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BOOK 62 PnE 51 <br />Similarly, Brazilian pepper is limited to the perimeter berm of the <br />11 -acre marsh ("B", Figure 1) immediately southwest of the <br />aforementioned wetland. This area, as described in the ADA, is <br />dominated by shallow freshwater marshes and flats, with low spoil ridges <br />traversing the site. These ridges are dominated by sea daisy and <br />groundsel bush. Through dike breaches and the main north -south canal <br />connected to the aforementioned tidal creek, this area is also tidally <br />connected. It is dominated by freshwater drainage and rainfall, <br />however, has much greater detrital and litter accumulation than the <br />adjacent marsh, and is tidally inundated only during extreme tidal <br />events. Marsh rabbits, raccoons, freshwater turtles, tree frogs, <br />leopard frogs, forage fishes, wading birds, red -winged blackbirds, and <br />grackles constitute the dominant fauna of this area. Alligators and <br />river otters have also been observed in these freshwater marshes and <br />ponds. <br />The remaining wetlands are adequately described in the ADA. The <br />largest system is a 40 -acre salt marsh ("C", Figure 1) complex of sea <br />daisy, saltwort, glasswort, saltgrass, sea lavender, salt jointgrass, <br />leatherfern, and mangroves. Shallow ditches are numerous in this <br />wetland which is essentially impounded except for a flap -gated culvert <br />connecting this system to a tidal marsh farther east ("D", Figure 1). <br />The flap -gate is on the tidal end of the culvert, so tidal penetration <br />occurs only via the imperfectly fitting flap -gate, or when the gate is <br />intentionally opened. Groundsel bush and Brazilian pepper occur on <br />elevated mounds and ridges in this marsh. <br />Two distinct 5 -acre marshes occur on the site. There is a tidal <br />high salt marsh ("D", Figure 1) with a perimeter ditch and cross ditches <br />supporting red, black, and white mangroves east of the southern end of <br />marsh. It has a 30 -foot -wide direct connection to the Indian River. <br />The development tract also includes 5 acres of an impounded marsh ("E", <br />Figure 1) at the southeast corner of the site. The 5 acres within this <br />project consist of a saltgrass marsh with mangroves bordering the <br />ditches at the marsh perimeter. This wetland is part of a triangular <br />16 -acre Brazilian pepper -marsh -mangrove system extending east to the <br />Indian River shoreline berm, and is the only completely impounded <br />wetland on the site. <br />Southwest of wetland "C" is a highly disturbed 20 -acre tract with <br />high ground dominated by Brazilian pepper, Australian pine, groundsel <br />bush, and other upland and transitional species ("F", Figure 1). The <br />wetlands and ditches in this area support cattails, smartweed, bacopa, <br />pluchea, and other opportunistic wetland species. <br />The applicant proposes to construct approximately 38 acres of <br />freshwater lakes and marshes to serve as project amenities, sources of <br />fill, stormwater retention basins, and irrigation sources. These lakes <br />and channels would occur on the western two thirds of the property, and <br />would be divided into 3 drainage basins which are briefly described in <br />the ADA. Generally, the basins would be connected in series via <br />overflow structures, with the final freshwater system outfalling into <br />the proposed estuarine channels. Few design details for the freshwater <br />system are presented in the ADA, but this system could potentially <br />provide significant fish and wildlife habitat. This appears to be one <br />of the developer's intentions, but we would need much greater design and <br />management details to assure this potential would be realized. <br />Provision of diverse slopes, habitats, and depths in the freshwater <br />system is essential to development of productive fish and wildlife <br />habitat. Transitional and upland buffers around created wetlands, <br />proper contouring and diverse species establishment in the created <br />wetlands, water level fluctuation and management, minimal shoreline <br />maintenance, control of exotic or egressive native plant species, and <br />water quality control are critical to long-term maintenance of <br />productive freshwater systems. The ADA contains an appropriate <br />framework for such a system, but does not include sufficient details to <br />ensure success. We would gladly work with the applicant to ensure <br />development of a high-quality, productive freshwater system. <br />62 <br />� s � <br />