation. The draft Waste Management Rules should be updated and passed as law. This would aid in the waste management problem we currently have in Trinidad and Tobago. Greater emphasis needs to be placed on the role of citizens protecting and managing our environmental resources. Informing and educating the public is key moving towards an environmentally sustainable society as well as getting them involved in every stage of sustainable development. A more active and progressive approach in detailing the strategies to achieve the goals and objectives of the NEP is required. In some instances, the strategies are vague and does not detail what will be done to achieve the goal, what is the target to measure success by or the expected time frame for achievement of goals. Strategies should be specific, realistic, measurable and within a given time frame. Inclusion of an implementation plan with milestones and respective timelines. This should indicate the approximate dates (e.g. by months) for the creation of the NCSD, the creation of the action plan, stakeholder engagement towards this etc. This is different to the implementation plan referenced within the NEP Action Plan and representative of a timeline the public can follow towards major milestones. In the absence of timelines, there will be little accountability towards these activities occurring.

Amend the 2nd paragraph under Section 3.02 (Implementation) to read "To further the implementation of this policy, a National Council for Sustainable Development (NCSD) will be established within one year of this NEP coming into effect." Add to Annex III (Implementation Plan) the following: 8) Risk Assessment and Management a) This section will identify, for each strategic action, perceived risks to the success of the strategic action. These risks may include, but are not limited to: critical assumptions, conditional resources, or potential changes to the social or economic dimensions surrounding the action that may delay or halt progress. b) This section will also contain a description of measures that will be taken to minimize risks to the successful achievement of strategic actions.

All sections of the draft revised NEP contain provisions for the development and/or amendment of legislation to further the management of the environment, inclusive of solid waste. The NEP is meant to guide the all stakeholders of the environment including but not limited to governmental entities, private sector, non-governmental organisations and individuals. The role of the public is emphasized throughout the document, however the improving the education, awareness and public participation the public is especially highlighted in Section 2.19. The Policy Statements in the NEP are not strategies in of themselves but rather declarations that set the context for future strategies. Annex III provides the framework for the NEP Action Plan which in of itself is comprised of two halves: A Strategic Approach and the Implementation Plan. The framework indicates that the NEP Action Plan must have targets and timeframes as well as S.M.A.R.T. Indicators. The development of the Action Plan will entail robust stakeholder consultations for the development of more refined and concrete strategies for each Priority Area of the NEP, aligned to policy statements. Section 3.02 sets general timeframes for the


The NEP Action Plan/Implementation plan should include a section on Risk Assessment and Management in keeping with project management guidelines. In a positive note, the revised NEP has covered the important environmental issues facing the country and details the government's intention to move towards sustainable development through measures they have detailed in the policy. The Trinidad and Tobago Field Naturalist Club, supports the revision of the NEP and is willing and ready to work alongside the GORTT to help our nation move towards a culture of sustainability.

creation of the Action Plan. A time frame for the creation of the NCSD will also be included. A more detailed (month to month) break down of how activities towards these milestones are achieved cannot be provided into the Policy. The creation of the NCSD and the NEP Action Plan will be done in keeping with the framework provided in Annex III and the principles of the NEP. In keeping with the principles of the draft revised NEP, framework of Annex III, and policy statements of Section 2.19 and 3.02, the EMA will maintain transparency and openness with the development of the NEP Action Plan and NCSD. As noted in the Preamble, stakeholders such as the TTFNC are expected to hold government accountable for their policies and raise questions regarding the implementation of this policy once it comes into effect.

Great initiative to run toward a future with the rest of the modern world.


General Comment.


Dear Madame, I am very grateful for the chance to contribute. Through no fault of the EMA, I noted the extension inviting public comment to the NEP late. I have not been able to read through the NEP draft in its entirety and while I recognize that this is not the forum for registering a complaint, please accept the brief context provided below. My concern seems to fit under Priority 3: Improving the Local Environment under Section 2: Environmental Priorities for Trinidad and Tobago. I grew up in a residential area but recall that one or two of our neighbours on the street ran small “self contained” businesses from the downstairs sections of their homes on a limited scale and for a limited time. Although within walking distance of the town centre, the area was, (and still is) residential. Some years ago a new neighbour acquired an adjacent vacant lot and set up a hardware. (I have attempted a bit of research and stumbled across a designation of “Mixed Use” for the area, from a recent draft document from the Regional Corporation where I live). We recently moved back in to our family home in the area and within a few weeks we became painfully aware of the nuisance and potentially grave health hazards arising out of the operation of this apparent convenience next door. Most pressing issues listed below. Nuisance impact due to parking/blocking of our driveway. Health impact due to our inhalation of Vehicular Exhaust on an “intermittent to regular” basis (particularly from diesel powered transport due to excessive idling, and at vehicle start up) Impact due to an increase in litter, dust and noise. We are particularly concerned about the vehicular exhaust

No amendments made. “How does the NEP provide an easy roadmap for ordinary citizens to be able to raise such matters for investigation and resulting action (efficient enforcement if necessary) without the citizen having to bear the burden of time and costs including potential reprisal.” Answer: The draft revised NEP does not detail a complaint investigation process. The NEP creates the enabling framework for fostering a more environmentally responsible society, greater compliance with environmental regulations, and the detection and enforcement of environmental breaches. Under the principle of “Good governance” it states “the GoRTT, all sub-national actors and international actors operating within the State’s boundaries shall adopt/maintain, where appropriate, the features of good governance required to galvanise environmental sustainability, including but not limited to… the right of every citizen to expose any environmental or health hazard without fear of reprisal.” This means that governmental entities responsible for enforcement establish and maintain procedures to ensure your confidentiality. Section 2.21 (Access to, and Implementation of Environmental Justice) gives the government’s commitment to developing systems for detecting, investigating and resolving environmental conflicts. Section 3.01 gives the


item because of infants in our family. We would also like to point out that there is more age vulnerability in the neighbourhood. Comments/Questions for NEP 1) How does the NEP provide an easy roadmap for ordinary citizens to be able to raise such matters for investigation and resulting action (efficient enforcement if necessary) without the citizen having to bear the burden of time and costs including potential reprisal. 2) Do government entities possess the competence (expertise and tools) to assess and evaluate plans prior to granting approval for such projects. How is EMA policy and T&T law integrated here. 3) Where can we easily find clarity for land and building use designations such as “Mixed Use”, and how is “Mixed Use” development made sustainable with all stakeholder input.

government’s commitment to “Strengthening mechanisms for compliance with the NEP and environmental legislation” “Do government entities possess the competence (expertise and tools) to assess and evaluate plans prior to granting approval for such projects. How is EMA policy and T&T law integrated here.” Answer: Yes, government entities do possess the competence (expertise and tools) to assess and evaluate plans prior to granting approval for businesses. However, capacity can always be improved among the agencies, laws tightened to close ‘loop holes’ in the permitting processes, and education and outreach improved so that all are aware of what needs to be done. The draft revised NEP advocates for all of these things broadly throughout the document. The specific ways in which capacity will be built and the specific laws to be improved will be determined in the creation of the NEP Action Plan. “Where can we easily find clarity for land and building use designations such as “Mixed Use”, and how is “Mixed Use” development made sustainable with all stakeholder input?” Answer: Land designation falls under the


purview of the Town and Country Planning Division (TCPD). You may approach them with future inquiries. “Mixed Use” is made sustainable by ensuring that approval processes are considerate of all stakeholder feedback. Section 1.19 (Communication, Awareness and Public Participation) reaffirms the government’s commitment to “Ensure that mechanisms established for meaningful participation in decision-making regarding environmental and/or development issues are appropriately promoted, and made available to the public.” Through public-participation in decision making, it is believed that all environmental and human health concerns can be successfully managed.


Please note the following with respect to the NAP: Sec 2.11 pg 23 – Asphalt is considered a Mineral under the Minerals Act, Chap. 61:03 Annex II – pg 52: under “Draft Policies” – the Quarry Policy White Paper (2007) should be removed, as this policy was replaced; also, remove Minerals Policy Green Paper (2014) as this was developed into a National Mineral Policy White Paper (2015). Sec 2.11 pg 23 – Asphalt is considered a Mineral under the Minerals Act, Chap. 61:03 Annex II – pg 52: under “Draft Policies” – the Quarry Policy White Paper (2007) should be removed, as this policy was replaced; also, remove Minerals Policy Green Paper (2014) as this was developed into a National Mineral Policy White Paper (2015). The rest of the draft NAP looks OK. There are a few typos that you need to fix in the document.

Regards, Monty Beharry Director of Minerals

Section 2.11 (Minerals and Hydrocarbon Resources) Replace the first sentence with "It is Government’s policy that the exploitation of non-renewable resources in the form of minerals (e.g. sand, asphalt, and gravel) or hydrocarbons (e.g. petroleum or natural gas) shall be done in a manner as to ensure minimal impact to human health, livelihoods, cultural assets, sensitive species and ecological function." ANNEX II Remove from list of "Draft" policies: the Quarry Policy White Paper (2007) and National Mineral Policy White Paper (2015). Add to list of FINAL Policies: National Mineral Policy White Paper (2015).

Mr. Beharry is the Director of Minerals and has the most contemporary knowledge of the state of policies related to minerals.

NO. COMMENT APPROACH RATIONALE

BASEL CONVENTION REGIONAL CENTRE FOR TRAINING AND TECHNOLOGY TRANSFER FOR THE CARIBBEAN REGION

1 There is no mention of marine litter as an issue for Trinidad and Tobago. This is a huge issue for the country as well as the region. It would be remiss of the Government of Trinidad and Tobago not to include this issue.

Amend Section 2.04 (b) to include: “(b)(iv) Combat marine litter, inclusive of marine debris and micro-plastics, in accordance with the most current resolutions of the United Nations Environment Assembly. “

The intention of item (a) is to advocate for a single overarching policy regarding waste management, and thus it is not appropriate to isolate marine litter in this policy statement. Penalties for marine littering is also too narrow of a approach as most marine litter is born from non-point sources or from land-based sources outside of Trinidad and Tobago’s jurisdiction.

2 Suggest including examples of environmental issues including existing policy, laws and programmes that are specific to Trinidad and Tobago with regard to each section. The existing policies etc are simply listed in the Annex and not referenced. Existing policy and legislation determine actions.

Feedback noted. However, in consideration of established best practices concerning the nature of policy documents an alternative approach has been adopted. As such, no modification to the text has been made.

These items were removed from a previous version of the NEP since they were considered too specific for the NEP which is envisioned as a broad policy document. "The NEP Action Plan will address specific pieces of legislation where appropriate.

3 Suggest less repetitive phrasing of corrective actions listed in each section / sub-section and provide more relevance actions in Trinidad and Tobago itself. Perhaps a few examples, scenarios, etc. More specific action points will engage the reader and promote more enthusiasm or involvement.

Policy items that are appear redundant will be clarified, merged or removed as necessary.

Phrasing may appear to be repetitive because the language in the document is intended to be uniform and broad. Specific examples/scenarios were removed from a previous version of the NEP since they were considered too specific for the NEP which is envisioned as a broad policy document.

4 Suggest including anecdotal information, organizational involvement, ongoing projects in Trinidad and Tobago or case studies in boxes (as was in the February draft) relevant to certain sections to connect the issue being discussed to Trinidad and Tobago to add relevance.

Feedback noted. However, in consideration of other feedback received an alternative approach has been adopted. As such no modification to the text has been made.

Specific examples were removed from a previous version of the NEP since they were considered too specific for the NEP which is envisioned as a broad policy document. The highlighting of specific projects as case studies was greatly criticized by stakeholders in previous drafts as inappropriate. There was great concern that the selection of specific projects, etc. could be interpreted as politically motivated and thereby dampening the credibility of the document. It was widely agreed that anecdotal information, while interesting, provided unnecessary ‘waffle’ to the policy document which should be clear on actions to be taken. It was agreed that anecdotal information and case studies of projects related to NEP themes are better suited for educational materials rather than the policy document.

5 The NEP should have quantifiable quotas/targets for the country to work towards and to focus the actions that arise to address these issues.


The NEP Action Plan Framework provided in Annex III will include targets and indicators for assessing the success of policy statements contained in the NEP.

6 When mentioning ‘incentive programmes’ be more specific with details relevant to section or issue being discussed. Give examples.


These items were removed from a previous version of the NEP since they were considered too specific for the NEP which is envisioned as a broad policy document. Specifics can be included in the NEP Action Plan. The details of incentive programs require detailed, methodical consultations surrounding their development and governmental review. The development of incentive programs will be a key item in the NEP Action plan where it will be done in accordance with the principles of the NEP.

7 Be more specific when mentioning “amend existing legislation or develop new legislation” for each section. Add details relevant to issue being discussed and action to be taken.


Specific changes to legislation were set out in the Legal and Policy Review during Phase 1. This information is considered too specific for the NEP which is envisioned as a broad policy document. Specific legislation will be identified by sub-working groups of the NCSD as part of the development of the NEP Action Plan. Highlighting specific legislation in the body of the NEP may possibly limit the NEP’s effectiveness as some legislation may be excluded, or add to the volume of the NEP as there are many pieces of legislation that may be amended. Please note as well that item 3.01(e ) speaks to updating the Environmental Code. The Environmental Code is a thorough legislative review that identifies how all existing environmental legislation is to be harmonized/amended.

8 Be more specific with details relating to category being discussed when mentioning the point “Empower government entities with the responsibility…to effectively implement their mandate”


This information is considered too specific for the NEP which is envisioned as a broad policy document. Empowerment may come in various forms (E.g. improving institutional, administrative, technical, technological, financial, or legislative capacity) The specific needs may vary between governmental entities and it is impractical to list all entities or their specific needs. Consider as well that the challenges and capacity needs may change with time and it would be short-sighted of the NEP to isolate any specific areas. The specific details may be furnished in the development of the Action Plan, informed by requisite studies and consultation.

9 Format – suggest keeping the section separation page (with the picture) consistent throughout. Same font, wording or introduction on page as in Section 2, etc.

Fonts will be made consistent on chapter separation pages.

10 Priority 1: Protecting Environmental and Human Health through Pollution Control – Page 12-17 Suggest giving examples of top sources of pollution relevant to each sub-section in Trinidad and Tobago.


Existing text sufficiently indicates common sources of pollutants. Please note that ‘top sources’ may vary over time and such categorization may be subject to debate. Thus, greater specificity adds to the word count but would not add much more value to the content since the policy actions proposed cover the entire gamut of sources regardless of whether sources are named.

11 The Section on water refers to Convention that Trinidad and Tobago are part, however, there is no mention of MARPOL – International Convention for the Prevention of Pollution from Ships. Additionally, the section on Air Emissions and Ozone Depleting Substances does not reference the UNFCCC and Montreal Protocol (Vienna Convention). The conventions should be mentioned for consistency.

Section 2.01 – Water Pollution, introductory paragraph. “To this end, the GoRTT reaffirms its commitment to the Convention for the Protection and Development of the Marine Environment of the Wider Caribbean Area, the Land-Based Sources Protocol of the Cartagena Convention, International Convention for the Prevention of Pollution from Ships (MARPOL), and SDGs 6 and 12 which speak to water quality management. Accordingly, the GoRTT will:” Section 2.01 – Water Pollution. Add new policy action, 2.01 (q) “Develop guidelines and policies, as appropriate, to reduce impacts to water quality due to the activities of marinas, boatyards, and/or vessels.” Section 2.01 – Air Pollution, Introductory paragraph. “Thus, to abate the threats of air pollution, in alignment with SDG 3, SDG13, and the objectives of the Vienna Convention for the Protection of the Ozone Layer and the United Nations Framework Convention on Climate Change, the GoRTT will undertake proactive measures to address the sources and forms of air pollution within its national boundaries.”

12 2.02: Air Emissions from Land Use Change, Commercial and Industrial Activities, Pg. 14: i) Suggest mentioning which cleaner fuels can be incorporated into TT’s commercial and industrial activities where applicable or whether research should be done to determine this.


Research into the appropriate fuel, fit-for-purpose is implicit in 2.02(e ) “Encourage the utilisation technologies and techniques that minimise emissions, including odours, from land-use changes, commercial activities, and industrial processes” and 2.02 (m) “Ensure the development, access to, and use of cleaner and/or alternative forms of fuel for vehicles, vessels and aircraft”. Therefore no further adjustment to the document is necessary. It is not the NEP’s purpose to suggest ‘which cleaner fuels can be incorporated’, this is to be determined on a case by case basis, following requisite feasibility/cost-benefit studies at the discretion of the industry. Rather the NEP can broadly advocate that it is to be done.

13 2.02: Air Emissions from Motor Vehicles, Vessels and Aircraft, Pg. 14 Continued reduction of air emissions from motor vehicles will be achieved by: Identification and implementation of cost-effective measures to improve roadways, traffic controls and artery capacities to reduce congestion.

2.02 (o) “Implement cost-effective measures to minimize vehicular traffic congestion, particularly in major urban centers. “

We acknowledge that immediate shorter term measures can include improved efficiency of the existing transportation system.

14 2.04: Solid Wastes, Pg. 15 According to the EMA’s 2016 Report ‘An inventory of Wastes Generated in Trinidad and Tobago from 2013 to 2015’ it was noted that the Guanapo landfill received the largest quantity of household hazardous waste.

Feedback noted. However, no modification to text will be made since comment does not highlight an area in need of improvement.

- Inclusion of that information is considered to be unnecessary.

SDG goals related to waste are 1,2,3,7,8,12,14


- the word ‘waste’ is only mentioned under SDG 11.6, 12.3, 12.4 and 12.5.

Pg. 16: b) ii Include separation into “Facilitate proper handling, storage and disposal of waste.

Already included.

- ‘separation’ is innate to proper handling and storage. There is no need to include the word separation. - Source separation is inherent to all of the policy items under the recycling section. There is therefore, no need to include for added emphasis. The conduct of a CBA is better suited in the NEP Action Plan, if it is determined by NCSD sub-working groups that it is necessary.

Pg. 16 Suggest including measures that would be taken to regulate solid wastes, such as encouraging household waste separation (which will inadvertently be reducing waste to the landfill) and responsible disposal. Include “Conduct a cost-benefit analysis on developing and operating a waste management facility to separate hazardous and non-hazardous components from waste electrical and electronic equipment (WEEE), to treat hazardous wastes, and to package recyclable wastes for transport to recycling facilities. Educate the public on negative effects of improper waste disposal, flooding, health impacts, etc.

Amend policy statement k) under Recycling, Recovery and Reuse to: “Undertake, in collaboration with non-governmental organisations, private sector and community groups sustained public education and awareness campaigns that highlight the consequences of improper waste disposal and encourage prevention, reduction, reuse, and recycling, of waste”

15 2.04: Recycling, Recovery and Reuse, Pg. 16 Suggest making note of the waste hierarchy. Mention considerations for the recycling of liquid waste and reference can be made to Green Fund Executing Unit funded project “Development of a Waste Oil Management System in Trinidad and Tobago” being executed by the BCRC-Caribbean. http://bcrc-caribbean.org/download/public_project_documents/waste_oily/Development-of-a-Waste-Oil-Management-System-in-TT-Project-Summary-Sheet.pdf http://www.tv6tnt.com/sevenpm-news/Waste-Oil-Management-in-Tobago-417248213.html


This information is considered too specific for the NEP which is envisioned as a broad policy document.

16 2.04: Hazardous Substances and Waste, Pg 17: u) There is no reference to the Minamata Convention Include storage. Pg. 17

Suggest the support to develop an interim storage facility in Trinidad and Tobago. For some hazardous materials, such as mercury, there is no final treatment or disposal facility in the Caribbean and therefore the waste would need to be exported. However, the development of an interim storage facility would provide for the removal of the waste substances from societal use until safely exported.


The GORTT is not party to the Minamata Convention and until then, the NEP will not address Minamata Convention directly. However, the management of wastes containing mercury (e.g. lamps and other e-wastes) would be addressed through the other policy recommendations.


- 2.04 (u) and others have been removed, as those policy actions are encompassed in what was formally l(b), now 2.04 (m). Storage is inherent in proper handling.

http://bcrc-caribbean.org/download/public_project_documents/waste_oily/Development-of-a-Waste-Oil-Management-System-in-TT-Project-Summary-Sheet.pdf

http://bcrc-caribbean.org/download/public_project_documents/waste_oily/Development-of-a-Waste-Oil-Management-System-in-TT-Project-Summary-Sheet.pdf

Suggest providing identification factors for the public to understand and identify products containing hazardous material, the dangers associated and the suggested methods of separation and disposal.

Suggest including the strengthening of import regulations and identification of products containing hazardous material as well as developing regulations to ensure transparent labelling for products manufactured in TT that include hazardous material.

Support the consideration for upgrading the landfill in Forres Park to a specially engineered landfill which will increase the capacity to manage hazardous wastes in Trinidad and Tobago.

Hazardous Wastes: It should be noted that the largest type of hazardous waste is waste oils according to the EMA’s 2016 Report “An Inventory of Wastes Generated in Trinidad and Tobago from 2013 to 2015” it was reported that for both the 2003 and 2004-2008 inventories, waste organic solvents and waste oils were significant waste streams with waste oils accounting for 81% of all wastes reported in 2003. The Green Fund Executing Unit funded the BCRC-Caribbean project “Development of a Waste Oil Management System in Trinidad and Tobago which aims to improve the management and reduce the environmental and human health consequences of used oil and oily wastes. The kick-off workshop for the main activities of this project (which will include a pilot waste oil treatment plant in Tobago) was held in March 2017 in collaboration with Planning Associates Limited: http://www.tctnt.com/sevenpm-news/Waqste_oil-Management -in-Tobago-417248213.html http://www.bcrc-Caribbean.org/download/public-porject-documents/waste-oill/development-of-a-Waste-Oil-Management-System-in-TT-project-summary-sheet.pdf Action to be taken to improve the management of hazardous waste: Specialized projects are being developed to assess and address the issue surrounding the disposal of e-Waste at the nation’s landfill. “Before the export of hazardous waste, an application must be made to the Environmental Management Authority which in the Competent Authority for regulating the transboundary movement of hazardous waste” – this also refers to import under the Basel Convention.


- The suggestion for upgrading Forres Park is too specific for the NEP but can be addressed in the NEP Action Plan if deemed appropriate by the sub-committees of the NCSD.


Policy statements related to the management of hazardous waste imports have been amended based on feedback submitted by stakeholders and is believed to be sufficient.

Feedback noted. However, no modification to the text will be made since this topic/suggestion is already captured under an existing policy statement (s).

- The labelling of waste is inherent to the proper management of waste as covered by other policy actions.


- Additional information on the WOMS Project is not fitting for the NEP document.



17 2 – Priority 2 Sustainably Managing Natural Assets. 2.05; Water. Pg. 18: b) Water management programmes such as… (include more details).


The structure and content of a water management programme should be determined based on the resources available and specific local area context. Additional details can be furnished in the NEP Action Plan, but not in the policy.

18 Resource management. Pg. 18 Suggest including current issues in Trinidad and Tobago with regard to water management (e.g. certain rural areas may be experiencing shortages especially during dry season) and more specific action to address this. Ensure water is reliably distributed to all areas.

The introductory paragraph of 2.05 will be amended to read: “Trinidad and Tobago produces potable water from a system of wells, from surface impoundments, from river extraction and more recently from desalination. However, 24/7 access to potable water by all citizens is constrained by climate variability and infrastructure capacity….”

The various measures proposed contribute to water security across all areas. A policy item ‘ensure water is reliably distributed’ implicitly advocates for central distribution which may not be the best/most feasible approach for all communities.

http://www.tctnt.com/sevenpm-news/Waqste_oil-Management%20-in-Tobago-417248213.html

http://www.bcrc-caribbean.org/download/public-porject-documents/waste-oill/development-of-a-Waste-Oil-Management-System-in-TT-project-summary-sheet.pdf

http://www.bcrc-caribbean.org/download/public-porject-documents/waste-oill/development-of-a-Waste-Oil-Management-System-in-TT-project-summary-sheet.pdf

19 2.06: Soil/Land management. Pg. 19 Discuss soil contamination sources: harmful chemicals in pesticides etc. Suggest mentioning issues related to quarrying and squatters and recommended action to address this. Also mention impacts on humans and the environment that can arise (such as flooding, soil erosion, fragmentation) if the soil/land is not conserved.


Soil contamination sources do not need to be identified in the text as existing policy actions encompass all possible sources. Quarrying and squatting (unplanned settlement) are addressed in other sections of the document. While it is understood that all areas of the NEP are interconnected, the distinction between topics is necessary for brevity.

20 2.07: Biodiversity Management. Pg. 19 “general well being of all citizens” – be more specific; livelihood of those communities that depend on fish, agriculture and wildlife, job creation and economic sustainability, health benefits, etc. Including slightly more specific wording and relevance to Trinidad and Tobago will grasp the reader’s attention.


This is covered in the introduction and preface. Rehashing of the benefits of biodiversity here would be redundant and unnecessary

21 Pg. 20: i) Suggest including ‘youth’ in participation of conservation programmes. Include educational programmes and awareness on how the community/youth can get involved.

Amend Section 2.07, item (i) to read “Encourage the meaningful participation of non-governmental organisations and community-groups, especially those involving youth, in the conservation, management, monitoring and evaluation of biodiversity”

22 Pg. 20 Continuous monitoring of biodiversity is crucial to ensure that conservation efforts are appropriate. Include education and public awareness on sustainable hunting strategies and methods (best practices):


All measures proposed fall under the broader actions already listed.

Strengthen regulation on hunting out of season (include fines, security measures). Feedback noted. However, no modification to the text will be made since the feedback is better suited for consideration during the preparation of the NEP Action Plan.

These items will be noted for discussion during the formulation of the NEP Action Plan.

Suggest giving list of endangered species or ongoing conservation projects to connect the issues back to Trinidad and Tobago. Suggest adding examples for methods of conservation, remediation and restoring of species back into the wild.


A list of species/on-going projects is inappropriate for inclusion into the NEP.

23 2.07: Invasive Species Management. Pg. 21 Include anecdotal box on Giant African Snail or Lionfish to add connection to Trinidad and Tobago.


It was previously agreed that anecdotal boxes and case studies do not belong in the NEP.

Include definition or description of invasive species and the impacts they can cause to a community/the environment.

Amend the introductory paragraph of Section 2.07 IAS Management to read: “Invasive Alien Species (IAS) are those which are non-native to Trinidad and Tobago’s ecosystems, and which, when introduced may cause harm to human health, the environment and economy. The GoRTT recognises Trinidad and Tobago is vulnerable to the impact of IAS by nature of being a SIDS…”

Include measures to be taken to educate the public on identification factors of these invasive species and distinguishing factors for comparable local species.

Include policy statement v) as follows: “educate the public on identification factors of invasive species and distinguishing factors for comparable local species”

24 2.08: Coastal and Marine Area Management. Pg. 21 Describe/give examples of non-material benefits of coastal resources; spiritual, religious, recreational and cultural services, etc.


Non-material benefits are already established in the introduction.

Discuss briefly some important coastal and marine areas in Trinidad and Tobago, the benefits they give the people of TT and why and how we should conserve it.


Detail on local coastal areas is extraneous and better suited for educational/promotional materials rather than the policy document.

Discuss management of solid and hazardous waste that end up in these coastal waters – how to prevent this from happening as well as clean-up efforts (legislation, fines, monitoring, etc).


- The management of solid waste is covered in its own section.

Include “Regulation regarding indiscriminate dumping of materials into waterways by the public” Feedback noted. However, no modification to the text will be made since the feedback is better suited for consideration during the preparation of the NEP Action Plan.

The specific recommendation for regulations regarding dumping will be considered in the formulation of the NEP Action Plan.

Suggest discussing education/awareness programmes on the negatively impacting activities related to tourism and how this can affect the tourism industry in the future.


- Education on threats to tourism would be noted as an area for discussion in the formation of the NEP Action Plan.

Suggest including sub-section on management of coastal industries (energy, port, etc.). Feedback noted. However, no modification to the text will be made since this topic/suggestion is already captured under an existing policy statement (s).

Aspects of coastal industries are addressed across the document. The addition of a sub-section that is industry specific would only duplicate policy statements already listed.

25 2.09: Fisheries Management. Pg. 22 Include efforts to upkeep an inventory of fish species and numbers to ensure no over-fishing/over exploiting.


The actions suggested are captured under the existing, broader policy statements.

Enforce surveillance. Feedback noted. However, no modification to the text will be made since the feedback is better suited for consideration during the preparation of the NEP Action Plan.

These specific recommendations will be considered in the formulation of the NEP Action Plan.

26 2.10: Agriculture. Pg. 23 In keeping with consistency, label heading as “Agriculture Management” Include increasing awareness among consumers on small-scale and local agriculture. Suggest including subsidies on local produce to encourage sales as opposed to imported goods.

Section 2.10 to be renamed Agriculture Management Add policy statement: (g) “Undertake, in collaboration with non-governmental organisations, private sector and community groups sustained public education and awareness campaigns that encourage sustainable agricultural practices, and the consumption of locally-produced agricultural goods.”

Incentive programs are broadly advocated for under 2.13(b). Specifics on subsidies require broader national consultation and discussion and cannot be placed in the NEP. The formulation of the NEP Action Plan would elucidate more with regards to the need for subsidies and the form it takes.

27 2.11: Mineral and Hydrocarbon Resources, Pg. 23 In keeping with consistency, label heading as “Mineral and Hydrocarbon Resource Management”.

Section 2.11 to be renamed “Mineral and Hydrocarbon Resource Management”

Specific references removed from previous versions to reduce the length of introductory sections.

Suggest highlighting the pitch lake and its unique qualities as a mineral (asphalt) resource in Trinidad.


28 2 – Priority 3: Improving the Local Environment. 2.12: Planning and Human Settlement.

Policy Statement a) in Section 2.12 to be reworded as follows: “a)Take urgent action, as appropriate, to address and monitor unplanned, unregulated, and illegal settlement of state lands, particularly in areas of high environmental sensitivity, historical or cultural significance;”

Specific responsibilities for monitoring unplanned settlements will be highlighted in the NEP Action Plan

Pg. 25: a) “address and monitor unplanned, unregulated and illegal settlement”.


29 2.13: Green Architecture and infrastructure. Pg. 25 Describe some components and practices with regards to green infrastructure and what it entails. Definite it.


No further elaboration on green architecture and infrastructure is needed

Suggest mentioning LEED certification, what it entails and the Savannah East building to bring relevance to Trinidad and Tobago.

2.13(c ) already addresses sustainable design. It will be too prescriptive to recommend LEED specifically.

Suggest also bringing back the information on the TTGBC-Trinidad and Tobago Green Building Council. Adding information on ongoing projects show that TT is making an effort and that we can continue along this road.

Information on the TTGBC is not necessary for the NEP. The TTGBC will be part of the formulation of the NEP Action Plan regarding sustainable architecture and design.

Suggest supporting provision of subsidies to promote construction and investment in green building practices and infrastructure and investment in training programmes.


- Incentive programs are broadly advocated for under 2.13 (b). Specifics on subsidies require broader national consultation and discussion and cannot be placed in the NEP. The formulation of the NEP Action Plan would elucidate more with regards to the need for subsidies and the form it takes.

This section should include the need for considering the location of buildings as part of greening infrastructure. Measures should be taken to enforce regulations dealing with building on environmentally vulnerable areas like floodplains, hillsides, etc. Decentralization of infrastructure could also be considered as green techniques as it could reduce traffic congestion in addition to reducing the strain placed on the infrastructure and resources in overcrowded and overused areas communities.

Amend 2.13 (f) to read: “ (f) Ensure that all planned human settlements are designed to: i. Incorporate ‘green spaces’, with particular emphasis on areas of high hydrological significance; ii. Include community spaces that encourage healthy lifestyles; iii. Minimize the fragmentation of forests and enhance the connectivity of parks, forests and green spaces; and iv. Withstand and alleviate the impacts of natural disasters and climate change. Add policy statement 2.12(g) that reads: (g) Ensure that all planned human settlements, as far as practicably possible, are not: i. Placed on hillsides, within flood plains, or other areas highly vulnerable to natural disaster; ii. Placed within environmentally sensitive areas where development may threaten environmentally sensitive or endangered species; iii. Placed within hydrological significant areas where development may threaten the quality or quantity of critical water supplies; iv. Placed on land determined to be best suited for agricultural production.

Interconnected network of park systems could also be used as transportation infrastructure and for community health improvement.

Development of a Green Architecture/Infrastructure Policy should also include recommendations to redevelop the nation’s green spaces to serve water and transportation purposes.

30 2.14; Heritage, Cultural and Archaeological Sites. Pg. 26 Discuss briefly Trinidad and Tobago’s history and culture and mention important sites.


Description of culture and listing of sites is too extraneous for the document.

Include incentives for privately owned historical sites. - Add a policy statement 2.14 (f) that reads: “(f) Utilise market-based and alternative incentive programmes to ensure the maintenance and preservation of privately owned heritage sites.”

31 2.16: Mass transit Solutions. Pg. 27 Suggest including specific information on solutions, improvement, systems that will benefit the nation.


- Suggesting solutions is not the purpose of the NEP. Potential solutions and their merits would be explored in the creation of the NEP Action Plan.

Include improvements of roads and transportation access in rural areas.


- Improvement of infrastructure is already captured under 2.16(d)

Suggest encouraging the increased use new technologies for vehicles.


alternative technologies and fuels are touched on in the sections related to air pollution and climate change.

Improved transportation infrastructure on the whole should be addressed. Deteriorating roadways, low capacity major arteries, inefficient traffic controls and a lack of alternative transport options are some issues that should be addressed to decrease congestion and increase resiliency of transportation infrastructure.


- Specifics on the challenges to transport will be discussed during the formation of the NEP Action Plan.

32 2-Priority 4: Evolving a Greener Economy. 2.17; Economic Transformation. Pg. 28 Discuss the components and details of a green economy / circular economy and how it relates to TT. Make mention of sustainable development, renewable energy, issues TT may face to implement components of a green economy and the benefits to TT specifically if the country makes this developmental change.


Items proposed redundant with introduction and other areas of document.

33 Priority 5: Fostering an Environmentally Responsible Society. 2.18: Availability of and public Access to Information. Pg. 29 Increase the awareness that environmental information is available and accessible for the public especially in rural communities.


The promotion of methods to access environmental information is already captured under 2.18 (b).

Need to highlight the fact that adequate environmental information is not recorded and that measures for consistent data collection should be implemented.


Consistent data collection will be addressed in the NEP Action Plan.

34 2 – Priority 6: Addressing Climate Change and Environmental Disasters. 2.22: Climate Change Mitigation and Adaptation. Pg. 32


Specific references on incentives removed from previous versions since the NEP is intended to be a broad policy document.

Suggest including the support for incentive programmes (with details) and subsidies to incorporate energy efficient technology and/or renewable energy.


Specific incentive measures to be discussed in the formulation of the NEP Action Plan.

35 2.22: Energy Efficiency and Energy Conservation. Pg. 33 Increase education and awareness on at-home/office energy conservation practices.


Already covered under existing policy statement o).

36 2.23: Renewable Energy Suggest mentioning the support for implementing capacity for Feed-in Tariffs.


Specific suggestions on feed-in-tariffs can be included in the NEP Action Plan.

37 2.23: Comprehensive Environmental Disaster Management. Pg. 35 Suggest mentioning the development of a contingency plan for the managing waste in the event of a disaster – environmentally sound disposal of disaster debris.


Already captured under 2.04 and 2.23.

Cathal Healy Singh

38 This is the 3rd iteration of national environmental policy development. The first NEP was approved by parliament in 1998 according to Section 18 of the Environmental Management Act (1995). The 2nd NEP was prepared in 2005 and approved in 2006. The Environmental Management Authority of Trinidad and Tobago commissioned local consulting company “Eco-Engineering” (EE) to revise the 2006 National Environmental Policy and to create an updated 2018 NEP. EE is well known to the EMA. Its core business is submitting applications for Certificates of Environmental Clearance (CECs) to the EMA on behalf of developers whose actions are likely to have significant environmental impacts. According to the EMA, EE was the sole responder to the invitation for bids to undertake this assignment. The Terms of Reference (TOR) for the revision requires EE to: (i) review and analyse the existing NEP (2006) with regard to its implementation over the last 10 years, (ii) review the extent to which the described objectives have been met, (iii) determine the positive and negative effects the NEP had on the environment and, (iv) conduct a policy, institutional and regulatory gap analysis related to the NEP. The revision included engagement of three “specialists and “distinguished persons”. Comments from EMA Technical Staff and Board were also received. Eleven Focus Group meetings were convened by EE to solicit the views of environmental groups and relevant state agencies. Nine open Public consultation events were hosted to receive comments on the prepared draft 2017 NEP. Consultations were held during the week starting at 6pm, over several months. The Administrative Record did not include numbers of participants. I made a request to view the Record as only the draft policy document was available on the EMA’s website. I am grateful that the EMA granted my request as it allowed me to see what other stakeholders had contributed to the consultation process. I must say however, that my own comments made at the POS consultation were very poorly recorded by EE, with most of what I said omitted. I am not sure it is fair to say that this might be the case for other contributors. My review of the record forms the basis for my comments. They are made in a language I hope everyone finds accessible and easy to understand. Those of you who take the opportunity to review my comments, I hope if you agree, that you will disseminate them through your networks. A final draft of the NEP is currently in the public domain for final comment by December 15th 2017. The EMA Board will submit the finalized NEP (2018) to the line Minister, who will present it to Parliament for ratification.


This wording provides a background to the process of amending the NEP and commented on the author’s contribution during the public meeting in Phase 2. The consultant was tasked to provide of a summary of issues to be addressed rather than a detail transcription of feedback. Complete audio of all consultations was captured and is available for the public to review review at the EMA's Information Center, 8 Elizabeth Street, POS.

39 The 1998 NEP recognized that T&T suffered from environmental problems associated with production of petroleum products and acknowledged that resource exploitation had been characterized by the search for short-term economic gain with little attention paid to long-term sustainability. According to the 1998 NEP, development was to be conservation-based. Renewable resources like soil, wild and domesticated organisms, forests, agricultural lands and marine and freshwater ecosystems were to be used sustainably. Non-renewable resources like oil, gas and minerals were to be conserved and optimally used to obtain the best possible benefits to all citizens and without impairing the value of other resources. By 2006, the Government was duty bound to ensure that T&T found the right balance between economic development and environmental conservation. The Government’s focus was now on sustainable management of the country’s assets rather than on the narrower concept of environmental protection, which tends to bring into conflict environment and development. The latest version of the draft 2018 NEP opens with “Wise use of the environment is compatible with economic and social development. Wise use is the cornerstone for ensuring that the needs and interests of present and future generations are met. It goes on to assure us that a healthy and sustainably managed environment enables foreign investment, job creation, security and enjoyment of property. Later on, the draft 2018 NEP declares “development and the pursuit of peace, justice and strong institutions in T&T must be done in a manner that strives to balance social, economic and environmental considerations. It is clear that a policy shift from the 1998 environmental “conservation” approach and the narrower concept of “protection” was replaced in 2006 by an attempt to strike a “balance” between economic growth and environmentally sound practice. In 2018, “wise use” assures a sustainably managed environment and that development must strive to balance not just economic and environment but also social considerations.


These words provides context to the question asked below

40 The 2018 NEP, if it is to in any way stem the tide of destruction we have already wrought upon ourselves and allow us to turn the proverbial corner, onto a path of sustainable development in T&T, it must include a bold commitment to ensure that the CEC decision making process itself, is open to and capable of assessing the full social-economic-ecological impacts of major development decision making.


This specific suggestion can be addressed in the NEP Action Plan

41 Alarmingly, the draft February 2017 NEP put out for public consultation contained no energy clause despite mentioning “energy” 98 times. It is a glossy document very different from the first two, full of ‘feel good’ colour pictures of intact natural spaces.


The 2006 energy policy statements ("energy clause") were not transcribed verbatim in the preparation of the 1st draft revised NEP. The central idea of the former statements are still reflected in the revised policy statements listed under Section 2.11 of the Second Draft NEP.

42 What both the 2006 and draft 2018 NEPs do not do is to continue to acknowledge that short-term gains from resource exploitation (especially oil and gas) compromise long-term sustainability. This may be a mistake since revenues gained from this exploitation are still not being directly invested in economic diversification especially towards self-sufficiency in food production, renewable energy, long-term water security, poverty alleviation and bottom-up investments to give the disadvantaged meaningful economic opportunities. The 2018 NEP does not adequately acknowledge this current challenge. It seems as if the EE took some note of my comments at the POS public consultation. However, what is presented in the draft 2018 NEP is a watering down of the 2006 NEP. While it does place the responsibility for conducting cost-benefit analyses into the TORs for the EIAs, it is not supported by systematic assessment as previously required in 2006. Final TORs are formulated with inputs from both the EMA and the applicant. It is unlikely that the EMA will commence doing this as it has never done so before despite its 2006 policy commitments. I would like to see the 2006 Energy Clause stand and welcome the proposed addition.

Amend Section 2.11 as follows: The GoRTT recognizes that the over-dependence on the exploitation of finite mineral and hydrocarbon resources is not a sustainable long-term strategy for national prosperity. However, the prudent use of these resources remains a critical component for economic growth and social development in Trinidad and Tobago. It is Government’s policy that the exploitation of non-renewable resources in the form of minerals (e.g. sand, asphalt, and gravel) or hydrocarbons (e.g. petroleum or natural gas) shall be done in a manner as to ensure minimal impact to human health, livelihoods, cultural assets, sensitive species and ecological function. Acknowledging that the exploration, extraction and processing of these materials often entail unavoidable environmental impacts, the GoRTT will: a) Encourage and support educational institutions, non-governmental organisations and private sector entities in undertaking a systematic assessment into the true cost of mineral and hydrocarbon exploitation for the purposes of selecting ventures that are most socially, environmentally and economically sustainable; b) Strengthen existent, or develop new institutional and regulatory regimes, as necessary, to support the wise use of primary energy resources for sustainable development based on Full Cost Accounting Practices; c) Utilise Environmental Impact Assessments (EIAs), and cost-benefit analysis to: i. Inform the decision-making process regarding projects that may have significant environmental impacts or where there is great uncertainty regarding potential impacts; and ii. Inform mitigation measures for projects that receive approval. d) Ensure that all stakeholders likely to be impacted by the exploitation of minerals and hydrocarbon resources have meaningful participation in the process of developing social and environmental safeguards. e) Ensure all extractive projects employ the best available technologies and mitigation strategies not exceeding excessive cost that have been historically effective at minimising environmental impact in Trinidad and Tobago or similar jurisdictions; f) Ensure the use of progressive rehabilitation at mining sites;

The government of the Republic of Trinidad and Tobago is committed to the sustainable use of its mineral and hydrocarbon resources for the economic growth of the country. The point is well received that on-going research needs to be done regarding the true cost or full cost of finite resource exploitation. The GORTT encourages research and private sector institutions to undertake this type of assessment to guide future energy sector ventures. The Environmental Impact Assessment process, by nature, can be used to account for the environmental and social cost of mineral and hydrocarbon resources. In Trinidad and Tobago, the EIA process is tied to the CEC process and as such, can be used to halt unsustainable projects as well as mitigate the impact of approved projects.

g) Amend existing legislation or develop new legislation, as necessary, to: i. Modernise fiduciary instruments and fees associated with site rehabilitation; ii. Mainstream the use of asset integrity management systems in extractive industries. h) Empower government entities to better undertake their mandates with respect to the regulation, monitoring and evaluation of mineral and hydrocarbon exploitation projects by way of enhanced technical, financial and human-resource capacity development; and i) Ensure that industries responsible for environmental disasters or significant impact to human health bear the complete cost of reconciliatory action, rehabilitation and restoration.

43 I hope it is clear that in finalizing the 2018 NEP, previous policy commitments associated with regulating pollution control and awarding CECs be scrutinized. Where deficiencies are found, the 2018 NEP should be strengthened to address them.


Pollution control policy statements are included in Sections 2.01, 2.02, 2.03 and 2.04 The specific suggestion related to CECs can be addressed in the NEP Action Plan.

44 Unacceptably, the 2018 NEP does not seek to redress enforcement failure nor provide new policy will to make improvements. Surely, our 2018 NEP should underscore the need for acceleration of the legal instruments to have these inadequacies, major issues and lack of enforcement addressed.


Amendment of legislation has been recommended in most sections of the revised NEP. Suggestion related to enforcement can be addressed in the NEP Action Plan.

45 Surely, given the new MEAs that T&T has signed since 2006, especially the Paris Climate Change Agreement (2016) and the longstanding failure to fulfil MEAs dating back to the 1970s, the public has every right to expect that the 2018 NEP makes specific commitment to enact all signed MEA as a matter of public priority or at the very least, make some form of commitment to do so. It would not be acceptable to leave them listed in an Annex of the 2018 NEP.


It is explicitly stated throughout the draft revised NEP that the GoRTT is committed to fulfilling the objectives of all MEAs to which they are party.

46 The 2018 NEP must therefore, acknowledge the imperative of “water security” giving primacy to natural sources and not to desalted seawater, which is vulnerable to oil spills, persistent pollution off Point Lisas and ultimately illogical as a public water supply source in a water rich islands like T&T.

Already addressed by existing policy statements in Section 2.05 while water pollution issues are addressed in Section 2.01.

General policy statements address these issues as noted. More specific targets and indicators will be addressed in the NEP Action Plan

47 Finally, issues like water security reinforce the need for the retention of cost-benefit analysis as a core policy principle and in doing so; ensure such analyses are required of all TORs in the determination of CECs for further allocation of fossil resources, promoting food and energy security and land use allocations, especially when high lost opportunity costs are apparent.


Specific suggestions on the CEC Process and Cost Benefit Analyses can be addressed in the NEP Action Plan.

48 Interestingly the concept of “Carrying Capacity” has not only been dropped as a specific objective and a basic principle in the draft 2018 NEP, it has been removed altogether. Again, this is astounding and demands an explanation from the EMA.


The core concept of carrying capacity is that there are limits to what the earth’s systems are able to tolerate. Even though the precise tipping point or threshold is nebulous, it is still recognized that we must act with precaution and pursue development responsibly. It is believed that this message is adequately embodied in the Precautionary Principle and the Prevention Principle of the draft revised NEP.

The de-emphasis of the term ‘carrying capacity’ is intentionally done because it inspires a false belief that there is a ‘magic number’ of development or pollution that we can achieve before there are problems, however there is a wealth of scientific literature that indicates that our best estimates of determining carrying capacity is always underestimated. This has prompted many to propose alternative models for quantifying the concept such as Limits of Acceptable Change (LAC), Planetary Boundaries, and Ecological Foot Printing. All of these models provide good illustrative tools but also have their flaws. As such any declaration of a limit can be open to scientific and legal challenge. From a regulatory perspective, by committing that development be guided by an incalculable number, it effectively renders the regulation of development impossible. Ironically, ‘carrying capacity’ can then be used to justify unmitigated development since there is no science-based consensus as to what the limits are. As such, it was believed best to drop the controversial terminology while maintaining the essence of the concept in the other included principles.

49 I would advise the CEO of the EMA to consider this suggestion carefully as it sounds like a recipe for more bureaucracy and an avenue for more political interference. Technocrats have failed to act independently of politicians. Politicians are widely deemed corrupt. What I would like to see is an immediate establishment of the NCSD giving prominence or at least parity to civil society representation, especially from uncompromised organizations that have functioned at the grass roots and demonstrated longstanding commitment to public interest matters. Hence, the 2018 NEP needs to emphasize public interests over technocrats.


The composition of the NCSD is clearly outlined in section 3.02. “The NCSD will provide a forum for Government, business and civil society to have ongoing oversight with advisory functions to the Action Plan. The composition of the NCSD will, at all times, also reflect the tenants of the principle of Good Governance; ensuring, inter alia, the meaningful involvement of women and youth.”

50 Finally, the most recent national environmental literacy rates published in 2016 by the EMA alarmingly reveal that only 2% of the national population is even aware that a National Environmental Policy exists. This in my view is a public interest crisis. If the 2018 NEP does not in fact “belong to the people” and is perceived to belong to the “1%” (special interests) and their attendant politicians, then the 2% who are actually aware of not only of its existence but its inherent weaknesses (including technocrats), may become increasingly apathetic and disillusioned. The other 98%, especially the youths, already feel betrayed and even angry at how a place as rich and blessed as we once were, could have succumbed to so much crime, corruption, pollution and poverty. Any NEP will remain insignificant to them unless it is crafted to serve their very best interests.


The EMA acknowledges the results of the literacy survey. This issue will be addressed in how the EMA promotes the revised NEP and other environmental documents.

INTITUTE OF MARINE AFFAIRS

51 Section 1.02, page 4, paragraph 1 The integrated solid waste management policy should not be included in this list as it is still in draft and has not been ''established" as yet. Along these lines, has the recycling policy been adopted?

“Integrated solid waste management” will be removed from Section 1.02, page 4, paragraph 1 as recommended.

The recycling policy has been adopted. No changes to be made to Annex II.

52 Section 1.05, page 6 This is a good list of environmental governance principles. It may benefit from the inclusion of additional principles, which are implicit to the draft NEP but are not explicitly mentioned in this list. These include: - Science-based decision making. - Adaptive management. - Ecosystem based approach (EBA) and Ecosystem based management (EBM). - Stewardship of the global environment.


Adaptive management and EBA/EBM are not principles, but rather, techniques. These techniques may embody principles but are not environmental principles in of themselves. Science- based decision making and global stewardship are implicit in the already listed principles and need not be further elaborated upon.

53 Section 1.05, page 7 Given the recent ruling by the Privy Council on the Water Pollution Rule, the section on the polluter pay principal would have to be revisited. What national standards is this section referring to?

The text of the Polluter Pays Principle will be enhanced for additional clarity as follows: The cost of preventing pollution, minimising environmental damage due to pollution, and/or compensation for damages due to pollution, shall be borne by those responsible for the pollution. Important elements of the application of this principle are: Charges are levied as: An application or processing fee proportional to the administrative cost of preparing a license or permit; and A purchase price of a licence or permit proportional to the quantities/ concentration/ amount of pollutants which the holder is entitled to generate, or to the best approximate of the total social cost of polluting activities undertaken; Charges are levied for compensation and damages associated with pollution in exceedance of national standards, or permitted amount; and Money collected will be used to correct environmental damages and enhance the pollution management framework.

The national standards refer to any standards including but not limited to the WPR. The recent Privy Council ruling does not impact the text of this section since the section highlights the broad aspects of this principle which remains unchanged by the judgement.

54 Section 2, foreword page This makes mention of "concerns described in Section 1.2" but this section does not exist in the Draft document.

The paragraph after bulleted list on forward page for Section 2 to be amended to remove the following sentence: “The concerns described in Section 1.2 must be given increased priority, in recognition that long-term economic growth, social transformation, poverty reduction and environmental sustainability are inter-linked.”

This sentence is no longer considered relevant since the previous section 1.2 was revised.

55 Section 2.01, page 12, paragraph 1 SDG 14 should be included alongside SDGs 6 and 12.

First paragraph in Section 2.01 will be amended to include SDG 14.

56 Section 2.01 Making some of these objectives SMART may be challenging because of the language/phrasing used. For example: - In (b), while the intention is noble the phrasing is not realistic, especially when referring to "water quality in any area" if this is tied with the absolute qualifiers used in, for example, b(i), (ii) and (viii). -In (c), what is the meaning of "pristine state"? -In (d), what water quality criteria is being referred to?

Policy statements in Section 2.01 will be reordered to allow for better flow. For example, policy statement k) should be listed before d)

A list of definitions was included in a previous version of the NEP. However this was not considered suitable for a policy document. It is noted that the operationalization of this policy statement will be challenging.

57 Section 2.01, page 13 Bullet point (j) should not be included in the NEP. This should be a prescription coming out of WASA/the IWRM Policy. Adequately treating water to be distributed to the public is not an environmental issue.


This policy statement is aligned to SDG 6 and adequate and safe drinking water is an environmental issue.

58 Section 2.02, page 14, Air emissions from motor vehicles, vessels and aircraft In bullet point (k) mention should also be made of developing efficient mass transit systems.


Mass transit systems included as Section 2.16

60 Section 2.04, page 17, Hazardous Substances and Wastes Are bullet points (r) - (y) already government policy? If they are, then there is no need to include them in the document. This level of detail in the procedures to manage hazardous substances and wastes is not in-keeping with the format applied to the rest of the document. Are these points not already implied in point (l)(a) and (l)(b)?


This section has already been significantly reworked based on feedback received from other commenters and these concerns have been addressed.

61 Section 2.07, page 19 SDG 14 should be included alongside SDG 15. Also the United Nations Convention on Law of the Sea (UNCLOS) should be listed in (a)(i) as it explicitly speaks to and addresses marine biodiversity conservation.

First paragraph in Section 2.07 to be amended to include SDG 14. Policy statement a) to be amended to include UNCLOS

62 Section 2.08, Page 22 Recommendation is that there should be 'no net loss of wetland functions and value' on publicly owned wetlands and waters. The function and value of a wetland is quite site specific, for instance, the function and value of a wetland in Mucurapo is different from the Caroni Swamp based on location, size, etc. - In bullet point (b) - It should be established that an Integrated Coastal Zone Management Policy, Strategies and Action Plan are to guide management and restoration of the coastal zone. -In bullet point (c)- The National Wetlands Policy (2001) needs to be updated before enabling the prescribed activities. This point should be made. - In bullet point (d) - Amend existing legislation or develop new legislation, as necessary, to establish and enforce building set-backs from shorelines and coastal wetlands.

Feedback noted. However, no modification to the text will be made since this topic/suggestion is already captured under an existing policy statement (s). Bullet points under Section 2.08 to be amended as follows: (b) Establish an Integrated Coastal Zone Management Policy, Strategies and Action Plan are to guide management and restoration of the coastal zone. (d) Amend existing legislation or develop new legislation, as necessary, to establish and enforce building set-backs from shorelines and coastal wetlands. Move d) to before c) to allow for better flow, such as reference to National Wetlands Policy

The National Wetland Policy is cited without a year deliberately so that the policy action applies to the most recent iteration of the document.

63 Sections 2.09 and 2.10, pages 22 and 23 These sections could be viewed as other examples of overreach of the NEP. The NEP is making prescriptions about Fisheries and Agricultural Policy in these sections e.g. speaking to development of aquaculture and encouraging sustainable agricultural processing and food production. It may be more important for the NEP to speak to minimizing the environmental impact of these sectors. For example, in fisheries, reducing overfishing and levels of by-catch. How the sectoral managers go about doing this (e.g. through developing aquaculture and moving away from wild caught fisheries) is not for the NEP to prescribe. In agriculture, much of what needs to be spoken to is addressed under Section 2.06.


Including these policy statements in an overarching document such as the NEP is intended to then guide more sector specific policies. These policy statements are guided by stated Government objectives.

64 Section 2.11 is a good example of addressing the environmental impacts of a sector without overreaching into prescribing how that sector is developed and managed.


65 Section 2.09 Fisheries Management. Fisheries is important both economically and socially for many of our coastal and rural communities. Fisheries resources exploited include finfish, shrimp, lobster, crab and shellfish (oysters, conch, mussels, and chip chip). Whilst the status of many freshwater resources is unknown, numerous assessments suggests that most of our marine fisheries resources are either heavily exploited or over exploited. The sustainable management of these resources is hampered by a number of factors including outdated legislation, an open access regime, high by-catch discards, illegal fishing, fishing subsidies, inadequate monitoring and enforcement of regulations and the lack of accurate data on fisheries. The development of the fisheries sector has an important role to play in long term food security, employment and development hence sustainable fisheries development needs to strike a balance between protecting the resources and its environment and meeting social and economic demands. In order to achieve the fisheries relevant targets of SDGs 12 and 14, The Government of Trinidad and Tobago proposes the following policy actions: a) Develop a National Fisheries and Aquaculture Sector Policy to guide the strategic development and growth of this sector. This Policy will be in harmony with internationally accepted principles and guidelines for promoting the sustainable development of fisheries and aquaculture. These include but are not limited to:

The FAO Code of Conduct for Responsible Fishing.

An Ecosystem Approach to Aquaculture as outlined in the FAO Technical Guide for Responsible Fisheries.

An Ecosystem Approach to Fisheries and Aquaculture. The Blue Growth Initiative. b) Review and amend existing legislation, regulations and guidelines to improve data collection and facilitate the implementation of appropriate technical measures for sustainable fisheries management c) Develop and execute, in collaboration with national stakeholders, programmes to give effect to the CAR/COM Community Common Fisheries Policy d) Promote participatory governance by strengthening the capacity of coastal communities for community based management of fisheries resources e) Utilise market-based solutions and alternative incentive programmes to integrate more sustainable practices into the fisheries sector f) Encourage the development of the aquaculture subsector g) Mobilise resources, or seek global partnership for the mobilization of resources, towards pollution prevention and coastal ecosystem protection measures likely to safeguard critical fish stocks h) Empower government entities to better undertake their mandates with respect to the management of fisheries and aquaculture by way of enhanced technical, financial and human-resource capacity development; and i) Encourage educational institutions, non-governmental organisations and private sector entities to engage in research relevant to fisheries and aquaculture j) Bullet c (b)- increase resilience to the impacts of climate change, pests and diseases

Replace the existing text in Section 2.09 with the following: “Fisheries resources exploited in Trinidad and Tobago include finfish, shrimp, lobster, crab and shellfish (oysters, conch, mussels, and chip chip). The sustainable management of these resources is hampered by a number of factors including outdated legislation, an open access regime, high by-catch discards, illegal fishing, fishing subsidies, inadequate monitoring and enforcement of regulations and the lack of accurate data on fisheries. The development of the fisheries sector, inclusive of ornamental fish trade and aquaculture, has an important role to play in long term food security, employment and economic development. It is also recognized that for many coastal communities that depend on fisheries and marine resources, a thriving fishery is a core component to their livelihoods, traditions, and cultural identity. Government’s policy is therefore that all fisheries will be managed in a sustainable manner. Accordingly, in keeping with SDGs 12 and 14, the GoRTT will:

Develop a National Fisheries and Aquaculture Sector Policy aligned with internationally accepted principles, guidelines and the CARICOM Common Fisheries Policy, to guide the strategic development and growth of this sector;

Review and amend existing legislation, regulations and guidelines, as necessary, improve data collection and facilitate the implementation of appropriate technical measures for sustainable fisheries management;

Develop and execute, in collaboration with national stakeholders, programmes to give effect to the CARICOM Common Fisheries Policy;

Promote participatory governance by strengthening the capacity of coastal communities for community based management of fisheries resources;

Utilise market-based and alternative incentive programmes to integrate more sustainable practices into the fisheries sector;

Encourage the development of the aquaculture sub-sector;

Mobilise resources, or seek global partnership for the mobilisation of resources, towards pollution prevention and coastal ecosystem protection measures likely to safeguard critical fish stocks;

Empower government entities to better undertake their mandates with respect to the management of fisheries and aquaculture by way of enhanced technical, financial and human-resource capacity development; and

Encourage educational institutions, non-governmental organisations and private sector entities to engage in research relevant to fisheries and aquaculture.

Encourage the use of ecosystem based approaches for enhancing the resilience of the fisheries sector to the effects of climate change, pests and diseases. “

The proposed text has useful components that should be integrated into the document.

66 Priority 3: Improving the local environment, page 25 Mention should be made of development and use of marine spatial planning to better manage ocean space. Planning where activities take place in the oceans and allocating space for particular users and uses will reduce conflict and can see the ocean and its resources used more sustainably and coherently. Planning within the context of this priority focuses too narrowly on planning human settlements.

Include a policy statement in Section 2.08 as follows: “Develop capacity in Government agencies towards the development and use of marine spatial planning to better manage ocean space.“

It is agreed that marine spatial planning is important. However, it is believed that such a policy statement is better suited to Section 2.08.

67 Priority Area 4: Evolving a Greener Economy, page 28 This Priority Area does not include a number of relevant topics and approaches that warrant consideration, development and implementation .Among these are:

The circular economy (related to recycling and waste to energy projects)

The Blue Economy (supported through the implementation of ICZM, Marine Spatial Planning etc.)

Decentralization in the provision of goods and services (aligns to sustainable cities and communities)

Phasing out perverse environmental incentives e.g. fuel subsidy, subsidies on pesticides etc.

Better identifying and internalizing the current externalities in production of goods and services.

Developing, or getting involved in established carbon trading schemes

Instituting formal arrangements for payment of ecosystem services.

Developing cultures of corporate social and environmental responsibility.

Priority Area 4 text amended as follows: The GoRTT recognises that the growth of a greener economy shares parity with environmental conservation and fosters an environmentally responsible society. Integrating environmental considerations into the way business is conducted reduces economic vulnerability and drives economic growth. Greening the economy is therefore a means to strengthen the country’s economic performance through the introduction of new value added economic activities, increased efficiency across all sectors, reduction of waste, and the generation of green jobs. Towards this end, the GORTT will: a) Mainstream the policy targets of this NEP and Action Plan into codes of conduct, voluntary agreements and codes of practice; b) Develop responsive and accessible financial support programmes for the private and non-governmental sector; c) Improve the national system of market-based economic instruments through measures that include, but are not limited to,: i. Phasing out perverse economic incentives which result in unintentional impacts to the environment; ii. Internalizing the negative environmental externalities in the production of goods and services by way of taxes and levies; iii. Developing markets based on the trading of pollution/emission licenses or credits; iv. Providing conditional payments for the voluntary protection of ecosystems and their services; and v. Developing deposit-refund systems that reward behaviours that abate pollution. vi. Developing subsidies and tax-breaks for environmentally responsible behaviours.

These suggestions are considered too specific to the NEP which is intended to be a broad policy document. Some of these suggestions are more appropriately addressed in the NEP Action Plan.

d) Enhance the existing legislation and body of standards for goods, services and activities in Trinidad and Tobago; e) Invest in human resources through education and skills training to facilitate the shift from ‘brown’ to ‘green’ jobs; f) Develop incentives to attract foreign direct investment as well as investment from the Caribbean diaspora; g) Encourage the growth and development of a circular economy in which waste is revalued and resources are recirculated locally as much as possible; h) Support the growth and development of alternative economies compatible with a greener economy including but not limited to: i. A “Blue Economy” based on the sustainable use of ocean resources; ii. A “Silver Economy” based on leveraging ageing populations and their needs to stimulate sustainable economic growth. To catalyse the growth of a greener economy, the GoRTT further commits to harmonising the regulations of the national environmental fund with this NEP by 2020 to enable the timely financial support of activities related to the NEP policy statements and strategic priorities identified in the Action Plan. Special emphasis will be given to programmes and projects that advance low-emissions development, enhance community resilience to natural disasters, and those in which private capital can be raised with additional public financial support. The revitalized economy will generate economic prosperity across Trinidad and Tobago, but especially in communities where income is generated through the direct or facilitated use of the environment. Whereas government’s actions will create the enabling environment for economic transformation, the private sector will be the innovators and leaders for creating socially-just and environmentally responsible employment opportunities. The GORTT will: i) Ensure that multi-national corporations operating in rural and/or coastal communities to exercise corporate-social responsibility through: i. The provision of employment opportunities for suitably qualified members of the community; ii. The provision of training, internship or mentoring opportunities aimed at improving the skills and qualifications of members of the community for future employment or entrepreneurship; j) Support entrepreneurial efforts aimed to address environmental issues, or foster economic prosperity in an environmentally responsible manner.

68 Section 2.23, page 35 This section does not adequately speak to maintaining features of the environment that provide protection and increased resilience in the face of natural disasters, especially those disasters that would be exacerbated by climate change. While creation of Emergency Response Plans, especially as relates to chemical and hydrocarbon spills, are important (and are exhaustively covered), maintaining environmental features such as mangroves, coral reefs and wind belts are also integral to comprehensive disaster management as it relates to mitigation of the effects of climate disasters.

Include a policy action in Section 2.23: “Enhance ecosystem-based measures to alleviate the impacts of natural disasters and climate change including, but not limited to the establishment, conservation and/or restoration of forests and coastal ecosystems. “

69 Section 3.01, page 38 In addition to the critical success factors identified, this section should also speak to filling legislative gaps. Also, under the "Strengthening mechanisms for compliance with the NEP and environmental legislation" category, improving enforcement capability of regulatory agencies needs to be addressed.


These specific recommendations are better addressed in the NEP Action Plan

MR. STEVE JAMES

70 “How does the NEP provide an easy roadmap for ordinary citizens to be able to raise such matters for investigation and resulting action (efficient enforcement if necessary) without the citizen having to bear the burden of time and costs including potential reprisal.”


The draft revised NEP does not detail a complaint investigation process. The NEP creates the enabling framework for fostering a more environmentally responsible society, greater compliance with environmental regulations, and the detection and enforcement of environmental breaches. Under the principle of “Good governance” it states “the GoRTT, all sub-national actors and international actors operating within the State’s boundaries shall adopt/maintain, where appropriate, the features of good governance required to galvanise environmental sustainability, including but not limited to… the right of every citizen to expose any environmental or health hazard without fear of reprisal.” This means that governmental entities responsible for enforcement establish and maintain procedures to ensure your confidentiality. Section 2.21 (Access to, and Implementation of Environmental Justice) gives the government’s commitment to developing systems for detecting, investigating and resolving environmental conflicts. Section 3.01 gives the government’s commitment to “Strengthening mechanisms for compliance with the NEP and environmental legislation”

71 “Do government entities possess the competence (expertise and tools) to assess and evaluate plans prior to granting approval for such projects? How is EMA policy and T&T law integrated here?”

Feedback noted. However, no modification to the text will be made since the feedback is better suited for consideration during the preparation of the NEP Action Plan.ed

Yes, government entities do possess the competence (expertise and tools) to assess and evaluate plans prior to granting approval for businesses. However, capacity can always be improved among the agencies, laws tightened to close ‘loop holes’ in the permitting processes, and education and outreach improved so that all are aware of what needs to be done. The draft revised NEP advocates for all of these things broadly throughout the document. The specific ways in which capacity will be built and the specific laws to be improved will be determined in the creation of the NEP Action Plan.

72 “Where can we easily find clarity for land and building use designations such as “Mixed Use”, and how is “Mixed Use” development made sustainable with all stakeholder input?”


Land designation falls under the purview of the Town and Country Planning Division (TCPD). You may approach them with future inquiries. “Mixed Use” is made sustainable by ensuring that approval processes are considerate of all stakeholder feedback. Section 1.19 (Communication, Awareness and Public Participation) reaffirms the government’s commitment to “Ensure that mechanisms established for meaningful participation in decision-making regarding environmental and/or development issues are appropriately promoted, and made available to the public.” Through public-participation in decision making, it is believed that all environmental and human health concerns can be successfully managed.