Army Corp of Engineers Asks for Comments on Coral World Dolphinarium Case # SAJ-1976-89037 (SP-EWG)

Alana: Is someone from the STEER committee involved? I know that isn't part of their territory, but they do have a lot of knowledge in water flow, current, etc. on the lagoon side of St Thomas.

I'll PM you the contact info to inquire directly.

As you probably know, the Governor of the Virgin Islands has signed the permit allowing Coral World to construct a 2-acre dolphinarium for swim with the dolphin tourist encounters and shows.

Coral World must still obtain a permit from the US Army Corps of Engineers. See the notice of public comment below this message and if you click on the link you will find more details. The Army Corps (ACE) permit covers environmental issues. The ethics of keeping dolphins in captivity are not involved with this permit so comments on that issue are not appropriate.

The public has a right to request a public hearing but in order for that to be granted we need to flood ACE with letters.

We are asking that you do the following:

1. Immediately send a short letter (1 or 2 paragraphs is fine)
(a) requesting a public hearing with specific reasons for your request. Those reasons can be as simple as the fact that this is an important/ highly controversial project and the public hasn't been given sufficient opportunity to comment.

(b) request that they extend the public comment period for a further 15 days from the 20 days in the notice (that date only allows comment until Nov. 30). 20 days is insufficient to get this notice out to the public at large and allow them to respond.

Your letter must reference:
Coral World Dolphin Exhibit Enclosure
File: SAJ-1976-89037 (SP-EWG) and be mailed to:

District Engineer, Antilles Permit Section

400 Fernandez Juncos Avenue

San Juan, PR 00901

We will arrange to pick up and mail your letters if you can't get them out yourself. The criteria for ACE to hold a public hearing is the number of letters they receive requesting one. Please tell your friends, forward this email to as many people as you can.

If you want me to send you a template I can. Individual letters are best but we know it's hard to get some people to write letters so petitions with lots of signatures can be sent too.

2. Send a separate Comment letter with the file number to the same address.

Unless they grant an extension your letter must be received by November 30.

Some of you know the issues. Comments do need to mention specific issues: for example water quality, construction issues, potential effect of dolphin feces on corals, damage to corals by their removal to build the pens, fish habitat, threatened or endangered species, adjacent wetlands, esthetics, economics, conservation, etc. For those of you who need some guidance with this, I will be sending out some bullet points to be compiled by a professional who is assisting us, within the next week.
If you have a concern about just one specific issue that's fine -- we don't expect you to cover everything.

Please please start by mailing a brief letter per item #1 above, requesting a public hearing and extension of the public comment period.

Please don't hesitate to email me: fionausvi@gmail.com if you have any questions or ideas or can help in any other way.

Thank you for your assistance and support. At this time these letters have to be sent by US mail. Unfortunately there is no email address to send comments.

Fiona

COMMITTEE TO SAVE WATER BAY
VI DOLPHIN VOICES
340-626-4690

A public notice for the permit application described below has been posted at http://www.saj.usace.army.mil/Missions/Regulatory/PublicNotices.aspx

Classification: UNCLASSIFIED
Caveats: NONE

Project Name: Coral World Dolphin Exhibit Enclosure
County: St Thomas
Comment Due Date: 30 November 2013
File Name: SAJ-1976-89037 (SP-EWG)

WATERWAY AND LOCATION: The project would affect waters of the United States associated with the Caribbean Sea. The project site is located at Water Bay on the north shore East End, St. Thomas.

PROPOSED WORK: The applicant proposes to build a dolphin exhibit as an addition to Coral World Ocean Park attractions. The project consists of a nearshore dolphin exhibit enclosures and a land side support and visitor education center. The "Education Center" is a 2 story structure located adjacent to the shore; it provides observation of the nearshore pens, facilities for staff and medical personal, storage for emergency and service equipment, and visitor orientation with public displays/changing area. The second floor will contain security center, personal living areas and additional sleeping areas for emergency and visiting staff. The dolphin pens are enclosed (approximately 300 feet x 250 feet) using the docks as the perimeter (Main Dock). The program is currently set for interactive encounters with up to 10 dolphins; this type of facility requires additional smaller pens located within the perimeter. The Main Dock is 12 feet wide with an elevation of 3.5 feet above mean high tide, service pen docks are 5 feet wide set 1.5 feet above mean high tide. The structures would be supported by a total of 158 pilings. The public will access the Dolphin Habitat via a 6 feet wide boardwalk ("Dolphin Walk"), integrated into the shoreline south of the staff roadway. There is one point of water access, a specially orchestrated gate will allow the access necessary for maintenance, and the interaction programs that will use special boats/or floating platforms. This same gate will be available in the future when dolphins are able to leave the pens to venture out into open water.

To provide security for the animals and facilities, as part of their request Coral World has set aside a "no access" zone 40 feet wide following the perimeter of the Main Dock. 3 warning buoys and approximately 100 float and lines between the buoys and the shore are proposed to restrict access of vessels.

The structures would impact approximately 0.32 acres (13,929 square feet) of scattered coral habitat, 0.01 acre (436 square feet) of seagrass in Porites rubble, 0.01 acre (436 square feet) of hard bottom and 0.02 acres (872 square feet) of scattered seagrass and coral.

Classification: UNCLASSIFIED
Caveats: NONE

http://stthomassource.com/content/commentary/open-forum/2013/11/15/coral-world-grateful-dolphin-habitat-project-outcome

Army Corps. of Engineers and NOAA have not yet signed off on this so please write them.

Here is an e-mail I rec'd:

Some of you have asked for talking points to use in your Comments Letter to the US Army Corps of Engineers (per the email sent earlier this week).

Here are many of the environmental issues (the scope of this permit does not cover the ethics of keeping dolphins in captivity). You can choose some or all of these points in your Comments Letter and of course put them in your own words if you wish.

Talking Points for the Army Corps of Engineers re: Coral World dolphinarium

Environmental Impacts

·

Cetaceansproduce a significant amount of waste on a daily basis, which in the wild is normally not concentrated in a single location. If flushing of the proposed dolphin enclosure area through tidal flow and/or current is inadequate, then the waste from several dolphinsand decaying fish parts that these dolphinsdo not consume during feeding can concentrate in an abnormal manner and accumulate around and through reefs. This material, consisting of organic debris, nutrients, and fecal coliform bacteria, can cause abnormal levels of algal growth, which can smother and kill corals and also sea grass beds. Biodiversity in such affected areas can decrease substantially – a study by Goreau (2003) suggests that this negative impact on reefs near open water dolphin pens has already occurred in Cozumel.

· The permit application cites only one study in its discussion of mechanisms by which dolphin waste will be eliminated from the enclosure: Sazima et al. (2006) which reports that dolphin waste is naturally consumed by certain fish species that associate with dolphins. The permit application implies that this fish consumption will reduce the dolphin waste burden inside and even outside the enclosure substantially. However, Sazima et al. (2006) was a study of wild dolphins, making the comparison an apples-and-oranges exercise.

In addition, the study focused on a different species (spinner dolphins) and an entirely different ecosystem (and hemisphere – the study was conducted in Brazil). While it is probable that some dolphin feces in Water Bay will be consumed by some fish, this is unlikely to be a major mechanism of eliminating waste from the enclosure or outside it, as 1) the waste will be concentrated in an artificial manner (see above) and 2) the fish species in Water Bay will not rely on dolphin waste as a food source, given that wild dolphins do not regularly inhabit this area and this type of scavenging relationship will have had no opportunity to evolve as a result.

· Coral World plans to relocate a large number of heads of the boulder coral, Montastrea annularis (which will soon be listed under the U.S. Endangered Species Act), as they are found within the footprint of the proposed enclosure. Coral World claims that other corals outside of the footprint will not be affected, due to flushing of the enclosure area. These more distant corals are endangered (Acropora palmata) or about to be listed (Dendrogyra cylindrus), which emphasizes at a minimum the need for references supporting these optimistic claims (no references supporting these predictions of “no impact” are provided in the permit application) and potentially the need for focused studies examining how this concentration of wastes might affect the corals in Water Bay. An ESA Section 7 consultation will also be required.

· Coral World is also claiming that water quality overall in the area will not be affected by the dolphin enclosure, either during construction or operation. These claims again are difficult to evaluate without knowing more about the water movement in Water Bay and the effect on that movement from the fencing and wave barrier to be installed. The permit application acknowledges that the fencing and wave barrier will reduce water movement, but downplays its significance. The claim that other sea pen enclosures have not experienced water quality impacts is both incorrect and irrelevant. There are in fact other facilities (see, for example, Alaniz and Rojas 2007) that have had significant water quality impacts; and while some facilities may have had minimal impacts, the water movement (and thus flushing of effluent) in these other areas may be greater than in Water Bay. Coral World provided water quality information for several other facilities, but no water movement data – both are necessary to support any comparison between two different sites.

· Coral World acknowledges that eutrophication has been an issue in Water Bay in the past but implies that this is a minor and easily addressed concern, when in fact there is insufficient information in the permit application to support this optimism.

· The permit application claims that harmful algal blooms are rare in the Virgin Islands. The lack of harmful algal blooms in the Virgin Islands historically is not a valid predictor of their future occurrence, given that the occurrence of harmful algal blooms is increasing globally.[1]

· At a minimum, adequate references must be provided before a confident conclusion can be drawn regarding the suitability of this site for a dolphinarium in regards to water quality. The permit application mentions “a number of studies…in regard to dolphin enclosures” (p. 92) and water quality that have been conducted, but does not cite them – at a minimum, Coral World must provide these citations.

References

Alaniz Pasini, Y. and L. Rojas Ortega. 2007. Delfinarios. AGT Editor, S.A. and Comarino, Mexico City, Mexico.

Goreau, T.J. 2003. Dolphin enclosures and algae distributions at Chankanaab, Cozumel: observations and recommendations. Report of the Global Coral Reef Alliance, Cambridge, Massachusetts, available at: http://www.globalcoral.org/Dolphin%20enclosures%20and%20algae%20distributions%20at%20Chankanaab,%20Co.htm

Sazima, I., C. Sazima, and J. Martins da Silva, Jr. 2006. Fishes associated with spinner dolphins at Fernando de Noronha Archipelago, tropical Western Atlantic: An update and overview. Neotropical Ichthyology 4:451-455.

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[1] This is likely a climate change-related phenomenon – see, for example, recent reports from the International Whaling Commission Scientific Committee’s Standing Working Group on Environmental Concerns at www.iwcoffice.org.

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If you haven't already sent a letter requesting a public hearing and an an extension of the 20-day Public Comment period (woefully inadequate for such a major and controversial project) then you can include that in your Comments letter.

The deadline for Comments is Wednesday, November 27 (the day before Thanksgiving) so please mail your letter within the next week to:

Mr. Edgar Garcia
District Engineer, Antilles Permit Section
400 Fernandez Juncos Avenue
San Juan, PR 00901

Please reference: Coral World Dolphin Exhibit Enclosure
File: SAJ-1976-89037 (SP-EWG)

Sorry, there is no email address to send Comments, they must be mailed.

Fiona Stuart
340-626-4690 (cell)

SAVE WATER BAY COMMITTEE
VI DOLPHIN VOICES

Never doubt that a small group of thoughtful, committed citizens can change the world. Indeed, it is the only thing that ever has.
Margaret Mead