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HomeMy WebLinkAbout2000 09 25 Regular A Future Development for Recreational Uses COMMISSION AGENDA ITEM A CONSENT INFORMATIONAL PUBLIC HEARING REGULAR X MGR. ~ /DEPT C Q Authorization September 25. 2000 Meeting REQUEST: The Parks and Recreation Department is requesting that the City Commission not proceed with mitigation in wetlands #1 for proposed sports fields on the Moss Road property (around police station) but direct staff to look into future development for recreational uses in the south 3.4 acres of the parcel which may include mitigation of wetland #4 which is .82 acres. PURPOSE: The purpose of this agenda item is to inform the City Commission of the wetlands study and obtain direction for future development on this parcel of land. ISSUE ANALYSIS: · On June 28,1999, the City Commission directed staff to consider the area around the Police Station for recreation practice fields. . On January 10,2000, the City Commission discussed the property and possible sports field activities and referred it to a Parks and Recreation Workshop. . On March 20, 2000, a Recreation Workshop was held and the Commission consensus was to bring back the information and budgetary amount to explore the wetlands. . On May 22, 2000, the City Commission approved $5,000.00 for Environmental Services, Inc. to do a wetland study and present a report containing estimated costs to mitigate the wetlands. I . ESTIMATED MITIGATION COSTS PER ACRE BY WETLAND Wetland Size (acres) Impact Acreae:e Mitigation Acres Needed Cost per Acre Total Cost of Mitie:ation 1 1 1 2 3 4 10.91 10.91 10.91 10.91 354 $113,656. 1 20 $ 70,000. 3.5 95 $ 95,000. Surface Water-No Mitigation Required Less than 0.5 acres-mostly like no mitigation required 0.82 9.8 $ 34,300. $ 34,300. $1,239,000. $ 70,000. $ 332,500. 0.82 WETLAND #1 . There is a very high cost per acre to just mitigate any of wetlands #1 and that cost does not include engineering, environmental permitting, permitting fees, land clearing, filling and construction. Staff does not recommend proceeding with any mitigation to wetlands #1. . WETLAND #2 . This location is a drainage ditch and not usable due to its size and location for any recreational purpose. It also fronts high traffic on 419. WETLAND #3 . This location is not suitable for recreation purposes because of high traffic and unsafe conditions. It also only provides 2.1 usable acres and would require additional park infrastructure for development. WETLAND #4 · However, wetland #4's location is very strategic. It fronts Moss Road and is directly across the street from Corey Lane. It is also adjacent to the new park improvements, which include playgrounds, sidewalks and a restroom facility. By mitigating Wetland #4 at .82 acres, an additional 2.58 acres of uplands is available (total 3.4 acres) for future park improvements and expansion that may be funded by Community Development Block Grant funds. CONCLUSION: The most cost effective solution is mitigation of wetland #4, which can be achieved for a reasonable mitigation cost and yield a total of 3.4 usable acreage for recreational use. 2 . Ms. Linda A. Olson, MS, CLP, Assistant Vice President of Environmental Services, Inc. who conducted the wetlands study and Mr. Bill Starmer of SRI, are present to answer any questions. FUNDING: N/A at this time RECOMMENDATION: The Parks and Recreation Department is recommending that the City Commission not proceed with mitigation in wetlands #1, #2 and #3 of the proposed sports fields on Moss Road but direct staff to look into future development for other recreational uses in the south 3.4 acres of the parcel which may include mitigation of wetlands #4 (.82 acres). IMPLEMENTATION SCHEDULE: September-October 2000 November 2000 Staff researches land use options and funding Staff makes recommendation to City Commission ATTACHMENTS: Attachment #1- Attachment #2- Attachment #3- Wetlands Survey Map Environmental Services Inc. Report Starmer Ranaldi Opinion Letter and Concepts A & D COMMISSION ACTION: Ageodal23 3 I I 100' 1/ ;v.. -, 1 I I I I I I I I I I I ___J ---- POND 'hETLANDS FOR CITY OF WINTER SPRINGS ATTACHMENT D 1 ---- -- Q1IdI.....IIIIIIIIIJI..... J) ..... '-'I . .. ~ ~~... _.... . .....-.--..... ......-... .. - lit ~ __ _...... Ii. ':"l:,:r.tl;..- - -..- -.- L""T':~~~ ~.._-- !It~.-...___~__....... ::"-=:'.~.t=.'Ie""..~- - - -~~NA~ - - - " " - - - WETLIlND #J ~ --- --~ E ~ l:l ~ ... q l!!i - ... ... .-.. ... ...11: '........ .. .... ...,....--. __ II .. .. ..... ==':'''Lb.~-:=:''''''''II~'' MUn F1n.D ==:. a:::. '.:.= ~~..~'::.~ ~==--:..~~.......... II&&....!!!!...-. ~ ,- -,,,- -. SHl:ET aim DAlE Ji~~eg~~g~r. !. _ . ........ ..... .... _ m--....... ~ . ....*~~~J:"~ -- 8'1 (~~ ATTACHMENT H2 -fJ ENVIRONMENTAL SERVICES. INC. 1353 NORTH COURTENAY PARKWAY. SUITE W MERRITT ISLAND, FLORIDA 32953 (321) 449-040<'3 12 September 2000 Mr. Chuck Pula, Director Parks and Recreation Department City of Winter Springs 1126 East State Road 434 Winter Springs, Florida 32708 RE: Moss Road Property Winter Springs, Seminole County, Florida Dear Mr. Pula: As per our contract, Environmental Services, Inc., (ESI) has evaluated the environmental feasibility of developing the Moss Road property into a city park. This assessment considered the presence of wetlands on the site, the quality of these wetlands, the on-site wetlands' relationship to surrounding land use and nearby Lake Jesup, project design alternatives, wetland impacts, wetland mitigation, permitability of the proposed project, and costs of wetland mitigation. Input on wetland quality, feasibility of wetland impacts, mitigation ratios, compensation alternatives, and permitability of the project was gained through coordination with regulatory agencies and local agencies and organizations involved with wetland mitigation in the vicinity of the project site. In addition, ESI staff coordinated with you regarding various site plan designs under consideration. SITE DESCRIPTION The property is a 28.12-acre site surrounded on three sides by roads and on the forth by residential development and Torcaso Park. Based on a map produced by Breedlove, Dennis & Associates, Inc., entitled Aerial and Wetland Delineation of the Torcaso/Sunshine Park Project Site, the subject site comprises three wetlands totaling 11.83 acres~ uplands totaling 14.25 acres, some of which recently have been developed into a police station; retention ponds totaling 0.89 acre; and ditches totaling 1.15 acres. Wetland 1 encompasses 10.91 acres, the majority of the central portion of the subject site. This wetland is a hardwood forest connected by ditches to the Lake Jesup ecosystem. An assessment of the wetland by ESI biologists and coordination with Tony Miller of St. Johns River Water Management District (SJRWMD) and Steve Brooker of U.S. Army Corps of Engineers (CE) led to the determination that with the exception of areas along the southwestern edge (about 0.5 acre) and about 1.0 acre in the south central region, Wetland 1 is a moderate to moderately high quality wetland. This evaluation resulted from the wetland's current condition as relatively undisturbed, its locale and connection to Lake Jesup, impact to the system from adjacent ditches, and fragmentation from the overall Lake Jesup system by surrounding development. In comparison to the majority of the wetland, the strip of land along the southwestern edge that is ENVIRONMENTAL SERVICES, INC. Page 2 Mr. Chuck Pula, Director Moss Road Property EC00031 12 September 2000 dominated by nuisance and exotic species, and the area in the south central region heavily overgrown by southern fox grape (Vilis munsoniana), were ranked as low quality and low to moderately low quality, respectively. Wetland 3, located in the northwestern comer of the site is a small (O.lO-acre) hardwood forest remnant. This wetland's small size, its isolation, and its location adjacent to a major thoroughfare resulted a ranking of low to moderately low quality. Wetland 4, in the southeastern comer of the site, is 0.82-acre. The hydrology of this wetland has been negatively affected by its connection to two ditches. Soil subsidence, encroachment by transitional plants and nuisance species such as elderberry (Sambucus canadensis), wild taro (Colocasia esculenta), and peppervine (Ampelopsis arborea) are visual representations in the wetland of the reduction in hydrology and the area's disturbance. This wetland also has been negatively affected by surrounding development. Wetland 4 is a low quality wetland. PERMITTING OVERVIEW If development is proposed that may impact jurisdictional wetlands, both CE and SJR WMD become part of the permitting process. Since the subject property is dominated by wetlands, it is likely that development of the site will impact wetlands and will require federal and state permits to proceed. As part of the permitting process CE and SJRWMD have been requiring increasingly stringent documentation of wetland avoidance and impact minimization; the higher quality the wetland, the more stringent the amount of proof required. In addition, it is often necessary to perform an alternative location analysis, to prove that no other suitable locations for the project occur and to justify the need for the proposed development in a location that would potentially impact wetlands. Finally, public interest and need also must be taken into account. If it is deemed that the need for the project is present, that no reasonable alternative locations are available, and that avoidance or minimization of wetland impacts is not practicable or economically feasible, the agencies will than consider compensation for wetland impacts through mitigation. Should mitigation be required for impacts, it can be in the form of wetland creation, wetland preservation, wetland enhancement, wetland restoration, or upland preservation. The amount of mitigation required is based on the type and condition of wetlands to be impacted and the type of mitigation proposed. SJRWMD is responsible for permitting projects other than single-family lots, certain industries, and landfills, which are regulated by Florida Department of Environmental Protection (DEP). SJRWMD exerts jurisdiction over all "waters of the State". Upland-cut ditches are also included under the jurisdiction of SJRWMD. An Environmental Resource Permit (ERP) would be required for development of this property, if wetlands impacts were proposed. The type of permit will depend on the amount of wetland area proposed for impact. A plan with wetland ENVIRONMENTAL SERVICES, INC. Page 3 Mr. Chuck Pula, Director Moss Road Property EC00031 12 September 2000 impacts can be permitted with a Standard General ERP or an Individual ERP. If wetland impacts are less than one acre and meet certain engineering requirements, then a Standard General ERP can be obtained. If this threshold is exceeded, an Individual ERP will be required. The difference between these two permits lies in the review process. A Standard General ERP is reviewed by the staff at the local SJRWMD office and is issued within 30 days of application completion. The Individual ERP is much more involved, requiring review by the SJRWMD Governing Board. This permit may take from three months to one year to obtain. If wetland impacts are avoided, then the project will require a stormwater only ERP from SJRWMD. SJRWMD categorizes wetland quality using values of 1 (low quality) to 5 (high quality) or on a verbal scale of low quality, low-moderate quality, moderate quality, moderately high quality, and high quality. SJWRMD mitigation ratios range accordingly from 1.5: 1 (mitigation: impact) to 5: 1 for wetland creation and restoration, 4: 1 to 20: 1 for wetland enhancement, 10: 1 to 60: 1 for wetland preservation, and 3: 1 to 20: I for upland preservation. In general, compensatory ratios for less degraded wetlands or portions of wetlands most likely will be in the middle to upper portions of the ranges while impacts to disturbed wetlands will be significantly lower. It should be noted that the SJR WMD regulations do not require mitigation for isolated wetlands less than 0.5 acre in size as long as the wetlands do not provide habitat for threatened and endangered speCIes. CE has jurisdiction over all isolated and connected wetlands. CE typically does not exert jurisdiction over upland-cut ditches. Impacts, through filling, to wetlands on the Moss Road site will require a permit from CE. The type of permit required will depend on the type and amount of impact. Impacts to the wetlands on this site, ifunder a total of 0.5 acre, may qualifY for a type of Nationwide Permit. However, due to the extent and distribution of wetlands on this site, if almost any type of development is proposed, this permitting option seems unlikely. Therefore, ESI believes that an Individual Permit will be applicable. An Individual Permit is more intensive, involves public input, and is more costly and time consuming. In general, an Individual Permit would require a 30-day public review and could take six months to more than one year to resolve, depending upon project sensitivity. Mitigation would also be a condition of permit issuance. Water quality certification is obtained through issuance of the SJR WMD permit. CE uses the Wetland Rapid Assessment Procedure (WRAP) as a guideline for assessing wetland quality and determining mitigation needs. WRAP produces a numerical value for a wetland which generally equates to the state's ranking system and which is used in evaluating the amount of functional wetlands lost. To determine the level of mitigation needed for CE, mitigation proposals must ensure that there is no net loss of wetlands function. Typically, a single mitigation plan can be developed that will satisfY both SJRWMD and CEo An exception to this typical consistency is in regard to wetland preservation. Generally, CE does not accept pure wetland preservation as mitigation for wetland impacts. ENVIRONMENTAL SERVICES, INC. Page 4 Mr. Chuck Pula, Director Moss Road Property EC00031 12 September 2000 Secondary impacts also will have to be addressed if any primary wetland impacts are proposed. Preventing secondary impacts to wetlands normally can be accomplished by placing upland buffers that average 25 feet in width around all remaining on-site wetlands. RELATIONSHIP OF DEVELOPMENT ALTERNATIVES TO PERMITTING We assessed the permitting feasibility, mitigation needs, and compensation costs associated with three development alternatives. These included two scenarios. The best case scenario would be one where impacts were limited to Wetland 4 and small portions, preferably those already disturbed, of Wetland 1. Starmer Ranaldi Planning & Architecture, Inc., (SRI) Site Plan Design A would be representative of the level of wetland impacts associated with a worst case scenario with about one-half of Wetland 1 impacted, but there would be no impacts to Wetlands 3 and 4. A second scenario might include impacts to up to one-third of Wetland 1 and to Wetland 4. Please note that a worst case scenario incorporating impacts to all of Wetland 1 was not included in our analysis because both Steve Brooker (CE) and Tony Miller (SJRWMD), during ESI's coordination with these agencies, stated that it was unlikely that permits would be issued for site plan designs proposing impacts to the entire Wetland 1 system. Assuming no alternative locations for the proposed park facilities were available, that a public need for the project could be shown, and that avoidance and minimization requirements could be met, Steve Brooker and Tony Miller suggested several mitigation options that might be available to compensate for wetland impacts on the subject site. These include on-site mitigation comprising combinations of wetland preservation, wetland enhancement, wetland creation, and upland preservation; off-site mitigation including purchase of property for preservation or enhancement within the Lake Jesup basin; or contribution of funds to ongoing Seminole County land acquisition programs; or a combination of on site and off site mitigation. CE and SJRWMD personnel stated that the amount of mitigation required would be directly related to the quality of the wetlands being impacted. Following is a summary of proposed impacts, potential mItIgation scenarios, and broadly estimated costs for mitigation representative of each of the design alternatives. We have assumed that to meet the objectives of each of the scenarios it will be necessary to impact some wetlands. Should wetland impacts be more or less than that presented for each scenario the mitigation requirements and costs will change accordingly. For planning purposes we have presented example ratios we believe are at the highest end of the range the agencies might require. The potential mitigation scenarios have been discussed with the agencies as hypothetical situations; however, if the project moves forward into actual permitting, it may be possible to negotiate with the agencies to reduce the ratios in light of the overall mitigation plan presented. In addition, the suitability and level of off-site mitigation will be dependent on the type of mitigation available; i.e., pure wetland preservation or a combination of wetland and upland preservation and enhancement. Based on CE's policy that, with few exceptions, they will not accept pure wetland preservation as mitigation, it will be necessary to find land that offers ENVIRONMENTAL SERVICES, INC. Page 5 Mr. Chuck Pula, Director Moss Road Property EC00031 12 September 2000 improvement options. However, for the purposes of providing you with the maximum potential level of costs associated with mitigation options, we have assumed that the only property available for off-site mitigation is pure wetland preservation and that we have convinced CE to accept this proposal as compensation for impacts to wetlands on the subject site. Consequently, it is possible that the amount of off-site land necessary to meet compensation needs could be less than those presented here and that costs would be reduced accordingly. Best Case (Neighborhood pool and facilities): Impacts Qualitv Example Miti2ation Ratios* E P U C Wetland 1 - 1.00 ac Moderately-low 8: 1 20:1 7:1 2:1 Wetland 4 - 0.82 ac Low 5:1 12: 1 5: 1 1.5: 1 * E=Enhancement P=Preservation U=Upland C=Creation On-Site Miti ation T e Preservation WI Preservation W3 Preservation U lands Enhancement WI Estimated Cost acts to W4 No future develo ment of the land No future develo ment of the land No future develo ment of the land Removal of plants and no future develo ment of the land $25,000 creation & plants ** $10,0005 yr monitoring plus maintenance No future develo ment of the land **$25,000 = earthwork + plant purchase + plant installation $10,000 = 5 annual monitoring events + annual monitoring report + maintenance of nuisance/exotic species. Please note that costs estimated for wetland creation are for lannin u oses only. Amount 9.51 acres 0.10 acre 3.07 acres 0.50 acre Credit Covers im 0.01 acre 0.44 acre 0.06 acre Wetland Creation 0.90 acre 0.45 acre On-Site and OfT-Site Mitieation Combination Type Amount Credit Estimated Cost Preservation WI 9.51 acres Covers impacts to W 4 No future development of the land Preservation W3 0.10 acre 0.01 acre No future development of the land Enhancement WI 0.50 acre 0.06 acre Removal of plants and no future development of the land Purchase Wetlands 19.00 acres 0.94 acre @ $3500/ acre; $66,500 (preservation only) ENVIRONMENTAL SERVICES, INC. Page 6 Mr. Chuck Pula, Director Moss Road Property EC00031 12 September 2000 Second Case (e.g. SRI Concept D): Impacts Quality Example Miti~ation Ratios" E p U C Wetland 1 - 0.50 ac Low 4: I 10: 1 3: 1 1.5: 1 Wetland 1 - 1. 00 ac Moderately-low 8:1 20:1 7:1 2:1 Wetland 1 - 2.00 ac Moderately High 12: 1 35: 1 17: 1 3: 1 Wetland 4 - 0.82 ac Low 5: 1 12: 1 5: 1 1.5: 1 * E=Enhancement P=Preservation U=Upland C=Creation On-Site and Off-Site Miti~ation Combination Type Amount Credit Estimated Cost Preservation WI & W3 7.51 acres Covers impacts to W 4 No future development of and 0.55 ac WI the land Preservation Uplands 3.07 acres 0.39 acre No future development of the land Enhancement WI 0.77 acre 0.09 acre Removal of plants and no future development of the land Purchase Wetlands 80.00 acres 2.48 acre @ $3500/ acre; $280,000 (Preservation only) Worst Case (e.g. SRI Concept A): Impacts Quality Example Miti~ation Ratios" E p U C Wetland 1 - 0.50 ac Low 4:1 10:1 3: 1 1.5: 1 Wetland 1 - 1.00 ac Moderately-low 8: 1 20:1 7: I 2:1 Wetland 1 - 5.50 ac Moderately High 12: I 35:1 17: 1 3: 1 * E=Enhancement P=Preservation U=Upland C=Creation ENVIRONMENTAL SERVICES, INC. Page 7 Mr. Chuck Pula, Director Moss Road Property EC00031 12 September 2000 On-Site and OfT-Site Miti2ation Combination Type Amount Credit Estimated Cost Preservation WI & W3 4.01 acres 0.5 acre No future development of the land Preservation Uplands 3.07 acres 0.39 acre No future development of the land Enhancement WI 0.82 acre 0.1 acre Removal of plants and no future development of the land Purchase Wetlands 203.00 acres 6.02 acres @ $3500racre; $711,900 (preservation only) Having outlined all of the above scenarios and assuming certain level of impacts we would like to emphasize that we believe that the best-case scenario can be permitted and mitigation completed that will be acceptable to the agencies. In fact, if we can reduce the amount of wetland impacts under this scenario it is likely that all mitigation can be completed on site while still leaving a portion of the uplands on the property for potential future development. It is also likely that the second scenario is permittable, however, it appears that with this option mitigation costs could become very expensive. The worst-case scenario would be difficult to permit and mitigation costs could be prohibitive. Please note that engineering and environmental permitting costs and permit application fees have not been incorporated into the above cost estimate scenarios. OTHER CONSIDERATIONS The extent and distribution of wetlands on the site would make it difficult and expensive to develop the land into a multiple use park providing active recreation facilities. Should development of the site into this kind of park prove to be unrealistic, other uses for the property might include use of the site as a passive recreational park; as mitigation for wetland impacts proposed for City of Winter Spring projects in other locations; or sale of the property to a private developer(s) for use as mitigation for wetland impacts within the Lake Jesup basin. Passive recreational use of the property such as nature and jogging trails, picnicking, and wildlife observation also is compatible with completing on site mitigation that includes preservation and enhancement of W3 and portions of WI such as with the best and second development scenarios. Although the tables above state that there can be no future development of areas preserved for mitigation, this does not preclude incorporating passive recreation and nature education into the areas set aside for conservation. ENVIRONMENTAL SERVICES, INC. Page 8 Mr. Chuck Pula, Director Moss Road Property EC00031 12 September 2000 SUMMARY A total of 11.83 acres of wetlands occur on the subject property. Should any of these wetlands be proposed for impact it will be necessary to obtain environmental permits from CE and SJRWMD and to complete compensation through mitigation for wetland impacts. If wetland impacts can be kept to a minimum, it is likely that mitigation can be completed on site. As wetland impacts become more extensive it will be necessary to complete mitigation as a combination of on-site and off-site activities or land purchases. Based on our various scenarios, we have estimated that mitigation costs potentially could become quite expensive, exceeding $700,000.00 and limiting future use of portions of the site set aside for conservation. Mitigation costs also can be assessed based on the individual wetlands. Following is a table that summarizes estimated mitigation costs per acre for each wetland and the total mitigation cost for each wetland. We have included in this table costs per acre for Wetland 1 under the various scenarios outlined earlier and also assuming impacts to all of Wetland 1. Please note that while we have estimated the cost to mitigate for impacts to Wetland I in its entirety, it is unlikely that CE and SJR WMD will issue a permit for this level of impact to Wetland 1. Estimated Mitigation Costs Per Acre By Wetland Wetland Size Impact Mitigation Cost per Total Mitigation Cose (acres) Acreage Acres acre2 Needed! 1 10.91 10.91 354 $113,565.00 $1,239,000.003 1 10.91 1 20 $70,000.00 $70,000.00 1 10.91 3.5 95 $95,000.00 $332,500.00 1 10.91 7 218 $109,000.00 $763,000.00 2 Surface water - no mitigation required 3 0.1 Less than 0.5 acre - most likely no mitigation required 4 0.82 0.82 9.8 $34,300.00 $34,300.00 1 Mitigation acres needed was derived from evaluating quality of the wetland proposed for impact and assuming that the only mitigation available is off-site preservation of wetlands. 2 Costs per acre and total mitigation costs were calculated using a cost of $3500.00 per acre for purchase and assuming that mitigation available consists only of wetland preservation. 3 It is unlikely that the CE and the SJRWMD will permit impacts to Wetland 1 in its entirety. ENVIRONMENTAL SERVICES, INC. Page 9 Mr. Chuck Pula, Director Moss Road Property EC0003l 12 September 2000 It is likely that we can acquire permits for development of the site into a neighborhood water playground and/or passive recreational park while keeping mitigation costs to a minimum. When considering the feasibility of developing the site please keep in mind that the site may also have value as mitigation for other City of Winter Springs projects or for sale as mitigation to private developers. We hope that this letter allows you to analyze your options regarding the Moss Road property. Should you have any questions please do not hesitate to contact me. In addition, I would be happy to meet with you to review the scenarios presented here and to be available to the Board should they have any questions. Sincerely yours, ENVIRONMENT AL SERVICES, lNe. ~ --Y~ Linda A. Olson, MS, CWD Assistant Vice President CC: Bill Starmer - Starmer Ranaldi Planning & Architecture, Inc. EC00031/mit let rev e. sri ATTACHMENT 113 12 Sept 00 Chuck Pula, Director Park and Recreation Department City of Winter Springs 1000 East SR 434 Winter Springs, Florida 32708 Re: Moss Road Property Chuck We have reviewed the Environmental Services, Inc. report dated 23 Aug 00 and respond accordingly. The report clearly demonstrates that development of this site is possible through various permitting mechanisms and the bottom line becomes whether development of this site for recreation purposes is practical or not. Looking at the attached site concept scheme D, the mitigation cost is approximately $ 280,000 for' 4.5 acres of land and looking at the attached site concept scheme A, the mitigation cost is approximately $ 710,000 for 6.5 acres ofland. . This represents a land cost of$ 62,200 and $ 109,200 per acre respectively for the two scheme's above and the question that begs to be asked is, can land be purchased in an acceptable area within the City for similar money. In our opinion the development of this property for sport and recreational fields, is likely not an appropriate use for several reasons: . . 1. the mitigation cost above do not include environmental consulting and permitting fees, thus the per acre cost will increase somewhat 2. in our opinion there maybe suitable land that could be purchased within the City, for additional recreational use at similar or less per acre cost . 3. there may be the perception from some entities within the City, that would consider the disruption of wetlands for recreational activities to be a inappropriate use of local government funds We realize this review of the report is brief but we understand that a presentation of the report will be held during the 25 Sept 00 City Council meeting and we would be happy to attend if you would like any additional oughts this matter. ~s . t Presi ent Starmer Ranaldi Planning and Architecture Inc. 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