Our letter to the Service follows:
SIERRA CLUB FLORIDA
1990 Central Avenue
St. Petersburg, FL 33712
April 25, 2016
Kenneth McDonald, Project Manager
U.S. Fish and Wildlife Service
South Florida Ecological Services Office
1339 20th Street
Vero Beach, FL 32960-3559
Via email: firstname.lastname@example.org
RE: Eastern Collier Habitat Conservation Plan
Dear Mr. McDonald:
The Sierra Club Florida urges the FWS to deny the request for an Incidental Take Permit because the Eastern Collier Habitat Conservation Plan falls significantly short of FWS requirements for permit approval.
· The plan shows little evidence of avoidance/minimization of impacts to the panther’s Primary Zone. Proposed losses of the Primary Zone near the Florida Panther NWR are of particular concern as this area should be maintained and the corridor width increased. HCP’s must minimize and mitigate to the maximum extent practicable.
· There should be no land use intensification in the Primary Zone.
· The areal extent of the Primary Zone must be maintained. Preserving existing panther habitat is far more valuable than generating funds or mitigating impacts to the Primary Zone.
· The HCP does not show functional corridor design. A landscape perspective is essential for developing functional corridors for panthers. The land cover of corridors must also be restored and protected.
· The HCP could potentially lead to over 100 miles of new or widened roads and up to 60,000 vehicle trips per day in some areas. This does not include the addition of state and local roads constructed by other entities. These roads with further fragment panther habitat and increase the risk of panther vehicular deaths. The plan does not address incidental takes that will occur due to road/traffic increases.
· The Plan does not consider cumulative impacts on habitat caused by Lee and Hendry County development and mining proposals.
- The impacts on the unique habitats of 15 other protected species (including the Everglades snail kite, Florida scrub-jay, crested caracara, wood stork and gopher tortoise) receive little to no consideration in the plan. The HCP does not provide adequate avoidance, minimization or mitigation for all covered species.
- A 50-year permit is excessive and would prevent necessary adjustments to attempt to reverse covered species population declines from this massive development.