Application 889588 · Permit 47575.000
Received March 1, 2024. The applicant’s withdrawal was effective December 6, 2024; SWFWMD’s acknowledgment is dated December 11, 2024.
Open the SWFWMD viewer (opens in a new tab)Application history, kept file by file
Applications on This Land
As last verified September 16, the public viewer still listed Application 930235 as Incomplete and had not shown a later applicant filing, completeness determination, or permit approval. Earlier files on the same parcels show what was asked for before. A withdrawn file is not an approval, and it is not proof the next file is identical—or different.
A filing is not secretly approved and not already dead. As of September 16, the public viewer still listed the application as Incomplete and had not shown a completeness determination or permit approval. The public still lacked a final agency-approved plan to test against the developer FAQ.
How to read the record
Three mitigation-bank application identifiers
Permit numbers can identify a family of related records, while application numbers identify particular filings. Keep each file’s date, request, and status attached to that file.
Application 907654 · ERP 47575.001
Received December 6, 2024 and withdrawn November 13, 2025. The official viewer lists 102 public documents. The applicant’s withdrawn design proposed substantial excavation, filling, wetland creation, and material export.
Open the SWFWMD viewer (opens in a new tab)Application 930235 · Permit 47575.002
Individual Brooker Creek Mitigation Bank application received November 14, 2025. As last verified September 16, 2026, the viewer still showed Incomplete and had not shown a later applicant filing, completeness determination, or permit approval.
Open the SWFWMD viewer (opens in a new tab)Same land does not mean same application
Compare each file on its own terms
On a phone, each table row becomes a labeled record card. Every limitation stays with the fact it qualifies.
| Identifier | Years | What was asked | Status | Earthwork/hydrology in THAT file | Boundary and plan notations | Title questions the District asked | What it does not prove |
|---|---|---|---|---|---|---|---|
| Application 889588Permit 47575.000 | Received March 1, 2024; withdrawal effective December 6, 2024; District acknowledgment dated December 11, 2024. | Conceptual approval of the Brooker Creek Mitigation Bank. The C-1 master site plan by 5M Civil, signed by Merly, P.E. 58113 and internally revised February 2, 2024, reports 6,407,200 square feet, or 147.09 acres. The application narrative describes a 168.40-acre bank. Application 907654 introduced the 172.59-acre figure; Application 930235 uses 172.46 acres. Open the official C-1 plan. | Supported by a dated historical document Withdrawn/deleted. FWC issued no comments in October 2024. |
The file described pond-to-marsh conversion, hydrologic restoration, seasonal-high-water-table work, ditch/berm features, vegetation work, cart-path removal, and fencing. It was not described as planting-only. | The C-1 plan identifies Parcel 3, reports a 147.09-acre site-data total, states “NO PROPOSED BUILDINGS,” and differs from the 168.40-acre narrative, Application 907654’s 172.59-acre figure, and Application 930235’s 172.46-acre figure. Save Tarpon Woods requests a signed-and-sealed reconciliation with the current bank and conservation-easement boundaries. | On August 14, 2024, the applicant response attached a February 3, 2022 Special Warranty Deed copy as “Attachment 2: Deed.” It describes a $1,650,000 transfer from Jan Stephenson’s Crossroads Foundation, Inc. to Tarpon Woods Properties, LLC covering folios 110-0400 and 140-0000. The copy in the file has no Clerk instrument number or Official Records book/page. Open the official applicant response. On August 28, 2024, SWFWMD’s clarification RAI from Robert A. Dasta, P.E. and Lee Hughes, P.W.S. to Jesus Merly kept these items open: Item 1 requested landowner authorization and entity-signer authority under Rule 62-330.060; Item 2 requested reasonable assurance of complete legal control because the project extended onto property |
Limitation: Withdrawal is not a merits denial, does not freeze the design, and does not show that every feature survived into Application 930235. The open title questions are not a finding that the deed is fake. The attached copy is not a Clerk recording, and a property-appraiser display with a placeholder book/page is not a Clerk determination. |
| Application 907654ERP 47575.001 | Received December 6, 2024; applicant withdrawal request and District withdrawal action dated November 13, 2025. | Individual authorization for a new wetland mitigation bank. The application separately reports 172.59 applicant-owned contiguous acres and 172.59 project acres, then displays 345.18 as “total land area”; because those entries may describe the same overlapping land or an automated sum, the apparent double-count requires clarification. It also reports 17.8 acres of proposed impact and no proposed impervious area. The environmental filing proposed a conservation easement over 172.59 acres and stated a total of 79.57 potential credits; its displayed 13.86- and 65.72-credit components sum to 79.58, a one-hundredth difference that may reflect rounding but requires reconciliation. Open the official docket. | Supported by dated official records The viewer identifies the file as deleted because the application was withdrawn. Withdrawal is not a merits denial or an approval. |
The applicant proposed excavating golf-course uplands to create 55.54 acres of freshwater marsh, restoring another 20.64 upland acres by excavation, and filling/restoring 17.27 acres of ponds plus 0.53 acre of ditch. In an August 2025 partial response, the applicant proposed selling excess fill to an unidentified buyer, offering FDOT or a nearby project as examples; no specific buyer or receiving project or site was identified. SWFWMD’s September clarification identified unresolved excavation, filling, crossings, haul routes, staging, access, numerous proposed, removed, or replacement pipes and control structures, modeling, and title or legal-interest issues. | The recovered 907654 documents report a 172.59-acre project and proposed easement. Save Tarpon Woods asks that those figures be reconciled with the earlier 147.09- and 168.40-acre records and the current 172.46-acre filing. | SWFWMD’s January 3, 2025 RAI requested evidence of sufficient legal control. Its September 19 clarification said legal-interest and title information remained unresolved, along with design inconsistencies. | Limitation: These are applicant proposals and agency questions in a withdrawn design. They are not approved work, released credits, a final agency finding, or proof that the same earthwork survives in Application 930235. They do require a version-by-version explanation of how the owner/proponent’s current “no earthwork” account differs from the 907654 plan. |
| Application 930235Permit 47575.002 | Received November 14, 2025; record and newly uploaded materials reviewed through September 16, 2026. | Individual mitigation-bank authorization under the same project name and the 47575 permit family. | Confirmed by current official record The applicants filed a 121-page RAI response on August 26, 2026. Filing is not a District acceptance, completeness determination, or permit approval; as last verified September 16, the viewer still listed the application as Incomplete and showed no later applicant filing, completeness determination, or permit approval. |
The August 26 applicant package and the applicant’s separate conservation website characterize the current proposal as involving no earthwork, while the work plan includes planting, thinning, removal, mowing or roller chopping, and pond- and ditch-restoration activity. Those remain applicant descriptions, not a permitted plan, and require quantified methods, locations, access routes, soil-displacement assumptions, and hydrologic analysis. Read the attributed owner page. | Save Tarpon Woods requests one signed-and-sealed exhibit reconciling the current survey, Parcel 3, bank boundary, security plan, credit polygons, and conservation-easement legal description. | The December 14, 2025 RAI contained 18 items and again requested deed, ownership, legal-interest, and title material. The applicants filed a 121-page response on August 26, 2026. In that response, they state that the deed transfer and recordation are still in process and promise to provide recorded evidence later. | Limitation: The August 26 package is an applicant filing, not a SWFWMD completeness determination or permit approval. Draft easements, a title commitment, and promises of later recordation do not establish that the District has accepted legal control, credit calculations, hydrologic assurances, site security, or financial responsibility. |
Newly traced agency-coordination record
The applicants discussed this bank with Pinellas County before the current SWFWMD filing. The complete trail belongs in the record.
Residents should not have to reconstruct a proposed 172-acre mitigation bank from scattered portals. Before SWFWMD approves anything, the applicants should disclose one complete, dated list of every meeting, request, plan, attachment, recording, response, and file number shared with Pinellas County, FDEP, and the U.S. Army Corps of Engineers.
Current 14-sheet survey review
The survey supplies detail—but not the single controlling project map the public needs.
The newly uploaded boundary and topographic survey identifies a February 27, 2025 field-survey date, a March 3, 2025 drawing date, a March 17, 2025 checking date, and a May 13, 2026 revision. It is certified to Avalon Building Corporation of Tampa Bay, Bryan J. Stanley, P.A., and Chicago Title Insurance Company. Its legal description includes Parcel 1 and Parcel 3 and reports 172.46 acres. Surveyor’s Note 9 says Parcel 2—an easement estate—was removed at the client’s request.
Those are important facts, but the survey should not be read in isolation. The survey refers to a February 18, 2026 title commitment while the August RAI response relies on a July 14, 2026 commitment. Schedule B-II marks multiple numbered items “Intentionally Deleted.” That phrase is a title-commitment convention, not proof of concealment, but it makes the version history indispensable: the applicant should provide every operative commitment and an item-by-item crosswalk showing what each exception was, who directed its deletion or renumbering, and the supporting recorded instrument.
Sheet 9: elevations next to Lots 53 and 54
Sheet 9 shows contours and spot elevations around the golf-course land adjoining numbered residential lots, including Lots 53 and 54. The sheet title block gives the survey’s general field date, but the visible sheet does not answer every documentation question residents have raised: when each elevation was collected; whether any values were inherited, interpolated, or updated; the exact instrument and collection method; calibration and control; contour-generation method; and what changed in the 2026 revision.
Campaign-requested answer: the surveyor should produce the sealed survey report or notes, raw field and control data, benchmark and datum information, instrument type, stated vertical accuracy, collection dates, breaklines, contour interval, revision cloud or log, and a written response to the specific points residents identified. Save Tarpon Woods is not declaring a surveyed elevation false from visual comparison alone; we are demanding the data needed to test it.
Segmented lines, fences, Parcel 3, and Figure 14
Segmented black lines on the survey cannot safely be called a property boundary, fence, floodway, or excluded parcel merely from appearance. Each line type must be tied to the legend and the relevant legal or field evidence. Figure 14 in the RAI response is a schematic aerial security map, not a boundary survey, and its red perimeter should not be substituted for the surveyed legal description.
Campaign-requested answer: place the surveyed boundary, fee parcels, easement estates, found monuments, field-observed fences, proposed security fencing, FEMA and County floodway/floodplain, wetland limits, credit polygons, conservation-easement limits, access and maintenance routes, and every work area on one signed-and-sealed georeferenced composite. If Figure 14 differs, state whether it is conceptual, correct it, and explain the difference.
2019 recorded County waiver: a 3.40-acre tract, not the entire golf-course property
Pinellas Clerk Instrument 2019338177, Official Records Book 20738, Page 2541, records a County waiver affecting specified management, maintenance, and treated-effluent-disposal rights only as to the 3.40-acre tract described in Exhibit A. The instrument expressly says the waiver applies to that tract and not to the remainder of the Golf Course Property
; it also says the agreement remains effective on the balance, including continued acceptance of treated effluent.
The metes-and-bounds courses in that 3.40-acre Exhibit A also appear in the title material filed in Application 930235 as Parcel 3 (Fee Estate). That document match is a reason to require a parcel-by-parcel title, survey, utility, and conservation-easement reconciliation. It is not a title opinion, an adjudication of the tract's present ownership, or proof that any particular right has or has not since changed under a later recorded instrument.
Current Property Appraiser indexing: useful checkpoint, not a deed citation
The Pinellas County Property Appraiser currently indexes both folios 34-27-16-00000-140-0000 and 34-27-16-00000-110-0400 to TARPON WOODS PROPERTIES LLC. On both parcel pages, however, the “Last Recorded Deed / Book-Page” field displays AAAAA/AAAA
.
What that means: the assessor pages are useful ownership, acreage, and folio research checkpoints, but the displayed placeholder does not identify the controlling Clerk instrument. The pages are not a title opinion or substitute for the recorded deed, current title commitment, survey, or recordable conservation-easement evidence.
DRM-23-00102: early bank, utility, and process consultation
The County record identifies Katie Cole of Hill Ward Henderson as the requester. The stated topics included establishment of a mitigation bank, reclaimed-water utility requirements, and the development-review process.
The closed record shows a meeting milestone scheduled for September 6, 2023 and “Meeting Notes Completed” on September 26, 2023. That proves mitigation-bank, utility, and process questions were raised in an applicant-side County consultation record. It does not prove the County approved the bank, accepted a particular design, or found that every issue remains operative.
Open official County record (opens in a new tab)DRM-24-00066: the prior excavation concept
The County record identifies Jesus Antonio Merly of 5M Civil as the contact for a 168.40-acre Brooker Creek Mitigation Bank consultation. One of the applicant's questions was direct: What are the permitting requirements for the excavation?
The applicant-entered conceptual pre-application description states 168.40 acres, an estimated cut of 273,000 cubic yards, and an estimated fill of 31,000 cubic yards. Guy Shoemaker, Development Project Manager I, issued preliminary pre-application comments on June 27, 2024 for a July 1 Development Review Committee meeting. The comments stated that no fill is permitted in the floodway; cut and fill must demonstrate no net fill with cut contiguous to the floodplain; whole-watershed modeling may be required; the applicant must show no effect on 10-, 25-, and 100-year flood elevations; an altered floodway must be reestablished at no more than a 0.1-foot rise; floodway and floodplain lines must be overlaid; applicable CLOMR/LOMR steps must surround construction; and an environmental site assessment must be provided. The County portal shows the record as continued, with several disciplines marked “Revisions Required.”
The attached C-1 master site plan adds a concrete acreage difference. Its site-data block reports 147.09 acres, not the portal description's 168.40 acres, while the same sheet says “NO PROPOSED BUILDINGS.” Save Tarpon Woods asks SWFWMD to obtain a signed-and-sealed explanation of the boundary and acreage difference.
Critical limit: the quantities are applicant-entered estimates, not County findings or approved quantities, and the comments were preliminary—not a permit or final determination. These materials belong to an earlier concept and do not prove that Application 930235 still proposes the same cut, fill, acreage, or treatment. Their arithmetic difference does not prove export or disposal because reuse, shrink or swell, water content, stockpiling, and final disposition remain unresolved. The record proves a substantial design history that Save Tarpon Woods asks the applicant and District to trace, rather than erase by relabeling the current proposal “no earthwork.”
Open DRM-24-00066 (opens in a new tab) Open the official C-1 planFDEP Worksheet 133182: not a final boundary decision
SWFWMD—not the applicant—initiated the FDEP Title and Land Records review associated with withdrawn Application 889588. FDEP recorded that an original mean-high-water boundary had not been established and that proprietary authorization for state-owned land was not required at this time
.
That limited conclusion is not a final determination of every title boundary, wetland line, state ownership question, or present applicant's legal interest. The current application must still prove the land, boundaries, interests, and areas it asks SWFWMD to encumber and credit.
Open official FDEP responseThe “Intentionally Deleted” entries are a title-version question
The current ALTA/NSPS survey references different title-commitment dates and revisions while marking numerous Schedule B-II entries “Intentionally Deleted.” Numbered exceptions are commitment- and revision-specific, so a shared number cannot be assumed to represent the same instrument across versions.
What Save Tarpon Woods requests: the February 18, 2026, July 14, 2026, intervening, and later current commitments, plus an underwriter- and surveyor-supported crosswalk identifying what each numbered item represented and the documentary basis for every deletion, release, satisfaction, or renumbering. This is a resident-requested completeness review, not an agency requirement or an allegation that any deletion was improper.
The apparent disclosure gap
The agency-coordination table reviewed in Application 930235 identifies the April 10, 2023 SWFWMD meeting. Other current-file materials separately describe a March 31, 2025 FWC/SWFWMD site visit connected to Application 907654, a November 5, 2025 FDEP/County meeting, a January 21, 2026 District meeting, and an unnamed later District meeting. The table also does not identify DRM-23-00102 or DRM-24-00066. That is an internal chronology and disclosure gap requiring a documented explanation—not proof of an intentional omission.
SWFWMD should require the applicants to reconcile every County, FDEP, and federal contact with the current table and place the underlying plans, comments, notes, recordings, and attachments in the permit record.
The design change SWFWMD must make them explain
The applicants should provide a signed-and-sealed, version-by-version change log showing how the earlier excavation-and-fill concept became the current “no earthwork” proposal. For every excavation, fill, ditch, pond, fairway, spoil, access, grading, planting, and hydrologic feature, the log should state what was removed, retained, relocated, or redesigned; when; by whom; and with what effect on flooding, the floodway, credits, costs, and disposal.
A new label is not an engineering reconciliation. The public needs the actual chain of drawings and calculations.
State and federal public-search results—with important limits
FDEP: September 1, 2026 Nexus searches covered the project name, exact address, both folios, the current applicant, and relevant consultant or representative names. Those searches did not locate a facility or document named for the Brooker Creek Mitigation Bank. FDEP's separate statewide layer of mitigation banks permitted under section 373.4136, Florida Statutes, says it contains available data through August 2026; a fielded substring query for Brooker, Tarpon, and Tarpon Woods returned no listing. The all-Pinellas query returned North Shore Seagrass—not Brooker Creek. This confirms only that Brooker Creek does not appear in that public layer of permitted banks; it does not rule out this pending SWFWMD application, for which the public viewer had shown no completeness determination or permit approval as of September 16, a withdrawn filing, an unissued matter, informal correspondence, or a differently indexed record. FDEP describes the map as illustrative and unsuitable for regulatory, engineering, or legal determinations.
U.S. Army Corps: The Corps' official ORM Project Locations public layer contains a project-location record under DA number SAJ-2025-02276-JLA for “TARPON WOODS PROPERTIES, LLC / BROOKER CREEK MITIGATION BANK / 1100 TARPON WOODS BLVD / PINELLAS,” with request type NWP. The layer supplies associated polygon geometry but does not state what boundary that polygon represents or establish its survey accuracy or legal effect. It also does not disclose the Nationwide Permit number, receipt or decision date, current status, jurisdictional determination, verification, conditions, authorization, or outcome. Separate RIBITS bank/site, Regulatory Request System public-notice, and Jacksonville District public-notice searches did not return the same project. RRS cannot expose another user's private request and is not presently a public portal for mitigation-bank proposals, so its silence is especially narrow. No single portal can be treated as the complete federal record.
The state ERP program remains active, while the separate Florida-assumed State 404 program has been vacated and the Corps presently handles section 404 permitting for discharges to waters of the United States in Florida. The 889588 and 930235 forms answered “No” to requesting state-owned-submerged-lands authorization, and the State 404 authorization boxes were not selected. Those form entries do not decide federal jurisdiction or prove that no federal authorization is required.
The applicant should produce and reconcile the complete administrative or permit record associated with SAJ-2025-02276-JLA—including any PCN or application, plans, jurisdictional materials, permit relied upon, section 401 and coastal-zone materials, correspondence, conditions, decision, and status—and identify every other FDEP or Corps contact. SWFWMD should not imply federal authorization from the existence of a location-layer entry or from silence in other portals. Read the federal-process explanation · Open the source explanation · Check EPA's current Florida status
What we demand before any approval
- A complete coordination ledger naming the agency, file number, date, participant, subject, and every attachment or recording.
- The full plan history and a signed-and-sealed reconciliation of the applicant-entered earlier estimated cut of 273,000 cubic yards and estimated fill of 31,000 cubic yards; the C-1 sheet's 147.09-acre total; the 168.40-acre narrative; Application 907654’s 172.59-acre figure; and Application 930235’s 172.46-acre figure.
- The complete underlying record and current status for SAJ-2025-02276-JLA, plus every other FDEP and Corps submission, jurisdictional map, permit request, prospectus, Interagency Review Team communication, and mitigation-banking instrument—or an unambiguous statement that none exists.
- A written explanation from SWFWMD of how the omitted County consultations affect completeness, technical review, floodplain analysis, cost estimates, and the technical support for “no earthwork.”
Exact-address County chronology
The broader 1100 Tarpon Woods Boulevard search separates owner filings, agency actions, contractor permits, and resident inquiries
Not every record attached to an address was submitted by the landowner or the mitigation-bank team. We reviewed the broader address return so residents and officials can see what each record actually is—and so unrelated or resident-originated records are not turned into applicant admissions.
Search scope and cutoff: On September 1, 2026, the Pinellas County global address search for 1100 Tarpon Woods Boulevard returned 94 records across all modules and 25 Development Review records. All three displayed result pages were reviewed. The owner-side mitigation-bank, utility, excavation, floodplain, and process consultations material to this page are DRM-23-00102 (opens in a new tab) and DRM-24-00066 (opens in a new tab). This is a dated, exact-address portal search, not a certification that the County has no other email, native file, attachment, archived record, differently indexed address, or nonpublic working material.
| Record | Who or what generated it | What the public record says | What it does not prove |
|---|---|---|---|
| ZCL-23-00690 (opens in a new tab) | Owner-side compliance filing and County action. | An issued, after-the-fact zoning clearance tied to CZO-23-00653 for dumpster screening and removal of fill from the parking lot. | It is a violation-remediation record, not approval of a residential project, mitigation bank, excavation program, or present site plan. |
| HTP-24-01289 (opens in a new tab) | Owner-side habitat/tree-removal permit and County action. | The approved record repeats the CZO-23-00653 compliance description and reports zero trees to be removed. Its application-information panel also displays “Requested - Multi-Family” and “Multi-Family/Commercial/Other.” | Those use-category fields do not overcome the zero-tree, violation-remediation description and do not establish a multi-family proposal or approval. |
| DRM-24-00069 (opens in a new tab) | Third-party/resident inquiry. It is not attributed to the owner or present applicant team. | A withdrawn inquiry asked what could be developed under the Recreation/Open Space future-land-use designation. | It is not an owner proposal, applicant admission, County endorsement, or development approval. Resident contact details are not republished here. |
| DRM-24-00106 (opens in a new tab) | Resident inquiry/comment. It is not attributed to the owner or present applicant team. | A withdrawn record requested public discussion and expressed neighborhood concerns about the concept. | It is not an applicant filing or a County merits decision. Resident contact details are not republished here. |
| CCM-25-00069 Clerk Instrument 2025260301 (opens in a new tab) |
Pinellas County code-enforcement case and recorded joint-stipulation order. | The four-page recorded order requires $378.95 in prosecution costs, sets December 8, 2025 as the minimum-housing compliance date, and provides for a $250-per-day fine for each continuing minimum-housing violation. It also states that the zoning violation had been abated by September 8, 2025. | The order concerns maintenance and enforcement. It is not a development approval, mitigation-bank permit, environmental finding, or proof of compliance after the dates stated in the order. Open the recorded order (opens in a new tab) Open the hearing agenda (opens in a new tab). |
| BC-RMR-25-00770 (opens in a new tab) | Contractor building-permit record. The current portal display says awaiting applicant action. | Commercial repair/remodel work for Hurricane Helene water damage, including drywall, framing, and exterior waterproofing at the golf club. | It is a storm-repair record, not approval of site redevelopment, the mitigation bank, or a change in land use. |
| BC-DMO-26-00029 (opens in a new tab) | Contractor building-permit record. The current portal display says awaiting applicant action. | Commercial demolition record for removal of a damaged roof structure required by plan review in connection with the repair permit. | It is not demolition of the golf course as a whole and not a redevelopment, mitigation-bank, or residential approval. |
The public record is still incomplete
Specific records the agencies and applicants should produce
Not yet obtained as of the September 1 research cutoff: each item below fills a documented gap between a public index, an earlier design, and the current filing. Their absence from our archive is not proof that they do not exist.
Two earlier gaps are now closed: we recovered all 102 documents publicly listed in the SWFWMD viewer for Application 907654 / ERP 47575.001 at the time of retrieval and the four-page recorded order in CCM-25-00069. Their verified facts are incorporated above; neither record approves the current bank, and the retrieved viewer archive is not represented as SWFWMD’s entire internal file.
- Pinellas County DRM-23-00102 and DRM-24-00066: native files and metadata, meeting recordings, complete comments, and omitted or oversized attachments.
- FDEP (opens in a new tab): project-, address-, parcel-, entity-, and representative-alias communications from January 1, 2020 forward, including meeting requests, referrals, jurisdiction/title work, submerged-lands correspondence, draft applications, and unposted records.
- U.S. Army Corps file SAJ-2025-02276-JLA: the PCN or application, precise Nationwide Permit number, plans, studies, delineations and jurisdictional determinations, section 401 and coastal-zone materials, mitigation-bank prospectus or instrument material, correspondence, RAI material and responses, public comments if any, conditions, decision, and current status, together with related pre-application meetings, RRS submissions, email, and attachments under the reviewed aliases. Open Jacksonville District records guidance (opens in a new tab).
Our demand: SWFWMD should not treat portal fragments as a complete administrative record. Require these documents, publish the material that lawfully belongs in the permit file, give residents a fair review period, and deny the application if the applicant cannot reconcile the missing records with its acreage, title, boundary, hydrology, construction, and financial-assurance claims.
Why closed files matter
Earlier designs are evidence of earlier requests—not a current answer
A later application can change earthwork, boundaries, credits, and labels—or keep them. Application 907654 is now the most recent detailed withdrawn design in the publicly retrieved record, and it proposed material work that the owner/proponent’s current “no earthwork” account must reconcile.
Where 930235 is silent, do not assume an old feature died and do not assume it survived.
Proponent’s main technical difference
Does “no earthwork” match the application history?
The public-facing promise and the withdrawn technical file do not describe the work the same way. The public record reviewed through September 16 does not yet resolve the difference.
Developer conservation site
The site describes planting and exotic-species removal and says there is “no earthwork associated” with the project.
Limitation: The conservation site is not an SWFWMD permit, staff report, or approval.
Withdrawn Application 889588
The earlier design described hydrologic restoration, pond/marsh conversion, seasonal-high-water-table analysis, ditch/berm features, vegetation work, and fencing—not planting alone.
Confirmed only as an owner/applicant statement on the withdrawn file
Applicant’s words: Lisa Cartwright, P.W.S., GreenSource Environmental Professionals, Inc., wrote in the August 14, 2024 RAI response: The overall design plan includes scraping down existing upland areas to create freshwater marsh wetlands, filling existing open water ponds to the seasonal high water elevation restoring freshwater marsh wetlands…
Open the applicant RAI response in the official Application 889588 record.
Limitation: A withdrawn design does not prove those details remain in the current application.
Current Application 930235
The applicants’ August 26 response now expressly says there is no earthwork associated with the project. At the same time, it seeks credit for restoring 10.92 acres of ponds to freshwater marsh and 0.73 acre of ditch to wetland forested mixed habitat, primarily through vegetation treatment and planting.
Limitation: This is the applicants’ design position. SWFWMD has not yet accepted the “no earthwork” approach or determined that the proposed hydrologic and vegetative measures support the requested credits.
Requires legal or technical interpretation
How the technical distinction should be tested
Creation and enhancement of wetland habitat commonly involve grading, excavation, filling, or other soil movement; preservation-only projects can be closer to “no earthwork.” This proposal is publicly described as restoration of a golf course, not preservation of an intact marsh.
Important limitation: That is a general technical distinction, not a finding that Chapter 62-342 requires earthwork on this site. The final answer depends on the complete plans, cross-sections, hydrologic design, conservation-easement exhibits, and agency review for Application 930235.
Withdrawn-file water record
Treated effluent and Brooker Creek
Applicant statement, not a District water-quality finding. The withdrawn file does not propose ending Pinellas County’s reclaimed-water disposal on these acres. It proposes keeping the quantity and routing it through created/restored marshes, with overflow to Brooker Creek.
What the applicant told Pinellas County Utilities
Lisa Cartwright’s April 18, 2024 letter, included as Attachment 7 to the August 14, 2024 applicant RAI response, says the site’s irrigation/stormwater lakes intermittently overflow to surface water bodies during storm events
; BCMB intends to maintain this Agreement
; The effluent discharges will flow through the wetland mitigation areas and ultimately discharge to Brooker Creek at specific elevations
; There will be no changes to the quantity of effluent discharges accepted on the Bank
; and spray irrigation will not be required.
Open the official Application 889588 response and Attachment 7.
What remains open
The August 21, 2024 Pinellas County BDRS project overview says the Reclaimed Water Use Agreement requires modification because of easement vacations for wetland construction and closure of the golf course. The reviewed record does not establish whether Application 930235 keeps the same routing, how the FDEP wastewater permit and Senate Bill 64 apply, or what water-quality outcome SWFWMD will find.
Important limitation: These are withdrawn-file applicant statements and a dated County snapshot. They do not establish the design or water-quality outcome of current Application 930235.
Evidence boundary
What we are not claiming
We are not claiming that either withdrawn design governs Application 930235; that the current “no earthwork” statement has been disproved or accepted by SWFWMD; that proposed work or potential credits in Application 907654 were approved; that Parcel 3 is outside the proposed bank; that title or conservation-easement authority is legally resolved; that continuing treated-effluent disposal is illegal; or that the current application will be approved or denied.
Last verifiedResearch cutoff for new facts. Recheck the live SWFWMD, County, FDEP, and federal records after seven days before relying on time-sensitive status.