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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 May 9, 2024 Jean-Pierre L. Oriol, Commissioner Department of Planning and Natural Resources Charles W. Turnbull Regional Library 4607 TuTu Park Mall St. Thomas, VI 00802 Re: WTJX Request for Coastal Consistency for the Demolition and Reconstruction of the WTJX’s Radio Station on Haypiece Hill, St. Thomas, St. Thomas Dear Commissioner Oriol: WTJX respectfully request a Decision of Coastal Consistency for Demolition and Reconstruction of their radio station Haypiece Hill on, St. Thomas. WTJX is a critical component of the U.S. Virgin Islands’ Communication Infrastructure and the Federal Aviation Administration (FAA) Communication System. The proposed action is to demolish all the existing buildings including the roof structure, exterior and interior walls, windows, doors, floors, and floor slabs. And to demolish all building utilities, piping ductwork, electrical fixtures, and debris down to soil. The plan proposes to removal all concrete decking, sidewalks, and steps to grade and to remove the existing retaining walls, and the concrete and asphalt parking areas. The removal of the existing diesel fuel and wastewater storage building structures and infrastructure and the complete demolition of the existing satellite antenna equipment, their foundations, and slabs. The new facility will then be rebuilt taking advantage of the previously developed areas to minimize impacts. The proposed project would begin as soon as the Coastal Consistency approval is granted as all other permits and approvals and funding are in place. The project will take a total of 24 months to complete. The following policies are set forth in the U.S. Virgin Islands Code Title 12, Conservation Chapter 21, Virgin Islands Coastal Zone Management [V.I. Code tit. 12, § 903(b)]. The proposed WTJX repairs and renovations meet each of the basic goals of the USVI for its coastal zone. Additional details are as follows: USVI Code Title Twelve Conservation, Chapter 21 § 903 (b) (1) protect, maintain, preserve and, where feasible, enhance and restore, the overall quality of the environment in the coastal zone, the natural and man-made resources therein, and the scenic and historic resources of the coastal zone for the benefit of residents of and visitors of the United States Virgin Islands. The project located at Parcels 158 and 158A Haypiece Hill, Southside Quarter, St. Thomas, is situated within the previously developed site. The project will have a minimal impact on any natural areas or undisturbed natural areas or historic resources. (2) promote economic development and growth in the coastal zone and consider the need for development of greater than territorial concern by managing: (1) the impacts of human activity and (2) the use and development of renewable and nonrenewable resources so as to maintain and enhance the long-term productivity of the coastal environment. The project proposes to repair the radio and TV infrastructure to enable the continued broadcasting of the WJTX station which provides critical broadcasting and communication services to the territory. The completely damaged site will be demolished, and the station reconstructed using the existing developed footprint. (3) assure priority for coastal-dependent development over other development in the coastal zone by reserving areas suitable for commercial uses including hotels and related facilities, industrial uses including port and marine facilities, and recreation uses. The radio station is not located within the coastal zone, and therefore will not affect coast zone dependent development within the coastal zone area. The project site is located on a hilltop. (4) assure the orderly, balanced utilization and conservation of the resources of the coastal zone, taking into account the social and economic needs of the residents of the United States Virgin Islands. The proposed project is situated within WTJX’s existing developed property. The proposed project provides a critical public service to the Territory to meet the broadcasting and communications needs of the Territory. (5) preserve, protect, and maintain the trust lands and other submerged and filled lands of the United States Virgin Islands so as to promote the general welfare of the people of the United States Virgin Islands. The proposed project will not impact trust lands or other submerged or filled lands of the U.S. Virgin Islands. (6) preserve what has been a tradition and protect what has become a right of the public by ensuring that the public, individually and collectively, has and shall continue to have the right to use and enjoy the shorelines and to maximize public access to and along the shorelines consistent with constitutionally-protected rights of private property owners; The proposed project will not affect public access to, or use of, the shoreline. The project is located on a hilltop and not on the coastline. (7) promote and provide affordable and diverse public recreational opportunities in the coastal zone for all residents of the United States Virgin Islands through acquisition, development, and restoration of areas consistent with sound resource conservation principles. The project will not affect public recreational opportunities in the coastal zone. The project will provide critical communication and broadcasting services for the Territory. • (8) conserve ecologically significant resource areas for their contribution to marine productivity and value as wildlife habitats, and preserve the function and integrity of reefs, marine meadows, salt ponds, mangroves, and other significant natural areas. The project is not likely to affect any natural resources and is limited to the previously developed site and will utilize best management practices to minimize the area of disturbance and will protect adjacent habitats. • (9) maintain or increase coastal water quality through control of erosion, sedimentation, runoff, siltation, and sewage discharge. The project site is located at the top of Haypiece Hill and is approximately 650 feet from the sea. The hill, and its accompanying slopes, are heavily vegetated, and there are no defined drainageways on the property. Therefore, the proposed actions should have a negligible impact on water quality. BMPs for sedimentation and erosion control will be implemented during all earth disturbance. We look forward to your earliest decision on this manner. Please do not hesitate to contact us if you have any question or concerns at bioimpact@islands.vi. Respectfully submitted, Amy Claire Dempsey, M.A. President, Bioimpact, Inc.