Re: Great St. James

I woke up last night thinking about the GSJ application. I believe that a frontal attack could be made on the application as being a subterfuge or a fraud. I am writing, therefore, to supplement the memo which I sent to you and Mr. Epstein yesterday. The argument is as follows:

• The scope of the current application is says that it is limited to an application:” To subdivide the island allowing for future residential development, and facilitating the construction of roads.”
• I have not read the EAR yet, but I suspect that the express limitation of the application is intended to allow the applicant to obtain an initial approval of this application without the necessity of confronting all the obvious, substantial environmental issues posed by the total build out of the island and, ultimately, how that build out will have to be maintained.
• In other words the application, if granted in this form and under these limited conditions, would permit the subdivision of the property, establish a barge landing, and permit rough out of the roads, the environmental impact of which can be minimized.
• If this occurs, individual CZM applications by the owner of each lot could be filed later, each of which would only address the impact of building that house on that particular site since each of these applications is considered separately; so the evolving big picture of the scope of all development is never put into play in the approval process.
• I do not know whether the CZM personnel will subscribe to this kind of tunnel vision, but it would seem prudent that some intervenor at the staff and hearing level press hard the fundamental point that the review of this application, as a matter of law and prudence, must entail a full review and evaluation of all of the consequences of build out and then maintenance of the property
• In this connection information in our possession about our project can which could be adapted to deal with the GSJ application:
• We have been looking at less square footage than build out at GSJ
• We are projecting materials requirements: concrete, block, structural materials and so on for our work
• We are projecting barge trips, container numbers, on site support requirements and the whole gamut of activities on LSJ
• We know that central generation of power is a practical necessity in this kind of island context
• We know that on island water generation is a practical necessity in this kind of island context
• We know that miles of infrastructure will have to be laid to distribute power and water in this kind of context
• We know what level of services are required post build out in this kind of context
• Maybe the EAR covers all this truthfully, but I doubt it; I believe that we will find that these points are either ignored or are obfuscated
• So we might consider supplying to someone somehow a real picture of construction and post construction reality posed by this application
• We could develop a prototype 5,000 square foot masonry or concrete home concept, estimate the amount of materials and effort which would be required to build it and then project what would happen if 40 or 50, or 200,000 square feet, of these homes were to come on line in a given period along with miles of roads and related necessary infrastructure; this could be provided informally to CZM or presented in hearings if this application gets to that point.
• The need for a full disclosure in the present context of all these consequences would become obvious so that the true scope of the consequences of the decision to approve such a monster would become apparent to the agency and the public.

Lafayette Construction LLC

6100 Red Hook Quarter, Suite A2-7

St. Thomas, VI 00802

Tel: 340 779-8054

Fax:340 779-8055

Cell:340 690-7194