12/1/21, 9:18 AM Gmail - San Juan Harbor dredge/ Condado lagoon fill

CORALations Culebra <coralations@gmail.com>

San Juan Harbor dredge/ Condado lagoon fill

1 message

CORALations Culebra <coralations@gmail.com> Wed, Dec 1, 2021 at 9:06 AM

To: paul.m.demarco@usace.army.mil, "Guerrero, Carmen" <Guerrero.Carmen@epa.gov>, Kerry Kehoe - NOAA Federal
<kerry.kehoe@noaa.gov>, Rose Ortiz <Ortiz_r@jp.pr.gov>, "Urelius, Karen M CIV USARMY CESAJ (USA)"
<Karen.M.Urelius@usace.army.mil>
Cc: Ruperto Chaparro <ruperto.chaparro@upr.edu>, Ariel Lugo <aelugo1234@gmail.com>, Edwin Hernandez-Delgado
<edwin.hernandezdelgado@gmail.com>, "Coalición Restauración Ecosistemas Santurcinos (CRES)"
<crespuertorico@gmail.com>, Ruth Santiago <rstgo2@gmail.com>, Arrecife Islaverde <pacolopez11a@gmail.com>, "Hon.
Juan Carlos Delmau" <jdelmau@senado.pr.gov>
Bcc: Nicolás Gómez <nicolas.x.gomez@gmail.com>, "alfredo.a.montanez@gmail.com" <alfredo.a.montanez@gmail.com>,
bgraglau@gmail.com, Jose Maldonado <jose@miprv.com>

Dear Mr. Demarco - 

Please reply that you received this.  

RE:  COMMENTS: Draft Supplemental Environmental Assessment  San Juan Harbor, Puerto Rico  Seagrass Mitigation, Additional Sand Source
https://usace.contentdm.oclc.org/utils/getfile/collection/p16021coll7/id/19495

Dear Mr. Demarco:  

CORALations is an award-winning, coral conservation organization, founded in 1995 and based in Puerto Rico.  We strongly disagree with the
conclusion that an Environmental Impact Statement is not required for the above mentioned project, or even the characterization of this project
as having in any way a potential for environmental benefit or ecological restoration.  This project involving over one mile of pipeline proposes to
transport dredge material from what may possibly be the busiest and most toxic bay in the Caribbean, to be used as fill in the shallow Condado
lagoon, an epicenter for various water sport activities including dragon boats, paddle boards, and snorkeling.  

This fill is being proposed as a separate project (?), when it appears to be the same dredge project.  This fill idea, poses a direct threat to the
great strides that have been made to improve water quality of the Condado Lagoon by the USEPA and affiliate organizations.  The project will
also pose cumulative impacts when the sediment laden waters resulting from the fill, mix with waters from Club Nautico Marina, under the
Condado bridge and through the bathing beach of La Playita in front of the Condado Playa Hotel.  

Older documents are referenced and conclusions we believe may be incorrectly drawn that there have been no significant changes over these
years when San Juan Bay, a busy commercial port lined with industry and subject to rising waters was impacted by two major hurricanes in
2017, as well as more recent major swell events.  

There appears to be no mention of the recent construction of a liquified natural gas dock in the bay, adjacent to very busy cruise boat terminals,
that may have failed to pass through any local or federal permitting process, let alone federal consistency evaluation, at least that we know of to
date.  

It is a matter of public record that the waters of San Juan Bay were the recipients of contamination from the cruise boat industry so egregious as
to warrant the highest water quality fines ever issued by the US Federal Court system.  These fines were issued in associated with a cruise ship
caught intentionally retooling their sewage discharge tube configuration in order to discharge while at port in the bay.  Thanks to the Coast
Guard who documented the violation there was a massive conviction and fine,  however, it is not clear how widespread this practice was in the
cruise ship industry, and for how long in this bay. 

The Corps cannot claim that the benthic substrate to be dredged and filled into Condado lagoon is not toxic without current and complete
evaluations. 

It must be stressed that the water quality ramifications from this proposal have potential to impact the swimming/snorkeling area of the Condado
lagoon, La Playito de Condado Lagoon with health ramifications to bathers that are local and also visitors to the Condado Plaza Hotel and area
resorts.  
While this project title “sounds" ecological, the concept is anything but.   Proposing the use of what has to be toxic dredge materials from the
bottom of San Juan Bay, in order to fill Condado lagoon and replant Halophila sp is ill-conceived in concept.  Haliphila sp have become such an
aggressive invasive over the years that it completely out-competes the ecologically important native sea grass Thallasia testinudum.   It may be
worth it to note that Thallasia around Culebra to three miles from shore is listed as Critical Habitat and has itself almost all been destroyed and
replaced by the invasive Haliphila sp. (personal communication regarding report issued by Dr. Edwin Hernandez Delgado)   This invasion was
likely proliferated thanks to increasing and cumulative stress from massive  sargassum invasion, chronic sedimentation, and shoreline
development and destruction of mangroves that have to date gone completely unregulated by local and federal agencies. 

To refer to Halophila sp. restoration as a sea grass restoration is itself misleading and depending on the severity of the toxicity of the sediments
dredged for the harbor,  unlikely to be successful.  

The waters of Conado lagoon are listed Critical Habitat for two coral species A. palmata and A. cervicornis, with other listed species found in a
site visit years ago (not sure if they are still alive) near the mouth of the opening to the sea as well as around Fortín San Geronimo where waters
benefit from Atlantic circulation. 

https://mail.google.com/mail/u/0/?ik=bf7a11e4c1&view=pt&search=all&permthid=thread-a%3Ar4442290847621281328%7Cmsg-a%3Ar505104625816430878&si… 1/2
12/1/21, 9:18 AM Gmail - San Juan Harbor dredge/ Condado lagoon fill
We are opposed to this moving forward in concept alone.  The fill will likely involve small toxic particles that could result in the chronic
sedimentation of Condado Bay Lagoon, leaving waters toxic and turbid.   There will not be a positive outcome and likely there will be signifiant
risks to bathers, chronically compromised water quality with ramifications to sustainable commercial water sports. 

The Corps minimally should present current toxicity information on the benthic materials being dredged from the lagoon, and proposed for fill
with concerns ranging from heavy metals to particle size of sediment. 

We would appreciate any recent toxicity analysis the Corps has obtained on the sediments to be moved from San Juan Bay.  

Thank you,  

Mary Ann Lucking 

Director 
CORALations 
PO Box 750 
Culebra, PR  00775 
787-556-6234

c.  Carmen Guerrero 

     Karen Urelius 
     Rose Ortiz
     Kerry Kehoe 

--

Mary Ann Lucking 

Director 

CORALations 

P.O. Box 750 

Culebra, PR 00775 

www.coralations.org   

787.556.6234     

email:  maryann@coralations.org, coralations@gmail.com

 
Trabajando con comunidades del Caribe para proteger y restaurar
sus arrecifes de coral.

<<><<<>>><>> 

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

CORALations_USACE_Condado Lagoon Fill Project .pdf

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