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Box 750
Isla de Culebra, Puerto Rico 00775 787-556-623

Hon. Tania Vázquez Rivera,
Department of Natural and Environmental Resources
P.O. Box 366147 San Juan, PR 00936
January 15, 2019

Dear Secretary Vázquez:

CORALations is an award-winning Caribbean coral reef conservation organization based on the island of
Culebra. This letter is to inform you of aggressive deforestation and earth movement in an environmentally
sensitive area of Culebra. We have been unable to obtain a formal complaint number from the local DRNA
Ranger’s office since the deforestation at this project site accelerated with the arrival of a large
trackscavator on the 7th of January, 2019. We are hoping you can provide a formal complaint number for
the following:

• no sign at the project sight indicating name of the project proponent, permit or permit numbers and
issuing agencies for deforestation, earth movement and road construction.

• no implementation of erosion control measures at the impacted site.

The receiving waters of impact from resulting erosion is the Flamenco lagoon wetlands, considered an area
of particular concern by the DRNA. To date earth moving exceeds an acre, including roads. Because there
is no public signage, our best estimate of location are these coordinates: 18° 19’ 20”. 65°18’ 33”. The
possible lot number assessed from the Planning Borard’s GIS website is: 473-051-014-07. Possible name
of project, again assessed from same GIS site: Villas Eco-Touristicas Andrades. The project is located
approximately 280ft above sea level with some areas recently cleared having an estimated slope of 35°—
45 °. The areas being deforested had /have diverse dry forest canopy, as can be documented from googel
earth and adjacent forest. These trees are slow growing and critical to soil stabilization and difficult to
mitigate. The soil type is highly erodible volcanic RS-Rockland. This adds to the cumulative impacts from
works impacting a wider area of this watershed. If this is the project does correspond to the one found on
the Planning Board’s GIS website, we would like to include in our formal complaint that it is not legal to use
fast track categorical exclusions as the basis for environmental permitting for projects on Culebra. The use
of Categorical Exclusions typically issued within 24 hours of initial application, is being abused over the
entire island.
After more than two decades of work, our organization today better understands how complex resource
conservation can be in this region, especially where the natural patrimony is also the attraction that
supports Culebra’s eco-tourism economy.

We are here to support the conservation and restoration of these spectacular coastal zone resources, so
please don’t hesitate to ask if you feel we can help.

We look forward to a response and a formal complaint number.


Mary Ann Lucking