Second of two parts
The Environmental Assessment Report for the proposed commercial center at Crown Bay was prepared as a matter of interagency courtesy based on a 1989 Memorandum of Understanding between the Port Authority and the St. Thomas Coastal Zone Management Committee. It essentially permits the development of anything similar to what was recommended in the 1984 Master Plan for Greater Crown Bay, which CZM accepted in 1986.
The proposed plan differs from what was in the 1984 recommendations; for one thing, the commercial area is larger than that suggested in the Master Plan. Further, some proposed uses are not permitted under the present zoning for the area.
The Master Plan itself raises questions. It was approved without public hearings. Asked to participate in its development, the League of Women Voters of the Virgin Islands raised objections because of its limited scope and because the general public had not been asked to participate in the process.
Based on the force of the memo of understanding, it is the League's opinion that the EAR for the proposed Crown Bay commercial center fails to address issues and concerns normally covered in a major CZM permit application for a project in the coastal zone.
The Master Plan recommended additional studies, addressing, among other things, "detailed improvements to traffic flow, public transportation, other design criteria, and the funding source for this work." It also called for the development of "a policy plan for the area to assist the ad hoc committee's assessment of functional, aesthetic and locational aspects of elements of development proposals as they arise." Had these things been done, with benefit of a public hearing, the League might not now be questioning the proposed commercial center development.
The Environmental Assessment Report for the Crown Bay commercial development clearly demonstrates the Port Authority's knowledge that public input was not needed for CZM approval of this component of the Crown Bay project. The EAR appears to have been thrown together at the last minute, with a few new sections added to duplicates of sections of the EAR for the pier expansion. Potential negative impacts are largely ignored. Drawings are deliberately conceptual. Details can come later, and be approved without public input.
A positive impact?
When two cruise ships are berthed at the expanded Crown Bay dock, the EAR asserts, a "positive visual impact " will be presented to the passengers. We agree that the commercial center will provide an attractive and pleasing picture of Gregerie Channel, Water Island and Hassel Island, but once the visitors turn around, they will have a picture that is decidedly less impressive. The Master Plan's recommendations that the entire Sub Base area be made more attractive have never been implemented.
As far as the social and cultural impacts are concerned, the EAR does not address potential adverse impacts on existing workers and businesses in the vicinity. In Part 1 of this series, the League noted the certain increase in traffic congestion (See "Crown Bay cruise port problems: the pier".)
Other than fishing off the dock and strolling along the waterfront — which may have to be curtailed because of security concerns — there are no recreational opportunities in the area, nor are any proposed — for passengers, crew or residents. The two Sub Base tennis courts are nearby; however, they are the only public tennis facilities on the entire island of St. Thomas.
In painting a rosy picture of a thriving commercial center at the Crown Bay facility, the economic analysis ignores the impact on already existing and struggling commercial enterprises to the east. No rationale is offered for a commercial development of the magnitude proposed, given that most of what it proposes to offer already exists elsewhere in Charlotte Amalie.
Going by the numbers of ships calling at St. Thomas during the 2001-02 winter season, there will be a need for the commercial facilities only three days per week during the prime tourist period. During the summer, there does not appear to be any day when there will be more than three ships calling at St. Thomas. How can new businesses at the Crown Bay facility survive under those conditions?
The commercial development should proceed in stages, starting very modestly and adding as and only if passenger increases reach expectations, with expenditures commensurate with growth in numbers of passengers.
The League agrees completely with the St. Thomas-St. John Chamber of Commerce (See Open Forum letter from Cassan Pancham on May 6, "New Crown Bay plan has all the ills of the old") that any commercial development at Crown Bay should be limited to an amenity center and space for the display and sale of locally produced items. That this commercial center would be much smaller than those in town and at Havensight is beside the point. The point is: Don't we already have more than enough?
The League also agrees with the Chamber, as Pancham states, that "the cruise lines should not be given the opportunity to have The West Indian Co. and the Port Authority bid against each other for business." However, the League does not agree with the Chamber of Commerce view that "berthing decisions must remain as they are now, in the hands of The West Indian Co." The League believes that, as described in the closing paragraphs of our Part 1 presentation, a compromise must be worked out that results in a fair distribution of cruise ship berthing on days when there are fewer than five ships.
The League is not convinced that the economic benefits presented in the Environmental Assessment Report are accurate or realistic. The figures do not reflect the amount that will have to be retained for any debt service for a bond issue to build the project, nor do they indicate which of the other scheduled Port Authority projects will be put on hold or otherwise impacted as a result of proceeding with this one.
Contrary to VIPA's assertion that residents will fill the construction jobs and the commercial center positions, the League believes that a substantial number of the new jobs at the proposed new commercial center might have to be filled by non-residents. Added to the passenger increase, an influx of non-residents into the work force will create further demands on the island's infrastructure, social services, schools, public health and public safety. How much of estimated revenues to the government of the Virgin Islands will be dedicated to a bond issue to build the facilities? How long will it be before these revenues will actually be available for basic infrastructure needs?
There is also a question as to whether the fast land can safely sustain large-scale construction. It is composed entirely of dredged fill, mostly sand. In the event of an earthquake or heavy seas, filled lands have the potential to liquefy, so the land is not really "fast." The Port Authority should recognize that the greater the load on the land (i.e., the weight of structures, close together), the greater the potential for liquefaction.
A slight break in the sea wall or in the surface of built-up filled land that has experienced wave or quake damage may cause the sand to begin to slip. Since the sand molecules are joined to each other like molecules of water, once liquefaction begins, it does not take long for the entire area to collapse into the sea.
When asked for comments on this concern, VIPA responded: "This question is properly addressed based upon the analyzed sizes of the granular materials proposed as backfill." We found no information in the CZM file for this project that covers granular size, or any determination that the fill material will not be subject
to liquefaction.
No legislative approval required
This project does not require legislative approval. The Legislature can decide only whether or not to ratify the CZM permit for the expansion of the cruise ship pier. However, there are avenues by which readers can make known their views on the proposed commercial development at the Crown Bay cruise ship facility — letters and guest editorials to the newspapers, and letters to the governor, the Port Authority board and the senators.
We hope that your letters to senators stress the point that the Legislature must postpone ratification of the pier expansion permit until two questions have been answered: the question of berthing preference and the question of how many cruise ship passengers will be accepted in Charlotte Amalie on any single day.
This is a subject long overdue for public debate. The League of Women Voters urges you tell us where you stand.
Editor's note: Erva Denham is president of the League of Women Voters of the Virgin Islands; Helen Gjessing chairs the League's Committee of Planning and Environmental Quality.
We welcome and encourage readers to keep the dialogue going by responding to Source commentary. Letters should be e-mailed with name and place of residence to source@viaccess.net.
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