Letter to NPS from Tonia Lovejoy, Executive Director Regarding Caneel Bay

On January 18, the National Park Service (NPS) published Caneel Bay Redevelopment And Management Plan Newsletter outlining the options under consideration for Caneel Bay, announcing opportunities for discussion, and asking for written feedback by March 4, 2022. This letter is the comment of Friends of Virgin Islands National Park:

March 3, 2022 

Superintendent Nigel Fields | Virgin Islands National Park

Caneel Bay Redevelopment and Management Plan Newsletter| Pre-NEPA Public Comment Period (Feb-March 2022)
Tonia Lovejoy | Executive Director | Friends of Virgin Islands National Park

Imagine a place pristine as any you have known. Like an emerald shining in waters clear blue, with beaches bright with coral sand, and trade winds steady, this place is a rare jewel. Endemic and rare plant species are found deep within its forest canopy. Around its coral-fringed shorelines, critically-endangered sea turtles, rays and fish can be spotted. Trails cut along its craggy hillsides reveal ruins that whisper the stories of the enslaved, and buried beneath the sands there is evidence of ancient people living nearly everywhere on the island. Truly, the biggest lessons for humanity are woven into its past, present, and perhaps future.

This place is the 24-square mile island of St. John, the smallest of the 3 islands that make up the U.S. Virgin Islands. Largely protected as Virgin Islands National Park and Coral Reef National Monument, the island is home to roughly 3,800 full-time residents, around 700 of which are school-aged youth. There are 3 schools, 2 towns, and 3 gas stations. There is no hospital, though we have a clinic that can take you via ambulance to the 1 emergency boat for a trip to St. Thomas. There are no lifeguards at any of the beaches. In 2016, a peak year for visitation, roughly 1 million visitors came to St. John.

As the philanthropic partner of Virgin Islands National Park since 1988, Friends recognizes it serves the public as both a vehicle and a voice to advocate for the preservation and protection of the natural and cultural resources found in Virgin Islands National Park and Coral Reef National Monument. As such, we are deeply vested in the future of Caneel Bay both on behalf of our members, our community on St. John, and future generations.

As we learn to live in the face of adversities such as hurricanes and pandemics, an evaluation of our gifts is apparent; we understand acutely that our protected natural and cultural resources are the greatest assets we can pass on to future generations. All too often our island communities, on the front line of climate change, small in scale, and dependent on tourism for their economy, are presented with choices that weigh protecting the environment for future generations against a promise of economic gain. Unsustainable compromises are often made in design and development without a understanding the cost of doing business on a tiny island at the end of a supply chain, leaving island residents with empty promises and subpar infrastructure to pass on to their children.

In fact, it is this reality that brings us to consider the redevelopment of Caneel Bay. Were it not for the complete devastation of the property in the two Category 5 hurricanes that hit the island in 2017, we would not find ourselves with this opportunity. Now, we can recalculate the destiny of this treasured part of the Park. We can respond to the current landscape that is St. John in 2022, and listen intently to comments from the St. John community, which reside in and around the Park.

Though St. John has remained largely protected from development as compared to its sister island of St. Thomas, its particular brand of tourism is driven by the Park. Thus, the NPS development decisions regarding Caneel Bay will continue to impact the St. John community and its socio-economic trajectory as a tourist destination for generations to come.

We need the NPS to meet its mission to “preserve unimpaired the natural and cultural resources and values of the national park system for the enjoyment, education, and inspiration of this and future generations” in particular when faced with decisions that will have long-lasting ramifications on land management and public access.

Friends advocates for NPS to:
1. Continue to be responsive to public feedback with the spirit and intent of NEPA.
2. Share insights as to why and how NPS makes its determinations, such as to pursue an EA or EIS, or offer another public scoping period for a draft review before any final packages or determinations are made.
3. Make information about the known environmental hazards on the site available to the publicas well as making information available regarding the remediation of those hazards.

There are a myriad of visions for the redevelopment of Caneel Bay. As our Park Superintendent Nigel Fields has stated, “It is important to understand that this process does not call on the public to vote for a particular concept, rather to offer meaningful feedback and insight that will help inform the NPS approach moving forward.” With that in mind, in response to the “Caneel Bay Redevelopment and Management Plan Newsletter”, Friends kindly requests the NPS take the following into consideration:

HOUSING: The landscape of St. John’s vacation rental model has changed dramatically as a result of the Hurricanes in 2017, the introduction of the AirBB marketplace, and the global pandemic. Similar to other communities which are near National Parks, we are experiencing a long-term and affordable housing crisis on the island resulting in an exodus of local families who are unable to afford to live on St. John. Investigation and research into the median home price reveals a significant increase in property value since the establishment of VI National Park. The most expensive private home real estate for sale on St. John presently is $16,999,000. A one-bedroom rents for $1000 per month or more. Any future employer/lease at Caneel Bay would need to address the existing employee housing crises.

EMPLOYMENT: A luxury resort or any additional overnight accommodations would necessarily increase the demand for employees both from the private sector and the NPS. The increased demand for workers, given the housing crisis, could create a vacuum for labor, further challenging locally-owned small business owners. Present-day Cinnamon Bay Resort concessionaire operator aims to employ locals, and even with a highly competitive employment package, has struggled to hire enough staff to operate. Another example, CBIA sub-leasee VI Ecotours, operating at Honeymoon Beach out of the Caneel Bay Property, has offered employee housing on St. Thomas as incentive to staff the business on St. John. Prior to 2017, when in operation, current RUE holder CBIA had shifted its employment model from its predecessors to employ workers seasonally and offered private housing outside the Park.

WASTE MANAGEMENT: St. John does not have municipal/city trash collection system, or a landfill. All waste is collected and is shipped via barge to the dump site on St. Thomas, which is operated in violation of numerous environmental regulations and is subject to a 2012 Federal Consent Decree for failing to meet environmental standards. Waste management, construction waste, storm/waste water runoff, and other factors that led to pollution on land and sea are serious concerns for the island.

SUSTAINABILITY: Most everything on St. John is imported today. Rainwater is collected through cisterns for most residents. The land is rocky with very little top soil, making growing (and building) difficult. In short, modern life on St. John is hardly sustainable. Any development plan for Caneel Bay needs to take into account, and plan for, long term pressures including the ability for the island to handle an increased number of visitors and related traffic, waste management etc. Friends urges the NPS to review and consider the conclusions of the Vision 2040 economic plan for the VI, as well as engage with the residents in participation in the upcoming Comprehensive Plan process by the VI government, due to start on St. John in the next few months and be completed within 16 months (Vision 2040 and Comprehensive Land and Water Use Planning in the Virgin Islands). Each of current options presented would strain the island’s capacity to function sustainably across all public sectors. Both NPS and the VI Territory would need to re-invest in current infrastructure to meet basic compliance standards. Friends urges the NPS to look through a more global lens, and take into account well-documented weather patterns of the USVI, including the frequency of Category 2 or higher hurricanes. Devastating hurricanes have been recorded since 1780. Most recently Hurricane Hugo in 1989, Hurricane Marilyn in 1995, and Hurricanes Irma and Maria in 2017 struck St. John causing catastrophic damage, which the island is still recovering from today. The devastation caused routinely by hurricanes should be enough to make NPS pause before ascribing to adding any near-coastal infrastructure to the Park.Land elevations and flood plain must be evaluated and inform any development/use of land decisions. To determine the best uses of the 150 acres, it is necessary to review in the context of the topography, vegetation (forest, meadow, beach), and cultural and natural resource locations. To do this, aerial photos with topography overlays are readily available on the VI government GIS site. For example, all of this flat(er) and open land area that would be accorded to the resort in the A option could have more broad use for the NPS purposes and visitor experiences on St. John, especially because of the proximity to the main island population center: Cruz Bay – and ready access from all points on the island, and by sea.

PARKING: Currently there are about 200 designated parking spots available in the Park. Traffic feeding into the Park is completely unmanageable in Cruz Bay and numerous efforts are being launched by the private sector and the Territorial government to identify solutions. Friends funded in 2009 in partnership with VIIS a Transportation Study which includes the best solutions to pursue, none of which have been implemented. Due to the current volume of park visitors afforded by the AirBB housing market (and other accommodation options on island) the Park has been overwhelmed and over-capacity for the past few years, resulting in violations that damage Park property (parking on vegetation) and cause safety hazards (parking in road). Regardless of the development options pursued by the NPS, VIIS must work in partnership with local agencies and partners to offer a sustainable transportation option (shuttle service) for park visitors. Friends objects to the construction of a road to Hawksnest Beach. Aside from the construction and maintenance impacts to natural and cultural resources in the area – the new vehicle traffic impacts to this pristine area are not acceptable. That road would be a NPS responsibility to maintain and the park cannot begin to adequately maintain current park roads (aside from the North Shore Road). Adding to that road inventory – especially when the road would never qualify for Federal Highways funding (the only funding that keeps North Shore Road up to standards) ignores the fact that the park cannot adequately maintain its current inventory.

RESOURCE PROTECTION: With 7 busy nesting beaches for the critically-endangered sea turtle, fringing coral reefs, plus known evidence of a robust settlements of humans (Amerindians) never before excavated, not to mention unique rare plants, the 150-acre Caneel Bay property is like a time capsule, demonstrating a level of preservation rare in the 21st Century! The Durloo Plantation, the largest ruins on the Caneel Bay property, was the epicenter for the 1733 Slave Revolt. As the earliest and longest slave revolt in the Americas, this event makes Caneel Bay one of the most significant sites in the Americas for interpreting slavery – the most relevant interpretative site in Virgin Islands National Park – and extremely culturally significant to ancestral St. Johnians.

Friends urges the NPS to take stock of the natural and cultural resources on the Caneel Bay property before the crafting of any lease or concessionaire agreement so that it can develop a Protection and Resiliency Plan to inform future land management decisions. Caneel Bay, like Cinnamon Bay, should be part of the National Register of Historic Places. Similar to assessing the land for its best use based on environmental conditions, such as elevation, so too should the property be assessed for cultural preservation and areas of significant cultural significance where ongoing archeological work and investigation should occur. These areas must be identified prior to any division of land for development/commercial lease purposes.

PARK OPERATIONS: To get an accurate understanding of potential impacts from what is being proposed in any of these alternatives the NPS should make it clear to the commenting public what the NPS funding and staffing requirements have been since the development of the Caneel Bay property by Mr. Rockefeller. 

The reality of VIIS current operational challenges due to severe budget limitations must be addressed at this juncture. With less of a budget than the early 90’s, VIIS struggles to keep the Visitors Center open just 5 days a week, let alone lead interpretative activities. Friends of VI National Park contributes on an annual basis more than $1 million in support of park programs, in addition to management and maintenance of the Park’s 27 miles of trails. VIIS has 2 interpretative rangers, neither is a Virgin Islander. 1 was hired in January, and the other is retiring in June 2022 after 25 years. We have 3-4 enforcement officers, 1 is on a 6-month detail. We currently do not have a Chief of Enforcement, Maintenance, or Interpretation. In short, VIIS is critically challenged to meet the mission of the NPS due to its severe lack of operational funds today.

Prior to the RUE in 1983, Caneel Bay was private property within the authorized boundaries of Virgin Islands National Park. The amount of park funding and staff required related to its operation was pretty much zero. After the RUE that responsibility and those costs increased by very little. Practically speaking – Rockefeller absolved the NPS of responsibility for monitoring, overseeing, or regulating operations of the resort. This has meant, for example that the park commercial services group (another historically understaffed and underfunded office) had no responsibility for monitoring, inspecting, or approving anything related to the operation of Caneel Bay Resort. No fee review or approval, no food service inspections, no lodging inspections, no safety inspections – nothing. No responsibility to respond to guests concerns or any issues related to the guest experience on the resort. This applies to every single park office and operation from environmental monitoring, to providing for the health and safety of resort guests, monitoring the natural and cultural resources, to ensuring that the infrastructure (water, sewer, roads, buildings, trails) on the resort are being maintained. None of these issues have been the day-to-day responsibility of the national park service or the local park staff. Once the RUE expires all these things and many not mentioned, will be the full responsibility of the local park staff. Every alternative proposed will put significant financial and staffing strains on an already underfunded park. Three of the four listed objectives for Caneel Bay would require a significant increase in park annual operating funds and permanent staff. Without an increase in operational funding and staffing the Superintendent can only fail to meet the legal and policy requirements or be forced to take funding from other underfunded park operations to increase the size of the commercial services personnel. This means less trash pick-up in the park or less cleaning of restrooms, less presence in the park by interpretive and protection rangers, less staff to protect and monitor the natural and cultural resources, etc. Friends urges the NPS to hire and train Virgin Islanders, which would empower local constituency in the act of environmental stewardship and conservation work, while also reducing the strain on the rental housing market. This would also help the NPS fulfill its commitment as cited in the VIIS enabling legislation “The Secretary is authorized and directed to the maximum extent feasible to employ and train residents of the Virgin Islands to develop, maintain and administer the Virgin Islands National Park.”

Friends urges the NPS to do a feasibility study of its own to imagine how it might operate to manage and protect the property while offering visitors access by using the mechanisms for generating income currently in place – mooring rental, pavilion rental, daily fees – as well as a pay parking lot. For example, what would be the revenue generated IF VIIS was properly staffed and able to collect overnight mooring fees from vessels in Caneel Bay (currently compliance is estimated at less than 30%). What could be the income generated by an event space (such as the one destroyed in 2017 at Maho, which the NPS chose not to rebuild due to the location being near-coastal and in a flood zone prone to hurricanes) and/or pavilions? How could the NPS charge a daily visitor fee (offering a local resident rate) to fund additional fee collectors and locally-hired NPS staff? What could a pay parking lot, daily entrance fee, and the ability to effectively collect rental fees from boat moorings and pavilions afford the Park? 

In closing, Friends will continue to advocate for the protection of the resources cradled in Caneel Bay on behalf of the people. Likewise, we support the NPS in meeting its mission and will continue to do all that we can to help Virgin Islands National Park and its staff. We thank you for your consideration.

Warmly, Tonia Lovejoy