Monday, May 19, 2025

MALARKEY: FDEP IG MUST Investigate Proposed GUANA LAND GRAB

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

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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