3/3/25, 1:14 PM Gmail - Re: [EXTERNAL] Re: URGENT Aerial application of rodenticide and Culebra staging area

CORALations Culebra <[email protected]>

Re: [EXTERNAL] Re: URGENT Aerial application of rodenticide and Culebra staging
area
1 message

CORALations <[email protected]> Mon, Mar 3, 2025 at 12:29 PM

To: "Mena, Lourdes" <[email protected]>
Cc: Edilberto Romero <[email protected]>, "Hon. Edilberto Romero" <[email protected]>, "Padron,
Silmarie" <[email protected]>, Comentarios de Junta <[email protected]>, "Tillman Marquez, Idalmaris"
<[email protected]>, "Phillips, Jereme" <[email protected]>, Juan J Baba Peebles
<[email protected]>, Andy Strelcheck <[email protected]>, Carlos Diez <[email protected]>,
"[email protected]" <[email protected]>, "Nilda M. Jimenez Marrero" <[email protected]>, "Guerrero, Carmen"
<[email protected]>, Gustavo Olivieri Cintron <[email protected]>, "Lcda. Margaret Ramírez-Báez"
<[email protected]>, Nicolás Gómez <[email protected]>, "[email protected]"
<[email protected]>, Abimarie Otaño-Cruz <[email protected]>, Miyoko Sakashita
<[email protected]>, Digna feliciano <[email protected]>, Lourdes Feliciano
<[email protected]>, Mayra Felix <[email protected]>, Pedro Saade Llorens <[email protected]>,
Ruth Santiago <[email protected]>, Tomas Ayala <[email protected]>, Edwin Hernandez-Delgado
<[email protected]>, Jane Becker Whitaker <[email protected]>, Dulce del Rio-Pineda
<[email protected]>, Ricardo Lugo <[email protected]>, aelugo1234 <[email protected]>,
Ruperto Chaparro <[email protected]>, "[email protected]" <[email protected]>

Dear Ms. Mena, et. al.:

Thank you for your response on behalf of your division of the USFWS indicating:

"It is our understanding that this project is currently on hold and may be delayed.
This delay may benefit the action agency (USDA) in having time to re-evaluate staging
areas for the project and environmental review requirements."

The Culebra issue regarding concerns to public health and environment remains urgent as the
lot suspected of being involved as the helicopter staging site,
has a new container. We are concerned this container could be storing the powerful second generation anti-coagulent.
We are asking that agencies confirm if this is holding the rodenticide, and if so see to its removal ASAP.
The container is not elevated, and area homeowners have
not been notified of its presence or to keep pets indoors as there's potential for secondary poisoning.
Finally if this container on the suspected lot contains the rodenticide, we are very concerned about impacts
to critical habitat listed areas on land and in coastal waters during storm season as this container is setting on a
windy bluff.

Federally funded projects that pose a threat to human health or the environment,
and that cross geographical territorial boundaries spanning multiple critical habitat
designated waters and lands, and also that bear cumulative impacts as acknowledged in the EA
produced by DOA for this project, clearly require a complete EIS and we still await responses from the
municipality and APHIS - USDA.

At this time we are requesting APHIS commit to providing a complete EIS for this project, and,
if the container on the lot now suspected as being the staging site is in fact holding the rodenticide,
we ask for a commitment in writing (email is fine) that it will be removed as soon as possible.

Thank You,

On Mon, Mar 3, 2025 at 7:02 AM Mena, Lourdes <[email protected]> wrote:

Dear Ms. Lucking:

Thank you for your February 20, 2025, letter regarding your concerns with the use of Culebra as a staging
area for the Savana Island project in the US Virgin Islands. The purpose of this effort is to provide

https://mail.google.com/mail/u/0/?ik=bf7a11e4c1&view=pt&search=all&permthid=thread-a:r-1251111012645110852%7Cmsg-a:r-7175490816409602289&simpl=m… 1/6
3/3/25, 1:14 PM Gmail - Re: [EXTERNAL] Re: URGENT Aerial application of rodenticide and Culebra staging area
additional predator free habitat for the endangered Virgin Island boa (Chilabothrus granti). In the future we
are hoping to introduce the boa to this island and provide an additional population of the boa in a more
secure habitat. The beneficial effects of the elimination of rats from islands has been well documented and
in the long term this will not only benefit the boa, but will also benefit nesting sea birds, the vegetation
structure, herpetofauna, and other resources of the island.

Currently, the involvement of the USFWS Caribbean Ecological Services Field Office (CESFO) is limited
to technical assistance to the project. In the past CESFO provided funding to Island Conservation for the
planning, survey and initial trials on Savana Island. Fortunately, Island Conservation was able to obtain
Bipartisan Infrastructure Law (BIL) through the Insular Affairs Office of the Department of Interior Office
to fund the implementation of the proposed rat eradication plan. It is our understanding that this funding is
being channeled through USDA, which was the agency that posted the 2023 EA cited in your letter. The
Savana Island project is currently a cooperative effort between USDA, DOI and USVI government.

The original project presented all actions occurring in Savana Island and as a result USDA did not consult
with CESFO, since there are no listed species under our purview on the island an Endangered Species
consultation with our office was not conducted or required.

Changes to the project, considering Culebra Island as a staging area, is new information for this project and
may require USDA to reconsider their environmental assessment and consultation with the Service. It is
our understanding that this project is currently on hold and may be delayed. This delay may benefit the
action agency (USDA) in having time to re-evaluate staging areas for the project and environmental review
requirements.

We appreciate your concerns with this matter, I will be returning your call to discuss your concerns.

Sincerely,

Lourdes Mena
---------------------
Field Supervisor
U.S. Fish and Wildlife Service
Caribbean Ecological Services Field Office
Office Park I, Suite 303
State Road #2, Km 156.5
Mayagüez, PR 00680
Phone: 352-749-2462
Cell phone: 904-460-4970

Work hours 7:00 am - 3:30 pm (sliding hours 6:30 am - 4:30 pm)

There is something infinitely healing in the repeated refrains of nature - the assurance that dawn comes
after night, and spring after winter -- Rachel Carson

NOTE: This email correspondence and any attachments to and from this sender is subject to the Freedom of Information Act
(FOIA) and may be disclosed to third parties.

From: CORALations <[email protected]>

Sent: Wednesday, February 26, 2025 5:50 PM
To: Edilberto Romero <[email protected]>; Hon. Edilberto Romero
<[email protected]>; Padron, Silmarie <[email protected]>; Comentarios de Junta
<[email protected]>; Tillman Marquez, Idalmaris <[email protected]>; Mena,
Lourdes <[email protected]>; Phillips, Jereme <[email protected]>; Juan J Baba Peebles
<[email protected]>; Andy Strelcheck <[email protected]>; Carlos Diez
<[email protected]>; [email protected] <[email protected]>; Nilda M. Jimenez Marrero
<[email protected]>; Guerrero, Carmen <[email protected]>; Gustavo Olivieri Cintron
https://mail.google.com/mail/u/0/?ik=bf7a11e4c1&view=pt&search=all&permthid=thread-a:r-1251111012645110852%7Cmsg-a:r-7175490816409602289&simpl=m… 2/6
3/3/25, 1:14 PM Gmail - Re: [EXTERNAL] Re: URGENT Aerial application of rodenticide and Culebra staging area
<[email protected]>; Lcda. Margaret Ramírez-Báez <[email protected]>
Cc: Nicolás Gómez <[email protected]>; [email protected]
<[email protected]>; Abimarie Otaño-Cruz <[email protected]>; Miyoko Sakashita
<[email protected]>; Digna feliciano <[email protected]>; Lourdes Feliciano
<[email protected]>; Mayra Felix <[email protected]>; Pedro Saade Llorens
<[email protected]>; Ruth Santiago <[email protected]>; Tomas Ayala
<[email protected]>; Edwin Hernandez-Delgado <[email protected]>;
Jane Becker Whitaker <[email protected]>; Dulce del Rio-Pineda
<[email protected]>; Ricardo Lugo <[email protected]>; aelugo1234
<[email protected]>; Ruperto Chaparro <[email protected]>
Subject: [EXTERNAL] Re: URGENT Aerial application of rodenticide and Culebra staging area

This email has been received from outside of DOI - Use caution before clicking on links, opening
attachments, or responding.

Dear Jurisdictional Agencies:

This is to remind agencies that they bear the non-discretionary duty of oversight to inform the people of federally funded
and or permitted projects that pose a threat to human health and the environment. While we understand this USVI
project was issued a Finding of No Significant Impact FONSI by agencies partnered on the project in the USVI, there
was no notice found or mention of Culebra Puerto Rico in the EA. That this complex and dangerous project impacts two
territorial jurisdictions with multiple critical habitat listings and the likelihood of cumulative impacts, clearly required a
complete EIS.

There was no coastal zone compliance certifications found either at USVI or at the Commonwealth of Puerto Rico.

We do not believe there has been an endorsement from the Culebra Conservation and Development Authority
regarding the private lot for use as a helicopter staging area for the rodenticide or what all that entails. We have
questions about storage, loading of rodenticide, helicopter refueling location and the decontamination of equipment.

We are again asking for any and all information.

The project proposes to introduce the critically endangered VI Tree Boa to Savana Island USVI, irrespective of
lessons-learned on Cayo Ratones where all snakes introduced were lost at public expense, due to the vulnerability of
the little scrub cays to storms.

If blessed without accidents, this aerial application of the potent second generation anticoagulant rodenticide
brodifacoum is expected by project proponents to result in the indiscriminate secondary poisoning or "take" of predators
and scavengers, some of whom are protected, i.e. migratory sea birds. This is neither a targeted nor a humane
management alternative for the rats or other introduced species like the feral cats.

The take of protected species is not acceptable, especially given the poor likelihood based on past lessons-learned in
this region of a successful introduction of another species to this cay. The rodenticide is persistent and attaches to
soils and has been known to contaminate aquatic ecosystems and fish.

This requires a discussion of cay closure to fishing and quarantines during application. Savana is surrounded by corals,
listed corals, critical habitat designated waters and essential fish habitat.

We understand from concerned members of the community that this is likely taking place on Lot Number 473-080-037-
02-000. No permits were found online at any lots east of the beach. The 150m critical habitat designation for nesting hawksbill
sea turtles, physically falls within this lot's parameters.

https://mail.google.com/mail/u/0/?ik=bf7a11e4c1&view=pt&search=all&permthid=thread-a:r-1251111012645110852%7Cmsg-a:r-7175490816409602289&simpl=m… 3/6
3/3/25, 1:14 PM Gmail - Re: [EXTERNAL] Re: URGENT Aerial application of rodenticide and Culebra staging area

Thank you for your immediate response to our concerns.

--
Mary Ann Lucking
Director
https://mail.google.com/mail/u/0/?ik=bf7a11e4c1&view=pt&search=all&permthid=thread-a:r-1251111012645110852%7Cmsg-a:r-7175490816409602289&simpl=m… 4/6
3/3/25, 1:14 PM Gmail - Re: [EXTERNAL] Re: URGENT Aerial application of rodenticide and Culebra staging area
CORALations
P.O. Box 750
Culebra, PR 00775
www.coralations.org
(c) 787.390.3133 (o) 787.556.6234
email: [email protected], [email protected]

Trabajando con comunidades del Caribe para proteger y restaurar

sus arrecifes de coral.

<<><<<>>><>>

Working with Caribbean communities to protect and restore their coral reefs.

On Thu, Feb 20, 2025 at 10:40 PM CORALations <[email protected]> wrote:

Year date correction on document. Please replace.

On Thu, Feb 20, 2025 at 3:17 PM CORALations <[email protected]> wrote:

This is to bring to your attention an urgent issue. We only recently learned that
Culebra will be the staging area for storage, loading and aerial dispersal of rodenticide on Savana Island. We
assume also decontamination but not enough information is known. Start date Feb 26, 2025.

Thank you for your immediate attention to this issue and responding that you received our concern.
--
Mary Ann Lucking
Director
CORALations
P.O. Box 750
Culebra, PR 00775
www.coralations.org
(c) 787.390.3133 (o) 787.556.6234
email: [email protected], [email protected]

Trabajando con comunidades del Caribe para proteger y restaurar

sus arrecifes de coral.

<<><<<>>><>>

Working with Caribbean communities to protect and restore their coral reefs.

--
Mary Ann Lucking
Director
CORALations
P.O. Box 750
Culebra, PR 00775
www.coralations.org
(c) 787.390.3133 (o) 787.556.6234
email: [email protected], [email protected]

Trabajando con comunidades del Caribe para proteger y restaurar

sus arrecifes de coral.

<<><<<>>><>>

https://mail.google.com/mail/u/0/?ik=bf7a11e4c1&view=pt&search=all&permthid=thread-a:r-1251111012645110852%7Cmsg-a:r-7175490816409602289&simpl=m… 5/6
3/3/25, 1:14 PM Gmail - Re: [EXTERNAL] Re: URGENT Aerial application of rodenticide and Culebra staging area
Working with Caribbean communities to protect and restore their coral reefs.

--
Mary Ann Lucking
Director
CORALations
P.O. Box 750
Culebra, PR 00775
www.coralations.org
(c) 787.390.3133 (o) 787.556.6234
email: [email protected], [email protected]

Trabajando con comunidades del Caribe para proteger y restaurar

sus arrecifes de coral.

<<><<<>>><>>

Working with Caribbean communities to protect and restore their coral reefs.

https://mail.google.com/mail/u/0/?ik=bf7a11e4c1&view=pt&search=all&permthid=thread-a:r-1251111012645110852%7Cmsg-a:r-7175490816409602289&simpl=m… 6/6