Stanley W H
~r~ar~ irai~ oh R Wdrsk. Eectie irto
Souhn 0 a JohR. Wodreka. Execuve Dtor
(*r, uxn U ionaa 'TtfIord C. Creel. Deputy Executive Dirfctor
Water Management District
)' )- f Post Office Box 24680 3301 Gun Club Road
k'^ ^ West Palm Beach, Florida 33416-4680
Telephone (305) 686-8800
Florida WATS Line 1-800-432-2045
PLY REFER TO:
November 6, 1986
Huey, Guilday, Kuersteiner
and Tucker, P.A.
Tallahassee, FL 32302
Attention: Mr. J.D. Boone Kuersteiner
Dear Mr. Kuersir:ei6
Subject: Appendix 7, Isolated Wetlands Rule
Pursuant to your requests, staff of the South Florida Water Management District
has collected for you biological and hydrological evidence relative to the
threshold in proposed Appendix 7. We had hoped to provide you with it at one of
the meetings scheduled with you to specifically discuss the proposed Appendix 7
and the thresholds. However, since none of the meeting times have proved
convenient, the bulk of the information is enclosed with this letter.
Appendix 7 provides for a 0.5 acre threshold for isolated wetlands below which
impacts on fish and wildlife and their habitats will not be considered during
the review of applications for surface water management permits.
Biological evidence for size thresholds has been provided by written and oral
presentations as well as through review of certain technical reports. This
information overwhelmingly suggests that all isolated wetlands, regardless of
size, have fish and wildlife functions and values. Therefore, if staff were to
base the threshold strictly on the biological evidence provided to date, we
would have to propose that impacts on fish and wildlife associated with all
isolated wetlands, regardless of size, be reviewed and considered when making
recommendations on surface water management permit issuance or denial.
A 0.5 acre threshold has been widely accepted as a size threshold for surface
water management systems' wet retention/detention areas as provided in Section
220.127.116.11.1 of the "Basis of Review for Surface Water Management Permit
Applications within the South Florida Water Management District". The 0.5 acre
number was selected during a rule adoption process which followed extensive
project design experience by engineering and scientific consultants and project
review experience by District staff. The number represents the size above which
water management areas are of sufficient significance such that side slopes,
water depths, littoral zones, etc. are a design consideration for water
quantity, quality and environmental purposes. Areas smaller than 0.5 acres were
considered to be of lesser design and operation si nificance and were therefore
W, am E Sacowski John F Flanigan
Chairman ,';ami Vice Chairman North Palm Beaor
olo J Neil Gallagher Nathaniel P Reed Kathleen Shea Abrams Ti...''E Powers Nancy H Roen Oscar M Corbin. Jr
St Clo)ti H|!te Sound Miami Stores Indlntown Plantation Ft Myers
Mr. J.D. Boone Kuersteiner
SNovember 6, 1986
removed from complex water management consideration by establishing them as dry
detention/retention areas. While the criteria contained in 18.104.22.168.1 is
essentially for created wet retention/detention areas, staff feels that this
particular area threshold (22.214.171.124.1.(a)) is also appropriate when designing a
surface water management system for a site that contains isolated wetlands. The
current draft Appendix 7 still proposes the 0.5 acre threshold.
Staff selected the 0.5 acre threshold based on the evidence to date and the
(1) The current use and acceptance of this threshold for surface water
management system design;
(2) The experience of staff regarding the design and operation of surface
water management systems and how they may affect wetland associated
fish and wildlife functions and values;
(3) The practicalities of administering a program with such a threshold
and the benefits provided by easing design and permit obstacles.
I have enclosed copies of pertinent written comments received to date, a
technical memorandum by staff with cited references, and summaries of three of
( the public workshops. Tape recordings from the public workshops are available
for you to either review or copy. Additional studies and treatises are also
relevant to the subject and can be collected and made available to you to
inspect at the West Palm Beach office.
Staff is still available to meet and discuss Appendix 7 with you at your
convenience. Your participation in the review of these draft rules is
harles A. Padera, Director
Natural Resource Management Division
Resource Control Department
cc: Richard N. Hartman, E.I.
Planning and Engineering
Orlando Central Park, Inc.
James B. Brown
Orlando Central Park, Inc.