May 24, 2003


Bernard Piawah, Planning Manager

Department of Community Affairs

Division of Research, Planning and Management

2555 Shumard Oak Boulevard

Tallahassee , Fl 32399


Re: City of Fort Myers proposed amendment 02-MA-1 and 2


Dear Mr. Piawah:


I am writing this letter on behalf of the Responsible Growth Management Coalition in regard to proposed amendments to the City of Fort Myers Comprehensive Plan 02-MA-1 and 02-MA-2 known as the Parker Daniels and Palomino Projects. 


The projects were recently approved by the Fort Myers City Council, after annexing the lands into the City, despite its location next to the Six Mile Cypress Slough.  These projects would adversely affect the slough system and its economic value for the citizens of South Florida .  The Parker Daniels parcel, for instance, bisects a Cypress Arm that is a critical water flowway into the Six Mile Cypress Slough.  The importance of this Cypress Arm is confirmed in the 1990 Six Mile Cypress Watershed Plan which was adopted by both Lee County and the South Florida Water Management District. The proposed amendments approved by the City Council will increase the density in these areas from 1 unit per acre to 3 units per acre. This will continue the detrimental impact from past development around the slough.


During the public hearing before the Fort Myers City Council consultants for Parker Daniels claimed that the proposed developments would be consistent with other developments already approved by Lee County .  They offered no comparative data, however, to demonstrate that development around a significant Cypress Arm is consistent with other developments around the slough.  No Data was offered, in fact, to demonstrate the impact of past developments on the slough.  For instance, in the last 13 years the hydroperiod for the slough has averaged 120 days.  This is only half of the 250 day hydroperiod that the National Audubon Society determined was typical under natural conditions for comparable sloughs.  The reduction of hydroperiod in the slough has already aided in the spread of invasive exotic plant species such as the Brazilian pepper and the melaleuca.  This has reduced the habitat for many listed species such as wood storks. 


The slough’s hydrology, water quality, natural fire regime, habitat composition and topography has been disturbed in these last thirteen years. The DEP’s Impaired Water process has divided the Six Mile Watershed into two water body ID’s.  Both ID’s were found to have dissolved oxygen below healthy levels.  The upper portion of the slough was also found to be impaired due to high nutrient levels.  It is obvious to all concerned in Lee County that the current declining health of the slough should encourage greater protection, not increased developmental pressure on its borders. A forthcoming TMDL will be determined to limit pollutants entering the slough.  Limiting dense development in this area will be necessary to improve water quality. 


Of equal significance the subject parcel contains 274 acres of uplands that provide a buffer to the slough and a refuge for wildlife during high water.  The subject parcel also includes 168 acres of wetlands that provide an important habitat for many wildlife species. The Florida Fish and Wildlife Conservation Commission has designated a portion of this area as a Biodiversity Hotspot and determined that the site contains 7+ focal species, the highest rating available.  Their Integrated Wildlife Habitat Ranking System gives a portion of this area the highest ranking of 10.  Many federally and state protected species have been observed in the subject areas such as the bald eagle, snowy egret, great blue heron, green heron and white ibis.  A Florida Black Bear also utilizes the Six Mile Cypress slough and is believed to forage on the subject parcels.  With the wetlands removed from buildable lands, the density on the uplands may be much higher than the present allowed.


The Six Mile Cypress slough is not just a sensitive and beautiful wetland/upland environment.  It is, as Lee County Commissioner Ray Judah stated during the City Council hearing, the Central Park of Lee County, serving City and county residents and thousands of visitors to our unique environment.  The Six Mile Cypress Slough Preserve attracts over 50,000 visitors a year.  These visitors come to observe the abundant wildlife and floral diversity of the slough.  A recent report by the Florida Fish and Wildlife Conservation Commission states that wildlife observation brings over $1.6 billion into Florida .  The financial impact from wildlife observation and other forms of eco-tourism is of significant importance for the City of Fort Myers and in Lee County , which depends upon tourism to fuel its economy, especially in this time of tremendous growth. 


If the environment suffers, the floral and faunal diversity declines; visitors will no longer be inclined to come to the preserve.  The economic impact from this alone cannot be calculated.  Add on top of this that the Six Mile Cypress slough is within the Estero Bay Watershed.  Any negative impact on the slough will be transferred to Estero Bay which has been designated an Outstanding Florida Water.  Florida state regulations state that increased construction and density in such sensitive areas should not be allowed unless “clearly in the public interest.” 


The Parker Daniels and Palomino projects are clearly in the private interests of the owners without regard to the impacts on Southwest Florida ’s biodiversity, environmental health or economy.   For this reason the Responsible Growth Management Coalition requests that you object to the City of Fort Myers Comprehensive Plan Amendments 02-MA-1 and 02-MA-2. 


Thank you for your time and attention in this matter.




Michael Andoscia M.A.

President: Responsible Growth Management Coalition

President RGMC