Exhibit_E13_-_Environmental_Supplement_Report_-_May_2024.pdf

TURRELL, HALL & ASSOCIATES, INC.

Marine & Environmental Consulting

3584 Exchange Avenue ● Naples, Florida 34104-3732 ● 239-643-0166 ● Fax (239) 643-6632 ● tuna@thanaples.com

June 7, 2024

South Florida Water Management District 2301 McGregor Blvd.

Fort Myers, FL 33901

Re: Application for ERP- Veteran’s Memorial Boulevard Extension Phase II Environmental Review Sections 9, 10, 11, 15, & 16, Township 48 South, Range 25 East, Collier County, Florida

The applicant is proposing to complete the extension of Veteran’s Memorial Boulevard from Livingston Road to U.S. 41 in north Collier County beginning at the terminus of Phase I (Permit No.

11-102981-P). As proposed this 58.07-acre linear project will extend 1.2 miles due west through wetland, upland, xeric and developed lands. Portions of the right-of-way will impact existing conservation easements for Turtle Creek Apartments (Permit No. 11-01367-P) and the Triangle Parcel (Permit No. 11-02353-P). There are 13.62 acres of wetlands within the right-of-way and proposed pond sites and 1.72 acres of Other Surface Waters which will be directly or temporarily impacted by the proposed work. In order to compensate for impacts the applicant is proposing to purchase 4.97 mitigation credits from Panther Island Mitigation Bank which is within the same basin and purchase 3.61 acres of land within the same basin to offset impacts to conservation easement lands.

The attached application includes the following attachments for review:

Appendices Exhibits 1 Vegetation Descriptions 1 Location Map

2 Turtle Creek & Triangle Parcel Conservation Easements 2 Overall Aerial 3 Master Site File Data 3 FLUCFCS Segment 1

4 UMAM Sheets 4 FLUCFCS Segment 2 5 Listed Species Survey 5 FLUCFCS Segment 3

6 Mitigation Plan 6 Proposed Project 7 Wetland Data Forms 7 Impacts Segment 1

8 Impacts Segment 2 9 Impacts Segment 3 10 Soils 11 Listed Species 12 Listed Species Segments 1 & 2 13 Listed Species Segment 3 14 Gopher Tortoise Burrow Tables 15 Listed Species Survey Transect

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Please let us know if you have any questions.

Respectfully, Tim Hall, Senior Ecologist Turrell, Hall & Associates, Inc.

tim@thanaples.com mailto:tim@thanaples.com

ENVIRONMENTAL SUPPLEMENT

VETERAN’S MEMORIAL BOULEVARD

PHASE II SEGMENT

May 2024

Prepared by:

3584 Exchange Avenue Naples, FL 34104

(239) 643-0166 tuna@thanaples.com mailto:tuna@thanaples.com

Veteran’s Memorial Boulevard Phase II Environmental Supplement- May 2024

TABLE OF CONTENTS

Chapter Page

1.0 INTRODUCTION 4

2.0 SITE DESCRIPTION 5

2.1 Segment 1 7

2.2 Segment 2 11

2.3 Segment 3 15

2.4 Soils 18

2.5 Listed Species 19

3.0 ENVIRONMENTAL CONSIDERATIONS 20

3.1 Wetlands & Other Surface Waters 20

3.2 Environmental Criteria 23

3.2.1 Elimination or Reduction in Impacts 23

3.2.2 Fish, Wildlife, Listed Species and their Habitats 24

3.2.3 Public Interest Test 25

3.2.4 Water Quality 27

3.2.4.1 Short Term Water Quality Considerations 27

3.2.4.2 Long Term Water Quality Considerations 27

3.2.5 Secondary Impacts 29

3.2.6 Cumulative Impacts 29

4.0 MITIGATION 30

4.1 Proposed Impacts by Segment 30

4.1.1 Segment 1 30

4.1.2 Segment 2 30

4.1.3 Segment 3 31

4.2 Proposed Compensation for Wetland and Conservation Easement Impacts 32

4.2.1 Segments 1 and 2 32

4.2.2 Segment 3 33

Figure 1: Segments 1 & 2 5 Figure 2: Segment 3 5

Table 1: FLUCFCS for Entire Project Site 6 Table 2: FLUCFCS for Segment 1 8 Table 3: FLUCFCS for Segment 2 12 Table 4: FLUCFCS for Segment 3 16 Table 5: Potential Listed Species Occurring on Project Site 19 Table 6: Railhead Scrub Preserve Listed Species 24 Table 7: Impacts for Segment 1 30 Table 8: Impacts for Segment 2 31 Table 9: Impacts for Segment 3 31 Table 10: Segments 1 and 2 Direct Impact Mitigation Summary (Credit Based) 32 Table 11: Segments 1 and 2 Secondary Impact Mitigation Summary (Credit Based) 33 Table 12: Direct Impacts (Conservation Easement Replacement)- Turtle Creek 33 Table 13: New Wetland Direct & Secondary Impacts- Turtle Creek 33

Table 14: Compensation for Original Mitigation Loss- Turtle Creek 34 Table 15: Direct Impact Conservation Easement Replacement- Triangle Parcel 34 Table 16: Compensation for Original Mitigation Loss- Triangle Parcel 34 Table 17: New Wetland Direct & Secondary Impacts- Triangle Parcel 35 Table 18: Total Mitigation for Project 35

Exhibit 1 Location Map Exhibit 2 Overall Aerial Exhibit 3 FLUCFCS Map Segment 1 Exhibit 4 FLUCFCS Map Segment 2 Exhibit 5 FLUCFCS Map Segment 3 Exhibit 6 Proposed Project Exhibit 7 Impacts Map Segment 1 Exhibit 8 Impacts Map Segment 2 Exhibit 9 Impacts Map Segment 3 Exhibit 10 Soils Map Exhibit 11 Listed Species Map Exhibit 12 Listed Species Map Segments 1 and 2 Exhibit 13 Listed Species Map Segment 3 Exhibit 14 & 15 Gopher Tortoise Burrow Tables 1 of 2 and 2 of 2 Exhibit 16 Listed Species Survey Transects

Appendix 1 Vegetation Descriptions Appendix 2 Conservation Easements- Turtle Creek and Triangle Parcel Appendix 3 Master Site File (DHR) Appendix 4 UMAM Forms Appendix 5 Listed Species Survey Appendix 6 Mitigation Plan Appendix 7 Wetland Data Sheets

1.0 INTRODUCTION

Veteran’s Memorial Boulevard (Phase I) was permitted to allow for an extension of the existing roadway west of Livingston Road, to the new Aubrey Rogers High School. Phase II is planned to continue the Phase I roadway from Livingston Road to U.S. 41 North (U.S.

41). In addition to impacts within the platted road right-of-way, there will also be habitat impacts to the north and/or south in a few locations for water management features and FDOT required sidewalks.

Veteran’s Memorial Boulevard Phase II is located within Sections 9, 10, 11, 15, and 16 Township 48 S, Range 25 E from the high school to U.S. 41, all within Collier County, Florida (See Location Map- Exhibit 1).

For simplicity Phase II of this project will hence be defined in this document as Segment 1 (high school to just east of the railroad crossing), Segment 2 (just east of the railroad crossing to Old 41 and a pond site south) and Segment 3 (Old 41 to U.S. 41).

Outlined are details of how the project complies with the development rules and guidelines as outlined in the Applicant’s Handbook Volume 1, specifically 10.0 Environmental Considerations.

2.0 SITE DESCRIPTION

This 58.07-acre project lies mostly within a dedicated road right-of-way (ROW) that has been slated for development for decades by Collier County. Each segment of this narrow project path is described in detail below. Figures 1 and 2 depict the proposed site boundary aerial.

Figure 1: Segments 1 and 2

Figure 2: Segment 3

A table of habitat types and their acreages according to the Florida Land Use Cover and Forms Classification System (FLUCFCS) for the project is found below as Table 1. Each road segment will be separated and classified, then briefly described. A detailed vegetative description is provided in Appendix 1.

Table 1: FLUCFCS Table for Entire Project

ID# FLUCFCS DESCRIPTION ACRES

1A Phase I Lands/Disturbed 1.75 1 814 Roads (Dirt) 0.04 2 411 E1 Pine Flatwood 0-25% Exotic 0.20 3 621 E4 Cypress >75% Exotic 0.39 4 625 E3 Hydric Pine Flatwood 50-75% Exotic 1.02 5 411 E2 Pine Flatwood 25-50% Exotic 0.18 6 621 E1 Cypress 0-25% Exotic 0.88 7 624 E2 Pine-Cypress-Cabbage Palm 25-50% Exotic 0.02 8 616 Inland Ponds & Sloughs 0.15 9 411/321 E2 Pine Flatwood/Palmetto 25-50% Exotic 0.55 10 624 E3 Pine-Cypress-Cabbage Palm 50-75% Exotic 1.54 11 621 E2 Cypress 25-50% Exotic 0.67 12 411 E4 Pine Flatwood >75% Exotic 0.14 13 625 E4 Hydric Pine Flatwood >75% Exotic 0.95 14 OSW Other Surface Waters 0.17 15 411 E3 Pine Flatwood 50-75% Exotic 1.58 16 421 D Disturbed Xeric Oak 3.25 17 OSW Other Surface Waters 0.22

17B OSW Other Surface Waters 0.02 18 411 E3 Pine Flatwood 50-75% Exotic 0.24 19 740 Disturbed Land 4.94 20 411 E3 Pine Flatwood 50-75% Exotic 0.39 21 OSW Other Surface Waters 0.10 22 742 E4H Detention Area Hydric >75% Exotic 2.71 23 740 Disturbed Land 0.47 38 411/321 E1 Pine Flatwood/Palmetto (0-25% Exotic) 5.27 39 641 E4 Disturbed Marsh 0.21 40 621 E2 Cypress 25-50% Exotic 0.58 41 624 Pine-Cypress-Cabbage Palm 0.12 42 641 Gallberry Marsh 0.01 43 641 Hypericum Marsh 0.03 44 740H Hydric Dirt Road 0.02 45 621 E3 Cypress 50-75% Exotic 0.79 46 618 Willow 0.09 47 621 E1 Cypress 0-25% Exotic 0.35 48 740 Dirt Road 0.03 49 832H Electrical Power Transmission Lines 0.66 50 812 Railroad Track 0.03

24R-TC 321/411 E1 Palmetto/Pine Flatwood 0-25% Exotic (ROW- TC CE) 0.82 24TP 321/411 Palmetto/Pine Flatwood (TP- CE) 0.03

25R-TC 625 E1 Hydric Pine Flatwood 0-25% Exotic (ROW-TC CE) 0.74 25TP 625 Hydric Pine Flatwood (TP- CE) 0.16

26R-TC 321/411 Palmetto/Pine Flatwood (ROW- TC CE) 0.42 27R-TC 421 E1 Xeric Oak 0-25% Exotic (ROW-TC CE) 0.74

28 141 Retails Sales and Services 6.55 29 421 E2 Xeric Oak 25-50% Exotic 0.15

30 421 E1 Xeric Oak 0-25% Exotic 1.44 31 411/321 E2 Palmetto/Pine Flatwood 25-50% Exotic 0.88 32 744 Filled Land 0.03 33 742H Detention- Hydric 1.32 34 740 Disturbed Land (Stormwater Berm) 1.95 35 520 Lake (Stormwater) 1.21 36 740 Disturbed Land 0.03 37 141 Retails Sales and Services 10.63 38 742H Detention- Hydric 0.21

TOTAL 58.07

TOTAL WETLANDS 13.62

TOTAL OSW 1.72

TOTAL UPLAND 42.73

2.1 Segment 1

Beginning at the terminal end of the constructed segment of Veteran’s Memorial Boulevard and the new county high school (Aubrey-Rogers), is a mixture upland and hydric pine flatwood habitats immediately adjacent to a cypress dome with a deep wetland pop ash center. Exotics are present in varying degrees surrounding the pop ash, while the pop ash habitat is primarily without exotics.

West of the cypress dome, habitats transition into a mixture of degraded hydric pine flatwood or pine-cypress-cabbage palm communities where melaleuca and ear-leaf acacia dominate. Further west the habitat shifts into mesic then xeric pine flatwood/saw palmetto and high xeric scrub before terminating at an abandoned railroad track. The high scrub area has been heavily bisected and impacted by ATV activity, thus it was given a designation for disturbed.

To the north of the Segment 1 is Mediterra Development and Golf Course, Conservation Collier preserved lands (Railhead Scrub Preserve). To the south of the project is a new county high school, 78.5 acres of private undeveloped lands (Parcel 0015316004), and Conservation Collier preserved lands (Railhead Scrub Preserve); the new pond site.

There are 5.62 acres of wetland impacts proposed in Segment 1 and 0.39 acres of Other Surface Waters. (See Exhibit 3- FLUCFCS Map)

Listed species identified in Segment 1 consisted mostly of gopher tortoise burrows and plants. There were 35 potentially occupied burrows inside the road right-of-way (ROW), 11 outside the ROW but inside a 25-foot buffer, and 5 abandoned burrows. Also identified were two lone listed plant species on the east end of the segment and numerous protected air plant species on the west half of the segment.

A habitat table is found below (Table 2) with brief habitat descriptions following. A detailed plant list for each habitat can be found in Appendix 1.

Table 2: FLUCFCS Table of Segment 1

1A Phase I Lands/Disturbed 1.75 1 814 Roads (Dirt) 0.04 2 411 E1 Pine Flatwood 0-25% Exotic 0.20 3 621 E4 Cypress >75% Exotic 0.39 4 625 E3 Hydric Pine Flatwood 50-75% Exotic 1.02 5 411 E2 Pine Flatwood 25-50% Exotic 0.18 6 621 E1 Cypress 0-25% Exotic 0.88 7 624 E2 Pine-Cypress-Cabbage Palm 25-50% Exotic 0.02 8 616 Inland Ponds & Sloughs 0.15 9 411/321 E2 Pine Flatwood/Palmetto 25-50% Exotic 0.55 10 624 E3 Pine-Cypress-Cabbage Palm 50-75% Exotic 1.54 11 621 E2 Cypress 25-50% Exotic 0.67 12 411 E4 Pine Flatwood >75% Exotic 0.14 13 625 E4 Hydric Pine Flatwood >75% Exotic 0.95 14 OSW Other Surface Waters 0.17 15 411 E3 Pine Flatwood 50-75% Exotic 1.58 16 421 D Disturbed Xeric Oak 3.25 17 OSW Other Surface Waters 0.22

TOTAL 13.70

TOTAL WETLAND 5.62

TOTAL OTHER SURFACE WATERS 0.39

TOTAL UPLAND 7.69

#1A- Phase I Lands/Disturbed There are areas impacted by Phase I construction on the south and north side of the pond site that also fall into Phase II boundaries for connectivity.

#1- 814 Roads & Highways This FLUCFCS area represents an old vehicle trail that ran the length of the property. The pathway consists of sand, exposed cap rock and weeds periodically.

#2- 411 E1 Pine Flatwood 0-25% Exotic Slash pine (Pinus elliottii), melaleuca (Melaleuca quinquenervia), ear-leaf acacia (Acacia auriculiformis), saw palmetto (Serenoa repens) and myrsine (Myrsine cubana) dominate habitat #2.

#3- 621 E4 Cypress >75% Exotic Habitat #3 is dominated by melaleuca with varying degrees of other exotics.

Groundcover has a moderate amount of native plant material though with saw grass

(Cladium jamaicense) and swamp fern (Telmatoblechnum serrulatum) dominating the stratum.

#4- 625 E3 Hydric Pine Flatwood 50-75% Exotic Melaleuca dominates this habitat with some remnant slash pine. Brazilian pepper (Schinus terebinthifolia) is also prevalent in the midstory along with melaleuca.

Groundcover is primarily swamp fern and saw grass.

#5- 411 E2 Pine Flatwood 25-50% Exotic Cabbage palm (Sabal palmetto) and slash pine are the dominant species with ear-leaf acacia and melaleuca found in smaller quantities. Brazilian pepper dominates the midstory with a few associated native species. Groundcover is also dominated by Brazilian pepper seedlings, but also noted were myrsine, beautyberry (Callicarpa americana), and snowberry (Chiococca alba).

#6- 621 E1 Cypress 0-25% Exotic This habitat surrounds a deeper wetland with pond cypress in the canopy and Brazilian pepper, pop ash (Fraxinus caroliniana) and pond apple (Annona glabra) in the midstory.

Groundcover is dominated by swamp fern and shield fern (Thelypteris kunthii) with scattered pop ash and buttonbush (Cephalanthus occidentalis).

#7- 624 E2 Pine-Cypress-Cabbage Palm 25-50% Exotic Slash pine, pond cypress, cabbage palm and melaleuca dominate this habitat with a few mature Australian almond trees (Terminalia muelleri) as well. Brazilian pepper and myrsine dominate the midstory, but two listed plant specimens were also identified here:

Mullein nightshade (Solanum donianum- State Threatened) and Simpson’s stopper (Myrcianthes fragrans- State Threatened). Both were solitary plants. Groundcover was comprised of Southern shield fern, myrsine, Brazilian pepper, swamp fern and saw grass.

#8- 616 Inland Ponds and Sloughs This deep wetland is mostly pop ash with a few pond cypress trees. Also present were pop ash, Carolina willow (Salix caroliniana) and pond apple in the midstory. The groundcover is sparse in the wet season, but as noted during the dry season it was comprised of Florida pellitory (Parietaria floridana), water paspalum (Paspalum repens), fire flag (Thalia geniculata), swamp fern, and a few seedlings of midstory species.

#9- 411/321 E2 Pine Flatwood/ Palmetto Prairie 25-50% Exotic There was approximately 35% canopy cover of mostly slash pine with a few cabbage palms, but the midstory was dominated by exotic species such as ear-leaf acacia, melaleuca and downy-rose myrtle (Rhodomyrtus tomentosa)with some cabbage palm and myrsine as well. Groundcover was mostly palmetto, cabbage palm and myrsine.

#10- 624 E3 Pine-Cypress-Cabbage Palm 50-75% Exotic Melaleuca was the dominant canopy species with minor amounts of slash pine, pond cypress and ear-leaf acacia. Midstory was dominated by Brazilian pepper and melaleuca with some cabbage palm, myrsine, wax myrtle, laurel oak (Quercus laurifolia) and ear-leaf acacia. Groundcover was dominated by swamp fern and saw grass.

#11- 621 E2 Cypress 25-50% Exotic Pond cypress and melaleuca were equally present in the canopy with pond cypress and Brazilian pepper nearly the same in midstory coverage. Groundcover was mostly comprised of swamp fern with scattered saw grass.

#12- 411 E4 Pine Flatwood >75% Exotic The canopy cover was low in habitat 12 with slash pine and melaleuca present, but the midstory was dense with Brazilian pepper and no other species. Groundcover when present was saw palmetto.

#13- 625 E4 Hydric Pine Flatwood >75 Exotic Ear-leaf acacia dominates this habitat with melaleuca and Brazilian pepper also prevalent. Native species present include slash pine and cabbage palm. Groundcover is dominated by swamp fern at decent coverage.

#14- OSW Other Surface Waters This is a sandy depression created from ATV use. The small amount of groundcover in dry season was dominated by torpedo grass and West Indian marsh grass. As the water table rises, this depression will inundate and remain an empty, ponded area until the water table drops again each winter. It is reliant on rainfall for hydrology.

#15- 411 E3 Pine Flatwood 50-75% Exotic Slash pine dominates this canopy, with downy-rose myrtle in the midstory along with gallberry (Ilex glabra), tarflower (Bejaria racemosa) and coastal plain staggerbush (Lyonia fruticosa). Groundcover is predominantly saw palmetto, down-rose myrtle and gallberry.

#16- 421D Disturbed Xeric Oak This high xeric scrub habitat is heavily segmented by ATV use giving it the Disturbed prefix. Dominant species are sand live oak (Quercus geminata), Florida rosemary (Ceratiola ericoides), hog plum (Ximenia americana), myrtle oak (Quercus myrtifolia), saw palmetto, sandyfield beakrush (Rhynchospora megalocarpa), narrowleaf silkgrass (Pityopsis graminifolia), sand spike-moss (Selaginella arenicola), and Chapman’s goldenrod (Solidago odora var. chapmanii). A full list of observed species is found in Appendix 1. There were a number of gopher tortoise burrows identified and marked in this habitat.

#17- OSW Other Surface Waters Like habitat #14, this depression in the high sand dune was created by ATV activities. In the dry season a few plant species grow in the lowest areas, but for the wet season it is an inundated sugar sand depression. An important note with #17 is that it continues across a fence line onto Conservation Collier’s Railhead Preserve lands and they have requested we also fill their portion so they can restore it to historical rosemary high scrub in hopes of increasing the site’s tortoise carrying capacity. This additional acreage is not noted on the FLUCFCS Map but is included on the impacts map as directly impacted habitat 17A.

2.2 Segment 2

From just east of the railroad easement to the railroad is disturbed sand with exotics. Just west of the railroad is a county stockpile area for various aspects of transportation staging work, with exotic-infested pine flatwood to the north, followed by a small segment of a north-south stormwater ditch infested with Brazilian pepper at its edge. The final stretch of land west to Old 41 is a raised and mowed powerline road segment, with a stormwater treatment detention area running parallel due north and due south of the raised road.

The north detention area is hydric but dominated by exotic plant species. Both detention areas will be improved for stormwater management.

To the north of Segment 2 is an industrial park and to the south is the western edge of the Railhead Scrub Preserve and a trailer park. Per discussions with the South Florida Water Management District the project’s primary stormwater pond for the segment west of the railroad tracks is now proposed south of Transportation’s staging area on Conservation Collier lands.

This new pond site will impact 2.20 acres of isolated wetland habitat directly to avoid rare xeric scrub where a number of protected species are located. The pond is planned immediately adjacent to a county drainage ditch. (See Exhibit 4 FLUCFCS Map)

A few gopher tortoise burrows were found along the northern edge of the County stockpile area abutting the disturbed pine flatwoods and additional ones were located south on the pond site. There were 8 potentially occupied burrows directly affected by site plans and 5 which lie within the 25-foot buffer zone. There are several cavity trees onsite, and a number of air plants found in the more xeric sections of the habitat adjacent.

The habitats within Segment 2 are found below in Table 3 with brief descriptions following. Detailed plant lists are found in Appendix 1.

Table 3: FLUCFCS Table of Segment 2

17B OSW Other Surface Waters 0.02 18 411 E3 Pine Flatwood 50-75% Exotic 0.24 19 740 Disturbed Land 4.94 20 411 E3 Pine Flatwood 50-75% Exotic 0.39 21 OSW Other Surface Waters 0.10 22 742 E4H Detention Area Hydric >75% Exotic 2.71 23 740 Disturbed Land 0.47 38 411/321 E1 Pine Flatwood/Palmetto (0-25% Exotic) 5.27 39 641 E4 Disturbed Marsh 0.21 40 621 E2 Cypress 25-50% Exotic 0.58 41 624 Pine-Cypress-Cabbage Palm 0.12 42 641 Gallberry Marsh 0.01 43 641 Hypericum Marsh 0.03 44 740H Hydric Dirt Road 0.02 45 621 E3 Cypress 50-75% Exotic 0.79 46 618 Willow 0.09 47 621 E1 Cypress 0-25% Exotic 0.35 48 740 Dirt Road 0.03 49 832H Electrical Power Transmission Lines 0.66 50 812 Railroad Track 0.03

TOTAL 17.06

TOTAL WETLAND 5.57

TOTAL OTHER SURFACE WATERS 0.12

TOAL UPLAND 11.37

#17B- OSW Other Surface Waters This tiny segment of the larger depression (17 and 17A) continues over the project line between Segments 1 and 2. There is no discernible difference between 17, 17A and 17B.

#18- 411 E3 Pine Flatwoods 50-75% Exotic Canopy cover consisted of slash pine and a minor amount of melaleuca, but the midstory was primarily Brazilian pepper, saw palmetto and the exotic plant carga agua (Senna angustisiliqua). Groundcover was also saw palmetto, Brazilian pepper and the exotic shrub sunflower (Tithonia diversifolia).

#19- 740 Disturbed Lands The state of this Transportation staging segment habitat changes regularly. It has been most recently scraped clean. The remainder is filled roadbed used as a powerline trail.

#20- 411 E3 Pine Flatwoods 50-75% Exotic This pine flatwood is dominated by ear-leaf acacia and Brazilian pepper with some slash pine and cabbage palm. Groundcover is mostly saw palmetto.

#21- OSW Other Surface Waters There is a north-south drainage ditch which must be piped under the raised road easement and one small corner of the ditch lies inside of the road right-of-way. It will be temporarily impacted to create proper drainage pipe connections for the roadway.

#22- 742 E4H Detention Area Hydric >75% Exotic This low stretch bordering the north property line was excavated for the powerline trail construction and serves as detention for that utility line and road easement. It is almost 100% dominated by exotic plant species, mostly ear-leaf acacia, melaleuca and creeping oxeye (Sphagneticola trilobata).

#23- 740 Disturbed Land Where the detention seems to end, ground elevation rises to match grade near Old 41. A previously cleared area that is all ear-leaf acacia and creeping oxeye occupies this acreage.

#38- 411/321 E1 Pine Flatwood/ Palmetto 0 – 25% Exotic Because this habitat is part of the Railhead Scrub Preserve it is managed by Conservation Collier. In the latter part of 2023 or early 2024 much of the habitat was chopped mechanically to reduce saw palmetto densities and improve the area for foraging. It was previously either very mesic and dense with palmetto and downy-rose myrtle or it was more xeric and open in nature. At this time, it is all very open except along the edges of wetland areas and in the more xeric fringes. The more open pine flatwood is dominated by low-growing saw palmetto and gallberry with random downy-rose myrtle, tarflower (Bejaria racemosa) and coastal plain staggerbush (Lyonia fruticosa).

#39- 641 E4 Disturbed Marsh This habitat is a low-lying area adjacent to the drainage canal. It is overrun with primarily exotic groundcover plant species and Lygodium. Desirable wetland species are randomly interspersed, but in small quantities. There are a few midstory sized plants, both desirable and exotic as well.

#40- 621 E2 Cypress 25 – 50% Exotic Pond cypress is the dominant canopy species with some dahoon in the canopy as well.

Midstory is more facultative with myrsine, cabbage palm, dahoon, wax myrtle, and ear-leaf acacia. Swamp fern dominates the groundcover. Downy-rose myrtle and Lygodium are also present in this habitat.

#41- 624 Pine-Cypress-Cabbage Palm This is a small depression just barely cut-off from habitat #40 by some palmetto upland.

It is dominated by slash pine, pond cypress, cabbage palm, dahoon, wax myrtle, swamp fern and gallberry.

#42- 641 Gallberry Marsh A tiny depression in the middle of mesic pine flatwood, this habitat was mowed with the saw palmetto and is regenerating as a gallberry marsh with some swamp fern, yellow-eye grass and Virginia chain fern.

#43- 641 Hypericum Marsh This depression appears to have been possibly partially man-made since it is on the south side of a dirt road. It however is dominated by quality wetland species such as St. John’s wort, Sabatia and Virginia chain fern. Dahoon is also present in the midstory, though in a very small amount. Hydrology is dependent on rainfall, as it sits within an upland palmetto habitat.

#44- Hydric Dirt Road This dirt road was created by ATV traffic before Conservation Collier purchased and preserved it and is part of the same depression of habitat #43. The remnant dirt road will fill in the wet season, losing all vegetation, but in the dry season it is covered with pink sundew (Drosera capillaris), Polygala rugelii, beaksedge (Rhynchospora fasciculatum) and yellow-eyed grass (Xyris sp.). The periphery has some St. John’s wort as well.

#45- 621 E3 Cypress 50 – 75% Exotic This pond cypress habitat abuts a drainage canal to the west and upland habitat north and south. There is a higher bank along the canal which creates a bowl effect in the wetland. Canopy is appropriate with 60% cover, but remaining strata have been impacted by altered hydrology. Midstory is relatively sparse with some dahoon and lateflowering thoroughwort (Eupatorium serotinum), but exotics such as Christmas senna (Senna pendula) and Peruvian primrose willow (Ludwigia peruviana) are also present in lesser quantities. Groundcover is mostly false nettle (Boehmeria cylindrica), with a few other species, exotic and desirable, but much of the habitat is coated in Lygodium.

#46 – 618 Willow Situated inside of habitat 45 and adjacent to upland, this small willow head is primarily just willow. On the outer edges some buttonbush and swamp fern are present as well.

#47- 621 E1 Cypress 0 – 25% Exotic A finger off of habitat 45 to the east, this area appears to have been a ditch possibly draining the railroad or an old fire break. It is very narrow in width but holds water in the wet season and is dense with mostly desirable vegetation. Vegetation is dominated by pond cypress, dahoon, gallberry and swamp fern. Some downy-rose myrtle is present along with a minor degree of Lygodium.

#48- 740 Dirt Road A historically used ATV access road lies across this segment of the pond site. It consists of dirt.

#49- 832H Electric Power Transmission Lines (Hydric) Like 22, this segment is a borrow area used as detention for this powerline trail. The powerline lies directly above this habitat and the road project will tie into this habitat for stormwater treatment.

#50- 812 Rail Road Track An abandoned segment of railroad track bisects the site in a north-south direction just west of the Segment 1 boundary.

2.3 Segment 3

A considerable portion of Segment 3 lands are under conservation easement (CE) to two different developments. Most of the road right-of-way is located in a CE dedicated to the South Florida Water Management District for Turtle Creek Apartments (Permit #11- 01367-P, CE- OR 2369, Page 0836), but does not appear to have been used as mitigation for the project. Also to be impacted by the project is a CE belonging to the Triangle Parcel commercial project (Permit #11-02353-P, CE- OR 4238, Book 3851).

Segment 3 begins at a palmetto/pine flatwood habitat and transitions into a hydric pine flatwood with low level exotic growth, before re-emerging into an upland palmetto/pine flatwood and ultimately a xeric scrub preserve. A stormwater berm and lake belonging to the Triangle Parcel lies to the south side of the right-of-way (ROW). Between U.S. 41 and the conservation lands the ROW crosses a dry detention area belonging to the Mercedes Benz dealership and an undeveloped xeric oak and pine/palmetto parcel abutting U.S. 41. The undeveloped xeric parcel (Parcel 00154600000) was recently purchased by Collier County to add space for turn lanes and a stormwater pond expansion at what will be a new intersection (U.S. 41 and Veteran’s Memorial Boulevard).

(See Exhibit 5- FLUCFCS Map)

Much of the ROW segment through Turtle Creek consists of a slightly raised historical dirt road bed.

Gopher tortoise burrows were located within all xeric habitats along the ROW and also on the Triangle Parcel’s stormwater pond berm ring. There are 73 potentially occupied burrows within the direct project footprint, 6 within the 25-foot buffer zone and 7 abandoned burrows. In the xeric habitats a number of listed air plant species are found as well.

The conservation easements for both sites can be found attached for reference as Appendix 2.

Table 4 below lists the various habitats in Segment 3 followed by brief descriptions. A detailed plant list of each can be found in Appendix 1.

Table 4: FLUCFCS Table of Segment 3

24R-TC 321/411 E1 Palmetto/Pine Flatwood 0-25% Exotic (ROW- TC CE) 0.82 24TP 321/411 Palmetto/Pine Flatwood (TP- CE) 0.03

25R-TC 625 E1 Hydric Pine Flatwood 0-25% Exotic (ROW-TC CE) 0.74 25TP 625 Hydric Pine Flatwood (TP- CE) 0.16

26R-TC 321/411 Palmetto/Pine Flatwood (ROW- TC CE) 0.42 27R-TC 421 E1 Xeric Oak 0-25% Exotic (ROW-TC CE) 0.74

28 141 Retails Sales and Services 6.55 29 421 E2 Xeric Oak 25-50% Exotic 0.15 30 421 E1 Xeric Oak 0-25% Exotic 1.44 31 411/321 E2 Palmetto/Pine Flatwood 25-50% Exotic 0.88 32 744 Filled Land 0.03 33 742H Detention- Hydric 1.32 34 740 Disturbed Land (Stormwater Berm) 1.95 35 520 Lake (Stormwater) 1.21 36 740 Disturbed Land 0.03 37 141 Retails Sales and Services 10.63 38 742H Detention- Hydric 0.21

TOTAL 27.31

TOTAL WETLAND 2.43

TOTAL OTHER SURFACE WATERS 1.21

TOAL UPLAND 23.67

Anything following with the R designation is right-of-way (ROW) under CE that has been at least partially filled and raised historically. It appears it was used as a dirt road decades ago.

#24R-TC- 321/411 E1 Palmetto/Pine Flatwood 0 – 25% Exotic (ROW) This upland habitat is dominated by slash pine and palmetto. Since it is under conservation easement and it had not been maintained for many years, it was cleaned-up and partially replanted in the past few years with a variety of upland, mesic and wetland plant species. Although it is under conservation easement it was not used as mitigation for Turtle Creek.

#24TP- 321/411 Palmetto/Pine Flatwood This area is a tall dense palmetto habitat under canopy of slash pine. Only a few other species are present.

#25R-TC- 625E1 Hydric Pine Flatwood 0-25% Exotic Slash pine dominates the canopy here, with dahoon, cabbage palm, myrsine, wax myrtle and a little melaleuca and ear-leaf acacia in the midstory. Groundcover was mostly blue maidencane (Amphicarpum muehlenbergianum), spadeleaf (Centella asiatica), cordgrass (Spartina bakeri) and southern beakrush (Rhynchospora microcarpa).

#25TP- 625 Hydric Pine Flatwood This mesic pine flatwood is dominated by slash pine and myrsine. A few other species are present, but groundcover is sparse. The hydrology here has been impacted by the raised roadbed bisecting this flow-way. It is questionably hydric anymore, but since it was permitted as a wetland and provided lift as a wetland for the Triangle Parcel it will remain classified as such.

#26R-TC- 321/411 Palmetto/ Pine Flatwood This habitat borders the Turtle Creek wetland and consists of slash pine with a sparse midstory of coastal plain staggerbush, tar flower and gallberry. Groundcover is mixture of palmetto and wire grass with minor associated upland/mesic wetland species.

#27R-TC- 421 E1 Xeric Oak 0 – 25% Exotic This xeric habitat is dominated by sand live oak, coastal plain staggerbush, hog plum, Florida rosemary and myrtle oak. Groundcover was a mixture of saw palmetto, wire grass, sand spike-moss, and Chapman’s goldenrod with other native scrub forbs and grasses. There is a minor amount of downy-rose myrtle present in habitat 27.

#28- 141 Retail Sales & Services Mercedes Benz of Naples is located at this site which sells and services vehicles.

#29- 421 Xeric Oak 25-50% Exotic This strip of scrub extends off the undeveloped upland parcel abutting U.S. 41 onto the boundary of the stormwater lake berm. It is a mixture of exotic and native trees such as ear-leaf acacia, live oak and cabbage palm with a midstory of the same, plus Brazilian pepper and hog plum. Groundcover is dominated by pinewoods fingergrass (Eustachys petraea), thalia lovegrass (Eragrostis atrovirens) and knotroot foxtail (Setaria parviflora).

#30- 421E1 Xeric Oak 0-25% Exotic This newly acquired upland parcel is mostly comprised of sand live oak, some slash pines, a few ear-leaf acacia, Florida rosemary, myrtle oak, live oak, hog plum and saw palmetto. Groundcover is a variety of scrub species such as saw palmetto, gopher apple (Ceratiola ericoides), wire grass, sandyfield beakrush, Chapman’s goldenrod, sand spike-moss, and reindeer lichen (Cladonia rangiferina). A number of gopher tortoises were located on this site.

#31- 411/321E2 Pine Flatwood/Palmetto 25-50% Exotic On the southern third of the new county-owned upland parcel is slash pine, ear-leaf acacia and palmetto, with dense downy-rose myrtle in areas, Brazilian pepper and some myrsine.

#32- 744 Filled Land Within project boundaries is a small segment of grass and sidewalk along U.S. 41.

#33- 742H Detention Hydric This mowed detention area will become part of the road water management system, impacts are temporary.

34#- 740 Disturbed Land This stormwater pond berm is manmade, grassed and mowed regularly. It also houses a small tortoise population on some of its banks and frequently on top of the berm.

#35- 520 Lakes This stormwater pond serving the commercial center to the south will be re-shaped and enlarged in a westerly direction, so impacts will be temporary.

#36- 740 Disturbed Land A narrow strip of the berm on the Old 41 drainage easement lies within the proposed site boundary. It is comprised of mowed grass and weeds.

#37- Retail Sales & Service These are commercial services such as furniture sales, car sales and car services.

#38- 742H Detention Hydric This small detention area is part of the lake outfall but is not planned for impact.

2.4 Soils

There are eight soils in the project footprint, four of which are hydric and four of which are designated non-hydric. Those soils are listed below with a brief description of each.

A soils map can be found as Exhibit 10.

39 Satellite Fine Sand (Non-Hydric) Sand scrub on rises, ridges and knolls of mesic uplands.

101 Basinger Fine Sand- Urban Land Complex (Non-Hydric) Sandy soils on flats of mesic or hydric lowlands. Sandy Flatwoods and Hammocks.

102 Cypress-Lake Fine Sand- Urban Land Complex (Non-Hydric) Sandy over loamy soils on flats of mesic or hydric lowlands. Flatwoods and Hammocks.

103 Cypress Lake, Riviera, Copeland Fine Sand (Hydric) Sandy over loamy freshwater isolated marshes and swamps.

117 Immokalee Fine Sand (Non-Hydric) Sandy soils on flats of mesic or hydric lowlands. Sandy Flatwoods and Hammocks(South Florida Flatwoods).

129 Pineda & Riviera Fine Sand (Hydric) Sandy over loamy freshwater isolated marshes and swamps.

131 Riviera Fine Sand, Limestone Substrate (Hydric) Sandy over loamy Flatwoods and Hammocks.

133 Satellite Fine Sand- Urban Land Complex (Non-Hydric) Sand scrub on rises, ridges and knolls of mesic uplands.

2.5 Listed Species

Associated with this project are the potential for listed species identified below in Table 5.

Table 5: Potential Listed Species Occurring on Project Site Common Name Scientific Name State

Status Federal Status

Probability of Occurrence

Reptiles & Amphibians Eastern indigo snake Drymarchon corais couperi ST FT Moderate/ High gopher tortoise Gopherus polyphemus SF High Birds

Florida sandhill crane Grus canadensis pratensis ST Low Florida scrub jay Aphelocoma coerulescens FT Low/ Moderate little blue heron Egretta caerulea ST Moderate/ High reddish egret Egretta rufescens ST Low tricolor heron Egretta tricolor ST Low woodstork Mycteria americana FT Low/ Moderate red-cockaded woodpecker Leuconotopicus borealis FE Low

Common Name Scientific Name State Status

Federal Status

Probability of Occurrence roseate spoonbill Platalea ajaja ST Low Mammals

Florida panther Puma concolor coryi FE Low Florida bonneted bat Eumops floridanus FE Moderate/High

Big Cypress fox squirrel Sciurus niger avicennia ST Low/ Moderate

Vegetation nodding pinweed Lechea cernua ST Moderate/ High spreading pinweed Lechea divaricata SE Low/ Moderate Curtiss’ milkweed Asclepias curtissii SE Moderate many-flower grass pink Calopogon multiflorus ST Low/ Moderate erect prickly pear cactus Opuntia stricta ST Moderate/ High

Mullein’s nightshade Solanum donianum ST Moderate/ High showy dayflower Stylisma abdita SE Low/ Moderate Florida gamagrass Tripsacum floridanum ST Low/ Moderate

White squirrel banana Asimina pulchella SE Low northern needleaf Tillandsia balbisiana ST Moderate/ High cardinal air plant Tillandsia fasciculata SE Moderate/ High twisted air plant Tillandsia flexuosa ST Moderate/ High fuzzywuzzy air plant Tillandsia pruinosa SE Moderate/ High giant air plant Tillandsia utriculata SE Moderate/ High soft-leaved wild pine Tillandsia variabilis ST Moderate/ High

Identified through surveys within the project footprint or a 25-foot buffer, were 138 potentially occupied gopher tortoise burrows and 12 abandoned, cardinal air plant, giant airplant, northern needleleaf, Simpson stopper (Myrcianthes fragrans), and Mullein nightshade. A Florida Bonneted bat acoustical survey is currently underway.

Conservation Collier has provided verbal confirmation that bears regularly cross the high sand dunes of Segment 1. No tracks have been identified during survey periods, but given the soft sand conditions, finding tracks would be limited.

Conservation Collier is working with FWC to establish a carrying capacity for Railhead Scrub Preserve in the hopes of taking some of the tortoises which will need to be relocated. What cannot be accommodated in the adjacent preserves will be taken offsite to a tortoise bank.

3.0 ENVIRONMENTAL CONSIDERATIONS

3.1 Wetlands & Other Surface Waters

In order for the project to meet the purpose of Section 10.1 of the Applicant’s Handbook (AH) Volume 1 the following sections of 3.0 provide documented assurances that there is no net loss of wetland function associated with the project and that water quality standards in wetlands and other surface waters will be maintained.

(a) A regulated activity will not adversely impact the value of functions provided to fish and wildlife and listed species by wetlands and other surface waters [paragraph 62-330.301(1)(d), F.A.C.];

The road right-of-way habitats are predominately upland in character, except the eastern extent which abuts the completed first phase of the project and a segment west of Old 41.

Segment 1 of the site is bordered to the north by Mediterra, to the east by Veteran’s Memorial Boulevard and to the south by a new high school. Natural water flows are obstructed by those areas of development and their stormwater berms. To the southwest of the site are undeveloped lands with adjacent wetlands, but they also abut development to the east and outfall into stormwater systems belonging to Imperial Golf Course Estates.

In addition to flow obstructions the vast majority of wetland habitat is moderately to severely degraded with dense exotic plant species which limit wading bird and bald eagle foraging on this site. Of the 17 listed species site surveys no wading birds were observed foraging. A known bald eagle nest less is than 0.5 mile south of the project site (CO931) located adjacent to several old mining lakes.

The two seasonally hydrated depressions in Segment 1 are less than one acre in size, contain sparse to no vegetation, and are man-made so they do not qualify for the provisions in most of the sections of the AH Vol. 1 dealing with fish and wildlife functions with relation to wetlands or other surface waters.

Segment 2 contains some disturbed hydric retention areas for the powerline trail which will become part of the roadway stormwater system. It also contains the 7.5-acre stormwater pond which abuts a county drainage canal. The pond site does contain some wetland areas, all of which are isolated, and some are merely very small depressions.

Wetland areas are cut-off from offsite flows by surrounding xeric habitat or a drainage canal berm, so they are already hydrologically impacted.

Segment 3 of the project will cross a hydric pine flatwood under conservation easement.

There will be pipes under this road segment which might actually help to restore the hydrological connection between Turtle Creek and The Triangle Parcel wetlands that are bisected currently by a raised dirt road bed in the right-of-way.

(b) A regulated activity located in, on, or over wetlands or other surface waters will not be contrary to the public interest, or if such an activity significantly degrades or is within an Outstanding Florida Water, that the regulated activity will be clearly in the public interest [subsection 62- 330.302(1), F.A.C.];

With the new high school completed and in-use, North Naples was rezoned for the 2023- 2024 school year to provide space for nearby neighborhood teens to move there instead of 7 miles to the east at the County’s most crowded high school. Also, immediately east of the high school are middle and elementary schools serving the same district. Currently the path to school for residents north of Immokalee Road and west of U.S. 41 is convoluted 8-to-9-mile drive requiring on already overcrowded roads. The public benefit to having a connector that keeps the bulk of the population off of Immokalee Road and Bonita Beach Road is high. The connector will reduce driving distances by up to 7 miles (one-way). Residents west of U.S. 41 routinely inquire about the timing of this connection being built.

A stormwater system for the roadway by-basin has been designed with pretreatment ponds as required for water quality assurances.

(c) A regulated activity will not adversely affect the quality of receiving waters such that the water quality standards set forth in Chapters 62-4, 62-302, 62-520, and 62-550, F.A.C., including any antidegradation provisions of paragraphs 62-4.242(1)(a) and (b), subsections 62-4.242(2) and (3), and Rule 62-302.300, F.A.C., and any special standards for Outstanding Florida Waters and Outstanding National Resource Waters set forth in subsections 62-4.242(2) and (3), F.A.C., will be violated [paragraph 62-330.301(1)(e), F.A.C.];

Water quality standards will be met with regard to the roadway stormwater run-off through a series of culverts, pipes, dry detention and stormwater treatment ponds. No groundwater or drinking water impacts will occur in association with this project and there are no Outstanding Florida Waters or Outstanding National Resource Waters near this project site or directly connected.

(d) A regulated activity located in, adjacent to or in close proximity to Class II waters or located in waters classified by the Department of Agriculture and Consumer Services as approved, restricted, conditionally approved, or conditionally restricted for shellfish harvesting will A.H.

Volume I December 22, 2020 10-2 comply with the additional criteria in section 10.2.5, of this Volume [paragraph 62- 330.302(1)(c), F.A.C.];

Not applicable to this development due to location.

(e) The construction of vertical seawalls in estuaries and lagoons will comply with the additional criteria in section 10.2.6, of this Volume [paragraph 62-330.302(1)(d), F.A.C.];

Not applicable to this development.

(f) A regulated activity will not cause adverse secondary impacts to the water resources [paragraph 62-330.301(1)(f), F.A.C.]; and

Most of the proposed project is without any kind of secondary impacts to wetlands.

Identified secondary impacts will be mitigated for offsite.

(g) A regulated activity will not cause unacceptable cumulative impacts upon wetlands and other surface waters [paragraph 62-330.302(1)(b), F.A.C.].

Wetland impacts associated with the proposed project will be mitigated for entirely within the same drainage basin, so no cumulative impacts will occur.

3.2 Environmental Criteria

3.2.1 Elimination and Reduction of Impacts

Because this project is confined to a platted road right-of-way its dimensions are extremely limited to accommodate a road, pedestrian and bicycle access meeting FDOT standards, and stormwater pre-treatment requirements. Every possible square footage of project area is being utilized for all of those previously mentioned building constraints, so elimination of impacts is not practicable or feasible.

This linear project, which is approximately 1.2 miles in length, consists of several drainage basins associated with stormwater management. The first basin encompasses Segment 1 and the second basin west of the railroad easement encompasses Segments 2 and 3. Some of the project basin drainage was able to be handled within the perimeter of the ROW boundary and existing Phase 1 pond site, however the western half of the project required a second sizable stormwater pond for which project space was not afforded within the ROW.

At the request of the South Florida Water Management District a proposed pond site that was originally located in a xeric scrub habitat under conservation easement to Turtle Creek was relocated to Collier County owned lands in the Railhead Scrub Preserve. After discussions with Conservation Collier who owns and manages the land where the new pond has been sited, we are avoiding rare scrub habitat in favor of impacting isolated wetland and mesic upland areas to avoid a number of listed plant and animal species.

Most of the new pond site is located along a county managed drainage ditch which runs north-south through the Railhead industrial park. Between the ditch and lands immediately adjacent is a small berm which severed the connectivity of wetlands to the west, while these wetlands are already surrounded by scrub and upland habitats east, north and south of the site. There are 2.10 acres of wetland within the pond footprint which are altered and isolated.

The siting rationale was that the xeric scrub habitat outside the pond impact zone is rare for Collier County unlike the altered wetlands, has numerous listed species documented by a detailed survey performed for Conservation Collier, and houses a population of gopher tortoises, a state threatened species. This rarity and density of protected species is why the land comprising up Railhead Scrub Preserve was purchased by Conservation Collier.

Table 6: Railhead Scrub Preserve Listed Species

3.2.2 Fish, Wildlife, Listed Species and their Habitats

A detailed and lengthy listed species survey occurred over three years throughout the site and immediately adjacent lands prior to the submittal of this application (see Appendix 5). There is a known bald eagle nest site (CO931) which lies 0.36 miles south of

Segment 1 and is situated near a larger offsite lake. This eagle has not been observed within the Phase II boundaries at any time thus far.

Wetland habitats within Segments 1 and 2 vary in function, typically between 30 and 50% of their potential value, due to hydrological flow obstructions, adjacent development and high densities of exotic plant species. There are limited opportunities for water-dependent species to forage within the project boundaries.

3.2.3 Public Interest Test

(a) Whether the regulated activity will adversely affect the public health, safety, or welfare or the property of others (subparagraph 62-330.302(1)(a)1, F.A.C.);

As proposed the project will not influence any rivers, streams, or bays, which eliminates any concerns over fishing or shellfish harvesting impacts. As a road with properly engineered stormwater treatment, it also does not pose any environmental health issues or create any hazardous waste concerns. A Stormwater Pollution Prevention Plan is included in the engineering plans to address pollution and construction waste concerns.

There are pipes, dry detention and pond sites for each minor drainage basin of the roadway proposed to handle stormwater run-off, as well piping under the road if crossing an existing and remaining wetland habitat. No water trespass or water table affects will be imposed on neighboring properties to the project.

In terms of improving traffic flow, driving distances from western Collier County towards the east, and easier public-school access, it provides a net public benefit.

(b) Whether the regulated activity will adversely affect the conservation of fish and wildlife, including endangered or threatened species, or their habitats (subparagraph 62- 330.302(1)(a)2, F.A.C.);

Most of the wetlands onsite are dense with exotics, or hydrologically isolated and not utilized by wading birds or bald eagles based on a number of listed species surveys conducted. Flows are impacted by development immediately adjacent to the north, south, east, and with uplands to the west so hydrology is not typical.

The one small road segment crossing a wetland in Segment 3 will provide piping to possibly restore connectivity of a flow-way that was bisected by a raised dirt road historically.

Gopher tortoise burrows are located within the right-of-way and on the pond site.

Conservation Collier is working with FWC to establish a carrying capacity for Railhead

Scrub Preserve so that they may take some of the tortoises from this project footprint, while the remaining tortoises will have to go to a mitigation bank or other adjacent xeric habitats as allowed by FWC.

(c) Whether the regulated activity will adversely affect navigation or the flow of water or cause harmful erosion or shoaling (subparagraph 62-330.302(1)(a)3, F.A.C.);

As previously discussed, this project will not affect any streams, rivers,…