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OCT, 2 a ms BOOK 62 PAG -L 513 The eastern indigo snake (threatened) has been observed on site, and would be more adversely impacted by the extensive habitat destruction proposed than by enlightened management of the wetland system. Also, the threatened Atlantic salt marsh snake, an endemic subspecies found only in the salt marshes of Volusia, Brevard, and Indian River counties, may occur in the tidal marshes of this tract. Enhancement of the salt marsh system, rather than conversion to a marina and channel complex would best provide potential habitat for this species. Severe pesticide (DDT) contamination of the wetland soils, due to pumped runoff from the adjacent citrus groves, is another problem confronting the marina proposal. This subject requires extensive analysis to determine the best available technology for safeguarding the Indian River from DDT contamination. Regarding the tidal and circulatory characteristics of the Indian River and proposed marina system, the applicant's hydrological consultant has verified that the proposed marina system would not flush adequately to prevent degradation of the marinas and, ultimately, the Indian River. System modifications to enhance flushing would require additional channels into the Indian River. Since no significant dredging in this Aquatic Preserve is acceptable, we must strongly recommend, as we have at every past meeting with the applicant, that only the existing marina basin and channel be developed as navigational waters. Even if these environmental concerns were not paramount, permitting construction of such a large marina system before completion of the Treasure Coast Regional Planning Council and Indian River County marina siting elements of their respective comprehensive plans would be inappropriate. Such action would allocate a disproportionately large percentage of the county's marina slips to one development project. Despite the obvious financial advantage for the developer of such a system, it is erroneous to claim that development of this tract of land requires this marina system to be financially rewarding. As we have repeatedly stressed to the applicant, we believe the tract is environmentally suited to development as proposed, except for the marina - estuarine channel system. In light of the above discussion, we recommend the following alternative scenario as an appropriate development plan: 1) Develop the existing uplands and freshwater lake system _ essentially as proposed, after implementing our previous recommendations and stormwater runoff precautions. 2) Limit marina development to the existing basin and navigable channel, with possible marina expansion into adjacent uplands or the highly disturbed northwest corner of wetland "A". A shallow flushing channel from the southern end of the existing basin to the Indian River may be appropriate. Also, the two fill pads in the basin could be scraped down to -5 feet msl to improve circulation, with the resulting spoil used to shallow portions of the basin to -5 feet msl. 3) The remainder of marsh "A", and the northern lobe of marsh "C" (north of the historic tidal creek) should be restored as a salt marsh impoundment. Management should include summer flooding for mosquito control as necessary, and connection to the Indian River to maximize tidal exchange between these systems. 4) The southern portion of marsh "C" (south of the historic tidal creek) should be restored and managed in the same manner as the marsh in 3) above. 64