ENVIRONMENTAL PROTECTION AGENCY
IN THE MATTER OF:
Culebra Resort Associates
P.O. Box 192336
San Juan, Puerto Rico 00917-2336
Villa Mi Terruiio Development
NPDES Permit Number PRU202016
Proceeding pursuant to Section 309(g)
of the Clean Water Act 33 U.S.c. §1319(g)
Docket No. CWA-02-2008-3356
Proceeding to Assess a Class I
ANSWER TO COMPLAINT AND REQUEST FOR HEARING
Regional Hearing Clerk
U.S. EPA Region 2
290 Broadway, 17th Floor
New York, New York 10007-1866
COMES NOW Respondent Culebra Resort Associates II S. en C. por A., S. E.
(hereinafter CRA) through its undersigned representative and respectfully alleges, states and
requests as follows:
On October 9, 2008, CRA received by mail an Administrative Complaint,
Findings of Violation, Notice of Proposed Assessment of a Civil Penalty, and Notice of
Opportunity to Request a Hearing (hereinafter Complaint), that had an attached certificate to the
effect that it was served by mail on October 6, 2008.
Within 30 days after receipt of the Complaint, and pursuant to 40 C.F.R. §22.15,
CRA hereby files an Answer to the Complaint contesting the jurisdictional findings and the
material facts upon which it is based, and contending that the proposed penalty is not applicable.
Respondent, CRA, without submitting to the jurisdictional authority regarding
subject matter of the Regional Administrator of Region 2, EPA and/or the Director of the
CRA admits paragraph number 11 of section II of the Complaint and clarifies that
it is a limited partnership organized under the Code of Commerce of Puerto Rico and a Special
Partnership under the Income Tax Act of Puerto Rico organized under the name of Culebra
Resort Associates II S. en C. por A., S. E. ("CRA").
CRA denies, as drafted, paragraph number 12 of section II of the Complaint.
eRA avers and clarifies that in 2002 and 2003 it purchased two parcels of rural agricultural
grazing land approximately 57 and 36 "cuerda