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.
Primary Zone Recommendations
· The Primary Zone is the focal area for most Florida panther conservation efforts in south Florida. The Primary Zone is defined as lands essential for the survival of the Florida panther in the wild. The definition of the Primary Zone hinges on the recognition that landscape-based habitat conservation and management is absolutely necessary for the survival of the panther population in south Florida. The Primary Zone covers 918,895 ha, of which 671,654 ha (73%) are in public ownership, 200,356 ha (22%) are in private ownership, and 46,886 ha (5%) are in tribal ownership (Table 18). The maintenance or enhancement of existing habitat conditions and landscape configurations within the Primary Zone is by definition essential for the survival of the population. Strategies must be developed to stem the current trends of habitat loss, fragmentation, and land use intensification due to development and agricultural expansion within the Primary Zone. With this key recommendation for the Primary Zone in mind, the following recommendations also apply:
· (1) Avoid the loss of panther habitat within the Primary Zone because additional losses will seriously threaten the survival of the panther population. Based on the known population density, the Primary Zone can support 71 to 84 panthers, which is barely within the minimum recommended base population of 80 to 100 necessary for persistence in south Florida. Therefore, the maintenance of existing home ranges and habitat conditions within the Primary Zone is essential to the survival of the Florida panther. Furthermore, any habitat loss that cannot be avoided within the Primary Zone must be replaced with the restoration or enhancement of habitat that maintains or increases the potential carrying capacity for panthers elsewhere within the Primary Zone. Replacement of function in terms of maintaining or enhancing carrying capacity may be the most appropriate method to assess the significance of potential habitat loss and to design appropriate compensation. Within the Primary Zone, loss of carrying capacity includes four main components: reduction or degradation of the habitat base, reduction in the areal extent of the Primary Zone, increasing landscape fragmentation, and land use intensification. Therefore, no net loss of function or carrying capacity within the Primary Zone requires maintaining the total available habitat area and quality for panthers within this zone. This includes the expansion of the Primary Zone where appropriate (such as into the Secondary Zone adjacent to protected habitat within the Primary Zone) to compensate for any losses that cannot be avoided, and the maintenance of landcover and landscape configurations that promote healthy prey densities, habitat connectivity, and habitat context. Compensation for loss of areal extent will require restoration of the Secondary Zone and incorporation into the Primary Zone. In addition, loss of function should also include assessing potential impacts to existing use of areas by panthers for home ranges, breeding access, denning sites, dispersal routes, and transient ranges used by non-resident males. A landscape evaluation process or tool to assess potential impacts and develop appropriate avoidance, minimization, and compensation techniques and procedures is discussed above in the recommendations for all zones.
· (2) The Primary Zone is the priority for habitat protection, compensation and restoration activities. Although all three zones are important for the survival of the panther in south Florida, the Primary Zone has the highest significance. All funds available for habitat protection, enhancement, and restoration in south Florida should be directed to the Primary Zone first. In addition, compensation for potential loss of habitat, degradation of landscape integrity, or reduction in carrying capacity by proposed activities within the Secondary Zone should first focus efforts on lands within the Primary Zone.
· (3) Maintain appropriate landscape configurations and functional connectivity within the Primary Zone. Habitat protection, enhancement, restoration, and compensation within the Primary Zone must maintain or enhance appropriate landscape configurations and functional connectivity between habitat blocks within the Primary Zone. More information is needed on the factors that constitute the functional arrangement of habitat blocks and agricultural land uses that provide habitat context and connectivity needed to maintain, enhance, or restore panther use, prey, breeding/denning sites, and corridors or connectivity between larger blocks of habitat.
Dispersal Zone Recommendations
· The Dispersal Zone contains the last, best opportunity to maintain natural connectivity between the Florida panther population south of the Caloosahatchee River and potential habitat further north up the Florida peninsula and throughout the rest of its historic range. This zone covers 11,284 ha (Table 18), all in private ownership. Based on habitat analyses and least cost path corridor modeling previously discussed, the Subteam concluded that the area used by at least three males to cross the Caloosahatchee was the best option to maintain the opportunity for connectivity across the river. Though other crossing opportunities may exist west of La Belle, these areas are hemmed in by scattered and increasing urbanization.
· Although habitat south of the Caloosahatchee River may be capable of supporting a population with a good opportunity for demographic stability, PVAs suggest that the future of the panther in south Florida would be greatly enhanced by the establishment of a breeding population north of the river. Though the capability of the lands north of the river to support a breeding population has not been established, the Dispersal Zone is necessary to maintain opportunities for the natural establishment of a population north of the river and to allow for natural interchange between populations on each side of the river if a population is established to the north. The following recommendations pertain to the Dispersal Zone:
· (1) Secure and protect a landscape linkage for dispersal across the Caloosahatchee River. Securing a protected landscape linkage that allows dispersal across the Caloosahatchee River is a high priority in the overall conservation efforts for the panther population. Protection of the Dispersal Zone is important because development pressure along the Caloosahatchee River could soon preclude connectivity. Once protected, the Dispersal Zone should be added to the Primary Zone.
We appreciate this opportunity to provide our comments and concerns and hope that the FWS will act upon them accordingly.
Ancient Islands Group
Sierra Club Florida
Florida Chapter Director