HCP comment september 2009x
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HCP comment september 2009x

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1) The items listed below should be included in any new ordinances that pertain to the Land Development Code on Perdido Key or Pensacola Beach. Additionally, these items should be made public to inform residents and visitors that many of their actions have a direct effect on wildlife. Realizing that this is a wish list and some items may take years to implement, it would be great to get as many of these implemented as soon as possible. Lighting: 2) This is a major issue for the adult turtles coming up on the beach to nest, and the hatchlings emerging from their nest trying to find the water. It adversely affects other wildlife as well. People feel that the more light there is, the safer the beach is and in reality that simply is not true. Night vision is diminished in bright lights. Lighting can be just as effective when kept low to the ground and toward the “red” end of the spectrum. 3) Gulf Power is in the process of installing shields on streetlights, but those shields do not completely circle the light and light does emit from the sides. They should be required to continue this program and maintain the shields. Private property owners now have equally bright lights on their property that need to be completely shielded so the light only points down. They need to be informed and required to adapt lighting to protect wildlife. 4) Parking lot lights (any high lights for that matter) are the worst, located in front of a building; they can also ...

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1) The items listed below should be included in any new ordinances that pertain
to the Land Development Code on Perdido Key or Pensacola Beach.
Additionally, these items should be made public to inform residents and visitors
that many of their actions have a direct effect on wildlife. Realizing that this is a
wish list and some items may take years to implement, it would be great to get as
many of these implemented as soon as possible.

Lighting:

2) This is a major issue for the adult turtles coming up on the beach to nest, and
the hatchlings emerging from their nest trying to find the water. It adversely
affects other wildlife as well. People feel that the more light there is, the safer the
beach is and in reality that simply is not true. Night vision is diminished in bright
lights. Lighting can be just as effective when kept low to the ground and toward
the “red” end of the spectrum.

3) Gulf Power is in the process of installing shields on streetlights, but those
shields do not completely circle the light and light does emit from the sides. They
should be required to continue this program and maintain the shields. Private
property owners now have equally bright lights on their property that need to be
completely shielded so the light only points down. They need to be informed and
required to adapt lighting to protect wildlife.

4) Parking lot lights (any high lights for that matter) are the worst, located in front
of a building; they can also shine on the beach if there is nothing there to shade
the lights.

Beach Chairs:

5) The condo beach chairs pose a major problem for nesting female sea turtles
to access a place to nest. Most of the time, the chairs are left out on the beach at
night and are placed close together for the length of the condo. This is
unacceptable. The chairs must be stacked to leave room for a 6’ turtle to crawl
up the beach unobstructed to nest. This needs to be enforced, especially during
turtle season, for all beach vendors and condo managers.

Tents/Umbrellas/Toys:

6) Residents and visitors tend to leave their belongings on the beach all night,
posing an obstacle for nesting females. We have seen the turtles come ashore
and have to negotiate going around these obstacles, occasionally bumping into
objects several times. Sea Turtles cannot back up and are very cumbersome on
land.

7) More education and oversight of development and condo management will be
a big help. 8) There is a need for some generalized development footprints such as what is
typical (permitted) for single family and commercial parcels. The HCP does
mention 55% to 75% of subject properties will remain in natural condition
(pervious), but this is vague. The HCP also mentions no net loss of habitats but
this cannot be achieved.

9) The HCP should provide a plan for the long term existence of the PKBM in
terms of habitat corridors and connectivity of the three sub populations.

10) The HCP key land acquisitions should be identified and goals and
methods should be identified and discussed to achieve these acquisitions.

11) The HCP suggests a site specific habitat determination will be
required prior to development. How long will this take and who is doing it? Why
isn't this accomplished during the development of this document?

12) It seems an impact area (footprint) could be provided
for each parcel and the owner could build within that approved footprint w/o
further regulatory intervention or review. A comment is included that states the
project area is too broad for specific determinations, but really there are only
about 150 undeveloped parcels left on the Key.

13) What about the County Conservation Plan and the mitigation
requirements (100,000 acre) why not include that in the attachments. This still
looks like piecemeal development without regard to an overall landscape plan to
allow the population to get to some of these "protected" areas.

14) I have now had a chance to carefully read the HCP. I find it to be a well
balanced document that would indeed help towards achieving an
environmentally- and economically-sustainable development of Escambia
County coastal watersheds, with particular emphasis on the protection of the
three species highlighted. A few reactions based on my years of research and
experience with all this:

15) In terms of the proactive measures listed, the adoption of buffer zones is
undoubtedly the most important one. Development will not be bad at all if
sufficient habitat is preserved for the mice, turtles, etc. In addition, leaving some
dune and forest buffer zones around the construction complex will increase the
asthetic and attractive value of the construction complex itself. So it is a win-win
situation for everybody. THIS CAN BE ACCOMPLISHED AND MUST BE
ACCOMPLISHED IF WE ARE TO KEEP OUR PLANET HEALTHY

16) Monitoring should also be required for restoration activities, as it is the case
for construction activities. If we do no implement a minimum of monitoring for
restored areas, we will not know if those restoration efforts are indeed working
17) Leaving corridors is also a pivotal point. Given the current uncertainty about
what size and shape corridors should have to make them most efficient (more
research needs to be done on that matter), we should use the precautionary
principle when designing corridors: if we have to err, it is important to err towards
the "safe" side (i.e. making sure the corridor will work).

18) In general, this documents gets a two thumbs up from me. Indeed a good
example for other counties to follow.

Written Comments Received 29 June 2009

19) I have read with interest the draft of Escambia County’s Habitat
Conservation Proposal. I’m sure this document represents many hours of work
by a number of individuals. . . consultants and county employees alike. . .as well
as a significant contribution from Escambia County taxpayers. I appreciate the
county wanting to develop and enforce strategies to protect the endangered
species on Perdido Key. . . something that, in my opinion, is long overdue.

20) In an ordinary world, a plan such as the one being presented by the county,
would be a significant tool in protecting the habitat of endangered species.
History tells us, however, that Perdido Key’s world is far from ordinary. For here
you have a small, fragile, body of land that also happens to generate enormous
income for Escambia County. This alone sets it aside from other places. Perdido
Key’s world is complicated, its issues complex and, as a result, its endangered
species have continually struggled at the hands of politicians and developers. . .
certainly more than they have from even the most severe hurricane.

21) As we all know, Escambia County has a significantly blemished record when
it comes to keeping politics away from policy decisions. And this is what troubles
me the most about this proposal. . . the potential for undue influence of politicians
when it comes to enforcing requirements related to protecting endangered
species. Because, ultimately, any plan put forward for protection of endangered
species on Perdido Key depends not upon the document. . . i.e., the written
words, but upon the commitment of the people representing, and enforcing the
words of the document.

22) Let me cite an example. . . It is well known, and often stated by local
politicians that Perdido Key is the county’s “cash cow.” Indeed, a significant
portion of county revenue is derived from the property tax assessments on
Perdido Key. So in 2008, recognizing that development and growth equates to
additional revenue, the county commissioners defied state law and chose to
amend the Comprehensive Plan. . . completely removing the dwelling cap on
Perdido Key. . . an act that would have allowed unbridled development. And, only
after the Perdido Key Association, the 1000 Friends of Florida, and the Florida
Department of Community Affairs intervened, did the County finally withdraw its
amendment. It’s been estimated the county spent upwards of $1million in taxpayer money trying to remove Perdido Key’s dwelling cap. So, I ask you, does
this sound like an entity that would have any regard. . . or any conscience for
protecting endangered species on Perdido Key; an entity that has continually
pushed for unlimited growth and development at any expense (certainly the
expense of endangered species) to gain revenue for county coffers. Let me also
be clear, this is not about county employees. My perception is most of them are
hard working individuals, who offer sound advice to their political superiors, yet
this advice is often neglected or overruled due to political influence. Even as I
stand here controversy is escalating over a proposed bingo parlor on Perdido
Key and the political issues related to the development order. Based on a decade
of documented, questionable behavior, I believe Escambia County politicians
should not be allowed to oversee, coordinate, or manage the protection of
federally endangered species on Perdido Key. Their past and current track
record clearly substantiates reasons why. I have also have other concerns about
this HCP outside the political arena. I’ll list them in no specific order.

23) 1) The plan itself. . . This plan is not about protecting. . . it’s about taking.
Only after reviewing the West End Committee’s PowerPoint presentation of the
HCP was I able to fully comprehend the true goals and objectives of the county’s
proposal. It is via these summary slides that one suddenly realizes this plan is
not about protecting endangered species, rather it’s about creating a method to
allow the legal “taking” of endangered species. In fact the word “take” is used
more than 20 times in this short presentation. Other terms like “assist in obtaining
timely incidental take authorizations;” “a permitting process over a 30 year term;”
“assurances that applications. . .which result in incidental take will be processed
in a timely and effective manner;” “one-stop shop;” “mitigation for unavoidable
impacts;” “incidental take permit management;” streamlined permitting process.”
Let us not fool ourselves that the major focus of this proposal is legitimizing the
taking of endangered species. . . not protecting them.

24) 2) All the information I have read in the HCP and related documents indicates
a significant decline in numbers of the PK beach mouse during the past few
years. . . especially following Hurricane Ivan. This also appears to be the case
with sea turtle nesting. Question. . . should we be approving any plan that allows
the “take” of a single endangered species? Shouldn’t a plan that authorizes the
“taking” of endangered species be tabled until numbers increase to viable levels?

25) 3) The proposed HCP appears to focus mostly on direct impacts to
endangered species and less on indirect impacts. Indirect impacts do play a
significant role, and have a cumulative effect, with regard to environmental
issues. This plan should incorporate a method to account for indirect impacts.

26) 4) I’m concerned that this plan authorizes, and opens for the county, a 30-
year window for “taking” the PK beach mouse and other endangered species.
This would seem entirely too long of a period.
27) 5) The HCP does not deal, in any way, with changes to State Road 292; yet
we have been shown drawings and renderings as well as repeatedly told by
politicians that plans are underway to widen the road. Shouldn’t any HCP include
all aspects of development on the Key and the effect on endangered species?
Recently, several Perdido Key organizations have asked the county to be a part
of an master overlay plan. . . that plan would certainly involve SR 292. So why
does the county’s HCP omit SR292 especially since they continually report
that work is underway.

28) 6) The steering committee for the HCP (West End Advisory) appears to be a
politically appointed entity with members being named by a single county
commissioner. Shouldn’t a committee attending to such important issues be
represented by as many varied interests as possible rather than a
commissioner’s select few?

29) 7) The use of the term “one stop shop” for permit application and review
(stated in the HCP) is in very poor taste. I believe “one stop shop” for the “take”
of endangered species is an inappropriate choice of words.

30) 8) I believe if you looked at the county’s past record of protecting endangered
species you would find that it is grossly inadequate. I understand the county has
an agreement (Conservation Management Fund) with USFWS and FFWCC yet I
have seen no visible signs of how these funds are being used to protect
endangered species.

31) Where have these CMF funds been spent? Where can progress reports be
secured? Who is responsible for the accounting?

32) 9) I believe Escambia County is one of the few coastal counties remaining in
the state that doesn’t have a turtle lighting ordinance. This is yet another example
of the county’s emphasis, or lack thereof, regarding the protection of endangered
species. For the past three years I have been on site for almost every turtle
hatching on the Key. In nearly every case the hatchlings turned toward the
artificial lights. . . away from the water. Had volunteers not been on site all
hatchlings would have perished. Proper lighting regulations are critical to all
wildlife. . . especially endangered species. The fact that Escambia County has
done nothing. . . not even enacted an ordinance like every other coastal county in
the state. . . is proof again that endangered species have not and are not a
priority.

33) 10) Beach furniture vendors continue to be allowed (by the county) unlimited
access to Perdido Key beaches. Their trucks, trailers, and tractors have left the
beach in deplorable condition on many occasions (I have photos if you like to
see). Their lounges at several locations create a barrier to any living creature
trying to come ashore and do not conform to FFWCC guidelines. Vendors
operate their vehicles on the entire length of the Key (from the FloraBama to Eden and eastward) when they should be carrying furniture to the beach through
the parking lots of each condominium. Perdido Key is now in the middle of turtle
season yet within the last few weeks (and even this morning 06.29.09) vendor
trucks have been driving on the beach. . . entering near the FloraBama or at
the old Sundown Condominium location and driving east along the dunes and
around vacationers (I have photos if you would like to see). I believe the county
has an ordinance preventing vehicles during turtle season. I have made repeated
complaints but I suspect employees have been instructed not press the issue.
Thus is just another example of why the county should not be involved in
managing the protection of endangered species.

34) 11) Several months ago I was told that the county received (on behalf of
Perdido Key) $3 million from FEMA related to the last hurricane. Where did these
funds go? How were they used?

35) 12) Due to the scope of this proposal, the HCP calls for significant amounts
of manpower and costs. . . whether related to predator control, live trapping,
tracking, monitoring, beach management, mapping, turtle patrol, hatchling
watches, lighting enforcement, nesting surveys, breeding inventories, data
management, field management, documentation, reporting, compliance and
enforcement, etc. These are just some of the manpower needs outlined in the
county’s HCP. Under these circumstances I believe it would be impossible for the
two or three employees mentioned in the HCP to effectively manage all of these
duties outlined and required by this document. And, based on past and current
evidence, it would be ridiculous to think the county would fund this plan to the
necessary levels to insure viability.

36) In summary, while Escambia County’s HCP offers good ideas, methods, and
strategies for protecting endangered species on Perdido Key, I believe the
county’s track record of using the Key as their “cash cow” at any expense to
endangered species makes this HCP unworkable. Again, based on the county’s
previous record (i.e., dwelling cap removal, lack of ordinances, and lack of active
participation in species protection), there is simply too much temptation and risk
in allowing the county have any part in protecting federally listed endangered
species. It would be akin to letting the fox watch the hen house. Perdido Key
would be much better off having outside independent parties (USFW, FFWCC,
etc.) protecting these valuable, endangered, and irreplaceable assets. I ask that
you give serious consideration to my comments and concerns. Thank you for
your time.






Written Comment Received September 2009

37) 1) Please explain the discrepancy between the most recent USFWS report (5-Year
Review of Perdido Key beach mouse) which implies the Perdido Key beach mouse is
near (or already in) jeopardy vs. approving an HCP that allows the taking of this
endangered species.
38) 2) Where is the data for this HCP that proves endangered species can survive and
flourish over the 30-year plan despite continual cumulative losses of their habitat?
39) 3) Does this consultant for the county have the level of experience with HCPs to
warrant the conclusions being used to justify their approval?
40) 4) Haven’t many HCPs (especially early ones) failed to protect listed species and
have significantly contributing to their continued decline? What assurance(s) do we
have that this one will be any more successful?
41) 5) Who are the technical people that have been involved with this HCP? What is
their credentials? What is level of experience? How many HCPs have they been
involved with prior to Perdido Key’s? Is it possible their findings required for HCP
approval have been loosely interpreted and made without adequate scientific
justification?
42) 6) Has there been an independent scientific review of this HCP? If so, when, and by
whom?
43) 7) How much money (to date) has Escambia County paid all consultants involved in
developing Perdido Key’s HCP? How much is the total estimate for the plan? What
budget is paying for this proposed plan? Where did these funds come from?
44) 8) How much time and resources have county employees spent on in developing
this plan? What duties have been neglected from working on this plan?
45) 9) Does USFWS often have the resources or the time to second-guess the work of
Escambia County’s high-paid consultants?
46) 10) Is it possible that the public getting a "sales job" that underemphasizes the
project's adverse cumulative impacts on species, while overstating the HCPs benefits?
Shouldn’t a comprehensive plan discuss both sides of an issue so the public can be
truly informed? Will the public be presented with these differences?
47) 11) How many public meetings were held?
48) 12) How were the HCP meetings publicized?
49) 13) How many people attended each public forum?
50) 14) In lieu of the extremely light turnout for meetings were other strategies
considered to notify and to involve the public in this important process?
51) 15) Who are the members of each committee (technical, West End, etc.)? Who
appointed them to these committees? How many have worked on HCPs prior to
Perdido Key’s?
52) 16) Where can the minutes of all committee meetings be found?
53) 17) How will this HCP process affect species recovery planning?
54) 18) Is this HCP plan being used being used in lieu of a federally mandated recovery
plan for any of the species?
55) 19) Is this HCP authorizing controlled take within species "reserve" areas, and
unlimited take outside of these areas?
56) 20) Does this HCPs requiring restoration of currently degraded lands? If so where
where is this property located. 57) 21) Does this HCPs contain insufficient mitigation measures to ensure the species'
ultimate survival (for that matter even recovery)?
58) 22) How will this HCPs be funded (list sources)?
59) 23) How is the county guaranteeing that funding is adequate over the life of the
entire plan (30 years)?
60) 24) What assurance does the public have that this HCP will have the adequate
funding to implement the mitigation measures in the plan and that the success (or
failure) of the mitigation efforts will be evaluated on a frequent basis over the life of the
plan?
61) 25) What will occur if the county does not meet funding requirements to sustain this
HCP?
62) 26) What are the consequences if the county does not meet the terms of the HCP?
63) 27) Who will be monitoring the county’s compliance with this plan? How often? To
what degree? Will the public have access to compliance reports?
64) 28) In lieu of the county’s blemished history in protecting endangered species what
assurances does the public have that they will honor the terms of this HCP?
65) Conclusion: HCPs are not about protecting endangered species. . . they are a
loophole in the ESA that legitimize the taking of a species. Let us. . . especially the
good folks at USFWS not be fooled. . . Instead, let’s look at who will be in charge of the
Perdido Key HCP if approved. . . the Escambia County Board of County
Commissioners. And what is their track record in protecting Perdido Key. . . aka their
cash cow. I believe their record speaks for itself. . .
• Escambia County has made no effort in the past two decade to enact a wildlife lighting
ordinance. As a result, countless thousands of endangered species have perished because of this. In fact, although a draft ordinance is mentioned in the plan, the
implementation of a lighting ordinance is unclear.
• Escambia County has continually looked the other way regarding vehicles on the
beach during endangered species breeding periods despite numerous public complaints
(I have photos).
• Escambia County has no policy in place regarding placement of beach furniture. . not
even adhering to FWCC guidelines for beach vendors. I’ll be happy to share photos with
you if you need proof.
• Escambia County has done little to enforce animal ordinances on the beaches. I live
on the beach almost year round and have never seen an enforcement officer address
the numerous violations.
• A few years ago Escambia County amended the comprehensive plan to completely
remove the dwelling caps on PK. . . and only after the Perdido Key Association, 1000
Friends of Florida and DCA intervened did they rescind the amendment. . . What does
this say about the county’s emphasis on habitat conservation?
• Escambia County recently had an opportunity to fund an overlay plan for PK and voted
against it. Think what this could have accomplished in bringing people together to plan
an environmentally friendly community on Perdido Key.
• Escambia County has plans and drawings on the table and before the public to 4-lane
SR292; yet this important environmental/transportation aspect has been left out of the
HCP. . . Why would a comprehensive HCP for Perdido not include the major
transportation artery along Perdido Key. Perhaps it would put the entire HCP in
jeopardy. Personally I believe the county is already in jeopardy.
• Escambia County has a questionable record in the issuance of development orders
and zoning matters on Perdido Key.
• Escambia County has looked the other way for 5 years with regard to requiring the
demolition of damaged structures from Hurricane Ivan

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