TO: Jdhn R. Wodraska, Executive Director
FRCM: Charles A. Padera, Division Director, Natural Resource Management
DATE: December 22, 1986
SUBJECT: Isolated Wetlands
Attached are materials you may find useful when discussing the District's
proposed Isolated Wetlands Rule. The major thrust of this rule is to satisfy
the requirements of the Florida Legislature and still maintain the standards and
flexibility of the current Basis of Review. The draft rule attempts to do this
by providing two pathways that a permit applicant may pursue. One pathway is
primarily quantitative in nature and utilizes numercial standards, ratios, etc.
to guage presumptions and reasonable assurances. This route is in response to
those advocating predictable and standard criteria to base site plan and
economic decisions. These criteria are conservative and should be if a
presumption is to be in favor of an applicant regardless of site specific
conditions. The other route is qualitative and is essentially what we do now.
The only new idea alluded to is one of "banking". Staff has committed resources
to pursuing this compensation tool.
The statutes required the water management districts to establish size
threshold(s) below which review for fish and wildlife impacts would not occur.
These thresholds are to be based on hydrological and biological evidence that
indicate minimal values. District staff proposes a 0.5 acre threshold based on
the acceptance of this size as a minimum hydrological criterion for surface
water management use. Biological evidence to date indicates a zero size
threshold would be appropriate if the specific language of the statute is the
guiding criteria for threshold establishment.
In summary, most, but not all, of what's proposed in this draft rule is
currently practiced and the rule would provide applicants more certainty (via
quantitative route) than what presently exists.