A Rinconvenient Truth
First Look at Rincón Blue Water’s Hotel and Casino
Updated: May 14, 2019
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In March, when Rincón Blue Water (RBW) spokeswoman Michelle Ramos Jiménez first met with the community to discuss the proposed beachfront hotel development in Ensenada, she insisted that her team could not share most of the project’s details since state authorities were still reviewing its viability.
Shortly after that meeting, A Rinconvenient Truth formally requested access to the project’s public records at the Permit Management Office (OGPE) to uncover the developer’s original plan to invest an estimated $150 million in almost three acres of prime real estate in Rincón, according to a letter the director of the Planning and Development Office of the Puerto Rico Tourism Company, Carlos Romo Aledo, addressed to OGPE’s auxiliary secretary María Cintrón Flores in January 2019.
The documents revealed that RBW’s chief executive Lonnie Fuller requested, via various local contractors, recommendations from the Puerto Rico Environmental Quality Board (JCA), Aqueducts and Sewer Authority (PRASA), Energy and Power Authority (PREPA), Roads and Transportation Authority (ACT), and the Telecommunications Regulatory Board (JRTPR) in late 2018, all summarized in environmental recommendation 2018-244912-REA-002828 that OGPE issued in January 2019.
Rincón Blue Water would be bigger than two American football fields.
According to a detailed description included in RBW’s application, the developer confirmed its plan to build a 206-room hotel and casino on 2.82 acres of beachfront property in Barrio Ensenada, less than a quarter mile away from both El Balneario Beach and the Tres Palmas Marine Reserve.
The hotel’s main entrance lies south of State Road 413, on kilometer 0.9, and opens into a two-way drive that leads to 49 surface parking spaces and the first of four main structures to the east, as shown in the site’s master plan drafted by the architectural firm Álvarez-Díaz & Villalón.
Shaped as an “L”, the main building is expected to house the hotel’s reception, administrative offices, a 7,000 square feet casino, a 4,600 sq. ft. restaurant, several conference rooms, and a pool area on its first level. The developer also plans to build a 12,000 sq. ft. ballroom, a 4,800 sq. ft. spa, and 24 rooms on the second level; a 1,500 sq. ft. gym and 26 more rooms are on the third; while levels 4 thru 6 are expected to house 27 hotel rooms each, for a total of 131 rooms in this building, alone.
Other files in the docket tallied an additional 171 parking spaces, most of which should be located on the ground level of the L-shaped structure, according to what the firm’s architect Natasha Yordán explained back in March.
Moving south, the developer plans to erect three more structures, with three stories each, to house the remaining 75 hotel rooms, two more pools, and a beach club with direct access to La Marina Beach.
But in order to connect the main building with the rest of the complex, the developer must first build an elevated pedestrian bridge across a 20-feet-wide stretch of land owned by the Puerto ACT. This narrow land strip, which previously housed the old train tracks, almost bisects RBW’s property and runs parallel to the hotel’s service entrance at Black Eagle Road.
Part of the hotel would lie feet away from wetlands, but the DRNA has raised no red flags yet.
In a December 2018 letter addressed to OGPE, the executive director of the Department of Natural and Environmental Resources (DRNA), Tania Vázquez Rivera, who also heads up the EQB, did not object to the developer’s environmental assessment of its own project.
According to this document, he site lies far enough (656 feet) from the only protected site in the area, the Tres Palmas Marine Reserve. Otherwise, the closest hydrological resource, 20 feet away, is Quebrada Ensenada, which the Environmental Protection Agency (EPA) does not list as “impaired waters.”
Puerto Rico Planning Board’s (JPPR) assessment of the area’s hydrological resources, available via its Geographic Information System, suggests that part of the hotel complex sits on top of a wetland, which the developer recognized in its own assessment.
“In the southeast edge is where the property sits on a freshwater wetland area and forest vegetation,” reads the developer’s Determination that the Proposed Action Does Not Entail a Significant Environmental Impact and Analysis, but Vázquez Rivera did not raise any concerns about this topic on her own letter.
The developer argued that the biggest environmental impact the new hotel poses is the estimated 4-12 tons of fugitive dust that could be released into the atmosphere on a yearly basis, and the additional 28-36 tons that could end up in the nearby bodies of water, like Quebrada Ensenanda and La Marina, due to water runoff, according to the EPA’s Compilation of Air Emissions Factors.
For that reason, Vázquez Rivera mentioned that prior to starting construction activities, the developer must consult with the EPA to determine the impact that runoff oil, fuel, and other chemicals produced during construction could have if they reach La Marina Beach only 525 feet south.
The executive director also explained that RBW must request and obtain the Consolidated General Permit, in accordance with the Joint Regulation for the Evaluation and Issuance of Permits Related to the Development and Use of Land of the JPPR, before breaking ground on the site.
Blue Land Crabs and Hawksbill Sea Turtles may be impacted during the hotel's construction.
In November 2018, Jorge Coll Rivera, a former director of Las Cabezas de San Juan Natural Reserve hired by RBW to study the site’s biodiversity, submitted a report in which he concluded that, out of the 41 plant and 26 animal species he identified on RBW’s land, only the Blue Land Crab (Cardisoma guanhumi), which bores its nests into the wetland’s soft soil in Quebrada Ensenada, is a low risk critical element according to DRNA guidelines.
“During field work, some cavities where this species lives were observed in the areas surrounding Quebrada Ensenada. The DRNA has designated the blue land crab as a critical element due to the destruction of its habitat and overharvesting,” Coll Rivera argued in his report.
Although the United States Fish and Wildlife Service (USFWS) lists at least three endangered species of sea turtles which have been known to bore their nests in Rincón’s beaches, the environmental consultant found no signs of them in or around the hotel development, when he conducted his field study in October 2018.
According to Sheila Bonet Muñiz, who monitors turtle populations all the way from the north coast (Camuy) to the southwest (Cabo Rojo) of the island for the DRNA and NOAA with her team at Vida Marina-Proyecto Tortugas Marinas Área Oeste, no turtle species has made La Marina Beach its nesting grounds, at least, for the last six years. Nevertheless, the endangered Hawksbill Sea Turtles (Eretmochelys imbricata), known locally as the Carey, are commonly found in the coral reefs near the old pier next to the proposed hotel.
OGPE’s Environmental Permit Division did not address land crabs, but it did recommend the developer use low intensity peripheral lighting so as to not disturb sea turtles, when it approved the project’s environmental recommendation in January 2019.
RBW must study Vista Azul Sanitary Pumping Station’s capacity.
Sections 2.0.3.06 and 4.02.04 of PRASA’s Rulebook of Design Standards dictate that hotels on the island must estimate their water consumption and sewage discharge at a rate of 700 and 525 gallons per room per day, respectively.
In accordance with these guidelines, Rincón Blue Water would require 144,200 daily gallons of potable water, which PRASA’s technical manager of Public and Private Projects, Iris Jusino Nazario, wrote could be possible if the developer connects to the main water line at the intersection of PR-115 with PR-413, in a letter addressed to OGPE’s executive director Ian Carlo Sema back in December 2018.
When compared to the neighbors of Barrio Puntas, northwest of Ensenada, whose daily per capita water consumption was estimated at 42.3 gallons by the Román Más Foundation and PRASA last year, RBW’s estimated demand equals that of approximately 1,140 people.
The hotel and casino would also produce about 108,150 gallons of sewage every day, which could be serviced by the Vista Azul Sanitary Pumping Station, according to Jusino Nazario, who also stated that the developer must study the station’s capacity and submit a set of improvements, if any are necessary, to manage the increased sewage flow, before starting construction.
In her letter, Jusino Nazario estimated that RBW must pay the public authority $1,000 per housing unit for the right to use the existing water distribution and sewage system. Although PRASA did not tally the total cost, if each of the hotel’s proposed 206 rooms counts as a housing unit, RBW would need to pay about $206,000 for these rights.
PREPA recommends RBW connect to its power substation in Barrio Ensenada.
In a November 2018 letter addressed to OGPE’s Infrastructure Division, PREPA’s interim superintendent of Distribution Engineering in Mayagüez, Alexander Del Río Mora, explained that the Rincón Blue Water Hotel, with an estimated demand of 2,000 kilowatt-amperes, could be serviced by the public authority’s 7301 substation at Barrio Ensenada.
For this to work, he added, the developer must draw a new 38-kilowatt feeder line from the hotel to the Ensenada substation about 0.2 miles east on PR-413. Additionally, Del Río Mora wrote that RBW must erect a 65-feet-tall reinforced concrete post in front of its property and mount a three-position switch on it to serve as the hotel’s connection to PREPA’s electric lines.
“Part of the work to be done by the owner of the project according to this report represents an improvement to the electrical system of the area, so it is exempted from the contribution for the proposed total load of 2,000 KVA,” the interim superintendent determined.
Traffic jams on PR-413 are the ACT's main concern with RBW.
When the director of the Transit Engineering Division of the Authority of Roads and Transportation (ACT) Lissette Lugo Colón submitted her recommendations for the Rincón Blue Water project in December 2018, she instructed the developer to conduct a transit study to determine PR-413’s present vehicular traffic density and how the hotel may increase it.
This study, Lugo Colón wrote, must include “. . . the improvements to be provided by this development in said road system to maintain an adequate level of service on it,” including traffic lights if necessary. Additionally, the developer must refrain from erecting any structure beyond the property’s limit.
The director also informed OGPE that the proposed hotel development could interfere with her team’s plan to build Paseo Lineal de Rincón, a linear bike path that would run along the old train tracks. Back then, ACT required RBW set up a meeting with the public authority’s design division to determine if the hotel’s plan to build a pedestrian bridge over the public land strip could impact ACT’s plan.
Her letter states that the developer must provide sufficient parking inside its premises, so guests and visitors do not need to park on either Black Eagle Road or PR-413. In that same manner, Lugo Colón wrote that, during the hotel construction’s, all vehicles entering the property must do so via Black Eagle Road and not PR-413. For this, the developer would first need to obtain the Municipality’s endorsement.
ACT cited Regulation Number 11-001, which enables it to levy charges on developers to mitigate their impact on state roads, when it determined that RBW must pay $206,000 when submitting its final plans for approval, before starting any roadside work – like a compulsory fence along the property’s boundary with PR-413.
Additionally, the Telecommunications Regulatory Board of Puerto Rico (JRTPR) requested the developer include details about the hotel’s underground telecommunication infrastructure in its final blueprint, before applying for the board’s final approval.
On May 5th, A Rinconvenient Truth requested comments from RBW spokesperson Michelle Ramos Jiménez on most of these topics, but she had not responded by the time this article was published.
With all the preliminary permits approved, Rincón Blue Water now has until November 2020 to address the state agencies’ recommendations and re-submit for final approval before the first permit it secured expires (PREPA). After that, if the developer gets the green light (the General Consolidated Permit), it can break ground on the new project.