AARP shares letter on Tibbar Energy Proposal

Magdalene Morancie, Acting Director
Department of Planning and Natural Resources
Division of Environmental Protection
45 Estate Mars Hill, Frederiksted VI 00840

Via E-mail: Madgalene.Morancie@dpnr.vi.gov

November 25th, 2014

Dear Director Morancie:

AARP Virgin Islands is concerned about the petition currently before the Virgin Islands Department of Planning and Natural Resources (“DPNR”). According to the Petition, the applicant Tibbar Energy intends to drill 22 water wells on St. Croix so that they may appropriate over 520,000 gallons of groundwater per day for the growth of Giant King Grass and other biofuel crops on leased agricultural lands of St. Croix. While we applaud the Territory’s expansion of renewable resources for electrical generation in the Territory, we are extremely concerned by the idea of any one company having a virtual monopoly on St. Croix’s fresh water supply. The fiscal and environmental dangers of privatizing the majority of the island’s fresh water reserves are considerable and bear judicious and conservative consideration. The projections the applicant has used to predict groundwater levels and refresh rates are, based upon news reports, from 40 year old geological studies. There are too many variables that could have changed in that time period. At the very least, this information is optimistic and needs independent verification by parties not in the employ of the applicant.

This proposed groundwater appropriation, if granted, locks up nearly all of the island’s remaining fresh water supply available for appropriation under one private entity. The aquifers are a public resource. Utilizing so much of a resource belonging to all island residents for a single corporation is an unfair exchange of such a valuable resource for such minimal gains. The proposed benefits are relatively tiny. The applicant purports to create only 40 new jobs on the island, and their biogas energy output to the Water and Power Authority is only expected to provide approximately 4% of the Territory’s energy needs. We are also concerned about the lack of personal experience of the Company’s principals in the biogas industry. Of additional concern, we note the criminal history of one of the Company’s principals, and the paid testimony of its environmental consultant Mr. Paul Chakroff. We are not impugning the character or veracity of either, but it does raise red flags to us as members of this community as to the ethical and moral implications of such a major decision, where the applicant, a for-profit entity, will self-monitor the use of the resource.

One of the mandates of VI DPNR is to protect the vital resources of the Territory. A decision that would shift control of such a massive amount of fresh water—the island’s most valuable resource—is extremely important to the future of the Territory. All testimony and commentary should be given the utmost consideration and due weight, including the independent verification of the applicant’s projections of the resource’s sustainability under their proposed use.

Moreover, while we should think of the value of renewable energy, we should not fail to underestimate the impact of such a massive shift on small businesses, and on other agricultural enterprises and the role they play in also growing and stimulating the economic climate on St. Croix.

For these and other reasons, we ask you to deny this petition. We believe it more appropriate to encourage this company to take advantage of the power of desalinized water systems that many of the major water users, like the major hotels on the island, rely upon to meet and satisfy their needs.

We thank you for your consideration of our commentary, and hope that you will decide to deny the applicant’s petition.