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9/6/15, 3:31 PM

Subject:

Re: PRELIMINARY DETERMINATION OF ACROPORID CORAL DCH ACROSS PUERTA DE TIERRA

CORAL REEFS

From:

Sonia Villaverde (gpsyblu@aol.com)

To:

lisamarie.carrubba@noaa.gov;

Cc:

jennifer.moore@noaa.gov; tom.moore@noaa.gov; sean.griffin@noaa.gov; michael.nemeth@noaa.gov;

Carmen.G.Roman@usace.army.mil; Anabel.Padilla@noaa.gov; maryann@coralations.org;

Date:

Thursday, March 5, 2015 11:16 AM

Dear Dr. Lisamarie Carruba,

Thank you for your response to this matter as it is critical for the wellbeing of the endangered coral reef
systems in the area. Yesterday there were some workers at the site but it does not appear that anything was
done at the beach area to control the seeping of the sediment into the ocean.
Respectfully,
Sonia Villaverde
San Juan, Puerto Rico
561-901-1185

On Mar 5, 2015, at 10:08 AM, Lisamarie Carrubba - NOAA Federal <lisamarie.carrubba@noaa.gov> wrote:
Thank you for your message. It is my understanding that the U.S. Army Corps of Engineers is
investigating to determine whether the work remains in compliance with the issued permit.
Dr. Lisamarie Carrubba
-Dr. Lisamarie Carrubba
NOAA Fisheries
Caribbean Field Office, PRD
P.O. Box 1310
Boquern, PR 00622
787-851-3700
787-851-5588 (fax)
On Tue, Mar 3, 2015 at 6:20 PM, Sonia Villaverde <gpsyblu@aol.com> wrote:
Dear Mrs. Lisamarie Carruba,

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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 Hernndez, 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

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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
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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 Carrubba
NOAA Fisheries
Caribbean Field Office, PRD
P.O. Box 1310
Boquern, PR 00622
787-851-3700
787-851-5588 (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. Hernndez-Delgado (1,2,3)
with the collaboration of Ivangs Rivera (1) and Samuel Suleimn 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:
1) Provide a rapid qualitative assessment of adjacent benthic communities
across the potentially impacted zone by project Paseo Lineal de San Juan
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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 Hernndez, in collaboration with his team from SAM and UPRCATEC, 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;
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3) Address impacts to EFH; and

4) 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 Rico
561-901-1184

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