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November 16, 2017 Ms. Lisa Bowers Southwest Florida Water

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November 16, 2017 Ms. Lisa Bowers Southwest Florida Water November 16, 2017 Ms. Lisa Bowers Southwest Florida Water Management District Tampa Service Office – Regulation Division Tampa, FL 33637-6759 RE: Request for Additional Information - Application No. 750337 44th Avenue East – Phase V Manatee County, Florida Dear Ms. Bowers: Please allow the information below to serve as our responses to the Environmental Considerations dated August 18, 2017, on the above-referenced parcel. ENVIRONMENTAL CONSIDERATIONS: 3. Please contact project reviewer, Lisa Bowers, at extension 2099, or at [email protected] to schedule a field visit to review the proposed scope of work, including: review of the proposed WRAP scores and mitigation requirements. Please be aware that additional questions regarding wetland and/or surface water boundary locations and wetland and surface water impacts may be required following the field visit. [Rules 62-330.060(2), 62- 330.301(1), and 62-330.302(1), F.A.C.] Response: A site visit was conducted on September 28, 2017. Review of the WRAP scores was conducted in the field, and the revised agreed upon numbers are included in the attached WRAP sheets. In addition, the Long Swamp Mitigation Bank credit ledger has been updated to account for the aforementioned revision. 4. Please provide assurance that the elimination or reduction criteria within Subsection 10.2.1, AHVI, have been met. Document in detail, if and how the avoidance of impacts to NE-WL-35; (a) requires the project to be significantly different in type and function, (b) is not technically feasible, or (c) is not economically viable. If removal of these impacts makes the development significantly different in type and function, provide details. If removal of these lots is technically infeasible, provide all necessary supporting data, including County or other agency specifications. If removal of these lots is economically unviable, provide specific information, including economic justification. [Rule 62-330.301 (4), F.A.C., and Subsection 10.2.1, AHVI]. Response: The roadway was evaluated with permanent filling impacts to the wetland and creek system exhibiting reduced functions and values. In relation to reduction and elimination, wetland impacts were reduced to the greatest extent possible in relation to Manatee County' pre-approved roadway alignment and the approved residential development SWERP boundary limits alignment which positioned this road to 1523 8th Avenue West, Suite B, Palmetto FL 34221 -- Telephone 941.722.0901 Fax 941.722.4931 213 East Park Avenue, Suite 101, Lake Wales FL 33853 -- Telephone 863.676.8996 www.ecoconsultants.net 44th Avenue East – Phase V SWFWMD RAI App No. 750337 November 6, 2017 Page 2 impact the narrowest, most disturbed area of Wetland NE-WL35. Complete avoidance of wetland impacts would result in a project that could not be effectively designed and would not be economically practicable. The design of the roadway does not allow for the complete avoidance of impacts to the forested wetland on site and requires that a portion of the wetland be impacted by filling for the road crossing. Efforts to eliminate and reduce wetland impacts were employed during project design including direct avoidance of numerous wetlands in the surrounding landscape, a minimized footprint, and the selection of a disturbed area where the forested wetland corridor is the narrowest. In addition, the site was chosen because the only relatively sensitive environmental feature within the project area consists of a historically impacted and hydrologically degraded wetland that does not support protected species and provides only minimal habitat value due to its drained nature, nuisance exotic infestation, and long term agricultural uses. 5. Please clearly label and quantify the acreage of all wetlands, surface waters, permanent impact areas, temporary impact areas, and buffer impact areas, as applicable, on the construction plans. [Rule 62-330.060(2), F.A.C.] Response: Please refer to the revised construction plans. 6. It appears that the proposed roadway may cross another wetland to the west of Uihlein Road. Please revise the plans and mitigation information to include this area if necessary. [Rule 62-330.060(2), F.A.C.] Response: Based on the Formal Wetland Determination (SWFWMD No. 742286) the area in question is a other surface water. Please see Attachment B of the SWERP application submitted by E Co Consultants. 7. Please address the potential for secondary impacts to wetland NE-WL-35. Please depict on revised drawings any proposed measures to offset secondary impacts. If secondary impacts are anticipated, please provide mitigation information for those areas to be affected. [Rule 62-330.301(1)(f), F.A.C.] Response: Secondary impacts will be mitigated for at the Long Swamp Mitigation Bank. Please see the WRAP assessments (Attachment G) for the revised sheets. 8. It appears there are other projects under review which will also utilize credits from the Long Swamp Mitigation Area. Please revise the included ledger to reflect these withdrawals. [Rule 62-330.301(1)(f), F.A.C.] Response: The revised ledger is provided as Attachment G. 9. UMAM scores were provided for impacts to WL-38, however it does not appear that WL-38 was included in the plans or on Section C of the Environmental Resource Permit Application. Please revise or clarify as necessary. If there are impacts to a WL-38 within the project area, please provide mitigation information utilizing the WRAP method. Response: WL-38 is not in the project area, there was a numbering error on the data sheet. NE-WL35 is the only wetland being impacted by the proposed roadway. E Co Consultants, Inc. 44th Avenue East – Phase V SWFWMD RAI App No. 750337 November 6, 2017 Page 3 10. Please provide revised drawings with a cross-section within the impacted section of NE-WL-35, including the existing wetland line, 25’ wetland setback, the existing and proposed grades, the fill slope, and erosion control, as applicable. [Chapter 62-340 and Rules 62-330.060(2), 62-330.301(d), and 62-330.301(1)(f), F.A.C.] Response: Please refer to the revised drawings of the impacted area. 11. Please provide the seasonal high water (SHW) elevations of all wetlands within the project area, including field data regarding the biological indicators utilized to estimate the ordinary/seasonal high water levels (OHWL/SHWL). Please provide the location of each of the surveyed indicators used on the plans for the project. If the water level indicators have not been verified previously, please contact Lisa Bowers at extension 2099, or at [email protected] to schedule an on-site inspection and evaluation. [Rules 62-330.060(1) and 62- 330.302(1)(a), F.A.C.] Response: The SHWL and biological indicators were field verified by Tasha Bowers during the Formal determination. 12. It appears that hydrographs were only provided for some of the wetlands near the proposed project. Please provide hydrographs for the additional wetlands, or provide an explanation of why they are not needed. [Rules 62-330.060(1) and 62-330.302(1)(a), F.A.C.] Response: Please refer to the original hydrographs submitted with the Stantec application, all wetlands in the project have been accounted for, and thus requiring no additional explanation. 13. Be advised that the permit will include conditions which require that the Permittee provide documentation to the District showing the transfer of mitigation credits prior to any wetland impacts. [Rule 62-330.301(1)(d), F.A.C.] Response: Prior to any wetland impacts, a permit modification to ERP No. 43012864.001 will be provided requesting the transfer of credits. 14. It appears that this application is dependent upon the approval of another application, therefore this permit cannot be issued until the Application No. 742286 entitled NE Sector JD is approved. [Rule 62-330.301(1)(i), F.A.C.] Response: Acknowledged. 15. Please note that since the proposed project includes activities in, on, or over, wetlands and/or surface waters, comments have been requested from the Florida Department of State, Division of Historical Resources (DHR). Therefore, please provide the District with the results of any cultural resource surveys conducted within the project area or any other additional information that supports whether or not the proposed project will adversely affect or enhance significant historical and archeological resources under the provisions of Section 267.061, Florida Statutes. Please provide any correspondence from DHR concerning the proposed project and please be advised that based on DHR’s E Co Consultants, Inc. 44th Avenue East – Phase V SWFWMD RAI App No. 750337 November 6, 2017 Page 4 recommendations, additional information or revisions to the project may be required. [Subsections 62-330.060(2) and 62-330.302(1)(a)(6), F.A.C and Subsection 10.2.3 of the ERP Applicant’s Handbook Vol. I] Response: The applicant acknowledges the request for a cultural resources assessment survey per the DHR letter dated September 5, 2017. Once the field survey is completed in accordance with Section 106 of the National Historic Preservation Act, it will be submitted under a different cover at a later date. An inquiry to the Division of Historical Resources (DHR) was initiated to determine if any sites of historical or archaeological significance may be located within the project area. A response from the Florida Master Site File on May 24, 2017 revealed that no historical or archaeological sites are located within the project area. As the project site is not known to contain any sites of historical or archaeological importance, is subject to intensive ongoing agricultural activities and does not contain and is not adjacent to any lakes, it is highly unlikely that this site would contain any of these resources. However, if artifacts of potential historical or archaeological significance are revealed during construction activities, DHR will be notified immediately.
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