Florida Keys Area of Critical State Concern Work Plan for Monroe County

July 5, 2020

The Honorable Ron DeSantis, Governor 
GovernorRon.Desantis@eog.myflorida.com

Florida Administration Commission  AC.Clerk@LASPBS.STATE.FL.US

RE: Revised Florida Keys ACSC Work Plan for Monroe County

Dear Governor DeSantis and Administration Commission:

I am writing on behalf of Last Stand, a volunteer organization whose mission is to promote, protect and preserve the quality of life in Key West, the Florida Keys and their environs, with a special emphasis on the environment.

Last Stand supports the recommendations made by NOAA’s Florida Keys National Marine Sanctuary  DEO Work Program Revision_FKNMS Comments_FINAL and offers the following additional comments.

WASTEWATER - Nearshore water quality continues to be a concern, despite the County having completed many of its work tasks.  As recommended by the FKNMS, effectiveness of the current wastewater infrastructure system needs to be monitored and improved as needed. We strongly encourage that this be incorporated into the County’s work plan.

STORMWATER MANAGEMENT - Last Stand agrees with FKNMS that proper stormwater management is necessary to avoid compromising nearshore water quality gains already attained by improvements in wastewater infrastructure.

HURRICANE EVACUATION - Last Stand has strong concerns about the ability of permanent Keys residents to evacuate 24 hours before tropical storm winds arrive in our islands. In light of recent warnings by the National Hurricane Center that Rapidly Intensifying Storms compromise their ability to issue advance forecasts to assist emergency planners in notifying the public to evacuate, public safety appears to be in potential jeopardy. Alarmingly, there have been additional building permits issued outside of what the TIME evacuation model indicates is a safe number. This action of generating additional building permit allocations (ROGOs) without consideration of evacuation realities is disturbing. We recommend that the County, in conjunction with DEO and the Florida Emergency Management Division, identify ALL County residents who would be evacuated within the 24-hour safe clearance period.  If the TIME hurricane evacuation model determines that these people cannot be safely evacuated, the County shall not be authorized to award any further building allocations (ROGOs).

LAND MANAGEMENT and HABITAT PROTECTION - Last Stand agrees with the Island of Key Largo Federation of Homeowner Associations that conservation and protection of natural, native habitat is important, and we continue to see these critical lands illegally cleared, despite the County’s Tier system constraints, conservation easements, and Comprehensive Plan Goal 107. Citizens expect that the aforementioned would provide the necessary protections for natural, native habitat. Last Stand recommends a work plan that requires an annual report to the DEO, listing these violations and associated actions taken by the County to bring all such violations into compliance.

Thank you for the opportunity to comment on the Monroe County work plan. Please consider our comments in your review and update.

For the Last Stand Board of Directors,

D. A. Aldridge, President