SEA presented comments to the Coastal Zone Management (CZM) Commission at the November 6, 2008, public hearing on the William and Punch development proposal. The full text of those comments and the related attachments can be accessed through the links below.

SEA is not opposed to a major development project at the William and Punch site, and SEA believes its concerns with the William and Punch Environmental Assessment Report (EAR) can be addressed. Our concerns relate primarily to the adequacy of the EAR and appended documents as currently submitted to CZM to meet the requirements of territorial and federal environmental law.

Insisting on an adequate EAR and other components of the CZM application is key. The CZM record and the conditions associated with the CZM permit will provide the basis for holding the developers (and their successors) accountable for their commitments to an environmentally sound and sustainable development. Now – before the permit is issued -- is the time to define those commitments in detail and memorialize them in the written requirements associated with the CZM permit. That is the purpose and thrust of SEA’s comments.



Summary of SEA testimony November 6, 2008 (not all delivered orally due to time constraints).

SEA's full written testimony to CZM November 6, 2008 (attachments below).
Attachment A: Letter from SEA to William and Punch, LLC, October 24, 2007. First written communication regarding environmental concerns.
Attachment B: DPNR Division of Fish and Wildlife comments to CZM (September 2008).
Attachment C: SEA comments to Army re: Section 404 permit, March 28, 2008.
Attachment D: US Fish and Wildlife comments re: Section 404 permit, May, 2008.
Attachment E: The Palms turtle lighting plan, July 2008.
Attachment F: Memorandum of agreement between the Department of the Army and US EPA.
Attachment G: Judge Brotman 1994 legal opinion regarding CZM requirements.
Attachment H: Audubon Golf Management practices.
Attachment I: Blue Flag marina criteria and notes.

SEA letter to the Avis regarding SEA testimiony on William and Punch, November 7, 2008.

CZM staff recommendations, January 14, 2009. The conditions in these recommendations were referenced in the CZM Commission's motion to approve the project permit, with the exception of #17 which was amended to lengthen the amount of beach to be maintained..
Coastal Zone Water Quality Review and Certification for William and Punch project, January 14, 2009.