DRAFT
I will ask FDLE and the Inspector General of the Florida Department of Environmental Protection to investigate the proposed GUANA LAND SWAP, and its etiology. The proposal is before the Florida FDEP ARC at their meeting in Tallahassee on May 19, 2025.
Here is the unsigned staff recommendation text, from the FDEP website:
M 4:
Consider a request, pursuant to section 253.42, F.S., to exchange approximately 600 acres of
state-owned land in St. Johns County for approximately 3,066.23 acres of property within the
Florida Wildlife Corridor in St. Johns, Lafayette, Osceola, and Volusia counties. All or a portion
of the adjacent lands and the exchanged land would be placed under a conservation easement.
LOCATION:
St. Johns County
APPLICANT:
The Upland, LLC
DSL STAFF REMARKS:
The Division of State Lands (DSL) received a land exchange request from the applicant, who
owns 104.47 acres in St. Johns County which is contiguous to the Guana River Wildlife
Management Area (WMA).
The applicant is requesting to exchange four parcels located within the Florida Wildlife Corridor
totaling approximately 3,066.23 acres including approximately 220 acres within the St. Johns
River Blueway Florida Forever Project in St. Johns County, approximately 1,392 acres within
the Lafayette Forest Florida Forever project in Lafayette County, approximately 1,201 acres
within the Big Bend Swamp/Holopaw Ranch Florida Forever Project in Osceola County, and
approximately 252 acres bordering the Volusia Conservation Corridor Florida Forever Project
and Little Big Econ State Forest in Volusia County for approximately 600 acres of state-owned
land. Pursuant to section 253.42(4), F.S., the applicant shall retain a conservation easement on all
or a portion of the land acquired as a result of the exchange.
The state-owned property is managed by the Florida Fish and Wildlife Conservation
Commission (FWC). FWC has provided a memo regarding their concurrence with the exchange.
The parcels that would come under state ownership should the exchange be approved by the
Board of Trustees of the Internal Improvement Trust Fund (BOT) would be managed by several
agencies.
Proposed Exchange:
Pursuant to section 253.42(4), F.S., a person who owns land contiguous to state-owned land
titled to the BOT may submit a request to DSL to exchange all or a portion of the privately
owned land for all or a portion of the state-owned land, whereby the state retains a permanent
conservation easement over all or a portion of the exchanged state-owned land.
This request meets the criteria set forth in this section including:
1. At least 30 percent of the perimeter of the privately owned land is bordered by state-owned
land and the exchange does not create an inholding.
2. The approval would not result in a violation of the terms of a preexisting lease or agreement
May 2025 ARC Meeting Page 1 of 17Item 4: Guana River WMA Exchange
by the BOT, the Department of Environmental Protection, the Department of Agriculture
and Consumer Services or FWC.
The BOT must make a determination that the exchange of land under this subsection will result
in a net positive conservation benefit, with consideration given to the recommendations of ARC
and DSL. To inform this, staff offers the following:
• The proposed exchange will provide a net positive conservation benefit because it provides
a net gain of approximately 2,466.23 acres of additional conservation lands within Florida
Wildlife Corridor. In addition to all parcels being within or bordering a Florida Forever
project boundary, both the Big Bend Swamp/Holopaw Ranch and Volusia Conservation
Corridor Florida Forever Projects are on the 2025-2026 Florida Forever Work Plan while
the Lafayette Forest parcel is considered an essential remaining parcel in the 2025 Florida
Forever Plan.
The parcel within the St. Johns River Blueway Florida Forever Project will create a new
access point to the Deep Creek Conservation Area. The parcel within the Lafayette Forest
Florida Forever project will expand public access to the Mallory Swamp Wildlife
Management Area. The parcel adjacent to the Volusia Conservation Corridor Florida
Forever Project will provide additional access to Lake Harney as part of the Buck Lake
Wildlife Management Area and additional frontage to the St. Johns River, connecting to
the riverfront Seminole Ranch Wildlife Management Area. The parcel within the Big Bend
Swamp/Holopaw Ranch Florida Forever project protects acreage in a highly developing
are in Central Florida and will provide additional public access as an addition to an existing
locally managed park system or as an addition within the state’s managed portfolio.
• All or a portion of privately owned land will be placed under a permanent conservation
easement ensuring that this unacquired property, currently considered to be an inholding
within the WMA will no longer be considered unacquired while ensuring additional
acreage within this rapidly growing region of the state is conserved.
This request is subject to BOT approval.
DSL STAFF RECOMMENDATION:
Recommend approval to the BOT.
ARC RECOMMENDATION:
( ) APPROVE
( ) APPROVE WITH MODIFICATIONS: ___________________________________________
( ) DEFER
( ) WITHDRAW
( ) NOT APPROVE
( ) OTHER: ___________________________________________________________________
May 2025 ARC Meeting Page 2 of 17"
SITE
A N
Ponte Vedra Blv
Guana
River
d
Marsh Sanctuary
1A N
A
San Pablo
Island
P
a
l
m
Vall
e
Pa
y Rd
lm V
Guana
River
Preserve
owers Bay
alley Rd
Durbin Swamp
Nocatee
Conservation
Easement
kwy
N
oca
tee P
Nocatee Pkwy
Guana River Wildlife
Management
Area
Ponte Vedra Blvd
Durbin Creek
Vacant
Property
Nocatee
Preserve
U
S Hig hway 1 N
Twelve Mile
Swamp Conservation Area
Deep
Creek State
Forest
Guana Tolomato Matanzas
National Estuarine
Research Reserve
GTMNERR - Guana
River
Site
Lake Guana
S Ponte V
Northeast Florida Blueway
Florida Forever BOT Project
edra Blvd
1
0 2 4
Subject Parcels
Florida Forever BOT Projects
State Managed Conservation Lands
City/ County Managed Conservation Lands
Private Managed Conservation Lands
Miles
´
Exchange Parcels
St. Johns County, FL
May 2025 ARC Meeting Page 3 of 17"
Guana
River
Preserve
SITE
Guana Tolomato Matanzas
National Estuarine
Research Reserve
Guana River
Wildlife
Management Area
GTMNERR - Guana
River
Site
Nocatee
Preserve
Subject Parcels
Florida Forever BOT Projects
State Managed Conservation Lands
City/ County Managed Conservation Lands
Private Managed Conservation Lands
0 4,000 8,000
2,000
US Feet
´
Exchange Parcels
St. Johns County, FL
May 2025 ARC Meeting Page 4 of 17Mussallem
Trail Head
State R
o
ad
Riverdale
Park
"
13
McCullough Creek
Conservation
Area
Co
Saturiwa
un
ty Road 13 S
Swamp
Conservation Area
SITE
St. Johns River Blueway
Florida Forever BOT Project
207
Putnam Land
Conservancy
Putnam Parcels
Deep Creek
Conservation Area
(SJRWMD)
13
Los Ninos
Agricultural and
Conservation Easement
Palatka-to-St.
Augustine
State Trail
State Ro ad 206 W
Fish Tail Swamp
Mitigation Bank
Cora
C. Harrison
Preserve
tate Road 207
S
FSA Conservation
Easement - Tract
32C
Matanzas to Ocala
Conservation Corridor Florida
Forever BOT Project
Deep Creek ROMA
and Conservation
Easement
Road 207
S
t
a
te
Cracker Swamp
Smith Family Farms
Conservation Easements
Subject Parcels
Florida Forever BOT Projects
Federal Managed Conservation Lands
State Managed Conservation Lands
City/ County Managed Conservation Lands
Private Managed Conservation Lands
1
0 2 4
Miles
´
County Road 13 South
St. Johns County, FL
May 2025 ARC Meeting Page 5 of 17"
SITE
Deep Creek
Conservation
Area (SJRWMD)
St. Johns River Blueway
Florida Forever BOT Project
Palatka-to-St.
Augustine
State Trail
Subject Parcels
Florida Forever BOT Projects
State Managed Conservation Lands
0 1,000 2,000 500
US Feet
´
County Road 13 South
St. Johns County, FL
May 2025 ARC Meeting Page 6 of 17Bay
27
E US 2
7
"
Suwannee River
Wilderness State
Troy Spring
Trail
Conservation
Area
129
27
SITE
Little River
Conservation
Area
Troy
Spring
State Park
E US 27
Florida's First Magnitude Springs- Troy
Spring Florida Forever BOT Project
Brushy Hammock
129
Suwannee River
Greenway at
Branford
27
E
US
2
7
Stuarts Landing
Conservation Area
Grady
Conservation
Area
Lafayette Forest
Florida Forever BOT
Project
Mallory Swamp
Restoration Area
S State Road 349
Subject Parcel
Florida Forever BOT Projects
State Managed Conservation Lands
City/ County Managed Conservation Lands
1
0 2 4
Miles
´
Lafayette Timber Site
Lafayette County, FL
May 2025 ARC Meeting Page 7 of 17"
SITE
Mallory Swamp
Restoration Area
Lafayette Forest
Florida Forever BOT
Project
Subject Parcels
Florida Forever BOT Projects
State Managed Conservation Lands
0 2,500 5,000
1,250
US Feet
´
Lafayette Timber Site
Lafayette County, FL
May 2025 ARC Meeting Page 8 of 17All
ig
a
t
or La
ke
E
Irlo B
Lake X
Conservation
Easements
"
r
onson Memorial Hwy
Birchwood
Acres
Preserve
Jug Creek
Swamp
Big Bend/Holopaw Ranch
Florida Forever BOT Project
192
SITE
Putnam Land Conservancy
Osceola Parcels
ake Gentry
Holopaw
Conservation
Area
Big Bend Swamp
Big Bend/Holopaw Ranch
Florida Forever BOT Project
E Ir
lo
Brons
on
Triple N Ranch
Wildlife
Management Area
Holopaw Rd
Osceola Pine Savannas Florida
Forever BOT Project
Memo
Lonesome Camp
Heart Bar
Swamp
Ranch Agricultural and
Conservation Easement #2
Heartbar Ranch
Agricultural and
Conservation Easement #1
91
Lonesome Camp Ranch
Conservation Area
Camp Lonesome
Conservation Easement
(RFLPP)
Camp
Lonesome Conservation
Easement (USFWS)
Camp Lonesome
Conservation
Easement (FDEP)
Camp Lonesome
CE -Phase II
Bronsons
Conservation
Easement
441
Subject Parcels
Florida Forever BOT Projects
Federal Managed Conservation Lands
State Managed Conservation Lands
City/ County Managed Conservation Lands
Private Managed Conservation Lands
1
0 2 4
Miles
´
Holopaw Groves Road Site
Osceola County, FL
May 2025 ARC Meeting Page 9 of 17Putnam Land Conservancy
Osceola Parcels
"
SITE
Holopaw
Conservation
Area
Big Bend/Holopaw Ranch
Florida Forever BOT Project
Subject Parcels
Florida Forever BOT Projects
City/ County Managed Conservation Lands
Private Managed Conservation Lands
2,000
0 4,000 8,000
US Feet
´
Holopaw Groves Road Site
Osceola County, FL
May 2025 ARC Meeting Page 10 of 17"
SITE
Deering
Preserve at
Deep Creek
Lake Harney
Wilderness
Area
Lake Harney
Black Cypress
Swamp
Volusia Conservation Corridor
Florida Forever BOT Project
Gopher Swamp
Lake Harney
Ranchette Parcels
Stone Island
State Road 46
Geneva
Wilderness
Area
Lake Proctor
Wilderness Area
46
E State R
oad
46
Kilbee Ranch
Conservation
Easement
LeFevre
Conservation
Easement
Mills Creek Woodlands
Little Big
Econ State
Forest
Clonts
Conservation
Easement
Puzzle Lake
Charles H.
Bronson
State Forest
East Central
Regional
Rail Trail
Farmton Volusia MRBOS
Conservation
Easement
Farmton-Brevard
Conservation
Easement
Farmton Volusia
Greenkey
Conservation Easement
Maytown Flatwoods Florida
Forever BOT Project
Colbert-Cameron
Mitigation Bank
Cabbage
Slough
Farmton
Mitigation
Bank
Volusia/FAS Mitigation
Conservation
Easement
46
Buck Lake
Conservation
Area
Seminole Ranch
Conservation Area
State
Ro
a
d 46
Subject Parcels
Florida Forever BOT Projects
Federal Managed Conservation Lands
State Managed Conservation Lands
City/ County Managed Conservation Lands
Private Managed Conservation Lands
1
0 2 4
Miles
´
Morgan Alderman Road Site
Volusia County, FL
May 2025 ARC Meeting Page 11 of 17"
SITE
Colbert-Cameron
Mitigation Bank
Buck Lake
Conservation
Area
Subject Parcels
Florida Forever BOT Projects
State Managed Conservation Lands
Private Managed Conservation Lands
0 1,000 2,000 500
US Feet
´
Morgan Alderman Road Site
Volusia County, FL
May 2025 ARC Meeting Page 12 of 17Item 4: Guana River WMA Exchange
MEMORANDUM
To: From: FDEP Division of State Lands
Florida Fish and Wildlife Conservation Commission
Subject: Proposed Land Exchange
A land exchange proposal has been received by the Florida Fish and Wildlife Conservation
Commission (FWC) requesting approximately 600 linear acres within the northern boundaries of the
Guana River Wildlife Management Area (WMA) in St. Johns County containing mesic hammock, xenic
hammock, scrub, mesic flatwoods, scrubby flatwoods, maritime hammock, depression marsh, and
basin swamp, to be exchanged for approximately 3,065 acres (5:1 exchange)of land located in 4
separate parcels throughout the state, including:
The Lafayette Timber Site, located in Lafayette County, totaling 1,392 approximate acres. The
property contains mixed scrub-shrub wetlands, coniferous pine plantations, upland hardwood forest,
basin swamp, gum pond, and wet coniferous plantations.
The Morgan Alderman Road Site, located in Volusia County, totaling 252 approximate acres. The
property contains mesic flatwoods, mixed hardwood coniferous, wet prairie, mixed scrub wetlands,
marshes, mixed wetland hardwoods, hydric pine flatwoods, and cabbage palm hammocks.
The Holopaw Groves Site, located in Osceola County, totaling 1,201 approximate acres. The property
contains mesic flatwoods, scrub, wetlands, marshes, cypress wetlands, swamps, mixed wetland
hardwoods, hydric pine flatwoods, and woodland pasture.
The County Road 13 Site, located in St. Johns County, totaling 220 approximate acres. The property
contains mixed hardwood coniferous, mixed wetland hardwoods, and mixed scrub wetlands.
The proposed land at Guana River WMA is under ownership of the Board of Trustee's, and as lead
manager of the property, and in accordance with F.S. 253.42, the FWC acknowledges the authority of
the Board of Trustee's and the Acquisition and Restoration Council in the review and disposition of
this land exchange proposal.
May 2025 ARC Meeting Page 13 of 17Item 4: Guana River WMA Exchange
ARC Questionnaire – Guana River Wildlife Management Area
Proposed Land Exchange
1. Description of when and under what program or fund the parcel under
consideration was acquired (EEL, LATF, CARL, P-2000, Florida Forever, etc.)
or donated.
Response: In 1984, the land in question was purchased by the State of Florida through its
Conservation and Recreation Lands (CARL) program, as part of a nearly
10,000 acre acquisition. This acquisition became the Guana River Wildlife
Management Area. In 1986, the parcel was granted to the Board of Trustees of
the Internal Improvement Trust Fund (TIITF) of the state of Florida. The
exchange parcel is approximately 600 acres (+599.77 acres), comprising about
6% of the total area.
2. Description of the purpose for the parcel's acquisition (P-2000 or Florida
Forever goals and criteria or similar purpose descriptions) or donation and any
restrictions or conditions of use that apply to the parcel, if any.
Response: The Conservation and Recreational Lands (CARL) program was established
by the Florida legislature in 1979 to acquire lands of environmental and cultural
significance. In 1989, the CARL program was replaced by Preservation 2000
and the funding increased to three billion dollars for conservation land
purchases. In 1998, a replacement program called Florida Forever broadened
the land purchasing criteria to include historical preservation.
3. Description of the current level of public recreational use or public access of the
parcel.
Response: The parcel is currently part of the Guana River Wildlife Management Area.
There is a pedestrian trail running north and south through the parcel. There is
also an unimproved road running north and south along the eastern boundary
of the parcel. The parcel is accessible to the public for waterfowl hunting,
fishing, paddling and wildlife viewing.
May 2025 ARC Meeting Page 14 of 17Item 4: Guana River WMA Exchange
4. Description of the natural resources, land cover, vegetation, habitat or natural
community, if any, that are currently present on the parcel.
Response: The parcels contain mesic flatwoods, scrubby flatwoods, freshwater marshes,
saltwater marshes, wet flatwoods, mesic and xeric hammock, scrub, maritime
hammock, and swamp habitats.
5. Description and list of the imperiled and other wildlife species, if any, that occurs
on or use the parcel.
Response: The overall parcel is known to contain various general wading birds and
waterfowl, primarily in the wetlands and waterways located to the east and west
of the exchange parcel. Although extensive wildlife surveys have not been
formally conducted, it is anticipated that the exchange parcel would include
wildlife species common to the uplands in the region, with listed species such
as the gopher tortoise (Gopherus polyphemus) and Eastern indigo snake
(Drymarchon couperi) possible.
6. Description and list of historical or archaeological resources, if any, that occurs
or has the potential of occurring on the site.
Response: There are no known historical archaeological resources known to exist within
the proposed exchange area.
7. Formal alternative site analysis that includes a description and assessment of
other potential alternative sites and why they are not feasible or practicable
alternatives.
Response: There are no alternatives other than the proposed exchange.
8. Assessment of the impacts the proposed alternative use will have on the
natural/historical/archaeological/recreational resources, if any, as well as on the
current public use and purpose for the site or parcel.
Response: The exchange parcel does not have an impact on archeological resources based
on the absence of any findings. The current recreational opportunities on this
parcel will not remain; however, the recreational activities throughout the
remainder of the more than 9,200 will continue. In addition, the replacement
parcels offered will provide for public recreational activities on 3,066.3 acres
compared to the Guana parcel totaling 600 acres. The increase in 411% of
public conservation lands is a benefit to the public.
May 2025 ARC Meeting Page 15 of 17Item 4: Guana River WMA Exchange
9. Assessment of the potential impacts on the larger area of conservation lands the
parcel is located within (park, wildlife management area, forest trail, etc.) and
on any surrounding conservation lands, if any.
Response: There are minimal impacts to the entirety of the conservation lands, as a
majority of the wetland habitats will be avoided to ensure they are under
conservation in perpetuity. Existing natural wildlife corridors to the
surrounding wildlife management area will remain to ensure there are minimal
impacts to wildlife, their habitats and natural movement patterns.
10. Assessment of how the proposed package of consideration and net positive
benefit for the requested alternative use of the parcel, such as the generally
standard requirement for replacement land (depending on the parcel's size), will
offset the impacts and benefit the larger area of conservation lands (park, forest,
wildlife management area, trail system, etc.) the parcel is within and particularly
how it will offset the impacts or benefit the natural/historical/ archaeological
resources, habitat and public recreational uses of the public conservation area
the parcel is located within.
Response: Four separate parcels totaling approximately 3,066.3 acres will be provided in
exchange for the approximately 600-acre Guana parcel. The proposed
replacement parcels are collectively larger in size. Additionally, the exchange
parcels are adjacent and connected to Florida Forever Lands and conservation
lands which will provide for more contiguous conservation areas within the
State of Florida.
The County Road 13 South Site (aka Elkton) totals approximately 220.09 acres
and is adjacent to the SJRWMD Deep Creek Conservation area and is Florida
Forever BOT lands. The County Road 13 South Site contains mixed hardwood
coniferous, mixed wetland hardwoods and mixed scrub wetlands. The
preservation of this parcel adds to denning, nesting and foraging habitat as well
as preserves upstream resources to Deep Creek Conservation Area.
The Morgan Alderman Road Site (aka Crude AG) totals approximately 252.17
acres and is adjacent to Lake Harney, Colbert Cameron Mitigation Bank, Buck
Lake Conservation Area, and nearby the Little Big Econ State Forest. The
Morgan Alderman Road Site contains mesic flatwoods, mixed hardwood
coniferous, wet prairie, mixed scrub wetlands, marshes, mixed wetland
hardwoods, and cabbage palm hammocks. The preservation of this parcel
completes the wildlife corridor of these existing conservation lands to Lake
Harney ensuring that a significant wildlife corridor will be preserved,
preventing any future fragmentation of this corridor connection from
development.
May 2025 ARC Meeting Page 16 of 17Item 4: Guana River WMA Exchange
The third replacement parcel, Holopaw Groves Road Site, totals approximately
1,201.97 acres and is adjacent to Quickdraw Mitigation Bank and Holopaw
Conservation Area, and is within Big Bend Swamp/Holopaw Ranch Florida
Forever BOT Project. The Holopaw Groves Road Site contains mesic
flatwoods, scrub flatwoods, mixed scrub wetlands, marshes, cypress wetlands,
swamps, mixed wetland hardwoods, hydric pine flatwoods, and woodland
pasture. The preservation of this parcel will also provide additional wildlife
corridor, foraging and denning habitat for wildlife species.
The Lafayette Timber Site totals approximately 1,392.07 acres and is adjacent
to the Mallory Swamp Restoration Area and nearby the Lafayette Forest
Wildlife and Environmental Area, Troy Spring State Park, as well as multiple
other conservation areas along the Suwannee River. Additionally, the Lafayette
Timber Site is within the Lafayette Forest Florida Forever BOT Project. The
Lafayette Timber Site contains upland hardwood forests, wet prairie, mixed
scrub-shrub wetlands, cypress wetlands, mixed hardwood-coniferous swamp,
basin swamp, and woodland pasture. Protecting these lands is essential to
preserving a critical wildlife corridor that connects to the Mallory Swamp
Restoration Area, ensuring the integrity of this natural connection and guarding
it against future fragmentation by development.
The Bald Eagle (Haliaeetus leucocephalus), Florida black bear (Ursus
americanus floridanus), Florida Sandhill Crane (Antigone canadensis
pratensis), Wood Stork (Mycteria americana), gopher tortoise (Gopherus
polyphemus), and Eastern indigo snake (Drymarchon couperi) are anticipated
to utilize the four exchange parcels. The exchange parcels contain vast tracts
of undisturbed lands with a mosaic of high-quality habitats that provide
exemplary foraging, nesting and breeding grounds for various listed species.
Overall, the replacement parcels for the exchange parcel offer a substantial
increase of lands to be placed under conservation for the state. The proposed
replacement lands are advantageous to the state due to the fact that these parcels
are in areas where conservation management goals and objectives can be
attained by forming more contiguous acreage of conservation lands in the state
of Florida. The replacement parcels consist of expansive tracts of land with
various natural habitat types which offer a wider range of optimal habitat for
native wildlife and public recreational use.
May 2025 ARC Meetin
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