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Ms. Elizabeth L. Ray Vice President Mission Support Services Air Traffic Organization U.S. Dept of Transportation Federal Aviation Administration Mission Support Services 800 Independence Ave. SW Washington, DC 20591 March 11, 2013 Dear Ms. Ray: CORALations is a non-profit coral conservation organization based on the island of Culebra, Puerto Rico. Through our normal course of doing business, we discovered a concern regarding No Hazard determinations to air traffic for a proposed wind farm near the airport on this small Caribbean island. Culebra is growing in tourism popularity. Visitors and locals access the island using ferry service from Fajardo or via small planes from San Juan, Ceiba and the Virgin Islands. There is no hospital on the island, and all medical emergencies depend on safe and smooth air evacuation to the big island via small planes, and during varying wind conditions. We first became aware of a problem when copies of No Hazard determinations were submitted by the Puerto Rico Administacin de Asuntos Energticos (AAE) (http://www.aaepr.net/detalle_rotator.asp?cnt_id=57), in an environmental impact study (EIS) for a proposed wind farm project, Proyecto Punta Flamenco Windfarm, DIA-2012-AAE-28. (LINK to No HAZ submitted in EIS)The wind turbines were sited along the ridge inside or directly adjacent to the flyzone of Culebra's small airport. This letter references the Feb 25th 2013 letter of response to our Freedom of Information Act request sent to your office on November 30th, 2012. With the FOIA response letter was a CD with the digital documents listed and attached to this communication. We understand a decision was made to redact some of the personal information in this disclosure, and we have no problem with that. The response, however, does not appear to be complete, and we still have the following concerns: The No Hazard determinations submitted in an AEE's, EIS were not based on the actual height of the proposed wind generators. The physical characteristics of the wind generators were not
presented in the EIS submitted to Puerto Rico's Environmental Quality Board. The public only learns at a short noticed public hearing moving through an expedited planning process, that the proposed wind generators are in fact 370 feet tall. The No Hazard determinations included in the EIS had already been terminated at the time of the public hearing, and replaced by others not available to the public online at the FAA website, forcing public to depend on a lengthy Freedom of Information Act process to evaluate a large wind generation project that would change the nature and character of the entire island, and that was proceeding via an expedited local Government planning process. The FOIA response failed to produce any of our communications to the FAA regarding these concerns and on record with your agency prior to the date of the FOIA request. The FOIA response makes no mention of determinations involving wind meters already installed on the ridge above the airport approach. The FOIA response failed to include documentation of public notice associated with any and all required determinations near Culebra's airport. This should be of serious concern to the FAA. One is forced to question such a complicated federal process that involves multiple branches of the Federal Government and public oversight, including the military, that could in any way conclude, and then also re-conclude new determinations, with no raised eye brows, given that the proposed site for these wind turbines lies inside or adjacent too Culebra's fly zone, and small air port. This intuitively seems reflexive of either a flawed or corrupted system, which warrants investigation by experts familiar with FAA rules, and local Government abuse of an expedited permitting process for renewable energies or otherwise, where the outcome could result in such obvious impacts to the safety of the local islanders, Culebra's medical emergencies and tourists that depend on air travel. We are re-writing again for all documentation including record of our email communications with your personnel and documentation and or negative certification of public notice regarding this FOIA. Any inconsistencies regarding documents included in files copied on the CD are noted and highlighted in the enclosure entitled: List of Files Submitted in FAA FOIA response to Lucking dated Feb 25, 2013 with online links to documents provided for the public's benefit. Sincerely,
List of Files Submitted in FAA FOIA response to Lucking dated Feb 25, 2013.
2012 WTE_1048_OE (Lucking) FOLDER
Analysis Report Folder
DOD_DHS_LRR_158820875.pdf DOD_MILOPS_158820889.pdf Military Conflicts_USA.pdf Military Conflicts_USAF.pdf Military Conflicts_USN.pdf MVA_MIA_158820869.pdf NASWATCH_AF_15_158820854.pdf NASWATCH_DOD_155820865.pdf NOAA_NEXRAD_158820886.pdf POS_158820855.pdf Traffic_PATTERN_158820861.pdf
Letters Folder
**NO CIR file? DNH_167063337.pdf NPH_161005630.pdf TER_169026390.pdf
Letters Folder
**NO CIR file. DNH_167063335.pdf NPH_161005912.pdf TER_169026394.pdf
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LETTERS Folder
CIR_163371250.pdf DNH_167062971.pdf NPH_161006176.pdf TER_169026395.pdf
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