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September 10, 2013 Susan C. Grandin Director, Division of State

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September 10, 2013 Susan C. Grandin Director, Division of State September 10, 2013 1101 Audubon Way Maitland, Florida 32751 Susan C. Grandin Tel: (407) 539-5700 Director, Division of State Lands Cell (407) 620-5178 Department of Environmental Protection www.audubonofflorida.org 3900 Commonwealth Blvd. MS #100 email: [email protected] Tallahassee, FL 32399-3000 Members, Acquisition and Restoration Council 3900 Commonwealth Blvd. Tallahassee, FL 32399-3000 RE: Conservation Land Assessment – Draft Surplus Lands List Dear Director Grandin and ARC Members: Audubon Florida has produced these comments and recommendations concerning the Draft Surplus Lands List as last updated on September 6, 2013, produced as a result of the Conservation Land Assessment. We have directed our comments herein to specific tracts identified on the list to which Audubon Florida has objections to a declaration of surplus. Tracts not specifically mentioned below are tracts that Audubon Florida either has no objections to, or tracts which Audubon does not have sufficient information about at this time to support substantive objections to inclusion on the proposed Surplus Lands List. General Thoughts and Considerations We have reviewed the draft Surplus Lands List with the following considerations in mind: (a) Ecological value and functions, and hydrological value and functions of each tract, including the purposes for which it was originally acquired; (b) Potential Impact of disposal of the listed tract upon the conservation and management of the remaining public lands known by Audubon Florida to be held by DSL, or other state or local agencies which surround, or are located in immediate proximity to the surplus tract. (c) Potential inconsistency of the results of disposal of the surplus tract (such as development that might be anticipated by private purchasers) with state policy objectives that are codified in statute, or rule. Allen David Broussard Catfish Creek Preserve State Park, DRP-4, DRP-5 This 10,000 acre preserve includes habitat for 19 rare or listed plant and animal species. The character of the tract overall is predominantly scrub and turkey oak habitat on the ancient ridge lands of Central Florida. The lands proposed for surplus are within the approved project boundaries of Catfish Creek and within the optimum boundaries identified in the Unit Management Plan. The Management Plan designates no lands for proposed surplus. The sale of these two tracts after declaration of surplus, 3.4 and 2.0 acres in size, would present significant management complications for the remainder of the tract. DRP-5 at 2.0 acres is continuous to the state land constituting the remainder of the preserve, while DRP-4 at 3.4 acres is essentially surrounded and landlocked by state lands in the preserve on 3 sides. Should these two tracts become home sites or be targeted for development or agriculture by prospective purchasers, provisions for access through the remainder of public lands in the preserve would likely be necessary. Private inholdings requiring access present significant management problems for public land units. Further, maintenance of the scrub habitat in the Allen David Broussard Catfish Creek Preserve State Park requires a regular program of prescribed fire. Should these sites be occupied by homes or other private structures, the existence of such structures would significantly complicate the possibility of maintaining proper fire management on adjacent lands within the preserve. While we recognize that these tracts appear disjunct from the main body of the preserve when viewed in a one-dimensional perspective a more careful examination suggests strongly that their retention is appropriate and perhaps vital to the viability of adjacent preserve lands. For this reason, Audubon Florida strongly objects to the surplus of these parcels. Anastasia State Park DRP-0 This 2.7 acre triangle shaped tract consists largely of maritime coastal hammock situated between U.S. Highway A1A and a residential side street to the west. It is directly across AIA from the entrance to the St. Augustine Amphitheatre, which is part of the State Park complex. Coastal maritime habitat, even in small sections is vital to the migration of bird species on the Eastern Flyway. Notable species, such as Painted Buntings make use of this type habitat for feeding and resting during their migration. In addition to its intrinsic habitat value, this elongate parcel provides a pleasant visual screen between the park and the Amphitheatre entrance and developed areas west of AIA. If this property were declared surplus and sold to private parties, highest and best use would likely involve convenience store and gas station commercial uses. Enhancing the visual experience of visitors to our state parks and avoidance of park entrance areas becoming choked with unpleasant commercial uses is an important objective. For these reasons, Audubon Florida objects to this site being declared surplus. Big Bend Wildlife Management Area FWC-BB 2 This site contains approximately 5.3 acres of river frontage on the north side of Rocky Creek, and is bounded on the north by Rocky Creek Road. The site includes coastal marsh wetlands, longleaf pine uplands adjacent to Rocky Creek, and a popular public boat launch area at the terminus of Rocky Creek Road. While the acreage of this site is comparatively small, from the standpoint of river frontage on Rocky Creek, it is very significant, with in excess of ¼ mile of river shoreline contained in the boundary. A review of the Conceptual Management Plan for the Big Bend Wildlife Management Area (BBWMA) 2004-2014 reveals the following regarding the potential for archeological sites in the area: “A review of the Florida Master Site File by the Department of State, Division of Historical Resources (DHR), revealed more than 190 archaeological sites on the BBWMA. These tracts are exceedingly rich in cultural resources. The sites found on the Big Bend represent stone quarries, camps, villages, mounds, and burial sites that date back for more than 12,000 years to Spanish contact. According to DHR, any high ground adjacent to the many rivers, streams and tidal creeks that flow into this area would have a high probability of containing significant archaeological and historic sites.” The high ground areas included in FWC-BB 2 appear to constitute precisely these type areas where a high probability of archaeological resources is likely to exist. Declaration of surplus and sale of this tract would eliminate a significant corridor of Rocky Creek where state ownership currently protects both shorelines. It also appears that declaration of surplus and sale would potentially remove an existing public boat launch area from public use, significantly impacting the ability of the public to use and enjoy the remainder of the BBWMA. This site is within a high velocity storm surge area and any development situated here would be served by undesirable septic tank systems, as there is no central sewer available. This site is situated directly upstream from the Big Bend Seagrass Aquatic Preserve, and any development at this location would impact Outstanding Florida Waters designated areas. Audubon Florida believes that the surplus and sale of this tract would be highly inappropriate, and we object to any surplus declaration for this site. Blue Spring State Park FLMA-16 This 22.4 acre tract consists of a narrow strip adjacent to the main body of the park property. The strip is in the range of 2.25 miles in length. This narrow property is the site of a proposed “Spring to Spring Trail”. The habitat on the narrow strip consists in large part of scrub and scrub oak habitat. Federally-listed Florida Scrub-Jays were observed by Park staff and volunteers in two locations on the property proposed for surplus in both the annual 2012 and 2013 surveys done by the Park Biologist and trained volunteers. These surveys provide highly reliable data due to the rigorous survey protocol supervised by the U.S. Fish and Wildlife Service, Florida Fish and Wildlife Commission, Florida Park Service, and Archbold Biological Station. Despite the railroad and powerline corridors on the property proposed for surplus, the property retains enough of the vegetation structure and plant communities that provide the biological functionality needed for survival of the Florida Scrub-Jays. Scrub-Jay “family” groups hold year-round nesting and foraging territories so the survey observations are interpreted as evidence that one or more Jay families is foraging on the property. If the land is sold as surplus, the Jays residing on this property are likely to be extirpated. In addition, when examining the configuration of this property it is difficult to imagine a practical use other than as a trail site or some type of other linear corridor type project. The range of potential buyers would appear to be very limited, and the use of this property, which now serves as a buffer to Blue Springs State Park for incompatible development purposes could impact the remainder of the park. Audubon Florida opposes the inclusion of this property on the surplus list and recommends that it be removed from the list. Box R Wildlife Management Area FWC-BX 1 This 26 acre tract consists of mature hardwoods largely contiguous to the remainder of the Box R WMA tract. This tract appears to have high wildlife habitat values. A narrow road separates this parcel from the remainder. The road does not appear to be an effective dividing line in the sense of management, and the habitat on both sides of the road appears identical. Other than the existence of this marginal roadway, it is not clear why this parcel would be selected out for surplus any more than any other like-sized parcel near the perimeter of the WMA. Removing this parcel by placing it in a surplus lands status and then selling it to private parties would potentially complicate the management of the Box R WMA.
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