Dear Governor Crist and Members of the Board:

The District has recently moved to suppress and exclude Technical Publication SJ2001-3 Assessing the Potential Occurrence of Rare, Threatened, and Endangered Species in the Upper St. Johns River Basin. At a June 6, 2007 workshop Bill Kerr, a member of St. Johns’ Governing board, said decisions needed to be based on the best scientific data available and assured the Indian River County Board of Commissioners that the District would use the best scientific data possible to determine the conservation value of the properties to be exchanged. He reminded the commissioners that they should not ignore the scientific data. It appears to me that the District has chosen to ignore the best scientific data and selected that data which it found most useful in achieving its objective of dispute settlement.

In its evaluation of “environmental value”, the District presented 1980’s vintage data which we do not feel is either the most current or best. The District had available the above mentioned report which is a purely scientific document from 2001.

It also had available the Florida Forever Conservation Needs Assessment first published in 2000 and subsequently updated. I believe the portion dealing with corridors was most recently updated in 2004 and showed need for increases, not decreases, to corridors and Sand Lakes is part of a corridor. This document was prepared for use as a tool for making acquisition decisions under Preservation 2000. It would seem relevant to surplus decisions also.

The District stated they don’t believe the corridor will be achieved and based that assertion on the unwillingness of the property owners to the North (Ansin) and the South (Corrigan) to sell and cost. In previous correspondence, I have acknowledged that we will probably have to rely on regulatory means to with regard to the Ansin’s. I remind you that it was the Districts decision to surplus Berry Groves that broke the connection of Sand Lakes and the Ansin property with the Blue Cypress Water Management area. The District is unilaterally determining what can or cannot be achieved and acting contrary to the corridor preservation goals outlined by the State

After about eight years of managing Sand Lakes, the District within the month prior to the June 6, 2007 workshop finally “discovered” fifty acres of scrub jay habitat they felt wothy of continuing protection with a conservation easement. If this is an example of the quality of scientific assessment produced by District staff, I can only wonder what staff? - janitorial?

If, as we contend, the Districts environmental evaluation of Sand Lakes is flawed, then every decision and action based on that evaluation should be considered potentially flawed and subject to review.

I again urge you to accept the appeals of St. Johns Administrative action.

Very truly yours,

Katherine H. Wegel
October 24, 2007

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