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The Coast Guard (USCG) Proposed Rule: Public Hearings on Liquefied Gas Carriers Transiting
Through San Juan Harbor, San Juan, PR
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Your comment:

Comment:
Re: USCG-2019-0460 US Coast Guard announces two public meetings to
receive comments regarding the safe navigation and mooring of LNG carriers
through the San Juan Harbor, San Juan PR.

CORALations is an award-winning coral conservation organization, founded and

based in Puerto Rico.

Summary
We are writing to request that additional hearings be announced and deadline
extended for public comment, consistent with the advanced notice and
publication requirements of the Administrative Procedures Act for reasons
described below. We ask Coast Guard to circulate official notice to the media,
with focussed attention to effectively inform affected stakeholders. We ask that all
related documents be posted online for public access and analysis as soon as
possible.

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7/26/2019 Regulations.gov - Your Receipt

For the Record:

The notice makes reference to “The operation of LNG gas carriers and add the
new facility within the San Juan Harbor, San Juan, PR.” It is not clear to us what
“add the new facility” means.

This notice was posted only 8 days prior to announced public hearings, and to
our knowledge, only in the Federal Registry. While it may be possible for the
Coast Guard to argue expedition on homeland security and navigational safety
issues, this would not apply to addition a new LNG facility.

We argue that meaningful public participation cannot be obtained anywhere with

only 8 days prior notice. Nowhere would that be more true than Puerto Rico
today. The island is at an historic crossroad as FBI continues arrests of local
government officials, and the governor was unseated by relentless, yet non-
violent street demonstrations. Local agencies involved in these critical
determinations are currently in organizational chaos. A significant extension is
only reasonable.

We recognize minimal due diligence on the part of the Coast Guard to meet
social justice obligations of public transparency and meaningful participation
would include dissemination of this notice to the media, with focussed outreach to
all impacted interests. This would include, but not be limited to: local communities
and industries found on the harbor, environmental organizations, interests that
protect local historic and cultural patrimony of the old city, local tourism, the cruise
ship industry, Isla Grande Airport, and commercial cargo shipping interests from
the States as well as the Lesser Antilles.

This very online form style prototype edition of the daily Federal Register on
Federal Register.gov,1 displays prominently:
“This document has a comment period that ends in 70 days. (10/04/2019)” The
description verbiage however, indicates deadline is on or before August 4th,
2019. This can confuse the general public, and could result in meaningful
comments not being recognized for the record.

If the amendments add a new facility then likely a determination of consistency

under the Federal Coastal Zone Management Act may be required.

A new facility or mooring or transit would require Section 7 compliance to the

Endangered Species Act, as the waters of the bay are listed critical habitat for the
acroporid corals, that at least pre-Maria were found near the harbor’s entrance.

This Harbor is surrounded by historic structures listed and/or eligible for listing in
the National Registration of Historic Places. It is possible that official notice must
be given to the National (NHPO) and local State Historic Preservation Offices
(SHPO).

Information concerning the proposed safety zone changes, and the other
https://www.regulations.gov/comment?D=USCG-2019-0460-0001&p=1 2/4
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documents referenced in the Federal Register 34323 Vol. 84, No. 138 were not
posted, making it impossible for the public to provide meaningful analysis and
comment. We therefor ask that this also be rectified by posting for review any and
all relevant documents in the federal record as well as those documents
referenced specifically in notice:

1) The proposed safety zone adjustment these hearings are being called for
regarding “the operation of LNG gas carriers and add the new facility within the
San Juan Harbor, San Juan, PR.”

2) The Letter of Intent and Waterway Suitability Assessment from New Fortress
Energy to construct and operate the required infrastructure for offloading and
transferring liquefied natural gas at the Army Terminal Turning Basin in San Juan,
Puerto Rico received on Dec. 12, 2017 by the U.S. Coast Guard.

3) The official response and recommendations from the Coast Guard to the Dec
12th letter from NFE.

4) The Coast Guard Sector San Juan determination of suitability for the proposed
operation in the Port of San Juan, September 26, 2018.

References
1. [https://www.federalregister.gov/documents/2019/07/18/2019-15267/public-
hearings-on-liquefied-gas-carriers-transiting-through-san-juan-harbor-san-juan-
pr]

Sincerely,

Mary Ann Lucking

Director
CORALations
PO BOX 750
Culebra, PR . 00775
787-556-6234

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2.Federal Register -- Public Hearings on ... Through San Juan Harbor, San
Juan, PR.pdf: success

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Regulations.gov: Regulations.gov:

First Name: Mailing ZIP/Postal

Mary Ann Address: Code:
PO Box 750 00775
Last Name:
Lucking City: Email Address:

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Culebra coralations@gmai
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United States Phone Number:
787-556-6234
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