November 15, 2003

Paul O’Connor, Director
Lee County Planning Division
Department of Community Development
1500 Monroe Street
Fort Myers, FL 33902

Re: Inclusion of a comprehensive study of the DR/GR in the 2004 Lee County EAR

Dear Mr. O’Connor:

The undersigned conservation organizations active in Lee County have organized to explore opportunities to protect environmentally sensitive lands and prevent urban sprawl in the Density Reduction/Groundwater Resource (DR/GR) lands in southeastern Lee County. In late July of this year we delivered a document to Lee County outlining the ongoing loss of wildlife habitat and wetlands in the DR/GR and listing several environmental concerns that need to be addressed in studies of the area.

The purpose of this letter is to request a comprehensive environmental and planning study of the DR/GR area to be a part of the 2004 Lee County Evaluation and Appraisal Report (EAR). We request that in the draft “Major Issues List for Lee County” under section 4 (Density Reduction/Groundwater Resource Areas) you add an issue c), “Protection of Wildlife Habitat and Wetlands in the DR/GR,” and that this issue be addressed through a comprehensive study of the DR/GR lands in southeastern Lee County. The study should address all issues raised in our document that was delivered to Lee County on July 31, 2003. As we explore opportunities to increase protections in the area, it is most appropriate to begin with a comprehensive look at current conditions that follows with recommendation based upon findings from the study.

Early on the EAR process it what recognized that the protection of eastern lands in Lee County was a concern. In the Department of Community Affairs Preliminary Major Issues list they cited “growth pressures occurring in eastern portions of the region” as a major issue, and asked if the comprehensive plan ensured protection of major natural systems. As we documented in our original document, our natural areas in southeastern Lee County have been eroded under the current DR/GR policies.

The development of a comprehensive environmental and planning study of the DR/GR will effectively gauge the overall health of the region and effectively evaluate the other two issues associated with the DR/GR in the Major Issues list, those being a) Effectiveness of DR/GR regulations and b) Allowable uses in DR/GR areas. A comprehensive study will also address other items from the Major Issues list including, but not limited to: resource protection, effectiveness of anti-sprawl regulations, environmental quality of local waterways, and regulations regarding native and non-native species.

In addition to evaluating several of the Major Issues raised by Lee County citizens, the State of Florida Department of Community Affairs, and Lee County staff, a comprehensive assessment of the DR/GR will also greatly aid the County in its overall evaluation of the Comprehensive Plan during the EAR process. A study such as this will be able to draw on data collected from several other completed and ongoing studies, including the Southwest Florida Feasibility Study and the Department of Environmental Protection’s Impaired Waters Program. Utilizing data already collected will lessen the amount of time and funds needed for the study.

In closing, we encourage Lee County to include the above request in the EAR process. A comprehensive look at the DR/GR lands in southeastern Lee County is the best approach to answering many of the questions and concerns raised through the EAR process.


Gary A. Davis Nancy Anne Payton
Director, Environmental Policy Southwest Florida Field Conservancy of Southwest Florida Representative
Florida Wildlife Federation

Ellen Lindblad, Executive Director Michael Andoscia, President
CREW Land and Water Trust Responsible Growth Management Coalition
Bradley M. Cornell Bobbie Lee Hasty, Chair
Environmental Policy Analyst Sierra Club Calusa Group
Collier County Audubon Society

Paul Andrews, President
Sanibel Captiva Audubon Society

cc: Wayne Daltry, Director, Lee County Smart Growth
Mary Gibbs, Director, Lee County Department of Community Development
Colleen Castille, Secretary, 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