Suggested Guidelines for Public Comment Letters to Army Corps of Engineers
The PUBLIC COMMENT PERIOD for the Summers End Group marina in Coral Bay, St John, has begun and will continue until MARCH 5, 2015. Your letter must be submitted before that date.
The factors considered by the Army Corps are described below:
“All factors which may be relevant to the proposal will be considered including conservation, economics, esthetics, general environmental concerns, wetlands, historical properties, fish and wildlife values, flood hazards, floodplain values, land use, navigation, shoreline erosion and accretion, recreation, water supply and conservation, water quality, energy needs, safety, considerations of property ownership, and in general, the needs and welfare of the people.”
The Public Notice may be found here.
Additional information regarding this project may be found in the Environmental Assessment Report (EAR) prepared by the Summers End Group for the local permits.
How to Direct Your Letter
Your letter should either be sent by postal mail or by email to the addresses below. It should include the permit application number in the subject line.
Email Subject: Application SAJ-2004-12518 (SP-JMS) – Coral Bay Marina
Email To Address: Johann.M.Sasso@usace.army.mil
Email cc Address: email@example.com
Postal Address: Mr. Johann M. Sasso, Antilles Permits Section, 400 Fernández Juncos Avenue, San Juan, Puerto Rico 00901-3299
If you are submitting via email, you may send a copy to the Save Coral Bay email address so we can keep track of total responses.
What You May Want to Include in Your Letter
The best letter is one that uses your own words to express your own concerns. Whether you are a resident of Coral Bay, a resident of the Virgin Islands, a homeowner, a visitor, or someone with general concerns about protection of parks and natural resources, your comments will be most meaningful if they are your own. Every letter will be read by the Army Corps, and any relevant concerns expressed will be summarized by the Corps and will require response from the applicant.
There is also an opportunity to request a public hearing about the application for the marina. In your letter to the Army Corps (particularly if you are a resident) please consider requesting a public hearing and your reason for requesting it. Some reasons might be (a) that there are serious issues with the analysis in the Summers End Group’s submission, (b) there is significant public interest in the project, (c) there is public controversy over the project’s impacts, (d) to enable people who were unable to comment to be able to share their concerns, or any other reason that seems appropriate.
Here are some of the potential impacts and concerns you may want to discuss in your letter:
- Environmental Concerns
- Impact on habitat for endangered species, including Green Sea Turtles, Hawksbill Turtles, and Leatherback Turtles.
- Impact on endangered coral species found in Coral Bay.
- Impact on the healthy mangroves in close proximity to the project site.
- Impact on fish nurseries – Lemon shark, Black Tip shark, conch, whelk and numerous juvenile reef fish who use the mangroves and sea grass meadows
- Impact on the marine meadows that provide filtration and trap sediments.
- Mitigation for any of the above – how will the applicant restore any of the resources lost or damaged by this project? How will the marine meadows be replaced?
- Economic Concerns
- Is there proven demand for mega yachts to use a marina in Coral Bay, and if not how can it be economically successful?.
- How will the construction noise and disruption impact tourism in Coral Bay? What are the risks that this will cause more economic harm than the benefit the marina claims to bring?
- What is the potential impact on real estate taxes? Is there a risk that people will be forced from their land if taxes increase?
- What sort of jobs are created by a marina? Are these year-round professional positions, or seasonal, low paying jobs?
- Infrastructural Needs
- Potable water – how many trucks per day? how will the roads be able to handle this added burden?
- Septic – how will the waste from mega yachts be handled ?
- Electric – how will the additional power required to operate the marina be supplied? What will happen during the frequent WAPA outages?
- Fuel – how will fuel be safely transported, stored, and pumped? How will spills be contained?
- Cultural and Historic Impacts
- The view of Fortsberg, a site of great historic and cultural importance, would be obstructed by the marina.
- The shoreline, used by fishermen and boaters, would be inaccessible following the construction of the marina.
- The types of luxury shops and the mega yacht culture have no connection with the historic culture of the Virgin Islands, or the East End of St John.
- Construction Impacts
- Noise, reverberating in the Coral Bay amphitheater, from pile driving on 1333 pilings. How long, what intensity, what impacts to people, animals, migratory whales, pelagic dolphins ?
- Siltation – the barge spuds and pile driving will release vast clouds of silt, how will this be contained to not result in killing acres of sea grass? A rainfall deposits silt, but it dissipates in a couple days. The construction will create years of silt and may present risks to the sea bottom vegetation.
- Construction water, electricity – how will the utility needs of the construction be met? Will there be constant diesel engines, pile drivers, generators creating daytime noise?
- Alternatives Available
- Large motor yachts can, and do, utilize the moorings maintained by the National Park Service. These moorings are safe to the seabed environment.
- The creek in Cruz Bay harbor, near the National Park gateway and headquarters, has all of the amenities and infrastructure required for a marina. Should this be considered as a far lower impact and more appropriate location?
- Location of the Marina
- The proposed location is on the windward shore of Coral Bay harbor. It is subject to extreme wind and wave action during any tropical storm.
- The proposed location is subject to waves whenever there is a SE wind. The majority of the slips are situated broadside to the waves.
- The main pier needs to extend almost 1000′ into the harbor in order to reach deep enough water for large yachts. At that length it would make it impossible to sail out of Coral Bay on most wind conditions.
- The north end of the harbor (behind Skinny Legs) is far more protected and appropriate for a marina.
- Impact on Recreational Use
- The proposal includes a “mooring field” of 75 moorings, but the design of the mooring field has been described by local captains as unrealistic. Are there concerns regarding the location, design, and operation of the mooring field?
- There are insufficient details on the mooring field to determine how it will function.
These are just some representative concerns. You are encouraged to write about your personal concerns based on your knowledge of the Virgin Islands, of St John, of Coral Bay, and the probably impacts of the proposed marina.
As an example, here is a letter that a frequent visitor to Coral Bay might write:
Subject: Proposed Marina in Coral Bay, St John – Application SAJ-2004-12518 (SP-JMS)
I am writing to express my opposition to the proposed “St John Marina” located in Coral Bay Harbor, St John, US Virgin Islands, a project of “The Summers End Group, LLC.” I believe this project is totally inappropriate in a location with such close proximity to the Virgin Islands National Park and the Coral Reef National Monument. The marina would be detrimental to the environment, detrimental to the local economy, and detrimental to the unique qualities of Coral Bay that make it a preferred vacation destination for thousands of visitors who come to St John to enjoy the national park lands and waters, including me.
As a regular visitor to St John, I choose this destination because St John in general, and Coral Bay in particular, is different from other Caribbean islands. Because there is no airport, or a cruise ship dock, or a marina, this island is visited by people who come here not for the convenience of the transportation infrastructure, but for the well protected natural environment. If a large marina were built in Coral Bay it might make it more convenient for small numbers of people visiting on large yachts, but it would destroy the environment that I, along with so many others, have come to love and value for their homes and vacation destination.
The Virgin Islands National Park, and the Coral Reef National Monument, are priceless and irreplaceable natural resources, and the proposed project would destroy much of their significance through visual, noise and environmental impacts. There are currently ample opportunities for yachts to use the many mooring facilities provided by the national park. Construction of a mega yacht marina in the heart of national park properties and waters threatens these pristine environments and cannot be justified for the convenience or profits of a few people.
I am not opposed to development, but this marina is wrong for Coral Bay for the following reasons:
- It is far too large – Coral Bay could possibly use a better dock for daytime boat access, but not the massive structure proposed by the Summers End Group.
- The construction and operation will undoubtedly hurt the local economy – The Coral Bay economy is based on eco-tourism, and the incessant noise of construction, the coming and going of large motor yachts, the lights and exhaust fumes would drive tourists such as me away from Coral Bay, and away from St John.
- The marina will impact natural resources and protected animals – There are dolphins, turtles, sharks and rare corals in Coral Bay. These would all be driven out by the construction and operation of a mega yacht marina.
- The pristine waters of Hurricane Hole, within the Virgin Islands National Park, are just one bay away from Coral Bay. The potential impacts to this unique and priceless resources cannot possibly be ignored for the sake of development.
- There are other viable options for boaters to visit St John, including the excellent mooring system maintained by the National Park Service.
For these and other reasons I do not believe it would be in the public interest to approve a permit for the “St John Marina” in Coral Bay, St John, as requested by the Summers End Group, LLC. Additionally, I formally request that the Army Corps convene a public hearing on this application because there is significant public interest in the project and there is public controversy over the project’s complex impacts.
Signed – Name, Address