From: Lisamarie Carrubba - NOAA Federal lisamarie.carrubba@noaa.govSubject: Re: PRELIMINARY DETERMINATION OF ACROPORID CORAL DCH ACROSS PUERTA DE TIERRA CORAL REEFS

Date: February 19, 2015 at 5:01 PMTo: Sonia Villaverde gpsyblu@aol.comCc: 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

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 thesidewalk collapsing. The stones that have been placed parallel to the coast were put there at our recommendation to trap sedimentsas they are working, leaving the area behind them with a trench where the sediments accumulate and are then cleaned out alongwith construction debris as work is done. The project is being undertaken by the Puerto Rico Highway and Transportation Authorityand is permitted by the Corps of Engineers. There will be a series of erosion control measures, including vegetation planting, to try toprevent future landslides in this area that do lead to harm to the coral reef ecosystem just offshore. Unfortunately, any projects of thistype do lead to temporary impacts but, from your photos, it looks like the stone berm and trench are working to prevent majortransport 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 CoralDesignated Critical Habitats Across Puerta de Tierra Urban Coral Reefs, San Juan, PuertoRico".

Please be advised that this document is a "Preliminary Report Submitted to theNational Marine Fisheries Service and the PR Department of Natural and EnvironmentalResources" written by Dr. Edwin A. Hernández-Delgado (1,2,3) with the collaboration ofIvangs Rivera (1) and Samuel Suleimán Ramos (1). (1) Sociedad Ambiente Marino (SAM) (2) University of Puerto Rico – Center for AppliedTropical 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 systemswas to:

1) Provide a rapid qualitative assessment of adjacent benthic communities across thepotentially 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 Laminarstar coral (Orbicella faveolata) within less than 200 m from the shoreline. Dr. Edwin Hernández, in collaboration with his team from SAM and UPR-CATEC, foundthat there were multiple colonies of A. Palmata located within 50 m or less from theshoreline. Preliminary observations suggested that, nearly the entire surveyed segmentdominated by colonized pavement and patch reefs constituted part of the Acroporidcorals DCH. Though only one colony of O. Faveolata was observed during the preliminaryinspection, and though no DCH has been officially designated yet for this species, thishabitat represents also critical habitats for its presence. The existing coral biodiversitypreliminarily documented in this survey showed a total of 26 species within 700 linearmeters of reefs along the shoreline, including 3 hydrocorals, 11 octocorals and 12scleractians or hard corals.

A preliminary survey of fish fauna also showed a total of 59 species, belonging to 37genera and 25 families. This is only a preliminary list and future surveys may guaranteethat this list is likely to grow. The surveyed reef segment constitutes a very importantessential fish habitat (EFH) for multiple reef fish species, including species managed by theCommonwealth of Puerto Rico and the National Marine Fisheries Service (NMFS). Therewas also presence of submerged aquatic vegetation (SAV) across the adjacent benthicsystems, 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 notaddressed. A massive landslide is significantly impacting the shoreline and adjacent coralreefs ecosystems. The recommendation is that there is a need to immediately stabilize an active landslide inthat coastline to reduce further impacts to adjacent coral reefs and SAV, including DCH ofAcroporid 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 adjacentreef bottoms;3) Address impacts to EFH; and

4) Initiate consultation with NMFS under section 7 of ESA; and5) 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 ofan abandoned breakwater in navigable waters of the Atlantic Ocean was permitted by theUS Army Corps of Engineers. This should also be addressed. According to the availablepublic record, potential environmental impacts of this project on coral reef ecosystemswere not addressed. It should be noted that the tracking number of the Notice of Intent

were not addressed. It should be noted that the tracking number of the Notice of Intentsubmitted to the EPA does not yield any results. This should also be examined.Though this project will not be constructed within navigable waters, there is significantpotential for permanent adverse impacts on coral reefs associated to the construction ofthis 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