|The mission of the Florida Native Plant Society is to|
promote the preservation, conservation, and restoration of
the native plants and native plant communities of Florida.
April 12, 2015
Robert Beltran, Executive Director
Southwest Florida Water Management District
2379 Broad Street
Brooksville, Florida 34604-6899
Subject: Comments on Proposal to Surplus District-held Conservation Lands
Dear Mr. Beltran:
The Florida Native Plant Society (Society) recognizes that the Southwest Florida Water Management District (District) is a critically important participant in Florida’s land conservation efforts. We hope you recognize the Society to be an especially supportive and engaged stakeholder given our regular participation on land management review teams, the assistance several of our local chapters have provided by conducting plant surveys on District lands, and the various other forms of support we have provided over the years.
We have evaluated the lands proposed for surplussing as part of the ongoing Biennial Assessment and disagree strongly with inclusion of a number of the parcels. The District has not shared any information on the assessment process that was used to assemble the list, and we believe such information must be shared with the public before a well-conceived proposal can be submitted for consideration by the Governing Board.
While we believe the surplussing of lands that truly lack conservation value is a responsible course of action, we also believe surplussing decisions must be based an expansive interpretation of what constitutes conservation value, and the adoption of a long-range view. The tremendous investment the public has made in funding these acquisitions, and will continue to make to ensure the lands are properly managed, demands nothing less.
Green Swamp Wilderness Preserve (GSWP)
The GSE-1, GSE-2 and GSE-3 parcels (left) are proposed to be surplussed with a conservation easement retained over them. Decisions on whether relinquishing fee title ownership is justified should be based first and foremost on whether the natural and societal values of a subject parcel can be conserved effectively through less-than-fee ownership. “Working landscapes” that provide income for a fee-title owner while conserving natural resources that benefit the public will be an essential part of the “mix” in Florida’s efforts to create a viable, sustainable network of conservation lands. The upland portions of GSE-1 have been converted to improved pasture, it is contiguous with other lands protected through easements, and is within an approved Florida Forever project area that has identified easements as a suitable mechanism for protection. We believe it may be appropriate to sell fee-title to GSE-1, provided a highly restrictive easement is retained that would preclude conversion of unaltered areas, logging in wetlands, extractive uses or subdivision, and that limit future uses to agricultural or silvicultural uses that would be compatible with conservation objectives for the Green Swamp. It should also include a requirement that invasive plants be controlled and any fire-maintained habitats be subjected to burns.
“Mega-Parcel” projects like Annutteliga Hammock are incredibly challenging. They require a long-term commitment and patience. We believe a decision to surplus the large number of small and largely disjunct parcels acquired through this project is premature. There is also a 160-acre parcel in the northwest corner of the project area that has superlative stand-alone conservation value, yet it is proposed for surplus. As illustrated by the series of maps below, the Annutteliga Hammock project seeks to conserve a land area with extraordinary natural significance. Recharge rates are as high as any recorded in the state. The corollary of this is that the vulnerability of the Floridan aquifer to contamination equally high – with the main headwater springs of the Chassahowitzka River less than 2 miles to the northwest. Minimizing development in this area, and the threat of groundwater contamination that it poses, should be factored into any decisions to surplus lands here. The Priority 2 Ecological Greenway ranking of the GSWP parcels discussed previously is significant; this project is a Priority 1 “Critical Linkage” and represents the last viable opportunity to maintain functional connectivity between the Chassahowitza complex of conservation lands along the coast and the Withlacoochee State Forest to the northeast.
Lastly, it should be noted the sandhill habitat of the project area is another Under-Represented Natural Community. Listed species known to inhabit the sandhill habitats of the Annuttliga Hammock and adjoining public lands include the Sherman’s fox squirrel, gopher tortoise, Florida mouse, gopher frog, giant orchid, Chapman’s skeletongrass, Florida pine snake, small-tailed snake, and pine pinweed.
Little Manatee River Corridor Southfork Tract
The parcels discussed above, and many others on your list, merit a much more in-depth discussion than we have provided here. For example, we are also especially concerned by the proposal to surplus two parcels within the Halpata Tastanaki Preserve, where the District’s history of habitat restoration and effective land management are achieving great success. That success is clearly illustrated by an observed expansion of the local Florida scrub jay population. These parcels provide an excellent opportunity to expand the population even more through habitat restoration given the xeric soils that underlie them. Indeed, if jays already inhabit these parcels, any actions that exclude them could be considered a taking of a federally-listed species and a violation of the Endangered Species Act. A federally listed plant species – the endangered longspur balm – may also occur on these xeric soils. The Preserve, in combination with the neighboring Ross Prairie State Forest, constitutes the only area of significant core habitat along the entire Cross Florida Greenway, from the Ocala National Forest to the Gulf of Mexico. We believe virtually every acre now under public ownership should be retained.
The District has the staff and other resources to conduct a comprehensive assessment of these lands you hold in trust for the public. The Society does not enjoy the benefit of such resources, yet there is little evidence to indicate that you have conducted an assessment as discerning as ours. We ask that you conduct a scientifically rigorous and transparent evaluation before you finalize the Biennial Assessment. We stand ready to assist you in any way we can, and look forward to continuing our constructive relationship with the District. Thank you for considering our concerns.
Florida Native Plant Society
full-size map images can be viewed on the FNPS Flickr page