Your Name: Sonia Villaverde

Your Email: gpsyblu@aol.com

Your City: San Juan

Your State: Puerto Rico

Your Zip: 00907

Your Phone: 561-901-1184

Suspected Violation Date: 01/2015

Suspected Violator Name: Autoridad para el Financiamiento de la Infraestructura

Suspected Violator Address: P.O. Box 41207

Suspected Violator City: San Juan

Suspected Violator State: Puerto Rico

Suspected Violator Zip: 00940‐1207

Still Occurring: no

Notified State DEP/DEQ/DEM: yes

Department Contact:Secretary of DRNA of PR (Departamento de Recursos Naturales y Ambientales), Hon. Carmen E. Guerrero Pérez

Characterized incident as:

Intent: Unknown

Type: Falsified

Media: Land

Media: Water

Media: Documents

Entity: Company

Description of incident or hazard: This complaint is in regards to a potential violation of the local law “Ley para la Proteccion, Conservacion y Manejo de los Arrecifes (Ley Num. 147 del 15 de Julio de 1999)”, in addition to the Coral Reef Conservation Act of 2000, the Clean Water Act §312 Program, the Clean Water Act §301(h), the Clean Water Act §403(c)

Program, the Coastal Zone Act Reauthorization Amendments in 1990, and the Coastal Zone Management Act of 1972 16 U.S.C. § 1455b, Protecting Coastal Waters by the construction project for a "multimodal transportation system" referred to as "El Paseo Lineal de Puerta de Tierra" by AFI (Autoridad para el Financiamiento de la Infraestructura). This construction is in process in the sloped coastline of an islet called Puerta de Tierra (approximately 0 to 38 meters above mean sea level). This project seems to disregard imminent environmental impacts that will be directly caused by the design of this construction on this site, especially to a sloped coast in crisis and the nearby reef systems. This coastline suffers from the effects of erosion and the design of the project does not seem to have considered nor be based on any geomorphological,

coastal dynamics, nor marine scientific investigations. The project consists of significant deforestation of palm trees, “uncommon” native trees and vegetation (more than 50% declared in a survey), use of heavy machinery for cutting, extractions and excavations (which has the potential to impact the integrity of the sloped coastline as well as arqueological sites), and rerouting of non-point source pollution into this coast/beach/ocean. The only document that has addressed the environmental impacts is the EA or Evaluación Ambiental (Environmental Evaluation). This evaluation fails to address any potential or imminent impacts to the coastline, coastal waters and the reef system from land based point and non-point sources of pollution. As stated by NOAA http://oceanservice.noaa.gov/education/tutorial_corals/coral09_humanthreats.html :

"One of the most significant threats to reefs is pollution. Land-based runoff and pollutant discharges can result from dredging, coastal development, agricultural and deforestation activities, and sewage treatment plant operations. This runoff may contain sediments, nutrients, chemicals, insecticides, oil, and debris (UVI, 2001)." During a second (citizen requested) meeting that was conducted yesterday, January 30, 2015, with the Executive Director from AFI (Autoridad para el Financiamiento de la Infraestructura) Grace M. Santana Balado, the Secretary of DRNA of PR (Departamento de Recursos Naturales y Ambientales), Hon. Carmen E. Guerrero Pérez, and the architect, Alberto Lastra, the local residents expressed their concerns about the lack of transparency of the process in this project. This concern is mainly driven by the fact that vital

reports for projects like this, such as the “Declaration of Environmental Impact”, was not required. In turn, the “Evaluation of Environmental Impacts” (EA) report submitted to obtain the construction permits fail to address issues of coastal integrity due to deforestation, fails to present any studies that address point and non-point sources of pollution of the coastal waters by the planned redesign of draining systems of the islet into the coastal waters, and the potential or imminent impact of this activity on the coast, marine environment and the reef ecology. The only mention of the reefs in the EA is that they are located at 200 meters from the project and, hence, they will not be impacted by this construction. Here I include links to the two documents that address the environmental impacts referred to above. The first is the “Evaluación Ambiental” (EA) and the

second is what I assume is “Anejo 3” “Estudio de Flora y Fauna” which does not present any studies or investigation on the marine environment, specifically, the local reefs. http://www.bgfpr.com/2013/Grants/TIGERGRANTS2014/Documents/SJMultimodal/03-DrawingsandTechnicalStudies/StateEnvironmentalEvaluation-PaseoPuertadeTierra.pdf http://www.bgfpr.com/2013/Grants/TIGERGRANTS2014/Documents/SJMultimodal/03-DrawingsandTechnicalStudies/FloraandFaunaStudy-PaseoPuertadeTierra.pdf

Specific Directions: From the International Airport Luis Muñoz Marin, exit into westward to Expreso Loiza (#26) which then becomes Expreso

Baldorioty de Castro (#26); continue northwest bound into Avenida Muñoz Rivera (#25) until going past "El Escambron" and reaching the top and beginning of the slope by the "El Hamburger" business on the left (south side). There is a collapse of the coastline at that site. That avenue is the site for this project up until the "Capitolio".

http://cfpub.epa.gov/compliance/sendmail/add_tc.cfm