Final
Water Quality Protection Program Document
                   for the
  Florida Keys National Marine Sanctuary

               September 1996
               I
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       U.S. Environmental Protection Agency
                  Region 4

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                        FINAL
  Water Quality Protection Program  Document
for the Florida Keys National Marine Sanctuary
            U.S. Environmental Protection Agency
            Oceans and Coastal Protection Division
                 Contract No. 68-C8-0134
                   Work Assignment 3-1
                     September 1996
                     Prepared by:

              Continental Shelf Associates, Inc.
                   759 Parkway Street
                  Jupiter, Florida 33477
                Telephone: (407) 746-7946
                     Prepared for:

                  Battelle Ocean Sciences
                  397 Washington Street
               Duxbury, Massachusetts  02332
                Telephone:  (617) 934-0571

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                          EXECUTIVE SUMMARY
The Florida Keys National Marine Sanctuary (FKNMS) was created with the signing of
HR5909 (Public Law 101-605, Florida Keys National Marine Sanctuary and Protection
Act) on 16 November 1990.  Included in the Sanctuary are 2,800 square nautical miles
of nearshore waters extending from just south of Miami to the Dry Tortugas.

Recognizing the critical role of water quality in maintaining Sanctuary resources,
Congress directed the Environmental Protection Agency (EPA) and the  State of Florida,
represented by the  Florida Department of Environmental Protection (FDEP), to develop
a Water Quality Protection Program for the Sanctuary.  This is the first such program
ever developed for a marine sanctuary. The purpose of the Water Quality Protection
Program is to "recommend priority corrective actions and compliance schedules
addressing point and nonpoint sources of pollution to restore and maintain the
chemical, physical,  and biological integrity of the Sanctuary, including restoration and
maintenance of a balanced, indigenous population of corals, shellfish, fish  and wildlife,
and recreational  activities in and on the water" (Florida Keys National Marine Sanctuary
and Protection Act). In addition to corrective actions, the Act also requires
development of a water quality monitoring program and provision of opportunities for
public participation in all aspects of developing and implementing the program.

The Water Quality  Protection Program described in this document consists of an
administrative framework and a set of initial recommendations for corrective actions,
monitoring, research/special studies,  and education/outreach.  The recommendations
have been included in the comprehensive management plan prepared by the National
Oceanic and Atmospheric Administration (NOAA) to guide the use of the Sanctuary.

Recommendations  for monitoring and research/special studies are being implemented
directly by EPA and FDEP under the administrative framework described below. For
educational activities, EPA and FDEP will assist NOAA, which is responsible for
educational programs in the Sanctuary. In contrast, most recommendations for
corrective actions will require coordinated activities by numerous Federal,  State, and
local government agencies.
                            PROGRAM DEVELOPMENT

The Water Quality Protection Program was developed in two phases. During Phase I,
information was compiled and synthesized on the status of the Sanctuary's natural
environment. Priority problems were identified through this literature review and
through discussions with technical experts and other participants in technical
workshops.  Phase II focused on developing options for corrective actions, developing a
water quality monitoring program and research/special studies program, and developing
a public education and outreach program.  Findings from Phases I and II were used to
develop the recommendations  in this Program Document.  A draft Program Document
was submitted to NOAA in 1993, and the Water Quality Action Plan (Appendix C) was
included in NOAA's Draft Management Plan/Environmental Impact Statement
(DMP/EIS).  This  updated version of the Program Document includes changes made in
response to public comments on the DMP/EIS.


                                     ES-1

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                         ADMINISTRATIVE FRAMEWORK

The Water Quality Protection Program is administered by EPA and FDEP, in cooperation
with NOAA.  The National Marine Sanctuaries Program Amendments Act of 1992
specified the establishment of a Steering Committee, Technical Advisory Committee,
and an EPA Florida Keys Liaison Officer to implement the program. A Management
Committee has also been established to coordinate and facilitate the activities of the
Steering Committee and Technical Advisory Committee.  Funding for the development
of the Water Quality Protection Program was provided by EPA.'

Through the administrative framework described in the Program Document, EPA and
FDEP are implementing recommendations for monitoring and research/special studies,
and are working with NOAA to develop and implement education/outreach programs
for water quality.  In addition, EPA and FDEP are working within the larger framework
of agencies, institutions, organizations, and individuals responsible for Sanctuary
management to implement recommendations for corrective actions. EPA and FDEP are
also responsible for evaluating progress and developing new or revised approaches as
necessary. Most of the funds to implement monitoring and research/special studies are
being provided by EPA.  NOAA and the South Florida Water Management District
(SFWMD) are also providing funds for implementation.
                            PROGRAM COMPONENTS

The Water Quality Protection Program consists of four interrelated components:

•      Corrective Actions. These are actions to reduce water pollution directly by using
       engineering methods, prohibiting or restricting certain activities, modifying
       existing regulations, and/or focusing enforcement.  Other actions are designed
       to make the regulatory/management system work more efficiently, leading
       indirectly to reduced pollution.

       Monitoring.  A comprehensive, long-term water quality monitoring program has
       been designed to provide information about the status and trends of water
       quality and biological resources in the Sanctuary. The program will also provide
       information about the effectiveness of remedial actions to reduce pollution.

•      Research/Special Studies. The purpose of the research/special studies program is
       to identify and understand cause/effect relationships involving pollutants,
       transport pathways, and biological communities of the Sanctuary.  Special
       studies will provide information to address specific management questions and
       concerns, improve general  understanding of Sanctuary ecosystems, develop
       predictive models, and develop monitoring tools and methodologies.

•      Public Education/Outreach.  The purpose of this component is to increase public
       awareness of the Sanctuary, the Water Quality Protection Program, and
       pollution sources and impacts on  Sanctuary resources.  This component also
       involves soliciting and incorporating public input in the design and
       implementation of the program.
                                     ES-2

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                              RECOMMENDATIONS

The Program Document presents recommendations for corrective actions, monitoring,
research/special studies, and education/outreach developed during Phase II. The
recommendations are organized into nine categories:

       Florida Bay/external influences
       Domestic wastewater
       Stormwater
       Marinas and live-aboards
       Landfills
       Hazardous materials
       Mosquito spraying
       Canals
       Monitoring and research/special studies

The Program Document provides a brief description and rationale for each
recommendation.  Details of implementing agencies, cost, schedule, etc. are in the
Water Quality Action Plan (Appendix C). Additional pertinent information and
assumptions are presented in the Phase II report.

Table ES-1 summarizes recommendations presented in the Program Document.
Table ES-2 ranks recommendations as high, medium, or low in priority. Table ES-3
lists only the high-priority recommendations  and provides a brief rationale for  each.
Prioritization is based on the projected effectiveness of the recommendations in
reducing water quality problems in the Sanctuary.  Recommendations that would
reduce pollution directly, provide information needed for critical decisions,  or allow
another high-priority recommendation to be  implemented are generally assigned a high
priority.  Recommendations that might indirectly reduce pollution by making the
management/regulatory system work more efficiently are generally assigned a lower
priority.  However, some high-priority recommendations involve significant prerequisites
to be implemented.  Conversely, some low-priority recommendations might be
implemented early if they involve simple, inexpensive measures.
                                     ES-3

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      Table ES-1.  Summary of recommendations.
m
          FLORIDA BAY/EXTERNAL INFLUENCES

Florida Bay Freshwater Flow
• The Steering Committee for the Water Quality Protection
Program shall take a leading role in restoring historical
freshwater flow (quantity, quality, timing, and distribution) to
Florida Bay, which is now in a state of crisis. In addition,
Sanctuary representatives shall work with appropriate federal,
state, and local agencies to ensure that restoration plans and
surface water improvement and management plans for South
Florida and the Everglades are compatible with efforts to
maintain water quality within the Sanctuary.

Special Studies: Florida Bay Influence
• Conduct research/special  studies  to understand the effect of
water transport from Florida Bay on water quality and resources
in the Sanctuary.

                 DOMESTIC WASTEWATER

Inspection/Compliance Programs
• Establish inspection/compliance programs for cesspits and
OSDS and continue the existing FDEP inspection/compliance
program for package plants.

OSDS Demonstration Project
• Conduct a demonstration project  to evaluate innovative
alternate* nutrient-removing on-site sewage disposal systems
(OSDS).
AWT Demonstration Project
• Conduct a pilot project to evaluate installation of a small,
expandable advanced wastewater treatment (AWT) plant to
serve an area of heavy OSDS use with associated water quality
problems.

Nutrient  Reduction Targets
• Evaluate the development of targets for reductions in
wastewater nutrient loadings necessary to restore and maintain
water quality and Sanctuary resources.

Sanitary Wastewater Master Plan
• Develop and implement a Sanitary Wastewater Master Plan
that evaluates options for upgrading existing systems beyond
current standards or constructing community sewage treatment
plants, based on nutrient reduction targets, cost and cost
effectiveness, reliability/compliance considerations, and
environmental and socioeconomic impacts.

Master Plan Implementation
• Implement the preferred wastewater treatment option
selected in the Sanitary Wastewater Master Plan.

City of Key West Ocean Outfall
• Upgrade effluent disposal for City of Key West wastewater
treatment plant. Evaluate deep well injection, including the
possibility of effluent migrating from the Boulder Zone into
Sanctuary waters. Evaluate options for reuse of effluent,
including irrigation and potable reuse. Discontinue use of the
existing ocean outfall and implement deep well injection,
aquifer storage, and/or reuse.

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      Table ES-1. Summary of recommendations (continued).
M
V3
Ol
Water Quality Standards
• Develop and implement water quality standards, including
biocriteria, appropriate to Sanctuary resources (corals and
seagrasses).

NPDES Program Delegation
• Delegate administration of the National Pollutant Discharge
Elimination System (NPDES) program for Florida to the State of
Florida.

Resource Monitoring of Surface Discharges
• Require all NPDES-permitted surface dischargers to develop
resource monitoring programs, including biological monitoring
where appropriate.

Improved Interagency Coordination
• Improve interagency coordination for industrial wastewater
discharge permitting.

OSDS Permitting
• Combine OSDS permitting responsibilities in one agency for
commercial establishments, institutions, and multi-family
residential establishments utilizing injection wells.

Monitoring of Revised OSDS Rules
• Monitor revised rules designed to improve the performance of
OSDS in the Florida Keys.

Laboratory Facilities
• Evaluate the feasibility of, and if appropriate, establish an
interagency laboratory capable of processing monitoring and
compliance samples.
                      STORMWATER

Stormwater Retrofitting
• Identify and retrofit stormwater hot spots using grass parking,
swales, pollution control structures, and detention/retention
facilities. Control stormwater runoff in areas handling toxic and
hazardous materials. Install swales and detention facilities along
limited sections of U.S.  1.

Stormwater Permitting
• Require that no development in the Florida Keys be exempted
from the stormwater permitting process.

Stormwater Management
• Require local  governments  to enact and implement
stormwater management ordinances  and comprehensive
stormwater management master plans. Petition the EPA to
include the Florida Keys in the  stormwater NPDES program if
adequate stormwater management ordinances and
administrative capability to manage such ordinances are not in
place by a certain date.

Best Management Practices
• Institute a series of Best Management Practices and a public
education program to prevent pollutants from entering
stormwater runoff.

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Table ES-1. Summary qf recommendations (continued).
                    MARINAS AND LIVE-ABOARDS

      Pollution Discharges
      * Reduce pollution discharges (e.g., sanitary wastes, debris,
      hydrocarbons) from vessels by implementing the 1994 Florida
      Clean Vessel Act and developing a public education program.
      Change the environmental crimes category associated with
      discharges from felony to civil offense, thereby removing the
      need to prove criminal intent.

      Mooring Fields
      • Evaluate the feasibility of establishing mooring fields in places
      having significant concentrations of live-aboard vessels. If the
m     study shows they are feasible, define criteria for mooring fields
j£     and establish mooring fields in appropriate areas

      Marina Pumpout
      • Develop a comprehensive plan for eliminating sewage
      discharges from live-aboard boaters. Require marinas with 10 or
      more slips to install pumpout facilities,

      Mobile Pumpout
      • Establish a mobile pumpout service through the local
      government, or a franchise with a private contractor, which
      would serve to pump out live-aboard vessels moored outside of
      marina facilities. Encourage the use of existing, and the
      construction of additional, shore-side facilities such as dinghy
      docks, parking areas, showers, and laundries for use by live-
      aboards.
                                                              Marina Permitting
                                                              • Improve interagency cooperation in marina permitting.

                                                              Marina Operations
                                                              • Reduce pollution from marina operations by establishing
                                                              containment areas for boat maintenance, encouraging marina
                                                              owners to participate in environmentally-oriented organizations
                                                              such as the International Marina Institute, and encouraging
                                                              marina owners to provide  a user manual with local
                                                              environmental information such as locations of pumpout
                                                              facilities and trash receptacles.

                                                              Environmental Awareness Program
                                                              • Formalize and expand the existing Florida Marine Patrol
                                                              District 9 environmental education program to heighten
                                                              awareness of how human activities contribute to water quality
                                                              problems.

                                                                                     LANDFILLS

                                                              Historical Landfill Search and Assessment
                                                              • Conduct a comprehensive search for abandoned landfills and
                                                              dumps. Evaluate each site to determine if they contain
                                                              hazardous materials or are causing environmental problems. If
                                                              problems are discovered, evaluate and implement appropriate
                                                              remedial actions such as boring or mining, upgrading closure,
                                                              collecting and treating leachate, constructing slurry walls, or
                                                              excavating and hauling landfill contents.

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Table ES-1. Summary of recommendations (continued).
Landfill Monitoring
• Intensify existing monitoring programs around landfills to
ensure that no leaching is occurring into marine waters. Identify
and monitor old landfills that were never permitted and
therefore have no closure plans or closure permits. If problems
are discovered,  evaluate and implement appropriate remedial
actions such as boring or mining, upgrading closure, collecting
and treating leachate,  constructing slurry walls, or excavating
and hauling landfill contents.

                 HAZARDOUS MATERIALS

Hazardous Materials Response
• Improve and expand oil and hazardous materials response
programs  throughout the Sanctuary.

Spill Reporting
• Establish a reporting system to ensure that all spills in and
near the Sanctuary are reported to Sanctuary managers.
Establish a geo-referenced  Sanctuary spills database.

Hazardous  Materials Handling
• Conduct an assessment and inventory of hazardous materials
handling and use in the Florida Keys including facilities, types
and quantities of materials, and transport/movement. Add
information to the FDEP/EPA/Monroe County geographic
information system (CIS) database.
                  MOSQUITO SPRAYING

Mosquito Spraying
• Refine the aerial mosquito spraying program to further reduce
aerial spraying over marine areas. This includes a review of
threshold levels used to initiate aerial spraying, development of
a more refined plan for flight lines, and use of improved
equipment. Reconsider the use of mosquito larvicides in
breeding areas, including those in currently restricted areas, to
reduce the need for aerial spraying of adult mosquito
populations. Evaluate the elimination of thermal fogs and
replacement with ultra-low volume spraying methods.

Pesticide Research
• Develop and implement an independent research program to
assess and investigate the impacts of, and alternatives to,
current pesticide practices. Modify the Mosquito  Control
Program as necessary on the basis of research findings. Conduct
a field survey of pesticide and herbicide use in the Keys.

                         CANALS

Canal Water Quality
• Inventory and characterize dead-end canals/basins and
investigate alternative management strategies to  improve their
water quality. Implement improvements (consistent with the
strategies developed for wastewater and stormwater)  in known
hot spots throughout the Sanctuary.

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Table ES-1.  Summary of recommendations (continued).
     MONITORING AND RESEARCH/SPECIAL STUDIES

Water Quality Monitoring Program
• Conduct a long-term, comprehensive water quality monitoring
program as described in the EPA Water Quality Protection
Program Phase II report and the Implementation Plan.

Special Studies: Predictive Models
• Develop phased hydrodynamic/water quality models and
coupled landscape-level ecological models to predict and
evaluate the outcome of in-place and proposed water quality
management strategies.

Special Studies: Wastewater Pollutants
• Conduct special studies to document the fate and ecological
impacts of wastewater pollutants.

Special Studies: Other Pollutants and Water Quality
Problems
• Conduct special studies to document the fate and ecological
impacts of non-wastewater pollutants, develop innovative
monitoring tools, and examine the effects of global climate
change on die organisms and ecosystems of the Keys.

Special Studies: Florida Bay Influence
• Conduct research/special studies to understand the effect of
water transport from Florida Bay on  water quality and resources
in the Sanctuary.
Regional Database
• Establish and maintain a regional database and data
management system for recording research/special studies
results and biological, physical and chemical parameters from
monitoring.

Dissemination of Findings
• Develop a program to synthesize and disseminate scientific
research/special studies and monitoring results, including an
information exchange network, conferences, and support for the
publication of research findings in peer-reviewed  scientific
journals,  i

Technical Advisory Committee
• Establish; a technical advisory committee for coordinating and
guiding research/special  studies and monitoring activities by
both EPA and NOAA.

Ecological Monitoring Program
• Develop and implement a Sanctuary-wide, intensive
ecosystem monitoring program. The objective of the program
will be to monitor the status of various biological and ecological
indicators of system components throughout the Sanctuary and
adjacent areas, hi order to discern the local and system-wide
effects of human and natural disturbances, and assess the
overall health of the Sanctuary.

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Table ES-2.  Prioritization of recommendations.  Key:  • = high  o = medium  x = low
Recommendation
Priority
Recommendation
Priority
Florida Bay/External Influences
   Florida Bay Freshwater Flow  	
   Special Studies: Florida Bay Influence
Domestic Wastewater
   Inspection/Compliance Programs  	
   OSDS Demonstration Project  	
   AWT Demonstration Project	
   Nutrient Reduction Targets  	
   Sanitary Wastewater Master Plan	
   Master Plan Implementation	
   City of Key West Ocean Outfall	
   Water Quality Standards	
   NPDES Program Delegation	
   Resource Monitoring of Surface Discharges
   Improved Interagency Coordination  	
   OSDS Permitting	
   Monitoring of Revised OSDS Rules	
   Laboratory Facilities  	
Stormwater
   Stormwater Retrofitting .  . ,
   Stormwater Permitting
   Stormwater Management  . ,
   Best Management Practices
Marinas/Live-Aboards
   Pollution Discharges  	
   Mooring Fields	
   Marina Pumpout	
   Mobile Pumpout	
   Marina Operations  	
   Marina Permitting	
   Environmental Awareness Program
     o
     x
     X
     X
     X
     X
     X
     o
     o
     o
     o
     o
     o
     •
     o
     o
     X
     o
             Landfills
                Historical Landfill Search and Assessment	o
                Landfill Monitoring	o

             Hazardous Materials
                Hazardous Materials Response	o
                Spill Reporting	x
                Hazardous Materials Handling	o

             Mosquito Spraying
                Mosquito Spraying  	  •
                Pesticide Research	  •
Canals
   Canal Water Quality
Monitoring and Special Studies
   Water Quality Monitoring Program	  •
   Special Studies: Predictive Models  	  •
   Special Studies: Wastewater Pollutants	  •
   Special Studies: Other Pollutants and Water Quality Problems . o
   Special Studies: Florida Bay Influence	  •
   Regional Database	  •
   Dissemination of Findings  	x
   Technical Advisory Committee	  •
   Ecological Monitoring Program	  •

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Table ES-3.  Rationale for high-priority recommendations.
Florida Bay/External Influences

• Florida Bay Freshwater Flow - Addresses a potentially major, external
influence on Sanctuary water quality.

• Special Studies: Florida Bay Influence - Helps to understand a
potentially major, external influence on Sanctuary water quality.

Domestic Wastewater

• Inspection/Compliance Programs - Cesspits are illegal and will
eventually be replaced.  Inspection/compliance programs-for OSDS
and package plants will yield some nutrient reduction regardless of
the ultimate decisions about wastewater systems.

• OSDS Demonstration Project - Provides critical information for
wastewater decisions.

• AWT Demonstration Project - Provides critical information for
wastewater decisions.

• Nutrient Reduction Targets - Provides critical information for
wastewater decisions,

• Sanitary Wastewater Master Plan - Develops a comprehensive
approach to wastewater management based on all available data.

• Master Plan Implementation - Directly reduces nutrient loadings to
Sanctuary waters.

• City of Key West Ocean Outfall - Directly reduces nutrient loadings to
Sanctuary waters.

Marinas and Live-Aboards

• Marina Pumpout - Requires new pumpout facilities which would
directly reduce nutrient  loadings from Hve-aboards and other boaters.
Mosquito Spraying

• Mosquito Spraying - Reduces aerial spraying of pesticides, leading to
reduced pollution of the marine environment.

• Pesticide Research - Evaluates alternatives to minimize impacts of
current pesticide practices.

Canals

• Canal Water Quality - Addresses documented water quality
degradation due to canal structure and orientation.

Monitoring and Research/Special Studies

• Water Quality Monitoring Program - Provides critical data on status
and trends in water quality and biological resources. Required by the
Florida Keys National Marine Sanctuary and Protection Act.

• Special Studies: Predictive Models - Develops useful tools for
management decisions about pollution control actions.

• Special Studies: Wastewater Pollutants •  Provides critical information
about cause/effect relationships linking wastewater pollutants and
Sanctuary resources. Information needed for wastewater decisions.

• Regional Database - Data management is an integral part of all
monitoring and research/special studies.

• Technical Advisory Committee - Establishes technical oversight for all
monitoring and research/special studies.

• Ecological Monitoring Program - Provides critical information on the
health of living  resources. Required by the Florida Keys National
Marine Sanctuary and Protection Act.

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                                CONTENTS
EXECUTIVE SUMMARY	  ES-I

1.0  INTRODUCTION	i
     1.1  Legislative Mandate and Purpose	1
     1.2  Background  	1
          1.2.1  Phase I  	2
          1.2.2  Phase II	2
          1.2.3  Initial Coordination with NOAA	3
          1.2.4  Changes in Response to Public Comment	4
     1.3  Program Document Organization	5

2.0  PROGRAM  DESCRIPTION  	6
     2.1  Administrative Framework	6
          2.1.1  Steering Committee  	6
          2.1.2  Technical Advisory Committee  	8
          2.1.3  EPA Florida Keys Liaison Officer	8
          2.1.4  Management Committee	8
     2.2  Program Components  	9
          2.2.1  Corrective Actions  	10
          2.2.2  Monitoring and Research/Special Studies	11
          2.2.3  Public Education/Outreach 	12

3.0  NEED FOR  ACTION  	13
     3.1  Corrective Actions and Education/Outreach  	14
     3.2  Monitoring	15
     3.3  Research/Special  Studies	15
     3.4  Pollution  Sources Targeted  	16

4.0  FLORIDA BAY/EXTERNAL INFLUENCES 	17
     4.1  Introduction/Problem  Description  	17
     4.2  Recommendations	18
          4.2.1  Florida Bay Freshwater Flow	18
          4.2.2  Special Studies: Florida Bay Influence	 18
     4.3  Public Comment and Changes  	19

5.0  DOMESTIC  WASTEWATER	20
     5.1  Introduction/Problem  Description  	20
     5.2  Wastewater Recommendations for Monroe County 	21
          5.2.1  Inspection/Compliance Programs	22
          5.2.2  OSDS Demonstration Project	 24
          5.2.3  AWT Demonstration Project 	24
          5.2.4  Nutrient Reduction Targets	24
          5.2.5  Sanitary Wastewater Master Plan	25
          5.2.6  Master Plan Implementation	25

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                               CONTENTS
                                 (continued)
     5.3 Wastewater Recommendation for City of Key West	26
         5.3.1   City of Key West Ocean Outfall	26
     5.4 Management Recommendations	27
         5.4.1   Water Quality Standards	27
         5.4.2   NPDES Program Delegation  	27
         5.4.3   Resource Monitoring of Surface Discharges  	28
         5.4.4   Improved Interagency Coordination	28
         5.4.5   OSDS Permitting  	29
         5.4.6   Monitoring of Revised OSDS Rules  	29
         5.4.7   Laboratory Facilities	29
     5.5 Public Comment and Changes 	30

6.0  STORMWATER	31
     6.1 Introduction/Problem Description  	31
     6.2 Recommendations	31
         6.2.1   Stormwater Retrofitting  	31
         6.2.2   Stormwater Permitting	32
         6.2.3   Stormwater Management 	33
         6.2.4   Best Management  Practices	33
     6.3 Public Comment and Changes 	33

7.0  MARINAS AND  LIVE-ABOARDS	34
     7.1 Introduction/Problem Description  	34
     7.2 Recommendations	34
         7.2.1   Pollution Discharges	34
         7.2.2   Mooring Fields	35
         7.2.3   Marina Pumpout  	35
         7.2.4   Mobile Pumpout	36
         7.2.5   Marina Operations	37
         7.2.6   Marina Permitting	37
         7.2.7   Environmental Awareness Program	37
     7.3 Public Comment and Changes 	38

8.0  LANDFILLS	39
     8.1 Introduction/Problem Description  	39
     8.2 Recommendations	39
         8.2.1   Historical Landfill  Search and Assessment  	39
         8.2.2   Landfill Monitoring	40
     8.3 Public Comment and Changes 	40
                                     11

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                                CONTENTS
                                 (continued)


9.0  HAZARDOUS MATERIALS 	41
     9.1  Introduction/Problem Description	~. .  41
     9.2  Recommendations	41
          9.2.1  Hazardous Materials Response	41
          9.2.2  Spill Reporting	42
          9.2.3  Hazardous Materials Handling	42
     9.3  Public Comment and Changes  	42

10.0 MOSQUITO SPRAYING	43
     10.1 Introduction/Problem Description  	43
     10.2 Recommendations	43
          10.2.1 Mosquito Spraying	43
          10.2.2 Pesticide Research	44
     10.3 Public Comment and Changes  	44

11.0 CANALS	45
     11.1 Introduction/Problem Description  	45
     11.2 Recommendation  	45
     11.3 Public Comment and Changes	45

12.0 MONITORING AND RESEARCH/SPECIAL STUDIES	46
     12.1 Introduction/Description	46
     12.2 Recommendations	46
          12.2.1 Water Quality Monitoring Program	46
          12.2.2 Special Studies: Predictive Models	47
          12.2.3 Special Studies: Wastewater Pollutants  	47
          12.2.4 Special Studies: Other Pollutants and Water Quality Problems ...  48
          12.2.5 Special Studies: Florida Bay Influence	\	48
          12.2.6 Regional Database  	49
          12.2.7 Dissemination of Findings	„  50
          12.2.8 Technical Advisory Committee	50
          12.2.9 Ecological Monitoring Program	51
     12.3 Public Comment and Changes  	51

13.0 REFERENCES	52

APPENDICES

A    Legislation

B    Summary of Public Comments and Responses

C    Water Quality Action Plan
                                     m

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                                FIGURES

2-1  Administrative framework for the Water Quality Protection Program
                                 TABLES

5-1  Estimated domestic wastewater loadings in the Florida Keys
5-2  Summary of wastewater engineering options developed in the Phase II
     report (Modified from: EPA 1993)	
                                                         20
                                                         23
                               ACRONYMS
AWT
DMP
EIS
EPA
FAC
FDCA
FDEP
FDHRS
FKNMS
FMRI
FY
CIS
MOU
NOAA
NPDES
NRC
OSDS
SFWMD
USCG
advanced wastewater treatment
Draft Management Plan
Environmental Impact Statement
Environmental Protection Agency
Florida Administrative Code
Florida Department of Community Affairs
Florida Department of Environmental Protection
Florida Department of Health and Rehabilitative Services
Florida Keys National Marine Sanctuary
Florida Marine Research Institute
fiscal year
geographic information system
Memorandum of Understanding
National Oceanic and Atmospheric Administration
National Pollutant Discharge Elimination System
National Research Council
on-site sewage disposal system (s)
South Florida Water Management District
U.S. Coast Guard
                                     IV

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                            1.0  INTRODUCTION

                    1.1  LEGISLATIVE MANDATE AND  PURPOSE

The Florida Keys National Marine Sanctuary (FKNMS) was created with the signing of
HR5909  (Public Law 101-605, Florida Keys National Marine Sanctuary and Protection
Act) on 16 November 1990.  A copy of the Act is provided in Appendix A. Included in
the Sanctuary are 2,800 square nautical miles of nearshore waters extending from just
south of Miami to the Dry Tortugas.

Recognizing the critical role of water quality in maintaining Sanctuary resources,
Congress directed the Environmental Protection Agency (EPA) and the State of Florida,
represented by the Florida Department of Environmental Protection (FDEP), to develop
a Water Quality Protection Program for the Sanctuary. This is the first such program
ever developed for a marine sanctuary.  The purpose of the Water Quality Protection
Program is to "recommend priority corrective actions and compliance schedules
addressing point and nonpoint sources of pollution to restore and maintain the
chemical, physical, and biological integrity of the Sanctuary, including restoration and
maintenance  of a balanced, indigenous population of corals, shellfish, fish and wildlife,
and recreational activities in and on the water" (Florida Keys National Marine Sanctuary
and Protection Act).  In addition to corrective actions, the Act also requires
development of a water quality monitoring program and  provision of opportunities for
public participation in all aspects of developing and implementing the program.

The Water Quality Protection Program described in this document consists of an
administrative framework and a set of initial recommendations for corrective actions,
monitoring, research/special studies, and education/outreach.  The recommendations
have been included in the comprehensive management plan prepared by the National
Oceanic and Atmospheric Administration (NOAA) to guide the use of the Sanctuary
(NOAA 1995).

Recommendations for monitoring and research/special studies are being implemented
directly by EPA and FDEP under the administrative framework described in  Section 2.0.
For educational activities, EPA and FDEP will assist NOAA, which is responsible for
educational programs in the Sanctuary.  In contrast, most recommendations for
corrective actions will require coordinated activities by numerous Federal, State, and
local government agencies (see Appendix C for implementation responsibilities).
                               1.2 BACKGROUND

The Water Quality Protection Program was developed in two phases.  During Phase I,
information was compiled and synthesized on the status of the Sanctuary's natural
environment (EPA 1992). Priority problems were identified through this literature
review and through discussions with technical experts and other participants in
technical workshops.  Phase II focused on developing options for corrective actions,
developing a water quality monitoring program and research/special studies program,
and developing a public education and outreach program (EPA 1993). Findings from
Phases I and II were used to develop the recommendations in this Program Document.

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A draft Program Document was submitted to NOAA in 1993, and the Water Quality
Action Plan (Appendix C) was included in the Draft Management Plan/Environmental
Impact Statement (DMP/EIS) (NOAA 1995).  This updated version of the Program
Document includes changes made in response to public comments on the DMP/EIS.
                                 1.2.1  Phase I

Phase I involved a compilation and synthesis of information on the environment within
the Sanctuary (EPA 1992). Recommendations regarding data adequacy and the
direction of the Phase II effort were also provided.  Phase I included the following five
main tasks:

•   Task 2 — Water Quality Assessment. Information was compiled and summarized on
    point, nonpoint, and external sources potentially affecting water quality.  Existing
    information on the physical oceanography and water quality of the region was
    summarized. The potential for water quality degradation in the future (Year 2010)
    was also discussed.

•   Task 3 — Coral Community Assessment. Information was compiled and summarized
    on coral communities within the Sanctuary. Known and potential causes of adverse
    impacts to Caribbean and Florida Keys coral communities were also discussed.

•   Task 4 — Submerged and Emergent Aquatic Vegetation Assessment. This task focused
    on seagrasses and mangroves within the Sanctuary. Known effects of water quality
    on these types of communities were discussed.  Community trends in the Sanctuary
    were  discussed relative to existing and potential water quality.

•   Task 5 — Nearshore and Confined Waters Assessment. This task involved an
    evaluation of water quality in nearshore and confined waters within the Sanctuary.
    Water quality studies conducted in nearshore and confined waters were presented
    and discussed.                                                      ,

•   Task 6 — Spill and Hazardous Material Assessment.  Information on historic spills
    and hazardous material contamination was reviewed.  Total numbers of previous
    spills, causes, and potential preventive measures were discussed.
                                 1.2.2 Phase II

Phase II built on the information base gathered during Phase I and focused on three
goals:

•  Developing options for corrective actions
•  Developing a monitoring program and a research/special studies program
•  Developing a public education and outreach program

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Phase II included seven main tasks to address these goals.  Other tasks involved
development of a Work/Quality Assurance Project Plan for Phase II and preparation,
review, and revision of the Phase II report (EPA 1993) and this Program Document.

•  Task 2 — Institutional and Agency Management Inventory.  This task involved
   identifying institutions and agencies with jurisdiction affecting water quality in the
   Sanctuary.

•  Task 3 — Management/Institutional and Agency Options.  Based on the institutional
   and agency management inventory (Task 2) and suggestions from agency personnel,
   a comprehensive range of management and institutional options was developed to
   reduce water pollution and improve the existing regulatory/management system.

•  Task 4 — Engineering Options. A comprehensive range of engineering options was
   developed  to reduce water pollution in the Sanctuary.

•  Task 5 — Funding Sources. This task identified and evaluated potential funding
   sources for implementing  corrective actions identified in Tasks 3 and 4.

•  Task 6 — Monitoring Program.  A comprehensive water quality monitoring program
   was designed to monitor the status of water quality and biotic resources, determine
   the effectiveness of pollution controls,  and redirect the Water Quality Protection
   Program if necessary.

•  Task 7 — Research/Special Studies Program. A research/special studies program was
   developed  to complement the Monitoring Program by identifying cause/effect
   relationships involving pollutants, transport pathways, and biological communities.

•  Task 8 — Public Education/Outreach Program.  A public education/outreach program
   was developed to promote public awareness of water quality issues.

Separate draft reports were prepared for each Phase II task listed, with the exception of
Tasks 3 and 4, which were combined into one report.  During the preparation of draft
task reports, two EPA/FDEP workshops were held to discuss preliminary findings and
receive input from technical experts and the public: a Monitoring and Research/Special
Studies Workshop  (July 1992) and an Engineering/Management  Options Workshop
(August 1992). Following the workshops, draft task reports were prepared and
reviewed by EPA, NOAA, and various state of Florida agencies. The draft reports were
then revised and combined into a draft Phase II report, which was circulated for public
comment and  revised (EPA 1993).  A separate Implementation Plan for monitoring and
research/special studies was subsequently produced (EPA 1995) which revised these
programs based on available funding and developed details of implementation.
                      1.2.3 Initial Coordination with NOAA

The Water Quality Protection Program was developed in coordination with NOAA,
which is responsible for developing and reviewing management alternatives for the
Sanctuary. NOAA developed five management alternatives, representing different levels

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of resource protection, with Alternative I being most protective and Alternative V the
least protective. Alternative III is the preferred alternative identified in the DMP/EIS
(NOAA 1995).

Each NOAA management alternative consists of numerous strategies. A strategy is an
action or group of related actions taken to address a specific issue.  Taken together, the
strategies are designed to ensure that the goals and intent of the Florida Keys National
Marine Sanctuary and Protection Act are met in the Sanctuary's management plan
(NOAA 1995). Strategies  are grouped under the following issues:

•  Channel marking
•  Education
•  Enforcement
•  Mooring buoy
•  Regulatory
•  Research and monitoring
•  Submerged cultural resources
•  Volunteer
•  Water quality
•  Zoning

During Phase II of the Water Quality Protection Program, options were developed for
corrective actions, as well as recommendations for monitoring, research/special studies,
and education pertaining to water quality issues.  These were presented to NOAA in
draft form at a NOAA/EPA water quality strategies workshop held October 14-16, 1992
in Rockville, MD.  Each EPA option was either adopted as a new NOAA strategy (with
or without modification), incorporated into an existing or modified  NOAA strategy, or
discarded.  Subsequently, EPA prepared a draft Program Document  in which each
recommendation corresponded to a strategy (or a component of a strategy, referred to
as an activity) included in the DMP/EIS (NOAA 1995).

To completely define management strategies, NOAA prepared Action Plans that present
details of implementation, including responsible agencies, schedule, cost,  etc A Water
Quality Action Plan was prepared as part of the draft Program Document and was
included in NOAA's DMP/EIS.  A revised/updated version is presented in Appendix C.
                 1.2.4 Changes in Response to Public Comment

NOAA's DMP/EIS, including the Water Quality Action Plan, was released to the public
in March 1995.  By the close of the public comment period on December 31, 1995,
NOAA had received over 6,000 written and oral comments.  Most of these were form
letters addressing issues other than water quality. Of the water quality-related
comments, most raised general issues and did not recommend specific changes in water
quality strategies.  NOAA summarized these general public comments and prepared
responses (Appendix B).  In general, many commentators agreed  that degradation of
water quality is  the greatest threat to both the natural resources and the economy of
the Keys. They  also agreed that funding for this program is vital. Some were more
concerned about the influences of water quality from sources beyond Sanctuary

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boundaries.  However, the plan addresses outside influences to water quality, and the
Water Quality Protection Program Steering Committee explores this issue regularly.
A few commentators stated that there was no water quality problem in the Keys.
However, many scientists  and users disagree with this statement based on observations
as well as documented scientific evidence.

Many specific recommendations were received from the Sanctuary Advisory Council, a
citizens' group established by the Florida Keys National Marine Sanctuary and
Protection Act to assist the Secretary of Commerce in the development and
implementation of the comprehensive management plan for the Sanctuary.  To respond
to these comments, NOAA designated a Water Quality Extended Review Team,
including EPA and FDEP representatives.  Substantial changes resulting from this review
process are noted at the end of each major section of the document (domestic
wastewater,  stormwater, etc.).

Finally, numerous other changes were needed to update the information in the Program
Document and Water Quality Action Plan. Examples include wording changes to
indicate activities which have already taken place, and updated estimates for nutrient
loading from domestic wastewater.
                    1.3  PROGRAM DOCUMENT ORGANIZATION

Section 2.0 describes the Water Quality Protection Program, including its components
and the administrative framework. Section 3.0 provides an overall rationale for action,
based on the Phase I literature review and technical workshops.  The remaining sections
present recommendations for corrective actions, monitoring, research/special studies,
and education developed during Phase II. The recommendations are organized into
nine categories:

•   Florida Bay/external influences (Section 4.0)
•   Domestic wastewater (Section 5.0)
•   Stormwater (Section 6.0)
•   Marinas and live-aboards (Section 7.0)
•   Landfills (Section 8.0)
•   Hazardous materials (Section 9.0)
•   Mosquito spraying (Section 10.0)
•   Canals (Section 11.0)
•   Monitoring and research/special studies (Section 12.0)

Each section briefly summarizes water quality problems associated with a specific source
or topic area and presents recommendations for corrective actions, education/outreach,
monitoring, or research/special studies.  Details of implementing agencies, cost,
schedule, etc.  are in the Water Quality Action Plan (Appendix C). Appendix A provides
a copy of the Florida Keys National Marine Sanctuary and Protection Act and the
National Marine Sanctuaries Program Amendments Act of 1992.  Appendix B
summarizes general public comments and responses on the Water Quality Action Plan.

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                      2.0  PROGRAM DESCRIPTION
The Water Quality Protection Program consists of an administrative framework and an
initial set of recommendations for corrective actions, monitoring, research/special
studies, and education/outreach.
                       2.1  ADMINISTRATIVE FRAMEWORK

The Water Quality Protection Program is administered by EPA and FDEP, in cooperation
with NOAA.  The National Marine Sanctuaries Program Amendments Act of 1992
(Appendix A) specified the establishment of a Steering Committee, Technical Advisory
Committee, and an EPA Florida Keys Liaison Officer to implement the program, as
described below. Funding for the development of the Water Quality Protection Program
was provided by EPA.

Through the administrative framework described here (Figure 2-1), EPA and FDEP are
implementing recommendations  for monitoring and research/special studies, and are
working with NOAA to develop and implement education/outreach programs for water
quality.  In addition, EPA and FDEP are working within the larger framework of
agencies, institutions, organizations, and individuals responsible for Sanctuary
management to implement recommendations for corrective actions. EPA and FDEP are
also responsible for evaluating progress and developing new or revised approaches as
necessary. Most of the funds to implement monitoring and research/special studies are
being provided by EPA.  NOAA and the South Florida Water Management District
(SFWMD) are also providing funds for implementation.
                          2.1.1  Steering Committee

A Water Quality Steering Committee has been established by EPA and FDEP.  The
purpose of the Steering Committee is to set guidance and policy for the development
and implementation of the Water Quality Protection Program.  Membership includes
representatives of the following agencies, groups, and individuals:

•  EPA
•  FDEP
•  NOAA
•  National Park Service
•  U.S. Fish and Wildlife Service
•  U.S. Army Corps of Engineers
•  Florida Department of Community Affairs
•  Florida Department of Health and Rehabilitative Services
•  SFWMD
•  Florida Keys Aqueduct Authority
*  Local government (three individuals)
•  Knowledgeable citizens (three individuals)

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                                         Steering Committee
        NOAA Sanctuary
        Advisory Council
                         Management
                        Committee and
                       EPA Florida Keys
                        Liaison Officer
 Technical
 Advisory
Committee
Figure 2-1.  Administrative frame-work for the Water Quality Protection Program.

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In addition to setting guidance and polity, the Steering Committee is responsible for
issuing a biennial report to Congress summarizing progress, modifications to the
program, and specific recommendations concerning the implementation of the program.
In addition to interacting with the Technical Advisory Committee and Management
Committee as described below, the Steering Committee receives input from the NOAA
Advisory Council, established by the Florida Keys National Marine Sanctuary and
Protection Act to assist the Secretary of Commerce in the development and
implementation of the comprehensive management plan for the Sanctuary.
                      2.1.2  Technical Advisory Committee

A Technical Advisory Committee has been established by EPA, NOAA, and FDEP.  The
purpose of the Technical Advisory Committee is to advise the Steering Committee and
to assist in the design and prioritization of programs for monitoring and
research/special studies. The Technical Advisory Committee is composed of scientists
from federal and state agencies, academic institutions, and private nonprofit
organizations, as well as knowledgeable citizens.
                     2.1.3  EPA Florida Keys Liaison Officer

The EPA will appoint a Florida Keys Liaison Officer, located within the State of Florida,
to assist in the implementation of the Water Quality Protection Program.  The Liaison
Officer will have the authority and staff to:

•   Assist and support the implementation of the program, including providing
    administrative and technical support for the Steering Committee and Technical
    Advisory Committee;

•   Assist and support local,' state, and federal agencies in developing and implementing
    specific actions designed to carry out the program;

•   Coordinate EPA actions with other federal, state, and local agencies in developing
    strategies to maintain, protect, and improve water quality in the Florida Keys;

•   Collect and make available publications and other forms of information related to
    water quality in and near the Sanctuary; and

•   Provide for public review and comment on the program and  implementing actions.


                         2.1.4 Management Committee

A Management Committee has been established to coordinate and facilitate the
activities of the Steering Committee and Technical Advisory Committee. The
Management Committee is a working group responsible for administering water quality
management in the Sanctuary. The committee has the following major responsibilities:
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•  Plan, prepare agenda for* and coordinate Steering Committee and Technical
   Advisory Committee meetings;

•  Advise the Steering Committee on all matters for which it has direct responsibilities,
   making recommendations for approval or disapproval;

•  Plan and develop budgets and schedules associated with overall program
   implementation; and

•  Monitor the progress of program activities to ensure that schedules are adhered to
   and objectives accomplished.

The committee includes the following people:

•  EPA Region IV Florida Keys Coordinator
•  EPA Florida Keys Program Scientist
•  FDEP Florida Keys Coordinator
•  NOAA Sanctuary Program Manager
•  FDEP/Florida Marine Research Institute Data Management Coordinator
•  Monroe County representative
                          2.2 PROGRAM COMPONENTS

The Water Quality Protection Program consists of four interrelated components:

•  Corrective Actions.  These are actions to reduce water pollution directly by using
   engineering methods, prohibiting or restricting certain activities, modifying existing
   regulations, and/or focusing enforcement.  Other actions are designed to make the
   regulatory/management system work more efficiently, leading indirectly to reduced
   pollution.

•  Monitoring.  A comprehensive,  long-term water quality monitoring program has
   been designed to provide information about the status and trends of water quality
   and biological resources in the Sanctuary. The program will also provide
   information about the effectiveness of remedial actions to reduce pollution.

•  Research/Special Studies. The purpose of the research/special studies program is to
   identify and understand cause/effect relationships involving pollutants, transport
   pathways, and biological communities of the Sanctuary.  Special studies will provide
   information to address specific management questions and concerns, improve
   general understanding of Sanctuary ecosystems, develop predictive models, and
   develop monitoring tools and methodologies.

•  Public Education/Outreach. The purpose of this  component is to increase public
   awareness of die Sanctuary, the Water Quality Protection Program, and pollution
   sources and impacts on Sanctuary resources.  Tjds component also involves
   soliciting and incorporating public input in the design and implementation of the
   program.

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Recommendations in Sections 4.0-11.0 are, with a few exceptions, for corrective
actions. Monitoring and research/special studies recommendations are presented
separately in Section 12.0. One recommendation for special studies pertaining to
Florida Bay Influence is also included in Section 4.0 (Florida Bay/External Influences).

Some of the recommendations in  Sections 4.0-11.0 include education/outreach
components.  Other aspects of the public education/outreach program discussed in
Task 8 of the Phase II report  (EPA 1993) will be implemented through NOAA's
Education Action Plan for the Sanctuary and are not presented here.
                            2.2.1  Corrective Actions

The main purpose of the Water Quality Protection Program is to "recommend priority
corrective actions and compliance schedules addressing point and nonpoint sources of
pollution to restore and maintain the chemical, physical, and biological integrity of the
Sanctuary." Options for corrective actions to reduce water pollution were developed  in
Tasks 3 and 4 of the Phase II report (EPA 1993).  Recommended actions are presented
in this Program Document.

Phase I of the Water Quality Protection Program included the identification of known,
suspected, and potential pollution sources affecting water quality in the Sanctuary (EPA
1992).  An updated pollution source inventory was provided in Tasks 3 and 4,
Appendix A of the Phase II report (EPA 1993).  More recently, domestic wastewater
loading estimates have been revised (W. Thiess, personal communication, Lindahl,
Browning Ferrari & Hellstrom, Inc.).  In Phase II, based on the available information,
pollution sources were targeted for corrective actions involving one or more of three
types of options:

•   Engineering Options.  These are options designed to reduce pollution directly
    through engineering methods.

•   Management Options.  These options would reduce pollution directly by prohibiting
    or restricting certain activities, tightening existing regulations, increasing
    enforcement, and/or increasing environmental awareness. Other management
    options are recommendations to make the regulatory/management system work
    more efficiently and would have little or no direct effect on pollution.

-   Institutional  Options. These are options for institutional control of the pollution
    source (if applicable). These would have little or no direct effect on pollution.

The Phase II engineering and management options form the basis of the
recommendations presented in Sections 4.0-11.0 of this Program Document.  Options
were presented to NOAA in draft form at a NOAA/EPA water quality strategies
workshop held October 14-16, 1992, in Rockville, MD. Each EPA option was either
adopted as a new NOAA strategy (with or without modification), incorporated into an
existing or modified NOAA strategy, or discarded.  Institutional options were regarded
as matters of implementation and were not adopted as strategies.  Subsequently, some
                                      10

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options (and hence strategies) were changed based on agency and public comments
received on the Phase II report.
                 2.2.2 Monitoring and Research/Special Studies

the Florida Keys National Marine Sanctuary and Protection Act requires establishment
of a comprehensive water quality monitoring program. In response to this requirement,
EPA and the State of Florida developed a marine environmental monitoring system that
includes both monitoring and research/special studies. As defined by the  National
Research Council (NRG 1990), a marine environmental monitoring system includes
"a range of activities needed to provide management information about environmental
conditions or contaminants. Depending on the requirements of any particular situation,
these activities could include conceptual and numerical modeling, laboratory and field
research, preliminary or scoping studies, time-series measurements, data analysis,
synthesis, and interpretation."

General program goals from the Florida Keys National Marine Sanctuary and Protection
Act are as follows:

•  To determine the sources of pollution causing or contributing to existing or
   anticipated pollution problems in the Sanctuary

•  To evaluate the effectiveness of efforts to reduce or eliminate those sources of
   pollution

•  To evaluate progress toward achieving and maintaining water quality standards and
   toward protecting and restoring the coral reefs and other living marine resources of
   the Sanctuary

The monitoring and research/special studies programs were originally developed under
Task 6 and Task  7 of the Phase II report (EPA 1993).  Details of implementation were
developed later when the programs were revised based on available funding (EPA
1995). Status and trend monitoring is the core of the program, providing information
about the condition of Sanctuary water quality and biological communities over time.
Special studies will provide additional information to identify pollutant sources and
mechanisms causing or contributing to pollution problems.

Both the monitoring and research/special studies programs were implemented in 1995.
As described in the Implementation Plan (EPA 1995),  the monitoring program currently
has three main components: (1) water quality monitoring; (2) coral reef/hard bottom
monitoring; and  (3) seagrass monitoring. The research/special studies program initially
is focusing on two priority topics: (1) wastewater pollutants and (2) Florida Bay
influence.  Components and priorities may change as these programs are periodically
reviewed and evaluated in the future.
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                        2.2.3 Public Education/Outreach

The public education/outreach program is described in Task 8 of the Phase II report
(EPA 1993).  Such a program is an integral part of the overall Water Quality Protection
Program goal of reducing pollution sources and their impacts on Sanctuary resources,
and increasing public acceptability and support of EPA's program. Public interest in and
concern about water quality in the Florida Keys is supported by an August 1, 1992
survey of Florida Keys residents designed to identify what people feel are the most
significant environmental problems facing the Florida Keys.  Overdevelopment and
water quality degradation were the two problems most frequently chosen (Faanes
1992).

The public education/outreach program is designed to achieve three fundamental
objectives:  first, to begin identifying and interacting with key stakeholders; second, to
use the information obtained through those interactions to create a framework to
structure the ongoing planning process; and third, to list and describe specific activities
(augmenting NOAA's Education Action Plan) to launch the plan implementation
process.  The goals of this planning process are to:

•  Increase public awareness of the EPA Water Quality Protection Program, the
   Sanctuary, and its resources;

•  Increase public understanding of the sources of pollution and their impacts on
   Sanctuary resources;

•  Solicit and incorporate public input into the Water Quality Protection Program; and

•  Gain sufficient acceptance of the program so that it can be successfully
   implemented.

The public education/outreach program described in Task 8 of the Phase II report
includes three main sections.  The first identifies the various public groups
(stakeholders) interested in the EPA Water Quality Protection Program.  The second
describes a directory developed by the NOAA Sanctuary education staff that lists
organizations conducting existing public education and outreach programs and activities
in the Florida Keys. The third provides a conceptual framework for developing a public
education and outreach program plan. The framework includes  an evaluation of
identified public education and outreach needs, and a preliminary public education and
outreach program plan.  Public education and outreach  needs identified by participants
of NOAA-hosted workshops and strategy sessions were used as the baseline for
developing the plan.  The preliminary public education/outreach program plan is
presented as a living document that will be revised as circumstances change and new
information is obtained.
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                          3.0 NEED FOR ACTION
The FKNMS is the first marine sanctuary to have a Water Quality Protection Program.
In establishing the Program, Congress recognized the critical role of water quality in the
Florida Keys. The ecological integrity of Sanctuary ecosystems is dependent on the
maintenance of outstanding water quality, including high water clarity, low or
undetectable nutrient levels (in the case of coral reefs), low concentrations of
xenobiotics, and variations in  other water quality parameters within the tolerance limits
of Sanctuary biota.  The habitats of the Sanctuary and adjacent areas, including Florida
Bay and the Everglades,  support an abundance of fish and wildlife, sustain enormously
valuable commercial and recreational fisheries, and attract anglers, divers, naturalists,
and other tourists from all over the world.  Thus, the economy of the Florida Keys is
tied directly to resources that depend on the maintenance of Sanctuary habitats and
water quality.

Phase I of the  Water Quality Protection Program involved a compilation and synthesis of
environmental information, including evaluation of data adequacy (EPA 1992). Based
on that review and more recent  information, there are many indications that marine
ecosystems of the Florida Keys are suffering a decline in environmental health possibly
related to water quality conditions (EPA 1992; Ogden et al. 1994; Lapointe 1995).  The
variety and magnitude of recent ecological problems  in the Sanctuary and adjacent
areas (e.g., Florida Bay) indicate that existing management actions are not adequate to
prevent continuing environmental degradation.  However, in some cases there is a lack
of scientific data to establish the extent of water quality problems and to determine
whether and where  the situation is declining or improving. After reviewing the
available scientific information, EPA and the State of Florida have reached the following
conclusions:

•  There  is enough information to take some actions now, including engineering and
   management measures and education/outreach activities to reduce pollution of
   Sanctuary waters.                                                   .

•  Long-term, comprehensive water quality monitoring is needed so that  future
   decisions can be based on better information about status and trends of water
   quality and biological resources.

•  Research/special studies are  needed to gain specific information for management
   decisions that will  need to be made in the near future. Long-term studies are also
   needed to better understand how the system works and to provide a better basis for
   sanctuary management.
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             3.1  CORRECTIVE ACTIONS AND EDUCATION/OUTREACH

Although knowledge of cause/effect relationships is incomplete, there is potential for
severe damage to Sanctuary resources if a comprehensive program to control pollution
and improve water quality is not implemented.  The following conclusions are based on
the Phase I report:

•   The Sanctuary is part of a complex hydrologic/ecological system that includes the
    Everglades, Florida Bay, and other adjacent areas. Major environmental problems
    are occurring in Florida Bay, including seagrass die-off, sponge die-off, mangrove
    decline,  and  algal blooms, and the Bay is now in a state of crisis.  Historical
    alterations in the quantity and timing of freshwater flow from the Everglades are
    believed to be the major cause. Action is needed in Florida Bay to avoid effects on
    Sanctuary water quality and resources.

•   Water quality in many confined waters (canals, some marinas,  and some
    embayments  with low water exchange rates) and some nearshore areas (e.g., within
    about 1 mile from shore) has already deteriorated, and there is a high potential for
    widespread water quality degradation. This degradation  may be adversely affecting
    biota and ecological processes in nearshore ecosystems, including seagrass
    meadows, hard bottom areas, and patch  reefs.

•   Septic leachate from on-site sewage disposal systems (OSDS) is degrading water
    quality in confined waters and may be degrading water quality in nearshore waters.

•   Discharges from sewage treatment/package  plants into nearshore receiving waters
    may be degrading nearshore water quality.

•   Sewage discharges from live-aboard vessels  are degrading water quality in nearshore
    and confined waters.

•   Decomposition of weed  wrack and other windblown organic debris is probably
    degrading water quality in some canals.

•   Stormwater runoff is degrading confined water quality and may be degrading
    nearshore water quality.

•   Water-temperature fluctuations, anthropogenically increased nutrient levels, reduced
    water transparency, sedimentation, contamination from spilled oil and petroleum
    products, pesticides, herbicides, trace elements, and heavy metals  may be affecting
    Sanctuary coral reef communities.

•   Degraded water quality is probably adversely affecting submerged and emergent
    aquatic vegetation in the Sanctuary.

On 6 February 1996, the Steering Committee for the Water Quality Protection Program
passed a resolution which emphasizes the importance of corrective actions to reduce
wastewater and stormwater nutrient loading. The Steering Committee Resolution cites
the following finding of the State of Florida  Administrative Hearing Officer:  "Nearshore
waters in the Florida Keys have exceeded carrying capacity for further assimilation of
nutrient impacts  caused by  inadequate stormwater and wastewater treatment." The
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resolution states that "the key to water quality improvement is the construction of
needed treatment facilities that meet best available technology."  It further specifies that
the Steering Committee "supports the use of local, State, and Federal funds for the
planning and construction of wastewater facilities and projects that meet best available
technology to improve water quality in the Florida Keys to the highest technically
feasible standard."

Taken together, these observations and conclusions indicate that actions are needed to
control pollution sources and improve water quality in the Florida Keys in order to
restore and maintain Sanctuary resources.  Actions should include engineering and/or
management measures, as well as education/outreach programs to reduce pollution.
More discussion of problems related to specific pollution sources is presented in the
introduction to subsequent sections (4.0-11.0) of this report.
                                3.2  MONITORING

During the Phase I literature review, it was apparent that many reports of water quality
problems in the Sanctuary are anecdotal or based on limited scientific data (e.g.,
limited to a few locations or time periods) (EPA 1992).  In general, there is a lack of
long-term,  spatially comprehensive data to determine the extent of water quality
degradation and whether or where the situation is declining or improving. A long-term,
comprehensive water quality monitoring program, as required  by the Florida Keys
National Marine Sanctuary and Protection Act, has been designed to provide this
information. The monitoring program is described in Task 6 of the Phase II report (EPA
1993)  and in more detail in the Implementation Plan (EPA 1995).
                        3.3  RESEARCH/SPECIAL STUDIES

A research/special studies program is needed because there is a lack of cause/effect
information linking ecological problems in the Sanctuary to specific water quality
parameters and pollution sources. Task 7 of the Phase II report (EPA 1993) identified
several specific information needs.  Two priority areas for research/special  studies were
identified in the Implementation Plan (EPA 1995): wastewater pollutants and Florida
Bay influence.

Despite the magnitude of wastewater pollutant loadings, there are limited data to
establish a cause/effect relationship between package plant, cesspit, borehole,  or OSDS
effluents and ecological problems in the Sanctuary.  Existing observations and studies,
together with the magnitude and extent of estimated pollutant loadings from
wastewater sources, are a strong indication that wastewater pollutants are reaching
nearshore waters  and affecting biological resources there.  However, given the potential
cost of the wastewater options under consideration (ranging into the hundreds of
millions of dollars; EPA 1993), additional data are needed to document ecological
impacts that can be specifically linked to these pollutants.  Additional studies are
needed to definitively link ecological problems to wastewater sources and to document
the extent and severity of known and suspected problems. .
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Transport of Florida Bay waters is recognized as a significant influence on water quality
in the Sanctuary.  However, little is known about the physical transport of waters
between Florida Bay and the Sanctuary. Limited studies have been conducted that
provide a basis for estimating net transport into the Sanctuary through the major tidal
passes and describing along-shore movement in Hawk Channel (Lapointe et al.  1992;
Smith 1993, 1994; Pitts 1994). As part of the SEAKEYS project, the Florida Institute of
Oceanography has documented boluses or filaments of turbid Florida Bay water moving
across Hawk Channel onto the reef tract (Forcucci and Ogden 1993). The indications
of these filaments are sporadic, and there does not appear to be a regular stream of
Florida Bay water across Hawk Channel.  More data are needed on the formation,
extent, and movement of these plumes.  Also lacking are data on the exchange
mechanisms at the shelf edge for Florida Bay water once it moves out onto the reef
tract or between reefs (N. Smith, pers. comm. 1994,  Harbor Branch Oceanographic
Institution).

In addition to these areas of information needs, technical workshop participants
indicated that the Sanctuary should conduct research/special studies to develop
(1) predictive models to provide information for management decisions and
(2) monitoring tools and methodologies that could provide early warning of ecological
problems.
                      3.4  POLLUTION SOURCES TARGETED

The Phase I report identified and discussed pollution sources potentially affecting
Sanctuary water quality. In the Program Document, the following pollution sources are
targeted for corrective actions, research/special studies, monitoring, and/or
education/outreach activities:

•   Florida Bay/external influences
•   Domestic wastewater
•   Stormwater                                                       ,
•   Marinas and live-aboards
•   Landfills
•   Hazardous materials
•   Mosquito spraying
•   Canals

The options developed in Phase II provided the basis for recommendations for each
source.  Existing problems for each topic are discussed at the beginning of each
subsequent chapter of this report.
                                       16

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               4.0  FLORIDA BAY/EXTERNAL INFLUENCES

                   4.1  INTRODUCTION/PROBLEM DESCRIPTION

Adjacent areas potentially affecting Sanctuary water quality include Florida Bay,
Biscayne Bay, and the Gulf of Mexico/Atlantic Ocean.  Extensive water quality sampling
in Biscayne Bay indicates that water quality in south Biscayne Bay is good and is
unlikely to degrade "Sanctuary waters. "The effects o"f the Tiulf of Mexico/Atlantic Dcean
on Sanctuary waters through upwelling and entrainment of nearby (e.g., Virginia Key
sewage outfall) or distant (e.g., Mississippi River) discharges are difficult to determine.
This difficulty is based,  in part,  on the great natural variability of the physical
oceanographic system and the level of entrainment and delivery to Sanctuary waters.
The discussion here focuses on  Florida Bay.

Severe water quality and ecological problems have developed in Florida Bay in recent
years.  Problems include a massive seagrass die-off, phytoplankton blooms, sponge
die-offs, mangrove die-backs, and population reductions in economically significant
species such as pink shrimp, sponges, lobster, and various  recreational gamefish.
Although the causes and mechanisms are not fully understood (Boesch et al. 1993),
changes in freshwater inflow from the Everglades are believed to be a major influence
(Mdvor et al. 1994).

Even under "normal" conditions, transport of Florida Bay waters of both high and low
temperature, variable salinity, and high sediment content is recognized as a significant
influence on water quality in the Sanctuary, e.g., restricting the  distribution of coral
reefs off the major tidal passes  in the middle Keys (Shinn et al.  1989).  However, little
is known about the physical transport of waters between Florida Bay and the Sanctuary.
Limited studies have been conducted that provide a basis for estimating net transport
into the Sanctuary through the  major tidal passes and describing along-shore movement
in Hawk Channel (Lapointe et al. 1992; Smith 1993, 1994; Pitts 1994). As part of die
SEAKEYS project, the Florida Institute of Oceanography has documented boluses or
filaments of turbid Florida Bay  water moving across Hawk Channel onto the reef tract
(Forcucci and Ogden 1993).  The indications of these filaments  are sporadic, and there
does not appear to be a regular stream of Florida Bay water across Hawk Channel.
More data are  needed on the formation, extent,  and movement  of these plumes. Also
lacking are data on the  exchange mechanisms at the shelf  edge  for Florida Bay water
once it moves out onto  the reef tract or between reefs (N.  Smith, pers. comm. 1994,
Harbor Branch Oceanographic Institution).

Problems in Florida Bay must be viewed as a potential threat to water quality and
resources in the Sanctuary. Water quality and natural resources in Florida Bay are
tightly linked to those of the  Sanctuary.  The need for actions to deal with water
delivery problems in Florida Bay has been strongly stressed by workshop participants
and other scientists during the development of the Water Quality Protection Program.
Two recommendations  are posed here: one to work with appropriate federal, state, and
local agencies to restore freshwater flow to Florida Bay; the other to conduct
research/special studies that will further document the influence of Florida Bay on
water quality and biological resources in the Sanctuary.
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                            4.2  RECOMMENDATIONS

                       4.2.1 Florida Bay Freshwater Flow

    • Recommendation: The Steering Committee for the Water Quality Protection
    Program shall take a leading role in restoring historical freshwater flow (quantity,
    quality, timing, and distribution) to Florida Bay, which is now in a state of crisis.
    In addition, Sanctuary representatives shall work with appropriate federal, state,
    and local agencies to ensure that restoration  plans and surface water improvement
    and management plans for South Florida and the Everglades are compatible with
    efforts to maintain water quality within the Sanctuary  [Phase II option El; NOAA
    strategy W. 19].

The Steering Committee for the Water Quality Protection Program includes high-level
representatives of all relevant agencies and can therefore take a leading role in water
management issues affecting Florida Bay, including restoring historical freshwater flow.
Both short- and long-term solutions must be pursued at high levels of management in
both state and federal agencies.

Sanctuary representatives should also participate hi the review and revision of
restoration plans and water management plans for Florida Bay and adjacent areas to
ensure that these proposals and/or actions will enhance and complement water quality
improvement efforts undertaken in the Sanctuary. These plans include, but are not
limited to, the Shark River Slough General Design Memorandum, C-lll basin, Taylor
Slough Restoration, West Dade Wellfield, US 1 widening, National Park Service
Everglades Restoration Plan, Lower East Coast Water Supply Plan, and Everglades
Surface Water Management and Improvement  Plan.
                   4.2.2  Special Studies: Florida Bay Influence

    • Recommendation: Conduct research/special studies to understand the effect of
    water transport from Florida Bay on water quality and resources in the Sanctuary
    [Phase II research recommendation; NOAA strategy W.24]

Water transport from Florida Bay through the passes is recognized as a significant
influence on water quality in the Sanctuary. Major concerns are changes in salinity,
temperature, turbidity, and nutrients associated with water moving through the passes
in the lower and middle Keys and  onto the reef tract.  The recommended
research/special studies would help scientists and managers to understand the effects of
recent water quality and ecological problems in Florida Bay on water quality and
resources in the Sanctuary. Understanding the influence of Florida Bay water will
provide context for decisions about wastewater and  other water quality problems in the
Sanctuary.

As a result of an Interagency Agreement on South Florida Ecosystem Restoration,  an
Interagency Working Group has developed an Interagency Florida Bay Science Plan that
focuses on research, monitoring, and modeling objectives that must be addressed to
guide the restoration of Florida Bay. The plan includes research on water budgets,

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circulation dynamics and salinity, water quality and nutrient cycling, seagrass and
mangrove communities, and other living resources. Among the pertinent work is the
development of a circulation model for Florida Bay.  The research/special studies
program for the Water Quality Protection Program will complement ongoing and
planned studies in Florida Bay and will focus on linkages between Florida Bay and the
Sanctuary.

One aspect of the proposed research/special studies would involve an historical
assessment of Everglades/Florida Bay/Florida Keys hydrology, as it has affected water
quality and biological communities in the Sanctuary.  It would clarify the role of
freshwater inflows and water quality from the Everglades, and other freshwater
discharges to the southwest shoreline of Florida, to Florida Bay and the Sanctuary.  The
activity would examine the effects of structural modifications and changes in timing and
volume of freshwater releases  from existing structures, as well as land practices
affecting the water quality of runoff.

A second aspect of this recommendation would involve circulation studies to estimate
long-term net transport and episodic transport from Florida Bay to the Sanctuary,
movement of Florida Bay water within the Sanctuary, and exchange mechanisms  at the
shelf edge for water moving out to the reef tract.  Circulation studies could  involve a
combination of field studies and modeling.  Studies of groundwater flow may be
included.

A third aspect of this recommendation would involve studies  to evaluate whether or not
changes in the quality of Florida Bay water flowing into the Sanctuary are influencing
Sanctuary communities, including seagrasses, coral reefs, nearshore hard bottom
communities, and other biota. Ecological studies could be coupled with circulation
studies or could involve separate experimental studies (laboratory, mesocosm, in situ),
historical studies (sclerochronology, geological reconstruction), and/or geographic
comparisons.
                      4.3 PUBLIC COMMENT AND CHANGES

There were no substantial changes to this part of the Water Quality Protection Program
as a result of public or Sanctuary Advisory Council comments.
                                       19

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                      5.0  DOMESTIC WASTEWATER

                   5.1  INTRODUCTION/PROBLEM DESCRIPTION

In the Florida Keys, domestic wastewater facilities include about 24,000 regulated
OSDS,  8,000 unregulated cesspits, over 250 small package treatment plants, and 2
municipal wastewater treatment plants (City of Key West and City of Key Colony
Beach). Estimated nutrient loadings from these sources (plus live-aboard boaters) are
summarized in Table 5-1. The loadings assume that all wastewater nutrients,
including those discharged into groundwater,  eventually reach Sanctuary surface
waters. About 50% of the total wastewater nitrogen and 60% of total wastewater
phosphorus loadings come from OSDS and  cesspits.  Although potentially significant
nutrient sources such as atmospheric and advective inputs have not been estimated,
these inputs are expected to be more diffuse than wastewater loadings, which can cause
local concentration increases  in confined  and  nearshore waters.

Extensive use of OSDS and cesspits, combined with severely limited soils and compact
clustering of development, have resulted  in substantial nutrient loadings to groundwater
and surface water in the Florida Keys.  Cesspits are an illegal and unacceptable method
of wastewater disposal, from  both public  health and environmental perspectives.
Permitted septic systems function adequately from a sanitary perspective but do little to
remove nutrients, especially in the carbonate substrates of the Florida Keys. As
described in the Phase I report (EPA 1992), degraded water quality has been
documented in confined waters such as canal  systems where there are large numbers of
OSDS and/or cesspits.  In addition, there is growing evidence of linkages between OSDS
enrichment of nearshore waters and effects on water quality (increased nutrient
concentrations, reduced dissolved oxygen, reduced water clarity) and biota (algal
blooms, seagrass trophic state) as reviewed by Lapointe (1995).  The fate and ecological
impacts of wastewater pollutants are being  further documented through the
research/special studies program (EPA 1995).

Table 5-1. Estimated domestic wastewater loadings in the Florida Keys.  Revised data are
         from W. Thiess (personal communication, Lindahl, Browning Ferrari &
          Hellstrom, Inc.) based on the Phase U report (EPA 1993).
Total Nitrogen

OSDS
Cesspits
Package plants (groundwater discharge)
Municipal wastewater treatment plants
Ib/day
932
283
758
320
Percent
of Total
39.2
11.9
31.9
13.5
Total Phosphorus
Ib/day
226
100
152
36
Percent
of Total
41.6
18.4
27.9
6.6
 (surface discharge, NPDES)

 Live-aboards                               84      3.5           30       5.5

	Total:    2377     100	544      100

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Lack of regular OSDS inspections may also be contributing to water quality problems.
A Monroe County ordinance requires OSDS facilities to be inspected at three-year
intervals to determine if they are functioning properly. However, the ordinance does
not specify who is to do the inspections, and the Florida Department of Health and
Rehabilitative Services (FDHRS) has never been given legal authority to inspect
previously approved systems unless there is a reported health problem. As a result,
such inspections have not been conducted.  In addition, the effectiveness of OSDS  rules
instituted specifically to protect surface waters in the Keys has never been monitored.

Package plants, which discharge wastes into groundwater via Class V injection wells
(boreholes), may also pose water quality problems. These plants provide secondary
waste treatment but are not efficient in nitrogen and phosphorus removal.  The
research/special studies program includes studies to determine the fate and effects of
injection well fluids.

Population growth must be a consideration in developing a comprehensive approach to
wastewater treatment.  However, the main focus in the Florida Keys should be on
correcting problems associated with existing systems, rather than new development.
The reason is that future growth in the Keys is expected to be dramatically curtailed,
based on the Monroe County Year 2010 Comprehensive Plan as implemented through
the Monroe  County Rate of Growth Ordinance. Therefore, new development will be
minor when compared to existing development. Most of the growth is expected to
occur as single family homes, built in areas already platted.
          5.2  WASTEWATER RECOMMENDATIONS FOR MONROE COUNTY

Continued reliance on high densities of conventional OSDS in severely limited
substrates is not compatible with restoring and maintaining the excellent water quality
necessary to support Sanctuary resources.  In the short term,  actions are needed to
identify cesspits and establish an inspection program to ensure that OSDS are operating
properly. Over the long term, a Sanitary Wastewater Master  Plan should be developed
which presents a comprehensive approach to improving wastewater treatment in the
Florida Keys, based on water quality and environmental considerations as well as public
health concerns. This approach probably will involve a combination of constructing
regional, subregional,  or community wastewater treatment plants, upgrading package
plants to advanced wastewater treatment (AWT), and replacing existing OSDS with
alternate, nutrient-removing systems.

The Phase II report presented seven options (W3a-g) for wastewater treatment and
disposal outside the City of Key West, which is served by a municipal plant The first
(W3a) would identify  cesspits and establish an inspection/compliance program for
OSDS and package plants. This is considered a minimum corrective action, and the
same concept is built into the other options. Beyond that level of treatment, two broad
approaches were identified:
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    •   Use existing systems, but upgrade the level of nutrient removal (options W3b and
       W3c),  Under this approach, either package plants or both package plants and
       OSDS would be upgraded beyond current standards to enhance nutrient
       removal. An option for upgrading OSDS  but not package plants was not
       considered. Because the expense of the OSDS upgrade is so much greater than
       that of the package plant upgrade,  it would not make sense to upgrade OSDS
       and leave the package plants at their current performance level.

    •   Construct community or subregional AWT plants and associated collection systems
       (options W3d-g). Under this approach, either 2 community plants, 7 community
       plants, 12 community plants, or 3 subregional plants would be constructed (in
       order of increasing percentage of Florida  Keys wastewater treated). The plants
       would provide a high level of nutrient removal for wastewater.

Further information about each option is provided in Table 5-2, including percentage
of wastewater flow treated, estimated cost, and advantages  and disadvantages. At
present, these options can be evaluated partially  on the basis of estimated total cost,
cost efficiency,  nutrient reduction efficiency, and reliability  of the technologies involved.

Option W3a (identification of cesspits and establishment of an inspection/enforcement
program for OSDS and package plants) is minimal but essential. All of the further
treatment options would build upon this minimal action.  Before a decision is made
among the other options for further treatment, information is needed  to evaluate the
nutrient removal efficiency, reliability (operating/maintenance requirements), and cost
of alternate, nutrient-removing OSDS,  Data from an alternate OSDS demonstration
project could show whether these systems would be appropriate for Keys-wide use, or
as a supplement to community/subregional wastewater  treatment plants. In addition,
the feasibility of developing nutrient reduction targets needs to be investigated.
Therefore, the recommendations in this section outline a process by which short-term
actions should be taken, information should be gathered,  and long-term solutions
should be evaluated and implemented.
                     5.2.1  Inspection/Compliance Programs

    • Recommendation: Establish inspection/compliance programs for cesspits and
    OSDS and continue the existing FDEP inspection/compliance program for package
    plants [Phase II option W3a; NOAA strategy W.3]

This recommendation would involve establishing an on-site inspection program to
identify all cesspits and ensure that OSDS are in compliance with existing standards.
This program, along with continuation of the existing FDEP inspection/compliance
program for package plants, would ensure that these systems are operating properly,
reducing nutrient loading to groundwater.  Cesspits identified through this activity
would eventually be replaced with an approved OSDS or a connection to a community
wastewater treatment plant, as determined by the Sanitary Wastewater Master Plan.
This would reduce nutrient loading to groundwater and eliminate health hazards from
untreated sewage. Because development and implementation of the Sanitary
Wastewater Master Plan is a long-term process, Monroe County should develop an
interim response policy to address non-compliance wastewater treatment systems as


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       Table 5-2.  Summary ofwastewater engineering options developed in the Phase II report (Modified from: EPA 1993).
to
Wastewater
Optiona
Percent of Wastewater
Receiving Advanced
Treatment
Entire Outside
Keys Key West
Total Cost
(Initial +
20-year
O&M)
($ millions)
Advantages/Disadvantages/Notes
        W3a - Upgrade existing           0
        systems to current standards


        W3b - Upgrade OSDS to          16
        current standards and
        package plants to BAT

        W3c - Upgrade OSDS to          53
        alternate, nutrient-removing
        systems and package plants
        to BAT
        W3d - Construct 2               73
        community AWT plants for
        Marathon and Key Largo;
        use excess capacity of Key
        West plant in Lower Keys

        W3e - Construct 7               83
        community AWT plants

        W3f - Construct 12               96
        community AWT plants

        W3g - Construct 3               96
        subregional AWT plants	
27
87
52
73


94


94
 57b      Little nutrient reduction, but sanitary/health conditions would be
          improved by eliminating cesspits and ensuring OSDS are operating
          properly

 64      Modest nutrient reduction for relatively low cost, but little effect on
          water quality problems caused by dense concentrations of OSDS


 546      Substantial nutrient reduction, but performance of alternate OSDS
          needs to be tested in the Keys. Alternate OSDS may require more
          stringent operating, maintenance, and inspection requirements than
          existing systems, a serious problem given the large number of OSDS
          and cesspits in the Florida Keys and their historical lack of
          inspection. Very expensive

 289      Substantial nutrient reduction. Would eliminate dense
          concentrations of OSDS and cesspits in the two most populous areas
          outside of Key West. Simplest and least costly of the community/
          subregional plant options; further plants could be  constructed to
          serve additional areas in the  future

 419      Would capture a larger portion of total Wastewater flows outside the
          City of Key West, but at substantially greater cost

 607      Maximum use of community plants in the Florida  Keys.
          Very expensive

 690      Same degree  of nutrient reduction as W3f but requires fewer sites
	for treatment plants. Very expensive                      	
       Abbreviations: AWT advanced wastewater treatment; BAT best available technology; OSDS on-site sewage disposal systems

       aAIl options include elimination of all cesspits.  For community and subregional plant options, all non-complying package plants and OSDS in
        areas beyond those served by proposed AWT plants would be upgraded to current standards (W3d, W3e) or to AWT or equivalent (W3f, W3g).
        See Task 3/4 of the Phase II report (EPA 1993) for further details on all options.
        Originally estimated at $42 million in the Phase II report including replacement of an estimated 5,000 cesspits at $5,000 each. More recent
        data indicate  8,000 or more cesspits, and the estimates were recalculated using that figure.

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part of this activity.  This activity will also include a public education/outreach
component which would inform the public about ways to assess and improve existing
wastewater treatment systems.
                       5.2.2  OSDS Demonstration Project

    • Recommendation:  Conduct a demonstration project to evaluate innovative
    alternate, nutrient-removing OSDS [Phase II option Wl; NOAA strategy W. 1]

This demonstration project would provide information to help determine the
appropriate role, if any, for alternate OSDS (septic systems) in wastewater management
in the Keys.  Although some alternate OSDS designs appear promising, it is not
appropriate to proceed with broad-scale installation of these systems until an
independent evaluation has been conducted.  Alternate OSDS designs  would be
reviewed and appropriate systems selected for evaluation.  Alternate OSDS designed for
nutrient removal would be installed and maintained in a manner consistent with actual
residential use. Influent, effluent, and groundwater quality (both background and
"down-gradient") would be monitored at regular intervals for at least a year.  In
addition to nutrient removal efficiency, the study would evaluate maintenance and
inspection requirements to keep units operating properly.
                        5.2.3 AWT Demonstration Project

    • Recommendation: Conduct a pilot project to evaluate installation of a small,
    expandable AWT plant to serve an area of heavy OSDS use with associated water
    quality problems [Phase II option W2; NOAA strategy W.2]

This pilot project would provide information to help determine whether elimination of
OSDS would improve water' quality in areas believed to be degraded by OSDS nutrients.
Existing OSDS in the test area would be connected to a small package plant providing
AWT, which includes nutrient removal.  The project would also provide information
about long-term performance of small AWT systems and septic tank effluent pumps or
other collection systems.  Both conventional and innovative technologies would be
considered.
                        5.2.4  Nutrient Reduction Targets

    • Recommendation:  Evaluate the development of nutrient reduction targets
    necessary to restore and maintain water quality and Sanctuary resources [NOAA
    strategy W.3]

The goal of this recommendation is to identify and evaluate alternative strategies for
developing nutrient reduction targets for wastewater and stormwater in the Florida
Keys National Marine Sanctuary.  The information will help the EPA and the State of
Florida to determine whether nutrient reduction targets should be developed and if so,
how development should proceed.


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This recommendation has already been addressed (EPA 1996). A report evaluating
alternative approaches to the development of nutrient reduction targets concluded that
"wastewater nutrient loadings should be reduced as soon as possible using a
technology-based approach.... It is not necessary to develop resource-based nutrient
reduction targets before proceeding with corrective actions."
                     5.2.5 Sanitary Wastewater Master Plan

    • Recommendation: Develop and implement a Sanitary Wastewater Master Plan
    that evaluates options for upgrading existing systems beyond current standards or
    constructing community sewage treatment plants, based on nutrient reduction
    targets, cost and cost effectiveness, reliability/compliance considerations, and
    environmental and sodoeconomic impacts [NOAA strategy W.3]

The Sanitary Wastewater Master Plan would evaluate options for wastewater treatment
and disposal developed in the Phase II report (as well as other options which may
subsequently be identified). Currently, these options can be evaluated partially on the
basis of estimated cost, cost effectiveness, nutrient reduction, and reliability of the
technologies involved.  However, the options should also be evaluated in light of the
information about the nutrient removal capacity, cost and cost effectiveness,  and
reliability of alternate, nutrient-removing OSDS and various conventional and
innovative AWT technologies.  This information will come from the OSDS
Demonstration Project and the AWT Demonstration Project. Environmental and
sodoeconomic impacts must also be analyzed. The Sanitary Wastewater Master Plan
will also specify details of costs, schedules, service areas, etc for implementation.  The
master plan should investigate the feasibility of wastewater utility districts and other
alternative funding mechanisms.  Development of the Sanitary Wastewater Master Plan
has been initiated by Monroe County and a technical advisory committee has been
established to provide assistance to the County.
                       5.2.6 Master Plan Implementation

    • Recommendation:  Implement the preferred wastewater treatment option selected
    in the Sanitary Wastewater Master Plan [an activity under NOAA strategy W.3]

The eventual preferred  option cannot be identified at this time. If an option involving
community or subregional wastewater treatment plants is chosen, implementation will
include setting up a wastewater utility.  Candidates include the Florida Keys Aqueduct
Authority (which already has the legislative authority to serve as a wastewater utility)
and Monroe County.
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          5.3 WASTEWATER RECOMMENDATION FOR CITY OF KEY WEST

                      5.3.1  City of Key West Ocean Outfall

    • Recommendation:  Upgrade effluent disposal for City of Key West wastewater
    treatment plant  Evaluate deep well injection, including the possibility of effluent
    migrating from the Boulder Zone into Sanctuary surface waters.  Evaluate options
   for reuse of effluent, including irrigation and potable reuse.  Discontinue use of the
    existing ocean outfall and implement deep well injection,  aquifer storage, and/or
    reuse.  [Phase II option W4; NOAA strategy W.4]

This recommendation would reduce nutrient loadings to surface waters from the Key
West wastewater treatment plant The City of Key West wastewater treatment plant
would continue providing secondary treatment of wastewater, and existing programs for
the extension of sewer service to areas not presently served and reduction of
infiltration/inflow would be continued.  However, the ocean outfall would be replaced
as the primary means of effluent disposal. Use of the ocean outfall would be
discontinued (except in emergencies), and effluents would be disposed through deep
well injection and/or reuse (to the extent feasible).

Before use of the ocean outfall is discontinued, both the environmental aspects of deep
well injection and the economics of effluent reuse need to be evaluated thoroughly.
Studies of deep well injection need to investigate the possibility of effluent migrating
from the Boulder Zone into Sanctuary surface waters. Reuse  options to be evaluated
include irrigation and further treatment to produce potable water. Reuse for local
irrigation may be limited due to the small number of application sites. Reuse for
irrigation in areas outside the Florida Keys would be considered only if it were proposed
for unincorporated Monroe County. Potable reuse, although requiring costly treatment,
might be cost-effective in the long term, considering the current cost of treating and
pumping in drinking water from Florida City.

Continued use of the existing ocean outfall with an upgrade in treatment and extension
of the existing outfall were determined not to be viable options.  The existing ocean
outfall has deteriorated and does not meet current FDEP requirements.  The cost of
constructing a new ocean outfall to meet current FDFJ* standards  would be greater than
that for deep well injection. Also, obtaining a permit for a new ocean outfall may be
difficult.

Prior to implementing this recommendation, monitoring of the Key West ocean outfall
should be continued until the database is adequate to assess impacts on receiving
waters and establish background conditions with the outfall in use.  Following
completion of an effluent disposal upgrade, monitoring of nearshore waters and systems
should be continued to document the  effects of removing this outfall from the
Sanctuary.
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                     5.4  MANAGEMENT RECOMMENDATIONS

                         5.4.1  Water Quality Standards

    • Recommendation:  Develop and implement water quality standards, including
    biocriteria, appropriate to Sanctuary resources (corals and seagrasses)
    [Phase II option W5; NOM strategy W.5]

The FDEP and EPA should work jointly to develop and monitor water quality standards,
including nitrogen and phosphorus standards and biocriteria, for the permitting of
wastewater and stormwater discharges.  Outstanding Florida Waters (OFW) standards
would continue to be used until research/special  studies indicate that new, more
stringent regulations are necessary.

The objective of regulating wastewater and stormwater discharges is to protect and
preserve the marine resources of the Sanctuary.  Nutrients, particularly nitrogen and
phosphorus, are suspected as the major contributors to eutrophication of nearshore and
confined waters in die Sanctuary. Water quality  standards for nitrogen and phosphorus
should be adopted, based on the recognition that minor fluctuations in nutrients in
Sanctuary coastal waters may have a greater impact on water quality and marine
resources than in most odier coastal areas  in Florida.

Biocriteria are "numerical values or narrative expressions that describe the reference
biological integrity of aquatic communities inhabiting waters of a given designated life
use" (EPA 1990). Biocriteria are valuable  because they directly measure the condition
of the resource  at risk, detect problems that other methods (e.g., chemical analyses of
water quality) may miss or underestimate,  and provide a systematic process for
measuring progress resulting from the implementation of water quality programs (EPA
1990).  EPA is directing states to adopt narrative biological criteria into state water
quality standards over the next few years.

As part of the development of biocriteria, research/special studies will need to be
conducted to identify and evaluate indicators (biochemical and ecological measures to
provide early warning of widespread ecological problems) in each type of ecosystem.
Examples are tissue C:N:P ratios, alkaline phosphate activity, and shifts in community
structure by habitat. In addition to providing the basis for new standards, these
measures should be appropriate for incorporation into the Water Quality Monitoring
Program.
                       5.4.2 NPDES Program Delegation

    • Recommendation:  Delegate administration of the National Pollutant Discharge
   Elimination System (NPDES) program for Florida to the state of Florida [Phase II
   option W6; NOAA strategy W.6]

The EPA administers the NPDES permitting program and has the authority to delegate it
to the states.  Delegation of NPDES permitting authority to the state of Florida, as has
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been done in many other states, would simplify the permitting process for surface water
dischargers by removing the need to apply for permits from both the EPA and FDEP.

This recommendation was implemented in 1995.  FDEP submitted an application to the
EPA to have the program delegated.  The two agencies entered into a memorandum of
understanding (MOU)  defining agency roles and responsibilities for NPDES permitting
in FlrvriHa
                5.4.3  Resource Monitoring of Surface Discharges
    • Recommendation:  Require all NPDES-permitted surface dischargers to develop
    resource monitoring programs, including biological monitoring where appropriate
    [Phase II option W7; NOAA strategy W.7]

This recommendation would help to evaluate environmental impacts of point-source
discharges by requiring all NPDES-permitted surface dischargers to develop resource
monitoring programs. This could be accomplished in one of two ways.  One way would
be for EPA to eliminate the baseline exemption for resource monitoring under the
Ocean Discharge Program, as it applies to the Florida Keys. All surface dischargers
except the City of Key West sewage treatment plant are currently exempted from
developing resource monitoring programs because the end of their discharge pipe does
not extend beyond the baseline (the mean low tide line).

A second way to accomplish the  same goal would be for FDEP, through the state of
Florida's permitting authority, to require resource monitoring when individual NPDES
permits  come up for renewal.  This approach probably would be easier because it can
be accomplished under existing rules,  whereas eliminating EPA's baseline exemption
would require a federal rule change.
                    5.4.4  Improved Interagency Coordination

    • Recommendation:  Improve interagency coordination for industrial wastewater
    discharge permitting [Phase II option W9; NOAA strategy W.8]

This strategy would improve coordination between the EPA, FDEP, and local
government relative to industrial wastewater discharge permitting and tracking (FDHRS
is included for special cases such as seafood processing plants discharging into septic
systems).  At present, much of the interagency coordination and tracking is handled
through a series of memoranda of agreement (MOAs) and MOUs. These agreements
would be reviewed, evaluated, and revised specifically for the Florida Keys.  This could
also indirectly reduce wastewater pollution by refining arid simplifying the OSDS
permitting process and increasing funds for compliance monitoring and enforcement.
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                             5.4.5  OSDS Permitting

    • Recommendation:  Combine OSDS permitting responsibilities in one agency for
    commercial establishments, institutions, and multi-family residential establishments
    utilizing injection wells [Phase II option WlOa; NOAA strategy W.8]

this recommendation would combine FDEP and FDHRS permitting responsibilities for
commercial establishments, institutions, and multi-family residential establishments in
one agency. Currently, for commercial establishments, institutions, and multi-family
residential uses with total daily flows less than 5,000 gallons, the Monroe Hounty~Public
Health Unit is authorized to permit the aerobic treatment unit and the filter unit,
whereas the FDEP permits the injection well (borehole). However, effluent from these
aerobic systems does not meet the more stringent wastewater treatment standards of
the FDEP.  Under this recommendation, the FDEP and FDHRS would enter into a MOU
delineating the roles and responsibilities of each agency regarding OSDS.  The agencies
would need to agree on establishing the same level of treatment requirements for
existing and new or innovative OSDS units to be permitted in the Florida Keys.  Once
agreement  is reached, the administrative rules regarding the quality of wastewater
being discharged into injection wells would be amended.
                    5.4.6 Monitoring of Revised OSDS Rules

    • Recommendation: Monitor revised rules designed to improve the performance of
    OSDS in the Florida Keys [Phase II option WlOd; NOM strategy W.8]

This recommendation will involve designing and implementing a monitoring program to
determine the effectiveness of recent revisions in Part II of Chapter 10D-6 FAC.
Effective March 1992, FDHRS implemented two key rule changes specifically targeting
the Florida Keys.  One change makes the use of Class V underground injection wells
(boreholes) an option of last resort.  The other requires placement of a minimum
12-inch thick filter layer of quartz sand below the drainfield absorption surface/of the
OSDS.  Data are needed to evaluate whether these changes are achieving their desired
effect
                           5.4.7 Laboratory Facilities

    • Recommendation: Evaluate the feasibility of, and if appropriate, establish an
    interagency laboratory capable of processing monitoring and compliance samples
    [Phase n option Wll; NOAA strategy W.9]

Under this recommendation, the FDEP and FDHRS would jointly evaluate the feasibility
of creating an interagency laboratory facility in the Keys  for processing compliance
monitoring samples.  Neither the FDEP nor the FDHRS has FDHRS-certified (or
equivalent) laboratory facilities in the Keys.  Because of quality control considerations
(holding times), it is difficult or impossible to ship compliance/enforcement samples to
Tallahassee for analysis, and use of contracted private  laboratory facilities is expensive.
The agencies should jointly evaluate the feasibility of establishing a laboratory facility


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certified by FDHRS or by the quality assurance section of FDEP. The laboratory would
be located in the FDEP office building in Marathon and would not process toxics or
status and trends samples from the water quality monitoring program.
                     5.5  PUBLIC COMMENT AND CHANGES

Several changes were made based on comments from the Sanctuary Advisory Council.
First, the recommendations for demonstration projects were reworded to emphasize
innovative technologies. Second, the Inspection/Enforcement recommendation was
rewritten to explain that cesspits would be initially identified, but not necessarily
replaced until the Sanitary Wastewater Master Plan is developed.  The recommendation
was also changed to state that Monroe County would develop an interim response
policy for non-compliance wastewater systems and would develop a public
education/outreach component. The Resource Monitoring recommendation was
changed to emphasize use of biological monitoring where appropriate.  The Laboratory
Facilities  recommendation was changed to evaluate feasibility first.

Other updates and reorganization were needed. Some of the background discussion
was simplified, and updated information on wastewater nutrient loadings was added.
The Water Quality Standards recommendation was changed to include research/special
studies on the development of indicators, which was formerly a separate
recommendation under the research/special studies program. The recommendations for
Nutrient Reduction Targets and NPDES Program Delegation have already been
implemented, and this has been noted.
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                             6.0  STORMWATER

                   6.1  INTRODUCTION/PROBLEM DESCRIPTION

Stormwater sources contribute about 21% of total wastewater/stormwater nitrogen and
44% of total wastewater/stormwater phosphorus loadings to Sanctuary waters (EPA
1993), There are few effective stormwater management systems in the Florida Keys, for
the following reasons:

•   Many of the larger subdivisions or developments were constructed before South
    Florida Water Management District (SFWMD) stormwater permitting requirements
    were in place.

•   Most developments constructed after SFWMD stormwater regulations were in place
    fell below die thresholds for those regulations (10 acres total or 2 acres of
    impervious surface).

•   Prior to 1986, Monroe County had no ordinance regulating stormwater
    management.  The 1986 ordinance was largely unenforceable because  of its
    stringent requirements with insufficient guidelines for implementation, and
    difficulties of enforcing compliance on residential lots.

•   The lack of available lands for detention or retention areas generally made
    voluntary stormwater management difficult.

Typical drainage in many areas consists of direct runoff to the nearest surface water,
with some attenuation provided by high infiltration rates. There are several engineered
stormwater management systems using one or more boreholes for disposal; most of
these systems are in the City of Key West or Marathon.  Most other noticeable
stormwater management improvements are in the U.S. 1 right-of-way, such as the
extensive swales located throughout much of Key Largo.

Because of the limited regulation of stormwater management in the Keys, the end result
is largely uncontrolled stormwater runoff.  If there is no organized effort toward the
improvement of stormwater management in the Keys, degradation  of nearshore waters
by stormwater runoff will continue due to loadings of sediment, toxics, and nutrients.

The Phase II report includes three gradations of a major engineering option (Sla-c) and
three management options (S2, S3a-b, and S4) to improve stormwater pollution control
in the Florida Keys.  At the NOAA/EPA water  quality strategies workshop on October
14-16, 1992, all four options were selected as NOAA strategies.
                            6.2  RECOMMENDATIONS

                         6.2.1 Stormwater Retrofitting

    • Recommendation:  Identify and retrofit stormwater hot spots using grass parking,
   swales, pollution control structures, and detention/retention facilities.  Control
   stormwater runoff in areas handling toxic and hazardous materials. Install swales
   and detention facilities along limited sections of US. 1 [Phase II option Sla; NOAA
   strategy W.I 1]

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Stormwater retrofitting is the application of control and treatment methods (such as
those identified above) to areas that were developed before SFWMD stormwater
permitting requirements were in place, or that fell below the thresholds for those
regulations. The purpose of stormwater retrofitting is to reduce loadings of sediment,
toxics, and nutrients to Sanctuary waters.  The Phase II report presented three
gradations of an engineering option for stormwater retrofitting:

•   Sla — hot spots ($200 million over 20 years)
•   Sib — hot spots and population centers ($810 million over 20 years)
•   Sic — Sanctuary-wide ($1.2 billion over 20 years)

The recommended option (Slal would apply control and treatment methods to
identifiable stormwater hot spots, where stormwater pollutant loadings are high and
degradation of receiving waters is obvious or already documented.  Although the other
two options would result in further stormwater pollutant control, the projected costs are
so high that, realistically, they probably would not be implemented.  For example,  the
$810 million cost of Sib is greater than the projected cost of any option considered for
domestic wastewater,  up to and including sewering over 90% of the Florida Keys (EPA
1993).  Option Sla focuses on providing stormwater pollutant control in areas that
need it most.

The effectiveness of stormwater control/treatment facilities is  not well known and is
highly dependent on site conditions, engineering methods, and level of maintenance.
Estimated reductions in nutrient loadings (percentage of total stormwater nutrients) are
0.2-0.5%, and estimated reductions in sediment loadings are 0.5-1.0%.  (These
percentages are Sanctuary-wide; pollution reduction in hot spots would be  much
greater).  Loadings of toxics  (e.g., metals and hydrocarbons) have not been estimated,
and, therefore the reductions cannot be quantified. However, stormwater control
methods would reduce loadings of toxics into Sanctuary waters.
                         , 6.2.2 Stormwater Permitting

    • Recommendation: Require that no development in the Florida Keys be exempted
   from the stormwater permitting process [Phase II option S2; NOAA strategy W.12]

The SFWMD, which currently has primary responsibility for stormwater permitting in
the Florida Keys, exempts developments of less than 10 acres in size or 2 acres of
impervious surface from having to obtain a stormwater permit  Most developments in
the Keys fall below this threshold. Local governments are in the process of developing
stormwater management ordinances and/or stormwater management master plans.
This strategy would require that the local government ordinances and master plans
cover all developments, with no minimum size threshold for requiring developments to
go through the stormwater permitting process.

Each local government (Monroe County and the municipalities) will be responsible for
implementing its own ordinance within its jurisdictional limits.  Since the preparation of
the draft Program Document,  Monroe County has implemented a stormwater
management ordinance which addresses  everything that falls below the SFWMD
permitting threshold.  The City of Key West's Land Development Regulations also
address developments that fall below the SFWMD permitting threshold.  As the state


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land planning agency for a designated Area of Critical State Concern, the Florida
Department of Community Affairs (FDCA) has an oversight responsibility to ensure that
local development regulations adequately protect the area's natural resources and are
consistent with those of their neighbors. The SFWMD may provide technical assistance
in the development of stormwater ordinances and master plans.
                         6.2.3  Stormwater Management

    • Recommendation:  Require local governments to enact and implement stormwater
    management ordinances and comprehensive stormwater management master plans
    on a continuing, county-wide basis.  Petition the EPA to include the Florida Keys in
    the stormwater NPDES program if adequate stormwater management ordinances
    and administrative capability to manage such ordinances are not in place by a
    certain date [Phase II option S3b; NOAA strategy W. 13]

This recommendation would help to reduce stormwater pollutant loadings (e.g.,
sediment, toxics, and nutrients) by requiring local governments to develop stormwater
management ordinances and master plans.  Currently, there  is little regulation of
stormwater runoff in the Keys.  Many developments were constructed before SFWMD
stormwater permitting requirements were in place, or, if they were constructed more
recently, fell below the acreage thresholds for those regulations.  Monroe County
recently passed a stormwater ordinance, and other local governments are either
developing ordinances and/or have stated in their comprehensive plans that stormwater
management master plans will be developed.  As a backup in the event that these
ordinances  and master plans are not developed in a timely manner, the EPA would be
petitioned to include the Keys in the NPDES stormwater permitting program for
municipal separate storm sewer systems. Monroe County falls below the population
threshold that would normally trigger inclusion in the program, but the state of Florida
can petition EPA to include a local government if necessary.
                       6.2.4 Best Management Practices

    • Recommendation:  Institute a series of Best Management Practices and a public
    education program to prevent pollutants from entering stormwater runoff [Phase II
    option S4; NOAA strategy W.14]

This recommendation would reduce pollution from stormwater runoff through a variety
of programs, including street sweeping; ordinances aimed at controlling fertilizer
application on public and private landscaping; collection locations and a public
education program for the proper use and disposal of fertilizers, pesticides, motor oil,
and other hazardous chemicals; and strenuous litter control programs.
                      6.3 PUBLIC COMMENT AND CHANGES

Based on Sanctuary Advisory Council comments, the recommendation for Best
Management Practices was reworded to emphasize that a public education program
would be included. Also, the status of existing stormwater management ordinances has
been noted under the Stormwater Permitting recommendation.

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                    7.0  MARINAS AND LIVE-ABOARDS

                   7.1  INTRODUCTION/PROBLEM DESCRIPTION

A live-aboard is defined as "an individual(s) whose continual residence is a boat, not
necessarily at a fixed location, for a period of time of more than two months" (Antonini
et al. 1990).  As described in the Phase I report, live-aboards can be found throughout
the Florida Keys, and the live-aboard population has increased significantly in recent
years.  Most are located in clusters in a few areas  such as Card Sound, Largo Sound,
Matecumbe Harbor, Marathon, and Key West.

Disposal of wastewater by live-aboards represents  an estimated 3 to 5% of all total
wastewater nutrient loadings to Sanctuary waters.  For this reason, detrimental effects
of live-aboard wastewater disposal are  not likely to be significant from a regional
standpoint.  However, because of the low level of treatment, the tendency of live-
aboards to congregate in  certain marinas or anchorages,  and the potential adverse
health effects of discharging untreated  wastewater into Sanctuary waters, live-aboard
wastewater disposal is a significant localized problem.

Marina operations with the potential for polluting water  or sediments include boat
bottom scraping and painting, fueling operations,  residual fuels and oils from engine
repairs or bilge cleaning,  and the use or disposal of resins and solvents associated with
fiberglass  construction or repair.  As noted in the Phase I report, a small number of
samples collected from paint scrapings  and bottom sediments at marinas in the Florida
Keys have indicated the presence of metal contamination. Available data are
insufficient to quantify loadings of pollutants to waters and sediments or to assess the
detrimental effects  of bottom painting operations.

In the  Phase II report, six management options were presented to reduce pollution from
marinas and live-aboards.  At the NOAA/EPA water quality strategies workshop on
October 14-16,  1992, all  of'the options were included in existing NOAA strategies.  One
of the recommendations was split into two strategies, so  there are seven
recommendations.  Additional data  concerning pollutant concentrations in water and
sediments of marinas and live-aboard areas will be collected through the Water Quality
Monitoring Program. These data should indicate the severity and extent of water
quality problems and whether there is a need for further pollution control measures.
                          7.2  RECOMMENDATIONS

                           7.2.1  Pollution Discharges

    • Recommendation:  Reduce pollution discharges (e.g., sanitary wastes, debris,
    hydrocarbons) from vessels by implementing the 1994 Florida Clean Vessel Act and
    developing a public education program.  Change the environmental crimes category
    associated with discharges from felony to civil offense,  thereby removing the need to
    prove criminal intent [Phase II options Bl  and H5; NOAA strategy B.7]
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The Florida Clean Vessel Act prohibits boaters from discharging sewage into state
waters, effective October  1, 1994.  In addition, all vessels 26 feet or more in length with
an enclosed cabin and berthing facilities are required to have a toilet on board.
Houseboats and floating structures  must, by October 1, 1996 have permanently
installed toilets attached to Type HI marine sanitation devices,  or directly connect their
toilets to shoreside plumbing.  Full implementation and enforcement of the Clean Vessel
Act would reduce sewage pollution of Sanctuary waters.  This would include a program
to educate the boating public about ways to reduce pollution from vessels. The
program would include providing information about the Clean Vessel Act and other
regulations affecting discharges from vessels.

In addition, it is recommended to change the environmental crimes category associated
with discharges from felony or misdemeanor to civil offense, thereby removing the need
to prove criminal intent.  Currently, it is difficult to prove criminal intent for actions
such as accidently discharging fuel or pumping out a shipboard sewage holding tank.
Therefore, in practice, law enforcement officers focus more attention on other crimes
that require a less rigorous burden of proof.  Making environmental crimes a civil rather
than criminal offense would lead to an increased level of enforcement of environmental
laws.  Civil penalties could take the form of major fines for such  accidents without
considering the intent of the individual  involved.  Implementation would require
changes in the Florida Statutes and Florida Administrative Code.
                              7.2.2 Mooring Fields

    • Recommendation: Evaluate the feasibility of establishing mooring fields in places
    having significant concentrations of live-aboard vessels.  If the study shows they are
   feasible, define criteria for mooring fields and establish mooring fields in
    appropriate areas [Modification of Phase II option B2; NOAA strategy Z.5]

Used in conjunction with shore-based or mobile pump-out facilities, mooring fields
could provide an effective  means of controlling waste discharges from live-aboard boats.
This recommendation would involve the following steps: (1) evaluate the feasibility of
establishing mooring fields in places having significant concentrations of live-aboard
vessels; (2) based on the results, define criteria for designating mooring fields; and
(3) depending on the outcome of the first two activities, establish designated mooring
fields or anchorage areas in places having significant concentrations of live-aboard
vessels.
                             7.2.3 Marina Pumpout

    • Recommendation: Develop a comprehensive plan for eliminating sewage
    discharges from live-aboard boaters. Require marinas with 10 or more slips to
    install pumpout facilities.  Enforce pumpout use [Phase II option B3b; NOAA
    strategy L1]

Under this recommendation, a comprehensive plan would be developed to deal with the
problem of sewage discharges from live-aboards and other boaters.  The plan could


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include elements such as requiring all marinas to install pumpout facilities, enforcing
pumpout use, establishing a mobile pumpout service, establishing mooring fields, and
evaluating the treatment and disposal of pumped out wastewater.

This recommendation would require all marinas (10 or more slips, as defined by the
State of Florida) to install pumpout facilities. This would eliminate marina live-aboard
vessels as a source of pollution in the Sanctuary.  Though live-aboards within marinas
may be a minor contributor to the total pollutant load, marinas are normally located in
confined waters that  may be more susceptible to the impacts of such loading. By
requiring marinas to  provide pumpout facilities, two problems may be resolved:
1) boats in marinas that don't currently pump out will be provided with the means to
do so; and 2) boats that moor outside of marinas can take advantage of the increased
number of pumpout facilities.

The recommendation also includes enforcement of pumpout use.  Although laws
already exist that allow the USCG to restrict discharges from marine sanitation devices,
a workable system of coordinated enforcement procedures has never been developed.
Current pumpout usage is low, in part because existing pumpout facilities are few and
some are inaccessible to the public. One possible enforcement tool would involve
issuing a large,  visible sticker to all boats anchored or passing through the Sanctuary.
Each time a vessel's holding tanks were pumped out, the sticker would be stamped with
the date and time. If the vessel had not had its holding tanks  pumped out within a
given length of time based on its size and carrying capacity,  a  citation would be issued.
                             7.2.4 Mobile Pumpout

    • Recommendation:  Establish a mobile pumpout service through the local
   government, or a franchise with a private contractor, which would serve to pump
   out live-aboard vessels moored outside of marina facilities.  Encourage the use of
   existing, and the construction of additional, shore-side facilities such as  dinghy
   docks, parking areas, showers, and laundries for use by live-aboards [Modification
   of Phase U option B3b; NOAA strategy L.6]

This recommendation would reduce sewage pollution from vessels by establishing a
mobile pumpout service.  No new legislation or legal authority is needed for the county
to develop a mobile pumpout service. A prototype study could be conducted to
determine how many live-aboard boaters in a given  area would voluntarily subscribe to
such a service.  If the idea appeared to be economically viable, the county could
advertise for suppliers of the service and sell franchises on a bid basis.
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                            7.2.5 Marina Operations

    • Recommendation:  Reduce pollution from marina operations by establishing
    containment areas for boat maintenance, encouraging marina owners to participate
    in environmentally-oriented organizations such as the International Marina
    Institute, and encouraging marina owners to provide a user manual with local
    environmental information such as locations of pumpout facilities and trash
    receptacles [Phase II option B4; NOAA strategy L.3]

Little effort is now directed toward containing and collecting wastes associated with
boat maintenance activities such as hull scraping and repainting, mechanical repairs,
fueling, and lubrication.  This recommendation would reduce pollution by establishing
containment areas to prevent paint chips or dust and other wastes from entering surface
waters. In addition, it would create secondary containment, generally in the form of
curbing or synthetic liners, for areas where significant quantities of hazardous or toxic
materials are stored.  Procedures to avoid or reduce fuel spillage during refueling
operations would be evaluated.

This recommendation also includes encouraging marina owners to participate  in
environmentally-oriented organizations such as the International Marina Institute.  They
would also be encouraged to provide a user manual with local environmental
information such as locations of pumpout facilities and trash receptacles.
                             7.2.6  Marina Permitting

    • Recommendation: Improve interagency cooperation in marina permitting
    [Phase II option B5; NOAA strategy L.2]

Marina operations are already subjected to numerous permits and permit review
processes. This activity would evaluate interagency cooperation to simplify the existing
permitting process, allow the implementation of Best Management Practices, and help
reduce pollution reaching adjacent coastal waters.  The possibility of consolidating
permitting requirements into a single, overall FDEP operating permit would be included
in this evaluation.
                    7.2.7 Environmental Awareness Program

    • Recommendation: Formalize and expand the existing Florida Marine Patrol
   District 9 environmental education program to heighten awareness of how human
   activities contribute to water quality problems [Phase II option B6; NOAA strategy
   E.4]

The Florida Marine Patrol, District 9 has an environmental awareness program that has
produced significant results in the past.  This recommendation would formalize and
expand the program and heighten environmental awareness of how human activities
adversely affect water quality in the Keys.


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                     7.3  PUBLIC COMMENT AND CHANGES

Sanctuary Advisory Council comments resulted in several changes to this section. The
Pollution Discharges recommendation  (formerly No-Discharge Zones) was rewritten to
emphasize implementing the 1994 Florida Clean Vessel Act and educating the boating
public about discharge regulations. A  separate recommendation for changing the
environmental crimes category was moved into Pollution Discharges from its previous
location in the Hazardous Materials chapter; this was done to match NOAA's strategy
organization. The Mooring Fields recommendation was changed to include first
evaluating the feasibility of mooring fields and then establishing criteria for designating
them. The Pumpout Facilities recommendation was split into Marina Pumpout and
Mobile Pumpout The Marina Operations recommendation (formerly Containment
Areas) was expanded to state that (1) marina owners should be encouraged to
participate in environmentally-oriented organizations such as the International Marina
Institute, and (2) they would be encouraged to provide a user manual with local
environmental information such as locations of pumpout facilities and trash receptacles.
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                               8.0  LANDFILLS

                   8.1  INTRODUCTION/PROBLEM DESCRIPTION

The Phase I report identified only one active landfill operation in the FKNMS, at Stock
Island (serving the City of Key West). This facility was scheduled to cease its operations
by November 1993.  Three other landfills, at Cudjoe Key, Long Key, and Key Largo,
were active in 1990  but have also ceased accepting waste. In December 1990, Monroe
County contracted Waste Management, Inc. to haul solid waste out of the County, and
the closed landfills serve as subdistrict transfer locations.  A seven-acre, synthetically
lined expansion of the Cudjoe Key landfill, completed in December 1990, is being kept
in reserve for emergency or future use.

In addition to these  four recently active landfills, FDEP files indicate that there are four
older landfills that have been closed for some time.  These are the old Key Largo,
Saddlebunch Key, Fleming Key, and Boot Key landfills. Four U.S. Navy landfills in the
Keys are being assessed and, if necessary, will be remediated under the Navy's
Installation Restoration Program. Also, according to knowledgeable state and local
government personnel, there are a number of smaller abandoned landfills and casual
dumping sites, many on private property, within the Florida Keys.

All landfill sites in theTlorida Keys (with the exception of the Cudjoe Key expansion)
were developed prior to current regulations requiring bottom liners and leachate
collection. At many sites, filling with solid waste probably occurred below the water
table in the early stages. Consistent with common practice at the time, there was
probably little or no control over materials deposited in these landfills. These
conditions indicate a significant potential for contamination of groundwater and surface
waters from these inactive landfills.

Although the potential exists for problems, monitoring data do not indicate that there is
leaching from landfills or water quality degradation in areas adjacent to landfills.
Therefore, no corrective actions  are proposed.  However, two investigative options were
proposed in the Phase II report to ensure that landfills are not causing water quality
problems. Based on the findings of these investigations, additional monitoring and/or
options for remedial actions could be designed on a case-by-case basis. At the
NOAA/TiPA water quality strategies workshop on October  14-16, 1992, both options
were incorporated into an existing NOAA strategy for solid waste disposal sites (NOAA
strategy L.7).  The two options are presented below as recommendations.
                            8.2  RECOMMENDATIONS

                8.2.1  Historical Landfill Search and Assessment

    • Recommendation:  Conduct a comprehensive search for abandoned landfills and
    dumps.  Evaluate each site to determine if they contain hazardous materials or are
    causing environmental problems.  If problems are discovered, evaluate and
    implement appropriate remedial actions such as boring or mining, upgrading
    closure, collecting and treating leachate, constructing slurry walls, or excavating
    and hauling landfill contents [Phase II option LI; activity 1 under NOAA strategy
   L.7]
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This recommendation would involve conducting a comprehensive search for abandoned
landfills and dumps. Each site would be evaluated to determine if it contains
hazardous materials or is causing environmental problems.  If problems were
discovered, appropriate remedial actions would be evaluated and implemented.

According to knowledgeable state and local government personnel, there are a number
of abandoned landfills and dumps, many on private property, within the Florida Keys.
A comprehensive program needs to be set up to locate, map, and evaluate these historic
casual dump sites to determine if they contain hazardous materials or are causing
environmental problems.

Monroe County already has  a fairly complete inventory of historic landfill sites within
the Florida Keys. The old sites where significant amounts of casual dumping have taken
place  are less well known. This option would be implemented by searching historical
data and conducting interviews with long-time residents to locate and map the potential
problem sites.  A one-time survey of all sites would then be made to see if they are
actually causing environmental problems. For those sites where problems are detected,
or those that have a high potential for causing problems hi the future, long-term
monitoring programs could be designed. If necessary, remedial actions could be taken.
                            8.2.2 Landfill Monitoring

    • Recommendation:  Intensify existing monitoring programs around landfills to
    ensure that no leaching is occurring into marine waters.  Identify and monitor old
    landfills that were never permitted and therefore have no closure plans or closure
    permits. If problems are discovered, evaluate and implement appropriate remedial
    actions such as boring or mining, upgrading closure, collecting and treating
    leachate, constructing slurry walls, or excavating and hauling landfill contents
    [Phase II option 12; activity 2 under NOAA strategy L.7]

This recommendation would involve intensifying the existing monitoring programs
around landfills to ensure that no leaching is occurring into marine surface waters or
groundwaters. Monitoring data from existing landfills in the Florida Keys do not
indicate that there is a leaching problem. However, the number of monitoring locations
is small, and the number of locations should be increased to ensure that no leaching is
occurring around these landfills. Old landfills that were never permitted and therefore
have no closure plans or closure permits would be identified and monitored, as
appropriate. If problems were discovered, appropriate remedial actions would be
evaluated and implemented.
                      8.3 PUBLIC COMMENT AND CHANGES

There were no substantial changes to this part of the Water Quality Protection Program
as a result of public or Sanctuary Advisory Council comments.  The name of the first
recommendation was changed to Historical Landfill Search and Assessment.
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                      9.0  HAZARDOUS MATERIALS

                   9.1 INTRODUCTION/PROBLEM DESCRIPTION

The Florida Keys are surrounded by environmentally sensitive marine resources.  The
handling, storing and managing of hazardous materials in this type of environment
poses a heightened level of risk.  As described in the Phase I report, small vessel spills,
small facility spills, tanker truck spills, and leaching from underground  storage tanks do
occur in the Florida Keys.  Because of the island structure of the Florida Keys, even
small spills can potentially have a significant impact on groundwater and surface water
contamination.  In addition, there is a risk of catastrophic oil spills from tankers passing
through the Straits of Florida.

The present management arrangement appears to be functioning adequately; however,
based on the Phase II report, some actions could be taken to further reduce the
potential for accidental spills. In the Phase II report, six management options were
presented to enhance spill response efficiency, improve data documentation, and
heighten enforcement effectiveness.  At the NOAA/EPA water quality strategies
workshop on October 14-16, 1992, four options were adopted within existing NOAA
strategies and two were dropped. Of the two dropped options, one would have
increased funding and personnel for the FDEP Marathon District Branch Office and the
Monroe County Public Health Unit to speed up inspection, enforcement, and retrofitting
of surface and underground fuel storage tanks. This option was  dropped on the
grounds that the existing inspection program is adequate. The other would have
increased funding and status of the Environmental Crimes Program within the Monroe
County Sheriffs Office and the Florida Marine Patrol. This option was dropped on the
grounds that requests for program funding are not water quality protection strategies.
Of the four accepted recommendations, one for changing the environmental crimes
category associated with small spills was moved to Marinas and Live-Aboards (see
Section 7.2.1).  The other three are presented below.
                            9.2 RECOMMENDATIONS

                     9.2.1 Hazardous Materials Response

    • Recommendation: Improve and expand oil and hazardous materials response
   programs throughout the Sanctuary [Phase II option HI; NOAA strategy W.I5]

This recommendation would reduce the chances  that a spill of oil or other hazardous
materials will have a significant negative impact  on Sanctuary resources. This would be
accomplished by improving coordination and cooperation between the federal, state,
and local agencies responding to spills; by encouraging improvements in response and
containment technologies appropriate to the Keys; and by creating a spill contingency
plan for the Sanctuary that includes crew and equipment staged in the Keys (possibly
including skimmers).

The main part of this recommendation would involve creating and periodically revising
a spill contingency plan for the Sanctuary that includes crew  and equipment staged hi
the Keys (possibly including skimmers).  The plan should cover spills of a size not

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responded to by the USCG and should include training and education of a local
response team.  A USCG marine safety field office would be established in the Keys at
the location where spill response equipment would be housed.  Because spills of
hazardous materials are handled independent of marine spills, improvement measures
will be developed for both response programs.

In addition to the spill contingency plan, coordination and cooperation between the
federal, state, and local agencies responding to spills should be improved.  Finally,
improvements in response and containment technologies appropriate to the Keys should
be encouraged.
                              9.2.2  Spill Reporting

    • Recommendation: Establish a reporting system to ensure that all spills in and
    near the Sanctuary are reported to Sanctuary managers. Establish a geo-referenced
    Sanctuary spills database [Phase II option H3; NOAA strategy W.16]

A reporting system should be established to ensure that all spills  documented by various
agencies  (e.g., USCG,  NOAA, FDNR) are reported to Sanctuary managers and managers
of impacted areas within the Sanctuary. Small spills, in particular, are under-reported;
they occur frequently and therefore may have a significant cumulative effect on water
quality in the Sanctuary.

In addition, a geo-referenced spills database for the Sanctuary should be established
and maintained. The database could be used to keep track of information  about spills
(e.g., locations, quantities, types of material spilled, environmental impacts).
                      9.2.3 Hazardous Materials Handling

    • Recommendation:  Conduct an assessment and inventory of hazardous materials
    handling and use in the Florida Keys including facilities, types and quantities of
    materials, and transport/movement.  Add information to the FDEP/EPA/Monroe
    County geographic information system (GIS) database [Phase II option H2;
    NOAA strategy L10]

This recommendation would involve conducting an assessment and inventory of
hazardous materials handling and use in the Florida Keys, including facilities, types and
quantities of materials,  and transport/movement.  Information would be added to the
FDEP/EPA/Monroe County Geographic Information System (GIS) database and tied into
the Florida Emergency  Response Program in the Keys.
                      9.3 PUBLIC COMMENT AND CHANGES

There were no substantial changes to this part of the Water Quality Protection Program
as a result of public or Sanctuary Advisory Council comments.
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                        10.0  MOSQUITO SPRAYING

                   10.1  INTRODUCTION/PROBLEM DESCRIPTION

As described in the Phase I report (EPA 1992), ground spraying by truck is the present
method of choice for controlling the adult mosquito population in Monroe County.
Aerial spraying is used only when the mosquito population reaches a specific threshold
as determined by mosquito landing counts per minute at given test sites within the
County. The Mosquito Control Program is administered by the Monroe County
Mosquito Control District.

There are no data indicating that the Mosquito Control Program is causing water quality
problems in the Sanctuary. However, there is little existing information on
environmental concentrations and/or effects of pesticides in the Sanctuary.  Additional
data concerning pesticide concentrations in sediments and biological tissue throughout
the area will be collected through the Water Quality Monitoring Program. Monitoring
should help to show whether mosquito spraying is affecting water quality or biological
resources  in the Sanctuary.

Based on the considerations discussed above, two options were proposed in the Phase II
report.  At the NOAA/EPA water  quality strategies workshop on  October  14-16, 1992,
both options were adopted as NOAA strategies.  The second option, which originally
included a temporary ban on aerial spraying, was modified as described below under
the second recommendation.
                            10.2  RECOMMENDATIONS

                            10.2.1  Mosquito Spraying

    • Recommendation: Refine the aerial spraying program to further reduce aerial
    spraying over marine areas. This includes a review of threshold levels used to
    initiate aerial spraying, development of a more refined plan for flight lines, and use
    of improved equipment. Reconsider the use of mosquito larvicides in breeding
    areas,  including those in currently restricted areas, to reduce the need for aerial
    spraying of adult mosquito populations. Evaluate the elimination of thermal fogs
    and replacement with ultra-low volume spraying methods [Phase II option'Ml a;
    NOAA  strategy W.I7]

Under this recommendation,  the Monroe County Mosquito Control Program would be
refined to minimize spraying over marine areas.  This could include reviewing (and
possibly raising) threshold levels used to initiate aerial spraying.  Also,  it is believed that
with a more refined plan for flight lines and use of improved equipment, the amount of
spray released over water could be  reduced.

In addition,  all agencies involved in mosquito control would reconsider using ground
spraying of mosquito  larvicides in breeding areas, even those on state and federal lands.
Use of larvicides  could help resolve a major problem  faced by the Mosquito Control
Program: the fact that large areas in and around the Florida Keys are nature preserves

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where mosquito control techniques cannot be applied, although populations of adult
mosquitos from those areas do appear in the inhabited portions of the Keys.  This is a
resource management question that requires balancing the environmental benefits of
reduced aerial spraying in the Sanctuary against modifying the natural environment in
preserve lands by removing mosquito larvae.

Finally,  responsible agencies should consider the elimination of thermal fogs, which
contain  diesel oil.  Ultra-low volume spraying techniques have been developed and are
now used in nearly all Florida counties.  These techniques would eliminate this source
of diesel oil being introduced into the environment.  Use of these techniques would
probably require some  additional training of pilots involved in aerial spraying.
                           10.2.2 Pesticide Research

    • Recommendation: Develop and implement an independent research program to
    assess and investigate the impacts of, and alternatives to, current pesticide
    practices.  Modify the Mosquito Control Program as necessary on the basis of
    research findings.  Conduct afield survey of pesticide and herbicide use in the Keys
    [modified from Phase II option Mlb; NOAA strategy W.18]

This recommendation would establish an independent research program to identify the
impacts that current spraying practices have on Sanctuary resources and identify
alternative means of mosquito control. Because pesticides used in mosquito-control are
nonspecific to the larval stages of crustaceans, fish, and natural mosquito control
predators, the effects of the chemicals used and all application methods employed need
to be examined. In addition, the effect of housing patterns, design, and landscaping as
they affect the demand for mosquito control needs to be investigated.  The results of
this research may be used to modify the mosquito control program.

The original Phase II option on which this recommendation is based included a
two-year ban on aerial spraying of mosquito adulticides (with exceptions in the event of
a health emergency).  This was modified to recommend research on pesticide impacts
and alternatives without specifying a temporary ban on aerial spraying.  The  rationale
was that, although a temporary ban or spatial restrictions on aerial spraying could be
useful hi evaluating pesticide impacts, experimental design should not be constrained at
this stage; scientists developing the research program should have the flexibility to
design appropriate experiments.
                      10.3 PUBLIC COMMENT AND CHANGES

Based on a comment from the Sanctuary Advisory Council, the Pesticide Research
recommendation was modified to include a field survey of the full suite of pesticides
and herbicides used in the Keys.
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                                11.0  CANALS

                  11.1  INTRODUCTION/PROBLEM DESCRIPTION

Many water quality problems in canals are clearly linked to wastewater discharges from
septic tanks of homes lining the canals. However, some problems may be partly caused
or exacerbated by canal structure and orientation. Reduced circulation and buildup of
weed wrack in dead-end canals and basins can lead to depressed dissolved oxygen
concentrations.  This recommendation would inventory and characterize canals and
investigate technologies to determine whether it would be worthwhile to implement
corrective actions such as weed gates and bubblers to improve water quality.  Any plan
for implementing such improvements would have to be developed in coordination with
plans for dealing with wastewater pollution from OSDS.


                            11.2  RECOMMENDATION

    • Recommendation:  Inventory and characterize dead-end canals/basins and
   investigate alternative management strategies to improve their water quality.
   Implement improvements  (consistent with the strategies developed for wastewater
   and stormwater) in known hot spots [NOAA strategy W.10]

This recommendation would involve a sequence of steps to improve canal water quality:

•  Evaluate and revise list of known hot spot canal systems.  (A workshop was
   conducted by the SFWMD in early 1996 to  update and prioritize the list of hot
   spots).

•  Inventory and characterize dead-end canals/basins and investigate alternative
   management strategies to improve their water quality.

•  Revise FDEP permit criteria to allow alternative  strategies  to improve water quality.

•  Identify and compile a list of technologies for canal restoration.

•  Develop a community education and involvement program, and conduct a canal
   system restoration pilot project.

•  Implement improvements (consistent with the strategies developed for wastewater
   and stormwater) in known hot spots throughout the Sanctuary.

The responsible agency for most of these activities will be FDEP. Other agencies with
primary roles will be the EPA, SFWMD, Monroe County, and the City of Key West.
                     11.3  PUBLIC COMMENT AND CHANGES

Based on Sanctuary Advisory Council comments, several new activities were added to
this recommendation, including a pilot project and a community education and
involvement program.
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        12.0  MONITORING AND RESEARCH/SPECIAL STUDIES

                       12.1  INTRODUCTION/DESCRIPTION

This section includes monitoring and research/special studies recommendations
designed to provide information for management decisions. These programs were
originally developed under Task 6 (monitoring program) and Task 7 (research/special
studies program) in the Phase II report (EPA 1993).  A separate Implementation Plan
for monitoring and research/special studies was subsequently produced (EPA 1995)
which revised these programs based on available funding and developed details of
implementation.

Goals of the water quality monitoring program (Section 12.2.1)  are (1) to provide long-
term, comprehensive information about the status and trends of water quality
parameters and biological resources in the Sanctuary; and (2) to evaluate the
effectiveness of remedial actions taken to reduce water pollution.

Goals of the research/special studies program (Sections 12.2.2 through 12.2.5) are
(1) to identify and document cause/effect linkages between specific pollutants, water
quality problems,  and ecological impacts; (2) to improve understanding of Sanctuary
ecosystems and develop predictive capabilities based on that understanding; and (3) to
develop innovative tools to detect pollutants, provide early warning of widespread
ecological problems, and identify cause/effect relationships.

Other recommendations in this  section are applicable to both research/special studies
and monitoring.  These are Regional Database (Section 12.2.6),  Dissemination of
Findings (Section  12.2.7), and Technical Advisory Committee  (Section 12.2.8).  Also
included is NOAA's recommendation for an Ecological Monitoring Program
(Section 12.2.9) which would be integrated with the Water Quality Monitoring
Program.
                            12.2 RECOMMENDATIONS

                    12.2.1  Water Quality Monitoring Program

    • Recommendation:  Conduct a long-term, comprehensive water quality monitoring
   program as described in the EPA Water Quality Protection Program, Phase II report
   and the implementation Plan [Phase II monitoring recommendation; NOAA
   strategy W.20]

Implementation of a long-term, comprehensive water quality monitoring program is
required under the Florida Keys National Marine Sanctuary and Protection Act and is
critical to maintaining and improving water quality in the Sanctuary.  The water quality
monitoring program will provide information about the status and trends of water
quality parameters and biological resources in the Sanctuary.  It will allow managers to
identify or confirm problem areas and determine whether conditions are improving or
degrading.  In addition, remedial actions taken to reduce pollution will be monitored to
evaluate their effectiveness. In addition to water quality sampling, biological

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monitoring of seagrass and coral reef/hard-bottom communities will be conducted.
Seagrass communities and hard-bottom communities (including offshore coral reefs and
nearshore hard-bottom areas) will be monitored by in situ sampling and remote
sensing.

Design of the Water Quality Monitoring Program is described in the EPA Water Quality
Protection Program Phase II Report, Task 6. An Implementation Plan was subsequently
developed (EPA 1995) which (1) revised the Program based on available funding and
(2) developed specific details of program design (e.g., locations of water quality, coral
reef, and seagrass sampling locations).
                    12.2.2  Special Studies: Predictive Models

    • Recommendation: Develop phased hydrodynamic/water quality models and
    coupled landscape-level ecological models to predict and evaluate the outcome of
    in-place and proposed water quality management strategies [Phase II research
    recommendation; NOAA strategy W.21]

Predictive models, used with appropriate scientific guidance, would allow resource
managers to predict and evaluate the outcome of various management strategies (e,g,,
engineering actions to reduce wastewater nutrient loadings). Initial conceptual models
would be developed, information needs would be identified, environmental data would
be gathered, and quantitative models would be developed  and refined  over the long
term and on a continuous basis to aid in management decisions.
                  12.2.3  Special Studies: Wastewater Pollutants

    • Recommendation: Conduct special studies to document the fate and ecological
    impacts of wastewater pollutants [Phase II research recommendation; NOAA
    strategy W.22].

This recommendation involves conducting special studies to: (1) establish pollutant
loading thresholds above which biotic communities are adversely affected; (2) detect
the presence of wastewater pollutants from OSDS, cesspits,  package plant boreholes,
and/or surface water dischargers and to determine the relative contributions of each to
Sanctuary surface waters, groundwaters, and/or sediments;  (3) document the transport
of pollutants and describe the severity and extent of ecological impacts that can be
specifically linked to these pollutants. The scope includes all sources of wastewater
pollutants throughout the Sanctuary. Potential approaches include experimental studies
(laboratory, mesocosm, in situ or combinations); eutrophication gradient studies;
studies of pollutant transport via groundwater; comparative studies of impacted and
non-impacted sites; historical  studies (sclerochronology, geological  reconstruction);
geographic comparisons (Keys vs. other areas); use of biochemical and ecological
indicators such as tissue C:N:P ratios, alkaline phosphate activity, and shifts in
community structure;  use of sewage tracers; and high-frequency and/or spatially
intensive water quality sampling.
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      12.2.4 Special Studies: Other Pollutants and Water Quality Problems

    • Recommendation: Conduct special studies to document the fate and ecological
    impacts of non-wastewater pollutants, develop innovative monitoring tools, and
    examine the effects of global climate change on the organisms and ecosystems of the
    Keys [NOAA Strategy W.23]

The first part of this recommendation would involve documenting the locations and
magnitudes of pollution inputs (other than wastewater) to the Sanctuary to better
understand what areas are at risk.  Sources will include those that are point, nonpoint,
and external to the Sanctuary (e.g., permitted discharges, OSDSs, stormwater runoff,
groundwater  leachates, marinas, C-lll, Biscayne Bay, Florida Bay, southwest Florida
and oceanic fluxes and gyre-induced upwelling). Pollutants will include hydrocarbons,
heavy metals, and pesticides.  Load estimates will be based on the best available
information, and will include engineering estimates where applicable.

A second part of this recommendation would involve conducting research/special
studies to identify and document causal linkages between non-wastewater pollutants
and specific ecological problems. This could include experimental studies (laboratory,
mesocosm, in situ), historical studies (sclerochronology, geological reconstruction), and
geographic comparisons.

A third part of this recommendation would identify and evaluate innovative monitoring
tools and methodologies to detect pollutants and identify cause/effect relationships
involving water quality and biological resources. New or modified monitoring tools and
methodologies may be needed because of the unique biota and environmental
conditions of the Sanctuary. An example would be the development  or refinement of
continuous, in situ sampling techniques and equipment which could be incorporated
into the monitoring program. Another possible focus of study would  be the
identification and evaluation of pollutant tracers which could be incorporated into the
monitoring program.

The fourth part of this recommendation would involve research/special studies to
examine the effects of stresses  associated with global change on the ecosystem.  Effects
of global change must be considered in the evaluation of water quality impacts from
anthropogenic activities.  Examples of stresses include temperature, salinity, frequency
and intensity  of storms, turbidity, sea level change, ultraviolet and visible radiation, etc
                  12.2.5 Special Studies: Florida Bay Influence

    • Recommendation: Conduct research/special studies to understand the effect of
    water transport from Florida Bay on water quality and resources in the Sanctuary
    [Phase II research recommendation; NOAA strategy W.24]

             [This recommendation is repeated verbatim from Section 4.2.2]

Water transport from Florida Bay through the passes is recognized as a significant
influence on water quality in the Sanctuary.  Major concerns are changes hi salinity,


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temperature, turbidity, and nutrients associated with water moving through the passes
in the lower and middle Keys and onto the reef tract.  The recommended
research/special studies would help scientists and managers to understand the effects of
recent water quality and ecological problems in Florida Bay on water quality and
resources in the Sanctuary. This understanding will provide context for decisions about
wastewater and other water quality problems in the Sanctuary.

As a result of an Interagency Agreement on South Florida Ecosystem Restoration, an
Interagency Working Group has developed an Interagency Florida Bay Science Plan that
focuses on research, monitoring, and modeling objectives that must be addressed to
guide the restoration of Florida  Bay. The plan includes research on water budgets,
circulation dynamics and salinity, water quality and nutrient cycling, seagrass and
mangrove communities,  and other living resources.  Among the pertinent work is the
development of a circulation model for Florida Bay. The research/special studies
program for the Water Quality Protection Program will complement ongoing and
planned studies in Florida  Bay and will focus on linkages between Florida Bay and the
Sanctuary.

One aspect of the proposed research/special studies would involve an historical
assessment of Everglades/Florida Bay/Florida Keys hydrology, as it has affected water
quality and biological communities in the Sanctuary. It would clarify the role of
freshwater inflows and water quality from the Everglades,  and other freshwater
discharges to the southwest shoreline of Florida, to Florida Bay and the Sanctuary.  The
activity would examine the effects of structural modifications and  changes in timing and
volume of freshwater releases from existing structures, as well as land practices
affecting the water quality of runoff.

A second aspect of this recommendation would involve circulation studies to estimate
long-term net transport and episodic transport from Florida Bay to the Sanctuary,
movement of Florida Bay water within the Sanctuary, and exchange mechanisms  at the
shelf edge for water moving out to the reef tract.  Circulation studies could involve a
combination of field studies and modeling. Studies of groundwater flow may be
included.

A third aspect of this recommendation would involve studies to evaluate whether or not
changes in the quality of Florida Bay water flowing into the Sanctuary are influencing
Sanctuary communities,  including seagrasses, coral reefs, nearshore hard bottom
communities, and other  biota.  Ecological studies could be coupled with  circulation
studies or could involve  separate experimental studies (laboratory, mesocosm,  in situ),
historical studies (sclerochronology, geological reconstruction), and/or geographic
comparisons.
                            12.2.6  Regional Database

    • Recommendation: Establish and maintain a regional database and data
    management system for recording research/special studies results and biological,
    physical and chemical parameters from monitoring [Phase E research
    recommendation; NOAA strategy W.28]
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A regional scientific database and data management system should be developed,
implemented, and maintained. To develop the database and data management system,
a user-needs assessment should be conducted, and an implementation plan should be
developed that addresses all aspects  of data management for research/special studies
and monitoring efforts, including information distribution, storage, archiving, and
quality assurance/quality control of data input. The regional database will include
biological, physical, and chemical parameters and instrument records, etc.
                        12.2.7 Dissemination of Findings

    • Recommendation: Develop a program to synthesize and disseminate scientific
    research/special studies and monitoring results, including an information exchange
    network, conferences, and support for the publication of findings in peer-reviewed
    scientific journals [Phase II research recommendation; NOAA strategy W.29]

A program should be developed to disseminate findings from research/special studies
and monitoring efforts among scientists and resource managers and to the general
public.  The program should include:

•   An information exchange network that would include a compendium of ongoing
    and planned research/special studies (whether funded through the Sanctuary or
    not) that would be updated periodically.

•   Conferences  to keep researchers and managers abreast of scientific findings and
    management actions in the Sanctuary.

•   Support for the publication of research/special studies and monitoring findings in
    peer-reviewed scientific journals.

•   Use of existing mechanisms and continued development of new mechanisms to
    synthesize and disseminate findings of the monitoring and research/special studies
    programs to  the public.
                      12.2.8 Technical Advisory Committee

    • Recommendation: Establish a technical advisory committee for coordinating and
    guiding research/special studies and monitoring activities by both EPA and NOAA
    [Phase II research recommendation; NOAA strategy W.32]

This recommendation will create a technical advisory committee as required by the
National Marine Sanctuaries Program Amendments Act of 1992 (see Appendix A). The
Technical Advisory Committee "shall be composed of scientists from federal agencies,
state agencies, academic institutions,  private non-profit organizations,  and
knowledgeable citizens."  It will guide the process of- setting priorities  for
research/special  studies and monitoring.
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                     12.2.9  Ecological Monitoring Program

    • Recommendation:  Develop and implement a Sanctuary-wide, intensive ecosystem
    monitoring program.  The objective of the program will be to monitor the status of
    various biological and ecological indicators of system components throughout the
    Sanctuary and adjacent areas, in order to discern the local and system-wide effects
    of human and natural disturbances, and assess the overall health of the Sanctuary
    [NOAA strategy W.33]

This is NOAA's recommendation which would establish a comprehensive, long-term
monitoring program throughout the Sanctuary and adjacent areas  that will have three
purposes: to supply resource managers with information on the status of the health of
living resources and the ecosystem; to determine causal relationships related to
management decisions;  and to evaluate the effectiveness of management actions such as
zoning implementation.

The Ecological Monitoring Program will be fully integrated with the Water Quality
Monitoring Program, and will include a temporal and spatial ecological information
system based  on current knowledge; a Technical Advisory Committee to assist NOAA
with the design and prioritization of the Research and Monitoring  Program; status and
trends assessments of corals, fishes, seagrasses, benthic organisms and algae, plankton,
and mangroves; a fisheries ecology monitoring and research component to examine
community composition and function within the Sanctuary's habitats; a sampling
protocol; a data analysis, management, and dissemination protocol; a quality
assurance/quality control protocol; the development of an index of Sanctuary health;
and a volunteer monitoring program.
                     12.3  PUBLIC COMMENT AND CHANGES

There were no substantial changes to this part of the program as a result of public or
Sanctuary Advisory Council comments.  However, changes were needed to update the
information and to make it simpler and more consistent with the actual programs which
are now underway.  Two new special studies recommendations were created. The first
is Wastewater Pollutants, which includes parts of previous recommendations for
Pollutant Assessment, Groundwater Leachate Transport, and Water Quality Impact
Research.  The second is Other Pollutants and Water Quality Problems, which includes
parts of recommendations for Pollutant Assessment, Water Quality Impact Research,
Other Monitoring Tools, and Global Change. The former recommendation for
Indicators was moved under Water Quality Standards in the Domestic Wastewater
chapter.  Minor updates and wording changes  were made throughout.
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                             13.0  REFERENCES
Antonini, G.A., L. Zobler, H. Tupper, and R. Ryder.  1990.  Boat Live-Aboards in the
   Florida Keys: A New Factor in Waterfront Development.  Fla. Sea Grant Rep. No. 98.

Boesch, D.F., N.E. Armstrong, C.F. D'Elia, N.G. Maynard, H.W. Paerl, and S.L. Williams.
   1993.  Deterioration of the Florida Bay Ecosystem: An Evaluation of the Scientific
   Evidence.  Report to the Interagency Working Group on Florida Bay.

CH2M Hill, Lindahl, Browning Ferrari & Hellstrom, Inc., and Continental Shelf
   Associates, Inc.  1996. Draft Wastewater Facilities Plan for the Marathon Area of the
   Florida Keys.  Prepared for Monroe County, Florida.

EPA.  1990.  Biological Criteria: National Program Guidance for Surface Waters.
   U.S. Environmental Protection Agency, Criteria and Standards Division, Office of
   Water Regulations and Standards, Washington, DC. EPA-440/5-90-004.  57 pp.

EPA.  1992.  Water Quality Protection Program for the Florida Keys National Marine
   Sanctuary: Phase I Report.  Final report submitted to the Environmental Protection
   Agency under Work Assignment 3-225, Contract No. 68-C8-0105.  Battelle Ocean
   Sciences, Duxbury, MA, and Continental Shelf Associates, Inc., Jupiter, FL.

EPA.  1993.  Water Quality Protection Program for the Florida Keys National Marine
   Sanctuary: Phase II Report. Final report submitted to the Environmental Protection
   Agency under Work Assignment 4-225, Contract No. 68-C8-0105.  Battelle Ocean
   Sciences, Duxbury, MA, and Continental Shelf Associates, Inc., Jupiter, FL.

EPA.  1995.  Water Quality Protection Program for the Florida Keys National Marine
   Sanctuary: Phase III Report. Implementation Plan for Water Quality Monitoring and
   Research Programs. Final report submitted to the Environmental Protection Agency
   under Contract No. 68-C2-0134, Work Assignment 1, Amendment 1. Battelle Ocean
   Sciences, Duxbury, MA, and Continental Shelf Associates, Inc., Jupiter, FL.

EPA.  1996.  Options for  a Strategy to Develop Nutrient Reduction Targets for the Florida
   Keys National Marine Sanctuary.  Final report submitted to the Environmental
   Protection Agency under Contract No. 68-C2-0134, Work Assignment 3-1. Battene
   Ocean Sciences,  Duxbury, MA, and Continental Shelf Associates, Inc. Jupiter, FL.

Faanes, C.A.  1992,  Refuge Issues in the Florida Keys:  The Need to Change Attitudes at
   Low Latitudes. Prepared for the U.S. Fish  and Wildlife Service.

Forcucci, D. and J.C. Ogden.   1993.  Automated environmental monitoring. Pp. 8-12
   in: J. C. Ogden, J. W. Porter, N. P. Smith, A.  M. Szmant, W. C. Jaap, and
   D. Forcucci, SEAKEYS Phase II. Sustained Ecological Research Related to Management
   of the Florida Keys Seascape. Year 2 report to the John D. and Catherine T.
   MacArthur Foundation, World Environment and Resources Program. Florida
   Institute of Oceanography, St. Petersburg, FL.
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Lapointe, B. E.  1995. Florida Keys Water Quality Plan: Background Scientific
   Information.  Prepared for South Florida Water Management District, West Palm
   Beach, FL. 14 pp.

Lapointe, B.E., N.P. Smith, P.A. Pitts, and M.W. Clark.  1992. Baseline Characterization
   of Chemical and Hydrographic Processes in the Water Column ofLooe Key National
   Marine Sanctuary. Final report to the National Oceanic and Atmospheric
   Administration, Office of Ocean and Coastal Resource Management, Washington,
   DC. 59 pp.

Mclvor, C.C., J.A. Ley, and R.D. Bjork. 1994.  Changes in freshwater inflow from the
   Everglades to Florida Bay including effects on biota and biotic processes: a review.
   Pp. 117-146  in: J. Ogden and S. Davis (Eds.), Everglades: The Ecosystem  and Its
   Restoration.  St. Lucie Press, Delray Beach, FL.

NOAA.  1995. Draft Management Plan/Environmental Impact Statement.  National
   Oceanic and Atmospheric Administration, Silver Spring, MD. 3 volumes.

National Research Council. 1990.  Managing Troubled Waters: The Role of Marine
   Environmental Monitoring. National Academy Press, Washington, DC. 125 pp.

Ogden, J.C., J.W. Porter, N.P. Smith, A.M. Szmant, W.C. Jaap, and D. Forcucci.  1994.
   "A long-term interdisciplinary study of the Florida Keys seascape."  Bull. Mar.
   Sci. 54(3):1059-1071.

Pitts, P.A. 1994.  "An investigation of near-bottom flow patterns along and  across
   Hawk Channel, Florida Keys." Bull. Mar. Sci.  54(3):610-620.

Shinn, E.A., B.H. Lidz, J.L. Kindinger, J.H. Hudson, and R.B. Halley. 1989.  A Field
   Guide: Reefs of Florida and the Dry Tortugas. U.S. Geological Survey, St.  Petersburg,
   FL

Smith, N. 1993.  Physical oceanography. Pp. 12-13 in: J.C. Ogden, J.W. Porter,
   N.P. Smith, A.M.  Szmant, W.C. Jaap, and D. Forcucci, SEAKEYS Phase II. Sustained
   Ecological Research Related to Management of the Florida Keys Seascape. Year 2
   report to the John D. and Catherine T. Macarthur Foundation, World Environment
   and Resources Program.  Florida Institute of Oceanography,  St. Petersburg, FL.

Smith, N.P.  1994. "Long-term Gulf-to-Atlantic transport through tidal channels in the
   Florida  Keys." Bull. Mar. Sci. 54(3):602-609.
                                       53

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APPENDIX A



LEGISLATION

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            PUBLIC LAW 101-605—NOV. 16, 1990
104 STAT. 3089
Public Law 101-605
101st Congress
                           An Act
To iT»*Hiffh the Florida Key* National Marine Sanctuary, and for other purposes.

    ?

  Be it enacted by the Senate and House of Representatives of the
United States of America in Congress assembled,

                         SHORT TITLE
    Nov. 16.1990
     [HJL5909]

   Florida Keys
   National Marine
   Sanctuary and
   Protection Act.
   Conservation.
  SECTION 1. This Act may be cited as the "Florida Keys National  16 USC1433
Marine Sanctuary and Protection Act".                            note
                           FINDINGS

  SEC. 2. The Congress finds and declares the following:
     (1) The Florida Keys extend approximately 220 miles south-
    west from the southern tip of the Florida peninsula.
     (2) Adjacent to the Florida  Keys  land mass are located
    spectacular, unique, and nationally significant marine environ-
    ments, including  seagrass meadows,  mangrove islands, and
    extensive living coral reeis.
     (3)  These  marine  environments  support  rich  biological
    communities possessing extensive  conservation, recreational,
    commercial, ecological, historical,  research, educational, and
    esthetic values which give this area special national signifi-
    cance.
     (4) These environments are the marine equivalent of tropical
    rain forests in that they support high levels of biological diver-
    sity, are fragile and easily susceptible to damage from human
    activities, and possess  high value to human beings if properly
    conserved.
     (5) These marine environments are subject to damage and loss
    of their ecological integrity from a variety of sources of disturb-
    ance.
     (6) Vessel groundings along the  reefs of the Florida  Keys
    represent one of many serious threats to the continued vitality
   of the marine environments of the Florida Keys which must be
   addressed in order to protect their values.
     (7) Action is  necessary to provide comprehensive protection
   for these marine environments by establishing a Florida  Keys
   National Marine Sanctuary, by restricting vessel traffic within
   such Sanctuary, and by requiring promulgation of a manage-
   ment plan and regulations to protect Sanctuary resources.
     (8) The agencies of the United States must cooperate fully to
   achieve the necessary protection of Sanctuary resources.
     (9) The Federal Government and the State of Florida should
   jointly develop  and implement a comprehensive program to
   reduce pollution in the waters offshore  the Florida Keys to
   protect and restore the water quality, coral reefs,  and other
   living marine resources of the Florida Keys environment.
  16 USC 1433
  note.
     49-138 O-MtfUl
                               A-l

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104 STAT. 3090
           PUBLIC LAW 101-605—NOV. 16,1990
16 USC 1433
note.
 16 USC 1433
 note.
16 USC 1433
note.
Records.
Public
information.
                     POLICY AND PURPOSE

  SEC. 3. (a) POLICY.—It is the policy of the United States to protect
and preserve living and other resources of the Florida Keys marine
environment.
  (b) PURPOSE.—The purpose of this Act is to protect the resources of
the area described in section 5(b), to educate and interpret for the
public regarding  the  Florida Keys marine  environment, and to
manage such human uses of the Sanctuary consistent with this Act.
Nothing in this Act is intended to restrict activities that do not
cause an adverse effect to the resources or property of the Sanctuary
or that do not pose harm to users of the Sanctuary.

                          DEFINITION

  SEC. 4. As used  in this Act, the term "adverse effect" means any
factor, force,  or action that  would  independently or  cumulatively
damage, diminish, degrade, impair, destroy, or otherwise harm—
      (1) any Sanctuary  resource, as defined in section 302(8) of the
    Marine Protection, Research, and Sanctuaries Act of 1972 (16
    U.S.C. 1432(8)); or
      (2) any of those qualities, values, or purposes for which the
    Sanctuary is designated.

                    SANCTUARY DESIGNATION

  SEC. 5. (a) DESIGNATION.—The area described in subsection (b) is
designated  as the  Florida Keys National Marine Sanctuary (in this
Act referred to as the "Sanctuary") under title III of the Marine
Protection, Research, and Sanctuaries Act of 1972 (16 U.S.C. 1431 et
seq.). The Sanctuary  shall be managed and regulations enforced
under all applicable provisions of such title HI as if the Sanctuary
had been designated under such title.
  (b) AREA  INCLUDED.—(1) Subject to subsections (c) and (d), the area
referred to in subsection (a) consists of all  submerged lands and
waters, including  living  marine and other resources within and on
those lands and waters, from the  mean  high  water mark to the
boundary described under paragraph (2), with the exception of areas
within the  Fort Jefferson National Monument. The Sanctuary shall
be generally  identified and depicted on National Oceanic and At-
mospheric  Administration charts FKNMS 1  and 2, which shall be
maintained on file and kept available for public examination during
regular business hours at the Office of Ocean and Coastal Resource
Management of the  National Oceanic and Atmospheric Administra-
tion and which shall be updated to reflect boundary modifications
under this section.
  (2) The boundary referred to in paragraph (1H-
      (A) begins at the northeasternmost point of Biscayne National
    Park located at approximately 25 degrees 39 minutes  north
    latitude, 80 degrees 5 minutes west longitude,  then runs east-
    ward to the 300-foot isobath located at aproximately 25 degrees
    39 minutes north latitude, 80 degrees 4 minutes west longitude;
      (B) then runs  southward and connects in succession the points
    at the following coordinates:
          (i) 25 degrees 34 minutes north  latitude, 80 degrees 4
        minutes west longitude,
          (ii) 25  degrees 28 minutes  north  latitude,  80 degrees 5
        minutes west longitude, and
                                      A-2

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            PUBLIC LAW 101-605—NOV. 16, 1990          104 STAT. 3091

          (iii) 25 degrees 21 minutes north latitude, 80 degrees 7
        minutes west longitude;
      (C) then runs  southward to the northeastern corner of the
    existing Key Largo National Marine Sanctuary located at 25
    degrees 16 minutes north  latitude, 80 degrees 8 minutes west
    longitude;
      (D)  then  runs southwesterly  approximating  the  300-foot
    isobath and  connects in succession the points at the following
    coordinates:
          (i)  25  degrees 7  minutes north latitude, 80 degrees 13
        minutes west longitude,
          (ii) 24 degrees 57  minutes north latitude, 80 degrees 21
        minutes west longitude,
          (iii) 24 degrees 39 minutes north latitude, 80 degrees 52
        minutes west longitude,
          (iv) 24 degrees 30 minutes north latitude, 81 degrees 23
        minutes west longitude,
          (v) 24  degrees 25 minutes north latitude, 81 degrees 50
        minutes west longitude,
          (vi) 24 degrees 22 minutes north latitude, 82 degrees 48
        minutes west longitude,
          (vii) 24 degrees 37 minutes north latitude, 83 degrees 6
        minutes west longitude,
          (viii) 24 degrees 40 minutes  north latitude, 83 degrees 6
        minutes west longitude,
          (ix) 24 degrees 46 minutes north latitude, 82 degrees 54
        minutes west longitude,
          (x) 24  degrees 44 minutes north latitude, 81 degrees 55
        minutes west longitude,
          (xi) 24 degrees 51 minutes north latitude, 81 degrees 26
        minutes west longitude, and
          (xii) 24 degrees 55 minutes north latitude, 80 degrees 56
        minutes west longitude;
      (E) then follows the boundary of Everglades National Park in
    a southerly  then northeasterly direction through Florida Bay,
    Buttonwood  Sound, Tarpon Basin, and Blackwater Sound;
      (F) after Division Point,  then departs from the  boundary of
    Everglades National Park and follows the western shoreline of
    Manatee Bay, Barnes Sound, and Card Sound;
      (G) then follows the southern boundary of Biscayne National
    Park and the northern boundary of Key Largo National Marine
    Sanctuary to the southeasternmost point of Biscayne National
    Park; and
      (H)  then follows the eastern boundary  of the Biscayne Na-
    tional Park  to the beginning point specified in subparagraph
    (A).
  (c) AREAS  WITHIN STATE OF FLORIDA.—The  designation under
subsection (a) shall not take effect for  any area located within the
waters of the State of Florida if, not later than 45 days after the date
of enactment of this Act, the Governor of the State of Florida objects
in writing to the  Secretary of Commerce.
  (d) BOUNDARY  MODIFICATIONS.—No later than the issuance of the
draft  environmental impact statement  for the Sanctuary under
section  304(aKlXCMvii) of the  Marine Protection,  Research, and
Sanctuaries Act  of 1972 (16 U.S.C. 1434(aXlXCXvii)), in  consultation
with the Governor of the State of Florida, if appropriate, the Sec-
retary of Commerce  may make minor modifications to the bound-
                                    A-3

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104 STAT. 3092
           PUBLIC LAW 101-605—NOV. 16,1990
16 USC 1433
note.
Regulations.
Effective date.
Intergovernmental
relations.
Regulations.
16 USC 1433
note.
aries of the Sanctuary as necessary to properly protect Sanctuary
resources. The Secretary of Commerce shall s -^mit to the Commit-
tee on Commerce, Science, and Transportation A the Senate and the
Committee on  Merchant  Marine and Fisheries of the House of
Representatives a written notification of such modifications. Any
boundary modification made under this subsection shall be reflected
on the charts referred to in subsection (bXD.

                  PROHIBITION OF CERTAIN USES

  SEC. 6. (a) VESSEL TRAFFIC.—(1) Consistent with generally recog-
nized principles of international law, a person may not operate a
tank vessel (as that term is defined in section 2101 of title 46, United
States Code) or a vessel greater than 50 meters in length in the Area
To Be Avoided described in the Federal Register notice of May 9,
1990 (55 Fed. Reg. 19418-19419).
  (2) The prohibition in paragraph (1) shall not apply to necessary
operations of public vessels. For the purposes of this  paragraph,
necessary operations of public vessels shall include operations essen-
tial for national defense, law enforcement, and responses to emer-
gencies that threaten life, property, or the environment.
  (3) The provisions of paragraphs (1) and (2), including the area in
which vessel operations are prohibited under paragraph (1), may be
modified by regulations issued jointly by the Secretary of the depart-
ment in  which the Coast  Guard is operating and  the Secretary of
Commerce.
  (4)  This subsection shall  be  effective on  the earliest of the
following:
      (A) the date that is six months after the date of enactment of
    this Act,
      (B) the date of publication of a notice to mariners consistent
    with this section, or
      (C) the date of  publication of new nautical charts consistent
    with this section.
  0?) MINERAL AND HYDROCARBON LEASING, EXPLORATION, DEVELOP-
MENT, AND PRODUCTION.—No leasing, exploration, development, or
production of minerals  or hydrocarbons shall be permitted within
the Sanctuary.
               COMPREHENSIVE MANAGEMENT PLAN

  SEC. 7. (a) PREPARATION  OF PLAN.—The Secretary of Commerce, in
consultation with appropriate Federal, State, and local government
authorities and with the Advisory Council established under section
208, shall develop a comprehensive  management plan and  im-
plementing regulations to achieve the policy and purpose of this Act
The Secretary of Commerce  shall complete  such comprehensive
management plan and final regulations for the Sanctuary not later
than 30 months after the  date of enactment of this Act. In develop-
ing the  plan and regulations, the  Secretary of  Commerce shall
follow the procedures specified in sections 303 and 304 of the Marine
Protection, Research, and Sanctuaries Act of 1972 (16 U.S.C. 1433
and. 1434), except those  procedures  requiring the delineation of
Sanctuary boundaries and development of a resource assessment
report. Such comprehensive management plan shall—
      (1) facilitate all  public and  private uses of the Sanctuary
    consistent with the primary objective of Sanctuary resource
    protection;
                                       A-4

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           PUBLIC LAW 101-605—NOV. 16, 1990          104 STAT. 3093

      (2) consider temporal  and geographical zoning,  to  ensure
    protection of Sanctuary resources;
      (3) incorporate regulations necessary to enforce the elements
    of the comprehensive water quality protection program devel-
    oped under section 8 unless the Secretary of Commerce deter-
    mines that such program does not meet the purpose for which
   • the  Sanctuary is  designated or is otherwise inconsistent or
    incompatible with the comprehensive  management plan devel-
    oped under this section;
      (4) identify needs for research and  establish  a long-term
    ecological monitoring program;
      (5) identify alternative  sources  of funding needed to fully
    implement the plan's provisions and supplement appropriations
    under section 9 of this Act and  section 313 of the Marine
    Protection,  Research, and Sanctuaries Act of 1972 (16  U.S.C.
    1444).
      (6) ensure coordination  and cooperation between Sanctuary
    managers and other Federal, State, and local authorities with
    jurisdiction within or adjacent to the Sanctuary;
      (7) promote education, among users of the Sanctuary, about
    coral reef conservation and navigational safety; and
      (8) incorporate the existing Looe Key and Key Largo National
    Marine Sanctuaries into  the Florida Keys National Marine
    Sanctuary except  the Looe Key  and Key Largo Sanctuaries
    shall continue to be operated until  completion  of the com-
    prehensive  management plan for the  Florida Keys Sanctuary.
  (b) PUBLIC PARTICIPATION.—The Secretary of Commerce shall pro-
vide for participation by the general public  in development of the
comprehensive management plan.
  (c) TERMINATION OF  STUDIES.—On the date of enactment of this
Act, all  congressionally mandated studies of existing  areas  in the
Florida Keys for designation as National Marine Sanctuaries shall
be terminated.  '
                 FLORIDA KEYS WATER QUALITY

  SEC. 8. (a) WATER QUALITY PROTECTION  PROGRAM.—(1) Not later  16 USC1433
than 18 months after the date of enactment of this Act,  the Adminis-  note-
trator of the Environmental Protection Agency and the Governor of
the State  of Florida, in consultation with the Secretary of Com-
merce, shall develop a comprehensive water quality protection pro-
gram for the  Sanctuary. If the Secretary of Commerce determines
that such comprehensive water quality protection program does not
meet the  purpose for which the Sanctuary  is  designated  or  is
otherwise  inconsistent or incompatible  with the  comprehensive
management  plan prepared under section  7, such water quality
program shall not be included in the comprehensive  management
plan. The purposes of such water quality program shall be to—
      (A)  recommend priority corrective actions and compliance
    schedules addressing point and nonpoint sources of pollution to
    restore and maintain the chemical,  physical, and  biological
    integrity  of the Sanctuary, including restoration  and mainte-
    nance of a  balanced, indigenous  population of corals, shellfish,
    fish and wildlife, and recreational activities in and  on the water;
    and
      (B) assign responsibilities for the implementation of the pro-
    gram among the Governor, the Secretary of Commerce, and the
                              A-5

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 104 STAT. 3094         PUBLIC LAW 101-605—NOV. 16,1990

                  Administrator in accordance with applicable Federal and State
                  laws.
                (2) The program required by paragraph (1) shall, under applicable
               Federal and State laws, provide for measures to achieve the pur-
               poses described under paragraph (1), including—
                    (A) adoption or revision, under applicable Federal and State
                  laws, by the  State and the Administrator of applicable water
                  quality standards for the Sanctuary,  based on water quality
                  criteria which may utilize biological monitoring or assessment
                  methods,  to  assure protection and restoration of the water
                  quality, coral reefs, and other living marine resources of the
                  Sanctuary;
                    (B) adoption  under applicable  Federal and  State laws of
                  enforceable pollution control measures (including water qual-
                  ity/based  effluent limitations and best management practices)
                  and  methods to eliminate or reduce pollution from point and
                  nonpoint sources;
                    (C) establishment of a comprehensive water quality monitor-
                  ing program to (i) determine the sources of pollution causing or
                  contributing to existing or anticipated pollution problems in the
                  Sanctuary, (ii) evaluate the effectiveness of efforts to reduce or
                  eliminate  those sources of pollution, and (iii) evaluate progress
                  toward achieving and maintaining water quality standards and
                  toward protecting and restoring the coral reefs and other living
                  marine resources of the Sanctuary;
                    (D) provision of adequate opportunity for public participation
                  in all aspects of developing ana implementing the program; and
                    (E) identification of funding for implementation of the  pro-
                  gram, including' appropriate Federal  and State cost sharing
                  arrangements.
                (b)  COMPLIANCE AND ENFORCEMENT.—The Administrator  of the
               Environmental Protection Agency, the Secretary of Commerce, and
               the Governor  of the State of Florida shall  ensure compliance with
               the program  required by this  section, consistent with applicable
               Federal and State laws.
                (c)  CONSULTATION.—In  the  development and implementation of
               the program required by paragraph (1), appropriate State and local
               government officials shall be consulted.

                                     ADVISORY COUNCIL

Intergovernmental   SEC. 9. (a) ESTABLISHMENT.—The Secretary of Commerce, in con-
is'uscuaa      sultation with the Governor of the State of Florida and the Board of
not*            County Commissioners of Monroe County, Florida, shall establish an
               Advisory Council to assist the Secretary in the development and
               implementation  of the comprehensive management plan for  the
               Sanctuary.
                (b)  MEMBERSHIP.—Members of the Advisory Council may be ap-
               pointed from among (1) Sanctuary managers. (2) members of other
               government agencies with overlapping management responsibilities
               for the Florida Keys marine environment, and (3) representatives of
               local  industries, commercial users, conservation groups,  the marine
               scientific and  educational community, recreational  user groups, or
               the general public.
                (c) EXPENSES.—Members of the Advisory Council shall not be paid
               compensation  for their service  as members and shall not be re-
               imbursed for  actual and  necessary traveling and  subsistence ex-
                                        A-6

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            PUBLIC LAW 101-605—NOV. 16, 1990          104 STAT. 3095

penses incurred by them in the performance of their duties as such
members.
  (d) ADMINISTRATION.—The Advisory Council shall elect a chair-
person and may establish subcommittees, and adopt by-laws,  rules,
and such other administrative requirements and procedures as are
necessary for the administration of its functions.
  (e) STAFFING AND  OTHER ASSISTANCE.—The  Secretary of  Com-
merce  shall make available  to the  Advisory Council  such  staff,
information, and administrative services and assistance as the Sec-
retary  of Commerce determines are reasonably required to enable
the Advisory Council to carry out its functions.

               AUTHORIZATION OF APPROPRIATIONS                  16 USC 1433
                                                                note.
  SEC.  10. (a) AUTHORIZATION FOR SECRETARY OF COMMERCE.—Sec-
tion 313(2XC) of the Marine Protection, Research, and Sanctuaries
Act of 1972 (16 U.S.C. 1444(2XO) is amended by striking "$3,000,000"
and inserting in lieu thereof "$4,000,000".
  (b) AUTHORIZATION  FOR  EPA  ADMINISTRATOR.—There are au-
thorized to be appropriated to the Administrator of the Environ-
mental Protection Agency $750,000 for each of the fiscal years 1991
and 1992.
  (c) REPORT.—The Secretary of Commerce  shall,  not later than
March 1,1991, submit to the Committee on Commerce, Science, and
Transportation of the Senate and  the Committee on  Merchant
Marine and Fisheries of the House of Representatives a report on
the future  requirements for funding the Sanctuary through  fiscal
year 1999 under title III of the Marine Protection, Research, and
Sanctuaries Act of 1972 (16 U.S.C. 14321 et seq.).

  Approved November 16,1990.
LEGISLATIVE HISTORY-H.R. 5909:

CONGRESSIONAL RECORD. Vol. 136 (1990):
     Oct. 26, considered and passed House.
     Oct. 27, considered and passed Senate.
WEEKLY COMPILATION OF PRESIDENTIAL DOCUMENTS, Vol. 26 (19901:
     Nov. 16, Presidential remarks and statement.
                             A-7

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                                              II
102D CONGRESS
   2p SESSION
H.R.5617
    IN THE SENATE OF THE UNITED STATES
        OCTOBER 6 (legislative day, SEPTEMBER 30), 1992
                     Received
                AN  ACT
     To provide Congressional approval of a Governing
  International Fishery Agreement, and for other purposes.
 1     Be it enacted by the Senate and House of Representa-
 2 tives of the United States of America in Congress assembled,
                   *
 3 SECTION 1. SHORT TITLE.
 4     Tnis Act may be cited as the "Oceans iAct of 1992".
                        A-8

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                       2
 i  TITLE   I—APPROVAL  OF   GOV-
 2      ERNING        INTERNATIONAL
 3      FISHERY AGREEMENT
 4  SEC. 1001. APPROVAL OF AGREEMENT.
 5      Notwithstanding section 203 of the Magnuson Fish-
 6  ery Conservation and Management Act (16 U.S.C. 1823),
 7  the governing international fishery agreement between the
 8  Government of the United States of America and the Gov-
 9  eminent of the Republic of Estonia, as contained in the
10  message to Congress from the President of the United
           ••
11  States dated June 24, 1992, is approved by the Congress
12  as a governing international fishery agreement for the
13  purposes of such Act and shall enter into  force and effect
14  with respect to the United States on the date of enactment
15  of this title.
16     TITLE II—NATIONAL MARINE
17        SANCTUARIES PROGRAM
18  SEC. 2001. SHORT TITLE.
19      This title may be cited as the "National Marine Sanc-
20  tuaries Program Amendments Act of 1992".
                    A-9

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                         3
 i  Subtitle  A—Amendments   To   Ma-
 2      rine  Protection,  Research,  and
 3      Sanctuaries Act of 1972
 4  SEC. 2101. FINDINGS, PURPOSES, AND POLICIES.
 5      (a) FINDINGS.—Section 301(a) of the Marine Protec-
      r
 6  tipn, Research, and Sanctuaries Act of 1972 (16 U.S.C.
 7  1431 (a)) is amended—
 8           (1) in paragraph  (2) by inserting ",  and in
 9      some cases international," after "national";
10           (2) in paragraph (4)—
11               (A) by inserting ", research," after "con-
12           servation"; and
13               (B) by striking "and"  after the semicolon
14          at the end;
15           (3) in paragraph (5) by striking the period at
16      the end and inserting "; and"; and
17           (4) by adding at the end the following:
18           "(6) protection of these special areas can con-
19     tribute to maintaining a natural assemblage of living
20     resources for future generations.".
21       (b) PURPOSES AND POLICIES.—Section 301(b) of the
22 Marine Protection, Research, and Sanctuaries Act of 1972
23  (16 U.S.C. 1431(b)) is amended to read as Mows:
24     "(b)  PURPOSES AND POLICIES.—The purposes and
25 policies of this title are—
                           A-10

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 1      World, and provides cultures of phytoplankton for
 2      critical research on global issues.
 3      (b)  DESIGNATION.—In light of the findings under
 4  subsection (a), the Provasoli-Guillard Center for the Cul-
 5  ture of Marine Phytoplankton located in West Boothbay
 6" Harbor,  Maine,  is designated as  a  National  Center and
 7  Facility.
 8  SEC. 2209. FLORIDA EEYS NATIONAL MARINE SANCTUARY.
 9      (a)  IMPLEMENTATION.—Section  8  of the Florida
10  Keys National Marine Sanctuary  and Protection Act (16
11  U.S.C. 1433 note) is amended by adding at the end the
12  following new subsection:
13      "(d) IMPLEMENTATION.—(1) The Administrator  of
14  the  Environmental Protection Agency .and  the Governor
15  of the State of Florida shall implement the program re-
16  quired by this section, in cooperation with  the Secretary
17  of Commerce.
18      "(2)(A) The Regional Administrator of the Environ-
19  mental Protection Agency shall with the  Governor of the
20  State of Florida establish a Steering  Committee to set
21  guidance and policy for the development and implementa-
22  tion of such program. Membership shall include represent-
23  atives of the Environmental Protection Agency, the Na-
24  tional Park Service,  the United States Fish and Wildlife
25  Service, the Army Corps  of Engineers, the  National Oce-
                         A-ll

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                          42
 1 anic and Atmospheric Administration, the Florida Depart-
 2 ment of Community Affairs, the  Florida Department of
 3 Environmental Regulation, the South Florida Water Man-
 4 agement District, and the Florida Keys Aqueduct Author-
 5 ity; three individuals in local government in the Florida
 6 Keys;  and three  citizens knowledgeable about such pro-
 7 gram.
 8      "(B) The Steering.Committee shall, on a  biennial
 9 basis, issue a report to Congress that—
10          "(i) summarizes the progress of the program;
11          "(ii) summarizes  any modifications to the pro-
12      gram  and its recommended  actions and plans; and
13          "(iii)  incorporates  specific  recommendations
14      concerning the implementation of the program.
15      "(C) The Administrator of the Environmental Pro-
16 tection Agency and the Administrator of the National Oce-
17 anic and Atmospheric Administration shall cooperate with
18 the Florida Department of Environmental Regulation to
19 establish a Technical Advisory Committee to advise the
20 Steering Committee  and  to  assist  hi the design  and
21 prioritization of programs for scientific research and mon-
22 itoring. The Technical Advisory Committee shall be cc  -
23 posed  of scientists from Federal agencies, State agencies,
24 academic institutions,  private non-profit  organizations,
25 and knowledgeable citizens.
                    A-12
            RDS

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                           43
 1      "(3)(A) The Regional Administrator of the Environ-
 2  mental Protection Agency shall appoint a Florida Keys Li-
 3  aison  Officer. The Liaison Officer, 
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                          44
 1          "(v)  provide for public review and comment on
 2      the program and implementing actions.
 3      "(4) (A) There are authorized to be appropriated to
 4  the Administrator of the Environmental Protection Agen-
 5  cy $2,000,000 for  fiscal year 1993, $3,000,000 for fiscal
 6  year 1994, and  $4,000,000  for fiscal year 1995, for the
 7  purpose of carrying out this section.
 8      "(B)  There are authorized to be appropriated to the
 9  Secretary of Commerce $300,000 for fiscal year 1993,
10  $400,000  for  fiscal year 1994, and $500,000 for fiscal
11  year 1995, for the purpose of enabling the National Oce-
12  anic and  Atmospheric Administration to carry out  this
13  section.
14      "(C)  Amounts  appropriated under this paragraph
15  shall remain available until expended.
16      "(D) No more than 15 percent of the amount author-
17  ized to be appropriated  under subparagraph (A) for any
18  fiscal year may be expended in that fiscal year on adminis-
19  trative expenses.".
20      (b) TECHNICAL AMENDMENT.—Section 8(c) of the
21  Florida Keys  National Marine Sanctuary and Protection
22  Act (16 U.S.C. 1433 note) is amended by striking "para-
23  graph (1)" and inserting in  lieu thereof "subsection (a)".
                     A-14

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               APPENDIX B



SUMMARY OF PUBLIC COMMENTS AND RESPONSES

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                               APPENDIX B

        SUMMARY OF PUBLIC COMMENTS AND RESPONSES
In 1993, EPA prepared the draft Program Document, which included a draft Water
Quality Action Plan.  The Action Plan was subsequently incorporated into NOAA's Draft
Management Plan and Environmental Impact Statement for the Sanctuary, which was
released to the public in March 1995.  By the close of the public comment period on
December 31, 1995,  NOAA had received over 6,000 written and oral comments. Most
of these were form letters addressing issues other than water quality.  Of the water
quality-related comments, most raised general issues and did not recommend specific
changes to water quality strategies.  NOAA summarized these general public comments
and prepared generic responses, which are provided in this appendix.
SUPPORT THE WATER QUALITY ACTION PLAN

Comment:  Many reviewers of the Draft Management Plan and Environmental Impact
Statement commented on the issue of water quality within the Sanctuary.  There was
almost unanimous agreement that deteriorating water quality is the major threat to the
health of Sanctuary resources, and most people supported actions to correct the
problems. Many reviewers specifically expressed support for the Water Quality Action
Plan.

Response: NOAA agrees that the major threat to the health of the Florida Keys coral
reef ecosystem is deteriorating water quality. The Florida Keys National Marine
Sanctuary and Protection Act directed EPA, in coordination with the State of Florida
and NOAA, to develop a Water Quality Protection Program for the Sanctuary. This was
the first Congressionally mandated Water Quality Protection Program for a National
Marine Sanctuary and was established to take corrective actions to restore water quality
in the Sanctuary. The Water Quality Action Plan reflects strategies developed under the
Water Quality Protection Program.
WATER QUALITY is AN ISSUE BROADER THAN THE SANCTUARY

Comment:  Although the majority of the reviewers recognized that deteriorating water
quality was the major threat to marine resources, the source or cause of problems was
questioned.  Many claimed the problems originate outside Sanctuary boundaries in the
upper portions of Florida Bay, or come as a result of poor water management practices
in South Florida. Reviewers stated that the problem is outside the Sanctuary boundary
and thus the Sanctuary does not have the authority to address these significant water
quality issues.

Response:  Some of the water quality problems in the Florida Keys occur outside and
upstream of the Sanctuary's boundary.  Deteriorating water quality in Florida Bay is
largely a result of water management practices in South Florida as has been
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documented by scientists. Other scientists point to possible sources of nutrients and
pollutants that enter Florida Bay through the Everglades drainage.  The Florida Keys are
at the end of the South Florida ecosystem and are the recipient of degraded water
quality that originates upstream. While EPA, the State of Florida and other agencies
will continue to address the land-based sources of pollution and water quality in the
Sanctuary, particularly through the Water Quality Steering Committee and the South
Florida Ecosystem Task Force, NOAA has an appropriate supplementary role in these
efforts.
WATER QUALITY PROBLEMS IN NEARSHORE WATERS

Comment: Some reviewers stated that there are no water quality problems in the
Florida Keys.  Other reviewers cited the poor wastewater treatment practices in the
Florida Keys, such as septic tanks, injection wells, and cesspits, as the main source of
water quality degradation in the Sanctuary.   Stormwater runoff was also viewed as a
contributing factor to poor water quality.  Some reviewers cited the findings from a
recently released State Hearing Officer's report.

Response:  NOAA disagrees with the implication that there  is not a water quality
problem in the Florida Keys.  Scientists have documented the decline of water quality in
the nearshore waters of the Florida Keys.  This deterioration  is caused by a variety of
sources  including excessive nutrients entering the nearshore waters because of
inadequate sewage treatment practices and problems related to stormwater runoff. The
findings of a State Hearing Officer were that the nearshore waters of the Florida Keys
have exceeded their carrying capacity and are in danger of collapsing. In  addition, the
report identified nutrients originating from inadequate treatment facilities  as the
primary cause of nearshore water quality  degradation in the  Florida Keys.  The Water
Quality Protection Program was established  to take corrective actions to restore water
quality in the Sanctuary. This must be accomplished at  the same time as,  or prior to,
the restoration of water quality upstream  in Florida Bay hi order to be successful.
Improvement of water quality in the Sanctuary will not be successful if only the
upstream or nearshore portion of the ecosystem is restored.  All parts of the ecosystem,
all the way to the coral reefs, must be restored and relieved of increasing human
impacts.
IMPLEMENTATION

Comment: Some reviewers stressed that the implementation of the Water Quality
Action Plan should supersede the implementation of other action plans such as zoning.
They emphasized cleaning up the water quality problems before continuing with other
management actions. Other reviewers stressed the importance of addressing the
deteriorating water quality issue hi the  Sanctuary, but advocated implementation of a
variety of management programs, including those that protect Sanctuary resources from
continued degradation.  In addition, some reviewers supported a plan with direct action
strategies to correct water quality problems.
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Response:  NOAA agrees that the major issue affecting the health of the Florida Keys
coral reef ecosystem is deteriorating water quality. Implementation of the Water
Quality Action Plan and the Water Quality Protection Program for the Sanctuary will
lead to improvement of water quality in the Sanctuary. Currently, some of the
corrective actions identified in the Water Quality Protection Program are being
implemented both within the boundaries of the Sanctuary and upstream in the South
Florida ecosystem.  These  ongoing activities will have a net positive benefit to Sanctuary
resources.

However, NOAA disagrees that all other management actions should be deferred until
the implementation of the Water Quality Protection Program and the Water Quality
Action Plan for the Sanctuary. Many of the management actions necessary to halt the
decline of water quality in the Florida Keys will take years to implement, and the
physical stresses and impacts  currently placed on Sanctuary resources from other
sources could be lessened  with management actions such as mooring buoys to prevent
anchor damage, channel markers  to mark boating routes through sensitive habitats, and
outreach programs to educate users about the resources of the Florida Keys.
MOSQUITO SPRAYING

Comment: Several reviewers expressed concern about NOAA's role in addressing
current mosquito control practices in Monroe County.

Response: Representatives from the Sanctuary and Monroe County will work together
through the Water Quality Protection Program to refine aerial mosquito spraying based
on research findings.  This action will reduce threats to marine resources which  may
result from mosquito spraying over the nearshore waters of the Florida Keys.
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       APPENDIX C



WATER QUALITY ACTION PLAN

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Water Quality Action Plan
The Florida Keys National Marine Sanctuary
September 1996
Prepared by:
Continental Shelf Associates, Inc.
and Battelle Ocean Sciences
Prepared for:
U.S. Environmental Protection Agency
Oceans and Coastal Protection Division
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                                                          Wafer Quality Action Plan
                                 Contents

Purpose and Organization  	  C-4

Introduction	  C-5
   Goals and Objectives  	  C-5
   Existing Programs	  C-6

Description of Strategies  	  C-7
   Florida Bay/External Influence Strategies  	  C-7
       Strategy W.19: Florida Bay Freshwater Flow  	  C-8
       Strategy W.24: Special Studies: Florida Bay Influence  	  C-9
   Domestic Wastewater Strategies  	  C-10
       Strategy W.1: OSDS Demonstration Project	  C-11
       Strategy W.2: AWT Demonstration Project	  C-12
       Strategy W.3: Wastewater Management Systems	  C-13
       Strategy W.4: Wastewater Disposal, City of Key West	  C-16
       Strategy W.5: Water Quality Standards  	  C-17
       Strategy W.6: NPDES Program Delegation  	  C-18
       Strategy W.7: Resource Monitoring of Surface Discharges	  C-19
       Strategy W.8: Wastewater Permitting	  C-20
       Strategy W.9: Laboratory Facilities   	  C-22
   Stormwater Strategies	  C-23
       Strategy W.11: Stormwater Retrofitting  	  C-24
       Strategy W.12: Stormwater Permitting	  C-25
       Strategy W.13: Stormwater Management	  C-26
       Strategy W.14: Best Management Practices	  C-27
   Marina and Live-Aboard Strategies	  C-28
       Strategy B.7: Pollution Discharges   	  C-29
       Strategy Z.5: Special-Use Areas	  C-30
       Strategy L.1: Marina, Pumpout	  C-31
       Strategy L.6: Mobile Pumpout	  C-33
       Strategy L2: Marina Siting and Design	  C-34
       Strategy L.3: Marina Operations  	  C-35
       Strategy E.4: Training/Workshops/School Programs	  C-37
   Landfill Strategies 	  C-38
       Strategy L.7: Solid Waste Disposal  Problem Sites  	  C-39
   Hazardous Materials Strategies 	  C-41
       Strategy W.15: Hazardous Materials Response  	  C-42
       Strategy W.16: Spill Reporting  	  C-43
       Strategy L.10: Hazardous Materials Handling	  C-44
   Mosquito Spraying Strategies	  C-45
       Strategy W.17: Mosquito Spraying   	  C-46
       Strategy W.18: Pesticide Research   	  C-48
   Canal Strategies  	  C-49
       Strategy W.10: Canal Water Quality	  C-50
   Monitoring and Research/Special Studies Strategies	  C-52
       Strategy W.20: Water Quality Monitoring Program	  C-53
       Strategy W.21: Special Studies: Predictive  Models	  C-55
       Strategy W.22: Special Studies: Wastewater Pollutants	  C-56
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                                                           Water Quality Action Plan
       Strategy W.23: Special Studies: Other Pollutants and Water Quality Problems ...  C-57
       Strategy W.28:  Regional Database  	  C-59
       Strategy W.29:  Dissemination of Findings  	  C-60
       Strategy W.32:  Technical Advisory Committee	  C-61
       Strategy W.33:  Ecological Monitoring Program  	  C-62

Implementation	  C-63
   Responsible Institutions	  C-63
   Priority Activities 	  C-63
   Schedule  	  C-63
   Cost	  C-63
   Geographic Focus	  C-64
   Personnel	  C-65
   Equipment  	  C-65
   Contingency Planning for Changing Budgets  	  C-65
   Evaluating  Program Effectiveness	  C-65
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                WATER QUALITY ACTION PLAN
                    Purpose and Organization

The purpose of this action plan is to describe the suite of activities—including
corrective actions, monitoring, and research/special studies—that are proposed to
deal with water quality problems in the Florida Keys National Marine Sanctuary. Each
strategy is derived from the set of recommendations included in the Phase II report
developed by EPA and the State of Florida. Although this is the final set of water
quality strategies for the Sanctuary, only a subset may be implemented due to a
limited budget. The numerous reports and plans (Phase I report, Phase II report,
Implementation Plan,  etc.) associated with the development of the Water Quality
Protection Program should be consulted for additional information about water quality
activities in the Keys.

This action plan outlines the Water Quality Protection Program's proposed water
quality strategies. The strategies provide a mechanism for achieving the goals of the
Program. The plan is  organized into three main sections: 1) Introduction,
2) Description of Strategies, and 3)  Implementation.

The introduction summarizes the goals and objectives of the Water Quality Action Plan
and provides background on the development of the plan.

The description of strategies section summarizes strategies grouped according to nine
themes:

   • Florida Bay/external influences;
   • domestic wastewater;
   • stormwater;
   • marinas and live-aboards;
   • landfills;
   • hazardous materials;
   • mosquito spraying;
   • canals; and
   • research/monitoring.

To the extent possible, each strategy is broken down into its component activities.
Activity descriptions discuss existing program implementation (if any), the parties
responsible for implementation (responsible agency, primary role, or assisting role),
and a proposed schedule for implementation.

The implementation section details how the entire group of strategies comprising the
Water Quality Action Plan will be implemented. It summarizes priorities, implementing
agencies, schedules,  costs, geographic focus, personnel and equipment
requirements, contingency planning for changing budgets, and how Program
effectiveness will  be evaluated.

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                                                          Water Quality Action Plan
                               Introduction

Recognizing the critical role of water quality in maintaining Sanctuary resources,
Congress directed the U.S. Environmental Protection Agency (EPA) and the State of
Florida to develop a Water Quality Protection Program for the Sanctuary. The purpose
of the Program is to "recommend priority corrective actions and compliance schedules
addressing point and nonpoint sources of pollution to restore and maintain the
chemical, physical, and biological integrity of the Sanctuary, including restoration and
maintenance of a balanced, indigenous population of corals, shellfish, fish and
wildlife, and recreational activities in and on the water" (Florida Keys National Marine
Sanctuary and Protection Act). In addition to corrective actions, the Act also requires
the development of a water quality monitoring program and provision of opportunities
for public participation in all aspects of developing and implementing the Program.

Goals and Objectives

The Florida Keys National Marine Sanctuary is the first to include a Water Quality
Protection Program. The purpose of the program is specified in the Florida Keys
National  Marine Sanctuary and Protection Act (HR5909, Public Law 101-605):

    "recommend priority corrective actions and compliance schedules addressing
    point and nonpoint sources of pollution to restore and maintain the chemical,
    physical, and biological integrity of the Sanctuary, including restoration and
    maintenance of a balanced, indigenous population of corals, shellfish, fish and
    wildlife, and recreational activities in and on the water."

The Program's goals are the protection and improvement of Sanctuary water quality
and enhancement of living resources. The Water Quality Protection Program proposes
many activities to achieve these goals such as reducing anthropogenic loading
(wastewater and stormwater) to Sanctuary waters. In addition to corrective actions, the
Program also includes development of a water quality monitoring program and a
special studies program, as well as provision of opportunities for public participation
in all aspects of developing and implementing the program.

As specified in the Act, the Water Quality Protection Program was developed by the
EPA and the Florida Department of Environmental Protection (FDEP), working in close
coordination with National Oceanic and Atmospheric Administration (NOAA). The
program was developed in two phases. During Phase I, information was compiled and
synthesized on the status of the Sanctuary's natural environment. Priority problems
were identified through this literature review, and through consensus of technical
experts and other participants in technical workshops. Phase II focused on developing
options for corrective actions, developing a water quality monitoring program and
associated research/special studies program, and developing a public education and
outreach program. Findings from Phases I and II were incorporated into the Water
Quality Protection Program Document. Options for corrective actions, research/special
studies, monitoring, and education presented in the Program Document were
incorporated into the strategies included in this action plan.
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                                                           Wafer Quality Action Plan
Existing Programs

The Florida Keys National Marine Sanctuary is the first to have a Water Quality
Protection Program. There are no existing programs at the Key Largo or Looe Key
national marine sanctuaries that focus specifically on water quality, although
Sanctuary education programs typically include water quality among the many
.environmental issues they address.

Many of the strategies included in the Water Quality Action Plan involve the
modification of existing programs operated by one or more of the agencies with
jurisdiction over water quality in the Florida Keys. Other strategies involve entirely new
programs, but these would necessarily build upon the existing regulatory/
management framework. Further information about existing programs operated by
agencies and institutions with jurisdiction over water quality in the Florida Keys is
provided in the Phase II Report.

Where appropriate, descriptions of strategies and activities in the Water Quality Action
Plan include a section describing "Existing Program Implementation."
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                                                           Water Quality Action Plan
                      Description of Strategies
Florida Bay/External Influence Strategies

Severe water quality and ecological problems have developed in Florida Bay in recent
years, and the bay is now in a state of crisis. Problems include a massive seagrass
die-off, phytoplankton blooms, sponge die-offs, mangrove die-backs, and all of the
potential cascading ecological effects of these phenomena. Since 1987, much of
Florida Bay has been affected by a massive, unprecedented seagrass die-off that has
left tens of thousands of acres of denuded sediments. Through the resulting sediment
resuspension and nutrient release, the seagrass die-off may be the cause of massive
phytoplankton blooms that have affected the Bay during recent years. Sponge die-offs
caused by phytoplankton blooms may have serious impacts on juvenile spiny
lobsters, which reside by day under sponges for protection from predation.

Most scientists believe that recent ecological problems in Florida Bay are the result of
long-term reduction in freshwater flow from the Everglades.  The mechanism has not
been documented, but high salinities per se and a long-term change from an
estuarine to a marine system may be  contributing factors.

These problems in Florida Bay must be viewed as a potential  threat to water quality
and resources in the Sanctuary. Water quality and natural resources in Florida Bay are
tightly linked to those of the Sanctuary. The need for actions to deal with water
delivery problems in Florida Bay has been strongly stressed by workshop participants
and other scientists during the development of the Water Quality Protection  Program.
Two strategies were developed to address this issue. One (W.19) would have the
Steering  Committee for the Water Quality Protection Program  take a leading role in
working to restore historical freshwater flow to Florida Bay. The other (W.24) would
conduct research/special studies that will further document the influence of Florida
Bay on water quality and biological resources in the Sanctuary.
  Florida Bay/External Influence Strategies

  W.19: Florida Bay Freshwater Flow
  • Establish leading role for Steering Committee
  • Participate in review/revision of water management strategies

  W.24: Special Studies: Florida Bay Influence
  • Conduct historical assessment
  • Conduct circulation studies
  • Conduct ecological studies
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                                                         Water Quality Action Plan
                              Strategy W.19:
                       Florida Bay Freshwater Flow
The Steering Committee for the Water Quality Protection Program shall take a leading
role in restoring historical freshwater flow (quantity, quality, timing, and distribution) to
Florida Bay, which is now in a state of crisis. In addition, Sanctuary representatives
shall work with appropriate federal, state, and local agencies to ensure that restoration
plans and surface water improvement and management plans for South Florida and
the Everglades are compatible with efforts to maintain water quality within the
Sanctuary.

Activity 1-Establish Leading Role for Steering Committee. The Steering Committee
for the Water Quality Protection Program includes high-level representatives of all
relevant agencies and can therefore take a leading role in water management issues
affecting Florida Bay, including restoring historical freshwater flow. Both short- and
long-term solutions must be pursued at high levels of management in both state and
federal agencies.

   • Implementation. The responsible agencies will be the EPA arid FDEP, which
   administer the Water Quality Protection Program. All other agencies represented
   on the Steering Committee will have a primary role, including NOAA, the National
   Park Service (NPS), the U.S. Fish and Wildlife  Service (FWS), the U.S. Army Corps
   of Engineers (ACOE), the Florida Department of Community Affairs (FDCA), the
   SFWMD, and the Florida Keys Aqueduct Authority (FKAA).

   • Schedule. This activity has been completed.

Activity 2-Participate in Review/Revision of Water Management Strategies.
Sanctuary representatives shall participate in the review and revision of restoration
plans and water management plans for Florida Bay and adjacent areas to ensure that
these proposals and/or actions will enhance and complement water quality
improvement efforts undertaken in the Sanctuary.  These plans include, but are not
limited.to, the Shark River Slough General Design Memorandum, C-111 basin, Taylor
Slough Restoration, West Dade Wellfield, US 1 widening, National Park Service
Everglades Restoration  Plan, Lower East Coast Water Supply Plan, and Everglades
Surface Water Management and Improvement Plan.

   • Implementation. The Management Committee of the Water Quality Protection
   Program is  responsible for administering water quality management in the
   Sanctuary. The responsible agencies will be the EPA and FDEP, which administer
   the Water Quality Protection Program. NOAA will have a primary role because of
   its overall responsibility for managing the Sanctuary. The main agencies involved
   in water management decisions for the Everglades and Florida Bay are the NPS,
   SFWMD, and ACOE. As the state land planning agency for a designated Area of
   Critical State Concern, the FDCA is also likely  to be involved. Other primary
   agencies are the FWS and Monroe County.

   • Schedule. This activity will have a medium level of action in year 1. It will require
   36+ months to complete.
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                                                          Wafer Quality Action Plan
                               Strategy W.24:
                  Special Studies: Florida Bay Influence
Conduct research/special studies to understand the effect of water transport from
Florida Bay on water quality and resources in the Sanctuary.

Activity 1-Conduct Historical Assessment. This activity will involve an historical
assessment of Everglades/Florida Bay/Florida Keys hydrology, as it has affected water
quality and biological communities in the Sanctuary. It will clarify the role of freshwater
inflows and water quality from the Everglades, and other freshwater discharges to the
southwest shoreline of Florida, to Florida Bay and the Sanctuary. The activity will
examine the effects of structural modifications and changes in timing and volume of
freshwater releases from existing structures, as  well as land practices affecting the
water quality of runoff.

    • Implementation. The SFWMD and the NFS will be the responsible agencies for
    this strategy. Assistance will be provided by the ACOE, which has historical data
    concerning water management activities affecting the Everglades and Florida Bay.

    • Schedule. This activity will have a high level of action in year 1. It will require 12
    months to complete.

Activity 2-Conduct Circulation  Studies. This activity will involve circulation studies to
estimate present-day long-term net transport and episodic transport from Florida Bay
to the Sanctuary. Studies of groundwater flow may be included.

    • Implementation. The EPA and FDEP will be the responsible agencies for this
    strategy.

    • Schedule. This activity will have a high level of action in year 1. It will require 48
    months to complete.

Activity 3-Conduct Ecological Studies. This activity will involve studies to document
ecological impacts, if any, of Florida Bay waters on Sanctuary communities, including
seagrasses, coral reefs, nearshore hard-bottom communities, and potentially
endangered or threatened species. Documentation of hypothesized impacts could
provide a stronger basis for actions to restore historical freshwater flow to Florida Bay.

    • Implementation. The EPA and the FDEP will be the responsible agencies for this
    strategy.

    • Schedule. This activity will have a low level  of action in year 1. It will require 36
    months to complete.
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                                                               Water Quality Action Plan
Domestic Wastewater Strategies

This section describes strategies for reducing pollution from land-based sources of
domestic wastewater. Pollution sources include cesspits, on-site disposal systems
(OSDS), package plants, and municipal treatment plants. Strategies for reducing
wastewater pollution from live-aboard boaters are covered in the marina and live-
aboard section of this action plan.

The first two domestic wastewater strategies (W.1 and W.2) are demonstration
projects that would  provide information to decide among options for the main strategy
(W.3) for wastewater management systems outside Key West. Strategy W.4 is also an
engineering strategy but is applicable only to Key West. The remaining domestic
wastewater strategies involve management activities designed to reduce pollution by
developing water quality standards (including biocriteria) specific to the Florida Keys
and making the regulatory/management system work more efficiently.
  Domestic Wastewater Strategies

  W.1: OSDS Demonstration Project
  • Select alternate OSDS and test locations
  • Conduct OSDS demonstration project

  W.2: AWT Demonstration Project
  • Select specific technology and test location
  • Conduct AWT pilot project

  W.3: Wastewater Management Systems
  • Establish inspection/compliance programs for cesspits and OSDS, and
  continue the existing FDEP inspection/compliance program for package plants
  • Evaluate development of nutrient reduction targets
  • Develop sanitary wastewater master plan
  • Implement master plan

  W.4: Wastewater Disposal, City of Key West
  • Evaluate disposal and reuse options
  • Upgrade effluent disposal

  W.5: Water Quality Standards
  • Develop and evaluate indicators
  • Develop water quality standards

  W.6: NPDES Program Delegation
  • Delegate NPDES  program

  W.7: Resource Monitoring of Surface Discharges
  • Require resource  monitoring

  W.8: Wastewater Permitting
  • Improve interagency coordination
  • Combine OSDS permitting responsibilities
  • Monitor revised OSDS rules

  W.9: Laboratory Facilities
  • Conduct feasibility study
  • Establish interagency laboratory
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                                                         Water Quality Action Plan
                               Strategy W.1:
                       OSDS Demonstration  Project
Conduct a demonstration project to evaluate innovative alternate, nutrient-removing
on-site sewage disposal systems (OSDS).

This strategy will provide information to help determine the appropriate role, if any, for
alternate OSDS (septic systems) in wastewater management in the Keys. Although
some alternate OSDS designs appear promising, it is not appropriate to proceed with
broad-scale installation of these systems until an independent evaluation has been
conducted.

Activity 1-Select Alternate OSDS and Test Locations. Alternate OSDS designs will
be reviewed, and appropriate systems will be selected for evaluation. Suitable test
locations will be selected.

    •  Implementation. The Florida Department of Health and Rehabilitative Services
    (FDHRS) will be the responsible agency for this activity. Other primary agencies
    involved will be the EPA, FDEP, FDCA, arid Monroe County.

    •  Schedule. This activity been completed.

Activity 2-Conduct OSDS Demonstration Project. Alternate OSDS  designed for
nutrient removal would be installed and maintained in a manner consistent with actual
residential use. Influent, effluent, and groundwater quality (both background and
"down-gradient") would  be monitored at regular intervals for at least a year. In addition
to nutrient removal efficiency, the study would evaluate maintenance and inspection
requirements to keep units operating properly.

    •  Existing Program Implementation. Congress provided $500K in  additional funds
    to the EPA's fiscal year ,1993 budget for the Water Quality Protection Program  to
    be used for demonstration projects. This was used to initiate the  OSDS
    Demonstration Project (strategy W.1) before  the fiscal year 1994 starting point for
    this action plan.

    •  Implementation. The FDHRS will be the responsible agency for this activity.
    Other primary agencies involved will be the EPA, FDEP, FDCA, and Monroe
    County.

    •  Schedule. This activity will have a low level of action in year 1.  It will require  36
    months to complete.
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                                                          Water Quality Action Plan
                                Strategy W.2:
                       AWT Demonstration Project
Conduct a pilot project to evaluate installation of a small, expandable advanced
wastewater treatment (AWT) plant to serve an area of heavy OSDS use with
associated water quality problems.

This strategy will provide information to help decide whether elimination of OSDS
would improve water quality in areas believed to be degraded by OSDS nutrients.
Existing OSDS in the test area would be connected to a small package plant
providing AWT, which  includes nutrient removal. The project will also provide
information about long-term performance of small AWT systems and septic tank
effluent pumps or other collection systems. Both conventional and innovative
.technologies will be considered.

Activity 1-Select Specific Technology and Test Location. Different technologies for
AWT will be reviewed and appropriate systems will be selected for evaluation.
Preferably, the test area will be one where water quality problems  believed to be
related to OSDS nutrients have already been identified. In addition, the location
should be appropriate for eventual expansion of the AWT package plant to a
community or subregional plant if the test proves successful.

    • Implementation. The FDEP will be the responsible agency for this activity. The
    EPA and Monroe County will be involved as a primary agencies.

    • Schedule. This activity will have a low level of action in year  1. It  will require 12
    months to complete.

Activity 2-Conduct AWT Pilot Project. A small, expandable AWT package plant will
be installed  to serve an area where there is high-density OSDS use in  close proximity
to confined waters. Initial background groundwater and surface water monitoring will
be conducted, and plant influent and effluent will then be monitored for at least one
year after the plant is in operation. Groundwater and surface water monitoring will be
continued for three to five years. Most facilities constructed for the project could be
incorporated into a larger system if results were favorable.

    • Implementation. The FDEP will be the responsible agency for this activity. The
    EPA and Monroe County will be involved as primary agencies.

    • Schedule. This activity will have a low level of action in year  1. It  will require 36
    months to complete.
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                                                         Water Quality Action Plan
                               Strategy W.3:
                   Wastewater Management Systems
Establish inspection/compliance programs for cesspits and OSDS and continue the
existing FDEP inspection/compliance program for package plants. Evaluate the
development of targets for reductions in wastewater nutrient loadings necessary to
restore and maintain water quality and Sanctuary resources. Develop and implement a
Sanitary Wastewater Master Plan that evaluates options for upgrading existing
systems beyond current standards or constructing community sewage treatment
plants, based on nutrient reduction targets, cost and cost effectiveness,
reliability/compliance considerations, and  environmental and socioeconomic impacts.

Activity 1-Establish Inspection/Compliance Programs for Cesspits and OSDS and
Continue the Existing FDEP Inspection/Compliance Program for Package Plants.
This activity would establish on-site inspection programs to identify all cesspits and
ensure that OSDS are in compliance with  existing standards. These programs, along
with the existing FDEP inspection/compliance program for package plants, would
ensure that these systems are operating properly, reducing nutrient loading to
groundwater. Cesspits identified through this activity would eventually be replaced
with an approved OSDS or a connection to a community wastewater treatment plant,
as determined by the Sanitary Wastewater Master Plan (activity 3). This would reduce
nutrient loading to groundwater and eliminate health hazards from untreated sewage.
Because development and implementation of the Sanitary Wastewater Master Plan is
a long-term process, Monroe County should develop an interim response policy to
address non-compliance wastewater treatment systems as part of this activity. This
activity will also include a  public education/outreach component which would inform
the public about ways to assess and improve existing wastewater treatment systems.

    • Implementation. The FDHRS will be the responsible agency. Other  primary
    agencies involved are  the EPA, FDEP, Monroe County, and the City of Key West.

    • Schedule. This activity will have a high level of action in year 1. It will require 36
    months to complete.                                               '

Activity 2-Evaluate Development of Nutrient Reduction Targets. The goal of this
activity is to identify and evaluate alternative strategies for developing nutrient
reduction targets for wastewater and stormwater in the Florida Keys National Marine
Sanctuary. The information will help the EPA and the State of Florida to determine
whether nutrient reduction targets should  be developed and if so, how development
should proceed.

    • Implementation. The EPA and  FDEP will conduct this activity.

    • Schedule. This activity will have a low level of action in year 1. It will require
    12 months to complete.

Activity 3-Develop Sanitary Wastewater Master Plan. This activity will  develop a
Sanitary Wastewater Master Plan to evaluate options for wastewater treatment
developed in the EPA Water Quality Protection Program  Phase II Report. The options
(using the numbering system in that report) are as follows:
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                                                         Water Quality Action Plan
       •  W3a: Upgrade existing systems to current standards
       •  W3b: Upgrade package plants with Best Available Technology (BAT),
          which may include AWT
       •  W3c: Upgrade package plants with BAT and upgrade OSDS to alternate,
          nutrient-removing systems
       •  W3d: Construct two community wastewater treatment plants for the two
          most populous communities in the upper and middle Keys and extend the
          service area for the Key West treatment plant to adjacent areas of the lower
          Keys, to treat 52% of wastewater flows outside the City of Key West
       •  W3e: Construct seven community wastewater treatment  plants for the most
          densely populated areas to treat 73% of wastewater flows outside the City
          of Key West
       •  W3f: Construct 12 community wastewater treatment plants to treat 94% of
          wastewater flows outside the City of Key West
       •  W3g: Construct three subregional wastewater treatment  plants to treat 94%
          of wastewater flows outside the City of Key West

Currently, these options can be evaluated partially on the basis of estimated cost, cost
effectiveness, nutrient reduction, and  reliability of the technologies involved. However,
the options should also be evaluated in light of the nutrient reduction targets which
may be developed under activity 2. In addition, information about the nutrient removal
capacity, cost and cost effectiveness, and reliability of alternate, nutrient-removing
OSDS and various conventional and innovative AWT technologies needs to be
considered; this information will come from the OSDS Demonstration Project
(strategy W.1) and the AWT  Demonstration Project (strategy W.2). Environmental and
socioeconomic impacts must also be analyzed. The Sanitary Wastewater Master Plan
will also specify details of costs, schedules, service areas, etc. for implementation. The
master plan should investigate the feasibility of wastewater utility districts and  other
alternative funding mechanisms.

    • Implementation. Monroe County will be the responsible agency.  EPA, FDEP,
    FDCA, and FDHRS will also be involved as primary agencies. Development of the
    Sanitary Wastewater Master Plan has been initiated by Monroe County, and a
    technical advisory committee has been established to provide assistance to the
    County.

    • Schedule. This activity will have no action in year 1.  It will require 36  months to
    complete.

Activity 4-lmplement Master Plan. This activity will implement the preferred
wastewater treatment options specified in the Sanitary Wastewater Master  Plan
developed under activity 3. The eventual preferred option  cannot be identified at this
time. However, two options are discussed below as examples.

    Option W3d-Construct Two Community Plants. Advanced wastewater treatment
    plants would be constructed for Key Largo and Marathon (the two most populous
    communities in the upper and middle Keys), and the service area for the Key West
    treatment plant would be extended to adjacent areas of the lower Keys. This would
    provide a high level of treatment for about 52% of the  wastewater flows outside
    Key West. Large reductions in nitrogen and phosphorus loadings would be
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                                                      Water Quality Action Plan
achieved in the Key Largo and Marathon service areas where cesspits, OSDS, and
package plants would be replaced by the new community plants.

• Implementation. The responsible agency for this option has not been
determined. Prior to constructing community wastewater treatment plants, it will be
necessary to identify an agency to serve as a wastewater utility. Candidates
include the Florida Keys Aqueduct Authority (FKAA), which already has the
legislative authority to serve as a wastewater utility, and Monroe County. Other
primary agencies likely to be involved are the EPA, FDEP, FDCA, and the Florida
Department of Transportation (FOOT). The FDHRS may have an assisting role.

• Schedule. This activity will have no action in year 1. Time to complete is
unknown.

Option W3b-Upgrade Package Plants with BAT. All package plants would be
upgraded using BAT, which could include advanced wastewater treatment.
Coupled with  elimination of cesspits and enforcement of existing standards for
OSDS, this option would reduce wastewater nutrient loadings to groundwater
Keys-wide. Cost would be much less than for option W3d; however,  this  option
would not provide any additional nutrient reduction from OSDS (including cesspits
eventually replaced by OSDS), which are the leading source of wastewater
nutrients.

• Implementation. The FDEP and the EPA will be the responsible agencies.
Monroe  County will also be involved as a primary agency, and the FDHRS may
have an assisting role.

• Schedule. This activity will have no action in year 1. Time to complete is
unknown.
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                                                          Water Quality Action Plan
                                Strategy W.4:
                           Wastewater Disposal,
                              City of Key West
Upgrade effluent disposal for City of Key West wastewater treatment plant. Evaluate
deep well injection, including the possibility of effluent migrating from the Boulder
Zone into Sanctuary surface waters. Evaluate options for reuse of effluent, including
irrigation and potable reuse. Discontinue use of the existing ocean outfall and
implement deep well injection, aquifer storage, and/or reuse.

Activity 1 — Evaluate Disposal and Reuse Options. Before use of the ocean outfall
is discontinued, both the environmental aspects of deep well injection and the
economics of effluent reuse need to be evaluated thoroughly. Studies of deep well
injection need to investigate the possibility of effluent migrating from the Boulder Zone
into Sanctuary surface waters. Reuse options to be evaluated include irrigation and
further treatment to produce potable water. Reuse for local irrigation may be limited
due to the small number of application sites.  Reuse for irrigation in areas outside the
Florida Keys would be considered only if it were proposed for unincorporated Monroe
County. Potable reuse,  although requiring costly treatment, might be cost-effective in
the long term, considering the current cost of treating and pumping in drinking water
from Florida City.

   • Implementation. The responsible agency will be the  City of Key West, or possibly
   FKAA (if selected as the Keys-wide wastewater utility). Other primary agencies
   involved are the FDEP, EPA, FDCA, and Monroe County.

   • Schedule. This activity will have a low level of action in year 1. It will require 12
   months to complete.

Activity 2-Upgrade Effluent Disposal. Use of the ocean  outfall would be discontinued
(except in emergencies), and effluents would  be disposed through deep well injection,
aquifer storage, and/or  reuse, as appropriate based on resulting of the preceding
activity. This strategy would reduce direct nutrient loadings to surface waters from the
Key West wastewater treatment plant.

   • Implementation. The responsible agency will be the  City of Key West, or possibly
   FKAA (if selected as the Keys-wide wastewater utility). Other primary agencies
   involved are the FDEP, EPA, FDCA, and Monroe County.

   • Schedule. This activity will have no action in year 1. It will require 48 months to
   complete.
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                                                          Water Quality Action Plan
                                Strategy W.5:
                         Water Quality Standards
Develop and implement water quality standards, including biocriteria, appropriate to
Sanctuary resources (corals and seagrasses).

Activity 1-Develop and Evaluate Indicators. This activity will identify and evaluate
indicators (biochemical and ecological measures to provide early warning of
widespread ecological problems) in each type of ecosystem. Examples are tissue
C:N:P ratios, alkaline phosphate activity, and shifts in community structure by habitat.
These measures could be incorporated into the Water Quality Monitoring Program,
and could provide the basis for resource-oriented water quality standards (biocriteria)
for the Sanctuary.

   • Implementation. The EPA and FDEP will be the responsible agencies for this"
   strategy through the Research/Special Studies Program. In addition to the FDEP
   and EPA, NOAA/National Marine Fisheries Service (NMFS) may have a role in
   these studies.

   • Schedule. This activity will have  a low level  of action in year 1. It will require
   36 months to complete.

Activity 2-Develop Water Quality Standards. This activity will develop water quality
standards, including nitrogen and phosphorus standards and biocriteria, appropriate
to Sanctuary resources (corals and seagrasses).  This activity will reduce impacts of
pollution on Sanctuary resources by determining water quality conditions to ensure
resource protection. The intent is to implement water quality standards as guidance in
determining permitted discharge limitations. Outstanding Florida Waters (OFW)
standards will be used until research/special studies indicate that new, more stringent
regulations are necessary.

   • Implementation. The responsible agency for changes to the state's water quality
   standards will be FDEP. The FDEP would need to initiate formal rule-making in
   accordance with Chapter 120 FS - Administrative Procedures Act. Once enacted,
   the new standards would be implemented at the time new permits were being
   issued or existing permits reissued. Other primary agencies involved in developing
   the standards will be the EPA and FDHRS.

   • Schedule. This activity will have  no action in year 1. It will require 60+ months to
   complete.
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                                                        Water Quality Action Plan
                               Strategy W.6:
                       NPDES Program  Delegation
Delegate administration of the National Pollutant Discharge Elimination System
(NPDES) program for Florida to the State of Florida.

Activity 1-Delegate NPDES Program. Under this activity, the EPA would delegate
NPDES permitting authority to the state of Florida, as has been done in many other
states.  This would simplify the permitting process for surface water dischargers by
removing the need to apply for permits from both the EPA and FDEP.

   • Existing Program Implementation. The NPDES program was delegated to the
   state in 1995.

   • Implementation. This activity was implemented by the EPA and FDEP. The EPA
   administers the NPDES permitting program and has the authority to delegate it to
   the states. FDEP submitted an application to the EPA to have the program
   delegated. The two agencies entered into a memorandum of understanding
   (MOD) defining agency roles and responsibilities for NPDES permitting in  Florida.

   • Schedule. This activity has been completed.
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                                                         Water Quality Action Plan
                               Strategy W.7:
              Resource Monitoring of Surface Discharges
Require all NPDES-permitted surface dischargers to develop resource monitoring
programs, including biological monitoring where appropriate.

Activity 1 — Require Resource Monitoring. This activity would help to evaluate
environmental impacts of point-source discharges by requiring all NPDES-permitted
surface dischargers to develop resource monitoring programs. This could be
accomplished in one of two ways. One way would be for the EPA to eliminate the
baseline exemption for resource monitoring under the Ocean Discharge Program, as it
applies to the Florida Keys. All surface dischargers except the City of Key West
sewage treatment plant are currently exempted from developing resource monitoring
programs because  the end of their discharge pipe does not extend beyond the
baseline (the mean low tide line). A second way to accomplish the same goal would
be for the FDEP, through the state of Florida's permitting authority, to require resource
monitoring when individual NPDES permits come up for renewal. This approach
probably would be  easier because it can be accomplished under existing rules,
whereas eliminating the EPA's baseline exemption would require a federal rule
change.

   • Implementation. The EPA and FDEP are the responsible agencies for this
   activity. The EPA could eliminate the baseline exemption as it applies to the
   Florida Keys. Alternatively, the FDEP could require resource monitoring as
   individual NPDES  permits  come up for renewal. The FDEP has the authority to
   require biological/resource monitoring under existing NPDES regulations.

   • Schedule. This activity will have a low level of action in year 1. It will require 36
   months to complete.
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                                                         Water Quality Action Plan
                               Strategy W.8:
                          Wastewater Permitting
Improve interagency coordination for industrial wastewater discharge permitting.
Combine OSDS permitting responsibilities in one agency for commercial
establishments, institutions, and multi-family residential establishments utilizing
injection wells.

Activity 1-Improve Interagency Coordination. This strategy would improve
coordination between the EPA, FDEP, and local government relative to industrial
wastewater discharge permitting and tracking (FDHRS is included for special cases
such as seafood processing plants discharging into septic systems). At  present, much
of the interagency coordination and tracking is handled through a series of
memoranda of agreement (MOAs) and MOUs. These agreements would be reviewed,
evaluated, and revised specifically for the Florida Keys. This could also indirectly
reduce wastewater pollution by refining and simplifying the OSDS permitting process
and increasing funds for compliance monitoring and enforcement.

   • Implementation. The responsible agency will be the FDEP, which will work
   through the Intergovernmental Coordinating Council to review existing MOAs and
   MOUs. Other primary agencies involved are the  EPA and FDHRS.  No new rules or
   governmental structures will be required to implement this  activity.

   • Schedule. This activity will have no action in year 1. It will require 24 months to
   complete.

Activity 2-Combine OSDS Permitting Responsibilities. This activity would combine
FDEP and FDHRS permitting responsibilities for commercial establishments,
institutions, and multi-family residential establishments in one agency. Currently, for
commercial establishments, institutions, and multi-family residential uses with total
daily flows less than 5,000 gallons, the Monroe County Public Health Unit is
authorized to permit the aerobic treatment unit and the filter unit, whereas the FDEP
permits the injection well (borehole). However, effluent from these aerobic systems
does not meet the more stringent wastewater treatment standards of the FDEP.

   • Implementation. The FDEP would be the responsible agency, working closely
   with the FDHRS. The two agencies would enter into an MOU delineating their
   respective roles and responsibilities. The agencies would need to agree on
   establishing the same level of treatment requirements for existing and new or
   innovative OSDS units to be permitted in the Florida  Keys. Once agreement is
   reached, the administrative rules regarding the quality of wastewater being
   discharged into injection wells would be amended.

   • Schedule. This activity will have no action in year 1. It will require 36 months to
   complete.
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                                                          Water Quality Action Plan
Activity 3-Monftor Revised OSDS Rules. This activity will involve designing and
implementing a monitoring program to determine the effectiveness of recent revisions
in Part II of Chapter 10D-6 FAC. Effective March 1992, FDHRS implemented two key
rule changes specifically targeting the Florida Keys. One change makes the use of
Class V underground injection wells (boreholes) an option of last resort. The other
requires placement of a minimum 12-inch-thick filter layer of quartz sand below the
drainfield absorption surface of the OSDS. Data are needed to evaluate whether these
changes are achieving their desired effect.

   • Implementation. The responsible agency will be FDHRS, with primary
   responsibility assigned to the Environmental Administrator of the State Health
   Office. The Monroe County Public Health Unit Environmental Health section would
   provide field staff. The change requiring a 12-inch thick filter layer of quartz sand
   will require finding homeowners with existing  OSDS willing to allow  their units to
   serve as a control group.

   • Schedule. This activity will have no action in year 1. It will require  36 months to
   complete.
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                                                          Water Quality Action Plan
                                Strategy W.9:
                            Laboratory Facilities
Evaluate the feasibility of, and if appropriate, establish an interagency laboratory
capable of processing monitoring and compliance samples.

Activity 1-Conduct Feasibility Study. This activity would evaluate the feasibility of
creating an interagency laboratory facility in the Keys for processing compliance
monitoring samples. Neither the FDEP nor the FDHRS has FDHRS-certified (or
equivalent) laboratory facilities in the Keys. Because of quality control considerations
(holding times), it is difficult or impossible to ship compliance/enforcement samples to
Tallahassee for analysis, and use of contracted private laboratory facilities is
expensive. The agencies should jointly evaluate the feasibility of establishing a
laboratory facility certified by FDHRS or by the quality assurance section of FDEP- The
laboratory would be located in the FDEP office building in Marathon and would  not
process toxics or status and trends samples from the water quality monitoring
program.

    • Implementation. FDEP would be the responsible agency, working with FDHRS
    and possibly Monroe County.

    • Schedule. This  activity will have no action in year 1. It will require 12 months to
    complete.

Activity 2-Establish  Interagency Laboratory. Depending on the outcome of
Activity 1, this activity would create  an interagency laboratory facility for processing
compliance monitoring samples.

    • Implementation. The FDEP would be the responsible agency, working with the
    FDHRS and possibly Monroe County.

    • Schedule. This  activity will have no action in year 1. It will require 36 months to
    complete.
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                                                             Water Quality Action Plan
Stormwater Strategies

This section describes four strategies for reducing pollution from stormwater runoff in
the Keys. The first (W.11) would involve engineering modification of hot spots to
control pollutants in stormwater runoff. The next two strategies (W.12 and W.13) work
together to require enactment of stormwater management ordinances and master
plans that would cover the entire Keys. The fourth (W.14) involves development and
implementation of widely used Best Management Practices and a public education
program to reduce pollutants entering stormwater runoff.
  Stormwater Strategies

  W.11: Stormwater Retrofitting
  • Inventory stormwater hot spots
  • Retrofit hot spots and portions of US 1

  W.12: Stormwater Permitting
  • Eliminate permitting threshold

  W.13: Stormwater Management
  • Develop and enact stormwater ordinances and master
  plans on a continuing, county-wide basis
  • Petition the EPA to include the Florida Keys in the
  stormwater NPDES program

  W.14: Best Management Practices
  • Develop and implement best management practices
  and a public education program
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                                                           Water Quality Action Plan
                               Strategy W.11:
                          Stormwater Retrofitting
Identify and retrofit stormwater hot spots using grass parking, swales, pollution control
structures, and detention/retention facilities. Control stormwater runoff in areas
handling toxic and hazardous materials. Install swales and detention facilities along
limited sections of US 1.

Activity 1-Inventory Stormwater Hot Spots. This activity would involve identifying
stormwater hot spots for possible engineering modification (retrofitting). Currently, no
hot spots specifically attributable to stormwater runoff have been identified, although
stormwater runoff may be a contributing factor in some identified hot spots.

    • Implementation.  Monroe County will be the responsible agency. Other primary
    agencies  involved  are the FDEP, FOOT, and SFWMD.

    • Schedule. This activity will have a low level of action  in year 1.  It will require 12
    months to complete.

Activity 2-Retrofit Hot Spots and Portions of US 1. This activity will involve using
grass parking, swales, pollution control structures, and detention/retention facilities to
control pollutants in stormwater runoff. Hot spots would be identified in activity 1.
Swales and detention facilities would be installed along portions of US 1. Engineering
actions would be taken to control stormwater runoff in areas handling toxic and
hazardous materials.

    • Implementation.  Monroe County will be the responsible agency for stormwater
    retrofitting. Other primary agencies involved are the FDEP, FOOT, and SFWMD.

    • Schedule. This activity will have no action in year 1. It will require 60+ months to
    complete.
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                                                         Water Quality Action Plan
                              Strategy W.12:
                          Stormwater Permitting
Require that no development in the Florida Keys be exempted from the stormwater
permitting process.

Activity 1-Eliminate Permitting Threshold. The SFWMD, which currently has primary
responsibility for stormwater permitting in the Florida Keys, exempts developments of
less than 10 acres in size or 2 acres of impervious surface from having to obtain a
stormwater permit. Most developments in the Keys fall below this threshold. Local
governments are in the process of developing stormwater management ordinances
and/or stormwater management master plans. This strategy would require that the
local government ordinances and master plans cover all developments, with no
minimum size threshold for requiring developments to go through the stormwater
permitting process.

   • Existing Program Implementation. Monroe County's stormwater management
   ordinance is in place and addresses everything that falls below the SFWMD
   permitting threshold. The City of Key West's Land Development Regulations also
   address developments that fall below the SFWMD permitting threshold.

   • Implementation. Each local government (Monroe County and the municipalities)
   will be responsible for implementing its own ordinance within its jurisdictional
   limits. As the state land planning agency for a designated Area of Critical State
   Concern, the  FDCA has an oversight responsibility to ensure that local
   development regulations adequately protect the area's natural resources and are
   consistent with those of their neighbors. The SFWMD may provide technical
   assistance in the development of stormwater ordinances and master plans.

   • Schedule. This activity is  in progress.
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                                                        Water Quality Action Plan
                              Strategy W.13:
                        Stormwater Management
Require local governments to enact and implement stormwater management
ordinances and comprehensive stormwater management master plans. Petition the
EPA to include the Florida Keys in the stormwater NPDES program if adequate
stormwater management ordinances and administrative capability to manage such
ordinances are not in place by a certain date.

This strategy would help to  reduce stormwater pollutant loadings (e.g., sediment,
toxics, and nutrients) by requiring local governments to develop stormwater
management ordinances and master plans. Currently, there is little regulation of
stormwater runoff in the Keys. Many developments were constructed before SFWMD
stormwater permitting requirements were in place, or, if constructed more recently
they fell below the acreage thresholds for those regulations. Monroe County recently
passed a stormwater ordinance, and other local governments are either developing
ordinances and/or have stated in their comprehensive plans that stormwater
management master plans will be developed.

Activity 1-Develop and Enact Stormwater Ordinances and Master Plans on a
Continuing, County-Wide Basis. Under this activity, local governments would enact
ordinances and master plans to control pollutants in stormwater runoff.

    • Implementation. Each local government (Monroe County and the municipalities)
    will be responsible for developing its own stormwater management ordinance.
    Subsequent modifications to each ordinance may be necessary once each local
    government adopts its stormwater management master plan. Under authorities of
    Sections 163.3161 and 380.05 FS, the FDCA has responsibility for ensuring that
    programs and regulatory rules enacted by local governments in Monroe County
    are consistent with the legislative growth management principles described in the
    above-mentioned sections of the Florida Statutes. The SFWMD may provide
    technical assistance in the development of stormwater ordinances and master
    plans.

    • Schedule. This activity will have a medium level of action in year 1. It will require
    12 months to complete.

Activity 2-Petition the EPA to Include the Florida Keys in the Stormwater NPDES
Program.  This activity would provide an alternate means of controlling stormwater
pollutants  in the Keys. It would be implemented only if adequate local stormwater
management ordinances and administrative capability to manage such ordinances are
not in place by the deadlines established under activity 1.

    • Implementation. The responsible  agency will be the FDEP, which would petition
    the EPA to include the Keys in the stormwater NPDES program for municipal
    separate storm sewer systems. Monroe County (including its municipalities)
    currently falls below the population threshold that would trigger the county's
    inclusion in the stormwater NPDES program. However, states may petition the EPA
    to include a local government in the program.

    • Schedule. This activity will have no action in year 1. It will require 24 months to
    complete.
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                                                         Water Quality Action Plan
                              Strategy W.14:
                       Best Management Practices
Institute a series of Best Management Practices and a public education program to
prevent pollutants from entering stormwater runoff.

Activity 1-Develop and Implement Best Management Practices and a Public
Education Program. This activity would reduce pollution from stormwater runoff
through a variety of programs, including street sweeping; ordinances aimed at
controlling fertilizer application on public and private landscaping; collection locations
and a public education program for the proper use and disposal of fertilizers,
pesticides, motor oil, and other hazardous chemicals; and strenuous litter control
programs.

   • Implementation. The responsible agency would be local governments (Monroe
   County and the municipalities). Other primary agencies involved are the FDEP,
   FDCA, and SFWMD. Educational aspects should be coordinated with the
   educational staffs of the Sanctuary (NOAA) and the SFWMD. In addition, the
   FDACS would be involved with respect to fertilizers and pesticides.

   • Schedule. This activity will have a low level of action in year 1. It will require 36
   months to complete.
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                                                               Water Quality Action Plan
Marina and Live-Aboard Strategies

This section describes strategies/activities to reduce pollution from marinas and live-
aboard boaters. Activities within seven strategies have been developed that would
help to reduce pollution from marinas and live-aboards. Four would attempt to reduce
pollution by restricting discharges and educating the public (strategy B.7),
concentrating live-aboards in areas where wastewater treatment facilities can be
provided (strategy Z.5),  and increasing the availability of pumpout facilities
(strategies L.1  and L.6). Strategy L.2 would evaluate interagency cooperation for
marina permitting. Strategy L.3 would reduce pollution from marina operations. The
last strategy (E.4) would reduce pollution from boaters and marinas in general,  by
expanding an existing education/environmental awareness program.

Additional data concerning pollutant concentrations in water and sediments of
marinas and live-aboard areas will be collected through the Water Quality Monitoring
Program described  in strategy W.20.  These data should indicate the severity and
extent of water quality problems, and whether there is a need for further pollution-
control measures.
  Marina and Live-Aboard Strategies

  B.7: Pollution Discharges
  • Implement the 1994 Rorida Clean Vessel Act
  • Develop and implement a public education program
  • Change environmental crimes category

  Z.5: Special-Use Areas
  • Evaluate feasibility of mooring fields
  • Establish criteria for mooring fields
  • Establish mooring fields

  L1: Marina Pumpout
  • Develop plan for sewage discharge elimination
  • Require marina pumpout facilities
  • Enforce pumpout use

  L.6: Mobile Pumpout
  • Establish mobile pumpout service

  L.2: Marina Siting and Design
  • Evaluate interagency cooperation in marina permitting

  L3: Marina Operations
  • Establish containment areas for boat maintenance
  • Encourage marina owners to participate in environmentally-
  oriented organizations
  • Encourage marina owners to provide a user manual with
  local environmental information

  E.4: Training/Workshops/School Programs
  • Expand environmental awareness program
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                                                          Water Quality Action Plan
                                Strategy B.7:
                            Pollution Discharges
Reduce pollution discharges (sanitary wastes, debris, hydrocarbons) from vessels by
implementing the 1994 Florida Clean Vessel Act and developing a public education
program. Change the environmental crimes category associated with discharges from
felony to civil offense, thereby removing the need to prove criminal intent.

Activity 1-Implement the 1994 Florida Clean Vessel Act. The Florida Clean Vessel
Act prohibits boaters from discharging sewage into state waters, effective October 1,
1994. Also, all vessels 26 feet or more in length with an enclosed cabin and berthing
facilities are required to have a toilet. Houseboats and floating structures must, by
October 1,  1996 have permanently installed toilets attached to Type III marine
sanitation devices,  or directly connect their toilets to shoreside plumbing. Full
implementation and enforcement of the Clean Vessel Act would reduce sewage
pollution of Sanctuary waters.

    • Implementation. The agency responsible for enforcing the Clean Vessel Act is
    the Florida Marine Patrol (FMP). NOAA will work with the EPA and the State to
    phase in the implementation of the Clean Vessel Act for Federal waters after full
    public review of the draft rules and public hearings, prior to issuance of final
    regulations. The Sanctuary regulations prohibit all marine sanitation discharges in
    the Replenishment Reserves and Sanctuary Preservation Areas.

    • Schedule. This activity will have  a low level of action in year 1. It will require
    12 months to complete.

Activity 2-Develop and Implement a Public Education Program. This activity would
create a program to educate the boating public about ways to reduce pollution from
vessels. The program would include providing information about the Clean Vessel Act
and other regulations affecting discharges from vessels.

    • Implementation. The lead agency will be the FMP, with assistance from EPA and
    NOAA.

    • Schedule. This activity will have  a low level of action in year 1. It will require
    12 months to complete.

Activity 3-Change Environmental Crimes Category. This activity would change the
environmental crimes category for discharges from felony or misdemeanor to civil
offense, removing the need to prove criminal intent. Currently, it is difficult to prove
criminal intent for actions such as accidently discharging fuel or pumping out a
shipboard sewage  holding tank. Therefore, in practice, law enforcement officers focus
more attention on other crimes that require a less rigorous burden of proof. Making
environmental crimes a civil rather than criminal offense would lead to an increased
level of enforcement of environmental laws. Civil penalties could take the form of
major fines for such accidents without considering the intent of the individual involved.

    • Implementation. The responsible agency will be the FMP. Implementation would
    require  changes in the Florida Statutes and Florida Administrative Code (FAC).
    NOAA and Monroe County may have an assisting role.

    • Schedule. This activity will have  no action in year 1.  It will require 36 months to
    complete.
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                                                           Water Quality Action Plan
                                Strategy Z.5:
                             Special-Use Areas
Establish zones to address special-use activities and concerns within the Sanctuary.
These zones can be used to set aside areas for educational and scientific purposes;
restorative, monitoring, or research activities; or to establish areas that confine or
restrict high-impact activities, such as power boat racing and personal watercraft use,
in order to minimize impacts on sensitive habitats and to reduce user conflicts. This
zone type will also establish live-aboard areas and mooring fields in areas where
adverse environmental impacts will be minimal.

Activity 1-Evaluate Feasibility of Mooring Fields. This activity would evaluate the
feasibility of establishing mooring fields in places having significant concentrations of
live-aboard vessels. The feasibility study would  evaluate whether mooring fields could
be used in conjunction with shore-based or mobile pumpout facilities to provide an
effective means of controlling waste discharges from live-aboard boats.

    •  Implementation.  The  NOAA Sanctuary Office would be the lead agency. Local
    government (Monroe County and/or City of  Key West) may have an assisting role,
    depending on the  location of the mooring field(s).

    •  Schedule. This activity will have a low level of action in year 1. It will require
    12 months to complete.

Activity 2-Establish Criteria for  Mooring Fields. This activity would define criteria for
designating mooring fields, based on the feasibility study conducted in activity 1.

    •  Implementation.  The  NOAA Sanctuary Office would be the lead agency. Local
    government (Monroe County and/or City of  Key West) may have an assisting role,
    depending on the  location of the mooring field(s).

    •  Schedule. This activity will have no action in year 1. It will require 12 months to
    complete.

Activity 3-Establish Mooring Fields. Depending on the outcome of activities 1 and 2,
this activity would establish designated mooring fields or anchorage areas in places
having significant concentrations  of live-aboard  vessels.

    •  Implementation.  The NOAA Sanctuary Office would be the responsible agency
    for designating mooring fields. The FDEP and USCG would assist in implementing
    this  activity by providing sufficient technical  expertise and jointly processing
    required permits. Legal designation of mooring fields requires a permit or land
    lease from the FDEP's  Bureau of Submerged Lands and Preserves. It also requires
    a USCG permit because it affects navigable waters. The FDEP conducts
    environmental inspections of selected sites and issues resource evaluations and
    impact assessments. Local government (Monroe County and/or City of Key West)
    may have an assisting  role, depending on the location of the mooring field(s).

    • Schedule. This activity will have no action in year 1. It will require 36 months to
    complete.
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                                                          Water Quality Action Plan
                                Strategy L.1:
                              Marina Pumpout
Require marinas with 10 or more slips to install pumpout facilities.

This strategy will eliminate marina live-aboard vessels as a source of pollution in the
Sanctuary. Though live-aboards within marinas may be a minor contributor to the total
pollutant load, marinas are normally located in confined waters that may be more
susceptible to the impacts of such loading. By requiring marinas to provide pumpout
facilities, two problems may be resolved: 1) boats in marinas that don't currently
pump out will be provided with the means to do so; and 2) boats that moor outside of
marinas can take advantage of the increased number of pumpout facilities.

Activity 1-Develop Plan for Sewage Discharge Elimination. This activity would
develop a comprehensive plan to deal with the problem of sewage discharges from
live-aboards and other boaters. The plan could include elements such as requiring all
marinas to install pumpout facilities (activity 2),  enforcing pumpout use (activity 3),
establishing a mobile pumpout service (strategy L.6), establishing  mooring fields
(activity 1 under strategy Z.5, Special-use Areas), and evaluating the treatment and
disposal of pumped out wastewater. However, before these activities are undertaken,
a comprehensive study of the options is needed to devise a coordinated approach.

    • Implementation. This activity could be implemented by local government
    (Monroe County and the municipalities). The FDEP and FDCA (the latter through
    its authority set out in Chapter 380 FS—-Critical Area Program), would also have a
    primary role. The EPA, NOAA, and the USCG would assist.

    • Schedule. This activity will have a low level of action in year 1. It will require
    12 months to complete.

Activity 2-Require Marina Pumpout Facilities. This activity would require all marinas
(10 or more slips,  as defined by the State of  Florida) to install pumpout facilities. This
would greatly increase the number and accessibility of pumpout facilities in the Florida
Keys. If pumpout facilities were more numerous and accessible, more people
presumably would use them.

    • Implementation. This activity could be implemented entirely by local government
    (Monroe County and the municipalities), which could pass ordinances requiring all
    marinas offering overnight docking to boats over a given length to have stationary
    or mobile  equipment to pump the holding tanks of such vessels. The same option
    could be implemented at the state or even the federal level, but implementation at
    these levels would be legislatively more complex and would take substantially
    longer to put into practice. Monroe County will actively seek funding and
    coordinate with marinas to facilitate compliance.

    • Schedule. This activity will have no action in year 1. It will require 36 months to
    complete.
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                                                         Water Quality Action Plan
Activity 3-Enforce Pumpout Use. This activity would enforce use of the expanded
pumpout facilities developed under activity 2 of this strategy and the mobile pumpout
service developed under strategy L.6. Although laws already exist that allow the USCG
to restrict discharges from marine sanitation devices, a workable system of
coordinated enforcement procedures has never been developed.  Current pumpout
usage is low,  in part because existing pumpout facilities are few and some are
inaccessible to the public. One possible enforcement tool would involve issuing a
large, visible sticker to all boats anchored or passing through the Sanctuary. Each
time a vessel's holding tanks were pumped out, the sticker would be stamped with
the date and time. If the vessel had not had its holding tanks pumped out within a
given length of time based on its size and carrying capacity, a citation would be
issued.

    • Implementation. The USCG would be the responsible agency. Enforcement must
    be coordinated among the USCG, NOAA Sanctuary staff, FMP, and the Monroe
    County Sheriff's Department. In addition, "boating rights" representatives from the
    Keys need to be represented in any discussions to implement enforcement
    measures. Coordination  could be formalized through a series  of MOUs or
    interlocal agreements.

    • Schedule. This activity will have no action in year 1. It will require 60 months to
    complete.
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                                                          Water Quality Action Plan
                                Strategy L.6:
                              Mobile Pumpout
Establish a mobile pumpout service through the local government, or a franchise with
a private contractor, which would serve to pump out live-aboard vessels moored
outside of marina facilities. Encourage the use of existing, and the construction of
additional, shore-side facilities such as dinghy docks, parking areas, showers, and
laundries for use by live-aboards.

Activity 1-Establish Mobile Pumpout Service. This activity would establish a mobile
pumpout service either through local government or a franchise arrangement with a
private contractor.

   • Implementation. Monroe County would be the responsible agency. No new
   legislation or legal authority is needed for the county to  develop a mobile pumpout
   service. A prototype study could be conducted to determine how many live-aboard
   boaters in a given area would voluntarily subscribe to such a service. If the idea
   appeared to be economically viable, the county could advertise for suppliers of the
   service and sell franchises on a bid basis. The USCG would have an assisting
   role.

   • Schedule. This activity will have no action in year 1. It will require 36 months to
   complete.
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                                                         Water Quality Action Plan
                                Strategy L.2:
                         Marina Siting and Design
Conduct an assessment of marina (10 slips or more) compliance with current
regulations and standards, including OSHA standards for marina operations. Evaluate
interagency cooperation in marina permit review process and initiate action to
eliminate conflicts in agency jurisdictions. Improve marina siting criteria to ensure that
only appropriate deep water access will be permitted and to provide for the proper
handling of noxious materials.

Activity 1-Improve Interagency Cooperation in Marina Permitting. Marina
operations are already subjected to  numerous permits and permit review processes.
This activity would evaluate interagency cooperation to simplify matters for the marina
operator, allow the implementation of Best Management Practices, and help reduce
pollution reaching adjacent coastal waters. The possibility of consolidating permitting
requirements into a single, overall FDEP operating permit would be included in this
evaluation.

    • Implementation. The responsible agency will  be the FDEP. The other primary
    agency involved will be the ACOE. The FDEP and ACOE should consider
    implementing a joint permitting process. Also, the FDEP needs to work with the
    EPA to make Florida a delegated state regarding NPDES stormwater discharge
    regulatory authority. This would avoid duplication in the permitting process.

    • Schedule. This activity will  have no action in year 1. It will require 36 months to
    complete.
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                                                          Water Quality Action Plan
                                Strategy L.3:
                             Marina Operations
Reduce pollution from marina operations by establishing containment areas for boat
maintenance, encouraging marina owners to participate in environmentally-oriented
organizations such as the International Marina Institute, and encouraging marina
owners to provide a user manual with local environmental information such as
locations of pumpout facilities and trash receptacles.

Activity 1-Establish Containment Areas for Boat Maintenance. This activity would
establish paved and curbed containment areas for boat maintenance activities such
as hull scraping and repainting, mechanical repairs, fueling, and lubrication. It would
create secondary containment, generally in the form of curbing or synthetic liners, for
areas where significant quantities of hazardous or toxic materials are stored.
Procedures to avoid or reduce fuel spillage during refueling operations would be
evaluated.

    • Implementation. The responsible agency will be the EPA, working with the
    FDEP. Local governments (Monroe County and the municipalities) may have an
    assisting role. The EPA NPDES stormwater discharge rule is the mechanism to
    implement this activity.  In 1990, the EPA enacted rules to control stormwater
    discharges from a variety of uses. The rule is known as the NPDES Permit
    Application Regulations for Stormwater Discharges. Marinas that are involved in
    boat maintenance activities (including vessel rehabilitation, mechanical repairs,
    painting, fueling, and lubrication) or equipment cleaning operations are considered
    industrial activities according to 40 CFR 122.26. Therefore, all marinas involved in
    such activities must apply for an NPDES stormwater permit. These permits require
    applicants to address how they plan to eliminate pollutants such as toxics from the
    stormwater runoff generated  as a result of their marina activities. The applicants
    have to identify the Best Management Practices they intend to use. One alternative
    is to construct containment areas and restrict all marine repair and boat hull
    reconstruction to these containment areas.

    • Schedule. This activity will  have no action in year 1.  It will require 36 months to
    complete.

Activity 2-Encourage Marina Owners to Participate in Environmentally-oriented
Organizations such as the International Marina Institute.

    • Implementation. The responsible agencies will be Monroe County and the
    municipalities, working with the FDEP.

    • Schedule. This activity will  have no action in year 1.  It will require 12 months to
    complete.
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                                                         Water Quality Action Plan
Activity 3-Encourage Marina Owners to Provide a User Manual with Local
Environmental Information. The information could include locations of pumpout
facilities and trash receptacles, as well as sensitive habitats.

    • Implementation. The responsible agencies will be Monroe County and the
    municipalities, working with the FDEP.

    • Schedule. This activity will have no action in year 1. It will require 12 months to
    complete.
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                                                         Water Quality Action Plan
                               Strategy E.4:
                 Training/Workshops/School Programs
Develop opportunities for instruction and training. This will include programs
conducted by teachers, Sanctuary staff, and volunteers. Training programs (e.g., Coral
Reef Classroom, submerged cultural resources, etc.) will also be provided for
teachers, environmental professionals, business owners and operators, and law
enforcement officials.

Activity 1-Expand Environmental Awareness Program. The FMP already has an
environmental awareness program that has produced significant results in the past. If
this program were expanded, additional reductions in pollution could be expected.

   • Existing Program Implementation. This activity would formalize and expand an
   existing activity—the FMP District 9 environmental education program. The
   program would be enhanced to heighten the environmental awareness of how
   human activities adversely affect water quality in the Keys.

   • Implementation. The FDEP would be the responsible agency in expanding the
   existing program operated by the FMP. All that is required to expand the program
   is additional funding and a management directive from the FDEP to improve and
   increase the range of its existing program. All public awareness programs should
   be coordinated with the educational efforts of the NOAA Sanctuary Office.

   • Schedule. This activity will have a medium level of action in year  1. It will require
   24 months to complete.
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                                                             Water Quality Action Plan
Landfill Strategies

This section describes strategies/activities to deal with potential pollution problems
due to leaching from landfills. All landfill sites in the Florida Keys (with the exception of
the Cudjoe Key expansion) were developed prior to current regulations requiring
bottom liners and leachate collection. At many sites, filling with solid waste probably
occurred below the water table in the early stages. Consistent with common practice
at the time, there was probably little or no control over materials deposited in these
landfills. These conditions indicate a significant potential for contamination of
groundwater and surface waters from these inactive landfills.

Although the potential exists for problems, monitoring data do not indicate leaching or
water quality degradation. Therefore, no corrective actions are proposed. However,
two investigative activities are proposed under strategy L.7, Solid Waste Disposal
Problem Sites. These activities would involve searching for and assessing abandoned
landfills and dumps  (activity 1) and intensifying existing monitoring  programs around
landfills (activity 2) to ensure that no leaching into marine waters is occurring. Under
activity 3, remedial actions would be evaluated and implemented, but only if problems
were discovered under activities 1 or 2.
  Landfill Strategies

  L.7: Solid Waste Disposal Problem Sites
  • Conduct historical landfill search and assessment
  • Intensify landfill monitoring
  • Evaluate and implement remedial actions
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                                                          Water Quality Action Plan
                                Strategy L.7:
                   Solid Waste Disposal Problem Sites
Conduct an assessment to identify solid waste disposal sites that pose threats to
water quality and/or sensitive areas, based on EPA's Water Quality Plan. Intensify
existing monitoring programs around landfills to ensure that no leaching is occurring
into marine waters. If problems are discovered, evaluate and implement appropriate
remedial actions such as boring or mining, upgrading closure, collecting and treating
leachate, constructing slurry walls, and excavating and hauling landfill contents.

Activity 1-Conduct Historical Landfill Search and Assessment. Conduct a
comprehensive search for abandoned landfills and dumps. Evaluate each site to
determine if they contain hazardous materials or are causing environmental problems.
According to knowledgeable state and local government personnel, there are a
number of abandoned landfills and dumps, many on private property, within the
Florida Keys. A comprehensive program needs to  be set up to locate, map, and
evaluate these historic casual dump sites to determine if they contain hazardous
materials, or are causing environmental problems.

   • Implementation. The responsible agency will be Monroe County, working with
   the FDEP. The U.S. Navy would have a primary role in dealing with landfills on its
   property. The EPA would have an assisting role.

   • Schedule. This activity will have no action in  year 1. It will require 36 months to
   complete.

Activity 2-lntensify Landfill Monitoring. Intensify existing monitoring programs
around landfills to ensure that no leaching is occurring into marine waters. Identify
and monitor old landfills that were never permitted, and therefore have no closure
plans or closure permits. This activity would help ensure that existing monitoring
programs are adequate to detect leaching from landfills. Monitoring data from landfills
in the Florida Keys do not indicate that there is a leaching problem. However, the
number of monitoring locations is small, and should be increased to ensure that no
leaching is occurring around these landfills. In addition, this strategy would provide for
monitoring of older landfills that are not currently being monitored.

   • Implementation. The responsible agency will be Monroe County, working with
   the FDEP. The U.S.  Navy would have a primary role in dealing with landfills on its
   property. The EPA would have an assisting role.

   • Schedule. This activity will have no action in year 1. It will require 36 months to
   complete.
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                                                          Wafer Quality Action Plan
Activity 3-Evaluate and Implement Remedial Actions. If problems are discovered,
evaluate and implement appropriate remedial actions such as boring or mining,
upgrading closure, collecting and treating leachate, constructing slurry walls, and
excavating and hauling landfill contents.

    • Implementation. The responsible agency will be Monroe County, working with
    the FDEP. The U.S. Navy would have a primary role in dealing with landfills on its
    property. The EPA would have an assisting role.

    • Schedule. This activity will have no action in year 1. It will require 60+ months to
    complete.
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                                                             Water Quality Action Plan
Hazardous Materials Strategies

This section describes strategies/activities to reduce the likelihood of pollution from
spills of hazardous materials in and near the Keys. The current management
arrangement appears to be functioning adequately; however, there are some actions
that could be taken to further reduce the potential for accidental spills. These
management strategies would enhance spill response (W.15), improve spill reporting
(W.16), and develop an inventory of hazardous materials handling and use in the Keys
(L.10).
  Hazardous Materials Strategies

  W.15: Hazardous Materials Response
  • Develop and revise Sanctuary spill contingency plan
  • Improve coordination and cooperation
  • Improve response/containment technologies

  W.16: Spill Reporting
  • Establish spill reporting system
  • Establish and maintain Sanctuary spills database

  L.10: Hazardous Materials Handling
  • Conduct HAZMAT assessment/inventory
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                                                        Water Quality Action Plan
                              Strategy W.15:
                     Hazardous Materials Response
                                                         •  ':  .•..." . :';' ;•!* '*."•*" '',
Improve and expand oil and hazardous materials response programs throughout the
Sanctuary.

This strategy will reduce the chances that a spill of oil or other hazardous materials
will have a significant negative impact on Sanctuary resources. This will be
accomplished by improving coordination and cooperation among the Federal, State,
and local agencies responding to spills; by encouraging improvements in response
and containment technologies appropriate to the Keys; and by creating a spill
contingency plan for the Sanctuary that includes crew and equipment staged in the
Keys (possibly including skimmers). This strategy recognizes that spills of hazardous
materials are handled independent of marine spills, and improvement measures will
be developed for both response programs.

Activity 1-Develop and Revise Sanctuary Spill Contingency Plan. This activity
would involve creating and periodically revising a spill contingency plan for the
Sanctuary that includes crew and equipment staged in the Keys (possibly including
skimmers).  The plan should cover spills of a size not responded to by the USCG and
should include training and education of a local response team. A USCG marine
safety field  office would be established in the Keys at the location where spill
response equipment would be housed. Because spills of hazardous materials are
handled independent of marine spills, improvement measures will be developed for
both response programs.

    • Implementation. The responsible agencies will be the USCG and FDEP. NOAA,
    Monroe County, and FDCA will assist.

    • Schedule. This activity will have no action in year 1.  It will require 36 months to
    complete.

Activity 2-lmprove Coordination  and Cooperation. This activity will involve improving
coordination and cooperation among the Federal, State, and local agencies
responding to spills.

    • Implementation. The responsible agencies will be the USCG and FDEP. NOAA,
    Monroe County, and the FDCA will assist.

    • Schedule. This activity will have a low level of action in year 1. It will require
    12 months to complete.

Activity 3-lmprove Response/Containment Technologies. This activity would
encourage  improvements  in response and containment technologies appropriate to
the Keys.

    • Implementation. The responsible agencies will be the USCG and FDEP. NOAA,
    Monroe County, and FDCA will assist.

    • Schedule. This activity will have no action in year 1.  It will require 36 months to
    complete.
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                                                          Water Quality Action Plan
                               Strategy W.16:
                               Spill Reporting
Establish a reporting system to ensure that all spills in and near the Sanctuary are
reported to Sanctuary managers. Establish a geo-referenced Sanctuary spills
database.

Activity 1-Establish Spill Reporting System. This activity would establish a reporting
system to ensure that all spills documented by various agencies (e.g., USCG, NOAA,
FDEP) are reported to Sanctuary managers. Small spills in particular are under-
reported; they occur frequently, and therefore may have a significant cumulative effect
on water quality in the Sanctuary.

   • Implementation. The responsible agency will be the USCG. Other primary
   agencies involved are NOAA and the FDEP. The FDEP would assist in reporting
   land-based spills that might affect Sanctuary waters.

   • Schedule. This activity will have a low level of action in year 1. It will require
   12 months to complete.

Activity 2-Establish and Maintain Sanctuary Spills Database. This activity would
establish and maintain a geo-referenced database for the Sanctuary that could be
used to keep track of information about spills (e.g., locations, quantities, types of
material spilled, environmental impacts).

   • Implementation. The responsible agency will be NOAA, with assistance from
   FDEP and the USCG.

   • Schedule. This activity will have no action in year 1. It will require 24 months to
   complete.
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                                                        Wafer Quality Action Plan
                               Strategy L.10:
                      Hazardous Materials Handling
Conduct an assessment and inventory of hazardous materials handling and use in the
Florida Keys including facilities, types and quantities of materials, and
transport/movement. Add information to the FDEP/EPA/Monroe County geographic
information system (GIS) database.

Activity 1-Conduct HAZMAT Assessment/Inventory. This activity would involve
conducting an assessment and inventory of hazardous materials handling and use in
the Florida Keys including  facilities, types and quantities of materials, and
transport/movement. Information will be added to the FDEP/EPA/Monroe County GIS
database.

    • Implementation. The  responsible agency will be the FDEP. Other primary
    agencies involved will be the EPA and Monroe County (e.g., Monroe County
    health  department maintains database on hazardous materials). The FDCA will
    have an assisting role.

    • Schedule. This activity will have no action in year 1. It will require 36  months to
    complete.
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                                                            Water Quality Action Plan
Mosquito Spraying Strategies

This section describes strategies/activities to reduce pollution from pesticides used in
mosquito spraying. There are no data indicating that the Mosquito Control Program is
causing water quality problems in the Sanctuary. However, there is little existing
information on environmental concentrations and/or effects of pesticides in the
Sanctuary. Additional data concerning pesticide concentrations in sediments and
biological tissue throughout the Sanctuary will be collected through the Water Quality
Monitoring Program (strategy W.20).

Based on the considerations discussed above, strategies for major changes to the
Mosquito Control Program are not appropriate at this time. Additional data from the
Water Quality Monitoring Program (strategy W.20) will help to determine whether
major changes are warranted. Two strategies are discussed below. The first (W.17)
will involve making refinements to the existing program. The second  (W.18) will
involve conducting research/special studies on the impacts of pesticide use in the
Keys, and alternative practices. Under strategy W.18, the mosquito control program
could be modified depending on the findings.  Strategy W.18 also includes a field
survey of the full suite of pesticides, herbicides, fungicides, etc. used in the Sanctuary.
  Mosquito Spraying Strategies

  W.17: Mosquito Spraying
  • Review aerial spraying threshold
  • Review flight plans and equipment
  • Reconsider larvicide use
  • Evaluate ultra-low-volume methods

  W.18: Pesticide Research
  • Research impacts and alternatives
  • Modify mosquito control program
  • Conduct field survey of pesticide and herbicide use
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                                                          Water Quality Action Plan
                               Strategy W.17:
                            Mosquito Spraying
Refine the aerial mosquito spraying program to further reduce aerial spraying over
marine areas.

This strategy would seek to reduce the amounts of pesticides entering Sanctuary
waters through refinement of the existing aerial spraying program. Ground spraying by
truck is the current method of choice for controlling the adult mosquito population.
However, aerial spraying is initiated when the mosquito population reaches a certain
threshold as determined by mosquito landing counts at test sites. Although the
Monroe County Mosquito Control District attempts to avoid marine areas during aerial
spraying, the potential for pesticides to reach marine waters might be reduced
through refinements in the program.

Activity 1-Review Aerial Spraying Threshold. The threshold for initiating aerial
spraying will be reviewed to determine whether it can be raised.

    • Implementation. The responsible agency will be the Florida Department of
    Agriculture and Consumer Services (FDACS). Also, FDCA will have an assisting
    role.

    • Schedule. This activity will have a high level of action in year 1. It will require 12
    months to complete.

Activity 2-Review Flight Plans and Equipment. The aerial spraying program would
be reviewed to determine whether the amount of spray released over water could be
reduced through development of a more refined plan for flight lines, and the use of
improved equipment.

    • Implementation. The responsible agency will be the FDACS. Also, the FDCA will
    have an assisting role.

    • Schedule. This activity will have a high level of action in year 1. It will require 12
    months to complete.

Activity 3-Reconsider Larvicide  Use. Ground spraying of larvicides in currently
restricted areas will be reviewed as a means to reduce the need for aerial spraying of
adult mosquito populations.

    • Implementation. The FDACS should be the responsible agency in organizing a
    meeting to discuss this issue. The FDCA will have an assisting role in  this activity.

    • Schedule. This activity will have a high level of action in year 1. It will require 12
    months to complete.
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                                                           Water Quality Action Plan
Activity 4-Evaluate Ultra-Low-Volume Methods. This activity will involve evaluating
the possibility of eliminating thermal fogs, which contain diesel oil. Ultra-low-volume
(ULV) spraying techniques have been developed which do not use thermal fogs and
therefore would eliminate this source of diesel oil in the environment. The use of these
techniques would likely require some additional training of pilots.

    • Implementation. The responsible agency will be the FPACS. Also, the FDCA will
    have an assisting role.

    • Schedule. This activity will have a high level of action in year 1.  It will require 12
    months to complete.
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                                                          Water Quality Action Plan
                               Strategy W.18:
                            Pesticide Research
Develop and implement an independent research program to assess and investigate
the impacts of, and alternatives to, current pesticide practices. Modify the Mosquito
Control Program as necessary on the basis of findings. Conduct a field survey of
pesticide and herbicide use in the Keys.

This strategy will establish an independent research program to identify the impacts
that current spraying practices have on Sanctuary resources, and will identify
alternative means of mosquito control. Because pesticides used in mosquito control
are nonspecific to the larval stages of crustaceans, fish, and natural mosquito control
predators, the effects of the chemicals used, and all of the application methods
employed,  need  to be examined. In addition, the impact of housing patterns, design,
and landscaping as they affect the demand for mosquito control needs to be
investigated. The results of this research may be used to modify the Mosquito Control
Program.

Activity 1-Research Impacts and Alternatives.  A research program will be
established to identify the impacts of current spraying practices on Sanctuary
resources,  and to identify alternative means of mosquito control.

    • Implementation. The responsible agency will be the FDACS. The FDEP will also
    have a  primary role regarding evaluations of pesticide toxicity. FDCA may also
    have an assisting role; as the state land planning agency for a designated Area of
    Critical  State Concern, the FDCA has an oversight responsibility to ensure that
    local development regulations adequately protect the area's natural resources.

    • Schedule. This activity will have no action in year 1. It will require 36 months to
    complete.

Activity 2-Modify Mosquito Control  Program. The results of the pesticide research
program will be used to modify the existing Mosquito Control Program as necessary.

    • Implementation. The responsible agency will be the FDACS. The FDEP will also
    be involved as a primary agency.

    • Schedule. This activity will have no action in year 1. It will require 36+ months to
    complete.

Activity 3-Conduct Field Survey of Pesticide and Herbicide Use. This activity would
involve a field survey of the full suite of pesticides, herbicides, fungicides, etc. used in
the Keys.

    • Implementation. The responsible agency will be the FDACS. The FDEP will also
    be involved as a primary agency.

    • Schedule. This activity will have no action in year 1. It will require 12 months to
    complete.
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                                                            Water Quality Action Plan
Canal Strategies

This section describes strategies/activities to reduce water quality problems in canals.
Although some of these problems are clearly linked to wastewater discharges (from
septic tanks of homes lining the canals), others may be due to the physical structure
and orientation of the canals. These factors can lead to low flushing and buildup of
weed wrack, which consumes oxygen and releases nutrients as it decays. The
strategy described here would inventory and characterize canals and investigate
technologies to determine whether it would be worthwhile to implement corrective
actions such as weed gates and bubblers to improve water quality. Any plan for
implementing such improvements would have to be developed in coordination with
plans for dealing  with wastewater pollution from septic tanks, which contribute to
water quality problems in many canal systems.
  Canal Strategies

  W.10: Canal Water Quality
  • Evaluate and revise hot spot list
  • Inventory and characterize canals
  • Develop and evaluate improvement strategies
  • Revise FDEP permit criteria
  • Identify and compile technologies
  • Develop community education and involvement program
  • Conduct canal system restoration pilot project
  • Implement improvement strategies
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                                                          Water Quality Action Plan
                               Strategy W. 10:
                            Canal Water Quality
Evaluate and revise list of known hot spot canal systems. Inventory and characterize
dead-end canals/basins and investigate alternative management strategies to improve
their water quality. Revise FDEP permit criteria to allow alternative strategies to
improve canal water quality. Identify and compile a list of technologies for canal
restoration. Develop a community education and involvement program, and conduct a
canal system restoration pilot project. Implement improvements (consistent with the
strategies developed for wastewater and stormwater) in known hot spots throughout
the Sanctuary.

Activity 1-Evaluate and Revise Hot Spot List. The SFWMD will conduct a hot spot
workshop in early 1996 to update and prioritize the existing list of hot spots.

       • Implementation. The responsible agency will be the SFWMD. Other agencies
       with primary roles will be the EPA, FDEP,  Monroe County,  and the City of Key
       West.

       • Schedule. This activity will have a low level of action in year 1. It will require
       12 months to complete.

Activity 2-lnventory and Characterize Canals. An inventory of dead-end canals and
other confined water bodies will be conducted to identify areas where reduced
circulation increases the risk of depressed dissolved oxygen, retention of both
dissolved and particulate pollutants and potential impacts on benthic and pelagic
environments. Canals  with water quality problems attributable mainly to their physical
structure and orientation (e.g., allowing weed wrack buildup) rather than wastewater
or stormwater pollutants would be targeted for improvements.

    • Implementation.  The responsible agency will be the FDEP. Other agencies with
    primary roles will be the EPA,  SFWMD, Monroe County, and the City of Key West.

    • Schedule. This activity will have no action in year 1. It will require 12 months to
    complete.

Activity 3-Develop and Evaluate Improvement Strategies. A comprehensive
management plan will be developed for improving water quality in nearshore confined
basins and canals. Potential methods of improving water quality (e.g., aeration, weed
gates, and air curtains) will be tested in limited areas to determine whether
widespread application is appropriate.

    • Implementation.  The responsible agency will be the FDEP. Other agencies with
    primary roles will be the EPA,  SFWMD, Monroe County,  and the City of Key West.

    • Schedule. This activity will have no action in year 1. It will require 24 months to
    complete.
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                                                          Water Quality Action Plan
Activity 4-Revise FDEP Perm ft Criteria. This activity would revise FDEP permit
criteria to allow selected canal water quality improvement strategies.

   • Implementation. The responsible agency will be FDEP. Other agencies with
   primary roles will be the EPA, SFWMD, Monroe County, and the City of Key West.

   • Schedule. This activity will have no action in year 1. It will require 12 months to
   complete.

Activity 5-ldentify and Compile Technologies. This activity would identify and
compile a list of technologies for improving water quality in canals.

   • Implementation. The responsible agency will be FDEP. Other agencies with
   primary roles will be the EPA, SFWMD, Monroe County, and the City of Key West.

   • Schedule. This activity will have no action in year 1. It will require 12 months to
   complete.

Activity 6-Development Community Education and Involvement Program. This
activity would involve developing a community education program, including citizens
monitoring.

   • Implementation. The responsible agency will be FDEP. Other agencies with
   primary roles will be the EPA, SFWMD, Monroe County, and the City of Key West.

   • Schedule. This activity will have no action in year 1. It will require 12 months to
   complete.

Activity 7-Conduct Canal System Restoration Pilot Project.

   • Implementation. The responsible agency will be FDEP. Other agencies with
   primary roles will be the EPA, SFWMD, Monroe County, and the City of Key West.

   • Schedule. This activity will have no action in year 1. It will require 12 months to
   complete.

Activity 8-lmplement Improvement Strategies. Effective improvement strategies
identified through previous activities will be implemented in all canals and basins
identified as hot spots.

   • Implementation. The responsible agency will be the FDEP. Other agencies with
   primary roles will be the EPA, SFWMD, Monroe County, and the City of Key West.

   • Schedule. This activity will have no action in year 1. It will require 60 months to
   complete.
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                                                              Water Quality Action Plan
Monitoring and  Research/Special Studies Strategies


This section includes monitoring and special studies strategies designed to provide
information for management decisions. Previously described strategies that require
information from research/monitoring efforts are W.3 (Wastewater Management
Systems), W.5 (Water Quality Standards), W.11  (Stormwater Retrofitting), and W.19
(Florida Bay Freshwater Flow).

Goals of the Water Quality Monitoring Program (strategy W.20) are the following.

    • Provide long-term, comprehensive information about the status and trends of
    water quality parameters and biological resources in the Sanctuary.

    • Evaluate the effectiveness of remedial actions taken to reduce water pollution.

Goals of the Research/Special Studies Program (strategies W.21 to W.24) are to
identify and understand cause/effect relationships involving pollutants, transport
pathways, and the biological communities of the Sanctuary. The Research/Special
Studies Program is  designed to do the following.

    • Identify and document cause/effect linkages between specific pollutants, water
    quality problems, and ecological impacts;

    • Improve understanding of Sanctuary ecosystems and develop predictive
    capabilities based on that understanding; and

    • Develop innovative tools to detect pollutants, provide early warning of
    widespread ecological problems, and identify cause/effect  relationships.

Other strategies in this section are applicable to both research/special studies and
monitoring. These are W.28 (Regional  Database), W.29 (Dissemination of Findings),
and W.32 (Technical Advisory Committee). Strategy W.32 must be implemented first
to provide technical oversight for the program. Strategy W.28 should also be
implemented  before specific special studies and monitoring efforts are undertaken.
                Monitoring and Research/Special Studies Strategies
  W.20: Water Quality Monitoring Program
  • Develop monitoring implementation plan
  • Identify organization/institution to conduct
  monitoring
  • Establish QA/QC authority and protocols
  • Implement monitoring

  W.21: Special Studies: Predictive Models
  • Conduct modeling workshop
  • Develop modeling implementation plan

  W.22: Special Studies: Wastewater Pollutants
  • Detect wastewater pollutants and ecological
  impacts

  W.23: Special Studies: Other Pollutants and Water
  Quality Problems
  e Estimate other pollutant loadings
  • Identify causal linkages between pollutants and
  ecological impacts
  e Develop & evaluate innovative monitoring tools
  • Conduct research/special studies on global change
W.24: Special Studies: Florida Bay
Influence
• Conduct historical assessment
• Conduct circulation studies
e Conduct ecological studies

W.28: Regional Database
• Conduct user needs assessment
• Develop implementation plan
• Implement & maintain data mgmt system

W.29: Dissemination of Findings
• Establish information exchange network
e Sponsor conferences
• Support journal publication
• Disseminate findings to the public

W.32: Technical Advisory Committee
• Establish technical advisory committee

W.33: Ecological Monitoring Program
(Refer to Research & Monitoring Action Ran)
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                                                          Water Quality Action Plan
                               Strategy W.20:
                    Water Quality Monitoring Program
Conduct a long-term, comprehensive water quality monitoring program as described
in the EPA Water Quality Protection Program.

This strategy will provide long-term, comprehensive information about the status and
trends of water quality parameters and biological resources in the Sanctuary. It will
allow managers to identify or confirm problem areas and determine whether
conditions are improving or degrading. In addition, remedial actions taken to reduce
pollution will be monitored to evaluate their effectiveness. Water column parameters to
be monitored include temperature, salinity, dissolved oxygen, pH, photosynthetically
active radiation, turbidity, nutrients, chlorophyll a, and alkaline phosphatase activity.
Sediment  parameters to be monitored include grain  size, mineralogy, organic content,
nutrients,  metals, pesticides, PCBs, petroleum hydrocarbons, and sewage tracers. In
addition to water and sediment sampling, biological  monitoring of seagrass,
hardbottom, and mangrove communities will be conducted. Seagrass communities
and hardbottom communities (including offshore coral reefs and nearshore
hardbottom areas) will be monitored by in situ sampling and remote sensing.
Changes in the area! coverage  of mangrove communities will be monitored by remote
sensing.

Design of  the Water Quality Monitoring Program is described  in the EPA Water Quality
Protection Program  Phase II Report, Task 6. An Implementation Plan was
subsequently developed which: 1) revised the Program based on available funding;
and 2) developed specific details of program design (e.g., locations of water quality,
coral reef, and seagrass sampling locations).

• Existing Program Implementation. All of the preliminary activities described here
have been completed, and monitoring is in  progress.

• General Implementation. The  responsible  agencies for water quality monitoring will
be the EPA and FDEP. In  addition, the FDEP will be  responsible for establishing and
maintaining the scientific database generated through the monitoring program (see
strategy W.28). Specific institutions, organizations, and/or individuals may be selected
to conduct various aspects of the program. These will be selected  by the EPA and
FDEP working with the Technical Advisory Committee (see strategy W.32).

• General Cost. The monitoring program is expected to cost about $5 million over the
FY 94 to FY 98 planning period. This cost is for actual execution of the program and
is not reflected in the costs for preliminary activities described below.

Activity 1-Develop Monitoring Implementation Plan. This activity will  develop an
implementation plan that will: 1) revise the design of the Monitoring Program based
on anticipated funding; and 2) describe specific steps to be taken in implementing the
Program. Revision of the Program will involve some  combination of reducing the
scope of individual components (e.g., number of stations, transects, etc.) and
prioritizing components to be funded first.

    • Schedule. This activity has been completed.
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                                                           Wafer Quality Action Plan
Activity 2-Select Organization/Institution to Conduct Monitoring. This activity will
involve selecting an organization or institution to conduct the Water Quality Monitoring
Program under the direction of the EPA, FDEP, and the Technical Advisory
Committee.

   • Schedule. This activity has been completed.

Activity 3-Establish Quality Assurance/Quality Control Authority and Protocols.
This activity will involve designating a quality assurance/quality control (QA/QC)
Officer, developing QA/QC protocols for the Monitoring Program, and developing
guidelines for researchers to prepare their own QA/QC plans for research/special
studies projects.
                                                                        \
   • Schedule. This activity has been completed.

Activity 4-lmplement Monitoring. This activity will involve conducting water quality,
coral reef, and seagrass monitoring as described in the Implementation  Plan
developed in activity 1.

   • Schedule. This activity will have a low level of action in year 1. It will require 60+
   months to complete.
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                                                         Water Quality Action Plan
                               Strategy W.21:
                   Special Studies: Predictive Models
Develop phased hydrodynamic/water quality models and coupled landscape-level
ecological models to predict and evaluate the outcome of in-place and proposed
water quality management strategies.

This strategy will develop predictive models which, used with appropriate scientific
guidance, would allow resource managers to predict and evaluate the outcome of
various management strategies (e.g., engineering actions to reduce wastewater
nutrient loadings). Initial conceptual models would be developed, information needs
identified, environmental data gathered, and quantitative models developed and
refined over the long-term and on a continuous basis, to aid in management
decisions.

• General Schedule. This is a long-term strategy that is expected to be ongoing
throughout the fiscal year 1994-98 planning period.

• Existing Program Implementation. The University of Miami's Center for Marine and
Environmental Analysis is undertaking a major, 6-year, multimillion dollar effort to
model various aspects of the South Florida environment.

Activity 1-Conduct Modeling Workshop. This activity will involve conducting a
workshop to discuss modeling approaches, develop preliminary conceptual models,
and define specific information needs for the models.

    • Implementation. The responsible agencies will be the EPA and FDEP.

    • Schedule. This activity will have a high level of action in year 1. It will require 12
    months to complete.

Activity 2-Develop Modeling Implementation Plan. This activity will involve
developing an overall plan for developing predictive models focused on management
needs.  The plan will include discussion of preliminary conceptual models, data needs,
data gathering, and model  development and refinement. The plan will also discuss
mechanisms for ensuring that the modeling effort remains closely tied to management
needs.

    • Implementation. The responsible agencies will be the EPA and FDEP. The NPS
    and SFWMD will have an assisting role because they are involved in model
    development for the Everglades and Florida Bay.

    • Schedule. This activity will have a high level of action in year 1. It will require
    12+ months to complete.
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                                                          Water Quality Action Plan
                               Strategy W.22:
                 Special Studies: Wastewater Pollutants
Conduct special studies to document the fate and ecological impacts of wastewater
pollutants.

Activity 1-Detect Wastewater Pollutants and Ecological Impacts. This activity
involves conducting special studies to: 1) establish pollutant loading thresholds above
which biotic communities are adversely affected; 2) detect the presence of wastewater
pollutants from OSDS, cesspits, package plant boreholes, and/or surface water
dischargers and to determine the relative contributions of each to Sanctuary surface
waters, groundwaters, and/or sediments; 3) document the transport of pollutants and
describe the severity and extent of ecological impacts that can be specifically linked to
these pollutants. The scope includes all sources of wastewater pollutants throughout
the Sanctuary. Potential approaches include experimental studies (laboratory,
mesocosm, in situ or combinations); eutrophication gradient studies; studies of
pollutant transport via groundwater; comparative studies of impacted and
non-impacted sites; historical studies (sclerochronology, geological reconstruction);
geographic comparisons (Keys vs. other areas); use of biochemical and ecological
indicators such as tissue C:N:P ratios,  alkaline phosphate activity, and shifts in
community structure; use of sewage tracers; and high-frequency and/or spatially
intensive water quality sampling.

    • Implementation. The EPA and FDEP will be the responsible agencies for this
    strategy. NOAA may also have a primary role, and Monroe County may assist

    • Schedule. This activity will have a low level of action in year 1. It will require 36
    months to complete.
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                                                         Water Quality Action Plan
                               Strategy W.23:
                    Special Studies: Other Pollutants
                       and Water Quality Problems
Conduct special studies to document the fate and ecological impacts of
non-wastewater pollutants, develop innovative monitoring tools, and examine the
effects of global climate change on the organisms and ecosystems of the Keys.

Activity 1-Estimate Other Pollutant Loadings. This activity will involve documenting
the locations and magnitudes of pollution inputs (other than wastewater) to the
Sanctuary to better understand what areas are at risk. Sources will include those that
are point, nonpoint, and external to the Sanctuary (e.g., permitted discharges, OSDSs,
stormwater runoff, groundwater leachates, marinas,  C-111, Biscayne Bay, Florida Bay,
southwest Florida and oceanic fluxes and gyre-induced upwelling). Pollutants will
include hydrocarbons, heavy metals, and pesticides. Load estimates will be based on
the best available information,  and will include engineering estimates where
applicable.

    • Implementation. The EPA and FDEP will be the responsible  agencies for this
    strategy. Assistance may be provided by NOAA, the NPS, and the SFWMD.

    • Schedule. This activity will have no action in year 1. It will require 36 months to
    complete.

Activity 2-ldentify Causal Linkages Between Pollutants and Ecological Impacts.
This activity will involve conducting research/special studies to identify and document
causal linkages between non-wastewater pollutants  and specific ecological  problems.

    • Implementation. The EPA and FDEP will be the responsible  agencies for this
    strategy. Assistance may be provided by NOAA, the NPS, and the SFWMD.

    • Schedule. This activity will have no action in year 1. It will require 36 months to
    complete.

Activity 3-Develop and Evaluate Innovative Monitoring Tools. This activity would
identify and evaluate innovative monitoring tools and methodologies to detect
pollutants and identify cause/effect relationships involving water quality and biological
resources. New or modified monitoring tools and methodologies  may be needed
because of the unique biota and environmental conditions of the  Sanctuary.

    • Implementation. The EPA and FDEP will be the responsible  agencies for this
    strategy. NOAA will also have a primary role.

    • Schedule. This activity will have no action in year 1. It will require 36 months to
    complete.
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                                                           Water Quality Action Plan
Activity 4-Conduct Research/Special Studies on Global Change. This activity will
involve research/special studies to examine the effects of stresses associated with
global change on the ecosystem. Examples of stresses include temperature, salinity,
frequency and intensity of storms, turbidity, sea level change, ultraviolet and visible
radiation, etc.

    • Implementation. NOAA will be the responsible agency. The EPA, FWS, and
    FDEP will provide assistance.

    • Schedule. This activity will have no action in year 1. It will require 36 months to
    complete.
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                                                         Wafer Quality Action Plan
                               Strategy W.28:
                            Regional Database
Establish a regional database and data management system for recording
research/special studies results and biological, physical, and chemical parameters
associated with Sanctuary monitoring programs.

Activity 1-Conduct User Needs Assessment. This activity will involve contacting
agencies, institutions, and individuals likely to be involved in water quality monitoring
and research/special studies efforts, to determine their needs in terms of data
products.

   • Existing Program Implementation. This activity has been completed.

   • Implementation. The FDEP will be the responsible agency. The EPA and NOAA
   will have a primary role in a committee that will oversee data management efforts.

   • Schedule. This activity has been completed.

Activity 2-Develop Implementation Plan. This activity will involve developing an
implementation plan that addresses all aspects of data management for
research/special studies and monitoring efforts, including information distribution,
storage, archiving, and QA/QC of data input. The regional database will include
biological, physical, and chemical parameters and instrument records, etc. The
implementation plan will discuss existing databases and address issues including
public access, volunteer data entry, GIS integration and compatibility, and integration
of new and historical findings.

   • Existing Program Implementation. This activity has been completed.

   • Implementation. The FDEP will be the responsible agency. The EPA and NOAA
   will also have a primary role in a committee that will oversee data management
   efforts.

   • Schedule. This activity has been completed.

Activity 3-lmplement and Maintain Data Management System.

   • Implementation. The FDEP will be the responsible agency. The EPA and NOAA
   will also have a primary role in a committee that will oversee data management
   efforts.

   • Schedule. This activity will have a low level of action in year 1.  It will require
   60+ months to complete.
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                                                          Water Quality Action Plan
                               Strategy W.29:
                         Dissemination of Findings
Develop a program to synthesize and disseminate scientific research/special studies
and monitoring results,  including an information exchange network, conferences, and
support for the publication of findings in peer-reviewed scientific journals.

This strategy would help to disseminate information about scientific findings among
scientists and resource managers and to the general public.

Activity 1-Establish Information Exchange Network. This activity will develop a
compendium of ongoing and planned research/special studies in the Sanctuary that
will be updated periodically.

    •  Implementation. The EPA and FDEP will be the  responsible  agencies for this
    strategy. NOAA will  have a primary role.

    •  Schedule. This activity will have a low level of action in year 1. It will require
    12 months to complete.

Activity 2-Sponsor Conferences. This activity will involve sponsoring conferences to
keep  both scientists and managers abreast of monitoring and research/special studies
results and existing/planned management actions.

    •  Implementation. The EPA and FDEP will be the  responsible  agencies for this
    strategy. NOAA will  have a primary role.

    •  Schedule. This activity will have no action in year 1. It will require 60+ months to
    complete.

Activity 3-Support Journal Publication. This activity will involve funding publication
of research/special studies and monitoring findings in peer-reviewed scientific and
management journals.

    •  Implementation. The EPA and FDEP will be the  responsible  agencies for this
    strategy. NOAA will  have a primary role.

    •  Schedule. This activity will have no action in year 1. It will require 60+ months to
    complete.

Activity 4-Disseminate Findings to the Public. This activity would use existing
mechanisms and continue to develop mechanisms to synthesize  and disseminate
findings of the research/special studies and monitoring programs to the public.

    •  Implementation. The EPA,  FDEP, and NOAA will be the responsible agencies for
   this strategy. NOAA's annual report will contain  a  synthesis of scientific findings
   written for the average citizen and will be distributed widely.

    •  Schedule. This activity will have no action in year 1. It will require 60+ months to
    complete.
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                                                          Water Quality Action Plan
                               Strategy W.32:
                      Technical Advisory Committee
Establish a technical advisory committee for coordinating and guiding
research/special studies and monitoring activities by both EPA and NOAA.

Activity 1-Establish Technical Advisory Committee. This activity will create a
technical advisory committee as required  by the National Marine Sanctuaries Program
Amendments Act of 1992. The Technical Advisory Committee "shall be composed of
scientists from Federal agencies, State agencies, academic institutions, private
nonprofit organizations, and knowledgeable citizens." It will guide the process of
setting priorities for research/special studies and monitoring.

   • Existing Program Implementation. This activity was completed during fiscal year
   1993, prior to the starting date used in this action plan.

   • Implementation. The EPA and FDEP will be the responsible agencies for this
   strategy. NOAA will have a primary role.
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                                                         Water Quality Action Plan
                               Strategy W.33:
                     Ecological Monitoring Program
Develop and implement a Sanctuary-wide, intensive ecosystem monitoring program.
The objective of the program will be to monitor the status of various biological and
ecological indicators of system components throughout the Sanctuary and adjacent
areas, in order to discern the local and system-wide effects of human and natural
disturbances, and assess the overall health of the Sanctuary.

This strategy will establish a comprehensive, long-term monitoring program
throughout the Sanctuary and adjacent areas that will have three purposes: to supply
resource managers with information on the status of the health of living resources and
the ecosystem; to determine causal relationships related to management decisions;
and to evaluate the effectiveness of management actions such as zoning
implementation.

The Ecological Monitoring Program will be fully integrated with the Water Quality
Monitoring Program, and will include a temporal  and spatial ecological information
system based on current knowledge; a Technical Advisory Committee to assist NOAA
with the design and prioritization of the Research and  Monitoring Program; status and
trends assessments of corals, fishes, seagrasses, benthic organisms and algae,
plankton, and mangroves; a fisheries ecology monitoring and research component to
examine community composition and function within the Sanctuary's habitats; a
sampling protocol; a data analysis, management, and dissemination protocol; a
quality assurance/quality control protocol; the development of an index of Sanctuary
health; and a volunteer monitoring program.

• General Implementation. NOAA will be responsible for the overall implementation of
the Ecological Monitoring Program, working with the EPA, FDEP, academic and
nongovernmental organizations, and the Technical Advisory Committee.  NOAA will
have lead  responsibility for .implementing most activities, but the FDEP will be
responsible for establishing an ecological information system (Activity 1) and data
analysis, management, and  dissemination protocol (Activity 6). The Technical Advisory
Committee will assist NOAA in establishing a sampling protocol (Activity  5).

• General Relationship to Other Strategies. Integration of the Ecological Monitoring
program and the Water Quality Protection Program will be achieved through the
Technical Advisory Committee (TAG) and Management Committee specified in the
Water Quality Protection Program. The TAG will be used by NOAA to assist in the
design and prioritization of the Research and Monitoring Program. The Sanctuary
Superintendent will serve on the Management Committee which coordinates and
facilitates the efforts of the TAG.

• General Schedule. The Ecological Monitoring Program will have a medium level of
action in year 1. It will require 60+ months to complete.
Refer to NOAA's Research and Monitoring Action Plan for a description of
activities.
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                                                          Water Quality Action Plan
                             Implementation


This section explains how the Water Quality Action Plan will be implemented. The
institutions responsible for each activity, and those agencies that will provide some
level of assistance, are identified. In addition, the number of months required to
complete, cost estimates, staff  and equipment requirements, and the geographic
focus of each activity are provided. The section concludes with a description of
contingency planning for changing budgets, and the process used to evaluate the
effectiveness of the Water Quality Action Plan as it evolves over time.

Responsible Institutions. The Water Quality Action Plan will be implemented by a
coordinated framework of Federal, State, and local agencies. The EPA and FDEP,
however, will have the lead responsibility in the overall implementation of the Plan.
They will coordinate closely with NOAA, which has overall responsibility for
implementing the Management Plan for the Sanctuary. Other agencies with lead
responsibility for one or more activities are the USCG,  FDHRS, FDCA, FDACS, FKAA
(possibly), Monroe County, and the municipalities. In addition, the SFWMD has a
primary or assisting role in several strategies. Table 1 lists the responsible institutions
and their level of responsibility  in each activity.

Priority Activities. Each activity included in the Water Quality  Action Plan is ranked as
high, medium, or low priority (Table 2). High-priority strategies (summarized in
Table 3) are those that have the greatest urgency and  are most likely to be
implemented first. A strategy's priority is also based upon its projected effectiveness in
reducing water quality problems in the Sanctuary. Strategies that would reduce
pollution directly,  provide information needed for critical decisions, or allow another
high-priority strategy to be implemented are generally assigned a high priority.
Strategies that might indirectly  reduce pollution by making the management/regulatory
system work more efficiently are generally assigned a low priority. However, some
low-priority strategies might be implemented early if they are simple and inexpensive.

Schedule. Table 2 lists the estimated time required for the implementation of each
strategy and activity included within the program. The number of months required to
complete each strategy and activity is provided. For this action plan, year 1 is defined
as beginning in fiscal year 1994, not in fall 1994 as in other action plans.
                                    ;
Cost. Table 2 also lists estimated costs to implement each strategy and its
component activities. Costs are divided into capital cost, and annual operating and
maintenance costs.

Most of the costs listed in the table are institutional costs  for implementing the
strategies, as developed at the "Institutional Arrangements and Approximate Costs
Work Session" held in the Florida Keys on October 21-22, 1992. However, estimates
for five strategies also include costs for upgrading, constructing, and/or maintaining
facilities:

       W.1 (OSDS Demonstration Project);
       W.2 (AWT Demonstration Project);
       W.3 (Wastewater Management Systems);
       W.4 (Wastewater Disposal, City of Key West); and
       W.11 (Stormwater Retrofitting).
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                                                          Water Quality Action Plan
These costs are from the Phase II report of the EPA Water Quality Protection Program.
Potential funding sources are also discussed in that report. Much more detailed
information on costs and implementation requirements would have to be developed
before these improvements were undertaken.

Based on the figures in Table 2, the cost to implement all activities in the Water
Quality Action  Plan is about $290 million to $510 million. However, much of this total
is accounted for by the following two very expensive strategies.

    • W.3 (Wastewater Management Systems):  At minimum, >$57 million to
      eliminate cesspits and upgrade OSDS (septic systems) to current standards.
       Plus, if chosen as the preferred wastewater treatment option, >$200 million to
      construct two community sewage plants serving Key Largo and Marathon.

    • W.11 (Stormwater Retrofitting): $200 million to implement stormwater
      engineering modifications to hot spots and portions of US 1.

Because of the high costs involved, substantial data collection through prerequisite
strategies (as noted in the strategy  descriptions)  will be necessary for decisions
regarding implementation of either strategy.

The following are additional strategies costing $5 million or more:

    •  L.7 (Solid Waste Disposal Problem Sites): >$10 million to implement remedial
       actions at landfill sites, if necessary. [Note: the most costly activity
       (remediation) is a low priority, because it would be implemented only if
      significant problems were detected through a landfill search and intensified
       monitoring.]

    • W.4 (Wastewater Disposal, City of Key West): >$7 million to upgrade effluent
       disposal (using deep well injection for a minimum estimate).

    • W.33 (Ecological Monitoring Program): $5 million to $7 million to monitor the
      status and trends of various ecological indicators of ecosystem health.

    • W.20 (Water Quality Monitoring Program): About $7 million to monitor status
       and trends in water quality and biological resources.

    • W.14 (Best Management Practices): >$5  million to implement best
       management practices for stormwater runoff.

Excluding the two very expensive strategies discussed above (W.3 and W.11), the
total cost of all strategies is $34 million to $55 million.  (This is based on totaling
strategy costs listed in Table 2).

Geographic Focus. The geographic focus (Sanctuary-wide, Upper Keys, Middle Keys,
or Lower Keys) for each activity is indicated in Table 2. Most of the activities are
Sanctuary-wide in focus. The two demonstration projects (strategies W.1  and W.2) will
be  conducted in specific areas of the Upper or Middle Keys but are intended to
provide broadly applicable information. Strategy  W.4 applies only to Key West.
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                                                         Water Quality Action Plan
Personnel. The staff required to implement the Water Quality Action Plan will be a
combination of personnel from various agencies and organizations identified in
Table 1. In addition, scientists from various universities, research institutions, and
environmental firms may be involved in the Water Quality Monitoring Program
(strategy W.20) and various research/special studies strategies (strategies W.21 to
W.24). Volunteers may be involved in conducting portions of the Water Quality
Monitoring Program, but their role has not yet been identified. The total number of
personnel likely to be involved in implementing each strategy are listed in Table 2.

Equipment. A variety of equipment will be required to implement portions of the Water
Quality Action Plan. Equipment needs cannot be summarized due to the variety and
complexity of activities described. The following strategies are essentially
administrative or "desktop" in nature and should not require equipment purchase:

      W.5: Water Quality Standards
      W.6: NPDES Program Delegation
      W.7: Resource Monitoring of Surface Discharges
      W.8: Wastewater Permitting
      W.12: Stormwater Permitting
      W.13: Stormwater Management
      W.16: Spill Reporting
      W.19: Special  Studies: Florida Bay Freshwater Flow
      W.29: Dissemination of Findings
      W.32: Technical Advisory Committee

Contingency Planning for Changing Budgets. The Water Quality Action Plan
includes a wide variety of strategies and activities that will be implemented by various
agencies and funded  through various mechanisms. A separate study of potential
funding sources was conducted by the EPA, and is included in the Water Quality
Protection Program Phase II Report. The EPA and FDEP, with guidance from the
Technical Advisory Committee (established under strategy W.32), will be responsible
for reprioritizing strategies and activities depending on the available funds.

Evaluating Program  Effectiveness. The EPA and FDEP will report  regularly to the
Steering Committee on the effectiveness of program activities. Each strategy will be
evaluated to determine whether it is being successfully implemented. The evaluation
will identify those types of activities which may no longer be useful and those which
have not been adequately addressed. The Steering Committee will meet regularly to
review and assess the EPA's and  FDEP's evaluation of Program implementation. As
required by the National  Marine Sanctuaries Program Amendments  Act of 1992, the
Steering Committee will prepare a biennial report to Congress that will:

   •  Summarize the progress of the program;
   •  Summarize any modifications to the Program and its recommended actions
      and plans; and
   •  Incorporate  specific recommendations concerning the implementation of the
      Program.
                                     C-65

-------
Table 1. Agencies/Organizations Identified for Implementing Strategies/Activities.
Strategy/Activity
FLORIDA BAY/EXTERNAL INFLUENCES
W.19 Florida Bay Freshwater Flow
Establish Leading Role for Steering Committee
Participate in Review/Revision of Water Management Strategies
W.24 Special Studies: Florida Bay Influence
Conduct Historical Assessment
Conduct Circulation Studies
Conduct Ecological Studies
Agencies/Organizations
N
o
A
A
N
M
F
S


o
o











DOMESTIC WASTEWATER
W.1 OSOS Demonstration Project
Select Alternate OSDS and Test Locations
Conduct OSDS Demonstration Project
W.2 AWT Demonstration Project
Select Specific Technology and Test Location
Conduct AWT Pilot Project
W.3 Wastewater Management Systems
Establish Inspection/Compliance Programs for Cesspits and OSDS
and Continue Existing FDEP Inspection/Compliance Program for
Package Plants
Evaluate Development of Nutrient Reduction Targets
Develop Sanitary Wastewater Master Plan
Implement Master Plan. Examples:
• W3d: Construct two community plants
• W3b: Upgrade package plants to AWT
W.4 Wastewater Disposal, City of Key West
Evaluate Disposal and Reuse Options
Upgrade Effluent Disposal
W.5 Water Quality Standards
Develop and Evaluate Indicators
Develop Water Quality Standards




































o

E
P
A


•
•


•
•
u
S
C
G








U
S
G
S








N
P
S


o
o

•




0
o

o
o

o
•
o

o
•

o
o

•
o


























































W
S


o
o





C
O
E


0
o

X



D
E
P


•
•


•
•

D
H
R
S









D
C
A


0
o





D
A
C
S









D
0
T








S
F
W
M
D
F
K
A
A
Monroe
County


o
o

•



o







0




City
of
Key
West
Other
Munici-
palities























































o
o

•
•

o
•
0

o
•

o
o

•
•

•
•




•

0

X
X





o

o
o






o

0


o
o

































o





































•


•
•




o
o

0
o

o

•

•
o

o
o










O






•
•






















                                                                                                                                                     a
• Lead   o Primary Role    x Assist

-------
Table 1. Agencies/Organizations Identified for Implementing Strategies/Activities (cont.)
Strategy/Activity
W.8 NPDES Program Delegation
Delegate NPDES Program
W.7 Resource Monitoring of Surface Discharges
Require Resource Monitoring
W.8 Wastewater Permitting
Improve Interagency Coordination
Combine OSDS Permitting Responsibilities
Monitor Revised OSDS Rules
W.9 Laboratory Facilities
Conduct Feasibility Study
Establish Interagency Laboratory
Agencies/Organizations
N
O
A
A




STORMWATER
W.11 Stormwater Retrofitting
Inventory Stormwater Hot Spots
Retrofit Hot Spots and Portions of US 1
W.12 Stormwater Permitting
Eliminate Permitting Threshold
W.13 Stormwater Management
Develop and Enact Stormwater Ordinances and Master Plans
Petition the EPA to Include the Keys In the Stormwater NPD^S Program
W.14 Best Management Practices
Develop and Implement Best Management Practices
and a Public Education Program



X
MARINAS AND LIVE-ABOARDS i
B.7 Pollution Discharges
Develop and Implement a Public Education Program
Change Environmental Crimes Category
o
o
X
N
M
F
S









E
P
A
•
•
o

U
S
C
G




U
S
G
S







o



o
0








N
P
S




F
W
S













A
C
O
E





D
E
P
•
•
•
•
•
•
f .'..,-. .:•- :;




0
o

•
o

D
H
R
S


o
o
•
o
0






D
C
A




;

O
O
O

D
A
C
S








X

D
O
T





o
o



S
F
W
M
D





o
o
X
X
o
F
K
A
A




Monroe
County



X
X
City
of
Key
Wo»t




Other
Munlcf-
pantlet









•
•
•
•
•

•
•
•

•
•
•
=_





•
•
•






X


• Lead    o Primary Role   x Assist

-------
Table 1. Agencies/Organizations Identified for Implementing Strategies/Activities (cont.)
Strategy/Activity
Z.5 Special-Use Areas
Evaluate Feasibility of Mooring Fields
Establish Criteria for Mooring Fields
Establish Mooring Fields
l_1 Marina Pumpout
Develop Plan for Sewage Discharge Elimination
Require Marina Pumpout Facilities
Enforce Pumpout Use
L6 Mobile Pumpout
Establish Mobile Pumpout Service
L2 Marina Siting and Design
Improve Interagency Cooperation in Marina Permitting
L3 Marina Operations
Establish Containment Areas for Boat Maintenance
Encourage Marina Owners to Participate in Environmental Organizations
Encourage Marina Owners to Provide a User Manual

E.4 Training, Workshops, and School Programs
Expand Environmental Awareness Program
Agencies/Organizations
N
O
A
A

•
•
•

X

o









o
N
M
F
S


















E
P
A





X





X

•




U
S
C
G



o

X

•

X








U
S
G
S


















N
P
S



















W
S



















C
O
E











0







D
E
P



o

o

o



•

o
o
o

•

D
H
R
S



















D
C
A





o













D
A
C
S



















D
O
T


















S
F
W
M
D


















F
K
A
A


















Monroe
County

X
X
X

•
•
O

•



X
•
•


City
of
Koy
Wml

X
X
X

•
•






X
•
•


Other
Munlct-
paHflai





•
•






X
•
•


LANDFILLS •.•..•<>--,.:,,: ....... . --,-,-: .4 ', , v,;; n . , .. ;. -1. .-->.".-• -.-r". •:.-.&.•& -•• •',:•:•/ ••..•.-••••.',:'••.•(.:•'.
L7 Solid Waste Disposal Problem Sites
Conduct Historical Landfill Search and Assessment
Intensify Landfill Monitoring
Evaluate and Implement Remedial Actions
HAZARDOUS MATERIALS
W.15 Hazardous Materials Response
Develop and Revise Sanctuary Spill Contingency Plan
Improve Coordination and Cooperation
Improve Response/Containment Technologies










X
X
X





X
X
X











•
•
•
































o
o
o






•
•
•















X
X
X




































•
•
•










X
X
X








                                                                                                                                                      §
• Lead    o Primary Role   x Assist

-------
Table 1. Agencies/Organizations Identified lor Implementing Strategies/Activities (cont.)


Strategy/Activity


W.1 6 Spill Reporting
Establish Spill Reporting System
Establish and Maintain Sanctuary Spills Database
L10 Hazardous Materials Handling
Conduct HAZMAT Assessment/Inventory
Agencies/Organizations

o
A
A


o
•



M
F
S







P
A






o

S
C
G


•
X



S
G
S







P
S








w
S








C
o
E







D
E
P


o
X

•
MOSQUITO SPRAYING -
W.1 7 Mosquito Spraying
Review Aerial Spraying Threshold
Review Flight Plans and Equipment
Reconsider Larvicide Use
Evaluate Ultra-low-volume Methods
W.1 8 Pesticide Research
Research Impacts and Alternatives
Modify Mosquito Control Program
Conduct Field Survey of Pesticide and Herbicide Use


















CANALS ;
W.10 Canal Water Quality
Evaluate and Revise Hot Spot List
Inventory and Characterize Canals
Develop and Evaluate Improvement Strategies
Revise FDEP Permit Criteria
Identify and Compile Technologies
Develop Community Education and Involvement Program
Conduct Canal System Restoration Pilot Project
Implement Improvement Strategies















































o
o
o
o
o
o
o
o



















































o
o
o

D
H
R
S












































o

















D
C
A





X
i,.

X
X
X
X

X



D
A
C
S






D
O
T


























F
W
M
D






K
A
A







County






O

CHy
of
Kay
West







Nhinld-
piHUai







" -~r ~ ™_



























.




























•
O
o
o
o
o
o
o










O
o
O
O
O
O
O
O




















O
O
o
o
0
o
o
o









                                                                                                                                                     TJ
                                                                                                                                                     §
• Lead    o Primary Role   x Assist

-------
 Table 1.  Agencies/Organizations Identified for Implementing Strategies/Activities (cont.)


Strategy/Activity


Agencies/Organizations

O
A
A


M
F
S


P
A



S
C
G


S
G
S


P
S



W
S



C
O
E


D
E
P


D
H
R
S
MONITORING AND RESEARCH/SPECIAL STUDIES «
W.20 Water Quality Monitoring Program
Develop Monitoring Implementation Plan
Identify Organization/Institution to Conduct Monitoring
Establish QA/QC Authority and Protocols
Implement Monitoring
W.21 Special Studies: Predictive Models
Conduct Modeling Workshop
Develop Modeling Implementation Plan
W.22 Special Studies: Wastewater Pollutants
Detect Wastewater Pollutants and Ecological Impacts
W.23 Special Studies: Other Pollutants and Water Quality Problems
Estimate Other Pollutant Loadings
Identify Causal Linkages Between Non-wastewater
Pollutants and Ecological Impacts
Develop and Evaluate Innovative Monitoring Tools
Conduct Research/Special Studies on Global Change
W.28 Regional Database
Conduct User Needs Assessment
Develop Implementation Plan
Implement and Maintain Data Management System
W.29 Dissemination of Findings
Establish Information Exchange Network
Sponsor Conferences
Support Journal Publication
Disseminate Findings to the Public
W.32 Technical Advisory Committee
Establish Technical Advisory Committee
W.33 Ecological Monitoring Program









o

X
X

o
•

0
o
o

0
o
o
•

o




























•
•
•
•

•
•

•

•
•

•
X

o
o
o

•
•
•
•

•





























































X



X
X





























X







































•
•
•
•

•
•

•

•
•

•
X










•




























D
C
A






























D
A
C
S

D
O
T


F
W
M
D

K
A
A


County



of
Koy
Wmt


Munlcl-
palffloi


.'.•••..;' - -' '•"' '/• " •':•••,':•"<.'





























































•X



X
X


















































X







































































Refer to Research and Monitoring Action Plan
                                                                                                                                                                             S
                                                                                                                                                                              3
• Lead    o Primary Role    x Assist

Abbreviations:  NOAA, National Oceanic and Atmospheric Administration; NMFS. National Marine Fisheries Service; EPA, U.S. Environmental Protection Agency; USCQ, U.S. Coast Guard- USGS  U S
Geological Survey; NPS, National Park Service; FWS, U.S. Fish and Wildlife Service; ACOE, U.S. Army Corps of Engineers; FDEP, Florida Department of Envfronmental Protection; FDHRS, Florida
Department of Health and Rehabilitative Services; FDCA, Florida Department of Community Affairs; FDACS, Florida Department of Agriculture and Consumer Services; FOOT, Florida Department of
Transportation; SFWMD, South Florida Water Management District; FKAA. Florida Keys Aqueduct Authority.

-------
Table 2. Schedule and Requirements for Implementation.

Strategy/Activity


Priority

Implementation
Planned
Level of
Activity in
Year!
FLORIDA BAY/EXTERNAL INFLUENCES
W.19 Florida Bay Freshwater Flow
Establish Leading Role for Steering
Committee
Participate in Review/Revision of Water
Management Strategies
W.24 Special Studies: Florida Bay
Influence
Conduct Historical Assessment
Conduct Circulation Studies
Conduct Ecological Studies
•




•




Medium
Done

Medium

High

High
High
Low
Months
to
Complete
• .:•.-. ••". ••:,
36+
0

36+

48
-
12
48
36
Funding
Available
to
Complete
Cost to Complete
Institutional
Capital
($1.0005)

100%
100%

100%

<50%

<50%
<50%
<50%
NC
NC

NC

NC

NC
NC
NC
O&M
(SI.OOOs)
Engineering/Facilities
Capital
($1 ,000s)

10-99
10-99

10-99

100-999+

10-99
100-999
100-999
O&M
($1 ,000s)
Total
($1 ,000s)

Geographic


No. of

;:.:-". -,;. ..'] ' • . .-. . :


10-99
10-99

10-99

100-999+

10-99
100-999
100-999

SW

sw



SW
sw
sw
1-2




3-5




DOMESTIC WASTEWATER a
W.1 OSDS Demonstration Project
Select Alternate OSDS and Test Locations
Conduct OSDS Demonstration Project
W.2 AWT Demonstration Project
Select Specific Technology and Test
Location
Conduct AWT Pilot Project
W.3 Wastewater Management Systems

Establish Inspection/Compliance Programs
for Cesspits and OSDS and Continue
Existing FDEP Program for Package Plants
Evaluate Development of Nutrient
Reduction Targets
Develop Sanitary Wastewater Master Plan
Implement Master Plan. Examples:
• W3d: Construct Two Community Plants

• W3b: Upgrade Package Plants to AWT
•


•



•











Low
Done
Low
Low
Low

Low
High

High


Low

None
None



36
0
36
36
12

36
36+

36


12

36
?



100%
100%
100%
100%
100%

100%
<50%

<50%


<50%

<50%
0%



10-99
NC
10-99
10-99
NC

10-99
5,000-
10,000
NC


NC

NC

5,000-
10,000
NC
10-99
1-9
10-99
10-99
1-9

10-99
1,000-
5,000
100-999


10-99

10-99

1,000-
5,000
10-99
30-60

30-60
300-600


300-600
98,000-
226,000
42,000






184,000

56,000
25-50

25-50
17-33


17-33
5,250

NC






5,250

400
100-999
1-9
100-999
100-999
1-9

100-999
> 57,000-
> 257,000
>57.000


10-99

10-99

>200.000

>56,000

UK, MK
UK, MK

UK, MK

UK, MK


SW


SW

SW

SW

SW
1-2


1-2





3-5


3-5



11-25

1-2
                                                                                                                                                        f
                                                                                                                                                        §•
                                                                                                                                                        TJ
                                                                                                                                                        §
 Abbreviations: SW, Sanctuary Wide; UK, Upper Keys; MK, Middle Keys; LK, Lower Keys; O&M, operations and maintenance.

 Priority:   • = High     o = Medium    x = Low

-------
Table 2. Schedule and Requirements for Implementation (cont.)
Strategy/Activity
W.4 Wastewater Disposal, City of Key
West
Evaluate Disposal and Reuse Options
Upgrade Effluent Disposal
W.5 Water Quality Standards
Develop and Evaluate Indicators
Develop Water Quality Standards
W.6 NPDES Program Delegation
Delegate NPDES Program
W.7 Resource Monitoring of Surface
Discharges
Require Resource Monitoring
W.8 Wastewater Permitting
Improve Interagency Coordination
Combine OSDS Permitting Responsibilities
Monitor Revised OSDS Rules
W.9 Laboratory Facilities
Conduct Feasibility Study
Establish Interagency Laboratory
Priority
•


o


X

X

X



X


Implementation
Planned
Level of
Activity In
YeaM
Low
Low
None
Low
Low
None
Done
Done
Low
Low
None
None
None
None
None
None
None
Months
to
Complete
48
12
48
60+
36
60+
0
0
36
36
36
24
36
36
36
12
36
Funding
Available
to
Complete
<50%
?
<50%
<50%
<50%
<50%
100%
100%
100%
100%
100%
100%
?
?
<50%
<50%
<50%
Cost to Complete
Institutional
Capital
($1 ,OOOS)
NC
NC

NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
10-99
10-99
10-99
O&M
($1 ,000s)
100-999
100-999

100-999
100-999
10-99
10-99
10-99
10-99
10-99
100-999
10-99
10-99
10-99
100-999
10-99
100-999
Engineering/Facilities
Capital
($1 ,000s)
7,000

7,000
O&M
($1 ,000s)
225

225





Total
($1 ,000s)
> 7,000
100-999
> 7,000
100-999
100-999
100-999
10-99
10-99
10-99
10-99
100-999
10-99
10-99
10-99
100-999
10-99
100-999
Geographic
Focus


LK

SW
SW

SW

SW

SW
SW
SW

MK
MK
No. of
Personnel
3-5


3-5


1-2

1-2

3-5



3-5


STORMWATER -e .<-. -^r.\%-. X-.-iv f • . -•-•*. , -.: V ^ . . • '• :' ' : = ? -' ":::' ^A-; ,. .. :. • , -.- ,
W.11 Stormwater Retrofitting
Inventory Stormwater Hot Spots
Retrofit Hot Spots and Portions of US 1
W.I 2 Stormwater Permitting
Eliminate Permitting Threshold
W.13 Stormwater Management
Develop and Enact Stormwater Ordinances
and Master Plans
Petition EPA to Include the Florida Keys in
the Stormwater NPDES Program
o


o

o


Low
Low
None
Done
Done
Medium
Medium
None
60+
12
60+
0
0
24
12
24
<50%
<50%
0
100%
100%
100%
100%
100%
>1 0,000
NC
> 10.000
NC
NC
NC
NC
NC
> 5,000
10-99
> 5,000
NC
NC
100-999
100-999
10-99
80,000

80,000
6,000

6,000


200,000
10-99
200,000
NC
NC
100-999
100-999
10-99

SW
SW

SW

SW
SW
6-10


None

1-2


                                                                                                                                                        I
                                                                                                                                                        I
                                                                                                                                                        •5-'
                                                                                                                                                        I.
                                                                                                                                                        §
                                                                                                                                                        5
Abbreviations: SW, Sanctuary Wide; UK, Upper Keys; MK, Middle Keys; LK, Lower Keys; O&M, operations and maintenance.

Priority:  • = High    o = Medium    x = Low

-------
Table 2. Schedule and Requirements for Implementation (cont.)
Strategy/Activity
W.14 Best Management Practices
Develop and Implement Best Management
Practices and a Public Education Program
Priority
0
Implementation
Planned
Level of
Activity in
YeaM
Low
Low
Months
to
Complete
36
36
Funding
Available
to
Complete
<50%
<50%
Cost to Complete
Institutional
Capital
($1 ,000s)
100-999
100-999
O&M
($1,0003)
1,000-
5,000
1,000-
5,000
Engineering/Facilities
Capital
($1 ,000s)

O&M
($1 ,000s)

Total
($1 ,000s)
> 5,000
>5,000

Geographic
Focus
SW
No. of
Personnel
3-5
MARINAS AND LIVE-ABOARDS
B.7 Pollution Discharges
Implement the 1994 Florida Clean Vessel
Act
Develop and Implement a Public Education
Program
Change Environmental Crimes Category
Z.5 Special-Use Areas
Evaluate Feasibility of Mooring Fields
Establish Criteria for Mooring Reids
Establish Mooring Fields
L1 Marina Pumpout
Develop Plan for Sewage Discharge
Elimination
Require Marina Pumpout Facilities
Enforce Pumpout Use
L.0 Mobile Pumpout
Establish Mobile Pumpout Service
L2 Marina Siting and Design
Improve Interagency Cooperation In
Marina Permitting
L3 Marina Operations
Establish Containment Areas for Boat
Maintenance
Encourage Marina Owners to Participate in
Environmental Organizations
Encourage Marina Owners to Provide a User
Manual with Local Environmental Information
o
o

o
X
o
Low
Low
Low
None
Low
Low
None
None
Low
Low
None
None
None
None
None
None
None
None
None
None
36
12
12
36
36
12
12
36
60
12
36
60
36
36
36
36
36
36
12
12
<50%
<50%
<50%
<50%
<50%
<50%
<50%
100%
100%
<50%
<50%
<50%
100%
100%
<50%
<50%
100%
100%
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
100-999
10-99
10-99
10-99
10-99
10-99
100-999
10-99
10-99
10-99
10-99
10-99
10-99
10-99
10-99
10-99
NC
NC






100-999
10-99
10-99
10-99
10-99
10-99
100-999
10-99
10-99
10-99
10-99
10-99
10-99
10-99
10-99
10-99
NC
NC
SW
sw
sw
sw
sw
sw
sw
sw
sw
sw
sw
sw
sw
sw
3-5

3-5
3-5
3-5
3-5
Abbreviations: SW, Sanctuary Wide; UK, Upper Keys; MK. Middle Keys; LK, Lower Keys; O&M, operations and maintenance.
Priority:  • = High    o = Medium    x = Low

-------
Table 2. Schedule and Requirements for Implementation (cont.)
Strategy/Activity
E.4 Training, Workshops, and School
Programs
Expand Environmental Awareness Program
Priority
o

Implementation
Planned
Level of
Activity in
Yearl
Medium
Medium
Months
to
Complete
24
24
Funding
Available
to
Complete
<50%
<50%
Cost to Complete
Institutional
Capital
($1 ,000s)
10
10
O&M
($1,0003)
5
5
Engineering/Facilities
Capital
($1 ,000s)


O&M
($1,0008)


Total
($1 ,000s)
20
20
Geographic
Focus

sw
No. of
Personnel
1-2

LANDFILLS
L.7 Solid Waste Disposal Problem Sites
Conduct Historical Landfill Search and
Assessment
Intensify Landfill Monitoring
Evaluate and Implement Remedial Actions
o



None
None
None
None
60+
36
36
60+
<50%
<50%
<50%
<50%
<10
NC
<10
<10
1,000-
5,000
10-99
10-99
1,000-
5,000

> 10,000
10-99
10-99
> 10,000

sw
sw
sw
1-2



HAZARDOUS MATERIALS
W.15 Hazardous Materials Response
Develop and Revise Sanctuary Spill
Contingency Plan
Improve Coordination and Cooperation
Improve Response/Containment
Technologies
W.1 6 Spill Reporting
Establish Spill Reporting System
Establish and Maintain Sanctuary Spills
Database
L.10 Hazardous Materials Handling
Conduct HA2MAT Assessment/Inventory
o


X


0

Low
None
Low
None
Low
Low
None
None
None
36
36
12
36
24
12
24
36
36
<50%
<50%
100%
<50%
<50%
?
<50%
?
?
10-99
10-99
NC
10-99
<10
NC
<10
NC
NC
100-999
10-99
10-99
10-99
10-99
10-99
10-99
10-99
10-99



100-999
100-999
10-99
10-99
10-99
10-99
10-99
10-99
10-99
sw
sw
sw

sw
sw

sw
1-2


1-2


1-2

MOSQUITO SPRAYING , ,= v> , - L
W.I 7 Mosquito Spraying
Review Aerial Spraying Threshold
Review Flight Plans and Equipment
Reconsider Larvicide Use
Evaluate Ultra-low-volume Methods
•




High
High
High
High
High
12
12
12
12
12
75-99%
75-99%
75-99%
75-99%
75-99%
10-99
NC
10-99
NC
NC
10-99
10-99
10-99
10-99
10-99

10-99
10-99
10-99
10-99
10-99

sw
sw
sw
sw
3-5




                                                                                                                                                        !

Abbreviations: SW, Sanctuary Wide; UK, Upper Keys; MK, Middle Keys; LK, Lower Keys; O&M, operations and maintenance.
Priority:   • = High    o = Medium    x = Low

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Table 2. Schedule and Requirements for Implementation (cont.)

Strategy/Activity
*
W.I 8 Pesticide Research
Research Impacts and Alternatives
Modify Mosquito Control Program
Conduct Field Survey of Pesticide and
Herbicide Use

Priority

•




Implementation
Planned
Level of
Activity in
Yearl
None
None
None
None

Months
to
Complete
36+
36
36+
12

Funding
Available
to
Complete
<50%
<50%
<50%
<50%

Cost to Complete
Institutional
Capital
(SI ,000s)
NC
NC
?
NC

O&M
($1 ,000s)
100-999
100-999
?
10-99

Engineering/Facilities
Capital
($1,0005)





O&M
($1.0005)





Total
($1 ,000s)
100-999+
100-999
?
10-99


Geographic


SW
sw
SW


No. of

3-5




:eANALS«-*i?aw»^:»^?-- •.••*•-.•* v^; ;.•:-•
W.1 0 Canal Water Quality
Evaluate and Revise Hot Spot List
Inventory and Characterize Canals
Develop and Evaluate Improvement
Strategies
Revise FDEP Permit Criteria
Identify and Compile Technologies
Develop Community Education and
Involvement Program
Conduct Canal System Restoration Pilot
Project
Implement Improvement Strategies 	
•











Low
Low
None
None

None
None
None

None

None
80+
12
12
24

12
12
12

12

60
<50%
<50%
<50%
<50%

100%
<50%
<50%

<50%

<50%
100-999
NC
NC
10-99

NC
NC
NC

100-999

1130-999
100-999
10-99
10-99
10-99

10-99
10-99
10-99

100-999

100-999

100-999
10-99
10-99
10-99

10-99
10-99
10-99

100-999

100-999

sw
sw
sw

sw
sw
sw

sw

sw
1-2











MONITORING AND RESEARCH/SPECIAL STUDIES v
W.20 Water Quality Monitoring Program
Develop Monitoring Implementation Plan
Identify Organization/Institution to Conduct
Monitoring
Establish QA/QC Authority and Protocols
Implement Monitoring
W.21 Special Studies: Predictive Models
Conduct Modeling Workshop
Develop Modeling Implementation Plan
•





o


High
Done
Done

Done
Low
High
High
High
60+
0
0

0
60+
12+
12
12+
<50%
100%
100%

100%
<50%
<50%
<50%
<50%
NC
NC
NC

NC
NC
NC
NC
NC
5,000+
10-99
<10

10-99
5.000
100-999
10-99
10-99


5,000+
10-99
<10

10-99
5,000
100-999
10-99
10-99

sw
sw

sw
sw

sw
sw
3-5





3-5


Abbreviations: SW, Sanctuary Wide; UK, Upper Keys; MK, Middle Keys; LK, Lower Keys; O&M, operations and maintenance.
Priority:  • = High    o = Medium    x = Low

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Table 2. Schedule and Requirements for Implementation (cont.)
Strategy/Activity
W.22 Special Studies: Wastewater
Pollutants
Detect Wastewater Pollutants and
Ecological Impacts
W.23 Special Studies: Other Pollutants
and Water Quality Problems
Estimate Other Pollutant Loadings
Identify Causal Linkages Between Non-
Wastewater Pollutants and Ecological
Impacts
Develop and Evaluate Other Monitoring
Tools
Conduct Research/Special Studies on
Global Change
W.28 Regional Database
Conduct User Needs Assessment
Develop Implementation Plan
Implement and Maintain Data Management
System
W.29 Dissemination of Findings
Establish Information Exchange Network
Sponsor Conferences
Support Journal Publication
Disseminate Rndings to the Public
W.32 Technical Advisory Committee
Establish Technical Advisory Committee
W.33 Ecological Monitoring Program
Priority
•

o




•



X




•

Implementation
Planned
Level of
Activity in
Yearl
Low
Low
None
None
None
None
None
High
Done
Done
Low
Low
Low
None
None
None
Done
Done
Months
to
Complete
36
36
38
36
'36
36
36
60+
0
0
60+
60+
12
60+
60+
60+
0
0
Funding
Available
to
Complete
<50%
<50%
<50%
<50%
<50%
<50%
<50%
<50%
100%
100%
<50%
<50%
<50%
<50%
<50%
<50%
100%
100%
Cost to Complete
Institutional
Capital
($1,0008)
NC
NC
NC
NC
NC
NC
NC
<10
NC
<10
<10
<10
<10
NC
NC
NC
NC
NC
O&M
($1,OOOs)
100-999
100-999
100-999
100-999
100-999
100-999
100-999
10-99
10-99
10-99
10-99
100-999
10-99
10-99
10-99
10-99
10-99
10-99
Engineering/Facilities
Capital
($1 ,OOOS)


O&M
($1.0003)






Total
($1 ,000s)
100-999
100-999
100-999
100-999
100-999
100-999
100-999
10-99
10-99
10-99
10-99
100-999
10-99
10-99
10-99
10-99
10-99
10-99
Geographic
Focus

SW

sw
SW
sw
sw

sw
sw
sw

sw
sw
sw
sw

sw
No. of
Personnel
3-5

3-5




1-2



3-5




3-5

Refer to Research and Monitoring Action Plan
                                                                                                                                                       I
                                                                                                                                                       I
                                                                                                                                                       I
Abbreviations: SW, Sanctuary Wide; UK, Upper Keys; MK, Middle Keys; LK, Lower Keys; O&M, operations and maintenance.

Priority:  • = High    o = Medium    x = Low

-------
                                                                      Water Quality Action Plan
Table 3.  High-Priority Strategies/Activities.
Strategy/Activity
FLORIDA BAY/EXTERNAL INFLUENCES
W.19 Florida Bay Freshwater Flow
• Establish Leading Role for Steering Committee
• Participate in Review/Revision of Water
Management Strategies
W.24 Special Studies: Florida Bay Influence
• Conduct Historical Assessment
• Conduct Circulation Studies
• Conduct Ecological Studies
Rationale

Addresses a potentially major, external influence on
water quality in the Sanctuary. The Sanctuary must be
involved in decisions affecting its jurisdiction.
Addresses a potentially major, external influence on
water quality in the Sanctuary. Florida Bay influence
must be considered in decisions regarding wastewater
management systems (strategy W.3) and in restoring
freshwater flow to Florida Bay (strategy W.19).
DOMESTIC WASTEWATER '
W.1 OSDS Demonstration Project
• Select Alternate OSDS and Test Locations
• Conduct OSDS Demonstration Project
W.2 AWT Demonstration Project
• Select Specific Technology and Test Location
• Conduct AWT Pilot Project
W.3 Wastewater Management Systems
• Establish Inspection/Compliance Programs for
Cesspits and OSDS and Continue Existing
FDEP Program for Package Plants
• Evaluate Development of Nutrient Reduction
Targets
• Develop Sanitary Wastewater Master Plan
• Implement Master Plan
W.4 Wastewater Disposal, City of Key West
• Evaluate Disposal and Reuse Options
• Upgrade Effluent Disposal
W.22 Special Studies: Wastewater Pollutants
• Detect Wastewater Pollutants and Ecological
Impacts
Provides critical information for decisions regarding
wastewater management systems (strategy W.3).
Provides critical information for decisions regarding
wastewater management systems (strategy W.3).
Will lead to major reductions in wastewater nutrient
loading to Sanctuary waters through enforcing existing
standards, upgrading existing systems, and/or
constructing community wastewater plants.
Directly reduces nutrient loadings to surface waters.
Provides critical information for decisions regarding
wastewater management systems (strategy W.3).
Provides critical information about cause/effect
relationships linking wastewater pollutants and
Sanctuary resources.
MARINAS AND LIVE-ABOARDS
L.1 Marina Pumpout
• Develop Plan for Sewage Discharge Elimination
• Require Marina Pumpout Facilities
• Enforce Pumpout Use
Develops and implements a coordinated plan to directly
reduce nutrient loadings from live-aboards and other
boaters, which can contribute to water quality
degradation in confined waters.
MOSQUITO SPRAYING
W.1 7 Mosquito Spraying
• Review Aerial Spraying Threshold
• Review Flight Plans and Equipment
• Reconsider Larvicide Use
• Evaluate Ultra-low volume Methods
Reduces aerial spraying of pesticides, leading to
reduced inputs of pesticides and diesel oil to the marine
environment.
                                              C-77

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                                                                   Water Quality Action Plan
Table 3. High-Priority Strategies/Activities (cont.)
Strategy/Activity
W.18 Pesticide Research
• Research Impacts and Alternatives
• Modify Mosquito Control Program
• Conduct Field Survey of Pesticide and
Herbicide Use
CANALS
W.10 Canal Water Quality
Evaluate and Revise Hot Spot List
Inventory and Characterize Canals
Develop and Evaluate Improvement Strategies
Revise FDEP Permit Criteria
Identify and Compile Technologies
Develop Community Education and
Involvement Program
Conduct Canal System Restoration Pilot Project
Implement Improvement Strategies
Rationale
Evaluates alternatives to minimize impacts of current
pesticide practices.

Addresses documented water quality degradation in
canals.
MONITORING AND RESEARCH/SPECIAL STUDIES
W.20 Water Quality Monitoring Program
• Develop Monitoring Implementation Plan
• Identify Organization/Institution to Conduct
Monitoring
• Establish QA/QC Authority and Protocols
• Implement Monitoring

W.22 Special Studies: Wastewater Pollutants
• Detect Wastewater Pollutants and Ecological
Impacts
W.24 Special Studies: Florida Bay Influence
• Conduct Historical Assessment
• Conduct Circulation Studies
• Conduct Ecological Studies
W.28 Regional Database
• Conduct User Needs Assessment
• Develop Implementation Plan
• Implement and Maintain Data Management
System
W.32 Technical Advisory Committee
• Establish Technical Advisory Committee
W.33 Ecological Monitoring Program
Provides critical data on long-term status and trends in
water quality and biological resources for management
decisions. The monitoring program is required by the
Florida Keys National Marine Sanctuary and Protection
Act.

(see above, Domestic Wastewater)
(see above, Florida Bay/External Influences)
Data management is an integral part of all monitoring
and special studies efforts; must be developed before
field/lab work begins.
Establishes technical oversight for all monitoring and
research/special studies.
Provides critical information on the health of living
resources and the ecosystem, and the effectiveness of
management actions. Required by the Florida Keys
National Marine Sanctuary and Protection Act.
                                             C-78

-------