COMMENTS ON FWC DRAFT BIOLOGICAL GOALS FOR GOPHER TORTOISESGENERAL COMMENT
It's time to think out of the box once again. We need to think in the real world since the goal will only be achieved if we realize that development will take, at current rates of development, just about everything natural that is not protected in some fashion in 20 years. I believe every protected species should have an oversight committee that works with FWC and partners to be sure that goals are achieved every year, every budget. If we do not do this now, we are just blowing smoke. We must work with every stakeholder, including developers, county and city governments, even Home Owner’s Associations to make this work. Therefore we need to have objectives that can easily be measured in numbers of tortoises, acres of land, and dollars in the budget. Paragraph 2 is theory on top of theory and a mess of guesses and does not demonstrate in any way that we will reach our GOAL or that the objectives have any conservation value.
- Paragraph One.
Point 1 (2005 range) I fail to see the reason to limit the attempts to the current range. I would say the historic range within the state of Florida. FOLKS, THIS IS THE GOAL
Point 2. MOST IMPORTANT
ADD: The primary goal is to create a program which will be designed to sustain minimum regional and county populations of gopher tortoises and habitat of not less than 10% of historic populations in perpetuity.
The objectives and the goals set forth should be done in a way that can easily be measured and reviewed in a way that will allow changes in all agencies involved in achieving these goals to insure their success.
(Reason) Unlike past attempts of creating biological goals and objectives or recovery plans, we are at a point where habitat, resources, and numbers remaining have made it clear that we need to be more specific in what we are trying to do, where we will do it and how. This helps to insure that the goals and objectives can be MEASURED by citizens from year to year.
THESE ARE OBJECTIVES TO ACHIEVE THE GOAL
You have stated THE GOAL. This goal is obtainable and measurable.
- Paragraph 2.
The objectives in paragraph 2 are not obtainable or measurable.
Because:
- At the current rate of natural and agricultural land in 30 years will leave 0 habitat for tortoises. In fact, under the Supreme Court rule on taking natural land for development, we could loose some natural areas we now think are protected.
- We do not know the ages or how old tortoises are nor do we really know what the replacement rate is. A very thin model is all we are basing this concept on.
- PROPOSAL
- We can now determine clearly what we need to have the land to sustain 10%. We know how many acres we have under protection and how many we need in each region and in each county to create the Assurance Colony Program. WE CAN DETERMINE MORE CLEARLY AT WHAT POINT IN EACH COUNTY AND REGION WHERE THAT POINT IS. In some counties we have already crossed that line so we will need to work up in those counties.
- Based on Habitat Type and real data, we can estimate populations that occur in what we have.
- We then can determine the habitat types we need (with minimal densities per habitat) to meet the goal.
- We then know how much $$$ and where the target areas are to reach the goals.
- We know how much it will take to sustain those habitats in both money and staff. This allows another measurable objective which is the foundation for the success in meeting the goal. HOW MUCH DO WE NEED AND HAVE TO SPEND? Even the commissioners can look at a spread sheet and see each budget year if enough was requested and if the FWC was successful in having the $$$$ and staff to achieve the tortoise conservation goal.
- This method opens the doors for meaningful partnerships both with local governments but also in developing a plan to work with development interests to participate in achieving the goals not only of preserving habitat to insure that it can be managed and protected in perpetuity.
- This also gives us an idea of how we handle the "humanitarian relocations" in the lower end of the Assurance Colony Program as well as how private landowners play a role in the transitional protected areas under the ACP.
- Acquisition Goals
- REALITY CHECK
Again the objectives spelled out here should be based on the Goal. We need X ACRES IN DADE AND PALM BEACH COUNTIES TO MEET THE GOAL. Then how many acres are there? This is the direction we need to go.
The prices of land are going to make it nearly impossible for state and local purchases.
Florida Forever has 2 more years of life. Purchases do not necessarily include tortoise habitat. The cost of buying easements on private land are now more expensive in most areas of the state than out right purchases were just 2 years ago.
MOST UPLAND HABITATS UNDER "PROTECTION" HAVE NO MONITORING PROGRAM RELATED TO BIODIVERSITY MANAGEMENT, MONITORING IS THE FIRST THING TO GET CUT WHEN BUDGETS GO AND SECOND, BURING IS DELAYED OR STOPPED AND THE ROTATIONS GET LONGER, ETC.
WE HAVE NO PROVEN TECHNOLOGY TO SUSTAIN NATURAL TORTOISE HABITAT WITHOUT FIRE. Most natural areas are going to be surrounded by communities, airports, hospitals and major highways. How much will it cost?
- RELOCATION & MITIGATION
A well planned and carried out program of relocation from development sites will help direct losses. However, FWC and partners will have to achieve methods in which mitigation becomes a real tool in local conservation of tortoises (of course we mean commensals too). This includes developing local plans for monies to fund procurement through not just fees but through land swaps, direct management of swapped lands, coordination with county officials, other federal and state lands within the area. Also through a well planned Assurance Colony Program, it would be difficult to have a take except by accident so a real Incidental Take permitting system could be imposed.
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