COMMENT PERIOD HAS CLOSED
The US Army Corps of Engineers has initiated a new PUBLIC COMMENT PERIOD for the proposed Summers End Group marina in Coral Bay, St John. This new comment period will continue until AUGUST 24, 2015. The public notice may be found here.
If you previously submitted a comment letter (in January/February 2015) we encourage you to resubmit that letter now. The new application does not include the 75 position public mooring field, so you may remove comments on this topic from your letter. You may submit your letter either by postal mail, or by email to the addresses below. Be sure to include the permit application number in the subject line.
Email Subject: Application SAJ-2004-12518 (SP-JCM) – Coral Bay Marina
Email To Address: firstname.lastname@example.org
Email cc Address: email@example.com
Postal Address: Mr. José A. Cedeño-Maldonado, Antilles Permits Section, 400 Fernández Juncos Avenue, San Juan, Puerto Rico 00901-3299
If you are submitting via email, please send a copy to the Save Coral Bay email address (firstname.lastname@example.org) so we can maintain a record of responses. The Army Corps email system does have some limitations, so please remember to send a copy to SaveCoralBay@gmail.com as further assurance that your comments will get to the Corps.
What has changed and why is there a new comment period?
The reason for the new comment period is that the “lead agency” for the permit review has moved from the Fish and Wildlife Service (FWS) to the Army Corps of Engineers. In the first comment round (January/February) the FWS was acting as lead agency. In March 2015 the FWS rescinded the grant they had previously awarded for this project, and in so doing they also gave up their lead agency status for the permit review.
When the Army Corps took over the “lead agency” role they determined that the prior application and notice were incomplete and they required a new application from the Summers End Group. They then decided to publish a more complete description of the project in a new Public Notice, and open a new Public Comment Period. The Public Notice may be found here.
The marina and upland buildings in the “new” application are IDENTICAL TO THE PREVIOUS APPLICATION and the only change in the physical project has been the elimination of the 75 position public mooring field which was a part of the prior application. So, unless you made comments on the mooring field, your previous letter is most likely still entirely relevant in this comment round. If you submitted comments regarding the 75 position mooring field, these are no longer relevant and may be removed from your letter.
Additional information regarding this project may be found in the Environmental Assessment Report (EAR) prepared by the Summers End Group for the local permits.
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 permit application. 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
- Potential impact on habitat for endangered species, including Green Sea Turtles, Hawksbill Turtles, and Leatherback Turtles.
- Potential impact on endangered coral species found in Coral Bay.
- Potential impact on the healthy mangroves in close proximity to the project site.
- Potential impact on fish nurseries – Lemon shark, Black Tip shark, conch, whelk and numerous juvenile reef fish who use the mangroves and sea grass meadows
- Potential 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 safely 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.
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 your knowledge and concerns about the potential impacts of the proposed marina development.