Attorney Robb Fox, representing Save Coral Bay, wrote to the Corps identifying the lack of requited territorial authority for the Summers End project.  A 2020 Consolidated CZM and Governor’s letter of modification, never approved by the CZM committee, expired in 2021, and not covering the project as proposed to the Corps, means that there is no valid federal consistency.  A 2014 Water Quality Certificate that does not cover any dredge or fill operation likewise prohibits the proposed mangrove island mitigation.  No trust land approvals further complete the lack of territorial authorization.