Agenda 09/29/2009 Item #10A
Agenda Item No. 10A
September 29, 2009
Page 1 of 51
EXECUTIVE SUMMARY
Recommendation to consider the Habitat Conservation Plan Advisory
Committee's Habitat Conservation Plan application for red-cockaded
woodpeckers.
OBJECTIVE: To have the Collier County Board of County Commissioners (BCC) consider
the Habitat Conservation Plan Advisory Committee's Habitat Conservation Plan (HCP)
application for red-cockaded woodpeckers.
CONSIDERA TION: The BCC adopted Resolution 2005-174 establishing the Habitat
Conservation Plan Ad-hoc Advisory Committee with the primary purpose to assess the
feasibility of a Habitat Conservation Plan to address red-cockaded woodpeckers (RCWs).
Subsequent to this resolution, the BCC adopted Resolution 2006-41 to add additional members
to the Committee and to broaden the scope of an HCP to be a multi-species plan that, depending
on geographical scope, would need to address more listed species than just RCW s. In October of
2008, the BCC adopted Resolution 2008-307 to reduce the number of members from thirteen to
nine and directed the committee to complete a Habitat Conservation Plan (HCP) for the red-
cockaded woodpecker (RCW). The resolution also included that the committee would sunset on
September 12, 2009.
The committee has developed an HCP for RCWs as directed and asks the Board to consider
submitting it to the U.S. Fish and Wildlife Service (FWS) for review and approval. In a series of
motions for additional changes, the committee approved the HCP in a 4:3 vote:
Ms. Katz amended the motion to approve the Plan (Draft Habitat Conservation Plan For Red-
Cockaded Woodpeckers" dated August 4,2009) subject to the changes discussed herein by the
Committee and the language requested by Mr. Anderson be incorporated into Section 1.5 -
Plan Area. Second by Mr. Bartareau.
The objective of this HCP would be to create an efficient and effective mechanism for providing
listed species protection ofRCWs in Collier County consistent with the Endangered Species Act.
The HCP is attached to this Executive Summary.
Staff reviewed the HCP to ensure it can be implemented according to current regulations. Staff
notes the Committee has included that applicants for Agricultural Clearing Notifications would
need to comply with the HCP's survey and mitigation requirements (HCP Section 5.6(1)).
County Attorney's Office staff has stated that review staff will not be able to mandate this
requirement due to state Right to Farm Act regulations. Staff can inform applicants of their
responsibilities for Endangered Species Act and other environmental regulatory requirements,
but cannot hold Agricultural Clearing Notifications until such permits are obtained by applicants.
FISCAL IMP ACT: The majority of County expense for the HCP will be in staff time to solicit
agency approval and to implement the HCP. Staff time will be required to move the HCP
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Agenda Item No. 10A
September 29, 2009
Page 2 of 51
through the approval process with the FWS. The amount of time is dependent on many factors
which make it difficult to assess approximately how much staff time would be needed. First, the
HCP will need to be certified, meaning it meets the issuance criteria. FWS will need to agree
that it is biologically sound and that they agree with the take, minimization and mitigation
proposed. A key component for which FWS will be reviewing the HCP is funding assurance.
For this HCP, there will need to be funding for staff to facilitate the HCP and money to manage
lands for mitigation under Conservation Collier. Another factor of the time required is whether
or not it is considered "low effect" under the federal National Environmental Policy Act (NEP A)
rule, which can add an additional two years on the approval time. The final foreseeable time
factor will be the amount of time it takes for the County to negotiate with the FWS for a final,
approved HCP.As a result of the approved HCP, staff time reviewing permits in the North Belle
Meade Overlay (NBMO) can be expected to increase by three to four times the current amount
spent by Environmental staff reviewing building permits for the NBMO, approximately five to
twenty hours depending on acreage of impacts and amount and type of mitigation needed.
However, with an approved HCP, property owners/applicants will have a "One Stop Shop" and
would work directly with County staff rather than FWS staff for RCW based impacts and with
that overall total review time should be significantly shortened. Additional staff time would be
needed for educating property owners, monitoring mitigation sites and coordination with other
agencies to oversee implementation and effectiveness of the plan. Staff would also need to
maintain GIS maps of the area, and report to the BCC in 10 years.
GROWTH MANAGEMENT IMPACT: Amendments to the Conservation and Coastal
Management (CCME) and Future Land Use Elements (FLUE) would be needed. Goal 7 of the
CCME would need to be changed to reference the HCP in the policy addressing RCW
management and the FLUE policy on North Belle Meade Receiving Lands would need to be
changed to reference the HCP since this section of the county is exempt from county
environmental review. Subsequent Land Development Code amendments would be needed to
implement the mitigation requirements of the HCP.
LEGAL CONSIDERATIONS: From the inception of this Committee, the County Attorney
expressed concerns that the adoption of a Habitat Conservation Plan (HCP) would expose the
County to litigation, both for wrongful issuance of a permit, as well as wrongful denial, in
regulating an area that is already regulated by both state and federal law. These concerns remain.
This is a legislative matter requiring no ex parte disclosures and simple majority vote of the
Board of County Commissioners. Implementing this plan will require amending the Land
Development Code. (JAK/STW)
RECOMMENDA TION: That the Board of County Commissioners consider the attached
Habitat Conservation Plan from the Habitat Conservation Plan Advisory Committee and provide
direction to the County Manager or his designee for subsequent actions.
PREPARED BY: Laura Roys Gibson, Senior Environmental Specialist, Engineering &
Environmental Services
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Agenda Item NO.1 OA
September 29, 2009
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COLLIER COUNTY
BOARD OF COUNTY COMMISSIONERS
Item Number: 10A
Item Summary: Recommendation to consider the Habitat Conservation Plan Advisory Committees Habitat
Conservation Plan application for red-cockaded woodpeckers. (Laura Roys Gibson, Sr.
Environmental Specialist, Engineering and Environmental Services Department, CDES)
Meeting Date: 9/29/20099:00:00 AM
Prepared By
Laura A. Roys Environmental Specialist Date
Community Development & Environmental Services 8/19/20099:10:55 AM
Environmental Services
Approved By
Judy l'Lilg Operations Analyst Date
Community Development & Community Development & 8/20/20094:14 PM
Environmental Services Environmental Services Admin.
Approved By
William D. Lorenz, Jr., P.E. Environmental Services Director Date
Community Development & Environmental Services 8/26/200910:50 AM
Environmental Services
Approved By
Steven Williams Assistant County Attorney Date
Attorney's Office Attorney's Office 8/31/2009 11 :00 AM
Approved By
Community Development &
Joseph K. Schmitt Environmental Services Adminstrator Date
Community Development & Community Development &
Environmental Services Environmental Services Admin. 8/31/20094:46 PM
Approved By
Jeff Klatzkow County Attorney Date
County Attorney County Attorney Office 9/4/2009 11 :03 AM
Approved By
OMB Coordinator OMB Coordinator Date
County Manager's Office Office of Management & Budget 9/16/20099:25 AM
Approved By
Mark Isackson Budget Analyst Date
County Manager's Office Office of Management & Budget 9/17/200912:26 PM
Approved By
Leo E. Ochs, Jr. Deputy County Manager Date
Board of County
Commissioners County Manager's Office 9/18/20094:52 PM
file:/ /C:\Agendatest\export\] 35-September 29, 2009\ 1 O. COUNTY MANAGER REPORT\]... 9/23/2009
Agenda Item NO.1 OA
September 29, 2009
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September 15, 2009
To: Board of Collier County Commissioners (BCC)
From: Habitat Conservation Plan Advisory Committee
Re: Draft Red-Cockaded Woodpecker (RCW) Habitat Conservation Plan
This memorandum summarizes the work of the Habitat Conservation Plan Advisory
Committee (HCPAC) since the Collier County Commission meeting of October 14,
2008. The membership of our committee has changed markedly since our last appearance
before this board and Judith Hushon was elected chair and Amber Crooks as vice chair.
The HCP AC has met at least monthly and has scheduled numerous subcommittee
working sessionslcimeet our September 2009 deadline.
As directed, we have prepared a Habitat Conservation Plan (HCP) for red-cockaded
woodpeckers (RCWs). Under this plan, the County will be the holder of an Incidental
Take Permit, which will give the County the right to issue permits which may result in
"take" of RCW s or their habitat for proposed projects within the North Belle Meade
Overlay.
Red-cockaded woodpeckers, their nests, and other habitat are regulated by the
Endangered Species Act (ESA). This HCP, when finalized, will provide relief from
liability under the ESA if the County grants building or clearing permits in an RCW area
which may potentially result in a "taking" of RCW s. Clearing restrictions are currently
established in the Collier County LDC and minimization/mitigation requirements for
"taking" of listed species currently exist within the ESA. This HCP will allow for
remaining RCW and their habitat to be preserved and will provide a streamlined system
for clearing and development to also occur. The goals of the HCP are to provide for:
1. No net loss or to increase and enhance existing RCW population size.
2. To maintain viable RCW habitat through perpetual, pro-active, habitat acquisition and
management.
3. To minimize conflicts between private landowners and the RCW management
program.
The HCP AC recently held a public neighborhood meeting with over 20 stakeholders of
the North Belle Meade Overlay area. There was a lively exchange of ideas and many
stakeholder comments or concerns have been addressed in this version of the HCP.
It is our goal to have this HCP move forward for formal review with the USFWS, a
process that can take several years and may result in modification of this present draft
before it is presented for your final signature. The term of the HCP AC will have to be
extended to accomplish this. With your approval, the HCP AC can also prepare and apply
for a Section 6 grant from the USFWS to cover the cost our remaining activities.
"",.,-
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HABIT A T CONSERV A TION PLAN FOR RED- COCKADED
WOODPECKERS IN COLLIER COUNTY
1. Introduction and Background
1.1 Overview
Southern Collier County, Florida is home to a small population of Picoides borealis
more commonly known as red-cockaded woodpeckers (RCW); this is a bird species
that is currently protected as an "endangered" species under the federal Endangered
Species Act and as a "species of special concern" under the Florida Code. To
provide for the welfare of these birds and to ensure that development does not further
endanger them, Collier County i_s proposing this Habitat Conservation Plan (HCP)
which calls for maintaining and improving their habitat as well as translocating birds
from private to protected lands if they are threatened by development permitted
under the Collier County Land Development Code (LDC).
1.2 Purpose of HCP Effort
The goal of this HCP is to ensure the long-term viability of the RCW in Collier
County, Florida through the preservation of sufficient nesting and foraging habitat to
allow the population to thrive and grow.
1.3 Permit Duration
This permit will be in effect for 30 years, but will be subject to review at 10-year
intervals to consider RCW population requirements and habitat options.
1.4 Regulatory Framework for the HCP
Collier County's LDC contains a section entitled "Protection of Threatened and
Endangered Species" (3.04) that includes red-cockaded woodpeckers in addition to a
number of other threatened and endangered species listed under the Federal
Endangered Species Act (ESA) and the Florida Code. In this section, language
referencing the USFWS 2003 Species RecovelY Plan for the Red-Cockaded
Woodpecker and this Habitat Conservation Plan and its provisions needs to be added.
Collier County will be the holder of an Incidental Take Permit, which will give the
County the right to issue permits that may result in take of red-cockaded woodpeckers
and their habitats and to manage mitigation activities. The concept of "take" is
discussed further in Section 4 of this HCP. The terms of this HCP will generally be
triggered when a vegetation clearing or agricultural clearing permit application is
received, so cross references will be required in those sections of the LDC.
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In this HCP, a map of areas of concern is proposed for inclusion in section 3.04.02 E
of the Collier County Land Development Code (LDC) along with procedures for
determining when various mitigation measures are appropriate. The mitigation
measures are based on the parcel size, proposed clearing or habitat-impacting
activities, and the location of the parcel. In Collier County the only currently
documented occurrences of RCW s on private lands are in the North Belle Meade
Overlay (NBMO) area. Section 2.4.1 of this HCP contains details on how this map
was constructed. The mitigation requirements are discussed in greater detail in
Section 5.6 of this HCP.
In addition, those sections dealing with clearing or vegetation removal will need to
include cross references to the requirements for RCWs. These include:
2.03.08 Rural Fringe Mixed Use (RFMU) ReceivingLands
2.a (3)(1) Allowable Uses-Agricultural Uses
3.a (l)(a) Neutral Lands Agricultural Uses
4.a (l)(a) Sending Lands Agricultural Uses
3.05.00 Vegetation Removal
3.05.02 C Agricultural Exemption
3.05.03 North Belle Meade Overlay (NBMO)
3.05.05 Criteria for Removal of Protected Vegetation
10.02.06 D Agricultural Land Clearing
Finally, definitions of Cluster, Foraging Area and Cavity Trees need to be added to
section 1.08.02 Definitions.
Cavity Tree - Any tree containing 1 or more cavities exhibiting fresh pine resin
associated with cavity construction, cavity maintenance, or resin well excavation by red-
cockaded woodpeckers. Any tree containing 1 or more artificial or constructed cavities
for red-cockaded woodpeckers.
Abandoned Cavity Tree - A cavity tree that has not been demonstrated to be in
active use by RCW s for five or more years.
Cluster - Grouping of at least 4 active and/or inactive suitable cavity trees in
proximity to each other supporting a breeding population and including nesting and
foraging habitats. A suitable cavity has a single entrance, an entrance tunnel that is
not enlarged, a cavity chamber that is not enlarged, a solid base, and is dry and free of
debris. The total cluster area is considered to include a minimum convex polygon
containing all of the group's cavity trees and the 61 m (200 ft) buffer surrounding that
polygon. The minimum cluster area size is 4.05 ha (10 ac).
Foraging Area - consists of mature pines with an open canopy, low densities of
small pines, little or no hardwood or pine midstory, few or no overstory hardwoods,
and abundant native bunchgrass and forb ground covers.
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Collier County has the right to charge for a vegetation clearing permit and this charge
could be specifically modified to cover the cost of a wildlife survey/site inspection by
County environmental personnel for properties located in potential habitat areas
within the NBMO.
1.5 Plan Area
The non-conserved area of Collier County where most of the known RCW habitat is
located and where RCW activity has been observed is known as North Belle Meade.
The North Belle Meade study area consists of approximately 15,960 acres of mixed
use and forested areas within sections 24,25,26 and 36 of Township 49 South, Range
26 East and Sections 13-15 and 19-36 of Township 49 South, Range 27 East and is
shown in Figure 1.
NORTH BELLE MEADE RCW HABITAT SURVEY
Legend
RCWHmiltl: RCWC.wti8s
_<>'0, ~ RCWC..ntyT'Mf
- + WMRC.....01
~ Axall'linO. . USfW RCW 03
~ , OIS , j , j M'..
Figure 1
North Belle Meade RCW Habitat Survey
There are two main RCW Management Units that are separated by natural or man
made features such as cypress forests, open pasture land or development features
(Collier County North Belle Meade Overlay Habitat Recovery Plan for the Red-
cockaded Woodpecker, 2003). Management Unit A is located in the western portion
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of the study area and includes Sections 24,25 and 36 of Township 49 South, Range
26 East and the western portions of Sections 30 and 31 in Township 49 South, Range
27 East. Management Unit B is located to the east and includes Sections 20, 29 and
32 and the eastern portions of Sections 30 and 31, and the western portion of Section
33 in Township 49 South, Range 27 East, Sections 14-15,22-23,26-27,34-35 and
the eastern portion of Section 33 in Township 49 South, Range 27 East. Sections 13,
16,21,24,25 and 36 of Township 49 South, Range 27 do not have significant
foraging or nesting habitats that would be considered large enough to be viable RCW
habitat. The NBMO Management Units are shown on Figure 2 which also contains
locations of the known RCW colonies which are shown as well as 0.5 mile buffers
around them. The buffer is needed to allow the birds in the colonies to relocate their
cavity trees and to forage in the vicinity of their nests. All of the buffer areas except a
portion of the foraging area for the Hideout cluster lies within the NBMO.
-
D HBMO Fig. U North Belle Meade Overlay 0
0 n::w_colony-hcp prOject
rcw_cotony_buffer 0.25 mile - - Mile,
o 0,25 0,5 1 1.5 2
1'.---"
Loon_oj n::w_cotony_buffer 0.5 mite
_ Cavity CaVity
_ Foraging
HCP _West Recovery Unit
r:;::;:<~1 HCP ..East Recovery Unit
Figure 2
RCW Habitat Areas and Recovery Units
This land is generally flat and has a native ecology characterized by hydric and non-
hydric pine flatwood or pine-palmetto (Serenoa spp.) uplands. It is located to the
north ofI-75.
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Lands designated as Receiving Lands in the NBMO, are included in the Management
Units solely for the purpose of allowing the owner of Receiving Lands to choose to
participate in the County's HCP. Otherwise, these HCP Regulations do not apply to
North Belle Meade Overlay Receiving Lands. Those landowners may apply directly
to the US Fish and Wildlife Service (USFWS) for a take permit.
1.6 Species to be Covered - Red-Cockaded Woodpeckers
About the size of a common cardinal, the red-cockaded woodpecker is approximately
7 inches long (18-20 centimeters) with a wingspan of about 15 inches (35-38
centimeters). Its back is barred with black and white horizontal stripes. The red-
cockaded woodpecker's most distinguishing feature is a black cap and nape that
encircle large white cheek patches. Rarely visible, except perhaps during the
breeding season and periods of territorial defense, the male has a small red streak on
each side of its black cap called a cockade, hence its name. Figures 3 and 4 are
photographs of male and female RCW s. The red-cockaded woodpecker feeds
primarily on beetles, ants, roaches, caterpillars, wood-boring insects, spiders and
occasionally fruits and berries (Jackson, 1994).
Figure 3
Figure 4
Red-cockaded woodpeckers are a cooperatively breeding species, living in family
groups that typically consist of a breeding pair with or without one or two male
helpers. Females may become helpers, but do so at a much lower rate than males.
The ecological basis of cooperative breeding in this species is the unusually high
variation in habitat quality, due to the presence or absence of critical habitat (Walters
1990, Jackson 1994).
Because of the cooperative breeding system, red-cockaded woodpecker populations
are usually resistant to environmental and demographic variation but are highly
sensitive to the spatial arrangement of habitat (Letchner et al. 1998). Colonization of
unoccupied habitat is a very slow process under natural conditions because cavities
take long periods of time to excavate and birds do not occupy habitat without cavities
(Connor and O'Halloran 1987; DeLotelle and Epting 1988).
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RCW populations are dynamic, preparing and moving to new cavity trees as need
arises, e.g., when their current tree is damaged by storms or fire or when the cavity is
taken over by another species. This is why it is important to provide for ample
nesting and foraging habitat and for corridors between clusters.
1.7 Need for a Recovery Plan
Historically, the range of the RCW extended from Florida to New Jersey and
Maryland, as far west as Texas and Oklahoma and inland to Missouri, Kentucky and
Tennessee. Today it is estimated that there are about 5000 groups of red-cockaded
woodpeckers, or 10,000 birds from Florida to Virginia and west to southeast
Oklahoma and eastern Texas, representing about one percent of the woodpecker's
original range (Jackson 1971; Ligon et al. 1986.). They are no longer found in New
Jersey, Maryland, Tennessee and Missouri.
Within Collier County there are only isolated populations of red-cockaded
woodpeckers. Today, most of Florida's red-cockaded woodpeckers are found on
large tracts of federal and state land and on private lands adjacent to such areas. Each
family group requires many acres of pine associated forests that include large areas of
mature open pine habitat and even short-term population stability requires a minimum
of about six groups in any area (Beever and Dryden 1992). Populations on public
lands are often intensively managed, but those on private lands are important as well.
They provide vital links between larger populations. This is especially true for the
populations in North Belle Meade that bridge between the other populations on public
lands.
2. Environmental Setting of Collier County
2.1 Overview
Collier County is located in southwestern Florida. It borders the Gulf of Mexico to
the West and South, Lee and Hendry Counties to the north, and Broward and Dade
Counties to the east. North Belle Meade is located north and east of 175. Figure 5
shows the location of North Belle Meade within Collier County. All ofthe known
remaining red-cockaded woodpecker activity in Collier County occurring on private
lands is located in this area.
2.2 Topography/Geology
The topography of the North Belle Meade section of Collier County is generally flat,
with a slight slope to the southwest. The surface soil is predominately Pineda-Boca-
Hallandale with inclusions of Holopaw-Malabar-Basinger-Immokalee. The fine sand
8/18/2009 rev 8/27/2009 6
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on the surface tends to be underlain by limestone. The area dead-ends into Route 1-75
that runs E -W. There is a canal to the north of the road and there are periodic
culverts connecting the north canal to a similar area on the south side of Route 1-75.
_NElIIC>
00-,-, MiI~s
8 12 16
Figure 5
North Belle Meade Overlay Area within Collier County
2.3 Vegetation Important to the RCW
The NBMO is characterized by having hydric and non-hydric pine flatwood or pine-
palmetto upland habitats. There is also RCW habitat and populations to the south of
1-75 in the Picayune State Forest and to the east in the Big Cypress Preserve. These
lands are already being managed for RCW s and are in conservation.
The red-cockaded woodpecker makes its home in mature pine forests. In South
Florida the South Florida slash pine (Pinus elliotii, var. densa) are most commonly
used (Beever and Dryden 1992). While other woodpeckers bore out cavities in dead
trees, where the wood is rotten and soft, the red-cockaded woodpecker is the only one
which excavates cavities exclusively in living pine trees. Figure 6 illustrates typical
RCW habitat in Collier County. The older pines favored by the red-cockaded
woodpecker often suffer from a fungus called red heart disease which attacks the
center of the trunk, causing the inner wood, the heartwood, to become soft (Jackson
1977). Cavities generally take 1 to 3 years to excavate (Bowman and Huh 1995).
The aggregate of cavity trees is called a cluster and may include 1 to 20 or more
cavity trees on 3 to 60 acres. According to the US Fish and Wildlife Service's 2003
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-
Figure 6
Typical RCW Habitat
RCW Recovery Plan, the minimum cluster size is about 10 acres. Cavity trees that
are being actively used have numerous small resin wells that exude sap. Figure 7
illustrates a typical cavity tree. The birds keep the sap flowing apparently as a cavity
defense mechanism against rat snakes and possibly other predators. The typical
territory for a group ranges from 125 to 200 acres, but observers have reported
territories in south Florida average 356.7 acres (Beever and Dryden 1992). The size
of a particular territory is related to both habitat
suitability and population density.
The red-cockaded woodpecker plays a vital role in
the intricate web of life of the southern pine forests.
A number of other birds and small mammals use the
cavities excavated by red-cockaded woodpeckers
such as chickadees, bluebirds, titmice and several
other woodpecker species, including the downy,
hairy, and red-bellied woodpeckers. Larger
woodpeckers may take over a red-cockaded
woodpecker cavity, sometimes enlarging the hole
enough to allow screech owls, wood ducks and even
raccoons to later move in. Several species of reptiles
and amphibians, and insects, primarily bees and
wasps, will also use red-cockaded woodpecker
cavities (Dennis 1971).
Figure 7
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2.4 North Belle Meade Habitat Assessment Activities to Date
Some work has already been perfonned in the North Belle Meade sector of Collier
County to try to identify red-cockaded woodpecker nesting and foraging locations
and to identify potential appropriate RCW habitat.
2.4.1 Assessment Criteria
The assessment criteria used to create Figures 1 and 2 were formulated using two
general habitat types which were delineated according to vegetative composition and
digitized onto a 2001 color aerial photograph scaled at approximately I" = 400'. Not
all cavity trees and clusters within this area were surveyed. However, data were
gathered that indicate that nest sites exist within, or near, the majority of the
management units, and therefore may exist to the extent allowed by habitat
limitations. The first type of habitat type is more specific, in that it provides
appropriate RCW habitat dynamics necessary for cavity trees and nesting habitat.
The second type of habitat consists of vegetative associations which provide potential
RCW foraging habitat. This not only includes mature slash pines, but also associated
open pine woodlands, savannas or potential open pine woodlands that can be created
through habitat restoration efforts.
The two habitat types were categorized by using seven variables which were
evaluated by aerial interpretation, and then selected areas were field verified for
accuracy. The field verified areas were then cross referenced with similar habitat
registers observed on the aerials and categorized by their habitat viability as it relates
to the RCW population requirements. The variables were:
. The percent of slash pine canopy,
. The density of the canopy,
. The sub-canopy composition and density,
. Density of exotic plants in association with other canopy or sub-canopy
speCIes,
. Connectivity to other viable RCW habitats,
. Proximity to open, mature pine woodlands, and
. Potential for restoration.
2.4.2 Survey Results
The field maps were digitized using the background aerial photographs. In most
areas there was sufficient detail to be comfortable with the data transfer. The study
identified ~ 3,547 acres (3546.85 acres via GIS) ofRCW Foraging Habitat and ~
3,210 acres of RCW Cavity Habitat in the North Belle Meade area. No RCW habitat
areas were identified in the eastern most sections of North Belle Meade. Figure 2
shows the results of this survey.
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Two management units that appear to have significant foraging or nesting areas have
been identified. The West Management Unit is located on the western portion of the
study area, and includes sections 24,25 and 36 of Township 49 South, Range 26 East
and the western portions of Sections 30 and 31 of Township 49 South, Range 27 East,
and Sections 20, 28, 29, 32 and 33 of Township 49 South, Range 27 East. The East
Management Unit includes sections 14, 15,22,23,26,27,34 and 35 of Township 49
South, Range 27 East.
Within each of the Management Units there are large areas designated as potential or
active RCW nesting or cavity tree habitat areas, which are connected by areas that are
too densely vegetated for viable nest tree habitat, but suitable for foraging. The East
and West Management Unit are also connected by potential foraging areas, but these
links appear to be dominated more by cypress than by pine habitats. The East
Management Unit has only a marginal connection through a cypress dominated
slough located within Section 33. It is also important to note that only West
Management Units had documented RCW activity, specifically within Sections 24,
25, 29 32, 33 and 36.
No RCWs were observed during the survey, but it was not within the scope of the
work to specifically look for cavity trees, and data were already available which
documented RCW sightings within these areas.
2.4.3 Implications for Management
Supplying good quality foraging habitat is a critical aspect of RCW recovery.
Especially over the long-term, as immediate threats from cavity and cluster limitation
are reduced. Our understanding of what constitutes good quality foraging habitat
comes from a synthesis of research into selection of foraging habitat and effects of
habitat characteristics on group fitness.
Both habitat selection and group fitness are influenced by the structure of the foraging
habitat. Important structural characteristics include:
1. adequate groundcovers of bunchgrasses and forbs,
2. minimal hardwood mid-story,
3. minimal pine mid-story,
4. minimal or absent hardwood over-story,
5. low to intermediate density of small and medium sized pines, and
6. substantial presence of mature old pines.
Thus, the quality of foraging habitat is defined by habitat structure. Although
geographic variation in habitat types exist, these structural characteristics of good
quality habitat remain true for all geographic regions and habitat types. Previous
management guidelines stressed quantity of foraging habitat as defined by the number
of medium and large trees. However, this needs to be expanded to include habitat
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quality, as defined by habitat structure, and use area metrics to address quantity.
RCWs require foraging habitat that is suitable in both quantity and quality.
Quantifying habitat structure (and thus habitat quality) is more complex than simply
requiring a given amount of habitat or number of trees, because habitat structure is
measured by multiple variables. Guidelines for foraging habitat are based on the
quantification of structural characteristics. Frequent fire can facilitate the restoration
and maintenance of all but one of these structural characteristics (mature and old
pines), and may provide further benefits by increasing the availability of nutrients.
These guidelines are based on the management plan developed by FFWCC (2003).
2.5 Species of Concern in the Plan Area
Several other imperiled species are known to oCGUpy the same upland slash pine
habitats. These include the Florida panther, Eastern indigo snake, Florida black bear,
gopher tortoise, Big Cypress fox squirrel and several species of wading birds,
including the wood stork. Maintenance of adequate cavity and foraging habitat for
active, known RCW clusters should also benefit these species in the area, but may not
provide adequate compensation for associated impacts to these species.
2.5.1 Florida Panther
Florida panthers (Puma conc%r coryi) and RCW s can occupy the same upland slash
pine habitats. There are a number of telemetry points for radio-collared panthers in
the North Belle Meade area. Much of the North Belle Meade has been classified as
being in the primary and secondary habitat zones by USFWS. Vehicle mortality
represents a major cause of death while habitat destruction has occurred due to
development and agriculture. Figure 8 includes panther telemetry points as well as
the locations of RCW s.
2.5.2 Eastern Indigo Snake
The Eastern Indigo Snake (Drymarchon corais couperi) is critically dependent upon
the availability of appropriate winter and summer refugia. Historically, these refugia
were most often provided by gopher tortoise burrows and stump holes. However,
gopher tortoises are now becoming rarer and many stumps have been commercially
removed.
2.5.3 Florida Black Bear
Florida Black Bear (Ursus american us floridanus) also occupy habitats within
NBMO. They are threatened due to loss of habitat to development and vehicle
mortality. Figure 8 also includes reported black bear incident and death locations.
8/18/2009 rev 8/27/2009 11
Agenda Item No. 10A
September 29, 2009
DRAF'fage 16 of 51
- -_. --
RCWCoIonV
I RCWObse''o!!Ition
. Florida Pan:herTdemetry
EI FIoridttPIlrihetRoecIdl
. Bled\ BewReportf
~ Btatt Beet Roadkll
MlrlnlIgemertlXiIA~)
D ManagemerilXlit Breed)
_0
Figure 8
NBMO Showing RCW, Panther and Bear Sitings
2.5.4 Gopher Tortoise
The Gopher Tortoise (Gophererus polyphmus is primarily associated with xeric scrub
pine flatwoods, and mixed hardwood-pine communities. The increasing loss of
habitat and urbanization has severely fragmented the populations on the southern
coasts.
2.5.5 Big Cypress Fox Squirrel
The Big Cypress Fox Squirrel (Sciurus niger avicennia) lives in forested uplands and
is threatened by loss of habitat.
2.5.6 Florida Pine Snake
The Florida pine snake (Pituophis melanoleucus mugitus) is found throughout the
state, but is uncommon. It requires dry sandy soils for burrowing and often lives in
8/18/2009 rev 8/27/2009 12
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September 29, 2009
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gopher tortoise burrows. It is found most often in open pine-oak woodlands and
abandoned fields, and also in scrub, sandhills, and longleaf pine forest (Pinus
palustris).
2.5.7 Wading Birds
Wading birds in North Belle Meade generally include egrets and herons (Egretta sp.),
white ibis (Eudocimus a/bus) and wood storks (Mycteria americana). . They
commonly feed in freshwater marshes, flooded pastures and ditches, and nest in
cypress or mangrove swamps. The woodstorks are the most endangered caused by
destruction and disturbance of suitable habitat.
3. Project Description Activities Covered by Permit -
Pursuant to the Endangered Species Act S4, the US Fish and Wildlife Service has
determined that the red-cockaded woodpecker is an endangered species. As
documented in the previous sections, areas within Collier County, namely the North
Belle Meade area, have habitat occupied by RCWs. In the absence of an Incidental
Take Permit (ITP) through the USFWS, some parcels being developed under
agricultural uses may not be providing appropriate RCW avoidance, minimization
and mitigation as intended under the ESA and undermining the protections
established in the Collier County Land Development Code (LDC) which protects 70
to 90% of native habitat in areas containing RCW habitat (see Section 4).
The Collier County RCW HCP was developed to help resolve conflicts between
protection/preservation of the RCW and its habitat and development/land cover
alterations. Establishing the Collier County ITP will remove the risk of possible
criminal or civil liability for "take" under the ESA, incidental to otherwise lawful
activity, for landowners within the plan area.
The HCP will cover future residential, commercial, industrial, agricultural, and
municipal County development occurring within the plan area. Collier County is
seeking an ITP to authorize, for a period of 30 years, incidental "take" of the RCW.
4. Potential Biological Impacts: Take
In Collier County, most RCW clusters exist on public lands such as Big Cypress
National Preserve and Picayune State Forest where large tracts of woodland habitat
have been maintained in suitable condition. These public land populations are under
management in an attempt to increase RCW numbers and contribute to recovery of
the species from its endangered status. Some Collier County RCWs also remain on
private land. The North Belle Meade region supports a small RCW population.
Suitable habitat has been maintained incidentally on tracts of private land. The RCWs
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on private lands belong to small, isolated populations on remaining fragments of
habitat. These birds are continuing to disappear without contributing to the future of
the species because of ongoing loss and fragmentation of habitat, lack of beneficial
management, and the negative effects of demographic isolation.
Private landowners are not required to contribute toward species recovery, but must
avoid "take" as defined by the USFWS. Avoidance of take necessitates that
landowners do not disturb or alter cavity trees or surrounding cavity and foraging
habitat used by RCWs. Minimum foraging habitat has been defined by the 2003
RCW Recovery Plan as 200 to 300 acres of Florida slash pine having at least 3000
square feet basal area of pines at least 10 inches in diameter near and contiguous to
the cavity trees. In south Florida, because the pines tend to be smaller, up to 1,000
acres of foraging habitat may be required (Jackson 2009). Preservation of the
foraging area may represent a lost income opportunity to some landowners who
propose habitat alteration, such as timber harvest or clearing, that would result in take
through loss of habitat.
In order to relieve the burden on the few private landowners with RCW s that belong
to small, isolated populations, while at the same time benefiting the overall RCW
population, Collier County is developing this habitat conservation plan (HCP) and
will become the entity responsible for managing and permitting development and
alteration of RCW habitat in the plan area. The proposed action is the issuance of a
permit under section lO(a)(1)(B) of the Endangered Species Act (ESA) to authorize
the incidental take of the endangered red-cockaded woodpecker within the
approximately 16,022 acres of the NBMO , Collier County, Florida.
Development within North Belle Meade that does not meet the standard for
agricultural exemption is subject to the Collier County Land Development Code
(LDC), which limits clearing. North Belle Meade lies within the County's Rural
Fringe District which utilizes a Transfer of Development Rights program. Parcels
within the "neutral lands" in Section 24, Township 49 South, Range 26 East, must
preserve a minimum of 70% native vegetation. "Sending" lands lying within the
Natural Resources Protection Act (NRP A) boundary must preserve 90% of native
vegetations; lands outside of the NRP A boundary must preserve 80% of native
vegetation, however, in some cases, off-site preservation is allowed (Collier County
LDC 3.05.07(3)). They are also subject to the requirements listed in section 5.6 of this
HCP for any "take" activities.
Some parcels may satisfy criteria for use as agriculture and may receive an exemption
from the Collier County Land Development Code regarding the amount of land that
may be cleared, but clearing activities will still be subject to state and federal
regulations covering listed species and will have to undertake the requirements
identified in Section 5.6 of this HCP.
Development or clearing of parcels within North Belle Meade may result in the
incidental taking of red-cockaded woodpeckers and their habitat.
8/18/2009 rev 8/27/2009 14
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For landowners who do not wish to develop, improve or clear their parcels and wish
to maintain suitable RCW habitat without incurring increased management
responsibility under the Endangered Species Act, the County will work with
landowners to facilitate "Safe Harbor" agreements through the USFWS. Under a
"Safe Harbor" Agreement, the baseline responsibility of any participating landowner
will be to maintain habitat for the number of RCW groups present at the time of the
agreement. Safe Harbor with a baseline of zero can be used to protect landowners
who have no RCW s on their land, but have a realistic probability of receiving
dispersing birds from nearby occupied RCW habitat.
4.1 Direct and Indirect Impacts'
The primary threats for the red-cockaded woodpeckers "all have the same basic
cause: lack of suitable habitat" (USFWS 2003). Throughout its range, but particularly
in Southwest Florida, habitat loss, fragmentation, and isolation, as well as fire
suppression, exotic vegetation cover all threaten the red-cockaded woodpecker. "In
South Florida, destruction and fragmentation of pine flatwoods habitat on private
lands due to urbanization is a major threat, particularly in southwest Florida"
(USFWS, 1999). Due to loss of habitat, "increasing isolation... could lead to
inbreeding and genetic depression" (USFWS 1999).
4.1.1 Habitat Loss
The red-cockaded woodpecker was once a common bird distributed continuously
across the southeastern United States. By the time it was listed under the Endangered
Species Act, RCWs had declined to fewer than 10,000 individuals in widely
scattered, isolated, and declining populations (Jackson 1971, Ligon et al. 1986). This
precipitous decline was caused by an almost complete loss of habitat. Fire maintained
old growth pine savannahs and woodlands that once dominated the southeast, on
which the woodpeckers depend, no longer exist except in a few small patches.
Longleaf pine ecosystems, of primary importance to red-cockaded woodpeckers, are
now among the most endangered systems on earth (Simberloff 1993, Ware et al.
1993). Shortleaf, loblolly, and slash pine ecosystems, important to red-cockaded
woodpeckers outside the range of longleaf, also have suffered severe declines (Smith
and Martin 1995). Loss of the original pine ecosystems was primarily due to intense
logging for lumber and conversion to agricultural fields. Logging was especially
intense at the turn of the century (Frost 1993, Martin and Boyce 1993, Conner et al.
2001). Impacts to easily accessible areas began with the arrival of Europeans, but
technological developments of the 1800's, such as the copper still, steam power, and
especially railroads, dramatically increased the rate and area of loss (Frost 1993). In
the late 1800's logging operations moved to the previously inaccessible interior
forests oflong1eaf, shortleaf, and loblolly pines. Two additional factors resulting in
the loss of original pine systems in the 1800's and earlier were exploitation for pine
resins and grazing by free-ranging hogs (Sus scrofa; Wahlenburg 1946, Frost 1993).
8/18/2009 rev 8/27/2009 15
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This especially intense period of logging from 1870 to 1930 resulted in the loss of
nearly all of the remaining old growth forest in the southeast (Frost 1993, Martin and
Boyce 1993, Conner et al. 2001). A common logging practice before the late 1800's
was to leave a number of residual trees, including small trees. Cavity trees of red-
cockaded woodpeckers probably were left. These residual pines enabled the red-
cockaded woodpeckers to survive the original devastation (Phillips and Hall 2000).
Later, in the 1900's, fire suppression and detrimental silvicultural practices had major
impacts on primary ecosystem remnants, second-growth forests, and consequently on
the status ofred-cockaded woodpeckers (Frost 1993, Ware et al. 1993, Ligon et al.
1986, 1991, Landers et al. 1995, Conner et al. 2001). Loss of residual trees in the
twentieth century has been a major factor in the decline of woodpecker populations
(Costa and Escano 1989, Conner et al. 2001; see 2D).
Southern pine forests today are very different from pre-colonial communities not only
in extent, but also in species composition, age, and structure (Ware et al. 1993, Noel
et al. 1998). Original pine forests were old, open, and contained a structure of two
layers: canopy and diverse herbaceous groundcover. These forests were dominated by
longleaf pine in the coastal plain, longleaf and shortleaf pines in the Piedmont and
interior highlands, and slash pine in south Florida. In contrast, much of to day's forest
is young and dense, with a substantial hardwood component and little or no
herbaceous groundcover (Ware et al. 1993, Noel et al. 1998).
Foraging habitat affects population densities; and it may be a secondary factor
currently limiting populations and will likely become a primary limiting factor once
abundant nesting habitat is provided (Walters et al. 2000, 2002a). Foraging habitat is
therefore also an important concern for long-term viability.
4.1.2 Habitat Degradation
Degradation and/or unsuitability of remaining pine habitat has been a major factor in
the decline of woodpecker populations. Exclusion and suppression of fire, which may
lead to smaller group sizes, reduced productivity, cluster abandonment, and/or low-
quality foraging habitat due to (1) replacement of native pines by off-site pine species
and hardwoods, (2) increased hardwood encroachment at the expense of pines and
groundcover, (3) higher stand densities and a predominant mid-story, and (4) changes
in the abundance, species composition, and distribution of the arthropod community.
Red-cockaded woodpeckers are directly and adversely affected by each of these
changes.
Reliance on dormant season prescribed bums has increased. These bums are not as
effective as early or mid-growing season bums at reducing hardwoods and promoting
native groundcover vegetation (Sparks et al. 1998, 1999).
There is also a low availability of old-growth pines, which are required for cavity
excavation and are an important component of optimal foraging habitat.
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Reproduction of pine has been severely restricted since the pre-colonial era because
of the absence of fire (Wahlenburg 1946, Frost 1993, Ware et al. 1993). Most second-
growth in existence today is 70 to 100 years in age (Kelly and Bechtold 1990, Frost
1993, Landers et al. 1995). At the present time, reproduction of pine is constrained by
hardwood midstory developed as a result of ineffective fire suppression (Landers et
al. 1995, Frost 1993, Peet and Allard 1993).
Several silvicultural practices have also been detrimental to red-cockaded
woodpeckers, including short rotations, clearcutting, and conversion to sub-optimal
pine species. Cutting of second- growth pines began during World War II and
continues today. Removal of second-growth pines has exceeded their replacement
rate by over 40 percent, and many of the remaining older pines are aging without
replacement (Landers et al. 1995).
- The years following W orId War II also saw the rise of plantation forestry. Plantations
of dense slash or loblolly pines covered over 4.9 million ha (12 million ac) by the mid
1960's and over 6.1 million ha (15 million ac) at present (Ware et al. 1993).
Plantations typically have been under rotations of 35 to 70 years for sawtimber
production and 20 to 40 years for pulp production (Conner et al. 2001), and industry
has continued to shift from logs and poles to pulp (Landers et al. 1995). With
technological developments such as chainsaws, the practice of leaving 'cull' pines
that were infected with red heart fungus or boxed for resin production declined. These
two practices-short rotations and the removal of all trees-had substantial negative
impacts on the woodpecker populations that remained after the initial logging
(Conner et al. 2001).
An additional threat to red-cockaded woodpeckers from past habitat loss is lack of
suitable foraging habitat. As described above, recent research indicates that optimal
foraging habitat is maintained by fire and contains an old growth or mature pine
component (Conner et al. 1991b, Hardesty et al. 1997, James et al. 1997,2001,
Walters et al. 2000, 2002a). Restoration of foraging habitat will likely increase red-
cockaded woodpecker densities (Walters et al. 2000, 2002a, James et al. 200 I; see
2E), which in turn will positively influence demography and dispersal.
4.1.3 Habitat Fragmentation
Habitat fragmentation and group isolation, which increase the RCWs' vulnerability to
adverse genetic, demographic, and environmental events, has been a major factor in
the decline of woodpecker populations.
A major impact of habitat loss on the viability of red-cockaded woodpeckers is the
result of fragmented distribution. Fragmentation and isolation have occurred both
among groups within a population and among populations, with serious consequences
for RCWs. RCWs are particularly sensitive to effects of isolation because of the
limited dispersal characteristic of cooperative breeders (Walters et al. 1988, Daniels
and Walters 2000a). Fragmentation among populations increases the vulnerability of
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DRAFfage 22 of 51
those populations to adverse genetic, demographic, and environmental events
(Walters et al. 1988a, Conner and Rudolph 1991, Hooper and Lennartz 1995),
because the dispersal that can help offset such threats is easily disrupted.
Fragmentation and isolation of groups within a population can substantially increase
that population's risk of extinction (Crowder et al. 1998, Letcher et al. 1998, Walters
et al. 2002b). Populations of red-cockaded woodpeckers are surprisingly persistent if
the spatial arrangement of groups within the population is tightly clumped. If groups
are isolated and dispersal behavior is disrupted, risk of population extinction increases
(Crowder et al. 1998, Letcher et al. 1998, Walters et al. 2002b).
An additional identified threat to species viability that stems from habitat loss are the
risks inherent to critically small populations. These are similar to fragmentation
effects, but rather than occurring through isolation, these threats are related to
population size. Small populations may be eliminated because of random
enviroiimental, demographic, genetic, and catastrophic events (Shaffer 1981, 1987).
Random environmental events such as an exceptionally severe winter that causes high
adult mortality affect an entire population. Random demographic events such as a
death due to predation, or a brood consisting of all males act on individuals within
populations. Random genetic events are losses or gains in frequency of any given
gene, simply due to chance inheritance. Lastly, catastrophic events, which can affect
large as well as small populations, are similar to environmental events but larger in
scale. Any of these processes alone or in concert can cause the elimination of a small
population. Such processes will continue to remain threats until population sizes are
sufficient to withstand them (Shaffer 1981, 1987, Crowder et al. 1998, Letcher et al.
1998, Walters et al. 2002b). Catastrophes will continue to threaten even the largest
populations in perpetuity, although the species as a whole will not be in danger once
enough large populations are established (e.g., Hooper and McAdie 1995).
Other factors unrelated to habitat loss may threaten red-cockaded woodpeckers, but
their importance has not yet been determined. Foremost among unevaluated threats
are the risks from pesticides and other environmental contaminants. Suburban groups
of woodpeckers may be at especially high risk of adverse effects from toxins.
Similarly, impacts of exotic species have not yet been assessed. Exotic species such
as melaleuca (Melaleuca quinquenervia) and red imported fire ants (Solenopsis
invicta) may be negatively affecting woodpeckers in some parts of their range.
4.1.4 Nest Site Alterations
Red-cockaded woodpeckers are unique among North American woodpeckers in that
they nest and roost in cavities they excavate in living pines (Steirly 1957, Short 1982,
Ligon et al. 1986). This unusual behavior is thought to have evolved in response to
the scarcity of snags and hardwoods in the fire-maintained pine ecosystems of the
southeast (Ligon 1970, Jackson et al. 1986). Use oflive pines is the primary reason
why the species requires mature pines, the loss of which has resulted in
endangerment. Cavities are an essential resource for red-cockaded woodpeckers
throughout the year, because they are used for both nesting and roosting. Thus, a
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September 29,2009
DRAFTage 23 of 51
thorough understanding of cavity tree ecology is fundamental to red-cockaded
woodpecker biology, management, and recovery.
The threat to woodpecker populations from low-quality or insufficient foraging
habitat is not as immediate as threats from habitat fragmentation and lack of suitable
nesting habitat. Fragmentation and lack of nesting habitat are presently limiting
populations and are responsible for recent declines (Walters 1991).
Wind is the second greatest cause of cavity tree mortality in non-hurricane situations
(Conner et at. 1991a). Cavity trees can be uprooted or snapped by high velocity
winds. Patterns of harvest near clusters should be carefully planned to avoid
funneling wind toward cavity trees (Conner et at. 1991 a, Conner and Rudolph 1995).
A forest buffer of uncut trees greater than 61 m (200 ft) wide around cavity trees is
adequate protection to minimize wind damage, wind snap, and wind throw during
isolated severe summer thUnderstorms (Conner and Rudolph 1995c).
Hurricane winds are a major threat to coastal woodpecker populations (Engstrom and
Evans 1990, Hooper et at. 1990, Hooper and McAdie 1995, Lipscomb and Williams
1995). For example, when Hurricane Hugo struck the Francis Marion National
Forests in South Carolina during September 1989, it destroyed 87 percent of the
cavity trees, 67 percent ofthe woodpeckers, and 70 percent of the foraging habitat
(Hooper et at. 1990, Hooper and McAdie 1995). The use of the recently developed
technique of drilled and inserted artificial cavities (Copeyon 1990, Allen 1991, Taylor
and Hooper 1991) enabled the rapid recovery of the Francis Marion population
(Watson et at. 1995). Conservation of inland populations and many separate coastal
populations will minimize the risk of extinction from hurricanes (USFWS 1985,
Hooper and McAdie 1995). Hooper and McAdie (1995) also suggest that pines
needed for future nesting habitat be grown in open conditions to promote the
development of large crowns, extensive root systems, and strong boles. Another
strategy to minimize impacts from hurricane winds is to avoid the creation of
openings greater than 10.1 ha (25 ac) in or near forests managed for red-cockaded
woodpeckers in hurricane-prone areas.
The third major cause of cavity tree mortality is fire. Managers must take appropriate
measures to protect cavity trees from prescribed bums and wildfires so that loss is
minimized. Foremost among these protective measures is regular burning within the
cluster and around cavity trees, to keep fuel at acceptable levels.
4.1.5 Introduced Predators
Since our country was first colonized, several thousand foreign plant and animal
species have established themselves in the u.S. Introduced predators often exert
multi-trophic cascading effects in terrestrial ecosystems. However, how such
predation may indirectly impact interactions between above- and below-ground biota
is poorly understood, despite the functional importance of these interactions.
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September 29, 2009
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4.1.6 Road Mortality
As the most mobile of terrestrial wildlife, birds are not often considered significantly
affected by highways (Keller et al. 1996). However, highway impacts to birds occur
in four major ways, some of which are unique to birds: by fragmentation, disturbance,
and direct and indirect mortality. These imp<l;cts could have considerable negative
effects on RCW populations, especially when considered in combination with other
sources of mortality and habitat loss.
Highways can fragment bird populations and habitats in three ways: loss of large
carnivores, habitat dissection, and the isolation of less mobile species. When
highways fragment large carnivore populations, birds can suffer increased
depredation from smaller carnivores such as bobcats, skunks and weasels (Crooks and
Soule 1999). Habitat dissection may result in 2~;ltches of habitat too small to complete
a territory. Woodland species such as RCW s are more affected by habitat dissection
than grassland species, which appear to be more willing to cross highways as part of
their territories (Keller et al. 1996). Highways can isolate small populations or
individuals because of habitat dissection. Isolation is a variant of habitat dissection,
but it also includes those situations where a portion of a daily or annual habitat is
difficult or dangerous to access because of the presence of a highway.
Disturbance from highways may be most pronounced during the breeding season, but
can also affect other life history periods. Territorial song is only effective if it is
heard by other birds, and noise from traffic can be so loud that bird song may be
distorted, resulting in difficulties in attracting and keeping females (Reijnen and
Foppen 1994). One method of migrant navigation is by reference to stars (Emlen and
Demong 1975). Light pollution from all sources reduces the visibility of stars, and
may entrap migrating birds in dangerous environments especially during inclement
weather, causing collision, apparent confusion, and mortality (Ogden 1996).
Direct mortality is the impact most people likely associate with highways. Birds are
listed as killed most frequently in most multiple taxa road mortality studies (Forman
et al. 2003). Habitat loss to highway development is huge and insidious because
highways may facilitate further development. When associated with highways,
powerlines, railroads and canals are a few structures cumulatively more hazardous to
birds. The expansion of several species of noxious plants and animals is facilitated by
the cleared line of sight along highways,
4.1. 7 Artificial Feeding
Many people feed wild birds to supplement their diet. However, the provision of
food to wildlife has been implicated widely as a causative factor that increases the
occurrence of infectious and non-infectious disease. Animals are attracted to artificial
sources of feed in higher density than normally occurs under natural conditions. As
animal density increases, competition for food also increases resulting in more
frequent contact among individuals. Contact can be direct through physical contact,
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September 29, 2009
DRAFfage 25 of 51
or indirect as occurs when two animals share the same portion of food. If one or more
animals are harboring an infectious organism, its transmission to uninfected
individuals is facilitated by the increased frequency of contact among animals
congregating at the feeding site. It is also suggested stress from crowding reduces
immunocompetence in some animals, increasing the likelihood of disease. Disease
can affect individual animals, populations, or communities. Depending on the nature
of the disease and the feeding location, disease can be transmitted within or between
species, between wildlife and domestic animals, or even between wildlife and
humans. Non-infectious disease also can occur when wild species are fed foods
incompatible with their digestive function, foods of poor nutritional quality; or
spoiled foods that have become toxic.
4.1.8 Single-Family Homes
-
Urbanization produces fundamental changes in ecosystem structure and populations.
Urbanization is likely to be the single most important driver of extinction of RCW s
during this century. Already, urbanization is the second most frequently cited cause of
species endangerment in the United States (Czech and Krausman 1997).
4.1.9 Failure in Suburban Settings
Human-caused disturbances in cluster areas during the nesting season may disrupt
RCW nesting activities, decrease feeding and brooding rates, and cause nest
abandonment. Such activities may include but are not limited to all-terrain and other
off-road vehicles, motorized logging equipment, and other vehicles that make
excessive noise and disturbance to which the woodpecker groups have not previously
become accustomed. Use of vehicles and other activities throughout the year may
cause indirect impacts to RCW s through excessive soil compaction, damage to cavity
tree roots, and disturbance of the groundcover. Soil compaction and root damage
elevate cavity tree mortality (Nebeker and Hodges 1985, Hicks et ai. 1987, Conner et
al. 1991a); changes in the groundcover may affect prey abundance (Collins 1998),
nutrient value of prey (James et al. 1997), and fire frequency and intensity through
changes in fuel.
4.2 Anticipated Take
"Take" is defined by the USFWS under the Endangered Species Act (50 CFR 17.3)
as actions "to harass, harm, hunt, shoot, wound, kill, trap, capture, or collect, or
attempt to engage in any such conduct." A notable component of this definition is the
definition of "harm." "Hann" in the definition of "take" means "an act that actually
kills or injures protected wildlife. Such acts may include significant habitat
modification or degradation where it actually kills or injures wildlife by significantly
impairing essential behavior patterns, including breeding, feeding, or sheltering."
Actions necessitating translocation of an RCW shall be considered a "take" and
subject to the terms of the HCP.
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4.2.1 Definition of Available Habitat
There is geographic variation in nesting and roosting habitat of red-cockaded
woodpeckers. The largest populations tend to occur in the primarily longleaf pine
(Pinus paiustris) forests and woodlands of the coastal plains and Carolina Sandhills
(Carter 1971, Hooper et ai. 1982,James 1995, Engstrom et ai. 1996). Pine habitat
occupied by red-cockaded woodpeckers covers a wide moisture gradient ranging
from hydric slash pine flatwoods in Florida (Beever and Dryden 1992, Bowman and
Huh 1995) to uplands in Oklahoma (Masters et ai. 1989, Kelly et ai. 1993), Alabama,
and Mississippi. Density of pine overstory in areas occupied by RCWs varies from
fairly dense in Texas (Conner and O'Halloran 1987, Conner and Rudolph 1989), to
sparse in the Orlando, Florida vicinity (DeLotelle et ai. 1987), to extremely low in the
Big Cypress National Preserve (Patterson and Robertson 1981).
--
Native slash pine communities support red-cockaded woodpeckers in south Florida
(Beever and Dryden 1992). This subspecies of slash pine (Pinus elliottii var. densa) is
the only native pine in this region and is similar to longleaf pine in both appearance
and fire resistance. Native slash pine like the longleafpine has a grass stage and large
taproot (Landers 1991). Much of the native slash used by RCW s is located in hydric
communities (Beever and Dryden 1992). It may be that slash pine replaces longleaf
pine in this region because it can better tolerate very wet conditions. For RCWs,
native slash pine habitats differ from those farther north in that the pines are generally
smaller and may be more sparsely distributed (Patterson and Robertson 1981, Beever
and Dryden 1992, Landers and Boyer 1999). The largest size that south Florida slash
pines achieve, even in old growth woodlands, is typically 20 to 30 em (8 to 12 in).
Cavity trees in this habitat type are smaller than those normally found in other
habitats (Beever and Dryden 1992, Bowman and Huh 1995). However, the presence
of fire and old trees in both nesting and foraging areas are also critically important.
Woodpeckers in native slash pine have not been well studied. Preliminary research
has indicated that home ranges of birds in native slash pine are larger than those in
other habitats (Patterson and Robertson 1981, Beever and Dryden 1992), but the
relationship between habitat requirements and habitat quality has not been
investigated in this forest type. Thus, it is not known whether larger home ranges in
south Florida result from degraded habitat, natural differences in habitat quality,
population density, or even lack of cavity trees. Although further research is
necessary to determine the cause of large home ranges in south Florida, results from
studies elsewhere suggest that as habitat quality increases, the size of these home
ranges will decrease. It is likely that, as pine density, age, and herbaceous
groundcovers of south Florida slash pine woodlands increase, resident woodpeckers
will still require more foraging habitat than woodpeckers in most other regions but
less than they appear to be using at the present time. Slash pine was historically a
minor component of coastal pine forests. It is a mesic pine that was generally found in
damp swales, narrow drainages, and along pond margins within longleaf pine forests
(Landers 1991, Christensen 2000). Slash pine is now much more widespread than was
true historically, as a result of fire suppression and aggressive planting programs. Off-
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site slash pine forests, such as that in North Belle Meade, support small numbers of
RCW s in some areas. Restoration of these sites to site-appropriate pines would be
beneficial; however, caution must be used to avoid unnecessary impacts to the RCWs
(FerraI1998).
4.2.2 Definition and Quantification of Take
Under this H CP, incidental take of RCW s, their cavity trees and other essential
habitat may occur. The total direct, indirect and cumulative impacts on the RCW s
within North Belle Meade will be directly related to the amount of future
development and land alterations and based on a multi-tier avoidance, minimization
and mitigation strategy detailed in Section 5.6 of this HCP.
5. Conservation Program - Measures to Minimize and Mitigate for
Impacts
The overall goals of this HCP are to increase the quantity and quality ofpublic1y-
preserved RCW habitat, to increase the number and health of the Collier County
RCW population, and to provide a comprehensive plan for landowners who wish to
utilize their lands within North Belle Meade but may be unable to do so currently due
to restrictions under the Endangered Species Act. The HCP will provide a benefit to
the species by protecting and enhancing both private and public lands that contain
red-cockaded woodpecker habitat, as well as dispersal corridors. A goal for the
Southwest Florida population of red-cockaded woodpeckers is to "establish additional
populations of red-cockaded woodpeckers on public and private lands, where
feasible, and create as much habitat connectivity as possible, to maximize dispersal
opportunities"(USFWS, 1999). This plan will result in preservation of RCW habitat
in a more cohesive and planned way because mitigation lands off-site will be adjacent
to existing RCW habitat. We anticipate that issuance of this permit will result in a
benefit to the species, as the HCP will provide a regulatory oversight mechanism for
small parcels that may not otherwise incur a nexus with federal agencies or may not
otherwise compensate for their impacts to RCW s and their habitat.
5.1 Biological Goal
The goal of this HCP is to maintain successfully breeding populations of red-
cockaded woodpeckers within Collier County, Florida and to facilitate recovery on
adjoining lands containing appropriate pine flatwood habitat.
5.2 Biological Objectives
There are active clusters of this indigenous woodpecker within the North Belle Meade
study area. The red-cockaded woodpecker has highly specific habitat requirements,
foraging and breeding in mature pine stands at least 30 years old, which do not
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exhibit an excessively dense hardwood mid-story. Because of its critically low
population, the RCW is a federally protected species. Therefore, Collier County BCC
will utilize its authority to establish compliance with the Endangered Species Act
(ESA), as amended, to protect and enhance RCW populations in North Belle Meade,
through the implementation of this RCW Habitat Conservation Plan. The
management goals and guidelines for this HCP are described below. There are three
primary goals for the management of the RCW in the North Belle Meade:
1. No net loss or to increase and enhance existing RCW population size.
2. To maintain viable RCW habitat through perpetual, pro-active, habitat
acquisition and management.
3. To minimize conflicts between private landowners and the RCW
management program.
5.2.1 No Net Loss
A "No net loss" policy can be defined as a principle by which counties, agencies, and
governments strive to balance unavoidable habitat, environmental and resource losses
with replacement of those items on a project-by-project basis so that further
reductions to resources may be prevented. "No net loss" policies can be applied to
almost every environmental issue and concern in Florida. From wetland protection,
where the policy is most widely known, from public hunting lands to private farmland
and single-family homes, "no net loss" policies have become important tools in
protecting Florida's environment and protecting the public's access to the
environment. This HCP shall meet the standards of "no net loss," with the biological
goal of providing a net benefit to the region's RCWs.
5.2.2 Maintain Connectivity and Viable Habitat
Managers have some limited tools to combat effects of fragmentation (e.g., strategic
location of recruitment clusters, retention of forest cover, and translocation). More
importantly, as populations recover, isolation effects will not be as intensely acute as
they are at present, because larger populations have greater resistance to impacts from
environmental and demographic threats, greater retention of genetic variation, and
thus greater probability of persistence. However, effects of fragmentation are likely to
remain serious threats to population viability throughout the period of recovery.
Tracts of cleared land, development, mining, as well as existing and proposed
transportation corridors (including 1-75) fragment existing RCW habitat in North
Belle Meade. Fragmentation of habitat create barriers to movement and introduces
secondary edge and cumulative impacts. The HCP has a goal of retaining occupied
RCW habitat that connects known clusters as well as unoccupied habitat that may
connect occupied habitat if restoration was performed. In particular, a potential link
between clusters north of 1-75 to those south ofI-75 in the Picayune Strand will be
explored.
,.-
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5.2.3 Minimize Landowner Conflicts
Part of the goal of this HCP is to inform property owners within the known RCW
habitat areas of the requirements of this plan as well as their existing obligations
under the federal and state laws protecting them as an "endangered species." This is
part of the "No Surprises" intention of an HCP so that requirements are known prior
to any development occurring. The inclusion of provisions in the Collier county Land
Development Code will also have this effect and can be cited when a clearing permit
is applied for by a landowner. The County will hold public meetings to inform
landowners of their rights and obligations under the endangered species regulations
and this proposed HCP program.
5.3 Strategies to Achieve Biological Goals
Cavities, cavity trees, and cavity tree clusters currently limit red-cockaded
woodpecker populations, and thus their careful management is foremost in
woodpecker conservation and recovery. Red-cockaded woodpeckers require large old
trees as nesting and roosting sites, in habitat that is free of pine and hardwood mid-
story. Each cavity tree is an important resource that must be protected, and until
potential cavity trees become more widely available, additional cavities and clusters
must be judiciously provided through the use of artificial cavity technology.
Hardwood encroachment causes abandonment of cavity tree clusters, with direct
effects on population status. Encroaching hardwoods must therefore be controlled,
preferably by frequent, early to mid growing season fire. These management
actions-protection of existing cavity trees, provisioning of artificial cavities and
clusters as appropriate, and hardwood control- form the basis of red-cockaded
woodpecker management. Loss of cavity trees and hardwood encroachment were
primary factors in the decline of the species throughout its range. Removal of these
limiting factors is therefore fundamental to conservation. As good quality foraging
habitat is limited in South Florida due to the ecology of the hydric slash pine habitats,
requiring foraging habitat that may exceed 200 acres in size to support a cluster is
critical (USFWS, 1999). Ensuring sufficient foraging habitat around clusters is also
essential to maintaining the RCW s in the plan area.
5.3.1 Maintain Habitat in Protected Areas
To protect cavity trees, a buffer zone of continuous forest, 0.5 mile in width, is
generally established around a group's active and inactive cavity trees. To facilitate
record keeping and protection, individual cavity trees within a cluster are commonly
marked with metal numbered tags, painted for easy detection, and mapped.
Lands proposed as mitigation shall be "located in the vicinity of the affected habitat,
where appropriate, to avoid further fragmentation and isolation of existing habitat"
(USFWS, 1999). Ifmore appropriate to the stability of the RCW population in
Southwest Florida, RCW s shall be translocated from threatened private lands to
public lands, and "is intended to result in a net gain of red-cockaded woodpeckers on
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public lands or in establishment oflarger, more secure private populations" (USFWS,
1999).
The carrying capacity of RCWs is "directly correlated with habitat quality," therefore,
efforts should focus on protecting habitat for the birds on private lands where
medium-sized populations (10 to 30 groups) are known to exist... and expanding
populations on key public lands" (USFWS, 1999). Noting that current known red-
cockaded groups within the North Belle Meade area are limited and below this
threshold, mitigation efforts, if not possible on-site, will be focused on the
recruitment into the established Picayune Strand State Forest red-cockaded
woodpecker population. This goal is supported by the Red-Cockaded Woodpecker
Recovery Plan, which aims to "increase, via translocation, the size of populations on
state and federal lands" (USFRWS, 2003). In 2000, Picayune Strand had
approximately three known red-cockaded woodpecker clusters. The goal is to grow
-. . the population to 25 clusters (USFWS, 2003).
5.3.2 Maintain Source Populations
This HCP proposes to maintain source populations through two strategies. The first
is to educate landowners of their responsibilities under federal and state legislation to
protect the RCWs that may be present on their property. The second is to include in
the Collier County Land Development Code provisions that will require
surveys/inspections and either protection on-site or movement and compensation that
may cover translocation and mitigation for impacts to habitat (see Table 1). This
compensation money can be used to purchase additional appropriate habitat to ensure
the continued health of existing RCWs.
5.3.3 Restore and Maintain Corridors
One of the goals of this HCP is to use some of the funds collected to acquire and
permanently protect appropriate RCW land. These funds will be earmarked for the
purchase of land that is good habitat and is either adjacent to known clusters (e.g.,
northwest comer of section 24) or provides a link between present populations and
appropriate but currently unoccupied habitat which could provide alternative habitat
to existing clusters if their current nesting areas are disturbed.
5.3.4 RCW Cavity Installation
Several large pines are selected in proximity to each other and are drilled and an
artificial insert placed in the cavity. Then, these cavities are fitted with a front piece
with a 1 "PVC pipe insert and surrounded by a wire mesh to prevent enlargement of
the hole).
-
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5.3.5 Movement of RCWs
If RCW s may be impacted by the proposed actions, translocation of the birds will be
required prior to the permitting of any habitat changes. Translocation will require that
habitat be acquired, exotics removed and quality habitat managed.or restored, and
artificial cavity trees established, as may be required per this HCP, before the
occupied habitat is impacted. Handling of RCW s, as well as design and placement of
artificial cavity trees will be subject to applicable local, state, and federal guidelines.
5.3.6 Monitoring
Population monitoring is a critical component of the conservation and recovery of
red...cockaded woodpeckers. Effective monitoring begins with explicit identification
of monitoring objectives, the appropriate metrics to be used in meeting objectives,
and familiarity with necessary sampling and monitoring techniques. It is then up to
managers and researchers to apply these standards in good faith. Finally, monitoring
results must be compared to stated objectives. Fortunately, red-cockaded
woodpeckers are more easily monitored than most species because of their
conspicuous active cavity trees and the exceptional stability of territory locations.
Surveys of the recruitment clusters will be conducted twice a year (at least one survey
during the breeding season) for five years. Surveys and County access to mitigation
areas will be conducted in accordance with applicable local, state, and federal
guidelines. Monitoring of the mitigation areas will also determine need for follow-up
exotic treatment and land management needs.
County staff will periodically (at least annually) monitor the presence and success of
known RCW clusters. The results will be maintained on the cluster map.
5.4 Adaptive Management Strategy
During the term of the HCP, considering increased surveying/inspection of
properties proposing to alter habitat, this HCP must allow for adaptive management.
Similarly, information will be gathered from monitoring inspections of birds left in
place and those that are translocated. Where properties were to be managed for
RCWs, this will also be inspected periodically by the County.
If a new cavity tree and/or cluster is found and verified, the cavity tree, cluster and
0.5 mile buffer foraging area will be subject to the HCP avoidance, minimization and
mitigation measures established in this HCP. These new cavity trees as well as those
from translocation activities will be located on the County's base map.
In Section 5.8.2, this HCP calls for a review of the success of the program after 10
years. That should be sufficient time to evaluate whether the initial activities as
outlined in this plan are effective, whether appropriate habitat land could be
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identified and purchased with mitigation money, and whether property in the NBMO
is being managed for the RCWs. Adaptive management practice calls for this type
of review and if problems are noted, or more effective measures are identified, they
should be incorporated in the plan and the County's Land Development Code, as
appropriate. Based on the findings of the initiallO-year review, the interval to the
next review cycle will be determined.
5.5 Measures to Minimize Impacts
Impacts to red-cockaded woodpecker habitat should be minimized on-site prior to
triggering mitigation measures. The priority habitat on-site will be "the most suitable
areas forred-cockaded woodpeckers, connect[ions] [to adjacent] preserves"
(USFWS, 1999). Minimization measures may include retention of all active and
inactive cavity trees, start hole or artificial cavity on the site and foraging habitat
within a 0.5 mile buffer, if possible.
5.6 County Permitting and Mitigation Process
The Hep will employ the strategies outlined in this section of the HCP to achieve its
overall and biological goals. Impacts to RCW habitat will be avoided by directing
development away from known and viable RCW habitat, including both cavity and
foraging habitat, particularly in priority areas including lands adjacent to public lands,
established clusters, and potential dispersal corridors. Impacts to RCW habitat will be
minimized by ensuring that activities requiring clearing reduce impacts that may
adversely affect red-cockaded woodpeckers, including minimization of
development/clearing footprint, appropriate buffers from the cavity tree, placing
incompatible uses away from the cavity tree and other RCW habitat areas, and
minimizing disturbance during nesting season. Where effects cannot be avoided,
impacts will be mitigated.
North Belle Meade consists of lands that are designated as "sending," "receiving,"
and "neutral" as shown in Figure 2. Clearing of vegetation on sending and neutral
lands requires a clearing permit from Collier County. Section 3.05.2 of the Collier
County Land Development Code states that receiving lands do not have to apply for a
clearing permit; however those participating in the HCP and proposing clearing
activities will require a survey and will be subject to this HCP.
Only activities on land resulting in a determination of "take", as defined in Section 4,
will require mitigation. As established in Section 4, avoidance of take necessitates
that landowners do not disturb or alter cavity trees or cavity and foraging habitat used
by RCW s. The required mitigation will be dependent on the property location, the
size of the property and the activity planned as detailed in the following tables.
Required mitigating activities, funds or lands will be based on the footprint of
proposed impacts to RCW habitat.
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The process to be followed when proposing clearing activities within the North Belle
Meade Overlay is as follows:
1. All County approvals, permits, or notification for vegetation or agricultural
clearing within the NBMO will be consistent with the approved Hep. All
properties within the NBMO will be required to submit a RCW survey prior to
any clearing activity. This survey should be perforrhed by a trained
environmental professional familiar with RCW survey protocols and signed.
Appendix A contains RCW survey guidance from the 2003 USFWS Recovery
Plan. If the survey identifies the presence of a cavity tree, it should be determined
whether the tree is currently active. Cavity trees will be considered active unless
it can be proven that there has been no RCW activity for the previous five years.
If a cavity tree is found during the survey, this will be reported to Collier County
which will conduct an inspection to verify and GPS the location, and the RCW
map will be updated. The designation or this property will be changed to reflect
its new status, and the mitigation requirements will change accordingly. The
County will generally conduct a verification survey prior to issuance of any
clearing permit.
2. Determine whether the property lies within East or West Management Units or
outside of these areas as depicted on Figure 2.
a. If the property lies within the West Management Unit, it must then be
determined whether it lies within the 0.5 mile buffer of a known cluster,
whether it lies in nesting habitat, whether it lies in foraging habitat or
whether it lies outside these areas. If it lies within nesting habitat, a
wildlife survey/site inspection will be required to determine whether an
active cavity tree exists on the property.
b. If the property lies within the East Management Unit, it must be
determined by a survey by a trained environmental professional to
determine whether or not RCW or cavity trees are present and whether it
lies within nesting habitat, foraging habitat, or outside of these habitats.
3. Using Table 1, determine the required mitigation for proposed agricultural or
non-agricultural clearing. The allowed non-agricultural clearing varies from 10%
to 30% depending on whether the land is designated as "sending," "neutral" or
"receiving" in accordance with the Collier County LDC.
4. The amount of mitigation that is required is directly extrapolated from the size of
the footprint of the proposed impacts. There are three basic types of mitigation
and each of these will be discussed below.
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Table 1
Mitigation Required in NMBO Area
Unit Parcel Cavity 1/2 mile of Cavity tree Foraging habitat Other
size tree/cluster area cavity tree habitat
affected
West :S] acre 1:1 1: 1 1:1 0.5:1 Survey
> 1 acre 4:1 4:1 2:1 2:1 Survey
East < ] acre 1:1 1: 1 1:1 0.5: 1 Survey
> 1 acre 4:1 4:1 1:1 1:1 Survey
a. On-site mitigation - Landowners can reduce their mitigation requirements by
half by committing to maintain the remainder of their property. This reduction
may not be applied to impacts proposed to cavity trees, and-may only apply
when the clearing is done in accordance with the clearing maximums allowed
in the Land Development Code. Land management must be conducted in
accordance with RCW management principles that include:
(1) Removal of understory including sabal palms and exotics such as
melalucca and brazilian pepper, by fire, mechanical, manual or
chemical means. No heavy equipment, including but not limited to
feller bunchers, rakes or hydro-axes, shall be used within fifty feet of a
cavity tree. No mechanical equipment shall be allowed within 200 feet
of a cavity tree during nesting season.
(2) Retaining potential cavity trees with a dbh of greater than 10", as well
as an adequate number of smaller slash pines to become
recovery/replacement cavity trees in the future.
Landowners who choose this option will receive regular inspections by the
County to ensure that the clearing is being performed.
This designation of property as "maintained as RCW habitat" will be recorded
as a conservation easement and will continue with the property in perpetuity.
b. Offsite mitigation - Compensatory lands must be managed and/or restored as
suitable for RCW s and must be maintained into perpetuity and be:
(1) Quality RCW habitat within or adjacent to the Picayune Strand State
Forest Project Boundary or other suitable permanently protected area
of at least 300 acres.
(2) Within a known or biologically-feasible dispersal corridor to help
protect and establish connectivity.
(3) Land value for compensation is determined by the current tax rolls for
the land at the time of the take.
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If compensatory lands are to be transferred to a public entity (such as Collier
County or the State of Florida), a land management fee determined by the
receiving entity shall be included in the mitigation package that is sufficient
for species-specific habitat management into perpetuity.
c. Translocation - Impacts to RCW cavity tree(s) can also be offset by
translocation to a created artificial cluster tree(s) in a preserved area adjacent
to occupied habitat or in a public preserve. Translocation costs will include
the cost of creating the new cluster of cavity trees, installing the birds, and
monitoring the cluster annually for five years and reporting the success of the
translocation to the County Environmental Services Department.
Professionals are available who can accomplish the translocation and
monitoring for a landowner and must follow all applicable local, state, and
federal regulations regarding removing the birds. -
Landowners who wish to "opt out" of the County HCP, may consult directly with the
USFWS. Landowners who may impact RCWs or their habitat outside of the NBMO
shall consult directly with the USFWS.
It should be noted that Collier County is exempt from Bert Harris claims in requiring
this mitigation since it is given the power to award Take Permits by the USFWS, a
federal agency.
5.7 Landowner Grievance Process
Landowners who are dissatisfied with the results of an inspection and imposition of a
mitigation process for land clearing, can appeal through the process defined in the
Collier County Land Development Code (LDC) and administrative code. The
landowners may also apply for their own HCP directly to the USFWS.
5.8 Monitoring and Reports
The County will keep a record of the take permits it has awarded. It will also
maintain the map shown in Figure 2 and update it to show clusters newly identified
during required property inspection/wildlife surveys as well as the locations of
translocated clusters.
5.8.1 Monitoring Measures
Monitoring reports are required for all translocated clusters for a period of five years
after the translocation to allow the county to measure the success of this process.
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5.8.2 Reports
At the end often years, the success of this RCW HCP in Collier County will be
evaluated. At that time the effectiveness of the measures will be assessed and the
effect of the procedures as well as natural processes on the native Collier County
RCW population will be examined. Based on this evaluation, a determination will be
made on whether the population is stable, continuing to decline or recovering. This is
also a time when measures that are found not to be working can be amended to
improve the plan's future implementation. Representatives from the USFWS,
FFWCC, Collier County's Environmental Services Division, and Conservation
Collier will agree on conclusions and present them to the Board of Commissioners of
Collier County.
6. Funding
Funding is required to finalize this HCP and then to put it into practice. The HCP
Advisory Committee has played a major role in bringing the plan this far and will
continue to play an active role, but minimal services will be required from the
Environmental Services Department and the County Attorney's Office, especially as
the agreement nears sign-off. Current levels of funding of about $ I 5,000/yr will
permit this process to continue. If the BCC approves, the HCPAC can submit a
Section 6 grant from USFWS to cover all of our expenses. 1
Operational funding for this program, once the HCP is signed by the BCC and the
participating agencies, will come from an increase in the cost of vegetation and
agricultural clearing permits in the NBMO. The NBMO could also be designated as a
special taxing district to recover the staff costs for maintaining this program once it is
enacted.
7. Alternatives
The main alternatives to this HCP are to:
I. Broadly implement a Safe Harbor Program among the landowners whereby they
would agree to protect those resources needed by RCW s occurring on their
property and to maintain their property in a way that maximally benefits the
RCW s; and
I For information, Section 6 Grant Applications for 2010 awards are due August 19,2009.
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2. Do nothing and allow development to occur with minimal respect to the RCW s.
Property owners are responsible for obtaining their own HCPs from USFWS, a
process that is more expensive and takes longer than a NBMO HCP.
8. Plan Implementation
8.1 Interagency RCW Habitat Management Task Force
An Interagency RCW Taskforce will be assembled including representatives of the
US Fish and Wildlife Service, the Florida Fish and Wildlife Conservation
Commission, Florida Department of Environmental Protection regulatory division,
the Collier County Department of Environmental Services, Conservation Collier and
the Habitat Conservation Plan Advisory Committee or its.successor entity. This
Taskforce will meet on an as needed basis to oversee the implementation of this plan
and to evaluate its effectiveness.
8.2 Changed Circumstances
In Southwest Florida there are a number of occurrences both natural and man-made
that can affect the future health of RCW populations.
8.2.1 Hurricanes
The mature Florida slash pines that red-cockaded woodpeckers use for their cavity
trees in Southwest Florida are particularly vulnerable to damage from high winds.
When the birds create their cavities, this weakens the overall tree structure and during
high winds, trees will tend to snap at this weakened point.
8.2.2 Acceleration of Habitat Loss and Fragmentation
Development and clearing of land results in significant loss of habitat. A number of
property owners in the North Belle Meade Overlay area of Collier County have used
their rights to clear land for agricultural purposes to establish nurseries. This results
in removal of the slash pines and total clearing of the native habitat. There have also
been several earth mines established in this area which also results in significant
clearing; mines are an allowed agricultural conditional use.
Another factor directly limiting the number of potential breeding groups is habitat
fragmentation and consequent isolation of groups, which results in disrupted dispersal
of helpers and failure to replace breeders. This limitation is best addressed through
the appropriate development practices, placement of clusters of artificial cavities and
implementation of silviculture and land management practices that minimize
fragmentation and provide wildlife corridors.
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8.2.3 Inadequate Habitat Management
The RCWs require open pine woodlands and savannahs with large pines for nesting
and roosting. Large old pines are required as cavity trees. There should be little or
no hardwood midstory. If the mid-story of cabbage palms, 'Brazilian pepper and
melaluca becomes too dense, the RCWs will abandon their cluster oftrees and search
for other suitable habitat. The RCW s also require suitable foraging habitat consisting
of mature pines with an open canopy, low to moderate densities of pines, little or no
hardwood or pine mid-story, few or no over-story hardwoods and groundcover
dominated by native grasses and forbs.
Fire suppression can result in proliferation of mid-story growth that has a negative
impact on RCW success. Then, if a fire does occur in an overgrown mid-story,
severe damage to the mature slash pines occurs as well.
8.2.4 Genetic Changes
Red-cockaded woodpeckers exhibit inbreeding depression and inbreeding avoidance
behaviors. Inbreeding is expected to affect population viability in populations of less
than 40 potential breeding groups, and may be a significant factor affecting viability
in isolated populations of 40-1 00 potential breeding groups as well. Immigration
rates oftwo or more migrants per year can effectively reduce inbreeding in
populations of any size including small ones.
Loss of genetic variation through the process of genetic drift is an inevitable
consequence of finite population size. New genetic variation arises through the
process of mutation. In large populations, mutation can offset loss through drift and
genetic variation is maintained. Just how large a population must be to maintain
variation is a difficult question. Currently, researchers recognize that in general, only
populations with actual sizes in the thousands, rather than hundreds, can maintain
long-term viability and evolutionary potential in the absence of immigration.
However, if populations are connected by immigration rates on the order of 1 to 10
migrants per generation (0.5 to 2.5 migrants per year), the genetic variation
maintained by these populations is equal to that of one population as large as the sum
of the connected populations. Thus, sufficient connectivity among populations can
maintain genetic variation and long-term viability of the species.
8.2.5 Demographic Changes
Effects of demographic changes on population viability may vary with the spatial
arrangement of groups. Populations as small as 25 potential breeding groups can be
surprisingly resistant to random demographic events if those groups are highly
aggregated in space. Populations as large as 100 potential breeding groups can be
impacted by demographic changes, if groups are not aggregated and dispersal of
helpers is disrupted. Demographic changes are not expected to affect populations
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larger than 100 potential breeding groups. Similarly, effects of environmental
changes may vary with the spatial arrangement of groups. Based on preliminary
results of models and estimates of potential environmental changes derived from
North Carolina Sandhills, 250 potential breeding groups will likely withstand effects
of any environmental changes regardless of their spatial arrangement.
8.2.6 Low Survival of Translocated Populations
Translocation of RCWs while well documented, is not always successful and its long-
term effectiveness as a population management tool has not been proven.
8.3 Unforseen Circumstances
- This HCP is being developed with the best current knowledge of RCWs, their habitat
requirements, and the local environment in which the Collier County population
dwells. There are many events that could affect the future of this plan and a few are
discussed below.
8.3.1 Persistently Low Juvenile Survival
There are a number of variables from weather to predator activity that affect the
survival of juvenile RCW s. If survival of juveniles is demonstrated to be reduced for
several years in a row, this plan and its strategy should be reviewed to determine
where changes might be made.
8.3.2 Prolonged Drought
Drought conditions in 2007 resulted in lower than normal reproduction rates in south
Florida clusters.
Drought also increases the danger of non-managed burns, i.e., wildfires and this also
happened in 2007, affecting the breeding colonies in the Picayune State Forest where
two of 12 cavity trees were destroyed by fire.
8.3.3 Long- Term Maintenance/Management
This HCP assumes that the management of the take permit process for RCWs will be
assumed by the Environmental Services Department of Collier County. It also
assumes that public lands such as the Picayune State Forest will continue to agree to
accept translocated colonies ofRCWs. Should either of these factors change, the plan
will need to be reviewed and an alternative management strategy developed.
8/18/2009 rev 8/27/2009 35
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8.3.4 New Environmental Issues
Scientists are predicting significant climate changes for South Florida including:
rising sea level, increased numbers and intensities of storm events, changes in
precipitation, and increase in temperatures and lengths of "summer" seasons. All of
these can have a potential effect on RCW s. Should adverse effects on the population
be noted, the plan will need to be reviewed and an alternative management strategy
developed that accommodates these changes.
9. Literature Cited
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Service, General Technical Report SE-73.
Beever, J. W. III, and K. A. Dryden, 1992. Red -cockaded woodpeckers and hydric slash
pine flatwoods. Transactions of the 57th North American Wildlife and Natural
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Bowman, R., and C. Huh, 1995. Tree characteristics, resin flow, and heartwood rot in pines
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Carter, J. H. III 1971. Birds of the central Sandhills of North Carolina. Chat 35:91-105.
Conner, R. N. and K.A. O'Halloran, 1987. "Cavity-tree selection by red-cockaded
woodpeckers as related to growth dynamics of southern pines." Wilson Bulletin
99:398-412.
Conner, R. N., and D. C. Rudolph. 1989. Red-cockaded woodpecker colony status and trends
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Conner, R.N., and D.C. Rudolph. 1991. Forest habitat loss, fragmentation, and red-cockaded
woodpeckers. Wilson Bulletin 103:446-457.
Connor, R. N., and D. C. Rudolph. 1995. Wind damage to red-cockaded woodpecker cavity
trees on eastern Texas national forests. Pp. 183-190 in D. L. Kulhavy, R. G.
Hooper and R. Costa, eds. Red-cockaded Woodpecker: Recovery, Ecologv and
Management. Center for Applied Studies in Forestry, Stephen F. Austin State
University, Nacogdoches, TX. -
8/18/2009 rev 8/27/2009 36
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Connor, R. N., D. C. Rudolph, D. L. Kulhavy, and A. E. Snow. 1991a. Causes of mortality
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seed-tree/shelterwood cuts in eastern Texas. Wildlife Society Bulletin 19:67-93.
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woodpecker. Wildlife Society Bulletin 18:303-311.
Costa, R., and R. Escano, 1989. Red-cockaded woodpecker translocations 1989-1994: state-
of-our-knowledge:- Pp.74-81 in Annual Proceedings of the American Zoo and
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ecology, restoration, and managemenT-Tall Timbers Fire Ecology Conference
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Hardesty, J.L. K.E. Gault, and F.P. Percival, 1997. "Ecological correlates ofred-cockaded
woodpecker (Picoides borealis) foraging preference, habitat use, and home range
size in northwest Florida (Eglin Air Force Base)." Final Report Research Work
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Hicks, R. R., Jr., J. E. Coster, and G. N. Mason. 1987, "Forest insect hazard rating," Journal
of Forestry 85(10):20-26.
Hooper, R. G. and M. R. Lennarz, 1995. "Short-term response of a high density red-
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D.L. Kulhavy, RG. Hooper and R. Costa, eds. Red-cockaded woodpecker:
recovery, ecology and management. Center for Applied Studies in Forestry,
Stephen F. Austin State University, Nacogdoches, TX
Hooper, R. G. and C. J. McAdie, 1995. "Hurricanes and long-term management of the red-
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eds. Red-cockaded woodpecker: recovery, ecology and management. Center for
Applied Studies in Forestry, Stephen F. Austin State University, Nacogdoches,
TX
Hooper, R.G., L.J. Niles, R.F. Harlow, and G.W. Wood, 1982. "Home ranges of red-
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Symposium IV, Fish and Wildlife Service, Savannah, GA.
,,_.
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Hooper, RG., J.C. Watson and R.E.F. Escano, 1990. "Hurricane Hugo's initial effects on
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224.
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Fisheries and Wildlife and Tall Timbers Research Station, Tallahassee, FL.
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163.
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Philadelphia, PA and the American Ornithologists' Union, Washington, DC.
Jackson, J.A. 2009. Personal communication.
Jackson, J.A., R.N. Conner, and B.J.S. Jackson, 1986. "The effects of wilderness on the
endangered red-cockaded woodpecker." Pp. 71-78 in D.L. Kulhavy, R.G. Hooper
and R. Costa, eds. Red-cockaded woodpecker: recovery, ecology and
management. Center for Applied Studies in Forestry, Stephen F. Austin State
University, Nacogdoches, TX.
James, F.C. 1995. "The status ofred-cockaded woodpecker in 1990 and the prospect for
recovery." Pp 439-451 in D.L. Kulhavy, RG. Hooper and R. Costa, eds. Red-
cockaded woodpecker: recovery, ecology and management. Center for Applied
Studies in Forestry, Stephen F. Austin State University, Nacogdoches, TX.
James, F. C., C. A. Hess, and B. C. Kicklighter, 2001. Ecosystem management and the niche
gestalt of the red-cockaded woodpecker in longleaf pine forests. Ecological
Applications 11 :854-870.
James, F. c., C. A. Hess, and D. Kufrin, 1997. "Species-centered environmental analysis:
indirect effects of fire history on red-cockaded woodpeckers." Ecological
Applications 7:118-129.
Keller, V., H.-G. Bauer, H.-W. Ley, and H. P. Pfister. 1996. The significance of wildlife
overpasses for birds. Der Ornithologische Beobachter 93:249-258.
Kelly, J.F.and W. A. Bechtold. 1990. The long leaf pine resource. Pp. 11-12, in R. M. Farrar,
Jr., ed., Proceedings, Symposium on the Management of LongleafPine. General
Technical Report SO-75. New Orleans, LA: U.S. Department of Agriculture,
Forest Service, Southern Forest Experiment Station.
8/18/2009 rev 8/27/2009 39
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Kelly, J. F., S. M. Pletschet, and D. M. Leslie, Jr. 1993. Habitat associations ofred-cockaded
woodpecker cavity trees in an old-growth forest of Oklahoma. Journal of Wildlife
Management 57: 122-128.
Landers, J. L. 1991. Disturbance influences on pine traits in the southeastern United States.
Pp. 61-98 in S. M. Hermann, ed. High -intensity fire in wildlands: management
challenges and options. Tall Timbers Fire Ecology Conference Proceedings, no.
17. Tall Timbers Research Station, Tallahassee, FL.
Landers, J. L. and W. D. Boyer, 1999. An old growth definition for upland longleaf and
south Florida slash pine forests, woodlands, and savannas. USDA Forest Service
General Technical Report SRS-29.
Landers, J. L., D. H. Van Lear, and W. D. Boyer, 1995. The longleafpine forests of the -
southeast: requiem or renaissance? Journal of Forestry 93(11):39-44. Letcher, G. H., J. A. Priddy, J. R Walters, and L. G. Crowder, 1998. An individual-based,
spatially explicit simulation model of the population dynamics of the endangered
red-cockaded woodpecker. Biological Conservation 86: 1-14.
Ligon, J. D., W. W. Baker, RN. Conner, J. A. Jackson, F. e. James, D. C. Rudolph, P. B.
Stacey, and J.R. Walters, 1991. "The conservation crisis-the red-cockaded
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the American Ornithologists' Union committee for the conservation of the red-
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Lipscomb, D. 1. and T. M. Williams, 1995. "The impact of Hurricane Hugo on cavity trees of
a red-cockaded woodpecker population and a natural recovery after two and a half
years." Pp. 167-171 in D.L. Kulhavy, R.G. Hooper and R. Costa, eds. Red-
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Masters, R.E. J.E. Skeen, and J. Whitehead. 1989. "Preliminary fire history ofMcCurtain
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Studies in Forestry, Stephen F. Austin State University, Nacogdoches, TX
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Nebeker, T. E. and J. D. Hodges. 1985. "Thinning and harvesting practices to minimize site
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Smith, E.B. and R. Martin, 1995. "Red-cockaded woodpecker distribution and status in
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Studies in Forestry, Stephen F. Austin State University, Nacogdoches, TX
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vegetation in restored pine-grassland communjties." Journal of Vegetation
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in the North Carolina sandhills." Fort Bragg Project Final Report. Virginia
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Hooper, and R. Costa, eds. Red-cockaded Woodpecker: Recovery, Ecology and
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University, Nacogdoches, TX.
10. Appendices
Appendix A
RCW South Florida Survey Protocol (Adapted from USFWS 2003)
:'\esting and Foraging Habitat
Surveys are used to detemrine \,"hether the nesting and/or foraging habitat of a red-
cockaded \'v"oodpecker group will be adyersely inlpacted by a proposed project. 111is is
an impOltant part of the conservation and management of this endangered species. and
therefore the Fish and \Vildlife Service has deyeloped standard stUyey and analysis
procedures for such detenninatiolls. 111ese detenninations must be undertaken prior to
the initiation of any project within the southeastel1l United States that calls for removal of
pine trees 60 years or older: typically such trees will be at least 25.4 em (10 in) dbh
(diameter at breast height) or larger. In south Florida slash pines as small as 15.2 cm (6
in) dbh can be tins old. The procedure is also used following new land acquisition by
state and federal agencies in the southeast or any other circulllStance in winch the
presence or absence of red-cockaded \voodpeckers is to be assessed.
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The flIst step in the slUTey procedure is to detennine if suitable nesting or foraging
habitat exists vdthin the area to be impacted by the project. lino suitable nesting or
foraging habitat is present within the project impact area. fmther assessment is
ullnecessmy and no effect to the red-cockaded \\'oodpecker is anticipated. If no suitable
nesting habitat is present within the project impact area. but suitable foraging habitat is
present and will be impacted. potential use of this foraging habitat by groups outside the
project bOlUldmies must be detelluined. TIus is accomplished by identifying any
potential nesting habitat within 0.8 km (0.5 nu) of the suitable foraging habitat that would
be impacted by the project. Any potential nesting habitat is then slUveyed for cavity
trees. This procedme is described in greater detail below. Ifno active clusters are fOlUld,
then to the red-cockaded \;roodpecker is anticipated. If one or more active clusters are
fOlUld. a foraging habitat analysis is conducted (see belo\v) to detemllne whether
sufficient amollllts of foraging habitat \,-ill remain for each group post-project.
-
For nesting and foraging habitat slllTeys witlun project inlpact areas and within 0.8 km
(0.5mi) of the project site. potential habitat is assessed at the level of the stand. A stand
is a tenll used to refer to a \vooded area recehillg past or ClUTent sihicultural treatment as
a single management unit. Here \:\"e expand the tenn to include any subset of a tract of
wooded land. divided by biological COlllllumity type, management histOlY. or any other
reasonable approach. A small tract of land may be considered a single stand or pm1 of a
large stand.
.--
IclentificatioIl of Suitable Foraging Habitat
For the plllpose of sm,:eying. suitable foraging habitat consists of a pine or
pine/hardwood stand of forest. woodland. or sa\-a11nah in \,-lnch 50 percent or more of the
donnnant trees are pines and the dominant pine trees are generally 60 years in age or
older. These charactelistics do not necessarily descIibe good quality foraging habitat:
rather. tins is a conservatiYe description of potemially suitable habitat. Identification of
pine and pine/hard\".;ood stands can be made using cO\-er maps that identify pille and
pine./hardwood stands, aerial photographs intelpreted by standard techniques. or a field
survey conducted by an experienced forester or biologist. Age of stands can be
detemnned by aging representatiye dominant pines in the stands using an incremem-
borer and COUmUl2: annual 2:1'owth rin2:s. Stand data describul2: size classes lUav be
'- ........... ,-. ..,
substituted for age if the average size of 60 year-old pUles is known for the local area and
ha bitat type.
If no suitable foraging habitat is present \\-ithin the project area (that is. no pUles 60 years
or older \.,-ill be impacted). then fiu1her eyaluation is llllllecessary and red-cockaded
\voodpeckers can be presumed absent. If the project area contaulS any suitable foraging
habitat that wi.1l be inlpacted by the project. that habitat. if it contains any 60 year old
trees or older. and all other suitable nesting habitat \:l;ithin 0.8 km (0.5 un) oftbe project
site. regardless of o\\'nerslnp. must be slUTeyed for the presence of red-cockaded
\voodpeckers. -
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DRAP'fage 49 of 51
Identification of Suitable Nesting Habitat
For the purpose of surveying, suitable nesting habitat consists of pine. pine/hardwood.
and hardwood/pine stands that contain pines 60 years in age or older and that are \\ithill
0.8 km (0.5 mi) of the suitable foraging habitat to be impacted at the project site (see
above). Additionally. pines 60 years in age or older may be scattered or c1mnped v\"ithin
YOlmger stands; these older trees within YOlmger stands must also be examined for the
presence of red-cockaded woodpecker cavities. TIlese characteristics do not necessarily
describe good quality nesting habitat rather. tIns is a conservative description of potential
nesting habitat.
Detern.unation of suitable nesting habitat may be based on existing stand data, aerial
photo interpretation. or field reco1Ulaissance. Trees should either be aged or assluued
suitable-if greater than 15.2 cm (6 in) dbh. .All stands meeting the above description.
regardless of o\\"nership. should be surveyed for cavity trees.
Cadt)" Tree Survey
Once suitable nesting habitat is identified (above), it must be surveyed for cavity trees of
red-cockaded woodpeckers by persOlUlel experienced in management and monitoring of
the species. Potential nesting habitat is S1u'veyed by l1.Umillg line transects through stands
and viS11ally inspecting allmedimn-sized and large pines for evidence of cavity
excavation by red-cockaded woodpeckers. Transects must be spaced so that all trees are
inspected. Necessary spacing will vary \vith habitat structme and season from a
maximum of 91 m (300 ft) between transects in very open pine stands to 46m (150 ft) or
less in areas with dense midstOlY. Transects are l1.111nOlth-somh, because many cavity
enn"ances are oriented in a westerly direction. and can be set using a hand compass.
\\71ule surveying for ca\ities look and listen for red-cockaded woodpeckers. If any are
obse1Ted record their location and behayior.
\\7JIen ca\'itv trees are found. their location is recorded in the field USin2 a Global
r ~
Positioning System (GPS) unit. aerial photograph. or field map. Actiyity status. cavity
stage (sta1t. advanced start or complete cavity). and any entrance enlargement are
assessed and recorded at this time. A cavity can only be considered abandoned if inactive
for five consecutive years. Again. it is extremely inlportant to haye all smyeys and ca\"ity
tree assessments pe1foffiled by experienced persOlUlel. If caYity trees are fOlmd, more
intense stu"veying \\-ithin 45i m (1.500 ft) of each cavity tree is conducted to locate all
cavity trees in the area. CaYity trees are later assigned into clusters based on obse1Tatiolls
ofred-cockaded woodpeckers as described in Service (2003. section3A).
8/18/2009 rev 8/27/2009 45
Agenda Item No. 10A
September 29, 2009
DRAF'fage 50 of 51
Smveys for foraging area boundmies require both breeding season surveys (Apri115
through June 15) and non-nesting season (fall) smveys (October 15 through December
15). Smveys should be conducted dtuing the llloming homs. from 1 hom prior to sunrise
to four homs past stuuise. Sup:eys outside of these time frames can be inconclusive.
Only calm clear days should be surveyed as red-cockaded .woodpecker acthity is limited
on .windy and rainy days. The foraging area smveys require 14 days of survey over the
season. Two methods of identifying foraging area botmdaries are provided depending 011
the circtunstances.
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..-..,
8/18/2009 rev 8/27/2009 46
Agenda Item No. 10A
September 29, 2009
DRAFT age 51 of 51
If there are active red-cockaded woodpecker cavities on the property the tenitory is
considered a O,.8-k111 (0.5 mi) radius area SUll'OlUlcling the cluster. This can be modified if
a foraging area slU'vey is conducted to detemllne the area bOlmdaries. A foraging area
slU'vey COll11nences with obsel'YatiollS of the red-cockaded \\'oodpeckers when they leave
their roosts. The sl1l'veyor documents the number ofbu'ds and tracks the bu'ds as they
forage through the adjacent habitats. Data should be collected at halfhom intervals.
recorded onlUaps, or doctmlented \\'ith GPS coordulates for later mapping. If the red-
cockaded woodpecker moves to a new location wlrile being obselved. the flight du'ection
and the location \\'here the red-cockaded woodpecker lands should be noted. Behayior
and vocalizations should be noted. especially behavior that would indicate cOlUtship or
nesting.
If there are no active red-cockaded woodpecker ca\ities on the property a meandering
pedesniall transect should be conq.ucted through all suitable habitat. TIle observer should
stop every 3 to 5 minutes, look and listen for red-cockaded woodpecker acthity. Since
these bu'ds are territoIial and \\ill defend their te11'itOlY from illtmsion by other
uldividuals. the use of red-cockaded woodpecker vocal recordings can facilitate
observation. TIlerefore, at each of the stops. play 30 seconds of continuous red-cockaded
woodpecker vocal calls. Tapes of red-cockaded woodpecker vocalizations are available
from Audubon and Peterson field guide series.
Report
A final stuvey report should uldude the following. as applicable:
A. Field data sheets that ulc1ude:
1. dates and startuH~ aud ending times of all stllvevs conducted:
"-.~ .
") weather conditions during all slUTeys. ulcludulg temperamre. \vuld speed and
direction. visibility. and precipitation: and
3. the total munber of red-cockaded woodpeckers obsep;ed and number of red-
cockaded woodpecker clusters.
Red-cockaded woodpecker acthity and ca\'iry tree u1.folluation should be submitted in a
sUITey report to the South Florida Ecological Seryices Office. 1339 20th Str.. Vera Beach.
FL 32960.
8/18/2009 rev 8/27/2009 47