TO WHOM IT MAY CONCERN: The Jacksonville District of the U.S. Army Corps of Engineers (Corps) has received an application for a Department of the Army permit pursuant to Section 404 of the Clean Water Act (33 U.S.C. §1344) and Section 10 of the Rivers and Harbors Act of 1899 (33 U.S.C. §403) as described below.
If you are interested in receiving an electronic copy of the project drawings associated with this Public Notice for the proposed project described, please send an e-mail to the project manager by electronic mail at Terri.M.Mashour@usace.army.mil.
APPLICANT: Florida Department of Environmental Protection,
Division of Recreation and Parks
Attention: David Matson
3800 Commonwealth Boulevard, MS 520
Tallahassee, Florida 32399
WATERWAY AND LOCATION: The project would affect aquatic resources associated with the Atlantic Ocean. The project site is located within Anastasia State Park, 300 Anastasia Road, Sections 9, 16, 21, 22, and 27, Township 7 South, Range 30 East, St. Augustine, Florida 32080. The proposed work would encompass approximately 3.5 miles of undeveloped beachfront property along the Atlantic Ocean shoreline between Range (R) Monuments R-126 – R-141.
Directions to the site are as follows: To drive from the U.S. Army Corps of Engineers Jacksonville Office to the project site, travel south on Interstate (I) – 95 for 31 miles. Take Exit 318 towards St. Augustine. Turn left onto FL-6-E, continue for 5.3 miles, then turn right onto North Ponce De Leon Boulevard. Travel for 1.3 miles, turn left onto West Castillo Drive, then continue for 0.3 miles to reach the A1A Scenic and Historic Coastal Byway and take a right. Travel for 0.5 miles, then turn left at the light and cross over the Bridge of Lions. Continue for approximately 2.1 miles and turn left into Anastasia State Park beach parking lot (pay to enter the Florida State Park). The beach parking area would be the staging area for the project. A dune walkover provides access to the beach. The project runs ~3.5 miles from south of the St. Augustine Inlet (R-126) to the southern boundary of the park (R-141).
APPROXIMATE CENTRAL COORDINATES: Latitude 29.880276°
Longitude -81.271122°
PROJECT PURPOSE:
Basic: The basic project purpose is shoreline stabilization and protection
Overall: The overall project purpose is to stabilize and protect the eroding shoreline between R-126 and R-141 along the Atlantic Ocean in St. Augustine, Anastasia State Park, St. Johns County.
EXISTING CONDITIONS: The system consists of a marine, saltwater system. The onsite vegetation consists of sand and no material would be placed in the vegetated dunes. The existing area surrounding the project area consists of Anastasia State Park.
PROPOSED WORK: The applicant seeks authorization for the following:
1. To place 580,000-cubic-yards of clean fill into 114.48 acres of aquatic resources (30,000-cubic-yards into 2.60-acres between the high tide line and the mean high water line (404 waters), 550,000-cubic-yards into 111.88-acres waterward of the mean high water line (Section 10/404 waters)) for shoreline stabilization and protection. The applicant proposes to utilize upland sand sources for sand placement, including the Goldhead Sand Mine, the Keuka Sand Mine, the Florida Inland Navigation District’s (FIND) Dredge Material Management Area (DMMA) FL-3 in Flagler County and FIND DMMA V-26 in Volusia County as additional sand sources.
There would be 770,000-cubic-yards of additional sand placed into 78.76 acres of uplands landward of the high tide line, which is an area that is not under the jurisdiction of the Corps; however, the proposed work would be reviewed pursuant to the National Environmental Policy Act (NEPA), Section 106 of the National Historic Preservation Act (NHPA), and the Endangered Species Act (ESA). The total proposed initial placement event for the proposed template would be 1,350,000-cubic-yards placed into 193.24 acres of uplands and aquatic resources for the dune and berm.
2. The applicant proposes an estimate of 3 renourishment events over the life of the proposed 15 year authorization for maintenance events in case storms create additional erosion. The applicant proposes to place up to 1,350,000-cubic-yards of fill into 193.24 acres (580,000-cubic-yards of clean fill into 114.48 acres of aquatic resources (30,000-cubic-yards and 2.60-acres between the high tide line and the mean high water line (404 waters), 550,000-cubic-yards into 111.88-acres waterward of the mean high water line (Section 10/404 waters), and 770,000-cubic-yards of sand placed into 78.76 acres of uplands landward of the high tide line) for each renourishment event.
The project design achieves a generally uniform post-construction dune and extension of the mean high water (MHW) line (+1.64 feet-NAVD88). The template fill density averages 83 cubic yards per foot across the project area. However, the fill density placed during construction may deviate significantly (up or down) from this average dependent on conditions during construction. The south end of the project is intended to tie into the USACE St. Augustine Shore Protection Project (SPP), which includes a fill taper from R-136.5 to R-139. Depending on sand availability and conditions during construction, this project may, or may not, occur concurrently with a future nourishment of the USACE St. Augustine SPP, so the actual southern limit of fill may fall somewhere between R-136.5 and R-141. As currently proposed, the template has a dune with a uniform crest width of 20 feet and a uniform crest elevation of +12 foot-NAVD88. Where the dune cannot tie into the existing dune, the fill will slope landward 1V:5H to the existing grade. The seaward dune face extends at a 1V:5H seaward slope to the berm, which has a uniform elevation of +9 foot-NAVD88, consistent with the USACE St. Augustine SPP to the south. The template MHW extension of 75 feet creates a berm that varies in width from approximately 100 feet to 250 feet, dependent on existing conditions. Notably, R-127 through R-131A, R-133, and R-134 include a greater extension of the MHW line due to the significant nearshore bar feature observed in the profile data and the dune washout area observed between R-130 and R-131A. From the seaward edge of the berm, the template slopes 1V:20H to existing elevations. Throughout the project, the beach fill ties into the existing beach at an elevation between -4 foot-NAVD88 and -14 foot-NAVD88. The entire template has a capacity of approximately 1,350,000 cubic yards (83 cubic yards/foot on average) relative to March/July 2023 conditions; notably, this will vary based on existing conditions and should be reevaluated prior to construction. Of the total capacity, ~30,000 cubic yards are below the High Tide Line (HTL, +2.01 foot-NAVD88) but above the MHW line (+1.64 foot-NAVD88), and ~550,000 cubic yards are below the MHW line. In total, the proposed placement area covers 193.24 acres.
AVOIDANCE AND MINIMIZATION INFORMATION – The applicant has provided the following information in support of efforts to avoid and/or minimize impacts to the aquatic environment:
“The applicant would comply with typical impact minimization measures required by Florida Department of Environmental Protection (FDEP) for beach and dune restoration activities, as detailed in the Listed Species Protection Plan and the ASP Beach/Dune Restoration Project Task 1 Project Narrative.
For work landward of the mean high water line (MHWL), the applicant would require the contractor(s) to conduct the project in compliance with all applicable terms and conditions of the following biological opinions:
• United States Fish and Wildlife Service (USFWS) 2015 Statewide Programmatic Biological Opinion (SPBO) for the Corps Civil Works & Regulatory Sand Placement Activities in Florida.
• 2013 Programmatic Piping Plover Biological Opinion (P3BO) for the effects of Corps Planning and Regulatory Shore Protection Activities on the Non-Breeding Piping Plover (Charadrius melodus) and its Designated Critical Habitat.
For work below the MHWL, the applicant would also require the contractor(s) to comply with all applicable Project Design Criteria listed in the National Marine Fisheries Service (NMFS) 2020 South Atlantic Regional Biological Opinion (SARBO).
Depending on the construction means and methods, the applicant will also require the Contractor(s) to comply with the following protection measures, as applicable:
• 2011 Standard Manatee Conditions for In-Water Work
• 2012 Measures for Reducing Entrapment Risk to Protected Species
• 2021 Protected Species Construction Conditions
• 2021 Standard Protection Measures for The Eastern Indigo Snake
• 2009 North Atlantic Right Whale Protection Measures.
Driving on the beach would be limited to the minimum necessary to complete the project (or any future maintenance events) with the Contractor(s) to establish driving corridors as necessary through coordination with park staff and FWC representatives.
Any sediment placed within the proposed project’s footprint would meet the quality standards laid out in the sediment Quality Assurance/Quality Control plans. For projects that include truck haul, the applicant would require the Contractor(s) to cover all trucks to prevent sand spillage during transport to the fill site. No unpermitted impacts to dune vegetation or listed species would be allowed. The Contractor(s) would utilize off-beach construction staging areas to keep equipment off the beach when no construction activities occur. A driving route would be selected for beach access based on current conditions at the time of construction. Following construction, all staging and ingress/egress areas would be restored to their pre-construction condition, including grading and/or vegetation, to the satisfaction of FDEP. No unpermitted impacts to dune vegetation or listed species shall be allowed. In addition to the placement of sand, dune restoration would also feature plantings (and optional sand fence installation) following construction.”
COMPENSATORY MITIGATION – The applicant has provided the following explanation why compensatory mitigation should not be required:
“Compensatory mitigation is not proposed for this project. The project's impacts to
jurisdictional waters have been avoided and minimized to the maximum extent practicable. The proposed activities are limited in scope, utilize existing infrastructure and previously disturbed areas as applicable for staging and access, and focus on restoring and nourishing the beach and protective dune within the park. Furthermore, the project does not involve any direct or secondary impacts to protected resources.
Within the project footprint and adjacent seafloor, there are no protected resources such as seagrasses, mangroves, or nearshore hardbottom. Where material is placed landward of the MHW line, wave and current action are minimized, limiting distribution of the material. Where material is placed in the nearshore, natural wave and current action will distribute the material within the surf zone and beach over time. This process aligns with the natural sediment dynamics in the area. Therefore, due to the project's minimal impacts and focus on beach restoration, compensatory mitigation is not considered prudent or necessary.
CULTURAL RESOURCES:
The Corps is aware of recorded historic resources within or adjacent to the permit area and is evaluating the undertaking for effects to historic properties as required under Section 106 of the National Historic Preservation Act. This public notice serves to inform the public of the proposed undertaking and invites comments including those from local, State, and Federal government Agencies with respect to historic resources. Our final determination relative to historic resource impacts may be subject to additional coordination with the State Historic Preservation Officer, those federally recognized tribes with concerns in Florida and the Permit Area, and other interested parties.
ENDANGERED SPECIES:
Species under the purview of the United States Fish and Wildlife Service (USFWS):
Anastasia Island Beach mouse: Anastasia Island beach mouse (Peromyscus polionotus phasma) distribution has declined significantly to Anastasia State Park to the Matanzas Inlet and they are also located along sections of the 4.2 miles of dune habitat at the Guana Tolomato Matanzas National Estuarine Research Reserve. For beach mouse protection, beach mouse habitat shall be avoided when selecting sites for equipment, pipes, vehicle storage and staging, and beach travel corridors to the maximum extent possible. Equipment placement or storage shall be excluded in the areas between 5 to 10 feet seaward of the existing dune toe in areas of occupied beach mouse habitat. Existing beach access points shall be used for vehicle and equipment beach access; location of new or expanded existing beach access corridors for vehicles and equipment shall be placed no closer than every 4 miles. Additionally reporting shall be submitted to the USFWS by December 31 after completion of construction related to the beach mouse, including acreage of new or widened access areas affected in beach mouse habitat, vegetation completed for new or widened access areas, and success rate of vegetation restoration. The activities are expected to directly or indirectly adversely affect Anastasia Island Beach Mice; however, the proposed project has undergone an evaluation process by the Corps to determine that it properly fits within a programmatic approach and it is appropriate to apply to the SPBO programmatic consultation. The Corps has determined that the minimization measures, Reasonable and Prudent Measures, and Terms and Conditions in the SPBO are applicable to the project, and the proposed work will be covered by the SPBO programmatic consultation. The Corps will request USFWS concurrence with this determination pursuant to Section 7 of the Endangered Species Act under separate cover.
Nesting Sea Turtles: The proposed work would result in sand placement along the Atlantic Ocean shoreline, which is nesting habitat for nesting sea turtles, specifically loggerhead (Caretta caretta), green (Chelonia mydas), Kemp’s ridley (Lepidochelys kempii), leatherback (Dermochelys coriacea), and hawksbill (Eretmochelys imbricata). Therefore, the Corps evaluated the route of effects the project would have on these species. The applicant has stated, and the Corps has verified, that the proposed project would follow all minimization measures, conservation measures, Reasonable and Prudent Measures, and Terms and Conditions found in the SPBO. The project may overlap sea turtle nesting season; however, the SPBO, dated March 13, 2015, states that in St. Johns County, Florida, sand placement may occur during the sea turtle nesting season. Additionally, the land manager must be involved with the project if the proposed work is on public land. In this case, the applicant is the land manager, Anastasia State Park. Protective, avoidance, and minimization measures have been incorporated into the project plan to avoid or minimize the potential impacts from the sand placement activities on nesting sea turtles. However, even with these measures, impacts to sea turtles are expected to occur from some aspects of the project activities. The activities are expected to directly or indirectly adversely affect nesting sea turtles; however, the proposed project has undergone an evaluation process by the Corps to determine that it properly fits within a programmatic approach and it is appropriate to apply to the SPBO programmatic consultation. The Corps has determined that the minimization measures, Reasonable and Prudent Measures, and Terms and Conditions in the SPBO are applicable to the project, and the proposed work will be covered by the SPBO programmatic consultation. The Corps will request USFWS concurrence with this determination pursuant to Section 7 of the Endangered Species Act under separate cover.
West Indian Manatee: The project site is accessible to the endangered West Indian manatee (Trichechus manatus). Heightened awareness of the possibility that marine mammals may occur in the project area and implementing the various precautions mandated in the Marine Mammal Protection Act would decrease the possibility of inadvertently harming manatees. Adherence to the Standard Manatee Construction Conditions would minimize the project’s effects on the manatee. Protective avoidance and minimization measures have been incorporated into the project plan to avoid or minimize the potential impacts from the sand placement activities on West Indian manatee. The 2011 Standard Manatee In-water Construction Conditions would be made a condition of any authorization; therefore, the Corps has determined that the proposed sand placement activities are not likely to adversely affect the Florida manatee or adversely modify its critical habitat. In addition, because no incidental take of manatees is anticipated, no such authorization under the Marine Mammal Protection Act (MMPA) is needed. The Corps has determined that the minimization measures, Reasonable and Prudent Measures, and Terms and Conditions in the SPBO are applicable to the project, and the proposed work will be covered by the SPBO programmatic consultation. The Corps intends to utilize the SPBO to conclude that the Project may affect, but is not likely to adversely affect the West Indian manatee. The Corps will request USFWS concurrence with this determination pursuant to Section 7 of the Endangered Species Act under separate cover.
Piping Plover and Rufa Red Knot: The Atlantic Ocean shoreline contains habitat for the threatened Piping Plover (Charadrius melodus) and the threatened Rufa Red Knot (Calidris canutus rufa). The site is not located in designated critical habitat for the Piping Plover. Based on the documentation provided, the applicant would follow all minimization measures, conservation measures, Reasonable and Prudent Measures, and Terms and Conditions found in the Piping Plover Programmatic Biological Opinion (P3BO) to ensure there would be no impacts to any Piping Plover, if found to be present within the project area. Therefore, the Corps determined that the project may affect, but is not likely to adversely affect, the Piping Plover. The applicant would adhere to the same P3BO conditions for the Rufa Red Knot to ensure there would be no impacts to any Rufa Red Knot if they were found to be present within the project area. Therefore, with the implementation of the P3BO Conservation Measures, the Corps has determined the proposed activities may affect, but are not likely to adversely affect the Rufa Red Knot in areas not identified as Optimal Rufa Red Knot Areas. The Corps will request USFWS concurrence with these determinations pursuant to Section 7 of the Endangered Species Act under separate cover.
Wood Stork: The Corps has determined the proposed project may affect, but is not likely to adversely affect the Wood Stork (Mycteria americana). The project site is within the 13-mile United States Fish and Wildlife Service (USFWS) North Florida core foraging area for a Wood Stork nesting colony. The Corps evaluated potential effects to Wood Stork using The Corps of Engineers, Jacksonville District, U.S. Fish and Wildlife Service, Jacksonville Ecological Services Field Office and State of Florida Effect Determination Key for the Wood Stork in Central and North Peninsular Florida, September 2008. Use of this key resulted in the sequential determination A > B > no effect, as the project would not impact suitable foraging habitat. Therefore, no additional consultation is required.
Eastern Indigo Snake: The Corps has determined the proposed project may affect, but is not likely to adversely affect the eastern indigo snake (Drymarchon corais couperi). The dune within the project area is currently severely eroded and the vegetation has been significantly impacted in this area; therefore, habitat for the eastern indigo snake is limited within the sand placement areas. Based on the information above, the Corps utilized the Eastern Indigo Snake Programmatic Effect Determination Key, January 25, 2010, addendum August 13, 2013, which resulted in the sequence A > B > C > D > E > not likely to adversely affect as there are less than 25 gopher tortoise burrows, holes, cavities or other refugia where a snake could be buried or trapped or injured during project activities, and any permit authorization would be conditioned to follow the Standard Protection Measures for Eastern Indigo Snake dated March 23, 2021. Therefore, no additional consultation is required.
USFWS Critical Habitat: The proposed work would be located within USFWS loggerhead sea turtle terrestrial critical habitat of the Northwest Atlantic Ocean loggerhead sea turtle population. The applicant would follow the minimization measures, conservation measures, Reasonable and Prudent Measures, and Terms and Conditions found in the SPBO. Additionally, loggerhead sea turtle habitat would be improved by the proposed work as additional sand would be added to the beach to allow for nesting. Therefore, the Corps has determined that the proposed projects “may affect, but are not likely to adversely affect” the terrestrial critical habitat of the Northwest Atlantic Ocean loggerhead sea turtle population. The Corps will request USFWS concurrence with this determination pursuant to Section 7 of the Endangered Species Act under separate cover.
Species under the purview of the National Marine Fisheries Service (NMFS):
Swimming sea turtles: Loggerhead (Caretta caretta), green (Chelonia mydas), Kemp’s ridley (Lepidochelys kempii), leatherback (Dermochelys coriacea), and hawksbill (Eretmochelys imbricata), Atlantic sturgeon (Acipenser oxyrinchus oyrinchus), Shortnose sturgeon (Acipenser brevirostrum), Smalltooth Sawfish (Pristis pectinata), Giant Manta Ray (Manta birostris), and North Atlantic Right Whale (Eubalaena glacialis): The Corps has determined the project may affect the threatened swimming sea turtles (Chelonia mydas, Eretmochelys imbricata, Lepidochelys kempii, Dermochelys coriacea, Caretta caretta): The Corps has determined the project may affect but is unlikely to adversely affect the smalltooth sawfish (Pristis pectinata), the Giant Manta Ray (Manta birostris) and the Northern Right Whale (Eubalaena glacialis). The Corps will review the proposed project for compliance with the National Marine Fisheries Service (NMFS) 2020 South Atlantic Regional Biological Opinion (SARBO). If required, the Corps will request initiation of formal consultation with NMFS pursuant to Section 7 of the Endangered Species Act by separate letter.
NOAA Coastal Critical Habitat: Sea turtle, loggerhead (Caretta caretta) LOGG-N-14 Nearshore Reproductive Habitat, North Atlantic Right Whale (Eubalaena glacialis) Unit 2 Southeastern U.S. Calving Area, sea turtle green (Chelonia mydas) FL01 Florida: The Corps has determined the proposed work may affect but is unlikely to adversely affect the loggerhead (C. caretta) designated migratory, breeding and reproductive critical habitats. The Corps will review the proposed project for compliance with the National Marine Fisheries Service (NMFS) 2020 South Atlantic Regional Biological Opinion (SARBO). If required, the Corps will request initiation of formal consultation with NMFS pursuant to Section 7 of the Endangered Species Act by separate letter.
On November 15, 2024, the Corps executed Regulatory Screening Tool (RST) from the National Regulatory Viewer for the Borrow Area 3A, pipeline area, the shoreline and the staging areas. The RST indicated that the Information for Planning and Consultation (IPAC) species that are found within Flagler County and could also be located at this project site include the Eastern Black rail (Laterallus jamaicensis ssp. jamaicensis), Florida scrub-jay (Aphelocoma coerulescens), and tricolored bat (Perimyotis subflavus). The project site does not include habitat to support these species; therefore, routes to effects for these species were not reviewed. The RST did not indicate that the site is utilized by, or contains habitat critical to, any federally listed threatened or endangered species, other than those mentioned above. The Corps also reviewed geospatial data and other available information. The Corps has not received or discovered any information that the project site is utilized by, or contains habitat critical to, any federally listed, threatened, or endangered species, other than those mentioned above.
ESSENTIAL FISH HABITAT (EFH): This notice initiates consultation with the National Marine Fisheries Service on EFH as required by the Magnuson-Stevens Fishery Conservation and Management Act 1996. The proposal would impact approximately 111.88 acres of open water waterward of the mean high water line utilized by various life stages of lemon shark, bluefish, bonnethead shark (Atlantic Stock), tiger shark, sailfish, bull shark, Atlantic Sharpnose shark (Atlantic Stock), summer flounder, sand tiger shark, clearnose skate, shrimp, sandbar shark, spinner shark, Atlantic butterfish, snapper grouper, basking shark, blacktip shark, finetooth shark, windowpane founder, blacknose shark, coastal migratory pelagics, scalloped hammerhead shark, spiny lobster, spinner shark, and Atlantic butterfish. Our initial determination is that the proposed action would not have a substantial adverse impact on EFH or Federally managed fisheries in the South Atlantic Region. Our final determination relative to project impacts and the need for mitigation measures is subject to review by and coordination with the National Marine Fisheries Service.
NAVIGATION: The proposed activity is located in the vicinity of a federal navigation channel.
SECTION 408: The applicant will require permission under Section 14 of the Rivers and Harbors Act (33 USC 408) because the activity, in whole or in part, would alter, occupy, or use a Corps Civil Works project.
NOTE: This public notice is being issued based on information furnished by the applicant. This information has not been verified or evaluated to ensure compliance with laws and regulation governing the regulatory program. The jurisdictional line has not been verified by Corps personnel.
COMMENTS regarding the potential authorization of the work proposed should be submitted in writing to the attention of the District Engineer through the Jacksonville Permits Section, address at the letterhead above, within 30 days from the date of this notice.
The decision whether to issue or deny this permit application will be based on the information received from this public notice and the evaluation of the probable impact to the associated wetlands. This is based on an analysis of the applicant's avoidance and minimization efforts for the project, as well as the compensatory mitigation proposed.
QUESTIONS concerning this application should be directed to the project manager, Terri M. Mashour, in writing at the Jacksonville Permits Section, address at the letterhead above; by electronic mail at Terri.M.Mashour@usace.army.mil; or by telephone at (904) 251-9179.
IMPACT ON NATURAL RESOURCES: Coordination with U.S. Fish and Wildlife Service, Environmental Protection Agency (EPA), the National Marine Fisheries Services, and other Federal, State, and local agencies, environmental groups, and concerned citizens generally yields pertinent environmental information that is instrumental in determining the impact the proposed action will have on the natural resources of the area.
EVALUATION: The decision whether to issue a permit will be based on an evaluation of the probable impact including cumulative impacts of the proposed activity on the public interest. That decision will reflect the national concern for both protection and utilization of important resources. The benefits, which reasonably may be expected to accrue from the proposal, must be balanced against its reasonably foreseeable detriments. All factors which may be relevant to the proposal will be considered including cumulative impacts thereof; among these are conservation, economics, esthetics, general environmental concerns, wetlands, historical properties, fish and wildlife values, flood hazards, floodplain values, land use, navigation, shoreline erosion and accretion, recreation, water supply and conservation, water quality, energy needs, safety, food, and fiber production, mineral needs, considerations of property ownership, and in general, the needs and welfare of the people.
The US Army Corps of Engineers (Corps) is soliciting comments from the public; Federal, State, and local agencies and officials; Indian Tribes; and other Interested parties in order to consider and evaluate the impacts of this proposed activity. Any comments received will be considered by the Corps to determine whether to issue, modify, condition, or deny a permit for this proposal. To make this determination, comments are used to assess impacts to endangered species, historic properties, water quality, general environmental effects, and the other public interest factors listed above. Comments are also used to determine the need for a public hearing and to determine the overall public interest of the proposed activity.
WATER QUALITY CERTIFICATION: Water Quality Certification may be required from the Florida Department of Environmental Protection.
COASTAL ZONE MANAGEMENT ACT CONSISTENCY: In Florida, the State approval constitutes compliance with the approved Coastal Zone Management Plan. In Puerto Rico, a Coastal Zone Management Act Concurrence is required from the Puerto Rico Planning Board. In the Virgin Islands, the Department of Planning and Natural Resources permit constitutes compliance with the Coastal Zone Management Plan.
REQUEST FOR PUBLIC HEARING: Any person may request a public hearing. The request must be submitted in writing to the District Engineer within the designated comment period of the notice and must state the specific reasons for requesting the public hearing.
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