The responses from Summers End to USACE and NOAA agency requests, initially submitted in December 2019, were updated with an additional round of document submissions in May 2020. With each round of documents Save Coral Bay did a thorough analysis and sent detailed commentary to NOAA and USACE. This required in-depth research into sediment transport, currents, bathymetry and other aspects of the technical reports. The Army Corps sent a critique of the December submission in March 2020 and that was the last interaction between SEG and USACE which we were aware of in 2020.
If you are interested in just one event on the timeline you can click on the item below to jump to that section. Alternatively you can simply read through the entire story, which is still unfolding …
- Background: Army Corps Permits
- 2014: The Year it All Started
- 2015: The Public and Federal Agencies Weigh In
- 2016: No Response from SEG …
- 2017: The Year of the Hurricanes … And Summers End Responds to Army Corps
- 2018: Army Corps Initiates Consultation With Federal Agencies
- 2019: Agencies Request Additional Information to Initiate their Reviews
- 2020: Federal Agencies and Army Corps Still Waiting for Adequate Responses
- March 4, 2020: Save Coral Bay Finds Multiple Deficiencies in SEG Agency Responses
- March 26, 2020: Army Corps Requests Additional Information from Summers End
- May 25, 2020: Summers End Final Response to Army Corps
- July 1, 2020: Save Coral Bay Analysis of SEG Response to USACE
- 2021: Major Developments – Historic Shipwreck and Extensive Deficiency List
March 4, 2020: Save Coral Bay Finds Multiple Deficiencies in SEG Agency Responses
The December 2019 submission by Summers End was not obtained by Save Coral Bay until March 5, 2020 and we immediately began to review the 18 files containing over 200 pages. It was quickly apparent that SEG had not come close to fully responding to the NOAA agency information requests, and although we were outside of a public comment period we felt it would be prudent to provide a detailed analysis of these documents to the Corps.
Working with the CBCC and with our federal counsel, Attorney Robb Fox, we wrote a detailed legal and technical analysis of the submitted documents and forwarded this to the new Army Corps reviewer, Ms. Kelly Egan, in the Palm Beach Gardens USACE office.
March 26, 2020: Army Corps Requests Additional Information from Summers End
Shortly after sending our comments, Ms. Kelly Egan (USACE) transmitted a list of deficiencies in the December 2019 submission to Summers End Group. As the cover letter clearly stated: “The application received has been reviewed and contains insufficient information to evaluate the proposal. The Corps considers your application incomplete. The Corps will not take further action until receipt of the information requested.” It went on to seven pages of details identifying the missing components of SEG’s submission.
We do not know if Ms. Egan received our extensive comments prior to writing her letter. Given the very close dates it is doubtful, but hopefully our comments will be read and become useful at a later date. The lengthy delays in the Freedom of Information Act process have become significantly worth with the onset of the Covid-19 pandemic.
May 25, 2020: Summers End Final Response to Army Corps
It appears that Summers End has added yet another consultant to their long list of hired “experts” – people with some level of professional credentials who have sold their expertise to the highest bidder and apparently do not place much value on professional integrity.
The May 25, 2020 response to the March letter from USACE was really nothing more than I collection of “you say / we say” rebuttals. In several instances the so-called experts were rebutting their own prior written statements. There didn’t appear to be anything substantially new in this latest reply. Notably, the response cover letter was entitled “Response Final” and it appears that SEG has nothing more to say for now.
July 1, 2020: Save Coral Bay Analysis of SEG Final Response to USACE
Save Coral Bay submitted 56 pages of final response to the SEG document submissions. We referenced our earlier (March 2020) technical analysis. We cross referenced the SEG responses to requested information. We thoroughly analysed SEG’s many versions of compensatory mitigation.
Next Page: SEG USACE History – 2021