January 7, Originally sent via . Dear Sir & Madam:

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1 January 7, 2008 José E. Hernández Borges, Director Ejecutivo Auxiliar para Infraestructura Thelma Valenzuela Sanchez, ACT/DTOP Oficina de Patrimonio Cultural PR Department of Transportation (DTOP) /ACT Centro Gubernamental Minillas PO Box San Juan, PR Originally sent via Dear Sir & Madam: The purpose of this letter is to follow up on the December 3, 2007 DTOP meeting at your offices. We appreciate your continued efforts to improve the plan and the ongoing opportunity to provide input for the proposed Rincón Bicycle and Pedestrian Trail. We kindly request that you keep us informed of any changes to the proposed plan. These comments compliment previous comments that were submitted by the Surfrider Foundation on March 4, 2004 and September 25, 2007, which are available for download at: Domes to El Faro: GL-5: La Torre de Observación We recommend that the whale observation tower be eliminated because it is redundant with the whale observation park found at El Faro. Additionally, elimination of this tower will eliminate the need for shoreline armoring proposed from station to station According to GL-16, elements of the whale observation tower (station points 1-20) appear to be located in the surf zone. GL-6 (formerly A-7): We recommend that the path be moved adjacent to the existing municipal road thereby 1

2 reducing construction cost and ongoing maintenance expense. Parking should be made available exclusively at an expanded upper level and the lower parking area should be eliminated. At the same time, restoring vegetation in the lower dirt parking area (as used today) would minimize erosion, sedimentation and runoff while enhancing public green areas. Implementation of these changes will make the plan compliant with the USFWS recommendations in their letter dated March 16, Those recommendations are: El Faro: In order to avoid impacts to sea turtles, we recommended that the trail be moved to existing dirt roads and trails or setback at least 50 meters above the high tide to eliminate any possible impacts to the Hawksbill sea turtle habitat. No clearing of coastal vegetation, no construction activity, machinery use, or vehicle traffic should be allowed in these areas. A reforestation program with sea grape and other coastal vegetation is recommended to enhance hawksbill habitat in the area. The beach in Section A-7 is a pristine pocket beach with a very well developed coastal forest, suitable for nesting for both hawksbill and leatherback sea turtles. We support enmienda #4 that eliminates the proposed parking and integrates the bike path plans with the Municipality s lighthouse renovation. GL-7: Indicators to Marias Beach Again we recommend moving the path adjacent the existing roadway. This will minimize the loss of vegetation and will make the path compliant with recommendations made in the April 4, 2001 USFWS letter: We continue recommending no vegetation clearing at the beach areas, construction activities be conducted from the area landward of the trail, restoration of coastal vegetation through planting of native coastal species, and full implementation of erosion and sedimentation control measures. GL-8: Marias, Pistons / Quebrada Piletas As discussed and agreed to at the December 3, 2007 meeting at DTOP, we support the elimination of the plazoleta at Maria s and instead the utilization of areas adjacent to the existing municipal road for parking, and restoration of the green areas for public use. We strongly recommend and support the consideration to move the path inland of the structures between Marias and Quebrada Piletas, near station This beach is a known sea turtle nesting area and would be impacted by the currently planned route. Reserva Marina Tres Palmas (GL9 GL 11) 2

3 The setback from the maritime zone throughout the Tres Palmas Marine Reserve should meet the requirements outlined by the USFWS. As stated in the March 16, 2000 USFWS letter, Although the majority of the route is proposed adjacent to existing roads, there are several section that go through beaches that harbor nesting habitat for the hawksbill sea turtle and leatherback sea turtle. In order to avoid impacts to sea turtles we recommended that the trail be moved to existing dirt roads and trails or setback at least 50 meters above the high tide to eliminate any possible impacts to the Hawksbill sea turtle habitat. No clearing of coastal vegetation, no construction activity, machinery use, or vehicle traffic should be allowed in these areas. Due to the sensitivity of Elkhorn coral to water quality impairment, we suggest careful consideration of runoff from the trail and recommend the elimination of the storm drains under the trail. Use of Low Impact Development alternatives identified in our March 4, 2004 letter should be implemented. GL-10: Steps Beach We support enmienda #2 that proposes to move the trail to avoid impacts to the mangrove and to provide additional parking. Moving the trail inland and avoiding the mangrove should eliminate the need for a bridge in this location. The redesign of this area should comtemplate beach access and restoration of the mangroves. Sufficient parking for existing users should also be considered well inland of the Reserve. GL-11 Steps to Calle Surf: For this section we recommend that the trail be rerouted along the old train right of way and behind Chris Clayton s structures thereby eliminating the need for shoreline armoring. This area is a known sea turtle nesting area and adjacent to the Reserva Marine Tres Palmas, home to some of the healthiest Elkhorn Coral communities in the Caribbean. Eliminating shoreline armoring will reduce impacts to those species listed as threatened and endangered by the Federal Endangered Species Act. GL-13: Finca Caro / Sunset Village We recommend that this section be moved inland to comply with the recommendations in the April 1, 2004 USFWS letter that recommends restoration to coastal zone and requires an 8 meter buffer zone as a requirement for your Section 7 consultation. That letter states. A buffer zone of approximately 8 meters between the designated maritime zone and the proposed trail will be created. General Comments: We are very supportive of the current redesign elements that reduce the scale of the project in certain areas and integrate the trail with other existing municipal projects. We 3

4 encourage other sections of the plan to also be scaled down to reduce costs and minimize environmental impacts. We recommend that fencing and guardrails be minimized to allow for vertical beach access (beach access from the land to the beach). We recommend that the trail be constructed using materials to minimize impervious surfaces and runoff to the ocean. Specific recommendations can be found in our March 4, This letter can be found at: Furthermore, we have illustrated many of these suggestions and other comments on a Google map that can be found on the Internet at: Finally, we greatly appreciate the opportunity to share our comments and suggestions with you and we remain available and willing to participate in an ongoing process to improve the design and ultimate outcome for the proposed Rincón Bike & Pedestrian Trail. Sincerely, Leon Richter Puerto Rico Field Coordinator Surfrider Foundation Phone: lrichter@surfrider.org Chad E. Nelsen Environmental Director Surfrider Foundation Phone: cnelsen@surfrider.org cc: Gabriel A. Rodríguez, DTOP Antonio J. Barceló Hernández Esq., DTOP Roberto Fonseca, FHWA 4

5 Carlos López Bonilla, Alcalde de Municipalidad de Rincón Julio C. Rodriguez ACT Oficina de Estudios Ambientales Dennisse Luciano Collazo ACT Construcción Región Oeste Felix Rodriguez Soto FHWA Eugenio Fernandez EFE Arquitectos José L. Torres FHWA Jorge A. Ramos Vélez ACT Región Oeste Daisy Ramos Pitre - DTOP Oficina Ing. y Agrimensura Edwin Rivera Malavé - DTOP Oficina Ing. y Agrimensura Ruperto Chaparro, PR Sea Grant Dr. Manuel Valdez Pizzini, CIEL, UPR-Mayaguez 5