EFTA00583471.pdf

Kellerhals Ferguson Kroblin PLLC Royal Palms Professional Building. 9053 Estate Thomas, Suite 101, St. Thomas, V.I. 00802 I www.kellfer.com November 7, 2016 Via Electronic Mail < Michele Baker, Esq. Legal Counsel Division of Coastal Zone Management 8100 Lindberg Bay, Suite 61 Cyril E. King Airport Terminal Building 2nd Floor St. Thomas, VI. 00802 Re: NOVA-04-16-STT Dear Attorney Baker: We have reviewed the Notice of Assessment of Civil Penalty, Order for Corrective Action and Notice of Opportunity for Hearing, dated November 4, 2016, and shall work with Great St. Jim, LLC to address DPNR's concerns regarding any and all issues claimed in paragraph seven (7) therein and to promptly cure any and all such issues in accordance with the requirements of the Settlement Agreement. While the Settlement Agreement requires that Great St. Jim, LW be given an opportunity to cure any alleged violations, we note that it does not specify a time-frame for that cure. In the absence of a specified cure period, a reasonable period of time is respectfully requested. In addition, the Notice to Cure provides no detail as to any environmentally appropriate cures that may be implemented which would be acceptable to DPNR. Under the circumstances, the ten (10) day cure period does not appear to be reasonable, and we would ask that any cure be subject to an agreed reasonable mobilization period, and any action steps be deferred until after our meeting. We will attend the meeting date you proposed, and look forward to seeing you on November 16th at 10:30 AM. Respectfully, Erika Kellerhals cc: Jean-Pierre Oriol, Director Division of CZM > John P. Woods, AIA Amy Claire Dempsey, M.A. < EFTA00583471