1000
Friends of Florida, Environmental & Land Use Law Center, Florida Wildlife
Federation, Loxahatchee River Coalition, Sierra Club – Loxahatchee Group
April 3, 2006
Colonel Robert Carpenter
USACOE, Jacksonville District
701 San Marco Boulevard
Jacksonville, FL 32307-0019
RE: Proposed Development in the Vicinity of Mecca Farms
Dear Colonel Carpenter:
As you know, the initial proposal to site the Scripps Research Institute
and accompanying research park at Mecca Farms significantly intensified
market activity and development proposals for westward expansion of
development in north western Palm Beach County. The proposal fueled
the anticipation of nearby and adjacent agricultural landowners to develop
their property for biotechnology, residential, or other uses at densities
and intensities far greater than those that had previously been considered
or analyzed. We are writing to bring to your attention several development
proposals in this region and to recommend the adoption of a programmatic
approach to coordinate the review and evaluate the impacts of these
proposals.
Development proposals
Currently, several major development proposals are being planned for
what is currently agricultural land within the immediate vicinity of
Mecca Farms. Along with Mecca Farms, development proposals for the 4700
acre Vavrus Ranch and the 4000 acre Callery Judge Groves properties
have been submitted to local planning officials and are undergoing Development
of Regional Impact (“DRI”) review under Florida law. Additionally, developer
GL Homes recently acquired the approximately 6000 acre Indian Trail
Grove, for which it is expected to submit a DRI proposal in the near
future. Altogether, nearly 17,000 acres of agricultural land within
a five mile radius is being proposed for urban development.
Developments of the size and scale of those proposed on each of these
sites are required to undergo the State DRI review process because the
character, magnitude, or location of the development would have a substantial
effect upon the health, safety, or welfare of local citizens of more
than one county.
The development proposals for these sites would significantly increase
the allowable density and intensity of development in what is currently
a rural and agricultural area. For example, both the Vavrus Ranch proposal
and the Callery Judge development seek authorization for 10,000 residential
units and several million square feet of commercial development where
under current rules only around 400 homes could be built. Both developments
necessitate the extension and expansion of roadways, such as PGA Boulevard
and Seminole Pratt Whitney Road, through environmentally sensitive conservation
lands.
Natural Resources
The natural lands included within and around the sites of the proposed
developments are strategically located within the watershed of the Wild
and Scenic Loxahatchee River–one of the most significant natural resources
in Southeast Florida, and contain some of the highest quality wetlands
and habitat in the region and provide habitat for numerous listed species,
including woodstork, red-cockaded woodpecker, bald eagle, snail kite,
Florida sandhill crane, and eastern indigo snake. The adjacency to the
Vavrus tract was one of our key concerns in opposing Mecca Farms as
the proposed site for the Scripps Biomedical Research Institute because
of the many detrimental impacts development would cause to wetland systems
in this area.
Additionally, these projects fall within the study area of Part 1 of
the North Palm Beach County CERP Project which is evaluating the use
of flow-ways across the subject properties to move water north and east
from the Palm Beach Aggregates rockpits to Grassy Waters, Loxahatchee
Slough and the Loxahatchee River. We expect that in addition to any
flow-ways, additional land for stormwater treatment may also be necessary
to treat the increased flows prior to discharge to these high quality
natural areas. We are very concerned about the impacts that the proposed
developments would have on the successful development and implementation
of this critical CERP component.
When considered together, the impacts of providing infrastructure to
and converting these 17,000 acres of agricultural land into urban uses
will certainly be significant. A real possibility exists that massive
development of the size and in the locations proposed in this watershed,
if undertaken without comprehensive analysis, could seriously complicate
or frustrate State and federal objectives to restore the Loxahatchee
River.
As indicated by the recent decision of Judge Middlebrooks, the error
of using an inadequate Environmental Assessment instead of a comprehensive
Environmental Impact Statement cannot be repeated, especially when the
pending development proposals are reasonably foreseeable and within
the immediate vicinity and encompass an area many times the size of
Mecca Farms. Because of their size, scale and location, the impacts
of these projects will be felt far beyond their individual development
boundaries. A regional scale programmatic analysis, however, could provide
the opportunity to comprehensively evaluate the impact of these multiple
large developments on wetlands and adjacent natural areas and CERP,
and offer regional water, wetland and habitat management solutions while
maintaining the integrity of this area’s precious natural heritage and
resources.
These projects require the full scrutiny offered by a comprehensive
EIS process, and our organizations are fully prepared to engage in whatever
process is necessary to see that this procedure is followed, with the
appropriate expertise and authority the Corps can bring to bear. We
believe a well conceived and complete EIS would offer the appropriate
forum to:
(1) comprehensively evaluate the entirety of direct and indirect impacts
of all the development proposals, as well as the cumulative effects
that result when the past, present and reasonably foreseeable future
development in this region is considered in its entirety;
(2) study and evaluate environmental impacts of the proposed developments
on nearby natural areas such as the Loxahatchee Slough, Hungryland Slough,
Corbett Wildlife area, Sweetbay Natural Area, Jonathan Dickinson State
Park and the Loxahatchee River;
(3) evaluate potential regional water management solutions in the context
of CERP and determine whether the developments as proposed will negatively
or positively contribute to restoration of the northern Everglades ecosystem,
as well as provide an opportunity for understanding what impacts, including
costs, to the restoration the development will have;
(4) identify and assess impacts of necessary infrastructure, particularly
roads, on hydrology, ecology, listed species, and fragmentation of habitat,
loss of use by the public, reduced enjoyment of publicly held natural
lands, wetland and upland impacts, wildlife corridors, road kill projections,
road noise, and stormwater runoff, nonpoint sources of pollution, and
the affects on wildlife and bird populations;
(5) evaluate the impacts of light, noise and domestic animals on wild
animal and bird populations using the best available data and studies;
(6) evaluate the impacts of mosquito spraying on wildlife and habitat,
especially alternatives to aerial spraying and no-spray alternative;
(7) evaluate impacts to listed species, considering nesting and denning
cycles, foraging habits and locations over all seasons so as not to
miss important details regarding the survival needs of listed wildlife
and plants;
(8) demonstrate that the region’s post-development hydrology is consistent
with historic levels for the natural areas, the Loxahatchee River and
the C-18 basin;
(9) provide extensive public participation to ensure that the public
interest in publicly held natural areas, the economy, and quality of
life is protected;
(10) evaluate social and quality of life issues affecting the human
population of the area, including economic impacts from the loss of
agricultural lands in the area, as well as affordable housing impacts
to the surrounding communities;
(11) assess the potential of hurricane damage, evacuation, and debris
storage on area resources;
(12) assess alternatives to the proposed projects, including no build
and reduced scale alternatives, as well as provide an evaluation of
the impacts of development at currently allowable densities.
A permit-by-permit approach is inadequate for these purposes, particularly
if all of the reasonably foreseeable cumulative and indirect impacts
throughout the entire region are not fully analyzed as part of the process.
Whatever the relevant administrative or legal process, the undersigned
groups are determined to see that all development proposals are fully
evaluated based on their full range of direct, indirect and cumulative
impacts and that only appropriate levels of development are allowed
in this sensitive part of Palm Beach County. We know you share our common
goal of making certain that any and all development here complements,
rather than conflicts with, the tremendously critical task to restore
the Everglades. We stand ready to support the Corps in the kind of comprehensive
analysis these projects require and look forward to your earliest possible
consideration of this letter.
Sincerely,
Charles Pattison
1000 Friends of Florida
Richard Grosso
Environmental & Land Use Law Center
Manley Fuller
Florida Wildlife Federation
Susan Kennedy
Loxahatchee River Coalition
Kay Gates
Sierra Club Loxahatchee Group
