V.I. Conservation Society and EAST urge CZM to consider questions raised about dolphinarium

The following is from Virgin Islands Conservation Society and the Environmental Association of St. Thomas / St. John (EAST) testimony to the Coastal Zone Management Commission about Coral World's proposed dolphinarium:

In preparation of our comments, VICS reviewers have taken care to set emotion aside, look at the facts, and focus on issues relevant to the CZM Commission's responsibility to determine if a Major CZM Permit application should be approved, conditionally approved, or disapproved.

After review of the Coral World project Environmental Assessment Report (EAR); review of literature related to the EAR; and a visit to and consultation with the director of Conservation, and the director of Dolphin Health Services at the National Aquarium, Baltimore, Md., VICS' reviewers concluded in our Nov 14, 2012, written comments that: a dolphin project could support the tourism sector, could generally support the Virgin Islands economy, could have potential merit in areas of marine conservation education and social service, and even could serve as a driver for improved water quality in Water Bay - but that the Environmental Assessment Report in its present state is insufficient for the CZM Commission to make a determination on.

We have continued to research issues related to the proposed project. The most valuable document we reviewed (other than the EAR itself) is a detailed letter addressed to the CZM Commission dated Dec. 11, 2012, from Humane Society International, Animal Welfare Institute and Whale and Dolphin, three highly respected international organizations.

The letter is well researched, documented and reasoned, and raises substantive questions that should be seriously considered by the CZM Commission.

The letter complements and supports many issues raised by V.I. Conservation Society, and we request that the CZM Commission require the applicant to respond specifically and in writing to the HSI et.al. and VICS letters.

VICS continues to find that Coral World's October 2012 Revised EAR is so deficient in certain areas that it does not support approval of a major CZM permit for the project without additional impact assessment, and enhancement of plans for mitigation of potential negative project impacts both on the captive dolphins and on the marine and coastal environment.

Specifically, the Environmental Assessments Report should be expanded to:

1. Include a description of the proposed dolphin show and encounter types and schedule;

2. Include a discussion of the impacts of nutrient loading on eutrophication, filamentous green alga growth and coral health; and if negative impacts are predicted for coral, the EAR mitigation section should be expanded accordingly;

3. Include comprehensive and detailed mitigation plans for sea turtles, and Acropora and other coral species listed as threatened or endangered at the time of the CZM permit approval.

4. Discuss requirements for infrastructure improvement to maintain improved water quality standards necessary for dolphin health and welfare.

5. Discuss opportunities for marine conservation and environmental education, and dolphin-assisted therapy.

6. Assess impacts of the management of the project on marine resources (including captive marine mammals) and habitat inside the proposed dolphin enclosure.

7. Coral World should commission a Water Bay current and water quality simulation study similar to the Naval Base Kitsap study cited by Coral World as adequate; and the EAR should be expanded to discuss the predictions of the Water Bay simulation.

Coral World should join and adhere to standards for marine mammal care prescribed by the Alliance of Marine Mammal Parks and Aquariums, and the Dolphin Consortium.

- Paul Chakroff, program manager , V.I. Conservation Society

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