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OCT- - M - a 789 -C'Iko end 5c� &� X/
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- Sheet2 Sheet3
L
nDated:
mment
Name
Pelican Bay
Resident
Other
Party
Resource
Concerns
nti-
Motorboat
Policy
Issues
(check one)
(check)
(check)
(check)
1
5/20/10
Bob Diffenderfer
X
X
X
2
5/19/10
Michael GrWer
X
X
X
L W6
3
5/17/10
Lewis Longman & Walker
X (represents)
X
X
4
5/147/2010
Philip & Rosamond Wyche
X
X
X
5
5/17/10
Henry & Jeir Price
X
X
ivy IF
6
5/17/10
David Rcellig
X
X
7
5117/10
Joe Adams
X
X
8
5/15/10
Patricia Mullen
X
X
9
5115110
Bill Van Arsdale
X
X
10
5/14110
sleeplezz @mac.com
X
11
5/14/10
Emilie Bromley
X
X
12
5/14/10
Marilyn Hochberger
X
X
X
13
5/14/10
Harriet Lickhalter
X
X
X
14
5114110
Robert Naegele
X
X
X
15
5114/10
Kathy Worley
X
X
16
5/14!10
MilesCroom /NMFS
X
X
17
5/14110
Claudia Osborn
X
X
X
18
5114110
Jay Rose
X
X
X
19
5/14/10
Gil Rashbaum
X
X
X
20
5/14/10
Estelle Fishbein
X
X
21
5/14/10
Judith Sokoll
X
X
22
5/14/10
Phil Germain
X
X
X
23
5/14/10
Patricia Owen
X
X
X
24
5114110
Terry McGuan
X
X
X
25
5/13/10
Gerald Bepko
X
X
X
26
5/13/10
Elaine Chase
X
X
X
X
27
5/13/10
Annice Gregerson
X
X
X
28
5/13/10
Art Ritas
X
X
29
5/13/10
Lilias Bruce
X
X
X
X
30
5/13/10
JeanneFndlater
X
X
31
5/13/10
Beth Sulzer - Azaroff
X
X
X
32
5113/10
Linda Roberts
X
X
X
33
5113110
Marc Russ
X
X
34
5/13/10
Ronnie Bellone
X
X
X
35
5/13/10
Rob & Darla Ebert
X
X
X
36
5113110
George Koliber
X
X
X
37
5/13/10
DorrineStolar
X
X
X
38
5/13/10
Stanley Stolar
X
X
X
39
5/13/10
Ted Raja
X
X
40
5113110
Anonyms
X
X
X
X
41
5/13/10
Gregg & Jean Johnson
X
X
X
42
5113110
Sr-a Strawbridge
X
X
43
5/13/10
Agnes Ison
X
X
44
5/13/10
Arthur Chase
X
X
45
5/13/10
Maida & John Domenie
X
X
X
46
5/12/10
Mary McLean Johnson (MAG)
X
X
47
5/12/10
Marcia Cravens
X
X
48
5/12/10
Lenid Azaroff
X
X
49
5/12/10
Judith Phillips
X
X
X
50
5/12/10
ChristopherFndlater
X
X
X
51
5/12/10
Chester Phillips
X
X
X
52
5 /12/10
Joan Klipping
X
X
X
53
5/12/10
Patrica Bush
X
X
54
5/11/10
j Kay Erickson
X
X
X
X
55
51111101
ComObley
X
X
X
56
5/111101
Linda Roth
X
X
57
51111101
Alice Potter
X
X
58
5/11/10
Ian McKeag
X
X
X
59
5/6/10
David Trecker
X
X
60
5/3110
Jo Dingler
X
X
61
63
NMFS agency contact
64
65
- Sheet2 Sheet3
L
P, S Z3 h(,"
4/10/12 COMMENTS OF CONCERN ON PROPOSED CLAM PASS DREDGING PERMITS by
Marcia.Cravens for Sierra Club Calusa Group and Save Clam Bay - Keep It Natural Petitioners:
(Please note that 20 pages of online petition comments are included with these comments)
Background: 1970's Environmental Conservation Non - Government Organizations (NGOs) and
general public advocacy to preserve and protect Clam Pass /Clam Bay natural resources resulted in
the Corps requirement for the Coral Ridge - Collier Properties owner developers of Pelican Bay to
agree to permit Special Conditions. The Department of Army (USACE) authorization to fill 78 acres of
coastal mangrove wetlands was predicated upon its Special Conditions and primarily required the
remaining 570+ acres of undeveloped coastal barrier natural resources within the Pelican Bay
Planned Unit Development / Development of Regional Impact boundaries to be set aside in a
manner that restricted it to be retained as a Conservation /Preservation area in perpetuity for the
benefit of the public. The Corps permit 79K -0282 issued on November 18,1981 required that the
permit with its Special Conditions be recorded in the County's Official Records of the conveyance of
the remaining 570+ undeveloped acres of Clam Pass /Clam Bay.
Concerns: Degradation of resources by construction /excavation is inconsistent with prior State and
Federal permit authorizations and inconsistent with the 1981 Corps permit Special Conditions
because of direct loss of benthic substrate from dredging and secondary erosional impacts from
combined enlargement of construction and excavation projects in the Clam Pass -Clam Bay
Conservation and NRPA Preserve. Repetitive and expanded dredging events alter its natural
characteristics and affect its functions of aquatic nursery, wetlands habitat, and natural beach /dune
areas resulting in disturbances to wildlife uses and human passive recreation that constitutes
unacceptable taking of established wildlife and human uses. The 2009 application to dredge Clam
Pass and later modification to infill existing tidal channel doesn't conform to Corps and County
requirements to retain natural conditions of the waters, creek - lagoon shorelines, beach and dune.
Conformance to prior authorizations should limit any dredging re- authorization to the minimal amount
necessary to keep the Clam Bays and creeks open to the Gulf of Mexico and never done to remove
the maximal amount of sand possible from the Clam Pass system. All prior permits authorized
placement of sand on adjacent beaches as Incidental benefit but not as a main purpose of dredging.
Summary:
The Clam Pass dredging application causes environmental conservation concerns because:
It fails to report project area's special designations to protect coastal resource of wetlands / beach;
It fails to provide official records that protect the area from development of construction /excavation;
It misrepresents the modest authorized dredge template of the 1998 JC permit and improperly
discredits the original engineer of record, David Tackney as not having provided specific modeling;
It omits important Cultural /Archaeological Sites that were shown by map and commented on by the
Florida Department of State - Division of Historical Resources with specific conditions to avoid
disturbance to them - which is inconsistent with the 1998 FDEP JC permits;
It fails to ensure continued passive recreation that's compatible with habitat and wildlife uses;
It fails to identify its current offshore assessment of live hardbottom differs significantly from that
submitted for the 1998 JC permits - which indicates an apparent loss of approximately 200 to 250 ft
of productive hard bottom seaward (offshore) of Clam Pass and adjacent beaches;
It improperly asserts that a Statewide Programmatic Biologic Opinion appled to this project;
EA /EIS or comprehensive data in lieu of an EA /EIS for environmental use impacts are unmet;
Core logs analyses from 1990s are submitted for dredged tidal channel and aren't current;
Recent cores analysis are mostly from beaches and may not meet dredge channel core criteria.
Conclusion:
The applicant's and applicant's consultants failed to reference and provide comprehensive reports on
the project area's history and environmental characteristics which other researchers / consultants
have referenced . This is likely to be largely responsible for a serious lack of understanding for the
project area, deficiency of necessary information and practicable alternatives that minimize or avoid
negative impacts to the project area and connected areas. This situation appears to risk insufficient
reviews by Regulatory agencies. Concerns remain the proposed are inappropriate to the project site.
Recommendation: Address NGO and public concerns to achieve the best environmental resource
permit outcome. For Clam Pass dredging projects -it is clear to the NGOs and public that Less is Best.
U.S. Army Corps of Engineers
Fort Myers Regulatory Office
1520 Royal Palm Square Boulevard, Suite 310
Fort Myers, FL 33919
Fax: (239) 334 -0797
11/2/2011
i J-." 10
1
Attn: Linda Elligott,
Please accept this correspondence for the record of File No. SAJ- 1996 -02789 (LE) and
respond to its content by return email to the Sierra Club Calusa Group. We are an advocate
for preservation and protection of the Clam Pass undeveloped portion of the coastal barrier
island including the location of the requested permit activity. We request that the Corps
conduct a permit Workshop to provide NGOs an opportunity for meaningful participation with
the permit reviewers which is not accorded by the limitations of written public comments and is
needed to remedy the deficient permit application.
Background:
Sierra Club members, other NGOs and general public advocacy to the Corps for Clam Pass/
Clam Bay resources resulted in the Corps requirement for the Coral Ridge - Collier Property
owner developers of Pelican Bay to abide by Corps permit Special Conditions which
predicated Corps authorization to fill a maximum of 78 acres of mangrove wetlands in the far
NW area for the Pelican Bay development only upon the owner /developers agreement that
the remaining 570 acres of coastal barrier natural resources within Pelican Bay development
boundaries would be set aside in a manner that restricted it to Conservation /Preservation in
perpetuity. The Corps permit 79K -0282 issued on November 18, 1981 is as it required, a part
of official county records pertaining to its Special Conditions of protection from further
development of the remaining 570 acres Clam Pass /Clam Bay coastal barrier resource area.
Sierra Club Calusa Group advocates on behalf of current and future members to retain their
ability to enjoy passive activities that are compatible with and do not degrade the Clam Pass/
Clam Bay Conservation and Natural Resource Protection Area (NRPA) Preserve. The human
benefits include its aesthetic beauty; opportunities to observe wildlife; guided nature walks;
nature photography; undeveloped beach experiences; fishing in Clam Pass, the surf and
backwaters; paddling through quiet meandering creeks with mangrove tunnels; swimming,
wading, snorkeling, etc.
The proposed dredging project is one of several projects planned by the County in the Clam
Pass CBRS FL -64P unit. These projects individually would directly degrade natural resource
characteristics that support diverse wildlife and that our members enjoy and benefit from.
Secondary impacts from each project are expected to further degrade areas that our
members and the general public expect to remain a protected natural resource preserve.
Degradation of resources by construction /excavation is inconsistent with the prior JC permit
authorization and inconsistent with the 1981 Corps permit Special Conditions. Cumulative
impacts from combined construction and excavation projects in the Clam Pass FL -64P unit /
Conservation and NRPA Preserve would reduce its functions of aquatic nursery, wetlands
habitat, and beach /dune areas and constitute an unacceptable taking of established listed/
unlisted wildlife and human uses.
The 2009 application to dredge Clam Pass /Clam Bay doesn't conform to Corps and County
requirements to primarily retain natural conditions of the waters, creek /lagoon shorelines,
beach and dune areas with limited exceptions. Conformance to prior authorizations should
limit any dredging re- authorization to the minimal amount necessary to keep the Clam Bays
and creeks open to the Gulf of Mexico and never done to remove the maximal amount of
sand possible from the Clam Pass system and should exclude dredging the Clam Pass ebb
shoal for the purpose of taking sand to use for beach nourishment. Prior JC permits
authorized placement of sand on adjacent beach as an Incidental benefit but not as the
purpose of the permits.
Summary:
Sierra Calusa Group recognizes the current application to dredge Clam Pass /Clam Bay as
incomplete for the following reasons:
It failed to report the project area's special designations intended to protect nearshore and
offshore aquatic resources, wetlands, and beach;
It failed to provide County official records that protect the area from further development
(construction /excavation) in the Clam Bay NRPA Preserve aka Clam Pass CBRS unit;
It misrepresented the minimal authorized dredging template of the 1998 JC permit, improperly
discredited the engineers of record and misrepresented that Tackney had not provded a
model;
It omitted important Cultural /Archaeological Sites that were shown by map and commented
on by the Florida Department of State - Division of Historical Resources with specific conditions
to protect those sites by avoiding disturbances to them for the 1998 FDEP JC permits;
It failed to identify that its current offshore assessment of live hardbottom differs significantly
from that submitted for the 1998 JC permits which indicates an apparent loss of
approximately 150 to 200 ft seaward that may be direct /secondary impacts from dredging and
beach sand placement.
The applicant's failure to reference many comprehensive reports on the area's environmental
characteristics which other researchers / consultants have referenced is likely to be largely
responsible for a serious lack of understanding for the project area and deficiency of
necessary information to inform a sufficient permit review by the Corps and its consulting
agencies.
Sierra Calusa Group requests the Corps to conduct a workshop with the consulting federal
agency persons already involved in biological reviews and include our participation for
submittal and discussion of materials we may provide that are missing from the permit
application and therefore cause it to be inaccurate and incomplete. We request this as a
means for meaningful participation to remedy the currently deficient permit application that is
cause for insufficient Corps and Consulting Agencies review of it. Consider these concerns to
also be the basis of a Corps permit hearing by the Sierra Club Calusa Group.
Bobbie Lee Gruninger
Chairperson, Sierra Club Calusa Group
bleegruninger @comcast.net
13 6GC lirLo�
April 11, 2012 Pelican Bay Services Division Board Regular Sessiond7/1�� C G�
7b. Chairman's Report. Board and Corps Correspondence re: support for Clam Bay dredging workshop C r�
Page 2 of 2
111 -c-K
COLLIER COUNTS GOVERNIN EV`T
Pelican Ka" Seer, ices Di"i ion
�t'I_uuta t7.,l {a�.,: •�:l:ii .,r,?• \.i c f- • _.
March 1 S, 2012
Ms. Linda A. Elligott
U. S. Army Corps of Engineers
Jacksonville Regulatory Division
Fort Myers Section
1520 Royal Palm Square Blvd., Suite 310
Fort Myers, Florida 33919
RE. Permit Application No. SAJ- 1996 -02789 (1P /LAE) "Clam Pass"
Dear Ms, Elligott.
The Pelican Bay Services Division /Municipal Services Taxing and Benefit Unit
(PBSD /MSTBU) Board acknowledges, supports and endorses requests fora
collaborative U.S. Army Corps of Engineers Clam Pass - Clam Bay Dredging
Permit Workshop with their Federal Permit Consultant Agencies that allows
meaningful participation by the Sierra Club Calusa Group, Conservancy of
Southwest Florida, Mangrove Action Group, and Collier County Audubon
Society.
Regards,
Keith J. Da4as, Chairman
Pelican Bay Services Division Board
7b. Chairman's Report. Board and Corps Correspondence re: support for Clam Bay dredging workshop
Page 1 of 2
11J -cR'
ResnickLisa
From: Elligott, Linda A SAJ [ Linda .A.Elligott @usace.army.mil]
Sent: Thursday, March 15, 2012 10:49 AM
To: ResnickLisa
Subject: RE: On Behalf of Pelican Bay Services Division Board Chairman Dallas - response from
ACOE (UNCLASSIFIED)
Classification: UNCLASSIFIED
Caveats: NONE
Lisa.
Thank you for your request on behalf of Pelican Bay Services Division. The Corps does not-have a function that supports
a Permit Workshop such as you have requested.
I appreciate your understanding and thank you for your interest in this project; if you have any questions, please do not
hesitate to contact me. Thanks, Linda
- - - -- Original Message---- -
From: ResnickLisa [mailto:LResnick(,collier og v.netl
Sent: Thursday, March 15. 2012 8:48 AM
To: Elligott, Linda A SAJ
Cc: Jim Powers (limAdmgfI.com); Keith Dallas
Subject: On Behalf of Pelican Bay Services Division Board Chairman Dallas
Dear Ms. Elligott:
On behalf of Pelican Bay Services Division Board Chairman Keith J. Dallas, please see attached.
Reizards,
Lisa Resnick
Pelican Bay Services Division
801 Laurel Oak Drive, Suite 605
Naples, FL 34108
Tel. 239.597.1749
Fax 239.597.4502
Iresnick(j� collier og v net <mailto:lresnickgcollier og v net> http:/ /pelicanbayservicesdivision.net
<http://pelicanbgyservicesdivision.net/>
Under Florida Law, e -mail addresses are public records. If you do not want your e -mail address released in response to a
public records request, do not send electronic mail to this entity. Instead, contact this office by telephone or in writing.
Classification: UNCLASSIFIED
Caveats: NONE
Xe
June 18, 2011
Ms. Linda Elligott
Jacksonville District
Army Corps of Engineers
1520 Royal Palm Square Blvd. — Suite 310
Fort Myers, FL 33919
Re: Public Notice of May 13, 2011, SAJ- 1996- 02789(IP- LAE)(Clam Pass Dredging)
Dear Ms. Elligott:
In my judgment the requested permit may not be issued at this time as proposed. Evidence has not
been furnished for public comment to meet various compulsory compliance requirements of federal
permit rules both for substance of analysis and for public comment opportunities.
Having said that, there does appear to be a clear public interest to approve some course of action
consistent with the primary objective of the proposal, i.e., to conserve the environment in Clam Bay
and the surrounding mangrove forest. This public interest in conserving Clam Bay and the
associated mangrove forest has previously been examined and approved in the 1981 Corps permit
to build Pelican Bay and the 1998 permit to implement the Clam Bay Restoration and Management
Plan (CBRMP).
With an interim course of action in place to continue conservation efforts, the appropriate
information to evaluate the current permit request can be documented and an opportunity for public
comment provided that would meet all the federal criteria and procedures for a decision on the
pending request.
The primary constraint on the decision process at this time is that there is no consensus on the
appropriate cross - section and volume of dredging to achieve the objective of resource conservation.
In the absence of such a consensus, federal regulatory rules require an explicit examination of
reasonable alternatives to the proposed course of action, an opportunity for public comment on the
alternatives, and selection of the least environmentally damaging practicable alternative.
I trust this evaluation will show that allowing the 1998 federally authorized dredging template at
Clam Pass, 4 feet deep and 40 feet wide, would be in the public interest at this time as an interim
or, if needed, emergency measure and that evaluation of the expanded template as requested in the
pending application could be considered for action once substantive and procedural steps of the
federal regulatory process are met.
My comments are based essentially on three major areas of compliance requirements in Corps
regulatory decisions: The National Environmental Policy Act (NEPA), the Clean Water Act
(CWA), and Title 33, Code of Federal Regulations, parts 320, et. seq. (Corps permit regulations).
I am certain you know all of these requirements and I do not presume to tell you how to conduct
you review of this application. I include them here simply to frame my comments in the context of
the standard federal permit requirements and to assist others not familiar with the federal regulatory
process to whom I am sending copies of these comments.
11J -�
These three areas of the federal rules, among others, address requirements for evaluation of
alternatives and include provisions for public involvement in one form or another.
First, it is critical to the identification and evaluation of alternatives and to generate relevant public
comment to have a clear statement of need and purpose for the proposal. One of the great
difficulties in commenting on this application is the variation in descriptions of the project need and
purpose over time. This clarity is critical in commenting because of its relationship to development
of reasonable alternatives. The 1981 permit to develop Pelican Bay was based on a project purpose
of and well established need for conservation of the resources in Clam Bay and the surrounding
mangrove forest. The 1998 permit for the Clam Bay Restoration and Management Plan (CBRMP)
provided a specific mechanism to meet both the purpose and need for conservation expressed in the
1981 permit through the CBRMP.
It is not clear whether the current proposal is intended to be a continuation of the 1981 and 1998
purpose or some expanded purpose. The April 23, 2010, Corps public notice states the purpose as
maintenance dredging, beach re- nourishment, and ecological restoration. That purpose was
modified in the May 13, 2011, revised public notice to identify ecological restoration as the "basic"
purpose with added periodic maintenance and concurrent beach re- nourishment as "overall"
purposes.
Also making commenting difficult is the absence of any discussion of the need for the work to go
along with the expanded purposes. To clarify this concern, the "purpose" deals with what is to be
done, the "need" deals with why it should be done including the need for the physical extent of the
proposal. To add to the confusion over the purpose, i.e., the "what," there is no discussion of
"why" the purpose has been expanded to include beach re- nourishment and maintenance dredging.
Both purpose and need, what and why, are required elements of the decision and critical to any
analysis of alternatives to meet the various public interest decision criteria.
If the proposal is a continuation of the CBRMP authorized in the 1998 permit to restore degraded
mangroves, alternatives to achieve that objective would likely be quite different from alternatives
that would have to be considered to include beach re- nourishment and maintenance dredging as
additional project purposes. Since no alternatives for any of the expressed purposes have been
discussed, it is not possible to make the determinations required by NEPA, CWA, or Corps
regulations.
Another concern with developing relevant comments is the misstatement of the federal decision
criteria in the both the April 2010 and May 2011 public notices. In the last paragraph on page 4 of
each public notice the description of decision criteria is a severely limited version of the actual
scope of federal decision criteria. The correct version is described on the unnumbered page
following page 4, signed by D. W. Kinard. Unfortunately, that "correct' ' version is substantively
different from the shortened version on Page 4 such that the Corps cannot have confidence that the
public has had an appropriate opportunity to offer the full range of comments that address the
actual scope of the decision process rather than the abbreviated version stated on page 4.
As backdrop to my examination of the relevant rules, it is my understanding that dredging in the
1990's was more extensive than what was allowed in the 1998 permit for the Clam Bay
Restoration and Management Plan. Dredging done in 1999 and 2002 under that plan appears to be
11J -�
within the scope of the 1998 permit. However, dredging done in 2007 appears to be much more
extensive than the 1999 and 2002 dredging.
If one constructs a time line, the following can be observed. When the larger dredging template was
used in the 1990's, the mangrove system appeared to be stressed, leading to the need for the 1998
CBRMP. When the smaller dredging template was used beginning in 1998, the mangrove system
was observed to recover well. The effects of the larger template dredged in 2007 are still being
assessed.
By all accounts, the mangrove system appears to be in good health. Whether there is a cause and
effect relationship between the dredging template and the health of the system has not been
established to the best of my knowledge. This reinforces the fundamental question of what is the
appropriate dredging template to approve at this time. This is a critical concept in applying the
federal regulations to the decision of whether to issue the permit as requested or take some other
appropriate action.
The following cites the specific relevant provisions of each of three federal rules and discusses the
implications for this permit application.
The National Environmental Policy Act.
The federal regulations for implementing the National Environmental Policy Act (NEPA) were
developed by Environmental Protection Agency. They are binding on federal agencies and include
numerous provisions for agencies to consider a range of alternatives in their decision processes.
See Sections 1500.2, 1501.2, 1505. 1, and 1507.2 especially subsection (d).
The NEPA regulations also include numerous provisions for extensive public involvement. See
Sections 1500.1, 1500.2, 1500.4, 1501.4 especially subsection (e)(4), 1503.3, 1505.1, and 1506.6.
Summarizing these various sections, all reasonable alternatives must be considered in federal
decision making and be made available for public review and comment. None of the documents
available to me discuss any alternatives for the current proposal. As noted above, there are at least
two clear alternatives that involve different dredging templates, a smaller template as dredged in
1999 and 2002, a larger template as dredged in 2007, and perhaps there are other reasonable
templates. But there apparently has been no effort to identify a reasonable range of alternative
templates for conservation purposes or any other project purposes. Without the explicit evaluation
of both of these two alternatives, and perhaps others, an explicit comparison of their relative effects
and an opportunity for the public to comment on the comparisons, compliance with NEPA
requirements cannot be achieved.
The Clean Water Act.
The Clean Water Act, Section 404(b)(1), requires the Environmental Protection Agency to develop
a set of guidelines which the Corps is required to use in reaching decisions regarding discharges of
dredged or fill material into waters of the United States. These are referred to as the 404(b)(1)
Guidelines and are codified at Title 40 Code of Federal Regulations Part 230. They require specific
findings by the Corps on a number of factors as described in the following discussion
Section 230.10. Restrictions on Discharges. "Although all requirements must be met, the
compliance evaluation procedures will vary to reflect the seriousness of the potential for adverse
effects...."
Comment: Based on this provision, the seriousness of adverse effects must be evaluated. In this
case, the analysis would require explicit consideration of the appropriate cross - section, based on an
explicit evaluation of reasonable alternative cross - sections. Clam Bay and the mangrove forest it
11J
contains are highly valued natural resources. The extent to which adding the purposes of beach re-
nourishment and maintenance dredging might change the analysis of potential serious effects is not
described in the public notice, and thus cannot be evaluated for comment.
Section 230.10(a). "... no discharge of dredged or fill material shall be permitted if there is a
practicable alternative to the proposed discharge which would have less adverse impact on the
aquatic ecosystem so long as the alternative does not have other significant adverse environmental
consequences."
Comment: No alternatives analysis has been provided. As noted above, the smaller cross - section,
4x40, appears to have worked well for conservation purposes, but the effects of the larger 5x80
cross - section are not well established. Given the level of uncertainty about effects of the larger
cross - section and what is know about the effects of the smaller cross - section, this provision of the
404(b)(1) Guidelines would appear at this time to point in the direction of selecting the smaller
4x40 cross - section in order to comply with the CWA.
Section 230.11 contains a series of factual determinations required to demonstrate compliance with
the 404(b)(1) Guidelines.
Comment: Because there is a rather significant difference of view as to some of the facts
supporting the proposal, it would be helpful in formulating public comments prior to final Corps
action on the application to have a copy of the required documentation describing those factual
determinations.
Section 230.20, et. seq. These provisions describe potential impacts on the physical and chemical
characteristics of the aquatic ecosystem that must be considered in finding compliance with the
Guidelines. In the spirit and letter of Corps regulations, the CWA, and NEPA regulations, it seems
appropriate to document these potential impacts and other 404(b)(1) analyses and provide them for
public comment, along with specific references to support the conclusions reached.
Section 230.1(c). "...material... should not be discharged into the aquatic ecosystem unless it can
be demonstrated that such a discharge will not have an unacceptable adverse impact either
individually or in combination with known and/or probable impacts of other activities affecting
ecosystems of concern."
Comment: This provision contains a rebuttable presumption that there will be adverse impacts
unless otherwise demonstrated. Clearly the risk of adverse effects of the proposed 5x80 dredging
template on the Clam Bay system have not been demonstrated whereas the effects of the 4x40
template, while not completely conclusive, appear to present a far less risk of adverse effects than
does the 5x80 template.
230.1(q). The term "practicable" means available and capable of being done after taking into
consideration cost, existing technology, and logistics in light of the overall project purposes."
Comment: The lack of clarity of project purpose discussed earlier adds a great deal of difficulty in
evaluating the practicability of potential alternatives and limits the public's ability to develop
relevant comments. For example, if the project purpose is for conservation, the need for developing
practicable alternatives for beach nourishment would not be part of the decision analysis. Placement
of the dredged material to nourish the beach could be done as an incidental convenience when
dredging for conservation purposes. However, beach re- nourishment would be part of the
considerations of appropriate disposal options to achieve the conservation objective rather than
drive the decision as to when and how much to dredge for beach re- nourishment purposes.
Conversely, if beach nourishment is a declared project purpose, the need for, type, and amount of
beach material would have to be considered as one purpose in a multi - purpose activity. This is not
say that that multiple purposes cannot be achieved simultaneously. It is to say that the public
11J -cR
interest evaluation process in a multi - purpose project is significantly different from a single
purpose project. The interaction of the multi - purpose aspects has not been described in the public
notice of the application. Any optimized multi - purpose approach must also be shown to be in
compliance with the Clean Water Act requirement for selecting the least environmentally damaging
practicable alternative.
Corps of Engineers Regulatory Program, Title 33 Code of Federal Regulations 320, et.seq.
Section 320.4
(a)(2) The following general criteria will be considered in the evaluation of every application:
(i) The relative extent of the public and private need for the proposed structure or work:
(ii) Where there are unresolved conflicts as to resource use, the practicability of using
reasonable locations and methods to accomplish the objectives of the proposed structure or work;
and
(iii) The extent and permanence of the beneficial and /or detrimental effects which the
proposed structure or work is likely to have on the public and private uses to which the area is
suited.
Comment: These provisions address the requirement for a comprehensive analysis of unresolved
conflicts as to resource use. In this instance there is little doubt that there are clearly unresolved
conflicts. These are the same considerations addressed in the discussion of NEPA and the CWA
above. The need has not been well described, especially for the maintenance dredging and beach re-
nourishment; there remain unresolved conflicts; and the extent and permanence of beneficial and
detrimental effects have not been described.
Section 325.1(d) requires a description of the location, purpose, and need for the work.
Comment: The purpose is not clearly defined as discussed above and the need is not addressed.
Section 325, Appendix B,
Par. 55. When the EA [Environmental Assessment] confirms that the impact of the applicant's
proposal is not significant and there are no "unresolved conflicts concerning alternative uses of
available resources" (section 102(2)(E) of NEPA), and the proposed activity is a "water
dependent" activity as defined in 40 CFR 230.10(a)(3), the EA need not include a discussion on
alternatives. In all other cases where the district engineer determines that there are unresolved
conflicts concerning alternative uses of available resources (emphasis added), the EA shall include
a discussion of the reasonable alternatives which are to be considered by the ultimate decision -
maker.
Comment: This is guidance on when the Corps may omit an alternatives analysis in its review of a
permit application. It clearly does not apply in this case where the key issue is "unresolved conflict"
concerning the alternatives available to meet the purpose of conserving Clam Bay and the
mangrove resources involved.
This provision of Corps regulations echoes Section 102(2)(E) of the National Environmental
Policy Act which states, "study, develop, and describe appropriate alternatives to recommended
courses of action in any proposal which involves unresolved conflicts concerning alternative uses
of available resources." EPA included the same requirement in its NEPA implementation
regulations, "When the EA confirms that the impact of the applicant's proposal is not significant
and (emphasis added) there are no unresolved conflicts concerning alternative uses of available
resources,... the EA need not include a discussion of alternatives.
Additional issue.
I I i - C-TZ'
There is one additional issue regarding a unified approach to managing the Clam Bay and
mangrove resources. The 1981 permit placed that responsibility with Collier County which in turn
placed the responsibility for conservation of the resources in a single agency. Collier County now
proposes to bifurcate responsibility between two agencies. Such bifurcation presents a risk that the
optimum plan for meeting the requirements of the 1981 permit might not be met.
I recognize it is not the business of the Corps of Engineers to tell a local community how to
organize itself to manage its resources, but it seems reasonable to conclude that bifurcated
responsibility for the resource could lead the different agencies involved to be working at cross
purposes. In my view this circumstance introduces a risk that the provisions of the 1981 permit
may not be achieved and the quality of the Clam Bay and mangrove system might be compromised.
I ask the Corps to review its public interest and compliance determinations from the 1981 permit to
address the national need to conserve the resource, and to condition any permit to ensure that the
original conservation purpose is maintained notwithstanding the bifurcated management structure.
I look forward to supplemental information consistent with the regulatory requirements discussed
above.
Sincerely,
Morgan R. Rees
5954 Pelican Bay Blvd. #221
Naples, FL 34108
I
WIWI
Lainie Edwards, Florida Department of Environmental Protection and Linda ElligI,J---C-R
US Army Corps of
PETITION: SAVE CLAM BAY WETLANDS - KEEP IT NATURAL
We, the undersigned, support the County's goal to provide more beach access at Clam Pass
Park, but We oppose the current plans that would degrade this serene NATURAL RESOURCE
PROTECTION AREA with significant construction in undisturbed mangrove habitat, dredging
out the ebb shoal, installing channel markers, or otherwise altering its shallow three bay
system.
Comments
Nothing is more important than saving our special natural
places. Clam Pass, its meandering creeks and three bays
is one of those special places.
The Earth can only function in it's Natural State.
Adulteration leads to demise.
Dear Commissioners, I am a certified Florida Master
Naturalist and an avid kayaker. Please maintain the
boating in Clam Bay system at its current level. No deep
dredging, please. The president and past - president
founder of the Paradise Coast paddlers, a 500 member
organization, both support this position. Currently paddlers
and boaters with small boats use the system in harmony.
The new Collier County kayak program run for young
paddlers by Saltwater Sports is a great program and would
be compromised by deep dredging and increased large
boat traffic. In addition, I am co- president of the Park West
neighborhood association. I can report that many of my
neighbors in Park West and Park Shore -- Naples*
northernmost communities and closest to Clam
Bay *support maintaining boating at the current level.
Thanks for your consideration Sincerely, Art Ritas
Since 1958 there have been no marker signs in Clam Bay.
It is the only natural waterway in Collier County left. If
marker signs and dredging occur this natural habitat will be
comprimised only to benefit the 88 or so homes located in
the Seagate comminity.
Paae 1 - Sianatures 1 - 12
Name
From
1.
marcia cravens
Naples, FL
2.
Karen Kamener
North Fort Myers, FL
3.
Panagiotis
Patras, Greece
Rigopoulos
4.
Pam Boland
Grovetown, GA
5.
Daile O'Connor
S Hackensack, NJ
6.
Bertil Saukkoriipi
Kiruna, Sweden
7.
Filomena Lomba
Melksham - wiltshire,
Viana
United Kingdom
8.
Bill C
Kempten, Germany
10.
Bonita Holland
East Hannibal, IL
11.
Art Ritas
naples, FL
12.
Steve Nagy
Naples, FL
Comments
Nothing is more important than saving our special natural
places. Clam Pass, its meandering creeks and three bays
is one of those special places.
The Earth can only function in it's Natural State.
Adulteration leads to demise.
Dear Commissioners, I am a certified Florida Master
Naturalist and an avid kayaker. Please maintain the
boating in Clam Bay system at its current level. No deep
dredging, please. The president and past - president
founder of the Paradise Coast paddlers, a 500 member
organization, both support this position. Currently paddlers
and boaters with small boats use the system in harmony.
The new Collier County kayak program run for young
paddlers by Saltwater Sports is a great program and would
be compromised by deep dredging and increased large
boat traffic. In addition, I am co- president of the Park West
neighborhood association. I can report that many of my
neighbors in Park West and Park Shore -- Naples*
northernmost communities and closest to Clam
Bay *support maintaining boating at the current level.
Thanks for your consideration Sincerely, Art Ritas
Since 1958 there have been no marker signs in Clam Bay.
It is the only natural waterway in Collier County left. If
marker signs and dredging occur this natural habitat will be
comprimised only to benefit the 88 or so homes located in
the Seagate comminity.
Paae 1 - Sianatures 1 - 12
18.
Name
From
13.
Marcin Sztwiertnia
Ustro* Poland
14.
Susan Snyder
Naples, FL
15.
Jeanette Chupack
Cape Coral, FL
16.
Chaz Gaily
Nelspruit, South
Berlusconi
Africa
17.
Alison clift
Chelsea, MA
18.
Sam Furman
Naples, FL
19.
Judith Nugent
Naples, FL
20.
Judith Nugent
Naples, FL
21.
Jay Rose
Naples, FL
22.
Kirk Otto
Marco, FL
23
24.
25
26
27
28
29
30.
Daniel Fineberg Hollywood, FL
Donald
McCumber
David N Moore
daniel soulas
Ralph Xx
Amy Schumacher
Jacqueline
Robinson
Linda Nelson
Lehigh Acres, FL
Bridgeport, CT
bordeaux, France
Freeland, Germany
Kettering, OH
Powder Springs, GA
Comments I I i
Florida has already appropriated enough land and
waterways for human consumption. Let's leave this natural
areal for animals and humans to enjoy together!
For more impact, add a personal comment here
Without unspoiled places like Clam Pass. I would consider
moving away .Many of my friends dislike FL because all
they have seen are the over built condos , strip malls etc.
etc When I introduce them to the " other " FL , they are
amazed . I consider this a Quality of life issue . PLEASE
DO NOT INTERFERE with this small, peaceful & beautiful
waterway. It is NOT progress !
Don't let a few greedy, arrogant, wealthy boat owners
coerce you into doing what a majority of users don't want
or need. This is strictly for the uncaring elite.
Leave Mother Earth alone, haven't we distroyed enouth
already?
Dredging the Clam Pass Natural Resource Protection Area
benefits a small, select group of people, but will do
irreparable, ongoing, and permanent harm to the local
ecosystem. Protect this natural resource - do not allow this
destruction of shallow water habitat. There are plenty of
places to launch power boats, but there is only one Clam
Pass.
Naples, FL Clam Pass has been a sanctuary to me. Kayaking,
swimming, bird watching, fishing. It would be a shame to
motorized and disturb this habitat that provides shelter to
so much wildlife and peaceful recreation. I support keeping
Clam Bay natural - -no big boats.
Paae 2 - Sianatures 13 - 30
Paae 3 - Signatures 31 - 50
Name
From
Comments
31. Sterling Mulbry
Boston, MA
Leave natural Florida as it is - there's a reason for it .
Unfortunately, this usually becomes clear after unalterable
change has been wrought by greedy developers.
I speak as a 7th generation Floridian who is disgusted by
rampant development in our lovely state.
32. Jamie Lee
Martinez, CA
33. Caridad Blanco
Miami, FL
34. Brenton Mongan
Naples, FL
Please do not do this to this proistine area! Thanks for
inspiring the movement to block this!
35. Ian Soldano
naples, FL
36. vincent pantano
naples, FL
38. Carey Parks
Cape Coral, FL
It's a great place. I'd be happy to take anyone who would
like to see what we are talking about on a trip thru there.
It's magic.
39. Fred Merker
Ft Myers, FL
40. Gary Bristow
Naples, FL
This is one of the only places left in Naples where you can
go and have a nice time in a canoe or kayak and fish or
whatever, very quiet and peaceful back there. We have
plenty of places for larger boats!!!! Even thou this place is
still used by many, the waters are very clean and quiet
because of no Large Motor boats.. Why destroy this..
There are plenty of home back there and we donAt need
more condos.. These people that bought here know what
they where getting into when they moved in. EVERYONE
knows there is no Large boat access.. If they donAt like it
they can move. What wrong with you people. GREED!
41. Kathryn Spitler
St. Clair Shores, MI
I come down to Florida at least once a year and enjoy
Kayaking while I'm down there. I believe there are already
enough resources for power boats and not enough for
those who quietly enjoy nature with no impact.
42. Peggy Webb
Orlando, FL
43. Andy Reschke
Naples, FL
This is one of the few places left in Naples where our
natural resources have been left untouched.
44. Meredith Levin
Van Nuys, CA
45. Sarah Manthey
Lakewood, OH
46. Kathleen Cole
Prague, Czech
Republic
47. Becky Visco
Wimberley, TX
48. Jonathan Antunez
Naples, FL
Clam pass is one of my favorite places to fish and canoe.
Please leave it the way nature intended. It is an important
estuary and backwater.
49. Jim Sanders
Naples, FL
50. Christopher
Bonita Springs, FL
I like hugging mangroves too!
Walczak
Paae 3 - Signatures 31 - 50
51
52
53
54
55
56
Paae 4 - Sianatures 51 - 56
■OflViF �, „'e,�
Name From
Comments
Michael Zion Naples, FL
Clam pass is fine the way it is. Why must we ruin a
nature's gifts by imposing our pointless needs upon it to
benifit a few people.
Louis G Wienecke Granbury, TX
We're looking to relocate to this area. Please don't ruin any
more of the natural environment.
Sophia Werbowy Addison, IL
Sandi Sprenger Naples, FL
There is nothing you can do to improve this area, it is as it
should be. Why do we ALWAYS have to ruin what we
have. You would think that we have enough examples of
how we have ruined this town over and over again in the
name of progress. I have been here 45 years and we just
can't get it right. Leave it alone. Let us have at least one
place that is unspoiled, untouched. Is that so hard to do?
Most of us who have been here long enough see the
damage that continues to be done by those that think they
know better. Stop the madness before it is too late once
again.
Richard Demarse Naples, FL
It is extremely important to protect this area. We should all
be working together to stop dredging of natural waterways,
not destroying them.
George Seifried Naples, FL
To my government representatives:
I am a Collier County property owner and I object to the
county's actions to create a navigational passageway
within what is generally called Clam Bay.
It is understandable that the county might wish to provide
access services to property owners and power boaters in
the Seagate area. To my knowledge, this area is naturally
very shallow, would not support powerboats with more
than eighteen inches of draft, and has been this way in
excess of twenty years. From my experience canoeing and
kayaking within this area, it shocks me that the county
would determine that this area is a navigable body of
water. Furthermore, it is not beyond my imagination that
the county would intend in the future to dredge areas of
this beautiful environment. What must you supporters of
this plan be thinking? Have you considered what effect
your announced plans would have during severe storm
events?
One reads everyday that the shore, and the various
wetland areas adjacent to it like Clam Bay, need to be
preserved in their beautiful and natural state. Shouldn't the
lessons from the nearby Everglades be considered? Have
you all not read the technical reports that the Everglades
should never have been "improved" by the COE many
years ago? Today, as this Clam Bay issue is discussed,
the COE is spending millions of our taxpayer dollars
returning much of the Everglades to what it was before the
COE "improved it ".
(continues on next page)
Paae 4 - Sianatures 51 - 56
Paae 5 - Signatures 56 - 77
Name
From
Comments J
56.
George Seifried
Naples, FL
(continued from previous page)
Please do not agree to change Clam Bay or make areas of
it a navigable waterway. This jewel needs to be protected
by our public representatives, not plundered.
George Seifried
57.
Jeff Dever
Atlanta, GA
58.
robert mohl
naples, FL
As Florida Master Naturalist, it would seem counterintuitive
to threaten this pristine mangrove wetland. Please exercise
prudent judgement. Thank you.
59.
Dick Artley
Grangeville, ID
60.
Terry McGuan
Mokena, IL
61.
Roxie McGuan
Bonita Springs, FL
62.
Ira Rubenstein
Naples, FL
We can't afford to continue to exploit our few precious
remaining natural areas to satisfy short term needs of a
small group of people. Sensitive mangrove estuaries
deserve preserving for the good of us all.
63.
David Isaacson
Naples, FL
It's a prized natural inlet that dosn't need to be "uglified" for
commerical purposes.
64.
James O'Neill
Naples, FL
65.
Alexander
Vienna, Austria
Destroying natural resources is usually an irreversible
Limberg
process. Don't let civilisation destroy the last sheltered
natural areas!
66.
Pearl Brostoff
Pittsburgh, PA
67.
Dennis Kaplan
Mayfield Heights, OH
68.
Joseph Taboada
Naples FL, FL
Why do so few people think they are entitled to ruin so
many natural things. They refuse to leave nature alone.
69.
John Waller
Naples, FL
70.
Harry Shafer
Van Nuys, CA
71.
Kayne Torman
Sarasota, FL
This is one of the few pristine little bayou's in Naples. If it
gets dredged and opened to boat traffic, the natural beauty
of it will be gone forever.
72.
Carol Chruniak
Cape Coral, FL
74.
Gene Rossano
Nokomis, FL
It wpuld seem much more in the counties and all peoples
interest to promote this area for what it now is, an
ecologically pure, pristine, tourist destination than to set
about altering natures desires and creating another
ongoing maintenance project to make work and build
budgets and government.
75.
Debby Bradford
Dania Beach, FL
76.
Marjorie Prolman
Naples, FL
77.
Miriam Knight
Punta Gorda, FL
The purity of FL's coastlines are diminishing
everywhere,due to housing. Please keep this "natural
resource protection area" PROTECTED!
Paae 5 - Signatures 56 - 77
Name From
Comments
78. Susan Farber Naples, FL
There are more small, non- motorized boaters that use
Clam Pass than potential large motorized boaters, AND we
pay the same taxes and have as much money to boot!
We just choose to have a smaller boat)
How do you justify satisfying the minority, in this case? IE,
What are the benefits to opening up Clam Pass?
79. sara gray Naples, FL
80. Inga Rusthoi Cape Town, South
Africa
81. Jody Guy Bonita Springs, FL
82. James Piacentini Naples, FL
Please vote no, Do not Dredge Clam Pass, and thanks for
caring !
83. Gayle Nathan Ft Myers, FL
PLEASE do not dredge Clam Pass. It is a natural jewel as
it is. Large power boats will drive wildlife away, and those
that fish, canoe and kayak will lose one of the few natural,
quiet spots left. Thank you for your consideration.
84. Daniel Medina homestead, FL
I visit the area a few times a year where i take my family to
wade and fish. There are very few natural preserved areas
these days and to eliminate another to appease a few
would be unjust. The owners knew that there was no deep
water access when they purchased their home and should
be more responsible and thoughtful prior to home
purchase if they had plans to have large boats. the
monetary value aspect is very appealing and in truth I
would guess that if the plan does go through and the home
values go up, 1/2 the residents will sell for a hefty profit.... I
say NO to dredging.
86. Debra Holoquist Cape Coral, FL
Let's not pave Paradise and miss it when it's gone!
87. THOMAS LONG NAPLES, FL
Clam Pass is beautiful just as it is. No dredging or
additional access to larger boats is going to improve Clam
Pass in any way, whatsoever. Please do the sensible,
correct thing, and make sure that Clam Pass is preserved
as it is, now.
Thomas Long
88. John Saco Ft.Myers, FL
89. Carlyn Lehbs naples, FL
90. Buck Blessing Naples, FL
Power boats would ruin the natural beauty of Clam Pass
91. Lynette Foster Stuart, FL
Look, this Earth is the only one that we have.
92. Aaron Kozol Naples, FL
93. Nancy Lien LAKE CITY, MN
94. Ralph Walton Naples, FL
This is a terrible idea. Ruin a quiet waterway to please a
few wealthy investors.
95. Bill Conn caper coral, FL
Paae 6 - Sianatures 78 - 95
Name From Comments
Maribel Figueroa Eastlake, OH Hope to visit this area with my kayaking friend when I go to
FL.
Marci Seamples
Michael Devlin
99. nancy lanning
100. Gale Weaner
101. PATRICIA
Dee -Kelly
102. Sunni Gothard
103. Michael Kropp
Naples, FL
NAPLES, FL Clam Bay /Pass is the only close in shallow water area in
Naples. The wildlife is fantastic. When the tides are right &
you can paddle in the MANGROVE TUNNELS- IT IS LIKE
STEPPING BACK IN TIME. The area where the markers &
dredging is to take place is absolutely fantastic for the
recreational paddlers young & old. I see kids playing with
their new kayaks as well as our more mature newcomers
to the sport. On holidays Clam Bay is the only truly safe
paddling area in Collier County. The power boats can't
swamp you there! Also the fishing is unbelievable. You can
paddle in the bay & cast towards the mangroves or paddle
out approximately 200 to 300 yards in front of the pass
opening & fish all around the reef. At the beginning of the
pass small 3' to 4' sharks just lay in wait for something to
swim into their mouths. I personally have followed
manatees through the bay & back out into the Gulf -being
ever so careful not to disturb their route. That day me in my
skin on frame kayak & the manatees were the tourist
attraction for the day. This is where I bring my friends from
other states & parts of Florida to kayak & go to the beach. I
am not nor have ever been a radical I believe that we need
extremist from both sides to find a middle. I have
suggestions but feel that everyone has dug in for a
showdown & my thoughts would fall upon deaf ears.
Dredging Clam Bay (at this point )would only benefit a few
homes. I have heard some very funny reasons for &
against dredging. At this point I must vote on the side of
preservation
Thank You,
Mike Devlin
This is just a sad
Carlsbad, CA
Duncanville, TX
sanibel island florida, Please listen to your people and realize that this will NOT
FL be a good thing for the enviornment and our planet.
Painesville, OH
Franklin, WI My mailing address may be in Wisconsin but my hart and
sole is in my kayak in Florida. I have been nearly run over
by powerboaters in dozens of places and I keep kayaking.
This does not have to be added to the list of places to be
run over by a powerboater. I spend 180 days a year in
Florida and most opf them kayaking and fishing
somewhere. I am also a powerboater but beleive
powerboaters don't need to be able to travel everywhere
(continues on next page)
Paae 7 - Signatures 96 - 103
Name
128. steve Kingery
129
130
131
132
133.
135.
136.
137.
138.
139.
140.
141.
142.
143.
144.
145
146.
147.
148.
149.
Kristin Kokal
Allan Moltmaker
gait dair
Renate Nebel
Bernard
Loren Wieland
Anthony
Montapert
Carlos
Schomaker
L Waldron
David Meiser
John Sestak
Razvan V.
Vincent Lucas
John Van Dellen
Carl Rosenstock
Octavian Paul
Draja
Steve Dale
Ann Smith
Cathy Schluessler
Jeffrey Shindle
Julie Lappetito
150. Peter Ansell
From
Crystal River, FL
Fort Myers, FL
Harrison Township,
MI
Perth, Australia
Naples, FL
Ft. Myers, FL
N Hollywood, CA
Fort Myers, FL
Gainesville, FL
Pipersville, PA
Mokena, IL
Brasov, Romania
Naples, FL
Naples, FL
Baraboo, WI
Arad, Romania
Frankston,victoria,
Australia
Naples, FL
Fort Myers, FL
naples, FL
Naples, FL
Marco Island, FL
Comments
encourage low impact uses of our natural resources and
save our tax dollars
As a family that loves Florida and seeks to protect natural
settings in preserving paradise now and for future
generations, please save Clam Bay wetlands and stop the
insanity of pandering to power boating that is detrimental to
this protected area. If we loose the preservation of Clam
Pass Natural Resource Protection Area, we loose much
more than we can ever realize.
Enough is enough... having had the experience of growing
up in Naples and watching the development over the years
I am shocked at this needless proposal. Personally I use
Clam Pass weekly kayaking and would be heart broken to
see this come to fruition. Let's stop and enjoy what we're in
Naples for, the nature, the beauty—please reconsider
I just moved to Marco Island and enjoy kayaking all over
Southwest Florida. We need to save as much natural area
as we can. The power boats have plenty of places to go.
Paae 9 - Signatures 128 - 150
161. Justin Woodson Austin, TX
162. Frances Davis Louisville, KY
163. Christopher
Name
From
151.
juliet araujo
naples, FL
152.
Elaine Robinson
Wolverhampton,
Naples, FL
166. Brack Barker
United Kingdom
153.
Roxann Hanson
Hudson, WI
154.
Ellen Peterson
Estero, FL
155.
joanne laibinis
Naples, FL
156.
Scott Kobler
Naples, FL
157.
constance ehrbar
naples, FL
158.
Stephen B Ellis
Naples, FL
159.
peter mendelson
naples, FL
160.
Louisa Woodson
Austin, TX
161. Justin Woodson Austin, TX
162. Frances Davis Louisville, KY
163. Christopher
Naples, FL
Risewick
168.
164. Frances Petty
Naples, FL
Sargent
Morris Hindman
165. Timothy Scanlon
Naples, FL
166. Brack Barker
Williston, FL
167.
Daniel Martin
Naples, FL
168.
eugenie cardenas
naples, FL
169.
Morris Hindman
Naples, FL
170.
Thomas Pirovano
Bern, Switzerland
171.
Sylwia Podgorska
Skocz6w, Poland
172.
Ron Martin
Collingwood, Canada
Comments 1 I J-1- cp,
SAVE PROTECT WETLANDS
it would not be advisable to let big boats roam these
waters- what are people thingking ?? the damage that will
be done will take years to repair.
this is a very bad idea - to let boaters roam this area -
small and very sensitive - what is everyone thinking - the
damage will take years to repair. let commom sense
prevail - why destroy this sensitive area - allowing
powerboats in -- it will take years to undo the damage that
will be done in a year.
I have been coming to Naples my entire life, and I hate the
idea of Clam Bay being anything other than its natural,
beautiful self. Please keep this special part of Naples alive.
Your comments inform Local, State and Federal agencies
that Clam Pass and its three shallow Clam Bays is a
Natural Resource Protection Area that is valued by you as
a thriving wildlife habitat for passive recreation only.
Have you asked the County Commissioners and Naples
Council to stop supporting this terrible project yet? What
are you waiting for?
Paae 10 - Sianatures 151 - 172
Comments
11�f -cam
I have kayaked in these beautiful wetlands and would not
like to .see them ruined by dredging. I appreciate this
opportunity to voice my concern. R. Martin
Clam Bay is a treasure we need to keep alive.
Thanks
Marcia Hawken
http:/ /www.pelicanbayluxuryreport.com
Let's keep it natural!
Please Don't Ruin Pelican Bay!
Ginny Lee
I FIRMLY BELIEVE CLAM BAY PASS SHOULD REMAIN
AS A NATURE AREA AND NOT BE USE FOR POWER
BOATING .THAT WOULD BE ENVIRONMENTALLY
DESTRUCTIVE AND DANGEROUS TO SWMMERS AND
OTHER RECREATONAL ACTIVITY.THIS IS ONE OF
THE LAST NATURAL AREAS REMINDING US OF THE
ORGIONAL NAPLES ENVIRONMENT.
Please do not let the desires of a few outweigh the benefits
for the many. As you know, if you enjoy the beach, that the
effect of powerboats on the tranquility are multiple. They
are a danger to the wildlife, to the environment and to the
people who enjoy the beach. Why is this even an issue if
we care for Florida's coast?
Much of Florida's natural beauty has been overwhelmed by
"progress ".We urge you to maintain clam pass as a haven
for kayaks, canoes, birds, wildlife and the Naples citizens
who want to enjoy a bit of untouched Florida, and keep it
free of motor boat traffic. After all motor boats, and other
large pleasure boats have all the rest of the gulf for
themselves!
Wildlife is losing out all over Florida. Please preserve this
area, they need every little bit of help they can get.
I support keeping the Clam Pass Preserve Waters FREE
from any more power boats. Installation of powerboat
markers in the Clam Pass Preserve waters misrepresents
it to be more navigable for powerboats than it is. It is and
(continues on next page)
Paae 11 - Sionatures 173 - 189
Name
From
173.
Ronald J.
Collingwood, Canada
MARTIN
174.
Dinda Evans
San Diego, CA
175.
Alvin Long
Redmond, WA
176.
Marcia Hawken
Naples, FL
177.
Ginny Lee
Naples, FL
178.
Dianne Rhodes
Naples, FL
179.
harry woehr
naples, FL
180.
Fred Eckler
Naples, FL
181.
Sharon Boots,
Naples, FL
ND, PhD
182.
Barbara M Rohrer
Naples, FL
184.
harriet Schley
Naples, FL
185.
Ruth Parks
Cape Coral, FL
186.
John Snyder
Naples, FL
188.
Cheryl Latif
Naples, FL
189.
Marlene Gargan
Naples, FL
Comments
11�f -cam
I have kayaked in these beautiful wetlands and would not
like to .see them ruined by dredging. I appreciate this
opportunity to voice my concern. R. Martin
Clam Bay is a treasure we need to keep alive.
Thanks
Marcia Hawken
http:/ /www.pelicanbayluxuryreport.com
Let's keep it natural!
Please Don't Ruin Pelican Bay!
Ginny Lee
I FIRMLY BELIEVE CLAM BAY PASS SHOULD REMAIN
AS A NATURE AREA AND NOT BE USE FOR POWER
BOATING .THAT WOULD BE ENVIRONMENTALLY
DESTRUCTIVE AND DANGEROUS TO SWMMERS AND
OTHER RECREATONAL ACTIVITY.THIS IS ONE OF
THE LAST NATURAL AREAS REMINDING US OF THE
ORGIONAL NAPLES ENVIRONMENT.
Please do not let the desires of a few outweigh the benefits
for the many. As you know, if you enjoy the beach, that the
effect of powerboats on the tranquility are multiple. They
are a danger to the wildlife, to the environment and to the
people who enjoy the beach. Why is this even an issue if
we care for Florida's coast?
Much of Florida's natural beauty has been overwhelmed by
"progress ".We urge you to maintain clam pass as a haven
for kayaks, canoes, birds, wildlife and the Naples citizens
who want to enjoy a bit of untouched Florida, and keep it
free of motor boat traffic. After all motor boats, and other
large pleasure boats have all the rest of the gulf for
themselves!
Wildlife is losing out all over Florida. Please preserve this
area, they need every little bit of help they can get.
I support keeping the Clam Pass Preserve Waters FREE
from any more power boats. Installation of powerboat
markers in the Clam Pass Preserve waters misrepresents
it to be more navigable for powerboats than it is. It is and
(continues on next page)
Paae 11 - Sionatures 173 - 189
Paae 12 - Signatures 189 - 209
Name
From
Comments C
189.
Marlene Gargan
Naples, FL
(continued from previous page)
should stay a passive recreational area, a great & safer
place to kayak or canoe and see all the marine, bird and
other wildlife. KEEP IT NATURAL!!!!
190.
genn brown
Bellevue, NE
191.
Caroline
Naples, FL
Coykendall
192.
Love Animals Too
Warwick, NY
193.
Helle Collin
Broenshoej, Denmark
194.
Michael Seef
Naples, FL
Dear Commissioner,
let's keep Clam Bay and Clam Pass Park natural. This is
one of the few remaining natural areas in the urban area
with mangroves, birds and fish in a mostly natural state.
Do not permit signs and no motor boats.
Thanks for your attention.
Michael
195.
Jim Marino
Fort Myers, FL
196.
Vanessa Otero
Chino, CA
197.
Dominick Tascher
Naples, FL
198.
leann anderson
naples, FL
199.
Kathleen Bradley
Ocala, FL
200.
carrie silva
naples, FL
201.
Jackie Belcher
Naples, FL
202.
Jackie Sweet
Naples, FL
Protect Clam Pass and its wetlands. That is your JOB!!!!
Please do it!
203.
Debra Wine
Naples, FL
Preserve our natural resources and our much sought after
environmental assets to keep Naples a tourist destination!
You are entrusted to maintain the natural elements that
combine to present Naples as a great place in which to to
live, work and visit!
204.
Scott Whitcomb
Naples, FL
205.
Maribeth Guididas
Naples, FL
206.
Julie Steuber
Naples, FL
207.
Margaret D'Auria
Tappan, NY
This is one of our favorite parks to visit when we are in
town because of its natural beauty. Please don't disturb the
area just to increase beach access. It would be a great
loss to your community.
208.
Mirty Branco
Naples, FL
'We all have ability. The difference is how we use it."
Stevie Wonder
209.
Charlie
naples, FL
Vickaryous
Paae 12 - Signatures 189 - 209
Paae 13 - Sianatures 210 - 229
Y2
Name
From
Comments
210. Brian Doyle
naples, FL
Dear county commisioners, Keep it Natural, posterity and
preservation will show history that we had cared for our
community/
211. Rebecca Taylor
Naples, FL
Please let the estuary remain as pristine as it is.
212. Mathew Silva
Naples, FL
213. Mary McCaughtry
Naples, FL
214. Suzi Thomas
Naples, FL
215. Nancy Lewis
Fort Myers, FL
216. Susan Haberkorn
Naples, FL
Please allow nature it's own space and the people who
visit there the opportunity to see an unspoiled habitat.
217. susan myhelic
naples, FL
218. Carol Bailey
Naples, FL
Please save Clam Pass....
Pelican Bay resident and Naples Realtor
Thank you, Carol Bailey
219. Joanne Hartman
Naples, FL
220. Marcie
Naples, FL
I have been taking my son to Clams pass for 10 years and
LaRochelle
I really wouldn't want to have anything change. It is so
beautiful, please keep it that way.
221. Janet Hoffman
Naples, FL
222. Frank Gerry
Dona Vista, FL
The planned constructions (destructions) would be
dangerous to the ecosystem.
223. Lisa Anderson
naples, FL
I have lived in Naples for 23 years and I walk the beach to
Clam's Pass almost every day. Over the years I have
watched the sea life change ... I have not seen a leopard
ray in over 3 years, there are less fighting conchs, smaller
star fish populations, no more large schools of cow nose
rays, the bird population is dwindling and I could go on. I'm
not a scientist, but I observe nature and what I see
saddens me deeply. Why on earth would you consider
upsetting the balance of one of the last pristine areas in
southwest Fl. Please Preserve Clam Pass and Every
Creature that depends upon that delecate ECO system.
224. Marshall DeMott
Naples, FL
I support keeping Clam Pass and Inner Clam Bay a natural
area, closed to all motorized navigation. I support access
by foot, by canoe and kayak and by any unmotorized craft.
No navigational markers should be placed anywhere in the
Pass. The Pass and Inner Clam Bay should be designated
as a natural area, protecting the habitat's flora and fauna
and fish ecosystems.
225. Paul Wolter
Naples, FL
226. Jennifer Wolter
Naples, FL
227. Nina van Dam
Naples, FL
228. Jeff Goodchild
naples, FL
229. Claudia Osborn
Naples, FL
Paae 13 - Sianatures 210 - 229
Name
230. Marianne Varney
231
232
233
234.
235.
236.
237
238
239
240
241
242
243
245
246
247
248
249
251
Joan Klipping
Mary & John
Quinn
ESTELLE
RAUCH
ellen tomasiewicz
Peggy Acosta
Ingrid Andersson
ursula gibbons
Richard Hollister
Sini Keto
chip spitzer
Les Gorsuch
Nadja Geyern
william perez
From Comments 11 J ' c( Z'-,
Naples, FL I endorse this petition and its intention of keeping the Pass
and Inner Clam Bay clean and peaceful for canoes,
kayaks, and wildlife watchers. As the last pristine spot in
Collier County, I see no justification for providing access to
large boats which would deny others the refuge of this
gorgeous spot.
Miami Beach, FL
Naples, FL Yes
Naples, FL We (my husband Sam too) are horrified at the proposal to
dredge for the purpose of power boating in such a pristine
setting!
I will forward a note to the County Commissioners ASAP
naples, FL
Womelsdorf, PA
Johanneshov,
Sweden
naples, FL
Tucson, AZ
Forssa, Finland
naples, FL
Cape Coral, FL
Naples, FL
naples, FL
Richard Kostyra Naples, FL
dana porcelli -blair
Lars Young
Gabriel Kamener
Sarah Galer
Henriette
Matthijssen
naples, FL
Naples, FL
North Fort Myers, FL
Fort Myers, FL
Boyle„ Canada
If we continue to abuse our piece of the planet there will
come a time when the damage becomes permanent. The
quality of our ecosystem in Lee and Collier counties is
what attracts so many visitors to this area. Do the right
thing now for our grandchildren. History will always show
what you did!
Would be a tragedy to destoy our prestine environment at
the Pass and Inner Clam Bay. When we development
stop?
We have too few natural mangrove habitat that can be
enjoyed by us. Let us not destroy more for unnecessary
purposes. There are an abundance of beach accesses
now. This proposal also places undue pressure on the
traffic system in the area.
Stop this project. The need does not exist and our county
funds are limited.
Pace 14 - Sianatures 230 - 251
Comments
We need to protect our coasts and coastal wetlands!!
Paae 15 - Sianatures 252 - 279
Name
From
252.
Vegan Dillon
Inverclyde, United
Kingdom
253.
Ivonne Engler
Magdeburg, Germany
254.
James Mulcare
Clarkston, WA
255.
Jennifer Gardner
Melbourne, FL
256.
Don Snyder
Naples, FL
257.
Bettina Lorenz
Rhede, Germany
258.
Diane Almy
Miami, FL
259.
Jeaneen Andretta
Florham Park, NJ
260.
George Martin
Loule, Portugal
261.
Cathala Corine
Pierrelatte, France
262.
Lena Rehberger
Grebenhain,
Germany
263.
Lidia Dzuba
Sochi, Russian
Federation
264.
Christopher
Clarkesville, GA
Webb, DVM
265.
He Huang
Burnaby, Canada
266.
Tess Van Niekerk
Cresta, South Africa
267.
Herve Berard
Orsay, France
268.
Annie PEYSSON
Pusignan, France
269.
Didy Poulin
Thetford Mines,
Canada
270.
Marie - Claude
Saint - amand- les -eaux,
Lefebvre
France
271.
Nancy Petitjean
Liege, Belgium
272.
Elzbieta
Lodz, Poland
Gotkowska
273.
Marie -Rose
Marseille, France
HECKMANN
274.
lag joelle
Bron, France
275.
Marion Gondre
Rouen, France
276.
meyer meyer
Villeneuve Tolosane,
France
277.
ALEXANDRE
Ger, France
LAURE
278.
Regine Foucher
Le Kremlin Bicetre,
France
279.
Bamboo Ab
Digoin, France
Comments
We need to protect our coasts and coastal wetlands!!
Paae 15 - Sianatures 252 - 279
Name
280. Carine Ostyn
281.
edwige. derer
282.
Nina Ceccarelli
283.
No mails Ch
Buslot
284. Philippe Tomballe
285. deplante sandrine
286. POIGNON Aurelie
287. joelle questel
288. Adriana
Stancheva
289. Canova Josy
290. catherine savoye
291. gionta natalie
292. Stephane Rouer
293. VIVIANE tits
294.
Briguet Mirsada
295.
jenna colin
296.
angelique
300.
RANDAVEL
297.
Grelet Nathalie
298.
ROUX josette
299.
Barbara
Mindermann
300.
Elodie Mara[
301.
isabel Barros
302. augen josette
303. Blond Gabrielle
304. Doniscia
VEYSSIERE
305. pley nicole
306. suppin nathalie
From
Saint - nicolas,
Belgium
Melle, France
Lyon, France
Hasselt, Belgium
Engis, Belgium
Le Versoud, France
Nancy, France
Ste -anne,
Guadeloupe
Sofia, Bulgaria
Sion, Switzerland
Lorrez Le Bocage,
France
Aix En Provence,
France
Bours, France
Angleur Belgique,
Belgium
Geneva, Switzerland
Nice, France
Saint - ybars, France
Beaufort- en- vallee,
France
Marseille, France
Marseille, France
Marseille, France
San Fernando,
Argentina
Amneville, France
Douchy Les Mines,
France
Labourse, France
Brevonnes, France
St Maime, France
Comments
Paae 16 - Sianatures 280 - 306
i 1J-cR
Comments
Paae 17 - Sianatures 307 - 335
11J -Cry.
Name
From
307.
christian demottes
Nice, France
308.
elodie genga
lure, France
309.
Daniele Tranchant
Castelsarrasin,
France
310.
Adeline
Pezens, France
Boncompain
311.
flament evelyne
Renescure, France
312.
Anne Gruaz
La Chaux De Fonds,
Switzerland
313.
emilie allion
Paris, France
314.
muriel douttez
Ozoir La Ferriere,
France
315.
neima NEIMA
Paris, France
316.
michel jocelyne
Kapelle Op Den Bos,
Belgium
317.
Fanny Sardaigne
Ervauville, France
318.
Vaillant anne
Esapalis, France
319.
cynthia branche
Le Luart, France
320.
Alain Maraillat
Limoges, France
321.
monneau estel
Cahors, France
322.
spano claudia
Herstal, Belgium
323.
hostillus severine
Pessac, France
324.
REBELLE et
Paris, France
DALILE
325.
Viviane Praet
Erpe -mere, Belgium
326.
Yolande
Ensisheim, France
Rauscher
327.
schalck sabrina
Champagney, France
328.
rene davis
Wellington, New
Zealand
329.
BUISSON Sylvie
Montredon
Labessonnie, France
330.
Monique Gabetty
Joinville Le Pont,
France
331.
Jean Poignet
Yerres, France
332.
Natacha PENET
Unieux, France
333.
Joel LUNEL
Tarascon, France
334.
cuvellier marie
Pau, France
335.
SEGURET
Beaulieu, France
ISABELLE
Comments
Paae 17 - Sianatures 307 - 335
11J -Cry.
Comments
We must act!
Paae 18 - Signatures 336 - 362
11,1 crZ
Name
From
336.
jean vaunier
Paris, France
337.
depre elisabeth
Villers Sur Mer,
France
338.
marie- th6r6se
Paris, France
bienvenu
339.
Anne - Sophie
Marseille, France
MORISOT
340.
Carole
Paris, France
BELLEUDY
341.
Emilie Ferron
Vanves, France
342.
Shyheim
Li6vin, France
NEMICHE
343.
St6phanie
Marseille, France
MORISOT
344.
Clare Edwards
Plant City, FL
345.
Cachera- Nouvel
Rognac, France
Aur6lie
346.
Fabienne
Ssw, Belgium
Lagneaux
347.
amandine herrero
Au Fond Du Trou,
France
348.
Raluca Keskin
Bucharest, Romania
349.
brigitte vitureau
St Maur Des Fosses,
France
350.
Kristian Beitlich
Ld Adenscheid,
Germany
351.
jean -Luc
Marseille, France
PALAZOTTO
352.
Manuela Haug
Leinzell, Germany
353.
Gillian King
Sartrouville, France
354.
odette chauve
Morangles, France
355.
VIER EVA
Paris, France
356.
Karen Vasily
Norristown, PA
357.
lamirand mo
Paris, France
358.
Iwona Krzeminska
Sosnowiec, Poland
359.
vives justine
La Trinite, France
360.
Peter Kralovic
Bratislava, Slovakia
361.
Odile
Marseille, France
HECKMANN
362.
Janet Chase
Bend, OR
Comments
We must act!
Paae 18 - Signatures 336 - 362
11,1 crZ
363.
364.
365.
366.
367
368.
369.
370.
371.
Name
Lucinda Swingley
Nina Soares
Alan Francisco
Kevin Burke
Margaret
macdougal
Jennifer Scheder
Carrie Gleason
Maria Bodor
Ted Raia
From
Naples, FL
Wethersfield, CT
San Diego, CA
Naples, FL
Naples, FL
Naples, FL
Arizona City, AZ
Chicago, IL
Naples, FL
372.
Sharon Davis
Jacksonville, NC
Debbie Johnson
Canty
Kathleen
373.
Val Rose
Pueblo, CO
374.
SANDRA ROCHA
Oporto, Portugal
375.
THEODORE
Piraeus, Greece
SPACHIDAKIS
376.
David Machado
Pagos De Ferreira,
377. Ana Fuentes
378. brenda collins
379.
Ellen Gutfleisch
380.
Debbie Johnson
381.
Kathleen
386.
Basiewicz
382.
Victoria Molinari
383.
Gudrun Dennis
384.
George Theobald
385.
Jennifer Newrick
386.
Karina Paller
387.
Carsten Meyer
388.
elisabeth karcher
389.
Lucia Vertkin
Portugal
Montevideo, Uruguay
London, United
Kingdom
Sussex, WI
Newark, CA
Dana, NC
Comments I I _ ��
As a registered Collier County FL voter, I urge all elected
officials to keep Clam Pass a Natural Resource Protection
Area for passive recreation only.
Kevin B. Burke
Please leave this area as it is for future generations
Clam Bay is a natural treasure that must be saved.
As of leaders of our community please do the right thing to
protect this resource.
Poulsbo, WA "The greatness of a nation and it's moral progress can be
judged by the way it's animals are treated."
- Mahatma Gandhi
Gainesville, FL
Cooktown, Australia
Kaiserslautern,
Germany
Ljubljana, Slovenia
Hannover, Germany
Marseille, France
Sharon, MA
Paae 19 - Sianatures 363 - 389
Name From
390. Caitlin Claytor Alturas, CA
391. Allain Hale North Port, FL
392.
Krista Hunsiker
Abington, PA
393.
Allain Hunsiker
Elkins Park, PA
394.
Ronald Jarvis
Naples, FL
395. tina tine' Knoxville, TN
397. norma laborie Saint Ouen, France
Comments
This is spawning gound for juvenile fish. Dredging and
increased boat traffic will destroy it. This has happened
again and again on every dredging project that has been
done.
Why don't you ask the President's of each Condo
Association to place an e-mail with your petition addressed
to each resident of each condo assn asap and ask for their
signature to stop spending money unnecessarily and
protect the natural environment we live in. Seems like all
the politicians at the County level as well as the
PBFoundation level are using irresponsible judgement as
well as a biased Strategic Planning Committee that is not
dooing a good job.
Paae 20 - Sianatures 390 - 397
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