Edgar W. Garcia, Project Manager
U.S. Army Corps of Engineers
RE: SAJ-1997-03682 (SP-EWG)
Dear Mr. Garcia:
We are requesting that the The Army Corps of Engineers conduct a
thorough Environmental Impact Study (EIS) and hold public hearings for the above referenced project.
The project proposes to dredge over 23 acres of sea grasses, and the Corps has determined the following endangered species or their critical habitat, may be affected: Elkhorn corals (Acropora palmata), Staghorn corals (Acropora cervicornis), the hawksbill (Eretmochelys imbricata), leatherbacks (Dermochelys coriacea) and green (Chelonia mydas) sea turtles.
The proposal currently fails to provide enough information regarding possible impacts to St. Croix, where spoils from the dredge will be dumped. Given the magnitude of this project, and environmental damage that can be caused when huge projects fail to plan properly, and the environmental impacts that have resulted from past dredging projects, we are requesting that the Corps hold public hearings to minimize any future conflicts.
Without more information, the Army Corps of Engineers clearly cannot fulfill their obligation to "assess the balance of the benefits, which reasonably may be expected to accrue from the proposal, against its reasonably foreseeable detriments." Neither potential impacts to endangered species and navigation, nor potential public benefits from this project can be evaluated without commitment to a credible project timeline. We are also concerned about the proposed mitigation, and obligations and oversight to required project outcomes.
As the United States Coral Reef Task force leaves the USVIs, we ask you to recall the policy associated with the 1998 Executive Order 13089 that created it:
All Federal agencies whose actions may affect U.S. coral reef ecosystems shall: (a) identify their actions that may affect U.S. coral reef ecosystems; (b) utilize their programs and authorities to protect and enhance the conditions of such ecosystems; and (c) to the extent permitted by law, ensure that any actions they authorize, fund, or carry out will not degrade the conditions of such ecosystems.