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rOCT 2 3 1985 <br />BOOK 62 PAF. 509 <br />be prepared and submitted to the Technical Subcommittee on Mosquito <br />Impoundments of the Governor's Working Group'on Mosquito Control. To <br />date, the applicant has apparently ignored all suggestions that such a <br />plan be developed, or that he initiate consultation with the <br />subcommittee. <br />We strongly recommend against development of an estuarine channel - <br />low marsh - deepwater basin system as proposed. Again, the Regional <br />Planning Council guidelines emphasize that management and preservation <br />of high marsh must be a major objective of the wetland management plan. <br />This is wholly appropriate, since this wetland type provides unique <br />habitat and other wetland benefits. Outright elimination of the high <br />marsh is simply an unacceptable proposal. Since open water marsh <br />management or other ditching strategies offer little hope of success for <br />this tract, we offer the rotational impoundment management scenario as <br />the best, and probably only, alternative which will provide adequate <br />mosquito control and management capabilities for the high salt marsh. <br />Regarding the proposed estuarine waterway system, let us <br />re-emphasize that the extensive, wide, 4 -foot -deep waterway system is <br />unacceptable, even without any additional marinas or other deep basins. <br />Shallow marsh systems do not require 4 -foot -deep channels to be <br />well -flushed. These channels would essentially become a navigable <br />inland waterway system for large boats. The Regional Planning Council <br />limit of 5 horsepower motors south of the major marinas is not adequate <br />in this regard. Large sailboats could still navigate and even anchor in <br />the channels, and the presence of such a system invites future docking <br />and marina development. <br />The entire wetland system south of the major marina #1 (and #2 if <br />it is relocated in accordance with our guidelines) should be considered <br />a wetland preserve, not a residential estuarine system. Therefore, only <br />electric motors or small boats such as canoes or rowboats should be <br />permitted in that area. We recommend that any inland channels south of <br />the marina be limited to 2 feet in depth, mean low water, and that they <br />be limited to 10 feet in width. <br />With regard to the specific mosquito control and "wildlife <br />enhancement" measures recently proposed by Dr. J. Shisler of the <br />Environmental Connection in New Jersey, we offer these brief comments. <br />Elimination of the high marsh is unacceptable, and will not be <br />considered a viable option for mosquito control in these wetlands. The <br />wildlife enhancement measures are poorly conceived, and range from some <br />of possible but insignificant value (nesting platforms or islands), to <br />the absurd (manatee sanctuaries and underwater viewing area3 in the <br />estuarine waterway system). These proposals although well -meant, offer <br />little significant habitat enhancement, and would be constructed through <br />destruction of the existing wetland system. <br />Thank you for the opportunity to comment on this development plan. <br />Please call me if we can be of further assistance. <br />Sincerely yours, <br />Brian S. Barnett <br />Biological Administrator <br />60 <br />