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Stormwater Comment Letter
August 5, 2001
Colonel James G. May, District Engineer
Atten: Paul Kruger paul.e.kruger@saj02.usace.army.mil
Atten: John Hall john.r.hall@saj02.usace.army.mil
Department of the Army
Jacksonville District Corps of Engineers
Miami Regulatory Division
11420 N. Kendall Dr., Suite 104
Miami, FL 33176
Re: Miami-Dade County: Stormwater to Wetlands
Permit Application No. 200101892 (IP-PK)
Recommended Denial
Dear Colonel James G. May:
I am writing in response to Permit Application No. 200101892 (IP-PK) submitted by Miami-Dade County based on your Public Notice dated July 6, 2001, proposing to use waters/wetlands of the United States for the detention and treatment of stormwater.
There is no indication in the Public Notice that an Alternatives Analysis has been conducted. There is no indication in the Public Notice that a Section 7 consultation has been conducted. There is no information on a Public Interest evaluation or determination. There is no discussion about indirect and cumulative impacts of the proposed action. The bottom line is that this application is grossly incomplete and should not have been posted as a public notice. This is a chronic problem with your agency.
Actions by the applicant and your agency - including but not limited to 1) promoting and permitting the dredging and filling and other means of altering the hydroperiods of natural wetlands in that area during development; 2) the excavation of pits; and 3) promoting the withdrawal of ground water from the very aquifer that sustains the natural wetlands (e.g., Everglades) - have resulted in the invasion and spread of alien species throughout that area. The proposed action of using natural wetlands for stormwater treatment add further insult to injury.
If the County's goal is to "develop alternative strategies for surface water discharge to the Bay", as stated in the public notice, then a series of public hearings should be held. Many environmentally-sensitive alternatives exists, but the County (and your agency) continue to ignore them.
Attached as rtf files, and pasted below, are copies of letters of comment that I submitted to your agency previously on the proposed Glassman and rock mining permit applications. These letters provide more details regarding my concerns about the proposed project. Thank you for the opportunity to provide comments. For your convenience, I also am forwarding a printed copy of my electronic letter, via US mail.
Attachments
Sincerely,
Sydney T. Bacchus, Ph. D.
Hydroecologist
cc: Steven Bell, Director steven195545@cs.com
Floridians for Environmental Accountability and Reform
Lesley Blackner, Esquire, Staff Counsel
Floridians for Environmental Accountability and Reform
Blackner, Stone & Associates LBlackner@aol.com
Dr. Robert J. Brock, Supervisory Marine Biologist
Marine Resources Program, Everglades/Dry Tortugas National Parks
National Park Service robert_brock@nps.gov
Michael Davis, Coordinator
Everglades Restoration Project
Office of Everglades Restoration Michael_L_Davis@ios.doi.gov
Honorable Peter Deutsch
Atten: Fritz Hirst, Legislative Director fritz.hirst@mail.house.gov
Honorable Bob Graham
Atten: Kasey Gillette, Policy Analyst kasey_gillette@graham.senate.gov
Atten: Pat Grise', Constituent Advocate pat_grise@graham.senate.gov
Juanita Greene, President
Friends of the Everglades greene6@earthlink.net
Roger B. Griffis, Coral Reef Task Force
Scott B. Gudes, Director
Ken Haddad, Ph. D., Director
Florida Fish and Wildlife Conservation Commission
Division of Marine Fisheries ken.haddad@fwc.state.fl.us
Sam Hamilton, Regional Director
U. S. Fish and Wildlife Service sam_hamilton@fws.gov
John Hall
Department of the Army john.r.hall@saj02.usace.army.mil
Dave Hankla, Field Supervisor
U. S. Fish and Wildlife Service dave_hankla@fws.gov
Honorable Patrick Kennedy
Atten: Matt Braunstein Matt.Braunstein@mail.house.gov
Atten: Joshua Richman Richman@patrickkennedy2002.gov
Barbara Lange
Sierra Club barbaralange@earthlink.net
A. Stanley Meiburg, Acting Regional Administrator
U. S. Environmental Protection Agency banister.beverly@epa.gov
Honorable Bill Nelson
Atten: M. Bridget Walsh, Leg. Assist. Bridget_Walsh@billnelson.senate.gov
Gale Norton, Secretary
U. S. Department of the Interior gale_norton@doi.gov
Craig Pittman, Staff Reporter
St. Petersburg Times craig@sptimes.com
Suzi Ruhl, Esquire, Director
Legal Environmental Assistance Foundationsruhl@leaf-envirolaw.org
Andrew Schock, Director
National Wildlife Federation, SE schock@nwf.org
Rebecca Sharitz, Ph. D.
Committee on Restoration of the Greater Everglades Ecosystem
Savannah River Ecology Laboratory sharitz@srel.edu
Honorable Clay Shaw
Atten: Bob Castro bob.castro@mail.house.gov
Atten: Mike Sewell mike.sewell@mail.house.gov
Jay Slack, Field Supervisor
U. S. Fish and Wildlife Service jay_slack@fws.gov
Richard Sommerville, Accountability Liaison
Floridians for Environmental Accountability and Reform
Honorable Robert Wexler
Atten: Jonathan Katz jonathan.katz@mail.house.gov
Christine Todd Whitman, Secretary
U. S. Environmental Protection Agency whitman.christine@epa.gov
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