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COMMENTS ON THE THIRD DRAFT OF THE GOPHER TORTOISE MANAGEMENT PLAN


From: Ray Ashton, Gopher Tortoise Conservation Initiative and Stakeholder Representative for the General Public

17 August 2007

Since the release of the second draft of the tortoise management plan, I have been meeting with a wide variety of people. Usually I have been invited to talk or do a workshop or giving programs and workshops. We have met with quite a cross section of people including consultants, large and small landowners, local government staff and elected officials. Basically, their comments can be put into the following:
  1. We want all Take removed from the attempts to protect gopher tortoises. We want to be sure that Incidental Take stops and that other forms of permitted take like those of the 5 or fewer/single family developments get controlled.
  2. We are concerned that the management and financing of relocation will become a disaster and lead to the loss of most of the tortoise resources in the state in the next generation. Neither of the previous drafts of the management plan demonstrated control in perpetuity.
  3. Local governments are going to take control with hopes to avoid the continuance of take or other policies that lead to the loss of local tortoise resources. At this point many local rules are conflicting with good tortoise conservation.
  4. Developers would like to see a method where they are paying directly for the conservation of tortoises including easements and the creation of a monitoring and management fund to insure that these activities are done before disaster takes place and those things like the conservation easement is used to insure that management is done. WITHOUT THIS FUND THE VAST MAJORITY AGREED THAT FWC WILL BE BACK AT THE DRAWING BOARD IN 20 YEARS TRYING TO SALVAGE WHAT WAS LEFT.
  5. Potential Host sites with a few to several thousand acres expect all costs to be covered, an easement is paid for based on what the easement requires (development rights 60% of fair market value and an additional percentage based on restrictions of land use. (See attached)
  6. State properties would like to have the program self-contained. They hire a managing team which handles the whole process of developing, contracting for tortoise, permits, monitoring and managing tortoises and short term management except what is prescribed by the agency for that site.
  7. Carrying capacity must be much greater than 2 per acre and based on the Host Site and the over all property, not just the recipient site, the number may be as high as 8 to 10. This is important from not just the Host Site but the Donor Site as well. These economics must work to sustain these and all sites in perpetuity.
  8. Communities should be allowed to manage tortoises; people should have them in their yards, etc.
  9. FWC should support educational programs like those provided by our Institute (courses for professionals, educators, naturalists, etc).

CONCLUSION

Based on comments received from our last two course participants. No one knows for sure what they have to do for relocation now. You most fence or not? Donor site owners are asking whether or not they should apply for Accidental Take because on one will take two tortoises/acre. AT allows for three tortoises/acre over an above the current resident density so it’s more cost effective. ACTION MUST BE TAKEN IMMEDIATELY TO BE SURE THAT RELOCATIION IS DONE WITH BOTH CONSERVATION OF THE TORTOISES AND THE ECONOMICS OF RELOCATION IN PLACE.

Thus far we have not been permitted to discuss in detail an economic plan that would work for both developers and Host Sites, not to mention assist with local conservation lands management and beyond. NO CONSERVATION PLAN WILL BE SUCCESSFUL IN THE LONG RUN IF THE COMMUNITY DOES NOT SUPPORT IT OR IT IS NOT ECONOMICALLY SUSTAINABLE.

We did not see anything in the plan that addresses:
    The needs for relocation in the next six months.

    The proposed easements are too complicated and do not address key issues. The funding for or what land (each recipient site? Host Site?)

    Public lands do not need easements so the funding should be put into a Trust Fund for Monitoring and Management to insure sites do not get managed to the point they are no longer tortoise habitat.

    There is no structure in the plan to show how FWC is going to monitor management in a timely fashion to keep from loosing habitat or stressing tortoise populations.

    There is no indication that FWC is going to train regular staff or have professional tortoise biologists to work with permits, over sight or training, a key issue today.

    A strong plan from FWC to work immediately toward a Conservation Tax Exemption or to help local governments who want to adopt same(as they can under the state constitution) with proper planning and wording so it will not be overturned in Tallahassee or not do what is needed for land conservation.
CLOSING COMMENT

When FWC staff say be patient, we will “Get Er Done” I do not doubt their conviction to do so. It was a different staff than was in place when we were concerned about the outcome of the current policy and recommended change in the draft. It never happened. The effort to eliminate URTD testing several years ago after documentation and powerful support to stop it was simply ignored. The results has been a program if anything promoted the decline of the species and resulted in public outcry. There has been great progress made over the past three years but we have come down to the wire without absolutely critical issues solved (see above).

We recommend that the public ask that FWC staff request and the Commission agree that issues relocated directly to the planning and management of the relocation program including permitting and funding be re-drafted and reviewed and then taken back to the Commission by December of 2007.

Meanwhile the FWC administration review and make sure that the permitting for relocation is done uniformly and with nothing more than with the best conservation concerns for the tortoise and its habitat.

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