From: Sonia Villaverde gpsyblu@aol.comSubject: Re: PRELIMINARY DETERMINATION OF ACROPORID CORAL DCH ACROSS PUERTA DE TIERRA CORAL REEFS

Date: March 3, 2015 at 7:20 PMTo: Lisamarie Carrubba - NOAA Federal lisamarie.carrubba@noaa.govCc: Jennifer Moore jennifer.moore@noaa.gov, Tom Moore - NOAA Federal tom.moore@noaa.gov, Sean Griffin - NOAA Affiliate

sean.griffin@noaa.gov, Michael Nemeth - NOAA Affiliate michael.nemeth@noaa.gov, Roman, Carmen G SAJCarmen.G.Roman@usace.army.mil, Anabel Padilla Anabel.Padilla@noaa.gov, Mary Ann Lucking maryann@coralations.org

Dear Mrs. Lisamarie Carruba,

I am writing to report the impact of the erosion control methods that were implemented today, March 3, 2015 in the Puerta de Tierra area. These photographs were taken between at 5:20 and 5:40PM at the area in front of El Hamburger. It looks like the stone berm and trench are not working to prevent transport of sediments as there is a significant amount of sediment seeping outside the beach area. The plume extends westbound along the shoreline. The Historic Wall on the east side appears to had been impacted as part of it has collapsed into the ground.

The photographs that you mentioned previously were taken by Dr. Edwin Hernandez as part of his preliminary inventory that he made were he determined the presence of A. Palmata.

Dr. Edwin Hernández, in collaboration with his team from SAM and UPR-CATEC, found that there were multiple colonies of A. Palmata located within 50 m or less from the shoreline. Preliminary observations suggested that, nearly the entire surveyed segment dominated by colonized pavement and patch reefs constituted part of the Acroporid corals DCH. Though only one colony of O. Faveolata was observed during the preliminary inspection, and though no DCH has been officially designated yet for this species, this habitat represents also critical habitats for its presence.

As a very concerned citizen, I respectfully request that this is investigated right away as this seems to be an urgent situation. I hope you act to remedy it immediately.

Sincerely,

Sonia Villaverde

On Feb 19, 2015, at 5:01 PM, Lisamarie Carrubba - NOAA Federal <lisamarie.carrubba@noaa.gov> wrote:

Sonia:

Thank you for your message and for the report you sent. I also received a message regarding this project from MaryAnn today.

For your information, this project is an erosion control project to address the severe landslide conditions that led to a portion of the sidewalk collapsing. The stones that have been placed parallel to the coast were put there at our recommendation to trap sediments as they are working, leaving the area behind them with a trench where the sediments accumulate and are then cleaned out along with construction debris as work is done. The project is being undertaken by the Puerto Rico Highway and Transportation Authority and is permitted by the Corps of Engineers. There will be a series of erosion control measures, including vegetation planting, to try to prevent future landslides in this area that do lead to harm to the coral reef ecosystem just offshore. Unfortunately, any projects of this type do lead to temporary impacts but, from your photos, it looks like the stone berm and trench are working to prevent major transport of sediments outside the beach area.

-- Dr. Lisamarie CarrubbaNOAA FisheriesCaribbean Field Office, PRDP.O. Box 1310Boquerón, PR 00622787-851-3700787-851-5588 (fax)

On Thu, Feb 19, 2015 at 3:45 PM, Sonia Villaverde <gpsyblu@aol.com> wrote:

Enclosed you will find a copy of the "Preliminary Determination of Acroporid Coral Designated Critical Habitats Across Puerta de Tierra Urban Coral Reefs, San Juan, Puerto Rico". Please be advised that this document is a "Preliminary Report Submitted to the National Marine Fisheries Service and the PR Department of Natural and Environmental Resources" written by Dr. Edwin A. Hernández-Delgado (1,2,3) with the collaboration of Ivangs Rivera (1) and Samuel Suleimán Ramos (1). (1) Sociedad Ambiente Marino (SAM) (2) University of Puerto Rico – Center for Applied Tropical Ecology and Conservation (UPR-CATEC) (3) University of Puerto Rico – Department of Biology.

The objective of this preliminary assessment of Puerta de Tierra marine natural systems was to:

was to:1) Provide a rapid qualitative assessment of adjacent benthic communities across the potentially impacted zone by project “Paseo Lineal de San Juan” northern segment (currently referred to as “Paseo Lineal de Puerta de Tierra”); 2) Determine if there were ESA-listed coral species across adjacent coral reefs;

3) Determine the spatial extension of Acroporid coral designated critical habitats (DCH) across the zone; and 4) Determine the spatial extension of essential fish habitats (EFH) across the zone. Surveyed benthic habitats showed the common presence of Endanged Species Act (ESA)- listed Elkhorn coral (Acropora palmata) and a very low abundance of the Laminar star coral (Orbicella faveolata) within less than 200 m from the shoreline.

Dr. Edwin Hernández, in collaboration with his team from SAM and UPR-CATEC, found that there were multiple colonies of A. Palmata located within 50 m or less from the shoreline. Preliminary observations suggested that, nearly the entire surveyed segment dominated by colonized pavement and patch reefs constituted part of the Acroporid corals DCH. Though only one colony of O. Faveolata was observed during the preliminary inspection, and though no DCH has been officially designated yet for this species, this habitat represents also critical habitats for its presence. The existing coral biodiversity preliminarily documented in this survey showed a total of 26 species within 700 linear meters of reefs along the shoreline, including 3 hydrocorals, 11 octocorals and 12 scleractians or hard corals. A preliminary survey of fish fauna also showed a total of 59 species, belonging to 37 genera and 25 families. This is only a preliminary list and future surveys may guarantee that this list is likely to grow. The surveyed reef segment constitutes a very important essential fish habitat (EFH) for multiple reef fish species, including species managed by the Commonwealth of Puerto Rico and the National Marine Fisheries Service (NMFS). There was also presence of submerged aquatic vegetation (SAV) across the adjacent benthic systems, but environmental impacts of the project Paseo Lineal of Puerta de Tierra (formerly named Paseo Lineal San Juan) to any of these marine ecosystems were not addressed. A massive landslide is significantly impacting the shoreline and adjacent coral reefs ecosystems. The recommendation is that there is a need to immediately stabilize an active landslide in that coastline to reduce further impacts to adjacent coral reefs and SAV, including DCH of Acroporid corals.

There is a need to:1) Determine the spatial extent of Acroporid coral DCH across adjacent reef bottoms;2) Determine the presence of any of the seven ESA-listed coral species across adjacent reef bottoms;

3) Address impacts to EFH; and4) Initiate consultation with NMFS under section 7 of ESA; and

5) Prepare an Environmental Impact Statement in full compliance with Law 147 of 1999.There is no evidence in the available public record of this project that the construction of an abandoned breakwater in navigable waters of the Atlantic Ocean was permitted by the US Army Corps of Engineers. This should also be addressed. According to the available public record, potential environmental impacts of this project on coral reef ecosystems were not addressed. It should be noted that the tracking number of the Notice of Intent submitted to the EPA does not yield any results. This should also be examined.There is significant potential for permanent adverse impacts on coral reefs associated to the construction of this project could be significant and permanent and must be immediately addressed.

I would like to thank you for the attention given to this matter. Sincerely,Sonia Villaverde

San Juan, Puerto Rico561-901-1184