Toll Roads Analysis - Detailed Assessment of Impacts on Native Plants and Native Plant Communities
by Eugene Kelly, Policy and Legislation Chair
Florida Native Plant Society
Have you heard about the “M-CORES Project”? If not, you may want to start paying attention because it will affect communities across much of Florida and will certainly impact native plants and native plant communities. Short for Multi-use Corridors of Regional Economic Significance, the project proposes to build more than 330 miles of new toll roads through huge swaths of rural land for the stated purpose of promoting economic development. The projects were proposed by the Florida Legislature and are not purported to meet any transportation need identified or vetted by the Florida Department of Transportation (FDOT). The Suncoast Connector would extend from the northern end of the existing Suncoast Parkway a distance of at least 160 miles to the Georgia border in Jefferson County. The Northern Turnpike Connector would extend about 30 miles, from the current northern terminus of the Turnpike to the Suncoast Parkway. And the Southwest-Central Connector would run 150 miles from Lakeland to Naples.
The immense scale of the projects makes it difficult to comprehend the full extent of potential impacts to natural resources. The M-CORES website provides interactive mapping tools that help provide some perspective (Suncoast Connector Webmap; Northern Turnpike Connector Webmap, and Southwest Central Florida Connector Webmap) just be sure to close out of the splash screen the first time you choose to use them. While the mapping tools provide access to a wealth of valuable information, from the locations of existing conservation lands to floodplains, wetlands, springsheds, and critical habitat for endangered animal species, there has been very little consideration given thus far to native plants.
This inattention to native plant concerns was underscored when I attended the October 30 meeting of the Southwest-Central Connector Task Force in Lakeland. The 47-member Task Force was provided on overview on the applicability of the US Endangered Species Act to the substance of their task, and it identified the 12 animal species present in the study area that are protected under the Act and must be considered during their future deliberations on the project. While harboring no hostility whatsoever towards the Florida Panther, Sand Skink, Manatee, or any of the other listed animal species being given proper consideration, I was squirming in my seat and fighting the urge to say aloud “what about the plants!”. I found some solace in the knowledge my turn would come during the public comment portion of the agenda. But a measure of relief came soon after when Task Force member Elizabeth Fleming, who represents the Florida Defenders of Wildlife, suggested that impacts to native plants might also merit some attention. Thank you, Elizabeth! Her suggestion received additional emphasis when I explained during the public comment period that there are twice as many listed plant species as animal species in the study area, many of them narrow endemics that occur nowhere else in the world. That comment, made on behalf of FNPS, actually elicited an audible response of surprise.
Rest assured that FNPS is assessing the potential impacts of these massive projects on native plants and other sensitive natural resources, and will share the results of our assessment with FDOT. Based on the preliminary results of our assessment, the FNPS Policy Committee is very troubled by the likely extent of impacts if these roads are ever constructed. The discussion and series of maps that follow illustrate the basis for some of our concerns. If you share our concerns about the impacts of these proposed roads on native plants and our remaining natural areas, or have other concerns of your own as a potentially affected resident, you can attend meetings of the advisory Task Forces that have been appointed to review the projects and make recommendations to FDOT. The third round of Task Force meetings will be conducted in December according to the schedule provided, and given the legislature’s extremely aggressive timeline for finalizing the road alignments and commencing construction, the December meetings may provide your best opportunity to influence FDOT’s decision-making on this critically important issue. Each Task Force meeting will include a period for public comment. You can also submit written comments at the meetings, attend a Community Open House to communicate directly with FDOT staff, or email comments to FDOT.Listens@dot.state.fl.us .
The Florida Natural Areas Inventory (FNAI) maintains extensive geographic data on occurrences of imperiled species and other sensitive natural resources. Collectively, these data comprise the foundation of the Florida Forever Conservation Needs Assessment, which helps the state identify lands that should be considered a high priority for protection through the Florida Forever program. The Rare Species Habitat Conservation Priorities (RSHCP) data identifies the most important remaining habitat for 281 rare species, including 151 plant species and 130 animal species, melded into a statewide composite map with weighted scores that reflect the level of priority for protection based on such factors as individual species rarity, levels of protection on existing conservation land, and amount of overlap among multiple species. The inclusion of so many plant species distinguishes the RSHCP as the single-best dataset for identifying habitat critical to native plant conservation.
Map 1 depicts the RSHCP data for the three M-CORES study areas, and reflects the presence of much high-value habitat. Large areas of urbanized or intensively altered lands are usually distinguished by the complete absence of a RSHCP score, or by a low score that reflects the presence of a species that is more tolerant of, or dependent on, such altered areas. The I-4 corridor through the northern end of the Southwest-Central Connector study area, the I-75 corridor where it bisects the Northern Turnpike Connector study area, and much of the US19 corridor through the central reaches of the Suncoast Connector study area are conspicuous. It is difficult to envision how major toll roads constructed through these study areas, for the purpose of promoting economic development, would not threaten the viability of the remaining high value habitat.
FNAI developed individual habitat models for each species included in the RSHCP data to delineate the habitat areas that were ultimately ranked in the statewide composite data used to create Map 1. The models are based on habitat requirements and other factors specific to each species included in the RSHCP data. This makes it possible to “tease out” habitat information for individual species. Map 2 zooms in on the Lake Wales Ridge region of Florida, located generally in central Polk and Highlands Counties and at the northern end of the Southwest-Central M-CORES study area. The “Ridge” is encompassed entirely within the study area and is widely recognized as a biodiversity “hot spot” that is home to a large number of imperiled, narrowly endemic species. Map 2 depicts habitat occurrences for 23 imperiled plant species.
Consistent with FNAI requirements that data on imperiled species occurrences be treated with sensitivity, the map does not clearly depict locational records for the species. The primary intent of the map is to convey the tremendous significance of the Lake Wales Ridge to native plants, which is illustrated in graphic terms by this tremendous concentration of narrowly-endemic species. All the plant species depicted on the map are restricted to Florida, and many occur nowhere else except in the scrub and scrubby flatwoods habitat of the Ridge – meaning their entire worldwide range is visible in Map 2. All 23 are protected under the US Endangered Species Act, with 19 designated as Endangered and 4 as Threatened. Given that level of imperilment, and the limited extent of remaining habitat for these species, a project like M-CORES could represent an enormous threat to their prospects for long-term survival.
We know FNPS members share a holistic view and appreciation of the natural world, so it bears mentioning that the biodiversity significance of the Ridge is not limited to its flora. A large number of imperiled animal species are likewise dependent on the Ridge’s well-drained scrubs, from narrow endemics like the Blue-tailed Mole Skink to more wide-ranging but still rare species like the Florida Scrub Jay and Eastern Indigo Snake.
FNAI accounted for these circumstances with another valuable set of spatial data incorporated into the Florida Forever Conservation Needs Assessment. Map 3 delineates the occurrence of Under-Represented Natural Communities in the northern half of the Southwest-Central M-CORES study area. The native plant community occurrences depicted on the map represent 5 of the 11 community types determined to be “under-represented” in the state’s network of protected conservation lands (i.e.less than 15% of historic total extent currently protected), and therefore are a priority for protection in future land conservation projects. The study area encompasses a significant proportion of the remaining unprotected occurrences of dry prairie (29,600 acres, or 55% of remaining statewide total), scrub and scrubby flatwoods (33,300 acres, or 25% of remaining statewide total), sandhill upland lake (15,300 acres, or 27% of remaining statewide total) and pine flatwoods (274,000 acres, or 25% of remaining statewide total) deemed sufficiently intact to be considered a priority for future protection. Although sandhill is also present in the study, it comprises a less significant proportion (1,900 acres, or less than 1% of remaining statewide total) of total unprotected sandhill statewide.
Dry prairie is a plant community endemic to Florida and is restricted largely to the south-central peninsula. It is the sole habitat of the endemic, critically imperiled Florida Grasshopper Sparrow and also serves as habitat for the Beautiful Pawpaw, Crested Caracara and Florida Burrowing Owl. The habitat values of the Lake Wales Ridge scrub have already been discussed. The seemingly large target for protection of pine flatwoods reflects its role as the “matrix” community for much of Florida, occurring in many variations throughout its extensive range, transmitting fire across natural landscapes, and providing habitat for a huge array of Florida’s native flora and fauna. Map 3 is another graphic illustration of the resource significance of this study area. We will soon complete an analogous evaluation of Under-Represented Natural Communities in the other two M-CORES study areas.
You have probably heard this axiom before: habitat fragmentation is second only to outright habitat destruction as a source of habitat loss. As the natural landscape becomes progressively more dissected by human development, sub-divided into ever smaller and more disjunct patches, it becomes progressively less able to maintain the natural ecological processes – like hydrologic function, fire transmission, and wildlife and plant movement to accommodate gene exchange and future adaption - that are necessary to maintain healthy, viable natural systems.
The Florida Ecological Greenways Network was developed by the University of Florida’s Center for Landscape Conservation Planning and is yet another important component of the Florida Forever Conservation Needs Assessment. It identifies the best remaining, relatively intact landscapes that remain capable of providing functional connectivity among Florida’s network of conservation lands. Critical Linkages are considered the highest priority for protection. Map 4 delineates the FEGN across much of the northern Florida peninsula, and the entirety of the land area encompassed by both the Northern Turnpike Connector and Suncoast Connector M-CORES study areas (approximately 6.9 million acres!).
The limited opportunities for maintaining connectivity among existing conservation lands in these study areas, and bridging gaps towards the interior of the state, are readily apparent in Map 4. The Marjorie Harris Carr Cross Florida Greenway, located at the southern end of the study area, provides an already tenuous connection between coastal conservation areas like Waccasassa Bay Preserve State Park and Goethe State Forest, and the Ocala National Forest, which is located far inland and serves as one of Florida’s core habitat areas. Both the Northern Turnpike Connector and Suncoast Connector would, of necessity, cross the Greenway if constructed and further compromise a corridor that is already interrupted by I-75, US19, US41, and State Road 200 among others. There is still an opportunity to maintain connectivity across the northern end of the study area between coastal conservation areas and the Osceola National Forest, another core habitat area that enjoys inter-state connectivity via the adjacent Okefenokee National Wildlife Refuge. The large San Pedro Bay Florida Forever Project is within a Critical Linkage in the FEGN and would bridge much of the remaining gap between the coastal sites and Osceola; but it remains unprotected and we all know that Florida Forever has been starved of funding since 2008.
FNPS will continue its assessments of M-CORES and continue engaging on your behalf. Thus far, we clearly see more arguments against construction than in support. Our perspective is framed primarily by the official FNPS, Board-adopted policy statement on transportation infrastructure. Most applicable among the six conclusions established by the policy statement is that “transportation infrastructure should be designed to implement, rather than direct, future land use decisions and must address genuine transportation needs. The promotion of economic development should not be accepted as a rationale for the construction of new transportation infrastructure”. The policy statement also concludes that “generally, the expansion of existing transportation corridors is preferable to the creation of new ones as a strategy for minimizing impacts to native flora and fauna”. Barring the appearance of new information, or some unanticipated revelations, it will be difficult to reconcile the guiding philosophy of our official policy statement with a conclusion in support of M-CORES.
There may also be some compelling arguments “against” M-CORES that are unrelated to potential natural resource impacts. For example, a financial feasibility analysis, which is required by statute and must meet minimum thresholds for projected toll receipts to cover debt service on the bonds that would fund construction, has not been completed and current toll receipts on existing sections of the Suncoast Parkway have fallen far short of projections. Impacts on agriculture, which is second only to tourism in terms of overall impact on the state economy, are another important consideration. While we will do our best to represent you on behalf of native plant conservation, there is nothing that can substitute for a strong response from the public. Please try to attend one of the upcoming task forces meetings or open house meetings if you are able, and speak of your own concerns. Or submit an email to FDOT.Listens@dot.state.fl.us
IFAS Auditorium
203 Forest Park Drive
Perry, Florida
Alton Family Life Center
2365 East US 27
Mayo, FL
Hilton Ocala
3600 SW 36th Avenue
Ocala, Florida
Wildwood Community Center
6500 Powell Road
Wildwood, FL
LaBelle Civic Center
481 State Road 80
LaBelle, Florida
North Collier Park – Exhibit Hall
15000 Livingston Road
Naples, Florida
Florida Native Plant Society
Have you heard about the “M-CORES Project”? If not, you may want to start paying attention because it will affect communities across much of Florida and will certainly impact native plants and native plant communities. Short for Multi-use Corridors of Regional Economic Significance, the project proposes to build more than 330 miles of new toll roads through huge swaths of rural land for the stated purpose of promoting economic development. The projects were proposed by the Florida Legislature and are not purported to meet any transportation need identified or vetted by the Florida Department of Transportation (FDOT). The Suncoast Connector would extend from the northern end of the existing Suncoast Parkway a distance of at least 160 miles to the Georgia border in Jefferson County. The Northern Turnpike Connector would extend about 30 miles, from the current northern terminus of the Turnpike to the Suncoast Parkway. And the Southwest-Central Connector would run 150 miles from Lakeland to Naples.
The immense scale of the projects makes it difficult to comprehend the full extent of potential impacts to natural resources. The M-CORES website provides interactive mapping tools that help provide some perspective (Suncoast Connector Webmap; Northern Turnpike Connector Webmap, and Southwest Central Florida Connector Webmap) just be sure to close out of the splash screen the first time you choose to use them. While the mapping tools provide access to a wealth of valuable information, from the locations of existing conservation lands to floodplains, wetlands, springsheds, and critical habitat for endangered animal species, there has been very little consideration given thus far to native plants.
This inattention to native plant concerns was underscored when I attended the October 30 meeting of the Southwest-Central Connector Task Force in Lakeland. The 47-member Task Force was provided on overview on the applicability of the US Endangered Species Act to the substance of their task, and it identified the 12 animal species present in the study area that are protected under the Act and must be considered during their future deliberations on the project. While harboring no hostility whatsoever towards the Florida Panther, Sand Skink, Manatee, or any of the other listed animal species being given proper consideration, I was squirming in my seat and fighting the urge to say aloud “what about the plants!”. I found some solace in the knowledge my turn would come during the public comment portion of the agenda. But a measure of relief came soon after when Task Force member Elizabeth Fleming, who represents the Florida Defenders of Wildlife, suggested that impacts to native plants might also merit some attention. Thank you, Elizabeth! Her suggestion received additional emphasis when I explained during the public comment period that there are twice as many listed plant species as animal species in the study area, many of them narrow endemics that occur nowhere else in the world. That comment, made on behalf of FNPS, actually elicited an audible response of surprise.
Rest assured that FNPS is assessing the potential impacts of these massive projects on native plants and other sensitive natural resources, and will share the results of our assessment with FDOT. Based on the preliminary results of our assessment, the FNPS Policy Committee is very troubled by the likely extent of impacts if these roads are ever constructed. The discussion and series of maps that follow illustrate the basis for some of our concerns. If you share our concerns about the impacts of these proposed roads on native plants and our remaining natural areas, or have other concerns of your own as a potentially affected resident, you can attend meetings of the advisory Task Forces that have been appointed to review the projects and make recommendations to FDOT. The third round of Task Force meetings will be conducted in December according to the schedule provided, and given the legislature’s extremely aggressive timeline for finalizing the road alignments and commencing construction, the December meetings may provide your best opportunity to influence FDOT’s decision-making on this critically important issue. Each Task Force meeting will include a period for public comment. You can also submit written comments at the meetings, attend a Community Open House to communicate directly with FDOT staff, or email comments to FDOT.Listens@dot.state.fl.us .
Impacts to Habitat for Imperiled Species
 |
| Map 1. Rare Species Habitat Conservation Priorities (vol. 4.1) for the M-CORES study areas. These data are generated and maintained by the Florida Natural Areas Inventory and serve as an element of the Florida Forever Conservation Needs Assessment used to identify, assess and rank lands proposed for protection under the Florida Forever land acquisition program. It is a composite that represents statewide habitat occurrences for a total of 281 rare species, including 151 plant species and 130 animal species. |
FNAI developed individual habitat models for each species included in the RSHCP data to delineate the habitat areas that were ultimately ranked in the statewide composite data used to create Map 1. The models are based on habitat requirements and other factors specific to each species included in the RSHCP data. This makes it possible to “tease out” habitat information for individual species. Map 2 zooms in on the Lake Wales Ridge region of Florida, located generally in central Polk and Highlands Counties and at the northern end of the Southwest-Central M-CORES study area. The “Ridge” is encompassed entirely within the study area and is widely recognized as a biodiversity “hot spot” that is home to a large number of imperiled, narrowly endemic species. Map 2 depicts habitat occurrences for 23 imperiled plant species.
 |
| Map 2. Habitat occurrences for 23 imperiled plant species in the Lake Wales Ridge region of Florida. This map represents occurrences for a suite of imperiled, endemic plant species and is a subset of the source data used to generate the Rare Species Habitat Conservation Priorities depicted in Map 1. Data provided by the Florida Natural Areas Inventory. |
 |
| Table 1. Imperiled plant species in the Lake Wales Ridge region of Florida. |
We know FNPS members share a holistic view and appreciation of the natural world, so it bears mentioning that the biodiversity significance of the Ridge is not limited to its flora. A large number of imperiled animal species are likewise dependent on the Ridge’s well-drained scrubs, from narrow endemics like the Blue-tailed Mole Skink to more wide-ranging but still rare species like the Florida Scrub Jay and Eastern Indigo Snake.
Imperiled Native Plant Communities
Threats to biodiversity do not occur solely at the species level. We know that some of Florida’s native plant communities are also rare, whether due to extensive loss in the face of human destruction or alteration, or a naturally small extent of occurrence. Sandhill can be placed in the former category because we know it was once a dominant community across the Southeastern US and has now been reduced to 3% or less of its former areal extent. Scrub, scrubby flatwoods, and dry prairie are endemic communities restricted entirely to Florida, and have suffered the double-whammy of being both geographically limited in occurrence and attractive for development in the case of scrub and scrubby flatwoods, and conversion to agricultural use in the case of dry prairie.FNAI accounted for these circumstances with another valuable set of spatial data incorporated into the Florida Forever Conservation Needs Assessment. Map 3 delineates the occurrence of Under-Represented Natural Communities in the northern half of the Southwest-Central M-CORES study area. The native plant community occurrences depicted on the map represent 5 of the 11 community types determined to be “under-represented” in the state’s network of protected conservation lands (i.e.less than 15% of historic total extent currently protected), and therefore are a priority for protection in future land conservation projects. The study area encompasses a significant proportion of the remaining unprotected occurrences of dry prairie (29,600 acres, or 55% of remaining statewide total), scrub and scrubby flatwoods (33,300 acres, or 25% of remaining statewide total), sandhill upland lake (15,300 acres, or 27% of remaining statewide total) and pine flatwoods (274,000 acres, or 25% of remaining statewide total) deemed sufficiently intact to be considered a priority for future protection. Although sandhill is also present in the study, it comprises a less significant proportion (1,900 acres, or less than 1% of remaining statewide total) of total unprotected sandhill statewide.
 |
| Map 3. Under-Represented Natural Communities in the north half of the Southwest-Central Connector M-CORES study area. These data are generated and maintained by the Florida Natural Areas Inventory and serve as an element of the Florida Forever Conservation Needs Assessment. |
Dry prairie is a plant community endemic to Florida and is restricted largely to the south-central peninsula. It is the sole habitat of the endemic, critically imperiled Florida Grasshopper Sparrow and also serves as habitat for the Beautiful Pawpaw, Crested Caracara and Florida Burrowing Owl. The habitat values of the Lake Wales Ridge scrub have already been discussed. The seemingly large target for protection of pine flatwoods reflects its role as the “matrix” community for much of Florida, occurring in many variations throughout its extensive range, transmitting fire across natural landscapes, and providing habitat for a huge array of Florida’s native flora and fauna. Map 3 is another graphic illustration of the resource significance of this study area. We will soon complete an analogous evaluation of Under-Represented Natural Communities in the other two M-CORES study areas.
You have probably heard this axiom before: habitat fragmentation is second only to outright habitat destruction as a source of habitat loss. As the natural landscape becomes progressively more dissected by human development, sub-divided into ever smaller and more disjunct patches, it becomes progressively less able to maintain the natural ecological processes – like hydrologic function, fire transmission, and wildlife and plant movement to accommodate gene exchange and future adaption - that are necessary to maintain healthy, viable natural systems.
The Florida Ecological Greenways Network was developed by the University of Florida’s Center for Landscape Conservation Planning and is yet another important component of the Florida Forever Conservation Needs Assessment. It identifies the best remaining, relatively intact landscapes that remain capable of providing functional connectivity among Florida’s network of conservation lands. Critical Linkages are considered the highest priority for protection. Map 4 delineates the FEGN across much of the northern Florida peninsula, and the entirety of the land area encompassed by both the Northern Turnpike Connector and Suncoast Connector M-CORES study areas (approximately 6.9 million acres!).
 |
| Map 4. Florida Ecological Greenways Network in the M-CORES Suncoast Connector and Northern Turnpike Connector study areas. |
FNPS will continue its assessments of M-CORES and continue engaging on your behalf. Thus far, we clearly see more arguments against construction than in support. Our perspective is framed primarily by the official FNPS, Board-adopted policy statement on transportation infrastructure. Most applicable among the six conclusions established by the policy statement is that “transportation infrastructure should be designed to implement, rather than direct, future land use decisions and must address genuine transportation needs. The promotion of economic development should not be accepted as a rationale for the construction of new transportation infrastructure”. The policy statement also concludes that “generally, the expansion of existing transportation corridors is preferable to the creation of new ones as a strategy for minimizing impacts to native flora and fauna”. Barring the appearance of new information, or some unanticipated revelations, it will be difficult to reconcile the guiding philosophy of our official policy statement with a conclusion in support of M-CORES.
There may also be some compelling arguments “against” M-CORES that are unrelated to potential natural resource impacts. For example, a financial feasibility analysis, which is required by statute and must meet minimum thresholds for projected toll receipts to cover debt service on the bonds that would fund construction, has not been completed and current toll receipts on existing sections of the Suncoast Parkway have fallen far short of projections. Impacts on agriculture, which is second only to tourism in terms of overall impact on the state economy, are another important consideration. While we will do our best to represent you on behalf of native plant conservation, there is nothing that can substitute for a strong response from the public. Please try to attend one of the upcoming task forces meetings or open house meetings if you are able, and speak of your own concerns. Or submit an email to FDOT.Listens@dot.state.fl.us
Suncoast Connector Task Force
Task Force Meeting #3
December 17, 2019, 10:00 am – 5:00 pmIFAS Auditorium
203 Forest Park Drive
Perry, Florida
Community Open House
December 19, 2019, 5:30 pm – 7:30 pmAlton Family Life Center
2365 East US 27
Mayo, FL
Northern Turnpike Connector Task Force
Task Force Meeting #3
December 18, 2019, 10:00 am – 5:00 pmHilton Ocala
3600 SW 36th Avenue
Ocala, Florida
Community Open House
December 19, 2019, 5:30 pm – 7:30 pmWildwood Community Center
6500 Powell Road
Wildwood, FL
Southwest-Central Florida Connector Task Force
Task Force Meeting #3:
December 9, 2019, 10:00 am -5:00 pmLaBelle Civic Center
481 State Road 80
LaBelle, Florida
Community Open House:
December 12, 2019, 5:30 pm – 7:30 pmNorth Collier Park – Exhibit Hall
15000 Livingston Road
Naples, Florida
Comments