ii Page IGY-AYH ST. THOMAS HOLDINGS, LLC American Yacht Harbor January 11, 2014 Commissioner Department of Planning and Natural Resources Division of Coastal Zone Management Cyril E. King Airport, Terminal Building Second Floor St. Thomas, USVI 00802 Re: IGY-AYH St. Thomas Holdings, LLC objections to St. Thomas Sport Fishing Center, Inc. 's ("STSFC') Application for Renewal of Major CZM Permit No. CZT-7-93W designated CZT-4-13W for submerged lands seaward of Parcel No. 16-3 Estate Smith Bay. St. Thomas, U.S. Virgin Islands (the "STSFC CZM Application') Dear Commissioner Please accept this letter as IGY-AYH ST. THOMAS HOLDINGS, LLC's ("AYH") notice and registration that it is an "aggrieved person" as that term is defined in 12 V.I.C. Section 902(a) of the Coastal Zone Management Act (the "CZM Act") and hereby reserve all rights and remedies available to it as an aggrieved person under the CZM Act, at law and in equity. AYH is the abutting owner of Parcel Nos. 18B Remainder, 18B-1 Remainder and 18A-1 Remainder Estate Smith Bay, St. Thomas and permittee for the use of adjacent submerged lands under Coastal Zone Management Permit No. CZT-05-11(W) comprising the Marina and commercial buildings generally known as American Yacht Harbor. In accordance with the Notice dated December 12, 2013 issued by the Department of Planning and Natural Resources and received on December 19, 2013, we hereby submit our written comments and objections regarding the STSFC CZM Application. I. AYH's Coastal Zone Management Permit No. CZT-05-11(W) (the "AYH CZM Permit") and the Survey Plan incorporated therein by reference, a reduced copy of the Survey Plan being attached hereto as Exhibit A (the "AYH Site Survey"), permit AYH's use of 4.36 acres of submerged lands for which AYH pays the Government of the Virgin Islands an annual Permit Fee in the amount of $65,000.00. The submerged lands boundary limits are shown on the AYH Site Survey and in particular show th