June 21, 2022

Sent by email

Barbara Conmy, Section Leader, Environmental Resource Bureau, Regulation Division
South Florida Water Management District bconmy@sfwmd.gov
3301 Gun Club Road
West Palm Beach, FL 33406

RE: Big Pine Key Hydrology Project; Permit Application Error

Dear Ms. Conmy,

A habitat classification error in the application for the Big Pine Key Hydrology Project (Project), which was permitted by the South Florida Management District (District), has come to our attention. Unfortunately, implementing the Project with that error could produce unintended consequences for the habitat of Keys’ wildlife and negatively impact an important current land-use protection on Big Pine Key.

The Project application misidentifies historically nontidal, freshwater wetlands south of Watson Boulevard as saltmarsh wetlands. The vegetative communities in saltmarsh wetlands are different than those in freshwater wetlands. With 23 endangered and threatened species on Big Pine Key, the availability of year-round fresh water is critical to their survival. To leave the habitat classification error in place in the permit and Project plans could reduce the Project’s overall value, by confusing management of this important area, which in the long term could reduce the availability of year-round fresh water on Big Pine Key.

Also, misclassification of the habitat in the Project area could jeopardize Monroe County’s current land-use regulations regarding development in freshwater wetlands on Big Pine Key. Treating freshwater wetlands as saltmarsh wetlands threatens current land-use prohibitions against development in freshwater wetlands and could allow development within currently protected areas. Over-development is an ongoing concern of Last Stand’s members, as it adversely affects residents’ quality of life and compromises residents’ safe evacuation in the event of an approaching hurricane.

Implemented properly, including underlying mapping accuracy, the Project could enhance habitat on Big Pine Key. Last Stand urges the District to refer to Monroe County’s 2009 Land Use/Land Cover maps for accurate habitat mapping.

Thank you for considering our concerns about this consequential issue. We would appreciate being notified regarding any District actions relating to the Big Pine Key Hydrology Project.

For the Last Stand Board,
//s//
Joyce Newman
Director

Cc: Steven Gornak, Project Manager, Florida Fish & Wildlife Conservation
Commission
Chris Eggleston, USFWS Project Manager, Florida Keys National Wildlife Refuges
Complex
Kevin Kalasz, USFWS Coastal Program Coordinator
Emily Schemper, Senior Director of Planning and Environmental Resources,
Monroe County