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P.O. BOX 132 KINGSHILL ST. CROIX, U.S. VIRGIN ISLANDS 00851 bioimpact@islands.vi Bioimpact.islands.vi@gmail.com 340 690 8445 fax 340 718 3800 August 25, 2025 Honorable Senate President Milton E. Potter 36th Legislature of the United States Virgin Islands The Capital Building Charlotte Amalie, U.S. Virgin Islands 00802 Re: Summer End Marina Federal Permit Status Dear Honorable President Potter, and Senate Members, Over the last several years Bioimpact Inc. has been working with SEG and federal agencies to further reduce the impacts of the marina, and to develop mitigation for the impacts of the development of the marina. In 2022 and 2023 benthic studies were updated using the most recent NOAA survey methods. The 2023 surveys once again documented the changes that were occurring in Coral Bay Harbor, including the impacts left by the sargassum inundations and passing storms. SEG worked with the agencies to reduce the overall impact of the marina and reduced the slip count to 115 and removed the managed mooring field. In order not to require a Coastal Zone Management (CZM) permit modification no changes were made to the design, footprint or construction methods, only the reduction of the project size by removing piers from the dock design and reducing dock lengths. What is proposed is within the original permitted footprint and the project will be using the same construction methods that were originally evaluated during the permit review by CZM. We then worked with NMFS to determine the agreed upon impact of the marina including both direct and indirect impacts. The impact calculations included both construction and operational impacts. Once the impact numbers were agreed upon, we began to develop mitigation plans to address each agency’s concerns and to offset the impacts. This is a process that has taken years and through this process SEG has taken the steps necessary to satisfy each of the federal reviewing agencies. National Marine Fisheries Service (NMFS), Protected Resources Division (PRD) agreed that the outplanting of 3000 ESA corals which will be grown by CWORI, and outplanted in Coral Bay would offset the potential impacts to corals. EPA wanted a watershed management plan and long-term monitoring of water quality in the bay. PRD and Habitat Conservation Division (HCD) decided to use the Uniform Mitigation Assessment Method (UMAM) to determine the mitigation for the seagrass. We work with the USACE and developed a mitigation strategy which restores, enhances and creates mangrove wetlands in 3 areas in Coral Harbor, one adjacent to the marina, one located to the northwest on USVI held land and one on the eastern side of Coral Harbor on land acquired by SEG. In each of these areas, mangrove wetlands will be enhanced, restored, and created, and at the end of the development phase these wetlands will be turned over to Virgin Islands Government under the management of USVI’s Division of Fish and Wildlife. With creation of these wetlands, we were able to tip the balance and offset the potential impacts of the project and these numbers did not include the mitigation already proposed for the coral outplant, and watershed management, which if they could have been considered in the scores would push the mitigation score even higher. Furthermore, as we were looking for mitigation ideas one of the potential mitigation ideas was the installation of moorings for large yachts for which moorings are not currently available. NMFS decided not to include that measure in their UMAM calculations to offsite impacts, but SEG felt that this was a worthy mitigation and committed to providing ten moorings for large yachts in Coral Bay. SEG will work with DFW on establishing locations and will install and maintain these moorings and these mooring would fall under the management of DPNR/DFW. This has been an exceptionally long very detailed process that has taken years, and we now are in the final stages of permitting. With the length of time the process has taken, new species have been listed as federal endangered species, and as late as Sunday this week we were doings survey for the recently listed queen conch to determine if any additional measures may be required. It has taken years for Summers End to get to this point where the federal permits will now be issued, and to get here SEG has committed to perform significant amounts of mitigation and will be putting up financial assurance instruments to ensure that these actions are implemented. Respectfully submitted, Amy Claire Dempsey, M.A. President, Bioimpact, Inc.