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All of us are affected by the air we breathe, the energy we use, the water we drink and our waste disposal system.  We count on you to help us to share information and ideas, so that we all may become more knowledgeable about our islands and coastal waters and what activities would hurt or help the islands, coastal waters, Virgin Islanders, endangered species and our planet Earth.


Our objective at is to create an environmental forum for Virgin Islanders, to share information on environmental issues, and to work with Federal and local agencies to find solutions to our environmental challenges in the United States Virgin Islands.





12/16/2016 Letter from the President


Dear Director Guerrero:


It was such a pleasure to meet with you. Right after I met with you I became very ill, and in and out of the hospital, so now I am much better and ready to give you the information we discussed.


My primary concern is unless fundamental steps are taken right now, in the US Virgin Islands, all the coral will be killed and all the turtle grass and turtles gone.  In addition, as I stated in my May 17, 2010 letter to Judith Enck, attached, we could easily have a cholera epidemic here, (which would also kill our economy). Haiti’s cholera epidemic which began in 2010 now has over 700,000 victims and over 9,000 deaths. That same year, 2010, VI Waste Management consciously and knowingly dumped over 300-400 million gallons of raw sewage and toxic materials into our coastal waters, which I proved to the EPA using their own data. See attached.


As promised, here are the two MOU’s on the ESA and on Minority jurisdictions, Executive Order 13089, as well a study by the IG showing the EPA engages in selective prosecution. When Judith Enck started in December 2009, she had many arrests in New York and New Jersey. She will not prosecute here, which is precisely contrary to the MOU’s and federal criminal law. The EPA refuses to take action against the people of VIWMA, DPNR or local EPA. When Geoffrey Garrison claimed the EPA made headway by retiring Carl Soderberg early, I said good, without a pension, in a jail cell, right? And now everyone behind him is going to start magically following the law?


As you see, the wording on both MOU’s are mandatory and unequivocal. Under the Endangered Species Act MOU, every time there is a dumping of contaminants, raw sewage, chemicals, toxins, and even cloudy or heated water (which damages or kills coral), the EPA MUST alert NOAA and file for a formal evaluation, which it has never done once in 32 years while VIWMA has been dumping hundreds of millions of gallons per year and continues to do so (pursuant to the records provided by your Jim Casey, newspaper articles and court testimony). Further, and even scarier, the EPA states VIWMA is only 1/3 of the problem- private dumping is twice as bad.


We citizens have no idea what private dumping exists on our islands, because we cannot get access to those records. We have sunshine laws here, but they mean nothing to the bureaucrats when faced with ordinary citizens. If DPNR will not enforce our environmental protection laws, the EPA has not only a duty to do so, there is an MOU to that effect, so the EPA MUST TAKE ENFORCEMENT ACTION. Further, in Executive Order 13089, attached, President Clinton in essence gave protection to ALL CORAL found in our waters, not just the ones listed.


The MOU for Minority jurisdictions attached below, says that the federal agencies MUST be proactive, as Big Brother, which is the only hope for the people who live here in the USVI, and for our coastal waters, because local corruption, inefficiency, etc. is so rampant. See the attachment on DPNR officials, and what the billionaires are doing below. I have been asking and pleading with Judith Enck to enforce the federal laws here, but so far she refuses to tell the US Attorney to prosecute. The EPA MUST tell the US Attorney to prosecute-you are obliged under these two MOU’s. Nevertheless, the EPA refuses to enforce federal criminal laws which protect turtles, coral and other endangered species, as well as us from Cholera, septicemia, etc.


Further, the IG’s Report attached shows the EPA does not prosecute equally in the US. Region 2 itself seems inexplicably biased against us here. Pursuant to the MOU on minorities, you MUST act as our Big Brother, taking care of us, yet the EPA refuses to prosecute the very people who are responsible for polluting our coastal waters, and land and air. Since 2010, the EPA seemed to have no problem putting many NY and NJ people in orange jumpsuits, yet the EPA will not prosecute here. WHY, when the EPA is mandated to do so? Will the EPA now start the formal evaluation of our coastal waters with NOAA?


I have been asking EPA Region 2 since 2010 to stop the dumping, to prosecute the criminals, and to start testing our water correctly.  So far, none of that has happened, despite the IG’s report itself that the EPA must take over WAPA, VIWMA and DPNR for their inefficiencies and pollution.  The EPA has spent millions on water tests that were all thrown out in 2010 as done wrong…then the EPA paid the same people to again perform bad water tests. By the way, Doug Pabst deleted my email to him without ever reading it. Geoffrey Garrison promised in August, 2013, that neither DPNR nor Amy’s outfit who got all the other tests wrong prior years would conduct any more of the VI water tests from now on…yet the EPA continues to fund the faulty testing.


For a true list of wastewater discharges- there is none. I have provided you the best list I could for years 2010 and 2011, dated 3-31-11 supplemented by emails to Attorney Gonzales. The VIWMA does not fill out its non-compliance reports, and yet they are accepted by DPNR and the EPA, often stating “ongoing” when LBJ pump house in St. Croix, for example, was dumping for 60 DAYS 1-15-10 – 1-16-10, and Figtree and Barren spot were dumping then too. VIWMA never states the amount of sewage it is dumping, but the LBJ alone spewed out 3.4 million per day. VIWMA admitted in Court to dumping 50 million gallons, but the figure is realistically much closer to 300-400 million. Please read also my emails to EPA Attorney Eduardo Gonzales of 4/1/10 and 4/11/10.


President Clinton’s Executive Order 13089 making All US Coral protected as Endangered Species


Memorandum of Understanding on the Endangered Species Act (ESA)


MOU EPA Minorities


OIG EPA Report that EPA engaging in selective prosecution


EPA IG Full Report that EPA take over WAPA, DPNR & VIWMA


EPA IG Report at-a-Glance



12/14/2015 Letter from the President



We at have been working to save the coral and turtles in VI coastal waters. In 2009, a few days after our letter and research to the Army Corps of Engineers was published, the VI withdrew its application to dredge the harbor and dump the spoils in Lindbergh Bay. Since then, we have been pressing federal agencies to take legal responsibility for their willful inaction.


As a regulatory agency, the EPA is legally responsible to ensure our  environment is being protected.   In 2009-2013, we lodged several complaints with the Inspector General’s Office which oversees the federal EPA, for failing to protect USVI coastal waters. In January 2014, the IG’s Office sent a team to the USVI, who investigated all the sea, land and air environmental issues, met with many federal and local agencies and met with us for several hours. We reviewed and furnished them with hundreds of documents.


The IG’s report was published on the EPA site on October 15, 2015, (see link) finding:


The USVI’s deficiencies place the public and environment at increased risk by allowing unmonitored or excess pollutants into the air, land, surface waters and drinking water.



EPA IG Report at-a-Glance


EPA IG Full Report


The IG’s report recommends the EPA take over VI Waste Management, DPNR and WAPA, evaluate the environmental problems and fix them.


Now that we have this report from the IG’s Office, this is the plan:


  1. We will first write to the Administrators of the EPA and NOAA jointly, along with the coral, turtle, and endangered species groups, urging them to agree to a joint investigation of USVI coastal waters and plan for amelioration, clean-up, recolonization of coral, sea grasses, etc.


  1. If no agreement is reached, then we file suit under the Endangered Species Act. Since 1984, the EPA has documented extensive dumping of raw sewage and chemicals in USVI waters, and on each of those occasions the EPA was REQUIRED to alert NOAA, for the protection of the Coral and Turtles. The EPA has never alerted NOAA, even in 2010, when VI Waste Management itself was knowingly dumping hundreds of millions of gallons of raw sewage and chemicals over reefs in St. Croix. The EPA is in violation of the Endangered Species Act, and therefore must pay to evaluate and ameliorate our coastal waters. This will bring great revenue into the territory, and create many jobs, as well as boost the enrollment in UVI marine studies.


  1. We would need to pay the Coral Expert fees and the ink, paper, mailing and equipment costs of bringing suit. We ask for volunteers for ideas, resources, and to work together to flesh out the overall environmental plan, which will include recycling and closing the dumps.

 Sincerely, Susan


Susan Wolterbeek, President          1A4 Estate St Peter

PO Box 306658     St Thomas, VI 00803          (340) 714-2233


2 Responses to Home

  • Alex Browne says:

    Just found out that the former CZM Director, now acting commissioner & his wife formed a company to do water testing. He was circumventing the bidding process for the water testing contracts out of CZM & awarding them to their company. I understand that the EPA is aware of this conflict of interest. How is it that after our heavy ground soaking 8 inch rainfall all St. Thomas beaches except Magen’s & Linquist/Smith Bay Park unfit for swimming or fishing? Believe report was in this week’s paper.

  • friv 2016 says:

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