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scheme : Indian Mer hnu v= r , including dike removal as mitigation for road 011, nn rte ,P"ad that the four recommendations of the VVrjd a Came and Froili t•u�r "Ish Commission be made revisions to the permit instrument.'' >) Flo -id- Dw, _ar,ment of Env tronM nt.tl R=egulation, 15 toy 1931 (excepts froo text of DER Permit Application Appraisal) "...The proposed road will .•ross wetlands that have been impounded for mosuuita control and la:gu : e . ioas that are filled wetlands (including back dikes). The impaers to these areas will be offset by fill removal and, therefore, racreating the tidal wetlands .. the restoration of tidal at tion t ; the impounded sites. " After endorsing the aforementioned recommendations of the Florida Game and Fresh Water Fish (',mmjss.on, the field appraisal further states that "...If a flap ysated culvert must be used then the flap gate must be installed on Lne upstream end of the culvert. The flap gate on the downsueam and serves only to drain the impoundment and not to ..._:tore tidal a, ion." These recommendations hive not ',, L"1.^.lKO in the project design. 5) Treasure Coast Regional Planning (Y"nail. 3 July 1980 "Council's primary concou , as t" naintain the integrity of thr wetlands wbic h the proposed road 111 transverse by taking whatever me3suros -oco ssary (e .g. , r -al ign i n;' the road to a more westerly location and improving fli_snins of the diked wetlands)." I have attached copies of these Keuments to this statement. Page 4.7 "Thew wetlands hovtt been previously disturbed by a dike system used for salt marsh mosquito control. These dikes have caused a toss of Kistorical ecological value by reducing plant and animal diversity; an-_ Lave terminated the export of detrital material to Indian <ivpr Estuary, tidal, and freshwater flushing; action, and Yater quality and sediment stabilization." This statement, though essenia.lt• correct, deni.gr:ate•_ thu wetland's current habitat value and does not express the potential for proper habitat manaSement_. In the f irst place, 12C plant species were recorded on-site; and although only lb bird npaciP3 were observed, nearly 100 species could probably be recordwa via gore extensive survey. Secondly, t fou h wai: ear -borne Pu'_r iant export has been eliminated, feeding, activi_tles of wading bira , and : iAratory waterfowl can provide substantial nutrient -export from impounded wetlands. With regarl for the porentia l of A wounded wetlands, I offer the following quote from zorrespondeno e of tie Florida Game and Fresh Water Fish Commission (19 May 1940, enclosed) "...when such areas are imp )ended cril y during the mosquito breeding season anti dewateied with tidal exchange via culverts during the cooler months, they become highly productive units of the estuarine ecosystem... With enlightened man gement, mosquito control impoundments provides goad :mosquito contr:al, uotiand wildlife habitat, and seasonal exchange of nutrients and biota w.tL He adjacent estuary..." Page 4.8 "No ;Tants or animals listed as rare, endangered, or thre;at.neu on either the Federal. or state lists were observed in the project study area. ' Appendix n of `he .epnu st.:ttrl;, however, that brown pelicans and ,:oo& storks were chserveo na site. These species are listed as threatened and undingered, respectively, by the 'lorida flame. and Fresh Wntcr ist Commission. Brown pelicans are al A listed as tmaingerec hv the U.S. Fish and Wildlife_ Service. Filo ondaneerod m.ir too tins been observed in the main .SRV! , nd at ; nant ni • Iw - s 4 :ani inK bird, found on-site are , isL _rd by Kit- WK ,. ecles of special concern. SEP 1 : r47 wor 41011A, � 11 J