Kellerhals Ferguson Kroblin PLLC Royal Palms Professional Building. 9053 Estate Thomas. Suite 101. St. Thomas, VI. 00802 Fax I www.kellfer.com February 13, 2019 Via Electronic Mail Vonetta Norman, Esq. Department of Planning & Natural Resources Division of Coastal Zone Management 4607 Tutu Park Mall St. Thomas, V.I. 00802 Re: Cease & Desist Order No. C&D-01-19-STT Great St. Jim, LLC ("Great St. Jim") Dear Attorney Norman, We appreciate you and Pedro Nieves meeting with Cecile DeJongh and I on January 29, 2019 to discuss the issuance of the Cease & Desist Order referenced above. This letter will address some of the concerns raised by your agency at the meeting, as well as the issues raised in your letter of January 28, 2019 and your email of February 1, 2018. There are some items about which we are still doing our own research. I will revert with any additional information as soon as it becomes available. Clearing of Area Near Cistern During our meeting, Mr. Nieves pointed out an area of roadside, dose to a cistern, which he believed had been recently cleared without a permit. Upon review of the appropriate Google Earth images and our files, we disagree with Mr. Nieves' assessment that the area was recently cleared. In fact, the area to which Mr. Nieves referred is an area that that was cleared years ago and was the subject of a prior settlement entered into between Great St. Jim and DPNR in July 2016. The staff on Great Saint James ("GSJ") maintains this and other areas on a regular basis to ensure that they do not become overgrown or create hazardous conditions for residents, staff, and vehicles traversing the island. Construction Activity Mr. Nieves provided us with photos taken by DPNR Enforcement Officers when they entered upon the island unannounced and proceeded to traverse the entire island, particularly near and around the island's residences, without permission. I will address photos KIMG 2052, KIMG 2054, KIMG 2098, KIMG 2099,