Puerto Rico-Water Quality

CORALations, Inc. corals at caribe.net
Thu Oct 29 15:52:24 EST 1998

Greetings coral-listers,

=09CORALations is NGO based in San Juan, Puerto Rico. We are looking for
support or endorsement to the following letter to the U.S. Environmental
Protection Agency, Region 2,  regarding the discharge of primary sewage
into our coastal waters. PR has 5 pending 301(h) waivers which allows legal
discharge of primary sewage into our waters. Plants have been discharging
primary sewage (when functioning properly) as EPA 301(h) waivers continue
pending for in some cases, well over a decade. The specific plant addressed
in this letter, has not even been built yet.  Since this stands to impact
shared resources throughout the Caribbean, we are hoping to generate
supporters from the list.
=09Those who wish to support, please email corals at caribe.net and include
name, title, organization or agency, address, area code and phone for
confirmation along with a brief statement of support. Thank you, Mary Ann
Lucking, Project Coordinator.

October 31, 1998

Mrs. Jeanne M. Fox
Regional Administrator
U.S. Environmental Protection Agency
290 Broadway
New York,  NY 10007-1866

Re: Dorado Regional Wastewater Treatment Plant 301(h) Application

Dear Mrs. Fox:

=09CORALations is a non-profit, ocean conservation organization based
in San Juan, Puerto Rico. We are writing to express our opposition to the
construction of yet another primary waste water treatment plant by the
Puerto Rico Aqueduct and Sewer Authority [PRASA] in Dorado, Puerto Rico.
We understand that PRASA has now requested another extension of the
deadline established by the Environmental Protection Agency to submit a
301(h) waiver application for this plant.

=09As you know, PRASA has been negligent in submitting the necessary
documents for the proposed Dorado plant as well as for other functioning
primary treatment plants, in some cases for more than a decade.  We do not
believe EPA originally introduced the 301(h) waivers with the intent of
facilitating this kind of abuse of the Clean Water Act, although this has
clearly been the outcome in Puerto Rico.

=09The discharge of improperly treated sewage into our coastal waters
has been documented by scientists as one of the major contributors to the
destruction of almost half of the coral reefs around the big island of
Puerto Rico.  Again, almost half of all our 7 to 9,000 year old reef
systems are dead.  The other half are dying at an alarming rate. Having
just returned from a meeting of the first U.S. Coral Reef Task Force
created in response to an Executive Order drafted to protect declining
reef systems, it is our understanding that EPA should now embrace the
following policy in all of its current decision making.

Section 2, Policy,  Executive Order 13089 -  Coral Reef Protection, Federal
Register Vol 83, No. 115, dated Tuesday, June 16, 1998:

(a) All Federal agencies whose actions may affect U.S. coral reef
ecosystems shall: (a) identify their actions that may affect U.S. coral
reef ecosystems; (b) utilize their programs and authorities to protect and
enhance the conditions of such ecosystems; and (c) To the extent permitted
by law, ensure that any actions they authorize , fund, or carry out will
not degrade the conditions of such ecosystems.

=09In this, =93The International Year of the Oceans=94, water quality
issues have been brought to the front lines of National concern. As
residents of Puerto Rico, it is not acceptable to us that your agency
allow an outdated primary treatment plant be constructed today, for use
well into the 21st century. During storms, our neighboring Loiza plant
discharges raw sewage. In Puerto Rico, water quality data is sparse and
often evaluated at intervals not sufficient to protect water recreators
and coastal residents.  We are concerned about entrusting an agency, which
has repeatedly demonstrated an inability to submit requests for 301(h)
waivers in a more than reasonable time frame, with the much more
complicated task of maintaining a primary plant in compliance to standards
as worded under 301(h) of the Clean Water Act.

=09Our recent review of the Environmental Impact Statement [EIS]
written in evaluation of a proposed deep ocean outfall for primary sewage
in Mayaguez, revealed incomplete data on seasonal currents for the area of
outfall, misleading conclusions drawn from insufficient data on species
documented in the area of outfall, and complete negligence on the part of
the originators to evaluate all practicable alternatives. We fear these
remaining pending waivers will be pushed forward in the same non-objective
and scientifically irresponsible manner, resulting in costly appeals for
all of us.

=09We join the many scientists around the globe who no longer embrace
=93dilution as the solution,=94 and who recognize the need to employ a
precautionary principle when engaged in waste water management planning.
This is especially important in such biologically diverse and sensitive
areas as the tropics.  There are cost effective waste water treatment
solutions which can be implemented in Puerto Rico. Our primary plants can
be re-fitted to secondary and the resulting waste discharged into man made
wetlands for final nutrient absorption.

=09We respectfully request that EPA deny PRASA's request for an
extension and also deny the pending 301(h) waiver for the proposed Dorado


M.A. Lucking
Project Coordinator

cc.=09Hon. Bruce Babbitt
=09Hon. William Daley
=09Hon. Jorge Acevedo Mendez

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