July 31, 2003


Mr. Ray Judah, Chairman                                            

Lee County Commission                                                          

PO Box 398                                                                            

Fort Myers, FL 33902-0398               


Re:       Future of the Density Reduction/Groundwater Resource Area in Southeast Lee



Dear Chairman Judah and Lee County Commissioners:


This letter from the undersigned conservation organizations active in Lee County is to support an expanded study of the Density Reduction/Groundwater Resource area of Southeast Lee County (“DR/GR”) to address natural resource and planning issues that go far beyond the mining and groundwater resource studies that have been discussed. Any discussion of the future of the DR/GR must be based upon an expanded study to gain a comprehensive understanding of all of the resources located in the DR/GR area. We have enclosed supporting information with this letter documenting the need for an expanded study.


As you are well aware, the DR/GR is of great importance to the environmental, economic, and social future of Lee County. The DR/GR was established in 1989 with the goals of controlling density and sprawl and protecting our groundwater recharge lands. While the DR/GR has been relatively successful at achieving these goals, this land use designation has not been successful in protecting valuable habitat for a plethora of State and Federally protected wildlife species, nor has it adequately prevented degradation of water quality in the Estero Bay watershed. We believe that it is time to address these shortcomings.


From land cover maps for 1987 and 1997 we have estimated that, during this ten year period before and after the creation of the DR/GR, 10,000 acres in the DR/GR were cleared for agricultural uses, 2,000 acres were cleared for mining and housing, and about 2,400 acres were impacted by other uses. This is nearly 16% of the DR/GR area in Southeast Lee County.  It is also important to keep in mind that 7,440 acres of DR/GR land have been taken out of the original DR/GR area and re-designated to more intensive land use categories in the fourteen years since the district was created. These include 133 acres converted from DR/GR to Urban Community in the early 1990’s to support the commercial needs of Lehigh Acres; 2,530 acres converted to University Community in 1992 to support Florida Gulf Coast University; 1,920 acres, known as the Garjulo property, converted to Rural in 1999 for residential development; and 2,857 acres converted to Airport Commerce to accommodate the expansion of the Southwest Florida International Airport. Because information on land cover changes by parcel is not readily available, we recommend a more definitive study to determine the impacts to native habitat that have occurred since the DR/GR District was created and how remaining habitat can be best protected in future land use decisions.

We encourage the County to move forward with a comprehensive study of the DR/GR to ensure that the best scientific information is gathered and made available for review as we  look for opportunities to strengthen protections for wildlife habitat, wetlands and flowways, and water quality in the DR/GR, while preventing sprawl. We recommend that the study address the following issues:


1)      Land Cover Changes

The conversion of native vegetation and wetlands in the DR/GR, as discussed above, has had a negative impact on the area’s wildlife habitat and water quality. Included in a DR/GR study should be a detailed examination of the loss of native vegetation and wetlands in the DR/GR.


2)      Panther Habitat

Except for Southwest Florida, the Florida panther is extinct throughout its historic range. Protection of panther habitat in southeast Lee County is critical to the longevity of the species. The majority of the DR/GR has been delineated as Priority I/II or Primary Panther Habitat.  Further degradation of panther habitat could lead to extinction of the species. Any DR/GR studies should examine increased protections for panther habitat.


3)      Wading Birds

Current available data show at least 10 substantial colonies of wood storks and other wading birds within or near the DR/GR. Any land use changes in or around these nesting and foraging areas will have direct effects on the health of these bird populations and the wetland ecosystems on which they depend. Any DR/GR studies should examine possibilities of increasing protections for wading bird nesting and foraging habitats, including critical isolated, small wetlands that may not be considered by State and Federal wetlands laws.


4)      Water Quality

Recent research conclusively demonstrates declining water quality in the Estero Bay Watershed. The DR/GR forms the headwaters of this watershed, and it is critical that we fully understand the impacts of land use decisions within the DR/GR on the water quality of the entire watershed. Strategies to improve water quality in the DR/GR and reduce the impacts of land use changes should be examined in greater detail. The protection of the Outstanding Florida Waters that are located downstream and drain the DR/GR should be included in this study.


5)      Flowways and Wetlands

The protection of flowways and wetlands in the DR/GR will have a positive impact on water quality and protected species in the region. A delineation of past impacts to flowways and wetlands in the DR/GR should be part of any study as well as a review of options for increasing the protection of remaining flowways and wetlands and for restoration of significant historic flowways.


6)      Groundwater Resources

It is our understanding that a focus of the Smart Growth Committee study proposal will be a reexamination of groundwater resources in the DR/GR. In addition to gathering and updating past research conducted in the area, which has demonstrated the need for the groundwater recharge component of the DR/GR designation, the study should also include interactions between surface water and groundwater, tracer travel time studies of groundwater, and the flow of groundwater toward public wellfields. The excavation of surface water lakes should also be examined to determine and quantify the resulting net groundwater resource losses to evaporation.


7)      Planning Issues

Any decisions regarding the DR/GR in Southeast Lee County will have long-term planning implications throughout Lee County. Decision making should be guided by a long-term vision for the area rather than through piecemeal conversions of land use for short-term gain. Decisions made should be based on sound planning principles, discouraging sprawl, and in the long-term best interests of Lee County as a whole. The DR/GR represents the last opportunity for Lee County to protect a large area of undeveloped land for the benefit of citizens and the environment alike.


The supporting documents and information that are enclosed with this letter clearly demonstrate the need for further consideration of these natural resource and planning issues for the DR/GR. It is not enough to simply study the groundwater resources and the potential areas for mining. Such an expanded study, however, does not presuppose changes to the DR/GR designation, nor are we calling for any at this stage. What we are calling for are stronger protections for the wildlife habitat and other natural resources in the area. We appreciate your consideration of this information and request that we be included in all discussions about the DR/GR as the studies move forward.





Gary A. Davis, Director,

Conservancy of Southwest Florida


Ellen Lindblad, Executive Director

CREW Trust


Michael Andoscia, President

Responsible Growth Management Coalition


Bobbie Lee Hasty, Chair

Sierra Club Calusa Group


Nancy Anne Payton, Southwest Florida Field Representative

Florida Wildlife Federation


Bradley M. Cornell, Environmental Policy Analyst

Collier County Audubon Society





cc:        Wayne Daltry, Director, Lee County Smart Growth

            Mary Gibbs, Director, Lee County Department of Community Development

            Colleen Castille, Director, Florida Department of Community Affairs

            Charles Gauthier, Interim Director, Division of Community Planning,

Florida Department of Community Affairs

Mayor Paul Pass, City of Bonita Springs

            Mayor Jim Humphrey, City of Fort Myers