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Federal Partnership Needed in Virgin Islands

April 22, 2010

Adam Warren

Director

VI Renewable Energy Pilot Project

National Renewable Energy Laboratory

1617 Cole Blvd.
Golden, CO 80401-3305
Adam.Warren@nrel.gov

Joseph McDermott

Acting Director Liaison

Office of Insular Affairs – Policy & Liaison Division
U.S. Department of the Interior
1849 C Street, NW
Washington, DC 20240

Joseph_McDermott@ios.doi.gov

Steve Meyers

Partnerships and Communications

NOAA Fisheries Service

1315 East West Highway

Silver Spring, Maryland 20910

steve.meyers@noaa.gov

Gentlemen:

I write to you as a stateside attorney and an environmental citizen’s advocate on St. Thomas.  It was a pleasure to speak with all of you in regard to the VI Renewable Energy Pilot Project, the current waste and energy challenges we face in the U.S. Virgin Islands, and the need to form a partnership with citizens, environmentalists and federal and local agencies to address these challenges together.

As you can see by the attached articles in the Virgin Islands Daily News, the VI Waste Management Authority (VIWMA) had a series of equipment breakdowns which resulted in dumping 1.2 million gallons of raw sewage per day over Long Reef in St. Croix from January 17 to mid-March.  The main station in St. Thomas, Cancryn, “has been without a working pump for close to nine months, Cornwall said.”   The landfill in St. Croix was scheduled to close years ago, and St. Thomas is not far behind. Clearly, VIWMA needs help, with a comprehensive approach toward both solid waste and wastewater treatment. These major Territorial issues are in addition to our energy woes, which you are already familiar with.

Understandably, the VI Senate is all the more pressed to find a solution to our landfill and wastewater problems as well as our energy issues.  Alpine and our local government, unilaterally, without citizen knowledge or involvement, entered into an agreement in 2009 for a waste to energy concept which is fueled primarily by petroleum coke and oil, and refuse derived fuel (rdf). Many factors are not addressed by Alpine, such as, for example, the horrendous toll on the environment from heavy metal and CO2 emissions. If we do not lower our CO2 emissions, all the remaining coral in the world will die.

There has been a vehement outcry of collective opposition to the Alpine plan by citizens and environmentalists, from both an economic and an environmental perspective. Many town and community meetings have been held, dozens and dozens of Letters to the Editor have been published, Testimony has been given before the VI Senate, and several environmentalists have devoted themselves full-time to researching and educating the rest of us as to the facts and the issues involved. I prepared a brief analysis for the Senate.  Please see the attached letter to Senator Malone which discusses the Alpine plan and how it is counter to the goals of EDIN and our Country’s and Territory’s pledge to decrease our reliance on oil-based solutions.

A portion of the Alpine plan was voted down by the VI Senate in March, 2010, but Alpine is modifying their proposal and will be submitting it to the VI Legislature within 2-4 weeks, according to VIWMA.  According to the VI Daily News, the new Alpine plan would only burn petroleum coke in an emergency. Yet that means that rather than building a straight rtf plant, they would be building a plant for an untried technology, (burning rtf and petroleum coke), just for an emergency situation. That is not logical from an economic aspect, unless they plan to have many emergencies. The previous plan called for burning up to 4,600 hours of oil a year, with the petroleum coke and rtf.  An oil-based solution, even with rtf, is not the best solution, and would tie us to the volatile oil market for at least 20 years, right when everyone has agreed in EDIN that we will be the pilot for renewable energy.

China and India are burning petroleum coke, and having a very negative impact on the world’s atmosphere.  Our federal agencies cannot do anything about those jurisdictions, but you gentlemen can make all the difference by helping our Territory to say no to Alpine, and instead, working together,  put great minds to the task of coming up with a comprehensive waste management system, and hopefully a waste to energy system using AC Plasma Gasification.

We citizens and environmentalists have been consulting with a Professional Engineer in Waste Management who is preparing a solid waste strategy/plan now, to submit to the VI Senate for their careful consideration as an alternative to the Alpine proposal. The concept is to address all of the USVI solid waste issues, to develop a comprehensive plan which is economical and environmentally responsible. By representatives of all concerned focused together, with transparency, we will be able to implement the plan much more efficiently, without collective energy focused on objections and lawsuits.  Further, since all federal and local agencies would be involved in the process from the outset, the permitting and approvals would be more streamlined.

Alpine’s waste to energy plan would tie the territory to using petroleum coke, oil or both for at least the next 20 years. Thus, this issue involves not only the EPA, but all the federal agencies who are committed to the success of the EDIN VI Renewable Energy Pilot Project. Further, the high CO2 and heavy metal emissions, in addition to other hazardous materials, affect the islands and coastal waters which are the responsibility of NOAA and FWS.  If all these federal agencies are helping us Virgin Islanders and our government to shoulder the collective responsibility for the success of this waste to energy project, we will succeed.

Our solid waste strategy/plan includes the consideration of alternating current (AC) plasma gasification, which would be a far more economical, environmentally green waste to energy system.  Since AC plasma gasification is cutting edge technology, it should be of great interest to the federal agencies involved in the VI Pilot Project. We will forward these documents to you as soon as they are submitted.

Sincerely yours,

Susan K. Wolterbeek

cc: Judith Enck, EPA Administrator, Region II

Miyoko Sakashita, Esq. Center for Biological Diversity

Letter to NOAA Bureau Chiefs

February 14, 2010

Sarah Heberling, NOAA

Steve Meyers, NOAA

Dave Bernhardt, NOAA

Miles Croom, NOAA

Dear NOAA Chiefs:

The Virgin Islands Waste Management Authority is dumping an enormous amount of raw sewage onto Long Reef, St Croix, US Virgin Islands, and has been doing so all last week. Please see the VI Daily News article below.   Sadly, I learned from Paul Chakroff, Executive Director of the St. Croix Environmental Association, that Waste Management has been dumping large quantities of raw sewage every few months for many years, and DPNR has kept on allowing it, every time. Each time they claim it is an emergency, so that they can qualify under a provision in a 1990 consent order between DPNR and VI Public Works, which is attached.

Paragraph 17 of said agreement states “DPNR records document an extensive chronology of unpermitted discharges of untreated sewage into the waters on all three islands.” Now, 20 years later, Waste Management is still dumping raw sewage, every few months.    I have alerted Judith Enck, our new EPA Regional Administrator, of the dumping. Ms. Enck had just visited the Virgin Islands, and met with not only the local government but also with local environmentalists and concerned citizen groups, one of the first meetings of its kind here with federal agents, which we deeply appreciated. Barely two days after Administrator Enck left, Waste Management suddenly had another quarterly emergency and the dumping began again. The EPA is investigating the matter from their end, but it would help to coordinate agency efforts, and to let the USVI citizens know that you care, because they are killing our coral, and this dumping of raw sewage has been going on and on for years.

Since DPNR is under NOAA, and you are all bureau chiefs and coral experts, won’t you please force Waste Management and DPNR to come up with at least an interim plan, immediately, so they will not do any more dumping? Second, can any funds and personnel be released to evaluate and clean up Long Reef, before it is too late? I emailed Dr. Lisamarie Carrubba, our local NOAA contact, but she has not even responded. Again, this has been an ongoing problem, for decades.  Can’t we please get a task force down here, from National Headquarters, before it is too late?

Waste Management still has all residents throwing garbage into huge dumpsters, without any recycling.  They have agreed to the Alpine plan to build petroleum coke/oil/garbage burning plants here, using the heavy metal refuse from Venezuelan oil, hence very high in sulphur, emitting far greater CO2 than at present, right into Stalley Bay, which the local government characterized a few months ago as “pristine”, and filled with endangered species.

A lease has already been signed to build these plants in St. Thomas and St. Croix, with 444 million of  Virgin Island ratepayers’ money, then run these plants for 20 years, with a renewal for another 20 years. They plan to build a 10 million dollar dock in St. Thomas, with 300 foot barges driving in all of the petroleum coke, ammonia, and other products, and barging out 370,000 tons of fly ash per year, without any spills or accidents. There would be huge intake and outflow pipes of “treated water” going out into this “pristine” bay.  It is very windy here in the Virgin Islands. They plan to build silos to contain only 2 days worth of fly ash. What if the barges were to run into heavy weather several days in a row? Please see the attached letter to Senator Malone, urging him to take action and dispense with Alpine.

I am taking a similar approach with Alpine as to that which worked so successfully in Lindbergh Bay, as you all may remember from October, and caused the local government to withdraw their application to dump dredge spoils just a few days after the letter to USACE was published in the VI Daily News.

In addition to all the citizens and environmentalists who have written daily Letters to the Editor for many months now, and testified before the Senate, and the appeal of the Public Service Commission decision, I am consulting with federal agencies, supplying documentary proof, and publishing the legal analysis, but I am a private citizen, unpaid, without resources or clout of a federal agency. If NOAA has a position for this sort of work, I am your woman, but otherwise it would be of enormous help if the federal agencies would take a more proactive role here, beginning with stopping the dumping of raw sewage onto our reefs.

After all, your agency is spending millions to fund coral and coastal zone programs.  Those monies and efforts are wasted if raw sewage is being dumped on the reefs, and petroleum coke/oil/garbage plants belch out heavy metals, dioxins and high levels of CO2 for the next 40 years.  May we please form a coalition, now, of federal agencies, local agencies, environmentalists and citizens to address our waste and energy issues?  Thank you for your consideration in regard to this matter. I look forward to hearing from you.

Sincerely yours,

Susan K. Wolterbeek

 

Miyoko Sakashita, Esq., Center for Biological Diversity

Dr. Caroline Rogers

Dr. Jeff Miller

Judith Enck, EPA Administrator, Region II

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