Re: Great Saint James Permit

Director Oriol:

In giving further to consideration to my conversation on January 5, 2017 with Paul Kalloo and my email to you of today's date, I am firmly convinced that a new CZM application would be wholly unnecessary. I refer you to ow transmittal letter of December 22, 2016, in which we requested what is effectively only a slight change in the work authorization sought by Great St. Jim, LLC ("Great St. Jim") in its permit application relating to Great St. James. The scope of "Phase I" shown in our December 22, 2016 transmittal is similar to what was initially proposed in Great St. Jim's permit application in that the activities proposed for "Phase I" in the December 22 transmittal are largely limited to cleaning up the island, limited landscaping, and flag pole installation. In accordance with subsequent meetings between Great St. Jim and DPNR, we have added to "Phase I", the stabilization of existing driveways, the creation of two additional

access ways to assist in the cleaning of the shoreline (which cleaning was contemplated by our original request), the hand paving ofa portion of one of the existing driveways, and pouring two concrete pads on existing clearings.

Although, at the request ofCZM, we have attempted to identify in our December 22 transmittal a second Phase ("Phase II") ofpossible future improvements that are under consideration at this time, no authorization for construction of those possible improvements has been requested. In accordance with CZM's direction, we have merely provided drawings conceptualizing five residential structures and two storage buildings at possible locations on Great St. James under consideration at this time for "Phase II". We fully understand that additional information may be required if and when we are ready to construct these buildings, but, at CZM's request, we are requesting only a conceptual approval and no work authorization at this stage.

In light of the relatively slight deviation from our initial permit request in "Phase I" and the exclusively conceptual approval sought for "Phase II," we believe it would make little sense to discard the significant efforts put forth by both CZM and us in the existing permit process to start a new and largely duplicative permit process. Moreover, there are significant health and safety reasons not to unnecessarily delay the permit process or the commencement of the requested work. We are hopeful that the requested revisions are acceptable and would very much appreciate CZM's prompt review and consideration.

John P. Woods

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morning john,

I know you sent in a letter back before Christmas, but have you filed an actual modification request, with drawings, depicting what it is you are requesting? from what I read, it is possible that the activities in your "Phase I" may be able to be processed as a modification to the last permit; however, like you correctly stated, the residential structures that are still in the design phase will not be a modification to the existing

permit (you can't modify a permit to remove brush and install a flagpole to now cover residential structures).

as you continue to speak with your client, I hope that you take our suggesting of having one overall master plan permit for the island into consideration, properly considering everything that is to take place on the island.

regards,

JP

Attached is E's response. I would like to send a response back to him right away. If I read it correctly, he is saying we can get all of the Phase 1 scope as a modification, but the Phase 2 buildings need to be applied for as a separate permit, either as an overall Master Plan, or individually.

JPW

Sent from my iPhone

tell him we will submit a master plan concept in a month or two. as we have not designed it yet. , but we would like to put the tiki bar back plant more trees around the point that you outlined and clean hopefully amy will submit dock permit today

I spoke to Mr. Richards asking about number of copies for hardcopies and disc. And he said I need to make sure with Michelle Baker that we can submit it because of the other issues. I am going ahead and getting everything ready. But just wanted to check with you to make sure it's OK that I do talk to her.

Amy Claire Dempsey,
President, Bioimpact, Inc.