Survey: substantial improvements needed in licensing, supervision and enforcement (VTH) for building, the environment and nature in the Caribbean Netherlands

The implementation of licensing, supervision and enforcement (VTH) with regard to building, environment and nature in the Caribbean Netherlands (Bonaire, St. Eustatius and Saba) is lacking. Despite the efforts of the island governments over the past few years. A key reason is that these Public Entities are too small to set up and run a robust VTH system.

Vergunningverlening, toezicht  en handhaving (VTH) in Caribisch Nederland

This is according to a survey by the Human Environment and Transport Inspectorate (ILT) commissioned by State Secretary Vivianne Heijnen (Environment). Heijnen sent the survey to the House of Representatives today, also on behalf of State Secretary Alexandra van Huffelen (Kingdom Relations), Minister Hugo de Jonge (Spatial Planning), and Minister Christianne van der Wal (Nature).

A well-functioning VTH system for building, the environment, and nature is important. Not having one could have adverse effects on nature, including the coral and the natural parks, and on the living environment, e.g. the air, water, and soil.


State Secretary Heijnen had called for the survey in response to concerns about the functioning of the VTH system. These concerns existed amongst Members of Parliament and in the Cabinet, but also amongst local official authorities and inhabitants of the islands. This survey shows that these concerns were justified.

The survey was presented today to the House of Representatives, the Executive Councils, the Government Commissioner, and the Island Councils by the State Secretary. Vivianne Heijnen: "The survey shows substantial shortcomings, at the cost of nature and the environment. For example, the coral off the coast of the islands. We really need to get to work now. We are going to work on improvement in the time to come. I want to do this carefully and in association with the Island governments.”


The ILT concludes that the implementation of the VTH tasks for building, the environment and nature on the three islands does not comply with the statutory requirements and local regulations. As a result, the environment and nature are not being adequately protected. To achieve the necessary improvement in this respect, a fundamental change is needed in the implementation of the VTH tasks.

The Public Entities are too small to organise the required knowledge and experience in a thorough manner and to be able to put sufficient checks and balances in place in the work processes, the ILT concludes. The size of the islands as small communities and the proximity of the administration further complicate a professional and independent implementation of the VTH tasks.

Incidentally, these problems are the result of a situation that has grown historically, in which several parties, including the Dutch Central Government, have had a role to play. Work is also currently under way in the European Netherlands to strengthen the VTH system.

Moreover, the ILT also concludes that the situation at the three Public Entities is similar to the situation of municipalities and provinces in the European Netherlands until 2013. Since then, the implementation of VTH tasks has gradually been transferred to environmental services.


The ILT makes four recommendations to the Central Government and the Public Entities to improve implementation of the VTH tasks with regard to building, the environment, and nature:

  1. Place the implementation of the VTH tasks for building, the environment, and nature of the three Public Entities with one existing environmental service in the European Netherlands as soon as possible. In this way, knowledge, experience, and continuity are guaranteed and distance from the administration is also realised; 
  2. Tackle the identified bottlenecks within the official organisation of the Public Entities in a swift and specific manner, in close cooperation with the environmental service. After all, part of the VTH process will continue to be carried out by the Public Entity; 
  3. Provide for up to date and adequate laws and regulations for building, the environment and nature; 
  4. Strengthen the position of the Kingdom Representative so they can intervene when things go wrong with the implementation of the VTH tasks.

How to proceed next?

The parties involved will now jointly start working on the recommendations and conclusions from the survey. Shortly after the summer, State Secretary Heijnen will inform the House of Representatives of the follow-up steps, including the recommendation on the deployment of an environmental service.

This will not be fixed overnight, therefore the existing support to the islands will continue. The parties involved are also jointly considering whether there are measures that can already be taken in the short term. 

Samenvatting Rapport Nulmeting uitvoering VTH-taken Bonaire (Engels)

Samenvatting Rapport Nulmeting uitvoering VTH-taken Saba (Engels)

Samenvatting Rapport Nulmeting uitvoering VTH-taken Sint Eustatius (Engels)