April 3, 2007

                                                                                                                                      

Madame Chair and Commissioners:

           

Re: Recommendations for the Substantial Deviation to the Previously Approved SpringHills Development of Regional Impact (DRI)

 

            EPAC has discussed the environmental aspects of the proposed substantial deviation to the SpringHills DRI and received a presentation on this issue by a team of tenured scientists supporting the Coalition for Responsible Growth (CRG) at our meeting on March 1, 2007.  Representatives of the applicant, PREIT, were invited to attend and make a presentation. In an e-mail dated 2/26/2007, Patrice Boyes offered to respond to any specific questions and stated: “This is an already approved Development of Regional Impact, and no additional regional environmental impacts are anticipated by the proposed amendment.”  However, EPAC feels there are several important environmental concerns that should be considered before approval of the comprehensive plan amendment to allow a substantial deviation to the previously approved SpringHills DRI. These concerns are summarized in the following paragraphs.  This letter was approved by a unanimous vote of EPAC members present at our April 3^rd meeting

 

            EPAC is especially concerned with the protection of wetlands on this site, particularly those that remain in a high quality state in the northern part of the project site.

 

            Some studies done for sufficiency review at the time of the original DRI are either out of date or not sufficiently comprehensive.  The County’s Comprehensive Plan requires protection of significant habitats, a fundamental aspect of which is the vegetation, since many animal species depend on habitat provided by vegetation. There is a lack of documentation that the plant surveys were done appropriately and considered specific species in upland forests; there also seems to be a lack of a mitigation plan. 

 

              EPAC is concerned about adverse impact to the San Felasco Preserve, a 7,000+ acre state wildlife preserve that is of great benefit to our community.  EPAC is also concerned that invasive plants from new homes would spread into San Felasco and, additionally, that the proximity of this development will further restrict prescribed burns. 

 

            EPAC is concerned that surveys of protected species may have been conducted at an inappropriate time of year, that improper methods may have been used, and that surveys for some protected species may not have been conducted.  Since 10 years have passed, it would seem appropriate to update these surveys, especially since the proposed more intense development would have greater impacts.  Careful attention must be given to the methodology employed to ensure that these surveys are comprehensive.

 

            SpringHills will impact the County’s water resources in three ways: 1) Consumption of water for domestic uses resulting in effluent that is disposed of in a deep aquifer; 2) Increased stormwater run-off that also increases the flooding potential; and 3) Increased impervious surfaces that reduce recharge of the drinking water aquifer that is the source of our water supply. 

 

              EPAC notes that SpringHills is upstream of an ancient streambed that was the location of severe flooding in recent years.  This project could increase flooding dangers to these areas if a comprehensive stormwater master plan is not developed; designs based on each portion of the project as it is constructed will fail to adequately account for the impact of portions not yet constructed. 

 

            Because SpringHills is located on the cross county fracture zone, there is a potential for contamination of the drinking water aquifer by stormwater.  EPAC supports the recommendation of the St. Johns River Water management District (SJRWMD) for a water quality monitoring and management plan for both ground and surface waters.  Water is an increasingly scarce resource in Florida and steps must be taken to reduce the impact of this development on regional water supplies.  Among these would be re-use of both reclaimed waste water and stormwater for irrigation, as well as, a water conservation plan as recommended by the SJRWMD.

 

            EPAC firmly believes any new development on this property must comply with all provisions of the current comprehensive plan including those regarding parks, wetlands and conservation/mitigation set aside areas.  PREIT seeks to have their substantial deviation approved under a prior comprehensive plan. This would set a disastrous precedent.  Therefore, EPAC recommend that the BoCC require that PREIT strictly adhere to the requirements of the current 2002 Comprehensive Plan.