On April 25, Sierra Club Florida submitted comments to the US Fish and Wildlife Service expressing strong opposition to the proposed Eastern Collier Habitat Conservation Plan. The proposal includes an incidental take permit authorizing the "unintentional" harm or killing of Florida panthers and other endangered species on 45,000 acres of new urban development. (See Naples News: Plan by large landowners to preserve, develop Collier land blasted by residents)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
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.
Sincerely,
Conservation
Chair
Ancient
Islands Group
Sierra
Club Florida
Conservation
Chair
Florida
Chapter
Sierra
Club
Frank Jackalone
Florida Chapter
Director
Sierra
Club
