The following is a letter Keys Last Stand sent to the State of Florida regarding Pier B's request to expand their cruise port and extend their lease. A description of what's happening from Key West Progress' Ray Warren is below our letter.

May 18, 2023

Jason Andreotta
Florida Department of Environmental Protection
Southeast District (WPB)
3301 Gun Club Road, MSC7210-1
West Palm Beach, Florida 33406

RE: Request to Modify Existing Submerged Lands Lease

Pier B Development Corp.
BOT Lease No. 440020075, Site No. 166412 / Project No. 401305
Parcel No. 00000200-000203, Monroe County – SLERC

Dear Mr. Andreotta,

Last Stand requests that you do not grant the Request to Modify Existing Submerged Lands Lease for Pier B Development Corp. We believe opposing this request is reasonable based on the following:

• The Citizens of Key West have repeatedly shown their desire for limiting the size of cruise ships in port. Pier B’s request would enlarge the lease of Florida state submerged land to Pier B by 40% and will allow larger cruise ships to berth. Additionally, Pier B’s request also provides a provision to extend the lease of the state land to Pier B for an additional 25 years. Pier B’s proposal is in opposition to the public interest of the people of Key West.

• The Pier B Cruiseport operates in an environmentally sensitive area, designated as Outstanding Florida Waters and within the FL Keys Area of Critical State Concern and the FL Keys National Marine Sanctuary. This area is federally designated critical habitat for two coral species listed under the Endangered Species Act (Staghorn and Elkhorn coral); and is proposed to be designated as critical habitat for five additional ESA-listed corals: Lobed star coral, Mountainous star coral, Boulder star coral, Pillar coral, and Rough cactus coral. Colonies of two of these federally listed threatened species were documented by City contracted engineers within 500’ of the Pier B cruiseport in 2020. Neither Pier B nor the State has addressed how larger ships using the larger lease area may impact sensitive marine resources including endangered species.

• The Pier B Cruiseport berthing structure was designed to mitigate cruise ship-generated turbidity and reduce the potential for serious environmental harm. Engineering studies did not consider ships larger than those authorized by the current lease. Neither Pier B nor the State has addressed how larger ships using the larger lease area may impact turbidity levels in local waters and associated environmental harm.

If Pier B’s request is approved, the practical effect it will have is to tie up the submerged land for decades, hurt an environmentally sensitive area and provide little benefit to the Citizens of Key West.

Thank you for considering our position.
Respectfully,
Mary Spillane
On Behalf of the Last Stand Board of Directors

Last Stand | P.O. Box 146 | Key West, FL 33041| info@keyslaststand.org | www.keyslaststand.org--

Mary Spillane
Executive Coordinato
rLast Stand of the Florida Keys

Ray Warren 

Re: Tonight's special City Commission meeting to respond to Pier B's request to the state to expand its lease of state lands. There is more to it than the expansion. There is also a pre-emptive request to lock the expansion in for decades to come.

Tucked into the proposal to enlarge the lease of Florida state submerged land to Pier B by 40%, is a provision to extend the lease to Pier B of the state lands it utilizes by 25 years. The lease is currently slated to expire on February 6, 2025. The proposal, after enlarging the leased area, proposes to extend the lease by an additional 25 years, (apparently until after 2050).

The last time the lease was renewed in 2015, it was for only ten years. Pier B, in its application to enlarge the footprint of its leased lands says: “there is significant long-term planning, maintenance AND CONSTRUCTION WORK [emphasis added] required to keep a cruise port operational and safe for the general public, which requires a substantial long-term financial commitment.”

The practical effect will be to tie up the submerged land for decades and complicate future efforts to move away from massive cruise ships. The rationale they provided also seems to indicate plans to expand operations as much as possible within the new land lease, and to do so two and a half times longer than the last lease renewal.

The effect of permanently expanding the footprint allowed for Pier B ships on the existing city owned mooring dolphin is not clear. But the expanded footprint might certainly allow construction of Pier B’s own mooring point within the same parameters. Either way, the intent is clearly to expand the footprint for mooring large ships at Pier B and to lock in that expansion for decades.