[email protected] www.bio-techconsulting.com April 4, 2017 Cory Catts SWFWMD 2379 Broad Street Brooksville, Florida 34604 Proj: Lake Charles Resort Site – Polk County, Florida SWFWMD Application No. 733689 (BTC File #923-01) Re: RAI Response Dear Mr. Catts: The purpose of this document is to respond to the Southwest Florida Water Management District (SWFWMD) request for additional information (dated Orlando Office 2002 East Robinson St. September 9, 2016) for the Lake Charles Resort Site ERP application Orlando, FL 32803 submittal. The SWFWMD’s comments and the responses are as follows: Vero Beach Office 4445 N. A1A Suite 221 8. Please contact the project review Environmental Scientist, Cory Catts, Vero Beach, FL 32963 to schedule a site visit to verify the location of the wetland boundaries, verify the seasonal high water levels (SHWL), inspect the Jacksonville Office 2036 Forbes St. areas of wetland impact, review UMAM analysis, and conduct a Jacksonville, FL 32204 general environmental assessment of the project area. Please ensure Tampa Office that all flags or stakes denoting the wetland line are clearly visible in 6011 Benjamin Rd. the field during the construction of the project. Please be aware that Suite 101 B Tampa, FL 33634 additional questions and clarification in regards to wetland/surface water features, proposed mitigation, UMAM assessments pursuant to Key West Office 1107 Key Plaza Ch. 62-345, F.A.C., and other environmental considerations may be Suite 259 required following the field visit findings. Key West, FL 33040 Aquatic & Land The site inspection with District staff was completed on March 29, 2017. Management Operations 3825 Rouse Rd. All wetland line changes are reflected on the revised plan sheets. Orlando, FL 32817 Native Plant Nursery DCC Farms 8580 Bunkhouse Rd. Orlando, FL 32832 407.894.5969 877.894.5969 407.894.5970 fax Orlando Vero Beach Jacksonville Tampa Key West Cory Catts, SWFWMD Lake Charles Resort Site (BTC File #923-01) RAI Response, App. No. 733689 Page 2 of 4 9. The project plans and summary indicate that an upland buffer has been provided to address secondary impacts. Be advised that the District can accept an undisturbed, upland buffer around wetlands, which is an average 25 feet wide, but never less than 15 feet, as a means of providing reasonable assurance that secondary wetland impacts will not occur. As currently shown on the plans the buffer does not meet the 15 foot minimum requirement in many areas of the proposed design. Please revise the project design to meet the 15 foot minimum and 25 foot average upland buffer or provide alternate methods to prevent secondary impacts to the adjacent wetlands. Please also clarify of the upland buffer will remain undisturbed or if any of the project side slopes are proposed for grading within the buffer area. If the buffer is to be disturbed please revise the project design to meet the 15 foot minimum and 25 foot average upland buffer or provide alternate methods to prevent secondary impacts to the adjacent wetlands. The majority of wetlands remaining in the post-development condition will be provided with a 15-foot minimum and 25-foot average upland buffer. However, there are two areas along Lake Charles and one along Wetland 5 in the northeast portion of the property that does not provide the required 15-foot minimum upland buffer. The potential for future secondary wetland impacts will be offset in these areas with plantings. The upland areas currently adjacent to the wetlands consist of maintained pasture and provide little to no buffer protection. The plantings will consist of 1-gallon sand cordgrass set on 2-foot centers and placed along three staggered rows. These plantings along with conservation area signage will provide reasonable protection of the wetlands from future secondary impacts. 10. Please provide a detailed alternatives analysis to justify the proposed wetland impacts throughout the project. This analysis should clearly show that you have made every effort through practicable design modifications to eliminate and reduce wetland impacts within the project. The site plan has been revised to minimize wetland impacts to the greatest extent practicable. The direct wetland impacts are limited to an isolated less than 0.5-acre wetland (W1B – 0.24 acres) and the outfall structures (0.01 acres). 11. Please provide information on the methodology used to collect the seasonal high water level (SHWL) and normal pool (NP) data for the wetlands and surface waters receiving the storm water discharges generated by the project. Please provide appropriate field data collected from all wetland indicators utilized to justify your estimations for the Cory Catts, SWFWMD Lake Charles Resort Site (BTC File #923-01) RAI Response, App. No. 733689 Page 3 of 4 elevations. Please provide the location of each of the surveyed indicators used on the plans for the project. Please see response from project engineer. 12. The project is proposing to route storm water through several wetlands within the project. Please demonstrate that adverse impacts to the wetland hydro periods will not occur by providing hydrographs of the 2.33 year mean annual storm. The graph should start and end at the pop-off elevation with Existing Condition and Proposed Condition hydrographs superimposed for comparison. Please provide a supporting narrative for the hydrographs explaining any variations that are shown. The invert of ditches may be the existing ‘pop-off’ elevation, or SHWL, of the wetland and may need to be considered when designing the storm water management system. Please provide reasonable assurance that there will be no adverse hydrologic impacts to on-site wetlands and/or demonstrate how the current hydroperiod, hydrological input patterns, and hydrologic conditions of the wetlands will be maintained after development. Please see response from project engineer. 13. Please note that comments have been requested from the Florida Department of State, Division of Historical Resources (DHR) regarding this project. Since activities are proposed in wetlands and/or surface waters, the receipt of a letter from the DHR indicating that additional information is not required or recommending certain requirements is a completeness item for this application. An archaeological survey was completed on the subject property in 2015. No historical resources were found within the project limits (see attached CRAS report). 14. Reasonable assurance that threatened or endangered species will not be adversely affected by the proposed construction and associated water dependent activity in the area has not been provided. Be advised that the District is coordinating with the Florida Fish and Wildlife Conservation Commission (Bureau of Imperiled Species) for comments regarding secondary impacts to threatened or endangered species in the area. Based on their recommendations, additional information or revisions may be needed in determining whether construction and operation of the proposed facility will cause significant adverse impact to threatened or endangered species. Cory Catts, SWFWMD Lake Charles Resort Site (BTC File #923-01) RAI Response, App. No. 733689 Page 4 of 4 The majority of intact wetlands within the subject property will remain in the post- development condition, along with adequate upland buffers. These areas will provide significant habitat for Listed wildlife species. Should you have any questions or require any additional information, please do not hesitate to contact our office at (407) 894-5969. Thank you. Regards, Daniel Gough Project Manager John Miklos President attachments CULTURAL RESOURCE ASSESSMENT SURVEY OF THE RESORT AT LAKE CHARLES PROPERTY POLK COUNTY, FLORIDA Prepared for: Bio-Tech Consulting Inc. 2002 East Robinson Street Orlando, Florida 32803 Prepared by: Florida’s First Choice in Cultural Resource Management Archaeological Consultants, Inc. 8110 Blaikie Court, Suite A Sarasota, Florida 34240 (941) 379-6206 Toll Free: 1-800-735-9906 February 2015 CULTURAL RESOURCE ASSESSMENT SURVEY OF THE RESORT AT LAKE CHARLES PROPERTY POLK COUNTY, FLORIDA Prepared for: Bio-Tech Consulting Inc. 2002 East Robinson Street Orlando, Florida 32803 Prepared by: Archaeological Consultants, Inc. 8110 Blaikie Court, Suite A Sarasota, Florida 34240 Marion Almy – Project Manager Elizabeth A. Horvath – Project Archaeologist Justin Winkler – Archaeologist Jorge Danta – Architectural Historian February 2015 EXECUTIVE SUMMARY Archaeological Consultants, Inc. (ACI) conducted a cultural resource assessment survey (CRAS) of the Resort at Lake Charles property in Polk County, Florida, for Bio-Tech Consulting, Inc. The purpose of this project was to locate and identify any cultural resources and to assess their significance in terms of eligibility for listing in the National Register of Historic Places (NRHP). This survey was conducted in February 2015 at the request of the Florida Division of Historical Resources (FDHR) who reviewed the project in accordance with Chapters 267.061 and 373.414, Florida Statutes (FS) (Bendus 2015: Appendix A). The resulting report meets specifications set forth in Chapter 1A-46, Florida Administrative Code (revised August 2002) and follows the guidelines in the Cultural Resources Standards and Operational Manual (FDHR 2003). Background research and a review of the Florida Master Site File (FMSF) indicated that no archaeological sites have been recorded within the property or within one mile of the project area. Based on previous investigations