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:
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ATTACHMENT H2
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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
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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. AA-002984
890 Northern Way Suite E-) Winter Springs, Aorida 32708 Phone 40l977.1 080 Fax 407 977 1019
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~Q~~ept d
NT5
.
sri
2~ APR =