I was again struck aghast by comments you made at last night's meeting just before the very controversial 3 to 2 vote to accept the "settlement" with developers to substantially change the conservation elements of the current Alachua County comprehensive plan. You asked county staff whether the plan, as amended with the proposed changes, would still protect natural resources. Of course, the answer from staff was yes. With all due respect, this line of reasoning only serves to obfuscate the real issues with the proposed amendments. All comprehensive plans protect natural resources, but this is meaningless. The legitimate question is whether the amended plan would *adequately* protect natural resources.

As a research scientist with a Ph.D. in Wildlife Ecology and Conservation and much relevant work experience in assessment and planning projects to conserve this region's biodiversity, I am very qualified to make an expert judgment on whether the amended plan adequately protects Alachua's natural heritage. To make that clear, my recent work experience includes:

• 1) I lead the landscape research team of the Multi-Species and Ecosystem Recovery and Implementation Team for the United States Fish and Wildlife Service to identify all areas and all policies needed to effectively recover all federally listed species in south Florida including the Florida panther, red-cockaded woodpecker, Key deer, and many others.
• 2) I am under contract with the United States Environmental Protection agency to develop guidelines to be used by all E.P.A. regions to comprehensively identify all critical ecosystems needs to effectively conserve biodiversity and ecological services throughout the United States.
• 3) I am under contract with the Southwest Florida Water Management District to develop a Geographic Information Systems (GIS) application that will help them assess all potential impacts of development activities on species of conservation interest.
• 4) I work with the Florida Department of Environmental Protection to identify, prioritize and protect the most important wildlife corridors and landscape linkages across the state.
• 5) I have recently completed an analysis for the Florida Chapter of The Nature Conservancy to identify all sites needed to effectively conserve biodiversity throughout the Florida peninsula.
• 6) I have worked with several county governments and NGOs (including Indian River, St. Johns, and St. Lucie) to identify the most important natural areas for protecting biodiversity in their counties.
• 7) I have worked with the East Central Florida Regional Planning Council to develop a GIS application to identify areas of ecological significance to avoid impacts from development.
• 8) I worked under contract with the Florida Fish and Wildlife Conservation Commission to develop habitat and regional landscape management guidelines to effectively conserve the Florida black bear.

As I have stated now on numerous occasions, the amended plan will not adequately conserve Alachua County's natural heritage. Many species including the Florida black bear will be in danger of extirpation under the amended plan. A large body of research shows that:

• 1) wetland buffers of 100 feet or less will not protect most wetland- dependent species and will lead to degraded wetlands significantly affected by nearby development.
• 2) Typical 5-acre lot development severely degrades wildlife habitat.
• 3) Protecting 50% or less of uplands within areas of significant habitat will not result in conservation areas large or connected enough to sustain functional ecological processes and most species.

Therefore it is fallacious to argue that the amended plan will adequately protect natural resources. It is also inappropriate to compare the amended plan with the old Alachua County comprehensive plan adopted in 1991 or most other existing county comprehensive plans. The state growth management laws and comprehensive planning requirements were enacted to provide for orderly growth that would minimize sprawl, reduce future infrastructure costs, and effectively protect natural resources. In practice, the comprehensive planning process has failed and the vast majority of county comprehensive plans, including the plan adopted in 1991, promote sprawl development patterns that cost citizens much more money, destroy and degrade wildlife habitat, endanger water resources, and reduce quality of life.

In contrast, the existing plan would limit ex-urban sprawl and do a very good job of protecting large, connected blocks of uplands and wetlands needed by most species of conservation interest while still allowing a significant amount of new development. The existing plan is exemplary of how growth management should be done, not how the Department of Community Affairs has allowed it to become.

As a politician it is your prerogative to argue that the amended plan will better balance the interest of those who want to conserve Alachua County's natural heritage and future quality of life with the financial interests of others who oppose adequate environmental protection. But it is misleading at best to suggest that the amended plan will still protect natural resources when all of the evidence shows that it will do a poor job of protecting the environment compared to the existing plan. Sincerely, Tom Hoctor

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