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P. O. Box 750 Isla de Culebra, PR 00775 (0) 787-556-6234 email: info@coralations.org Luis Abreu

P. O. Box 750

Isla de Culebra, PR 00775

(0) 787-556-6234

Luis Abreu Noble Director Ejecutivo, y, La Junta de Directores de ATM PO Box 41118 San Juan, PR. 00940

July 31, 2018

Re: Proposed changes to tariffs for Culebra and Vieques public ferry system.

Introduction: My name is Mary Ann Lucking and I am the Director of CORALations an incorporated NGO based on the island for many years and that is affected by the performance of the ATM.

QUESTION 1 - Is there a formal record of these proceedings being made during this important public hearing. A formal recording? ANSWER - No, we are taking notes.

The maritime service provided to Vieques and Culebra is intended to function with benefit of federal subsidies as do other highway systems throughout the US and other nations, to provide safe, reliable, affordable and accountable transportation services to the public. This transportation provides access to services critical to the people of the low-income, traditionally underserved municipal islands of Culebra and Vieques, including access to education, health care, veterinarians, communication and computer repair and many goods and services available only to municipal island residents on the main island of Puerto Rico. The ATM is also supposed to provide safe and affordable transportation of fuels to the islands. The economy of Culebra also depends on the ability of the ATM to provide reliable, respectful and efficient services for visitors, critical to the island’s tourism economy.

The study supporting the increase in tariffs was produced in association with

Government plans to semi-privatize the service.

and Convenience Study for the Puerto Rico Maritime Transportation Services

This study, entitled: Desirability

Project, April 2018 will here to forward be referred to as “The study.” was posted only in English,


ANSWER: Sr. Abreau Noble confirmed he only saw the one study and it was posted only in english.

Because the study supporting this tariff increase is a study associated with the privatization of services, one cannot separate the proposed tariff increases from the proposed privatization and plans to relocate the ferry terminals to Ceiba, to the obvious detriment of both local municipal island residents, and what’s left of the fragile economic stability of businesses that serve the small islands in Fajardo.

It seems clear the privatization will only benefit well connected big interests associated with the development of Ceiba, and this fast track fare raise appears to the public as an obvious attempt to sweeten the deal to privatize a government service that like so many nationally subsidized, critical transportation systems around the globe, operates at a loss. To be clear, the proposed semi-privatization would not involve competition by multiple private entities, but instead forge a public-private partnership with one commercial business that in order to collaborate on providing this costly, critical public service, are being offered a 20 year contract meaning until 2038, and full dominion over the development of all ancillary concessions at all ports including the repair facilities in Isla Grande and Ceiba. Unfortunately it is the objective of business to turn a profit, and it is the objective of government to provide critical social services to the public. No increase in fares should be considered without presentation of a viable plan to improve services.

The study pretends to serve as a plan to address current problems and propose solutions, but provides no cost-benefit analysis based on relevant data. It fails to identify all problems, the largest being corruption of the system where multimillion

dollars in federal subsidies are involved.

un-needed trips, without specifying which trips are currently not needed.

It proposes reducing costs by eliminated


ANSWER: Sr. Abreau Noble - said he could not answer that because he was there to collect public input only on proposed tariffs.

What is clear is that this privatization will result in significant local job loss, of those Viequenses and Culebrenses who work for the ferry system.

Proposed Passenger Ferry Changes:

Proposed is an increase in passenger transport costs of over 500%.

the ATM for not proposing increases in cost of transport to local islanders, the ATM provides no viable data that reflects impacts of the proposed increase to the local tourism economy of Culebra, specifically where summer tourism benefits mainly from an internal (Puerto Rico) tourism demographic that offers cultural similarities of specific benefit to the small, local businesses. Unfortunately, and by its own admission, the study supporting this increase from the perspective of costs to visitors, is compromised by a very limited data set collected from a survey conducted “between August 3rd, and August 10, of 2015.

While we thank

The study fails to quantify specifically how many days of data were collected between the limited range of days they reference. August falls just outside of Culebra’s tourism peak and the 2015 information is now outdated and does not reflect our post Irma and Maria tourism realities, nor the 2017 revelations of ATM fraud and corruption, a critical problem to be addressed in order for future financial sustainability of the service to be realized.

An informal survey with a small sample of July tourists revealed that summer visitors would tolerate some increase in passenger ferry costs, if they were assured more reliable service. Our visitor data for the Reserve on Culebra, collected from April 2017 to present indicates a profound impact to local tourism, specific to internal tourism demographic in the summer with an decrease of about 100 persons at Playa Tamarindo, during peak hourse after the hurricane.

Currently the ATM distinguishes locals from residents using licenses, and there was consensus expressed at a July 25, 2018 meeting of residents and business owner that this system is not working. Also it does not provide a mechanism for local students to identify themselves, if they don’t yet have a drivers’s license. The community also expressed concerns that it feels insulted by a plan that would charge returning family members a visitors rate, for family that have since moved or been forced off island by the 2017 storms. The consensus was that this issue alone, could in no way be rectified given ATMs current limited communication with the community and time limits imposed by the very ambitious Sept start date of these fare changes.

Should the ATM implement an increase in passenger ferry costs, it must consider the implementation of PR Law 193, 2004 which requires the agency collect $2.00 from every visitor arriving by ferry or plane and provide this to the the Authority for the Conservation and Development of Culebra, to help with resource management on the island.

Cargo Ferries

Regarding proposed cargo increases, the increase in tariffs presented by the Maritime Transport Authority cannot be accepted for the following reasons:

1. The proposed deadline of September 1, 2018, does not comply with the law that governs these proceedings of the ATM, specifically the "Uniform Law for the

Revision and Modification of Tariffs"Act No. 21 of May 31, 1985, as amended.

our best knowledge from a copy of this law provided by a Puerto Rico Senator, this law still allows for 60 days for public comments after the ATM publishes the report of the public hearings.*


2. The tariffs provided in the proposed changes announcing the public hearings,

reflect current cargo costs presented as a range.

ongoing violations of ATM of Puerto Rico Law 21, 1985. This confusion on the part of the ATM also makes the financial “benefits” of proposed tariff increases impossible for either ATM, or the community to evaluate. The current rates for certain cargo are presented as a range of costs in the official public notice document, and do not so much as specify if this implies one way, or round trip. We assumed one way. QUESTION 4: Was the data presented reflexive of fares that are one way or round trip? ANSWER: Sr. Abreau Noble indicated he

thought it was one way.

nothing posted, nor any official cost sheet to hand out.

demonstrates ongoing abuse of power by the agency that may imply serious civil rights violations as cost for specific services has apparently been arbitrarily applied for some time.

This in itself appears to reflect

When we ask for specific cargo rates the ATM has

We believe this

Specifically, this confusion is as follows:

A. Carros Pequeños y carros mediana: In addition to the civil rights concerns presented by the cost range indicated, the proposed fare increases for both are identical, which is a redundancy that appears to reflect an error on the part of the agency.

B. Vehiculo de carga / cargo truck and Pickup Trucks and Vans: In addition to the civil rights concerned presented by the cost range indicated, the ATM fails to recognize the redundancy associated with cargo trucks, pick up trucks and vans which all bear cargo license plates and are charged more than non-cargo vehicles during marbete renewal. It appears that this redundancy reflects an error on the part of the agency.

C. Current cost ranges are also presented for > 30 feet and for construction vehicles that are > and < 30 tons. The confusion actually


leaves proposed fares reduced for arbitrarily reduced for construction vehicles by as much as 159.00 per trip during the week, when stated purpose of increasing fares of other cargo clearly impacting locals and quality of life of all locals on the island was to increase ferries to better meat operational costs.

D. Proposed tariff changes are further confounded by changes in proposed rates for weekdays and weekends which would disproportionately impact the island’s weekend shoppers and also confounds any meaningful analysis on cost benefits gained by these proposed changes for the agency regarding return trip calculations.

E. The ATM proposes to effectively distinguish residents from visitors using

license as an ID, when this has failed to date.

how to distinguish local students who don’t yet have a license, and culebrenses returning to visit. The agency outlines no mechanism described for a viable means to do this that can possibly be implemented by September 1st.

There is no proposal for

The recent round trip costs obtained (hand written) from the Ayudante del Director Ejecutivo in Fajardo, were as follows:

Auto compact: $26.00 Auto mediana: $36.00

Pick up:


Pick up 250:


Pick up 350:


Camion de volteo:


Camion cajon desde:


Flat bed y gruas:


Agency Transparency and Fiscal Sustainability

Many feel the current system failures are more linked to corruption than inefficiency. In any event, it is difficult for the public to assess the potential

benefits of proposed fare increases in terms of financial benefits to improve existing services in a system that completely lacks public accountability. For services of this importance to the local communities, a method of public, fiscal transparency would allow the many members of the Vieques and Culebra community the opportunity to watch dog specifically the fiscal accountability concerns for their services. Such a transparent system would likely have prevented the 5 years of overtime fraud from occurring, which according to June 2017, El Nuevo Dia articles cost the public 3

million dollars.

no report issued by this agency in this regard and after a year after referral. The

Also, while the ATM fraud was referred to the DOJ, there has been

ATM has therefore forced the public into this position of being limited to commenting on impacts from proposed tariff increases without being presented with any idea of potential benefits.

Going forward, a viable study is needed that reflects the post hurricane picture and presents data from both the local community and visitors of the affordability, accountability and financial sustainability of the service for both the passenger and cargo fare changes proposed. While we understand the operational costs for government have increased over the years, the Culebrenses have not benefited from associated cost of living pay increases. To not take this into consideration could result in cargo costs being passed onto the community which would force people off island. To not allow the people a voice in the relocation of their ferry services on the main island may be unconstitutional. We would like to see a local community commission created that can provide a mechanism for consultation and input from ferry users, and with full access to the fiscal data, so the many with serious interests can provide fiscal oversight in a citizen watchdog capacity at no additional cost to government.

*We are not lawyers and making the best interpretation of laws referenced in this document. We reserve the right to submit written comments that could differ with statements made here by the deadline for public comments depending on information provided by the ports authority today.


Gmail - ponencia de CORALations

7/31/2018 Gmail - ponencia de CORALations CORALations Culebra <coralations@gmail.com>

CORALations Culebra <coralations@gmail.com>

ponencia de CORALations

1 message

CORALations Culebra <coralations@gmail.com> To: nelson­torres@msn.com

Tue, Jul 31, 2018 at 7:57 PM


Adjuntamos nuestra ponencia con las respuestas del Sr. Abreau Noble.


­­ Mary Ann Lucking Director CORALations P.O. Box 750 Culebra, PR 00775



email: maryann@coralations.org, coralations@gmail.com

Trabajando con comunidades del Caribe para proteger y restaurar sus arrecifes de coral.


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

communities to protect and restore their coral r eefs. 99.2.Ponencia Tariff ATM copy .pdf 221K

99.2.Ponencia Tariff ATM copy.pdf