Sarasota
County has submitted their final response to the Florida Department of Environmental Protection (DEP) requesting permission
to dredge open Midnight Pass. Please email Governor Charlie Crist and the DEP to express opposition to this dredging project
at:
Charlie.Crist@MyFlorida.com
lizbeth.childs@dep.state.fl.us
michael.sole@dep.state.fl.us
michael.barnett@dep.state.fl.us
or
write
Lizbeth
Childs, E.I.
Florida
Department of Environmental Protection (DEP)
Marjory
Stoneman Douglas Building
3900
Commonwealth Boulevard, Mail Station 300
Tallahassee, Florida 32399-3000
ManaSota-88 strongly recommends the
Sarasota Board of County Commission withdraw its endorsement and financial support to conduct additional studies to dredge
open Midnight Pass for the following reasons:
1. Midnight Pass has migrated significantly over its existence and the Sarasota Board of County Commission cannot insure
that a reopened Midnight Pass would not migrate again. If migration did occur, it appears likely Midnight Pass would adversely
affect private property and potentially cost the taxpayers of Sarasota County millions of dollars. Chapter 62B-41.005(12),
Florida Administrative Code specifically prohibits the creation of artificial new inlets or flushing outlets. Previously dredged
openings must be hydraulically stable. A historic review of Midnight Pass clearly shows that it is not a hydraulically stable
system and is likely to migrate if dredged open.
2. The State Hearing Officer produced a Recommended Order and the Secretary of the Department of Environmental Regulation
issued a Final Order that upheld the denial of Sarasota Countys permit to dredge Midnight Pass in 1991.
3. The Army Corps of Engineers staff reviewed the eligibility of the Midnight Pass dredging project under Section 1135
in 1996 and stated: Opening the pass to improve circulation will have a significant consequence and may not be permitable.
4. The Sarasota Department of Natural Resources (SDNR) stated in its review of the History and Status of Midnight Pass
of June 1997 that: it is extremely unlikely that any permitting agency would allow impacts to a natural ecosystem to occur
in order to open a pass, then simply allow the pass to close. The SDNR further stated: Another feasibility study may not
tell us any more than we already know.
5. The habitat value of the former Midnight Pass location provides for a variety of important fish species. The closing
of Midnight Pass contributed to the establishment of a rich haven for young fish and shellfish. Due to past development within
the Little Sarasota Bay watershed, such fisheries are in short supply. There appears to be no biological benefit in dredgingMidnight
Pass.
6. A productive marine community including young mangroves, nesting least terns, and loggerhead sea turtle nests, currently
exists or has existed within the proximity of the former Midnight Pass area since its closure. Dredging Midnight Pass would
severely impact the established marine community of the area.
7. An adequate tidal prism probably does not exist between Little Sarasota Bay and the Gulf of Mexico to keep Midnight
Pass open. Long-term adverse impacts to the marine environment can be expected due to routine and frequent maintenance dredging
required to keep Midnight Pass open.
8. Water quality benefits from dredging Midnight Pass appear to be insignificant and localized and would not offset the
direct loss of valuable marine and shoreline habitat.
9. Little Sarasota Bay is designated an Outstanding Florida Waters (OFW). Dredging Midnight Pass is clearly not in the
publics interest as is required for an OFW designation. Dredging Midnight Pass does not provide public benefits as described
in 62B41.005(11)(c). F.A.C.
