Letter to the Editor:
On Tuesday, March 20, Friends of Coral Bay appealed the St. John CZM Committee’s decision to approve Reliance Housing Foundation’s request to modify its CZM permit to construct housing at Calabash Boom to the Board of Land Use Appeals.
Friends of Coral Bay has participated in the permitting process from the beginning and our position has been clear and consistent.
We recognize the need for affordable housing on St. John and support its use in Calabash Boom. However, any development located so close to a fragile bay should be properly scaled to minimize harm to the environment, and must meet the standards in the Coastal Zone Management Act.
Friends has filed this appeal because Reliance continues to side-step provisions of the Coastal Zone Management Act that are specifically designed to protect the environment.
Reliance abandoned its original ill-considered proposal to convert seawater from Coral Bay to potable water by reverse osmosis. It now proposes a combination of a well and roof catchments. However, Reliance’s own data are contradictory and indicate that there will be insufficient quantities of water from these sources.
For example, in July 2005, Reliance stated in documents submitted to CZM, that “the existing wells have been tested and have been found to have insufficient flow to serve the proposed community. It is the opinion of the geotechnical and well experts that the aquifer in general cannot meet the projects demand…Due to the proximity to the sea it is probable that this well would become brackish if it were to be put into continuous use.”
If the aquifer could not reliably provide sufficient water in 2005, how is it possible now?
Reliance has also suggested that essential potable water could be supplemented by trucking water from Cruz Bay. By our calculations, using Reliance’s data, there will be an average monthly shortfall (from the well and roof catchments) of 157,862 gallons (and that assumes the well can produce the volume predicted, which is unlikely.) At an average price of 75 cents per gallon, this amounts to an additional cost, for a family of four, of $170 per month.
Complicating matters still further, WAPA just announced this past week that it will not be able to complete the pipeline from St. Thomas as expected due to the government not having the funds for this project, thus further stressing an already scarce water supply on St. John. If WAPA cannot reliably provide potable water, where will it come from?
While Reliance proposes to eliminate the reverse osmosis intake and discharge lines into Coral Bay, it fails to address the fact that its own data indicate that the well water is contaminated with fecal coli form bacteria, and will become brackish through continued use.
Furthermore, Reliance’s own experts have indicated that some 5,000 gallons of brine wastewater will be generated daily. What will happen to this brine wastewater in the rainy months when the ground cannot absorb any more moisture?
These are just some of the questions that neither Reliance nor the CZM raised or answered before the modification was approved.
We concur with Judge Gomez, who in January of this year issued a temporary restraining order on this project. In his conclusion, he states:
“The Friends cite the public interest in preventing destruction to the environment, while Reliance cites the public interest in creating affordable housing…Reliance suggests that the interests in offering affordable housing and protecting the environment are in conflict. The Court is not persuaded by Reliance’s suggestion. Indeed, these two interests are entirely capable of co-existing. It is reasonable to conclude that the public interest would be served by constructing affordable housing in a manner that preserves the environment.”
The CZM Act exists to protect our environment. While the Act encourages development, it demands that all development, regardless of type, (1) have no significant adverse effects on the coastal resources, and (2) incorporate, to the maximum extent feasible, mitigation measures to substantially lessen or eliminate any and all adverse environmental impacts.
The Act also specifically provides that if these standards are not met, “the permit application shall be denied.”
Friends does not take this appeal lightly. Nor is it unmindful of its implications. However, the Virgin Islands Legislature has, in its wisdom, determined that our environment and coastal resources must be preserved for the benefit of present and future generations. We cannot give in to expediency. Even a desirable development cannot be allowed to be done poorly.
On behalf of Friends of Coral Bay
Stephen Cottrell, Barry Devine, Eleanor Gibney, David Grove,
Anna Lawson, Bob McNabb, Bruce Schoonover, Richard Sullivan
and Alan Smith, Attorney for Friends of Coral Bay