THIS IS THE CRITICAL MOMENT

 

Eastern Borrow Site / Suncoast Parkway Phase 3A

 

We are now at a pivotal stage in the permit review process for the proposed Eastern Borrow Site (FDOT’s Sand Mine) connected to Suncoast Parkway Phase 3A.

 

Please visit our “How 2 Help” page for:
• step-by-step instructions,
• email addresses,
• a copy and paste email,
• key project facts,
• and simple points you can use in your own words.

Even short public comments matter.

The permit review process is happening NOW.

 

Please take just 10 minutes to make your voice heard by sending one email to the Southwest Florida Water Management District (SWFWMD) regarding the pending Environmental Resource Permit (ERP).

 

Your comments could help stop this project. We need decision-makers to see that Citrus County residents are paying attention and demanding denial of this permit to protect our aquifer, springs, wetlands, wildlife, private wells, and drinking water.

 

We truly can make a difference together.

 

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WHAT IS THE EASTERN BORROW SITE?

​

FDOT is seeking approval for a massive excavation project in Crystal River connected to Suncoast Parkway Phase 3A.

According to FDOT’s own submitted materials and the newly signed May 6, 2026 State Environmental Impact Re-Evaluation (SEIR), the proposed Eastern Borrow Site would:

• disturb approximately 344.9 acres

• excavate more than 5.1 MILLION cubic yards of material

• involve approximately 313 excavation acres

• directly interact with shallow groundwater

• route stormwater toward low-lying karst areas

• impact wetlands and floodplain areas

• disturb a sensitive springs recharge area connected to Kings Bay and Crystal River

• and affect approximately 342 potentially occupied gopher tortoise burrows, including approximately 258 active burrows

​

Combined with surrounding roadway disturbance, the total impacted area now approaches approximately 894 acres within this short 5.5-mile stretch of the Suncoast Parkway corridor.

 

WHY MANY RESIDENTS ARE CONCERNED

​

FDOT’s own documents acknowledge:

• direct infiltration into groundwater,
• shallow groundwater conditions,
• karst terrain,
• high infiltration soils,
• shallow limestone conditions in portions of the site,
• and limited protective separation above limestone.

​

This project is located within an Outstanding Florida Springs Priority Focus Area, one of Florida’s most environmentally sensitive groundwater regions.

​

Hydrogeologic evaluations for this same site identified hydraulic communication between groundwater systems, raising concerns about how excavation, groundwater interaction, and stormwater infiltration could affect connected aquifer systems, springs, wetlands, private wells, and downstream water resources.

 

Many residents are also concerned because:

• this excavation footprint appears substantially larger than earlier roadway-focused reviews,
• the same general site previously failed to advance as the Southworth / Crystal River Borrow Pit proposal,
• and FDOT’s current proposal now involves a significantly expanded excavation footprint at the same sensitive location.

 

WHY PUBLIC COMMENTS MATTER

​

SWFWMD is currently reviewing FDOT’s permit application and responses.

Public comments submitted NOW become part of the official permit record and help demonstrate that Citrus County residents are paying attention and demanding protection of:
• groundwater,
• springs,
• wetlands,
• wildlife,
• private wells,
• and the Kings Bay / Crystal River system.

Once permits are issued and excavation begins, many impacts may be difficult or impossible to reverse.

 

 

Below is our formal public comment submission outlining many of the environmental, groundwater, transparency, and permitting concerns identified within FDOT’s own submitted materials and the ERP record.

 

Comment One:

 

Please Include in Official Public Comment Records – FDOT May 7 Response Does Not Demonstrate Prior PD&E Review of Eastern Borrow Site

​

Dear Ms. Tolksdorf and Mr. Catts,

Please include this correspondence in the official public comment record for:

• SWFWMD ERP 43016897.016 / Application 935264 (Eastern Borrow Site)

• ERP 43016897.012 (original Suncoast Parkway Phase 3A roadway ERP)

 

Stop the Sand Mine is writing to address FDOT’s May 7, 2026 response to SWFWMD’s request for clarification regarding whether the PD&E study covers the limits of the Eastern Borrow Site.

SWFWMD asked FDOT to provide documentation demonstrating that the proposed borrow site is within the project limits of the prior PD&E review.

​

FDOT’s response still does not demonstrate that the Eastern Borrow Site was previously evaluated as part of the original roadway corridor. Instead, FDOT states that, “an additional reevaluation of this PD&E has been completed which includes the project site.”

​

That is a critical distinction.

​

The May 6, 2026 SEIR re-evaluation itself confirms that the Eastern Borrow Site is a newly added major design change, not merely an incidental roadway drainage feature. The SEIR states that the proposed construction of the borrow site will result in changes to land use and will be located on approximately 344.9 acres of currently undeveloped property adjacent to the Suncoast Parkway Phase 3A mainline limited access right-of-way.

​

The SEIR also identifies approximately 313 acres of excavation limits and more than 5.1 million cubic yards of embankment material. This is a major borrow excavation project, not simply a roadway feature within previously evaluated right-of-way.

​

FDOT’s May 7 response further confirms that no roadway stormwater is being routed or piped to the borrow site and that the roadway project’s permitted stormwater ponds will function independently of the borrow site. This reinforces that the Eastern Borrow Site is operating as a separate excavation and hydrologic system, not as part of the roadway stormwater treatment system.

​

The timing is also significant. The SEIR re-evaluation incorporating this borrow site was signed on May 6, 2026, only one day before FDOT’s May 7 clarification response. A newly completed May 6, 2026 re-evaluation does not demonstrate that the borrow excavation was evaluated under the original 1998 PD&E or prior roadway approvals. It confirms that FDOT is now attempting to incorporate a large, separate borrow excavation through a late-stage re-evaluation.

​

This matters because the Eastern Borrow Site involves approximately 344.9 acres of undeveloped land, major land-use change, expanded right-of-way needs, wetland impacts, floodplain/water-resource impacts, direct groundwater infiltration, and protected-species impacts. The SEIR documents approximately 342 potentially occupied gopher tortoise burrows within the project area, including 258 active burrows.

​

Accordingly, FDOT’s May 7 response should not be treated as resolving SWFWMD’s question regarding whether the prior PD&E review adequately covered this borrow site. The record shows that the Eastern Borrow Site was added later through a May 6, 2026 re-evaluation and should be reviewed as a separate major excavation activity with its own environmental, hydrologic, and public-interest impacts.

​

To be clear, we are not opposing the Suncoast Parkway itself.

​

At minimum, the current record demonstrates that significant questions remain regarding the scope of prior environmental review, hydrologic impacts, groundwater interaction, and the applicability of earlier roadway evaluations to the current borrow excavation proposal. Until those issues are fully resolved, it is difficult to conclude that the application presently provides the reasonable assurance required under SWFWMD ERP permitting standards.

​

The concern is whether this particular borrow excavation belongs in this location.

​

The current proposal would convert hundreds of acres of undeveloped land within a sensitive springs recharge area into a large excavation project designed to interact directly with shallow groundwater connected to the Kings Bay / Crystal River system.

​

Combined with surrounding roadway disturbance, the overall impact area now approaches approximately 894 acres within an identified Outstanding Florida Springs Priority Focus Area along this relatively short 5.5-mile stretch of the Suncoast Parkway corridor.

​

This is precisely the type of location where the public expects heightened scrutiny, transparency, and careful protection of Florida’s water resources.

​

Respectfully, the public deserves full, transparent and independent review before this excavation proceeds.

​

Colleen Farmer Chair and Tony Ayo Co-Chair,
Stop the Sand Mine Committee
stopthesandminecc@gmail.com

Email sent on May 11, 2026

 

Comment Two:

​

Formal Public Comment – Request for Independent Review and Heightened Scrutiny – Eastern Borrow Site ERP 43016897.016 / App. 935264 and ERP 43016897.012

May 13, 2026

 

Dear Ms. Tolkdorf and Mr. Catts

 

Please include this correspondence in the official record for:
SWFWMD ERP 43016897.016 / Application 935264
(Eastern Borrow Site / Suncoast Parkway Phase 3A) and ERP 43016897.012 (original Suncoast Parkway Phase 3A roadway ERP)

 

The proposed borrow excavation is located within a karst-sensitive Outstanding Florida Springs Priority Focus Area (OFS/PFA) connected to the Kings Bay / Crystal River springshed, where groundwater recharge, wetland hydrology, and subsurface connectivity are critical to regional water resources.

 

The following comments are submitted regarding:

 

• direct interaction between the proposed excavation and shallow groundwater

• wetland function

• hydrologic connectivity

• public-interest considerations

• legal-control issues

• and the adequacy of environmental review associated with the proposed Eastern Borrow Site excavation project

 

Recent 2026 FDOT materials, including the May 6, 2026 SEIR Re-Evaluation and May 8, 2026 Stormwater Management Design Report, now expressly characterize the Eastern Borrow Site as a separate large-scale borrow excavation project involving approximately 346 acres, approximately 313 excavation acres, and over 5.1 million cubic yards of excavation material within this karst-sensitive springs recharge setting connected to the Kings Bay / Crystal River system.

 

 

I. Prior Application History, Special Master Findings, and Site Continuity

 

The current Eastern Borrow Site application (SWFWMD ERP 43016897.016 / Application 935264) corresponds to the same physical location previously proposed under the Crystal River Borrow Pit ERP application (Application 912905), involving property owned by George L. Southworth / 3KS Family, LLLP.

 

The prior Crystal River Borrow Pit application was initiated March 4, 2025 and underwent extensive agency and local review over approximately one year.

 

Critically, during the June 27, 2025 quasi-judicial hearing, the Citrus County Special Master recommended denial of the proposed land use change based on Citrus County Comprehensive Plan Policy 17.13.4, which provides:

 

“Resource extraction which will result in an adverse effect on environmentally sensitive areas which cannot be restored shall be prohibited.”

​

(Citrus County Special Master Hearing – June 27, 2025).

​

The Special Master’s recommendation followed testimony from the applicant’s own expert during the prior Crystal River Borrow Pit proceedings acknowledging that the proposed excavation could not be restored to pre-mining conditions and would result in a permanent lake feature.

 

This finding established that the proposed excavation would result in permanent, non-reclaimable alteration of environmentally sensitive areas within this same site location.

​

Following that determination:

 

1. The application did not proceed to the Board of County Commissioners (BOCC)

 

2. The required local land-use approval was never obtained

 

3. The ERP application was subsequently withdrawn on February 23, 2026

 

Despite approximately one year of review, the application did not advance to final approval and was ultimately withdrawn, as unresolved environmental and land-use concerns remained associated with excavation at this location.

 

FDOT now proposes excavation within this same site area through the Eastern Borrow Site application while substantially expanding the proposed excavation footprint.

 

Importantly, FDOT’s own May 2026 materials now expressly characterize the Eastern Borrow Site as a separate large-scale borrow excavation project rather than merely incidental roadway disturbance. FDOT’s own SEIR materials further characterize the project as involving land-use change across currently undeveloped property adjacent to the roadway corridor.”

 

The May 6, 2026 SEIR Re-Evaluation states:

 

“The purpose of this re-evaluation is to document changes for the construction of a soil borrow pit adjacent to Suncoast Parkway Phase 3A.” (SEIR Re-Evaluation – May 6, 2026).

 

The same document further states:

 

“The proposed borrow site total project area is approximately 346 acres, with 313 acres of excavation limits, resulting in over 5.1 million cubic yards of suitable roadway embankment material.”

(SEIR Re-Evaluation – May 6, 2026).

 

FDOT’s current proposal therefore represents:

​

• a substantially expanded excavation footprint

• a substantial expansion of disturbance

• changed land-use impacts

• changed hydrologic interaction

• direct groundwater infiltration

• and materially different excavation activity from the originally evaluated roadway corridor.

​

This is particularly important because the Eastern Borrow Site is being advanced through a SEIR re-evaluation pathway tied to the original 1998 transportation corridor review, while simultaneously involving direct groundwater interaction and excavation within a karst-sensitive Outstanding Florida Springs Priority Focus Area connected to the Kings Bay / Crystal River springshed.

 

The continuity between the earlier Crystal River Borrow Pit proposal and the current Eastern Borrow Site review is further reflected by the inclusion of prior Southworth / Crystal River Borrow Pit pre-application meeting materials within the current Eastern Borrow Site ERP record.

 

The administrative record also reflects continuity in SWFWMD review of the same site area between the earlier Crystal River Borrow Pit proceedings and the current Eastern Borrow Site evaluation. The prior Crystal River Borrow Pit application did not advance to final approval following extensive review and unresolved environmental and land-use concerns associated with excavation at this location. The current ERP review therefore does not involve entirely new groundwater, excavation, or hydrologic concerns arising in isolation, but rather continuing review of substantially related excavation activities and hydrogeologic conditions within the same sensitive springs-recharge setting.

 

The current FDOT ERP 43016897.016 / Application 935264 (Eastern Borrow Site) record also reflects continuitywith earlier Southworth hydrogeologic evaluation materials, including overlapping CR24-series investigation points and hydrogeologic data associated with the same site area.

 

Within FDOT’s April 3, 2026 RAI response, Tierra states that it reviewed results from “temporary piezometers installed by others across the site made available to the Turnpike for use in the Turnpike’s design and permit.” FDOT’s later SHWT mapping materials include CR24-series investigation points that overlap with earlier Southworth hydrogeologic materials, including CR24-12 and CR24-13.

(Applicant Response to Request for Additional Information – April 3, 2026, Response 6b and Attachment 6b, “Locations of Estimated SHWT Levels.”)

 

The same site location was previously evaluated under the Crystal River Borrow Pit ERP materials by hydrogeologic expert George Foster, P.G., whose signed project materials acknowledged hydraulic connection between groundwater systems within the project area.

(Geotech-Hydro-Mitigation Plan – Crystal River Borrow Pit ERP materials pg.3).

​

This is particularly significant because FDOT’s current 2026 engineering documents now expressly describe the Eastern Borrow Site excavation as interacting directly with shallow groundwater within a karst landscape.

 

Together, these records indicate that the proposed excavation is not hydrologically isolated, but instead occurs within a groundwater-connected setting requiring careful independent evaluation of:

 

• Groundwater interaction

• Wetland function

• Cumulative impacts

• and potential effects to connected spring systems

 

Where a prior formal review identified permanent impacts within this same hydrogeologic setting, and the current proposal substantially expands the excavation footprint and scale of disturbance, heightened scrutiny regarding public interest, hydrologic connectivity, groundwater interaction, and cumulative spring-system impacts is warranted.

 

The Eastern Borrow Site also represents a substantial increase in overall disturbance associated with this relatively short segment of the Suncoast Parkway Phase 3A corridor. Based on current materials, the roadway and associated borrow excavation together involve approximately 894 acres of disturbance within an Outstanding Florida Springs Priority Focus Area connected to the Kings Bay / Crystal River system.

 

 

II. FDOT’s Current Materials Confirm Direct Groundwater Interaction and Karst Conditions

 

Project materials submitted by FDOT in 2026 expressly acknowledge that the proposed Eastern Borrow Site excavation is intended to interact directly with shallow groundwater within a karst-sensitive setting.

 

The Stormwater Management Design Report – Permit Submittal dated May 8, 2026 states:

 

“any runoff draining to the two depressional areas on site will infiltrate into the underlying soils and discharge directly into the groundwater table.”

 

(Stormwater Management Design Report – Permit Submittal, May 8, 2026, p. 4).

 

The same report further states:

 

“the groundwater table will be encountered at elevations ranging from approximately +5 to +10 feet, NAVD88.”

 

(Stormwater Management Design Report – Permit Submittal, May 8, 2026, p. 4).

 

The report also states:

 

“The area of Citrus County along most of the Phase 3A alignment is known for its karst topography and conditions…”

 

(Stormwater Management Design Report – Permit Submittal, May 8, 2026, p. 4).

 

 

In addition, the report states:

 

“The gradually sloping site also allows the proposed bottom to maintain a minimum 1-foot separation above the groundwater table…”

 

and

 

“…a minimum 3-foot separation from the limestone layer.”

 

(Stormwater Management Design Report – Permit Submittal, May 8, 2026, p. 4).

 

These statements are significant because FDOT is no longer merely discussing possible groundwater interaction.

 

Instead, FDOT’s own engineering documents expressly describe a large-scale excavation specifically designed to function in direct hydraulic relationship with shallow groundwater conditions.

 

The submitted materials therefore acknowledge:

 

• Direct infiltration into groundwater

• Shallow groundwater conditions

• Shallow limestone conditions

• Karst terrain

• and minimal vertical separation between excavation and groundwater

 

Additional subsurface materials submitted with the April 3, 2026 RAI response further identify:

 

• Seasonal high groundwater elevations ranging approximately from +4.7 to +9.6 feet NAVD88 throughout portions of the excavation footprint

• Groundwater encountered in temporary piezometers onsite

• Repeated limestone encounters across multiple borings

• Aquitard-associated soil strata identified as Soil Strata 3,4, or 5

 

(Applicant Response to Request for Additional Information – April 3, 2026; “Locations of Estimated SHWT Levels” and “Summary of Soil Boring Information” materials).

 

Together, these materials indicate that groundwater interaction is not incidental to the proposed excavation, but instead represents a central component of the excavation design itself.

 

This continuity is particularly significant in light of earlier hydrogeologic findings prepared for the same site area within the prior Crystal River Borrow Pit application materials.

 

The February 22, 2025 CES Geotechnical Summary / Hydrogeological Summary / Ground Mitigation Plan, prepared for George L. Southworth and signed by expert George K. Foster, P.G., is directly relevant because it evaluated the same site area for mining-related aquifer impacts. The report states that its purpose was to “establish the hydrogeological setting of the site” and evaluate potential onsite and offsite impacts on the underlying aquifer resulting from mining operations. Under the hydrology discussion, the CES report states that water levels in the piezometers were similar to those predicted for the Floridan aquifer and concludes: “This suggests the two aquifers are in hydraulic communication.” The report further states that this conclusion was supported by borings that penetrated sand and then limestone, with “no intervening clay (or low permeability soils).”

(Geotechnical Summary / Hydrogeological Summary / Ground Mitigation Plan, Creative Environmental Solutions, Inc., prepared for George L. Southworth, February 22, 2025, p. 4.)

 

That finding is significant because clay or other low-permeability material is what normally helps provide separation between surface infiltration, shallow groundwater, and deeper aquifer systems. FDOT’s later Eastern Borrow Site materials likewise identify shallow groundwater, karst terrain, limestone encounters, and multiple borings across the proposed excavation footprint where aquitard-associated soils were either absent, discontinuous or not encountered. FDOT’s April 3, 2026 RAI response also includes CR24-series investigation points that appear to overlap with earlier Southworth site investigation points, including CR24-12 and CR24-13.

(Applicant Response to Request for Additional Information, April 3, 2026, Attachment 6C, “Summary of Soil Boring Information in relation to SWFWMD ERP Handbook Vol. I Section 8.5.2”; “Locations of Estimated SHWT Levels.”)

 

The continuity between the earlier Southworth hydrogeologic evaluation and the current FDOT Eastern Borrow Site review is further reflected by overlapping subsurface investigation identifiers within the record. The February 22, 2025 CES hydrogeologic materials for the Crystal River Borrow Pit identify CR24-series investigation points, including CR24-12 and CR24-13, with associated coordinates and piezometer installations. FDOT’s later April 3, 2026 “Locations of Estimated SHWT Levels” materials likewise identify CR24-12 and CR24-13 within the Eastern Borrow Site investigation record, together with additional CR24-series points, SB borings, and HA borings. These overlapping identifiers support continuity between the earlier Southworth hydrogeologic investigation and the current FDOT excavation review.

(Geotechnical Summary / Hydrogeological Summary / Ground Mitigation Plan, Creative Environmental Solutions, Inc., February 22, 2025; Applicant Response to Request for Additional Information, April 3, 2026, “Locations of Estimated SHWT Levels.”)

 

Taken together, these records raise serious questions regarding whether stormwater directed into sandy soils at this location is adequately separated from underlying aquifer systems.

 

Technically, this raises concerns about reduced hydraulic separation between surface infiltration, shallow groundwater, and the Floridan aquifer. In plain terms, where sand lies directly over limestone with little or no protective clay layer, directing runoff into the groundwater can function more like an open sieve into the aquifer than a protected filtration system.

 

This is especially important because FDOT’s own May 8, 2026 Stormwater Management Design Report – Permit Submittal states that runoff will infiltrate into underlying soils and discharge directly into the groundwater table, while also acknowledging that the project area is located in known karst conditions. (Stormwater Management Design Report – Permit Submittal, May 8, 2026, p. 4.)

 

This is particularly important because the proposed excavation is located within an Outstanding Florida Springs Priority Focus Area connected to the Kings Bay / Crystal River springshed, where groundwater recharge and subsurface connectivity are critical to regional water resources.

 

This is also directly relevant to surrounding communities that rely heavily on groundwater and private wells for drinking water. FDOT’s own materials state that runoff from the excavation area is intended to infiltrate directly into the groundwater table within a karst-sensitive setting involving shallow limestone and reduced confining separation in portions of the site. In areas where groundwater systems are closely connected, disturbances affecting recharge and groundwater quality are not merely theoretical concerns, they are directly relevant to the water resources relied upon by nearby residents. This is particularly important in an area where many residents rely upon private wells drawing from groundwater systems connected to the regional aquifer.

 

Under these circumstances, careful independent evaluation of groundwater interaction, wetland function, hydrologic connectivity, and cumulative impacts is warranted rather than reliance solely on prior roadway assumptions or applicant characterization.

 

Importantly, FDOT’s later 2026 engineering materials associated with the Eastern Borrow Site appear consistent with the earlier hydrogeologic concerns identified within the prior Southworth / Crystal River Borrow Pit evaluation for this same site area regarding shallow groundwater interaction, limestone proximity, and reduced confining separation within portions of the excavation area.

 

 

III. Wetland Identification, Hydrologic Function, and Need for Independent Review

(Cyrus Street Wetland 3, Eastern Borrow Site/Sacramento Ave Wetland 3 & Wetland H)

 

The administrative record reflects the use of the designation “Wetland 3” to identify two different wetland features within the Suncoast Parkway Phase 3A permitting materials.

 

Clarification of these features is important to ensure that prior environmental analyses, wetland evaluations, jurisdictional assumptions, and hydrologic conclusions are being applied to the correct wetland systems and locations.

 

A. Original Roadway Wetland 3 (Cyrus Street Wetland 3)

 

Within the original roadway ERP application (ERP 43016897.012 / Application 893678), the first identified Wetland 3 is described as:

 

• Approximately 0.40 acres

• FLUCCS 617 / 6170

• Located south of W Cyrus Street and west of N Donovan Avenue

 

The feature is further described within the April 2024 Ecological Assessment Report prepared by DRMP, Inc. as an isolated mixed wetland hardwood system exhibiting:

 

* saturated soils

* standing water during assessment

* buttressing at the base of oaks

• water staining on vegetation

 

(Ecological Assessment Report – Suncoast Parkway 2 Segment 3A, April 2024, p. 8).

 

B. Eastern Borrow Site Wetland 3 (Sacramento Ave Wetland 3) & Wetland H

 

Within the current Eastern Borrow Site application (ERP 43016897.016 / Application 935264), a different feature is identified as  a second Wetland 3 within the proposed borrow-site excavation footprint near N Sacramento Avenue / W Cavalry Lane.

 

Based on overlapping mapped location, acreage, wetland characteristics, and prior ERP materials, the current Eastern Borrow Site Wetland 3 corresponds to the feature previously identified as Wetland H within the earlier Crystal River Borrow Pit application materials. For clarity, this feature will be referred to herein as Wetland 3/H.

 

This wetland feature is identified within the current ERP materials as:

 

* approximately 1.86 acres

* FLUCCS 641 freshwater marsh

• included within approximately 2.48 acres of wetland impacts associated with the proposed excavation area

• Located near N Sacramento Avenue / W Cavalry Lane

(ERP 43016897.016 wetland impact tables and location maps).

 

 

The term “Wetland 3” does not refer to a single continuous feature across the Suncoast Parkway records.

 

The original roadway Wetland 3 (“Cyrus Street Wetland 3”) and the current Eastern Borrow Site Wetland 3/H aredifferent wetland systems located in different portions of the project area.

 

Because the same wetland designation is being used across related permitting materials for different wetland systems, independent verification is necessary to ensure that:

 

1. prior jurisdictional assumptions are being applied to the correct feature

2. wetland scoring and classification changes are accurately tracked

3. hydrologic conclusions are based on current site conditions

4. and groundwater-connected wetland functions are not overlooked within this karst-sensitive setting

 

The distinction between these wetland systems is particularly important where hydrologic assumptions regarding isolation may affect evaluation of groundwater interaction, recharge function, and jurisdictional assumptions and related regulatory conclusions within this karst-sensitive setting.”

 

 

C. Documented Wetland Function and Groundwater-Recharge Characteristics

 

The October 21, 2024 wetland 3/H evaluation prepared by Clark Hull

classified the feature as a PEMC1 freshwater marsh, identified groundwater recharge as a wetland function, and assigned the wetland high UMAM scores of 9/10 within all three rated categories.

 

A subsequent August 29, 2025 evaluation prepared by Brady Hart likewise identified freshwater marsh characteristics and specifically identified the wetland as providing:

 

• groundwater recharge

• Water quality functions

• Nutrient cycling

• and wildlife habitat

(Wetland Evaluations dated October 21, 2024 and August 29, 2025 for wetland 3/H).

 

These listed functions inherently depend upon hydrologic interaction with surrounding soils, shallow groundwater, or connected hydrologic systems.

 

The October 21, 2024 Clark Hull wetland evaluation and associated UMAM materials were submitted within the earlier Crystal River Borrow Pit ERP record. The later August 29, 2025 Brady Hart evaluation was subsequently included within the current Eastern Borrow Site review materials involving the same wetland feature and site area.

 

 

 

D. Persistent Hydrologic Indicators

 

Following extended dry conditions, including periods before and after the Brady Hart reevaluation of Wetland 3/H during which little to no meaningful rainfall reportedly occurred, field observations conducted September 21, 2025 documented:

 

• Persistent standing water

• Saturated organic soils

• Dark organic sediments

• Cold water conditions despite the summer heat

• And sustained wetland vegetation within the marsh feature

• Unusually clear, fresh-appearing water conditions

• No stagnation or sulfur-type odors

 

The field observer described these conditions as consistent with persistent groundwater-supported recharge and expressed the opinion that the feature appeared spring-fed or seep-influenced.

(Field observations and photographs dated September 21, 2025 pictures provided).

 

The presence of standing water and saturated soils during notably dry conditions is significant because it suggests persistent hydrologic support rather than solely short-term stormwater ponding.

 

This is particularly important where FDOT’s own 2026 engineering documents now expressly acknowledge that:

 

• stormwater runoff from the excavation area is intended to infiltrate directly into groundwater

• Shallow groundwater elevations occur throughout portions of the excavation footprint

• The project area is located within karst terrain

• and excavation is designed with minimal separation above groundwater and limestone conditions

 

(Stormwater Management Design Report – Permit Submittal, May 8, 2026, p. 4; Applicant Response to RAI – April 3, 2026, “Locations of Estimated SHWT Levels” and boring summary materials).

 

In late October 2025, an excavation incident reportedly occurred adjacent to the proposed borrow-site area within FDOT right-of-way, where water entered and remained within the excavation area for an extended period. Shortly afterward, a new well request was made and groundwater withdrawals were reportedly observed for construction-related water use.

 

While causation cannot be established from these observations alone, the chronology raises reasonable questions regarding whether excavation activity, groundwater withdrawal, altered drainage, or subsurface hydrologic changes may have influenced later observations that portions of Wetland 3/H appeared substantially drier by January 2026.

 

Together, the available record does not support simplistic assumptions that the wetland system is functionally isolated from surrounding groundwater conditions.

 

E. Need for Independent Evaluation

 

Given the documented groundwater recharge function, persistent hydrologic indicators, field observations suggesting possible seep or groundwater influence, karst conditions, and direct groundwater interaction acknowledged within FDOT’s own engineering materials, careful independent evaluation under Section 404 is warranted rather than reliance solely on applicant-provided characterization.

 

 

IV. FDOT’s Current Materials Confirm a Separate Large-Scale Excavation Project

 

FDOT’s own 2026 materials characterize the Eastern Borrow Site as a newly defined, large-scale borrow excavation project involving substantial excavation activity beyond the originally permitted roadway footprint.

 

The May 6, 2026 SEIR Re-Evaluation states:

 

“The purpose of this re-evaluation is to document changes for the construction of a soil borrow pit adjacent to Suncoast Parkway Phase 3A.”

(SEIR Re-Evaluation, May 6, 2026).

 

The same document further states:

 

“The proposed borrow site total project area is approximately 346 acres, with 313 acres of excavation limits, resulting in over 5.1 million cubic yards of suitable roadway embankment material.”

(SEIR Re-Evaluation, May 6, 2026).

 

These descriptions are significant because FDOT itself now characterizes the Eastern Borrow Site as:

 

• A large-scale borrow excavation project

• Involving hundreds of acres

• Involving millions of cubic yards of excavation

• and requiring design change re-evaluation

 

This is not merely incidental roadway drainage or minor construction activity.

 

FDOT’s own SEIR materials further characterize the project as involving land-use change across the currently undeveloped property adjacent to the roadway corridor.

 

Rather, the current record reflects a substantial excavation project specifically intended to function in direct interaction with shallow groundwater conditions within a karst-sensitive Outstanding Florida Springs Priority Focus Area connected to the Kings Bay / Crystal River springshed.

 

FDOT’s own May 8, 2026 Stormwater Management Design Report further states:

 

“any runoff draining to the two depressional areas on site will infiltrate into the underlying soils and discharge directly into the groundwater table.”

(Stormwater Management Design Report – Permit Submittal, May 8, 2026, p. 4).

 

The same report acknowledges:

 

• shallow groundwater elevations

• karst terrain

• minimal separation above groundwater

• and shallow limestone conditions

 

Taken together, FDOT’s current materials reflect a substantially expanded excavation activity involving changed scope, major land-use change acknowledged within FDOT’s own SEIR materials, changed hydrologic interaction, and a larger disturbance footprint than the originally evaluated roadway corridor.

 

The current record therefore raises significant questions regarding whether the borrow-site excavation itself has undergone sufficient independent environmental scrutiny relative to the scale and hydrologic sensitivity of the proposed excavation activity.

 

This is particularly important where the proposed excavation occurs within a groundwater-sensitive Outstanding Florida Springs Priority Focus Area connected to the Kings Bay / Crystal River springshed and where excavation is specifically designed to interact directly with shallow groundwater conditions.

 

V. Property Control, Permit Contingencies, and Public Interest Concerns

 

Recent application materials include a Purchase Agreement and Addendum between 3KS Family, LLLP and the Florida Department of Transportation concerning the Eastern Borrow Site property associated with the proposed excavation project.

 

At the same time, SWFWMD separately identified unresolved questions regarding legal control of the property under Rule 62-330.060(3), F.A.C.

 

In its May 3, 2026 Request for Clarification of Received Information, SWFWMD stated:

 

“Please clarify the entity applying for this permit…”

 

and further requested demonstration that the applicant/permittee possessed legal control of the property under Rule 62-330.060(3), F.A.C.

(Request for Clarification of Received Information – May 3, 2026).

 

The subsequent response stated that the property had been conveyed from George L. Southworth to 3KS Family, LLLP pursuant to a recorded quitclaim deed and indicated that Citrus County Property Appraiser records had not yet been updated.

(Response to Request for Clarification – May 7, 2026).

 

However, while the response clarified the ownership transfer to 3KS Family, LLLP, it did not fully clarify the relationship between:

 

• The listed applicant (Florida’s Turnpike Enterprise)

• The proposed purchaser “Florida Department of Transportation”

• And the entity identified as possessing current legal control (3KS Family, LLLP)

 

The timing and sequencing of the current record also raise significant procedural concerns. SWFWMD itself requested clarification regarding the identity of the permit applicant and demonstration of legal control under Rule 62-330.060(3), F.A.C., during active ERP review. At the same time, FDOT’s SEIR Re-Evaluation characterizing the Eastern Borrow Site as a major borrow excavation and land-use-change project was not signed until May 6, 2026, immediately preceding the May 7, 2026 clarification responses.

 

Taken together, the current record reflects that significant project characterization, ownership clarification, legal-control documentation, and hydrologic review continued evolving during the permitting process itself.

 

This is particularly important because Rule 62-330.060(3), F.A.C. requires sufficient real property interest and legal control to be demonstrated by the applicant in connection with the proposed permitted activity. Where legal-control relationships, acquisition status, project characterization, and excavation scope remain actively evolving during ERP review for a large-scale groundwater-interacting excavation project, heightened scrutiny and careful independent review are warranted.

 

Taken together, the current record indicates that:

 

• The proposed borrow excavation represents a separate large-scale excavation activity

• Significant project characterization and legal-control documentation continued evolving during active ERP review

• and legal-control relationships required clarification by SWFWMD during the permitting process

 

These issues are directly relevant to:

 

• Rule 62-330.060(3), F.A.C.

• The ERP public-interest review

• and the level of scrutiny appropriate for a large-scale excavation project within a karst-sensitive Outstanding Florida Springs Priority Focus Area connected to the Kings Bay / Crystal River springshed

 

Under these circumstances, heightened scrutiny and careful independent review of groundwater interaction, wetland function, hydrologic connectivity, cumulative impacts, and public-interest considerations are warranted before reliance on assumptions associated with the originally evaluated roadway corridor.

 

VI. Conclusion and Request for Heightened Independent Review

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Taken together, the current record reflects:

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• the same site area previously associated with unresolved environmental and land-use concerns during the Crystal River Borrow Pit review process

• a substantially expanded excavation footprint and disturbance area

• FDOT’s own acknowledgment that the Eastern Borrow Site represents a major land-use-change borrow excavation project

• direct infiltration into shallow groundwater within a karst-sensitive setting

• continued hydrogeologic concerns involving shallow limestone, limited confining separation, and groundwater interaction

• overlapping hydrogeologic investigation materials connecting the earlier Southworth review and the current Eastern Borrow Site evaluation

• and continuing questions regarding wetland function, hydrologic connectivity, and the adequacy of reliance on prior roadway assumptions for the current excavation proposal

 

The Eastern Borrow Site is not merely incidental roadway disturbance. FDOT’s own 2026 materials characterize the project as a large-scale excavation activity involving approximately 346 acres, approximately 313 excavation acres, and more than 5.1 million cubic yards of material within an Outstanding Florida Springs Priority Focus Area connected to the Kings Bay / Crystal River springshed.

 

Under these circumstances, heightened scrutiny and careful independent evaluation of groundwater interaction, wetland function, hydrologic connectivity, cumulative impacts, legal-control issues and public-interest considerations are warranted before excavation activities proceed.

 

This is precisely the type of location where the public expects heightened scrutiny, transparency, and careful protection of Florida’s water resources.

Respectfully, the public deserves full, transparent and independent review before this excavation proceeds.

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Colleen Farmer Chair and Tony Ayo Co-Chair,
Stop the Sand Mine Committee
stopthesandminecc@gmail.com

Submitted May 13, 2026