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Stopping the intentional dumping of raw sewage

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From: Susan Wolterbeek []
Sent: Tuesday, November 06, 2012 12:39 PM
To: ‘’
Cc: ‘’; ‘’

Subject: Stopping the intentional dumping of raw sewage into VI coastal waters; working with the federal government and citizens on WAPA and VIWMA
Importance: High

November 4, 2012

Edward Horton

Chief Administrative Officer


Dear Chief Administrative Officer Horton:

                                                                       I am writing to you on behalf of, an environmental organization of 4,966 Americans, growing larger every day, and we really need your help. VI Waste Management has been intentionally dumping raw, untreated sewage into our Virgin Islands coastal waters, with the full awareness of the EPA, the Federal District Court and the local government, for the past 29 years. Please see the Federal District Court Order of 3/31/11.

In February, 2010, Regional Administrator Enck sat at my dinner table and promised to soon stop allowing VI Waste Management to dump raw sewage into the very waters where we swim and snorkel, and where the coral and turtles and local fish live.

Since that promise, 2 ½ years ago, VIWMA has dumped an estimated 300 million more gallons of raw, untreated sewage into our coastal waters. We hope you agree that VI Waste Management should not be allowed to keep dumping raw, untreated sewage any longer than 29 years.

Now dozens of our beaches are polluted. Trip Advisor talks of the smell of raw sewage in areas of St. Croix, so this pollution is obviously negatively impacting Tourism, which our economy is based upon, as well as killing the remaining 3% of coral and polluting the nutritional food vital to hawksbill and green turtles, who are also supposed to be protected by your Endangered Species laws.

None of this is accidental. As May Adams Cornwall testified on May 11, 2011, much of the dumping could have been averted by purchasing, repairing and maintaining the necessary pumps. She openly blamed this on executive failure of VIWMA, of which she is the Chief Executive, and admitted VIWMA had not followed the Emergency Court Order of 3/10, even to purchase certain Court Ordered pumps.

Every single dumping of raw sewage is a violation of federal criminal and civil laws, including the Endangered Species Act and the Clean Water Act, yet no federal agency has taken charge, no one is being held responsible, or accountable, and the dumping continues, often on a daily or weekly basis. By law, the EPA has an absolute duty to report each of these federal violations to NOAA and must formulate a plan to stop the dumping and help our underwater community. We have written dozens of letters to Bureau Chiefs at NOAA, and they say they are following the EPA’s lead, yet the dumping continues.

We filed an Emergency Motion to Intervene/Citizen’s Suit in Federal District Court, against Waste Management and the EPA on May 12, 2011, which is attached. 18 months later, nothing has happened. Administrator Enck says she is currently understandably busy with the aftermath of Hurricane Sandy on NY and NJ, but why, in 3 decades, are we never a priority? You can read all the filed documents and letters on our website at

WAPA, our power company, is also polluting our air and coastal waters, as you can see by the enclosed photos, and WAPA is crippling the people and businesses of the USVI, charging us 600-800% of the average US rate, while working at as low as 13% efficiency, according to a federal audit. Many VI Businesses are struggling endlessly to hang on, or are going into bankruptcy. We have written to the Inspector General’s Office of the Dept. of Energy, who said they would investigate…yet this month we have just gotten another unjustified rate increase.

At this point, we can either plead with the Third Circuit to finally enforce these federal laws, or work together, as we have been requesting of the federal agencies all along. We are asking the Governor and prospective VI Senators to commit to support a joint committee of local government, NOAA, the EPA, Dept. of the Interior and the Dept.of Energy and to work together, to achieve our goals of:

  1.  Finally stopping the dumping of raw, untreated sewage into VI coastal waters;
  2.  Creating recycling centers, with comprehensive structure, funding, and plan implementation;
  3.  Utilizing efficient, environmentally sound energy systems which will substantially decrease cost per customer as low as reasonably possible;
  4. Working with, which will maintain a website providing up to date information, schedules, transparency of data, studies, information, a blog so that all caring citizens may weigh in with their thoughts, physical help, equipment, and volunteer fulfillment of work and materials.
  5. Comprehensive study of the coastal waters and a clean-up and rejuvenation plan;
  6. Payment to implement all this through combining discretionary funds from the various federal agencies;
  7. Agreement by the local government to not oppose us, but to work together to achieve these goals.


It is election day, a tremendous opportunity for change. Senator Sean Michael Malone, and prospective Senators Clarence Payne and Andreas Tietje have proven themselves time and again to be concerned protectors of our environment. We are going to polling areas, and calling on prospective Senators. We hope that all members of the new VI Legislature will agree to make WAPA and VIWMA our joint priority and will agree to a simple pledge that we must work together, now, to protect the environment in which we live.

We look forward to hearing from you, as soon as possible. We are available by the below phone or email 24/7.






Susan K. Wolterbeek

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