Last Stand Gives Public Comment on Restoration Blueprint for Florida Keys National Marine Sanctuary
NOAA (National Oceanic and Atmospheric Administration) has published a proposed management plan and regulations for the Florida Keys National Marine Sanctuary (FKNMS). The 2022 Restoration Blueprint will guide the management and use of the sanctuary for years to come.
Last Stand is involved in the process to finalize the Restoration Blueprint by asking questions, submitting comments at a virtual forum, and attending and providing testimony at each of the three in-person meetings on September 20, 21 and 22 in Key Largo, Marathon, and Key West. Our testimony at each of the forums is below and reflects the unique concerns of each area. We were limited to 3 minutes at each location so our written response will be more in depth. Also included here below are summaries of each speaker’s comments as provided by NOAA.
There is a lot of information in the Restoration Blueprint documents. Last Stand and our non-profit partner organizations are still reviewing options for a comprehensive written response. We will share that here on our website when it is finalized. Write to us if you have comments or concerns on our testimony to date. As we develop specific positions that need to be supported by our members, we will reach out with updates and meeting reminders. You may also submit written comments online at this link now and until October 26th.Last Stand needs your help to continue monitoring and guiding officials in protecting our fragile environment. Please consider donating, becoming a member or joining our board.
Last Stand Testimony, Tuesday, September 20, Tavernier
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Good evening. I am Dottie Moses, representing Last Stand. Last Stand has been active in Monroe County since 1987 promoting, protecting, and preserving the quality of life in the Florida Keys with an emphasis on the natural environment. We have supported the sanctuary since inception and will provide detailed written comments in coming weeks.
We are encouraged that zoning protections we supported in the Draft EIS for corals and wildlife are in the proposed rule and we recommend adopting them.
Water quality in the Keys continues to be a top concern of Last Stand. More can be done to reduce adverse impacts to key marine species and habitats. We will be recommending the addition of a new Management Plan activity. We’re calling for the sanctuary to recognize the adverse impact of degraded water quality near Marathon. We’re asking the sanctuary to intervene in DEP permit approvals for shallow well disposal of treated sewage in Marathon and throughout the Keys.
Prop scarring caused by boaters unfamiliar with the Key’s shallow waters is avoidable. We strongly support establishing a mandatory boater education program for the sanctuary. We’re asking in our written comments that you study the success of mandatory boater education in Everglades National Park and implement a similar mandatory program for the sanctuary.
We have observed adverse impacts on nesting birds from frequent fireworks displays in the Upper Keys. We are encouraging sanctuary staff to work with Monroe County for better wildlife protections from the impacts of frequent fireworks displays.
We support the new Pelican Key Wildlife Management Area as a 23-acre No Entry zone to protect nesting pelican and magnificent frigatebirds.
Thanks for the opportunity to provide input. Last Stand is always seeking help from dedicated, concerned citizens as we advocate for the quality of life in the Florida Keys. For more information go to our website, keyslaststand.org .
Last Stand Testimony, Wednesday, September 21, Marathon
Good evening. I am Ann Olsen, representing Last Stand. Last Stand has been active in Monroe County since 1987 promoting, protecting, and preserving the quality of life in the Florida Keys with an emphasis on the natural environment. We have supported the sanctuary since inception and will provide detailed written comments in coming weeks.
We are encouraged that zoning protections we supported in the Draft EIS for corals and wildlife are in the proposed rule and we recommend adopting them. Expanding the sanctuary boundary to cover Pulley Ridge provides significant protection for these deep-water corals.
Water quality in the Keys continues to be a top concern of Last Stand. More can be done to reduce adverse impacts to key marine species and habitats. We will be recommending the addition of a new Management Plan activity. We’re calling for the sanctuary to recognize the adverse impact of degraded water quality near Marathon. We’re asking the sanctuary to intervene in DEP permit approvals for shallow well disposal of treated sewage in Marathon and throughout the Keys.
Prop scarring caused by boaters unfamiliar with the Key’s shallow waters is avoidable. We strongly support establishing a mandatory boater education program for the sanctuary. We’re asking in our written comments that you study the success of mandatory boater education in Everglades National Park and implement a similar mandatory program for the sanctuary.
Although we strongly supported more protections for Western Dry Rocks Wildlife Management Area, we are encouraged with the first steps to establish a seasonal fishing prohibition between April 1st and July 31st for this multispecies spawning aggregation site. We encourage the sanctuary to continue studying the best ways to protect this important area.
In the Draft EIS, we supported the no wake/no motor proposal within 100 yards of shoreline. This would have significant benefits for fishing and wildlife nesting and foraging. It would be straightforward to implement if there were an effective boater education program. We are asking that Alternative 4 from the Draft EIS be part of the final regulations.
Thanks for the opportunity to provide input. Last Stand is always seeking help from dedicated, concerned citizens as we advocate for the quality of life in the Florida Keys. For more information go to our website, keyslaststand.org .
Last Stand Testimony, Thursday, September 22, Key West
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Good evening. I am Roger McVeigh, representing Last Stand. Last Stand has been active in Monroe County since 1987 protecting and preserving the quality of life in the Florida Keys emphasizing the natural environment. We have supported the sanctuary since inception and will provide you with more detailed written comments.
We are encouraged that zoning protections we supported for corals and wildlife are in the proposed rule and recommend you adopt them.
We support the proposed rule for large vessel mooring buoys to better protect sensitive habitat.
We encourage mandatory boater education on how to safely use small vessel mooring buoys.
Water quality in the Keys continues to be the top concern of Last Stand. More can be done to reduce adverse impacts to key marine species habitats. We’re calling for the sanctuary to recognize the adverse impact of degraded water quality near Marathon.
We’re asking the sanctuary to intervene in FLDEP permit approvals for shallow well disposal of treated sewage in Marathon and throughout the Keys.
The Pulley Ridge boundary change and no anchor zone is important to protect deep-water corals.
The western expansion of Tortugas South will provide science- based protection for fish spawning and deep-water corals. We and you know large, contiguous, highly protected marine zones are effective. That’s why we support both the Pulley Ridge and Tortugas South boundary changes.
Last Stand strongly supports establishing the Marquesas Keys Turtle Wildlife Management Area. This has been shown to be an important foraging area for sea turtles, so we are concerned that the proposed protected area is smaller than Alternative 3.
We are asking that the protected area be expanded and that you provide necessary exceptions for military use within the area to maximize protected turtle habitat.
We support sanctuary regulations to prohibit cruise vessel greywater discharge to provide protection similar to those in Glacier Bay National Park.
Thanks for the opportunity to provide input. Last Stand is always seeking help from dedicated, concerned citizens and groups as we advocate for the quality of life in the Florida Keys. For more information go to our website, keyslaststand.org or email us at info@keyslaststand.org. Thank you
Summary of Public Comments
Tavernier Meeting 9/20
Spencer Slate: owner/operator Cap Slates
In opposition to fish feeding prohibition
68 years of fish feeding (currently injured)
Did ask for permitting for existing operators (as written in rule)
Dottie Moses – Last Stand
Longstanding support for sanctuary
Recommend adopting zoning protections
Recommending addition of inclusion of degraded wq in Marathon and shallow wells as mgt plan activity
Support boater education
Support the inclusion of additional protections from fireworks
Support Pelican Key WMA
A. Aldridge – Resident / FL Keys Restoration Partnership
Stronger safeguard for Key issues
Pelican Key WMA – Support no entry
Pigeon Key WMA – Support no entry
Fish Feeding – generally supported in DEIS, supportive of prohibition and including land-based operations
Glenn Patton – Resident of KL
Opposes no anchor at Tavernier Key – claims more harmful than not, for rec users on NE side
2011 condition report – fair/poor and says it is still in decline
Supports coral restoration work and more restoration sites
Water quality infrastructure improvements in upstream communities
WQ impacts from Lake O mgt, sugar industry, and Everglades restoration
Captain Bill Kelly – FL Keys Commerical Fishermans Association
Report card for FKNMS and a failing grade
Notes barriers to understanding/accessing the blueprint by rec / commercial sanctuary users
Climate impacts since 2009
Covid impacts
Overtourism impacts
Development issues
Enforcement concerns – did no
WQ – algal blooms, lack of Everglades restoration
Bacterial pollution near sandbars
Ask for better - targeted outreach to commercial guides
Ernie Paton – Zoning Working Group
Commercial fisherman displaced by existing zoning
Leading to pressures in other locations in the sanctuary
Blaming out-of-town day trippers
Support boater education for out-of-county folks
Need more enforcement
Frustrated by zoning expansion, including Carysfort in particular
Believes proposed zoning will do more harm than good
Joseph Mastrangelo Jr. – President of Veterans Sailing Inc.
Draconian plan
Pelican Key WMA – opposes proposed changes
Pigeon Key, Barnes Sound opposes as well
Tav Key / Rodriguez Key/ Dove Key – claims anchoring necessary on windy days
Ginette Hughes – MarineLab Key Largo
Supports closure at Pelican Key WMA
Supports closure at Whitmore Bight
Supports marine zoning and expansion of FKNMS for students she serves
Dianne Harbaugh – Islamorada Charter Boat Association
Doesn’t support boundary expansion because of enforcement pressures
Concerned that Gov will not be able to weigh-in on Sanctuary expansions as they are outside of state waters
Questioned where $$ for new mooring buoys, concerned with who will maintain and does not support no anchoring provision in SPAs
Does not support Alligator Reef SPA expansion
Supports artificial reefs and inclusion in blueprint
Does not support temporary closure plan
Does not support Asheby-Horeshoe
Education, enforcement, WQ
Mark Edwards – sailor /diver
Generally supportive of Blueprint
Rule change can have unintended consequences
Tav Key – does not support no anchor expansion to N – claiming very few anchorages available for sailors
Limit no anchor zone to current no motor line
Proposes no anchor zone reduced to allow recreational use
Paige Gysan
Looking for compromise on Tav Key
Support boater education
Law Enforcement
WQ
Walter Rentz – resident
Against all boundary expansions for shorelines to reef from DEIS
WQ
Wants to see greater sanctuary presence on the water (research)
Noted lack of buoys in existence
Angered by comments on Pennekamp
Overuse
Jessica Bibza - NWF
Balance of traditional uses with resource protection
Support much of the management plan and marine zoning
Education, enforcement, WQ
More specificity needs to be articulated in plan
Support cruise ship prohibition, fish feeding, derelict vessel
Support Carysfort and feels it does not go far enough
Key Largo Dry Rocks – Grecian Rocks as connectivity example
Tav Key and Pelican WMAs
Protect to lowest common denominator
Tracey Froitzhein
Pleased that Tennessee Reef Long Key SPA was not included
Asked for more enforcement at Long Key
Vicky Rodriguez – resident in Tavernier
Great swimming area at Tavernier Key for family
Does not support no anchor zone for Tavernier Key
Gary Sands – KL Commercial Fisherman
KL has some of the most restrictive zoning
Does not support the expansion of boundary / marine zones
Echoed Bill Kelly’s comments
WQ
Noted significant decline in reef tract
No one but God can fix this mess
Opposes MPAs / authority of FKNMS
Steve Friedman – FKFGA
Concern w/ enforcement
Boater safety traffic
Inexperienced boaters
Channel marking
Disease, wq issues
Support artificial reefs
Implore them to employ adaptive management
Chris Bergh – TNC
Reef in worse condition despite current protections
Impacts of climate change, ocean acidification, fishing, diving and boating impacts
Seagrass meadows cut to ribbons by more boats, bigger engines, less experienced folks driving boats
Improvements: goliath grouper, conch, sea turtles
Regulations support species recovery
Supports public making comments on management plan
Barry Wray – FKEC
Supports marine zoning and expansions / changes
Notes enforcement, WQ
Supports the public reaching out to local and state officials to address water quality
Pely Perez – Resident of Tavernier / Weekender
Recreational users of Tavernier / Rodriguez Key
Does not support no anchor provision
Claims it will lead to user pressures elsewhere
Does not support n. side inclusion in zoning
Captain Ginny Oschaben
Does not support no entry / no motor at Pelican Key WMA
Ambassador location to explore mangrove habitat for eco-tour operators
Claims nesting birds stay regardless of boating in and out of area
Important for sustainable, experiential tourism in Key Largo
Ann Helmers – Friends of John Pennekamp Coral Reef State Park
Nearly 1 million visitors to the park
FKNMS being loved to death
Underscores the importance to stewardship and protection
Cynthia Gneiser – Amoray Dive Center – Teacher at OSCS
Opposes Pelican Key closure for educational purposes
Concerned about removal of protections from French Reef
Marathon Meeting 9/21
Captain Spencer Slate
Appreciates and recognizes outreach
Opposes no anchor in SPAs
Captain Bill Kelly
WQ, Education, Enforcement
Opposes ‘casitas’
Buoys for lobster sites
Concern for marine debris
Enforcement
Education for non-residents
Daniel Smith - Commercial Fisherman
Opposes sanctuary expansion and strengthening regs
WQ
Phil DeMeo – Marathon Resident
Buoys – supportive
Supports artificial reefs / wrecks
Generally supports FKNMS
Jessica Bibza
Support no anchor in SPAs
Support Cheeca Rocks + contiguous areas similar to KL Dry Rocks – Grecian
Support Snake Key
Ann Olsen – Last Stand
Adopt additional marine protections
Support Pulley Ridge
Shallow water well WQ focus
Support mandatory boater education
Support Western Dry Rocks seasonal closure and addl study
100 yd shoreline slow speed support
Gary Nichols – Lower Mat
Did not support shore to reef in DEIS
Lobsterman okay with Alligator expansion
Does not support Tennessee deep reef protection / expansion
Turtle Shoal – supports as written / zoned
Supports Coffins Patch
Does not support Sombrero expansion / zoning
WQ / Overfishing / Overtourism
$$ for WQ / marine debris removal
Oppose casitas
Jeff Cramer – Conch Key Commercial / SAC Member
Oppose Channel Key Banks
Exclude ‘z-cut’ for commercial and backcountry
WQ / Overtourism
Support restoration areas
Jimmy Gagliardini - Resident
Notes severe decline
Supports strengthened protections and zone/boundary expansion
Expedite adoption and implementation
Chris Bergh - TNC
Support boundary expansion proposal
Support Pulley Ridge expansion
Include Tortugas Corridor
Jorge Blanco – KW Resident – Commercial Fisherman
Oppose Tortugas expansion
Oppose proposed changes at Marquesas
Key West Meeting 9/22
Spencer Slate – Captain Slate’s Dive Charters
WQ – Expedite Everglades Restoration
Nutrient loading to stormwater
Ken Harris – KW Extreme Adventures Shark Tours
Opposes fish feeding prohibition
Highlighted coordination with fishing community to try shark repellent rather than culling fish
Does not support Marquesas Turtle WMA
Does not support permitting provision
BUT would want to be involved if it is included in the plan
Gerald Ward – Resident / Coastal Engineer
Supports robust public input
Support WQ
Too little, too late
Simplify zoning info
Underscores the importance of the management plan
Supports interagency consultation and communication (particularly state)
Dave Harris – KW Extreme Adventures Shark Tours
Opposes fish feeding prohibition
Brice Barr – President KW Charter Boat Association
Noted lack of buoys in SPAs
Issues with enforcement due to lack of buoys
Opposes W. Sambo expansion (issues w/GPS companies as noted by other guides)
Idle zone at Boca Grande – bait spot (as flagged by Will)
Oppose Marquesas Turtle WMA – esp for quick sands
Oppose Barracuda Keys
Support Artificial Reefs
Support Pulley Ridge large vessel no anchor
WQ
Supports opening Rock Key
Why are there SPAs where you can fish but not dive?
Daniel Padron – FL Keys Commercial Fisherman Association
Lack of enforcement
Improve channel markings
Does not see user impacts at Boca Grande to justify idle zone
Sambos – need buoys and markers
Consistency w/in jurisdictions for all user groups
Mimi Stafford – SAC Member
Noted transparency
Supports boundary expansions and strengthening protections
Lee Starling – Commercial Fisherman
Does not support 30 x 30 initiative
Asks for state intervention in rulemaking
Simon Stafford – Commercial Fisherman
Supports sanctuary boundary expansion
Supports Pulley Ridge no anchor for large vessels
Supports expansion of Western Sambo
?s about restoration areas in KW
Doesn’t support change from no motor to no access at Pelican Shoal
Daniel Smith – Commercial Fisherman / Diver
Does not support boundary expansion and strengthened protections
WQ concerns
Abolish the sanctuary
Chris Bergh
Notes the success of past conservation measures (conch, sea turtles, etc..)
Zoning, markers, important for seagrass habitats
Support no anchor in SPAs
Arlo Haskell – KW Committee for Safer, Cleaner Ships
WQ
Local, point source pollution impacts
Cruise ship turbidity
Does not explicitly ban ballast discharge water – relationship w/stony coral tissue loss disease
Unregulated propeller dredging in sanctuary waters in KW
Leslie Levis – Resident – Dive Operator
Restrict diving and snorkeling in addition to fishing
Supports additional closures on reef
WQ
Expedite Everglades restoration
Leave reefs alone for 5 years at a time (adaptive management)
Jessica Bibza -
Support Turtle WMA
Support cruise ship prohibition
Support adaptive management
Rick Gage – Keys Boater Alliance
Lack of enforcement
Opposes closures
Judd Wise – Rec Guide
Opposes Boca Grande and whistle
Opposes Marquesas WMA
Support improved signage, buoys, markers, education
Justin Benson – Dive instructor / captain
Oppose removal of protections at Rock Key as a rec diver
Support protections generally
Roger McVeigh – Last Stand
Support expanded boundary and strengthen protections
Support large vessel mooring buoys
Support mandatory boater education
WQ
Shallow water wells in Marathon
Supports Pulley Ridge expansion
Support W expansion of Tortugas S
Support Marquesas WMA and expansion like Alt 3 in DEIS
Support cruise ship discharge prohibition
Mark Songer
Follow the science on WMA
Support nesting birds, restoration areas