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CORALations, Inc.

Agency Notice 17 APRIL 2024 Page 1 of 3

Carmen R. Guerrero Pérez Anaís Rodriguez Vega


Director Secretary
Caribbean Environmental Protection Division Puerto Rico Department of Natural and
United States Environmental Protection Agency Environmental Resources,
Environmental Quality Board, and
Andy Strelcheck
Southeast Regional Administrator Julio Lassus Ruiz
NOAA Fisheries President
Puerto Rico Planning Board
Jennifer Grandholm Federal Coastal Zone Consistency
Secretary
US Dept of Energy Steven Muldrow
US Attorney District of Puerto Rico
US Environmental Crimes Task Force

Re: Evidence of egregious water quality impacts, San Juan Bay dredge project

Dear Agency Representatives:

This is to inform you of recent evidence shared on social media site Ocean Physics Education,
documenting serious water quality impacts associated with the San Juan Bay dredge and
ocean-dumping project. We understand that ocean-dumping is managed by EPA.

The dredging permit issued by the US Corps of Engineers were challenged in court for failing
to respect NEPA planning requirements speci c to considering a complete EIS as this is a
complex and risky project for area Environmental Justice communities, listed endangered
species, designated critical habitat waters, a busy cruise port, an airport, the Capitol of Puerto
Rico and multiple UNESCO Heritage sites. The dredging began as we await a nal ruling from
the appellate court.

Please understand this is not a routine dredge maintenance project needed to support
navigational commerce in San Juan Bay. This project is a risky expansion of dredging needed
to support the passage of massive LNG tankers to the New Fortress Energy transfer facility.
The facility was constructed during hurricane recovery without FERC oversight and is
surrounded by EJ neighborhoods and tank elds that store highly combustible fuels.

The US Army Corps invited agencies to participate in an EIS planning process, (LINK
Appendix J), but instead based the permit issued on a series of fragmented EA's referencing
insu cient data collected before before impacts from two back-to-back major hurricanes in
2017. Also not taken into planning consideration is public input on site-speci c BMPs needed
to meaningfully reduce sedimentation and with respect to dramatic and recent environmental
change including the annual and massive in ux of sargassum, seasonal weather, dramatically
increasing sea surface temperatures and accelerating coral collapse.

Dredge technology has not changed in over 150 years and federal subsidies that provide over
$60 million to accommodate the well-healed fossil fuel industry's dock access, lock Puerto
Rico into a continued reliance on this dirty energy. The fossil fuel industry could a ord to
implement alternatives to this dangerous ocean dumping practice of toxic dredge spoils.
Puerto Rico is not close to meeting its 40% by 2024 renewable energy goals established in the
PR100 Plan, and these federally subsidized impacts extend local dependency on less resilient,
dirty, fossil fuel energy. The permit issued serves as contract and the series of fragmented EAs
submitted obscure not only these coastal waters, but likely confound accountability on this
federal spending as well.

PO Box 750 Culebra, Puerto Rico 00775 coralations@gmail.com


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CORALations, Inc. Agency Notice 17 APRIL 2024 Page 2 of 3

Link to Face Book:


https://www.facebook.com/share/p/uDCxps3JDLPcfbYy/?mibextid=WC7FNe

Screen shots of Social Media, Ocean Physics Education taken 17 April 2024:

Translation:

OPE keeps its promise. Here are the images of the extensive
sediment plume of dredged material from San Juan Bay,
whose point of origin is from the place designated for deposit of
the dredged material (see map). In the visible image I could
measure an extension of 57 km and with the chlorophyll-a
signal I could measure 78 km. The dredged material was
deposited in the place designated by law, but ocean currents
moved the plume of suspended sediment in a northwesterly
direction. Marine currents decide where the suspended
material is distributed. The dredging of San Juan Bay is so that
ships can bring natural gas to Puerto Rico.

PO Box 750 Culebra, Puerto Rico 00775 coralations@gmail.com


CORALations, Inc. Agency Notice 17 APRIL 2024 Page 3 of 3

Thank You,

Mary Ann Lucking


Director

PO Box 750 Culebra, Puerto Rico 00775 coralations@gmail.com

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