Draft Programmatic Environmental Assessment

# Wastewater Management Improvements

in the Florida Keys, Florida

![](media/image1.wmf)

Prepared For

The Federal Emergency Management Agency

Region IV

3003 Chamblee-Tucker Rd.

Atlanta, GA 30341

Prepared By

URS Group, Inc.

200 Orchard Ridge Drive, Suite 101

Gaithersburg, MD 20878

700 South Royal Poinciana Blvd. Suite 1000

Miami Springs, FL 33166

September 20, 2002

Section 1 Introduction [1-1](#section-1-1-introduction)

1.1 DISASTER BACKGROUND AND FEMA REGULATORY GUIDANCE
[1-1](#disaster-background-and-fema-regulatory-guidance)

1.2 THE PROGRAMMATIC ENVIRONMENTAL ANALYSIS PROCESS
[1-1](#the-programmatic-environmental-analysis-process)

1.3 THE IMPACTS OF WATER QUALITY DEGRADATION IN THE FLORIDA KEYS
[1-3](#the-impacts-of-water-quality-degradation-in-the-florida-keys)

1.4 SOURCES OF KEYS WATER QUALITY DEGRADATION
[1-4](#sources-of-keys-water-quality-degradation)

1.5 Focusing on Wastewater Management in the Florida Keys
[1-4](#focusing-on-wastewater-management-in-the-florida-keys)

1.6 WATER QUALITY DEGRADATION AND Long-Term Recovery
[1-7](#water-quality-degradation-and-long-term-recovery)

1.7 WATER QUALITY PROTECTION MEASURES AT THE LOCAL, STATE, AND FEDERAL
LEVELS
[1-8](#water-quality-protection-measures-at-the-local-state-and-federal-levels)

1.8 PURPOSE AND SCOPE OF THE draft PEA DOCUMENT
[1-9](#purpose-and-scope-of-the-draft-pea-document)

1.9 PURPOSE OF AND NEED FOR ACTION
[1-10](#purpose-of-and-need-for-action)

1.10 PUBLIC PARTICIPATION PROCESS AND REGULATORY FRAMEWORK
[1-10](#public-participation-process-and-regulatory-framework)

Section 2 Alternatives Evaluated
[2-1](#section-2-2-alternatives-evaluated)

2.1 ALTERNATIVE DEVELOPMENT BACKGROUND
[2-1](#alternative-development-background)

2.2 DECISION MODELS FOR WASTEWATER MANAGEMENT ALTERNATIVE DEVELOPMENT
[2-1](#decision-models-for-wastewater-management-alternative-development)

2.3 ALTERNATIVES EVALUATED [2-5](#alternatives-evaluated)

2.3.1 Alternative 1 -- No Action Alternative
[2-7](#alternative-1-no-action-alternative)

2.3.2 Alternative 2 -- Centralized Wastewater Treatment Plant
Alternative
[2-7](#alternative-2-centralized-wastewater-treatment-plant-alternative)

2.3.2.1 Wastewater Treatment Plant Collection Options:
[2-8](#wastewater-treatment-plant-collection-options)

2.3.2.1.1 Collection Option 1 -- Vacuum Pumping
[2-8](#collection-option-1-vacuum-pumping)

2.3.2.1.2 Collection Option 2 -- Low-Pressure Grinder Pump Sewer System
[2-9](#collection-option-2-low-pressure-grinder-pump-sewer-system)

2.3.2.2 Wastewater Treatment Plant Effluent Disposal Options:
[2-9](#wastewater-treatment-plant-effluent-disposal-options)

2.3.2.2.1 Disposal Option 1 -- Shallow Injection Wells
[2-9](#disposal-option-1-shallow-injection-wells)

2.3.2.2.2 Disposal Option 2 - Wastewater Reuse
[2-12](#disposal-option-2---wastewater-reuse)

2.3.3 Alternative 3 -- On-Site Treatment Upgrades
[2-13](#alternative-3-on-site-treatment-upgrades)

2.4 ALTERNATIVES CONSIDERED BUT DISMISSED
[2-13](#alternatives-considered-but-dismissed)

2.4.1 Collection Options Under Alternative 2
[2-14](#collection-options-under-alternative-2)

2.4.2 On-site Treatment Options Under Alternative 3
[2-15](#on-site-treatment-options-under-alternative-3)

Section 3 Affected Environment and Environmental Consequences
[3-1](#section-3-3-affected-environment-and-environmental-consequences)

3.1 Topography, Soils, and Geology [3-1](#topography-soils-and-geology)

3.1.1 Topography [3-1](#topography)

3.1.1.1 Affected Environment [3-1](#affected-environment)

3.1.1.2 Environmental Consequences [3-2](#environmental-consequences)

3.1.2 Soils [3-2](#soils)

3.1.2.1 Affected Environment [3-2](#affected-environment-1)

3.1.2.2 Environmental Consequences [3-4](#environmental-consequences-1)

3.1.3 Geology [3-4](#geology)

3.1.3.1 Affected Environment [3-4](#affected-environment-2)

3.1.3.1.1 Upper Water-Bearing Zone [3-7](#upper-water-bearing-zone)

3.1.3.1.2 Floridan Aquifer System [3-8](#floridan-aquifer-system)

3.1.3.2 Environmental Consequences [3-10](#environmental-consequences-2)

3.1.3.2.1 Alternative 1 -- No Action Alternative
[3-10](#alternative-1-no-action-alternative-1)

3.1.3.2.2 Alternative 2 -- Centralized Wastewater Treatment Plant
Alternative
[3-10](#alternative-2-centralized-wastewater-treatment-plant-alternative-1)

3.1.3.2.3 Alternative 3 -- On-Site Treatment Upgrades
[3-12](#alternative-3-on-site-treatment-upgrades-1)

3.2 WATER RESOURCES AND WATER QUALITY
[3-13](#water-resources-and-water-quality)

3.2.1 Regulatory Setting [3-13](#regulatory-setting)

3.2.2 Groundwater [3-15](#groundwater)

3.2.2.1 Affected Environment [3-15](#affected-environment-3)

3.2.2.2 Environmental Consequences [3-17](#environmental-consequences-3)

3.2.2.2.1 Alternative 1 -- No Action Alternative
[3-17](#alternative-1-no-action-alternative-2)

3.2.2.2.2 Alternative 2 -- Centralized Wastewater Treatment Plant
Alternative
[3-18](#alternative-2-centralized-wastewater-treatment-plant-alternative-2)

3.2.2.2.3 Alternative 3 -- On-Site Treatment Upgrades
[3-19](#alternative-3-on-site-treatment-upgrades-2)

3.2.3 Inland, Nearshore, and Offshore Waters
[3-21](#inland-nearshore-and-offshore-waters)

3.2.3.1 Affected Environment [3-21](#affected-environment-4)

3.2.3.1.1 Inland Waters [3-21](#inland-waters)

3.2.3.1.2 Nearshore and Offshore Marine Waters
[3-22](#nearshore-and-offshore-marine-waters)

3.2.3.1.3 Stormwater [3-23](#stormwater)

3.2.3.2 Environmental Consequences [3-27](#environmental-consequences-4)

3.2.3.2.1 Alternative 1 -- No Action Alternative
[3-27](#alternative-1-no-action-alternative-3)

3.2.3.2.2 Alternative 2 -- Centralized Wastewater Treatment Plant
Alternative
[3-27](#alternative-2-centralized-wastewater-treatment-plant-alternative-3)

3.2.3.2.3 Alternative 3 -- On-Site Treatment Upgrades
[3-29](#alternative-3-on-site-treatment-upgrades-3)

3.2.4 Floodplains and Wetlands [3-29](#floodplains-and-wetlands)

3.2.4.1 Affected Environment [3-29](#affected-environment-5)

3.2.4.1.1 Floodplains [3-29](#floodplains)

3.2.4.1.2 Wetlands [3-32](#wetlands)

3.2.4.2 Environmental Consequences [3-32](#environmental-consequences-5)

3.2.4.2.1 Alternative 1 -- No Action Alternative
[3-32](#alternative-1-no-action-alternative-4)

3.2.4.2.2 Alternative 2 -- Centralized Wastewater Treatment Plant
Alternative
[3-33](#alternative-2-centralized-wastewater-treatment-plant-alternative-4)

3.2.4.2.3 Alternative 3 -- On-Site Treatment Upgrades
[3-34](#alternative-3-on-site-treatment-upgrades-4)

3.3 Biological Resources [3-35](#biological-resources)

3.3.1 Affected Environment [3-35](#affected-environment-6)

3.3.1.1 Terrestrial Environment [3-35](#terrestrial-environment)

3.3.1.1.1 Pine Rocklands and Tropical Hardwood Hammocks
[3-35](#pine-rocklands-and-tropical-hardwood-hammocks)

3.3.1.1.2 Mangrove Forests and Salt Marshes
[3-36](#mangrove-forests-and-salt-marshes)

3.3.1.1.3 Freshwater Systems [3-37](#freshwater-systems)

3.3.1.1.4 Dunes and Coastal Ridges [3-37](#dunes-and-coastal-ridges)

3.3.1.2 Aquatic Environment [3-38](#aquatic-environment)

3.3.1.2.1 Seagrass Beds and Sand Flats
[3-38](#seagrass-beds-and-sand-flats)

3.3.1.2.2 Coral Reefs [3-38](#coral-reefs)

3.3.1.2.3 Hardbottom [3-40](#hardbottom)

3.3.1.2.4 Sandy Bottom [3-40](#sandy-bottom)

3.3.2 Environmental Consequences [3-40](#environmental-consequences-6)

3.3.2.1 Alternative 1 -- No Action Alternative
[3-40](#alternative-1-no-action-alternative-5)

3.3.2.2 Alternative 2 -- Centralized Wastewater Treatment Plant
Alternative
[3-41](#alternative-2-centralized-wastewater-treatment-plant-alternative-5)

3.3.2.3 Alternative 3 -- On-Site Treatment Upgrades
[3-42](#alternative-3-on-site-treatment-upgrades-5)

3.3.3 Special Status Species [3-43](#special-status-species)

3.3.3.1 Affected Environment [3-43](#affected-environment-7)

3.3.3.2 Environmental Consequences [3-44](#environmental-consequences-7)

3.3.3.2.1 Alternative 1 -- No Action Alternative
[3-44](#alternative-1-no-action-alternative-6)

3.3.3.2.2 Alternative 2 -- Centralized Wastewater Treatment Plant
Alternative
[3-45](#alternative-2-centralized-wastewater-treatment-plant-alternative-6)

3.3.3.2.3 Alternative 3 -- On-Site Treatment Upgrades
[3-46](#alternative-3-on-site-treatment-upgrades-6)

3.4 Air Quality [3-47](#air-quality)

3.4.1 Affected Environment [3-47](#affected-environment-8)

3.4.2 Environmental Consequences [3-48](#environmental-consequences-8)

3.4.2.1 Alternative 1---No Action Alternative
[3-48](#alternative-1no-action-alternative)

3.4.2.2 Alternative 2 -- Centralized Wastewater Treatment Plant
[3-48](#alternative-2-centralized-wastewater-treatment-plant)

3.4.2.3 Alternative 3 -- On-Site Treatment Upgrades
[3-49](#alternative-3-on-site-treatment-upgrades-7)

3.5 CULTURAL Resources [3-50](#cultural-resources)

3.5.1 Affected Environment [3-50](#affected-environment-9)

3.5.1.1 Paleo-Indian Period (ca. 12,000 to 10,000 BP)
[3-50](#paleo-indian-period-ca.-12000-to-10000-bp)

3.5.1.2 Archaic Period (ca. 10,000 to 3,000 BP)
[3-51](#archaic-period-ca.-10000-to-3000-bp)

3.5.1.3 Glades Period (ca. 2,500 BP to AD 1500)
[3-51](#glades-period-ca.-2500-bp-to-ad-1500)

3.5.1.4 Historic Period (ca. Mid-1500s to 1951)
[3-51](#historic-period-ca.-mid-1500s-to-1951)

3.5.1.5 Monroe County Cultural Resources
[3-52](#monroe-county-cultural-resources)

3.5.2 Environmental Consequences [3-53](#environmental-consequences-9)

3.5.2.1 Alternative 1 -- No Action Alternative
[3-53](#alternative-1-no-action-alternative-7)

3.5.2.2 Alternative 2 -- Centralized Wastewater Treatment Plant
Alternative
[3-53](#alternative-2-centralized-wastewater-treatment-plant-alternative-7)

3.5.2.3 Alternative 3 -- On-Site Treatment Upgrades
[3-54](#alternative-3-on-site-treatment-upgrades-8)

3.6 Socioeconomic Resources [3-55](#socioeconomic-resources)

3.6.1 Tourism [3-55](#tourism)

3.6.1.1 Affected Environment [3-55](#affected-environment-10)

3.6.1.2 Environmental Consequences
[3-56](#environmental-consequences-10)

3.6.1.2.1 Alternative 1 -- No Action Alternative
[3-56](#alternative-1-no-action-alternative-8)

3.6.1.2.2 Alternative 2 -- Centralized Wastewater Treatment Plant
Alternative
[3-57](#alternative-2-centralized-wastewater-treatment-plant-alternative-8)

3.6.1.2.3 Alternative 3 -- On-Site Treatment Upgrades
[3-57](#alternative-3-on-site-treatment-upgrades-9)

3.6.2 Fishing Industry [3-57](#fishing-industry)

3.6.2.1 Affected Environment [3-57](#affected-environment-11)

3.6.2.2 Environmental Consequences
[3-59](#environmental-consequences-11)

3.6.2.2.1 Alternative 1 -- No Action Alternative
[3-59](#alternative-1-no-action-alternative-9)

3.6.2.2.2 Alternative 2 -- Centralized Wastewater Treatment Plant
Alternative
[3-59](#alternative-2-centralized-wastewater-treatment-plant-alternative-9)

3.6.2.2.3 Alternative 3 -- On-Site Treatment Upgrades
[3-59](#alternative-3-on-site-treatment-upgrades-10)

3.6.3 Local Fees and Taxes [3-59](#local-fees-and-taxes)

3.6.3.1 Affected Environment [3-59](#affected-environment-12)

3.6.3.1.1 Existing Wastewater Management Costs in Monroe County
[3-60](#existing-wastewater-management-costs-in-monroe-county)

3.6.3.1.2 Wastewater Management Costs and Affordability for Florida Keys
Residents
[3-62](#wastewater-management-costs-and-affordability-for-florida-keys-residents)

3.6.3.1.3 Wastewater Management Costs and Affordability for Keys
Businesses
[3-64](#wastewater-management-costs-and-affordability-for-keys-businesses)

3.6.3.2 Environmental Consequences
[3-65](#environmental-consequences-12)

3.6.3.2.1 Alternative 1 -- No Action Alternative
[3-65](#alternative-1-no-action-alternative-10)

3.6.3.2.2 Alternative 2 -- Centralized Wastewater Treatment Plant
Alternative
[3-66](#alternative-2-centralized-wastewater-treatment-plant-alternative-10)

3.6.3.2.3 Alternative 3 -- On-Site Treatment Upgrades
[3-68](#alternative-3-on-site-treatment-upgrades-11)

3.6.4 Public Health [3-69](#public-health)

3.6.4.1 Affected Environment [3-69](#affected-environment-13)

3.6.4.2 Environmental Consequences
[3-71](#environmental-consequences-13)

3.6.4.2.1 Alternative 1---No Action Alternative
[3-71](#alternative-1no-action-alternative-1)

3.6.4.2.2 Alternative 2 -- Centralized Wastewater Treatment Plant
[3-72](#alternative-2-centralized-wastewater-treatment-plant-1)

3.6.4.2.3 Alternative 3 -- On-Site Treatment Upgrades
[3-72](#alternative-3-on-site-treatment-upgrades-12)

3.7 Demographics and Environmental Justice
[3-73](#demographics-and-environmental-justice)

3.7.1 Affected Environment [3-73](#affected-environment-14)

3.7.1.1 Population and Race [3-73](#population-and-race)

3.7.1.2 Income and Poverty [3-74](#income-and-poverty)

3.7.1.3 Wastewater Management Costs and Affordability for Keys
Lower-Income Residents
[3-76](#wastewater-management-costs-and-affordability-for-keys-lower-income-residents)

3.7.1.4 Alternative 1 -- No Action Alternative
[3-77](#alternative-1-no-action-alternative-11)

3.7.1.5 Alternative 2 -- Centralized Wastewater Treatment Plant
Alternative
[3-78](#alternative-2-centralized-wastewater-treatment-plant-alternative-11)

3.7.1.6 Alternative 3 -- On-Site Treatment Upgrades
[3-80](#alternative-3-on-site-treatment-upgrades-13)

3.8 Hazardous Materials and Wastes
[3-81](#hazardous-materials-and-wastes)

3.8.1 Affected Environment [3-81](#affected-environment-15)

3.8.2 Environmental Consequences [3-82](#environmental-consequences-14)

3.8.2.1 Alternative 1 -- No Action Alternative
[3-82](#alternative-1-no-action-alternative-12)

3.8.2.2 Alternative 2 -- Centralized Wastewater Treatment Plant
Alternative
[3-82](#alternative-2-centralized-wastewater-treatment-plant-alternative-12)

3.8.2.3 Alternative 3 -- On-Site Treatment Upgrades
[3-83](#alternative-3-on-site-treatment-upgrades-14)

3.9 Infrastructure [3-84](#infrastructure)

3.9.1 Traffic and Circulation [3-84](#traffic-and-circulation)

3.9.1.1 Affected Environment [3-84](#affected-environment-16)

3.9.1.1.1 Alternative 1 -- No Action Alternative
[3-85](#alternative-1-no-action-alternative-13)

3.9.1.1.2 Alternative 2 -- Centralized Wastewater Treatment Plant
[3-85](#alternative-2-centralized-wastewater-treatment-plant-2)

3.9.1.1.3 Alternative 3 -- On-Site Treatment Upgrades
[3-86](#alternative-3-on-site-treatment-upgrades-15)

3.9.2 Utilities and Services [3-86](#utilities-and-services)

3.9.2.1 Affected Environment [3-86](#affected-environment-17)

3.9.2.2 Environmental Consequences
[3-87](#environmental-consequences-15)

3.9.2.2.1 Alternative 1 -- No Action Alternative
[3-87](#alternative-1-no-action-alternative-14)

3.9.2.2.2 Alternative 2 -- Centralized Wastewater Treatment Plant
[3-87](#alternative-2-centralized-wastewater-treatment-plant-3)

3.9.2.2.3 Alternative 3 -- On-Site Treatment Upgrades
[3-88](#alternative-3-on-site-treatment-upgrades-16)

3.10 Land Use and Planning [3-89](#land-use-and-planning)

3.10.1 Affected Environment [3-89](#affected-environment-18)

3.10.1.1 Future Land Use and Planning
[3-90](#future-land-use-and-planning)

3.10.1.2 Land Use, Planning, and Wastewater Management
[3-93](#land-use-planning-and-wastewater-management)

3.10.1.3 Conservation and Recreation Lands
[3-94](#conservation-and-recreation-lands)

3.10.1.4 Coastal Zone [3-94](#coastal-zone)

3.10.1.5 Barrier Island Resources [3-94](#barrier-island-resources)

3.10.2 Environmental Consequences [3-96](#environmental-consequences-16)

3.10.2.1 Alternative 1 -- No Action Alternative
[3-96](#alternative-1-no-action-alternative-15)

3.10.2.2 Alternative 2 -- Centralized Wastewater Treatment Plant
Alternative
[3-97](#alternative-2-centralized-wastewater-treatment-plant-alternative-13)

3.10.2.3 Alternative 3 -- On-Site Treatment Upgrades
[3-98](#alternative-3-on-site-treatment-upgrades-17)

3.11 NOISE AND Visual Resources [3-100](#noise-and-visual-resources)

3.11.1 Noise [3-100](#noise)

3.11.1.1 Affected Environment [3-100](#affected-environment-19)

3.11.1.2 Environmental Consequences
[3-101](#environmental-consequences-17)

3.11.1.2.1 No Action Alternative, Centralized WWTP Alternative, and
OWNRS Alternative
[3-102](#no-action-alternative-centralized-wwtp-alternative-and-ownrs-alternative)

3.11.2 Visual Resources [3-105](#visual-resources)

3.11.2.1 Affected Environment [3-105](#affected-environment-20)

3.11.2.2 Environmental Consequences
[3-105](#environmental-consequences-18)

Section 4 Cumulative Impacts [4-1](#section-4-4-cumulative-impacts)

4.1 Concurrent Projects [4-1](#concurrent-projects)

4.1.1 Comprehensive Wastewater Management Activities
[4-1](#comprehensive-wastewater-management-activities)

4.1.2 Comprehensive Stormwater Management Activities
[4-1](#comprehensive-stormwater-management-activities)

4.1.3 Everglades Restoration [4-1](#everglades-restoration)

4.2 Cumulative Impacts [4-2](#cumulative-impacts)

4.2.1 Topography, Soils, and Geology
[4-2](#topography-soils-and-geology-1)

4.2.2 Water Resources and Water Quality
[4-2](#water-resources-and-water-quality-1)

4.2.3 Biological Resources [4-3](#biological-resources-1)

4.2.4 Air Quality [4-3](#air-quality-1)

4.2.5 Cultural Resources [4-4](#cultural-resources-1)

4.2.6 Socioeconomics [4-4](#socioeconomics)

4.2.7 Demographics and Environmental Justice
[4-4](#demographics-and-environmental-justice-1)

4.2.8 Hazardous Materials [4-4](#hazardous-materials)

4.2.9 Infrastructure [4-5](#infrastructure-1)

4.2.10 Land Use and Planning [4-5](#land-use-and-planning-1)

4.2.11 Noise and Visual Resources [4-5](#noise-and-visual-resources-1)

Section 5 Public Involvement [5-1](#section-5-5-public-involvement)

Section 6 List of Preparers [6-1](#section-6-6-list-of-preparers)

Section 7 References [7-1](#section-7-7-references)

Tables Page

Table 1-1 Recent Chronology of Regulatory Milestones of Regulatory
Milestones of Wastewater Management in the Florida Keys 1-9

Table 2-1 Quality Standards for Discharged Effluent 2-12

Table 3-1 Big Pine Key Treatment System Nutrient Removal Rates 3-20

Table 3-2 Year 2000 Maximum Recorded Criteria Pollutant Levels for
Monroe and Neighboring Counties in Florida 3-47

Table 3-3 Trends in Monroe County Fishery 3-58

Table 3-4 Connection Fees and Monthly Sewer Charges for Non-2010
Compliant Monroe County WWTPs per EDU 3-61

Table 3-5 Estimated Monthly Charges for Non-Compliant Wastewater Systems
per EDU 3-62

Table 3-6 Estimated Average Monthly Expenses for Households in the
Florida Keys 3-63

Table 3-7 Selection of Monthly Wastewater Rates for Cities in Florida
and Across the U.S. 3-64

Table 3-8 Approximate Monthly Charges for Existing 2010 Compliant
Wastewater Systems per EDU 3-65

Table 3-9 Approximate Centralized WWTP Costs 3-67

Table 3-10 Enteric Disease Counts of Monroe and Neighboring Counties
(1999) 3-70

Table 3-11 Functional Population of Monroe County (1990-2015) 3-73

Table 3-12 Discretionary Income of Low-Income Residents -- 2001/2002
3-76

Table 3-13 Existing Land Use Classification for Monroe County 3-89

Table 3-14 Approximate Noise Levels in Decibels Based on Land Uses
(representing project sites) 3-100

Table 3-15 Addition of Decibels 3-101

Table 3-16 Noise Levels Associated with Common Construction Activities
3-103

Table 3-17 Noise Levels Associated with Wastewater Treatment Plant
Operations 3-103

Figures

Figure 1-1 Vicinity Map 1-2

Figure 1-2 Process Schematics for Wastewater Treatment Options for the
Florida Keys 1-6

Figure 2-1 Upper Keys Wastewater Management and Hot Spots 2-2

Figure 2-2 Middle Keys Wastewater Management and Hot Spots 2-3

Figure 2-3 Lower Keys Wastewater Management and Hot Spots 2-4

Figure 2-4 Decision-Making Process for Wastewater Management
Alternatives 2-6

Figure 2-5 Shallow Injection Wells 2-10

Figure 3-1 Tidal Movement in the Florida Keys 3-3

Figure 3-2 Submarine Topography 3-5

Figure 3-3 Floridan Aquifer 3-6

Figure 3-4 Boulder Zone of Southern Florida 3-9

Figure 3-5 Groundwater Circulation in the Floridan Aquifer System 3-11

Figure 3-6 Stormwater Retrofit and Rehabilitation Projects 3-26

Figure 3-7 Monroe County Floodplain 3-31

Figure 3-8 Monroe County Minority Status 3-75

Figure 3-9 Map of Coastal Barrier Resource System Units 3-95

Appendices

Appendix A Acronyms

Appendix B Definitions\*

Appendix C Hot Spot Locations

Appendix D Water Quality Improvement Analysis

Appendix E Applicable Permit Information

Appendix F Federally Listed Species in Monroe County and Fishery Species

Appendix G Federal and State Agency Correspondence

Appendix H Funding and Financing Options

Appendix I Public Notice

Appendix J Supporting Information for the Low-Income Demographic

\*NOTE: Those words whose first occurrence is in bold text in the
document body are defined in Appendix B for reader assistance.

# Section 1 1 Introduction

## DISASTER BACKGROUND AND FEMA REGULATORY GUIDANCE

In 1998, after Hurricane Georges, Congress enacted Public Law 106-31,
Emergency Supplemental Appropriations Act for Fiscal Year 1999, to
provide additional monies for long-term disaster recovery projects in
the State of Florida. The funds were allocated to assist counties whose
needs were yet unmet through allocation of primary disaster relief
funds. This Unmet Needs money was earmarked for the counties most
impacted by Hurricane Georges, including Monroe County. The Federal
Emergency Management Agency (FEMA), State of Florida, and the impacted
counties determined funding priorities. Monroe County requested that
wastewater management improvement projects be considered for disaster
funding since many existing wastewater facilities in Monroe County are
not storm-resistant, do not provide adequate treatment, and contribute
greatly to degraded water quality in the Keys (Figure 1-1). Since then,
FEMA has received grant applications from the Village of Islamorada
(Islamorada) and the Keys Aqueduct Authority (FKAA) requesting Federal
assistance to upgrade or replace their existing wastewater treatment
facilities.

Unmet Needs funding is a one-time distribution of funds and is
administered by FEMA and the Florida Division of Emergency Management
through a grant process. The Act provides communities with cost-share
funds for projects that can reduce future hazard disaster-related
property damages and loss of human lives. The Act's implementing
regulations provide FEMA with a regulatory framework for administering
these funds. These were published on August 8, 1999 in Volume 64, Number
151 of the Federal Register.

## THE PROGRAMMATIC ENVIRONMENTAL ANALYSIS PROCESS

FEMA is considering the provision of funding assistance related to
several proposed alternatives, which are designed to improve wastewater
treatment, and ultimately water quality, in the Keys. The **National
Environmental Policy Act** of 1969 **(NEPA)**, Council on Environmental
Quality (CEQ) regulations implementing NEPA (40 Code of Federal
Regulations \[CFR\] Parts 1500 to 1508), and FEMA regulations for NEPA
compliance (44 CFR Part 10) direct FEMA to fully understand and take
into consideration during decision making, the environmental
consequences of proposed Federal actions (projects). Accordingly, FEMA
prepared this draft **Programmatic Environmental Assessment** (**PEA**)
on the effects of implementation of a range of wastewater collection,
treatment, and disposal alternatives proposed in the Keys.

FEMA has determined through experience that the majority of the typical
recurring actions proposed for funding, and for which an Environmental
Assessment (EA) is required, can be grouped by type of action or
location. These groups of actions can be evaluated in a PEA to comply
with NEPA and its implementing regulations without having to produce a
stand-alone EA for every action.

**FIGURE 1-1, VICINITY MAP**

Because actions proposed for funding under this draft PEA and impacts of
these actions can vary based on location, alternatives, and other
site-specific criteria, a **supplemental environmental review** document
(**SER**) will be prepared for each individual project covered by this
draft PEA. The resulting SER will tier off this draft PEA, in accordance
with 40 CFR Part 1508.28, and consist of either a **Supplemental
Environmental Assessment** (**SEA**) or **Environmental Impact**
**Statement (EIS).** Projects for which it has been determined that
potentially **significant**, adverse impacts exist will go through the
EIS process as required by NEPA.

This draft PEA applies to centralized wastewater improvement actions and
on-site system upgrades using nutrient removal systems proposed for FEMA
funding. The analysis in this draft PEA has relied upon FEMA's historic
experience of project typology, description, and consequences described
in environmental documents (Categorical Exclusions \[CATEXs\] and EAs).
Analysis in this draft PEA is also based on review of scientific
literature, consultation with regulatory agencies, and expert opinion.
To support the data presented in this document, Section 6 has a list of
State and Federal agencies consulted during this analysis; Section 7
lists the individuals involved in the technical research, evaluation,
writing, and peer review of this draft PEA and their experience; and
Section 8 provides a summary of text, internet, and interview references
used to create this document.

## THE IMPACTS OF WATER QUALITY DEGRADATION IN THE FLORIDA KEYS 

The complex and dynamic environment of the Keys is reliant upon clear
waters, low in nutrients and sediment, to support numerous endemic
species, sustain the world's third largest coral reef system, and
provide the economic lifeblood of the Keys in terms of tourism and the
fishing industry. While the beauty and diversity of environmental
attributes in the Keys create a world-renowned location, those same
attributes draw millions of visitors a year to the Keys and have
provided reason for a boom in population growth and rapid development.
Human activities have negatively impacted the ecological balance of the
Keys ecosystem where changes to the physical-chemical conditions that
result in direct effect on one community type can affect adjacent
community types (Voss, 1988; Kruczynski, 1999). The continued
degradation in water quality and in the abundance and vitality of
seagrass beds, coral reefs, and numerous marine species is evidence that
the cumulative effects of continued nutrient loading from the Keys and
other sources is upsetting the Keys equilibrium. The economy and quality
of life of Keys residents, which depend upon a vital marine environment,
are being affected. Fecal contamination resulting from poorly treated
wastewater, presents not only a public health risk, but could lead to
additional beach advisories, which may affect tourism in the long-term
if degraded water quality is left unabated. Considering that 70% of
tourism in the Keys, which generates over \$1.3 billion per year and
supports over 21,000 jobs, is founded on water-based activities such as
fishing, snorkeling, beach activities, and observing wildlife and nature
(English, et al., 1996), it seems that the way of life in the Keys is
dependent upon good water quality. It should be noted that improving
wastewater treatment would improve the water quality of inland and
nearshore waters; however, pollution from wastewater is only one of
several sources of contamination as described in the following section.

## SOURCES OF KEYS WATER QUALITY DEGRADATION

Wastewater treatment and management and stormwater management practices
in the Keys have not advanced to serve the growing Keys populations
adequately. Many recent studies evaluating the state of the Keys
environment conclude that wastewater discharges and stormwater runoff
and canal flushing contribute greatly to water quality degradation. Of
the nutrient pollution emanating from the Keys, discharges from **septic
tanks**, **cesspits**, and shallow (90 feet) **injection well**s,
account for 80% of the nitrogen and 55 to 56% of the phosphorus loading
to nearshore waters. Similarly, 20% of the nitrogen and 44 to 45% of the
phosphorus loads from the Keys to the nearshore waters are deposited by
stormwater runoff (EPA, 1996; Kruczynski, 1999).

In addition to the Keys' inadequate stormwater and wastewater
management, several additional sources of nutrient loading have been
found to contribute to water quality degradation, including Florida Bay,
the Gulf of Mexico, oceanic upwelling, and atmospheric deposition.

Florida Bay, a shallow embayment composed of basins separated by mud
banks and mangrove islands bordering the Keys' northwestern edge, has
represented a source of nutrient-rich and turbid waters to the Keys for
about the last 4,000 years (Kruczynski, 1999). Cook (1997) and others
have found that the turbid, nutrient-rich waters of Florida Bay is
having a detrimental effect on coral reef communities seaward of the
tidal passes in the Keys.

In a study examining nutrient sources to Florida Bay, Rudnick et al.
(1999) found that nitrogen and phosphorus inputs from the Gulf of Mexico
greatly exceeded inputs from the Everglades National Park in South
Florida. The freshwater Everglades were identified with contributing
less than 3% of all phosphorus inputs and less than 12% of all nitrogen
inputs to Florida Bay. Additional research is required to assess the
source of nutrients in the Gulf of Mexico. The nutrients entering
Florida Bay from South Florida were primarily attributed to runoff from
agriculture and residential areas, natural nutrient levels, oceanic
upwelling and atmospheric deposition (Rudnick, et al., 1999). The
oceanic upwelling in this case results from the upwelling of deep, cool,
nutrient-rich water driven by the Florida current.

Although numerous studies identify water quality degradation and propose
potential sources, very little quantitative data exists that
specifically addresses the relative contributions to nutrient pollution
in nearshore and offshore marine water in the Keys. Kruczynski (1999)
emphasizes that although nutrient inputs from sources external to the
Keys may be equal to or greater than **anthropogenic** loadings from
wastewater and stormwater coming from the Keys; anthropogenic nutrient
loadings and their effects on water quality and biological resources are
no less important. As discussed in this draft PEA and in other studies,
localized nutrient sources, such as those from on-site wastewater
systems, can have immediate negative impacts that can result in
"cascading" effects through the ecosystem (Kruczynski, 1999, Lapointe et
al., 1990, Lapointe and Clark, 1992, Paul et al., 1995a, EPA, 1993a, and
others). Additionally, wastewater nutrients seep out of the
bedrock/aquifer and may cause concentration increases in canals and
confined nearshore waters well above those caused from atmospheric and
other sources (Kruczynski, 1999).

## Focusing on Wastewater Management in the Florida Keys

Wastewater management in Monroe County consists of a variety of
collection, treatment, and disposal methods. Currently, about 23,000
private on-site systems and 246 small **Wastewater Treatment Plants**
(**WWTP**) are operating throughout the Keys (Figure 1-2). It is
estimated that of the 23,000 on-site systems, 15,200 are permitted
septic systems, 640 are Aerobic Treatment Units (ATU), and 7,200 are
unknown systems, of which 2,800 are suspected to be illegal cesspits
(Monroe County, 2000a). Given the variety of wastewater collection,
treatment, and disposal methods currently used in the Keys, effective
treatment of the wastewater stream varies greatly as well.

Under **primary treatment**, large solids, settleable solids, greases,
oils, and other floatable materials are separated from the wastewater.
This level of treatment clarifies the **effluent** to some extent, but
does not remove all the nitrogen, phosphorus, suspended solids, or other
pollutants from the effluent. In general, it is estimated that primary
treatment removes 40 to 50% of the organic wastes responsible for
**biochemical oxygen demand (BOD)** and minimal nutrient removal. Thus,
levels of nitrogen, phosphorus, and other contaminants remain high in
effluent treated via primary methods (National Research Council, 1993).
**Secondary treatment** uses primary treatment and a second level of
either biological or chemical treatment to remove more solids and
nutrients. For example, activated sludge treatment, a common form of
secondary treatment, removes about 89 to 97% of **total suspended solids
(TSS)** and 86 to 98% of organic wastes responsible for BOD. While a
substantial improvement over primary treatment alone, this secondary
process removes no more than 63% of **total nitrogen (TN)** and 66% of
phosphorus (National Research Council, 1993).

On-site systems, which are common in the Keys, are much less effective
at removing nutrients. Kruczynski (1999) estimates that properly
functioning septic systems remove only 4% nitrogen and 15% phosphorus.
An ATU system provides secondary treatment and can remove 80 to 90% of
the TSS and organic wastes resulting in BOD, but is not effective at
removing dissolved nutrients; in fact, an ATU removes only slightly more
nitrogen than a septic system (Kruczynski, 1999). Cesspits provide
little to no effluent treatment, and effluent and associated nutrients
can migrate rapidly to surface and ground waters.

Overall, with exception of the WWTPs, Keys' wastewater management
consists largely of systems with limited effective effluent treatment.
The degraded water quality of the Keys demonstrates a need for holistic
wastewater system improvements area-wide.

A number of recent studies have documented the contribution of failing
septic tanks and **cesspools** to the deterioration of Keys' canal and
nearshore marine water quality. Lapointe et al. (1990) and Lapointe and
Clark (1992) found that the use of septic tanks increase nutrient
concentrations in the groundwaters that discharge into shallow nearshore
marine waters, resulting in coastal **eutrophication**. The studies
attribute increased algal blooms, seagrass die-off, and the loss of
coral cover on patch and bank reef ecosystems to inadequate on-site
wastewater management systems. Additionally, Paul et al. (1995a) and
Shinn et al. (1994) found fecal indicator bacteria in groundwater and
marine waters surrounding the Keys.

FIGURE 1-2, PROCESS SCHEMATICS FOR WASTEWATER TREATMENT OPTIONS FOR THE
FLORIDA KEYS

A direct connection with septic tank waste disposal and the nearshore
marine waters was shown by a viral tracer study in Key Largo. Tracers
added to a domestic septic tank appeared in a canal in 11 hours and in
nearshore marine waters in 23 hours (Paul et al., 1995a). An ensuing
study that used a simulated injection well in Key Largo and an active
disposal well in the Middle Keys found that viral tracers appeared after
short periods of time in groundwater (8 hours after injection) and
marine waters (10 hours and 53 hours for Key Largo and the Middle Keys,
respectively) (Paul et al, 1997). The study indicated that present
wastewater practices allow inadequately treated effluent to make its way
rapidly to marine waters where it "may contribute to water quality
degradation" (Paul et al., 1997). The U.S. Environmental Protection
Agency (EPA) found that the observations and studies, together with the
magnitude and extent of estimated nutrient loadings from wastewater
sources are a strong indication that domestic wastewater sources are
regionally substantial (EPA, 1993a).

## WATER QUALITY DEGRADATION AND Long-Term Recovery

Most of the Keys are characterized by low land elevations, which when
combined with a proximity to ocean waters, render the Keys susceptible
to storm-surge flooding. Given these characteristics, the vast majority
of the Keys are mapped within the designated 100-year floodplain (FEMA,
1999). Disaster mitigation is important in the Keys not only to
strengthen the Keys' resistance to flood damage on the whole, but also
to prevent further degradation of marine waters. As stated previously,
the Keys have numerous cesspits and septic systems, which by the nature
of their operation and of the soils in the Keys, communicate with
shallow groundwater and nearshore waters. When storm surge events occur,
ocean water can surge beyond the beach zone and flood developed areas,
including the cesspits and septic systems. When this occurs, effluent
and associated contaminants are flushed from the cesspits, and from the
shallow limestone, ultimately discharging to the nearshore waters.
Protecting the Keys against storm surge flooding would be a difficult
task; however, improving wastewater treatment practices is less
difficult and can reduce storm surges from aggravating already degraded
water quality.

While coral reefs provide substantial ecological and recreational
functions, they also provide a protective offshore structural barrier to
catastrophic waves and storm surges generated by tropical storms and
hurricanes (USGS, 1997). Coral reef systems worldwide have deteriorated
to the extent that 30% of all reefs have reached the critical stage,
another 30% are seriously threatened, and that less than 40% are
considered stable (Wilkinson, 1993; 1996). In the Keys, six areas of
coral reef systems were monitored for seven years by Porter and Meier
(1992), who found that all six areas lost between 13 and 29% of their
species richness, with a net loss of 7.3 to 43.9% of their coral cover.
While the direct cause of the observed accelerated deterioration is
difficult to clearly define, the primary factors include nutrient
enrichment, sediment loading, over-fishing, and physical damage
(Kruczynski, 1999). Continued water quality degradation may contribute
to the decline in coral reefs, potentially reducing the long-term
effectiveness of storm surge and wave flooding protection.

## WATER QUALITY PROTECTION MEASURES AT THE LOCAL, STATE, AND FEDERAL LEVELS

Wastewater treatments in the Keys have come to the forefront as
principal concerns in the Monroe County, State of Florida, and U.S.
legislatures. In response to decreased Keys' water quality, a number of
laws, regulations, and standards have been promulgated by Federal,
State, and local agencies, including the EPA, National Oceanic and
Atmospheric Administration (NOAA), U.S. Army Corps of Engineers (USACE),
State of Florida Departments of Environmental Protection (FDEP) and
Health (FDH), FKAA, South Florida Water Management District, Florida
Keys National Marine Sanctuary (FKNMS), and Monroe County. The Keys'
marine environment is also managed through the FKNMS, whose geographic
area covers the entire stretch of the Keys, and whose technical advisory
and steering committees include representatives from the aforementioned
organizations, along with the U.S. Fish and Wildlife Service (USFWS),
Everglades National Park, Florida Keys Environmental Fund, and the City
of Key Colony Beach and the Key Largo area. This section is a summary of
wastewater management improvement regulatory milestones and the intent
behind each mandate and plan (Section 3.2 discusses Water Quality and
Water Resources in detail).

A number of Federal, State, and local laws and regulations govern water
quality in the Keys including the Florida Keys National Marine Sanctuary
and Protection Act, Clean Water Act (CWA), Resource Conservation and
Recovery Act (RCRA), and EPA's Ocean Discharge, Gulf of Mexico, and
Underground Injection Control (UIC), among others. Most notably, Monroe
County and the State of Florida have established mandates over the last
seven years specifically to improve wastewater treatment methods in the
Keys (Table 1-1).

Concerned about the water quality in the Keys, the *Monroe County Year
2010 Comprehensive Plan,* adopted in final version by the county in
1997, mandates that nutrient loading levels be reduced in the Keys'
marine ecosystem by the year 2010. In 1998, the Florida Governor issued
**Executive Order** (**EO**) 98-309 that charged local and State
agencies with coordinating with Monroe County to execute the *Year 2010
Comprehensive Plan* to eliminate cesspits, failing septic systems, and
other substandard on-site sewage systems. The EO also required that all
wastewater discharge be treated to **Advanced Waste Treatment (AWT)**
levels or **best available technology** (**BAT**) (these standards are
referred to as the **Florida Statutory Treatment Standards** in this
document). Passed by Florida Legislature in 1999, Florida Law (F.L.)
99-395 pertains to on-site sewage treatment and disposal systems
(OSTDSs), and includes specific requirements for all sewage treatment,
reuse, and disposal facilities and all OSTDSs in Monroe County. The
provisions prohibit any new or expanded discharges into surface waters,
and require that existing surface water discharges be eliminated before
July 1, 2006. The law also establishes effluent standards produced by
sewage facilities of varying capacity.

To meet regulatory requirements and achieve water quality improvements,
Monroe County prepared the Sanitary Wastewater Master Plan (MCSWMP)
(Monroe County, 2000a) that defines specific planning areas for the
entire developed areas of the Keys (except for the cities of Key West
and Key Colony Beach). The MCSWMP also addresses wastewater management
alternatives including the construction of new treatment plants,
conversion of **on-site wastewater treatment systems** (**OWTS**) to
**on-site wastewater nutrient reduction systems** (**OWNRS**), use of
**cluster system**s (i.e., OWNRS that accommodate multiple homes),
effluent disposal, and wastewater collection. The MCSWMP identifies
preferred alternatives to improving wastewater treatment in the Keys via
an extensive decision model process, which is detailed in Section 2,
Alternatives Evaluated, in this document. The alternatives evaluated in
this draft PEA parallel the preferred alternatives identified in the
MCSWMP.

Additionally, in 1998 the Florida Legislature amended the enabling
legislation of the FKAA (F.L. 76-441) to reinforce the FKAA's
involvement in wastewater for Monroe County. The FKAA is the main
potable water supplier for the Keys. A Memorandum of Understanding (MOU)
between Monroe County and the FKAA was signed to "request that the FKAA
exercise its authority to purchase, finance, construct, and otherwise
acquire and to improve, extend, enlarge, and reconstruct a wastewater
collection, transmission, treatment, and disposal system or systems in
the Florida Keys."

Table 1-1 - Recent Chronology of Regulatory Milestones of

Wastewater Management in the Florida Keys

+-----+----------------------------------------------------------------+
| 1   | -   Initial adoption of Monroe County Year 2010 Comprehensive  |
| 993 |     Plan.                                                      |
+-----+----------------------------------------------------------------+
| 1   | -   Monroe County Comprehensive Plan Amended to comply with    |
| 997 |     Florida Statutes.                                          |
|     |                                                                |
|     | -   Administration Commission adopts amendments to Monroe      |
|     |     County Year 2010 Comprehensive Plan and established        |
|     |     Five-year Work Program (Rule 28-20.100).                   |
|     |                                                                |
|     | -   MCSWMP begins.                                             |
|     |                                                                |
|     | -   Monroe County established original Identification and      |
|     |     Elimination of Cesspools Ordinance, 03-1997; this          |
|     |     ordinance was unsuccessful and was later rescinded.        |
+-----+----------------------------------------------------------------+
| 1   | -   Governor's Executive Order 98-309 (State and Local Agency  |
| 998 |     Participation in Carrying Out Monroe County Year 2010      |
|     |     Plan).                                                     |
|     |                                                                |
|     | -   Florida Legislature amends the enabling legislation of the |
|     |     FKAA (F.L. 76-441) to reinforce the FKAA's involvement in  |
|     |     wastewater for Monroe County                               |
|     |                                                                |
|     | -   Monroe County enters into a Memorandum of Understanding    |
|     |     with the FKAA requesting that the FKAA exercises its       |
|     |     authority to finance, construct, and operate wastewater    |
|     |     systems in the Keys                                        |
+-----+----------------------------------------------------------------+
| 1   | -   Governor Bush and his cabinet amend the 1997 Five-Year     |
| 999 |     Work Program (Rule 28-20.100) to accelerate pace of        |
|     |     program, identify "Hot Spots," and initiate cesspool       |
|     |     identification outside of "Hot Spot" areas.                |
|     |                                                                |
|     | -   Monroe County passes ordinance 031-1999 (Revised           |
|     |     Identification and Elimination of Cesspools) to comply     |
|     |     with the Governor's revised Five-Year Work Program.        |
|     |                                                                |
|     | -   F.L. 99-395 passed (New requirements for all sewage        |
|     |     treatment, reuse and disposal facilities, and all on-site  |
|     |     systems Monroe County; prohibits new or expanded           |
|     |     discharges into surface waters, and require existing       |
|     |     surface water discharges be eliminated before July 1,      |
|     |     2006).                                                     |
+-----+----------------------------------------------------------------+
| S   |                                                                |
| our |                                                                |
| ce: |                                                                |
| Mo  |                                                                |
| dif |                                                                |
| ied |                                                                |
| f   |                                                                |
| rom |                                                                |
| Mon |                                                                |
| roe |                                                                |
| C   |                                                                |
| oun |                                                                |
| ty, |                                                                |
| 20  |                                                                |
| 00a |                                                                |
+-----+----------------------------------------------------------------+

## PURPOSE AND SCOPE OF THE draft PEA DOCUMENT

The purpose of this document is to facilitate FEMA's compliance with
NEPA and associated environmental and historic preservations laws and
regulations, by providing a framework to evaluate several wastewater
treatment project alternatives feasible in the Keys. This document
evaluates projects that were originally proposed by Monroe County in its
MCSWMP (2000a).

This draft PEA discusses the potential environmental effects from
implementing various wastewater collection and disposal project
alternatives fully or partially funded by FEMA. Section 3 describes the
range of potential effects on resources associated with the
Alternatives. This draft PEA also provides the public and
decision-makers with the information needed to understand and evaluate
these potential environmental consequences. Section 4 discusses
cumulative impacts, which would also be discussed in the SER. This draft
PEA applies immediately to all projects described in Section 2 of this
document, which have been proposed for FEMA funding. The description of
proposed actions by alternative action category is provided in Section
2.

## PURPOSE OF AND NEED FOR ACTION

Wastewater treatment in the Keys has come to the forefront as a
principle concern in Monroe County, the State of Florida and U.S.
legislatures. Numerous scientific studies have documented the
contribution of failing septic tanks and cesspools to the deterioration
of Keys' canal and nearshore water quality (Lapointe et al., 1990;
Lapointe and Clark 1992; Paul et al., 1995a; Shinn et al., 1994; Paul et
al., 1997; EPA, 1993a; Kruczynski, 1999 and others). The *Monroe County
Year 2010 Comprehensive Plan* mandates that nutrient loadings be reduced
in the marine ecosystem of the Keys by the year 2010 and that wastewater
systems meet more stringent Florida Statutory Treatment Standards. In
light of regulatory requirements and in the interest of protecting
public health and water quality, the purpose of the FKAA and the Village
of Islamorada projects is to reduce wastewater nutrient loading at
selected County identified hot spots. Due to the high capital cost of
implementing these improvements, the project applicants have applied for
FEMA grant funding, through the Unmet Needs program established under
P.L. 106-31, to help achieve their wastewater treatment objectives.

## PUBLIC PARTICIPATION PROCESS AND REGULATORY FRAMEWORK

The topic of wastewater management improvements and water quality
degradation in the Keys is of particular public interest to agencies and
citizens alike. For this reason, public participation throughout the
draft PEA and SER processes is of high concern not only in terms of
upholding the intent of NEPA and other applicable environmental
statutes, but also to ensure that FEMA conducts studies with the
knowledge that public and agency opinions were gathered and considered,
ensuring a well-documented and well-represented study. FEMA has specific
requirements for public participation in compliance with its
implementing regulations for NEPA, EO 11988 (Floodplain Management) and
EO 11990 (Wetland Protection) and EO 12898 (Environmental Justice).
Furthermore, as described in Section 6, Monroe County has conducted
public involvement in relation to the development and issuance of the
MCSWMP that guides future wastewater management activities in the Keys.
Additional information on FEMA's public involvement activities, as of
draft PEA release, and the environmental review process is further
detailed in Section 6.

# Section 2 2 Alternatives Evaluated

## ALTERNATIVE DEVELOPMENT BACKGROUND

Wastewater treatment in the Keys has come to the forefront as a
principal concern in both the State of Florida and the Monroe County
legislatures. Several planning objectives, county ordinances, and State
standards were established to set goals and guidelines to direct
wastewater treatment and management improvements in the Keys (these
mandates are discussed in Section 1, Introduction, and in Section 3.2,
Water Resources and Water Quality, of this document). In essence, these
mandates urge water quality improvements through development of
wastewater management solutions, establishment of more stringent
nutrient limits, participation of relevant agencies and entities in
making wastewater management improvements, and identifying and
eliminating cesspools. These mandates were developed to provide holistic
changes in how wastewater is managed at all levels, from the Federal
agency to the county resident.

While there are several contributing sources of water quality
degradation in the Keys, Monroe County narrowed their focus on improving
the wastewater management methods and associated infrastructure within
the county. As mentioned in Section 1, Monroe County has both WWTPs and
on-site systems. On-site systems are estimated to contribute 4.88
million gallons per day (mgd) of wastewater, and WWTPs contribute 2.40
mgd of wastewater. None of the on-site systems or WWTPs provide adequate
nutrient removal, with effluent from all facilities having nutrient
levels that exceed the Florida Statutory Treatment Standards (Monroe
County, 2000a).

To further focus their efforts, Monroe County evaluated the existing
county treatment areas and identified several high priority "Hot Spots"
believed to substantially contribute to water quality degradation
(Figures 2-1, 2-2, and 2-3; Appendix C). These "Hot Spots" were
identified based on population density, nutrient discharge, and the
number of unpermitted on-site waste disposal systems. These "Hot Spots"
represent priority areas where the high concentration of people and poor
existing wastewater management practices (such as cesspools) justify the
installation of a more advanced wastewater treatment system (such as a
WWTP) within that area. In accordance with the MCSWMP, wastewater system
improvements would be focused first within these "Hot Spot" areas, and
then proceed outside these areas when priority improvements were
complete. In support of this approach, the alternatives presented in
this draft PEA and in subsequent SERs are proposed for dense, urban
areas.

## DECISION MODELS FOR WASTEWATER MANAGEMENT ALTERNATIVE DEVELOPMENT 

The alternatives presented herein parallel alternatives studied and
approved for consideration by Monroe County, as in the MCSWMP (2000a).
The decision-making process for wastewater management involves a
comprehensive evaluation of many variables, and ultimately, prioritizing
those variables. Specifically, the Monroe County Citizens Task Force on
Wastewater (Task Force), Sanitary Wastewater Master Plan Technical
Advisory Committee (SWMP TAC), and Board of County Commissioners (BOCC),
together with representatives from the community at large, developed the
models and considered the alternatives in terms of cost, technical
feasibility, performance, environmental impacts, potential for service
disruption, reliability, implementation, and strength and weaknesses in
order to evaluate alternatives.

**FIGURE 2-1 UPPER KEYS**

**FIGURE 2-2 MIDDLE KEYS**

**FIGURE 2-3 LOWER KEYS**

As depicted in Figure 2-4, the alternative evaluation model has three
levels. The first lists the principle objective decided by the decision
makers, which is to maximize the benefit of the wastewater management
alternative. The second level lists a series of issues considered
important to address, such as minimizing cost while maximizing ease of
implementation, environmental benefits, secondary impacts, and
reliability. The third level lists performance criteria, which measures
how well an alternative meets the principle objective (maximizing the
benefit of the wastewater management alternative). The combined score
(represented in parentheses in Figure 2-4) is the importance given to
each criterion by the stakeholder groups. As Figure 2-4 shows, the
highest score demonstrates that the environmental performance criterion
is most important, followed by minimizing costs, and maximizing
reliability.

The results of this model were used to recommend the most appropriate
alternatives for implementation in Monroe County. These alternatives are
also presented in this draft PEA as proposed alternatives for FEMA
funding, and for evaluation under NEPA. The alternatives discussed in
this document support established Federal, State, and county objectives
by presenting and evaluating alternate methods of wastewater collection
and disposal.

As part of the MCSWMP development, Monroe County also implemented a
decision-model for selecting sites for the proposed projects. The siting
models focused on Maximizing Public Acceptance, Minimizing Cost,
Maximizing Beneficial Land Use Characteristics, and Minimizing
Environmental Impacts as a framework for selecting the most appropriate
sites. Similar to the alternatives development model described above,
stakeholders and the SWMP TAC developed measures to evaluate and weigh
the framework criteria. Using this model, 42 sites were identified as
having the potential to accommodate community and regional WWTPs (Monroe
County, 2000a). While site selection is critical to determining
site-specific impacts, and thus would be evaluated in the SER, specific
sites are not discussed in this draft PEA because the scope is much
broader and is not area-specific by design. The SER would detail the
site selection process undertaken by Monroe County and the project
applicants, and would provide a site-specific analysis of impacts.

## ALTERNATIVES EVALUATED

This section describes a range of projects related to wastewater
management methods and upgrades and explains the proposed alternative
actions as well as a brief description of other alternatives that were
identified but eliminated from further consideration. The potential
environmental impacts of each alternative are described in Section 3. It
should be noted that funding may be specific to individual situations
and include several funding sources. Projects are described independent
of the source or amount of funding.

**FIGURE 2-4 DECISION-MAKING MODEL**

### Alternative 1 -- No Action Alternative

FEMA would not provide funds to the project applicants for wastewater
management improvements. The county is presently pursuing several State
and Federal sources of funding to finance the large capital costs
associated with improving their wastewater treatment systems to meet the
compliance requirements established by the State of Florida for
treatment standards by 2010. FKAA or Islamorada would not have the
benefit of FEMA assistance under the No Action Alternative. Communities
currently utilizing on-site systems, such as cesspools and septic
systems, to manage wastes would have to construct either community or
regional WWTPs or on-site wastewater nutrient reduction systems to
effectively manage waste nutrients to levels that meet the Florida
Statutory Treatment Standards of 2010.

### Alternative 2 -- Centralized Wastewater Treatment Plant Alternative

The project applicant, with FEMA grant funds, would construct a new
community or regional WWTP or perform facility upgrades to existing
systems at selected locations in the Lower, Middle, and Upper Keys
(refer to Figures 2-1, 2-2, and 2-3). The project applicants would be
responsible for the construction and oversight of these facilities, with
compliance monitoring performed by FDEP. Specific details on the roles
and responsibilities of the project applicant with respect to design,
construction, post-construction, maintenance and operation activities
would be described at the site-specific SER level.

New construction of community and regional WWTPs would be targeted in
densely populated areas, where the installation of central sewers would
eliminate a high number of declining and inadequate on-site wastewater
treatment methods such as septic tanks and cesspools. As the population
of a community grows, and thus the number of citizens serviced by the
community WWTP increases, established community plants may be
consolidated into larger regional plants to maintain cost-effectiveness.
However, community systems may remain independent if the service area is
isolated and not in proximity to a regional plant, thus rendering
consolidation cost-prohibitive. Most likely, community WWTPs in the
Lower Keys would remain independent, while consolidation of community
plants in the Upper and Middle Keys would occur steadily over time as
populations increase. All proposed regional WWTPs would be expandable to
accommodate higher quantities of wastewater as needed. Capacity
expansions to existing WWTPs as well as treatment level upgrades may
also occur under this alternative (Monroe County, 2000a).

Flow projections for the 10-year planning horizon (to 2008) were
determined from Rate of Growth Ordinance (ROGO) allocations (by
geographic distribution), estimated future ROGO allocations, and the
number of future units in each area that have development potential and
were vested or exempt from ROGO. The total estimated increase in
residential wastewater flows in Monroe County for the 10-year planning
period is 9%. Increases in non-residential growth were estimated by
assuming commercial development under the Commercial ROGO, which for a
10-year period equals 3% (Monroe County, 2000a). (See Section 3.10, Land
Use and Planning, for more information on ROGO and community growth).

The WWTP design, size, location, and construction methods would be
identified and studied in the respective SERs. In general, WWTP acreage
for the average regional WWTP in Monroe County is about 3 acres, while
community and interim community WWTPs would use smaller sites. The
construction time for a WWTP in the Keys has been estimated to be about
36 months (Teague, Pers. Comm., 2001). Regional facilities would process
0.5 mgd to 6.0 mgd of effluent and community facilities would process
about .004 mgd to 0.5 mgd. Avoidance of sensitive locations (such as
residential or natural areas) would be preferred when conducting site
selection, however, available land in the Keys is limited and siting may
occur within these areas due to lack of options. As a requirement of
NEPA, FEMA's implementing regulations with respect to NEPA, and other
applicable Federal, State, and local environmental regulations,
appropriate mitigation measures to reduce the adverse effects associated
with sensitive locations would be implemented.

Specific details on the nature, extent, and duration of construction
activities associated with WWTPs would be further developed in SERs. The
WWTP construction would typically require the installation of treatment
tanks, in-ground and aboveground pipes, pumping stations, and sand or
fabric filtration facilities. Project activities would also likely
include the construction of storage facilities for maintenance
equipment, treatment chemicals, and other operations materials; as well
as, administrative buildings, parking lots, and paved access points. For
WWTP projects that would replace community-wide, existing on-site septic
systems and cesspools, construction activities would likely include the
removal of septic systems, excavation and disposal of fill, and new
sewer connections. WWTP construction would be conducted pursuant to
applicable facility planning regulations at the State and county level.
It is expected that coordination between the Monroe County Building
Department, Public Works, and City Engineers, among other parties, would
be required to ensure that the WWTP's structural and mechanical
integrity meet current code, and to ensure that permits relating to
siting, planning, design, and operation are obtained, and any conditions
to those permits are met. Appendix E provides a summary of potentially
required permits.

Under this alternative, the disposal of solid waste, such as sludge and
septic waste, would remain consistent with present practice in the Keys.
Most wastewater sludge and septic waste generated in the Keys is
currently hauled to one of three transfer facilities located on Cudjoe
Key, Long Key, and Key Largo. From these transfer stations, the sludge
is hauled to a regional wastewater treatment facility in Miami-Dade
County for treatment. The Key West WWTP dewaters partially stabilized
secondary solids, which are disposed via a private hauler at an
agricultural land application site near Okeechobee, Florida. Because the
solids are only partially stabilized, they are incorporated into the
soil the same day they are applied to meet FDEP **vector attraction
reduction** requirements.

Plants with capacities of less than 100,000 gallons per day (gpd) would
temporarily store decanted sludge in an aerated holding tank and haul
the liquid sludge to the Monroe County Solid Waste Transfer Station.
Plants with capacities of 100,000 gpd or more would process their solids
via **belt filter press dewatering**, **Class B lime stabilization**,
and truck hauling of dewatered cake to a remote agricultural land
application site.

#### Wastewater Treatment Plant Collection Options:

##### Collection Option 1 -- Vacuum Pumping 

A vacuum sewer system consists of one or more vacuum stations,
collection system piping, and vacuum sewer services. Vacuum stations
provide both vacuum pumping to draw wastewater to the station, and
discharge pumping to pump wastewater through a pressure force main to a
WWTP. Vacuum valves regulate the entry of wastewater and air into the
collection system piping. Vacuum stations are usually concrete block
buildings on concrete foundations with plan dimensions of 25 feet by 30
feet. Part of the structure is constructed below grade to accommodate
entry of the vacuum sewer, and slope requirements (to allow vacuum
function) often require grade control and excavation to a somewhat
greater depth. A typical residential vacuum sewer system consists of a
gravity line from one or more structures to a 30-gallon holding tank
equipped with a vacuum line. Air enters the system behind the
wastewater. This air is necessary to drive wastewater in the line to the
vacuum station. As a benefit, this air provides some aeration of
wastewater as it passes through the vacuum collection system. This
eliminates anaerobic conditions and associated odor and corrosion
problems. The collection tank receives the air and sewage transported by
the collection piping. Construction activities associated with the
implementation of the vacuum pumping collection option could include
excavation of fill and installation of new sewer lines and/or the
removal of existing water pipelines.

##### Collection Option 2 -- Low-Pressure Grinder Pump Sewer System 

Grinder pump systems use a small grinder pump station at each wastewater
source (such as a residence or business) and small-diameter,
low-pressure sewers for transmission either to lift stations or directly
to a WWTP. The grinder pump station accepts the entire wastewater stream
from the residence or business and is not used in conjunction with a
septic tank. All solids in the waste stream are ground to **slurry** and
pumped through pressure sewers. Low-pressure grinder pump systems would
typically include the use of either centrifugal grinder pumps or
progressive cavity grinder pumps. Centrifugal grinder pumps are
generally designed for lower pressure applications and require larger
water pipe sizes in comparison to progressive gravity pumps.
Construction activities associated with the implementation of the
low-pressure grinder pump sewer system could include excavation of fill
and installation of new sewer lines and/or the removal of existing water
pipe. The installation of gravity grinder pumps at individual residences
and other wastewater sources would require the excavation of several
cubic feet of soil, along with the establishment of new sewer
connections.

#### Wastewater Treatment Plant Effluent Disposal Options:

##### Disposal Option 1 -- Shallow Injection Wells

Disposal of treated effluent would be via shallow injection well, with
the depth and treatment levels depending on the design capacity of the
WWTP. As dictated by Florida Administrative Code (F.A.C.) 99-395,
shallow injection wells must be at least 90 feet deep with at least 60
feet of the well encased in steel and/or PVC and grouted with cement.
Construction of a monitoring well, wellhead facilities, and piping from
the treatment plant to the wells is also necessary (Monroe County,
2000a). F.A.C. 99-395 specifies that volumes less than 1 mgd be disposed
of through shallow injection wells and volumes greater than 1 mgd be
disposed of through deep injection wells (greater than 2,000 feet deep).
For the purpose of this study, the wastewater facilities would be
handling less than 1 mgd and no deep wells would be used, therefore only
shallow wells are considered. Figure 2.5 depicts a typical shallow
injection well.

**FIGURE 2-5 SHALLOW INJECTION WELL**

Permitting Class I and Class V Injection Wells

The underground injection wells under consideration in this draft PEA
would be regulated under the joint EPA/FDEP UIC program that oversees
underground injection of waste. The EPA/FDEP UIC program divides
underground injection into five classes for regulatory control purposes:
Classes I through V. Each class includes wells with similar functions,
and construction and operating features so that technical requirements
can be applied consistently to the class. The shallow wells would
typically be permitted as Class V injection wells.

Class I injection wells are defined as wells that inject fluids beneath
the lowermost formation containing, within one quarter mile of the well
bore, an underground source of drinking water (USDW). Under F.A.C.
62-528, applicants for Class I injection wells must demonstrate that the
hydrogeologic environment is suitable for waste injection and without
modifying the ambient water quality of other aquifers overlying the
injection zone. Additional requirements of Class I injection wells
include casing and cementing to prevent the movement of fluids to
maintain the ground water quality in aquifers above the injection zone,
exploratory pilot holes, monitoring well, and alternate disposal method
for emergency events. Under F.A.C. 62-600.540, Ground Water Disposal by
Underground Injection, all facilities using Class I wells discharging
domestic effluent into G-IV waters (i.e., non-potable water use, ground
water in confined aquifers, which has a total dissolved solids content
of 10,000 mg/L or greater such as those in the Keys) must meet secondary
treatment and pH limitations. Additional information related to the
permitting requirements of Class I injection wells for domestic
wastewater is in FDEP's regulations for domestic wastewater facilities
(F.A.C. 62-600) and underground injection control (F.A.C. 62-528).

Class V injection wells are typically shallow wells, used to place
non-hazardous fluids directly below the land surface. However, Class V
wells can be deep, highly sophisticated wells (EPA, 2001a). According to
FDEP UIC program implementing regulations, the variety of Class V wells
and their uses dictate a variety of construction designs and preclude
specific standards for each type of Class V well. However, wells require
FDEP permitting and FDEP may apply any of the criteria of Class I wells
to the permitting of Class V wells if FDEP determines that without the
application of Class I permitting criteria, the Class V well may cause
or allow fluids to migrate into a USDW which may cause a violation of
drinking water standards.

In addition to the standards promulgated under Sections 62-600 and
62-528 of F.A.C., F.L. 99-395 specifies design standards and effluent
water quality standards for Class V wastewater injection wells as
follows:

Table 2-1: Quality Standards for Discharged Effluent

  ---------------- ------------ -------------- -------------- --------------
                   **BOD\       **TSS\         **TN\          **Total
                   (mg/L)**     (mg/L)**       (mg/L)**       Phosphorus\
                                                              (mg/L)**

  **Sewage         5            5              3              1
  facilities with                                             
  design                                                      
  capacities                                                  
  greater than                                                
  100,000 gpd**                                               

  **Sewage         10           10             10             1
  facilities with                                             
  design                                                      
  capacities less                                             
  than 100,000                                                
  gpd**                                                       

  **On-site sewage 10           10             10             1
  treatment and                                               
  disposal                                                    
  systems**                                                   
  ---------------- ------------ -------------- -------------- --------------

##### Disposal Option 2 - Wastewater Reuse

Treated wastewater may be reused for various purposes in compliance with
FDEP regulations governing wastewater reuse. Present uses of treated
effluent in Florida include the irrigation of landscaped areas such as
golf courses, parks, highway medians, and residential properties; urban
uses such as toilet flushing, car washing, dust control, and decorative
fountains; irrigation of edible food crops such as citrus, corn and
soybeans; wetlands creation, restoration, and enhancement; recharging
ground water; and industrial uses such as plant wash down, processing
water, and cooling water purposes.

At present, slow-rate land application of treated wastewater is the
principal type of reuse system in Florida. Land application involving
public access spray irrigation systems is restricted to plants equal to,
or greater than, 100,000 gpd in capacity, and the wastewater must be
treated to secondary treatment standards, followed by high-level
disinfection. Land application by subsurface application systems can be
used for any plant size and has reduced effluent quality requirements
and only basic disinfection is required. Because of the nutrient
benefits to the land, nitrogen and phosphorus removal are not required
for land application systems.

Infrastructure requirements would vary depending on the type of
wastewater reuse application. The wastewater reuse option may require
the installation of water line systems to convey treated wastewater for
use in land, urban, or industrial applications. This disposal option may
also involve the use of a trucking system to convey wastewater to
application sites. Of the 246 WWTPs in the Keys, only 7 were using some
form of reuse in 1998. Subsurface drip irrigation is the only reuse
method permitted by FDEP for plants less than 100,000 gpd in capacity,
which include 241 of the 246 WWTPs in the planning area. The selection
of wastewater reuse as a disposal option would require backup disposal
systems or storage. Due to land use restrictions in the Keys, the use of
storage ponds, tanks, and surface water disposal is not a viable backup
system. In most cases, reuse systems would likely be used in conjunction
with injection wells for backup disposal and would comply with the
applicable Florida Statutory Treatment Standards. FKAA and/or Islamorada
would be responsible for identifying a willing recipient of the treated
effluent if this option is selected or used in conjunction with other
options.

### Alternative 3 -- On-Site Treatment Upgrades 

Project applicants would use FEMA funds to convert OWTS, such as
cesspools and septic tanks with drainfields, to OWNRS to improve
wastewater management in the Keys (Figure 1-2). OWNRS are engineered
treatment systems that, at a minimum, meet BAT treatment standards and
require routine maintenance and service from an approved maintenance
entity. OWNRS that dispose of 10,000 gpd of wastewater or less are
regulated by FDH; OWNRS that process more than 10,000 gpd of wastewater
are governed by FDEP and operate under operating permits monitored by
the Monroe County Health Department. A biological nitrogen removal
system coupled with physical/chemical phosphorus removal system,
disinfection (through chlorination or other means), and disposal through
either **subsurface drip irrigation** systems (**SDI**) or shallow
injection wells are proposed under this alternative. Under this
alternative, a "cluster system" would be designed such that multiple
homes would use one OWNRS system.

An OWNRS system could vary in required land area based on establishment
flow and whether or not the treated effluent is disposed of using SDI or
an injection well (Briggs, Pers. Comm., 2001). An OWNRS system utilizing
SDI generally requires, at a minimum, 273 square feet for a dwelling
unit smaller than 2,250 square feet. For extremely small lots that do
not have sufficient area for an SDI system, the OWNRS system would
discharge effluent to a shallow injection well (i.e., 90-foot well depth
with a cement grouted 60-foot casing). Although SDI has been used in
Monroe County, it may not be feasible at all sites due to land area and
topsoil requirements. It should be noted that of the households that
received funding from the Cesspit Identification and Elimination Grant
Program (CIEGP), none chose to install SDI systems. Additional details
on CIEGP are in Section 3.6.3.2.1.

Construction activities associated with the conversion of septic tanks
to OWNRS may require the excavation, removal, and disposal of existing
septic tanks and removal of brick, stone, or block that previously lined
seepage areas. The installation of an OWNRS would likely include the
placement of new tanks and treatment units on vacant land in the area.
For OWNRS employing SDI systems, construction activities would include
the excavation of soil, placement of irrigation pipe, replacement of
soil, and revegetation. As described in MCSWMP clustered OWNRS can range
in size from those serving one home to a centralized OWNRS that serves a
large number of homes (Monroe County, 2000a). \[Note: Most homes in the
Keys have at least two bedrooms. The FDH uses a wastewater generation
estimate of 100 gpd per bedroom; therefore, each home would generate at
least 200 gpd. Because the FDH standards for OWNRS specifies a maximum
of 10,000 gpd, the maximum number of two bedroom homes that could be
served is estimated at 50 (FDH, 2001a)\]. For OWNRS serving large
numbers of homes, construction activities may include the development of
storage and staging areas for servicing equipment and operations
materials, such as treatment chemicals. Community sewer systems linking
residences to OWNRS would likely be constructed, and require excavation
and placement of pipeline, and/or grinder pumps at individual residences
(Briggs, Pers. Comm., 2001).

## ALTERNATIVES CONSIDERED BUT DISMISSED

Several alternative approaches to wastewater collection and disposal
were evaluated towards selecting the most appropriate alternatives to
meet the purpose and need for improving wastewater management methods in
the Keys. Alternate actions to those proposed under Alternatives 2 and
3, which were considered for detailed evaluation but ultimately
dismissed, are summarized below. It should be noted that all disposal
options under Alternative 2 were retained for further detailed study,
and for this reason, no disposal options are discussed in this section.

### Collection Options under Alternative 2

Conventional gravity sewers are the most widely used method of
wastewater collection for residential and other developed areas.
Wastewater is transported by gravity from each service connection to a
main gravity sewer. The main gravity sewer is sloped to provide a flow
velocity adequate to convey solids and minimize settling (generally 2
feet per second). Because of the continuous slope, the depth of gravity
sewers increases with distance downstream until the depth becomes too
great for economical construction, generally 12 to 14 feet. In the Keys,
flat topography, the high water table, and limestone bedrock makes deep
excavation impractical. For this reason, conventional gravity sewers
were dismissed from further evaluation.

Simplified gravity sewers resulted from a design modification to
conventional gravity sewers. Excavation depths are shallower and
manholes are smaller in diameter. While their excavation requirement is
somewhat less than conventional gravity sewers, these systems would have
high excavation and construction costs due to flat terrain, the presence
of rock at the surface, and the presence of a high water table in the
Keys. This option was also dismissed.

Small diameter gravity sewers (SDGS) use septic tanks at the wastewater
source to remove solids and floating materials, such as oil and grease.
Effluent from the septic tanks is then discharged to the SDGS. Because
solids are removed in the septic tanks, SDGS lines are not designed to
transport them. This reduces the velocity and the gradient required.
SDGS collection systems require that each connected unit have a septic
tank. In order to avoid maintenance problems in the SDGS lines, the
septic tanks must be properly maintained, including pumping of septage
at regular intervals. The cost of pumping, hauling, treating, and
disposing of septage must be included in the overall system operation
and maintenance costs. Many of the developed lots in the Keys do not
currently have proper septic facilities, and many have none at all. The
additional cost of inspecting and/or providing new septic tanks for each
connection are an added cost of SDGS that must be considered. The SDGS
waste stream is anaerobic and may release hydrogen sulfide upon exposure
to air. Hydrogen sulfide can cause odor or corrosion problem in the
collection and treatment systems. As with any purely gravity collection
system, the flat terrain, shallow depth to rock, and high water table in
the Keys would drive construction costs upward. For these reasons, this
option was dismissed from further study.

Septic tank effluent pump (STEP) systems are similar to SDGS systems
because they use septic tanks at the wastewater source for removal and
decomposition of settleable and floating solids. Instead of using SDGS
lines to convey septic tank effluent to the WWTP, STEP systems use small
STEP stations and pressure sewers. Like SDGS systems, STEP systems have
the disadvantage of utilizing numerous septic tanks that must be first
inspected or provided and then regularly maintained. Pumping, hauling,
treatment, and disposal of septage must be included in the operation and
maintenance costs for STEP systems. Another disadvantage of STEP systems
is the large number of pumps in the system that must be maintained. This
option was dismissed from further study.

### On-site Treatment Options under Alternative 3

Conventional OWTS consist of a septic tank and a subsurface wastewater
infiltration system, or drainfield, and rely on naturally occurring
soils to provide wastewater treatment. The drainfield and unsaturated
underlying soils are the most critical components of the conventional
OWTS and provide most of the treatment. The problem with installing OWTS
in the Keys is that very little or no natural soils exists over the
ancient coral/limestone rock, and soil must be imported to construct
these systems. The limited soils in the Keys thus reduce the treatment
effectiveness of these systems, especially for nutrients. Since a
majority of the present water quality issues stem from these types of
on-site systems, they do not meet the purpose and need and were
dismissed from further study.

ATUs, small aerobic biological treatment systems, are essentially
miniature WWTPs, which function similarly to centralized wastewater
treatment facilities. Effluent from these systems is discharged either
to a drainfield or to a mineral aggregate filter, and then to a shallow
injection well drilled to a depth of 90 feet. To meet the Florida
Statutory Treatment Standards, an anoxic biofilter (ABF) or an internal
recycle loop for nutrient reduction, and a phosphorus removal system
would need to be designed and added to the ATU. In many cases, the cost
and additional land requirements for these components make
implementation impractical. Therefore, this option was dismissed from
further study.

Cesspools consist of a large excavation in the ground lined with brick,
stone, or concrete block that allow raw wastewater to seep into the
natural rock or groundwater. Without a significant soil layer, little,
if any treatment of the wastewater occurs in the cesspool, especially if
it intercepts groundwater. Pollutant removal is very limited, and
nutrient levels approaching those of raw wastewater are being discharged
to groundwater. Cesspools, like septic systems, are a contributor to
water quality degradation in the Keys waters, and therefore, were
dismissed from further consideration because they would likely worsen
the water quality problem.

# Section 3 3 Affected Environment and Environmental Consequences

## Topography, Soils, and Geology 

### Topography

#### Affected Environment

The Keys are a chain of low-lying islands off the southern tip of
Florida, extending southwest from near Miami to Key West (Figure 1-1).
The Keys are flanked by the Gulf of Mexico to the north and west and the
Atlantic Ocean to the south and east. As generally thought, Key Largo is
the most northerly island and Key West the most westerly; the distance
from Key Largo to Key West is about 110 miles, and the total area of the
islands is about 66,000 acres.

The Keys are subdivided into the Upper Keys and Lower Keys. The Upper
Keys extend from Upper Matecumbe Key to Key Largo, and are termed the
coral keys that were probably an active coral reef in recent time. The
Lower Keys, extending from Lower Matecumbe Key to Key West, are termed
the **oolite** keys because the surface materials consist of oolites,
small spherical grains of calcium carbonate deposited in shoals after
coralline islands were leveled by wave erosion at times of higher sea
levels. (It should be noted that topographic data distinguish between
upper and lower keys, which includes the area referred to as the middle
keys in other areas of this document. A middle keys division is not made
with respect to references used in developing this section.)

The Upper Keys (coral keys) have a denuded surface from which the
original coral has been completely removed. The surface has some
considerable local relief and in places has the ragged, irregular
appearance of **microkarst**. Local accumulations of residual soils also
exist. The highest elevations in the coral keys are about 16 to 18 feet
above mean sea level, on Key Largo and Windley Key. The lower parts of
the Upper Keys have a smoother surface that appears to have resulted
from marine erosion (White, 1970). Near the edges of the relict coral
reef, the surface slopes gently down to the present shore, where it is
being cut back by wave splash in the present cycle of shoreline erosion.
The shore zone affected by wave splash has an extremely ragged,
irregular surface that is honeycombed with solution holes, a few inches
to a foot in size.

The Lower Keys (oolite keys) are generally smoother than the coral keys
and of lower elevation than the coral keys. Typically the surface is
flat and smooth in the center of an island and slopes gently downward
near the shore. There is little if any residual soil in the Lower Keys.
It appears that the Lower Keys were leveled by the sea when sea level
was about 4 to 5 feet higher than at present.

Natural vegetation occurs mainly in tropical hammocks at higher
elevations and in mangrove swamps in low-lying areas and along
shorelines. About half the area of the Keys is covered by mangrove
swamps. In the early 20^th^ century some of the islands were developed
for bananas, vegetables, and citrus crops; however, following a
hurricane in 1935, crop production ceased and no land in the Keys is
currently classed as agricultural (Hurt et al., 1995).

Offshore of the Keys on the Atlantic side, the Florida Current flows
northward parallel to and east of the Keys and east of the 2-5 mile
shelf that supports the growth of modern corals along its outer margins
(Halley et al., 1997) (Figure 3-1). Landward of this reef tract is White
Bank, a shallow sand shoal studded with patch reefs, and Hawk Channel,
an inner shelf lagoon 18-24 feet deep. Just seaward of the Keys, bare
limestone equivalent to that exposed in the Keys extends nearly 1 mile
offshore. Coral reefs, because they grow at or close to sea level, act
as natural breakwaters parallel to the chain of the Keys. As such, they
tend to moderate the erosive potential of wave action on the islands of
the Keys. Section 3.3.1.2.2 provides a more detailed discussion of the
active coral reefs.

Florida Bay, an arm of the Gulf of Mexico, lies northwesterly of the
Keys. Florida Bay is a shallow lagoon (average depth about 4 feet)
characterized by mangrove-covered mud and peat islands, mudbanks, and
shallow marine basins. These mudbanks, islands, and basins are underlain
by Pleistocene age limestone equivalent to the limestones that form the
Keys (Halley et al., 1997).

#### Environmental Consequences

The effects on topography are similar across all of the alternatives.
Topographic impacts appear to be limited to temporary surficial
disturbances during construction of sewers, treatment plants, and
clustered OWNRS. Grading requirements (if any) would permanently change
the surficial topographic elevation of the project area, but this impact
is minor because it would not significantly alter the flat surface
topography of the Keys. Additional details on effects on topography as a
result of construction activities would be in the project-specific SER.

It has been suggested that unless the nutrient problem is resolved,
further damage to coral reefs will result in greater wave erosion during
storms, resulting in major effects on the Keys' topography. As noted by
Kruczynski (1999), coral habitats are exhibiting declines in health, but
there are no definitive studies on the geographic extent of the impact
of anthropogenic nutrients. A variety of diseases that cause coral
decline have been reported worldwide from pristine as well as polluted
areas (Kruczynski, 1999) and the impacts of nutrient enrichment to coral
reefs are not always clear cut or devastating to the coral community.
Thus, it is speculative to relate the proposed alternatives to possible,
minor, adverse future effects of wave erosion on topography of the Keys.
Overall, surficial effects to topography via construction would occur,
but long-term effects on topography are unlikely.

### Soils

#### Affected Environment

The following brief description of soils is adapted mainly from Soil
Survey of Monroe County, Keys Area, Florida (Hurt et al., 1995). In
general, the soils are sparse and thin and confined largely to hammocks
in the higher parts of islands and mangrove swamps in the lower lying
areas. About 76% of the total area is mapped in seven soil units; four
of these making up 46% of the area are classed as muck, and 35% of the
total area represents urban land complexes, rock outcrop complexes and
open water (Hurt et al., 1995). The thickness of the soils is generally
quoted as less than 10 inches, although some units have maximum depths
of up to 82 inches (Hurt et al., 1995).

FIGURE 3-1: TIDAL FLOW

Of special interest is the fact that in urban developments, totaling 21%
of the total area, the land has been largely filled with crushed
limestone excavated in constructing canals and spread over the natural
surface. Typically the fill material consists of 32 inches of gravelly
sand underlain by 40 inches of marl (Hurt et al., 1995).

According to the Soil Survey, there are no prime farmland soils in
Monroe County; therefore, the requirement to comply with the Farmland
Protection Policy Act is not triggered. Specific soil types at the
designated project site would be described in the individual SERs.

#### Environmental Consequences

The effects related to all alternatives are similar. Soils would be
disturbed during the construction processes and implementation of
appropriate **best management practices** (**BMPs**) and development of
an Erosion and Sedimentation Plan should occur prior to and during
construction to protect area water bodies and stormwater canals.
Applying BMPs and appropriate erosion mitigation (such as use of silt
fences) would limit soils effects on temporary disturbances during
construction of sewers, treatment plants, and clustered OWNRS under the
various alternatives considered.

### Geology

#### Affected Environment

The Keys occupy the southernmost part of the Florida Platform, a
15,000-foot-thick sequence of carbonate and evaporate sediments with
relatively minor amounts of fine-grained siltstones and shales. As shown
by the submarine topography on Figure 3-2, the Florida Platform,
delineated by the minus 330-foot contour, is submerged beneath the Gulf
of Mexico, and the coral reef of the Keys approximately define its
southern margin. Seaward of the Platform, the continental slope declines
sharply to depths of 2,640 feet or more in the Straits of Florida and to
nearly 10,000 feet in the Gulf of Mexico. As shown on Figure 3-3, the
strata that make up the Floridan Aquifer system are essentially flat
lying beneath the Platform but dip seaward beneath the Atlantic
continental slope.

The numerous geological formations have been grouped into two principal
aquifer systems, the Floridan Aquifer System, comprising water-bearing
carbonates (Paleocene through Miocene age), and the Biscayne Aquifer
(Pleistocene age), which underlies 4,000 square miles of South Florida.
In this report, the Pleistocene age deposits in the Florida Keys are
termed the Upper Water-Bearing Zone to avoid confusion with the
fresh-water bearing Biscayne Aquifer of the south Florida mainland. The
various geologic strata have been subdivided into formations and the
stratigraphic terminology used by the U.S. Geological Survey (USGS) is
followed herein (USGS, 1990).

INSERT FIGURE 3-2: SUBMARINE TOPOGRAPHY

**INSERT FIGURE 3-3: FLORIDAN AQUIFER**

##### Upper Water-Bearing Zone

The Upper Water-Bearing Zone is the principal supply of fresh water
throughout South Florida and the Keys are supplied with fresh water by a
pipeline from a mainland well field. The Biscayne Aquifer is highly
permeable and its groundwater is under unconfined conditions (in
**hydraulic communication** with the atmosphere). In the Keys, the water
of the Upper Water-Bearing Zone is generally saline, although on the
larger islands, such as Key West, thin fresh-water lenses replenished by
rainfall recharge float on the denser underlying saline water. Such
fresh water lenses provided small water supplies during the early
development of the Keys, but are inadequate to supply the present
population. Saline groundwater is used in at least one location (Ocean
Reef Club on Key Largo) as input to a reverse osmosis desalination
system.

Throughout the extent of the Biscayne Aquifer, it is separated from the
deeper Floridan Aquifer System by about 1,000 feet of
low-**permeability**, clayey deposits (termed the Upper Confining Unit)
that effectively isolate the fresh waters of the Biscayne from the
saline water in the Keys' Floridan Aquifer System.

In South Florida, the Biscayne Aquifer supplies essentially all the
fresh municipal and irrigation water supply systems, and together with
the Floridan Aquifer System supplies saline water for a variety of uses
including industry, input to desalination systems, and cooling.
Particular interest in recent decades has focused on the deep saline
zones of the Floridan Aquifer System as receptors of municipal and
industrial wastewaters.

The Biscayne Aquifer of mainland South Florida is generally unconfined
and can become degraded by surface contaminant sources. Numerous
incidents of localized contamination by petroleum products, commercial
solvents, and toxic metals have been recorded; however, the aquifer
continues to serve as the main source of potable water and irrigation
supply throughout South Florida. In the Keys, the water of the Upper
Water-Bearing Zone ranges from brackish to saline and therefore, is
little used for potable supply; however, the widespread use of OWTS
throughout the Keys has led to extensive nutrient and pathogen
contamination as described in Section 3.2, Water Resources and Water
Quality.

The Upper Water-Bearing Zone comprises the Pleistocene carbonate rocks
that underlie the Keys. In the Keys, these rocks are subdivided into the
Key Largo Limestone and Miami Oolite on the basis of their
**lithologic** character. The Lower Keys Miami Oolite consists of
well-sorted oolite grains with varying amounts of coral, echinoid,
mollusk and other skeletal material and some quartz sand (Halley et al.,
1997). The Miami Oolite is 9-15 feet thick and was deposited on marine
banks and bars. The Key Largo Limestone of the Upper Keys, in contrast,
consists of coral remains, interbedded **calcareous** sands, and thin
beds of quartz sand. The thickness of the Key Largo Limestone varies but
200 feet was cored at Big Pine Key. At the south end of Big Pine Key,
the Miami Oolite grades laterally into the Key Largo Limestone, and
elsewhere the Miami Oolite overlies the Key Largo Limestone.

Because of the saline character of the groundwater of the Upper
Water-Bearing Zone, there has been little testing of its hydraulic
characteristics. However, Halley et al. (1997) estimate the **hydraulic
conductivity** of the Miami Oolite to be about 120 meters per day, and
of the Key Largo Limestone to be about 1,400 meters per day.

##### Floridan Aquifer System 

The Floridan Aquifer System underlies all of Florida and parts of
Georgia, South Carolina, Alabama, and Mississippi. The Floridan Aquifer
thickens southward from about 2,000 feet in northern Florida to more
than 3,000 feet in southernmost Florida (Figure 3-3). In South Florida
and the Keys, the Floridan Aquifer System contains saline water and is
not used for water supplies except for industrial cooling and similar
uses.

There has been little exploration of the Floridan Aquifer System in the
Keys, so what information is available is based on regional
extrapolation summarized in USGS Hydrologic Atlas 730-G (USGS, 1990).
The Floridan Aquifer System thickness ranges from 2,600 feet at the
north end of Key Largo to 3,400 feet near Key West. The Floridan Aquifer
System consists of a thick sequence of carbonate rocks, principally
limestones and dolomites, mostly of Paleocene to early Miocene age, that
are hydraulically connected in varying degrees. Although predominantly
limestone and dolomite, other rock types including dolomitic limestone,
marl (calcareous, clayey deposits), and phosphatic limestones occur
within the system. The Floridan Aquifer System is tightly confined
throughout South Florida and the Keys, meaning the upper confining unit
is generally greater than 100 feet thick and is unbreached (USGS, 1990).
The **hydraulic head** is about 40 feet above mean sea level at the
eastern of the Keys and less than 40 feet west of Key Largo; these
conditions are fairly unchanged from pre-development conditions (USGS,
1990). This is an important consideration because in order to inject
wastewater into the Floridan, pumping must be used to overcome this
artesian pressure. The Boulder Zone, a highly permeable cavernous zone
in the Lower Floridan Aquifer System, extends throughout the Keys and
its top ranges from about --2,800 feet at the north end of Key Largo to
--3,300 feet near Key West (Figure 3-4).

The Boulder Zone was first recognized by oil-well drillers in Collier
County, Florida, where several commercial oil fields were developed in
the early 1940s (Meyer, 1989). The term "Boulder Zone" is a misnomer as
this zone is massive, extensively cavernous and fractured dolomite
(Miller, 1986). The caverns and fractures result in slow drilling and
rough bit action similar to that with drilling through boulders. This
behavior gave rise to the misnomer "Boulder Zone," first applied to the
cavernous dolomite by drillers and subsequently adopted by Kohout (1965)
and later authors. Miller (1986) further observes that the "Boulder
Zone" has no stratigraphic significance, but rather represents a
widespread zone of paleokarst in South Florida due to solution of the
dolomite at a time when the rocks were close to land surface, above the
water table. Subsequent vertical geological movement has carried the
paleokarst zone to its present depths of about 2,500 to 3,500 feet.

In 1965, F.A. Kohout of the USGS (Kohout, 1965) proposed a conceptual
model for regional flow in the Floridan Aquifer in south Florida. This
conceptual model was summarized together with post-1965 substantiating
field evidence by Meyer (1989).

INSERT FIGURE 3-4: BOULDER ZONE

Figure 3-5, adapted from Meyer 1989, shows the essential features of
groundwater circulation in south Florida as follows: (1) cool sea water
flows inland from the Straits of Florida through the Boulder Zone and
other permeable strata in the Lower Floridan Aquifer (upper and middle
dolostones); the inflowing sea water is warmed by geothermal heat as it
moves inland, becoming less dense as the temperature increases; (2) the
lighter, warmer sea water migrates upward through confining units above
the lower Floridan Aquifer into the lower part of the upper Floridan
Aquifer where it mixes with fresher water recharged from the land
surface; (3) the blend, somewhat less saline than sea water, then flows
seaward to discharge points along the continental slope on all sides of
the Florida Peninsula.

The key features of the circulating system (Figure 3-5) have been
substantiated by field data, including stratigraphy, carbon-14 dating of
water of the Boulder Zone and upper Floridan Aquifer, uranium isotope
ratios in the water of the Boulder Zone, groundwater temperatures, and
hydraulic head data. On the key point of upwelling of the warm saline
water from the Boulder Zone, Meyer (1989) summarizes temperature and
salinity data from several locations on the west coast of Florida near
Ft. Myers, and along a structural feature near the east coast about 20
miles inland from St. Lucie Inlet. The locations of these temperature
anomalies are shown on Figure 3‑2 of this report, which also shows lines
of equal temperature of water of the lower Floridan Aquifer and
submarine topography off south Florida.

Because the salinity and temperature of the water in the Boulder Zone
are similar to those of modern seawater, the zone is thought to be
connected to the Atlantic Ocean, possibly about 25 miles east of Miami
where the sea floor is almost 2,800 feet deep along the Straits of
Florida (USGS, 1990; Singh and Sproul, 1980; Hickey, 1984).

#### Environmental Consequences

##### Alternative 1 -- No Action Alternative

The project applicant would not receive FEMA funding to help meet
Florida Statutory Treatment Standards by the year 2010. Under this
alternative, the construction of WWTPs, clustered OWNRS, and other
wastewater management activities would occur, but without FEMA funding.
While project applicants are seeking alternative funding sources,
wastewater treatment improvements would likely be delayed until adequate
funding becomes available.

Effects on geology related to the construction of WWTPs and clustered
OWNRS focus on the use of injection wells to dispose of treated
wastewater effluent and are further described in Sections 3.1.3.2.2 and
3.1.3.2.3. Impacts relating to the use of a grinder pump or vacuum pump
system for collection, and water reuse, as a disposal option would
result in minor, temporary impacts relative to geology.

##### Alternative 2 -- Centralized Wastewater Treatment Plant Alternative

Aside from potential impacts related to the use of injection wells, the
construction of a WWTP is not expected to result in adverse effects on
geology. The environmental consequences to the geologic environment with
shallow injection well use are expected to be limited to the effects of
injection of relatively fresh effluent into brackish to saline water
aquifers, which could affect the rate of limestone solution.

INSERT FIGURE 3-5: CIRCULATION

Shallow wells in the context of wastewater disposal in the Keys refers
to wells that are at least 90 feet deep with at least 60 feet of the
well encased in steel and/or PVC and grouted with cement. Injection of
relatively fresh effluent into a unconfined, brackish to saline water
aquifer could conceivably increase the rate of limestone dissolution,
resulting in enlargement of voids and development of sinkholes.
Carbonate rocks are readily dissolved where they are exposed at land
surface or overlain by soil zones. Precipitation absorbs some carbon
dioxide, sulfur oxides, and nitrogen oxides from the atmosphere as it
falls, and from soil organic matter as it percolates down to the water
table, thus forming weak carbonic, sulfuric, and nitric acids. This
acidic water dissolves carbonate rocks, initially by enlarging
pre-existing openings, such as pores and fractures in the rock. These
small solution openings become larger as more acidic water moves through
the rock; eventually the openings may be tens of feet in diameter. The
end result of dissolution of carbonate rocks is a type of terrain called
"karst," which is characterized by caves, sinkholes and other solution
openings, and by interconnected underground drainage systems. The acids
that cause solution are depleted, or buffered, in reactions with the
carbonate rocks, thus the most vigorous solution generally occurs above
or near the water table. Deeply buried solution zones, such as the
Boulder Zone, generally represent ancient solution activity, called
"paleokarst," at a time when the rocks were close to land surface.

In mainland Florida, such sinkhole development, especially in areas of
declining water tables, has been a severe engineering problem. Sinkholes
can result in the collapse of the land surface, damaging roads and
building foundations, and posing public safety risks among other adverse
impacts. However, in the Keys, the water table is generally within five
feet of the land surface and water tables have not been declining. If
disposal of relatively fresh wastewater and effluent from OWTS and
through disposal wells has resulted in accelerated dissolution, the
effects have not yet been observed as an engineering issue.

To mitigate the potential effects of limestone dissolution on shallow
well design and function, appropriate geotechnical studies would be
conducted by the applicant prior to design and construction to
adequately characterize the geological and geotechnical environment. The
SER would incorporate the data, results, and design measures as
appropriate to fully discuss effects on geology. However, based on
present observations, accelerated oolite and limestone dissolution may
not occur, though engineering design should take adequate precaution
against the possibility.

##### Alternative 3 -- On-Site Treatment Upgrades

Aside from potential impacts related to the use of injection wells, the
construction of clustered OWNRS is not expected to result in adverse
effects on geology. For disposing of treated effluent, clustered OWNRS
may employ either SDI or shallow injection wells. As described in
Section 3.1.3.2.2, if disposal of relatively fresh wastewater and
effluent from existing on-site systems through shallow injection wells
has resulted in accelerated limestone dissolution, the effect has not
been observed as an engineering issue in this case. To mitigate the
potential effects of limestone solution OWNRS design and function,
appropriate geotechnical studies would be conducted by the applicant
prior to design and construction to adequately characterize the
geological and geotechnical environment.

## WATER RESOURCES AND WATER QUALITY

### Regulatory Setting

With its diverse marine ecosystem, natural beauty, and extensive and
lucrative recreational opportunities, the Keys constitute an important
part of Florida's tourist industry and a significant part of the
nation's collective natural resources. Much of the Keys economic and
natural resource value relies on the maintenance of high water quality.
In order to protect the Keys' environmental health and water quality, a
number of laws, standards, and regulations have been promulgated by
Federal, State, and local agencies including the EPA, NOAA, USACE, FDEP,
FDH, FKAA, South Florida Water Management District, FKNMS, and Monroe
County. The marine environment in the Keys is also managed through the
FKNMS whose geographic area covers the entire stretch of the Keys, and
whose technical advisory and steering committees include representatives
from the aforementioned organizations along with the USFWS, Everglades
National Park, Florida Keys Environmental Fund, and the Cities of Key
Colony Beach, Layton, and Key West.

A number of Federal, State, and local laws and regulations govern water
quality issues in the Keys, including the Florida Keys National Marine
Sanctuary and Protection Act, CWA, RCRA, and the EPA's Ocean Discharge,
Gulf of Mexico, UIC, and Ocean Dumping Programs, among others.

The waters surrounding the Keys have been declared as "Outstanding
Florida Waters" (OFW) by the State of Florida (FDEP, 1985). "Special
Waters" and OFWs include 39 of Florida's 1700 rivers, several lakes and
lake chains, several estuarine areas, and the Keys. By regulation, input
of materials that could be considered pollutants to open surface waters
cannot exceed the concentration of those materials that naturally occur
in water. However, ambient background conditions can change seasonally
or at different phases of the tidal cycle. Because of the OFW
designation, direct surface water discharges of pollutants have been
eliminated, or are being phased out (Kruczynski, 1999).

Proposed activities in OFWs that would normally require a FDEP permit
are required to meet the following separate requirements for direct and
indirect discharges:

-   New direct pollutant discharges must not lower existing ambient
    water quality.

-   New indirect pollutant discharges (discharges to waters that
    influence OFWs, although not placed directly into an OFW) must not
    significantly degrade nearby OFWs.

New project activities receiving FDEP permits must also be "clearly in
the public interest." Existing legal discharges are "grandfathered" and
may continue without any new OFW requirements.

As part of the evaluation of the Keys as OFW, water quality "Hot Spots"
were identified. These "Hot Spots" are canals and other confined water
bodies that demonstrate signs of eutrophication (i.e., higher levels of
BOD, TSS, TN, and **total phosphorus** \[**TP**\]) and have been
targeted by FDEP as priority areas for water quality management
activities. A list of the "Hot Spot" rankings and a map of their
locations are included as Appendix C and Figures 2-1, 2-2, and 2-3,
respectively.

In concert with the establishment of the FKNMS, EPA, and FDEP developed
the Water Quality Protection Program (WQPP) for the Sanctuary. The
purpose of the WQPP is to recommend priority corrective actions and
compliance schedule for addressing point and multipoint sources of
pollution to restore and maintain the chemical, physical, and biological
integrity of the Sanctuary, including restoration and maintenance of a
balanced, indigenous population of corals, shellfish, fish, and
wildlife, and recreation activities on the water (Florida Keys National
Marine Sanctuary and Protection Act).

State of Florida water quality standards are promulgated in Chapter
62-302 F.A.C. Rule 62-302.400 classifies surface waters of the State
according to designated uses that include: Class I, Potable Water
Supplies; Class II, Shellfish Propagation or Harvesting; Class III,
Recreation, Propagation and Maintenance of a Healthy, Well-Balanced
Population of Fish and Wildlife; Class IV, Agricultural Water Supplies;
and Class V, Navigation Utility and Industrial Uses. Marine waters in
the Keys are classified as Class III Marine Waters and include criteria
levels for 89 potential pollutants under Rule 62-302.530.

Both the EPA and NOAA have direct mandates to conduct monitoring in
FKNMS. Comprehensive, long-term monitoring program was begun by Florida
International University under contract to the EPA as part of the WQPP
in 1995. These monitoring efforts include 42 fixed stations throughout
the Keys to monitor coral population dynamics, 154 fixed stations from
Key Largo to the Dry Tortugas that monitor water quality parameters such
as nutrients, salinity, **turbidity**, and **phytoplankton** biomass,
and 51 sites throughout the FKNMS to monitor seagrass dynamics (FKNMS,
2001). Some recent results of this monitoring program are presented in
Section 3.2.3.1.2 of the draft PEA.

The Safe Drinking Water Act of 1974, to protect the quality of drinking
water in the U.S., promulgates drinking water regulations. This law
focuses on all waters actually or potentially designed for drinking use,
whether from above ground or underground sources. Florida State
regulations classify potable water supplies as Class I under Rule
62-302.400. The Keys' potable water supply is provided by the FKAA from
water drawn from wells in the Biscayne Aquifer below a pineland preserve
west of Florida City in Dade County, on the mainland.

The South Florida Water Management District (SFWMD) provides flood
control protection and water supply protection to residents living and
working in cities or on farms within south Florida; and is working to
restore and manage ecosystems from the Kissimmee River to the Everglades
and Florida Bay. SFWMD issues permits for the construction of water
supply wells, as well as environmental resource permits that regulate
wetland resources, mangrove alteration, and surface water management in
accordance with the Florida Environmental Regulation Act of 1993. SFWMD
defers wastewater regulation, including the construction of wastewater
injection wells to FDH and FDEP (Leckler, Pers. Comm., 2001).

Of particular relevance to this analysis is F.L. 99-395 that pertains to
OSTDSs. Passed by Florida State Legislature in 1999, this law includes
specific requirements for all sewage treatment, reuse and disposal
facilities, and all OSTDSs in Monroe County. The provisions prohibit any
new or expanded discharges into surface waters, and require that
existing surface water discharges be eliminated before July 1, 2006. As
detailed in Table 2-1 in Section 2.3.2, F.L. 99-395 specifies effluent
standards produced by sewage facilities of varying capacity.

In addition to the State standards, the *Monroe County Year 2010
Comprehensive Plan*, initially adopted in 1993 and amended in 1997,
mandates that nutrient loading levels be reduced in the marine ecosystem
of the Keys by the year 2010. In 1998, the Florida Governor issued EO
98-309 that charged local and State agencies with coordinating with
Monroe County to execute the *Year 2010 Comprehensive Plan* in order to
eliminate cesspits, failing septic systems and other substandard on-site
sewage systems, and to require that all wastewater discharge be treated
to AWT or BAT. Construction of WWTPs and wastewater effluent injection
wells are regulated by FDEP for wastewater quantities in excess of
10,000 gpd, and by FDH for quantities below 10,000 gpd.

### Groundwater

#### Affected Environment

While large quantities of saline water underlie the Keys, fresh water
resources are limited to a few fresh water lenses beneath some of the
larger islands of the Lower Keys. The islands of the Upper Keys are
generally long and narrow and the groundwater is at best brackish and of
little potential utility except as input for desalination systems. In
the Lower Keys, some islands are relatively large and underlain by the
Miami Oolite, which is favorable for small fresh water to slightly
brackish water lenses. Such lenses have been used in the past for
domestic water supply and for irrigation and other water uses.

The potable water supply resources used by Monroe County are obtained
from wells tapping the Biscayne aquifer in Miami-Dade County, entirely
outside of Monroe County's jurisdiction. No new wells have been
permitted in the Keys since 1986, which would limit use of underground
brackish/saline resources in the Keys as potential potable water
resources. The FKAA is the agency that obtains and distributes potable
water in the Keys. Since the potable water source for Monroe County is
located entirely within Miami-Dade County, aquifer protection related to
the FKAA's Florida City Wellfield is accomplished through the provisions
of the Miami-Dade County Wellfield Ordinance. In Monroe County,
groundwater resource protection and management takes place in the
context of intense Federal, State, and private interest in natural
systems as evidenced by the extensive amount of protected lands and
waters (Monroe County, 1997).

The Key West and Big Pine Key fresh water lenses have been studied and
reported on. The Key West lens in 1986 (defined as groundwater of less
than 250 mg/L chloride content) averaged about 1.5 meters thick at its
center, and was estimated to contain 30 million gallons (Mgal) at the
end of the rainy season and 20 Mgal at the end of the dry season (Halley
et al., 1997). A Big Pine Key lens (defined as ground water of less than
500 mg/L chloride content) extends down to about 16 feet, and the lens'
base corresponds to the base of the high permeability sediments of the
Miami Oolite (Halley et al., 1997).

Of greater interest in the Keys is the use of groundwater for waste
disposal. It is reported that about 26,000 Keys properties are served by
on-site sewage disposal systems, including 18,000 permitted septic tank
systems and 7,200 unpermitted systems, presumably largely cesspools.
Multifamily dwellings and commercial facilities commonly rely upon
package WWTPs, of which there are some 250 permitted (Kruczynski, 1999).

Because of stringent regulatory standards for surface-water discharges,
the package plants generally discharge treated effluent through
permitted "shallow" Class V injection wells, of which 750 have been
permitted in the Keys (Kruczynski, 1999). These shallow Class V wells
are required to be 90 feet deep and with a grouted cement casing to 60
feet; thus, they discharge relatively fresh but nutrient rich waters
into the Upper Water-Bearing Zone. By virtue of their design, the 26,000
on-site systems also discharge their effluents into the Upper
Water-Bearing Zone.

As described in more detail in Section 3.2.2.2.2.2, the deeper Floridan
Aquifer has been used for the disposal of treated effluent through deep
injection wells in various parts of Florida for more than 40 years with
the deep injection well in operation in Broward County in 1959 (Earle
and Meyer, 1973; Vecchioli et al., 1979). There are about 120 of these
types of deep injection wells in Florida, classified as Class I (FDEP,
2001a). Most of the Class I injection facilities in Florida dispose of
non-hazardous, secondary treated effluent from domestic WWTPs. At
present, there is one deep injection well used to dispose treated
municipal wastewater operating in the Keys. Located in the City of Key
West, the deep injection well has been in operation since early
September 2001 and replaces an ocean outfall. The deep injection well is
used to dispose of treated municipal wastewater, and has average daily
flow of 4.0 mgd and maximum capacity of 7.2 mgd (Fernandez, Pers. Comm.,
2001).

The EPA (1996) estimates that nutrient loading from the Keys to
nearshore marine waters total 2,377 lbs/day of TN and 544 lbs/day of TP.
Of these totals, about 80% of TN (1,900 lbs/day) and 56% of TP (305
lbs/day) were attributed to wastewater disposal; the remaining 20% (475
lbs/day) of TN and 44% (239 lbs/day) of TP were allocated to stormwater
runoff from the Keys. These loading estimates assume that all wastewater
nutrients, including groundwater sources, reach nearshore marine waters.
Of the total loading cited above, 13.5% (321 lbs/day) of TN and 6.6% (36
lbs/day) of TP were attributed to municipal outfall discharges chiefly
of the City of Key West, which replaced their ocean outfall with a deep
injection well in September 2001. Live aboard boats discharging sewage
directly to marine waters account for 3.5% (84.1 lbs/day) of TN loading
and 5.5% (30 lbs/day) of TP loading. Deducting the direct nutrient
contributions from outfalls, boats, and stormwater runoff results in
about 1,497 lbs/day of TN and 239 lbs/day of TP as the groundwater
contribution to the total nutrient loading of the nearshore marine
waters. These data suggest that nutrient-rich groundwater accounts for
about 79% of TN and about 78% of TP loading from the Keys to the
nearshore marine waters (EPA, 1996). As described in Section 1.4,
nutrient levels in these nearshore marine waters are also influenced by
external sources, such as the Gulf of Mexico and Florida Bay.

Long, continued waste disposal into the Upper Water-Bearing Zone has led
to major groundwater quality changes in the developed areas. While the
wastewater is of lower salinity than that of the natural groundwater,
the wastewater is enriched in the nutrients nitrogen and phosphorous, as
well as **fecal coliform** bacteria, and it is oxygen-depleted. As
groundwater is minimally used in the Keys, this groundwater quality
degradation has been of little direct concern. However, the Upper
Water-Bearing Zone is in direct communication with the nearshore marine
waters, and the degraded groundwater can discharge into the marine
environment within hours to days. Because of the high groundwater
salinity in the Upper-Water Bearing Zone, there has been little testing
of its hydraulic characteristics. However, Halley et al. (1997) estimate
the hydraulic conductivity of the Miami Oolite to be about 120 meters
per day, and of the Key Largo Limestone to be about 1,400 meters per
day. This pattern of rapid groundwater discharge to nearshore marine
waters is exacerbated by the 700 or so dead-end canals constructed over
the past several decades, for the purposes of providing boat access to
residences and dredge material for landfilling. Generally, these canals
were excavated to 10 to 20 feet to maximize the amount of material
available for landfilling. These deep dead-end canals in residential
areas served by on-site sewage disposal systems have the general effect
of speeding the groundwater discharge to marine waters. The water
quality effects are described Section 3.2.3.

#### Environmental Consequences

##### Alternative 1 -- No Action Alternative

As described in Section 2.3.1, FEMA funding would not be available for
the wastewater management projects, but individual property owners
and/or communities would still comply with the Florida Statutory
Treatment Standards by 2010.

Disposal of nutrient-rich sewage effluent to the shallow groundwaters of
the Keys would be largely ended. Effluent would be disposed of in
shallow injection wells. Solid wastes (sludge) from the waste treatment
facilities would be disposed of at appropriate licensed disposal sites
in mainland Florida.

According to the MCSWMP, areas that are not served by new or upgraded
WWTPs would be required to replace existing OWTS with OWNRS that meet
Florida Statutory Treatment Standards. New or upgraded OWNRS systems
would use either shallow injection wells (90 feet deep) or SDI for
treated effluent disposal.

*[Expected Water Quality Benefits of Meeting Florida Statutory Treatment
Standards]{.underline}*

Replacing existing cesspools and septic systems with OWNRS systems and
centralized WWTPs in compliance with Florida Statutory Treatment
Standards would greatly reduce the overall nutrient and pathogen inputs
to the shallow groundwater of the Keys, and thus contribute to overall
groundwater quality improvements.

As part of preparation of this draft PEA, an analysis was conducted to
estimate the extent of water quality improvements that might be expected
by improving wastewater management within an existing service area in
the Keys (Appendix D). The analysis focused on a proposal for four small
WWTPs in the Village of Islamorada that had average daily flow
capacities of 0.534 mgd, 0.062 mgd, 0.186 mgd, and 0.129 mgd,
respectively with effluent treated to AWT standards (i.e., 5 mg/L BOD, 5
mg/L TSS, 3 mg/L TN, 1 mg/L TP), (Islamorada, 2001a). The analysis
assumes that currently all sewage disposal is by on-site septic systems
(i.e., no cesspools/cesspits), and that the wastewater inflow is the
average daily flow of the proposed plants (i.e., 0.911 mgd). The
assumption that all on-site systems are septic tanks is a conservative
estimate of existing nutrient loadings because the existing cesspools
typically generate higher nutrient loadings than septic tanks.
Additionally, the analysis assumes that raw sewage nutrient
concentrations are the same as those estimated in the Big Pine Key
Demonstration Project (Ayres Associates, 1998), and that TP is not
removed from groundwater by reaction with aquifer limestones. The
results of the analysis found that the replacement of existing OWTS
(assumed all septic systems) with WWTPs that meet AWT standards result
in a 92% reduction in TN input to groundwater (i.e., 280 lbs/day
decreased to 22.8 lbs/day), and a 86% reduction in TP input to
groundwater (50 lbs/day to 7.6 lbs/day). In groundwater transit to
discharge to marine waters, negligible TN reduction occurs, and it is
assumed that TP is not removed from water by chemical reaction with the
aquifer's carbonate rocks. Thus, the benefit of AWT systems in terms of
nutrient removal would be in the form of 92% reduction in TN and 86%
removal of TP. Please see Appendix D of this draft PEA for additional
details pertaining to the results of this analysis.

It should be noted that the treated effluent would still contain limited
nutrients even under conditions that meet the 2010 standards. Similarly,
under the most favorable circumstances, low levels of contaminants would
still reach the groundwater with leakage from domestic sewers and
collection systems and from fugitive stormwater runoff and leakage from
stormwater sewers. While the limited nutrients and pathogens would enter
the shallow groundwater of the Keys even under after implementation of
the alternative, the overall result is a net improvement in groundwater
quality when compared to nutrient and pathogen levels prior to
alternative implementation. Even with alternative implementation, years
to centuries would be required to flush existing contaminants and
nutrients from the shallow groundwater. However, with cleanup efforts
focused on major problem areas, incremental benefits in the form of
improvement in groundwater quality should be observed promptly.

##### Alternative 2 -- Centralized Wastewater Treatment Plant Alternative

This alternative would involve the construction or upgrade of WWTP
systems with the assistance of FEMA funding. Effects on groundwater
would be similar to those described under the No Action Alternative. The
water quality improvements expected under this alternative would be on
the order of those described in the No Action Alternative and further
outlined in Appendix D (i.e., 92 and 86% reductions in TN and TP
loadings, respectively). However, it is difficult to determine the exact
extent of these improvements due to a number of unknown variables. These
include the length of time it would take to flush out present levels of
nutrients and other pollutants presently in the groundwater, local
variations of hydrogeologic characteristics, and the extent to which
limestone substrates remove phosphorus from injected effluent.

WWTP construction would require several FDEP permits in accordance with
F.A.C. Applicable permits for WWTP construction and operation are
described in Appendix E.

###### Collection Options: Vacuum Pumping (Option 1) and Low-Pressure Grinder Pump Sewer System (Option 2)

Assuming proper design and reasonable operating conditions, neither the
use of vacuum pumping nor low-pressure grinder pump sewer system would
involve significant effects on groundwaters. Establishment of the
collection system as part of new treatment plant construction would
require the FDEP permits identified in Appendix E.

###### Disposal Option 1 --Shallow Injection Wells

Most WWTPs in the Keys currently dispose their treated effluent into
shallow injection wells (cased 0 to 60 feet, open hole 60-90 feet). The
effluent represents recharge to the highly permeable Upper Water-Bearing
Zone limestones. As further described in Section 2.3.2.2.1, such wells
are considered as Class V wells and at plants of less than 100,000 gpd
capacity are required to meet BAT limitations (i.e., 10 mg/L BOD, 10
mg/L TSS, 10 mg/L TN, and 1 mg/L TP). Plants of larger than 100,000-gpd
capacity are required to meet more stringent AWT effluent limitations
(i.e., 5 mg/L BOD, 5 mg/L TSS, 3 mg/L TN, and 1 mg/L TP).

The application of effluent limitations to injection wells represents a
major improvement when compared to cesspools and septic systems.
However, even in compliance with the Florida Statutory Treatment
Standards, effluent limitations would still allow for some nutrient
inputs to shallow groundwater. The expected water quality improvements
are described further in Section 3.2.2.2.1.

Present Federal requirements prohibit any injection activity that may
endanger USDW (40 CFR Part 144). Similarly, present Federal regulations
require all owners and operators of Class V injection wells to provide
inventory information to FDEP, the State UIC authority. Construction of
new wells or upgrade of existing "shallow" Class V injection wells would
require compliance with joint EPA/FDEP UIC regulations and the
FDEP-administered permits referenced in Appendix E. As further explained
in Section 3.6.4, Public Health, effluent would be disinfected to reduce
the health risk of fecal contamination through such techniques as
biological treatment and/or chlorination.

###### Disposal Option 2 -- Wastewater Reuse

Under present State regulations, effluent reuse is authorized for
various purposes of which land application for irrigation is the
principal reuse practiced in Florida. However, in the Keys, land
application has not been widely used, owing to the absence of
agricultural demand and the high cost of effluent reuse due to stringent
treatment standards, which is not competitive with the cost of fresh
water imported from the mainland via pipeline. Under continuation of
present policies and conditions, it is not expected that effluent reuse
would significantly affect groundwater in terms of quality or quantity.

The application of treated wastewater is regulated through FDEP. The
required permits for this alternative depend on the type of application.
The applicable permits are referenced in Appendix E.

##### Alternative 3 -- On-Site Treatment Upgrades

FEMA funding would be used to assist in the conversion of OWTS to
clustered OWNRS. New OWNRS would be required to meet BAT standards of 10
mg/L BOD, 10 mg/L TSS, 10 mg/L TN, 1 mg/L TP.

As estimated by Ayres Associates (1998), raw residential wastewaters
typically contain 200 to 400 mg/L BOD, 200 to 400 mg/L TSS, 35 to 100
mg/L of TN, and 12 to 18 mg/L of TP. Septic systems typically reduce
these levels to average values of 138 mg/L for BOD, 49 for TSS, 45 for
TN, and 13 for TP (SSWMP, 1978). Cesspools and cesspits probably offer
little reduction in these parameters below the raw-water concentrations.
Regulated OWTS and cesspits/cesspools are estimated to account for 50%
of the wastewater TN loading and 60% of the wastewater loading emanating
from the Keys, respectively (Ayres Associates, 1998).

An OWNRS demonstration project, funded by FDH and EPA, was conducted at
Big Pine Key to demonstrate the use and capability of alternative
on-site technologies for the Keys (Ayres Associates, 1998). The OWNRS
demonstration project consisted of detailed treatment system performance
evaluations at a central test facility on Big Pine Key and general field
evaluations of alternative on-site systems installed at three individual
homes in the Lower Keys. The Big Pine Key Road Prison was selected as
the central test facility and the design was set up to allow comparative
testing of five on-site wastewater treatment processes simultaneously,
under controlled conditions, with a common wastewater source. The
loading schedule of the systems was programmed to simulate the diurnal
wastewater flow characteristics of a single-family residence, with peaks
in the morning and early evening hours (Ayres Associates, 1998).

The following treatment processes were tested to evaluate their
potential to reduce organic, solids, and nutrient loading to near-shore
waters of the Keys:

1.  Conventional septic tank coupled with a recirculating sand filter
    (RSF) and ABF.

2.  Conventional septic tank coupled with SDI in porous media irrigation
    beds.

3.  Fixed Activated Sludge Treatment (FAST), (proprietary).

4.  Continuous Feed Cyclic Reactor System (CFCRS), (proprietary).

5.  Rotating Biological Contactor (RBC), (proprietary).

Additional unit processes were tested for nitrogen and phosphorus
removal as add-ons to the above methods. These included a chemical
precipitation unit (CPU), engineered porous media intermittent filter
beds with SDI, and a carbon tablet feeder/ABF for de-nitrification.

Table 3-1 below summarizes the nutrient removal levels associated with
each treatment process (1-5) as compared to the Florida Statutory
Treatment Standards (in italics) for each nutrient.

Table 3-1: Big Pine Key Treatment System Nutrient Removal Rates

  -------------------- ----------- ---------- --------------- -------------
  **System Number**    **BOD\      **TSS\     **TN\           **TP\
                       (mg/L)**    (mg/L)**   (mg/L)**        (mg/L)**

                       *10*        *10*       *10*            *1*

  1                    2.18        2.25       20.76           1.76

  2                    2.81        4.09       21.15           0.6

  3                    2.63        4.63       10.97           5.38

  4                    3.19        6.85       15.46           6.24

  5                    1.68        5.75       12.52           4.67
  -------------------- ----------- ---------- --------------- -------------

In summary, all the systems tested met the BAT limits and AWT limits for
BOD and TSS. None of the systems tested met the BAT limit for TN and
only one met the TP limit. Ayres Associates (1998) concluded that a
combination of unit processes with discharge to an engineered media SDI
could reduce TN by 85%, and together with process optimization and/or
supplemental carbon addition could produce effluent discharged from the
SDI close to the AWT TN limit of 3 mg/L and effluents could meet AWT
limits for BOD (5 mg/L), TSS (5 mg/L), and TP (1 mg/L).

With respect to the environmental consequences to groundwater resources,
the upgrading of OWTS to OWNRS standards would reduce contributions of
nutrient (TN and TP) and pathogen loadings to groundwaters of the Keys,
and thus would be beneficial to that environment. However, after
upgrading is completed, years to centuries of flushing of the existing
nutrient load from the aquifers would be required before optimal levels
of nutrient discharge to nearshore marine waters could be expected. Only
long-term observation would answer the question of how long it will take
to correct the existing nutrient discharge to nearshore sea waters.
Additionally, problems of non-compliance with design standards and
operation and maintenance procedures could reduce the potential for
water quality improvements.

The results of field tests reported by Ayres Associates (1998) were
highly encouraging regarding the ability of OWNRS to meet the Florida
Statutory Treatment Standards of 2010. However, it should be recognized
that not all upgraded systems would perform as well as research-style
field tests. It is unlikely that all systems would meet design
standards, and operation and maintenance procedures are difficult to
monitor and enforce. Thus, continued contamination of nutrients at low
levels exceeding the OWNRS limits may be expected under Alternative 3.
In order to mitigate this potential adverse impact, the project
applicant would be required to establish a monitoring, compliance, and
enforcement plan to help ensure that clustered OWNRS systems meet
Florida Statutory Treatment Standards on a consistent basis.

### Inland, Nearshore, and Offshore Waters

#### Affected Environment

The surface water resources of the Keys include: (1) inland ponds, which
compose 3,400 acres or 5.2% of the total area of the islands (Hurt et
al., 1995); (2) about 700 canals constructed to provide boat access to
marinas and residential developments; (3) stormwater runoff to ditches
and drainage systems in developed areas; and (4) nearshore marine
waters. There are no permanent streams on the Keys as most rainfall
evaporates, infiltrates directly into the ground, or runs off as sheet
flow to canals or the shoreline. Although the orthophoto maps of Hurt et
al. (1995) identify seven features as creeks, these features in all
cases are tidal channels connected at both ends to marine waters.
Although the inclusion of nearshore marine waters as surface waters of
the Keys may seem odd because their outer extent is ill defined, the
degradation of the marine environment is the focus of public concern
about environmental degradation in the Keys. Although degradation of the
marine environment is the focus of public concern, owing to the diffuse
nature of stormwater runoff and groundwater discharge to marine waters,
little comprehensive data is available on the quantity and quality of
surface runoff and groundwater discharge to the marine environment.

##### Inland Waters

Degraded water quality within canals throughout the Keys has been
documented since the early 1970s. Barada and Partington (1972) concluded
that excavating artificial canals causes serious environmental
degradation within the canals themselves and in waters adjacent to
canals. Deep, narrow, box-cut canals with dead-end configurations
gradually accumulate oxygen-demanding and toxic sediments and organic
wastes, causing low dissolved oxygen, objectionable odors (hydrogen
sulfide), and floating sludge that can result in fish kills and
undesirable conditions. Eutrophication often occurs in canals with poor
circulation and is accelerated by a heavy pollution load, which is
related to population density and shoreline length (Barada and
Partington, 1972; Kruczynski, 1999).

Studies also indicate that sewage discharged from cesspits and septic
tanks are a significant source of nutrients and pathogens to canal
waters. A direct connection with septic tank waste disposal and canal
waters was shown by a viral tracer study in Key Largo. Tracers added to
a domestic septic tank appeared in a canal in 11 hours (Paul et al.,
1995a). The rapid hydraulic conductivity of Keys aquifers of wastewater
and the influence of tides have been identified as major sources of
water quality problems in canals (Kruczynski, 1999). As further evidence
of the eutrophication of canal waters, seagrass beds located near the
mouths of some degraded canal systems show signs of eutrophication, such
as increased **epiphyte** load and **benthic algae** growth.

Canals and other confined water bodies that showed signs of
eutrophication during a review of OFW in the Keys were listed as "Hot
Spots" (Appendix C; Figures 2-1, 2-2 and 2-3). Three recommendations
were made for all higher priority, poorly designed canal systems:
install BAT sewage treatment, collect and treat stormwater runoff, and
improve canal circulation (Kruczynski, 1999; EPA, 1993a).

##### Nearshore and Offshore Marine Waters

The Keys ecosystem has been described as an "open" system because of the
high degree of communication between ground, canal, and nearshore and
offshore marine waters. The Keys' nearshore waters are primarily
influenced by the Gulf of Mexico, either directly (primarily Lower Keys)
or via passage through Florida Bay (primarily Middle Keys). There is a
net flow of surface and groundwater flow from the bay-side to the
ocean-side of the Keys. A higher mean sea level in Florida Bay than in
Hawk Channel provides a "head" that drives net water flow towards Hawk
Channel (refer to Figure 3-1). In general, net water transport within
Hawk Channel is to the west with an offshore component. Because of this,
water passing through the large passes of the Middle Keys flows west and
south and has relatively little influence on ocean-side waters of the
Upper Keys. Periodically, oceanic waters from the Florida Current can
influence lower portions of Hawk Channel depending upon offshore
circulation patterns and tides (Monroe County, 2001a).

Water flow through the Keys is primarily tidally driven with the
underlying differential sea levels influencing the net transport. Wind
events also affect such transport, particularly in winter when northerly
winds enhance this net north to south movement and reduce sea levels,
exposing shallow banks. The flow velocity (speed of water movement) in
the channels is strongly influenced by tidal height differentials
(greater during spring tides) as well as wind. Average and extreme flow
velocities are important physical factors in determining the nature of
marine sediment distribution and the associated benthic communities
(Monroe County, 2001a).

Several recent studies have found a connection between fecal
contamination and eutrophication of nearshore waters and septic tanks.
Lapointe and Clark (1992) found a gradient in nutrients from nearshore
to offshore waters with canals having elevated soluble reactive
phosphorus (0.3 micromole (μM)) compared to seagrass meadows (0.1 μM),
patch reefs (0.05 μM), and offshore reef banks (0.05 μM). The results of
the study concluded that the widespread use of septic tanks increases
the nutrient contamination of groundwaters that discharge into shallow
nearshore waters, resulting in coastal eutrophication. In a later study,
Lapointe et al. (1994) found that nutrient enrichment from land-based
sewage inputs can significantly affect seagrass productivity for
considerable distances from shore (3 to 4 miles). Paul et al. (1997)
used an active shallow Class V disposal well in the Middle Keys and a
simulated injection well in Key Largo to understand the transport and
fate of wastewater. In both areas, viral tracers appeared after short
periods in marine waters (10 hours and 53 hours for Key Largo and the
Middle Keys, respectively).

Szmant and Forrester (1996) measured distribution patterns of nutrients
to determine whether nutrients from the Keys may be reaching the outer
reef tract. Samples were taken along transects at stations located in
tidal passes and canal mouths to about 0.5 km seaward of the outermost
reef (Kruczynski 1999; Szmant and Forrester, 1996). In the Upper Keys,
water column nitrogen and chlorophyll were elevated near marinas and
canals, but returned to **oligotrophic** concentrations within 0.5 km of
shore. Phosphorus concentrations were higher at offshore stations and
were attributed to upwelling of deep water along the shelf edge at time
of sampling (Kruczynski 1999; Szmant and Forrester, 1996). In the Middle
Keys, both water column nutrients and chlorophyll concentration were
higher than observed in the Upper Keys, and there was a lower gradient
of nearshore-offshore waters in comparison to the Upper Keys. Sediment
nutrients were also higher, and there were no differences in nutrient
concentrations at nearshore and offshore areas. In general, the results
of the study found that nutrient pollution emanating from the Keys had
greater nearshore effects than offshore effects due to the high level of
dilution from currents and tidal movement. Offshore areas in the Middle
Keys that had higher nutrient levels than offshore areas in the Upper
Keys were attributed to the relatively high nutrient-content of Florida
Bay (Kruczynski 1999; Szmant and Forrester, 1996).

In addition to directed scientific research, water quality monitoring
has been conducted by Florida International University as part of the
WQPP since 1995 as introduced in Section 3.2.1. Of the several water
quality parameters that have been monitored, the program has revealed
significant trends in TP, nitrate (NO~3~), and total organic nitrogen
(TON). According to the Fiscal Year 2000 Annual Report, trend analysis
showed statistically significant increases in TP for the Tortugas,
Marquesas, Lower Keys, and portions of the Middle and Upper Keys over
the 5-year sampling period. The trends were identified as linear
increases with little seasonality. No TP trends were observed in Florida
Bay or in those FKNMS sites most influenced by transport of Florida Bay
waters. Concentrations of NO~3~ increased over the period with most of
the increases occurring in the Shelf, Tortugas, Marquesas, Lower Keys,
and Upper Keys. TON decreased over the 5-year sampling period. The
monitoring program speculates that regional circulation patterns arising
from the Loop and Florida Currents were responsible for the decreases in
TON (Jones and Boyer, 2001). It should be noted that several other
studies, including Cook (1997) and Rudnick et al. (1999), identify
Florida Bay and the Gulf of Mexico as significant contributors of
nutrients to the marine waters of the Keys. Additional research is
needed to identify the relative contributions of the various sources of
water quality degradation in the nearshore and offshore waters of the
Keys.

Rainfall in the Keys rapidly flushes nutrients into canals and adjacent
nearshore waters (Lapointe and Matzie, 1996). The highest levels of
dissolved inorganic nitrogen, soluble reactive phosphorus, and
chlorophyll occurred during periods of high winds, low tides, and rain.
Low tides allow rapid drainage of nutrient enriched groundwater to
adjacent nearshore waters (Kruczynski 1999; Lapointe and Matzie, 1996).

##### Stormwater

Monroe County has a mild, subtropical climate with an average
temperature of about 77 degrees Fahrenheit, and seasonal deviation of
monthly mean temperatures of only about 10 degrees Fahrenheit. Dominated
by the trade winds, the Keys receive about 65% of the average annual 38
inches of rainfall during the wet season from May to October (Monroe
County, 1997). Rainfall from this period is augmented by tropical
weather systems in various stages of development. Although the Keys do
not receive direct impact of tropical storms or hurricanes every year,
it is not unusual to have considerable rainfall and moderate winds
associated with tropical weather systems that pass some distance away.
Annual rainfall in Monroe County is the lowest in Florida (Monroe
County, 2001a). The prevailing winds are from the southeast during
spring and summer and from the northeast in fall.

The overarching stormwater concern for residents of Monroe County is the
low-lying topography combined with the threat of flooding by
hurricane-driven storm surges. As described in Section 3.2.4, the
majority of the Keys lies within the 100-year floodplain, and is
classified as an area of special flood hazard (Monroe County, 1997).
Because of the combination of the proximity to the ocean, dense
vegetation, permeable soil, and unlimited outfall capacity of the
surrounding water bodies, the citizens of Monroe County have
traditionally given little concern to stormwater runoff (Monroe County,
1997).

The Upper and Middle Keys are underlain by Key Largo Limestone, a highly
permeable remnant of prehistoric reefs. This formation is filled with
fissures and cavities that allow tidal seawater to move freely in and
out of the rock structure. Rainfall quickly permeates the rock and
combines with the seawater. In the Lower Keys, the upper stratum of
bedrock is Miami Oolite, a very porous, solution riddled, carbonate
rock. The vertical permeability of the Miami Oolite is extremely high,
but many of the solution pipes are not interconnected, leading to a much
lower horizontal permeability. This low horizontal permeability limits
the intermixing of rainfall and seawater and gives rise to the fresh
water lenses found in some of the Lower Keys (Monroe County, 1997).
Although few data exist, Monroe County has represented U.S. 1 as the
topographic divide for each island, whereby lands to the bay side of
U.S. 1 drain mainly toward Florida Bay and lands to the ocean-side of
U.S. 1 drain toward the Florida Straits (Monroe County, 2001a).

Stormwater discharge is regulated on the Federal level through the CWA
and the National Pollution Discharge Elimination System (NPDES) permit
programs. The State of Florida has designated the SFWMD to regulate
surface waters within the district that includes all of Monroe County.
Under Part IV of Chapter 373, Florida Statutes, and rule Chapter 40E-4,
and 40E-40 F.A.C., the SFWMD is responsible for permitting the
construction, alteration, maintenance and operation of most real
property improvements, which are designed to control surface waters. An
applicant for a surface water permit must show that the proposed project
would not be harmful to the water resources of the SFWMD. In addition,
the operation and maintenance of the systems cannot be inconsistent with
the overall objectives of the District or be harmful to the water
resources of the District. Additionally, the SFWMD has been delegated
stormwater quality responsibility by FDEP under Chapter 17-25 F.A.C.
Within the Keys, SFWMD requires an Environmental Resource Permit (ERP)
for the alteration of a natural drainage. Among other activities, the
ERP process regulates developments greater than 10 acres or one acre or
more of construction by requiring the implementation of BMPs (Monroe
County, 2001a). In August 2001, Monroe County released a Stormwater
Management Master Plan (SMMP), an integrated approach for addressing
stormwater management throughout the Keys that includes proposed
management alternatives (Monroe County, 2001a).

In the past, property owners and developers were responsible for
drainage projects. Dredge spoil from canal construction was used to fill
low areas and mosquito ditches were cut to drain natural wetlands. Boat
canals were treated as primary drainage facilities with building sites
draining directly into them by sheet flow, or ditches or percolation. On
several Keys, ditches along U.S. 1 have served as the primary drainage
system, transporting stormwater along the axis of the highway to the
ocean. Much of U.S. 1 lacks an organized drainage system (Monroe County,
1997).

In all, 254 structures were located as of the SMMP inventory. Of the
structures found, 167 or 66% had a water quality treatment system
(infiltration trench or detention/retention pond). Inlets were found on
110 structures, 64 systems had wells, and four systems had oil/water
separators (Monroe County, 2001a). The results of surveys conducted as
part of the SMMP found that swale treatments were the predominant form
of BMP currently in use (Monroe County, 2001a).

In the Keys, stormwater runoff from roadways, bridges, driveways and
yards, rooftops, and shopping center parking lots contribute stormwater
loading to nearshore waters. Section 3.10 describes land use in the Keys
that constitutes a major factor in the amount and quality of stormwater
runoff. Each land use has characteristic imperviousness and associated
pollutants. The largest percentage of land is vacant (34.4%), followed
by conservation (33.7%). Single-family residential land uses account for
13.7% and all other land uses represent about 5% or less of the total
(Monroe County, 2001a). Estimates of total loadings of nitrogen and
phosphorus from wastewater and stormwater from the Keys' land surface
were summarized in the Phase II Report of the WQPP (EPA, 1993a). Recent
estimates attribute about 20% of the TN load and about 45% of the TP
load to stormwater (EPA, 1993a; Kruczynski, 1999).

In July 1999, a study was conducted to identify water quality "hot
spots" that are likely stormwater induced problem areas. These
stormwater induced "hot spots" were selected from the initial list of
water quality hotspots that were identified as part of the WQPP and were
mainly attributed to wastewater contamination. The criteria for ranking
problem areas was based on flood severity, expected growth, expected
county benefit, priority, and water quality benefit (Monroe County,
2001a).

According to the SMMP, 15 problem areas have been selected for retrofit
improvements and 10 problem areas that are already permitted but need
rehabilitation were selected for rehabilitation. The implementation of
the recommendations and projects proposed in the SMMP began in fall 2001
and continue over the course of the next 4 or 5 years on rights-of-way
and county properties (Garrett, Pers. Comm., 2001). The locations of the
proposed stormwater improvement projects are shown in Figure 3-6.

**INSERT FIGURE 3-6: STORMWATER**

#### Environmental Consequences

##### Alternative 1 -- No Action Alternative

The project applicant would not receive FEMA funding to help meet
Florida Statutory Treatment Standards by the year 2010. As described in
Section 3.2.2.2.1, the installation and upgrading of WWTPs and
conversion of OWTS to clustered OWNRS are expected to lead to
incremental improvements to canal and nearshore marine waters (i.e., 92
and 86% reductions in TN and TP loadings, respectively, Appendix D).
Although treated to significantly higher BAT or AWT standards, depending
on the quantity of wastewater treated, the input of nutrients to the
shallow groundwater body would continue, but at reduced rates. In order
to quantify the extent of water quality improvements more specifically,
a comprehensive evaluation of the present water quality situation would
be required. This would include an extensive series of test wells and
monitoring throughout the Keys. In order to evaluate the timing of water
quality improvements both onshore and offshore, it would be necessary to
carry out simulation modeling of the groundwater systems and the effect
of nutrient contamination on nearshore and offshore waters.

Implementation of the No Action Alternative is expected to result in
generally positive effects on the water quality of stormwater flows.
Under the No Action Alternative, the Monroe County community, including
residents, businesses, and local government would be required to
implement wastewater management projects to meet Florida Statutory
Treatment Standards. The construction of WWTPs would replace OWTS
systems, many of which overflow during storm events leading to nutrient
pollution and fecal contamination of canals and nearshore waters. The
conversion of OWTS to clustered OWNRS under this alternative is also
expected to have a beneficial effect on the water quality of stormwater
flows.

##### Alternative 2 -- Centralized Wastewater Treatment Plant Alternative

This alternative would involve the construction or upgrade of WWTP
systems with the assistance of FEMA funding. The environmental
consequences to inland, nearshore, and offshore water are closely
related to those described under groundwater because of the
connectedness between groundwaters and canal and nearshore waters
(Sections 3.1.3 and 3.2.2).

As described in Section 3.2.2.2.1, improvements to water quality are
expected under this alternative on the order of 92 and 86% reductions in
TN and TP loadings, respectively, under the model assumptions outlined
in Appendix D. However, it is difficult to determine the exact extent of
these improvements due to a number of unknown variables. These include
the length of time it would take to flush out present levels of
nutrients and other pollutants currently found in groundwater,
variations between Keys in terms of localized hydrogeologic
characteristics, and the extent to which limestone aquifer can actually
remove phosphorus from injected effluent.

Based on the results of the studies referenced in Section 3.2.3.1.2, it
may be expected that WWTP projects in the Upper Keys would result in
greater localized improvements to canal and nearshore marine waters than
projects located in the Middle Keys because offshore and nearshore
waters in the Middle Keys receive greater quantities of nutrients from
Florida Bay waters, an additional source of nutrient inputs (Kruczynski,
1999; Szmant and Forrester, 1996).

The project applicant would be required to develop and implement a
stormwater management plan as part of its WWTP engineering and operation
designs in order to adequately accommodate stormwater flows on site.
Construction activities of the WWTP would require a NPDES permit from
the SFWMD if the facility results in ground disturbance in excess of 5
acres, as well as a general stormwater permit for the operation of the
facility, itself. The implementation of a stormwater management plan
would include specific measures such as storm inlets, swales, and/or
drain wells to control stormwater runoff and prevent effects on
stormwater quality.

The use of erosion control BMPs would be employed during construction
activities to reduce soil erosion from entering stormwater flows,
canals, and nearshore marine waters. Construction of the treatment plant
facility would require several permits from FDEP in accordance with
F.A.C. Applicable permits for the wastewater facility are referenced in
Appendix E, Applicable Permit Information.

###### Collection Options: Vacuum Pumping (Option 1) and Low-Pressure Grinder Pump Sewer System (Option 2) {#collection-options-vacuum-pumping-option-1-and-low-pressure-grinder-pump-sewer-system-option-2-1 .unnumbered}

Insofar as environmental effects on inland and nearshore water quality
are concerned, there is little basis for choice between options.
Assuming proper design and reasonable operating conditions, neither
would result in adverse impacts on stormwater flows or quality assuming
proper maintenance.

###### Disposal Option 1 -- Shallow Injection Wells {#disposal-option-1-shallow-injection-wells-2 .unnumbered}

As explained in Section 3.2.2, Groundwater, the injection of effluent
through shallow wells migrates to inland and nearshore waters rapidly.
Although the effluent would be treated to BAT standards, the effluent
would have a higher level of nutrients than ambient nearshore waters. In
order to quantify the extent of water quality improvements more
specifically, a comprehensive evaluation of the present water quality
situation would be required. This would include an extensive series of
test wells and monitoring throughout the Keys. In order to evaluate the
timing of water quality improvements both onshore and offshore, it would
be necessary to carry out simulation modeling of the groundwater systems
and the effect of nutrient contamination on nearshore and offshore
waters.

###### Disposal Option 2 -- Wastewater Reuse {#disposal-option-2-wastewater-reuse-1 .unnumbered}

Under this alternative, treated effluent would be available for
irrigation, dust control, car washes, lawns, laundry, ponds, and other
accepted uses. FDEP regulates the reuse of treated wastewater through
its Domestic Wastewater and Water Reuse Programs in accordance with
Florida State objectives in Section 373.250 and Section 403.064 Florida
Statutes of encouraging and promoting reuse. For the reuse of reclaimed
water, wastewater must be treated to secondary treatment, with basic
disinfection and pH control for non-edible agricultural and land
application. Additional levels of preapplication treatment, such as high
level disinfection, is required by FDEP as a result of: the method of
reclaimed water or effluent application/ distribution, the extent of
intended public access, the characteristics of the potential receiving
nearshore water or ground protection pursuant to reuse or effluent
disposal provisions of Chapter 62-610, F.A.C. Definitions of high level
and basic disinfection are in Section 3.6.4.2.1. These uses would not
likely adversely affect inland, nearshore or offshore waters provided
that required permitting is obtained and effluent standards are met. The
application of treated effluent for irrigation purposes, such as
maintaining lawns and landscaping, is not expected to have a significant
negative impact on marine or terrestrial resources. The relatively low
level of TP in treated effluent would be largely removed by
precipitation or adsorption on contact with limestone bedrock (Corbett
et al., 1999). TN in treated effluent would be largely taken up by
terrestrial plant biomass (e.g., lawn grasses and other landscape
plants). Although some fraction of these nutrients could be re-released
as the biomass decays, the fraction of TN returned to the system is
expected to be negligible. Further details regarding the application
method and required effluent treatment standards would be included in
the project-specific SER.

##### Alternative 3 -- On-Site Treatment Upgrades

As the shallow groundwaters of the Keys discharge nutrients to nearshore
marine waters, the environmental consequences of the alternative mirror
those described under Section 3.2.2, Groundwater. The principal
differences are that part of the TP loading to groundwater probably is
removed by **adsorption** on limestone of the aquifer (Kruczynski,
1999), and direct discharges to marine waters by outfalls and boats do
not apply to groundwater. These latter nutrient contributions as of 1996
(Ayres Associates, 1998) comprised 320 lbs/day and 84 lbs/day of TN and
36 lbs/day and 30 lbs/day of TP, respectively.

Ayres Associates (1998) concluded that AWT could be met for BOD, TSS,
and TP by OWNRS using engineered media SDI systems or by combining other
systems/processes tested in the field. They concluded further that by
using biological treatment, which incorporates
nitrification/de-nitrification and discharges to an engineered SDI
system, TN could be reduced by 85%. Thus, under the assumption that all
OWTS are replaced by suitably designed OWNRS and package plants are
upgraded to comparable limits, the TN loading to groundwater from
wastewater disposal, and hence to surface waters, could be reduced to
about 300 lbs/day, or less than the 475 lbs/day allocated to stormwater
runoff. With TP at the AWT limit of 1 mg/L, the groundwater contribution
of TP loading to nearshore marine waters would be reduced by an
estimated 86% as discussed in Appendix D.

The conversion of OWTS to clustered OWNRS systems is expected to have a
positive effect on stormwater quality. OWNRS systems would replace
cesspits and septic tanks that have been identified as significant
contributors to poor water quality in canals and nearshore waters.
Currently, most OWTS systems do not have the capability to withstand
increased storm flows and the release of untreated effluent presents a
severe canal and nearshore water quality problem. As part of the
establishment of clustered OWNRS, the project applicant would be
required to develop a stormwater management plan to ensure OWNRS
facilities adequately accommodate and protect against increased storm
flows. A NPDES permit from SFWMD may be required depending on the degree
of disturbance during construction. The SER would evaluate the quantity
of ground disturbance when site-specific construction designs are
available.

### Floodplains and Wetlands

#### Affected Environment

##### Floodplains

EO 11988, Floodplain Management, requires Federal agencies to take
action to minimize occupancy and modification of floodplains.
Furthermore, EO 11988 requires that Federal agencies proposing to site a
project in the 100-year floodplain consider alternatives to avoid
adverse effects and incompatible development in the floodplain.
According to 44 CFR Part 9, critical actions, such as developing
hazardous waste facilities, hospitals, or utility plants, must occur
outside of the 500-year floodplain. If no practicable alternatives exist
to siting a project in the floodplain, the project must be designed to
minimize potential harm to or within the floodplain. Furthermore, a
notice must be publicly circulated explaining the project and the
reasons for the project being sited in the floodplain. FEMA applies the
Eight-Step Decision-Making Process outlined in 44 CFR Part 9 to ensure
that it funds projects consistent with EO 11988. By its nature, the NEPA
compliance process involves the same basic decision-making process as
the Eight-Step Decision-Making Process. In effect, the Eight-Step
Decision-Making Process has been applied through implementing the NEPA
process. As part of the individual SERs, the Eight-Step process would be
followed.

The present floodplain maps for Monroe County were completed in December
1998. A review of the FEMA's computerized Q3 floodplain maps indicated
that almost all of Monroe County is within the 100-year flood zone
(Figure 3-7). Most of the land area in the Keys is two to three feet
above mean high tide. Maximum elevations reach 18 feet in two locations.
As a result, the Keys are extremely susceptible to storm surge flooding
(Monroe County, 1997).

Floodwater sources potentially affecting the Keys include the Florida
Straights, Florida Bay, Biscayne Bay, and the Gulf of Mexico. In
general, coastal areas that border these water bodies are subject to
storm surge flooding as a result of hurricane and tropical storm
activity. Large tidal surges combined with wave action and heavy
rainfall that accompanies these storms can result in severe flooding
(Monroe County, 1997).

In 1989, FEMA completed a detailed coastal flooding analysis of the
complete coastline of Monroe County. This study investigated the
existence and severity of flood hazards, and both floodplain maps and
flood elevations were developed. Analyses were carried out to establish
the peak elevation-frequency relations for each flooding source.
Hydraulic analyses, considering storm characteristics and the shoreline
and bathymetric characteristics of the water bodies studied, were
completed to provide estimates of the elevations of floods of the
selected recurrence intervals along all shorelines in the Keys (FEMA,
1999). Flood zone designations, which have been assigned to areas within
Monroe County, are as follows (FEMA, 1999).

**[Zone AE]{.underline}**: corresponds to the 100-year floodplain that
is determined in the Flood Insurance Study by detailed methods.
Whole-foot base flood elevations derived from the detailed hydraulic
analysis are shown at selected intervals within this zone.

**[Zone VE]{.underline}**: corresponds to the 100-year coastal
floodplain that has additional hazards associated with storm surge.
Whole-foot base flood elevations derived from the detailed hydraulic
analyses are shown at selected intervals within this zone.

**[Zone X]{.underline}**: corresponds to areas outside the 100-year
floodplain, areas of 100-year floodplain where average flood depths are
less than one foot, areas of 100-year floodplain where the contributing
drainage area is less than one square mile, and areas protected from the
100-year flood by levees. No base flood elevations of depths are shown
within this zone.

Flood elevations for the coastal storm having a recurrence interval of
100 years (Zone AE) range from 7 feet to 12 feet National Geodetic
Vertical Datum (NGVD). Below this elevation, the 100-year storm event
would flood most areas (Monroe County, 1997).

INSERT FIGURE 3-7: FLOODPLAIN

Only a few Keys have land that lies above the 100-year flood elevation
(within Zone X). This includes land along US Hwy 1 on Key Largo,
Plantation Key, Windley Key, and Upper Matecumbe Key, comprised of a
strip encompassing the highway right-of-way and adjacent lands about
1,000 feet in width. The only exception is on Key Largo from the Card
Sound turnoff south to Florida 107, where the area outside of the
floodplain narrows to include only the US Hwy 1 right-of-way. Other
areas in the Keys outside of the 100-year floodplain include the sites
of the US Hwy 1 bridge abutments on Big Pine Key at Spanish Harbor
Channel and North Pine Channel (Monroe County, 1997).

##### Wetlands

The term "wetland," refers to areas that are inundated or saturated by
surface or groundwater at a frequency and duration within 18 inches of
the surface, sufficient to support, and that under normal circumstances
do support, a prevalence of vegetation typically adapted for life in
saturated soil conditions. Wetlands generally include swamps, marshes,
bogs, lakes, rivers, streams (including intermittent streams), mudflats,
sloughs, and similar areas.

Under EO 11990 (Protection of Wetlands), Federal agencies are required
to minimize the destruction, loss, or degradation of wetlands and
preserve and enhance their natural and beneficial values. If a Federal
action has the potential to impact jurisdictional waters of the United
States as defined by Section 404 of the CWA, the USACE would be
contacted for appropriate permitting requirements. Section 404 of the
CWA authorizes the USACE to issue permits, after notice and opportunity
for public hearing, for the discharge of dredged or fill material into
U.S. waters at specified disposal sites. FEMA applies the Eight-Step
Decision-Making Process, required by 44 CFR Part 9, to meet the
requirements of EO 11990. A step-by-step analysis of the Eight-Step
Decision-Making Process as applied to the specific projects would be
documented in the SER.

Most wetlands in the project area are coastal tidal wetlands, consisting
of mangrove swamps, salt marshes, and salt pans. Marine seagrass meadows
may also fall under the wetlands definition. Descriptions of wetlands
communities, if applicable, would be included in the SER once specific
sites are selected. In many cases, Keys wetlands are unusual in that
they may develop directly on the limestone bedrock with very little soil
and thus little evidence of characteristic wetland soils. Freshwater
wetlands are very rare in the project area due to the low elevations,
shallow soils, and limited freshwater availability. Their occurrence is
largely limited to areas where rainfall may accumulate in depressions,
forming shallow rockland lakes and wet prairie wetlands.

#### Environmental Consequences

##### Alternative 1 -- No Action Alternative

Monroe County wastewater system owners/operators would likely undertake
a number of WWTP and clustered OWNRS projects to meet Florida Statutory
Treatment Standards by 2010. Given the fact that most of the Keys lie
within the regulated 100-year floodplain, siting of individual projects
outside of the floodplain would be difficult. While floodplain locations
should be selected as project sites only if no reasonable alternative
exists, it is expected that most selected sites would affect floodplains
either partially or wholly given the predominance of floodplain
designated areas in the Keys. Monroe County Ordinance Sections 9.5-315,
9.5-316, and 9.5-317 specify that public facilities such as water and
gas main, electric, telephone and sewer lines, and streets and bridges
be protected from high flood hazards. For non-residential structures,
instead of elevating the structure to the base flood elevation (BFE),
the structure may be designed such that structure below the BFE is
watertight, with walls substantially impermeable to the passage of water
and with structural components having the capability of resisting
hydrostatic and hydrodynamic loads and effects of buoyancy.

In accordance with 44 CFR 60.3 (e) (4), building structures in a VE Zone
floodplain must be floodproofed or elevated with solid walls to prevent
operational failure and structure damage during storms and flooding.
Fill is not feasible for structural support for buildings within a VE
Zone because of the severe erosion potential of such locations. Limited
fill is allowed for landscaping, local drainage needs, and to smooth out
a site for an unreinforced concrete pad. The stringent design standards
for facilities located in the VE Zone would make the selection of these
sites for wastewater facilities either infeasible from an engineering
standpoint or cost prohibitive.

Impacts to wetlands and other jurisdictional waters of the United States
regulated by USACE under the CWA have the potential to be negatively
impacted by the No Action Alternative. Depending on the extent of
wetland impacts from construction activities, a local, State, and/or
USACE permit may be required. USACE's policy requires wetland effects be
avoided or minimized before any permits are issued. The FDEP also
regulates activities within wetlands through the ERP process (Chapters
62-341, 343, and 330, F.A.C.). The State permit process includes other
stormwater systems and related activities that may affect wetlands or
surface waters. The Monroe County Land Development regulations require
County review of wetlands as potential habitat areas. The net effect of
the various wetland permit requirements is to avoid or minimize adverse
impacts.

##### Alternative 2 -- Centralized Wastewater Treatment Plant Alternative

As with the No Action Alternative, it is expected that most selected
sites would affect floodplains given the predominance of floodplain
designated areas in the Keys. If structures associated with the
wastewater treatment alternatives (e.g., WWTPs, pump stations, etc.) are
constructed in the floodplain, they must be floodproofed or elevated
with fill or solid walls to prevent operational failure and structure
damage during storms and flooding. Standards and regulations pertaining
to construction in the floodplain in Monroe County are promulgated in
amendments to Monroe County Ordinance. These amendments specify design
features required for structures proposed in the floodplain and vary
depending on the level of flood hazard. As specified in 44 CFR 9,
structures must be elevated such that the lowest floor of the structures
is at or above the level of the base flood. For non-residential
structures, instead of elevating to BFE, the structure may be designed
such that structure below the BFE is water tight, with walls
substantially impermeable to the passage of water and with structural
components having the capability of resisting hydrostatic and
hydrodynamic loads and effects of buoyancy.

Additionally, there is a public concern that the proposed WWTP would
lead to further development of the floodplain within the project area by
introducing key infrastructure, which is often linked to additional
development. However, development within the Keys is not controlled by
addition of key infrastructure, but instead by Monroe County's ROGO
permit allocation system as described in Section 3.10. The construction
of new wastewater treatment infrastructure in the Keys is essential to
effectively treat existing wastewater flows, and is not proposed as a
way to introduce or support increased development. Therefore, if growth
and development in the floodplain occurs following implementation of
this alternative, it is a function of established county planning and is
not directly related to proposed projects for wastewater management
improvements. Given the above points, an evaluation of secondary effects
on floodplains with regard to the potential for increased development
under the alternatives was not conducted.

While adverse effects are expected to be minimal, this alternative has
the potential to affect wetlands. Effects would be evaluated within the
site-specific SERs. Much as described in Section 3.2.4.2.1, depending on
the extent of wetland impacts from construction activities, a local,
State, or USACE permit may be required. USACE maintains a policy that
wetland impacts should be avoided or minimized before any permits are
issued. The FDEP also regulates activities within wetlands through the
ERP process (Chapters 62-341, 343, and 330, F.A.C.). The State permit
process includes other stormwater systems and related activities that
may affect wetlands or surface waters. The Monroe County Land
Development regulations require County review of wetlands as potential
habitat areas. Moreover, should a wetland be affected under this
alternative, the previously described Eight-Step-Decision-Making Process
would be triggered. The net effect of the various wetland permit and
Executive Order requirements is to avoid or minimize adverse impacts.

###### [Collection Option 1 -- Vacuum Pumping]{.underline} {#collection-option-1-vacuum-pumping-1 .unnumbered}

Aside from the construction activities described above in Section
3.2.4.2.2, the selection of the vacuum pumping collection option is not
expected to result in any major effects on wetlands and floodplains.

###### [Collection Option 2 -- Low-Pressure Grinder Pump Sewer System]{.underline} {#collection-option-2-low-pressure-grinder-pump-sewer-system-1 .unnumbered}

Aside from the construction activities described above in Section
3.2.4.2.2, the selection of the low-pressure grinder pump sewer system
is not expected to result in any specific effects on wetlands and
floodplains.

###### [Disposal Option 1 -- Shallow Injection Wells]{.underline} {#disposal-option-1-shallow-injection-wells-3 .unnumbered}

Siting of wastewater injection wells may affect jurisdictional wetlands
if the project activities would result in the fill or alteration of
wetlands. Project-specific effects on wetlands and floodplains would be
considered in the SER for the individual project.

###### [Disposal Option 2 -- Wastewater Reuse]{.underline} {#disposal-option-2-wastewater-reuse-2 .unnumbered}

Selection of wastewater reuse as a disposal option is not expected to
result in the fill or modification of wetland areas or floodplains.

##### Alternative 3 -- On-Site Treatment Upgrades

The conversion of OWTS to clustered OWNRS may require the importation,
movement, and/or excavation of a limited amount fill used in grading
activities. Effects on floodplains are similar to those described under
the Section 3.2.4.2.2, Centralized Wastewater Treatment Plant
Alternative. Effects on wetland areas as a result of this alternative
would be evaluated in the site- and project-specific SER.

## Biological Resources

Natural vegetation and habitat in the Keys includes six major
terrestrial communities (pine rocklands, tropical hardwood hammocks,
mangroves, salt marsh, freshwater systems and dunes/coastal ridges) and
four major marine communities (seagrasses, coral reefs, hardbottom and
sandy bottom). It is important to note that much of the land area in the
Keys has been significantly altered (fragmented) by human activities,
including clearing for residential and commercial uses. Natural
vegetation in these areas has largely been replaced by planted
ornamental species and weedy and exotic species. Brazilian pepper
(*Schinus terebinthifolius*) and Australian pine (*Casuarina
equisetifolia*) are two of the more ubiquitous exotic nuisance species
that tend to invade disturbed upland and wetland habitats. Terrestrial
and aquatic environments are discussed separately in the following two
sections.

### Affected Environment

#### Terrestrial Environment

##### Pine Rocklands and Tropical Hardwood Hammocks

The terrestrial habitats in the Keys are underlain by a limestone
substrate, with varying amounts of overlying sand or organic matter.
Throughout most of the Keys, the limestone is a fairly hard coral reef
limestone, but in the Key West and Sugarloaf Key area of the Lower Keys,
the substrate is a friable oolitic precipitate limerock. The relative
abundance of pine rockland and tropical hardwood hammocks on these
substrates is largely a function of elevation and a lack of natural fire
occurrence.

Pine rocklands are limited in the Upper Keys, but abundant in the Lower
Keys, with somewhat extensive pinelands occurring on Big Pine, Little
Pine, No Name, Cudjoe, and Sugarloaf Keys. Pine rocklands are upland
forest communities with an open canopy dominated by the native Florida
slash pine (*Pinus elliottii* var. *densa*). Keys pine rocklands are
fire-adapted and dependent on periodic fires for their long-term
persistence. Surrounded by wet prairie habitats and/or mangroves,
pinelands typically occur on locally elevated areas of bedrock, which
may flood seasonally or during extreme storm events. Xeric conditions in
this habitat are partly caused by locally low rainfall and the exposed
rock ground cover. Vegetation is dominated by canopy of Florida slash
pine. The extent of subcanopy development in a pineland is dependent
upon the frequency of surface fires. Pine rocklands with a
well-developed subcanopy typically include species such as saw palmetto
(*Serenoa repens*), strongbark (*Bourreria cassinifolia)*, locust berry
(*Byrsonima lucida*), silver thatch palm (*Coccothrinax argentata*),
pineland croton (*Croton linearis*), rough velvetseed (*Guettarda
scabra*), wild sage (*Lantana involucrata*), and long-stalked stopper
(*Psidium longipes*). Shrub vegetation includes caesalpinia
(*Caesalpinia pauciflora)*, dune lily-thorn (*Catesbaea parviflora)*,
pisonia (*Pisonia rotundata*), and pride-of-Big-Pine (*Strumpfia
maritima)* (Snyder et al., 1990).

Tropical hardwood hammocks occur on slightly higher elevations not
exposed to saltwater flooding and have a better-developed soil layer of
largely organic matter. Along with pinelands, tropical hardwood hammocks
represent the climax upland community type in the Keys and are second in
terms of biodiversity (Ross et al., 1992). Tropical hardwood hammocks in
the Keys are closed, broad-leaved forests that occupy elevated,
well-drained, and relatively fire-free areas. Tropical hardwood hammocks
are comprised of more than 150 species of tropical trees and shrubs
(Snyder et al., 1990). Common dominant species throughout the Keys
include gumbo limbo (*Bursera simaruba*), pigeon plum (*Coccoloba
diversifolia*), and white stopper (*Eugenia axillaris*). Other species
have a more regional occurrence, such as mahogany (*Sweitenia mahagoni*)
and mastic (*Sideroxylon foetidissimum*), which are not present in the
Lower Keys and wild tamarind (*Lysilomalatisiliquum*) (which is much
less common in the Lower Keys). Other canopy species may include Jamaica
dogwood (*Piscidia piscipula*), live oak (*Quercus virginiana*), cabbage
palm (*Sabal palmetto*), willow bustic (*Bumelia salcifolia*), and
strangler fig (*Ficus aurea*). Common understory species are inkwood
(*Exothea paniculata*), white stopper, poisonwood (*Metopium
toxiferum*), marlberry *(Ardisia escallonioides*), lancewood (*Nectandra
coriacea*), satinleaf (*Chrysophyllum oliviforme*), Spanish stopper
(*Eugenia foetida*), torchwood (*Amyris elemifera*), cinnamon-bark
(*Canella winterana*), strongbark (*Bourreria ovata*), soapberry
(*Sapindus saponaria*), myrsine (*Myrsine floridana*), wild coffee
(*Psychotria nervosa*), and black ironwood (*Krugiodendron ferreum*).
Undisturbed hammocks generally have a very sparse herbaceous cover,
usually including panic grass (*Panicum dichotomum*), woods grass
(*Oplisnenus stetarius*), and blue paspalum (*Paspalum caespitosum*),
Boston fern (*Nephrolepsis exaltata*), sword, and several orchids such
as wild coco *(Eulophia alta*) and ladies tresses (*Spiranthes* spp.)
(USFWS, 1999; Meyers and Ewel, 1990).

##### Mangrove Forests and Salt Marshes

Mangrove forests and salt marshes form an important transition between
the upland and marine systems. These communities are an important buffer
zone, filtering nutrients, solids, and pollutants from stormwater
runoff, stabilizing sediments, protecting the shoreline from erosion,
and providing food, nesting and nursery areas for many fish and wildlife
species.

Throughout the Keys, mangrove forests form the predominant coastal
vegetation community. Mangroves are found along the edges of shorelines,
bays and lagoons and on over wash areas throughout the Keys. In 1974,
the Coastal Coordinating Council estimated that there were 94,810
hectares (ha) of mangrove forests in Monroe County. Due to more
stringent dredge and fill laws enacted between 1975 and 1989, it is
unlikely that this number has changed significantly.

Mangrove communities consist of facultative halophytes, tolerant of
anaerobic saline soils and periodic tidal flooding. Red mangrove
(*Rhizophora mangle*), black mangrove (*Avicennia germinans),* and white
mangrove (*Laguncularia racemosa*) are the dominant species in mangrove
forests in the Keys. Mangrove forests in the Keys are generally of the
"fringing forest" or "basin forest" types (Lugo and Snedaker, 1974). The
fringing forests comprise fairly narrow bands along the shorelines,
while basin forests occur in wider depression areas with less tidal flow
and flushing. Red mangroves occur in the middle and lower intertidal
zone and upper subtidal zone. Black mangroves dominate the upper
intertidal zone and generally occur in a zone between red and white
mangroves. White mangroves occur on the landward edge of mangrove
forests, throughout the intertidal and in the upper portions of the
forests. Ground cover within a mangrove forest consists of leaf litter
and decomposing forest debris. Buttonbush (*Conocarpus erectus*) and
blolly (*Guapira discolor*) may occur in the transition zone from
mangrove forest to upland communities. Mangroves typically create a
system with peaty soils with a low pH. The community's biological
productivity usually depends on external sources of carbon and
nutrients, such as run off from terrestrial sources, tidal input, and
bird droppings. Nitrogen fixation does occur, so that productivity is
usually limited by other nutrients. Carbon export to marine systems is a
major function of the mangrove community.

Mangrove ecosystems are important habitat for at least 1,300 species of
animals including 628 species of mammals, birds, reptiles, fish, and
amphibians as they provide areas for breeding, nesting, foraging, and
shelter. Many of the larger motile species are not restricted to
mangroves, but are seasonal or opportunistic visitors. However, most
invertebrate and some resident vertebrate species are totally dependent
upon mangroves to survive and complete important life cycle functions
(Tomlinson, 1986). Fish and marine invertebrates are frequent visitors
to mangrove communities, as are birds and mammals from nearby
terrestrial systems (USFWS, 1999).

Salt marshes are not well developed in most of the Keys. These usually
consist of largely monospecific (single species) stands of black
needlerush (*Juncus roemerianus*) and salt marsh cordgrass (*Spartina
alterniflora*). Other common species in the Keys include marsh elder
(*Iva frutescens*), saltbush (*Baccharis halimifolia*), seaside
goldenrod (*Solidago sempervirens*), salt grass (*Distichlis spicata*),
sea purslane (*Sesuvium portulacastrum*), and mangroves. Sand or
limerock areas at the upper end of the tidal range may have sea ox-eye
(*Borrichia arborescens*), saltwort (*Batis maritima*), seablite
(*Suaeda linearis*), and sea lavender (*Limonium carolinianum*).

##### Freshwater Systems

Although freshwater wetlands are widespread in southern Florida, less
than 300 acres of freshwater marshes and 600 acres of forested
freshwater wetlands remained in the Keys in 1991 (McNeese, 1998; Folk et
al., 1991). Freshwater wetlands are restricted to areas landward of the
seasonal high tide level and are primarily restricted to portions of the
Lower Keys underlain by freshwater lenses (McNeese, 1998). Freshwater
marshes in the Keys are typically isolated, seasonally flooded
depressions dominated by sawgrass (*Cladium jamaicense*). Forested
freshwater systems are generally pine forests with a sawgrass understory
(McNeese, 1998). Freshwater wetlands and surface waters represent the
only dry season source of freshwater for wildlife (McNeese, 1998).
Freshwater systems also play an important role in attenuating nutrients
and other contaminants in surface water runoff. The absence of fire from
freshwater wetlands promotes the growth of woody exotic vegetation,
including Brazilian pepper (*Schinus terebinthifolius*) and Australian
pine (*Casuarina equisetifolia*) (Kushlan, 1990). Dominant species
typically occurring within the Keys freshwater systems include
buttonwood, sawgrass, fringe-rushes (*Fimbristylis* spp.), cattail
(*Typha latifolia*), leatherfern (*Acrostichum danaeifolium*), and flat
sedges (*Cyperus* spp.).

##### Dunes and Coastal Ridges

Dune systems form along sandy beaches where wind- and wave-borne sand is
trapped and accumulated by extremely salt-tolerant low-lying beach
vegetation. These growing sand piles are further colonized by plant
species tolerant of salt spray, desiccating environments, shifting sands
and high substrate temperatures (USDA, 1984); in the Keys, these
"foredune" species include sea oats (*Uniola paniculata*), railroad vine
(*Ipomoea pescaprae*) and beach bean (*Canavalia maritima*; (USDA, 1984;
Johnson and Barbour, 1990). Over time, the area landward of the foredune
can support woody vegetation, including seagrape (*Coccoloba uvifera*)
and bay cedar (*Suriana maritima*). Dune assemblages provide beach
stabilization and help protect landward areas from wave action during
storms. In the Keys, the persistence of dunes and coastal ridges is
limited primarily by natural patterns of sand movement associated with
wind and waves, construction of coastal structures, and human and
vehicular traffic.

#### Aquatic Environment

##### Seagrass Beds and Sand Flats

Seagrass communities are the most abundant marine bottom community in
the Keys, particularly in Florida Bay and the Gulf of Mexico (FMRI,
2000). Distribution of seagrass communities is influenced by the
interaction of factors such as water quality, water depth, sediment
depth, and current velocity (FMRI, 2000).

In the Keys, seagrass communities are dominated by turtle-grass
(*Thalassia testudinum*) and manatee-grass (*Syringodium filiforme*),
with shoal-grass (*Halodule wrightii*) becoming dominant in more
eutrophic areas (Fonseca et al., 1998). These three species account for
more than 95% of the total plant biomass in the FKNMS. Paddle-grass
(*Halophila decipiens*) and star-grass (*Halophila englemannii*),
although minor, are also widely distributed (FMRI, 2000). Also found
scattered in the seagrass meadow areas throughout the Keys are benthic
and epiphytic algae such as *Halimeda* spp., *Penicillus* spp.,
*Rhipocephalus* spp. *Caulerpa* spp., and *Udotea* spp. These algae may
increase organic matter production, and decay of their calcareous
skeletons adds to the cycling of calcium and carbon in the shallow
ecosystem.

Seagrasses in the Keys generally occur at water depths ranging from
intertidal to about 10 meters, with about 90% of all seagrass beds occur
between depths of 3 to 6 feet (Kurz et al., 1999). *Thalassia* and
*Syringodium* typically occur in the middle of the seagrass depth range,
while *Syringodium* and *Halodule* can occur to depths of more than 20
feet (Williams, 1988).

Seagrass beds dominate the benthic habitat in the Upper Keys and are
most predominant in Hawk Channel and Card Sound (FMRI, 2000). Sparser in
the Middle Keys, seagrass beds are found shoreward of the reef tract on
the Atlantic side and are extensive north of Marathon and Duck Key
(FMRI, 2000). In the Lower Keys, seagrass abundance is variable with
dense beds of *Thalassia* growing mostly in the Lakes Passage area on
the Gulf side (FMRI, 2000).

Seagrass communities are among the most productive habitats of the
nearshore environment (Livingston, 1990) and they provide critical
nursery habitat and food for many fish and invertebrates. Seagrass beds
also help trap suspended sediments and prevent the loss of accumulated
sediment to wave and current action (Fonseca et al., 1998). Seagrass
meadows also support endangered species such as the green sea turtle
(*Chelonia mydas*) and West Indian manatee (*Trichechus manatus*).

##### Coral Reefs

EO 13089 (Coral Reef Protection) directs Federal agencies whose actions
affect U.S. coral reef ecosystems and provides for the implementation of
measures to reduce impacts from pollution, sedimentation, and fishing.

The Florida Coral Reef Tract represents the most extensive nearshore
coral reefs of continental North America, and the reef is still actively
building only in the Keys. The Florida Reef Tract extends from south of
Miami to the Dry Tortugas (about 230 miles) on the Atlantic side of the
Keys and does not occur on the West Florida shelf (FMRI, 1998; DeFreese,
1991). The largest reefs are east of large unbroken or tightly clustered
islands such as Key Largo and the Lower Keys complex, where the islands
act as barriers to the transport of silts and other materials from
Florida Bay.

In the Florida Keys Reef Tract, there are two main categories of reefs:
patch reefs and platform margin (bank) reefs. Patch reefs, which often
are in shallower waters closer to shore, generally consist of small- to
medium-sized clusters of corals surrounded by areas of barren sand or
seagrasses. Platform margin (bank) reefs are those that form a more or
less continuous structure parallel to the coastline. There are five
classifications of platform margin reefs:

-   Shallow spur and groove, which are well developed, actively
    accreting, platform margin reefs found on the fore reef of the reef
    tract.

-   Drowned spur and groove, which are older platform margin reefs that
    are not actively growing and are often buried in sand that has
    migrated.

-   Remnant -- low profile reefs lack the distinctive spur and groove
    characteristics. The vertical relief of these reefs varies from 1.5
    to 6.5 feet.

-   Back reef, which is the landward section of the spur and grove type
    platform margin reefs. This is typically a rubble zone, colonized by
    heartier corals.

-   Reef rubble areas, where unstable pieces of the reef fractured from
    wave action exist in these areas with little or no visible
    colonization.

In the Upper Keys, the reef tract is located about 6 miles offshore,
forming an almost continuous community that parallels the Keys from
Carysfort Reef at the north end to Crocker Reef at the south (FMRI,
2000). This area has a large abundance of patch reefs and well-developed
bank reefs. The Middle Keys, which are smaller and separated by numerous
wide channels connecting with Florida Bay, have limited reef
development, largely due to a lack of protection from the variations in
temperature, salinity and clarity of water coming from the Gulf of
Mexico and Florida Bay (FMRI, 2000). In the Lower Keys, the reef tract
extends from Looe Key Reef to Cosgrove Shoal, south of the Marquesas
(FMRI, 1998).

Biodiversity of visible organisms is much higher on nearshore reefs than
on sandy bottom. Epifaunal organisms flourish on the stationary foothold
provided by the rock and are virtually absent in areas where shifting
sands preclude settlement. Algae also flourish on this reef substrate.
At the bottom of the food chain, algae provide a primary food source for
a variety of organisms including invertebrates, fishes, and the
federally listed green sea turtle. Fish are also more abundant on
nearshore reefs. About 192 species are known to inhabit the nearshore
reefs of South Florida (Lindeman, 1997).

Relatively abundant food fish species occur on nearshore and midshelf
reefs. These include the sheepshead *(Archosargus probatocephalus),* the
porkfish *(Anisotremus virginicu*s), black margate *(Anisotremus
surinamensi*s), mutton snapper *(Lutjanus anali*s), gray snapper
*(Lutjanus* analis), black sea bass *(Centropristis striat*a), flounder
*(Paralichthys dentatu*s), and gray triggerfish *(Balistes capriscu*s).
Juveniles of commercial importance include the gag grouper
*(Mycteroperca microlepi*s), red grouper *(Epinephelus mori*o), and
black grouper *(Mycteroperca bonac*i). Another abundant predator on the
reefs is the sport and food fish, the common snook. Many other species
are collected for aquariums. These include angelfish (*Pomacanthidae*),
butterflyfish (*Chaetodontidae*), wrasses (*Labridae*), damselfish
(*Pomacentridae*), and doctorfish (*Acanthuridae*). The smaller tropical
fish are important ecologically as prey for grouper, snook, and other
piscivores (fish eaters). Other important prey would include the silver
porgy *(Diplodus argenteu*s) and at least two species of mojarra
*(Eucimostomus* sp.).

Recent assessments of the conditions of the Florida Reef Tract have
indicated accelerating degradation. Bleaching, sedimentation, salinity,
light availability, heavy rainfall, drought, temperature (winter cold
fronts), algal overgrowth, and pollution from point and nonpoint sources
contribute to the declining health of reefs (Dustan, 1999; Jaap, 1984).

##### Hardbottom

Low-relief hard-bottom communities are characterized by their proximity
to shore, shallow depth (\<3 m), and visual dominance of octocorals
(Chiappone and Sullivan, 1994). These communities occur within 1.25
miles of shore on either side of the Keys at depths of about 3 to 16
feet (Chiappone and Sullivan, 1996). Hard-bottom communities in the Keys
and adjacent Florida Bay exhibit extreme variability in terms of
community size, dominant species, and community structure response to
environmental parameters (Jaap, 1984). These communities provide refuge
for juvenile stages of species of interest for fisheries (e.g.,
*Panilirus argus*), may serve as preliminary indicators of
eutrophication, and affect the nearshore-to-offshore recruitment of
invertebrate and fish larvae (Chiappone and Sullivan, 1994).

##### Sandy Bottom

Bare bottom communities, over either calcareous muds or calcareous sand,
are devoid of macrophytes, specifically algae and seagrasses. The
typical flora of these areas includes calcareous algae, such as
*Udotea*, *Halimeda*, and *Penicillus.* The fauna is sparse, typically
dominated by sponges and small corals (Chiappone, 1996).

### Environmental Consequences

#### Alternative 1 -- No Action Alternative

Improved wastewater management activities would be implemented to meet
the new Florida Statutory Treatment Standards. However, without FEMA
funding, the rate at which wastewater treatment improvements are made
would be slower than under Alternatives 2 and 3, while project
applicants identify additional financing options. Adverse effects on
nearshore marine environments, such as coral reefs, would continue as a
result of inadequate septic tanks and cesspools/cesspits potentially
releasing high levels of nutrients into shallow groundwater.

Once funding is identified and necessary permits obtained, construction
would begin. Construction of new facilities or additions to existing
facilities could result in vegetation or habitat loss of about 1 to 5
acres for each facility depending on specific site design. Since most
facilities are expected to be located near highly developed areas, many
potential sites may be degraded and have reduced habitat value. If no
other suitable sites are available, some loss to high quality habitat
areas could result from construction. The potential for effects to high
quality upland habitat (e.g., tropical hardwood hammocks) is higher for
the Upper Keys project area.

Beneficial effects on nearshore marine habitats including seagrass
meadows and coral reefs would likely occur due to the reduction of TSS,
nutrients, and pathogens released to the nearshore waters by runoff and
seepage in the surficial aquifer from cesspools, septic tanks, and small
package treatment systems that would be replaced by the WWTPs. Corals
typically thrive in an oligotrophic (nutrient-poor) environment with the
assistance of specialized symbiotic algae (i.e., zooxanthellae); these
algae derive their nutrients from the waste products of their coral
hosts and, as such, are not typically limited by the availability of
free nutrients from the water column (Hallock et al., 1993). Nutrients
released into the marine water column by existing treatment systems may
negatively impact marine communities in several ways. First, these
nutrients may contribute to the rapid growth of phytoplankton, resulting
in algal "blooms" that reduce water clarity, decrease light penetration,
and decrease seagrass and coral growth. Second, nutrients tend to favor
the growth of non-symbiotic mat-forming macroalgae, which strip
nutrients from the water column, enabling them to grow quickly and
colonize hardbottom areas that could otherwise support slower-growing
stony corals (Dustan, 1999). These non-symbiotic macroalgae can
out-compete and shade corals, causing bleaching and eventual death.

Other benefits of decreased TSS and nutrient release may include
increased growth of seagrasses due to increased light penetration. Algal
blooms may also become less frequent, pervasive and damaging as a result
of reduced TP and TN concentrations.

While nutrients (particularly TP) from existing cesspits and septic
tanks could theoretically contribute to the growth and productivity of
mangroves (Snedacker and Lugo, 1973), no documentation or other evidence
suggests that mangrove communities in the Keys are nutrient limited
(Odum and McIvor, 1990). Therefore, a reduction in nutrients caused by
wastewater management upgrades is not likely to negatively impact
mangroves.

It should be noted that the beneficial impacts of improved water quality
to marine resources would be most prevalent in nearshore waters because
much of the nutrients released into nearshore waters are taken up by
marine flora (Hallock et al., 1993).

Concerns have been raised about the possible environmental effects of
using liquid chlorine to disinfect wastewater. Since chlorine is toxic
to aquatic life at low concentrations, wastewater in Florida that is
released directly into surface water is dechlorinated (Klineman, Pers.
Comm., 2002). Dechlorination, however, is not required for all
discharges. It increases chlorination costs by 30 to 50% and the
long-term effects of dechlorinated compounds on the environment are
unknown (EPA, 1999). In addition, chlorine is so reactive that it is not
likely to move through the ground and enter groundwater or to be stored
by plants and animals (EPA, 1994c).

The Monroe County Land Development Regulations have provisions to reduce
the environmental impacts of development by encouraging design of a
development on a parcel of land to incorporate clustering of the
development away from the natural areas on the parcel that are the most
susceptible to harmful development impacts (Monroe County Code (M.C.C.)
Sec. 9.5-345). The regulations also require the preparation of a habitat
analysis, and replacement or transplantation of certain native plant
species, including tropical hammock vegetation and plant species used by
wildlife (M.C.C. Sec. 9.5-335). Compliance with M.C.C. would minimize
adverse effects to regulated plant communities.

#### Alternative 2 -- Centralized Wastewater Treatment Plant Alternative

Effects on and mitigation requirements for biological resources under
Alternative 2 would be similar to those described under the No Action
Alternative, Section 3.3.2.1. It is expected that beneficial impacts
would occur more quickly under Alternative 2 because FEMA funding would
be applied to the projects. Furthermore, beneficial effects to coral
reef communities, as described above, would be consistent with the
intent EO 13089, Coral Reef Protection.

##### [Collection Option 1 -- Vacuum Pumping and Collection Option 2 -- Low-Pressure Grinder Pump System]{.underline} {#collection-option-1-vacuum-pumping-and-collection-option-2-low-pressure-grinder-pump-system .unnumbered}

This system requires the placement of several vacuum stations. Depending
on location, construction of these buildings has the potential to result
in some vegetation and habitat loss. Siting vacuum-pumping stations in
developed, previously disturbed areas would minimize effects on
biological resources. Sewer lines would be placed in existing utility
rights-of-way and are not expected to adversely impact existing natural
resources. Site-specific impacts would be further considered in the
project-specific SER level.

##### [Disposal Option 1 -- Shallow Injection Wells]{.underline} {#disposal-option-1-shallow-injection-wells-4 .unnumbered}

The effects on the biological environment of siting wastewater injection
wells would be evaluated in the project-specific SER. The use of shallow
injection wells for treated wastewater disposal is expected to result in
improvement to water quality in areas that were previously serviced by
cesspools and septic tanks on the order of 92 and 86% reductions in TN
and TP loadings to nearshore marine waters (Appendix D). Although
treated to Florida Statutory Treatment Standards, effluent would have a
higher level of nutrients than ambient concentrations. There is little
available research that specifically assesses the impact of effluent
treated to BAT and AWT standards on biological resources in the Keys. As
discussed in Section 3.3.2.1, in general, while mangrove swamps could
benefit slightly from increases in TP, coral reefs prefer oligotrophic
environments with clear waters and low turbidity and therefore would be
adversely affected by increased nutrient levels. The major impetus for
improving wastewater management in the Keys and installing WWTPs such as
those proposed under this alternative is to improve the ecological
health by reducing the pollutant load. Implementation of the WWTP that
meets Florida Statutory Treatment Standards would reduce nutrient
loading and result in a corresponding improvement to ecological health.

##### [Disposal Option 2 -- Wastewater Reuse]{.underline} {#disposal-option-2-wastewater-reuse-3 .unnumbered}

Treated wastewater would be available for application for irrigation,
car washes, fountains, and other practical uses. Although treated to
Florida Statutory Treatment Standards, recycled effluent would have
higher level of nutrients than potable, freshwater that might otherwise
be used. Generally, the effect on biological resources of wastewater
reuse would be minimal for closed systems such as public fountains and
car washes. The application of treated effluent for irrigation purposes,
such as maintaining lawns and landscaping, is not expected to have a
significant negative impact on marine or terrestrial resources. The
relatively low level of TP in treated effluent would be largely removed
by precipitation or adsorption on contact with limestone bedrock
(Corbett et al., 1999). TN in treated effluent would be largely taken up
by terrestrial plant biomass (e.g., lawn grasses and other landscape
plants). Although some fraction of these nutrients could be re-released
as the biomass decays, the fraction of TN returned to the system is
expected to be negligible.

#### Alternative 3 -- On-Site Treatment Upgrades

Effects and mitigation requirements to biological resources under
Alternative 3 would be similar to those described under the No Action
Alternative, Section 3.3.2.1. Beneficial effects are expected to occur
more quickly under Alternative 3 because FEMA funding would expedite
project implementation. Furthermore, beneficial effects to coral reef
communities, as described above, would be consistent with the intent EO
13089 (Coral Reef Protection). Upgrading OWTS to clustered OWNRS would
result in positive effects on water quality by greatly reducing the
nutrient loading thereby lowering the potential for eutrophication,
algal blooms and decreases in bio-available oxygen levels. Most upgrades
to OWTS would be expected to occur in existing developed areas, such as
residential areas, and business districts. As such, the effects on
biological resources of siting clustered OWNRS are expected to be
minimal. In order to assess the impact, site-specific SERs would
evaluate impacts of the installation of clustered OWNRS on the immediate
biological environment.

### Special Status Species

#### Affected Environment

The Endangered Species Act (ESA) of 1973 requires Federal agencies to
consider impacts of their actions on threatened and endangered species
of fish, wildlife, and plants, and their habitats, and take steps to
conserve and protect these species. National Marine Fisheries Service
(NMFS) holds the responsibility for listing most marine species, and the
USFWS administers the listing of all other plants and animals.

In addition to the requirements of ESA, Federal agencies must also
comply with the 1996 amendments to the Magnuson-Stevens Fishery
Conservation and Management Act (MSA) (16 U.S.C. 1801 et seq.) that
requires the identification of Essential Fish Habitat (EFH) for
federally managed fishery species and the implementation of measures to
conserve and enhance this habitat. In the Keys, federally regulated
fisheries are managed through the Gulf of Mexico (GMFMC) and South
Atlantic (SAFMC) Fishery Management Councils. A compiled list of the
fishery species under GMFMC and SAFMC management are attached as
Appendix F. Essential fish habitat means those waters and substrate
necessary to fish for spawning, breeding, feeding, or growth to maturity
(Magnuson-Stevens Act, 16 U.S.C. 1801 et seq.). The MSA requires Federal
agencies to consult with NMFS on activities that may adversely affect
EFH. There are many situations where designated EFH overlaps with the
habitat (including critical habitat) of species listed as threatened or
endangered under ESA. As described in guidance for integrating MSA and
ESA published by NMFS, EFH consultation can be completed using the ESA
Section 7 consultation process provided that the Federal action agency
supplies the information required by 50 CFR 600.920(g) for an EFH
Assessment, and NMFS clearly distinguishes its EFH Conservation
Recommendations from ESA conservation recommendations under 50 CFR
402.14(j) or any other ESA measures or conditions. If NMFS has made a
finding for another environmental review process that meets the
requirements for completing EFH consultations, the Federal action agency
may decide which process to use for any given EFH consultation (NMFS,
2001).

A list of federally protected species with the potential to occur in
Monroe County was obtained from USFWS (USFWS, 2000). Additionally, a
list of species under the jurisdiction of NMFS that have the potential
to occur in Florida's Atlantic Coast and Gulf of Mexico was obtained
from NMFS (NMFS, 2001). The compiled species list, including habitat
type and likelihood of occurrence in the Keys, is included in Appendix
F. A similar table documenting plants and animals listed for protection
at the State level is provided in Appendix F.

Many of the native plant species are endemic to the region or are more
characteristic of the Caribbean flora than of the temperate flora
typical of the Florida mainland and the rest of North America. In
contrast, most of the animal species are more characteristic of the
temperate faunal element. In each case, numerous endemic subspecies and
varieties have developed as a result of isolation in the islands of the
Keys.

Threatened and endangered species in the Keys often have ranges that
include several habitat types. However, certain communities provide the
primary habitat for most species. Designated Critical Habitat, under the
ESA, is present in the Keys for three species. Nearshore waters of
Florida Bay and associated Sounds south to Long Key (approximate
boundary of Everglades National Park) have been designated as Critical
Habitat for the American crocodile (*Crocodylus acutus*). Similar waters
south to Buttonwood Bay near Key Largo are designated Critical Habitat
for the West Indian manatee (*Trichechus manatus*). All land areas above
the mean low tide of Little Pine Key, Big Torch and Middle Torch Key,
Water Keys, Raccoon Key, Johnston Key, and Saddlebunch, Cudjoe, and
Summerland Keys north of US 1 are designated Critical Habitat for the
Key rice rat (*Oryzomys argentatus*).

Federally listed species that occur in the pine rocklands and tropical
hardwood hammocks in the Upper Keys include the Key Largo woodrat
(*Neotoma floridana smalli*), Key Largo cotton mouse (*Peromyscus
gossypinus allapaticola*), eastern indigo snake (*Drymarchon corais
couperi*), Schaus' swallowtail butterfly (*Heraclides aristodemus
ponceanus*). Key deer (*Odocoileus virginianus clavium*) use hammocks
and pine rocklands in the Big Pine and No Name Key areas. Tropical
hardwood hammocks are important forage habitats for the Stock island
tree snail (*Orthalicusreses reses*). Pine rockland habitat also
supports two plant species listed as Threatened or Endangered at the
Federal level: the Key tree cactus (*Cereus robinii*) and Garber's
spurge (*Chamaesyce garberi*) (Chafin et al., 2000).

Mangrove forests and other wetlands also are a key habitat for several
federally listed species, including the American alligator (*Alligator
mississippiensis*) Keys marsh rabbit (*Sylvilagus palustris hefneri*),
American crocodile, eastern indigo snake, bald eagle (*Haliaeetus
leucocephalus*), and peregrine falcon (*Falco* *peregrinus*) (Hipes et
al., 2000). Additionally, the rice rat and key deer may be found in
coastal wetlands on Big Pine Key and nearby islands in the Lower Keys.
Unvegetated or poorly vegetated shorelines and beach/dune areas provide
habitat for the roseate tern (*Sterna dougallii*). Waters adjacent to
mangrove forests provide habitat for the West Indian manatee and
numerous fish species.

Little use of disturbed habitats and developed areas is made by
federally listed species in the Keys.

#### Environmental Consequences

##### Alternative 1 -- No Action Alternative

FEMA would not be the Federal action agency; therefore, FEMA would not
be required to undertake activities related to compliance with Section 7
of ESA and EFH. However, specific effects on special status species
would be considered in the SER following issuance of the final PEA.
Because this alternative may involve construction of WWTPs and/or
clustered OWNRS, effects on special status species would likely be
similar to those under Alternatives 2 and 3 discussed below.

##### Alternative 2 -- Centralized Wastewater Treatment Plant Alternative

Assessing effects on special status species depends on the specific
siting of WWTPs as well as their design component details; therefore,
effects on protected species and their habitats would be considered as
part of the project-specific SER (including all collection and disposal
options proposed under this Alternative). In compliance with Section 7
of ESA, FEMA would conduct appropriate consultation, including seeking
concurrence for findings of effect, with USFWS and/or NMFS with regards
to proposed projects and their potential to impact protected species and
their habitats. Mitigation measures developed in consultation with USFWS
and/or NMFS during the Section 7 process would become applicant
conditions for project implementation.

Additionally, FEMA would conduct appropriate EFH consultation with NMFS
in accordance with MSA regulations at the project-specific SER level. To
the extent practicable, this coordination would be integrated with
Section 7 ESA compliance.

In a letter dated October 1, 2001 pertaining to preparation of this
draft PEA, the Florida Keys Field Office of USFWS recommended that
project applicants avoid certain habitat types in siting wastewater
management activities (Appendix G). This includes avoiding parcels that
have significant areas of tropical hardwood hammock, pine rocklands,
buttonwood grasslands, or freshwater marshes. Accordingly, FEMA would
require project applicants to consider feasible alternatives that site
WWTP facilities outside of these areas as part of preparation of the
project-specific SER. Also, in response to preparation of this draft
PEA, both NMFS and USFWS stated support of advanced wastewater treatment
facilities in the Keys and the resulting nearshore environmental
improvements (Appendix G).

As discussed in Sections 3.3.2.1 and 3.3.2.2 (No Action Alternative and
Alternative 2), reductions in the release of nutrients and pathogens to
marine habitats would occur under this alternative. A reduction in
nutrients and TSS released to the marine water column may benefit
seagrass-dependent protected species such as the West Indian manatee and
the green turtle by reducing the growth of phytoplankton, improving
water clarity and potentially increasing seagrass productivity and
growth.

A reduction in nutrients released to marine waters may also benefit
coral reef-dwelling species listed for protection, including sea
turtles, groupers (*Epinephelus* spp.), and the State-listed pillar
coral (*Dendrogyra cylindrus*). As discussed in Section 3.3.2.1, reduced
nutrients favor corals by limiting the growth of non-symbiotic
mat-forming algae that can out-compete corals.

Questions have been raised regarding a possible connection between
chemicals (such as chlorine, by-products, and daughter compounds) and
nutrients and a marked increase of Fibropapillomatosis (FP) in sea
turtles. The disease is generally characterized by multiple lobe-shaped
tumors (fibropapillomas) ranging from a few millimeters to 25
centimeters in diameter. Juveniles are affected most severely, with half
or more of the immature green turtles in some coastal foraging pastures
of Florida and Hawaii exhibiting tumors (Balazs, 1997). A herpes virus
has been found in more than 95% of the fibropapillomas of green and
loggerhead sea turtles in Florida (Klein, 1998), but the exact role it
or any other possible etiological (disease-causing) agents play, and the
extent to which pollution, genetics, and other factors are involved
remains unclear. Thus far, despite numerous studies, no solid link has
been established between disease occurrence and the chemicals and other
pollutants in question (Aguirre, 1998). Additional informational on the
Public Health effects of chlorine are in Section 3.6.4.2.1, Public
Health.

##### Alternative 3 -- On-Site Treatment Upgrades

Effects on special status species, and consultation requirements, would
be similar to those described in Alternative 2 and would be further
developed in preparation of the project-specific SER.

## Air Quality

### Affected Environment

The Clean Air Act requires EPA to set National Ambient Air Quality
Standards (NAAQS) for pollutants considered harmful to the public health
and the environment. The Clean Air Act established two types of national
air quality standards. Primary standards set limits to protect public
health, including the health of "sensitive" populations such as
asthmatics, children, and the elderly. Secondary standards set limits to
protect public welfare, including protection against decreased
visibility, damage to animals, crops, vegetation, and buildings.

The EPA Office of Air Quality Planning and Standards has set NAAQS for
six principal pollutants, known as "criteria" pollutants: carbon
monoxide (CO), nitrogen dioxide (NO~2~), ozone (O~3~), lead (Pb),
particulate matter less than 10 microns (PM 10), and sulfur dioxide
(SO~2~). The FDEP has two Special Purpose Monitoring stations in Monroe
County, one on Stock Island at JR College Road and US Highway 1 and the
other in Marathon at 2796 Overseas Highway (FDEP, 1999). These stations
only monitor PM 10. The average of the 1-hour maximum recordings in the
last 4 years was 46 micrograms per cubic meter (μg/m^3^) with no
exceedances in any year. This is well below the NAAQS 24-hour average
standard value of 150 μg/m^3^.

According to FDEP and EPA acceptable limits on ambient air quality,
Monroe County is considered in attainment for all six major principal
pollutants (Monroe County, 1997). Counties surrounding Monroe County
include Broward, Collier, and Miami-Dade and they are also in
attainment. There can be exceptional events (fire or natural
occurrences) that would exempt certain areas of Florida from compliance.
In the Keys, there is a time of the year when African Dust can be a
problem, but thus far, it has not exceeded compliance (Edds, Pers.
Comm., 2001).

Table 3-2: Year 2000 Maximum Recorded Criteria Pollutant Levels for
Monroe and Neighboring Counties in Florida

  ---------------- ------------- ----------- -------- -------- ---------- -------- ----------
                   **Pollutant                                                     
                   (in parts per                                                   
                   million                                                         
                   \[ppm\])**                                                      

  **County**       SO~2\         Lead\       CO\      CO\      NO~2~\     Ozone\   PM 10\
                   ~Max 24-hr.\  Max         Max      Max      Max        Max      Max 24-hr\
                   (.14 ppm\*)   Quarterly   1-hr.\   8-hr.\   Annual\    1-hr.\   (150
                                 Mean\       (35 ppm) (9 ppm)  Average\   (.12     μg/m^3^)
                                 (1.5                          (.053 ppm) ppm)     
                                 μg/m^3^)                                          

  **Monroe**       N/A           N/A         N/A      N/A      N/A        N/A      59 μg/m^3^

  **Broward**      .031 ppm      05 μg.      7.5 ppm  4.1 ppm  .010 ppm   .092 ppm 47 μg/m^3^
                                 /m^3^                                             

  **Collier**      N/A           N/A         N/A      N/A      N/A        N/A      42 μg/m^3^

  **Miami-Dade**   .004 ppm      N/A         8.7 ppm  4.8 ppm  .016 ppm   .100 ppm 54 μg/m^3^

  *Source: FDEP,                                                                   
  2000 -- EPA                                                                      
  Aerometric                                                                       
  Information                                                                      
  Retrieval*                                                                       
  System (AIRS).                                                                   
  ---------------- ------------- ----------- -------- -------- ---------- -------- ----------

### Environmental Consequences

#### Alternative 1---No Action Alternative

Monroe County grant applicants would not receive FEMA funds for
wastewater management but would still have to meet Florida Statutory
Treatment Standards by 2010. The systems upgrades would likely require
the operation of heavy equipment during construction and would result in
minor temporary adverse effects on air quality from increased exhaust
pollutants. Windblown soil and dust may also occur during the
construction phase as a result of equipment movement over exposed soil
areas. Fugitive dust can be greatly minimized by appropriate dust
control measures such as wetting the surfaces, mulch, and by
re-vegetating disturbed areas as soon as possible following
construction.

#### Alternative 2 -- Centralized Wastewater Treatment Plant

Minor, temporary, and localized adverse effects on air quality may
result from the construction or upgrade of WWTPs. The operation of heavy
equipment during construction would result in minor temporary adverse
impacts on air quality from increased exhaust pollutants. The new
wastewater treatment facilities would result in the ingress and egress
of maintenance equipment. Windblown soil and dust may also occur, as
described in Section 3.4.2.1, No Action Alternative.

After construction of the proposed facility, daily operations may
increase the presence of objectionable odors, such as from hydrogen
sulfide. Objectionable odor is addressed in F.A.C. 62-604.400 and
62-296.320. These regulations specify that the project applicant would
give reasonable assurance that the facility would not cause odor at such
levels that they adversely affect neighboring residents, in commercial
or residential areas, so as to be potentially harmful or injurious to
human health or welfare or unreasonably interfere with the enjoyment of
life or property, including outdoor recreation. In order to mitigate
odors, the project applicant would be required to design and implement
an odor control system such as hydrogen sulfide or ozone removal system,
or use aeration, establishment of buffer zones, or innovative structural
design to control odors. The use of specific mitigation measures for
odor control would be further developed in the project-specific SER. A
Federal (40 CFR Part 63) or State of Florida (F.A.C. 62-210) air permit
is not required for existing or newly constructed WWTP unless operating
a sludge incinerator (Lucas, Pers. Comm., 2001; Edds, Pers. Comm.,
2001).

##### [Collection Option 1 -- Vacuum Pumping]{.underline} {#collection-option-1-vacuum-pumping-2 .unnumbered}

The vacuum pumping system aerates odors during the transport sewage to
the treatment facility by allowing air into the pump system behind
wastewater that has accumulated in holding tanks. The odor in these
systems is decreased due to high dissolved oxygen, on the order of 6 to
8 ppm. The only release of air occurs at the vacuum station, which is
run through a biofilter before being released. The biofilter removes
99.9% of the hydrogen sulfide (Carney, Pers. Comm., 2001). Temporary
adverse effects to air quality may result from construction activities,
similar to those described in Section 3.4.2.1, No Action Alternative.

##### [Collection Option 2 -- Low-Pressure Grinder Pump Sewer System]{.underline} {#collection-option-2-low-pressure-grinder-pump-sewer-system-2 .unnumbered}

Temporary adverse effects to air quality may result from construction
activities. These effects are similar to those described above under
Alternative 2.

##### [Disposal Option 1 -- Shallow Injection Wells]{.underline} {#disposal-option-1-shallow-injection-wells-5 .unnumbered}

Temporary adverse effects to air quality may result from construction
activities. These effects are similar to those described above under
Alternative 2.

##### [Disposal Option 2 -- Wastewater Reuse]{.underline} {#disposal-option-2-wastewater-reuse-4 .unnumbered}

There is not expected to be any adverse effects of wastewater reuse on
air quality.

#### Alternative 3 -- On-Site Treatment Upgrades

Impacts related to construction activities would be similar to those
described in Section 3.4.2.1, No Action Alternative. The installation of
clustered OWNRS systems would require periodic maintenance and
subsequently result in a minor increase in the number of vehicles
traveling through the area.

A vent stack constructed as part of the OWNRS is normally used to push
odors outside and prevent odors from backing up into residences and
businesses. Initially, clustered OWNRS may release foul odors from
treatment tanks following the first several months of use; however, as
bacteria start to reproduce and grow, odors in the system would be
reduced (Brookman, Pers. Comm., 2001).

## CULTURAL Resources

### Affected Environment

Cultural resources are protected by a variety of laws and regulations,
including the National Historical Preservation Act (NHPA) of 1966, as
amended, NEPA, the Archaeological Resources Protection Act (ARPA), the
American Indian Religious Freedom Act (AIRFA), and the Native American
Graves Protection and Repatriation Act (NAGPRA).

Section 106 of the NHPA and implementing regulations (36 CFR 800)
outline the procedures to be followed in the documentation, evaluation,
and mitigation of impacts for cultural resources. The Section 106
process applies to any Federal undertaking that has the potential to
affect cultural resources. The Section 106 process includes identifying
significant historic properties and districts that may be affected by
the proposed actions or alternatives, and mitigating adverse effects to
those properties listed, or eligible for listing, in the National
Register of Historic Places (NRHP) (36 CFR 60.4). Historic properties
are defined as archaeological sites, standing structures, or other
historic resources listed on, or determined potentially eligible for,
the NRHP.

The cultural resources of South Florida, including the Keys, are as
diverse as the residents of the area today. From the earliest periods of
human occupation, the vast natural resources of the Everglades area
supported cultures uniquely adapted to a coastal/marsh existence.
Although the focus of the draft PEA is on the Keys, the Florida State
Archaeology Plan classifies the Keys as part of the Everglades (FSHPO,
1993).

#### Paleo-Indian Period (ca. 12,000 to 10,000 BP)

The earliest human inhabitants of Florida were Paleo-Indian and entered
the region by about 12,000 BP. The Paleo-Indian period is thought to
have lasted through 10,000 before present (BP). Paleo-Indians are
generally thought to have been hunter-gatherers, who lived a nomadic
existence, following game and exploiting seasonally available plant
life. Generally, all that remains of Paleo-Indian sites are lithic
artifacts including blades, projectile points, and other tools and
by-products of tool manufacture. Because of the high acidity of Florida
soils, other tools and artifacts made of bone or wood have decomposed.
The environment during the Paleo-Indian period was substantially
different from that observed today. Based on pollen and fossil evidence,
the climate appears to have been much drier (FSHPO, 1993). During this
period, the vast glacial ice sheet that covered North America to as far
south as Pennsylvania resulted in sea level elevations that were far
lower than today. Thus, the Atlantic coast of Florida is estimated to
have been 72 to 90 miles east of its present location (FSHPO, 1993). As
a result of the subsequent global warming and rising sea level, it is
likely that a number of Paleo-Indian sites are now submerged beneath the
Atlantic Ocean.

The Florida State Historic Preservation Plan suggests that Paleo-Indian
sites that withstood the dramatic environmental shifts of the late
Pleistocene period would most likely be found:

-   Where erosion has exposed deeper and earlier strata or sediments

-   Where sediment accumulation has occurred at a slower rate

-   Near sinkholes where deep sediments are exposed to the present
    surface

-   Along the central Gulf Coast, where sea-level rise has exposed
    Pleistocene limestone outcroppings (FSHPO, 1993)

The Florida State Historic Preservation Office's Master Site Files
database of archaeological sites has only one known Paleo-Indian site,
Grass Key Rock Pit site (8MO1297), within the Keys region. That site is
located in Monroe County. Though located some distance from the Keys,
the Cutler Fossil Site (8DA2001) in Dade County is considered a
significant Paleo-Indian manifestation in the Everglades cultural area.

#### Archaic Period (ca. 10,000 to 3,000 BP)

The Archaic period extends from about 10,000 BP through about 3,000 BP.
This period is generally characterized by an increase in the diversity
of resources exploited. Fishing, hunting, and gathering were all
strategies used to procure food. The Archaic period has been divided
into three phases by archaeologists, based on stylistic changes in
stemmed projectile points and the development of fiber-tempered pottery.
The Early Archaic (10,000 -- 7,000 BP) is defined by the presence of
Dalton, Hamilton, and Kirk-serrated projectile points. The Middle
Archaic (7,000 -- 5,000 BP) is characterized by the presence of Marion
and Putnam projectile points. Finally, Late Archaic (5,000 -- 2,500 BP)
archaeological sites may possess Clay and Lafayette projectile points,
as well as fiber-tempered pottery.

According to the Florida Master Site Files (FMSF) database of
archaeological sites, Key Largo 1 (8MO25) has been identified in Monroe
County and determined to potentially be Late Archaic. It is the only
Archaic Period site listed in Monroe County, and is a multi-component
shell midden site. The Cutler Fossil Site (8DA2001) noted above also has
evidence of Archaic Period.

#### Glades Period (ca. 2,500 BP to AD 1500)

From about 2,500 BP to European contact during the 16^th^ century, the
development of diverse cultural traditions occurred throughout Florida.
In south Florida, the Glades tradition is divided into many sub-periods
based primarily on differences in ceramic decoration styles. Lithic
artifacts are sparse in south Florida; chert outcrops are rare, so other
materials such as wood, bones, and shells were used to configure tools.
Ceramics during the "pre-Glades" period (ca. 2500 BP to AD 1) are
normally undecorated (Glades Plain and Goodland Plain) (FDHR, 2001). The
Glades I early period (AD 1-500) ceramic type is characterized by quartz
sand and grit temper. Later Glades periods (AD 500-1700) included the
appearance of punctated, incised, and stamped decoration on pottery, as
well as European artifacts during the Glades IIIc period (FDHR, 2001).

The Glades period is characterized by a reliance on shellfish and marine
resources, as well as hunting and gathering on the land. Generally,
there are four types of Glades period sites: primary habitation,
secondary habitation, resources procurement/processing, and mound sites
(FSHPO, 1993). Important Glades period sites include the Bear Lake Site
(8MO33), Upper Matecumbe Key (8MO17), and Rock Mound (8MO26-27).

#### Historic Period (ca. Mid-1500s to 1951)

Spaniards in search of gold, silver, and other natural resources first
arrived in Florida in the mid-1500s, marking the beginning of contact
that would forever change, and virtually eradicate, Florida's native
cultures. Once the Spanish realized that the riches of South and Central
America were not to be found in Florida, their focus turned to
converting the native population to Christianity. Relations with the
Timucua, the Guale, and the Apalachee were tumultuous at best, and
aspects of this adversarial relationship are reflected in the
archaeological record. The building, burning, and rebuilding of missions
occurred with confusing frequency (FSHPO, 1993). Chaotic relations
between Native populations and Europeans were common throughout the
southeast. European trade interests exacerbated difficulties and
boundary squabbles. Florida eventually became home to the Seminole
Indians, who were comprised of Creek Indians from the north who were
fleeing British encroachment in that region. In the Keys, the Tequestas
and Calusas, two early south Florida tribes, disappeared before the new
Seminole population arrived. The Seminoles continue to inhabit parts of
Florida today.

European control of Florida vacillated between the British and Spanish
during these early years until Florida became part of the United States
in 1821 (FSHPO, 1993). The first settlers to the Keys arrived just a
year later in 1822 at the same time that the United States established
the Navy Pirate Fleet in Key West. These pioneers were known as "Conchs"
and were largely fisherman who also salvaged shipwrecks along the reefs
of the Keys. In fact, "the English 'fisherman' began to grow wealthy
from salvaging wrecked ships...and the shakier characters were helping
the salvage business along by stringing lanterns from palm trees,
tricking captains into the shallow water reefs" (Florida Keys Virtual
Traveler, 2001).

By 1845, Florida gained statehood. During the Civil War, Union forces
blockaded Florida's ports and occupied Fort Zachary Taylor. With the
economy already faltering, the end of the war only meant difficulty for
industries and their recovery due to the vast destruction to
infrastructure and the land. It was not until after World War II that
the economy began to rebound and Florida's "frontier" period ended
(FSHPO, 1993). The railroad entrepreneur Henry Flagler helped bring an
end to this "frontier" period with his extension of the Florida East
Coast Railroad, which extended from Homestead to Key West. Before the
rail line's completion in 1912, transportation in the Keys was exclusive
to boats. Unfortunately, the rail line was destroyed in 1935 by the
Labor Day hurricane and transportation was again limited to boats
(Florida Keys Virtual Traveler, 2001). Today, the Overseas Highway
follows the old Florida East Coast Railroad route to Key West and is the
Keys' artery to the mainland.

#### Monroe County Cultural Resources

As stated in the Monroe County Comprehensive Plan, there is no specific
inventory of historic resources for this area. However, the FMSF has the
most complete listing of registered archaeological sites and historic
architecture in the State. According to this database, 449
archaeological sites have been identified in Monroe County dating from
nearly every time period. In addition, over 1,000 historic structures
have been identified within the county. An Internet search of records of
the NRHP indicates that there are 37 resources listed for Monroe County,
Florida ranging from archaeological districts to individual homes.
Finally, although several counties in Florida (such as Duval County)
have developed predictive models for locating cultural resources, Monroe
County does not currently have such models (Taylor, Pers. Comm., 2001).

### Environmental Consequences

#### Alternative 1 -- No Action Alternative

FEMA would not provide funds to Monroe County grant applicants for
wastewater management improvements. Thus, the project would not be
subject to FEMA Section 106 review for potential effects to cultural
resources. Nevertheless, because Alternative 1 would consist of a
combination of Alternatives 2 and 3, effects on cultural resources would
be similar to those discussed in Sections 3.5.2.2 and 3.5.2.3.

#### Alternative 2 -- Centralized Wastewater Treatment Plant Alternative

Under this alternative, cultural resources may be adversely affected in
areas where new treatment facilities or modifications to existing
facilities are made. Adverse effects to historic architectural resources
within view of wastewater facilities are unlikely since there are no
known historic structures within the viewshed of any of the currently
known WWTP sites. Furthermore, buffering around the facilities would
likely preclude potential adverse effects of actions proposed under this
Alternative.

Though separate from Section 106 requirements, the Florida
Administrative Code attempts to mitigate visual effects on adjoining
properties by requiring WWTPs to:

> "...give reasonable assurance that the facility shall not cause odor,
> noise, or lighting in such amounts or at such levels that they
> adversely affect neighboring residents, in commercial or residential
> areas, so as to be potentially harmful or injurious to human health or
> welfare or unreasonably interfere with the enjoyment of life or
> property, including outdoor recreation. Reasonable assurance may be
> based on such means as aeration, landscaping, treatment of vented
> gases, buffer zones owned or under the control of the permittee,
> chemical additions, prechlorination, ozonation, innovative structural
> design, or other similar techniques and methods, as may be required."
> (*F.A.C., 1996)*

Archaeological resources may be affected by ground disturbing activities
associated with the construction of, or modification to these
facilities. Proposed activities at each facility should be reviewed for
the potential for ground disturbance in previously undisturbed areas.
Coordination with the FSHPO should be completed as part of the
site-specific SERs prior to any construction activity that involves new
ground disturbance.

##### [Collection Options 1 and 2 -- Vacuum Pumping and Low Pressure Grinder Pump]{.underline} {#collection-options-1-and-2-vacuum-pumping-and-low-pressure-grinder-pump .unnumbered}

These systems require the construction of vacuum stations, and/or
associated piping which could result in potential adverse effects to
archaeological and architectural resources. Any potential effects are
likely to be similar to those described in Section 3.5.2.2, Alternative
2. New construction under these options would have to be reviewed for
potential adverse effects to archaeological resources prior to ground
disturbance.

##### [Disposal Option 1 -- Shallow Injection Wells]{.underline} {#disposal-option-1-shallow-injection-wells-6 .unnumbered}

This alternative has similar implications to Alternative 2 as described
above, and would likely have similar impacts. Injection wells would be a
component of the treatment facility. Potential effects on cultural
resources would be evaluated at the project specific SER level.

##### [Disposal Option 2 -- Wastewater Reuse]{.underline} {#disposal-option-2-wastewater-reuse-5 .unnumbered}

The effects of installing a wastewater reuse system would be similar to
those described under Collection Options 1 and 2. This would include
limited excavation and laying of pipes. Potential effects to cultural
resources are project specific, and as such, would be evaluated in an
SER.

#### Alternative 3 -- On-Site Treatment Upgrades

Existing on-site systems would be upgraded or replaced with a clustered
OWNRS, which requires a relatively small area for each unit. Depending
upon the scale of modification required to upgrade these systems and the
need for new subsurface pipes, adverse effects to archaeological
resources may occur in areas of previously undisturbed ground. Since
OWNRS do not involve significant building retrofits and are mostly
installed below ground, it is unlikely that historic buildings and
viewsheds would be affected. Potential effects of the clustered OWNRS
systems on cultural resources would be evaluated further at the project
specific SER level.

## Socioeconomic Resources 

The projects proposed for funding are located in Monroe County, which
has a population of 79,589 (Y2000) with a **median household income
(MHI)** of \$42,283, (Y1999) and **median family income** **(MFI)** of
\$50,734 (Y1999) (U.S. Census, 2000b). The average household size in
Monroe County is 2.3 people. According to a comparison of Florida price
level indices, Monroe County residents experience the highest cost of
living in the State of Florida due, in part, to the desirability of the
area to both tourists and residents, relatively high transportation and
water delivery costs, limited space for development, and high property
values. Monroe County's economic base expanded during the 1980s
outperforming the State and the nation in terms of high employment
growth, low unemployment levels, and increases in per capita income
(Monroe County, 1997). In the 1990s, sprawling populations and the
desire for local control led to more cities becoming incorporated. The
millions of tourists that visit the county each year provide the major
source of employment and financial input to the local economy. Through
the mid 1990's, Monroe County's unemployment remained two to three
percentage points below statewide and national levels (Monroe County,
1997). The main employment remained the tourist industry, followed by
commercial fishing, retail services, and government. In consideration of
the major components of the socioeconomic environment and the proposed
projects, impact analysis related to tourism, the fishing industry, and
local fees and taxes are discussed separately in the following sections.

### Tourism

#### Affected Environment

Beautiful natural surroundings, temperate weather, clear waters,
cultural diversity, and the world's third largest coral reef system make
the Keys popular as both a tourist destination and retirement community.
The Keys received about 2.9 million visitors from June 1997 to May 1998
(Leeworthy and Vanasse, 1999). During that period, visitor spending
approximated \$1.19 billion with about 60% of that figure spent on goods
and services remaining within Monroe County. This translates to an
estimated 13,655 jobs in direct employment based on the tourism industry
alone, and represents 42% of the total number of those employed in
Monroe County.

Because of its heavy reliance on tourism, the local economy fluctuates
seasonally. Employment is at its highest level from December to April
during the tourist season, steadily declines from May through October,
then begins rising again in November. Monroe County's base of income is
largely independent of employment due to the importance of the tourism
industry and the large population of retired people living in the Keys
who are drawing pensions, retirement pay, dividends, and interest on
investments, and social security (English, et al., 1996). Cruise ship
passengers also represent significant contributors to the Keys' tourism
industry. In 2000, an estimated 656,866 cruise ship passengers went
through Key West Harbor (Kozma, Pers. Comm., 2001).

Some of the more popular tourist activities include sightseeing and
attractions, swimming and beach activities, snorkeling, visiting museums
and historic sites, wildlife observation, and, to a lesser extent,
personal watercraft use, fishing, scuba diving, and camping (Leeworthy
and Wiley, 1996). There is a strong connection between the abundance and
diversity of natural resources in the Keys and the value of the tourism
industry (Leeworthy and Bowker, 1997).

Tourist populations use hotels, restaurants, marinas, retail stores, and
other public places with utility systems, and therefore, include a large
portion of the population that contributes to the county's sewage. Thus,
tourism is a key factor in wastewater quality and capacity issues. In an
analysis of seasonal fluctuations in potable water use, FKAA found a
direct relationship between an increase in water use and an increase in
the tourist seasonal demand (Cates, 2001).

Inadequate wastewater treatment and disposal has been blamed for posted
health advisories throughout the Keys, though no formal beach closures
have been recorded (Teague, Pers. Comm., 2001). During the summer of
2000, numerous beaches and canals in the Keys tested positive for
**enterococci**, a bacterium whose presence serves as an indicator of
fecal pollution. Representatives from the EPA and Monroe County
Department of Health identified the cause to be raw sewage escaping
wastewater collection systems through storm drain pipes and groundwater
flow into nearshore beach waters (Bill Kruczynski, EPA, and Jack Teague,
formerly of Monroe County Health Department, in Karnatz, 2000). As of
publication of this draft PEA, no available studies estimate the impact
of these beach and water quality advisories on tourism and the local
economy (Kozma, Pers. Comm., 2001). Over the past 15 years, the number
of tourists has steadily increased; and, in the past 5 years, the
population of tourists visiting the Keys has increased at an average
yearly rate of about 4% (Kozma, Pers. Comm., 2001). Although health
advisories do not appear to be influencing tourism in the Keys, it may
be predicted that the periodic health advisories likely affect the use
of beaches on a localized scale. Posted health advisories may cause
tourists to recreate at alternate beaches that do not have posted health
advisories or choose to participate in alternate recreational
activities.

#### Environmental Consequences

##### Alternative 1 -- No Action Alternative

No FEMA funds would be provided to Monroe County grant applicants or
applied to wastewater management projects. Alternative funding would be
needed to improve wastewater management so that it would comply with
Florida Statutory Treatment Standards by 2010.

Depending on the choice of funding vehicle and total assistance funding,
the implementation of wastewater management projects may affect local
fees and taxes, and may increase tourists' vacation costs. Higher
vacation costs may reduce the number or alter the demographics of the
visitor population as higher rates may make vacations to the Keys less
affordable. A more detailed discussion on the impact of the No Action
Alternative on local fees and taxes is discussed in Section 3.6.3.2.1.

The No Action Alternative would improve ground and nearshore water
quality and probably reduce or eliminate the number of health advisories
in local beaches and canals. The No Action Alternative may increase the
number of visitors to beaches that formerly posted advisories, and/or
reduce visitor pressure on alternate beaches and recreational
activities. This is discussed in detail in Section 3.6.4, Public Health.

Construction activities associated with the implementation of wastewater
management projects proposed in the MCSWMP have the potential to result
in localized and temporary, adverse effects on tourism. Depending on the
location of these projects, traffic may be re-routed or tourist
attractions may be temporarily closed. Temporary construction activities
associated with wastewater management upgrades would be short-term and
generally considered part of routine maintenance of facilities. With
effective mitigation, such as timing the construction in the off-season,
the effects would be negligible.

##### Alternative 2 -- Centralized Wastewater Treatment Plant Alternative

Effects on tourism under Alternative 2 are similar to those described
under Alternative 1 in Section 3.6.1.2.1. A more detailed discussion on
the impact of Alternative 2 on local fees and taxes is discussed in
Section 3.6.3.2.2.

Localized temporary construction effects on tourism and visitors'
enjoyment of the Keys would be discussed in the SER prepared to evaluate
a site-specific project. The SER would include mitigation measures, such
as developing a traffic management plan, to reduce effects on tourism as
a result of this alternative. None of the collection or disposal options
is expected to impact tourism beyond those effects described in Section
3.6.3.2. Temporary construction activities associated with wastewater
management upgrades would be short-term and generally considered part of
routine maintenance of facilities.

##### Alternative 3 -- On-Site Treatment Upgrades

Effects on tourism under Alternative 3 are similar to those described
under Alternative 1 in Section 3.6.1.2.1. A more detailed discussion on
the impact of Alternative 3 on local fees and taxes is discussed in
Section 3.6.3.2.2.

Localized temporary construction impacts on tourism and visitors'
enjoyment of the Keys would be discussed in the SER prepared to evaluate
a site-specific project. The SER would include mitigation measures, such
as recommendations for traffic management plans, to reduce impacts on
tourism. Temporary construction activities associated with wastewater
management upgrades would be short-term and generally considered part of
routine maintenance of facilities.

### Fishing Industry

#### Affected Environment

Next to tourism, commercial fishing is the Keys' second largest industry
(NOAA, 2000). The dockside value of Monroe County's commercial fishing
industry has been estimated at \$55 million annually. This is equivalent
to over 20 million pounds of seafood and marine products per year (Table
3-3), (Brown, Pers. Comm., 2001). In a survey of the nation's 60 major
commercial fishing ports, Key West was rated in the top ten for overall
value in the years 1995 to 2000, but is ranked between 40^th^ and 50^th^
for quantity (NMFS, 2000). There were 1,982 active commercially
registered vessels in Monroe County accounting for 2,428 commercial
fishing licenses in 2000 (Brown, Pers. Comm., 2001).

Spiny Lobster represents the largest Keys' fishery harvest, at about
\$25,600,000 per year based on an average of 1995 to 2000 harvest-value
figures. Established in the late 1940's, the Tortugas pink shrimp
industry is the second largest fishery business, at about \$6,150,000
annually (NOAA, 1999 and Brown, Pers. Comm., 2001). Large stone crab is
the third largest at \$3,860,000 annually (Brown, Pers. Comm., 2001). It
is likely the high value of commercial fishing in the Keys is due to the
high profitability of the three main harvests: lobster, crab, and
shrimp. Statistically, fin fishes, such as grouper, tuna, snapper,
ballyhoo, and flounder, have fluctuated in harvest, but generally
declined by an average of about 9% between the years 1995 and 2000, with
an uncharacteristic increase in fin fish in 1999. Harvesting of live
rock and live sand, used in decorative aquariums, has also declined,
however this is likely due to a ban on harvesting live rock and live
sand in Florida State waters (Table 3-3).

Table 3-3: Trends in Monroe County Fishery

  ------------------ ---------------- ---------------- ---------------- ---------------- ---------------- ---------------- ----------
  **Year**           **1995**         **1996**         **1997**         **1998**         **1999**                          **2000**

  **Fish (in                                                                                                               
  pounds)**                                                                                                                

  Fin Fish           7,759,793        7,125,859        6,413,043        6,010,078        6,373,180        5,410,236        

  Invertebrates^1^   9,719,450        10,116,097       10,060,710       8,839,995        10,610,628       7,858,628        

  Shrimp             5,313,128        6,388,154        3,695,231        6,156,735        3,968,242        3,425,180        

  Bait Shrimp        70,597           218,448          86,565           102,190          92,695           117,667          

  Marine Life Fin    123,001          99,930           108,463          119,690          110,199          98,201           
  Fish^2^                                                                                                                  

  Marine Life        1,089,559        1,041,728        965,442          1,519,671        1,827,976        2,165,134        
  Invertebrates^3^                                                                                                         

  Plants             18,908           7,871            9,103            7,911            11,243           10,720           

  Live Rock/Sand     493,548          119,622          68,114           16,512           21,325           28,406           

  **Total**          **24,587,984**   **25,117,709**   **21,406,671**   **22,772,782**   **23,015,488**   **19,114,172**   

  ^1^Invertebrates                                                                                                         
  include: crabs,                                                                                                          
  lobster, octopus,                                                                                                        
  sponge, and squid.                                                                                                       

  ^2^Marine Life                                                                                                           
  refers to landings                                                                                                       
  of live species                                                                                                          
  for the tropical                                                                                                         
  ornamental trade.                                                                                                        

  ^3^Marine Life                                                                                                           
  Invertebrates                                                                                                            
  include conchs,                                                                                                          
  crabs, jellyfish,                                                                                                        
  lobsters,                                                                                                                
  anemones, snails,                                                                                                        
  stars, urchins,                                                                                                          
  and sanddollars.                                                                                                         

                                                                                                                           

  Source: Florida                                                                                                          
  Fish and Wildlife                                                                                                        
  Conservation                                                                                                             
  Commission                                                                                                               
  ------------------ ---------------- ---------------- ---------------- ---------------- ---------------- ---------------- ----------

The commercial and recreational fishing industry in the Keys is
regulated through the Gulf of Mexico and South Atlantic Fishery
Management Councils, NMFS, and Florida Fish and Wildlife Conservation
Commission. Additional information related to federally regulated
fisheries, the MSA, and EFH compliance are in Section 3.3.

Changes in vegetation due to water quality problems in Florida Bay have
been held responsible for the loss of about \$32 million in the
commercial fishing industry between 1986 and 1994 (McPherson and Halley,
1996). Numerous sources have been identified with declines in water
quality in Florida Bay, including inadequate wastewater management,
stormwater runoff, nutrients and heavy metal contamination from marinas,
and the reduction of freshwater flow from the Everglades. As a result,
populations of Florida Bay sponges have died, which has impacted
harvests of spiny lobster and pink shrimp (McPherson and Halley, 1996).
Although there are currently restoration projects being carried out in
the Everglades, estimates at this time of project effects on Florida Bay
and consequently to the nearshore environment in the Keys would be
difficult to quantify. Water quality deterioration in Florida Bay
affects the fishing industry because the Bay acts as a fish nursery.
Less information exists on the relationship between wastewater
management activities and effects on fisheries on the Atlantic-side of
the Keys (Beaver, Pers. Comm., 2001).

#### Environmental Consequences

##### Alternative 1 -- No Action Alternative

Keys Communities would not receive FEMA funds for wastewater management
and still would have to meet Florida Statutory Treatment Standards by
the year 2010. Keys nearshore marine waters would likely improve as
planned wastewater management activities reduce the amount of nutrients
and other pollutants entering the marine waters. Because detailed
studies related to the impact of septic tanks and cesspit systems on
commercial fisheries have not been completed for the Keys, it is
difficult to quantify the expected improvement to fisheries associated
with meeting the Florida Statutory Treatment Standards. As described in
the Water Quality Section 3.2.2.2.1, the replacement of existing
cesspits and septic systems with OWNRS systems and centralized WWTPs
would greatly reduce the overall nutrient and pathogen inputs to the
shallow groundwater of the Keys. Generally, it may be predicted that
harvested species that occur in nearshore waters such as spiny lobster,
white mullet, gray snapper, various flounder, shrimp, and stonecrab
would benefit from improved water quality. In consideration of the
cumulative effect of on-going stormwater management activities and other
wastewater management activities in the Keys, the benefits may range
from relatively insignificant to potentially substantial improvements in
harvest rates. These effects cannot account for pollutants from Florida
Bay, which would continue to adversely affect commercial fisheries
regardless of wastewater treatment improvements in the Keys. As
described in Section 4, the Everglades restoration activities would
likely assist in decreasing nutrient inputs to Florida Bay.

##### Alternative 2 -- Centralized Wastewater Treatment Plant Alternative

FEMA would provide funding to aid in the construction or upgrade of
community and regional WWTPs throughout the Keys. Effects on commercial
fishing due to the use of WWTPs are similar to those described in
Section 3.6.2.2.1. None of the collection or disposal options is
expected to impact fisheries beyond the effects described in Section
3.6.2.2.1.

##### Alternative 3 -- On-Site Treatment Upgrades

FEMA would provide funding to Monroe County grant applicants to upgrade
OWTS to OWNRS to improve wastewater management in the Keys. Effects on
commercial fishing due to the use of clustered OWNRS are similar to
those described under Alternative 1 in Section 3.6.2.2.1.

### Local Fees and Taxes

#### Affected Environment 

Monroe County residents must pay county, State, and Federal taxes.
County taxes vary depending on the specific community within Monroe
County; however, the average property tax for all districts in Monroe
County is 13.4% of the appraised property value, not including property
tax deductions such as the homestead exemption (Monroe County, 2001b).
Several taxing bodies within Monroe County affect the total millage rate
that composes the property tax. Depending on the district, these taxing
bodies may include the Monroe County School District; law enforcement,
jail, and judicial system; mosquito control project; local health
clinic; fire and ambulance district; local city tax authority; and
county general fund. Additionally, the SFWMD levies property taxes from
Monroe County residents for the Everglades and Lake Okeechobee projects
that provide watershed management and water supply protection for the
Keys' potable water resources.

Monroe County has a 7.5% sales tax (1.5% county and 6.0% State).
Additionally, the County's residents, businesses, and visitors pay
Florida State taxes, including insurance premium, estate, fuel, gross
receipts utility, dry cleaning, coastal protection, water quality,
inland protection, hazardous waste, and tourist development taxes;
infrastructure, education, indigent care, and charter county transit
surtaxes; and rental car, waste tire, lead acid battery, and audit and
warranty fees and surcharges. The State of Florida does not impose a
personal income tax; however, it does levy a 5.5% corporate income tax.
Residents and businesses are subject to Federal taxes.

##### Existing Wastewater Management Costs in Monroe County

For the purpose of this draft PEA, wastewater management cost
discussions may include reference to: 1) **system capital costs** which
include expenses associated with planning, designing, engineering,
purchasing, building, and installing a wastewater treatment system, and
its needed wastewater conveyance piping in public right-of-ways and
selected effluent disposal method (e.g. injection wells, SDI, reuse); 2)
**abandonment and lateral costs** which include the expenses associated
with removal and disposal of the existing wastewater treatment system,
and piping on service recipient's property for connection to a new
system; and 3) **operation and maintenance (O&M) costs** for the system.
Each of the above costs may be combined into a monthly rate structure,
where the system is administered by a utility, which would include
amortization of some costs, as detailed in the discussion.

Five basic types of wastewater systems are presently used in Monroe
County: cesspits, septic tanks, on-site ATUs, OWNRS, and centralized
WWTPs. The OWNRS and some of the WWTPs are already compliant with
Florida Statutory Treatment Standards. Wastewater costs associated with
them are addressed in Section 3.6.3.2, which discusses the consequences
of implementing wastewater management improvements that meet Florida
Statutory Treatment Standards.

Almost all Keys' cesspits are at residences that were built before 1970.
From discussions with wastewater service companies in the Keys, it was
gathered that "properly" functioning cesspits (i.e., those that drain
and leach out effluent into the surrounding soil and subsurface
limestone) do not need to be pumped out; and consequently, do not have
any associated operation and maintenance costs. As most of them were
installed over 30 years ago, there are also currently no associated
system capital costs. Cesspits are currently illegal to install in
Monroe County, and are being removed as part of Monroe CIEGP. This
program is discussed in detail in Section 3.6.3.2.1.

Septic systems are prevalent in Monroe County, for both homes and small
businesses. Septic systems collect sewage in a tank and allow the liquid
waste to filter through the drainfield into shallow soils and subsurface
limestone. For septic systems in working condition, pumping to remove
solid waste is only needed about every six to ten years (D and D
Enterprises, Inc., Pers. Comm., 2001). The cost to pump a standard size
septic tank of 1,000 gallons is about \$300, equating to an approximate
annual cost of \$38 or a little over \$3 a month (assuming pumping every
8 years).

Many new or recently built homes and some large residential wastewater
generators (e.g., resorts, motels, RV parks, trailer parks) in Monroe
County use non-compliant ATUs to treat waste. Currently, these systems
handle only a very small percentage of the total amount of wastewater
generated in the Keys. Non-compliant ATUs clarify the waste stream, but
do not meet the Florida Statutory Treatment Standards; therefore, they
are consequently only approved for use until 2010. ATUs require either
an injection well or an SDI for disposal of the treated wastewater and
the FDH requires that users hold an active maintenance contract.

The system capital cost for a non-compliant ATU is about \$7,800, with
roughly \$3,000 comprising the cost for either an injection well or an
SDI (equivalent cost for both). If this system capital cost is amortized
over 20 years at 6% interest, this equates to a monthly cost of \$56.
Additionally, a two-year maintenance contract costs about \$400, or \$17
per month. In total, a non-compliant ATU system has an approximate
system capital and O&M cost of \$73 per month per **equivalent dwelling
unit** (**EDU**). This system capital cost is lower if more than one EDU
shares the purchase and installation cost of an injection well (even the
smallest wells can handle flow from at least 3 EDUs), but because there
are many social and legal complications associated with this, injection
wells are not commonly shared (Sears Aerobic Service, Pers. Comm.,
2002).

Today, there are five local utility-operated WWTP systems, two of which
are compliant with Florida Statutory Treatment Standards. The service
recipients on these systems are charged for the initial connection costs
in addition to a monthly sewer bill. Total monthly wastewater management
rates for the three non-compliant systems that do not meet Florida
Statutory Standards are shown in Table 3-4 below and range from \$55 to
\$64, assuming the capital, abandonment, and lateral costs are amortized
over 20 years at 6% interest. If paid in lump sum at the time of
connection, connection costs for Key Haven Utilities, Ocean Reef Club,
and K W Resort Utilities are \$1,215, \$2,400, and \$2,700,
respectively. Public authorities regulate all utility companies that
provide centralized sewer service. The private companies in the Keys are
regulated by the Florida Public Service Commission (FPSC). Consequently,
all wastewater management rates charged by private companies are
authorized by the FPSC and any proposed annual rate increases go through
a public commission review and approval process before being
implemented.

Table 3-4: Average Monthly Operation and Maintenance Costs and Total
Rates for Non-2010 Compliant Monroe County WWTPs Per EDU

  ---------------------- --------------- --------------- ----------------
  **Utility Company**    **System        **Average       **Average Total
                         Capital Cost**  Monthly O&M     Monthly
                                         Wastewater      Wastewater Rate
                                         Cost**          ^1^**

  Key Haven Utilities    \$1,215         \$48            \$56

  Ocean Reef Club        \$2,400         \$46            \$64

  K W Resort Utilities   \$2,700         \$35            \$55
  ---------------------- --------------- --------------- ----------------

> ^1^ including system capital, abandonment, and lateral cost amortized
> at 6% interest, over 20 years; March 2002 figures

The following table summarizes monthly wastewater management costs
relative to each wastewater system, as well as, the information source
of each cost parameter.

Table 3-5: Estimated Monthly Costs per EDU for Non-Compliant Wastewater
Systems

+----------+------------+------------+------------+------------------+
| **Wa     | **System   | *          | **Total    | **Source**       |
| stewater | Capital    | *Operation | Cost per   |                  |
| System** | Cost**     | and        | Month      |                  |
|          |            | M          | ^1^**      |                  |
|          |            | aintenance |            |                  |
|          |            | Cost per   |            |                  |
|          |            | Month**    |            |                  |
+==========+============+============+============+==================+
| >        | > \$0 ^2^  | > \$ 0 -   | > \$0 -    | > Mitchell Enos  |
|  Cesspit |            | > \$3      | > \$3      | > Septic Tank    |
|          |            |            |            | > Corp., 2002    |
|          |            |            |            | >                |
|          |            |            |            | > Sears Aerobic  |
|          |            |            |            | > Service, 2002  |
+----------+------------+------------+------------+------------------+
| > Septic | > \$0 ^2^  | > \$3 -    | > \$3 -    | > Synagro and    |
| > System |            | > \$4      | > \$4      | > Accurate       |
|          |            |            |            | > Enterprises of |
|          |            |            |            | > South Florida, |
|          |            |            |            | > Inc., 2001     |
+----------+------------+------------+------------+------------------+
| >        | > approx.  | > approx.  | > approx.  | > Sears Aerobic  |
|  Interim | > \$7,800  | > \$17     | > \$73     | > Service, 2002  |
| > ATU    |            |            |            |                  |
+----------+------------+------------+------------+------------------+
| > WWTP   | >          | > \$35 -   | > \$55 -   | > Pers. Comm.    |
|          |  \$1,215 - | > \$48     | > \$64     | > with Key Haven |
|          | >          |            |            | > Utilities,     |
|          | \$2,700^3^ |            |            | > Ocean Reef     |
|          |            |            |            | > Club, and K W  |
|          |            |            |            | > Resort         |
|          |            |            |            | > Utilities      |
+----------+------------+------------+------------+------------------+

^1^ including system capital costs amortized at 6% interest over 20
years; March 2002 figures

^2^ assumed to be already paid for

^3^ includes abandonment and lateral costs

##### Wastewater Management Costs and Affordability for Florida Keys Residents

Of particular importance is the question of what constitutes fair and
affordable wastewater management costs for Keys residents and
businesses. Although not specifically addressing wastewater utility
rates, many Federal and State agencies have set affordability standards
for utility service at a particular percentage of MHI. This is an
acceptable method of affordability determination if the household's
income is relatively close to the median. However, this method would
give false conclusions regarding affordability if the household income
being used is significantly below the median or if the cost of living is
so high that discretionary income is very small. For this reason, the
discussion of wastewater rate affordability in this analysis is
separated into affordability analysis of near median-income populations
(presented below) and low-income populations (Section 3.8, Demographics
and Environmental Justice).

In order to assess wastewater rate affordability and reasonableness, a
representative minimal financial situation was considered to determine
the approximate average monthly living expenses for a household of two
adults and one child in Monroe County (Table 3-6).

Table 3-6: Estimated Average Monthly Costs for Household Expenses in the
Florida Keys

+---------------------------+---+-----------+---+-----------------------------+
| **Average Monthly         | * |           | * |                             |
| Expenses (Household of    | * |           | * |                             |
| Two)**                    | E |           | S |                             |
|                           | s |           | o |                             |
|                           | t |           | u |                             |
|                           | i |           | r |                             |
|                           | m |           | c |                             |
|                           | a |           | e |                             |
|                           | t |           | * |                             |
|                           | e |           | * |                             |
|                           | d |           |   |                             |
|                           | C |           |   |                             |
|                           | o |           |   |                             |
|                           | s |           |   |                             |
|                           | t |           |   |                             |
|                           | p |           |   |                             |
|                           | e |           |   |                             |
|                           | r |           |   |                             |
|                           | M |           |   |                             |
|                           | o |           |   |                             |
|                           | n |           |   |                             |
|                           | t |           |   |                             |
|                           | h |           |   |                             |
|                           | * |           |   |                             |
|                           | * |           |   |                             |
+---------------------------+---+-----------+---+-----------------------------+
| > Rent / Mortgage         |   | > \$1,248 |   | > Census, 2000              |
+---------------------------+---+-----------+---+-----------------------------+
| > Food                    |   | > \$356   |   | > USDA, 2001                |
+---------------------------+---+-----------+---+-----------------------------+
| > Electricity             |   | > \$95    |   | > City Electric, 2001       |
+---------------------------+---+-----------+---+-----------------------------+
| > Water                   |   | > \$30    |   | > FKAA, 2001b               |
+---------------------------+---+-----------+---+-----------------------------+
| > Telephone               |   | > \$21    |   | > Bell South, 2001          |
+---------------------------+---+-----------+---+-----------------------------+
| > Wind and Flood          |   | > \$200   |   | > Johnson's Insurance       |
| > Insurance               |   |           |   | > Company, 2002             |
+---------------------------+---+-----------+---+-----------------------------+
| > Incidentals (clothing,  |   | > \$100   |   | > Assumed Cost for Purpose  |
| > medical, etc.)          |   |           |   | > of Analysis               |
+---------------------------+---+-----------+---+-----------------------------+
| > **Total**               |   | > **      |   |                             |
|                           |   | \$2,050** |   |                             |
+---------------------------+---+-----------+---+-----------------------------+

The cost of a monthly rental or mortgage payment in the Keys was based
on the estimated nation wide figure of one third of household income
going towards lodging expenses. Though it is known that 10.5% of Keys
residents pay over one third of their income on housing, it is not
specifically known how much more they are paying; and consequently, the
value of \$1,248 is a conservative estimate (Pers. Comm., Casey, 2002).
The costs shown for food, water, telephone, insurance and incidentals
are best-guess estimates of average costs from the sources cited. City
Electric's estimate for an average per month was \$95 for about 1,000
kilowatt-hours. FKAA estimates potable water costs at an average of \$10
per person per month based on \$4.93 per 1,000 gallons. The monthly
expenses do not include wastewater rates that renters or homeowners may
be paying at present. It should be noted that the expenses listed above
are basic, and do not include other potential monthly costs such as
transportation expenses.

To determine the approximate discretionary income for median income
households, the 2001 MHI figure of \$44,948 per year (inflated from the
1999 Census-2000 figure) can be converted to a monthly value of \$3,746.
Net monthly income is \$3,184 after subtracting federal tax rate of 15%.
With the total basic monthly expenses subtracted, the result is a
discretionary income of \$1,134 for a household with an income near the
median in Monroe County.

The question of what wastewater management cost amount should be
considered reasonable and affordable for a household with a
discretionary income of \$1,134 per month is difficult to answer
definitively. The EPA uses a figure of 2.0% of MHI as its threshold of
affordability for drinking water projects (EPA, 1993b). The U.S.
Department of Housing and Urban Development uses a range of 1.3% to 1.4%
of MHI to determine household affordability for water and sewer bills
(cited in EPA, 1998). The National Consumer Law Center recommends less
than 2.0% for water and sewer bills (cited in EPA, 1998). Many states
have developed multi-tiered affordability criteria, listing different
percentages of MHI for different income brackets. The State of
Pennsylvania uses a sliding scale of 1.0% to 2.0% of MHI for water
rates, depending on the socioeconomic condition of the community (cited
in EPA, 1998). The State of New York uses three price levels of 1.0%,
between 1.0 and 1.5%, and 1.5% of MHI for drinking water prices for
three delineated income groups (cited in EPA, 1998).

Table 3-7 shows a selection of monthly wastewater management rates for
domestic users throughout the U.S. for October 2001 and their
corresponding percentage of the monthly MHI for that county. (Note: All
figures represent either 1,000 gallons/month usage or minimum flat rate
costs, either with 5/8 inch meter size.)

Table 3-7: Selection of Monthly Wastewater Management Rates for Cities
in Florida Cities and Across the U.S.

+--------------+--------------+------------+--------------------------+
| **City and   | **Average    | **% of     | **Source**               |
| State**      | Monthly      | county     |                          |
|              | Sewer Bill   | monthly    |                          |
|              | 2001**       | 2001 MHI** |                          |
+--------------+--------------+------------+--------------------------+
| > Sanibel,   | > \$31.52    | > 1.00%    | > [FKAA,                 |
| > FL         |              |            | > 2002]{.underline}      |
+--------------+--------------+------------+--------------------------+
| > Marco      | > \$31.52    | > 0.84%    | > [FKAA,                 |
| > Island, FL |              |            | > 2002]{.underline}      |
+--------------+--------------+------------+--------------------------+
| > San Diego, | > \$29.81    | > 0.82%    | > [http://www            |
| > CA         |              |            | .sannet.gov]{.underline} |
+--------------+--------------+------------+--------------------------+
| > Rochester  | > \$10.88    | > 0.20%    | > [http://www.rochest    |
| > Hills, MI  |              |            | erhills.org]{.underline} |
+--------------+--------------+------------+--------------------------+
| > Aiken, SC  | > \$20.63    | > 0.59%    | > [http://ww             |
|              |              |            | w.aiken.net]{.underline} |
+--------------+--------------+------------+--------------------------+
| > Fairbanks, | > \$39.98    | > 0.93%    | > [http://www.           |
| > AK         |              |            | state.ak.us]{.underline} |
+--------------+--------------+------------+--------------------------+
| > Cocoa, FL  | > \$17.51    | > 0.52%    | > [http://www.           |
|              |              |            | cocoafl.org]{.underline} |
+--------------+--------------+------------+--------------------------+
| > Amarillo,  | > \$6.21     | > 0.24%    | > [http://www.ci.ama     |
| > TX         |              |            | rillo.tx.us]{.underline} |
+--------------+--------------+------------+--------------------------+
| > Kent, WA   | > \$19.75    | > 0.42%    | >                        |
|              |              |            |  [http://www.southcounty |
|              |              |            | journal.com]{.underline} |
+--------------+--------------+------------+--------------------------+
| > Silverton, | > \$44.03    | > 1.30%    | > [http://www.silv       |
| > OR         |              |            | erton.or.us]{.underline} |
+--------------+--------------+------------+--------------------------+
| > Settler\'s | > \$10.85    | > 0.23%    | > [http://www.           |
| > Bay, AK    |              |            | state.ak.us]{.underline} |
+--------------+--------------+------------+--------------------------+

This sample of rates shown in the table above is not meant to be
representative of the whole country, but to illustrate that wastewater
management rates vary greatly. Many of these rates are influenced at
least in part by the users, in public forums, where the issue of
affordability is debated. They are also strongly influenced by the
sophistication of the systems (e.g., the level of treatment of the
wastewater) and the age of the infrastructure that the utility companies
must maintain.

With a MHI of \$3,746 per month in Monroe County, it can be seen that
the common maximum affordability criteria of 2.0% or \$75 per month is
only 6.6% of monthly discretionary income (at \$1,134 per month). For
households in Monroe County that have incomes close to the county's MHI,
a wastewater rate of near 2.0% of MHI appears to be affordable. Given
the very complex connections between the Keys economy (e.g., tourism and
fishing), residents' quality of life, and water quality, residents with
incomes close to the median would potentially be more willing and able
to pay for upgrades to wastewater treatment than other users around the
United States, whose economy and surrounding environment may not receive
as apparent benefits from their wastewater system upgrades.

##### Wastewater Management Costs and Affordability for Keys Businesses

Commercial wastewater management rates are often slightly higher than
domestic rates for the same area. This is because utility rate
regulators generally assume that businesses are "for profit" and are
able to bear more financial burden than residents. When determining
wastewater cost affordability for commercial businesses, a number of
questions arise. How much of an increase in cost can an individual
business withstand? Can the business pass on the increased cost of
wastewater to the consumers of its goods or services? Will the increased
cost threaten the existence of the business? If so, what will be the
impact on the local community if the business goes out of service? The
answers to these questions depend on what type of business is being
examined, the labor and economic conditions of the community that the
business serves, the quantity of effluent produced, and the financial
condition of the business in question.

Although medium and larger businesses could likely afford wastewater
cost increases, corporations with branches or stores in Monroe County
may look unfavorably at lower profit margins and decide to move to a
more profitable location. Small businesses may be able to survive price
increases by lowering wages or charging more for their services, but
already small profit margins or elastic demand for goods or services may
not allow for much of a price increase (Note: A good or service has an
elastic demand when the quantity demanded is responsive to price
changes. For example, fewer people would use a car wash if the price
goes up by 50 cents a wash). Businesses that would inevitably be hit the
hardest would be those that are high wastewater generators, like
laundromats and car washes.

#### Environmental Consequences

##### Alternative 1 -- No Action Alternative

No FEMA funds would be used for wastewater management projects in Monroe
County. In order to become compliant with Florida Statutory Treatment
Standards, wastewater system owners would have to use alternative
funding sources to upgrade or construct community or regional WWTPs,
and/or install OWNRS.

Table 3-8 below presents the wastewater management costs for the
compliant systems in use in Monroe County that were not recipients of
FEMA funding; however, they were recipients of other sources of funding.

**Table 3-8: Approximate Monthly Costs for Existing 2010-Compliant
Wastewater Systems per** EDU

+-----------+--------------+--------------+--------------+------------+
| **W       | **System     | **Operation  | **Total Cost | **Source** |
| astewater | Capital      | and          | per Month    |            |
| System**  | Cost**       | Maintenance  | ^2^**        |            |
|           |              | Cost per     |              |            |
|           |              | Month ^1^**  |              |            |
+-----------+--------------+--------------+--------------+------------+
| **        | \$1,600      | \$36         | \$46         | Key West,  |
| WWTP**^3^ |              |              |              | 2002       |
|           | \$4,550      | \$30         | \$68         |            |
| > Key     |              |              |              | Key Colony |
| > West    |              |              |              | Beach,     |
| >         |              |              |              | 2002       |
| > Key     |              |              |              |            |
| > Colony  |              |              |              |            |
| > Beach   |              |              |              |            |
+-----------+--------------+--------------+--------------+------------+
| **O       | \$2,500^5^   | \$45^5^ -    | \$63 - \$118 | Sears      |
| WNRS**^4^ | --           | \$59^6^      |              | Aerobic    |
|           | \$8,200^6^   |              |              | Service,   |
|           |              |              |              | 2002,      |
|           |              |              |              | Monroe     |
|           |              |              |              | County,    |
|           |              |              |              | 2000a      |
+-----------+--------------+--------------+--------------+------------+

> ^1^ March 2002 figures
>
> ^2^ Including system capital costs amortized at 6% interest, over 20
> years; March 2002 figures
>
> ^3^ Does not include abandonment and lateral costs. Does include cost
> of new piping up to property edge and connection to WW system
>
> ^4^ Includes abandonment costs. Assumes 4 EDUs on system. Does not
> include purchase cost of the land on which the system would reside.
>
> ^5^ Cost estimated by Sears Aerobic Service, 2002
>
> ^6^ Cost taken from Monroe County, 2000a for Four Home Shared OWNRS

The design, construction, and operation of systems that meet Florida
Statutory Treatment Standards to serve all currently non-compliant
systems represent an enormous cost. Monroe County estimates that the
total capital cost of the identified improvements to serve all of the
county's wastewater service areas is \$438 million (Monroe County,
2000a). In the absence of federal, state, and local grant funding, the
capital costs for a single centralized WWTP system could range from
\$14,000 to \$17,000 per EDU for a service area of 300 to 550 EDUs
(Shelby, Pers. Comm., 2002). Numerous funding and financing options
exist including user fees and charges; taxes and assessments; bonds and
loans; grants and contributions; redirection of existing programs or
funding; and financial assistance. The FKAA and Village of Islamorada
have identified potential grant funding sources external to FEMA funding
at the time of publication of this draft PEA as described in Table H-1
in Appendix H. These options and potential sources of funding are
described more fully in Appendix H. The choice of funding vehicle may
also be determined by the Monroe County BOCC, FKAA, or local
jurisdictions (Shelby, Pers. Comm., 2001).

Though not currently available, funding recently existed to assist in
converting cesspits to OWNRS. The Monroe County's CIEGP provided grants
through the Monroe County Department of Health that covered 62% or more
of the capital cost of OWNRS systems. Individuals with cesspits were
eligible for the program, as well as a group of residences that were
interested in sharing an OWNRS system. Program administrators indicated
that only a very small number of users had expressed interest in sharing
a system, but that a few shared systems were funded. As of March 2002,
the program had exhausted all of its funds, but administrators were
optimistic that new funds would be allocated and that the program would
be continued and eventually expanded to target users with septic systems
also. It is interesting to note that none of the households that
received aid from the CIEGP chose to install a SDI system for wastewater
disposal (Pers. Comm., Sleighter, 2002).

Economic effects of the No Action Alternative on local wastewater
management costs or taxes are difficult to quantify beyond the above
information, because they would depend on the final costs of the system
improvements, the number of individuals served, the amount of State and
Federal grants and contributions, the details of the chosen financing
options, including applicable repayment terms, and set affordability
thresholds. However, as a group, owners of cesspit or septic systems are
likely to see the greatest increase in costs over their present
wastewater management expenses. Project-specific effects would be
further evaluated in the SER.

In the event that wastewater system owners/operators do not comply with
wastewater regulations, FDEP and FDH can initiate non-compliance
enforcement action. For WWTPs under FDEP jurisdiction, penalties can
range from warning letters to fines of \$10,000 per day, until system
compliance is reached (Rios, Pers. Comm., 2001). Although enforcement
action has not been defined, the FDH has jurisdiction over smaller WWTPs
and on-site systems (Bibler, Pers. Comm., 2001). Furthermore, the DCA
may retain 20% of unincorporated Monroe County's building permits as a
non-compliance enforcement action (Lazar, Pers. Comm., 2001).

##### Alternative 2 -- Centralized Wastewater Treatment Plant Alternative

FEMA would provide funding for the construction of new community and
regional WWTPs, and treatment upgrades to existing centralized systems
at selected locations in the Lower, Middle, and Upper Keys. As described
in Section 1.4, Monroe County has an obligation to meet more stringent
treatment standards regardless of proposed FEMA funding. However, the
availability of FEMA funds to reduce capital costs of proposed WWTPs
would reduce the financial burden to the Monroe County government and
service recipients. Although discussed below, FEMA funds would not be
applied towards the long-term monthly O&M costs, which would be the
responsibility of service recipients.

Similar to Alternative 1, the impact of Alternative 2 on local fees and
taxes is difficult to quantify because it would depend on the final
costs of the system alternatives, the number of individuals served, the
amount of other State and Federal grants and contributions, and the
details of the chosen financing options, including applicable repayment
terms. Actual project costs and funding structure would be discussed in
more detail, as needed, in the project specific SER whereby economic
impacts can be better quantified in relation to affordability thresholds
presented in this draft PEA. However, wastewater management projects
receiving FEMA funding would not be expected to greatly exceed the
affordability threshold of 2% of MHI (approximately \$75 per month)
described in Section 3.6.3.1.2., as detailed below. The impact of these
rates on low-income households is discussed in detail in section
3.8.1.4.

As an example, FKAA is currently building a centralized WWTP that will
serve the Little Venice community without FEMA funding. The projected
cost of this WWTP is over \$7.2 million and FKAA has received an EPA
grant for \$4.35 million. The remaining \$2.85 million in costs will be
passed on to the service recipients as a system development fee. This
system development fee will be split into two parts. The first part is a
one-time charge of \$4,700 per EDU. The \$4,700 can either be paid up
front in full or paid annually through a non-ad valorem property tax
assessment of \$473 for ten years. The second part is a monthly cost of
\$25, which will be called a monthly capital cost. This monthly capital
cost of \$25 will be added to the monthly operation and maintenance
cost, which will also be around \$25, for a total monthly rate of
approximately \$50 (Teague, Pers. Comm., 2002).

Considering the costs of completed or in-progress wastewater management
projects and preliminary estimates for planned projects, the costs to
service recipients, once funding assistance has been applied, are
expected to range as follows. The system capital costs are generally
expected to range between \$3,000 and \$4,500 per EDU. The abandonment
and lateral costs are generally expected to range between \$1,500 and
\$5,000 per EDU. The monthly O&M costs are generally expected to range
between \$30-\$60 per EDU (Shelby, Pers. Comm., 2002; Islamorada,
2001c). Incorporating the system capital, abandonment, and lateral costs
into the monthly O&M costs gives a monthly range of \$63 to \$128 per
EDU. While the actual costs to service recipients are expected to fall
within this range, most are expected to incur a monthly cost near the
commonly used 2 percent of MHI affordability threshold or \$75 per
month. Costs to service recipients beyond these ranges may be considered
unreasonable.

**Table 3-9: Approximate Centralized WWTP Costs**

  ------------- -------------- --------------- ------------ --------------
                **System       **Abandonment   **O&M        **Total
                Capital        and Lateral     Costs**      Monthly
                Costs**        Costs**                      Costs**

  Initial Costs \$3,000 -      \$1,500 -       n/a          n/a
                \$4,500        \$5,000                      

  Monthly Cost  \$22 - \$32    \$11 - \$36     \$30 - \$60  \$63 - \$128
  at 6% over 20                                             
  yrs                                                       
  ------------- -------------- --------------- ------------ --------------

Under Alternative 2, abandonment and lateral costs would be an important
issue to those users who have already paid for or are currently paying
for wastewater systems. Users who have installed non-2010 compliant
systems could face continuing monthly payments on financed capital costs
for systems (or parts of systems) that are obsolete. The situation that
would be facing users who currently have 2010-compliant systems has yet
to be determined, but mandatory hook-up to the central WWTP, even
without use, could be required. The impacts to these users, including
effects on businesses that have recently purchased on-site systems,
would be further examined in the project-specific SERs, as needed.

###### [Collection Options 1 and 2]{.underline} {#collection-options-1-and-2 .unnumbered}

Regardless of which collection option is selected, local wastewater
costs would likely increase. The extent of increase would depend on the
rate structure and financing details. The rate structure may be
all-inclusive or the service recipient may be required to separately pay
abandonment and lateral costs associated with conveying wastewater from
the residence/business to the street wastewater piping.

###### [Disposal Option 1 -- Wastewater Injection wells]{.underline} {#disposal-option-1-wastewater-injection-wells .unnumbered}

Effluent disposal costs are part of the system capital costs and are
built in to the corresponding rate structure.

###### [Disposal Option 2 -- Wastewater Reuse]{.underline} {#disposal-option-2-wastewater-reuse-6 .unnumbered}

Under the wastewater reuse disposal option, capital costs are generally
more expensive than with alternative disposal methods, such as injection
wells, because of the additional effluent pumps, storage tanks,
generators, distribution pumps, and distribution piping required to
convey treated effluent to the disposal sites. Therefore, this
alternative may have higher system capital and O&M costs, and may result
in even higher wastewater management costs as these are distributed to
service recipients. However, the distribution of costs associated with
this disposal option depends on the destination of reused wastewater. As
described in Section 2.3.2.2.2, reused wastewater may be employed for a
variety of purposes. Accordingly, recipients of reused wastewater would
likely incur most of the conveyance costs.

As an example, the Village of Islamorada considered wastewater reuse for
several proposed WWTPs within its service area. The results of the
analysis found that the establishment of wastewater reuse infrastructure
could add additional monthly costs per EDU ranging from \$5.50 to
\$19.75, depending on how many properties within the Islamorada service
area would receive treated effluent (Islamorada, 2001b).

The SERs would evaluate project specific cost effects for this disposal
option.

##### Alternative 3 -- On-Site Treatment Upgrades

FEMA would provide funding assistance to project applicants for the
conversion of OWTS to clustered OWNRS, thereby reducing the financial
burden to service recipients.

As shown in Table 3-8, if an OWNRS system is shared by four EDUs, the
cost would range from \$2,500 to \$8,200 with a monthly cost of \$63 to
\$118, which includes operation and maintenance costs and amortized
system capital costs. Under Alternative 3, FEMA would help fund the use
of these systems in clustered arrangements with the actual number of
EDUs per cluster to be determined at the project-specific level. In
addition, costs to larger wastewater generators, such as businesses,
would potentially be reduced from those shown in the table, by the
purchase of larger capacity systems, thus benefiting from economy of
scale.

The actual wastewater management costs per EDU as a result of on-site
treatment upgrades are difficult to quantify because they would depend
on the final system capital costs, the number of EDUs served per
cluster, the amount of State and Federal grants and contributions, and
the chosen financing options. In addition, the cost of the land on which
the system would be installed would need to be accounted for. With the
availability of FEMA funds to substantially reduce the system capital
costs and/or abandonment and lateral costs of a clustered OWNRS, the
monthly wastewater costs to service recipients are not expected to
greatly exceed the 2% of MHI (\$75 per month) affordability threshold
described in Section 3.6.3.1.2. More specific details on costs and taxes
relative to the installation of OWNRS systems would be included in the
project-specific SERs.

### Public Health

#### Affected Environment

FDH maintains a wide range of public health statistics for the 67
counties in the State of Florida. Monroe County ranks highest in the
State of Florida for Acquired Immune Deficiency Syndrome (AIDS) per
100,000 persons for the period 1998 to 2000 (FDH, 2001b). Hepatitis A
ranks fourth, but examining all **enteric** diseases, which includes
campylobacterioisis, shigellosis, salmonellosis, giardiasis, and
Hepatitis A, Monroe County is in the bottom third of total counties for
incidents of infections per 100,000 persons for the period 1998 to 2000.
Monroe County ranks less than the State average for Hepatitis B for the
period 1998 to 2000, and there are no known cases of Cholera in the last
ten years. In 1999, the major cause of death in Monroe County was
cancer, at 714 persons (FDH, 2001b).

Contaminated water in Monroe County has led to many beach
closings/advisories in recent years. In 1999, there were 30 days with
either a beach closing or advisory with the number jumping to 60 days in
2000 (EPA, 2001b). There has been evidence of microbial indicators of
sewage pollution such as fecal coliform, *Enterococci*, and *Clostridium
perfringens* in the nearshore and offshore waters throughout the Keys
(Paul et al., 1995a; Paul et al., 1995b; Paul et al., 1997). These
enteric microbes were linked to septic tanks and cesspits in several
recent studies. In one study, viral tracers placed in shallow Class V
injection wells in Key Largo and the Middle Keys appeared in 8 to 11
hours in ground water and 23 to 53 hours in marine waters (Paul et al.,
1995b; Paul et al., 1997).

In another study, none of 19 sites tested throughout the Keys violated
ambient water quality standards for fecal coliform. However, 79% of the
sites tested positive for the presence of enteroviruses, 63% of sites
tested positive for Hepatitis A, and 10% of the sites tested positive
for Norwalk viruses (Griffin et al., 1999).

The influx of polluted water from on-site systems to groundwater, canal,
and nearshore marine waters varies seasonally. In one study, nutrient
concentrations of groundwaters were twice as high during the winter
compared to summer, while nutrient concentrations of surface waters were
twice as high during the summer. The increased pollution to inland and
nearshore waters was attributed to the higher maximum tides and
increased hydraulic head during the summer, wet season, which increases
the rate of exchange between groundwaters and inland and nearshore
waters (Lapointe et al., 1990). The movement of microbes is expected to
follow this pattern of increased flow from groundwater to nearshore
water during the summer months and decreased flow during the winter
months.

The presence of enteric microbes in canals and nearshore marine waters
can pose a health risk if ingested while swimming or eating contaminated
seafood (Paul et al., 1995a, Caffry, Pers. Comm., 2001). A study
published in June 2000 estimates that about one third of the
participants in the 23^rd^ Annual Swim Around Key West event held on
June 12, 1999 reported at least one illness as a result of swimming in
contaminated nearshore marine waters (Nobles et al., 2000). This was
based on a total of 192 respondents (55%) out of 350 race participants.
As part of the study, the researchers collected water samples over a
four-day period and found that levels of *Enterococcus* and fecal
coliform ranged from low to extremely high levels over that period.
Although the study did conclude that demonstrable health effects were
related to poor water quality around the Key West area, the reliability
of its conclusion has been called into question because swimmers were
asked to recall health effects suffered five months after the swim event
occurred. An additional study conducted in the United Kingdom in 1998
assessed the severity of illnesses associated with swimming in
recreational waters contaminated with domestic sewage. This study found
that an average duration of illness ranged from about 4 to 8 days, 4.2
to 22.2% of those affected sought medical treatment, 7.0 to 25.9%
reported loss of at least one day of normal daily activity, 34.5%
experienced gastroenteritis and 65% of the participants experienced ear
infections (Fleisher et al., 1998 as cited in Nobles et al., 2000).

It should also be noted that fecal coliform is not considered a truly
viable indicator of human sewage because it is found in dogs, birds, and
other animals, and there have been cases where fecal coliform has been
isolated in tropical waters far from human contact (Griffin et al.,
1999). In comparison to four other counties in southern Florida, Monroe
County ranks third in cases of enteric disease counts per 10,000
population and 1,000 children under 6.

**Table 3-10: Enteric Disease Counts of Monroe and Neighboring Counties
(1999)**

+------------------+----------+------------+------------+------------+
|                  | **       | *          | **Dade**   | *          |
|                  | Monroe** | *Collier** |            | *Broward** |
+------------------+----------+------------+------------+------------+
| Reported Cases   | 4.12     | 9.39       | 4.90       | 3.50       |
| per 10,000       |          |            |            |            |
| population       |          |            |            |            |
+------------------+----------+------------+------------+------------+
| Reported Cases   | 1.61     | 4.95       | 2.25       | 1.57       |
| per 1,000        |          |            |            |            |
| children under 6 |          |            |            |            |
| years of age     |          |            |            |            |
+------------------+----------+------------+------------+------------+
| Source: Florida  |          |            |            |            |
| Department of    |          |            |            |            |
| Health, 2001     |          |            |            |            |
|                  |          |            |            |            |
| Note: Statistics |          |            |            |            |
| are based on     |          |            |            |            |
| reported cases   |          |            |            |            |
| only and do not  |          |            |            |            |
| likely include   |          |            |            |            |
| tourists that    |          |            |            |            |
| may represent a  |          |            |            |            |
| high proportion  |          |            |            |            |
| of transient     |          |            |            |            |
| beach users in   |          |            |            |            |
| Monroe County    |          |            |            |            |
+------------------+----------+------------+------------+------------+

#### Environmental Consequences

##### Alternative 1---No Action Alternative

Without FEMA funds for wastewater management, Monroe County project
applicants would still have to reach Florida Statutory Treatment
Standards by 2010. It is likely that water quality conditions nearshore
and offshore, as this relates to public health, would improve but at a
slower rate than with FEMA funding. The available data does not
conclusively demonstrate instances of infection or health problems
specifically related to groundwater or offshore contamination caused by
present sewage treatment practices. However, as described in Section
3.6.4.1, studies indicate the presence of viruses and bacteria
associated with human sewage; therefore, it may be assumed that public
health risks exist.

If this alternative were chosen, the potential for public health risks
would continue in the short term due to a possible lag in upgrading
sewage treatment systems. However, the health risk for bacteria and
viruses would presumably decline with the implementation of specific
wastewater treatment processes. Shallow injection well use would include
biological treatment, such as an Immersed Membrane Bioreactor (IMB)
process, which disinfects effluent through the addition of liquid
chlorine or UV disinfection, and has demonstrated a virus removal
effectiveness of greater than 99.99% (Islamorada, 2001a). There are two
specific levels of disinfection as defined by FDEP: basic disinfection
and high-level disinfection. As defined in chapter 62-600 of the F.A.C.,
Regulations of Domestic Wastewater Facilities, basic disinfection
results in water with no more than 200 fecal coliform values per 100 ml
of sample, while high-level disinfection results in water with fecal
coliform values below detectable limits per 100 ml of sample. In
compliance with F.A.C. 62-600, shallow injection wells (Class V) are
required to meet high-level disinfection requirements.

Health concerns have been raised regarding the use of liquid chlorine
for the disinfection of wastewater. Nevertheless, only about 30 of the
centralized domestic wastewater treatment facilities in the State of
Florida use UV radiation as their primary disinfection method, and the
remaining 2,500 employ chlorination (Sawicki, Pers. Comm., 2002).
Although it is a hotly debated topic, chlorine has not been found to
cause cancer in animals and is not classified by the EPA or U.S.
Department of Health and Human Services for carcinogenicity (EPA, 1994b
and EPA, 1994a, and Dunnick et al., 1993). However, byproducts such as
trihalomethanes (THMs), which are formed as a result of chlorination,
have been linked to an increased risk of bladder and rectal cancer (EPA,
1994d; Komulainen et al., 1997; Dunnick, 1993; Morris et al., 1992). The
EPA has known since the 1970s that THMs, specifically chloroform, are
carcinogenic to animals (FDEP, 2001b). Because of the known risks, THMs
are closely regulated and monitored by FDEP and EPA. Under Florida
regulations (F.A.C., Rule 62-550.514), community water supply systems
that serve at least 10,000 people are required to monitor total
trihalomethanes (TTHMs) quarterly (FDEP, 2001b). According to David
York, Coordinator of Florida's Wastewater Reuse Program, there is has
not been a major problem with THMs; on average, he sees a 50/50 split
between plants violating THM limits and those not reaching the limit
(York, Pers. Comm., 2002). In general, the State of Florida concedes in
its Administrative Code that it is aware of the risks associated with
chlorination and even encourages the use of alternative disinfection
methods (FDEP, 2001c).

##### Alternative 2 -- Centralized Wastewater Treatment Plant

FEMA would provide funding for upgrade or construction of new community
and regional WWTPs at select locations throughout the Keys. With FEMA
funding, the project applicant would likely be able to improve
wastewater conditions at a more efficient rate.

It is expected that risks to public health would be reduced. The
centralized WWTP would eliminate the use of cesspits and septic tanks
within the service area, which contribute to bacterial and viral
contamination to nearshore and offshore waters. However, the extent of
improvement is difficult to determine due to the lack of available data
related to groundwater or nearshore marine contamination, and the actual
benefits of replacing cesspits and septic tanks. Even without specific
data, the health risk for bacteria and viruses is expected to decline
greatly with the implementation of wastewater treatment processes that
meet Florida Statutory Treatment Standards. The level of disinfection
depends on the method of disposal and is further discussed below.

###### [Collection Options 1 and 2]{.underline} {#collection-options-1-and-2-1 .unnumbered}

Either option would provide beneficial impacts such as those described
in Section 3.6.4.2.1.

###### [Disposal Option 1 -- Wastewater Injection wells]{.underline} {#disposal-option-1-wastewater-injection-wells-1 .unnumbered}

Injection wells permitted as Class V require high-level disinfection
under F.A.C. 62-600.540. To achieve this level of disinfection, the WWTP
would include biological treatment, such as an IMB process that
disinfects effluent through the addition of liquid chlorine or
ultraviolet light and has demonstrated a virus removal effectiveness of
greater than 99.99% (Islamorada, 2001a). Treatment to this level of
disinfection would effectively reduce sewage-related public health risks
for that service area.

###### [Disposal Option 2 -- Wastewater Reuse]{.underline} {#disposal-option-2-wastewater-reuse-7 .unnumbered}

Selection of this disposal option is not expected to result in long-term
adverse effects on public health because the effluent would comply with
FDEP regulations and F.A.C. 62-600 and 62-610 that require basic or high
level disinfection depending on application before being used in a
public setting. Effluent disinfection would likely be accomplished
through the use of chlorine or UV treatment (Teague, Pers. Comm., 2001).

##### Alternative 3 -- On-Site Treatment Upgrades

Under Alternative 3, OWTS such as cesspits and septic tanks with
drainfields would be converted to clustered OWNRS to improve wastewater
management. The construction of the OWNRS would eliminate the use of
cesspits and septic tanks, which contribute to bacterial and viral
contamination to nearshore and offshore waters (Paul et al., 1995a).
Under FDH regulations and F.A.C. 64-E6, systems that treat effluent
quantities less than 10,000 gpd and use shallow injection wells are
required to disinfect effluent by chlorination or some other
disinfection method approved by FDH. Clustered OWNRS that dispose of
quantities of effluent in excess of 10,000 gpd through injection wells
are regulated through FDEP and are required to meet high-level effluent
disinfection. Compliance with these regulations would effectively reduce
sewage-related public health risks for that service area.

## Demographics and Environmental Justice

EO 12898 (Environmental Justice) requires Federal agencies to make
achieving environmental justice part of their mission. Agencies are
required to identify and correct programs, policies, and activities that
have disproportionately high and adverse human health or environmental
effects on minority and low-income populations. EO 12898 also tasks
Federal agencies with ensuring that public notifications regarding
environmental issues are concise, understandable, and readily
accessible. Socioeconomic and demographic data were studied to determine
if minority or low-income persons have the potential to be
disproportionately and adversely affected by the alternatives.

### Affected Environment

#### Population and Race

Monroe County has a permanent population of about 80,000 people. It
comprises an approximately 997-square-mile area that includes the
communities of Key Largo, Tavernier, Bay Point, the Village of
Islamorada, and the Cities of Marathon and Key West. Key West has a
population of about 25,000 people, approximately 32% of the total county
population (U.S. Census, 2000a). Between 1990 and 2000, the population
of Monroe County increased 2%, while the population of the State of
Florida increased 23.5% during the same time (U.S. Census, 2000a).
Population density in the Keys is estimated to be about 79.8 persons per
square mile. For comparison, the average population density in the State
of Florida is estimated to be 296.4 persons per square mile (U.S.
Census, 2000a).

Because of the large number of visitors to the Keys, the functional
population consists of both permanent and seasonal residents. Monroe
County estimated the sum of seasonal and permanent residents to be about
159,000 people, which represents the maximum number of people in the
Keys on any given evening (Monroe County, 2000b). The functional
population of the incorporated and unincorporated areas of Monroe County
is expected to increase by an average of about 4% between 2000 and 2010
(Table 3-11), to approximately 165,000 people.

Table 3-11: Functional Population of Monroe County (1990-2015)

  ------------------- ----------------- -------------- --------------------
  **Year**            **Functional      **Numerical    **Percent Change**
                      Population**      Change**       

  1990                149,348           \*             \*

  1995                154,255           4,907          3.29%

  2000                159,113           4,857          3.15%

  2005                162,041           2,929          1.84%

  2010                164,769           2,727          1.68%

  2015                165,366           597            0.36%

  Source: (Monroe                                      
  County, 2000b)                                       
  ------------------- ----------------- -------------- --------------------

In a comparison study of the counties of the South Florida region (i.e.,
Broward, Miami-Dade, and Monroe), Monroe County had the lowest rate of
growth at 2% compared to 29% and 16% for Broward and Miami-Dade
Counties, respectively. The City of Key West ranked 36 out of 59
municipalities in the South Florida region in terms of absolute
population growth with a 2% rate of growth between 1990 and 2000 (SFRPC,
2001). Additional information pertaining to projected growth, land use,
and planning is in Section 3.10.

Of the total population of Monroe County, 90.7% identified themselves as
White, 4.8% Black or African-American, 0.4% American Indian and Alaska
Native, 0.8% Asian, 1.5% of other race, and 1.8% of two or more races.
About 15.8% identified themselves as persons of Hispanic or Latino
origin. For comparison, of the total population of the State of Florida,
78.0% identified themselves as White, 14.6% Black or African-American,
0.3% American Indian and Alaska Native, 1.7% Asian, 0.1% Native Hawaiian
and Other Pacific Islander, 3.0% of other race, and 2.4% of two or more
races. About 16.8% identified themselves as persons of Hispanic or
Latino origin (U.S. Census, 2000a).

As part of preparation of this draft PEA, a spatial analysis using
Geographic Information Systems (GIS) was conducted to determine the
geographical distribution of minority populations in Monroe County
(Figure 3-8). U.S. Census Blocks within Monroe County were evaluated for
the percent of the population that exceeded 22% persons of non-white
ethnicity (i.e., populations that exceed the average percent of
minorities for the State of Florida at-large). Additionally, Census
Blocks that had populations exceeding 50% persons of non-white ethnicity
were identified as areas where non-white populations composed the
majority of the population.

One Census Block in the City of Marathon has a population that is
greater than 22% minorities. Several Census Blocks in Key West area also
have minority populations that are greater than the Florida State
average of 22% non-white persons. Two Census Blocks in Key West have
populations that are more than 50% of non-white ethnicity.

#### Income and Poverty

According to the 2000 Census, the 1999 MHI for Monroe County was
\$42,283 (U.S. Census, 2000b), which was about 13% greater than the MHI
for the State of Florida (U.S. Census, 2001a). Of the total Monroe
County population in 1999, approximately 10.2% of individuals fall below
the U.S. Census Bureau's poverty threshold (U.S. Census, 2001b). This
poverty threshold is set for the entire nation and, with the exception
of Hawaii and Alaska, is not adjusted for local cost-of-living
deviations. For the year 2001, the poverty threshold was set at \$13,738
for a household of three people (U.S. Census, 2001b). In an area like
the Keys where the cost of living is higher than the national average,
\$13,738 buys less than elsewhere, effectively making a household near
the poverty threshold in the Keys poorer than the same household in an
area where the cost of living is lower. In fact, according to the Monroe
County Housing Authority, which uses HUD MFI-based income levels to
administer its assistance programs, surviving in the Keys at such a low
income is almost impossible (Casey, 2002).

FIGURE 3.8 -- MINORITY STATUS

Accordingly and pursuant to EO 12898, FEMA has adopted HUD's income
levels for its low income assistance programs, as they are administered
by the Monroe County Housing Authority for the purpose of evaluating and
mitigating FEMA-funded wastewater project economic effects on low-income
populations. *Low-income* is defined as less than 80 percent of MFI and
*very-low-income* is defined as less than 50 percent of MFI. In 2002,
MFI was estimated at \$55,100, *low-income* was \$39,650 and
*very-low-income* was \$24,800. Appendix J contains additional
information on the HUD income limits for the *very-low-* and
*low-income* designations.

Before adopting HUD's income levels, consideration was given to the
policy/methodology used by other federal agencies, such as the U.S.
Department of Health and Human Services, U.S. Environmental Protection
Agency, and U.S. Department of Energy; to determine low income
ability-to-pay and levels of assistance. There are several important
advantages to using the income indicator chosen. First, the dollar value
of MFI is already projected (calculated) and published by the Department
of Health and Human Services (HHS) on an annual basis. Second, MFI is
calculated at the county level and incorporates the Keys's economic
demographics. And lastly, the county level MFI is published with
adjusted values for various family sizes and qualification standards and
is currently used by the Housing Authority and the Department of Health
for their assistance programs.

Finally, because the most apparent effect on a low income population is
economic in this case, it is more appropriate to use the individual
household rather than a 'population' as the unit used for discussion. An
individual low income household within a project service area would
incur project effects and consequently would trigger compliance with EO
12898, for FEMA funded wastewater projects. The typical approach under
EO 12898 is to identify a relatively larger low income 'population' in
proportion to an affected area's population demographics, to discuss
project effects.

#### Wastewater Management Costs and Affordability for Keys Lower-Income Residents

Section 3.6.3.1.2 describes wastewater management costs and establishes
an affordability threshold (near 2% of MHI) above which costs may be
considered unaffordable and unreasonable. This affordability threshold
should be applied to households in the Keys whose incomes approximate
Monroe County MHI; however, it is not appropriate for determining what
constitutes affordable wastewater management costs for households with
incomes much below the median.

For purposes of administering Federal housing assistance to low-income
families, HUD has established a set of income limits that designate
three income levels below the median. These levels use MFI instead of
MHI and are designated as *low-income, very-low-income,* and *30% of
MFI*. To administer their programs more accurately, HUD makes annual
projections of MFI by county and adjusts for family size.

The Monroe County Housing Authority currently uses the first two tiers
of the HUD income limits to administer its local assistance programs and
notes that, in Monroe County, very few families fall into the lower
tier. The Housing Authority notes it is almost impossible to survive
financially in the Keys at such low incomes, therefore people in those
tiers typically choose to live in other counties.

Table 3-12: Discretionary Income of Low-Income Residents -- 2001/2002

+--------------------+---------+----------+--------------+------------+
| **MFI for family   | *       | *        | **Estimated  | **Monthly  |
| of three**         | *Yearly | *Monthly | Average      | Dis        |
|                    | I       | Net      | Monthly      | cretionary |
|                    | ncome** | Inco     | Exp          | Income**   |
|                    |         | me^1.^** | enses^2\ ^** |            |
+--------------------+---------+----------+--------------+------------+
| > ***Low-Income*** | \       | \$2,808  | \$2,050      | \$758      |
|                    | $39,650 |          |              |            |
+--------------------+---------+----------+--------------+------------+
| > ***              | \       | \$1,756  | \$2,050      | \$0        |
| Very-Low-Income*** | $24,792 |          |              |            |
+--------------------+---------+----------+--------------+------------+
| ^1^ Net income     |         |          |              |            |
| incorporates 15%   |         |          |              |            |
| Federal tax rate   |         |          |              |            |
+--------------------+---------+----------+--------------+------------+
| ^2^ See Table 3-6  |         |          |              |            |
+--------------------+---------+----------+--------------+------------+

[]{.mark}

Table 3-11 above shows the 2002 HUD income levels for a family of two
adults and one child in Monroe County (HUD, 2002). The table illustrates
that a household of three at the *low-income* level has a discretionary
income of \$758 a month after basic expenses, the *very-low-income*
level a discretionary income of \$0 a month. As noted in Section
3.6.3.1.2, these basic expenses do not include other potential monthly
costs such as transportation expenses. Although these figures are very
rough estimates, they support the Housing Authority's determination that
the cost of living in the Keys is prohibitively high for families below
the *very-low-income* designation. It is likewise clear that unmitigated
additional wastewater management costs would result in a highly
disproportionate and adverse economic impact to the low-income service
recipients.

Environmental Consequences

#### Alternative 1 -- No Action Alternative

The project applicants would not receive FEMA funding to help meet
Florida Statutory Treatment Standards by the year 2010. As described in
Section 3.6.3, Local Fees and Taxes, implementation of the No Action
Alternative has the potential to result in higher wastewater management
costs than would be expected with the benefit of FEMA funding.

Given the assumptions stated in Section 3.7.1.3, households at or below
the *low-income* level would incur financial hardship if wastewater
management costs increase to levels that approximate the affordability
thresholds of 2% (\$75/month). If unmitigated, increased wastewater
management costs would disproportionately and adversely affect
*low-income* populations, as the increased financial burden would
represent a greater percentage of their discretionary income in
comparison to service recipients whose incomes approximate the median.

Monroe County came to this same conclusion when analyzing the impact of
increased wastewater management costs on the community of Little Venice.
Given the FKAA's future estimated monthly costs for wastewater service,
Monroe County concluded that the cost increase would cause a major
financial hardship on *low-income* and *very-low-income* households. In
order to help mitigate the impacts of this cost increase, the Housing
Authority has applied for and received Federal grant money through HUD's
Community Development Block Grants. To determine how best to allocate
the money among *low-* and *very-low-income* service recipients, the
Housing Authority will be conducting a door-to-door survey of household
income levels in the Little Venice community. As of March 2002, survey
results were not complete, and no allocation formula had been decided
upon (Berard, Pers. Comm., 2002).

As described in Section 3.6.3.1, some funding recently existed to assist
in converting cesspits and septic tanks to OWNRS through the Monroe
County CIEGP. This program provided grants that covered 62% or more of
the system capital costs. Residents whose homes had an assessed value of
less than \$100,000 received an additional grant of \$3,000 (over the
62% grant amount), or about 84% of the total system capital cost of an
OWNRS. Those with homes assessed between \$100,000 and \$200,000
received an additional grant of \$1,000, or 69% of the total system
capital cost of these systems (Monroe County, 2000a). Although this
funding has run out, the county hopes to have more funding available in
the near future. Most important to note is that this program is only
available to homeowners and may not offset potential increased costs to
renters.

Funding to assist low-income households with meeting wastewater
treatment standards is also available from State and Federal agencies,
and additional funding may become available through new grants and
initiatives before the Florida Statutory Treatment Standards take effect
in 2010 (Smith, Pers. Comm., 2001). Additional sources of assistance may
include the Florida State Revolving Fund and the Florida Department of
Community Affairs (DCA) Community Development Block Grant program
(Smith, Jetton, Pers. Comm., 2001). Beyond the programs discussed above,
Appendix H contains a list of funding options, some of which could be
tailored to assist low-income households. The exact contribution from
these funding sources would depend on the final costs of the system
improvements, the number of individuals served, the total amount of
State and Federal grants and contributions, and the details of the
chosen financing options, including applicable repayment terms.

The implementation of wastewater management projects under the No Action
Alternative would likely result in water quality improvements to shallow
aquifers, canals, and nearshore marine waters. The reduction of fecal
contamination and nutrient pollution would likely reduce adverse effects
on public health. Low-income and minority populations are expected to
benefit from these wastewater management improvements to the same degree
as other demographic populations in the Keys. No disproportionately high
or adverse effects to minority populations are anticipated, unless they
are also low-income, which is discussed above.

Although the No Action Alternative has the potential to result in
disproportionately high and adverse impacts to low-income populations,
FEMA would not be the Federal action agency; therefore, FEMA would not
be required to undertake activities related to compliance with EO 12898.

#### Alternative 2 -- Centralized Wastewater Treatment Plant Alternative

The project applicant would construct new or upgrade existing WWTPs at
selected locations in the Keys. As described in Section 3.6.3, Local
Fees and Taxes, implementation of the Centralized Wastewater Treatment
Plant Alternative has the potential to result in higher wastewater
management costs. Potential effects on low-income and minority
populations would be similar to those described under the No Action
Alternative. No disproportionately high and adverse effects to minority
populations are anticipated. This alternative would similarly affect the
entire service area population, regardless of demographics, unless
minorities are also low-income, which is discussed above. The physical
siting of WWTP and other wastewater facilities is not expected to cause
highly disproportionate or adverse effects to minority and/or low-income
populations in the Keys. Noise and visual resources impacts associated
with the siting of WWTPs are expected to be negligible as discussed
further in Section 3.11. Unmitigated increased wastewater management
costs to low-income service recipients as a result of this alternative
would cause disproportionately high adverse effects.

In light of EO 12898 and NEPA, the following low-income household
assistance guidelines would apply to FEMA-funded projects. This
assistance would be in addition to the basic economic benefit the
service area's population would receive from the grant award.

In developing these guidelines, emphasis was placed on the use of
available local economic data, practical implementation for FEMA
applicants, applicability to the various proposed projects, and
consistency with programs.

The guidelines specify the basic qualifying criteria and amount of
Federal assistance available to service area residential applicants and
is based on HUD's *very-low-income* and *low-income* levels. The balance
of wastewater management costs would be paid by the service recipient.
The assistance is for system capital costs and lateral costs only. No
assistance is provided here for the monthly operation and maintenance
costs, as these are long-term cost-of-living expenses. An example of the
guidelines can be found in Appendix J, along with the HUD income limits
for Monroe County for 2002.

The qualifications for the assistance guidelines are:

-   Property Owner(s) must verify ownership of the residential property.

-   Property Owner(s) must verify that the property has qualified (or
    application made) for eligibility for Florida's Homestead Exemption
    for declaration of primary residence.

-   Property Owner(s) must verify qualified family income is within the
    established HUD MFI as either *very-low-income* (0 to 50% of MFI) or
    *low-income* (50 to 80% of MFI).

Assistance Guidelines

  ----------------------------------- -----------------------------------
  **Income Levels**                   **Amount of Assistance**

  *Very-low-income* Qualified Family  90% of System Capital Costs

  *Very-low-income* Qualified Family  90% of Existing System Abandonment
                                      costs and private property lateral
                                      installation up to an allowance
                                      amount of \$3,000

  *Low-income* Qualified Family       70% of System Capital Costs

  *Low-income* Qualified Family       70% of Existing System Abandonment
                                      costs and private property lateral
                                      installation up to an allowance
                                      amount of \$3,000
  ----------------------------------- -----------------------------------

It should be noted that the above guidance is a minimum level of
assistance that FEMA applicants would be required to achieve to mitigate
adverse effects on low-income households. The applicants, at their own
discretion, may further reduce these costs. Additionally, where extreme
conditions exist related to abandonment costs and/or private property
lateral installation costs create extraordinary hardship for qualifying
low-income households, the FEMA applicants shall establish a contingency
fund to further reduce costs.

In light of the above assistance guidelines, additional wastewater
management costs from Alternative 2, exclusive of monthly O&M costs, are
not anticipated to result in highly disproportionate and adverse effects
to qualifying low-income households. It should be noted that low-income
renters in the service areas may be highly and disproportionately
adversely affected if landlords increase rents to cover additional
wastewater management costs. Although FEMA does not have specific
requirements under EO 12898 to assist low-income renters, they may seek
remedy through locally available assistance programs, such as the Monroe
County Housing Authority. In the project-specific SER, effects on
low-income populations in the service area would be further considered
as needed.

#### Alternative 3 -- On-Site Treatment Upgrades

The project applicants would upgrade the selected service area's
existing on-site wastewater treatment systems by installing clustered
OWNRS serving multiple EDUs. This alternative also would require
compliance with EO 12898 because of FEMA funding. As with Alternative 2,
no disproportionately high adverse effects to minority populations are
anticipated since service recipients would be similarly affected,
regardless of demographics. However, if minority populations are also
low-income, they could incur disproportionately high adverse effects if
costs are unmitigated. The physical siting of clustered OWNRS is also
not expected to cause highly disproportionate or adverse effects to
minority and/or low-income populations in the Keys. Noise and visual
resources impacts associated with the siting of clustered OWNRS are
expected to be negligible as discussed further in Section 3.11.

As described in Section 3.6.3, Local Fees and Taxes, implementation of
this alternative has the potential to result in wastewater management
costs that are higher than present, and possibly even higher than
Alternative 2. Accordingly, and based on the ability-to-pay information
presented in Section 3.7.1.3, adverse economic effects to low-income
households in the service areas could be even more disproportionate than
those described under Alternative 2. However, the availability of FEMA
funding under this alternative would reduce the cost of wastewater
treatment improvements to service recipients. Moreover, the additional
assistance guidelines for low-income households outlined in Section
3.7.1.5 would also apply under this alternative. The qualifying
criteria, and type and level of assistance would the same. Consequently,
highly disproportionate adverse effects to qualifying low-income service
recipients are not anticipated from this alternative; however, as
described in Alternative 2, low-income renters could incur
disproportionately high costs under this alternative.

## Hazardous Materials and Wastes

### Affected Environment

Hazardous Waste is defined by RCRA as a solid waste, or combination of
solid wastes, which because of quantity, concentration, or physical,
chemical, or infectious characteristics, may cause, or significantly
contribute to, an increase in death rate or an increase in serious
irreversible, or incapacitating reversible, illness or pose a
substantial present or potential hazard to human health and the
environment when improperly treated, stored, transported, or disposed
of, or otherwise managed. Although defined as a solid, according to
RCRA, a solid waste can be a solid, a semi-solid, a liquid, or a
contained gas (EPA, 2001b). Waste is considered hazardous if it is found
in the list published in the 40 CFR Part 261. If it is not identified on
the list, it may be hazardous if it is ignitable, corrosive, reactive,
or toxic.

Hazardous materials and wastes are regulated in Florida via a
combination of federally mandated laws and region-specific laws
developed by FDEP Division of Waste Management, Bureau of Solid and
Hazardous Waste. The hazardous waste statutes are part of the Florida
Public Health section, Chapter 403, Resource Recovery and Management.
Portions of Title 40 CFR Parts 260-271 are incorporated into F.A.C. Rule
62-730.

Monroe County has three hazardous materials collection centers located
at Cudjoe Key Transfer Station, Key Largo Recycling Yard, and Long Key
Transfer Station. Most wastewater sludge and septic waste generated in
the Keys is currently hauled to one of three transfer facilities. They
do not accept explosives, asbestos, biohazards, or radioactive wastes.
Wastewater sludge is not disposed of in the Keys (Bergin, Pers. Comm.,
2001). From these transfer stations, the sludge is hauled to a regional
wastewater treatment facility in Miami-Dade County for treatment and
eventual disposal to a remote agricultural land application site.

New State regulations pertaining to all forms of wastewater solids
disposal, except landfilling, took effect in 1998. These regulations
mirror the 40 CFR Part 503 Sewage Sludge Regulation published in 1995 by
the EPA. Both sets of regulations address pathogen reduction, vector
attraction reduction, and heavy metal limits. The regulations specify
two alternative levels of pathogen reduction: Class A or Class B. Class
A biosolids (i.e., WWTP residual solids that have been stabilized and
made into a product that can be beneficially recycled) can be applied
via bulk application to public access areas, including private lawns and
home gardens; Class B biosolids are prohibited from such application.
Both Class A and Class B biosolids can be applied to agricultural land,
but more stringent site restrictions are imposed when Class B biosolids
are applied.

Phase I Environmental Site Assessments would be completed at each
project site to characterize the recognized environmental conditions
before construction activities ensue. For WWTP project sites, a Phase I
Environmental Site Assessment would be conducted in accordance with
American Society of Testing and Materials (ASTM) standard E 1527-97. The
Phase I Environmental Site Assessment is to visually identify and record
any obvious existing, potential, or suspect conditions resulting from
the use, handling, and disposal of hazardous substances at the site or
adjacent site(s), which may pose an environmental liability to, or
restrict the use of, the subject property. A Phase I Environmental Site
Assessment would be conducted for each site as part of the SER, and the
presence and risk of hazardous materials would be evaluated based on
specific site conditions and proposed designs.

### Environmental Consequences

#### Alternative 1 -- No Action Alternative

No hazardous waste impacts are expected because hazardous waste is not
allowed in the sewage waste stream. However, there may be environmental
conditions (e.g., leaking underground storage tanks) at the sites
selected for WWTP construction or OWNRS upgrades that could result in
adverse effects if not remediated prior to ground-disturbing
construction activities. The potential for this impact is unknown.
Wastewater sludge waste from the Keys would continue to be hauled to a
transfer facility and taken to a wastewater treatment facility in
Miami-Dade County for treatment.

####  Alternative 2 -- Centralized Wastewater Treatment Plant Alternative

FEMA would provide funding to aid in the construction of new community
and regional WWTPs throughout the Keys. With the help FEMA funding, the
project applicant would likely be able to improve wastewater conditions
at a more efficient rate.

For WWTPs with capacities of about 100,000 gpd or less, decanted sludge
would be temporarily stored in an aerated holding tank on-site, and the
liquid sludge would be hauled by truck to one of the three Monroe County
Solid Waste Transfer Stations. Miami-Dade has committed to accepting
increased loads and has the capacity to accommodate the expanded waste
quantity from Monroe County (Williams, Pers. Comm., 2001).

For larger WWTPs, the sludge would be processed through belt filter
press dewatering, Class B lime stabilization, and then the dewatered
cake would be hauled to a remote agricultural land application site
outside of Monroe County, in the Lake Okeechobee area of South Florida,
as per MCSWMP. This would be beneficial if processed and applied to
agricultural land by reducing the amount disposed in landfills.

Effluent is tested once a month and a licensed operator is required to
report any WWTP operating problems immediately. Hazardous materials that
enter a WWTP are likely to be caught immediately by monitoring stations
as required by FDEP regulations (Rios, Pers. Comm., 2001).

The most common hazardous materials that enter the systems are grease
and typical household cleaning products (Rios, Pers. Comm., 2001).
Inadvertent disposal of hazardous wastes in wastewater effluent is more
likely to occur in smaller plants than larger plants because the
materials are usually more diluted in the larger plants. Hazardous
material that enters a WWTP has the potential to kill the biological
component that treats the waste, and is normally pumped out and sent to
a larger treatment plant for reprocessing. There are three programs
administered by FDEP: Conditionally Exempt Small Quantity Generators,
and Regulated Small Quantity Generators and Large Quantity Generators
that were created to educate the public and give detail on what is
hazardous waste. The FDEP is implementing these public education
programs to reduce the potential for hazardous materials to enter
wastewater effluent.

##### [Collection Options 1 and 2]{.underline} {#collection-options-1-and-2-2 .unnumbered}

FEMA may fund the purchase of lands required for new pump stations and
piping right-of-ways. Prior to acquiring properties, a Phase I
Environmental Site Assessment would be completed, as part of preparation
of the SER, to determine whether any recognizable environmental
hazardous material and/or waste exist at or around the site(s). These
results and recommended remedial and/or mitigation measures would be
presented in the SERs.

##### [Disposal Option 1 - Shallow Injection Wells]{.underline} {#disposal-option-1---shallow-injection-wells .unnumbered}

Wastewater injection well effects would be similar to those discussed in
Section 3.8.2.1.

##### [Disposal Option 2 - Wastewater Reuse]{.underline} {#disposal-option-2---wastewater-reuse-1 .unnumbered}

Reuse systems require full storage or backup disposal systems whenever
treatment requirements are not met (Monroe County, 2000a). Since a
certain treatment standard must be met before treated effluent would be
applied, this option is not expected to result in the release of or
effect on hazardous materials.

#### Alternative 3 -- On-Site Treatment Upgrades

OWTS such as cesspits and septic tanks with drainfields would be
converted to clustered OWNRS to improve wastewater management. This
system proposes biological nitrogen removal coupled with a
physical/chemical phosphorus removal system and either a shallow
injection well or SDI. The potential effects of inadvertent hazardous
materials disposal are discussed under the environmental consequences of
Alternative 2 in Section 3.8.2.2.

Septic tank sludge from the clustered OWNRS would continue to be hauled
to a transfer facility and then hauled to a WWTP in Miami-Dade County
for treatment and disposal for eventual agricultural land application in
compliance with disposal regulations promulgated by FDEP.

## Infrastructure

### Traffic and Circulation

#### Affected Environment

The Keys consist of many islands connected by 42 bridges along over 100
miles of US Highway 1. This is the main road in the Keys and functions
as an arterial, collector, and Main Street. US 1 is the most important
road in Monroe County but there are several smaller roads serving the
local communities. US 1 is about 112.5 miles long in Monroe County, with
about 19 miles of bridges, extending from Dade County border to Fleming
Street in Key West. About 108 miles and 41 bridges of US 1 run through
areas that are unincorporated. US 1 and South Roosevelt Boulevard are
the only State-maintained roads in Monroe County. The county maintains
about 450 miles of secondary roads, including 1.6 miles of bridges that
link US 1 to the residential areas. The Florida Department of
Transportation (FDOT) classifies all public roads based on the type of
service the road provides, found in Chapter 335.04 of the Florida
Statutes. The roads are classified into three categories: arterial,
collector, and local (Monroe County, 1997).

Traffic capacity limitations are found along four segments of US 1. The
conditions of the roadway are based on levels of service (LOS). This is
defined by the 1985 Highway Capacity Manual as a qualitative measure
describing operational conditions within a traffic stream, and their
perception of motorists. Roadway LOS is ranked from A (the best) to F
(the worst), with C being the average. Plantation, Upper Matecumbe Key,
Lower Matecumbe Key, and Big Pine Key did not meet LOS C and are
considered to be critical growth constraints. The improvements needed
vary and include: widening roads, restriping to provide more left lanes,
traffic signal re-timing, fencing to control Key deer crossing, and
highway overpasses and underpasses to facilitate safe Key deer movement
(Monroe County, 1997). A reconstruction of an 18-mile stretch of US 1
starting in Miami-Dade to Monroe County has been planned (Molins, Pers.
Comm., 2001). Also along US 1, the Jewfish Creek Drawbridge will be
replaced with a high-level fixed-span bridge and the installation of
culverts to improve the tidal flow to the surrounding wetlands (Monroe
County, 2001a).

The largest improvement scheduled by the county is the Card Sound
Project. Card Sound Road connects with North Key Largo to the Mainland
and is an alternative route to US 1. The road currently is affected by
flooding due to unusually high tides. The project is proposed to raise
and widen the road, which will also serve as a hurricane evacuation
route (Monroe County, 1997). Monroe County currently does not have any
plans for new roads. Construction activities in the foreseeable future
include bridge repairs and resurfacing along County Route 905 and Card
Sound Road (Capell, Pers. Comm., 2001).

Another form of transportation is the use of canals in the Keys for
recreational boat traffic. 95% of all marinas and boat dock facilities
in Monroe County are privately owned. These facilities provide over 90%
of the saltwater slips and moorings in the County. As described in
Sections 1 and 3.2, canal water has been negatively affected by nutrient
pollution and fecal contamination as a result of inadequate wastewater
management facilities in the Keys.

There is limited public transportation throughout Monroe County. The
only public transit system is based in Key West. This is a bus service
operated by the Key West Port and Transit Authority (PATA). This bus
runs from downtown Key West to Stock Island, known as the "Conch Loop"
(Monroe County, 1997). There are about 40 miles of off-road bike and
pedestrian paths in Monroe County (Monroe County, 1997). In the next
five years additional bike paths are planned for several locations.

Environmental Consequences

##### Alternative 1 -- No Action Alternative

Construction traffic would temporarily increase during the
implementation of wastewater management projects; however, any impacts
would be minimal since improvements would likely take place on a small
scale and over a long period of time. Although FEMA does not have
regulatory responsibility over non-FEMA funded projects, it would be
expected that funding and/or permitting agencies would require the
development and implementation of traffic control plans. These plans
would include specific information about temporary traffic control,
alternate routes, staging area locations, and optimal working times to
minimize traffic disruption. With the transition to new wastewater
systems that meet Florida Statutory Treatment Standards, the water
quality of canal waters would be expected to improve thereby benefiting
the owners and users of canal boating facilities. Other impacts from
Alternative 1 would be similar to those explained below in Alternatives
2 and 3.

##### Alternative 2 -- Centralized Wastewater Treatment Plant 

The new wastewater treatment facilities would temporarily increase the
traffic to and from each facility due to construction depending on
capacity and operations. Due to temporary and/or partial road closures,
traffic would increase near the proposed facility and would be expected
to last up to 18 months, depending on the scope of work, from the start
of construction. It would be expected that a traffic control plan would
probably be developed and implemented as described in Alternative 1. Any
traffic and circulation effects are expected to be short-term in nature
and minimal. Additional information related to traffic and circulation
would be in the project-specific SER.

###### [Collection Options 1 and 2]{.underline} {#collection-options-1-and-2-3 .unnumbered}

The installation of pumping systems would have temporary, localized
adverse impacts on traffic in the Keys. Trenches for piping would be up
to 5 feet wide along road right-of-ways, detours of one or two blocks or
temporary road closings are expected. FDOT permitting is necessary where
road cuts are to be made, but authorization can be obtained locally.
During construction activities, vehicular traffic would increase in some
areas with the ingress and egress of construction equipment.

The WWTP facility would require piping over navigable waterways (such as
along the underside of existing bridges) to connect to residences. Any
impacts associated with the construction of the piping, however, would
likely be minimal and temporary for waterway traffic because boats would
still be able to pass under bridges during construction, where
applicable.

###### [Disposal Option 1 \-- Shallow Injection Wells]{.underline} {#disposal-option-1----shallow-injection-wells .unnumbered}

The installation of new shallow wastewater injection wells is not
expected to have notable impacts on transportation network in the Keys,
as the wells would likely be built next to the WWTP to minimize piping
costs. Traffic may temporarily increase in some areas due to temporary
partial road closures requiring two lanes of traffic to use one lane of
a road during well construction, but the impact should be minimal.

###### [Disposal Option 2 -- Wastewater Reuse]{.underline} {#disposal-option-2-wastewater-reuse-8 .unnumbered}

Possible adverse effects of Disposal Option 2 on traffic and circulation
would be the aforementioned delays due to the laying of new pipe as
discussed above under collection options. The specific details of the
impacts of installing reused-water pipes for transport to points of use
would be discussed in the project specific SER.

##### Alternative 3 -- On-Site Treatment Upgrades

Construction traffic would temporarily increase during the upgrade from
OWTS to OWNRS; however, impacts would be minimal since improvements
would likely be on a smaller scale. Though local roads would primarily
be impacted by on-site treatment upgrades, it is expected that the
development and implementation of a traffic control plan would be
necessary as described in Alternative 1.

### Utilities and Services

#### Affected Environment

The Monroe County Division of Public Works provides service in solid
waste, public facilities maintenance, engineering, fleet management, and
county road and bridge maintenance. Monroe County Public Works does not
provide utility services but works closely with utility companies when
planning, designing, constructing, or inspecting projects (Monroe
County, 1997).

The Florida Keys Electric Cooperative (FKEC) purchases electricity from
Florida Power and Light and supplies it to residents of Monroe County
east and north of the Seven-Mile Bridge (Monroe County, 1997). During
the year 2000, FKEC had 30,034 accounts at a density of 38.15 customers
per square mile (FKEC, 2000). This translates to about 788 miles of
linear power lines. There are six substations and 126 employees (FKEC,
2000). The average monthly electric bill is \$80.58, and equates to
about 1,000 kilowatt-hours (FKEC, 2000). Key West City Electric Services
(CES) generates electricity and supplies it to residents west and south
of the Seven-Mile Bridge (Monroe County, 1997). The major gas companies
in the Keys include Suburban, Amerigas, and Homestead Gas. These
companies all provide primarily propane gas to businesses and homes
(Monroe County, 1997). Propane gas systems have pipes underground that
run from a tank on the property up to the business or home.

In 1937, the Florida State Legislature created the FKAA. The FKAA is the
provider of potable water for all Keys residents, and the average
monthly water cost is \$20 per household. Potable water is transported
to the Keys from the mainland through a 130-mile transmission pipeline,
with an additional 649 miles of distribution pipelines that deliver
water to the customer\'s property (FKAA, 2001). The potable water supply
resources used by Monroe County are obtained from wells tapping the
Biscayne aquifer in Miami-Dade County, entirely outside of Monroe
County's jurisdiction. No new wells have been permitted in the Keys
since 1986, which would limit utilization of underground brackish/saline
resources in the Keys as a potential potable water resource. The FKAA
has primarily focused on potable water until environmental concerns
started to arise regarding wastewater issues (FKAA, 2001). The *2010
Comprehensive Plan* required that Monroe County complete a Sanitary
Wastewater Master Plan for the entire unincorporated area of the county.
The FKAA has an agreement with Monroe County to identify priority areas
and establish treatment plant sites (FKAA, 2001). The FKAA then has
legal jurisdiction to purchase, construct, manage, and operate sewage
collection, treatment, and disposal services to any entity or area of
the county (Monroe County, 1997). The cities of Key West and Key Colony
Beach also operate their own regional wastewater systems independent of
the FKAA. Islamorada plans to implement its own wastewater
infrastructure.

#### Environmental Consequences

##### Alternative 1 -- No Action Alternative

Long-term adverse effects to utilities and services are not expected.
With the coordination of wastewater management activities with public
utilities, there should be minimal effects on stormwater, gas, or
electric service. The establishment of WWTPs would increase reliability
of the wastewater service area on a regional basis as these systems
would be centrally controlled and maintained by an independent utility.
OWNRS are generally more difficult to monitor than WWTPs because they
are decentralized, which may place an operational burden on responsible
monitoring and enforcement agencies.

##### Alternative 2 -- Centralized Wastewater Treatment Plant 

There would likely be temporary adverse effects on utilities and
services during the construction phase. The SER would evaluate effects
on individual utilities, although no long-term impacts would occur if
proper utility notification and construction practices are observed. The
project applicant would be required to contact the diggers/excavation
utility hotline at the Sunshine State One Call Center at least two
business days prior to construction. Installation of WWTP piping could
disturb existing drinking water piping, among other utilities. In this
case, the pipes for either the WWTP or drinking water would be rerouted,
depending on which is more feasible (Teague, Pers. Comm., 2001). This
action would mitigate effects, though there may be temporary
interruptions in water supply services.

Collection Option 1 -- Vacuum Pumping

Aside from the impacts discussed above in Alternative 2, the selection
of this collection option is not expected to result in long-term adverse
effects on public utilities and services. Vacuum pumping systems do not
require electric power at each residence; however, electric power at a
central vacuum station is necessary. Vacuum valves have a shorter life
than pumps, have a higher rate of energy consumption, have the potential
to emit unpleasant odors at the vacuum facility, and require more
frequent repair (Head et al., 2001). The project applicant would be
required to develop backup power plans in the event that main power is
lost to the vacuum pumping station.

Collection Option 2 -- Low-Pressure Grinder Pump Sewer System

Aside from the impacts discussed above in Alternative 2, the selection
of this collection option is not expected to result in long-term adverse
effects on public utilities and services. The low-pressure grinder pump
sewer system requires less power than the vacuum system; however, power
outages shut down the system. Periodic pumping of tanks at residences
and businesses would be required, as would effluent pumps and grinder
pumps needed at each residence (Head et al., 2001).

Disposal Options 1 and 2

It is not expected that impacts related to disposal options would occur
beyond those discussed in Section 3.9.2.2.2.

##### Alternative 3 -- On-Site Treatment Upgrades

Aside from the impacts discussed above in the No Action Alternative, the
selection of this alternative is not expected to result in long-term
adverse effects on Public Utilities and Services. An OWNRS demonstration
project in Big Pine Key indicated that the systems provided BAT
treatment levels as required by Florida Statutory Treatment Standards.
As described in the No Action Alternative, the use of clustered OWNRS is
more difficult to monitor because they are decentralized. To mitigate
this effect, the project applicant proposing the clustered OWNRS would
be required to establish a monitoring, compliance, and enforcement plan
to help ensure that clustered OWNRS meet water quality and service
reliability standards on a consistent basis.

## Land Use and Planning

### Affected Environment

About 90% of Monroe County is on mainland Florida. This portion of the
county is located within either the Everglades National Park or Big
Cypress National Preserve. While mainland Monroe County is almost
uninhabited and consists almost entirely of federally owned and managed
parklands, the majority of the county's development is located in the
Keys (Monroe County, 1997).

Residential land uses, including single-family detached homes, mobile
homes, multi-family apartments, and mixed-use residential areas are
found on almost every one of the 38 Keys along US Highway 1. Residential
uses account for 10,790 acres, or 17.6% of the total area of the Keys.
Single-family detached homes are the predominant residential type in the
Keys, and account for about 8,379, or 78% of the residential land use
category. Mobile homes occupy the second largest residential land area,
and include 1,063 acres. Multi-family residential development, including
apartments, condominiums and cooperatives, account for 638 acres, or 6%
of the developed residential land area. Mixed residential areas include
about 711 acres, representing about 7% of the residential land use
category (Monroe County, 1997).

Commercial land uses can broadly be defined as those uses associated
with the buying and selling of goods and/or services. Commercial uses
account for 2,270 acres, or 3.7% of the land area for the Keys portion
of unincorporated Monroe County. Commercial land uses include general
commercial, commercial fishing, and tourist commercial land uses.
General commercial uses include retail and office uses oriented toward
the resident population and represent the majority of commercial uses.
Most of the commercial land uses are found along US 1 in the more
populated areas of Key Largo, Marathon, and Upper Matecombe. Commercial
fishing uses include land uses such as commercial marinas and landing
areas, processing plants, boat repair and maintenance, and equipment and
trap storage areas. Commercial fishing is heavily concentrated in the
Lower Keys. Tourist commercial uses represent about 45% of the total
commercial land use category, and are more heavily concentrated in the
Upper and Middle Keys than the Lower Keys (Monroe County, 1997).

Conservation lands include lands that have been acquired by public
agencies and private organizations for conservation purposes. This is
the single largest land use category after vacant lands, and accounts
for about 20,696 acres or 34% of the total land area of the Keys. These
conservation lands are primarily located in the Upper and Lower Keys and
indicate that the Federal and State governments have been actively
acquiring environmentally sensitive lands and habitats of rare,
threatened and endangered species. This category includes such
conservation lands as Crocodile Lake National Wildlife Refuge, the
National Key Deer Refuge, and the John Pennekamp Coral Reef State Park
(Monroe County, 1997).

Vacant lands are the largest land classification in the Keys, and
include an area of about 21,127 acres, or 34% of the total area of the
unincorporated portion of the Keys. Vacant lands are heavily
concentrated in the Lower Keys, as about 44% of the Lower Keys are
classified as vacant (Monroe County, 1997).

Existing land uses are summarized in Table 3-13.

Table 3-13: Existing Land Use Classification for Monroe County

  ------------------ ------------- -------------- ----------------------------------
  **Land Use         **Acreage     **Percentage   **Description**
  Classification**   (approx.)**   of Total Land  
                                   Area**         

  Vacant Land        21,127        34.0           Concentration in Lower Keys, about
                                                  44%

  Conservation Land  20,696        34.0           Heavy concentration in Upper and
                                                  Lower Keys

  Residential        10,790        17.6           Single-family detached homes
                                                  account for 78% of this category

  Military Land      3,300         5.0            Located entirely in Lower Keys

  Commercial         2,270         3.7            This category includes general
                                                  commercial, commercial fishing,
                                                  and tourist commercial

  Recreation Land    1,791         3.0            Both public and private

  Public Facilities  539           1.0            Land owned by public utilities and
                                                  service providers

  Industrial Land    515           \<1.0          Concentration in Lower Keys; about
                                                  73%

  Institutional Land 116           \<1.0          Includes hospitals, churches,
                                                  cemeteries and service clubs

  Public Building/   61            \<1.0          Includes all government offices;
  Grounds                                         local, State and Federal

  Source: Monroe                                  
  County                                          
  Comprehensive                                   
  Plan, Technical                                 
  Document, 1997.                                 
  ------------------ ------------- -------------- ----------------------------------

Military lands account for about 5% of the total land area. The Keys
have long been recognized as strategically significant by the U.S.
military forces, and military operations still play an important role in
the economy of the Keys (Monroe County, 1997). To a much lesser extent,
land uses in the Keys include industrial, agricultural/ maricultural,
institutional, educational, public buildings/grounds, public facilities,
historic, recreation, conservation, and vacant lands (Monroe County,
1997).

According to the Monroe County Comprehensive Plan, Monroe County has
about 37,128 lots zoned Improved Subdivision (IS), Urban Residential
Mobile Home (URM), and Commercial Fishing Village (CFV).

#### Future Land Use and Planning

According to the Monroe County Comprehensive Plan, existing and future
land use development in Monroe County is guided by three central
principles: carrying capacity limitations, natural resource protection,
and enhancement of community character. According to recent revisions of
the Monroe County Comprehensive Plan, one goal of the county's
comprehensive planning is to shift residential growth towards lower
density single-family development and away from multi-family condominium
and hotel/motel resort development, and toward the construction of new
residential growth as infill development. Generally, this concept
encourages development within established subdivisions and discourages
growth within undeveloped subdivisions, acreage tracts, and areas that
have sensitive natural resources or natural hazards (Monroe County,
1997).

Due to Monroe County's development constraints, the Comprehensive Plan
provides for a level of growth based on the county's carrying capacity,
rather than matching growth to projected population based on estimated
future demand. According to the Monroe County *Comprehensive Plan*,
carrying capacity refers to the capability of a natural and built
environment to accommodate additional population growth within the
parameters of an acceptable environment (Monroe County, 1997).

In 1974, the State designated the Keys as an Area of Critical State
Concern, a legal distinction authorizing extraordinary development
controls and growth limits. However, unregulated growth continued until
the Monroe County BOCC adopted the ROGO in 1992. ROGO was developed as a
response to the inability of the road system to accommodate a
large-scale hurricane evacuation in a timely manner. This ROGO system is
used to distribute the number of permits for new dwelling units both
geographically and over time, based on hurricane evacuation capacity of
the road system. Each ROGO planning sub-area of unincorporated Monroe
County and several incorporated areas receive a set number of
allocations for new residential permits, which can be issued during that
particular ROGO year. The total number of ROGO allocations that can be
issued in a ROGO year is a maximum of 255 for unincorporated Monroe
County, the Village of Islamorada, and City of Marathon, unless reduced
by the Florida Administration Commission under its rule making
authority. The number of allocations available to a particular area is
based upon the supply of vacant developable, platted subdivision lots
that could potentially be developed located in that area prior to the
start of the ROGO system. The Director of Planning has 30 days to sort,
evaluate, and rank applications by Upper, Middle, or Lower Keys
sub-areas. Applications are placed in a sub-area according to their
building locations (McGarry, Pers. Comm., 2002).

Under this permit allocation system, potential residential development
proposals compete based on explicit performance criteria developed by
the County. Criteria are assigned points (positive or negative) based on
whether they support or detract from Monroe County's future land use
concept and its three central development principles of carrying
capacity, resource protection, and maintaining or enhancing community
character (Monroe County, 1997). These categories that have scored
criteria include habitat protection, affordable housing, coastal high
hazards, water conservation, and energy conservation among others.
Through the point system, development located and designed to provide
the greatest public benefit have the strongest chance of receiving a
ROGO allocation award that authorizes the issuance of a building permit.
Wastewater management improvements are not included among the scored
criteria.

In conjunction with the ROGO permitting system, Monroe County also
implements a nutrient reduction credit program required by Policy
101.2.13 of the Monroe County Year 2010 Comprehensive Plan. The nutrient
reduction credit program requires that each ROGO allocation award must
be matched with a nutrient reduction credit. Nutrient reduction credits
are generated through the elimination of cesspools/substandard
wastewater treatment systems and their upgrading to an approved
wastewater treatment system. Building permit applicants are eligible to
receive or purchase nutrient reduction credits once their approved
building permit application has been entered in the ROGO system
(Stankiewicz, Pers. Comm., 2001). The Monroe County Health Department
administers the nutrient reduction program and is responsible for the
tracking of these credits through a unique number of identifying
systems. A nutrient reduction credit is issued when a cesspit or
non-compliant wastewater treatment system is replaced with a wastewater
treatment system compliant with Florida Statutory Treatment Standards in
accordance with Table 3.1-1 of Policy 101.2.13 in the Monroe County Year
2010 Comprehensive Plan. A ROGO allocation award will not be made until
a nutrient reduction credit is available in that same ROGO planning
sub-area (e.g., Upper, Middle, or Lower Keys). As non-compliant systems
are replaced and the new systems receive final inspections, nutrient
reduction credits become available. Except for nutrient reduction
credits that are purchased, credits are issued in the order that the
ROGO applications were ranked. Nutrient reduction credits are divided
between market rate residential units and affordable housing residential
units in an 80:20 proportion. Thus, the first four market rate
applications receive nutrient reduction credits and then the first
affordable housing application and so forth.

A ROGO applicant has the option of purchasing his/her nutrient reduction
credit rather than waiting for it to become available independently. The
nutrient reduction credit will be reserved with the Monroe County Health
Department until the quarter in which the ROGO applicant receives a ROGO
allocation ranking sufficiently high enough to otherwise receive a
building permit. An applicant must be in the ROGO system before a
nutrient reduction credit can be reserved.

Development is also constrained to maintain a balance of land uses. The
Comprehensive Plan's Policy 101.3.1 states:

> "Monroe County shall maintain a balance between residential and
> non-residential growth by limiting gross square footage of
> non-residential development over the 15 year planning horizon in order
> to maintain a ratio of about 239 square feet of non-residential
> development for each new residential unit permitted through the Permit
> Allocation System..."

There has been a de facto moratorium on non-residential growth since
January 4, 1996 because the amount of non-residential floor area
exceeded the 239-foot ratio established by the Monroe County
Comprehensive Plan. Residential development has continued and by
December 2000 had equaled the non-residential permits. A draft
"Non-residential Rate of Growth Ordinance" adopted by Monroe County on
July 18, 2001 proposes to maintain a ratio of about 239 square feet of
non-residential floor area for each new residential permit issued
through ROGO.

The Monroe County Planning and Environmental Resources Department is
required to prepare an annual assessment of public facilities capacity
mandated by Section 9.5-292 of the Monroe County Land Development
Regulations. Furthermore, the State of Florida requires all local
jurisdictions to adopt regulations to ensure the public facilities and
services which are needed to support development are available
concurrent with the impacts of development in addition to maintaining
the adopted Level of Service (Chapter 9J-5 of the F.A.C.).

According to the Monroe County Comprehensive Plan, population growth
over the next 10 years in Monroe County (unincorporated and
incorporated) will correspond to the number of building permits that
will be issued for new residential units. This is because development is
based on maintaining hurricane evacuation clearance times at or below 24
hours as required by the Monroe County Comprehensive Plan (McGarry,
Pers. Comm., 2002). The use of the ROGO permit allocation system as the
guiding policy that limits population growth in the Keys suggests that
population growth is not directly based on accommodating market demand
for development, matching development to available or planned public
facilities and services, responding to competing factors outside of the
community such as growth in adjoining Miami-Dade County, or unilaterally
maintaining past rates of growth.

Separate from the Monroe County's Comprehensive Plan, the Village of
Islamorada has its own Comprehensive Plan which became effective on
December 6, 2001. As part of the plan, the Village adopted a Building
Permit Allocation System (BPAS), which is similar to and replaces ROGO
within Islamorada. The BPAS regulates both residential and
non-residential growth through the year 2020 and the residential
allocations include the same nutrient reduction requirements as Monroe
County. During the period from 2001-2020 the BPAS allows a total of 302
residential unit, an average of 15 per year. These allocations are
comprised of 171 market rate and 131 affordable. Non-residential floor
area is limited to 28,680 square feet over the same period or an average
of approximately 1400 square feet per year (Tindle, 2002).

#### Land Use, Planning, and Wastewater Management

Wastewater flow and customer projections were developed from the FKAA
water use records for each of the 27 study areas outlined in the MCSWMP
for the baseline year 1998 and for the 10-year and 20-year planning
horizons, 2008 and 2018, respectively. This included residential (i.e.,
residential single unit, senior citizens, and residential multi-units)
and non-residential components (i.e., remaining sources such as
restaurants, laundry facilities, etc.). Total residential flow is
estimated to increase from 31,847 EDUs (4.5986 Mgal) to 34,613 EDUs
(5.0183 Mgal) between 1998 and 2008, or an approximately 8.7% increase.
Total non-residential wastewater flow is estimated to increase from
17,004 EDUs (2.5475 Mgal) to 17,594 EDUs (2.6341 Mgal) between the same
period, or an approximately 3.5% increase. For the 20-year planning
horizon, total residential and non-residential flows are estimated to
increase approximately 17% and 7% between 1998 and 2018, respectively.
Increases in residential EDUs for the 10- and 20-year planning periods
were determined from historical ROGO allocations, estimated future ROGO
allocations, and the number of future units in each study area that have
development potential and were vested or exempt from ROGO. Future
residential flow projects for the study areas were calculated by
multiplying the increase in EDUs by the average flow per EDU within each
study area. Increases in non-residential flow within the study areas
were estimated by assuming the commercial development would resume in
1999 under "Commercial ROGO" allocations described in Monroe County Year
2010 Comprehensive Plan and that this commercial growth would be within
the 239 square foot ratio distributed in proportion to residential
growth.

The Keys have very little industrial and agricultural activity; however,
permits are required for non-residential development such as industrial,
commercial, non-profit, and public buildings. The predominant form of
non-residential development is commercial. Commercial entities cannot be
placed on vacant land unless it is permitted (referred to as commercial
moratorium), however wastewater treatment facilities can be located in
any land use district other than residential land use districts
(Garrett, Pers. Comm., 2001). In addition, once a plant is placed in a
certain land use district, zoning does not change. The Monroe County
BOCC is considering allowing wastewater treatment facilities to be
placed in residential land use districts. The BOCC is currently
reviewing changes to the land development regulation in the Monroe
County Code, and it is certain if and when they will make their decision
(Reisinger, Pers. Comm., 2001).

#### Conservation and Recreation Lands

The Conservation and Recreation Lands (CARL) acquisition program, or
Forever Florida program, seeks to protect and conserve environmentally,
archaeologically, historically, or naturally significant lands in
Florida. Properties acquired by CARL are purchased by the State under
FDEP, and management of the land is performed by other State agencies
having an interest in the operation of the land. The program emphasizes
the acquisition of lands from willing landowners that contribute to the
program voluntarily. Although anyone may propose a certain project for
acquisition, The Acquisition and Restoration Council perform the
ultimate selection and ranking of projects by significance each year.
The entire acquisition program is supervised by the Governor and
Cabinet, and they retain the authority to approve the recommended
acquisition list, approve specific purchases, and declare eminent domain
for the purposes of preserving lands that are significantly rare,
sensitive, or threatened. Within Monroe County, about 34% of the land
area is designated with a land use classification termed Conservation
Land, which includes CARL lands. These areas are concentrated in the
Upper and Lower Keys and comprise about 20,696 acres in Monroe County.

#### Coastal Zone 

The Coastal Zone Management Act (CZMA) was passed by Congress to
encourage coastal states to develop programs that would comprehensively
manage activities having coastal impacts. States with an approved
coastal zone management program have the authority to review Federal
actions for program consistency. Florida's DCA, which serves as the lead
coastal agency, implements the regulations of the CZMA.

In Monroe County, coastal zone protection is provided under the Monroe
County Code of Ordinances (Ordinance Number 2-1980) and incorporated
into the Monroe County Comprehensive Plan.

#### Barrier Island Resources

Areas of Monroe County are designated as Coastal Barrier Resource System
(CBRS) units or undeveloped coastal barriers along the Keys. These
coastal barriers provide protection for diverse aquatic habitats and
serve as a defense against the impacts of severe coastal storms and
erosion. The Coastal Barrier Resources Act (CBRA) of 1982 prohibits
Federal funding for any project that could result in an increase in
development in the CBRS units. Monroe County policies regarding
protection of the CBRS units are included under Objective 102.8 of the
Year 2010 Comprehensive Plan Policy Document. This objective specifies
that Monroe County would discourage the extension of facilities and
services such as electricity and telephone service to CBRS units.
Additionally, the objective discourages developments, and construction
of access via bridges, causeways, paved roads, or commercial marinas to
or on CBRS units. In early 2002, Monroe County adopted an Overlay Zoning
District for 14 of the CBRS units, which implements the policies and
objectives of the Comprehensive Plan. A map of CBRS units is included as
Figure 3-9.

FIGURE 3-9 CBRS MAP

### Environmental Consequences

#### Alternative 1 -- No Action Alternative

Given the similarity of impacts across all land uses, the following
discussions pertain to all land uses designated above. Effects on a
particular land use are specified where appropriate.

-   The construction of new WWTPs and/or installation OWNRS is not
    expected to result in major changes to existing land uses. New
    wastewater treatment systems would likely be located on vacant land,
    and occupy between 1 and 5 acres depending on the size of the
    system. According to the Monroe County Planning Department (Tummini,
    Pers. Comm., 2001), wastewater treatment systems may be placed on
    land zoned in the following categories:

```{=html}
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-   Urban Residential

-   Urban Residential Mobile

-   Suburban Community District

-   Urban Residential Mobile Home Limited

-   Suburban Residential District

-   Sparsely Settled Urban Residential District

-   Native Area District

-   Improved Subdivision

-   Improved Subdivision Vacation Rental District

-   Mixed Use District

-   Industrial District

-   Airport District

-   Suburban Commercial

The installation of new WWTPs, upgrading of WWTPs, and conversion of
OWTS to OWNRS is not expected to cause changes in growth. The capacity
of wastewater treatment alternatives proposed in the MCSWMP are based on
accommodating a 17% increase in residential wastewater use and 7%
increase in non-residential use over a 20-year planning period (1998 to
2018). As is typical for capital-intensive projects that have project
lives in excess of 10 years, the capacity of proposed wastewater
management projects take into account future demand for wastewater
disposal. As described in Section 3.10 above, these growth projections
are based on the present ROGO permitting system that limits growth in
Monroe County. This analysis assumes the ROGO system will continue as it
has historically. The project-specific SER would consider change to ROGO
should they occur.

Under the No Action Alternative, wastewater management improvements
would be done at a slower rate without FEMA funding. As described in
Section 3.10.1.1, the release of ROGO permits is based on the
availability of nutrient reduction credits. Credits become available
when inadequate on-site wastewater systems are replaced with systems
that meet Florida Statutory Treatment Standards. Accordingly, if
wastewater management improvements occur at a slower rate, the
availability of nutrient reduction credits is also slowed; therefore,
growth rates and patterns may be altered from those initially set forth
by the Monroe County planning department. It should be noted that
regardless of the availability of nutrient reduction credits, the number
of new buildings allowed in unincorporated Monroe County is set forth by
the ROGO system that is established by the Monroe County BOCC.

The impact of wastewater management projects on CARL lands and
conservation lands, areas managed under the CZMA, and CBRS units in the
Keys would depend on the siting of individual projects in relation to
these lands. Although projects that do not receive Federal funding are
not obligated to comply with CZMA or CBRA, they may result in cumulative
effects on these special status lands in relation to other Federal
actions considered in the draft PEA. Local land development regulations
promulgated by the Monroe County Comprehensive Plan also set forth
requirements related to CARL, CBRS, and conservation lands that would be
adhered to.

In terms of the positive impacts on ground and nearshore waters
identified in Section 3.2 of this draft PEA, the proposed WWTP should
result in generally positive effects on the natural resource value of
CARL and conservation lands, CBRS units, and coastal areas that derive
their natural resource value from good water quality; although these
benefits would likely occur later in time with FEMA funding assistance.

#### Alternative 2 -- Centralized Wastewater Treatment Plant Alternative

The construction or upgrading of new WWTPs is not expected to result in
major changes to existing land uses. New wastewater treatment systems
would likely be located on vacant land, and occupy between 1 and 5 acres
depending on the size of the system. According to the Monroe County
Planning Department (Tummini, Pers. Comm., 2001), wastewater treatment
systems may be placed on land zoned in the categories referenced above
in Section 3.10.2.1. Depending on the specific siting location, the
construction of a new WWTP may have the effect of establishing a
precedent for more industrial or non-residential land uses in the
project area. Because the effect on land use is both project and site
specific, these impacts would be further developed in the SER prepared
for the individual project.

The installation or upgrading of new WWTPs is not expected to cause
changes in growth. The capacity of wastewater treatment alternatives
proposed in the MCSWMP, the plan from which FEMA-funded projects would
be selected, are based on accommodating a 17% increase in residential
wastewater use and a 7% increase in non-residential use between 1998 and
2018. As is typical for capital-intensive projects that have project
lives in excess of 10 years, the capacity of proposed wastewater
management projects take into account future demand for wastewater
disposal. These growth projections are based on the present ROGO
permitting system that limits growth in Monroe County.

Because of the Federal funding assistance, implementation of this
alternative would likely result in a quicker availability of nutrient
reduction credits in the service area. This could result in an apparent
short-term, increase in growth in the area where the credits are made
available. However, the growth rate would be constrained by ROGO, as
described in Section 3.10.1.1. The site-specific SER would contain a
more detailed discussion of nutrient reduction credits, as appropriate.

The impact of wastewater management projects on CARL lands and
conservation lands in the Keys would depend on the siting of individual
projects in relation to these lands. Because these impacts are both
project and site specific, the individual SER prepared for a subject
project would evaluate effects on CARL lands.

As part of the SER, FEMA would determine whether proposed project is
located within the jurisdictional area of the CZMA. If this is the case,
the Florida DCA would be required to review the plans of the WWTP for
consistency with its comprehensive coastal management program. As
described in Section 3.10.1.5, CBRA prohibits Federal funding for any
project that could result in an increase in development in the CBRS
units. Accordingly, no FEMA funding would be granted to project
alternatives that site a WWTP in or serve CBRS units. In terms of the
positive effects on ground and nearshore waters identified in Section
3.2 of this draft PEA, the proposed WWTP should result in generally
positive effects on the natural resource value of CARL and conservation
lands, CBRS units, and coastal areas that derive their natural resource
value from good water quality.

##### [Collection Option 1 -- Vacuum Pumping]{.underline} {#collection-option-1-vacuum-pumping-3 .unnumbered}

The selection of vacuum pumping alternative would require the siting of
one or more vacuum pumping stations. Land use and planning effects
associated with this alternative would be similar to those described in
Section 3.10.2.2.

##### [Collection Option 2 -- Centrifugal Grinder Pump System]{.underline} {#collection-option-2-centrifugal-grinder-pump-system .unnumbered}

Since this system operates underground, there would be no notable
effects to land use and zoning other than those described for the WWTP
itself in Section 3.10.2.2.

##### [Disposal Options 1 and 2]{.underline} {#disposal-options-1-and-2 .unnumbered}

Both disposal options would have impacts similar to those described in
Section 3.10.2.2.

#### Alternative 3 -- On-Site Treatment Upgrades

On-site treatment system upgrades to clustered OWNRS that remain in the
same geographic location are expected to have a minimal effect on land
use and planning. Clustered OWNRS that would be sited at new locations
are expected to result in minimal effects on existing land use because
they would be presumably sited on vacant lands. According to the Monroe
County Planning Department (Tummini, Pers. Comm., 2001), wastewater
treatment systems may be placed on land zoned in the categories
referenced in Section 3.10.2.1. Because the effect on land use is both
project and site specific, these impacts would be further developed in
the SER.

The conversion of OWTS to OWNRS is not expected to cause changes in
growth. OWNRS are generally constructed for existing development or in
light of short (1 to 5 year) planning horizon. This is because they
serve limited numbers of households (1 to 50 households possible),
(Monroe County, 2000a). As with Alternative 2, implementation of this
alternative would likely result in a quicker availability of nutrient
reduction credits in the service area. This could result in an apparent
short-term, increase in growth in the area where the credits are made
available. However, the growth rate would be constrained by ROGO, as
described in Section 3.10.1.1. The site-specific SER would contain a
more detailed discussion of nutrient reduction credits, as appropriate.

The impact of OWNRS on CARL lands and conservation lands in the Keys
would depend on the siting of individual projects in relation to these
lands. Because these impacts are both project and site specific, the
individual SER prepared for a subject project would evaluate effects on
CARL lands. Effects on CZMA, CBRA, and CARL would be similar to those
described in Section 3.10.2.2.

## NOISE AND Visual Resources

### Noise

#### Affected Environment

Noise, or unwanted sound, was originally managed at the Federal level by
the Noise Control Act of 1972, which was administered by the EPA. Under
this Act, Congress tasked the EPA with determining the extent and
effects of different qualities and quantities of noise and to define
acceptable levels of noise towards public health and safety (NPC, 2001).
Since 1982, the responsibility of noise abatement and control has been
delegated to the State and local governments, but the noise levels and
exposure recommendations developed by EPA under the Noise Control Act
are still relevant. The EPA describes sound in terms of its amplitude
(loudness), frequency (pitch), and time pattern (continuous,
fluctuating, intermittent, impulsiveness). A decibel (dBA) is a unit of
sound amplitude, whereas a hertz (Hz) is a unit of sound frequency. For
the purpose of discussing noise levels in this draft PEA, sound will be
measured and discussed in units of decibels.

The State of Florida achieves noise control through a State noise
statute (Title XXIX, Public Health, Chapter 403) that outlines general
and specific prohibitions relative to noise levels. Additionally,
Article III, Sections 13-51 to 13-55 of Monroe County Code has the
Monroe County noise ordinance regulations. Noise effects are discussed
in terms of public hazards, where the focus is on the effects to
community citizens and adjacent land uses, and in terms of occupational
hazards, which focuses on effects on laborers (as mandated in 29 CFR
1910.5, Occupational Noise Exposure, administered by the Occupational
Safety and Health Administration \[OSHA\]). Under the proposed
alternatives, it is likely that both public and occupational noise
impacts would occur.

Sensitive noise receptors in the Keys could include schools, residential
areas, hospitals, churches, and public facilities, such as parks and
recreational areas. Sensitive receptors are considered areas that
sustain greater impacts from noise sources than other areas (such as
industrial areas). An evaluation of sensitive receptors in the specific
project areas would be conducted as part of the SER.

Ambient noise levels (background sound) at the proposed project sites
would vary depending on noise sources present in the areas. For the
purpose of discussing impacts, existing noise levels at the sites are
represented by land uses and their corresponding average noise levels,
since specific sites are yet unknown. Table 3-14 presents estimated
outside noise levels associated with certain land uses and locations
measured in dBAs (Day-Night Sound Level \[Ldn\]). The presented noise
levels serve as baseline noises, from which impacts will be discussed.
As point of reference, a consistent level of 70 dBAs is identified for
all areas in order to prevent hearing loss (EPA, 1974).

**Table 3-14: Approximate Noise Levels in Decibels Based**

**on Land Uses (representing project sites)**

  --------------------------------------------------------------------------
  **Land Use**      **Decibel**   **Similar Sound\        **Overall Noise
                                  (Point of Reference)**  Level**
  ----------------- ------------- ----------------------- ------------------
  Wilderness Area   35            Library (37-42 dBA)     Quiet

  Rural Residential 39            Library (37-42 dBA)     Quiet
  Area                                                    

  Agricultural Crop 44            Bird calls (38-52 dBA)  Quiet
  Land                                                    

  Wooded            51            Rainfall (31-55 dB)     Quiet
  Residential Area                                        

  Old Urban         59            Sewing Machine (57-63   Quiet to
  Residential Area                dBA)                    Moderately Loud

  Urban Housing on  68            Vacuum cleaner (65-82   Moderately Loud
  Major Avenue                    dBA)                    

  Freeway Traffic   70            Vacuum cleaner (65-82   Moderately Loud
                                  dBA)                    

  Downtown Area     79            Ringing Telephone       Moderately Loud
  with Some                       (78-82 dBA)             
  Construction                                            
  Activity                                                

  Heavy Traffic     85            Handsaw (83-87 dBA)     Moderately Loud

  Sources: Noise                                          
  Center of the                                           
  League, 2001;                                           
  NCP, 2001; and                                          
  Branch et al.,                                          
  1970.                                                   
  --------------------------------------------------------------------------

As a final distinction between noise levels and land use, it is
preferable that areas associated with hospitals and schools measure less
than 45 dBAs, and areas that allow outdoor human activities (such as a
park) should measure less than 55 dBAs. These noise thresholds allow
spoken conversation, sleeping, work, and recreation activities without
interference or annoyance (EPA, 1974).

#### Environmental Consequences

For the purposes evaluating consequences, noise impacts are considered
in terms of a baseline ambient noise for a given area (represented in
this document by land uses) combined with noises generated by the
alternatives. When adding noise levels (when several different noises
occur at the same time), the decibels associated with a noise are
combined on a logarithmic scale (decibels cannot be added or subtracted
in the usual arithmetical way). The table below illustrates a simplified
manner in which to combine noise levels. As an example, if one machine
emits a noise of 90 dBA, and a second identical machine is placed beside
the first, the combined sound level is 93 dBA, not 180 dBA. Adding a
noise that is less than the ambient noise results in no numerical change
because the additional noise would be imperceptible. Adding noise that
is 10 dBAs or higher than the ambient noise would result in a new noise
level of the louder noise. For example if your workplace noise is 80 dBA
and you add a machine measuring 95 dBA, the overall noise level would
equal 95 dBA (CCOHS, 2001).

**Table 3-15**: Addition of Decibels

  ----------------------------------- -----------------------------------
  **Numerical Difference Between the  **Amount to be Added to the Highest
  Two Noise Levels (dBA)**            of the Two Noise Levels (dB or
                                      dBA)**

  0                                   3.0

  0.1 -- 0.9                          2.5

  1.0 -- 2.4                          2.0

  2.4 -- 4.0                          1.5

  4.1 -- 6.0                          1.0

  6.1 -- 10                           0.5

  10                                  0.0

  Source: CCOHS, 2001                 
  ----------------------------------- -----------------------------------

##### No Action Alternative, Centralized WWTP Alternative, and OWNRS Alternative

Given that the activities under each of these alternatives would involve
a range of construction activities, the impacts related to construction
and noise at the project sites would similar for all alternatives;
therefore, this discussion pertains to all alternatives. Following this
discussion, an analysis of noise and WWTP operations is presented, but
pertains only to the Centralized WWTP alternative. It should be noted
that business and residential citizens located adjacent to project sites
and laborers working at the sites will incur different levels of impact
due primarily to distance and noise reduction of buildings. For these
reasons, effects on citizens and laborers are discussed separately.

Effects on Citizens

All construction activities under all alternatives would have some noise
impacts. Noise levels at all project sites are expected to rise above
typical day-night averages, which in this document are represented by
land uses since the specific sites are yet undetermined (refer to Table
3‑13: Approximate Noise Levels in Decibels Based on Land Uses). Land use
noises are defined by noise levels that are generally "quiet" or
"moderately quiet." Construction noises would typically occur at
decibels over those associated with project site noise levels.
Therefore, noise level increases could be substantial when compared with
existing ambient noise levels. However, even though the change in sound
energy associated with construction noise is substantial, the overall
decibel level may not be significant in terms of adverse health effects.

While the overall decibel increase at project sites would likely be
substantial over present ambient levels, the distance between residents
and business owners and the construction activity, as well as noise
reduction offered by buildings (where these populations would likely be
most of the time) would dilute the level of sound actually reaching most
citizens adjacent to the construction sites. The contribution of outdoor
noise to indoor noise is usually small, 0.5 to 1.5 dB (NPC, 2001). The
intensity of a source, the distance of that sound, and the sound level
reduction afforded by a building influence the amount of sound that
ultimately enters a building and disturbs citizens located inside.
Buildings constructed in cold climates offer greater sound reduction
than those constructed in warm climates, although the difference is
minimal, 0.5 to 1.0 dB. Given the warm climate of the Keys, it is
assumed that a building can reduce outside sounds by 12 dBA s when
windows are opened, and by 24 dBAs when windows are closed (NPC, 2001).
This reduction represents a substantial change in overall noise levels
entering a residence, business, or school.

Additional reductions can be assumed when factoring in distance and
buffering materials located between the citizen and the construction
activity. According to Marsh (1991), the magnitude of sound from a
source decreases at a rate of 3 to 6 dBA with each doubling of travel
distance. Further, vegetation in the path of sound can absorb and divert
some sound. Vegetative buffers are most effective when a topographic
barrier (berm or embankment) is used alongside plantings.

Overall, effects on citizen groups would vary from site to site,
depending on the type of construction activity, the distance between the
site and population affected, and whether windows are opened or closed.
An increase in localized noise levels is expected during construction at
various locations over the course of about 36 months (Teague, Pers.
Comm., 2001), and area populations may endure annoying and disruptive
noises during allowable construction work hours, as cited in the
applicable noise ordinance. The potential for a population to experience
hearing damage or loss due to construction noises is considered low,
however the SER would evaluate site-specific characteristics to
adequately evaluate risks. To mitigate noise impacts, the applicant
would implement measures such as use of vegetative barriers and would
obey the established noise ordinance, Article III, Sections 13-51 to
13-55 of Monroe County Code in order to reduce annoying and disruptive
noises to adjacent areas. Citizens can mitigate indoor noise by keeping
windows closed for the duration of construction. Impacts related to
noise would be further evaluated in the SER that would also include
project-specific mitigation measures.

Impacts on Workers

All alternatives would have some noise levels that may adversely affect
workers at the construction sites and in the WWTP facilities.
Construction noise levels can damage human hearing abilities depending
on the sound and exposure levels (Table 3-16). It is expected workers
would not have the noise reduction benefits of distance, vegetative
buffers, or buildings. Once construction of WWTPs is complete, noises
associated with typical WWTP operations may adversely affect the workers
(Table 3-17).

**Table 3-16**: Noise Levels Associated with Common Construction
Activities

  ----------------------------------------------------------------------------
  **Construction   **Associated   **Risk from         **Permissible Exposure
  Activity**       Decibels**     Exposure            Limits (minute/hour at
                                  (representative of  maximum level; no
                                  range of            protective equipment
                                  decibels)**         worn)**
  ---------------- -------------- ------------------- ------------------------
  Rock Drilling    Up to 115      Chance of Hearing   15 minutes
                                  loss to Harmful to  
                                  Hearing             

  Heavy Equipment  95 -- 110      Chance of Hearing   30 minutes
  Operation                       loss to Harmful to  
                                  Hearing             

  Jack Hammer      102 -- 111     Chance of Hearing   26 minutes
                                  loss to Harmful to  
                                  Hearing             

  Concrete Joint   99 -- 102      Chance of Hearing   1 hour, 30 minutes
  Cutter                          Loss                

  Skilsaw          88 -- 102      Chance of Hearing   1 hour, 30 minutes
                                  Loss                

  Bulldozer        93 -- 96       Chance of Hearing   3 hours, 30 minutes
                                  Loss                

  Earth Tamper     90 -- 96       Chance of Hearing   3 hours, 30 minutes
                                  Loss                

  Crane            90 -- 96       Chance of Hearing   3 hours, 30 minutes
                                  Loss                

  Backhoe          84 - 93        Chance of Hearing   5 hours, 18 minutes
                                  Loss                

  Gradeall         87 - 94        Chance of Hearing   About 4 hours
                                  Loss                

  Source: Marsh,                                      
  1991.                                               
  ----------------------------------------------------------------------------

**Table 3-17: Noise Levels Associated with Wastewater Treatment Plant
Operations**

  ----------------------------------- -----------------------------------
  **WWTP Operating Area**             **Estimated Noise Level (dBA)**

  Generator Room                      77-91

  Pump Room                           77-100

  Vacuum Pump Trucks                  74-92

  Sludge Thickening Rooms             63-98

  Source: State of New Jersey, 2001   
  ----------------------------------- -----------------------------------

To mitigate noise impacts, workers would comply with applicable
occupational safety regulations and implement appropriate noise control
measures, such as wearing hearing protection (e.g., ear plugs, ear
muffs, a helmet, or canal caps) and limiting exposure times, as
appropriate. If these measures are implemented during construction and
operations, no adverse effects on workers should occur. Impacts related
to noise would be further evaluated in the SER that would also include
project-specific mitigation measures.

### Visual Resources

#### Affected Environment

Visual resources refer to the landscape character (i.e., what is seen),
visual sensitivity (i.e., human preferences and values regarding what is
seen), scenic integrity (i.e., degree of intactness and wholeness of
landscape character), and landscape visibility (i.e., relative distances
of seen areas) of a geographically defined viewshed. The Keys' viewshed
is presented below in general terms, and the viewsheds of each project
site would be described in the specific SER.

Keys' visual resources vary greatly depending on the location. The Keys
has dense urban development dominated by roadways, boating canals, boat
marinas, and residential, industrial, and commercial structures. In
general, even the urban areas support many vegetation types, providing a
lush setting for the communities. The Keys support many natural areas,
which provide vistas of coastal communities consisting of mangrove
forests and salt marshes; upland communities consisting of tropical
hardwood hammocks and pine rockland communities, both on slightly higher
elevations; and marine habitats including beaches and nearshore waters.

In order to assess the viewshed of a given project area, a visual
resource assessment may be conducted that integrates the benefits,
values, desires, and preferences regarding aesthetics and scenery for
all levels of land management planning. A visual resource assessment
would assess and evaluate landscape character, scenic integrity,
constituent information, landscape visibility, and scenic class of the
viewshed relative to each project site. The purpose of this assessment
is to create a numeric value score for each project site relative to
each of the parameters based on accepted methodology, and to use the
numeric score to interpret the degree of visual impacts.

#### Environmental Consequences

Depending on the existing visual quality of a proposed site, FEMA would
assess impacts related to visual resources in the project-specific SER.
This assessment would examine viewshed effects in terms of the scenic
quality, unique natural communities, high quality and unique views, and
the proximity of project activities to developed and natural areas.

# Section 4 4 Cumulative Impacts

Cumulative impacts, in the NEPA context, are the environmental impacts
that result from the incremental impacts of the proposed action when
added to other past, present, and reasonably foreseeable future actions,
regardless of what agency (Federal or non-Federal), business, or person
undertakes such other actions. Cumulative impacts can result from
individually minor but collectively significant actions taking place
over a period of time.

In order to adequately address the cumulative impacts of a given
wastewater management improvement project, it is necessary to examine
project-specific details. As such, the cumulative impact discussion of
the projects proposed for FEMA funding assistance would be focused at
the project-specific SER level. However, due to the wide array of
projects concerned with water quality currently planned or underway in
the Keys and South Florida, the below discussion focuses on the
cumulative impacts of these regional projects as related to the proposed
FEMA-funded projects.

## Concurrent Projects

### Comprehensive Wastewater Management Activities

As a result of declining nearshore water quality in the Keys, a number
of Federal, State, and local laws and regulations have been implemented
to improve wastewater and stormwater management, monitor water quality,
assist in financing water quality improvements, and establish new water
quality monitoring standards. In particular, the *Monroe County Year
2010 Comprehensive Plan*, as well as, Florida EO 98-309 and F.A.C.
99-395, mandate that nutrient loading levels be reduced in the marine
ecosystem of the Keys by the year 2010. Specific actions include
eliminating cesspits, failing septic systems and other substandard
on-site sewage systems, and requiring that all wastewater discharge be
treated to Florida Statutory Treatment Standards. In response to the
mandated wastewater treatment improvements, Monroe County prepared the
MCSWMP, which has recommendations for a number of wastewater management
projects that would improve water quality throughout the Keys. In total,
the MCSWMP recommends 12 community WWTPs and 5 regional WWTPs. Five of
the 12 community WWTPs feature interim WWTPs that, over time, will be
phased into larger regional systems.

### Comprehensive Stormwater Management Activities

In addition to developing a comprehensive wastewater management plan,
Monroe County has prepared a comprehensive stormwater management plan to
address the detrimental effect to water quality of stormwater flow
emanating from developed areas. Recent estimates attribute about 20% of
the nearshore nitrogen loading and about 45% of the phosphorous loading
emanating from the Keys to stormwater (EPA, 1993a; Kruczynski, 1999).
Released in August 2001, the SMMP recommends 24 site-specific stormwater
management projects (e.g., vegetated berms and porous pavement), to
reduce sediment loading.

### Everglades Restoration

The Everglades ecosystem extends from the Chain of Lakes south of
Orlando to the reefs surrounding Fort Jefferson southwest of the Keys.
The natural system has been severely degraded by flood control and water
distribution systems, growth and development, and agriculture. High
levels of phosphorus, mercury, and other contaminants have occurred in
the water system from urban stormwater and agricultural runoff (FDEP,
2002). In an effort to restore the Everglades ecosystem, the
Comprehensive Everglades Restoration Plan (CERP) was developed with
USACE and SFWMD as the lead agencies. The CERP includes a broad range of
projects including the examination of aquifer storage and recovery;
in-ground reservoir technology; levee seepage management technology
adjacent to Everglades National Park; and advanced wastewater treatment
technology to determine the feasibility of using reuse water for
ecological restoration. Additionally, components of the CERP include the
Arthur R. Marshall Loxahatchee National Wildlife Refuge internal canal
structures, the Lake Okeechobee watershed water quality treatment
facilities, and the Keys Tidal Restoration Project. There have been
concerns that the large-scale environmental restoration projects in the
Everglades will increase the freshwater flow to Florida Bay and,
subsequently, increase nutrient loading.

## Cumulative Impacts

### Topography, Soils, and Geology

The cumulative effects on topography and soils as result of the
concurrent, region-wide projects are expected to be minimal. The
implementation of new wastewater treatment alternatives throughout the
Keys would result in the cumulative increase in the impervious surface
area due to the construction of WWTPs and clustered OWNRS systems;
however, the actual land area required for these activities is limited
relative to the extent of the Keys surface area. Given the flat
topography of the Keys, wastewater projects are not expected to change
surface topography. As described in Section 3.1.1.3, the reduction of
nutrients inputs as a result of wastewater and stormwater management
projects would likely benefit coral reefs; thereby, reducing the
potential for wave erosion during storms. Soils would be temporarily
disturbed during stormwater and wastewater management projects; however,
the implementation of the comprehensive SMMP would decrease the
potential for long-term surface soil erosion. With respect to geology,
the potential cumulative effects of wastewater management projects are
expected to be minimal as described in Section 3.1.3.2.2. This section
discusses sinkhole development, limestone solution, and pressure buildup
as they relate to the hydrogeology of the Keys.

### Water Resources and Water Quality

In light of concurrent wastewater and stormwater management activities
and the CERP, improvements to the water quality of canal, nearshore, and
offshore waters are expected. Water quality sampling, such as that being
conducted through the WQPP as described in Section 3.2.3.1.2 would
assist in quantifying the extent of these improvements. As further
detailed in Section 3.2.2.2.1 and Appendix D, the conversions of
cesspits and septic tanks to systems that meet Florida Statutory
Treatment Standards are expected to result in about 92% reduction in TN
input to groundwater and 86% reduction in TP input to groundwater
attributed to wastewater sources in the Keys. Reduced groundwater
nutrient loading would also reduce nearshore nutrient loading because of
groundwater movement. Wastewater has been estimated to account for 80%
of the TN and 55 to 56% of the TP loading to nearshore waters.
Similarly, it is estimated untreated stormwater runoff accounts for 20%
of the TN and 44 to 45% of the TP loads to nearshore waters (EPA, 1996;
Kruczynski, 1999). Accordingly, successfully implementing both the
MCSWMP and MCSMMP should substantially reduce nutrient loading from the
Keys, resulting in a cumulative benefit to at least nearshore water
quality.

Additionally, there have been concerns that the large-scale Everglades
restoration projects will increase freshwater flow to Florida Bay and,
subsequently, increase nutrient loading. In an analysis of how changing
freshwater inflow to the southern Everglades is likely to change the
input of nutrients to Florida Bay, Rudnick et al. (1999) found that TP
inputs from the Everglades are not likely to increase; however, an
increase in TN may be expected. Despite these results, the study found
that nitrogen and phosphorus inputs from the Gulf of Mexico greatly
exceeded inputs from the Everglades. The freshwater Everglades were
identified as contributing less than 3% of all phosphorus inputs and
less than 12% of all nitrogen inputs to Florida Bay. These nutrients
were primarily attributed to runoff from agricultural and residential
areas, natural nutrient levels, and atmospheric deposition (Rudnick, et
al., 1999).

### Biological Resources

The overall cumulative effects to biological resources as a result of
the concurrent projects identified in Section 4.1 are expected to be
beneficial. As described in Section 3.3.2.1, positive effects to
nearshore marine habitats including seagrass meadows and coral reefs
would likely occur due to the reduction of TSS, nutrients, and pathogens
released to the nearshore waters that would be expected as a result of
wastewater improvement activities; as well as stormwater improvements
and the CERP. Corals typically thrive in an oligotrophic (nutrient-poor)
environment with the assistance of specialized symbiotic algae (i.e.,
zooxanthellae); these algae derive their nutrients from the waste
products of their coral hosts and, as such, are not typically limited by
the availability of free nutrients from the water column (Hallock et
al., 1993). Other benefits of decreased TSS and nutrient release may
include increased growth of seagrasses due to increased light
penetration. Algal blooms may also become less frequent, pervasive and
damaging as a result of the reduced TP and TN concentrations.

The project activities associated with the wastewater and stormwater
programs in the Keys have the potential to result in the loss of
habitat; however, most activities would occur in developed, disturbed
areas with low habitat value. Appropriate site selection and mitigation
measures would minimize the cumulative impacts of these programs. Any
potential loss in terrestrial habitat would need to be considered in
terms of the improved water quality that would result from wastewater
and stormwater management activities and subsequent benefits to aquatic
habitats, such as seagrasses and coral reefs communities.

Cumulative effects to special status species would be similar to those
described for biological resources, in general. Site selection, the
implementation of appropriate mitigation measures, and coordination with
responsible agencies such as USFWS and NMFS would minimize potential,
cumulative adverse impacts.

### Air Quality

Potential cumulative effects on air quality as they relate to the
projects described in Section 4.1 are expected to be minimal.

### Cultural Resources

The wastewater and stormwater programs, as well as the CERP, may result
in ground disturbing activities that may impact historical and
archaeological resources if present. However, these impacts are expected
to be minimal because most work would be done at previously disturbed
sites. The implementation of mitigation measures, appropriate site
selection, and coordination with the FSHPO would minimize these
potential cumulative impacts.

### Socioeconomics

The implementation of the wastewater and stormwater programs would
cumulatively improve ground and nearshore water quality and presumably
reduce or eliminate the number of health advisories in beaches and
canals in the Keys. This would likely increase the number of visitors to
beaches that formerly posted advisories, and/or reduce visitor pressure
on alternate beaches and recreational activities. These water quality
improvements would also benefit commercial fisheries to the extent they
are currently being adversely impacted by nutrient pollution. Generally,
it may be predicted that harvested species that occur in nearshore
waters such as spiny lobster, white mullet, gray snapper, various
flounder, shrimp, and stonecrab would benefit from improved water
quality. In consideration of the cumulative effect of on-going
stormwater management activities, wastewater management activities in
the Keys, and the CERP, the benefits may range from relatively
insignificant to potentially substantial improvements in harvest rates
thus benefiting the fishing industry.

### Demographics and Environmental Justice

In terms of Demographics and Environmental Justice, no adverse
cumulative economic impacts are expected as a result of the
comprehensive stormwater program or the CERP. However, as described in
Sections 3.8 and 1.2.6, implementation of the MCSWMP throughout the Keys
would generally increase wastewater management costs for residents.
Based on the information in Section 3.8.1.3, it was determined that the
low-income population could not afford an increase in wastewater
management costs over present costs. When combined with the high cost of
living in the Keys, the cumulative impact of implementing the wastewater
program may result in disproportionate adverse economic effects on
low-income populations. These impacts would depend on system costs, the
grant funding and financing options related to the capital costs of
wastewater improvement projects, and the availability of funding from
assistance programs targeted to low-income service recipients.

The siting of WWTP and other wastewater facilities is not expected to
cause cumulative adverse effects to minority and/or low-income
populations in the Keys, when combined with the above concurrent
projects.

### Hazardous Materials

Potential cumulative effects on hazardous materials as they relate to
the projects described in Section 4.1 are expected to be minimal.

### Infrastructure

WWTP construction or upgrade and OWTS conversion to clustered OWNRS as
part of the MCSWMP implementation, along with implementation of the
MCSMMP would result in a cumulative increase of the infrastructure
required for these projects. However, adverse cumulative effects on
Monroe County's overall infrastructure, as described in Section 4.1, are
expected to be minimal.

### Land Use and Planning

The installation of new WWTPs, upgrading of WWTPs, and conversion of
OWTS to OWNRS as part of comprehensive wastewater management is not
expected to cause changes in the existing growth pattern of the region.
The capacity of wastewater treatment alternatives proposed in the MCSWMP
are based on accommodating a 17% increase in residential wastewater use
and 7% increase in non-residential use over a 20-year planning period
(1998 to 2018). As is typical for capital-intensive projects that have
project lives in excess of 10 years, the capacity of proposed wastewater
management projects take into account future demand for wastewater
disposal. As described in Section 3.10, these growth projections are
based on the present ROGO permitting system that limits growth in Monroe
County. An expiration date of July 13, 2002 was set on the ROGO system
plan. Changes to the rate of growth and building permit allocation
system are at the discretion of the Monroe County BOCC and the Florida
DCA.

The impact of improved wastewater and stormwater management and CERP on
CARL lands and conservation lands, and areas managed under the CZMA
would depend on the siting of individual projects in relation to these
lands. Conscientious siting of projects outside of these lands,
compliance with CZMA, and the implementation of mitigation measures
would assist in reducing adverse cumulative effects on these special
status lands. Proposed projects identified in this draft PEA are not
eligible for FEMA funding if sited in or serving areas that are CBRS
units; therefore there would be no cumulative impacts on CBRS units. In
terms of the positive effects on ground water and nearshore waters
identified in Section 3.2 of this draft PEA, the proposed WWTP should
result in generally positive effects on the natural resource value of
CARL and conservation lands, CBRS units, and coastal areas that derive
their natural resource value from good water quality.

### Noise and Visual Resources

Potential cumulative effects on noise and visual resources as they
relate to the projects described in Section 4.1 are expected to be
minimal.

# Section 5 5 Public Involvement

The topic of wastewater management improvements and water quality
degradation in the Keys is of particular public interest to agencies and
citizens alike. For this reason, public participation throughout the
draft PEA and SER processes is of high concern not only in terms of
upholding the intent of NEPA and other applicable environmental
statutes, but also to ensure that FEMA conducts studies with the
knowledge that public and agency opinions were gathered and considered,
ensuring a well-documented and well-represented study. FEMA has specific
requirements for public participation in compliance with its
implementing regulations for NEPA, EO 11988 (Floodplain Management) and
EO 11990 (Wetland Protection); and EO 12898 (Environmental Justice).

To date, FEMA's public involvement activities have centered on
notification of the draft PEA preparation as part of the scoping
process. Public notification was issued via a Notice of Intent (NOI)
published in the Key West Keynoter, the Key West Citizen, and The
Reporter newspapers from the end of August through September 10, 2000
(Appendix G). Since publication of the NOI, FEMA has received comments
from interested parties pertaining to the proposed wastewater
improvement projects. FEMA has considered these concerns during
preparation of the draft PEA as they relate to NEPA and the
environmental review process.

In addition to initiating public involvement, FEMA has notified relevant
Federal, State and local agencies of preparation of this draft PEA
through a agency coordination letters sent on August 15, 2001. The
letters provided brief descriptions of FEMA's funding mechanism, the
NEPA review process, proposed project alternatives; and invited agencies
to provide preliminary comments on the information therein. To date,
only four agencies responded to this letter; their responses are in
Appendix I.

Additional means of public outreach are planned following issuance of
the draft PEA. In accordance with FEMA procedures and NEPA public
noticing requirements, the draft PEA will be advertised in local
newspapers and available at local repositories for a 30-day comment
period. Public comments submitted to FEMA during this time will be
reviewed and addressed, as appropriate, in the ensuing final PEA
document. Similarly, preparation of the project-specific SERs will
include a public outreach component. Draft versions of the SER will be
made available for public comment before issuance of the final document.
Additional forms of public outreach may include public meetings, the
posting of notices and other relevant information via the Internet, as
well as project information disseminated through local media outlets.

Public involvement has also been an integral element of Monroe County's
wastewater planning process and the development of the MCSWMP. Public
involvement activities conducted as part of the MCSWMP included over 30
meetings with key stakeholders and the public hosted by the FKAA and the
County held between 1998 and 2000; public forums in the Upper, Middle,
and Lower Keys; press releases to the media; distribution of fact sheets
outlining key project milestones and other project-related information;
presentations at Monroe County BOCC meetings; radio talk show
appearances; project video presentations; and a school-based outreach
program among other modes of public involvement. Participants providing
comments generally expressed concerns regarding implementation costs,
extent of improved water quality, implementation approaches, alternative
conveyance/treatment technologies, measuring project performance, and
County responsiveness to public input. Additional details on the public
involvement associated with the development of Monroe County's
wastewater management planning, including the decision analysis for
alternatives, can be found in the MCSWMP (Monroe County, 2000a).

# Section 6 6 List of Preparers

**[Project Management and Technical Research]{.underline}**

**Erica Zamensky, URS Group, Inc., Project Manager, Project
Environmental Scientist.** Ms. Zamensky has 10 years of experience in
Natural Resources Management and Planning, with 8 of those years in
managing NEPA documentation projects of varying scopes. Project
experience includes stormwater, construction of dams and reservoirs,
floodwalls, retention and detention ponds, and hydraulic improvements to
river and streams, as well as in construction of public housing,
schools, and pump stations. Ms. Zamensky has experience in managing
small and large teams in fieldwork operations, technical topic research,
and document writing relative to NEPA and other natural resource
planning and management tasks. Ms. Zamensky serves as Project Manager,
technical researcher, and document author.

**Jonathan Randall, URS Group, Inc., Senior Environmental Scientist.**
Mr. Randall has more than 5 years of experience, with specialized
expertise in NEPA compliance studies, Section 7 Endangered Species Act
biological assessments, ecological field surveys and natural resource
studies, quantitative policy analyses, and technical writing and
editing. In compliance with FEMA's implementing regulations, he has
prepared a broad range of NEPA documentation, including assessments for
natural hazard mitigation projects such as school building relocations,
stream bank stabilizations, detention basins, and fuels modification and
management. He serves as assistant project manager, technical
researcher, and document author.

**George H. Davis, P.G., URS Group, Inc.,** **Principal
Hydrogeologist.** Mr. Davis is a hydrogeologist who has been with URS
(formerly Woodward Clyde Consultants) since 1985 following a 32-year
career with the U.S. Geological Survey. His USGS career culminated with
3 years' service as Assistant Director of the agency. His more than 40
years of experience comprises groundwater and surface water hydrology,
water supply studies, and water contamination investigations; and
includes field investigations, remedial investigations, and feasibility
studies of contaminated sites, regulatory agency interactions, and
siting and permitting of radioactive, hazardous, and municipal waste
projects. He has had extensive experience at public and regulatory
hearings, and as an expert witness in court proceedings. His
extracurricular activities include service on International and National
Research Council committees, and as managing editor of *Water Resources
Research* and *Journal of Hydrology*. Mr. Davis serves as technical
researcher and document author.

**Thomas W. Bodor, URS Group, Inc., Senior Archeologist.** Mr. Bodor has
12 years of experience in cultural resource management, with a focus on
prehistoric and historical archaeology. He has completed all levels of
archaeological investigations for Federal, State, and local clients in
the Mid-Atlantic, Midwest, Southeast, and Southwest regions of the
United States. A majority of recent projects includes the preparation of
documents in compliance with Section 106 of the National Historic
Preservation Act, and other Federal regulations. Mr. Bodor serves as
technical researcher and document author.

**Joyce Friedenberg, URS Group, Inc., Economist**. Joyce Friedenberg
recently joined URS after having worked as a production economist for
four years at a multinational corporation. She has worked overseas as an
advisor and extension agent in community economic development and in the
mid-west as a small business researcher, specializing in project
profitability assessment. Prior to her training and experience as an
economist, Ms. Friedenberg worked as a water resource engineer,
analyzing agricultural, domestic and commercial water use efficiency for
the U.S. Department of Agriculture and for the Colorado Water Resources
Research Institute. Ms. Friedenberg serves as lead economic analyst and
document author.

**Sonya Krogh, URS Group, Inc., GIS Analyst/NEPA Research Assistant.**
Sonya Krogh has 4 years experience in Geographic Information Systems
(GIS), environmental geography, natural resource management,
environmental justice, water resources management, conservation, and
ecology. Ms. Krogh serves as lead GIS Analyst, technical researcher, and
document author.

**[Technical Peer Review]{.underline}**

**Colin Vissering, AICP, URS Group, Inc., Master Planner and
Environmental Resource Management Department Head.** Mr. Vissering is a
senior planner with experience in environmental and urban planning,
policy, and emergency management and hazard mitigation programs. He has
managed environmental and cultural resource compliance activities for
Federal disaster programs, providing oversight for numerous NEPA
Environmental Assessments and related natural resource studies. His
experience includes development of hazard mitigation plans and related
planning guidance, environmental training, Federal environmental
regulatory and policy development, and drafting and implementation of
National Historic Preservation Act (NHPA) agreement documents. Mr.
Vissering is currently the department head of the Environmental Resource
Management Group for URS in Gaithersburg, Maryland. This group is
comprised of the landscape architecture/planning, cultural resource
management, and NEPA and natural resource management teams. Mr.
Vissering serves as document peer reviewer.

**Daniel M. Savercool, URS Group, Inc., Senior Ecologist and Ecological
Resources Group Manager.** Mr. Savercool has over 19 years experience in
the ecology, restoration and creation of freshwater and estuarine
marshes, mangrove forests, seagrass meadows and adjacent upland
habitats. Over 15 years of this experience is focused on coastal plant
and estuarine benthic communities of peninsular Florida, with particular
expertise in the Everglades and the Keys. He has studied plant and
animal colonization of recently restored or impacted coastal habitats,
experimental revegetation of wetlands utilizing both marine and
freshwater species and management techniques for the control of
undesirable exotic vegetation. Mr. Savercool\'s published research
includes artificial reefs, estuarine benthic communities and control of
exotic vegetation in Florida. He serves as technical peer reviewer for
the biological resources sections of the draft PEA.

**Michael S. Knapp, P.G., L.S. Sims and Associates, Inc., Consulting
Geologist.** Mr. Knapp is a hydrogeologist with over 27 years of
specialized experience in well site geological evaluations, Underground
Injection Control permitting, aquifer performance tests, and geophysical
log interpretation with the majority of his experience in the State of
Florida. Prior to joining L.S. Sims and Associates, Mr. Knapp served as
President of HydroDesigns, Inc., Senior Hydrogeologist for the SFWMD,
and District Geologist for the Florida Geological Survey. He has worked
extensively with FDEP in the permitting aspects of underground injection
wells, and is considered an expert on Florida Stratigraphy. Mr. Knapp
serves as a technical peer reviewer of the topography, geology, and
soils, and water quality and water resources sections of the draft PEA.

**Thomas Kwader, Ph.D., P.G., URS Group, Inc., Hydrogeologist and Vice
President.** Dr. Kwader has worked extensively as a hydrogeologist in
the Southeastern Coastal Plain of the United States in his over 25 years
of experience. In the early 1980s, he was one of the 12 members
appointed by the Florida Department of Environmental Regulation (now
FDEP) to serve on the Technical Advisory Committee to develop the
Underground Injection Control rule for primacy in the State of Florida
to address the underground injection of wastewater in Florida. Dr.
Kwader is considered an expert in most all types of well construction
and borehole geophysical logging, having personally logged a wide range
of sewage effluent and high-pressure industrial injection wells. He is
technical editor of the professional journal, *Groundwater*, and a
member of the committee that developed the hydrostratigraphic units
currently used in Florida. Dr. Kwader serves as a technical peer
reviewer of the topography, geology, and soils, and water quality and
water resources sections of the draft PEA.

# Section 7 7 References

Aguirre, A.A. 1998. Fibropapillomas in Marine Turtles: A Workshop at the
18th Annual Symposium on Biology and Conservation of Sea Turtles. Marine
Turtle Newsletter. 82: 10-12.

Ayres Associates. 1998. Florida Keys Onsite Wastewater Nutrient
Reduction Systems Demonstration Project. Final Report. March.

Barada, W. and W.M. Partington, Jr. 1972. Report of investigation of the
environmental effects of private waterfront canals. Environmental
Information Center, Florida Conservation Foundation, Inc. 63 pp. As
cited in Kruczynski, 1999.

Balazs, G.H., et al. 1997. Occurrence of Oral Fibropapillomas in the
Hawaiian Green Turtle: Differential Disease Expression. Marine Turtle
Newsletter. 76: 1-2.

Beaver, Rick. 2001. Fishery Specialist, Florida Institute of Marine
Fisheries, Fish and Wildlife Conservation Commission. Personal
communication with Sonya Krogh, URS Group, Inc.

Bell South. 2001. Personal communication with Joyce Friedenberg, URS
Group, Inc., November 2, 2001.

Berard, Ms. 2002. Monroe County Housing Authority. Personal
communication with Joyce Friedenberg, URS Group, Inc., March 14, 2002.

Bergin, Tim. 2001. Director of Engineering Division, Environmental
Services Department. Florida Keys Aqueduct Authority. Personal
communication with Joyce Friedenberg, Sonya Krogh, Jonathan Randall, URS
Group, Inc.

Bibler, Bart. 2001. Florida Department of Health. Personal communication
with Erica Zamensky, URS. September 4.

Branch, M.C., et al. 1970. Outdoor Noise and the Metropolitan
Environment. Sound Levels and Relative Loudness of Typical Noise Sources
in Indoor and Outdoor Environments. Los Angeles, California.

Briggs, Gerald. 2001. Chief, Bureau of Onsite Sewage Programs, Florida
Department of Health. Personal communication with Sonya Krogh, URS
Group, Inc.

Brookman, Bill. 2001. Environmental Health Supervisor. Monroe County
Health Department. Personal communication with Sonya Krogh, URS Group,
Inc.

Brown, Steve. 2001. Fishery Specialist, Florida Institute of Marine
Fisheries, Fish and Wildlife Conservation Commission. Personal
communication with Sonya Krogh, URS Group, Inc.

Caffry, Wendy. 2001. Medical Technologist, Lower Keys Medical Center.
Personal communication with Jonathan Randall, URS Group, Inc.

Canadian Centre for Occupational Health and Safety (CCOHS). 1999.
Physical Agents, Noise -- Basic Information. June 3. Accessed from
www.ccohs.ca/oshanswers/phys_agents/noise_basic on Sept. 21, 2001.

Capell, Dave. 2001. Roads and Bridges Department, Monroe County Public
Works. Personal communication with Sonya Krogh, URS Group, Inc.

Carney, Patricia. 2001. Consulting Engineer. Post, Buckley, Schuh, and
Jernigan. Personal communication with Sonya Krogh, URS Group, Inc.

Casey, Rick 2002. Monroe County Dept. of Housing. Personal
correspondence with Joyce Friedenberg, June 21 and July.

Cates, Jolynn, Engineering Department, FKAA. Fax transmittal regarding a
URS Greiner study conducted in March 1999 on visiting tourists in the
Florida Keys. February 23, 2001.

Chafin, L.G. 2000. *Field Guide to the Rare Plants of Florida*. Florida
Natural Areas Inventory (FNAI), Tallahassee, Florida.

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