After reviewing the Army Corps letter of October 5, 2024, which requested an INFORMAL consultation on with NOAA Fisheries Protected Resource Division under Section 7 of the Endangered Species Act, we determined that the Corps had failed to demonstrate that they met the criteria for an informal consultation.

The Endangered Species Act (“ESA”) not only protects threatened and endangered species, but it also protects the habitat which is critical to their recovery and survival.  For the Green Sea Turtle, critical habitat includes sea grass meadows which are found in Coral Bay and which would be severely impacted by the Summers End Group marina.

In our letter of November 25, 2024, we challenged the Army Corps finding that the SEG project would “Not Likely Adversely Affect” the critical habitat of the Green Sea Turtle.  We determined that, according to the ESA and NOAA regulations, the project would clearly have substantial adverse affects by shading betwen 4 – 8 acres of sea grass and impacting water quality with chronic turbidity throughout Coral Harbor.  In this letter we cited the Army Corps findings and requested that NOAA reject the NLAA determination and require a formal consultation under Section 7 of the ESA.

UPDATE:  On December 2, 2024, we sent a second letter to NOAA NMFS Protected Resource Division, requesting formal Section 7 consultation under the Endangered Species Act for impacts to the Green Sea Turtles species, in addition to the critical habitat impacts addressed in the November 25, 2024, letter.  The second letter follows the one below.

The letter below addresses the potential for vessel impact injuries to Green Sea Turtles.