Cayo Norte CZ ACE Comments

8/6/2019 Cayo Norte CZ ACE Comments

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SENT VIA EMAIL AND CERTIFIED MAIL

June 23, 2011

Deborah J. Cedeno-MaldonadoU.S. Army Corps of EngineersAntilles Regulatory SectionJacksonville District400 Fernandez Juncos Ave.San Juan, PR 00901-3299Email: [email protected]

Rose A. OrtizUnidad de Zona CostaneraOficina de la SecretariaJunta de PlanificacinP.O. Box 41119San Juan, Puerto Rico 00940-1119Email: [email protected]

Loida Soto NoguerasSecretariaOficina de SecretaryJunta de Planificacin de Puerto RicoPO Box 41119San Juan, PR 00940 1119Email: [email protected]

Maryguel FuentesOficina de la SecretariaJunta de PlanificacinP.O. Box 41119San Juan, Puerto Rico 00940-1119Email: [email protected]

Re: Public Notice/Permit Application SAJ-2010-01592 and Puerto Rico Joint PermitApplication CZ-2010-0601-064

Dear Decision-makers:

Please accept the following comments on behalf of the staff and members of the Center forBiological Diversity (Center), CORALations, Vegabajeos Impulsando Desarrollo AmbientalSustenible (VIDAS), GuardaMar, and La Asociacin de los Pescadores de la Isla de Culebra.The Center is a national, nonprofit organization whose mission is to protect and restoreendangered species and wild places through science, policy, education, advocacy, andenvironmental law. The Center has over 320,000 members and on-line activists, some of whomreside and recreate on mainland Puerto Rico and on Culebra. CORALations is an award winningCaribbean coral reef conservation organization based on the island of Culebra, Puerto Rico.CORALations is a membership organization, with over 500 long term members located in PuertoRico and the US Virgin Islands. Its mission is to conserve, nurture and educate with a focus onCaribbean coral reefs and local community empowerment through collaborative partnerships toprotect and restore these critical coastal resources.

We have reviewed Public Notice Permit Application No. SAJ-2010-01592 and the Puerto RicoJoint Permit Application CZ-2010-0601-064 and have the following comments.


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In its Puerto Rico Joint Permit Application (JPA), the applicant seeks a 404 Clean Water Actpermit, a CZM Certification, Water Quality Certification, and Submerged Land Use Concession.In the JPA, the applicant states that the application is not a part of a multi-phase project, yetadmits that the purpose of the proposed project is for the transportation of homeowners, guests,staff, workers, service personnel and government officials, materials, and supplies to and from

Cayo Norte, and that the applicant has plans for a residential compound comprising three (3)houses, staff housing and accessory facilities including a maintenance building. 1 The applicantenvisions the need for the dock to include mooring of vessels transporting people and supplies,to accommodate the owners and visitors vessels, and for the transportation of vehicles,equipment, supplies, construction materials and work force. 2 Finally, the applicant offers asmitigation the use of informational buoys and a three-year seagrass and coral monitoringprogram, and concludes that the proposed project will not have any significant impact on theenvironment.

The PR Junta de Planificacin and the Army Corps of Engineers (Corps) cannot issue permitsor approvals for the proposed project at this time because it is evident that the full impacts of the

proposed project cannot yet be known. The Corps has a mandatory duty to evaluate the direct,indirect, and cumulative impacts of the proposed action and determine whether there will beunavoidable significant impacts. The overall project purpose is to provide reliable access toCayo Norte for future residential development, 3 yet the applicant has not provided plans for thefuture residential development or disclosed the potential impacts. This major issuenotwithstanding, the proposed project on its own may have considerable affects to the naturalenvironmental of Cayo Norte, affecting imperiled species and water quality. Because of thesignificant impacts the proposed project may have on Cayo Norte, off-site waters, and otherlocalities, a permit issuance is not legally possible or defensible. Unless the Corps can ensurethat all potential impacts have been disclosed and will be fully mitigated or avoided throughadditional special conditions not specified in the public notice and environmental assessment(EA), the Corps must deny the permit. Should it move forward with the application, the Corpsmust fully analyze the future residential development and likely produce an EnvironmentalImpact Statement prior to issuing a permit. Additionally, we urge the PR Junta de Planificacinto deny the CZM Certification and any other environmental permitting the applicant seeks for thereasons detailed below.

I. Clean Water Act ComplianceThe proposed project presents several obstacles preventing the Corps from issuing a 404 permitunder the Clean Water Act (CWA): the project is improperly segmented; the EA does notmeaningfully offer practicable alternatives; the project is not in the public interest; andpermitting the project may cause or contribute to the violation of water quality standards.

The Corps has a mandatory duty to evaluate the direct, indirect, and cumulative impacts of theproposed action and determine whether there will be unavoidable significant impacts. Theapplicant intends that this dock construction will be the first stage and a necessary project for theadditional, subsequent island construction. By omitting plans for the future residential

1 JAP at 1.2 JAP at 1.3 SAJ Permit Application at 1.


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development, the applicant is attempting to impermissibly segment the project. This hamstringsthe Corps duty to consider the immediate full impacts of the proposed project as well as thereasonably foreseeable impacts of the proposed project, including the future plans to develop theisland. Without detailed information about the planned future residential development, the Corpsis unable to assess impacts of the dock since it does not truly know how the dock will be used

such as increased boat traffic (how many boats, how frequently the boats arrive/department, andhow the passengers may affect the area), nor is it able to assess the cumulative impacts of thereasonably foreseeable future residential development and whether the impacts will be fullymitigated.

The applicant must first avoid all impacts to the maximum extent practicable, then it mustminimize any remaining impacts so they are as small as practicable, and then finally for anyremaining impacts, there must be compensatory mitigation. In issuing the permit, the Corps mustensure that the project will not cause any significantly adverse effects on human health, welfare,aquatic life, and aquatic ecosystems; or recreational, aesthetic, or economic values. It is unclearhow the project, as currently proposed, will avoid such significant impacts or how the Corps will

assess those impacts.A. Practicable Alternatives

Section 404(b)(1) of the CWA guidelines provide that no discharge of dredged or fill materialshall be permitted if there is a practicable alternative...which would have less adverse impacts onthe aquatic ecosystem. 4 A practicable alternative is one that is both available and capable of being done after taking into consideration cost, existing technology, and logistics in light of overall project purposes. An aquatic site possesses special ecological characteristics of productivity, habitat, wildlife protection, or other important and easily disrupted ecologicalvalues, and includes wetlands. 5 A water dependent activity require[s] access or proximity to orsiting within the special aquatic site to fulfill its basic purpose. 6 Because plans for the futureresidential development have not been provided, it is difficult to analyze whether there arepracticable alternatives.

The Corps may find that the proposed action fails to comply with the 404(b)(1) guidelines if there is a practicable alternative to the proposed discharge that would have less effect on theaquatic ecosystem or if there is not sufficient information to make a reasonable judgment as towhether the proposed discharge will comply with the guidelines. 7 Here, the applicant has failedto provide sufficient information, as is his burden, for the Corps to make a reasonable judgmentas to whether there is a practicable alternative that will have less effect on the aquatic ecosystem.

B. Public InterestPursuant to 404 of the CWA, the Corps may issue permits for the discharge of dredged or fillmaterial into the waters of the United States if such discharge is in the public interest. 8 For

4 40 CFR 230.10(a).5 40 C.F.R. 230.3(q-1); 40 C.F.R. 230.41. An alternative is practicable if it is available and capable of beingdone after taking into consideration cost, existing technology, and logistics in light of overall project purposes. 40C.F.R. 230.10(a)(2).6 40 C.R.R. 230.10(a)(3).7 40 CFR 230.12(a)(3)(i), (iv).8 33 USC 1344(a).


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purposes of the Corps obligations, public interest encompasses a broad range of values,including conservation, economics, aesthetics, general environmental concerns, wetlands,historic properties, fish and wildlife values, flood hazards, floodplain supply and conservation,water supply and conservation, water quality, energy needs, safety, food and fiber production,mineral needs, considerations of property ownership and, in general, the needs and welfare of the

people.9

In essence, before issuing a 404 permit, the Corps must identify, evaluate andbalance all the competing and sometimes conflicting interests in a project. It is clear that theproposed project particularly the future residential development would not be in the publicinterest.

The proposed area enjoys shoreline coral reefs and listed corals considered essential fish habitat.Area seagrass support at least three different species of conch important to local subsistencefishers. Shallow shoreline reef are important habitat for juvenile fish especially in areas thatborder healthy coastal wetlands as nutrients and detritus enter the environment in quantitiesbeneficial to corals reef and related benthic organisms, in contrast to shoreline wetlands wherefragile beach berms are compromised by deforestation and construction activities. Deforestation

and construction that compromises the integrity of beach berms separating these wetland areasfrom shore can result in large influxes of sediment lethal to corals and sea grass. This has beenwell documented even in relatively low density subdivisions (RO-5) in the southeast sector of Culebra where poorly planned and constructed dirt roads have laden coastal wetlands withsediment that now discharges into coastal waters with every heavy rainfall. National MarineFisheries Service of National Oceanic and Atmospheric Administration, has recentlydemonstrated concern by allocating funding toward restoration of these problem areas. The dock and future residential development may likely impact these important coral reefs.

1. Inconsistent with the Coastal Zone Management PlanThe Culebra Segment of the Coastal Zone Management Plan of 1975, adopted verbatimimperatives from the Joint Report, issued in 1973 by the US Secretary of the Interior and theGovernor of Puerto Rico. The overall stated objectives with respect to the conservation andeconomic development (III-1) of the island of Culebra are stated as follows:

It is consequently the firm resolve of the undersigned, the Secretary and theGovernor, that the highest priority shall be given to the protection of Culebrasnatural and human environment...The Governor has assured the Secretary that theCommonwealths concern for the ecological integrity of Culebra will bemanifested by strong legislative and executive action to safeguard theenvironment in the interim.

The report goes on to indicate the two principle opportunities created by the Navys departure,which also represent the overall goals that Puerto Rico expects to achieve through theimplementation of a management program on Culebra, are Conservation and EconomicDevelopment for the Culebrenses.

First, conservation. Slow economic development and low population have largelyspared Culebras reefs, mangroves and other remarkable natural assets from the

9 33 CFR 325.3(C)(1).


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destruction that has so often been a consequence of development elsewhere.Widespread appreciation of Culebras assets, heightened by growing popularawareness of past mistakes of the development process, creates a specialopportunity to preserve the unique attributes and resources of Culebra and itssurrounding waters, reefs and keys.

Second, economic development. Partly as a result of the Navys presence, theeconomic development of Culebra has been stunted. The departure of the Navywill create an opportunity to replace that stunted growth with normal growth growth sufficient to provide for the residents of Culebra a standard of livingcomparable to the average standard enjoyed on Puerto Rico's main island.

Today, and largely because of these slow growth initiatives adopted by the Culebra Segment of the Coastal Zone Management Plan for Culebra, and the Culebra Master Plan, originally adoptedby the Puerto Rico Planning Board I 1971, substantially revised and then signed by the Governorin 1976, maintain a focus of development that directly benefits the local community. Because of

this dual focus on conservation and local development, slow growth tourism based on naturalresources has benefitted the local population who for the past two decades, enjoyed up until thislatest financial recession, 0% involuntary unemployment when these statistics were measuredindependent of statistics for the east coast of Puerto Rico.

The Joint Report, that is the basis for the Culebra Segment of the Coastal Zone ManagementPlan, goes on to state that to achieve the overall goals of conservation and development, fourcategories of land and water use are proposed: Wildlife or biological preserves, recreation,development, and conservation areas.

The ecological value specifically of offshore keys is recognized:

Many areas in Culebra are natural habitats for native species of birds, fish andreptiles. Culebras offshore keys and the northwest tip of Peninsula Flamenco(Punta Molinos) comprise one of the most prolific nesting areas for the oceanicbirds found anywhere in the world. The mangrove roosts are high breedinggrounds for many species of fish and other marine animals. Other sites on Culebraare habitats for rare and endangered species of waterfowls and reptiles.

It is essential in these areas that the natural conditions which have made suchareas natural habitats be preserved, that people be prevented from adverselyinterfering with the wildlife found there, and that harmful development beprohibited in these and adjacent areas. Therefore, these areas in Culebra shouldbe set aside and protected, and should be managed so as to maintain and improvetheir natural characteristics.

The Joint Report also recognizes that Culebra and its surrounding keys offer opportunities for atremendous variety of outdoor active and passive recreational activities, and that Included arethe entire littoral zone, especially the beaches, the surrounding coral reefs, the bioluminescentbays, areas which have concentrations of flora with special natural significance, and open areas


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which are ideal for relaxed and passive recreation. These natural resources are among the mostimportant ones in Culebra. Their virtually unspoiled state makes them an asset for both theresidents of Culebra and visitors; every attempt should be made to keep them so.

The Plan assumed that potable water limitations would naturally impede rapid or remote

development: Thus even without the strict controls this Joint Report contemplates, the transferof naval training activities away from Culebra can not lead to large scale development. Scarcityof water is the most important of the natural limits to growth. In the case of Cayo Norte, whichhas no natural sources of potable water, this appears to have been a bad assumption.

The Joint Report also required that:

To protect the natural qualities of Culebra against pressures for haphazard andinsensitive development, it is not enough to designate and protect the limitedareas set aside for wildlife refuge, recreation, and development. Therecommended policy of this Joint Report is that those areas which are not

specifically set aside for wildlife refuge, recreational use, or development, bedesignated as conservation areas, that is, as open space, for agricultural and otherlow intensity uses consistent with the natural character of the island.

The Culebra Segment of the Coastal Zone Management Program included all of Culebrasmangroves, lagoons and beaches in their inventory of significant coastal natural resources. (seemap below) and states: Since the Culebra Segment includes all of Culebra and surroundingwaters, it clearly includes all transitional and intertidal areas, wetlands and beaches.


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The area proposed for development is considered by the Culebra Segment of the Coastal ZoneManagement Plan to be a Geographic Area of Particular concern. The offshore reefs in the areaproposed for development are characterized as Particular need for continuing surveillance(reefs-mangroves) with potential conflicts indicated where recreation conflicts with naturalresource conservation.

Finally, the public policy as established by PR Ley 66, 1975 (as amended) is clear and states it isto protect the ecological integrity of the island. Issuing the permits would frustrate the intent of this policy.

2. Inconsistent with Cayo Norte ZoningCayo Norte enjoys RO-25-C zoning where R reflects Residential, O-Special zoning intent onconserving natural integrity of Culebras spectacular resources and reducing the threat of fragmentation, 25 for one house per 25 cuerdas to reduce density and development stress and Creflecting the Planning Boards definition for the best use of the area Conservation. Theproposed beach infrastructure which is indicated as a necessity to support unspecified

development of the island of Cayo Norte, does not comply with Culebras special zoningdefinitions.

The PR Planning Board establishes as a special case for any development proposed in R0-25Cunder JP-215 (First Extension). This norm designates the R-0 zones of Culebra as specialareas within the meaning of section 6.18. Thus, any developer within the R-0 zones becomes aspecial case subject to special rules. Planning Board Resolution JP-215-A, is another norm.It establishes zoning standards, which are much stricter than those otherwise applicable to governthe special cases in Culebra (i.e. , all development within R-O zones in Culebra.)

The JP 215, August 13, 1975, recognizes the PR Planning Board has the responsibility of preserving and protecting the few natural areas of Puerto Rico for the enjoyment of present andfuture generations, and also the responsibility to watch over the places of exceptional beauty andto prohibit isolated development that may deteriorate or destroy that beauty.

The JP 215-A August 13, 1975 also recognizes that these norms pursue the purpose of regulatingthe special cases that arise in special areas established in low density residential districts (R-0) of Culebra. The same have their legal basis in Article 6.18 of Planning Board Regulation #4. Theyalso have their legal basis in the special areas, which are identified by numbers that are added asa suffix to the zoning symbol of R-0-25-C and R-0-1-C. These districts pursue the purpose of calculating the direction and the control of development in the Municipality of Culebra, and toprotect and preserve the various unique natural and agricultural areas. The island municipality of Culebra is of exceptional beauty, of unique characteristics, of historical, socio-economic,physical and natural. At present existing pressures may provoke disorganized development inthe municipality. This adds a sense of urgency to the establishment of norms and controls thatmay permit directing adequately urban suburban and rural development of Culebra, and topreserve and protect from deterioration its valuable natural resources and agricultural lands.

Article 11 of this norm indicates that in these special areas, Occupied Area (includingaccessories building) in an Area 25-C will depend on the use to be given the structure, which


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must conform to the permitted uses of the area 25-C. For residential use, such area must notexceed three hundred square meters for living space. Article 12: Gross floor area: In no casemay the gross floor area exceed twice the permitted occupied area. No residential structure forone family may exceed three hundred square meters of gross floor area. It also notes thatCulebra is not suitable for most types of facilities serving more than one locality. The size and

location of the island, together with the severe natural constraints on its development, cause thisunsuitability. pg V-12

3. Unexploded OrdnanceAs you are aware, the island of Culebra, including its cays, was used for U.S. Navy and Marinesand NATO forces for training throughout the 20 th century. It was principally used as a bombingand gunnery range. Unexploded ordnance is suspected in these offshore waters as indicated byNOAA Nautical Chart warnings found throughout this area. According to unexploded ordnancedivision experts these bombs can be too deep under the sand to defy detection, even if there werean attempt at in water clean up of the area. The bombs can surface or be exposed as changingoffshore currents or storms expose these hazards. To issue permits for construction or boat

traffic in such an area could be reckless endangerment. The Corps is responsible for clean up onthe island, and has recognized that this area is medium or high risk.


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The unexploded ordnance causes a huge concern for the public health and welfare and is scarcely

address in the JPA. The Corps cannot approve a project where the public interest weighs soheavily against the proposed project.

C. Water Quality Standards:CWA 404(b) guidelines prohibit discharges from a permitted project that cause or contribute toviolations of water quality standards or toxics effluent standards. 10 Because the 404 permit maynot legally authorize the discharge of these impairing pollutants above water quality standards,the Corps analysis must fully address the discharge and relative distribution of these impairingpollutants resulting from the development. 11

According to the Soil Survey of Humacao Area of Eastern Puerto Rico, issued in 1977, Cayo

Norte soils are volcanic and highly erodible in nature. To the west, the island is characterized asDrF Descalabrado-Rock land complex, 40-60% slope, and to the east, DeE2- Descalabradoclay loam, 20 to 40 percent slope, eroded. Any disturbance of these steep sloping volcanic soils,held together with fragile, xeric and specialized vegetation poses a serious risk to these coastalwetlands, coastal waters and shoreline reef. As the stated purpose of the dock is to support thefuture residential development of the island, the Corps must consider these impacts.

10 40 CFR 230.10(g)(1-2).11 40 CFR 131.12.


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The Corps must undergo formal consultation with FWS and NMFS under 7 of the ESA toensure that permitting the project will not result in jeopardizing the continued existence of alisted species or the destruction or adverse modification of its critical habitat. Because the projectwill likely jeopardize a number of federally listed species, and will certainly result in the adverse

modification of critical habitat for a few, we maintain that application must be denied. At thevery least, the risk to the species must be evaluated as part of a complete EIS, and the Corpsmust complete consultation with FWS and NMFS pursuant to the ESA.

The EA acknowledges the following endangered and threatened species are known to occur inthe project area: hawksbill sea turtle ( Eretmochelys imbricata ), green sea turtle ( Cheloniamydas ), leatherback turtle ( Dermochelys coriacea ), and elkhorn coral ( Acropora palmata ). Italso acknowledges that the entire Cayo Norte area falls within designated critical habitat for thegreen sea turtle, that the adjacent sandy beach is used by hawksbill sea turtles to nest, and thatthe project site includes consolidated hard bottom and dead coral rubble which provides theprimary constituent elements of the designated critical habitat for A. palmata . However, the

Corps has determined that the project may affect, but is not likely to adversely affect the speciesor their designated critical habitat. Such an assessment is premature given that, as describeabove, the Corps is not yet able to assess the full impacts of the proposed project.

The analysis of impacts to these species and the proposals to protect them are wholly inadequate.Absent complete avoidance and impacts, the Corps must undergo formal consultation beforeissuing a permit.

Furthermore, the applicant completely fails to acknowledge the potential presence and impact toother threatened and endangered species including: loggerhead turtle, blue whale, finback whale,humpback whale, sei whale, sperm whale, West Indian manatee, and the Virgin Islands tree boa.Additionally, consultation on Essential Fish Habitat as required by the Magnuson-StevensFishery Conservation and Management Act of 1996. The Corps must analyze the proposedproject for impacts to these species and provide information on how the applicant plans to avoidimpacts to these species.

Also, Cayo Norte is littered with unexploded ordnance. In order to construct anything there, thearea must be cleared. The Corps own guidance states: 16

Prior to the commencement of clearance activities, including vegetation removaland removal of unexploded ordnance, on Culebra, Culebrita, Cayo Norte andCayo Luis Pena the contractor shall appoint a Project Biological whosequalifications shall be submitted for the approval of the contracting officer and theFWS. All beach clearance activities, including vegetation removal and removal of unexploded ordnance, will be closely coordinated with FWSThe ProjectBiological shall perform morning beach patrols to identify the potential presenceof new nests prior to and during nesting season.

16 US Army Corps of Engineers Jacksonville District, Standard Operating Procedures for Endangered SpeciesConservation and their Habitat on DERP-FUDS Project No. I02PR006802. Culebra Island, Puerto Rico .


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The Standard Operating Procedures go on to list a litany of actions and protective measures thatmust occur to protect endangered species. The Corps must address these measures.

A. Elkhorn coralThe National Marine Fisheries Service (NMFS) has identified stressors contributing to the

threatened status of the elkhorn corals to include reduced population sizes, sedimentation, andanthropogenic abrasion and breakage. Again, without knowing more about the future residentialdevelopment, it is impossible to predict whether sedimentation from runoff from the constructionand operation of the development will result in the take of the species, and how to estimate thefrequency of the inevitable water vessel contact. Furthermore, the location of the dock to coralpopulations will increase the probability of human-coral interaction which is known to result intake of the species.

Corals are slow to adapt to habitat changes and have a limited ability to reproduce over largedistances. 17 Habitat degradation is among the factors imperiling elkhorn coral. Sediment fromcoastline erosion, runoff, beach renourishment, and coastal development are known to threaten

corals.18

Corals require nutrient-limited, clear waters and runoff from agriculture, sewage, andother land sources increases algal growth impairing the fitness of corals. 19 Additionally, abrasionand breakage from vessels, construction, dredging, and other activities can harm corals and theirhabitat. The construction and operation of the project as planned will conclusively result in thetake of the species.

The projects proposed avoidance and mitigation measures are wholly inadequate to prevent theadverse modification of the species habitat or avoid the jeopardization of the continuedexistence of the species, and will certainly result in the take of the species. The proposed dock may lead to increased snorkeling which may lead to the take of the species. Recent studies haveindicated that human impacts such as sunscreen may be responsible for reproductiveconsequences within Acropora species. Damage to acropora corals by inexperienced swimmersis well documented in Florida and Puerto Rico and is one of the most common impacts onthese species.

Studies consistently conclude that proximity to coastal development is a primary factor in thedecline of coral reef ecosystems. Around the world, reefs close to population centers, ports, andtourism are either of lower quality than reefs removed from such activities or they have simplydisappeared. 20 Coastal development has long been a major problem throughout the Caribbean

17 73 Fed. Reg. at 6897.18 73 Fed. Reg. at 6902.19 Id. 20

Wilkinson, Clive (ed.). 2008. Status of Coral Reefs of the World: 2008. Global Coral Reef Monitoring Network and Reef and Rainforest Research Centre. Townsville, Australia, 296 p.; Waddell, J.E. and A.M. Clarke (eds.).2008. The State of Coral Reef Ecosystems of the United States and Pacific Freely Associated States: 2008 . NOAATechnical Memorandum NOS NCCOS 73. NOAA/NCCOS Center for Coastal Monitoring and AssessmentsBiogeography Team. Silver Spring, MD. 569 pp.; Jokiel, Paul L. and Erik K. Brown. 2004. Global warming,regional trends and inshore environmental conditions influence coral bleaching in Hawaii. Global Change Biology 10: 16271641, doi: 10.1111/j.1365-2486.2004.00836.x.; Pandolfi, J.M., J. B.C. Jackson, N. Baron, R.H. Bradbury,H.M. Guzman, T. P.Hughes, C.V.Kappel, F.Micheli, J.C. Ogden, H. P. Possingham, E. Sala. 2005. Are U.S. coralreefs on the slippery slope to slime? Science 307: 1725-1726; Jackson, Jeremy B.C. 2008. Ecological extinction andevolution in the brave new ocean. Proceedings of the National Academy of Sciences 105: 11458-11465.


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and is increasingly threatening the Coral Triangle, an area comprising 2% of the global oceansthat hosts 75% of coral species and 35% of the worlds coral reefs. 21

Coastal development causes both short and long term damage to corals. During initialdevelopment, construction can physically damage reefs through dredging to create and maintain

shipping channels, building marinas and docks, and disturbances to the coastline resulting inerosion, sedimentation, and increasing water turbidity. After construction, long-term chronicimpacts include pollution from sewage and chemicals associated with the increased humanpresence and storm run-off from roads. 22 Runoff from developed watersheds tends to carry moresediment and higher concentrations of waste products (including freshwater inputs fromwastewater, oil, pesticides and fertilizer, animal excrement, and garbage) than that fromundeveloped areas. 23 Sediments tend to accumulate in nearshore areas with gentle slopes and lowflushing rates, and wave action typical of reef habitat can continuously re-suspend introducedsediment with subsequent negative impacts on coral communities. 24 The Corps must addressthese issues as the applicant intends to use this dock to facilitate the development of the island.

1. Other Imperiled Coral Potentially in the Area:The public notice indicates that a benthic survey along the project area discovered that the seabottom was dominated by communities of hermatipic corals, including Diploria strigosa , D.labyrinthiformes , D. clivosa , Siderastrea radians , Montastraea annularis , Porites asteroides ,and Favia fragum. Executive Order 13089 created the U.S. Executive Coral Reef Task Force inresponse to unprecedented coral decline in United States Waters. It compels all federal agenciesto do everything within their jurisdictional authority to protect existing coral reefs.

21 Turgeon, D.D., R.G. Asch, B.D. Causey, R.E. Dodge, W. Jaap, K. Banks, J. Delaney, B.D. Keller, R. Speiler,

C.A. Matos, J.R. Garcia, E. Diaz, D. Catanzaro, C.S. Rogers, Z. Hillis-Starr, R. Nemeth, M. Taylor, G.P. Schmahl,M.W. Miller, D.A. Gulko, J.E. Maragos, A.M. Friedlander, C.L. Hunter, R.S. Brainard, P. Craig, R.H. Richond, G.Davis, J. Starmer, M. Trianni, P. Houk, C.E. Birkeland, A. Edward, Y. Golbuu, J. Gutierrez, N. Idechong, G.Paulay, A. Tafileichig, and N. Vander Velde. 2002. The State of Coral Reef Ecosystems of the United States and Pacific Freely Associated States: 2002 . National Oceanic and Atmospheric Administration/National OceanService/National Centers for Coastal Ocean Science, Silver Spring, MD. 265 pp; Wilkinson 2008; Waddell andClarke 2008.22 Turgeon et al. 2002, Waddell and Clarke 2008.23 Waddell 2005.24 Id.


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However, because neither the public notice nor the EA include an analysis of the impacts tothose coral or what other corals may be found along the routes boats may take to get to and fromthe dock, we offer comments on the following coral that are known to be found throughout theCaribbean, and in particular Puerto Rico. Also, in a recent personal communication with Dr.Edwin Hernandez Delgado 6/21/2011, we learned all three Acroporid species are in this area. Weare uncertain whether all of these sensitive species occur in the area, but recommend that if theydo, that the Corps take into consideration impacts on these coral as they are valuable marineresources.

Dendrogyra cylindrus The IUCN lists this species as vulnerable. It is widespread, yetuncommon throughout its range. It is susceptible to bleaching and disease, and localizedthreats including hurricane damage, other diseases, damselfish predation, and bioerosionfrom sponges.

Elliptical star coral ( Dichocoenia stokesii ) The IUCN lists this species as vulnerable,and is susceptible to bleaching, disease, and sedimentation. It is suffering estimatedpopulation declines of 38% over 30 years and faces a significant likelihood of being lostwithin one generation from reefs.

Boulder Star coral ( Montastraea annularis ) The IUCN lists this species as endangeredand it is believed that the species has undergone a decline exceeding 50% over the past30 years due to disease, bleaching, and other anthropogenic-related factors. Specifically,this species has suffered a severe decline in the overall cover and abundance in severalparts of the Caribbean, including cover losses of 72% off of St. John. 25 Threats to this

25 Edmunds and Elahi 2007.


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species include climate-related ocean acidification and bleaching, infectious diseases,predation by Sparisoma viride (stoplight parrotfish), hurricane damage, loss of habitat atrecruitment from algal overgrowth and sedimentation, localized bioerosion by spongesand other organisms, and other diseases.

Mountainous Star coral ( Montastraea faveolata ) The IUCN lists this species as

endangered and it is believed that the species has undergone a decline exceeding 50%over the past 30 years due to disease, bleaching, and other factors. This species facessimilar threats to the Boulder Star coral and current rates of mortality are exceedinggrowth and recruitment, and the chances of recovery are limited due to the speciesextreme longevity, low recruitment rates, and long generation times.

Montastraea franksi The IUCN lists this species as vulnerable and though it iswidespread and common throughout the Caribbean. The species is at risk of being lostwithin one generation, and the species is projected to lose 38% of its population over 30years.

Mycetophyllia ferox The IUCN lists this species as vulnerable. It is widespread andcommon, but susceptible to bleaching and disease. It is vulnerable due to its recent

increased threats and is estimated a loss of 38% of the population will occur within 30years. Large ivory coral ( Oculina varicose ) The IUCN lists this species as vulnerable as the

species is estimated to have undergone a decline of greater than 30% due to the effects of bottom-tending fishing gear. NMFS has identified this species as a species of concern andidentifies it as a keystone species due to the scientific correlation established between thelocal health of the species colonies and the presence of both economically valuable fishand invertebrate biodiversity. They also provide essential fish habitat for federallymanaged species.

B. Brown Pelican

Although no longer a listed species, the brown pelican is still monitored as a species of concern.Various studies have indicated a decline in the Puerto Rican and Virgin Islands populations of the brown pelican. 26 In addition to human causes of nest disturbances, the decline has beenattributed to everything from a mystery illness to weather-related nest disturbances. Theproposed project may result in the take of brown pelican.

The Culebra Segment acknowledges that the coastal lagoons, marsh ponds and mangroveswamps support: Bahama pintail, the masked duck, and nesting areas for the ruddy duck andconstitute the most important wintering grounds for migratory water fowl on the island.Adjacent small cay support nesting areas for the blue footed boobies, and the Northern cliffs of Cayo Norte itself, support nesting areas for the beautiful Tropic birds, whose populations are

noticeably dwindling. Pelicans and listed species of terns also forage in these areas.Construction activities on or in these areas can irreparably harm through their disturbance, thesecoastal and wetland foraging grounds for birds.

An environmental assessment could in no way properly evaluate the avian populations in thearea and a complete EIS for this cay which supposedly enjoys protected zoning, must be

26 Williams, Ernest H., L. Bunkley-Williams, and I. Lopez-Irizarry, Die off of brown pelicans in Puerto Rico and theUnited States Virgin Islands , American Birds, Winter 1992, p. 1106; Collazo et. al. 1998, pp. 63-4.


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completed before reasonable assessment of risks and mitigation can be evaluated for avianspecies.

C. Sea TurtlesAs you are no-doubt aware, Culebra has some of the most important sea turtle nesting beaches

in the U.S. Caribbean. The leatherback, hawksbill, and green sea turtles use these beaches. TheFWS designated the beaches on Culebrita, Cayo Norte, and Playa Larga, Brava, and Resaca onCulebra as critical habitat in recognition of their vital importance to the future of the species. 27 Also, the Corps has recognized that the waters surrounding Culebra and its cays, including CayoNotre, provide sea grass beds which are foraging habitat for the species and that the benthichabitat, including seagrass beds, coral reefs, and colonized hardbottom, around Culebra and itssurrounding islands and cays provides foraging and refuge habitat for sea turtles. 28

The green sea turtles nesting season in Puerto Rico is roughly June through October. Theleatherbacks nesting season is from about February to August. However, the hawksbill can nestall year long, with the peak season between August to November. The Corp must explain how

the applicant will avoid impacts to the species particularly during these very vulnerable times.We would also like to point out that the entire southeast side of the Cayo Norte beach is alsodesignated critical habitat for the hawksbill sea turtle from mean high tide inland to a point 150meters from shore. 29

Also, the area up to three nautical miles around Culebra and its cays is designated critical habitatfor the green sea turtle.

27 50 CFR 17.95.28 US Army Corps of Engineers Jacksonville District, Standard Operating Procedures for Endangered SpeciesConservation and their Habitat on DERP-FUDS Project No. I02PR006802. Culebra Island, Puerto Rico .29 Image from USFWS, 2007, Critical Habitat Designations for Puerto Rico and the U.S. Virgin Islands at 10.


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Therefore, the Corps must not only consider impacts to the waters and nesting beaches generally,but must ensure that the proposed project will not adversely modify the critical habitat.

Additionally, in 1993, FWS designated the Culebra seagrass beds as Resource Category 1, asthey are critical foraging habitat for juvenile green turtles. Resource Category 1 habitat is uniqueand irreplaceable and loss of the habitat is not acceptable. The Corps must ensure that noseagrass beds will be lost.


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Playa Zoni, across the water from Cayo Norte is now a major nesting beach, and leatherback nesting continues to be monitored there. Former National Wildlife Refuge Manager, TeresaTallevast, indicated through personal communication that there have been multiple sightings of leatherbacks swimming in the water between Culebra and Cayo Norte that were reported to herover her years of service with the FWS. Also, one mortality has been reported to Department of

Environmental and Natural Resources when parts of a slashed carapace of a leatherback washedashore Playa Brava on Culebra, witnessed by a group of visiting volunteer students from theRamy Highschool in Isabella on a turtle watch. The Department determined that the injurieswere consistent with impacts from a large boat or ship propeller. The proposed infrastructuresupports and unquantifiable number of boat related activities that pose a threat to not just to thethreatened green sea turtles, but to these two endangered sea turtles en route to their nestingbeaches.

III. National Environmental Policy Act ConsiderationsBefore issuing a 404 permit, the Corps must comply with mandates of NEPA. NEPA requiresfederal agencies to prepare an EIS for any approval or action significantly affecting the quality

of the human environment.30

At this time it is unclear whether the proposed project will havesignificant impacts, jeopardize federally listed species and water quality, or be in the publicsinterest.

NEPA requires that an EIS be prepared for all major Federal actions significantly affecting thequality of the human environment. 31 In determining whether a federal action has significanteffects, the Corps must consider both the context and the intensity of the proposed action. 32 When evaluating the context of a proposed action, the Corps must consider it in severalcontexts such as society as a whole (human and national), the affected region, the affectedinterests, and the locality[b]oth short and ling-term effects are relevant. 33 The intensity of aproposed action refers to the severity of impact on everything from public health and safety,and roads and buildings, to cultural and historic sites and endangered species. 34 Also relevant tointensity is how controversial the effects are likely to be; whether the action may establish aprecedent; and whether the proposed action will have cumulatively significant impacts whenconsidered with other federal and non-federal actions. 35

NEPA regulations define direct effects as those that are caused by the action and occur at thesame time and place. 36 In this case, direct effects include: the taking of endangered species,the destruction of their habitat; the potential increased sedimentation and runoff affecting localwater quality and corals, and impact to the Culebra community.

NEPA regulations go on to define indirect effects to include those that

30 42 USC 4332(2)(C).31 Id .32 42 USC 4332(2)(C); 40 CFR 1508.27.33 40 CFR 1508.27(a).34 40 CFR 1508.27(b).35 Id .36 40 CFR sec 1508.8(a).


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are caused by the action and are later in time or farther removed in distance, butare still reasonably foreseeable. Indirect effects include growth inducing effectsand other effects related to induced changes in the pattern of land use, populationdensity or growth rate, and related effects on air and water and other naturalsystems, including ecosystems. 37

In this case, indirect effects include the growth-inducing effects of the proposed project, theprecedent it sets for future development and destruction of Culebra coastlines, and the speciesthat rely on them, the longterm affects to already imperiled corals, and the untold affect to waterquality.

The direct and indirect impacts of the proposed action will most certainly be significant. Underthese circumstances, a Finding of No Significant Impact is not legally possible. If the Corps doesnot deny the application, it must prepare an EIS before it can properly consider the applicationand evaluate how issuing the requested 404 permit would jeopardize federally listed species,water quality, and how it would not be in the publics interest. At a minimum, the Corps should

request additional information on the future residential development.If there is sufficient public controversy surrounding the potential impacts of a federal agencyaction, the agency is required to prepare an EIS. The controversy can arise where substantialquestions are raised as to whether a project may cause significant degradation of some humanenvironmental factor or there is a substantial dispute about the size, nature, or effect of the majorfederal action. Here there is dispute over all three.

A. Marine ResourcesMarine resources near Cayo Norte may be significantly impacted by the proposed development.

The creation of the dock itself may have significant impacts. The operation of the mooring fieldmay result in impacts to shallow patch reefs and shallow seagrass beds while vessels aremaneuvering. The applicant offers assurance that the proposed dock will not evolve into amarina to better serve the residents by proposing a steel cable such an assurance is insufficient particularly in light of the fact that the applicant has not disclosed the details of the plan toconstruction a residential development.

Also, boat traffic is a major threat wherever humans come in contact with coral reefs. Propellersspeeding through shallow waterways break corals, scar seagrass beds, and kill endangeredmarine mammals. Coral reef habitat frequently overlaps with heavy shipping and boating traffic,and island ports as well as large ports located near shallow water reefs increase the probability of vessel-associated damage to reefs. Ship groundings and reef damage from navigational buoys arecommon in Guam due to the frequency of typhoons in the region. 38 Boat groundings and anchors

37 40 C.F.R. 1508.8(b).38 Burdick, David, Valerie Brown, Jacob Asher, Mike Gawel, Lee Goldman, Amy Hall, Jean Kenyon, Trina Leberer,Emily Lundblad, Jenny McIlwain, Joyce Miller, Dwayne Minton, Marc Nadon, Nick Pioppi, Laurie Raymundo,Benjamin Richards, Robert Schroeder, Peter Schupp, Ellen Smith, and Brian Zgliczynski. 2008. The State of CoralReef Ecosystems of Guam. In: Waddell, J.E. and A.M. Clarke (eds.). 2008. The State of Coral Reef Ecosystems of the United States and Pacific Freely Associated States: 2008 . NOAA Technical Memorandum NOS NCCOS 73.


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cause significant localized damage to shallow water coral reefs. 39 Physical coral reef damageassociated with anchors and ship groundings includes the direct loss of corals and other marineinvertebrates when they are dislodged, fractured, and crushed. In the US Virgin Islands, newlyestablished anchorages on a highly valued local reef were shown to reduce coral cover by over87%, coral species richness by 54%, and rugosity (reef surface complexity) by 43.5%. 40 The

applicant offers no avoidance or mitigation measures for the increased boat traffic. In fact, theapplicant has not even provided a true estimate how boat traffic will increase.

Furthermore, if the applicant intends to develop the island, it is unclear how electricity will besupplied to Cayo Norte absent either the submarine cable or regular fuel deliveries. The Corpsmust evaluate the impact of regular fuel deliveries and potential impacts to the environment.Groundings are a common cause of contamination from oil and toxic chemicals. One suchgrounding and fuel spill occurred in the popular, formerly intact snorkeling lagoon of Majuro(Marshall Islands) in 2007, resulting in the destruction of several dozen Porites colonies and thenear destruction of an endemic colony of three-banded anemone fish. 41 In Palau, a 2005grounding event damaged 875 square meters reef edge with high coral cover, crushing 350

square meters of reef and causing an additional 300 square meters of coral to bleach.42

Virtually100% of bleached corals died following this event, and studies of the area 14 months laterrevealed a complete lack of any coral recruitment in the damaged area, leading scientists toconclude that toxins from the large amount of copper-based bottom paint deposited during thisevent subsequently prohibited the reestablishment of many organisms. 43 The applicant mustpropose avoidance and mitigation measures for the fuel transport.

B. Terrestrial ResourcesThe proposed project may also significantly impact terrestrial resources. However, the Corps andthe public have no way of knowing that at this time. The applicant must provide adequateinformation regarding the future intended use of the island and propose avoidance and mitigationmeasures.

C. Cumulative ImpactsAs is repeated throughout these comments, one of the factors the Corps must consider inevaluating the application is whether the proposed project, when taken together with otheractions in the vicinity, will have cumulatively significant environmental impacts. 44 NEPAregulations define cumulative impact as

the impact on the environment which results from the incremental impact of theaction when added to other past, present, and reasonably foreseeable futureactions regardless of what agency (Federal or non-Federal) or person undertakes

NOAA/NCCOS Center for Coastal Monitoring and Assessments Biogeography Team. Silver Spring, MD, pp. 465-509.39 Waddell and Clarke 2008.40 Id. 41 Waddell and Clarke 2008.42 Id. 43 Id. 44 40 C.F.R. sec 1508.27(7).


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such other actions. Cumulative impacts can result from individually minor butcollectively significant actions taking place over a period of time. 45

The Public Notice provides no information on any possible cumulative impacts even thoughthe applicants stated purpose of the project is to facilitate a future residential development. The

Corps cannot even identify, much less evaluate, many of the cumulative impacts the proposedproject will have.

Because the 404 permit will facilitate everything from the construction phase to postdevelopment, the Corps must address the proposed project including the future development atall phases of development, not merely the initial dock construction phase. It must also considerthe cumulative impact on water quality standards and beneficial uses resulting from thedischarge of impairing pollutants from the project.

D. Climate Change & Ocean AcidificationThere is no evaluation of the effects of climate change. The applicant only considers the effect of

hurricanes on the dock, and only to the extent that it acknowledges the dock could be collapsed.It does not address the carbon footprint of the construction and maintenance of the dock or thefuture residential development, or the impact the project will have on corals taking intoconsideration that fact that the coral will continue to be stressed due to climate change and oceanacidification.

The world is getting warmer. Massive quantities of greenhouse gases, most notably carbondioxide, are released into the atmosphere each year, primarily from the burning of fossil fuels forenergy and transportation. Carbon dioxide and other greenhouse gases reduce the amount of solar radiation that can escape from our atmosphere back into space, thereby causing the earthsclimate to warm, much like the interior of a common greenhouse.

That global warming is occurring is no longer the subject of credible scientific dispute. In 2001,the Intergovernmental Panel on Climate Change (IPCC) concluded that over the next century,average global temperatures will rise between 2.5 and 10.5 degrees F (7-10 degrees C). 46 Dr.Rajendra Pachauri, the chairman of the IPCC, has stated that the world has already reached thelevel of dangerous concentrations of carbon dioxide in the atmosphere, and that [w]e arerisking the ability of the human race to survive. 47

Atmospheric carbon dioxide rates are also leading ocean acidification. The ocean absorbs carbondioxide from the atmosphere, which alters seawater chemistry causing slightly alkaline waters tobecome more acidic. Ocean acidification is advancing rapidly as humans release carbon dioxide

45 40 C.F.R. sec 1508.7.46 IPCC, Climate Change 2001: The Scientific Basis. Contribution of Working Group I to the Third Assessment

Report of the Intergovernmental Panel on Climate Change [Houghton, J.T., Y. Ding, D.J. Griggs, M. Noguer, P.J.van der Linden, X Dai, K. Maskell, and C.A. Johnson (eds.)]. Cambridge University Press, Cambridge, UnitedKingdom and New York, NY, USA.47 Global Warming Approaching Point of No Return, Warns Leading Climate Expert , The Independent, January 23,2005.


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into the atmosphere, increasing 2 ppm annually. 48 By the end of this century, carbon dioxide ispredicted to reach 788 ppm and the pH of the ocean will drop by another 0.3-0.4 units,amounting to a 100-150 percent change in acidity. 49

Changing marine pH and carbonate concentrations are fundamentally altering ocean chemistry.

Carbonate is an important constituent of seawater because many organisms form their shells andskeletons by complexing calcium and carbonate. Calcium carbonate is present in the ocean intwo common forms, calcite and aragonite. When seawaters become undersaturated with respectto calcium carbonate they are corrosive to organisms that produce calcium carbonate shells, liths,and skeleton. Modeling predicts that by the end of the century global aragonite production willbe reduced by 29% and total calcium carbonate production by 19% relative to preindustriallevels. 50

Ocean acidification also decreases the calcification of corals. Calcification rates of reef-buildingcorals are expected to decrease 30-40% with a doubling of atmospheric carbon dioxide. 51 Scientists predict that ocean acidification coupled with increasing ocean temperatures will

destroy the worlds reefs by mid-century.52

Within the past decade, scientists have observed asignificant decrease in the saturation state of a calcium carbonate mineral, aragonite, in thegreater Caribbean region. 53

ConclusionAs explained in these comments, the Corps cannot permit this proposed project as currentlyenvisioned. In addition to the insufficiencies detailed throughout the comment letter, we werealso unable to secure a complete copy of the EA and have requested additional time to presentmore complete comments to the Corps and the PR Planning Commission. The EA was notavailable online, and when obtained via email was incomplete. Additionally, the public meetingson the project are being conducted in the mainland where it is difficult for the Culebracommunity to participate.

48 Environmental Protection Agency. 2009. Ocean Acidification and Marine pH Water Quality Criteria; 74 FederalRegister 17484.49 Orr, J. C., et al. 2005. Anthropogenic ocean acidification over the twenty-first century and its impact on calcifyingorganisms. Nature 437:681-686; Meehl, G. A., et al. 2007. 2007: Global Climate Projections. in S. Solomon, D. Qin,M. Manning, Z. Chen, M. Marquis, K. B. Averyt, M. Tignor, and G. H. Miller, editors. Climate Change 2007: ThePhysical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the IntergovernmentalPanel on Climate Change. Cambridge University Press, Cambridge University Press, Cambridge, UK, and NewYork, NY, USA.50 Gangst, R., M. Gehlen, B. Schneider, L. Bopp, O. Aumont, and F. Joos. 2008. Modeling the marine aragonite

cycle: changes under rising carbon dioxide and its role in shallow water CaCO3 dissolution. BiogeosciencesDiscuss. 5:16551687.51 Kleypas, J.A., et al. 2006. Impacts of Ocean Acidification on Coral Reefs and Other Marine Calcifiers; Hoegh-Guldberg, et al. 2007. Coral Reefs Under Rapid Climate Change and Ocean Acidification, Science 318:1737-1742;Guinotte, J.M., Fabry, V.J. 2008. Ocean acidification and its potential effects on marine ecosystems. Ann. N.Y.Acad. Sci. 1134: 320342.52 Hoegh-Guldberg, et al. 2007. Coral Reefs Under Rapid Climate Change and Ocean Acidification, Science318:1737-1742.53 Gledhill, D.K, et al. 2008. Ocean Acidification of the Greater Caribbean Region 1996-2006. Journal of Geophysical Research 113:C10031.


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Executive Order 12898 (1994) on Environmental Justice applies to all requiring federal permitsand or money. All PR communities are recognized as EJ communities. Further, Culebra issubsistence fishing community. Minimally there should time for community input, with publichearings held on Culebra. Notification of this was made and extension requested on the 22 of June, 2011 (attached).

Also, we believe that pursuant to Puerto Rico Law 66, this project requires endorsement from theCulebra Conservation and Development Authority, which it has not received and likely will notreceive as a private dock. 54 Please keep me informed of any Corps decisions regarding thisproject. While these comments were primarily directed at the Corps, we also offer them to thePR Planning Commission and urge it to deny the CZM Certification for the reasons outlinedthroughout the comments, namely that the applicant has impermissibly segmented the project,preventing a true assessment of the projects impacts. Please contact us if you would like todiscuss these comments or the proposed project. We appreciate the opportunity to have thesecomments taken into consideration.

Sincerely,

/s/Jaclyn Lopez /s/Mary Ann LuckingJaclyn Lopez, Staff Attorney Mary Ann Lucking, DirectorCenter for Biological Diversity CORALations415-436-9682 x. 305 787-556-6234

[email protected] [email protected]

Enclosures

Courtesy copies sent to:

U.S. Army Corps of EngineersJacksonville DistrictAttn: CESAJ-DP (FUDS Program Manager)701 San Marco Blvd.Jacksonville, FL 32207

Dr. Lisamarie CarrubbaNOAA FisheriesCaribbean Field OfficeP.O. Box 1310Boquern, PR [email protected]

Ricardo de SotoGuardaMarPrograma GuardaMar de Puerto RicoPO Box 906-5920Pta. de Tierra Sta.San Juan, PR [email protected]

Amanda D. EllisonPublic Affairs SpecialistCorporate Communications OfficeU.S. Army Corps of EngineersJacksonville [email protected]

54 Culebra and the Coastal Zone Management Act, Section 923.22(3) In Culebra, no work on private project canbe approved by any agency without a prior endorsement from the CCDA certifying that the work done does notconflict with plans and policies. at V-24.


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Lourdes Feliciano, SecretariaLa Asociacin de las Pescadores de la Isla deCulebraPO Box 240

Isla de Culebra, PR [email protected]

Thomas R. Freeman [email protected]

Edwin A. Hernndez-Delgado, Ph.D.Affiliate Researcher University of Puerto RicoCenter for Applied Tropical Ecology andConservationCoral Reef Research GroupP.O. Box 23360San Juan, Puerto Rico [email protected]

Ricardo LaureanoPresidente e Investigador ArrecifalIndependienteVegabajeos Impulsando DesarrolloAmbiental Sustenible (VIDAS)PMB 304 Avenida Alejandrio 3071Guaynabo, PR [email protected]

Charles LeeDirector of the Office of Environmental Justice(OEJ),USEPA Headquarters, Ariel Rios Building,1200 Pennsylvania Avenue, N.W.,Washington, DC [email protected]

Felix [email protected]

Jose M. Mendez, PE,MBA Project ManagerUS Army Corps of Engineers400 Fernandez Juncos San Juan, P. R. [email protected]

Mr. Jose RiveraNMFS Conservation [email protected]

Wilmaire Rivera [email protected]

Daniel [email protected]

Ana [email protected]

Susan [email protected]


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Page 1

From: CORALations ([email protected])To: [email protected]; [email protected];Date: Wed, June 22, 2011 9:10:40 PMCc: [email protected]; [email protected]; [email protected];[email protected];Subject: Fw: Documentos (CZ-2010-0601-064)

Buenos Dias:

Ms. Ortiz envo una copia de los documentos el 17 de junio de 2011 (abajo,) para el proyecto CZ-20 10-0601-064.

Sin embargo, los documentos en el archivo adjunto A de EA, esta incompleto, con los nmerosimpares solamente. Solicitamos respetuosamente el documento completo y ms tiempo parapresentar nuestros comentarios. Esperamos su respuesta lo antes posible, porque hoy es la fechalimite.

El gobierno federal considera la comunidad de Culebra, como una comunidad de justiciaambiental.

Gracias,

Mary Ann LuckingDirectorCORALationsP.O. Box 750Culebra, PR 00775www.coralations.org 787.556.6234email: [email protected]

Trabajando con comunidades del Caribe para proteger y restaurar

sus arrecifes de coral.

< < < > > >

Working with Caribbean communities to protect and restore their coral reefs.

----- Forwarded Message ----
http://www.coralations.org/http://www.coralations.org/


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Documents

Transcript of Cayo Norte CZ ACE Comments