Exhibit_F7_-_S5_-_250814-56017_-_Response_to_Comments_Letter.pdf

PDF 178 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, dated August 4, 2026, submitted to the South Florida Water Management District (SFWMD) regarding an Environmental Resource Permit (ERP) application for Veterans Memorial Boulevard Phase 2B in Collier County, Florida. The letter addresses four substantive comments and several advisory comments issued by SFWMD staff on June 26, 2026, concerning the proposed roadway extension and associated improvements. Key milestones include a site inspection scheduled for August 12, 2026, to verify site conditions of off-site mitigation parcels and field-stake wetland boundaries. The applicant clarified that the overall project was split into two phases—Phase 2A under Application No. 260529-64674 and Phase 2B under Application No. 250814-56017—each reviewed separately. The response includes supplemental exhibits and revised documentation addressing stormwater management, nutrient analysis specific to Phase 2B, drainage basin delineation, seasonal high water table data, control elevations, FEMA flood elevations, and peak discharge rates. Collier County requested that a special permit condition be included requiring documentation of necessary property authorizations prior to construction, as the County is acquiring subject parcels through eminent domain authority.

The applicant must provide a complete substantive response to all comments within 90 days of the June 26, 2026 letter, or the application will be processed for denial in accordance with ERP Applicant's Handbook provisions. The SFWMD is reviewing this application concurrently with Applications Nos. 251205-59840 and 251205-59839, modifications to existing ERPs for the Triangle Parcel and Mercedes Benz of Bonita Springs, due to the inseparable nature of the stormwater management system. An extension request may be submitted through the RegPermitting website before the 90-day deadline expires. Processing fees paid may be applied to a new application submitted within 365 days if withdrawal occurs, though denied applications will not receive fee refunds or credits.

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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 Request for Additional Information Application No. 250814-56017 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, 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: With regards to the proposed Conservation Easement release request, please contact Liz Blessing at eblessin@sfwmd.gov, or (239) 338-2929 X 7743 to schedule a site inspection to verify site conditions of the off-site mitigation parcel(s). Prior to the field inspection, if applicable, wetland boundaries should be field staked or flagged. The function analysis will be discussed on site.

Dependent on the site inspection, additional information may be required. [Section 7.2, Vol. I or Section 7.3, Vol. I]

Response 1: A site inspection has been scheduled for August 12.

Comment 2: In response to comment 5 of the RAI dated April 03, 2026, staff acknowledges your submittal. Please remove other surface water impacts from the functional assessment on Table 10, Basin 2. Once the wetland boundaries, wetland impacts, and functional assessment scores have been finalized, please submit written correspondence from the mitigation bank confirming the appropriate credits needed for this project have been reserved for purchase. [F.A.C.; Section

10.3.1.3, Volume I]

Response 2: We understand this comment is in reference to the other section of Veterans

Memorial Blvd Phase 2A under application 260529-64674.

Comment 3: In regards to comment 3 of the previous RAI's the project is being reviewed concurrently with Application Nos. 251205-59840 and 251205-59839, for modification to ERP No. 11-02353-P for

Triangle Parcel, and modification to ERP No. 11-03669-P for Mercedes Benz of Bonita Springs, respectively. These applications are incomplete. Because of the inseparable nature of these applications and the stormwater management system, and in accordance with the 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.

Response 3: Acknowledged. Collier County is working to acquire the subject parcels through its eminent domain authority. We request that a special permit condition be included requiring documentation of the necessary authorizations and property interests for the affected parcels to be provided to the District prior to construction. This approach would allow permit processing to continue while ensuring all required authorizations are in place before implementation of the proposed improvements.

Comment 4: 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 exhibit that shows the limits of each sub-basin of the overall Drainage Basins 2 & 3 as shown in page 26 of the engineering report.

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

c. Provide a separate exhibit that includes the following information for each basin: seasonal high water table, control elevation, FEMA flood elevation (if applicable), minimum roadcrown elevation, minimum perimeter berm elevation, and rainfall and the peak stage elevation 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 2B project.

Response 4: Please see the attached supplemental exhibits and supporting documentation provided in response to this comment. The requested materials include:

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

• SWM Report Sheets 36-52: 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.

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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