In my town there is an attempted rezone of an area. The request would change the area for the worse forever. The area in question is residential, with our state park, Stump Pass State Park to the south. This park being. My happy place. A place where one could go and feel they could get away. Unencumbered by the world’s stress. This development directly negatively impacts it. Also the sea turtles and shorebirds that depend on it for reliable habitat and foraging grounds. 

My letter to zoning and commissioners. 

Members of the BOCC:

My name is Carol McCoy. I am a full-time resident and taxpayer in Charlotte County, and I have served as a volunteer sea turtle monitor with the Coastal Wildlife Club for more than ten years.

The application materials submitted for this rezoning appear to be incomplete, and I have specific questions that I want answered on the public record.

I am against the re-zone for the reasons listed below:

THE SCALE OF THIS PROJECT DEMANDS SCRUTINY

The Manasota Key Resort currently operates 85 units. This application seeks to expand to 246 units — nearly three times the current size. This is a barrier island served by one narrow two-lane road — Beach Road and Gulf Boulevard, County Road 776 — and one drawbridge over Lemon Bay. There is already limited parking. The infrastructure of this island was not designed for development of this scale.

I am not opposed to business. I am asking whether this board has fully examined what a project of this magnitude means for the infrastructure, the taxpayers, the wildlife, and the human safety of this specific location — before it votes.

THIS BEACH AND SHORELINE SUPPORT PROTECTED WILDLIFE

The beach behind this resort is not simply a nice beach. In 2014, the U.S. Fish and Wildlife Service formally designated Manasota Key as critical habitat for the loggerhead sea turtle under the Endangered Species Act — an official federal determination that this beach contains the physical and biological features essential to the conservation of a threatened species. Manasota Key is also within the area proposed for critical habitat designation for the North Atlantic Distinct Population Segment of the green sea turtle, which would add a second layer of federal protection to this same beach.

The nesting area immediately surrounding this resort is a large, U-shaped stretch of beach — not a single linear strip, but an envelope of habitat that gives nesting sea turtles open, sandy access from multiple directions. CWC has documented nesting here by loggerhead, green, and in 2024, Kemp’s ridley sea turtles — the most critically endangered sea turtle in the world. A development expanding to 246 units, with its associated lighting, construction disturbance, increased foot traffic, and hard coastal structures, threatens that entire nesting envelope.

This beach and the adjacent Lemon Bay shoreline are also important habitats for migratory and resident shorebirds and seabirds. Florida’s Gulf Coast lies within the Atlantic Flyway — a major migratory corridor used by hundreds of bird species traveling between their northern breeding grounds and southern wintering areas.

Charlotte County’s own natural resources documentation confirms that county beaches, including this stretch, provide nesting and foraging habitat for state-threatened species including the least tern, black skimmer, American oystercatcher, and snowy plover. These birds nest directly on the sand, making them especially vulnerable to development, lighting, construction activity, and increased human presence. All native bird species are additionally protected under the federal Migratory Bird Treaty Act, regardless of whether they migrate. Beyond the birds, this beach and surrounding area also supports gopher tortoises, another state-listed species.

The wildlife value of this location does not belong only to conservation advocates. It belongs to every resident, every tourist, every birder, every angler, and every family that visits this island. It is part of what makes this place worth protecting — and worth visiting.

Given the documented presence of three sea turtle species and multiple state-threatened shorebirds, this application should have been referred to the Florida Department of Environmental Protection and the Florida Fish and Wildlife Conservation Commission before reaching this board. FDEP has jurisdiction over coastal construction and the adjacent Lemon Bay Aquatic Preserve. FWC has direct authority over sea turtle and shorebird protection in Florida. Neither agency appears to have been consulted, and that is a serious gap in this review process.

TWO PROTECTED DESIGNATIONS — ONE PROPERTY

Lemon Bay — the body of water the Tom Adams Bridge crosses, and the bay that borders this property on its eastern side — is a state-designated Aquatic Preserve and an Outstanding Florida Waterbody, managed by FDEP. This property sits between two formally protected resource designations: federally designated critical habitat on the Gulf side, and a state Aquatic Preserve on the bay side. That context is absent from this application and should not be.

QUESTION 1: THE SEA WALL

The sea wall of concern is located on the Gulf beach side of the property, behind the garage structure. There are additional, disconnected sea walls to the north and south. The U-shaped nesting beach wraps around this entire area.

This project involves construction on a federally designated critical habitat beach that receives federal funds for periodic renourishment. Rebuilding, expanding, or modifying a sea wall in this context may require authorization from the Army Corps of Engineers and a state permit from FDEP.

Has either permit been applied for? If so, those documents are public records and should be in this application. They are not.

QUESTION 2: THE ROAD AND THE BRIDGE

Tripling the resort’s capacity will generate a permanent and significant increase in traffic on a two-lane island road. Large construction trucks will cross the Tom Adams Bridge repeatedly over an extended construction period. The road and bridge may require reinforcement to handle both the construction phase and long-term increased use.

The Tom Adams Bridge is a drawbridge over the Intracoastal Waterway. As such, it is subject to U.S. Coast Guard regulatory oversight independent of county ownership.

Any structural modification involves federal jurisdiction. The bridge also sustained significant structural damage during Hurricane Milton in 2024 — undermining at all four quadrants — and has since been repaired by Charlotte County.

My question: are any public funds — county, state, or federal — anticipated for road or bridge upgrades as a result of this project? That disclosure is not in this application, and it should be.

QUESTION 3: PROCESS CONCERNS

A traffic study was conducted for this project — during the summer months. In Southwest Florida, summer is our lowest-traffic season. Peak season, when roads and the bridge carry their highest loads, runs fall through spring. A study conducted during the off-peak season does not reflect real-world conditions. I am asking this board whether it considers that study adequate, and if not, to require a peak-season study before any vote.

An environmental survey appears to have been waived for this project. On a federally designated critical habitat beach bordered by a state Aquatic Preserve, with documented nesting by three sea turtle species and state-threatened shorebirds, that decision demands a public explanation. I want to know, was a waiver authorized that waiver, who waived it, under what authority, and why. That answer belongs on the record.

QUESTION 4: EMERGENCY EVACUATION AND HUMAN SAFETY

Manasota Key is Evacuation Zone A — the highest-risk category in Charlotte County, ordered to evacuate first in every storm. Charlotte County issued Zone A evacuation orders for Manasota Key during Hurricane Ian, Hurricane Helene, and Hurricane Milton, three major events in three years. Charlotte County has no certified Red Cross shelters; evacuees may need to travel to another county.

This project would nearly triple the number of guests, employees, and visitors who would need to evacuate across one two-lane road and one drawbridge. Its long-term load capacity under storm conditions has not been publicly evaluated in connection with this application.

Emergency evacuation planning for a project of this scale on a Zone A barrier island is not optional. 

I am asking this board: have the following agencies been consulted, and where are the records of that consultation?

Charlotte County Office of Emergency Management — primary Zone A evacuation authority.

Florida Division of Emergency Management — state coordination required under Florida Statute Chapter 252.

Charlotte County Sheriff’s Office — evacuation traffic and public safety.

Charlotte County Fire and EMS — emergency response capacity on a barrier island.

Florida Department of Health, Charlotte County — medical evacuation and special needs planning.

U.S. Coast Guard — marine evacuation if road or bridge access is lost during a storm.

The Florida Legislature, in Chapter 252, specifically identified growth in coastal populations and seasonal visitors as factors complicating the state’s ability to coordinate emergency management. These are life-safety questions, not bureaucratic ones. They were not addressed in this application.

MY FORMAL REQUEST TO THIS BOARD

I am requesting that this board require the applicant to provide, prior to any approval vote:

1. Documentation of any Army Corps of Engineers or FDEP permit applications or determinations related to the Gulf-side sea wall.

2. Referral to FDEP for evaluation of coastal construction impacts and impacts to the Lemon Bay Aquatic Preserve.

3. Referral to FWC for evaluation of impacts to sea turtle nesting habitat, state-threatened shorebirds (least tern, black skimmer, American oystercatcher, snowy plover), and other state-listed species including the gopher tortoise.

4. Documentation of any U.S. Coast Guard coordination related to the Tom Adams Bridge in connection with this project.

5. Documentation of any FDOT or U.S. DOT involvement related to County Road 776.

6. A complete disclosure of all public and private funding sources for every component of this project, including infrastructure.

7. A public explanation of who authorized the waiver of an environmental survey, under what authority, and why.

8. A peak-season traffic study that reflects real-world conditions, including bridge load capacity.

9. Written confirmation from the Charlotte County Office of Emergency Management, Florida Division of Emergency Management, Charlotte County Sheriff, Fire and EMS, and Florida Department of Health that each has reviewed and accepted the evacuation implications of nearly tripling resort capacity on a Zone A barrier island.

This beach is sandwiched between two formally protected resource designations. It is served by one road and one storm-damaged bridge. It sits in Evacuation Zone A in a county with no certified Red Cross shelter. A project proposing to triple the density of this location required a thorough, transparent, multi-agency review — an off-season traffic study and a waived environmental survey are not that. The people of this county, the visitors who would stay in those 246 units, and the wildlife this shoreline supports all deserve better before this board acts.

Thank you.
Carol McCoy
Englewood, FL 

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