EAC LDC Subcommittee Agenda 10/11/2007 EAC LDC
Subcommittee
October 11, 2007
9:30 a.m.
Development Services Center Room 609
1. Review/Change to Agenda
2. Committee Discussion:
Preserve Management Plan Revisions (Policy 6.1.1 (6) CCME GMP)
Stormwater Uses Criteria in Preserves (Policy 6.1.1 (5) b CCME GMP)
3. Public Comments
4. Setting Next Meeting Date(s)
5. Adjournment
In addition to the opportunity for the general public to speak during "Public Comments", any member of the
general public will be allowed to speak on each Agenda item before the Committee takes any action or moves
on to the next item of the Agenda.
1
EAC LDC Subcommittee meeting dates
Collier County Community Development and Environmental Services
Division
Room 609
9:30 a.m.
August 29, 2007 -Wednesday
September 13, 2007 - Thursday
September 27, 2007 - Thursday
October 11, 2007 - Thursday
October 31, 2007 - Wednesday
November 27, 2007 - Tuesday
December 13, 2007 - Thursday
December 27, 2007 - Thursday
January 10, 2008 - Thursday
January 24, 2008 - Thursday
February 14, 2008 - Thursday
February 28, 2008 - Thursday
March 13, 2008 - Thursday
March 27, 2008 — Thursday
Revised October, 2007
EAC LDC
Subcommittee
October 11, 2007
9:30 a.m.
Signup sheet
Name E-mail address
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EAC LDC Subcommittee
Meeting Summary
October 11, 2007 meeting
9:40a.m. until 11:30 noon
Attendees: Judith Hushon, Richard Miller, Bruce Layman, Alison Huber, Stephen
Lenberger, Debbie Tyson, Jennifer Hecker,Nick Penniman, Lauren McCulloch, Mac
Hatcher, Andy Woodruff
Attendees discussed EAR-based Amendments identified for discussion during the last
Subcommittee meeting. Items discussed included the following.
Stormwater in preserves
Review stormwater language proposed by Bruce Layman
Mixed wetland and upland
Control elevation important
10 year storm is what we should design for
Ponding in uplands a concern
No berming around uplands
Meet additional SFWMD water treatment standards without impacting preserves
Drained wetlands should be re-hydrated
Need to re-hydrate upland preserves where drainage has occurred due to canals
Storm events can affect water elevations downstream in wetlands and uplands in the
same drainage basin.
Use of impervious pathways for wheelchair access and for use such as bicycles should be
allowed in preserves. Promotes use of preserve.
Soil survey good tool
Soils need to be verified in the field
Deviation vs. administrative process
Legal issue regarding EAC and if they can review of water management aspects of
projects
EAC can review impacts to uplands and listed species
150% water treatment— SFWMD allows some treatment in preserves (after first inch of
rainfall)
Need to evaluate
Full treatment needs to occur prior to discharge into preserves
SFWMD guidelines seem to be working, no problem cases identified
Preserves at the new County regional park may have too much water, among
other problems.
Problems exist but can't pinpoint problem to just stormwater
Should have to prove ecological benefit
County could be more restrictive than SFWMD
Preserve management plans
Review preserve manager language change proposed by Bruce Layman
Maintaining 30% coverage of mid-story for RCWs has been used for management of
sites and has been approved by Jim Beever when he worked for the FFWCC
5 yr interval for area with grassy understory
Possibly more frequent for areas with dense midstory
Brush hogging can be used to maintain grass layer
Proposed LDC text change to reflect staff intent (re. preserve manager) Page 1 of 1
From: Bruce Layman [mailto:BruceLayman@wilsonmiller.com]
Sent: Wednesday, May 23, 2007 3:54 PM
To: mason_s
Cc: Tom Trettis
Subject: Proposed LDC text change to reflect staff intent (re. preserve manager)
«189069v3.DOC»
Susan,
Following is the rationale for revising the existing LDC text to reflect what we believe was staff intent:
In conversation with you in May 2007 regarding the intended responsibility and liability of preserve managers, you
stated that preserve managers have no legal liability if there are non-compliance issues found within a preserve.
Rather, the preserve manager was intended to function as a source of guidance for the owner to advise the owner
of how to maintain preserves in compliance with permit conditions, or to advise them of how to responsibly
remedy non-compliance issues.
LDC section 3.05.07 H.1.g.iii, however is currently written to suggest that the "Preserve Manager shall be
identified as the responsible party to ensure that the Preserve Management Plan is being complied with."
Additionally, the code states that"both parties" (i.e., the preserve manager and the owner) "will be
responsible..." Further it later states that the "homeowner's association and the preserve manager shall be
responsible for the annual maintenance of the preserve..."
The text, as written could easily be interpreted by an average person to implicate the preserve manager as liable
if compliance issues arise, based upon the LDC text noted above. As a result, we have drafted a revision to the
existing text that identifies the owner as the party responsible for compliance with permit conditions and the
preserve manager as responsible for offering guidance to the owner as it relates to preserve maintenance.
The blue text reflects new text, or text that was moved from another location within the original paragraph; red text
reflects deletions; and the black text remains unchanged from the original code.
Please let me know if staff decides to carry this forward and if so, when, and whether the text proposed by staff
will be the same as what we proposed.
Thanks very much. We're eager to provide input, particularly if it will help clarify the intent of the code.
Thanks.
Bruce
Confidentiality Notice: This e-mail is for the sole use of the recipient(s). Any unauthorized review,
use, disclosure or distribution is prohibited.
file://C:\Documents and Settings\mendicino c\Local Settings\Temporary Internet Files\OL... 10/8/2007
03.05.07 H.1.g.iii. Designation of a Preserve Manager. The Preserve Manager shall be
responsible for providing the developer (property owner) with technical assistance regarding
compliance with the Preserve Management Plan. A Preserve Manager shall be idcntificd as the
minimum, the Preserve Manager shall have the same qualifications as are required for the
author of an EIS, as set forth in section 10.02.02 A.3. The individual's name, address and
phone number shall be listed on the Preserve Management Plan. The same information shall
be provided regarding the developer. The developer shall be identified as the responsible party
to ensure that the preserve Management Plan is being complied with. Both parties The
developer will be responsible until such time that the homeowners association takes over the
management of the preserve. At that time, the homeowners association shall amend the plan to
provide the homeowner association information and information regarding the persons Preserve
Manager hired by the association. to manage the preserve. The homeowner's association and
the preserve manage shall be responsible for annual maintenance of the preserve, in
perpetuity.
5/22/2007-189069-Ver:2-TKING
CA#43
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via son i er
MEMORANDUM
TO: EAC LDC Subcommittee
rt t
FROM: Bruce Layman "
-A A CK
DATE: 22 September 260-7---- —
SUBJECT: Points for Discussion in Drafting/revising Stormwater Use Criteria in Preserves
In order to move forward in drafting this code, there is some important information that is worthy
of consideration, so that at the end of the day, we'll have a drafted responsible code that
furthers staffs'direction and minimizes the potential for unintended consequences.
There are six points, followed by proposed revisions to the EAC-approved code from last year.
The purpose of the six points is to support/defend the proposed revisions.
Base Information:
1. The approved GMP states in Policy 6.1.1.(5)(a), that" Passive recreational uses that do not
impact the minimum required vegetation or cause a loss of function to the preserve area. Loss
of function to the preserve area includes a reduction or a change in vegetation within the
preserve and harming any listed species present in the preserve."
This requirement is equally applicable to wetlands and uplands. Don't make either too dry or
too wet at risk of changing their vegetative composition.
2. The approved GMP states in Policy 6.1.1.(5)(b), that"Discharge to preserves having
wetlands requires treatment that will meet water quality standards as set forth in Chapter 62-
302. F.A.C. and will conform to the water quality criteria requirements set forth by the South
Florida Water Management District."
Freshwater wetlands typically need more water than directly falls on them to support their
hydroperiod and depth of inundation. Water falling on natural adjacent uplands charges the
water table and/or runs off to the low point on the landscape (i.e., the wetlands). If the uplands
get developed, much of the rain falling on the now-developed uplands no longer seeps into the
water table or runs off to the wetlands; it is shunted to the water management system (typically
lakes) before it is discharged off site. The net result is that the preserved wetlands can become
underhydrated unless they are incorporated into the project's stormwater management system.
This is why preserves containing wetlands, that have been permitted by SFWMD over the past
20+ years, have often been incorporated into the water management systems. If this practice
was inappropriate, there would be examples of vegetation dying as the result of the excess or
inappropriate water application. Such examples have yet to surface.
3. The LDC (3.05.07.A.1) and the GMP (6.1.1.(2)) now direct that preserves used to satisfy the
native vegetation retention requirement need to be designed "emphasizing the largest
contiguous area possible".
As a result, if there are wetlands located on site that are preserved, the potential is very high
that a single preserve could include wetlands, uplands that surround and are adjacent to the
wetlands (i.e., buffers), and uplands not immediately adjacent to the wetlands.
4. The importance of detention for stormwater on site has been repeatedly discussed in
relation to the health of downstream water bodies, including canals, rivers, lakes, and estuaries.
This could be in the form of decreased turbidity and current, increased water quality, and in the
case of estuaries, freshwater influence. Experts have suggested that responsible detention of
stormwater is a very positive project design feature for the health of the regional system.
5. In Southwest Florida, all but the driest uplands typically experience standing water or
saturated soil conditions. The frequency varies seasonally and the extent is a gradation. There
are no absolute natural physical boundaries, such as soil map polygons, that can define how
wet something should or should not be. Soils maps were generated on a very large gross
scale. As a result, the author of the maps has pointed out the need to assess in situ conditions
in order to determine (approximate) actual hydrologic conditions.
6. Based upon LDC section 8.06.03.0.2, "the surface water management aspects of any
petition, that is or will be reviewed and permitted by South Florida Water Management District
(SFWMD), are exempt from review by the EAC", it appears that if there is a deviation that would
go before the EAC through the appeal process, and the deviation is the result of the surface
water management design of an approved SFWMD ERP, the EAC would not have the authority
to review it. This may require a legal determination.
Given the discussion, above, in relation to the proposed LDC text from last year's EAC
approval, I'd like to propose the following revision in order to both retain the spirit of the EAC
text, and avoid some unanticipated pitfalls of the prior text.
Proposed Text Revisions:
3.05.07 Preservation Standards.
H. Preserve standards.
1. Design standards.
* * * * * * * * * * * *
h. Allowable uses within preserves. For the purposes of this Section, preserves are those
areas that fulfill the native vegetation retention standards and criteria of Section 3.05.07.
Wetland preserves are those containing SFWMD wetlands, or wetlands and uplands, and
upland preserves are those containing only uplands. Only the following uses subject to the
associated design criteria have been determined to ensure that the ecological functions of the
preserves are maintained and are allowed within preserves.
Passive recreational uses subject to the following criteria.
a) Passive recreational uses are allowed within preserves, as long as any clearing required
to facilitate these uses does not impact the minimum required native vegetation. These uses
would allow limited access to the preserve, in a manner that will not cause negative impacts to
the preserve. Allowed uses include, but are not limited to, pathways, benches and educational
signs. Fences and walls are prohibited within the preserve.
ii. Treated stormwater subject to the following criteria.
a) Treated stormwater shall be allowed in wetland preserves in accordance with an
approved SFWMD Environmental Resource Permit(ERP), or in accordance with SFWMD
water quality treatment guidelines if an approved ERP does not require preservation of said
wetland(s), so long as it will not negatively affect listed species present.
b) Stormwater may be allowed in upland preserves at a frequency, duration, and depth
similar to a typical un-impacted community type of similar vegetative composition, so long as it
will not negatively affect listed species present.
c) Discharge of treated stormwater into a preserve shall be in a controlled manner to
prevent erosion, scour, and to promote even distribution.
d) When stormwater is allowed in preserves, the associated stormwater facilities such as
berms, swales, or outfall structures, may be located within the preserve, but the area of such
facilities can not count towards the native vegetation preservation requirement pursuant to
Section 3.05.07 of the LDC. These facilities are not subject to setback requirements as found in
Section 3.05.07.H.3 of the LDC. These facilities must be placed under a drainage easement.
e) Where stormwater is allowed in a preserve, the Preserve Management Plan as required
in Section 3.05.07.H.1.g of the LDC must address preserve maintenance and shall provide a
monitoring program comparable to SFWMD guidelines.
f) Stormwater shall be allowed in preserves containing uplands in the RLSA-WRA areas
in accordance with section 4.08.00 Rural Lands Stewardship Area Overlay District standards
and Procedures.
g.) A property owner may request an administrative deviation from the above regulations,
3.05.07.H.1.h.ii. Staff shall review the plans and proposed deviations to ensure wetlands in the
preserve will receive a benefit and uplands in the preserve will receive no adverse impact from
the deviations being proposed. If the deviation cannot be resolved administratively and it
involves a preserve that has no jurisdictional oversight by SFWMD for review or permitting, the
process for granting deviations shall follow the procedure as set forth in the Appeal section
(10.06.00???or 8.06.10???)for the EAC, and shall be heard ata public hearing of the EAC.
There is one last point that we as a group have not really discussed. The code, in section
3.05.07.H.1.h.i.a, requires paths in preserves to be pervious. In a county that is not rich in
boardwalks, paths, or even bike trails, does the impervious nature of a path outweigh the
benefit gained by providing convenient ADA access or access to outdoor activities like roller-
blading, bicycling, or stroller-jogging? My thinking is that if there is anything that we can do to
promote outdoor activities such as expanding the potential uses of such paths, we should
�-. seriously consider it.
3.05.07 Preservation Standards. 4 (Formatted:Tabs: 2.98",Left )
H. Preserve standards.
1. Design standards.
* * x * * * • * t + 4 *
h. Allowable uses within preserves. For the purposes of this Section,
preserves are those areas that fulfill the native vegetation retention standards Deleted:any
and criteria of Section 3.05.07. Wetland preserves are those containing SFWMD wetlands,or peter_ rvied:,such as .
wetlands and uplands,and uplandpreserves are those containing only uplands. Only the petered.peous
following uses subject to the -
associated design criteria have been determined to ensure that the ecological Deleted:Fences may be utilized
9 g outsidetl
functions of the preserves are maintained and are allowed within preserves. of the preserves to provide protection
• in the preserves in accordance with
i. Passive recreational uses subject to the followingcriteria. they
I protected species section 3.04.01
D.1.c.
a) Passive recreational uses are allowed within preserves,as long as any Deleted only
clearing required to facilitate these uses does not impact the minimum required Deleted: we'llthawe'llnative vegetation.These uses would allow limited access to the preserve,in a • comprised of jurisdictional wetlands
manner that will not cause legative impacts to the preserve.Allowed uses jnclude,but are not uplands comprised solely of hydric
soirstl
limited to. as mapped in the Soil Survey of
pathways,benches and educational signs.,Fences and walls are prohibited within i collier County Area,Florida,(USDA,
the preserve. up 199Ends that serve as buffers around
the wetland,
ii. Treated stormwater subject to the following criteria. Deleted:the
a) Treated stormwater shall be allowed,in wetland preserves jn accordance with aa. • Deleted:a combination thereof
approved SFWMD Environmental Resource Permit(ERP),or,in accordance with SFWMD water Deleted:shall not
quality treatment guidelines if an approved ERP does not require preservation of said Deleted:discharged into
wetland(s),so long as it will not negatively affect listed species present. Deleted:utilized by¶
listed species. Stormwater shall be
b) Stormwater may,be allowed in,upland preserves at a frequency,duration,and depth allowed yr jurisdictional wetland
preserves¶
similar to a typical unimpacted community type of similar vegetative composition,so long as it with fisted species,but shall have no
will not negatively affect listed species present, negative impact on those listed
species
c) ,pischarge of treated stormwater Deleted:Stormwater entering the
preserve must be treated to meet the
into a preserve shall be in a controlled manner to prevent erosion,scour,and waters
to promote even distribution. i quality volumetric requirements of
Section 5.2.1(a)of the Basis of
Review Form
d) When stormwater is allowed in preserves,the associated stormwater Environmental Resource Permit
facilities such as berms,swales,or outfall structures,may be located within Applications Within the South Florida
the preserve,but the area of such facilities can not count towards the native waterll
Management District,(SFWMD
vegetation preservation requirement pursuant to Section 3.05.07 of the LDC. February 2006).
These facilities are not subject to setback requirements as found in Section Formatted:Font:5 pt
3.05.07.H.3 of the LDC. These facilities must be placed under a drainage
easement.
e) Where stormwater is allowed in a preserve,the Preserve Management Plan
as required in Section 3.05.07.H.1.g of the LDC must address preserve, Deleted:poor
maintenance,and shall,provide,a monitoring program comparable to SFWMD guidelines. Deleted:problems
f) Stormwater shall be allowed in,preserves containing uplands in the RLSA-WRA areas Deleted:also
in accordance with section 4.08.00 Rural Lands Stewardship Area Overlay District �Ddaeed:br
standards and Procedures. (Deleted:upland
g.) A property owner may request an administrative deviatiog,from the above regulations, (Deleted:s
3.05.07.H.1.h.ii. Staff shall review the plans and proposed deviations to
ensure wetlands in the preserve will receive a benefit and uplands in the
preserve will receive no adverse impact from the deviations being proposed. If the deviation
cannot be resolved administratively and it involves a preserve that has no jurisdictional
Del
oversight by SFWMD for review or permitting, e ( retell:d:T
process for granting deviations shall follow the procedure as set forth in the
Appeal section(10.06.00???or 8.06.10???)for the EAC,and shall be heard at a public hearing
of
the EAC.
Formatted:Font:5 pt
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