CORALations, Inc.

Playa Brava Culebra Puerto Rico December 23, 2019

Recent Dirt Road Construction Deforests Federally Listed Critical Habitat Lands, Culebra, Puerto Rico.

10-05-2019 Playa Brava N 10-05-2019 Playa Brava SE

Please visit album to see and download high resolution images, and extended file information. https://coralations.smugmug.com/Playa-Brava-2019/

DESCRIPTION: A dirt road was recently opened down steep sloping, volcanic lands (RS-Rockland), deforesting ecologically sensitive coastal
dry forest, including listed critical habitat to the historic east side access area of Playa Brava. Recent work was also observed on multiple lots in
the area. No signs were posted to indicate permit number, name(s) of project proponent(s), or a coastal zone permit application for the
delineation of the public’s dominion for this shore (ZMT). No erosion control was observed, nor planning to slope or contour consistent with
engineering best management practices. The deforestation runs parallel and within 300m of the Culebra National Wildlife Refuge (CNWR)
boundaries, and the area deforested, reflects the same high ecological value of coastal forests seen on adjacent refuge lands. The road
fragments ecologically sensitive lands, and poses a serious threat of erosion and sedimentation (1-8) to coastal beach and the receiving waters
of Bahia de Oleaja. The beach and waters of this bay are listed as critical habitat for nesting and foraging sea turtles, as well as reef building
corals found offshore. Federal, and/or Commonwealth listed species this deforestation may have impacted, and/or now pose an increased
threat of impacts to, include: Virgin Island tree boas (Epicrates monensis), the endangered, endemic Culebra giant anoles, (Anolis roosevelti),
hawksbill sea turtles (Eritmochyls imbricata), leatherback sea turtles (Dermochelys correacea), green sea turtles (Chelonia mydas), elkhorn corals
(Acropora palmata), three species of boulder star coral (Obicella sp.), and pillar coral (Dentrogyra cylindrus). Migratory birds and essential fish
habitat also may be impacted by sedimentation and increased, unmanaged uses of these critical habitat areas. Playa Brava, offers no facilities
and is a dynamic and dangerous north shore beach, so named for its breaking waves and strong rip currents. The road plowed has since eroded
significantly, and today presents an increased risk and associated burden to rental car companies and a small municipality responsible for visitor
safety and rescue. Previous dirt roads plowed in this area have dramatically eroded into coastal waters during heavy rains, leaving deep culverts
in the lowlands.

While a matter of public record that CORALations has defended pubic access roads to Culebra beaches, the organization has advocated
designation and official documentation of hiking access trail to Playas Brava and Resaca, to protect a sustainable public access for future
generations. Brava’s walking trail has always been seen as an asset to Culebra’s high caliber, repeat, nature tourism product, and is treasured by
locals who have, for years, visited, surfed and cared for this beach.

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

CORALations, Inc. Playa Brava Culebra Puerto Rico December 23, 2019

Critical Habitat Deforested

Estimate of Area of Impact

Critical habitat was designated in Culebra waters (see reference below) to Conservative estimates of area
three miles from shore for hawksbill and green sea turtles, as well as two
Caribbean Acroporid coral species.
deforested were determined with the aid
of Google Earth (GE). The area near the
beach (A) and road segment (E) were
estimated at 12ft (3.6m) width. Where
the slope increases greater than 30O, the
road with increases to15ft (4.6m) with
larger areas cleared not included in this
analysis.

Direct Impacts to Critical Habitat

Designated Lands: 47 FR 27295,
(June 24, 1982) designated terrestrial
critical habitat for the hawksbill sea turtle
(Erytmochelys imbricata), including the
beach front of Playa Brava, Culebra
Puerto Rico, from mean high tide to a
point 150m from the shore. The use of
this beach for leatherback (Dermochelys
coreacea) has been well documented by
government agencies. The red dashed
lines show the 150m from mean high
tide.

Coastal waters of Culebra, including the waters of Bahía de Oleaje, were also designated as critical habitat for green (Chelonia
mydas) and hawksbill (Eretmochlys imbricata) sea turtles. 63 Fed. Reg 46693 (Sept. 2, 1998) and elkhorn (Acropora palmata) and
staghorn (Acropora cervicornis) corals. 63 Fed. Reg. 72210 (Nov. 26, 2008).

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

2
CORALations, Inc. Playa Brava Culebra Puerto Rico December 23, 2019

Venture Management, Inc.

473-000-003-07-000
Brava Preservation and
Recreation SE
473-000-003-08-000

Culebra
National
Rafael Diaz Romero
Wildlife 473-000-008-27-000 Josephine B. Steven
Brice Thompson
Refuge 473-000-008-28-000 473-000-003-06-000
473-000-003-05

Ralph Houston Diaz

373-000-003-01 Brice Thompson
473-000-003-000

Maria de
VEZPA la Cruz Marquez
473-000-008-26-000 473-000-003-29-000

Petra Marquez Laureano, c/o Bryce

Jorge Guerrero Thompson. 473-000-003-08-000
Calderon
473-000-008-25-000

Hollis Burbank
Hammerlund
473-000-008-08-000

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

3
CORALations, Inc. Playa Brava Culebra Puerto Rico December 23, 2019

1993-1994: Documents are available at USFWS via FOIA that report past deforestation in this area.

JAN 20, 2007: Site visit of recent deforestation/road construction. There were no signs posted with permit numbers or erosion
control. Knowltons attempted to stop machines by blocking beach access road and indicating walking access only.

https://coralations.smugmug.com/BRAVALeatherback-Sea-Turtles-Upland-Erosion-Threatens-Playa/

Jan 20, 2007

JAN 21, 2007: CORALations filed complaint # QC-02-07 with local DRNA, for failure to implement erosion control, and no permit
sign.

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

4
CORALations, Inc. Playa Brava Culebra Puerto Rico December 23, 2019

FEB 2007: Knowlton’s shared the following documents. An add appeared on Craig’s list selling property in December of 2006.

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

5
CORALations, Inc. Playa Brava Culebra Puerto Rico December 23, 2019

MARCH 8, 2007: Deforestation was stopped by local DRNA Ranger, when machines moved through Knowlton’s downland
property, at that time collaboratively owned with Bryce Thompson 473-000-003-000. The photo of bulldozer was taken a few hours
before the order of paralysis, and just before the machines finished clearing deep washouts on their way to the beach entrance.

March 8, 2007

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

6
CORALations, Inc. Playa Brava Culebra Puerto Rico December 23, 2019

MARCH 20, 2008 historic high surf (marejada) on Playa Brava - with water flowing into and out of lagoon.
This is evidence that the ZMT setback should start at the back of the Brava lagoon. Please visit album to see and download high resolution
images, and extended file information. https://coralations.smugmug.com/Surfs-Up-Playa-Brava-Culebra/

March 20, 2008

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

7
CORALations, Inc. Playa Brava Culebra Puerto Rico December 23, 2019

JAN 6, 2011, a new sign and fence post was photographed installed at the entrance of Playa Brava. This album shows photos of
road erosion over 2m deep in areas. The album also shows beach erosion and a terrestrial marker on the beach. Please visit album to
see and download high resolution images, and extended file information. https://coralations.smugmug.com/Playa-Brava/

January 6, 2011
January 6, 2011

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

8
CORALations, Inc. Playa Brava Culebra Puerto Rico December 23, 2019

APRIL 4, 2012: Exploradores Marinos Teo, Felix and JanLee document listed species of corals on east side surf
break of Matojo . Please visit album for high resolution downloads and to view extended file information:

https://coralations.smugmug.com/Exploradores-Marinos-18/

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

9
CORALations, Inc. Playa Brava Culebra Puerto Rico December 23, 2019

Zoning: Planning Board of Puerto Rico: RO-5-C

Clasificación del PUT, 30 de noviembre de 2015: SREP-E  “Suelo Rústico Especialmente Protegido Ecológico” -
“Special, protected ecological lands.”

NOTE: DECEMBER 27, 2012 Radical Zoning Changes Without Meaningful Public Participation.
Culebra’s low-density protective zoning was changed on December 27th, 2012, during a change of administration, and without
benefit of meaningful public participation with the adoption of the Plan de Ordinación Territorial. It is not clear what level of
autonomy the island currently enjoys, but we understand there is currently no local planning board consistent with requirements of
PR Law 81, for full local autonomy. Local residents received no official notice of zoning changes affecting their own property. No
notice for Federal Consistency review, nor proposed amendment to the Culebra Segment of the U.S. Coastal Zone Management
Plan were found on record.

Previous protective zoning was defined as follows:

R - residential, O for special ecological protection zoning, 25 - low density, one house per 25 cuerdas, and C, which if the Planning
Board’s best use for these lands, “conservation.”:

Puerto Rico Law 66, 1975 (as amended ) Article 2 (21 L.P.R.A. § 890a) defines the public policy for Culebra as follows:

Article 2. - Public Policy and Legislative Intention. (21 L.P.R.A. § 890a)

It is declared to be the public policy of the Government of Puerto Rico to conserve the ecological integrity of
Culebra, including its keys, islands and surrounding waters and ensure that the continued development of
Culebra protects and conserve, to the maximum, its extraordinary natural environment that is part of the Puerto
Rican heritage.

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

10
CORALations, Inc. Playa Brava Culebra Puerto Rico December 23, 2019

References

1. Bégin, C., Brooks, G., Larson, R. A., Dragicevic, S., Ramos-Scharrón, C. E., and Côté, I. M. (2014). Increased sediment loads over
coral reefs in Saint Lucia in relation to land use change in contributing watersheds. Ocean Coast. Manag. 95, 35–45. doi: 10.1016/
j.ocecoaman.2014.03.018

2. Bégin, C., Schelten, C. K., Nugues, M. M., Hawkins, J., Roberts, C., and Côté, I. M. (2016). Effects of protection and sediment stress
on coral reefs in Saint Lucia. PLoS One 11:e0146855. doi: 10.1371/journal.pone.0146855

3. Carlson Rachel R., Foo Shawna A., Asner Gregory P.(2019) Land Use Impacts on Coral Reef Health: A Ridge-to-Reef Perspective
Frontiers in Marine Science 6, 562. doi 10.3389/fmars.2019.00562

4. MacDonald, L. H., Anderson, D. M., and Dietrich, W. E. (1997). Paradise threatened: land use and erosion on St. John, US Virgin
Islands. Environ. Manag. 21, 851–863. doi: 10.1007/s002679900072

5. MacDonald, L. H., Sampson, R. W., and Anderson, D. M. (2001). Runoff and road erosion at the plot and road segment scales, St.
John, US Virgin Islands. Earth Surf. Process. Landf. 26, 251–272. doi: 10.1002/1096-9837(200103)26:3<251::aid-esp173>3.3.co;2-o

6. Ramos-Sharron, C.E. and Lee, H.M. (2006) Runoff and suspended sediment yields from an unpaved road segment, St
John, US Virgin Islands, Hydrogeological Processes 21, 35-50 doi: 10.1002/hyp.6175.

7. Ramos-Scharrón, C. E., and MacDonald, L. H. (2005). Measurement and prediction of sediment production from unpaved roads,
St John, US Virgin Islands. Earth Surf. Process. Landf. 30, 1283–1304. doi: 10.1002/esp.1201

8. Ramos-Scharrón, C. E., and MacDonald, L. H. (2007). Measurement and prediction of natural and anthropogenic sediment
sources, St. John, U.S. Virgin Islands. Catena 71, 250–266. doi: 10.1016/j.catena.2007.03.009

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

11