Title: Recommendations of the Wildlife Advisory Group to the Department of Community Affairs
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Title: Recommendations of the Wildlife Advisory Group to the Department of Community Affairs
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Language: English
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Spatial Coverage: North America -- United States of America -- Florida
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Abstract: Recommendations of the Wildlife Advisory Group to the Department of Community Affairs October 26, 1988 Final Review Version
General Note: Box 7, Folder 4 ( Vail Conference 1989 - 1989 ), Item 68
Funding: Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.
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Bibliographic ID: WL00000969
Volume ID: VID00001
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RECOMMENDATIONS OF THE WILDLIFE ADVISORY GROUP
TO THE DEPARTMENT OF COMMUNITY AFFAIRS

[OCTOBER 26TH FINAL REVIEW VERSION]

CHARGE OF THE WILDLIFE ADVISORY GROUP

On April 25, 1988, Secretary of the Florida Department of
Community Affairs, Thomas G. Pelham, appointed twelve members
with experience in the Development of Regional Impact (DRI)
review process to the Wildlife Advisory Group. In appointing the
members, Secretary Pelham charged the advisory group with
proposing a statewide approach to ensuring the protection of
significant upland vegetation and wildlife resources which could
be impacted by DRIs. The members of the Wildlife Advisory Group
believe that this report and its three sets of recommendations,
the product of seven months of effort on the part of its members,
fulfills the charge given to the advisory group by the Secretary
in April.

BACKGROUND

Florida possesses a number of unique upland habitats and
plant communities, such as those of the Central Florida Highlands
Ridge, the Florida Keys, and the slope forests of the upper
Apalachicola River. Of the 36 million acres in Florida,
approximately 11 million acres were upland forest, scrub and
brush in 1984 (DCA, 1987). Yet, unlike wetland habitats, upland
habitats and their biota are relatively unprotected by present
local, state or federal regulations in Florida. In some regions
such as central and south Florida, native upland habitat losses
due to agricultural, silvicultural and developmental activities
have been relatively greater than the 55% overall wetland loss
often cited as a major reason for wetlands preservation and
permitting in Florida. Other regions, such as north Florida have
also experienced conversion of native upland habitats, but not at
the accelerated rate of that in central and south Florida.

As high and dry developable lands, native upland areas in
some regions of Florida have been heavily impacted over the past
150 years. Estimates are that Florida has lost 65% of its
subtropical pine forest, 85% of its sand pine scrub, and 84% of
its northern sandhill communities in the last thirty years
(Klopatek, et. al.; Means and Grow). [ROBIN HART I NEED FULL
CITATION] For the Lake Wales Ridge scrub habitat, conversion of
native habitat to other land uses has meant the elimination of
almost the entire native community type (estimated 5% of the
original scrub habitat remains). Due to the well-drained,
accessible nature of this ridge, the scrub habitat has been
replaced and isolated by citrus groves, rangeland, highways, and
development. Additionally, the few remaining ridge tracts of
sizeable scrub habitat are under continuing conversion pressures.








Statewide, there are approximately 37 upland, state-listed
threatened and endangered animals, and 204 upland, state-listed
threatened and endangered plants. There are many factors that
cause the need for a species to be listed as threatened or
endangered, but the principal factors are associated with human
impacts and species habitat destruction. It has been estimated
that over the past ten years, almost ten million acres of
wildlife and wildlife oriented recreational habitat has been lost
in Florida as a result of man's agriculture, silvaculture and
development activities (State Land Development Plan, 1988). The
vast majority of this loss in wildlife habitat has occurred in
the uplands. However, in some areas of the state such as north
Florida, land and time still exist to be able to wisely preserve,
regulate and manage existing native upland communities.

State policy, as promulgated in the State Comprehensive Plan
adopted by the legislature in 1985, mandates that Florida shall
protect and acquire unique natural habitats; restore degraded
natural systems to a functional condition; prohibit the
destruction of endangered species and protect their habitats; and
establish an integrated regulatory program to assure the survival
of threatened and endangered species within the state.
Presently, one of the few state programs with implemented
regulatory/planning authority over upland species and habitats is
the Development of Regional Impact (DRI) review process [Section
380.06, Florida Statutes].

Although some members of the Wildlife Advisory Group have
questioned the authority of the DRI review process to address
certain upland habitat issues, throughout the fifteen year
history of the DRI process it has dealt with the planning and
regulation of significant resources in upland areas under the
broad authority provided by the act to protect the natural
resources and environment of the state. The specific charge of
the Wildlife Advisory Group has been to address and make
recommendations to the Department of Community Affairs concerning
the impacts of DRIs on upland native vegetative communities and
wildlife habitats. However, it must be recognized that the DRI
review process involves only between 5-10% of the total
development in Florida, and can adequately address only a small
part of the native uplands habitat conversion problem in
Florida. Even if the Department establishes a DRI rule based
upon the following Wildlife Advisory Group's recommendations,
other planning, regulatory, and acquisition programs will need to
be developed and implemented to fully address the ongoing
conversion and loss of Florida's unique native upland habitats
and plant communities.
GENERAL RECOMMENDATIONS

The recommendations of the Wildlife Advisory Group are
separated into three categories: (1) Specific proposals for a
Development of Regional Impact (DRI) rule establishing criteria








for guaranteeing when DCA would not appeal a DRI development
order on issues relating to upland communities, upland listed
species and their habitats.; (2) General recommendations to the
Application for Development Approval (ADA) Revision Advisory
Committee on appropriate wildlife and plant survey methodology
guidelines for use in the DRI ADA; and (3) Recommendations to DCA
for consideration in addressing upland vegetation and wildlife
issues equally for all development in the state, not just DRIs.

RECOMMENDATION 1: PROPOSAL FOR A DRI UPLAND HABITAT POLICY RULE

An Upland Habitat Policy Rule should be promulgated by the
Department of Community Affairs. The rule should establish
standards by which the Department would evaluate the adequacy of
upland habitat conditions of approval in development orders for
Developments of Regional Impact (DRIs) relating to the following
thirteen categories of upland resources: (1) State Listed
Endangered Animal Species; (2) State Listed Threatened Animal
Species; (3) State Listed Animal Species of Special Concern; (4)
Special Listed Animals; (5) Colonial Bird Nesting Sites; (6)
Migratory Bird Concentration Areas; (7) Non-listed Wildlife,
Plants, and their Habitats; (8) Disruption of Regional
Populations; (9) Publicly Owned Wildlife and Plant Habitats; (10)
Wildlife Corridors; (11) State Listed Endangered Plants; (12)
State Listed Threatened Plants; and (13) Rare Plant Communities
of State Concern.

Additionally, as the allowance of offsite compensation under
appropriate circumstances is a key aspect of the Wildlife
Advisory Group's recommendations, an additional recommendation is
included on the rule criteria that need to be established to
guide offsite compensation, whether through land-banking or other
approved means. This provision for offsite compensation is
essential as it allows a developer, in most circumstances, the
flexibility to undertake his development onsite, while providing
adequate compensation offsite for the impacts of his development
on upland native habitats.

The Upland Habitat Policy Rule should be promulgated in a
format similar to the Department's existing Transportation Policy
Rule and proposed hurricane preparedness policy rule. Therefore,
the rule should establish standards and criteria for regionally
significant upland resources, substantial impacts to regionally
significant upland resources, and development order conditions
adequate to address substantial impacts to regionally significant
upland resources.

The type and endangerment of natural upland systems in
Florida vary widely by region. For many regions of the state,
the proposed criteria for upland habitat protection will be
sufficient to adequately address DRI developmental impacts.
However, in other areas of the state, where particular upland
habitats have been substantially eliminated and are quickly








disappearing, more stringent mitigative measures may be necessary
to adequately protect unique uplands species and communities.
Therefore, some members of the Wildlife Advisory Group recommend
that, similar to the DCA Transportation and Hurricane
Preparedness Policy Rules, any promulgated Upland Habitat Policy
rule needs to recognize the ability of regional planning councils
and local governments to impose more stringent mitigative
measures than those delineated in the rule. Other members
recommend that the Department's rule establish maximum exactions
that cannot be exceeded by regional planning councils. The full
Wildlife Advisory Group recommends that the rule should recognize
specific upland policies for Areas of Critical State Concern,
adopted pursuant to Section 380.05, F.S., and Resource Management
Plans, adopted pursuant to Section 380.045, F.S., where such
policies are more stringent than those delineated in the Upland
Habitat Policy Rule.

It is acknowledged that the Department of Agriculture and
FGFWFC's threatened and endangered wildlife and plant lists can
be incorporated by reference into a state agency rule only in
their present form, and that future changes to these listed
species lists will need to be amended into the DCA rule by
additional rulemaking, probably on a yearly to biennial basis.
Therefore, it is also a recommendation of the group to
incorporate the specific state listed species addressed by the
rule directly into the Upland Policy Rule by scientific, and
where applicable, by common names. Listed species not
specifically included in the rule would not be addressed by the
rule. The advisory group was divided on whether the Department
has the authority, or even should address and include state
listed threatened and endangered plant species in any proposed
rule by the Department.

Additionally, it should be noted that, in general,
developmental representatives on the advisory group considered
most of the numerical criteria listed below to be too
restrictive, whereas environmental representatives on the
advisory group considered most of the following criteria as not
restrictive enough to protect the regional resources. In all
instances where dissenting recommendations are noted, except
where noted otherwise, the Wildlife Advisory Group was
essentially equally divided in its recommendations.

The following criteria are the Wildlife Advisory Group's
specific recommendations to be incorporated into a DRI Upland
Habitat Policy Rule by the Department of Community Affairs.
Where offsite compensation is allowable, the rule should be non-
cumulative when addressing the same habitat area onsite under
separate criteria; for example, if both threatened species and
species of special concern were to occur onsite in the same
habitat area, only the more restrictive of the two rule criteria
would apply for preservation or compensation for the same onsite
acreage.
4








(1) Endangered animal species. The regional resource would
be considered to occur onsite wherever endangered species are
documented onsite or are documented on a contiguous suitable
habitat for the endangered species. A substantial impact would
consist of any proposed adverse impact to such an endangered
species habitat or population. These species would require 100%
habitat protection, except where noted below that only the cave
site is intended for protection, and the development of a
management plan to address non-habitat management factors such as
the introduction of domestic animals, motorized vehicles and
other secondary effects of development.

Listed Species covered:

American Crocodile Crocodvlus actutus;
Chadwick beach cotton mouse Peromvscus aossvpinus
restricts;
Choctawhatchee beach mouse Permvscus Dolionotus
allophrvs;
Goff's pocket gopher Geomvs Dinetis aoffi;
Gray bat Mvotis arisescens [CAVE SITE PROTECTION ONLY];
Key Largo woodrat Neotoma floridana small;
Key Largo cotton mouse Peromvscus aossyvinus allabaticola;
Key deer Odocoileus virainianus clavium;
Pallid beach mouse Peromvscus Dolionotus decoloratus;
Perdido Key beach mouse Permvscus Dolionotus trissvlleDsis
Schaus' swallowtail butterfly Heraclides aristodemus
ponceanus;
Silver Rice Rat Orvzomvs araentatus;
Stock Island tree snail Orthalicus reses

(2) Threatened Animal Species. A regional resource would be
considered to be suitable habitat onsite that is either
documented to have the species or that is large enough, counting
available habitat on adjacent lands, to support a population of
the species.

(A) Any proposed development that would cause either the
effective loss of 25 acres of threatened species habitat, or a
specified minimum viable habitat size, whichever is less, would
be considered to require compensation. Proposed compensation
would consist of preservation onsite or offsite of acreage
equivalent to 30% of the onsite defined habitat areas. Onsite
compensation would be allowed only when there is sufficient
habitat, management and protection capabilities to maintain a
sustainable population. Offsite compensation would include
criteria for acquisition of habitat specifically suited for and
used by the species that is capable of being properly managed.
Listed Species covered:

Big Pine Key ringneck snake Diadophis punctatus acricus;
Blue-tailed mole skink Eumeces eareaius lividus;








Everglades mink Mustela vison everaladensis;
Florida brown snake Storeria dekavi victa;.
Florida ribbon snake Thannophis sauritus sackeni;
Mangrove fox squirrel Sciurus niaer avicennia;
Miami black-headed snake Tantilla political
Sand skink Neoseps revnoldsi;
Southeastern kestrel Falco sparverius paulus;
White-crowned pigeon Columba leucocephala

(B) Any proposed development that would adversely affect
identified upland nesting by threatened bird species would be
considered to require nesting protection. Where upland use is
restricted to nesting habitat, protection would consist of
preservation of the nest site, along with suitable habitat onsite
(applies prinicipally to snowy plovers, bald eagles, roseate
terns, and least terns). Otherwise, protection would consist of
preservation of the nest site and a suitable buffer where upland
foraging habitats will remain close enough to the nest after
development to support the nesting animal (e.g. caracara).

Listed Species covered:

Bald Eagle Haliaeetus leucocephalus;
Caracara Polvborus plancus;
Florida sandhill crane Grus canadensis Dratensis;
Least tern Sterna antillarum;
Piping plover Charadrius melodus;
Roseate tern Aiaia aiaia;
Snowy plover Charadrius alexandrinus tenuirostris;

(3) Species of Special Concern. A regional resource would
be considered to be suitable habitat onsite that is either
documented to have the species or that is large enough, counting
available habitat on adjacent lands, to support a population of
the species.

(A) Any proposed development that would cause either the
effective loss of 50 acres of species of special concern habitat,
or a specified minimum viable habitat size, whichever is less,
would be considered to require compensation. Proposed
compensation would consist of preservation onsite or offsite of
acreage equivalent to 20% of the onsite defined habitat areas.
Onsite compensation would be allowed only when there is
sufficient habitat, management and protection capabilities to
maintain a sustainable population. Offsite compensation would
include criteria for acquisition of habitat specifically suited
for and used by the species that is capable of being properly
managed.
Listed Species covered:

Bog frog Rana okaloosae;
Eastern chipmunk Tamias striatus
6








Florida mouse Peromvscus floridanus;
Florida Keys mole skink Eumeces eareaius eareaius;
Gopher frog Rana areolata;
Gopher tortoise Gopherus Dolvyhemus;
Homosassa shrew Sorex lonairostris eionis;
Pine barrens treefrog Hvla andersonii;
Red rat snake Elaphe auttata auttata;
Sanibel Island rice rat Orvzomvs palustris sanibeli;
Sherman fox squirrel Sciurus nicer shermani;
Sherman's shrew Blarina carolinensis shermani

(B) Any proposed development that would adversely affect
identified upland nesting by species of special concern bird
species, or would adversely affect identified cave sites of
species noted below, would be considered to require protection.
Where upland use is restricted to bird nesting habitat,
protection would consist of preservation of the nest site, along
with suitable habitat onsite. Otherwise, protection would
consist of preservation of the cave site, or protection of the
bird nest site and a suitable buffer where upland foraging
habitats will remain close enough to the bird nest after
development to support the nesting animal.
Listed Species covered:

Borrowing owl Athene cunicularia;
Georgia blind salamander Haideotriton wallacei [CAVE SITE
PROTECTION ONLY];
Marians's marsh wren Cistothorus palustris marianae;
Osprey Pandion haliaetus [MONROE CO. POPULATION
PROTECTION ONLY];
Scott's seaside sparrow An odramus maritimus peninsulae;
Wakulla seaside sparrow Ammodramus maritimus luncicolus;
Worthington's marsh wren Cistothorus Dalustris arieseus

(4) Special Listed Animals.

BACKGROUND: This category involves specific threatened and
endangered listed animal species that need to be excluded from
the impact protection criteria developed above for listed
wildlife species, for reasons related to their life history,
endangerment, or inability to be adequately documented onsite or
protected through the criteria listed above. Therefore, the
recommendations for these wildlife are made on a species by
species basis:

CRITERIA:

Specific listed species covered:

Florida Panther (Felis concolor corvi) Because of the
extremely large home ranges and the difficulty of defining
precise habitat needs in the DRI process, the general
7








compensation provisions proposed for non-listed wildlife habitats
and wildlife corridors would be relied upon for protection; no
additional protection is proposed.

Florida black bear (Ursus americanus floridanus) Because of
the extremely large home ranges and the difficulty of defining
precise habitat needs in the DRI process, the general
compensation provisions proposed for non-listed wildlife habitats
and wildlife corridors would be relied upon for protection; no
additional protection is proposed.

Indiao snake (Drvmarchon corais couperil A regional
resource would be considered to be the presence of 5000 acres of
contiguous, suitable habitat onsite and on adjacent lands.
Compensation would be required for development proposing to
eliminate 50 acres of hardwood hammock or sandhill habitat, and
would consist of preservation offsite of 10% of the acreage of
hardwood hammock or sandhill habitat present onsite.

NOTE: Members of the Wildlife Advisory Group are divided on this
recommendation; dissenting members recommend that indigo snake
protection be addressed in a manner similar to the panther and
black bear, due to the large range requirements of the species.

Pine snake (PituoDhis melanoleucus muaitusl A regional
resource would be considered to be the presence of suitable
habitat onsite. Compensation would be required for development
proposing to eliminate 50 acres of hardwood hammock or sandhill
habitat, and would consist of preservation offsite of 10% of the
acreage of hardwood hammock or sandhill habitat present onsite.

Short-tailed snake (Stilosoma extenuatuml A regional
resource would be considered to be the presence of suitable
habitat onsite. Compensation would be required for development
proposing to eliminate 50 acres of sandhill habitat, and would
consist of preservation offsite of 10% of the acreage of sandhill
habitat present onsite.

Red-cockaded woodpecker (Picoides borealis). A regional
resource would be the identified nesting or foraging onsite of
the species. Any development causing a 20% reduction in foraging
trees onsite, or any development proposed within 200 feet out
from the outermost active, or inactive nesting or roosting trees
would be considered a significant impact needing protection.
Protection would consist of preserving 80% of the forage trees
onsite and establishment of a preservation buffer 200 feet out
from the outer most active, inactive or start hole trees of a
colony, except when it can be scientifically demonstrated that
the onsite population is not a sustainable colony. Non-
sustainable colony compensation would involve the offsite
preservation in a protected, managed area of foraging and/or
nesting habitat equal in area to that present onsite.
[NOTE: LEW FRIEDLAND MAY OFFER DISSENTING RECOMMENDATION]
8







Scrub Jay Aphelocoma coerulescens coerulescens). A regional
resource would be the presence onsite of potentially suitable
or 3b jay habitat. Any development proposing to adversely affect
C ( rcres or more of potentially suitable scrub jay habitat within
7 miles of the nearest active scrub jay territory would require
protection. Protection would consist of preservation onsite or
compensation offsite of a minimum of 14 acres, plus 25 percent of
all remaining acreage of potentially suitable habitat onsite.

Grasshopper sparrow (Ammodramnus savannarum floridanus) ~the

potential suitable hi t-wit.hin the ge-g-raphi ran. e-of-the
species, The presence of the species onsite er en-eenbignou-
sites would require protection. Protection would consist of a
combination of on-site protection and long term management, or
offsite compensation and initial management that will result in
no long term decrease in the population of the species.

(5) Colonial Bird Nesting Sites. A regional resource would
be the presence of nesting colonial nesting birds, excluding
cattle egrets.

(A) Any development that would adversely affect 5 mixed
pairs of state listed nesting colonial nesting birds would
require protection. Protection would consist of preserving the
nesting area and providing land-uses adjacent to the nesting
areas appropriate to preserve and protect the nesting areas.

^ Listed Colonial Nesting Birds covered:

Brown pelican Pelecanus occidentalis;
Least tern Sterna antillarum;
Little blue heron Earetta caerulea;
Reddish egret Earetta rufescens;
Roseate spoonbill Aiaia aiaia;
Roseate tern Sterna douaallii;
Snail kite Rostrhamus sociabilis;
Snowy egret Earetta thula;
Tricolored heron Earetta tricolor;
Wood stork Mvcteria americana

(B) Any development that would adversely affect 25 mixed
pairs of non-listed nesting colonial nesting birds would require
protection. Protection would consist of preserving the nesting
area and providing land-uses adjacent to the nesting areas
appropriate to preserve and protect the nesting areas. [NOTE:
The Wildlife Advisory Group members are divided on the above
recommendation, with some members objecting to the inclusion of
non-listed colonial nesting birds for protection criteria].








Non-listed Colonial Nesting Birds covered:


Anhinga Anhinaa anhinaa;
Black-crowned night-heron Nvcticorax nvcticorax;
Black skimmer RvnchoDs niara;
Brown noddy Anous stolidus;
Caspian tern Hvdropoone caspia;
Cliff swallow Petrochelidon pvrrhonota;
Common tern Sterna hirundo;
Double-crested cormorant Phalarcrocorax auritus:
Glossy ibis Pleaadis falcinellus;
Great blue heron Ardea herodias;
Great egret Casmerodius albums;
Gull-billed tern Gelochelidon nilotica;
Laughing gull Larus atricilla;
Magnificent frigatebird Freaata maonificens;
Rough-winged swallow Stelaidoptervx ruficollis;
Royal tern Thalasseus maximus;
Sandwich tern Thalasseus sandvicensis;
Sooty tern Sterna fuscatc;
White ibis Eudocimus albus;
Yellow-crowned night-heron Nvctanassa violacea

(6) Miaratorv Bird Concentration Areas.
BACKGROUND: The spring migration of birds across the eastern
part of the United States involves (1) Trans-Gulf migrants that
travel via water routes across the open Gulf of Mexico and (2)
Circum-Gulf migrants that travel principally via land routes
around the Gulf of Mexico. The vast majority of forest-dwelling
migrants are predominately Trans-Gulf migrants (Stevenson,
1957). Trans-Gulf migrants accumulate large fat storage prior
to their non-stop water crossing flights of 600 miles or more,
but often reaching the Florida coast exhausted and with their fat
reserves depleted. Foraging among the Florida coastal forests
for a day or two to rebuild their fat reserves immediately after
their cross-Gulf flight is mandatory if these birds are to
survive and continue their migration. The birds appear to
forage in all types of coastal forests, with different species
utilizing different parts of the forest.

CRITERIA: A regional resource would be the presence of migratory
bird concentration areas in coastal hardwood hammock areas. Any
development that would result in the removal of 25 acres of
canopy or groundcover in coastal areas supporting coastal
hardwood plant communities would require protection. Protection
would consist of protecting 80% of the canopy and 50% of the
groundcover onsite. [ELIGIBLE FOR OFFSITE COMPENSATION??]
(7) Non-listed Wildlife. Plants and their Habitats.
BACKGROUND: Upland vegetative plant communities in Florida that
do not contain state listed plant and animal species provide
important environmental functions by providing wildlife habitat,
maintaining clean air and water, and supplying protection to
10


/A S'e4








important watersheds. As habitat loss is the single most
important cause mandating the listing of a species as endangered
or threatened, it is critical to manage major habitat losses
before it became necessary to list associated plant and animal
species as threatened or endangered. Furthermore, wildlife
species legally belongs to the citizens of Florida regardless of
the location of their occurrence. Therefore, with major
dissention among members of the Wildlife Advisory Group regarding
the appropriateness of the following criteria and a question as
to whether Chapter 380, F.S., provides legal authority to address
non-listed species in the DRI process, the following
recommendations are deemed important and necessary by some
members to address non-listed wildlife, plants and their
habitats. (RANDI FITZGERALD IS TO SUPPLY DISSENTION DISCUSSION].

CRITERIA: A regional resource would be non-listed wildlife,
plants and their native upland habitats. Any development
proposing the removal of 1,000 acres of native upland habitat
would require compensation. Compensation would consist of
preservation onsite or offsite of 10% of the onsite non-listed
species' native upland habitat.
(8) Disruption of Regional Pooulations. Any development
proposing the disruption of 10% of the regional population of any
species would require compensation. Compensation would involve
onsite preservation, where a discrete population occurs onsite in
relatively defined areas, along with a suitable buffer. The
burden of demonstrating such a regional population disruption
should be on state, federal, or regional governmental agencies.
[EXAMPLES OF SUCH SPECIES USEFUL??]

(9) Publicly Owned Habitat. A regional resource would be any
publicly owned habitat. Any development proposed adjacent to
publicly owned habitat that would interfere with the stated
habitat management and use objectives of that property would
require compatibility review. Compatibility review would involve
a cooperative effort between the agency managing the publicly
owned habitat and the developer of the adjacent property to
ensure compatible habitat management practices and adjoining land
uses.

(10) Wildlife Corridors. A regional resource would be a
major corridor important to the conservation of a listed wildlife
population. Any development that would isolate or sever a single
population to the extent that an isolated segment would not
remain a viable population would require protection
consideration. The degree of corridor protection required, if
any, would depend on the significance of the anticipated loss
within the region. The burden of demonstrating such a
population isolation should be on state, federal, or regional
governmental agencies.

11


/5,//







(11) Endangered Plants. The regional resource would be the
occurrence of state listed endangered plants onsite. Protection
would be required for any adverse impact to the endangered plant
species population, occupied habitat, or area necessary for the
population to persist at the site. Protection would be 100%
onsite preservation and an adequate buffer to provide protection
from the impacts of development.

Species covered:

Adiantum melanoleucum (fregrant maidenhair fern)
Amorpha crenulata (Miami lead plant)
Aauileaia canadensis (Columbine)
Aristida floridana (Key West three-awn)
AscleDias curtissii (Curtiss milkweed)
Asimina tetramera (four-petal pawpaw)
Asplenium auritum (auricled spleenwort) (fern)
Asplenium monanthes (San Felasco spleenwort)
AsDlenium Dumilum (dwarf spleenwort)
Blechnum occidentale (sinkhole fern)
Bonamia arandiflora (Florida bonamia)
Bulbophvllum Dachvrhacis (rat-tail orchid)
Campanula robinsiae (Chinsegut bellflower)
Camvploneurum anaustifolium (narrow swamp fern)
Cassia kevensis (Key cassia)
Catesbaea Darviflora (dune lily-thorn)
Catoosis son. (all native species catopsis)
Celtis iouanaea (Iguana hackberry)
Celtis oallida (spiny hackberry)
Centroaenium setaceum (spurred Neottia)
Cereus eriophorus (Indian River prickly-apple)
Cereus aracilis (West Coast prickly apple)
Cereus robinii (tree cactus)
Chamaesvce aarberi (Garber's spurge)
Chionanthus pvcmaeus (pygmy fringe-tree)
Chrysophvllum oliviforme satinleaff)
Chrvsonsis cruiseana (Cruise's golden-aster)
Chrvsoosis floridana (Florida's golden-aster)
Clusia rosea (balsam apple)
Cordia sebestena (Geiger tree)
Croomia pauciflora (croomia)
Cupania alabra (cupania)
Deerinaothamnus pulchellus (white squirrel-banana)
Deerinaothamnus ruaelii (yellow squirrel-banana)
Dicerandra cornutissima (Robin's mint)
Dicerandra frutescens (Lloyd's mint)
Dicerandra immaculate (Olga's mint)
Encvclia boothiana (Epidendrum boothianum) (dollar orchid)
Epiaaea repens (trailing arbutus)
Euaenia rhombea (red stopper)
Gentiana pennelliana (wiregrass gentian)
Gossvpium hirsutum (wild cotton)
Guaiacum sanctum (lignum vitae)
12







Guzmania monostachia (Fuch's bromeliad)
Harperocallis flava (Harper's beauty)
Hedeoma araveolens (mock pennyroyal)
Hepatica americana liverleaff)
Hvpericum cumulicola (Highlands scrub hypericum)
Ionopsis utricularioides (delicate ionopsis orchid)
Jacauemontia curtissii (pineland jacquemontia)
Jacauemontia reclinata (beach jacquemontia)
Justicia coolevi (Cooley justicia)
LeDanthopsis melanantha (tiny orchid)
Liatris ohlinaerae (scrub blazing-star)
Liatris provincialis (Godfrey's blazing-star)
Licaria triandra (licaria)
Linum arenicola (sand flax)
Lupinus aridorum (McFarlin's lupine)
Lvcopodium dichotomum (handing club-moss)
Macbridea alba (white birds-in-a-nest)
Maanolia ashei (Ashe magnolia)
Maanolia pvramidata (pyramid magnolia)
Mallotonia anaphalodes (sea-lavender)
Matelea spp. (all native species) (spiny-pod)
Monotrooa hvpopithvs (pine-sap)
Monotroosis revnoldsiae (pygmy-pipes)
Nemastvlis floridana (fall-flowering ixia)
Nolina atonocarpa (Florida beargrass)
Okenia hvooaaea (burrowing four-o'clock)
Oncidium varieoatum (dancing-lady orchid)
Oxvpolis areenmanii (gaint water-dropwort)
Pachvsandra procumbens (Allegheny-spurge)
Parnassia arandifolia (grass-of-Parnassus)
Peperomia soP. (all native species) (peperomia)
Phoradendron rubrum (mahogany mistletoe)
Pitvopsis flexuosa (golden-aster)
Polvaala lewtonii (Lewton polygala)
Polvaala smallii (tiny polygala)
Polvrrhiza lindenii (ghost orchid)
Pseudophoenix saraentii (buccaneer palm)
Remirea maritima (beach-star)
Restrepiella ophiocephala (snake orchid)
Rhododendron alabamense (Alabama azalea)
Rhododendron austrinum (orange azalea)
Rhododendron chapmanii (Chapman's rhododendron)
Ribes echinellum (Miccosukee gooseberry)
Rovstonea elata (Florida royal palm)
Rudbeckia nitida (St. John's Susan)
Sachsia behamensis (Bahama sachsia)
Schizaea aermanii (tropical curly-grass)
Spiaelia aentianoides (gentian pinkroot)
Spiranthes polvantha (Ft. George ladies-tresses)
Stewartia malacodendron (silky camellia)
Taxus floridana (Florida yew)
Tectaria coriandrifolia (Hattie Bauer halberd fern)
Tillandsia pruinosa (fuzzy-wuzzy air-plant)
13








Torreva taxifolia (Florida torreya)
Trillium lancifolium (lance-leaved wake-robin)
TroDidia Dolvstachva (Young-palm orchid)
Veratrum woodii (false hellebore)
Viola hastata (halberd-leaved yellow violet)
Warea amplexifolia (clasping warea)
Warea carter (Carter warea)
Zanthoxvlum flavum (yellowheart)

(12) Threatened Plants. The regional resource would be the
occurrence of state listed threatened plants onsite. Protection
would be required for any loss of an onsite area equal to (1) 20%
of the population, (2) 20% of the occupied habitat, or (3) 20% of
the area necessary for the population to persist at the site.
Protection would consist of preservation onsite or compensation
offsite of acreage equivalent to 80% of the onsite defined
habitat areas. Onsite preservation would be allowed only when
there is sufficient habitat and management capabilities to
maintain a sustainable population. Offsite compensation would
include criteria for acquisition of habitat specifically suited
for and used by the species that is capable of being properly
managed.

Species covered:

Actaea Dachypoda baneberryy)
Anemonella thalictroides (Rue-anemone)
Aristolochia tomentosa (Dutchman's pipe)
Asclepias viridula (green mildweed)
Aster spinulosus pinewoodss aster)
BaDtisia hirsuta (hairy wild-indigo)
BaDtisia megacarpa (Apalachicola wild-indigo)
Baotisia simplicifolia (scare-weed)
Brickellia cordifolia (Flyr's nemesis)
Bumelia lvcioides buckthornn)
Calamintha ashei (Ashe Calamintha)
Callirhoe Dapaver (poppy mallow)
Cienfueaosia heterophvlla (yellow hibiscus)
Clitoria fraarans (pigeon-wing)
Conradina alabra (Apalachicola rosemary)
Cornus alternifolia (pagoda dogwood)
Crvptotaenia canadensis (honewort)
Eraarostis tracvi (Sanibel lovegrass)
Erioaonum floridanum (scrub buckwheat)
Ernodea littoralis (beach-creeper)
Erythronium umbilicatum (dimpled dogtooth-violet)
Euaenia confuse (redberry eugenia)
Eugenia simpsonii (Simpson eugenia)
Garberia heteroohvlla (garberia)
Hexastvlis arifolia heartleaff)
Hvdranaea arborescens (wild hydrangea)
Hvyelate trifoliata (inkwood)
Ilex kruaiana (Krug holly)
14

/S.//








Illicium floridanum (Florida anise)
Jacauinia kevensis joewoodd)
Kalmia latifolia (mountian laurel)
Lubinus westianus (Gulfcoast lupine)
Maanolia acuminata (cucumber-tree)
Malus auoustifolia (crabapple)
Marshallia obovata (Barbara's-buttons)
Medeola virainiana (Indian cucumber-root)
Polvaonella macrophvlla (large-leaved jointweed)
Prunus aeniculata (scrub plum)
Ruellia noctiflora (night-flowering ruellia)
Scaevola plumieri inkberryy)
Schisandra alabra (schisandra)
SDhenosticma coelestinum (Bartram's ixia)
Staphvlea trifolia (bladder-nut)
Swietenia mahaaoni (mahogany)
Tetrazyaia bicolor (tetrazygia)
Verbesina chapmanii (Chapman crownbeard)

(13) Rare Plant Communities of State Concern. [INCLUDE
BACKGROUND STATEMENT??] The regional resource would be the
occurence of Category I, II, III, or IV plant communities
onsite.

CATEGORY I: COASTAL ROCK BARREN; PINE ROCKLAND; UPLAND GLADES
AND HIGH QUALITY SHELL MOUNDS.
Protection would be required for any impact to these Category I
plant communities. Protection would consist of 100% onsite
preservation.

CATEGORY II: BEACH DUNE; COASTAL GRASSLAND; COASTAL BERM;
COASTAL STRAND; ROCKLAND HAMMOCK; LAKE WALES RIDGE SCRUB; SLOPE
FOREST; SEEPAGE SLOPES; AND UPLAND LONGLEAF PINE FORESTS ON CLAY.
Protection would be required for any impact to these Category II
plant communities. Protection would consist of 80% preservation
onsite of high quality examples of these plant communities.
Otherwise, protection would consist of preservation onsite or
compensation offsite of acreage equivalent to 80% of non-high
quality onsite defined plant community areas. Onsite
preservation would be allowed only when there is sufficient plant
community and management capabilities to maintain the plant
community. Offsite compensation would include criteria for
acquisition of an equivalent quality plant community site that is
capable of being properly managed. v

CATEGORY III. MARITIME HAMMOCK COASTAL SCRUB; SANDHILL; XERIC
HAMMOCK; AND UPLAND HARDWOOD FOREST-CA.-
Protection would be required for any impact to these Category III
plant communities. Protection would consist of preservation
onsite or compensation offsite of acreage equivalent to 15% of
onsite defined plant community areas. Onsite preservation would
be allowed only when there is sufficient plant community acreage
and management capabilities to maintain the plant community.
15








Oftsite compensation would include criteria for acquisition of an
equivalent quality plant community site that is capable of being
properly managed.

CATEGORY IV. SCRUBBY FLATWOODS; AND MIXED FORESTS (HIGH QUALITY
AND MODERATE QUALITY EXAMPLES ONLY).
Protection would be required for any impact to these Category IV
plant communities. Protection would consist of preservation
onsite or compensation offsite of acreage equivalent to 10% of
onsite defined plant community areas. Onsite preservation would
be allowed only when there is sufficient plant community acreage
and management capabilities to maintain the plant community.
Offsite compensation would include criteria for acquisition of an
equivalent quality plant community site that is capable of being
properly managed.
OFFSITE COMPENSATION.

Offsite compensation is one of the recommended, allowable
methods to compensate for the impacts of DRI-sized development on
upland habitats under most circumstances. Recently, in the
Withlacoochee and Northeast Regional Planning Council regions,
DRIs have made contributions for offsite wildlife habitat to
begin the establishment of offsite, upland habitat compensation
land-banks under the guidance of the Florida Game and Freshwater
Fish Commission (FGFWFC). Experience from this effort has
indicated the need to establish general criteria for offsite
compensation in any promulgated rule addressing upland habitat
protection. The following offsite compensation policies are
recommended for establishment in the proposed DCA rule:

Habitat Tyve-for-TvDe Offsite Compensation. Offsite
compensation sites for specific species shall be biologically
appropriate and suitable for the wildlife and plant species
requiring compensation, but are not necessarily required to
contain the same plant community being impacted onsite by
development. However, the intent of offsite compensation is
type-for-type habitat compensation for the same species quality
habitat. Variances will be allowed for species that successfully
utilize other habitat types, but with a requirement to compensate
on a pro rata acreage equivalency basis for the individual
specie's carrying capacity in the differing habitat type.
Offsite compensation sites for unique plant communities shall
be habitat similar as much as possible to the plant community
being impacted onsite by development; variations to this
requirement will be allowed on a case-by-case basis, and shall
consider the recommendations of both the regional planning
council involved and the Florida Game and Fresh Water Fish
Commission.







Offsite Compensation Site Options. Acceptable offsite
compensation sites should be (1) Established offsite compensation
land-banks; (2) Additions of land to already established public
managed areas, such as state and federal parks; and (3) Other
lands identified by a developer, or recommended by a federal,
state or regional agency, when such lands meet all appropriate
protection, habitat suitability, management and appropriate size
criteria. In order to more successfully accommodate the land-
banking approach to offsite compensation each regional planning
council should be required to expeditiously identify potential
land-bank sites for specific habitat types within the region.
In all cases, proposed offsite compensation sites shall be
for the purpose of the in perpetuity preservation of the habitat
and acreage proposed for protection with sufficient legally
binding mechanisms to guarantee such in perpetuity
preservation. Appropriate offsite compensation site selection
should not be restricted to the same county, but should be within
the same region, when feasible. In determining whether or not to
appeal the selection of a particular offsite compensation site as
inappropriate, the Department should consider overall habitat
suitability, protectability of the site, manageability of the
site, size of the site, and recommendations concerning the site
from the regional planning council, local government of
jurisdiction, the Florida Game and Freshwater Fish Commission,
and, if necessary, other regional, state and federal agencies.
Offsite Compensation Costs. Monetary assessment costs to a
developer for offsite compensation shall be solely limited to
land acquisition related costs. Administrative and management
costs involved with the offsite compensation site shall not be
the developer's responsibility, unless fee simple interest in
such offsite compensation lands remains in the control or
ownership of the developer.
In the absence of an appropriate, existing land-bank, a
developer may elect to contribute funds towards the establishment
of a new land-bank, with the concurrence of the regional planning
council, local government, and the Department. The developer's
contribution shall be determined through a joint regional
planning council and developer appraisal of acquisition costs for
appropriate habitat acreage available to establish such a new
land-bank, on a compensation acre for acre basis, as described
elsewhere in the DCA rule. As a minimum, the appraisal costs of
at least 3 potential, appropriate offsite compensation sites must
be included to formulate the developer's average appraisal or
contribution cost. Additionally, the developer must demonstrate,
with reasonable assurance, that appropriate, offsite compensation
acreage to establish the new-land bank will be available for
acquisition by any contributed funds.


17

/s.//








In the presence of an appropriate, existing land-bank, any
developer's contribution shall be based upon the actual
acquisition cost, on an acre for acre basis, of the land included
in or added to the existing land-bank.

Offsite Compensation Contribution Timina. The development
order shall establish the amount of offsite compensation, the
timing of any monetary contributions, and the schedule of
development, with assurances that the onsite habitat being
compensated for will not be lost prior to adequate compensation.

Land-bankina. An interim holding trust fund, such as the
Growth Management Trust Fund, should be identified and utilized
by DCA to hold offsite compensation contributions from DRI
developments until such funds can be applied to the purchase of
appropriate compensation land-bank acreage. Land-banks should be
held in fee simple title or lessor interest by state or federal
agencies, for the in perpetuity preservation of the habitats
purchased. Depending upon the protection needs of the species
and communities being protected, limited passive use of such
land-bank preserves should be allowed. Land-banks should be
managed by the Florida Game and Fresh Water Fish Commission, as
appropriate, or by other appropriate lead agencies. Land-banks
should be of sufficiently large size (typically >1000 acres) to
establish, maintain, and preserve biologically intact ecological
systems. All land-bank sites must be protected for habitat
preservation through legally binding mechanisms sufficient to
guarantee in perpetuity preservation.

RECOMMENDATION 2 DRI SURVEY METHODOLOGY

Many of the Wildlife Advisory Group's recommendations for a
proposed DRI Upland Habitat Policy Rule will indirectly affect
the natural resource surveys that are typically carried out for
Question 18 of the DRI Application for Development Approval
(ADA), relating to wildlife and vegetative communities that are
present onsite. Additionally, the Wildife Advisory Group has
been requested by the Department of Community Affairs (DCA) to
coordinate the efforts and recommendations of the group with the
ADA Revision Advisory Committee that has been established to
revise the ADA.

Therefore, the Wildlife Advisory Group is making the
following recommendations to the ADA Revision Advisory Committee
for their consideration in revising Question 18 of the ADA. The
basic premise of these recommendations is that monitoring
requirements fall into basically three species and four plant
community categories. The current ADA questions should be
revised to address these categories. The species categories are
based upon: (A) those species whose presence onsite can be, and
should be, adequately determined onsite by specific surveys; (B)
those species whose presence onsite can be determined onsite by
surveys, but for whom it can be difficult or expensive to survey







for onsite; and (C) those species whose presence onsite cannot be
adequately determined onsite by surveys. The plant community
categories are based upon identification of the specific rare
plant community.

Survey Categories

CATEGORY "A" WILDLIFE AND PLANTS The presence or absence of
species in this grouping is determined by the use of appropriate
sampling methodologies. Where suitable habitat is present,
species occurrence is determined by the use of appropriate
sampling methodoligies. Sampling for these species is cost
effective and results do provide reliable estimates of species
presence or absence.

Species Covered:

American Crocodile
Gray Bat-Cave Site
Key Largo Woodrat
Key Largo Cotton Mouse
Key Deer
Silver Rice Rat
Chadwick Beach Cotton Mouse
Choctawhatchee Beach Mouse
Stock Island Tree Snail
Florida Grasshopper Sparrow
Scrub Jay
Florida Sandhill Crane
Bald Eagle Nest Site
Burrowing Owl Nest Site
Sherman's Fox Squirrel
Eastern Chipmunk
Osprey Nest
Pine Barrens Treefrog
Bog Frog
Sanibel Island Rice Rat
Red-cockaded Woodpecker
Gopher Tortoise
Florida Mouse
All Colonial Bird Nesting Sites
All Migratory Bird Concentration Areas
All Listed Plant Species

CATEGORY "B" WILDLIFE Species in this grouping are presumed
present when a site contains suitable habitat for a species and
falls within the known geographic range of the species. Sampling
efforts require special techniques and manpower commitments and
are generally not cost effective. However, the presumption of
species occurrence may be refuted by the results of a FGFWFC
approved sampling program.









Species Covered:


Schaus' Swallowtail Butterfly
Big Pine Key Ringneck Snake
Florida Brown Snake
Miami Black-headed Snake
Florida Ribbon Snake
Blue Tailed Mole Skink
Sand Skink
Snowy Plover Nest Site
Piping Plover Nest Site
Least Tern Nest Site
Roseate Tern Nest Site
Everglades Mink
Mangrove Fox Squirrel
Caracara Nest Site
Southeastern Kestrel
Red Rat Snake
Keys Mole Skink
Georgia Blind Salamander Cave Site
Wakulla Seaside Sparrow Nest
Scott's Seaside Sparrow Nest
Marian's Seaside Sparrow Nest
Worthington's Marsh Wren Nest
Homosassa Shrew
Sherman's Shrew
Gopher Frog

CATEGORY "C" WILDLIFE Species in this grouping are presumed
present when a site contains suitable habitat for a species and
falls within the known geographic range of the species. Sampling
efforts are too ineffective to provide reliable indications of
species absence or presence within a site.

Species Covered:

Goff's Pocket Gopher
Pine Snake
Florida Panther
Florida Black Bear
Indigo Snake
Short-tailed Snake

CATEGORY "I" PLANT COMMUNITIES Coastal Rock Barren, Pine
Rockland, Upland Glades, and High Quality Shell Mounds.

CATEGORY "II" PLANT COMMUNITIES Beach Dune, Coastal Grassland,
Coastal Berm, Coastal Strand, Rockland Hammock, Lake Wales Ridge
Scrub, Slope Forest, Seepage Slopes, and Upland Longleaf Pine
Forests on Clay.

CATEGORY "III" PLANT COMMUNITIES Maritime Hammock, Coastal
Scrub, Sandhill, Xeric Hammock, and Upland Hardwood Forest on
Clay. 20









CATEGORY "IV" PLANT COMMUNITY Scrubby Flatwoods, and Mixed
Forests (High Quality and Moderate Quality Examples Only).

Definition

"Significant wildlife and plant resources" means species
designated as endangered, threatened, or species of special
concern; colonial bird nesting sites, migratory bird
concentration areas, wildlife corridors, publicly owned wildlife
or plant habitat, rare plant communities of state concern, and
major concentrations of non-listed wildlife, plants or their
habitat.

ADA Questions

18-A. Identify the dominant species and other unusual or unique
features of the vegetation communities on Map F. Indicate
whether any Category I, II, III, or IV plant communities occur
on-site. Show the amount of all plant communities that will be
preserved in a natural state following development.

18-B. Discuss what survey methods were used to determine the
absence or presence of Category A or B wildlife and plants.
State actual sampling times and dates, and discuss any factors
that may have influenced the results of the sampling effort.
Show on Map W (minimum scale 1" 400') the location of all
transects, trap grids, or other sampling stations used to
determine the on-site status of significant wildlife and plant
resources.

18-C. List all significant wildlife and plant resources that
were observed on the site and show location on Map W. List all
significant resources presumed to occupy the site and show the
location of suitable habitat and observed species on Map W.
Besides listed species, these lists need to address colonial bird
nesting sites, migating bird concentration areas, proximity to
publicly owned wildlife habitat, and important wildlife
corridors. For species that are either observed or presumed to
utilize the site, discuss the home range, population size onsite,
extent of adjacent, contiguous habitat offsite, and any special
habitat requirements of the species.

18-D. Indicate what impact development of the site will pose to
affected significant wildlife and plant resources.

18-E. Discuss what measures will be taken to mitigate impacts to
significant wildlife and plant resources. If protection is to
occur on-site, describe what legal instrument will be used to
protect the site, and what management actions will be taken to
maintain habitat value. If protection is to occur off-site,
state the amount and type of lands to be compensated as well as
whether compensation will be through a regional compensation








land-bank, by acquisition of lands that adjoin existing public
holdings, or by other means.

RECOMMENDATION 3 NON-DRI DEVELOPMENT

The Department of Community Affairs should consider the
following proposals for study by a state-wide task force dealing
with Upland Habitat Loss in Florida, in conjunction with other
governmental agencies, to address the severe impacts that are
occurring in Florida from the ongoing conversion of unique native
upland habitats. The Department should give consideration to
these recommendations in recognition that it is neither practical
nor equitable to preserve the upland habitat of state listed
plants and animals solely through the DRI process.
The planning framework basis for the following recommen-
dations is implementation of the goals and policies of the State
Comprehensive Plan (SCP) and the State Land Development Plan
(SLDP), including:

SCP GOAL 10: Florida shall protect and acquire unique
natural habitats and ecological systems such as wetlands,
tropical hardwood hammocks, palm hammocks, and virgin
longleaf pine forests, and restore degraded natural systems
to a functional condition.

SCP POLICY: Establish an integrated regulatory program to
assure the survival of endangered and threatened species
within the state.

SLDP POLICY: Ensure that all land use decisions involving
lands containing or impacting significant listed species
populations or habitats include an adequate combination of
mitigative measures including preservation, management,
public education, and the provision of adequate protective
buffers.

Upland Permittina Proaram. In the absence of other new
funding or regulatory programs, the authority of the Game and
Fresh Water Fish Commission to protect the habitat of endangered
and threatened species should be clarified. A specific
permitting process should be applied to any proposed development
of native threatened and endangered species habitat in the
state. Existing habitat of upland endangered and threatened
species could not be converted from its natural state without a
permit from the Commission. The permitting program should be
funded by permit fees. The fees should be used to provide
adequate staff for permitting and enforcement. Within the
permitting process, there should be a potential to establish and
use Best Manangement Practices (BMPs), when the BMPs are designed
to protect habitat values.








The authority of the Commission should also be clarified to
include the role of lead agency in the development of habitat
conservation plans designed to protect critical habitat, and to
balance conservation and development interests. In this role, it
will necessary for the Commission to have the specific ability to
address threatened and endangered plant resource issues that
arise in the permitting process. The habitat conservation plans
should be developed in conjunction with the state land planning
agency, regional planning councils, local governments, affected
developers, and other interested and affected parties.
Additionally, as part of the permitting and habitat conservation
plan programs, the Commission is encouraged to develop upland
habitat land-banks.
Native Uplands Acauisition Program. (alternative name: Save
Our Native Uplands Program). As a substitute for the above
described expanded uplands permitting program, the Wildlife
Advisory Group strongly recommends the establishment of an
acquisition program, in addition to and separate from the
Conservation and Recreational Lands (CARL) Program, specifically
focused on the purchase and preservation of native uplands
important for state listed threatened and endangered species.
Lands purchased through this program would be for the single
purpose of preservation and conservation of state listed plant
and animal species, and high quality upland communities.

Funding to purchase, in fee simple or lesser interest,
critical habitats for listed species and high quality uplands
must be made available to purchase such uplands before their
pending conversion to agriculture, silvaculture, or
development. As the recommendation of the Wildlife Advisory
Group, potential funding sources, such as the documentary stamp
tax should be utilized to fund $50 to $100 million annually for
the purchase of such lands.

Local Government Acauisition Proarams. Local governments
should be encouraged to set up separate acquisition programs, at
the local level, for the purpose of preservation of native upland
habitats within their jurisdiction.




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