March, 14, 2008
Regulatory Division, Special Projects/Enforcement Branch, Jacksonville District Corps of Engineers
Department of the Army
2170 SW Canal Street
Stuart, FL 34997
Re: Permit Application No. SAJ-2006-7857 (IP-AAZ)-Seminole Pratt Whitney Road extension from Northlake Boulevard to Beeline Highway/SR710, Palm Beach County
The Palm Beach County Environmental Coalition (PBCEC) is opposed to the Expansion of this road. It should never be built, It should never have been proposed. We suggest a denial of this permit and the pursuit of a no-build option.
It will be a four-lane road divided highway 160-feet wide, comparable to Northlake Boulevard, Six miles in length along the eastern boundary of the J.W. Corbett Wildlife Management Area going basically straight north from the southern public entrance to Corbett. It will permanently separate two natural areas, Corbett and Palm Beach County Hungryland Slough Natural Area, making the hydrological connection (sheet flow) of water from Corbett to Hungryland Slough Natural Area impossible, hindering regional restoration efforts. We feel that Mecca farms, which is adjacent property now in public ownership, and Vavrus, which is identified on the Northeast Everglades Natural Area (NENA) map by the County´s Environmental Resource Management (ERM) as desired land, should be restored--this road would lessen the restoration value of those sites.
The road will be built on a 2/3 mile long, 100-foot wide portion of southeastern Corbett (10 acres) and on 2 acres of northeast Corbett; it fills over 28 acres of wetlands, and likely much more when wet flatwoods and wet prairie area included. There will secondary impacts to wetlands next to the road which will have hydrologic issues due to drainage through culverts under road for the entire length of the extension.
The Permit application states that no Bald Eagles, Red-cockaded woodpeckers or Everglades snail kites were observed in the wildlife survey in the applicant´s Environmental Assessment. Participants with the PBCEC have visited the proposed corridor of the road extension (and the surrounding areas) on multiple outings and have seen the abovementioned listed species on numerous occassions in the area.
We have seen for ourselves that wading birds, including: wood storks, white ibis, little blue heron, roseate spoonbill, snowy egrets and tricolor herons, will lose foraging areas. We believe there will likely be increased road kills for sandhill cranes. Road kills will also increase for reptiles, amphibians, small mammals and large, both prey and predator. Fencing and underpasses for wildlife will not help, as we can look at dead animals all along Northlake Blvd outside the fences. This road will also remove Hungryland Slough Natural Area from Red Cockaded Woodpecker (RCW) recovery plans. The road will cause petro-chemical runoff into wetlands and will be vector for exotic plants.
Portions of the Hungryland Slough Natural Area were purchased from unwilling sellers through eminent domain for environmental preservation and portions of this Natural Area are being restored for mitigation credits (the value of which is questionable when it is cut off from Corbett and becomes an isolated County park). This road would further push the climate of distrust that currently exists between the general public and government agencies regarding important restoration-oriented land acquisition projects.
We must also ask why this road is desired. Will it really improve transportation? To where? For who? It has been planned for 30 years, at a time before the Comprehensive Everglades Restoration Plan (CERP) was created. Government agencies once wanted to drain the entire Everglades; we now recognize the value of restored hydrology for both wildlife habitat and human water supply. We now know the cumulative danger to the Everglades watershed of ´death by a thousand cuts´. Just because a road is in the Palm Beach County Comprehensive Plan, does not mean we are stuck with it. Exemptions are made for private developments, many of which are against the public interest, all the time; why would we not make exemptions for wildlife and the protection of public land?
The Seminole Pratt extension is not needed for evacuations. Hurricane plans emphasize local evacuations from the coast to the area of this road. It is not needed for access to central Martin County, which currently has no housing or development--recent polling has shown that it is not desired there. It appears that the only apparent reason for this road is to facilitate the development and expansion of two industrial complexes next to Corbett: Pratt Whitney and the North County Industrial Park. These complexes were intended to be anchors for development that is never coming. They were sent into rural Palm Beach County on the trojan horse of ¨more jobs¨, similar to the recent debacle with the Scripps Biotech Research Park (which was exposed and defeated). The inhabitants of the Everglades region—human and non-human--can´t afford to be tricked by greed and private interests any longer.
It has been said that this extension is a “missing link” in the Seminole-Pratt Whitney Road. Well, what about the missing link in the Hungryland Slough/Loxahatchee River watershed that we are spending billions in public money to restore?!
A responsible proposal to get people from the Acreage community to the coast would focus on improving traffic flows on Northlake, Okeechobee and Southern Boulevards, which are existing corridors. More specifically, the PBCEC wants to see increased public transit access in theses areas--in light of our Governor´s Executive Orders on Climate Change, we feel strongly that this is where County and State Transportation funds should be directed. And most importantly, for sane traffic flow, as well as the longterm viability of our South Florida communities, we must stop over development and sprawl in western Palm Beach County immediately. Denying this permit is a step in the direction of sustainability.
Thank you for considering our comments. If you have any questions regarding our position, please do not hesitate to get in touch,