PETITION TO THE UNITED STATES ARMY CORPS OF ENGINEERS

The undersigned individuals oppose the approval of Army Corps permit application number SAJ-2004-12518 for the construction of a commercial marina by the “Summers End Group LLC” in Coral Bay, St John, US Virgin Islands.

The fundamental problems with the proposed marina are: (1) it is in the wrong location with exposure to the open ocean, on a lee shore, and directly over protected habitat (2) it is far too large for Coral Harbor, and (3) it is designed for mega yachts which cannot safely navigate in the shallow waters of Coral Bay.

We strongly urge the Corps to deny this permit because the Summers End marina project is clearly not in the public interest.  Any benefit which could accrue is overshadowed by the extreme negative impacts on the public interest factors that USACE must consider pursuant to 33CFR325.  These factors include:

1. CONSERVATION: The extensive impacts to protected resources, including sea grasses, essential fish habitat, protected corals, sea turtles and marine mammals are not compensated by any of the mitigation proposals offered by the applicant.
2. ECONOMICS: The conversion of Coral Harbor into a mega yacht marina will have serious adverse economic impacts to the existing economy of Coral Bay, which is based on low-impact eco-tourism.  The economic benefits of the project accrue disproportionately to the project proponents, not to the residents of St John.
3. AESTHETICS: Coral Bay is known for its historic setting and its low-key ambiance within the Virgin Islands National Park.  The transformation of Coral Bay into the largest marina in the US Virgin Islands would dramatically change the aesthetics and character of the community, depriving Coral Bay of its special character.
4. GENERAL ENVIRONMENTAL CONCERNS: The United States Environmental Protection Agency has designated Coral Bay as an “Aquatic Resource of National Importance” due to its unique habitats and ecosystems.  The EPA has urged the Corps to deny the permit due to its unacceptable adverse impacts on the Coral Bay environment.
5. WETLANDS: The fringing mangroves are a documented nursery for shark species, native and migratory birds, and other valuable marine life.  The mangroves will be impacted by turbidity, toxic marine effluents, and fuel spills, all well-documented and unavoidable consequences of marina construction and operation.
6. HISTORIC PROPERTIES: The entire setting of Coral Bay is deeply rooted in historic events of St John.  The view over the harbor to Fortsberg, listed on the National Register of Historic Places, will be obscured by large yachts in the marina.  The historic view from the listed Emmaus Moravian Church will be blocked by the marina.  And most significantly, the oldest shipwreck ever discovered in the nearshore waters of St John is within the footprint of the proposed marina and would be severely impacted, if not destroyed by the construction and operation of the marina.
7. NAVIGATION: The traditional means of navigation in Coral Harbor, by sail and wind power, will be rendered impossible with the presence of a marina stretching more than half way across the entirety of the harbor.  Sailboats are often incapable of straight line navigation in and out of the harbor due to the prevailing southeasterly winds.
8. RECREATION: The “Kids and the Sea” program which teaches young Virgin Islanders safe boating and sailing skills will not be possible if the harbor becomes a mega yacht marina.  The small KATS boats cannot safely navigate in the presence of large motor yachts.
9. WATER QUALITY: The accumulated sediments on the seabed of Coral Harbor will become released and resuspended due to the die-off of sea grasses from shading, the propeller wash from large maneuvering yachts, and the installation of around one thousand pilings.  This will likely result in chronic turbidity with impacts on healthy corals at Penn Point and Marina Point.  The federally sponsored projects over the past decade to reduce storm water impacts and runoff into Coral Harbor will be rendered useless by this project.
10. SAFETY: Coral Harbor is the primary means of ingress and egress for the community of Coral Bay at times when the single roadway from Cruz Bay is not passable.  After the hurricanes of 2017 emergency relief arrived by water, which would likely have been impossible if the harbor had been blocked with marina wreckage.   The potential for massive fuel spills and hundreds of wrecked pilings in the harbor renders this a deeply flawed plan during an era of increasing tropical storm frequency and intensity.
11. CONSIDERATIONS OF PROPERTY OWNERSHIP: The water rights of shoreline property owners have been infringed by the expansive size of the proposed marina.  The Summers End Group does not own any property in Coral Bay.  Other shoreline property owners have been unable to progress their own plans due to the excessive size of the Summers End marina project.
12. THE NEEDS AND WELFARE OF THE PEOPLE: Although there is a recognized need to address boating infrastructure in Coral Harbor, this project does not meet that need.  It is designed for large yacht owners, who are not residents of St John.  It adversely impacts public safety, climate resilience, and the local economy, in favor of the economic benefits to the project proponents.  The small number of jobs that may be created do not offset the employment losses anticipated due to the negative economic impacts on the eco-tourism based current economy.

For the reasons cited above, we respectfully urge the United States Amy Corps of Engineers to DENY the permit requested by the Summers End Group LLC for construction of a private commercial marina in Coral Harbor, St John, United States Virgin Islands.