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C-1 <br />• <br />.BOARD OF COUNTY Y COMMISSIONERS <br />1890 25th Street, Vero (leach, Florida 32960 <br />TeleWwM: (305) 567-M <br />June 2, 1987 <br />Mr. Frank B. McGilvrey, Coastal <br />Barriers Coordinator <br />Coastal Barriers Study Group <br />National Park Service <br />U.S. Department of the Interior <br />P.O. Box 37127 <br />Washington, D.C. 20013-7127 <br />Dear Mr. McGilvrey: <br />SunCom Telephone: 424-1011 <br />Please be advised that the Board of County Commissioners of <br />X11dian River County, Florida wishes to comment on the Department <br />of Interior's proposed modifications to the existing Coastal <br />Barriers Resource System. The primary concern of the Commission <br />is Unit P-10, located on the barrier island in north Indian <br />River County, For the reasons listed below, it is the Com- <br />mission's feeling that the cNisting P-10 Unit was incorrectly <br />designated as an undeveloped coastal barrier and that the <br />Proposed vdditionw to P-10 are inappropriate and inconsistent <br />With the intent of the Act. <br />When designated in 1982, the existing P-10 Unit comprised a 1.7 <br />mile long portion of the barrier island. The northern point of <br />the existing P-10 Unit is located approximately two miles south <br />Of tile Sebastian Inlet. The Department of the Interior in <br />Report To Congress: Coastal Harrier Resources System, Volume 14, <br />Florida (East Coast), describea this unit as follows, "The only <br />apparent alteration of the habitat other than the highwa <br />that: of mosquito control ditches throughout the southy is <br />ern half is <br />the mangrove swamp".of <br />That statement, however, is not an accurate description of the <br />existing P-10 Unit now nor its condition in 1982. More than <br />half of the existing P-10 Unit consists of an 84 unit subdivi- <br />sion of river to ocean 'lots which was platted in 1924. In 1983, <br />there were 28 dwelling units on these lots within the area <br />designated as Unit p-10. Since 1983, at least eight more houses <br />have been constructed or are presently being constructed on lots <br />in this subdivision within P-10. Not only did the 1983 develop- <br />ment pattern conflict with the Department of Interior'sdescrip- <br />tion of the P-10 Unitt but when applying the Department's 1 unit <br />per 5 upland acres, completed infrastructure, or one quarter <br />mile of undeveloped shoreline criteria to determine whether the <br />area is considered developed, the P-10 Unit would be considered <br />developed. Therefore, it is the County's position that the <br />existing P-10 Unit was incorrectly designated and should now be <br />deleted from the CBRS. <br />Regarding the proposed additions to the P-10 Unit, please be <br />advised that the Board of County Commissioners feels that the <br />new areas proposed for <br />part of the CBRS. inclusion should not be designated as <br />Although most of the area proposed to be <br />added to the P-10 Unit is not characterized by urban develop- <br />ment, much of it is developed as agriculture and is presently <br />50 <br />