EFTA00795104.pdf

GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS 0 DEPARTMENT OF PLANNING AND NATURAL RESOURCES Coastal Zone Management Program 8100 Lindberg Bay, Suite 61 Cyril E. King Airport Terminal Building Vied Floor St. Thomas, U.S. Virgin Islands 00802 Telephone: (340) 774.3320 FAX: (340) 714-9524 November 17,2017 Erika Kellerhals Kellerhals Ferguson Kroblin PLLC 9053 Estate Thomas, Suite 101 St. Thomas, Virgin Islands 00802 SUBJECT: Major CZM Permit Application No. CZT-1-18(W) Great St. Jim, LLC St Thomas, Virgin Islands Dear Ms. Kellerhals: Your application for the above-referenced CZM permit has been reviewed and found to be INCOMPLETE. Please see attached list of deficiencies. All responses should correspond to deficiency items. Responses will be accepted within ninety (90) days of the notice of deficiency. All items noted on this checklist, the drawing requirements handout, and in the EAR guidelines must be included or adequately addressed for an application to be considered complete. If any item is missing, your application will continue to be deemed incomplete. If you fail to submit the requested information, the application will be deemed voluntarily withdrawn by the applicant. Should you have any further questions about this matter, please contact DPNR/CZM at 773- 3450 for St. Croix and 774-3320 for St. Thomas/St. John. Sincerely, J n-Pierre L Oriol Dc ctor of CZM EFTA00795104 CZT-1-1.4(N9 Great St. Jim. LLC. Letter ofIncompleteness CZT-1-18(W) Great St. Jim, LLC. St. Thomas, Virgin Islands LIST OF DEFICIENCIES 1. Please provide a list Of Adjacent property owners. This can be obtained at the Lt. Gov. Office. 2. Please submit an approval letter from the State Historic Preservation Office (SHPO) for this project. 3. Please provide all property maps associated with this project. These can be obtained at the Lt. Gov. Office. 4. Please provide qualification & background for BCSC DOSPIVA. Letter - The letter mentions the existing unpermitted dock in Shallow Bay to be removed. The methods and procedures necessary to accomplish this task have not been discussed in the EAR. Please include. Zonina- The Zoning for the Island is R-1 and private piers/boat ramps are permitted only as an accessory to an existing upland residence or structure on the same parcel. Please note that the application fails to disclose the ultimate use or justification for these structures being sited at three separate remote locations. Form L&WD-2 1. Please provide an email address as requested. Legal- Please provide the following: A. An IRB Tax clearance letter for Owner dated after July 1, 2017. B. Provide the Articles of Organization and Operating Agreement from Great St. Jim, LLC. C. Provide corporate documents from Poplar, Inc. D. Provide document showing that Epstein is an authorized signatory for Poplar, Inc. E. Certificates of Good Standing are required. Please provide for Great St. Jim, LLC & Poplar, Inc. F. Property tax clearance letter submitted are all dated Nov. 14, 2016. We need letters dated 2017 as verification that the property taxes are up to date. G. Please submit a copy of deed(s) associated with this application. Drawings- Your drawings for the project have been reviewed and some concerns have been expressed: 2 EFTA00795105 CZT-1-18(W) Great St Jim. LLC. Utter ofIncompleteness 1. Dock Site No.1 — The construction detail for the bollards appear to be stabilized within an on-grade slab. The site plan shows them placed in the sand bed. Please clarify. Also, a 7' long bollard, once installed, will be completely submerged in water depths of 7'+ and becomes a hazard to vessels. Please address. 2. Dock Site No. 2- No information was provided on the piling plan. Please provide along with the longitudinal section and the total piling count. 3. Dock Site No. 3- The overlay of dock/ramp footprint on site plan is not to scale. The 100' section will be closer to corals than presented. Please correct. • Also, the profile does not show the100' length. It is unclear as to how this structure functions as a barge ramp. Please provide drawings for clarification and evaluation. • Thirdly, the piling plan for this structure is of concern and deemed excessive, inevitably resulting in serious negative environmental impacts. Please revisit and reconsider keeping in mind that the entire island is within the STEER boundaries and all development should result in a beneficial • Please provide more information and the manufacturers specifications on the wave attenuation reef making system. EAR- Section 3: 00 ABSTRACT - This section again makes mention of the existing dock in Shallow Bay. Please provide a description of the dock. See notes under List of Deficiencies entitled LETTER above. Section 4:00 STATEMENT OF OBJECTIVES - The statement discloses the proposed use of the temporary barge and the dock in Christmas Cove. The need for the barge/dock structure on the south end if the island has not been disclosed. Please provide. Section 5:00 SUMMARY OF PROPOSED ACTIVITY - The opportunity for the cleanup of old pilings left from former dock exists and should be considered as part of this application. The southern dock/barge is located closer in proximity to the ESA corals than depicted on site plans. Consequently, the barge approach to the end of this structure is more likely than not to cause irreparable damage to the nearby corals. Please address. The Project Work Plan/Schedule should be presented as a timeline, showing start and finish for each segment of the projects. Please provide. Section 6:00 ENVIRONMENTAL SETTING & PROJECT IMPACTS It is stated in EAR that the piling count for the barge/ramp at the southeast of the island requires a total of 60 piles. In contrast, the engineering drawings submitted show a total of 274 pilings required. This amount is of serious concern. If a dock restructuring was done, then new drawings will be required to reflect that change. Part B of the concluding paragraph under Impact of Construction states that the locations of the docks resulted in a minimization of their sizes. However, the sizes proposed are determined to be excessive for residential use, and furthermore their determination as accessory structures to existing upland development have not been proven. Section 7:00 IMPACTS ON THE HUMAN ENVIRONMENT Correction: The construction of the dock and ramps, especially with the demolition of the temporary ramp, will definitely produce some waste. Correction: The docks and landings will have a continual impact on the roads on the island. The application failed to present information on the present conditions of these existing infrastructures. 3 EFTA00795106 CZT-1-1809 Great St. Jim, LLC. Letter ofIncompleteness - The construction of the dock in Christmas Cove could be quite near to the existing moorings according to DPNR records. Though beach access may not be affected, it's location may pose an obstruction and or danger to passengers and the many vessels that frequent the area. Please revisit. EFTA00795107