Title: Memorandum: Section 373.414, Florida Statues
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Permanent Link: http://ufdc.ufl.edu/WL00000736/00001
 Material Information
Title: Memorandum: Section 373.414, Florida Statues
Physical Description: Book
Language: English
Publisher: Florida Game and Fresh Water Fish Commission
 Subjects
Spatial Coverage: North America -- United States of America -- Florida
 Notes
Abstract: Memorandum: Section 373.414, Florida Statues, July 7, 1986
General Note: Box 7, Folder 2 ( Vail Conference 1987 - 1987 ), Item 12
Funding: Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.
 Record Information
Bibliographic ID: WL00000736
Volume ID: VID00001
Source Institution: Levin College of Law, University of Florida
Holding Location: Levin College of Law, University of Florida
Rights Management: All rights reserved by the source institution and holding location.

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FLORIDA GAME AND FRESH WATER FISH COMMISSION


STHOMAS L. HIRES, SR. WILLIAM G. BOSTICK, JR. C. TOM RAINEY, D.V.M. J.H. BAROCO MRS. GILBERT W. HUMPHREY
Chairman, Lake Wales Vice-Chairman, Winter Haven Miami Pensacola Miccosukee

Wildlife Research Laboratory
ROBERT M. BRANTLY, Executive Director 4005 South Main Street
F.G. BANKS, Assistant Executive Director0 ouh Main Str
Gainesville, Florida 32601
(904) 376-6481

July 7, 1986

MEMORANDUM

TO: Brad Hartman, Vic Heller, Randy Kautz, and Don Wood

FROM: Paul Moler A-1.

SUBJECT: Section 373.414, Florida Statutes (copy attached)

Section 373.414 FS requires affected water management districts to adopt
a rule, by March 31, 1987, establishing specific permitting criteria for
small isolated wetlands, including size thresholds below which impacts
on fish and wildlife and their habitats will not be considered. The law
provides further guidance, however, that "These thresholds shall be based
on biological and hydrological evidence that shows the fish and wildlife
values of such areas to be minimal.

I have previously discussed with each of you the dependence of many
amphibian species on small, often ephemeral, wetlands as breeding sites.
I am concerned that, without guidance from GFC (or worse, with uninformed
guidance from GFC), the districts will fail to recognize the vital
wildlife values of small isolated and/or ephemeral wetlands. The
following is a list of Florida amphibians which are more or less restricted
in breeding habitat to small isolated wetlands:

Oak toad Bufo quercicus
Pine Woods Treefrog Hyla femoralis
Barking Treefrog Hyla gratiosa
Squirrel Treefrog Hyla squirella
Little Grass Frog Limnaoedus ocularis
Florida Chorus Frog Pseudacris nigrita
Ornate Chorus Frog Pseudacris ornata
Spadefoot Toad Scaphiopus holbrooki
Gopher Frog Rana areolata
Flatwoods Salamander Ambystoma cingulatum
Mole Salamander Ambystoma talpoideum
Tiger Salamander Ambystoma tigrinum

Many of these are common and widespread species. However gopher frogs,
flatwoods salamanders and tiger salamanders often occur in scattered
populations, and a population may be totally dependent on a single 1/4
"= acre pond for its continued existence. In short, there is no threshold
size for which "biological...evidence" can show "the fish and wildlife
values...to be minimal." The necessary biological evidence would require a









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breeding season surveys) and an assessment of availability of other
alternate breeding sites in the immediate area. In other words, a site
specific assessment. Certainly, the interim value of 5 acres in
Section (3)(a) is inappropriate.

I urge you to seize this opportunity to provide input to the water
management districts in the development of these rules.


PM/ld


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