Surfrider Foundation: Rincón, Puerto Rico

August 8, 2005: Letter from Surfrider Foundation to National Marine Fisheries Service

National Marine Fisheries Service
Assistant Regional Administrator
Protected Resources Division
Southeast Regional Office
Protected Resources Division
263 13 th Avenue South
St. Petersburg, Florida 33701
(via email to Acropora.Info@noaa.gov

Re: RIN 0648-XB29

August 8, 2005

Dear Sirs:

The Surfrider Foundation, our 60 chapters and 40,000 members, including the Rincón Chapter of the Surfrider Foundation respectfully offer the following comments of the Caribbean Fisheries Management Council. The Surfrider Foundation is a non-profit environmental organization dedicated to the protection and enjoyment of the world's oceans, waves and beaches for all people, through conservation, activism, research and education. The Surfrider Foundation has been active in Puerto Rico (PR) for over a decade and was most recently involved in the establishment of the Reserva Marina Tres Palmas -- a marine reserve that protects some of the healthiest elkhorn coral found in the Caribbean¹. Additional information can be found at this web page.

We support the proposal to place Elkhorn (Acropora palmata), Staghorn (A. cervicornis), and the rare Fused Staghorn (A. prolifera) on the list of endangered species under the Endangered Species Act of 1973, as amended.

These coral reefs provide a number of ecosystem services and are good for the economy. Coral reefs provide important habitat for many species including fish that are caught for food, they provide a buffer against coastal erosion and tsunamis, create a platform for many popular surfing spots, and attract tourists who dive and snorkel on them.

The coral reef in Rincón, Puerto Rico provides environmental and economic benefits to the small community: the Tres Palmas reefs protect the adjacent shoreline from erosion and Elkhorn colonies provide essential fish habitat.² Rincón has a long tradition as a fishing community and a small but important demographic continues to rely on fishing for income. The reefs provide world-class snorkeling & surfing opportunities for tourists. With 60 percent of Rincón's workforce & 40 percent of its income generated by coastal tourism, the Tres Palmas reefs are among Rincón's strongest natural and economic assets.³

Additional Suggestions:

Include Fused Staghorn in the Designation

We encourage you to designate not only Elkhorn and Staghorn, but also the rare Fused Staghorn for additional protection. It will be difficult and challenging for enforcement officers to distinguish between these varieties of acroporid corals when trying to enforce this designation in the field under the similarity of appearance protocol. The fused Staghorn is far more rare than Elkhorn or Staghorn and is thought to be a hybrid of the other two species. While it is not yet known if it is sterile or reproductively viable, it needs equal protection as a true endangered species unless it is proven otherwise.

Upgrade Designation from Threatened to Endangered

We encourage you to designate each of the three corals as endangered, not just threatened based on the following findings. Your review team found that in the few locations where quantitative data are available (i.e. Florida Keys, Dry Tortugas, Jamaica and the US VI), declines in abundance are estimated at greater than 97 percent. This severe finding of loss is the major reason for recommending the higher level of protection. Given the rapid decline of these species and the unknowns regarding whether small remnant populations will survive, the precautionary approach would mandate that you provide these species with this additional level of protection of endangered rather than threatened.

Designation of Critical Habitat

We agree with coral reef experts who have recommended designating the following coral reef areas as candidates for inclusion in the critical habitat designation:

Florida Keys
Broward and Palm Beach County
Puerto Rico (See above)
U.S. Virgin Islands
Navassa

Proposed Actions to be Taken

We support the additional actions to increase coral reef protection:

Dedicated funding to upgrade wastewater and stormwater treatment in upland areas near coral reefs. Coral reefs in the Florida Keys, Broward County, the Palm Beaches, Puerto Rico and the U.S. Virgin Islands are being damaged by poorly treated sewage effluent that is reaching coastal and offshore coral reefs. Coral reefs need clear, clean, nutrient free waters to thrive. Funding is needed to replace sewer outfalls that discharge directly into coastal areas; aging and leaking septic systems; package plants that discharge partially treated sewage into shallow injection wells that migrate into nearshore waters; deep injection wells that allow the migration of waste through underground cracks and fissures; cesspits that deliver untreated waste to nearshore waters. Cruise ships discharge an average of 30,000 per day of concentrated and poorly treated waste en route to ports in Florida, Puerto Rico, and the U.S. Virgin Islands. I support the recommendation to: (1) Adopt a uniform federal standard of advanced nutrient-stripping sewage treatment for all coastal areas adjacent to coral reefs, (2) The direct discharge of treated sewage effluent should no longer be permitted into coastal areas near fragile coral reefs. (3) The new nutrient standard should be applied to existing package plants utilizing shallow injection wells in areas adjacent to coral reefs. (4) Any sewage treatment plant that is currently permitted to dispose of secondarily-treated waste into deep injection wells adjacent to coastal areas with coral reefs should be required to upgrade treatment to this advanced nutrient stripping level. (5) This new federal standard should apply to cruise ships that visit ports in areas of U.S. jurisdiction where coral reefs exist. (6) Most importantly, federal funding should be dedicated to match state and local funding to achieve this much needed goal of upgraded wastewater treatment for all coastal areas adjacent to coral reefs in Florida, Puerto Rico and the U.S. Virgin Islands. These are among the most important federal actions that can be taken to protect these endangered coral reefs.

Agriculture and stormwater runoff onto coral reefs should not be permitted.

The number one threat to the elkhorn reefs off of Rincón, Puerto Rico is sedimentation from storm water. We believe this site is indicitive of problems occurring through Florida and the Caribbean. Actions must be taken to reduce, mitigate and eliminate agricultural and stormwater runoff from impacting coral reefs. These efforts include stricter regulations, enforcement of stormwater regulations, education and outreach regarding land-sea connections, an eco-system based approach to coral reef protection and the development of easy to read best management practice (BMP) guides in both English and Spanish.

The Endangered Species Act is our nation's safety net for fish, wildlife, and plants on the brink of extinction. We owe it to our children and grandchildren to be good stewards of the environment. Our Caribbean corals need the Endangered Species Act to help them recover. It will provide these corals with a comprehensive recovery plan that will serve as a strategic and comprehensive blueprint for research into coral diseases and their cures. Research projects that are consistent with this plan will find additional funding and support. The Endangered Species Act will also protect the corals' critical habitats. Finally, the listing will require greenhouse gas emitting industries to consider the impacts of their emissions on corals.

A nationwide poll found that 86% of American voters support the Endangered Species Act. Please support a strong Endangered Species Act so that our corals can be enjoyed by future generations.

In conclusion, we provide several recommendations to restore Elkhorn, Staghorn and Fused Staghorn coral populations in U.S. Territories. They have been endorsed by many other individuals and organizations representing literally thousands of U.S. citizens. Thank you for the opportunity to submit these comments to you.

Sincerely,

Chad E. Nelsen
Environmental Director
Surfrider Foundation
cnelsen@surfrider.org

Leon Richter
Salva Tres Palmas Campaign Coordinator
Rincón, Puerto Rico
lrichter@surfrider.org

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FOOTNOTES:

¹ Bruckner, Andrew PhD. Letter to Puerto Rico Department of Natural Resources. December 6, 2001.

² Ibid.

³ Pendleton, Linwood PhD. "A Preliminary Study of the Value of Coastal Tourism in Rincón, Puerto Rico", University of Southern California, March 2002.