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SEA’s public comments to DPNR on Limetree’s CZM permit application

Updated: Apr 25, 2023



St. Croix Environmental Association, Defenders of Wildlife, and the Center for Biological Diversity partnered to submit comments regarding Limetree Bay Terminals and Limetree Bay Refining’s latest Major Coastal Zone Management permit application. SEA has significant concerns about the negative environmental impacts and urges the Coastal Zone Management Commission to deny the application. While SEA understands the need for economic opportunities in the USVI, the restart of the oil refinery must comply with Federal and Territorial law and thus cannot imperil human health and welfare, tourism, and marine and terrestrial environments.


The permit application and its Environmental Assessment Review aims to restart the oil refining activities and consolidate the Refinery’s permits into one “master permit” – an act that would decrease transparency to the public. SEA believes that Limetree must provide more transparency in the application and comment process, not less, so the public can be informed about Limetree’s impacts on our environment. Already too many communities and ecosystems have been contaminated by Limetree’s predecessor Hovensa, so Limetree must do better to ensure environmental protections, especially given the reality of severe hurricanes such as Maria and Dorian, as well as safeguarding our welfare and safety.

SEA’s specific concerns with the Environmental Assessment Review provided in the application include insufficient details regarding:

  1. Human and Environmental Health: insufficient data on public health impacts of refinery restart, exposure to VOCs and other toxics, and possible refinery-related increase in cancer rates;

  2. Extreme Weather Events and Earthquakes: lacks mitigation measures to prevent and adequately respond to oil spills (i.e. Hurricane Dorian in the Bahamas); acknowledgement of the latest climate science on increasing numbers of severe hurricanes and changing rainfall patterns; and no contingency plans to deal with earthquakes or tsunamis;

  3. Climate change impacts: lack of discussion of facility ability to adapt to temperature increases and droughts, resulting wildlife and coral reef impacts on the coastal ecosystem, increased sea level rise, coastal flooding, storm surge, and higher contributions of GHG emissions into atmosphere;

  4. Wildlife impacts: inadequate plans to protect the 22 threatened and endangered species that stand to be impacted by the facility, prevent and mitigate oil spill impacts on wildlife, potential impacts of an oil spill on Sandy Point Wildlife Refuge, potential impacts from increased vessel traffic; and compliance with Federal and Territorial laws governing endangered species protection;

  5. Water quality: lacks detailed discussion of contaminated water leakages into water resources and compliance with the Clean Water Act;

  6. Air quality: vague statements about compliance with the Clean Air Act and plans for emission reduction modifications that lack needed transparency;

  7. Long-term economic impacts: need to include more detailed data pertaining to economic impacts of oil spills and reef-related tourism;

  8. Permit Process reform: streamlining and consolidation of the permit process is an obstruction to promoting public participation and DPNR’s jurisdiction to review CZM permits

Read the full Major Coastal Zone Management (CZM) Permit Application No. CZX-10-19(L&W) comments document


CZX-10-19LW-Comments-SEA-CBD-DoW-Neville
.pdf
Download PDF • 282KB


SEA thanks DPNR for reviewing and considering our public comments.

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