I request that the U.S. Army Corps of Engineers deny Permit SAJ-2015-01503 for the Long Bar Pointe development beside one of Sarasota Bay’s last largely uninterrupted mangrove shorelines unless, at a minimum, the project includes a genuine 50-foot, permanently protected wetland buffer, avoids wetlands and undergoes a full environmental review. 

Carlos Beruff’s proposal would allow wetlands to be dredged and filled with an 8- to 10-foot wall constructed next to fragile mangroves, wetlands, and an important estuary without an adequate functioning buffer. That raises serious concerns for Sarasota Bay, where wetlands protect water quality, provide habitat for fish and wildlife, reduce erosion, and serve as a natural barrier during storms. Without a genuine wetland buffer, the project could leave the shoreline more vulnerable and prevent mangroves from migrating inland as water levels rise. 

I am also deeply concerned that the project’s full cumulative impacts have not been adequately reviewed. If permitted as requested, this development could set a dangerous precedent for replacing natural wetland buffers with walls and fill. A development of this size should not proceed while significant questions remain about sea-level rise, mangrove migration and adaptation, stormwater runoff, flooding, wildlife habitat, water quality, and archaeological resources. These are not minor details. They determine whether the shoreline can remain healthy and whether nearby communities will face greater flooding, storm damage, and loss of natural protection. 

The loss or decline of mangrove wetlands could also cause serious economic harm to Sarasota Bay’s fisheries, tourism, boating, and recreational economy. Mangroves provide essential nursery habitat for fish, shellfish, and other marine life that support both commercial and recreational fishing. 

Sarasota Bay, a nationally recognized estuary, deserves better than a development plan that dredges or fills living wetlands and natural buffers to make way for buildings and a wall. Federal rules require the applicant to demonstrate that no practicable, less environmentally damaging alternative exists before wetlands may be filled. That showing has not been made. 

The application also appears to evaluate impacts only within a smaller portion of property under common ownership or control. The Corps should review all connected wetlands and mangrove areas, including lands previously proposed or permitted as part of a state mitigation bank, for secondary and cumulative impacts. Dividing related properties or permit applications should not be used to narrow the environmental review of one connected shoreline and wetland system. 

It is critical that the Corps require a complete environmental review, a meaningful analysis of alternatives, current water-level and flood data, a long-term mangrove migration analysis, and a genuine 50-foot protected wetland buffer. The permit should be denied unless every requirement of federal law is met and enforceable protections are established to preserve the wetlands and mangrove shoreline for future generations.