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Stop the Sand Mine

With a discontinuous clay layer, the surficial sands and the Floridan limestone aquifer function as one connected system. So when the ground was excavated deeply, the aquifer water rose directly into the pit from below.

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Clarification on Test Lab Geotechnical Materials

 

The geotechnical borings referenced on this site were performed by Test Lab, Inc. for Superior Construction, a construction firm involved in Suncoast Parkway activities, using Florida Department of Transportation (FDOT) design standards and specifications. The resulting boring location plans and soil profile sheets were compiled into FDOT-formatted project documents associated with the Suncoast Parkway Phase 3A project (FPID 442764-2-52-01). Test Lab has advised us that the borings were not commissioned directly by FDOT.

 

These materials later appear in the Southworth Environmental Resource Permit (ERP) record. Our concern remains focused on the documented subsurface conditions and risks reflected in the data, as well as the lack of transparency in how roadway-oriented geotechnical work has been repurposed within the mining permit process.

 

 

How These Geotechnical Materials Were Used in the ERP Review at the Southworth Borrow Pit Site — and Why They Did Not Resolve the Deficiencies

 

The Test Lab geotechnical borings referenced on this site were not part of the original Southworth ERP application. A geotechnical report dated March 3, 2025—prepared by Test Lab, Inc. for Superior Construction using FDOT design standards—was introduced into the ERP record on August 11, 2025, as part of a response to a Request for Additional Information (RAI) issued by the Southwest Florida Water Management District (SWFWMD).

 

SWFWMD’s RAI required the applicant to demonstrate compliance with ERP Applicant’s Handbook Vol. II §5.4.1, including maintaining required separation between excavation depth and underlying limestone, avoiding excavation into clay or aquitards in karst areas, and addressing potential groundwater impacts associated with the proposed borrow pit.

 

Rather than conducting a mining-specific geotechnical investigation, the applicant relied on the previously prepared Test Lab report and associated boring location plans, materials originally developed for roadway-related purposes, to respond to these mining-specific requirements.

 

However, in a follow-up letter dated September 10, 2025, SWFWMD determined that the application still lacked critical information. The District identified unresolved issues including:

• Insufficient separation between the proposed excavation depth and underlying limestone, contrary to ERP Applicant’s Handbook Vol. II §5.4.1;

• The potential excavation into clay layers in a karst setting, where breaching an aquitard is not permissible;

• Significant variability in subsurface conditions and seasonal high groundwater levels across the site, triggering the need for groundwater mounding, seepage, and post-development water-level analysis;

• The need to reassess stormwater routing and retention assumptions based on unresolved groundwater conditions.

In other words, the geotechnical data submitted on August 11, 2025 did not resolve the ERP deficiencies. Instead, the data revealed additional conflicts with ERP standards that remain unaddressed.

This sequence underscores our concern that roadway-oriented geotechnical work has been retroactively applied to a mining permit without a mining-specific investigation capable of demonstrating compliance with Florida’s environmental protection rules.

12/7/25  FDOT / Political /  Mike Arnold Rebuttal

Groundwater Breach, Not Stormwater:

The Facts Behind the October 24th Excavation Collapse

 

It’s hard to find much truth in Mike Arnold’s Citrus Chronicle article, “State: Flooded Excavator was working in a permitted stormwater pond, not unapproved borrow pit,” published December 4, 2025. Mr. Arnold did not even identify the Southworth sand mine location correctly (see SWFWMD inspector map). The actual site is on the right side of the SunCoast Parkway, only a few hundred feet from the excavation and ground-collapse incident. Mr. Arnold also repeats the claim that a “SWFWMD inspector… found no signs of illicit digging at the unpermitted borrow pit.” Yet these are the only detailed comments made by the inspector:

• “Was unable to find signs of construction activity on the borrow pit parcel, or related to the borrow pit.”

• “The excavator ‘hole’ was within the SunCoast Parkway permit area and is related to pond 3-3B.”

• “Photos in relation to the ‘excavator hole’ in question. Water was not blue or clear. Location on map shows the photos in relation to the borrow pit permit area.”

These minimal observations, without analysis, findings, or professional conclusions, are not evidence of anything. Yet the article presents them as if they resolve the groundwater breach.

Even more concerning, the individual who conducted the initial site inspection was not equipped to make professional determinations about whether this incident involved stormwater, groundwater, or aquifer exposure. On December 1, 2025, a Stop the Sand Mine representative spoke directly with the inspector, who stated that he is not an engineer, does not have hydrology experience, and indicated that he likely should not be discussing the matter. In contrast, SWFWMD has since publicly stated that “the initial inspection was conducted by a compliance inspector trained in stormwater best management practices, hydrology, geology and engineering science, followed up by involvement from ERP compliance engineering staff.” To date, the District has released no formal technical evaluation, findings, or analysis supporting its conclusions regarding the source of the water or the hydrogeologic implications of the collapse.

 

To date, SWFWMD has not identified any engineer who conducted an on-site investigation, nor released any written technical analysis, modeling, or findings prepared by ERP compliance engineering staff related to this incident.

 

Why did SWFWMD’s site inspection occur more than two weeks after the October 24 collapse, when no contractors appeared to be working, no active construction activity was evident, and all heavy equipment appeared to have been removed? The inspection report prepared by Chase Wagner is dated November 7, 2025. Regardless of the precise inspection date, the photographs included in the report show no vehicles, personnel, or active construction anywhere on site. This raises a fundamental question: were these photographs taken by the inspector during a site visit, or were they provided to SWFWMD by another party? The absence of any visible on-site activity at the time the photos were taken underscores the limited evidentiary value of the inspection and highlights the lack of timely, direct observation following a serious excavation and groundwater incident.

What is even more troubling is that the Chronicle article mirrors almost word-for-word the same narrative now being repeated publicly by elected officials. When incomplete or inaccurate reporting aligns with political talking points, the public is left with the false impression that the groundwater breach has been properly investigated. It has not. Instead, the seriousness of the event is minimized while key technical facts documented by agencies themselves are ignored.

This is why it is essential that elected officials receive the full and accurate record, not the simplified narrative presented in the Chronicle.

SWFWMD spokesperson Martinez Tarokh stated that “the water surge that overtook the machine was not a groundwater blowout, but the result of work within an approved stormwater pond footprint.”

But stormwater cannot surge upward from the bottom of a 10–20-foot excavation with no rainfall. The explanation offered by SWFWMD is physically inconsistent with what occurred on October 24.

 

FACTS

• There was no rainfall during or before the collapse.

• Accident photographs show water rising from the bottom of the excavation, not flowing in from the sides.

• Excavation walls show sloughing and collapse, consistent with groundwater inflow under hydraulic pressure.

• The pit filled and remained full for weeks, even without rain.

• FDOT requested a new well three days after the accident, approximately 650 feet away.

New wells are typically installed for groundwater monitoring, water-quality evaluation, or drawdown assessment following incidents involving potential aquifer impacts, particularly in karst terrain where preferential flow paths may exist.

We are also concerned by the presence of tankers drawing water from this well. SWFWMD has told us that no Water Use Permit exists for this withdrawal, and we are confirming that information.

• Juan Cardenas, P.E., project manager for Superior Construction, confirmed in writing that the excavation filled with groundwater after the excavator became stuck. This was “expected,” he wrote, because the excavation bottom was at elevation 0 to –1 feet, while groundwater in that area typically lies between 3 and 4 feet.

This confirms the excavation penetrated below the local water table, allowing groundwater to flow directly into the pit—a clear hydrologic interaction, not a stormwater event.

While Stop the Sand Mine understands the long-range plan may ultimately designate this area as a “drainage basin,” it is not plausible that the October 24 excavation was part of a “stormwater pond footprint,” as claimed. A pond footprint is not a pond, and nothing about this excavation matches stormwater-facility construction.

 

In reality, FDOT was not excavating a stormwater pond or drainage basin at this location. The evidence is clear:

• Legitimate drainage basins do not have vertical 10–20-foot walls; they have gentle 3:1 or 4:1 slopes (documented by the Citrus County Department of Health).

• There was no stormwater infrastructure present.

• There was no liner, berm, embankment, or preparation for water storage.

• The land was dry upland sand prior to excavation.

• The photographs do not resemble a drainage basin under construction.

For these reasons, we reject the misleading narrative being promoted by FDOT, SWFWMD, and political leaders who have repeated these claims without verifying the facts.

Stop the Sand Mine does not dispute that the incident occurred within FDOT’s right-of-way under an existing SunCoast permit. However, FDOT is not operating under the “higher standard” it frequently claims. FDOT has repeatedly stated, including in the 2024 SEIR, that a federal §404 permit was “obtained.”

This is not true.

FDOT does not have a §404 permit.

FDOT proceeded under a No Permit Required (NPR) letter.

That NPR letter functioned as the mechanism by which FDOT avoided the only federal regulatory process that would have evaluated impacts to aquifers, springs, groundwater, and wetlands. As a result, FDOT is now moving forward with plans that would destroy Wetland H with no federal aquifer or groundwater analysis.

Wetland H is not an isolated case. More than 70 acres of wetlands along SunCoast Parkway Sections 3A and 3B have been dismissed as “isolated” and “non-jurisdictional,” leaving them without federal protection despite their location within an Outstanding Florida Spring Priority Focus Area.

The SWFWMD spokesperson quoted in the Chronicle also stated that the District would “not prepare a formal report beyond the photo documentation.” The entire response consists of five sentences and five photographs, three showing a deep water-filled pit and two showing its location. This does not constitute a meaningful investigation of a groundwater breach.

Even more concerning is SWFWMD’s coordination with the Florida Turnpike Enterprise (FTE). SWFWMD or FDEP should serve as the independent oversight authority for an incident involving potential aquifer exposure, not coordinate with the entities responsible for the excavation activity itself.

Neither agency appeared on site within days of the collapse. Instead, weeks later they issued minimal documentation that appears designed to quiet public concern rather than establish facts.

We still have no answers regarding water sampling:

• Why have water samples not been released publicly?

• Why were samples reportedly not shared with the Citrus County Department of Health?

• Why were samples collected by the contractor, rather than by an independent agency, as FDEP acknowledged?

Without transparency about when, where, and how samples were collected, the public cannot have confidence that they represent conditions at the incident site at all.

Stop the Sand Mine maintains that every appropriate avenue of evaluation must be undertaken for the Southworth property, including full review of the excavation and collapse incident in the same hydrogeologic setting. FDOT continues to pursue acquisition of this property with taxpayer funds despite numerous documented red flags in technical assessments associated with this project. Proceeding under these conditions represents a misuse of public resources and exposes taxpayers to significant future liabilities.

 

Geotechnical Context and Aquifer Connection

 

The Test Lab geotechnical borings referenced here were conducted by Test Lab, Inc. for an FDOT contractor using FDOT design standards and were incorporated into FDOT-formatted SunCoast Parkway project documents associated with FDOT Project ID 442764-2 (commonly used for Phase 3A).

 

FDOT project manager Anil Sharma confirmed at the October open house that FDOT did not evaluate alternative sand sources and that surplus material from a prior phase had already been sold. If FDOT now claims a sand shortage, the public deserves to know why those materials were not retained—and when FDOT entered the sand-mining business at all.

 

The Test Lab borings tied to the SunCoast Parkway project were taken within a few hundred feet of the October 24 collapse, directly adjacent to where groundwater was struck and the excavation filled from the bottom up.

 

With a discontinuous clay layer in this area, the surficial sands and Floridan limestone aquifer function as one connected system.

 

Based on Test Lab geotechnical data incorporated into SunCoast project materials, CES piezometer measurements, documented voids, and the bottom-up filling of the excavation, it is clear that the digging intersected a groundwater system already proven to be in hydraulic continuity with the Upper Floridan Aquifer. This was an aquifer breach, not stormwater.

 

The same karst-prone subsurface conditions documented beneath the collapse site are present beneath the Southworth/Crystal River borrow pit site. If the State intends to rely on this land and this data for SunCoast construction, then the same information must be used to evaluate aquifer interaction, groundwater pathways to Kings Bay and Crystal River, and contamination risk within this first-magnitude spring system.

 

This is one connected system, one connected project, and one connected risk.

 

Floridians should not be forced to finance a high-risk borrow pit that endangers our springs, aquifer, water supply, and community. We deserve transparency, science-based decision-making, and agencies that follow the law—not find ways around it.

 

 

Stop the Sand Mine Committee

Colleen Farmer, Chair – 518-637-6829

Tony Ayo, Co-Chair

David Bishop, Vice-Chair

stopthesandminecc@gmail.com

www.stopthesandmine.com

Stop FDOT from wasting taxpayer money to buy, build, or operate a sand mine in Citrus County

 

Protect Kings Bay, Our Aquifer, Our Springs and Our Water

 

The Southworth property can no longer be dismissed as a “private borrow pit” unrelated to the Suncoast Parkway. FDOT and the Florida Turnpike Enterprise (FTE) have been directly involved with this land as a primary sand source for the Suncoast Parkway expansion, and at the October open house FDOT publicly confirmed that it is purchasing this property. Even based on conservative estimates, we believe this acquisition could approach $22 million or more—a cost borne by Florida taxpayers.

 

 

Why FDOT’s Proposed Purchase of the Southworth Sand Mine /

Borrow Pit Is Not a Responsible Use of Public Funds

 

1. Documented Karst and Sinkhole Risk at the Southworth Site

 

Florida taxpayers are being asked to fund a borrow pit located in an area already documented as geologically unstable. A geotechnical report prepared by Test Lab, Inc. using Florida Department of Transportation (FDOT) design standards and incorporated into FDOT-formatted Suncoast Parkway project documents issued a clear warning regarding karst instability at this site:

 

“The site is underlain by limestone bedrock that is susceptible to dissolution and the subsequent development of karst features such as voids and sinkholes in the natural soil overburden… internal soil erosion and ground subsidence could affect mine expansion. It is not possible to eliminate future sinkhole-related problems — the owner must understand and accept this risk.”

 

 

 

2. Wetland H Is a Spring or Spring Seep

 

Wetland H is part of an approximately two-mile wetland system on this property. Wetland H scored 9 out of 10 in all categories of its Uniform Mitigation Assessment Method (UMAM) evaluation. UMAM is Florida’s standardized method for assessing wetland functions and determining impacts and mitigation requirements. The assessor acknowledged that Wetland H provides important groundwater recharge functions.

 

These high scores indicate optimal ecological condition and full wetland function.

 

A local Floridian described Wetland H as follows:

 

“Having grown up in Florida, when you wade into shallow ponds in hot months the water is like bath water. As I waded in here, the water was extremely cold, despite weeks without rain. The ground was heavily saturated in every direction. Vegetation was vibrant green, and wildlife use was obvious. The water was clear and fresh, with no stagnation or sulfur odors, meaning it was being actively replenished — spring-fed.”

 

Based on these observations and the technical record, we believe Wetland H is a spring or spring seep.

 

 

 

3. FDOT Bypassed Federal Aquifer and Wetland Protections

 

FDOT does not operate under a “higher standard” as it frequently claims. Without a §404 Clean Water Act permit—and relying instead on a No Permit Required (NPR) letter, FDOT is moving forward with plans that would destroy Wetland H without federal aquifer, spring, or groundwater evaluation.

 

The NPR letter functioned as the mechanism by which FDOT avoided the only federal regulatory process designed to protect aquifers, springs, and wetlands. The same approach is being used to dismiss more than 70 acres of wetlands along Suncoast Parkway Sections 3A and 3B as “isolated” and “non-jurisdictional,” leaving them without federal protection despite their location within an Outstanding Florida Spring Priority Focus Area.

 

 

 

4. Geotechnical Data and the Collapse Show One Connected Aquifer System

 

A geotechnical investigation completed in March 2025 by Test Lab, Inc. for an FDOT contractor, using FDOT design standards, included 35 borings on and around the Southworth property. The report was addressed to Juan Cardenas, P.E., Project Manager for Superior Construction, and states:

 

“The purpose of the exploration was to evaluate the encountered subsurface conditions to identify depths of select fill for use on FDOT projects, specifically as fill during construction of the nearby Suncoast Parkway.”

 

The boring location plans and report materials were compiled into FDOT-formatted Suncoast Parkway project documents labeled:

 

• “State of Florida Department of Transportation – Future Borrow Pit”

• FDOT Project ID 442764-2 (commonly used for Suncoast Parkway Phase 3A)

 

FDOT project manager Anil Sharma confirmed at the October 9 FDOT Open House that FDOT did not evaluate alternative sand sources and that surplus sand from a prior Suncoast phase had already been sold off. If FDOT truly faces a sand shortage, why was that surplus not retained? And when did FDOT enter the sand-mining business at all?

 

The location of these Test Lab borings matters.

 

They were taken within a few hundred feet of the October 24 excavation and ground-collapse incident, directly adjacent to where FDOT contractors struck groundwater and the pit filled from the bottom up.

 

With no protective clay layer, the surficial sands and the Floridan limestone aquifer function as one connected system.

 

It is because of the Test Lab geotechnical data incorporated into Suncoast project materials, Creative Environmental Solutions (CES) piezometer data, the absence of a confining clay layer, documented subsurface voids, and the bottom-up filling of the excavation that we know the digging intersected a groundwater system already proven to be in hydraulic continuity with the Upper Floridan Aquifer. This was an aquifer breach, not stormwater.

 

State agencies and elected officials can no longer ignore this reality.

 

The same karst-prone subsurface conditions documented beneath the collapse site are present beneath the Southworth/Crystal River borrow pit site. If the State intends to use this land and this geotechnical data for Suncoast Parkway construction, then that same data must be used to evaluate:

 

• How excavation interacts with the aquifer

• How groundwater pathways connect to Kings Bay and Crystal River

• How quickly contamination could spread in a first-magnitude Outstanding Florida Spring Priority Focus Area

 

This is one connected system, one connected project, and one connected risk to our springs, aquifer, and community.

 

 

 

5. FDOT Does Not Have a §404 Water Permit

 

A §404 Clean Water Act permit is the cornerstone of wetland and water-resource protection. It is the only process that requires:

 

• Hydrogeologic analysis

• Aquifer–spring connectivity review

• Groundwater modeling

• OFS/PFA protection review

• EPA and U.S. Army Corps oversight

• Selection of the Least Environmentally Damaging Practicable Alternative (LEDPA)

 

FDOT did not obtain a §404 permit. Instead, the Florida Department of Environmental Protection issued a No Permit Required (NPR) letter, which provides none of these protections.

 

FDOT treated the NPR letter as if it were a §404 permit, effectively eliminating the only federal review process that would have evaluated the exact type of excavation failure that occurred on October 24.

 

This is not a minor misunderstanding—it goes to the heart of aquifer and spring protection in the Kings Bay Outstanding Florida Spring Priority Focus Area.

 

 

Closing Statement

 

FDOT is asking Florida taxpayers to fund the purchase, development, and operation of a sand mine in one of the most hydrogeologically vulnerable areas in the state—an area already documented to contain karst, voids, shallow groundwater, spring-fed wetlands, and direct hydraulic connection to the Upper Floridan Aquifer.

 

Yet FDOT continues to move forward without a §404 permit, without federal oversight, without groundwater modeling, and without the protections required for an Outstanding Florida Spring Priority Focus Area. By relying on a No Permit Required letter, FDOT bypassed the only regulatory process designed to prevent the type of aquifer breach that has already occurred.

 

Floridians should not be forced to finance a high-risk borrow pit that endangers our springs, aquifer, water supply, and community. We deserve transparency, science-based decision-making, and assurance that state agencies are following the law—not finding ways around it.

 

For all of these reasons, we urge FDOT and FTE to halt any planned purchase of the Southworth sand mine, reevaluate environmental risks under a proper §404 review, and protect Kings Bay, Crystal River, and Citrus County before irreversible harm is done.

 

Stop FDOT from wasting taxpayer money.

Protect our springs, our aquifer, and our community.

 

 

Red circle above shows location of Excavator Incident and water levels found at each boring sample.

Apparent disregard and disrespect of this once Pristine Priority Focus Area. This site is connected to our drinking water and feeds Kings Bay as well. Where $$$,$$$ has been spent on clean up.

Ariel view of excavator incident location - appears to be a breach of the Spring/Aquifer as water continues to rise and fall with the Aquifer. Clearly not a case of water "Runoff".

Conveyor submerged in what appears to be a spring/aquifer breach, not water run-off. If there was standing water on this site it would have filled the pit as it was dug. It appears the pit was dug and then filled with water from the bottom when the Spring/Aquifer was penetrated. Exactly what the scientific data and research showed would happen and will continue to happen in this PFA.

Water appears to have entered this site from the bottom of the excavation site, Not conceivable as water run off, as claimed by FDOT. Surrounding soils and excavated sand piles show no evidence of water runoff.

The Excavator sat submerged in the breached Spring/Aquifer from 10/24/ 25 until 11/4/25, (11 Days later) after possible contamination from fuels and oils. The water level remains consistent despite claims made by FDOT that it is water runoff, but that is not likely especially during a period of little to no rain.

FDOT Misled the Public and

Subverted the Process in the Southworth Borrow Pit Deal

Citrus County residents fighting the proposed Southworth borrow pit say Florida’s Department of Transportation (FDOT) misled the public about its plans to purchase and mine the Southworth site. What officials called a “new review” had already been underway 8 months ago. FDOT continues to work behind the scenes to advance a denied mine project, and is now poised to purchase and spend millions of taxpayer funds on this land riddled with sinkhole and aquifer risks. The full timeline and documentation are presented below.

The Public Was Told One Thing, The Record Shows Another

At an October 9, 2025 FDOT open house, officials told residents that evaluation of the Southworth site was just beginning and would take 30–60 days. FDOT claimed it had no prior material information on the property.

 

But records prove otherwise:

• March 3, 2025 – FDOT’s consultant TestLab submitted a report addressed directly to FDOT, stating:

“This report explains our understanding of the project and provides a description of the site, the subsurface conditions encountered and presents our conclusions regarding depths of

select fill for Florida Department of Transportation (FDOT) purposes/projects.”

The detailed report of the Southworth borrow pit warns the site is underlain by limestone bedrock that is susceptible to dissolution, karst terrain, sinkhole risk, and direct aquifer

connection — exactly the vulnerabilities residents have warning about.

• April 18, 2025 – A TestLab report addressed to Mr. Southworth was filed in the ERP record. The maps in the report were for FDOT, and the property was already labeled a “Future Borrow

Pit.” This raised questions whether FDOT was quietly helping advance Southworth’s ERP application.

• August 11, 2025 – The March 3 FDOT-addressed report surfaced publicly for the first time in the ERP file. Until then, the public had no access to it. Residents say it was buried among

multiple uploads.

 

August 12, 2025 – County Attorney Announces Eminent

Domain Before It Was Filed

On the morning of the BOCC land-use hearing, the applicant’s attorney requested a last-minute continuance, forcing the County to cancel the hearing. 

 

After the meeting, County Attorney Denise Dymond Lyn told several individuals that the State had taken the property by eminent domain. She made this statement before FDOT had actually filed paperwork (filed the next day, August 13). She also never clarified which parcel was taken, leaving the public to believe the borrow pit itself had been seized. 

 

In residents’ view, this was no accident. On May 27, 2025, FDOT District 7 Secretary Justin Hall had already told the BOCC that FDOT had the authority to take the property by eminent domain. 

Lyn's premature statement appeared to confirm that warning and left the impression that the fight was already over. 

 

The reality: the eminent domain filing applied only to adjacent parcels, not the borrow pit. But residents had no way of confirming this for weeks. During that time, the Southworth ERP continued to advance under a private applicant — even though the land-use change was canceled and never rescheduled.

Key Question: Is it even legal for the Southworth ERP to continue advancing when the land-use change it depends on has no date to be continued or heard?

June 27, 2025 – Special Master Finds Project Violates

County Policy

On June 27, 2025, the Citrus County Special Master recommended denial of the Southworth mine/borrow pit, citing Policy 17.13.4 because the site cannot be restored to its pre-mining type, nature, and function (the applicant’s own expert testified it would become a lake, not a reclaimed system).

This local finding is pivotal: a project that cannot meet County restoration policy also undercuts ERP consistency under F.A.C. 62-330.301 (public interest/compliance), making subsequent

efforts to advance the ERP or state purchase even more problematic.

____

September 23, 2025 – Procedural Loophole: A Shift From

Denial to Purchase

On September 23, 2025, Citrus County quietly adopted Resolutions 2025-070 through 072, authorizing unelected staff to sign permits and agreements with FDOT, SWFWMD, and FDEP —

without public hearings, without BOCC approval, and without the County Seal.

These sweeping resolutions were passed with little public notice of their implications. They empowered staff to execute “any and all instruments in connection” with permits, certifications, or approvals involving these three agencies — even for controversial or legally unresolved projects.

The timing is critical. Just weeks earlier, the August 12 BOCC hearing on the Southworth land-use change had been canceled under confusing circumstances, initially leaving the public with the impression the project was over. In reality, the ERP was still active under a private applicant — when the resolutions were passed citizens were highly concerned that the resolutions now provided a new pathway for coordination to continue behind the scenes.

By September, neighbors had already seen FDOT and Turnpike Enterprise staff on or near the Southworth property. At the October 9 open house, FDOT’s Teresa Driskell went further,

stating the ERP was “set to be approved.” That statement raised an obvious question: if the Southworth ERP was on track, why did FDOT need to buy the property at all?

Residents believe the answer is simple:

Southworth, the County, and FDOT all realized the land-use change could never survive

public opposition or legal challenge. Eminent domain bought time, while a private sale was arranged for the rest. The BOCC resolutions created the cover needed to finalize it — without

BOCC votes, without transparency, and without public scrutiny. This sequence of events is outrageous. Instead of transparency, it appears FDOT, SWFWMD, FDEP, and Citrus County all played a role in shifting this project behind closed doors. What should have been an open decision about one of Citrus County’s most sensitive aquifer recharge zones was handled in a way that silenced opposition, avoided responsibility, and eroded public trust.

October 10 Open House Raises More Questions Than Answers

At the October 10 FDOT open house, residents were well prepared and pressed the agency on critical issues: the spring and spring-seep misclassified as “Wetland H,” the hydrogeological connection to the aquifer, how much sand is actually needed, and why the Phase 2 surplus was sold off rather than reserved for Phase 3A — among many other questions.

Instead of clear answers, residents say they were shuffled from table to table — told one person could only answer about “construction,” another about “environmental,” another about

“procurement.” No one could give a full, accountable response.

When residents asked who made the decision to purchase the Southworth property, they were told only that “they” had made the decision — “a board or a group” — but no one could name

who “they” actually were.

A few things did become clear:

• FDOT has never purchased another borrow pit along the Suncoast Parkway.

• FDOT admitted it did not look at any alternative locations; the Southworth site was chosen simply because it was said to be the “most convenient” for trucking sand.

• There was a documented sand surplus in Phase 2, and FDOT allowed contractors to sell that material off. Why wasn’t it reserved for Phase 3A if there was such a shortage?

• Residents also asked: what do the mass diagrams and cut/fill calculations for Phase 3A show?

Instead of answers, residents were told multiple times — and shown diagrams — that FDOT was now in a “30–60 day review” of the property because they supposedly “did not have any

detailed information yet.”

The contradiction is glaring: FDOT said in October they were “just beginning” to evaluate the Southworth property, but the agency had already been in possession of very detailed

geotechnical reports since March.

FDOT’s Duty to Bid and Justify Purchases Florida law and FDOT’s own rules require transparency when taxpayer money is on the line:

• Florida Statutes, Chapter 287 requires competitive bidding for state contracts above certain thresholds, unless specifically exempt.

• FDOT Procurement Policy Manual requires competitive solicitation (Invitation to Bid, RFP, or ITN) for any purchase over $35,000 unless exempt. 

• FDOT Right-of-Way Manual / Land Acquisition requires land purchases to be supported by independent appraisals and clear justification of the price. If FDOT is purchasing the Southworth property without a competitive process, without demonstrating a sand shortage, and without comparative analysis of alternatives, that raises two major red flags:

1. Procurement Transparency – Are statutory requirements for competitive solicitation being bypassed?

2. Valuation Justification – Even if this is treated strictly as a land acquisition, where is the appraisal and public purpose justification?

At the May 27, 2025 BOCC meeting, FDOT District 7 Secretary Justin Hall told commissioners that contractors had “been able to source the material” and that he “personally thinks the issue’s been addressed.”This statement undercuts the entire premise of a new borrow pit, if the material need was already met, why is FDOT paying out what residents moderately estimate could be a $22 million taxpayer-funded purchase for this site?

For residents, this raises a simple but urgent question:

 

How are we supposed to know what is true from FDOT? In May, the agency said there was no shortage. In October, it told the public there was. When answers change depending on the audience, accountability is lost.

FDOT’s own published policies make this contradiction even sharper.

The agency’s procurement and sustainability commitments emphasize transparency, environmental stewardship, and responsible investment of public resources.

Yet those principles appear ignored in the Southworth acquisition:

• Sustainability Commitments: FDOT’s Office of Environmental Management states: “FDOT shall prioritize avoidance of impacts to natural resources and promote mitigation hierarchy principles to minimize long-term environmental damage.” 

Choosing a site in a FEMA floodplain, a Priority Focus Area for the Kings Bay Outstanding Florida Spring, and with documented karst risks directly contradicts this mandate.

• Public Trust: The Florida Transportation Plan (FTP) calls for “efficient and responsible investment of public resources.” Yet this transaction lacks public disclosure of purchase price, justification of sand need, or updated environmental review.

_____

 

Why This Site Is the Wrong Place to Take Sand FDOT’s own consultant has already acknowledged the unavoidable risks of digging here. In its March 3, 2025 geotechnical report, TestLab warned: 

“The site is underlain by limestone bedrock that is susceptible to dissolution and the subsequent development of karst features such as voids and sinkholes… It is not possible to investigate or design to completely eliminate the possibility of future sinkhole related problems."

 

In any event, the Owner must understand and accept this risk.”Despite this, FDOT is moving to purchase a 344-acre borrow pit located in one of Florida’s most environmentally sensitive regions — an Outstanding Florida Spring Priority Focus Area (OFS/PFA), a Basin Management Action Plan (BMAP) zone, and a FEMA-designated Special Flood Hazard Area. Excavation here would cut directly into groundwater, destroy a spring-fed wetland, and drop the pit up to 10 feet below FEMA’s flood line with no flood protections in place. The Citrus County Special Master has already ruled the site cannot be restored under local policy. Residents stress that the aquifer risks will be more fully addressed separately, but even on the facts already in FDOT’s possession, this site is clearly unsuitable. Proceeding anyway not only ignores Florida’s spring protection laws — it undermines decades of restoration work and millions of dollars already invested to save Kings Bay.

_______

 

Southworth’s Long History with State Agencies Residents also question whether Southworth’s history with state agencies helped smooth the way:

• His company, Concrete Impressions of Florida, Inc. (CGC1518861), has worked with FDOT for more than 40 years and advertises its “favorable and valuable relationship with FDOT and its districts.” 

 

• In 2021, SWFWMD purchased a 589-acre “Southworth Tract” in

the Weekiwachee Preserve directly from George Southworth.

(Hernando Sun, Dec. 15, 2021) These are not isolated transactions — they show a long pattern of state agencies doing business with George Southworth. His company openly touts its “favorable and valuable relationship” with FDOT, and in 2021 SWFWMD paid to acquire nearly 600 acres from him for conservation. Residents argue this history matters because it raises the possibility of insider access and preferential treatment. The question is no longer whether Southworth had an easier path — but whether FDOT and other agencies are now bending rules, inflating prices, and bypassing oversight to help a long-time contractor and land seller.

Bottom Line

• FDOT possessed a detailed borrow pit site report months

earlier but told the public in October that review was “just

beginning.”• The County Attorney announced eminent domain before it was

legally filed, misleading residents.

• The Special Master already ruled the site violates County restoration policy and cannot be reclaimed.

• BOCC resolutions eliminated transparency, allowing coordination outside of public view for behind-the-scenes coordination between FDOT, SWFWMD, FDEP, and Citrus County staff.

• FDOT’s own leadership (Justin Hall May 27, 2025) stated there was no need for more sand — undercutting the entire justification for a new borrow pit, but later FDOT stated the opposite.

• Taxpayers now face what could be a multi-million dollar purchase in a floodplain for land riddled with sinkhole risk, aquifer vulnerability, and floodplain hazards.

• Southworth’s long history of lucrative transactions with state agencies raises troubling questions of favoritism and insider access.

Closing Statement 

Residents say this site is too environmentally fragile, too procedurally flawed, and too dangerous to the aquifer and springs to justify any public investment. What should have

been a transparent, science-based process has instead become a case study in how State agencies and the County subverted public oversight. We believe FDOT, SWFWMD, FDEP,

and Citrus County must be held accountable for their role in pushing this deal forward behind closed doors at the expense of both taxpayers and one of Florida’s most vulnerable

spring systems.

*Location Clarification – November 2025:

Recent review of FDOT right-of-way mapping (September 2023) and Citrus County Property Appraiser data indicates that the excavation site lies at or near the shared boundary between FDOT’s right-of-way and property listed under the George L. Southworth Revocable Trust.

 

We continue to verify boundary details as records are updated, but the environmental concerns remain unchanged: this work occurred within the Kings Bay Springshed, a floodplain and aquifer-sensitive zone, without a corresponding Environmental Resource Permit (ERP).

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For inquiries or to show your support, and to get on our mailing list, feel free to reach out to us. Together, we can make a difference.

OUR CAUSE

Our Water, Our Springs, Our Future. Say No to the Sand Mine.

If you mine here, you will change the water table. If you change the water table, you change the springs.  If you change the springs, you change Crystal River, Kings Bay, and the manatee habitat — forever

AWARENESS CAMPAIGN

Our awareness campaign aims to educate the public about the negative impacts the Sand Mine will have on our Equestrian Community.

COMMUNITY ENGAGEMENT

Engage with us through events, social media, and community activities to amplify our voices and protect our shared environment.

ADVOCACY EFFORTS

Our advocacy work involves interacting with local authorities and raising awareness to halt the approval of the harmful Sand Mine project.

Transparency Statement:

The Stop the Sand Mine Committee is a grassroots organization of concerned residents. We verify all information to the best of our ability through public records, field documentation, and official sources. Because this process and the facts on the ground have changed rapidly, we regularly update and amend our materials when new information becomes available.

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