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BOOK 47rAr,E 696 An essential first step is for Indian River County to employ a professional environmental planner who is trained in the ecology and management of natural systems. It would be fruitless to assign the task of resource management to the Planning Department, without also providing the technical expertise to design, evaluate, and implement such a program. The Treasure Coast Regional Planning Council; Florida Departments of Agriculture, Environmental Regulation, and Natural Resources; Florida Game and Fresh Water Fish Commission; U.S. Fish and Wildlife Service; and U.S. Soil Conservation Service can be relied on to provide input to resource inventory and management, but none of these agencies have the capability to supervise a program specifically for Indian River County. That is the responsibility of our local government. The list of needed studies -and regulations presented in the Comprehensive Plan is a good start. We wish to suggest additional topics, however, which should be considered. 1. Indian River County possesses coastal strand, tropical coastal hammocks, sand pine scrub, and other unique upland habitats which are not protected by regional, State, or Federal statutes. In addition to their educational and aesthetic values, these habitats are extremely important for stabilization of unconsolidated sediments and recharge of the shallow aquifer along the sand ridge. Because development pressure is greatest in upland areas, the County would be wise to acquire, or limit distruction of these unique habitats now, while they are relatively plentiful, rather than to wait until they are nearly depleted and prohibitively expensive. 2. Restrictions on fill placement, drainage, and vegetative destruction within wetlands are vital to effective management of these resources. These development actions are partially regulated by State or Federal agencies, but local government must not depend on these "big brothers" to do the job for us. An excellent example of effective environmental control over wetland resources, albeit 30 years late, is Dade County's Department of Environmental Resources Management. 3. We must reduce unit densities and development within the 100 year floodplain, particularly along the Sebastian and Indian Rivers. Encouraging development in the floodplain not only increases the public costs of stormwater drainage, transportation, and civil emergency planning, but courts natural disaster. Accordingly, the County should re-evaluate its position of support for the Federal Flood Insurance Program. This program, originally intended to discourage Federal participation in or support of floodplain development, has been perverted into an incredibly expensive bureaucracy which encourages and financially subsidizes wetland and floodplain development. 4. We enthusiastically support the establishment of Special Treatment Districts as proposed in the Comprehensive Plan. The transfer of residential densities to adjacent lands under unified ownership is a progressive and equitable solution. These rights, however, should not be assessed on a one-to-one ratio based on acreage and density districts. Rather, the transfer ratio should be based on the realistic potential developabilty of the Special Treatment Lands. For example, intertidal red mangrove swamp has a negligable potential for development because of State and Federal statutes. Any transfer of development rights should be appropriately minimal, regardless of the surrounding area's density district status. Also, the current proposal does not provide for those landowners who do not possess lands outside of, but adjacent to, their Special Treatment District Holdings.