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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

[embed]https://youtu.be/a4NWi3eDF1s[/embed] 

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

[embed]https://youtu.be/Af9XcX1uczw[/embed] 

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

  1. 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)

  2. 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

  3. 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

  4. 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

  5. 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

  6. 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

  7. 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

  8. 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

  9. 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

  10. 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

  11. Paige Gysan

    • Looking for compromise on Tav Key

    • Support boater education

    • Law Enforcement

    • WQ

  12. 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

  13. 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

  14. Tracey Froitzhein

    • Pleased that Tennessee Reef Long Key SPA was not included

    • Asked for more enforcement at Long Key

  15. Vicky Rodriguez – resident in Tavernier

    • Great swimming area at Tavernier Key for family

    • Does not support no anchor zone for Tavernier Key

  16. 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

  17. 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

  18. 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

  19. 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

  20. 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

  21. 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

  22. 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

  23. 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

  1. Captain Spencer Slate

    • Appreciates and recognizes outreach

    • Opposes no anchor in SPAs

  2. Captain Bill Kelly

    • WQ, Education, Enforcement

    • Opposes ‘casitas’

    • Buoys for lobster sites

    • Concern for marine debris

    • Enforcement

    • Education for non-residents

  3. Daniel Smith - Commercial Fisherman

    • Opposes sanctuary expansion and strengthening regs

    • WQ

  4. Phil DeMeo – Marathon Resident

    • Buoys – supportive

    • Supports artificial reefs / wrecks

    • Generally supports FKNMS

  5. Jessica Bibza

    • Support no anchor in SPAs

    • Support Cheeca Rocks + contiguous areas similar to KL Dry Rocks – Grecian

    • Support Snake Key

  6. 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

  7. 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

  8. Jeff Cramer – Conch Key Commercial / SAC Member

    • Oppose Channel Key Banks

    • Exclude ‘z-cut’ for commercial and backcountry

    • WQ / Overtourism

    • Support restoration areas

  9. Jimmy Gagliardini - Resident

    • Notes severe decline

    • Supports strengthened protections and zone/boundary expansion

    • Expedite adoption and implementation

  10. Chris Bergh - TNC

    • Support boundary expansion proposal

    • Support Pulley Ridge expansion

    • Include Tortugas Corridor

  11. Jorge Blanco – KW Resident – Commercial Fisherman

    • Oppose Tortugas expansion

    • Oppose proposed changes at Marquesas

Key West Meeting 9/22

  1. Spencer Slate – Captain Slate’s Dive Charters

    • WQ – Expedite Everglades Restoration

    • Nutrient loading to stormwater

  2. 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

  1. 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)

  2. Dave Harris – KW Extreme Adventures Shark Tours

    • Opposes fish feeding prohibition

  3. 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?

  4. 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

  5. Mimi Stafford – SAC Member

    • Noted transparency

    • Supports boundary expansions and strengthening protections

  6. Lee Starling – Commercial Fisherman

    • Does not support 30 x 30 initiative

    • Asks for state intervention in rulemaking

  7. 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

  8. Daniel Smith – Commercial Fisherman / Diver

    • Does not support boundary expansion and strengthened protections

    • WQ concerns

    • Abolish the sanctuary

  9. Chris Bergh

    • Notes the success of past conservation measures (conch, sea turtles, etc..)

    • Zoning, markers, important for seagrass habitats

    • Support no anchor in SPAs

  10. 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

  11. 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)

  12. Jessica Bibza -

    • Support Turtle WMA

    • Support cruise ship prohibition

    • Support adaptive management

  13. Rick Gage – Keys Boater Alliance

    • Lack of enforcement

    • Opposes closures

  14. Judd Wise – Rec Guide

    • Opposes Boca Grande and whistle

    • Opposes Marquesas WMA

    • Support improved signage, buoys, markers, education

  15. Justin Benson – Dive instructor / captain

    • Oppose removal of protections at Rock Key as a rec diver

    • Support protections generally

  16. 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

  17. Mark Songer

    • Follow the science on WMA

    • Support nesting birds, restoration areas