Culebra March 2011 Sardinas Aloe Fulladoza

8/7/2019 Culebra March 2011 Sardinas Aloe Fulladoza

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PO Box 750Culebra, PR 00775

[email protected]

PhotosMarch 28, 2011

To: Jaime Lopez, US EPA Enforcement, [email protected] Soderberg, US EPA, CEPD Director [email protected] Enck, EPA Regional II Administrator [email protected] Cedeo-Maldanado US Army Corps of Engineers [email protected] Castillo, Chief, Antilles Regulator Branch, US ACE [email protected]

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Lcda. Mariel Coln Eliza, Daniel Galn KercadDirectora, SecretarioOficina Regional de Humacao DRNAPO Box 8568 PO Box 366147Humacao, PR 00972 San Juan, PR 00936

Lcdo. Pedro Nieves MirandaPresidentePuerto Rico Junta de Calidad AmbientalPO Box 11488San Juan PR 00910


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Land clearing with inadequate erosion controlalong shoreline road, greater than one acre, nosignage. DRNA Vigilante would not takecomplaint indicating it was under jurisdictionalauthority of EQB to evaluate the effectiveness of erosion control installed. Vigilante indicatedproject had a Simple Permit, and a sign was soonto be posted at this project site. Clearing was inexcess of what is allowed by simple permit.Threatened water body:Ensenada Honda, Culebra Puerto Rico.

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Culebra Resorts Associates (CRA) cements shallow sediment retention pond.In culverts passing to the sea, the cement appeared to be poured without the use of molds or rebar into shoreline mangroves, terminating a few feet from the waters edge.

This work was apparently moving under multiple, expired Simple Permits from the DRNA.

Vigilantes took complaint: QC-018-2011 - March 28, 2011.

History: In response to citizen complaint from impacts to coastal waters, EPA issuedviolation and fine indicating failure to obtain NPDES storm water discharge plan/permit.EPA then indicated the project did not need the plan/permit because it was not officiallymoving. Because an NPDES permit has yet to be formally requested, there has been noFederal Sec. 7 endangered species oversight triggered. The receiving waters on twocoasts of this project enjoy multiple critical habitat listings put in place to protectthreatened coral, sea grass and sea turtles.

The project is sited in an area that enjoys a special low density zoning put into placedecades ago, based on soil constraints and with the intent to protect coastal water qualityand Culebras stellar coastal natural resources on which its tourism industry and localpopulation depends.

Impacted Water Body: wetlands and waters of Ensenada Honda, Culebra PuertoRico.

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March 28, 2011 4

flow of water

View from road facing uplandof culvert now filled withcement.


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Cemented shallow retention pond. This and other ponds are ineffective at controlling sediment dueto physical constraints limiting their depth, such as proximity to the sea and soil type. The amountof water now canalyzed by the poorly planned and constructed dirt roads would require deeper ponds to slow the velocity of water and allow sediment to settle. One pond does not catch water during heavy rains. See video of impacts and pond failures:http://www.youtube.com/watch?v=fNOOQkwFhRk

flow of water


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March 28, 2011 6View of culvert emerging under shorelineroad into mangrove area.

View from road of cemented culvert passinginto mangroves to shore.

View of culvert on project side of the shoreline road.Concrete has also greatly reduced the capacity of theundersized tubes to pass water under the road.Twice the velocity of runoff has taken pavement off the top of shoreline public road in this area.

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No implementation of erosion control,dramatic clearing near and acrossintermittent river beds. No publichearing or EIS.

Threatened water body:

Bahia Fulladoza, Culebra, Puerto Rico

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Culebra March 2011 Sardinas Aloe Fulladoza

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