Florida bonneted bats are listed by US Fish and Wildlife as endangered, and protected by the Endangered Species Act.
1. The applicant’s environmental consultant’s reports confirmed some good things:
-they recorded 2048 bonneted bat calls (this is considered high bat activity)
-291 calls were within 1.5 hours after sunset (indicates roosting is likely to occur nearby)
-4 calls contained “social calls” (also criteria for high bat activity)
2. Our concerns:
-required weather conditions to collect data were NOT met on 19/28 of the acoustic survey nights (so the activity could be significantly higher)
-an emergence survey was not conducted (to identify possible additional trees with cavities)
-they provided a cavity tree and roost survey (Dec 16/17 2020) but only identified 7 trees with cavities (there are 580 trees identified on the golf course)
-they didn’t find any evidence that the bonneted bat is roosting on the golf course (they checked the existing old building structures, and the 7 trees with cavities)
-no documentation has been provided of any consultation between the applicant and US Fish and Wildlife, even though the US FWS 2019 consultation key says “Applicants with projects in the South Florida Urban Bat Area should contact the USFWS for specific guidance addressing this area and individual consultation.” pg 5 of US FWS letter and guidance available here: 2019 US FWS Bonneted Bat Consultation Key
3. DERM (Division of Environmental Resources Management) Memo dated November 8, 2021 states that they recommend approval of the proposed development with the following condition:
“Prior to obtaining the earlier of a soil improvement permit, building permit, or tree removal permit within 330 feet of the documented rookery, the Applicant shall submit to DERM: (i) the results of six (6) site inspections to be conducted every month between March 2022 and August 2022, during the Florida Fish and Wildlife Conservation Commission’s recommended wading bird survey period for Florida’s South Zone; and (ii) a plan for DERM’s review and approval demonstrating how the nesting, feeding, and roosting habitat of the little blue heron, the tricolored heron, and any other Federal or state threatened, or endangered species will be protected and buffered from the proposed development and to ensure further degradation of such habitat is not authorized; (iii) a plan for DERM’s review and approval demonstrating how County designated species shall be conserved and (iv) agreement to implement the Florida bonneted bat best management practices (BMPs) that have been approved by DERM. The applicant has acknowledged that compliance with this condition could result in the permitted scope of the development being reduced.”
4. We feel strongly that much more information is needed before any permits should be issued. We are particularly concerned about the trees, since we don’t have confidence in the acoustic monitoring or cavity search/roosting survey. Trees are critical since bonneted bats may roost in the trees, and also because 577 of the 580 trees are planned to be removed. Full wildlife utilization MUST be provided before ANY trees are removed from the property.