January 27, 2020
Sarah Fangman, Superintendent
Florida Keys National Marine Sanctuary
33 East Quay Road
Key West, FL 33040
Dear Superintendent Fangman,
I am writing on behalf of Last Stand, a volunteer-led organization of over 200 members in the Florida Keys. From Key Largo to Key West, our board of directors is connected throughout the community through leadership positions in homeowner and other environmental organizations. These relationships helped form our comments that follow. Since 1987 our organization has worked to promote, protect and preserve the quality of life in Key West and the Florida Keys with a special emphasis on the environment. This focus for over 30 years establishes the basis for our opinion that protecting the environment in the Florida Keys improves not only the quality of life, but also sustains the economic engines of tourism and commercial uses of sanctuary waters.
We would like to commend NOAA staff and the SAC for the time and effort spent creating the Restoration Blueprint. We encourage you to follow science and reason when determining which alternatives will be in the final Environmental Impact Statement (EIS) and to make decisions with environmental conservation for future generations as the highest priority. The Draft Environmental Impact Statement (DEIS) is an excellent start to finding solutions to a whole series of issues we must face as government organizations, non-profits, commercial, and recreational groups.
Water quality issues are not well addressed by the Restoration Blueprint. Human activity continues to add nutrients to sanctuary waters, changing the historical balance of the ecosystem. We recognize that many water quality issues relate to sources outside the sanctuary. However, there are specific steps we encourage NOAA and its partners to take to better address water quality issues.
- We encourage sanctuary managers to partner with U.S.E.P.A, Florida D.E.P. and Florida F.W.C. to reinvigorate efforts to communicate the importance of local water pollution and remediation efforts and to continue to seek out and eliminate the sources of this pollution via the Sanctuary’s Water Quality Protection Program.
- One point of concern is disposal of untreated stormwater and treated wastewater effluent in shallow wells. Studies have shown that shallow well disposal allows water to quickly rise to the surface, impacting freshwater lenses and nearshore waters. In April 2014 the report on the design and implementation of the dye-tracer injection test at Cudjoe Key stated, “We conclude that there are convincing evidences that injected freshwater at the current injection depth of 80’ to120’ and at the experimental injection rate of 420 gal/min, readily migrates upward and then laterally to the unconfined shallow aquifer and eventually to surface waters. These results are similar to those found by other researchers elsewhere in the Florida Keys.” The City of Marathon disposes of over 800,000 gallons per day of treated effluent in shallow wells. Analysis of publicly available data shows nearshore water quality declines since these treatment plants were put into service. The data for Dissolved Inorganic Nitrogen and Total Phosphorus between 2011 and 2017 at two SHORE stations in Marathon show an increasing number of samples exceed EPA-developed Strategic Targets for the Water Quality Monitoring Project and an upward trend in nutrients present in near -shore waters. Although the analysis does not directly link the shallow-well effluent to the increasing nutrient levels, the trend line demands further investigation as to the source that is causing decline in water quality. We encourage sanctuary officials to be more active and vocal regarding remedies for this significant and ongoing discharge of nutrient-rich water that migrates into sanctuary waters.
- Existing regulations prohibit discharge of untreated personal sewage from liveaboard vessels. However, the regulation is not adequately enforced. We urge the sanctuary to work with Florida F.W.C. to increase staffing for enforcement in areas outside of City-and County-monitored mooring fields where liveaboard vessels anchor.
- We urge the Sanctuary to play a larger role in advocating for progress in Everglades restoration through increased participation with the South Florida Ecosystem Restoration Task Force, Working Group, Science Coordination Team, Biscayne Bay Regional Restoration Team, and current efforts to develop a Combined Operations Plan for Southern Everglades projects.
- We strongly support the update to discharge regulation exception Alternative 2 on page 62 that would prohibit discharge other than clean water from a cruise ship within sanctuary waters. Giving FKNMS the same protections as other sanctuaries will help compliance here as well as other sanctuaries where cruise ships frequent. We also encourage you to partner with Florida F.W.C. and U.S. Coast Guard to enforce the updated regulation.
Modification to Sanctuary Boundaries
We support expansion of the sanctuary boundary to encompass the Area To Be Avoided, to align with the boundary of Biscayne National Park and to cover additional habitat in the Tortugas region. Expanding the boundaries to align with the Area To Be Avoided and encompass the Particularly Sensitive Area around the Tortugas South Reserve will simplify compliance with sanctuary regulations. Because additional protections of sanctuary regulations will help to preserve the unique resources of Pulley Ridge mesophotic reef ecosystem and complement protections proposed by the Gulf of Mexico Fishery Management Council, we encourage you to use Alternative 4 on page 29 for the final EIS, with the added restriction that anchoring of ships greater than 50 meters in length should be prohibited to eliminate anchor and chain damage that is documented to occur there.
- We agree that compliance and enforcement will be enhanced by conforming the existing sanctuary boundary with the Area To Be Avoided. However, we do not agree that the cost of enforcement and compliance for an additional 1,000 square nautical miles will be insignificant. We will continue to educate Florida’s elected representatives in Washington about the importance of enforcement and advocate for them to provide FKNMS the financial resources necessary to be effective in enforcing compliance with regulations.
- Pulley Ridge is an importance resource and deserves protection. With its remote location, adding protection of sanctuary-wide regulations should not have a significant impact to recreational users. We believe protecting the deep-water coral community that has demonstrated direct connections to the sanctuary ecosystem will be a significant enhancement to the mission of FKNMS.
Shoreline Slow Speed
We support Alternative 4 on page 33 that would create a no wake zone within 100 yards of any shoreline, except in marked and traditional channels and routes that do not conflict with natural resource and public safety protection. This is a commonsense approach to better protection of habitat and wildlife. It may also be useful in reducing the number of restrictions to access in some proposed zones that would be inaccessible without having a vessel on plane due to very shallow water. Enforcement of this regulation will be very difficult. That is a reason that we are recommending mandatory boater education, marking channels where practical and employing the best technology to guide users, as further discussed later in our comments.
New Prohibition on Fish Feeding
Fish feeding, apart from traditional fishing activity, alters fish behavior and is inconsistent with the conservation of this important resource for the enjoyment of future generations. For that reason, we support the recommended Alternative 2 on page 37 to prohibit the feeding of fish, sharks or other marine species from any vessel and/or while diving.
We recommend that this new prohibition be extended to land-based fish feeding. We have witnessed land-based fish feeding from public and private shoreline property. The behavior modification that results is obvious to even a casual observer.
Vessel groundings and derelict and deserted vessels
We agree with the premise that more attention needs to be given to groundings caused by derelict and deserted vessels. Sanctuary managers need to be able to reduce environmental concerns from derelict vessels and deserted vessels by acting before harm is done. Adding the prohibition against leaving harmful matter on a grounded or deserted vessel may allow NOAA to prevent discharges.
However, the proposed language “at risk of becoming derelict” concerns us. This language is very broad and subjective. We are concerned about consistency of application of 327.4107 Florida Statutes indications of at risk of becoming derelict including: (a) taking on water without an effective means to de-water, (b) sealing off enclosed spaces and (c) in danger of breaking loose from an anchor. Likewise, we are concerned that it appears occupying a vessel at risk of becoming derelict may be both a violation of the regulation and a condition necessary for the owner to remedy indications noted above. We observe many vessels within the Sanctuary are occupied as an alternative to high-cost, land-based workforce housing. We recommend that sanctuary managers work with FWC agents to be consistent in application of these potentially subjective indicators with respect for the vessel owners who have no other affordable housing options.
Large vessel mooring buoy regulation
We support efforts to reduce damage that mooring buoy anchoring hardware can do when the buoy is not properly used. To be effective, education and outreach to recreational boaters is necessary to support compliance with rafting of multiple vessels to ‘small vessel’ mooring buoys. We support Alternative 2 on page 41 and recommend boater education courses emphasize this regulation and what is allowable. We encourage the sanctuary to use the availability of small- and large-vessel mooring buoys to limit access to sensitive areas that have been damaged by overcrowding and intensive use.
Overnight use of mooring buoys
We share the concerns noted on page 41 that overnight use of mooring buoys is monetizing a free service provided by the sanctuary by commercial and/or private services. We support Alternative 2 on page 41 to prohibit overnight mooring on designated buoys.
Protections for Multi-Species Spawning Aggregations
Western Dry Rocks
Last Stand strongly supports Alternative 4 on page 163 that would establish a Transit Only zone of 796 acres to protect the multi-species spawning aggregation site at Western Dry Rocks.
We realize that it is not practical to protect each and every site along the reef edge where all fish spawn and lobster release their eggs, as that would more than likely include the entire reef line. However, it is practical (and essential) to give special protection to unique areas of the reef line where multiple species aggregate to spawn. The Western Dry Rocks site is such an area and a classic example of what fisheries biologists and managers refer to as a ‘multi-species spawning aggregation site’. The size proposed for this zone is the minimum required to be an effective protection. The only other known multi-species spawning aggregation site protected to date in the Florida Keys is Riley’s Hump in the Tortugas area. That site is completely protected with limited access for research purposes.
Some of the reef fish species documented to spawn at the Western Dry Rocks site are: Mutton Snapper (May-June); Gray Snapper (July-August, FWC publication); Permit (May-July, Bonefish and Tarpon Trust); Black Grouper (year round, peaks from Dec.-March, Crabtree/Bullock 1998); Hogfish (Feb.-March, Colin 1982); and Yellowtail Snapper (April-August, Collins/Finucane 1989). Lobsters release eggs April-June (FWC data). Other reef fish that have either been observed to spawn at or collected for life history work in spawning condition from the Western Dry Rocks site are Queen, French, Gray and Blue Angelfish, Surgeonfish, and numerous other marine life fish species (tropical fish).
The board of Last Stand is fully aware of arguments brought forth by fishermen that there are other areas of the Florida Keys where commercially- and recreationally important species such a Mutton Snapper, Gray Snapper, Black Grouper and Permit spawn. However, these are single species spawning sites and not multi-species spawning aggregation sites such as Western Dry Rocks.
The above list is by no means a complete inventory of spawning times and all species that spawn at the Western Dry Rocks site. It does demonstrate that spawning activity takes place every month of the year. In addition, some snappers and groupers are ‘resident fish’ that stay on the site all year. For those reasons, we believe that this multi-species spawning aggregation site deserves special year-round protection from all fishing, both extractive and catch-and-release.
We believe that Transit Only, without the ability for users to troll, is vital for the protection of this area. A study published in 2005 documents the consequences of allowing trolling in Marine Protected Areas. Summarizing in layman terms, you cannot control what bites your lure, and it is also known that some of the biggest, strongest, and largest providers of egg and sperm will permanently reside in these spawning sites year-round. Allow the species to reproduce in peace, and you will see fish stocks explode throughout the reef tract.
Tortugas Ecological Reserve South
Last Stand supports Alternative 2 on page 172 that would expand an existing Transit Only zone by 18 square miles to better protect diverse habitat and species, including Riley’s Hump multi-species spawning aggregation.
Riley’s Hump is an unqualified success story. Expanding this zone will enhance protections for the spawning aggregations of Black Grouper and Cubera Snapper that have recently been documented on the western edge. Expanding this area will contribute to its continued success. It is likely that offspring from successful spawning at Riley’s Hump provide recruits to reef fish populations throughout the sanctuary. The economic impact of increased abundance of commercially targeted species, including Black Grouper, should mean that both recreational and commercial fishers will benefit by adopting Alternative 2.
Modifications to Marine Zones in General
Although our membership spreads throughout the Florida Keys, we do not have personal experience with all areas where changes in marine zones are considered in the Restoration Blueprint. To guide our opinions, Last Stand is using the following questions to frame our recommendations on changes to marine zones:
- What is the resource to be protected?
- Are there any users either advantaged or disadvantaged by the proposed change?
- Is the recommended alternative for change in zoning the best way to protect the resource and treat all users fairly?
Support for new and expanded SPAs for coral restoration
To be successful, coral restoration areas need more than casual protections. Establishing zones with No Anchor, Idle Speed and Transit Only will reduce conflicts between users and restoration teams and give the coral nurseries and restoration areas the opportunity to fulfill their potential. These zones are generally proposed to be small areas and we believe the tradeoff will benefit the long-term goals of the Sanctuary.
Last Stand supports the following alternatives proposed to protect coral nurseries and restoration sites:
Upper Keys Region
Key Largo Dry Rocks, Grecian Rocks, and North Rocks SPAs Alternative 2 on page 95 to expand from 0.2 to 1.2 sq. miles and create No Anchor and Idle Speed zone will protect an Acrophora coral restoration site.
New Zone: Pickles Reef SPA Alternative 2 on page 101would establish a 40-acre No Anchor and Idle Speed zone to protect active restoration sites for staghorn and elkhorn coral populations.
Davis Reef SPA Alternative 2 on page 104 would impose No Anchor and Idle Speed zone over 88 acres that contains a coral restoration site.
Middle Keys Region
Alligator Reef SPA Alternative 2 on page 115 adds 127 acres to an existing zone plus No Anchor and Idle Speed restrictions to protect an important staghorn coral restoration area.
New Zone: Marathon Key SPA Alternative 2 on page 121 would establish a 70-acre No Anchor and Idle Speed zone to protect an important coral nursery and provide an area for restoration of degraded coral reef.
New Zone: Delta Shoal SPA Alternative 2 on page 124 would establish 83 acres of No Anchor and Idle Speed to provide an area for restoration of degraded coral reef.
Lower Keys Region
Newfound Harbor Key SPA Alternative 2 on page 136 adds No Anchor and Idle Speed to an existing 107-acre SPA to protect a nearshore patch reef community that is being used for coral restoration.
Looe Key Conservation Area Alternative 4 on page 137 would reduce the size of the SPA to 2.3 sq. miles in the middle third of the existing management area while at the same time establishing a Transit Only conservation area into the eastern third of the existing zone. Protecting important restoration sites and the only remnant elkhorn coral thickets in the Lower Keys should be balanced against conflicting activities in this high-use dive and snorkel area. Retaining the SPA designation in the middle third will still allow access for dive and snorkel users.
New Zone: Key West Sanctuary SPA Alternative 2 on page 159 adds a 14-acre SPA that is provided for restoration of degraded coral reef ecosystem.
Support for new and expanded WMA for small, high priority nesting sites
A key aspect of the National Wildlife Refuges Complex that exists within the sanctuary is to promote breeding and abundance of birds, reptiles and manatees. Adding access restrictions in small areas to protect nesting birds and in shallow water to protect other wildlife is a high priority.
Last Stand recommends the following zoning changes be approved to support this purpose:
Upper Keys Region
New Zone: Barnes Card Sound WMA Alternative 2 on page 91 will establish a 628-acre No Motor zone in 1 to 2 feet of water to decrease disturbance to wading and nesting birds, gamefish and prevent further prop-scarring of seagrass.
Eastern Lake Surprise WMA Alternative 2 on page 92 changes No Access along shoreline to No Entry to better protect American crocodile and West Indian manatee.
New Zone: Pelican Key WMA Alternative 4 on page 96 establishes 23-acre No Entry zone to protect nesting pelican and magnificent frigatebirds.
New Zone: Pigeon Key WMA Alternative 2 on page 100 establishes a 51-acre No Entry zone near the Intracoastal Waterway to protect nesting birds.
Middle Keys Region
Snake Creek WMA Alternative 2 on page 111 would add 562 acres of No Motor zone south of Snake Creek channel towards Windley Key, with exceptions for channels, and places 31 acres of Idle Speed zone between shoreline and No Motor zones in shallow water subject to prop-scaring, in order to protect nesting bird habitat.
Cotton Key WMA Alternative 2 on page 112 adds 174 acres of No Motor zone and marks the channel as Idle Speed zone to protect nesting birds.
Lower Keys Region
New Zone: East Bahia Honda Key WMA Alternative 3 on page 131 would establish a 49-acre No Entry zone generally in 1 to 4 feet of water to protect nesting birds, including white crowned pigeon and great white heron.
New Zone: West Bahia Honda Key WMA Alternative 3 on page 132 would establish a 64-acre No Entry zone mainly in 2 feet of water, to protect nesting birds including white crowned pigeon and great white heron.
Horseshoe Key WMA Alternative 3 on page 133 converts an existing 107-acre No Access zone in shallow water bordering the island to a 138-acre No Entry zone to protect nesting and roosting birds.
New Zone: Little Pine Mangrove Key WMA Alternative 3 on page 134 establishes a 29-acre No Entry zone in 1 to 2 feet of water to protect nesting and roosting birds.
New Zone: Water Key Mangroves WMA Alternative 3 on page 135 establishes a 42-acre No Entry zone in 1 to 2 feet of water to protect nesting and roosting birds.
New Zone: Torch Key Mangroves WMA Alternative 3 on page 138 adds 29 acres No Entry zone in 1 – 2 feet of water to protect nesting and roosting birds.
New Zone: Crane Key WMA Alternative 3 on page 141 establishes a new 32-acre No Entry zone surrounding an island used for roosting and nesting.
New Zone: Northeast Tarpon Belly Keys WMA Alternative 3 on page 142 establishes a new 16-acre No Entry zone to protect nesting magnificent frigatebirds.
Sawyer Keys WMA Alternative 2 on page 143 adds 6 acres to an existing No Entry zone to protect nesting birds and ESA-listed sea turtle nesting habitat.
New Zone: Happy Jack (Galdin) Key WMA Alternative 3 on page 144 establishes a new No Entry zone of 86 acres to decrease disturbance of wading bird foraging habitat and nesting of reddish egret and great white heron.
East Harbor Key WMA Alternative 2 on page 150 converts a 15-acre No Access to No Entry zone. The zone protects nesting bald eagles and resting shorebirds.
Lower Harbor Keys WMA Alternative 2 on page 150 rearranges 42 acres of Idle Speed zone to increase the size to 47 acres. The area decreases disturbance of nesting and roosting birds.
Bay Keys WMA Alternative 3 would add 39 acres No Access and 8 acres Idle Speed zones in ½ to 1 foot of water to protect nesting and roosting birds.
New Zone: Demolition Key WMA Alternative 2 on page 153 would add 23 acres of No Entry zone to protect nesting and roosting birds.
New Zone: Archer Key WMA Alternative 3 on page 160 creates a 98-acre No Entry zone surrounding Archer Key to decrease disturbance to nesting and roosting birds and protect seagrass habitat, soft corals and sponges.
Boca Grande Keys WMA Alternative 2 on page 164 would slightly expand the No Entry zone north, east and offshore from the current zone to decrease disturbance of nesting and roosting birds and ESA-listed sea turtle nesting beaches.
Fireworks Permits Impacts on WMA
The use of fireworks within the FKNMS requires a special use permit. Special use permits are issued if they are compatible with the purposes for which the sanctuary is designated and with protection of sanctuary resources. Many existing and proposed Wildlife Management Areas are designated to decrease disturbance of nesting and roosting birds.
Loud fireworks displays cause birds to abandon their nests and established roosting habitat in alarm.
One of the goals, objectives and activities of the proposed FKNMS management plan is to reduce threats to sanctuary resources and manage human uses and associated impacts by evaluating cumulative impacts of permitted activities, such as fireworks, on sanctuary resources and modify permitting procedures as necessary to reduce those impacts.
There have been repetitive fireworks permits issued for discharge next to nesting and roosting bird habitats which have changed the behavior of the birds using the area. Last Stand recommends that the sanctuary modify their special use fireworks permit conditions so that a permit cannot be issued if the pyrotechnic display is to take place near a WMA.
Restrictions requiring Blue Star operator certification
Last Stand supports educating operators and users about how to enjoy and not damage the sanctuary waters and habitat. Blue Star certified operators have demonstrated that they are well- informed about sanctuary regulations and best practices. To remain certified, they should effectively share that information with their clients. However, we don’t think the lack of Blue Star certification is enough to exclude non-certified operators. We are aware of non-certified operators that do as good or better job of educating tourists in how to respect and comply with sanctuary regulations. As an alternative to requiring Blue Star certification to limit users at certain locations, we do encourage limiting the number of mooring balls in high use areas where corals and other benthic resources have not already been degraded by intensive use.
Last Stand opposes restrictions for only Blue Star commercial operators in these alternatives:
Upper Keys Region
Carysfort Reef SPA Alternative 3 on page 90 would add a restriction to require Blue Star certification for commercial operators.
Middle Keys Region
Sombrero Key SPA Alternative 3 on page 125 would add a restriction to require Blue Star certification for commercial operators.
Sand Key SPA Alternative 3 on page 159 would add the requirement for commercial operators to be Blue Star certified.
Mandatory Boater Education
Last Stand strongly recommends implementing a voluntary boater education course with the added provision that it would be mandatory for anyone renting a boat or personal watercraft for use within the sanctuary. This mandatory rental boater education should emphasize problems caused by operating in shallow water and the regulation requiring slow speeds within 100 yards of shorelines.
In addition, we recommend monitoring of prop-scarring to confirm that zoning and educating renters has decreased prop-scarring impacts in shallow waters. After changing zoning and increasing education, if there is no reduction in prop-scarring, we recommend that universal, mandatory boater education focused on protected shallow water areas should be implemented.
Protection of Cultural and Historical Resources
Last Stand supports developing an agreement with the Florida Department of State Division of Historical Resources and the Advisory Council on Historic Preservation that would prohibit the removal, injury, or possession of sanctuary historical resources (i.e. lighthouses and shipwrecks), limit work at these sites to permitted scientists, and create a single-permit system.
Cultural and historical resources are limited, and every effort must be undertaken to protect them. When examining land archeological sites, the law does not permit the removal of any artifact for private use, sale or distribution. Rather, cultural and historical artifacts are held and protected for the public. We recommend that this standard should also be required within the sanctuary for any sites not previously permitted for salvage operations.
Last Stand acknowledges that artificial reefs may sometimes act to decrease pressure on heavily- used dive sites within the sanctuary. Anecdotal evidence shows that instead of reducing the frequency of visits to intensively used sites, the presence of artificial reefs adds one more dive to a tourist’s trip. Concentration of target fish species may increase conflicts between wreck divers and spear fishers at the opening of season. We are not aware of evidence that increasing the presence of artificial reefs acts to increase the health of natural coral reefs. Absent scientific evidence of benefit to sanctuary resources, we do not recommend that the sanctuary issues new permits for artificial reefs.
Structure and Content of the Draft Environmental Impact Statement
Data supporting the analysis of socioeconomic resources and human uses in Section 4.6 beginning on page 235 often rely on U.S. Census Bureau information from 2010. More current data from the University of Florida Bureau of Economic and Business Research and the Office of Economic Demographic Research used by the Florida legislature would more accurately reflect current socioeconomic parameters in the Florida Keys, and we recommend that NOAA consider incorporating it in addition to Census Bureau data.
Presentation of the Socioeconomic Resources and Human Use in section 4.6 beginning on page 235 makes no mention of the previous opposition to the formation of the sanctuary and the current negative view of the sanctuary held by many vocal Florida Keys stakeholders. We cannot condone personal attacks voiced against sanctuary staff at public meetings, nor the short-sighted wishes of some groups to change nothing in the current sanctuary management plan. Ignoring this historic and continuing dynamic without addressing it when looking at the Alternatives hinders an objective discussion of what may be accomplished to improve the sanctuary. Recognizing the attitude of mistrust of the sanctuary, fears expressed about the economic impact of proposed changes to stakeholder livelihood and enjoyment of sanctuary resources will be an important part of future discussions with affected user groups to obtain buy-in.
The DEIS generally acknowledges conflicts between users and conservation goals. However, in the final EIS, we recommend that these stakeholder comments and concerns be addressed, particularly when the final Recommended Alternatives will continue or expand the objections these stakeholders have strongly expressed.
NOAA Staffing and Resources Required for Implementation
Individually, the cost to implement and enforce changes proposed in the DEIS may not be significant. However, the number of new zones proposed, the increased size of the sanctuary and enforcement of No Anchor / Idle Speed restrictions is indeed a significant issue, given current sanctuary staffing levels.
We believe that additional sanctuary staffing is essential to enforcing current regulations and will support NOAA efforts to increase Federal funding to ensure that new regulations adopted in this plan may be enforced.
As discussed earlier in this comment, we believe that mandatory boater education is an important component of protecting nearshore shallow seagrass habitat and hardbottom. We will support NOAA efforts to increase Federal funding to develop and administer mandatory boater education programs.
Education is not the only way to protect shallow habitats. We will support NOAA efforts to obtain additional funding to establish user-friendly and practical marking of both restricted and preferred access areas. We encourage the sanctuary to install physical markers where possible and practical and establish GPS coordinates for preferred routes and restricted areas. The sanctuary needs to take advantage of today’s best technology navigation tools as an effective way to communicate restrictions to users who have no local knowledge nor experience with sanctuary regulations.
There is great potential for achieving the conservation goals of the sanctuary through adopting alternatives in the DEIS. We are hopeful that our comments will help sanctuary staff to achieve these goals. We look forward to continued involvement in the process of preserving sanctuary resources for future generations.
For the Last Stand Board of Directors,
Mark E. Songer, President
Cc: Florida Fish and Wildlife Conservation Commission:
Robert A. Spottswood, Chairman
Michael W. Sole
 Final Report submitted to CH2M Hill on behalf of Florida Keys Aqueduct Authority dated April 14, 2014 by Briceno, Garcia, Gardinali, Boswell, Serna and Shinn. See Appendix A.
 Evaluation of SHORE Monitoring Stations in the Context of Nutrient Compliance Targets in Florida Keys National Marine Sanctuary dated May 1, 2019 by McKee. See Appendix B
 56th Gulf and Caribbean Fisheries Institute by Andrew David, NOAA Fisheries, Southeast Fisheries Science Center Attached as Appendix C