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• Since the Gibson Street roadway improvement will be 700 linear feet in length and may affect 30 to 40 feet of wetlands throughout its entire length, the total Gibson Street wetlands impact could be about a half acre. This is a half acre more of wetlands impact than was anticipated by the HCP and ITP. Both of those documents envisioned the right-of-way being abandoned and being incorporated into the NSCA property. For the Kirrie proposal to be implemented, the wetlands issue will need to be addressed by two agencies First, FWS will need to approve the improvement of Gibson Street since the ITP is conditioned on the right-of-way being abandoned. Second, the St. Johns River Water Management District (SJRWMD) will have to issue an environmental resource permit for the wetlands impact. There may be mitigation required by that permit Besides wetlands, native uplands will also be impacted by the Kirrie proposal. Although the NSCA Natural Communities Map indicates that the County owned land designated by the Kirrie proposal for swap is scrubby flatwoods, a recent field check revealed that the 60 foot wide strip is xeric oak scrub. Unlike scrubby flatwoods the subject strip does not have a predominant tree canopy; instead, it consists largely of oak scntb and other scrub type vegetation. The County property proposed for swap contrasts significantly with the Kirrie land proposal for swap. Unlike the County property, the Kirrie land is not resource" area. It is open, previously cleared property. Construction of an access road on the County 60 foot strip would result in the removal of virtually all the xeric scrub vegetation on the property. Because xeric scrub is the most productive scrub jay habitat, the road construction will impact a federally protected species. In contrast to the County 60 foot stnp, the Kirrie swap land is not resource property which would provide comparable benefit if conserved. For that reason, FWS may require mitigation for the loss of resource value. Although the Kirrie swap strip is not resource property. it could serve to preserve resource land. Because a 20 to 30 foot fire break must be created and maintained along the perimeter of the NSCA to allow for prescribed burns, the unvegetated Kirrie swap strip could serve as the fire break along that boundary of the NSCA With that, there would not be a need to clear resource property for a fire break. That advantage is offset, however, by the need to create fire breaks along portions of both sides of the new access road and portions of both sides of the 700 foot Gibson Street paved area. These fire breaks are not needed if the Kirrie proposal is not implemented. • Infrastructure As indicated, the Kirrie proposal involves construction of 700 feet of Gibson Street and construction of an access road on the County swap strip. With these roadways management of the NSCA will be more difficult. These roadways will physically separate a portion of the NSCA from the remainder of the conservation area, making both fire management and site security more difficult. To prevent illegal dumping and prevent off road vehicle access, the County will need to fence both sides of both roadways. FEBRUARY 5, 2002 • -65-