I request that this document, in its entirety, be considered by the USACE and be made part of the Pasco County Park/Sunwest Harbortown Project, SAJ-2007-05788 (IP-MGH) permanent file.

Please deny permit request SAJ-2007-05788 (IP-MGH).

This permit application is highly flawed containing vagaries, inconsistencies and inaccuracies.

 After more than 4 years of requests for straight forward definition and clarification, this permit application remains laden with vagaries, inconsistencies and inaccuracies that  would allow the applicant a 50 year liberty to destroy nearly 30 acres of economically and environmentally valuable coastal resources without viable mitigation. 

●   There remain throughout this permit application uncountable discrepancies and vague definitions of the number of acres of both wetlands and seagrass beds to be impacted, and claimed mitigation acreage.

●   There is no detailed plan for restoration/mitigation of seagrass beds and wetlands that will be destroyed by dredging and future boat traffic.

●  Justification for the seven (7) proposed boat ramps is false. There is no demand for boat ramps for 250 boats per day in Pasco County except on occasional peak holiday weekends, approximately 20 days per year. Occasional peak demand is not adequate public benefit for a project with the potential to do this much damage.   

●  The request for permit neglected to address soil potentially contaminated with arsenic, and perhaps mercury, that may be disposed of in offshore United States waters.

●  There is no viable plan for protection of the local population of endangered manatee. The application for the Corps permit claims that provisions for protecting manatee populations will be made with speed zone signage when the Fish and Wildlife Conservation Commission [FWC] has denied the application for that signage.

●   The also required Florida Department of Environmental Protection (FDEP) permit is for one set of plans while the requested Corps permit  is for a significantly different set of plans. For  example, the channel dredge described in the FDEP permit is 85’ wide while the Corps request is for a channel 80’ wide.

Some of these discrepancies are serious, some seem just careless.  However, they beg the question, are the petitioners for this highly flawed permit application intentionally deceptive or just inept?  Neither is a good option. 

The public has been grossly misled !

 The public has been grossly misled regarding the scope of this project.  Projected seagrass and wetlands impact projections were dramatically increased after the required Public Comment Periods of both January 17, 2008 and April 12, 2011, including a six[6] fold increase, from 3.6 to 21.6 acres of seagrass to be impacted. The public has had no opportunity to comment on the actual scope of the project.

The NOAA National Marine Fisheries Service states this permit “should not be issued”.

The NOAA National Marine Fisheries Service have repeatedly reviewed this permit application.  Upon every review NMFS has written strong advisement that this permit “should not be issued” .

The project itself has not been adequately described.  Primary, secondary and cumulative impacts have not been adequately addressed. It has not been openly presented to the public and is not supported by NOAA NMFS. 

Please deny permit request SAJ-2007-05788. 

Sincerely,