Exhibit_F2_-_S2_-_260529-64674_SFWMD_Response_to_Comments.pdf

PDF 183 KB Posted

Attached to
Design Services for Veterans Memorial Blvd. Phase II
Solicitation number
26-8668
Issued by
Collier County, Florida

About this file

This is a Response to Comments letter from Kimley-Horn and Associates, Inc., on behalf of the project applicant, submitted to the South Florida Water Management District (SFWMD) regarding an Environmental Resource Permit application for Veteran's Memorial Boulevard Phase 2A in Collier County, Florida. The letter addresses seven substantive comments and associated requests for additional information issued by SFWMD on June 26, 2026, concerning the proposed roadway extension and associated improvements. The applicant provided responses confirming completion of required actions, including payment of the $4,500 application fee on July 10, 2026, submission of an updated Mitigation Plan removing impacts to other surface waters, revision of civil plan sheets and stormwater management reports to address drainage basin limits and nutrient analysis specific to Phase 2A, clarification that the project maintains independent stormwater management systems from adjacent developments, confirmation that no dewatering is required, and acknowledgment of potential additional information requests. The applicant submitted revised Civil Plan Set sheets and Stormwater Management Report sheets addressing hydrological data, design storm stages, discharge rates, and basin-specific information as requested by District staff.

The letter establishes that all responses must be received within 90 days of the June 26, 2026 issuance date, after which the application will be processed for denial if substantive responses are not provided, or the applicant may request an extension through the RegPermitting website. The SFWMD noted that review of applications for Veteran's Memorial Boulevard Phase 2A (Application No. 260529-64674) and Phase 2B (Application No. 250814-56017) will occur separately but concurrent with related applications for the Imperial Lakes residential development (Application No. 260127-6108) and Imperial Drainage Basin Stormwater Improvements (Application No. 250930-57510) due to the inseparable nature of certain ERP applications. The applicant must submit all additional information electronically through the District's RegPermitting website or provide one original hard copy labeled with the application number to the Fort Myers Service Center. District staff contacts for clarification include Elizabeth Blessing, Carmen Quan, P.E., and Rich Walker, along with the project representative Christopher Wright, P.E., at Kimley-Horn.

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Text version

kimley-horn.com 2640 Golden Gate Parkway, Suite 201, Naples, FL 34105 239 999 3187

August 4, 2026

SFWMD

Fort Myers Service Center 2301 McGregor Blvd Fort Myers, FL 33901

RE: Veteran’s Memorial Boulevard Phase 2A Request for Additional Information Application No. 260529-64674 Collier County

The purpose of this letter is to provide satisfactory answers to the comments/questions issued in a comment letter dated June 26th, 2026. The answers are listed below in bold and italics and are preceded by the comments/questions listed in the original letter.

As staff discussed with Ms. Marielle Nageon de Lestang on June 25, 2026, the District is requesting the following information, in accordance with Section 5.0 or 7.0, as applicable, Environmental Resource Permit (ERP) Applicant's Handbook (AH) Volume (Vol.) I, adopted by reference in Subsection 62.330.010(4)(a), Florida Administrative Code (F.A.C.), to complete the application and provide reasonable assurances for permit issuance:

Comment 1: Please provide the required application fee of $4,500.00 for an Individual Environmental Resource Permit (ERP). The application is not complete until the required application fee has been paid. Payment of application fees can be done by credit card on the District's RegPermitting website, or by check. If submitted by check, please make the check payable to the South Florida Water Management District and reference Application No. 260529-64674 in the memo section of the check to ensure adequate processing. [Rule 62-330.071(1), F.A.C.]

Response 1: The application fee was paid on 7/10/2026 and the fee receipt is on Regpermitting.

Comment 2: As discussed with Marielle Nageon de Lestang of Turrell, Hall, and Associates, Inc., please update the function assessment to remove impacts to other surface waters. Please submit written correspondence from the mitigation bank, confirming the 2.85 freshwater forested credits needed for this project have been reserved for purchase. [F.A.C.; Section 10.3.1.3, Volume I]

Response 2: An updated Mitigation Plan has been attached removing OSW habitats from the

UMAM and mitigation needs. A letter of reservation for 2.85 freshwater forested credits from

Panther Island Mitigation Bank has been requested and we are waiting on the letter of reservation from Desmond Duke.

Comment 3: The overall proposed roadway extension and associated improvements was split in two phases and each phase will be reviewed separately under Application No. 260529-64674 for Phase 2A and Application No. 250814-56017 for Phase 2B. Address the following [Rule 62.330.060, F.A.C.]:

a. Provide an aerial exhibit that shows the limits of each sub-basin of the overall Drainage Basin 1 as shown in page 13 of the engineering report.

b. Indicate in the nutrient analysis, the portion specifically relating to Phase 2A.

c. Provide a separate exhibit that includes the following information: seasonal high water table, control elevation, minimum finished floor, FEMA flood elevation (if applicable), minimum roadcrown and parking lot elevations, minimum perimeter berm elevation, and rainfall and the peak stage elevations for the controlling design storms, and the allowable and peak discharge rates.

d. The engineering report does not include any references to Phase 2A and 2B. It appears the limits are east and west of the railroad, however it is not clear. Staff requests that the SWM report be revised to include only information regarding the Phase 2A project.

Response 3: Please see the revised Civil Plan Set and SWM Report sheets below for requested information:

• Civil Set Sheet 7: An aerial identifying the limits of each sub-basin within Drainage Basin 1.

• SWM Report Sheets 26-39: Nutrient analysis information specific to Phase 2A.

• Civil Set Sheet 8: A table summarizing the seasonal high-water table, control elevation, minimum finished floor elevations, FEMA flood elevation (where applicable), minimum roadway and parking lot elevations, minimum perimeter berm elevation, design storm stages, and allowable and peak discharge rates.

• A revised Stormwater Management Report and including information specific to the Phase 2A project.

Comment 4: As currently presented it is unclear if the proposed project will impact proposed facilities for the Imperial Lakes residential development as shown in incomplete Application No. 260127-6108.

Please clarify and provide supporting documentation and relevant computations that demonstrates no adverse impacts will occur to the Imperial Lakes development as a result of the proposed project. Due to the inseparable nature of these ERP applications, District staff will review these applications concurrently and final agency action will be taken once all applications are deemed complete. [Rule 62.330.060, F.A.C.]

Response 4: The proposed project is a standalone development with separate project boundaries and an independent stormwater management system from the Imperial Lakes residential development (Application No. 260127-6108). Coordination has occurred with the Imperial Lakes Engineer of Record. The proposed wildlife crossing is located west of the Imperial Lakes property, and the proposed cross-drain discharges to the Imperial Lakes preserve area in a manner that maintains existing southward drainage patterns. As a result, the proposed project does not rely upon, modify, or adversely impact the Imperial Lakes stormwater management system. Accordingly, the projects are not interdependent and should be reviewed independently.

Comment 5: As currently presented it is unclear if the proposed project will impact proposed facilities for the Imperial Drainage Basin Stormwater Improvements project under Application No.

250930-57510. Please clarify and provide supporting documentation and relevant computations that demonstrates no adverse impacts will occur to the Imperial Drainage Basin Stormwater

Improvements project as a result of the proposed project. Due to the inseparable nature of these

ERP applications, District staff will review these applications concurrently and final agency action will be taken once all applications are deemed complete. [Rule 62.330.060, F.A.C.]

Response 5: The proposed project will not adversely impact the Imperial Drainage Basin

Stormwater Improvements project (Application No. 250930-57510). Based on the ERP application and supporting documentation, the referenced project consists of improvements to downstream control structures and conveyance features located south of the project area and downstream of Veterans Memorial Boulevard. The proposed project satisfies all applicable discharge rate and stage criteria independent of those improvements and is not hydraulically connected to the project for storm events up to and including the 25-year storm event. Therefore, the projects are independent, no adverse impacts are anticipated, and the applications should be reviewed separately.

Comment 6: Will temporary dewatering be required as part of the construction activities? Please contact Sean Roberts at 239-338-2929 ext #7719, email: sroberts@sfwmd.gov to determine if a

Water Use Permit will be required for dewatering. Because of the inseparable nature of water use and surface water management, and in accordance with Subsection 2.3(b), Environmental

Resource Permit Applicant's Handbook Volume II, District staff will review these applications concurrently and final agency action will be taken once both applications are deemed complete.

[WU AH - 1, 1.4.1]

Response 6: No dewatering is proposed.

Comment 7: Please note that new information submitted may result in additional requests for information to complete this permit application. [Rule 62.330.060, F.A.C.]

Response 7: Acknowledged.

Advisory Comments: The following comments are advisory in nature and do not require a response to the District.

Please be aware that properties within the South Florida Water Management District (District) may be subject to canal, road and/or oil, gas or mineral (OGM) reservations issued to the District or The Board of Trustees of the Internal Improvement Trust Fund of the State of Florida (TIITF). These reservations encumber title to specific properties by granting certain rights to the District or TIITF to use the property to perform activities stated in the reservation documents, regardless of approvals/permits acquired or improvements constructed by the fee owner. It is the property owner’s responsibility to verify whether reservations exist on the property. The property owner may apply to the District or TIITF (or both, if applicable) to release reservations on the property at ReleaseApplications@sfwmd.gov. Issuance of an ERP for a proposed project on a specific property does not obligate the District or TIITF to release any reservations encumbering the property. Construction of approved/permitted works on property with unreleased reservations is at the risk of the fee owner.

If any of the items in this RAI need clarification or discussion, please contact: Elizabeth Blessing, Senior Environmental Analyst at (239) 338-2929 Ext. 7743 or via email at eblessin@sfwmd.gov; Carmen Quan, P.E., Engineer Senior at 7714 or via email at cquan@sfwmd.gov; and Rich Walker, Property Analyst at (561) 682-6741 or via email at rdwalker@sfwmd.gov.

In accordance with Section 5.5.4, ERP AH Vol. I, adopted by reference in Subsection 62.330.010(4)(a), FAC review of the application will not resume until a substantive response to each comment has been received.

Please submit the complete response electronically on the District's RegPermitting website at www.sfwmd.gov/regpermitting using the 'Submit Additional Information' link. Information regarding RegPermitting is enclosed. Alternatively, please provide one original hard copy of the requested information, labeled with the application number, to the Fort Myers Service Center.

If a complete response is not provided within 90 days of this letter, this application will be processed for denial, in accordance with Section 5.5.3.5 ERP AH Vol. I. If additional time is necessary, please submit a request for an extension via RegPermitting before the 90-day period ends, including a description of the circumstances requiring the extension of time.

For projects where more than 90 days will be needed to develop a complete application, it is recommended that the applicant withdraw the current application and resubmit a complete application at a later date. The processing fee, if paid, can be applied to a new application that is submitted within 365 days, pursuant to Rule 62-330.071(3), FAC. If the application is denied by the agency, fees will not be returned or credited.

Please contact me at (239) 214-0392 or christopher.wright@kimley-horn.com should you have any questions or concerns.

Sincerely, Christopher Wright, P.E.

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