KEY AREA TO COMMENT ON REGARDING THE DRAFT TORTOISE MANAGEMENT PLAN

Dear Friends and Members

There are a number of issues that need to be addressed in your comments that are critical to the success of the plan. Please look at my comments for more details. Look on the Stakeholder Page of our webpage for comments on the Assurance Colony Program. Finally thanks so much for your comments. I have included quite a number in mine and, in the presentation I did at the last Stakeholder meeting.

1. The single family home properties (or 5 or fewer tortoise permits) must be changed from what is in the plan. FWC needs to get local governments or consultants to make sure the people buying lots and building get permits and arrange for their relocation. Now that FWC wants big money people will ignore these permits more now than when they were voluntary. Charges for these permits should pay for the eyes on inspectors be they private or public, but should be scaled say, based on the assessed value of the land.
    
2. FWC needs to adopt the cooperative; conservation begins at home and establish the Assurance Colony program to develop various levels of conservation for the tortoises and costs. This is a way to establish an economically sustainable program that makes sure there are good conservation lands for tortoises in each county in perpetuity. Such a program should assist counties with conservation lands acquisitions, funding monitoring and management and encourage local people to manage tortoises in their neighborhoods.
    
3. FWC must develop a program that is designed on a business-like contractual basis with landowners and local governments and all should work on a financial program that has a goal to replace on a 1:1 basis of the entire tortoise habitat lost in any development and that all tortoises are relocated. The cost per acre is a line in the sand so to speak but there should be ways from redesigning plans, swapping land, buying conservation easements instead of fee simple purchases, developers working together with other stakeholders to create large parcels at much less cost than the cost per acre. The goal is 0 loss of habitat, not squeezing out money and punishment of the developers.
    
4. All state and federal and endemic commensal species like the Indigo Snake, Florida Mice, and many invertebrates should by 2008, have their own management plans and proper procedures for relocation today they are just left or just tossed to wherever the tortoises are being relocated.
   
   5. Incidental Take as now permitted should be stopped by August 2007. There should be no grandfathered permits after that point and no perpetual permits given to land at all. THERE IS NO CONSERVATION VALUE IN INCIDENTAL TAKE.
    
5. All relocations unless on areas over 500 acres should require fencing to keep relocated tortoises in their new home sites for no less than 6 months. These sites must meet minimum standards for forage, canopy cover, burrow sites. Minimum size is 10 acres and FWC should encourage people to pre-manage sites so they can put up to 4 tortoises per acre.
    
6. All data collected on development lands must be taken by properly trained consultants and, the data should be collected in a way that an FWC, county or expert could tell if the data was taken correctly and accurately.
    
7. The Tortoise Management Plan should demonstrate realistic budgets for all aspects of FWC involvement and what will go to partnerships. The plan should be evaluated one year after its adoption by a team of stakeholders and every year after.
    
8. Research should be done on real potential problems that are going to face tortoise colonies in the future. How do we manage when we cannot burn? How are tortoises being affected by contaminants in the ground water in which they live? Now that we know tortoises eat so many species, just what are their nutritional needs for each age class and what plants play key roles in them. What if any diseases are affecting tortoises including the 6 or 8 that are known and some of the new ones that have been found recently.
    
9. How will FWC take over or help GTCI continue to educate the public, professionals and other stakeholders in the future?
    
10. The plan has basically left out the key elements in encouraging agriculture and forestry interests in becoming willing partners in this plan. There is a need to establish a program that gives Conservation Tax Exemptions for leaving natural lands in place. Today these lands in most counties are not eligible for agricultural tax exemptions. The required 600 tress per acre for silviculture exemptions must be changed. This density creates sterile habitat and causes lapses in fire management. Forestry interests should have a way to sustain wildlife habitat and produce trees and have a conservation exemption. Cow pastures based on our studies can handle extremely dense populations of tortoise’s right along with cattle. This important safety value habitat needs incentives such as increased tax exemptions over what is offered for cattle as well as properly prepared conservation easements paid for by developers. Similar incentives should be offered to citrus and other agricultural interests.