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Honorable Commissioner Adams <br />December 21,1998 <br />Page 2 <br />some cases prevent, such impacts. Proper management of County -owned beach access areas and <br />development of guidelines for other beachfront properties would also mi unite impacts to marine turtles. <br />Finally, the issues associated with beachfront lighting could be addressed by undertaldng a review of the <br />existing lighting ordinances (County, Vero Beach and Town of Indian River Shores) and the level of <br />compliance with these ordinances. The HCP could suggest potential resolutions to impacts from coastal <br />lighting that is not in compliance with these ordinances. <br />To the extent that beach restoration provides suitable marine turtle nesting habitat, it is self -mitigating for <br />some level of adverse impacts. The HCP could include construction criteria designed to minimize impacts <br />to marine turtles, their nests and nesting habitat Specific design criteria to minimiimpacts to marine <br />turtles include avoiding borrow sites with sand that is too fine or too coarse or has large amounts of shell, <br />reducing the berm elevation and slope if necessary to approximate a more natural beach profile, and <br />requiring restoration of a dune at the landward edge of the fill project. <br />It is essential in our opinion to incorporate an outreach program to educate beachfront property owners, <br />beachfront builders, potential beachfront property owners, municipalities, and others about the dynamic <br />nature of the coastal area, marine turtles, and the County's HCP. Many partners could assist in this effort, <br />but it should be organized by the County. We would offer our technical assistance in this area as well. <br />We are committed to worldng with the County on this important project My staff will assist the County in <br />its development of the HCP and provide technical assistance on all marine turtle issues. Please feel free to <br />call me at (850)9224330 with any questions. <br />Sincerely, <br />,d,. A) (�� <br />David W. Arnold, Chief <br />Bureau of Protected Species Management <br />cc: Dr. Devereaux, BBCS <br />Jeff Tabar, Indian River County <br />Virginia Gilbert, Town of Indian River Shores <br />Cliff Southard, City of Vero Beach <br />Pam Dawson, Sea Oaks Condominium <br />Sandy MacPherson, USFWS <br />Jay Harrington, USFWS <br />David Godfrey, Sea Turtle Survival League <br />MARCH 2, 1999 <br />—33— BOOK 108 PAGE 4 d <br />