Final Programmatic Environmental Assessment


-Appendices 


Wastewater Management Improvements 
in the Florida Keys, Florida 


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


December 23, 2002 


Appendix A 
Acronyms



Appendix A 
List of Acronyms 

ABF Anoxic biofilter 
AIDS Acquired Immune Deficiency Syndrome 
AIRFA American Indian Religious Freedom Act 
ARPA Archaeological Resources Protection Act 
ASTM American Society of Testing and Materials 
ATU Aerobic Treatment Units 
AWT Advanced Wastewater Treatment levels 
BAT Best Available Technology 
BFE Base flood elevation 
BMPs Best management practices 
BOCC Board of County Commissioners 
BOD Biochemical oxygen demand 
BP Before present 
BPAS Building Permit Allocation System 
CARL Conservation and Recreation Lands 
CATEX Categorical Exclusion 
CBRA Coastal Barrier Resources Act 
CBRS Coastal Barrier Resource System 
CEQ Council on Environmental Quality 
CERP Comprehensive Everglades Restoration Plan 
CES Key West City Electric Services 
CFCRS Continuous Feed Cyclic Reactor System 
CFR Code of Federal Regulations 
CFV Commercial Fishing Village 
CIEGP Cesspit Identification and Elimination Grant Program 
CO Carbon monoxide 
CPU Chemical precipitation unit 
CWA Clean Water Act 
CZMA Coastal Zone Management Act 
dBA Decibel 
DCA Department of Community Affairs 
EA Environmental Assessment 


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Appendix A 
List of Acronyms 

EDU Equivalent Dwelling Unit 
EFH Essential Fish Habitat 
EIS Environmental Impact Statement 
EO Executive Order 
EPA U.S. Environmental Protection Agency 
ERP Environmental Resource Permit 
ESA Endangered Species Act 

F.A.C. Florida Administrative Code 
FAST Fixed Activated Sludge Treatment 
FDEP Florida Department of Environmental Protection 
FDH Florida Department of Health 
FDOT Florida Department of Transportation 
FEMA Federal Emergency Management Agency 
FKAA Florida Keys Aqueduct Authority 
FKEC Florida Keys Electric Cooperative 
FKNMS Florida Keys National Marine Sanctuary 
F.L. Florida Law 
FMSF Florida Master Site File 
FPSC Florida Public Service Commission 
GIS Geographical Information System 
GMFMC Gulf of Mexico Fishery Management Council 
gpd Gallons per day 
Ha Hectares 
HHS Department of Health and Human Services 
HUD U.S. Department of Housing and Urban Development 
Hz Hertz 
IMB Immersed Membrane Bioreactor 
IS Improved Subdivision 
Ldn Day-Night Sound Level 
LOS Levels of Service 
M.C.C. Monroe County Code 
MCSWMP Monroe County Sanitary Wastewater Master Plan 
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Appendix A 
List of Acronyms 

MFI Median family income 
Mgal Million gallons 
mgd Million gallons per day 
g/m3 Micrograms per cubic meter 
MHI Median household income 
MOU Memorandum of understanding 
MSA Magnuson-Stevens Fishery Conservation and Management Act 
NAAQS National Ambient Air Quality Standards 
NAGPRA Native American Graves Protection and Repatriation Act 
NEPA National Environmental Policy Act of 1969 
NGVD National Geodetic Vertical Datum 
NHPA National Historical Preservation Act 
NMFS National Marine Fisheries Service 
NO2 Nitrogen dioxide 
NO3 Nitrate 
NOAA National Oceanic and Atmospheric Administration 
NOI Notice of Intent 
NPDES National Pollution Discharge Elimination System 
NRHP National Register of Historic Places 
O&M Operations and Maintenance 
O3 Ozone 
OFW Outstanding Florida Waters 
OSHA Occupational Safety and Health Administration 
OSTDS On-site sewage treatment and disposal system 
OWNRS On-site wastewater nutrient reduction systems 
OWTS On-site wastewater treatment systems 
PATA Key West Port and Transit Authority 
Pb Lead 
PEA Programmatic Environmental Assessment 
PM 10 Particulate matter less than 10 microns 
ppm Parts per million 
RBC Rotating Biological Contactor 


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Appendix A 
List of Acronyms 

RCRA Resource Conservation and Recovery Act 
ROGO Rate of Growth Ordinance 
RSF Recirculating sand filter 
SAFMC South Atlantic Fishery Management Council 
SDGS Small diameter gravity sewers 
SDI Subsurface Drip Irrigation system 
SEA Supplemental Environmental Assessment 
SER Supplemental Environmental Review 
SFWMD South Florida Water Management District 
SMMP Stormwater Management Master Plan 
SO2 Sulfur dioxide 
STEP Septic tank effluent pump 
SWMP TAC Sanitary Wastewater Master Plan Technical Advisory Committee 
THM Trihalomethane 
TN Total nitrogen 
TON Total organic nitrogen 
TP Total phosphorus 
TSS Total Suspended Solids 
TTHM Total trihalomethane 
UIC Underground Injection Control 
URM Urban Residential Mobile Home 
USACE U.S. Army Corps of Engineers 
USDW Underground source of drinking water 
USFWS U.S. Fish and Wildlife Service 
USGS U.S. Geological Survey 
UV Ultraviolet 
WQPP Water Quality Protection Program 
WWTP Wastewater Treatment Plants 


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Appendix B 
Definitions



Appendix B 
Definitions


Abandonment costs  These include the expenses associated with removal and disposal of an 
existing wastewater treatment system. 

Adsorption  Adhesion of molecules of gases or of ions or molecules to the surfaces of solid 
bodies with which they are in contact. 

Advanced Wastewater Treatment (AWT)  Also known as tertiary treatment, AWT follows 
Secondary Treatment. Removal of soluble nitrogen and phosphorus compounds is a common 
application of AWT. AWT may involve chemical addition, filtration, or activated carbon 
processes. As referred to in the MCSWMP, effluent treated to AWT standards meets 5 mg/L 
BOD, 5 mg/L TSS, 3 mg/L TN, and 1 mg/L TP. 

Anthropogenic  Relating to humans and their impact on the natural environment 

Belt Filter Press Dewatering  A process used to remove water from sludge thereby producing 
dewatered biosolids that contain equal to or greater than 20% dry solids. 

Benthic Algae  Algae relating to the bottom of a water body. 

Best Available Technology (BAT)  The level to which wastewater treatment systems are 
designed. As referred to in the MCSWMP effluent treated to BAT standards that 10 mg/L BOD, 
10 mg/L TSS, 10 mg/L TN, and 1 mg/L TP. 

Best Management Practices (BMP)  A set of minimum practices developed and implemented 
to improve the physical, chemical, and biological integrity of the nations waters. Examples 
include installation of silt fencing at a construction site to prevent eroded soils from entering a 
nearby waterway. 

Biochemical Oxygen Demand/Biological Oxygen Demand (BOD)  The oxygen that is 
needed and used by aerobic organisms living in water that is rich in organic material (such as 
waters polluted by sewage). 

Boulder Zone  A very permeable, cavernous zone in the lower Floridian Aquifer System that is 
about 2800 to 3300 feet below ground surface. 

Calcareous  Containing calcium carbonate. As applied to rock, the predominant percentage of 
the rock is calcium carbonate. 

Cesspool/Cesspit  An unregulated and unpermitted effluent disposal method that consists of an 
excavated area (100 to 1000 cubic feet, 4 to 8 feet deep) into the ground surface. The area is 
covered with a slab of concrete, and untreated sewage is then deposited into the pit. Liquid 
wastes are discharged through the porous limestone formations and ultimately to the nearshore 
areas. Solid wastes are retained in the pit, which is often abandoned after it becomes full. 

Class B Lime Stabilization  The process used to reduce harmful bacteria and odors in sludge 
or biosolids. Lime is added to untreated sludge in sufficient quantity to raise the pH to 12 or 
higher. The high pH creates an environment that is not conducive to the survival of 
microorganisms. Class B Lime Stabilization refers to the EPA classification for the safe 
treatment, beneficial use, and disposal of biosolids that contain pathogen concentrations levels 
low enough for some beneficial uses, such as land application with restrictions. 

Class I Injection Well  The first of five well classifications developed by the U.S. 
Environmental Protection Agency under their underground disposal control program to 
categorize the injection of various types of liquid wastes. Class I wells are typically used by 


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Appendix B 
Definitions


hazardous waste generators and operators, as well as industrial and municipal disposal systems, 
to inject fluids into a geologic formation that is beneath the lower-most formation containing an 
underground source of drinking water within  mile of the well bore. A Class I Well must meet 
siting, construction, operation, and maintenance criteria specific to this well class, as established 
by the U.S. Environmental Protection Agency and the Florida State regulating agency. 

Class V Injection Well  Similar to a Class I Injection Well, the U.S. Environmental Protection 
Agency established this well category for a broad range of specialty applications to dispose 
liquid wastes, which are not categorized under the other four injection well classes. For example, 
a Class V well could be used to drain stormwater runoff into an aquifer. 

Cluster System (of OWNRS)  An OWNRS that serves multiple homes. Clusters can be 
composed of small groups (such as 2 homes), which share one treatment system, or of large 
groups (50 homes), which use low-pressure sewers to connect the cluster to a centralized 
OWNRS. 

Effluent  The waste stream from a wastewater treatment system collection unit. 

Enteric  Relating to the intestines. Over 100 different human enteric pathogens, including 
viruses, parasites, and bacteria may be found in municipal wastewater and surface runoff. 

Enterococci  A bacterium whose presence indicates Fecal Coliform. 

Environmental Impact Statement (EIS)  A public document prepared pursuant to NEPA 
containing a detailed analysis and evaluation of all the impacts of a proposed major federal 
action and all its reasonable alternatives that has the potential to significantly affect the quality of 
the human environment. This is a more rigorous analysis than an Environmental Assessment and 
provides for formal public involvement. 

Epiphyte  A plant growing on another plant but getting little nutrition from its host. 

Equivalent Dwelling Unit (EDU)  A household of 2.3 persons generating about 168 gallons of 
effluent per day. 

Eutrophication  The process by which a body of water becomes nutrient-rich and oxygen-
deficient. 

Executive Order (EO)  A Presidential mandate that directs a federal agency to consider certain 
issues as an agency plans their actions. For example, former President Jimmy Carter directed all 
agencies to minimize the destruction and loss or degradation of wetlands under EO 11990, 
Protection of Wetlands. 

Fecal Coliform  A bacterium used as an indicator of total sewage biological contamination. 

Florida Statutory Treatment Standards  Quality standards for discharged wastewater 
effluent as promulgated in F.A.C. 99-395. Treated effluent generated by sewage facilities with 
design capacities greater than 100,000 gpd must meet 5 mg/L TP. Sewage facilities with design 
capacities less than 100,000 gpd must meet 10 mg/L BOD, 10 mg/L TSS, 10 mg/L TN, and 1 
mg/L TP. On-site sewage treatment and disposal systems must meet 10 mg/L BOD, 10 mg/L 
TSS, 10 mg/L TN, and 1 mg/L TP. 

Hydraulic Communication  Water movement from one area to another (such as from the 
Boulder Zone to the ocean). 

Hydraulic Conductivity  An aquifers water transmission rate; similar to transmissivity. 


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Appendix B 
Definitions


Hydraulic Head  The driving force influencing groundwater movement, waters total energy at 
a given location. 

Injection Well (shallow and deep)  An underground well designed to pump treated effluent (or 
other materials) into shallow (e.g., 90 feet) or deep (e.g., 2,100 feet) geologic locations. Injection 
wells are designed to account for physical and chemical characteristics of the injection matrix, 
and require monitoring to ensure mechanical integrity of the well. 

Lateral costs  These include the expenses associated with installing wastewater piping on the 
service recipients property for connection to the conveyance piping in the street for a new 
wastewater system. 

Lithologic  A rocks descriptive characteristics, including color, structure, mineral composition, 
and grain size. 

Median Family Income (MFI)  as defined by the U.S. Census Bureau, refers to the income of 
a family where a family is defined as two or more people (one of whom is the householder) 
related by birth, marriage, or adoption residing in the same housing unit. 

Median Household Income (MHI)  as defined by the U.S. Census Bureau, refers to the 
income of a household where a household is defined as all people who occupy a housing unit 
regardless of relationship. A household may consist of a person living alone or multiple 
unrelated individuals or families living together. 

Microkarst  Karst features on the scale of millimeters. Karst is a type of landform developed 
over limestone, dolomite, or gypsum through solution of the rock, typified by closed depressions, 
caves, and underground drainages. 

National Environmental Policy Act (NEPA)  A congressional act established in 1969 that 
directs all federal agencies to consider the environmental effects of their programs, projects, and 
funding decisions. NEPA considers the effects on all resources of natural and built environments 
and includes compliance requirements with all other applicable federal laws, such as the 
Endangered Species Act and the Environmental Justice Executive Order. 

Norwalk Virus - Norwalk viruses (and related caliciviruses) are important causes of sporadic 
and epidemic gastrointestinal disease in the United States, and have typically been associated 
with eating contaminated shellfish. Water and ice are other sources of infection. Symptoms of 
Norwalk virus infection include nausea, vomiting, diarrhea, headache, low-grade fever, and 
abdominal cramps. Persons with this infection usually recover within 2-3 days without serious or 
long-term health effects. 

Oligotrophic  A body of water that is nutrient-poor. 

On-Site Wastewater Nutrient Reduction System (OWNRS)  An on-site wastewater 
treatment system that meets a minimum level of BAT treatment, or 10 mg/L BOD, 10 mg/L 
TSS, 10 mg/L TN, and 1 mg/L TP. 

On-Site Wastewater Treatment System (OWTS)  Any of several wastewater treatment types 
that are located on the property they serve. Examples include septic systems, cesspools, aerobic 
treatment units (ATU), and On-Site Wastewater Nutrient Reduction Systems (OWNRS). 

Oolites  Rocks consisting mostly of small, spherical calcium carbonate grains. 


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Appendix B 
Definitions


Operation and maintenance (O&M) costs  These include the monthly or annual costs 
incurred by service recipients for long-term operation and maintenance of the wastewater 
management system. 

Permeability  The capacity of porous material to transmit water or other fluid. In bedded 
sediments, horizontal permeability is measured parallel to the bedding direction, and vertical 
permeability is measured transverse to the bedding. 

Phytoplankton -Plant plankton, which float or weakly swim, are often microscopic (e.g., many 
algae species), and are the primary food source in most aquatic and marine ecosystems. 

Primary Treatment  The first level of wastewater treatment that removes solids, greases, oils 
and other floatable solids from the waste stream, partially clarifying the effluent. Suspended 
solids, dissolved organic materials, and other pollutants are not removed from the effluent. 

Programmatic Environmental Assessment (PEA)  A concise public document prepared 
pursuant to NEPA. It contains sufficient analysis to determine the likely significance of a group 
of similar proposed actions (projects) and alternatives impacts, to aid decision making as to 
whether or not to prepare an EIS. A project- and site-specific effects evaluation document 
supplements the PEA, generically called a Supplemental Environmental Review (SER), 
(described below). 

Secondary Treatment  Used in concert with Primary Treatment. This second level of 
treatment removes dissolved organic materials and more suspended solids, however nutrients 
such as nitrogen and phosphorus remain in the effluent. 

Septic Tank  An OWTS using a tank and drainfield to capture waste, separate solids from 
liquids, and drain liquid to adjacent soils. 

Significantly  In the NEPA context, this term is used to describe both the context and intensity 
(severity) of impacts. For a detailed description of this term, see Section 1508.27 of the 
Presidents Council on Environmental Qualitys regulations implementing NEPA. 

Slurry  Mixture of coarsely ground solids and liquid. 

Specific Gravity  Ratio of a given mass to the mass of an equal volume of water at a specified 
temperature. 

Subsurface Drip Irrigation (SDI)  A form of clarified effluent disposal with discharge into 
soils via subsurface piping. 

Supplemental Environmental Assessment (SEA)  A secondary NEPA public document that 
references relevant data presented in the PEA and presents site- and project- specific details and 
evaluation of effects. 

Supplemental Environmental Review (SER)  A generic phrase used herein for referencing 
the site- and project-specific NEPA document that would be prepared following issuance of a 
final PEA. This document would be either an SEA or EIS depending on the significance of the 
specific project impacts. 

System capital costs  These include expenses associated with planning, designing, engineering, 
purchasing, building, and installing a wastewater treatment system, and its wastewater 
conveyance piping in public right-of-ways and selected effluent disposal method (e.g., injection 
wells, SDI, reuse). 


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Appendix B 
Definitions


Total Nitrogen/Nitrogen (TN/N)  Nitrogen is a common element found in nature and in 
wastewater. Nitrogen is an essential nutrient for plants, but contributes to water body 
eutrophication when more abundant. Total nitrogen describes nitrogen in four oxidation states: 
organic nitrogen, ammonia nitrogen, nitrite nitrogen, and nitrate nitrogen. Removal or reduction 
of TN from wastewater effluent involves nitrification (where organic N and ammonia N are 
converted to nitrite N, which easily converts to nitrate N) and denitrification (where nitrate N is 
converted to nitrogen gas). 

Total Phosphorus/Phosphorus (TP/P)  Phosphorus is a natural element, however most 
phosphorus enters waterways via human activities (i.e., untreated wastewater or fertilizer runoff). 
Similar to nitrogen, phosphorus is an essential nutrient for plants, but eutrophication occurs when 
phosphorus is more abundant. Total phosphorus is in organic and inorganic forms and can 
occur in solution, particles, or micro-organisms (such as polyphosphates, which account for 70% 
of wastewater phosphorus). TP removal or reduction from wastewater effluent typically involves 
biological treatment (to convert P to the orthophosphate forms), which are then removed via 
chemical processes. 

Total Suspended Solids (TSS)  TSS are solids in water, such as silt, decaying plant and animal 
matter, and sewage, that can be trapped by a filter. High concentrations of suspended solids can 
cause many problems for water body health and aquatic life. For example, high TSS can block 
light from reaching submerged vegetation. 

Transmissivity  An aquifers ability to transmit water, proportional to the aquifers saturated 
thickness; similar to Hydraulic Conductivity. 

Turbidity  A measure of the water clearness as a function of suspended sediment. 

Vector Attraction Reduction  Decreasing the characteristic of sewage sludge that attracts 
rodents, flies, mosquitoes or other organisms that transmit infectious agents. 

Wastewater Treatment Plant (WWTP)  An effluent collection, treatment, and disposal 
system that collects waste from homes and businesses, and transports collected waste through a 
series of sewers to a centralized treatment plant. Physical, chemical, and biological processes 
clarify the effluent at the WWTP so that the treated water can be safely released into the 
environment via water reuse, deep or shallow well injection, or other permitted methods. 


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Appendix C 
Hot Spot Locations



Appendix C 
Hot Spot Locations 


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Appendix C 
Hot Spot Locations 


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Appendix D 
Water Quality Improvement Analysis



 Appendix D 
Water Quality Improvement Analysis 

Comparison of Nutrient Contributors from Islamorada Service Area to Groundwater and 
Marine Waters under Present Conditions versus Wastewater Systems that Meet AWT 
Standards for Effluent Disposal (5 mg/L BOD, 5 mg/L TSS, 3 mg/L TN, 1 mg/L TP) 


Sources of Information: 

1. Average daily flow (gpd): Islamorada (2001a) Design/Build/Operate Wastewater 
Management System(s), Islamorada, Village of Islands. 
2. Raw sewage nutrient concentration: Ayres Associates (1998). 
3. Nutrient removal by septic systems (TN 4%, TP 15%) Kruczynski (1999, Table 7). 
4. Removal of TP from groundwater by chemical reaction with aquifer limestone 
Kruczynski (1999, p. 22) 
5. Removal efficiency of AWT for TN, TP Islamorada (2001a, p. 18), and disposal of 
AWT effluent to Class V shallow wells Islamorada (2001a, p. 26). 
Assumptions: 

1. Currently all sewage disposal is by onsite septic systems; no cesspit/cesspool 
systems; and inflows total  AWT system average daily flow. 
2. TP is not removed from groundwater by reaction with aquifer limestones. This is a 
conservative assumption. 
3. Raw sewage nutrient concentrations are the same as Big Pine field experiments 
(Ayres Associates, 1998, p. 5-1). 
Calculations: 

1. Total wastewater flow = 911,000 gpd x 3.785 gal/L 
= 3,448,135 L/d 
2. Total nutrient loading in raw sewage: 
TN = 38.4 mg/L x 3,488,135 = 132,408 mg/day 
x .002204 = 292 lbs/day 


TP = 8.39 mg/L x 3,448,135 = 28,930 mg/day 
x .002204 = 64 lbs/day 



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 Appendix D 
Water Quality Improvement Analysis 

3. Reduction of nutrients by septic systems: 
TN 
TP 
Raw 
Sewage 
292 lbs/d 
64 lbs/d 
Septic System 
Removal 
4% 
15% 
Septic System 
Effluent 
GW 
Removal 
280 lbs/d 0% 
54 lbs/d 0% 
To 
Seawater 
280 lbs/d 
54 lbs/d 
4. Reduction of nutrients by AWT system: 
Raw Sewage Effluent Concentration 

TN 292 lbs/d 3 mg/L x 3,448,135 L/d = 10,344 gm/d 

x .002204 lbs/gm = 22.8 lbs/day 

TP 64 lbs/d 1 mg/L x 3448,135 L/d = 3,448 gm/d 

x .00224 lbs/gm = 7.6 lbs/day 

5. Reduction of nutrients in groundwater transit to marine discharge from AWT: 
Septic System 
Loading Removal Efficiency To Seawater 

TN 22.8 lbs/day 0% 22.8 lbs/day 

TP 7.6 lbs/day 0% 7.6 lbs/day 

Conclusion: 

Replacement of existing OWTS (assumed all septic systems) with wastewater management 
systems that meet AWT treatment standards would result in 92% reduction in TN input to 
groundwater (280 lbs/day to 22.8 lbs/day), and 86% reduction in TP input to groundwater (54 
lbs/day to 7.6 lbs/day). In groundwater transit to discharge to the sea negligible TN reduction 
occurs, and it is assumed here that no TP is removed by chemical reaction with carbonate rocks 
of aquifer. Thus, benefit of AWT systems in terms of nutrient removal would be in form of 92% 
reduction in TN; and an 86% removal of TP. 


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Appendix E 
Applicable Permit Information



Appendix E 
Applicable Permit Information 
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1. Forms needed for Injection Well Permits: 
ADMINISTERING 
AGENCY FORM TITLE FORM # 
FDEP Application to Construct/Operate/Abandon 
Class I, III, or V Injection well Systems 
62-528.900(1) 
FDEP Certification of Plugging Completion Class I, III, 
or V Well 62-528.900(2) 
FDEP Construction/Clearance Permit Application for 
Class V Well 62-528.900(3) 
FDEP Certification of Class V Well Construction 
Completion 62-528.900(4) 
FDEP Authorization for Class V Well Use 62-528.900(5) 
FDEP Application for Class V Well Plugging and 
Abandonment Permit 62-528.900(6) 
FDEP General Permit Form for Closed-Loop Air 
Conditioning Return Flow Class V Injection well 62-528.900(7) 
FDEP Notification to the Florida Department of 
Environmental Protection of Class V Well 
Ownership 
62-528.900(8) 
FDEP Certification of Monitor Well Completion 62-528.900(10) 
2. Forms needed for Collection System Permits: 
ADMINISTERING 
AGENCY FORM TITLE FORM # 
FDEP Application to Construct Domestic Wastewater 
Collection/Transmission System 62-604.300(7)(a) 
FDEP Domestic Wastewater Collection/Transmission 
Systems Certification of Completion of 
Construction 
62-604.300(7)(b) 
FDEP Notice of Intent to Use General Permit for 
Wastewater Collection/Transmission System 62-604.300(7)(c) 

Appendix E 
Applicable Permit Information 
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3. Forms needed for Wastewater Rinse Permits: 
ADMINISTERING 
AGENCY FORM TITLE FORM # 
FDEP Notice of Intent to Use General Permit For 
Addition of a Major User of Reclaimed Water 62-610.300(4)(a)1 
FDEP Annual Reclaimed Water Utilization Report 62-610.300(4)(a)2 
FDEP Application for Permission To Place A Public 
Access Reuse System In Operation 62-610.300(4)(a)3 
FDEP Wastewater Permit Application  Form 1 General 
Information 
62-620.910(1) 
FDEP Reclaimed Water of Effluent Analysis Report 62-620.910(15) 
4. Forms needed for Treatment Plant Construction & Operation Permits: 
ADMINISTERING 
AGENCY 
FORM TITLE FORM # 
FDEP Application for a Domestic Wastewater Facility 
Permit -Form 2A 
62-620.910(2) 
FDEP Discharge Monitoring Report 62-620.910(10) 
FDEP Notification of Completion of Construction for 
Wastewater Facilities 
62-620.910(12) 
FDEP Notification of Availability of Record Drawings and 
Final Operation and Maintenance Manuals 
62-620.910(13) 
FDEP (Application For Permit to Operate a Non- 
Discharge/Closed Loop Recycle System Form 
2CR14) 
62-620.910 
FDEP Dedicated Disposal Site Plan 62-640.210(2) (b) 
FDEP Standard Domestic Wastewater Residuals 
Record Keeping Form 
62-640.210(2) (c) 
5. Forms needed for Stormwater Permits: 
ADMINISTERING 
AGENCY 
FORM TITLE FORM # 
FDEP Discharge Monitoring Report 62-620.910(10) 

Appendix E 
Applicable Permit Information 
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6. Forms needed for Onsite Sewage Treatment and Disposal Systems 
ADMINISTERING 
AGENCY 
FORM TITLE FORM # 
FDH Innovative OSTDS Temporary Permit Application DH 3143 
FDH Homeowner Acknowledgement of Installation of 
Innovative OSTDS 
DH 3144 
FDH Innovative OSTDS Review Information DH 3145 
FDH Application for Onsite Sewage Treatment and 
Disposal System Construction Permit - 
Application 
DH 4015 
Page 1 
FDH Application for Onsite Sewage Treatment and 
Disposal System Construction Permit  Site Plan 
DH 4015 
Page 2 
FDH Site Evaluation and System Specifications DH 4015 
Page 3 
FDH Existing System and System Repair Evaluation Dh 4015 
Page 4 
FDH Construction Permit DH 4016 
Page 1 
FDH System Repair Certification DH4016 
Page 3 
FDH Application for Onsite Sewage Treatment and 
Disposal System Operating Permit (includes DH 
4081A  Assessment of Waste Handling and 
Business Activities 
DH 4081 

Appendix F
Federally and State-Listed Species in Monroe County and Fishery Species



Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

Federally Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
TERRESTRIAL MAMMALS 
Key Largo 
woodrat 
Neotoma floridana 
smalli 
E USFWS Tropical hardwood hammock Likely 
Key deer Odocoileus 
virginianus clavium 
E USFWS Tropical hardwood hammock, Mesic temperate 
hammock, Pine rockland, Mesic pine flatwoods, 
Hydric pine flatwoods, Freshwater marsh, 
Mangrove, Saltmarsh 
Likely 
Lower Keys 
silver rice rat 
(=silver rice rat) 
Oryzomys palustris 
natator(=O. 
argentatus) 
E (CH) USFWS Freshwater marsh, Mangrove, Saltmarsh Likely 
Key Largo 
cotton mouse 
Peromyscus 
gossypinus 
allapaticola 
E USFWS Tropical hardwood hammock Likely 
Florida panther Puma (=Felis) 
concolor coryi 
E USFWS High pine, Tropical hardwood hammock, Scrub, 
Maritime hammock, Mesic temperate hammock, 
Pine rockland, Scrubby flatwoods, Mesic pine 
flatwoods, Hydric pine flatwoods, Dry prairie, Wet 
prairie, Freshwater marsh, Seepage swamp, Pond 
swamp, Mangrove 
Not Likely 
Lower Keys 
marsh rabbit 
Sylvilagus palustris 
hefneri 
E USFWS Beach dune/Coastal strand, Freshwater marsh, 
Mangrove, Saltmarsh 
Likely 
Florida black 
bear 
Ursus americana 
floridanus 
C USFWS High pine, Tropical hardwood hammock, Scrub, 
Maritime hammock, Mesic temperate hammock, 
Pine rockland, Scrubby flatwoods, Mesic pine 
flatwoods, Hydric pine flatwoods, Dry prairie, Wet 
prairie, Freshwater marsh, Seepage swamp, Pond 
swamp, Mangrove 
Not Likely 


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Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

Federally Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
MARINE MAMMALS 
West Indian 
manatee 
Trichechus manatus E (CH) USFWS/NMFS Mangrove, Seagrass, Nearshore reef Likely 
blue whale Balaenoptera 
musculus 
E NMFS Offshore marine Not Likely 
finback whale Balaenoptera 
physalus 
E NMFS Offshore marine Not Likely 
humpback 
whale 
Megaptera 
novaeangliae 
E NMFS Offshore marine Not Likely 
right whale Eubalaena glacialis E NMFS Offshore marine Not Likely 
Sei whale Balaenoptera 
borealis 
E NMFS Offshore marine Not Likely 
sperm whale Physeter 
macrocephalus 
E NMFS Offshore marine Not Likely 
FISH 
Alabama shad Alosa alabamae C NMFS Large flowing rivers Not Likely 
shortnose 
sturgeon 
Acipenser 
brevirostrum 
E NMFS Coastal rivers Not Likely 
Gulf sturgeon Acipenser 
oxyrhynchus desotoi 
C NMFS Coastal rivers and offshore marine waters Possible 
Atlantic 
sturgeon 
Acipenser 
oxyrhynchus 
oxyrhynchus 
C NMFS Coastal rivers, estuarine waters Not Likely 
dusky shark Carcharhinus 
obscurus 
C NMFS Coastal surf zone to offshore marine Likely 


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Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

Federally Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
night shark Carcharinus 
signatus 
C NMFS Deep offshore marine Likely 
speckled hind Epinephelus 
drummondhayi 
C NMFS Hard bottom reefs Likely 
jewfish / goliath 
grouper 
Epinephelus itajara C NMFS Nearshore reefs to shallow offshore waters Possible 
Warsaw grouper Epinephelus nigritus C NMFS Deepwater reefs Possible 
Nassau grouper Epinephelus striatus C NMFS Nearshore reefs Likely 
saltmarsh 
topminnow 
Fundulus jenkensi C NMFS Saltmarsh and brackish water Likely 
Key silverside Menidia conchorum C NMFS Isolated lagoons; shallow, protected waters Likely 
opposum 
pipefish 
Microphis 
brachyurus lineatus 
C NMFS Freshwater associated with panic grass and smart 
weed 
Likely 
sand tiger shark Odontaspis taurus C NMFS Nearshore and offshore marine Likely 
smalltooth 
sawfish 
Pristis pectinata C NMFS Shallow coastal waters Possible 
mangrove 
rivulus 
Rivulus marmoratus C NMFS Land-crab burrows, mangrove forests, mosquito 
ditches 
Likely 
BIRDS 
Cape Sable 
seaside sparrow 
Ammodramus(=Am 
mospiza) maritimus 
mirabilis 
E (CH) USFWS Wet prairie, Freshwater marsh Possible 
piping plover Charadrius melodus T USFWS Beach dune/Coastal strand, Nearshore reef Likely 
Kirtland's 
warbler 
Dendroica kirtlandii E USFWS Upland pine, mesic hammock, rockland hammock, 
xeric scrub 
Not Likely 


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Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

Federally Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
peregrine falcon Falco peregrinus E USFWS Disturbed/Cultivated land, Freshwater marsh, 
Saltmarsh., Prairie, Ponds/Lakes, Streams/Rivers, 
Swamp 
Possible 
bald eagle Haliaeetus 
leucocephalus 
T USFWS High pine, Scrubby high pine, Maritime hammock, 
Mesic temperate hammock, Pine rockland, 
Scrubby flatwoods, Mesic pine flatwoods, Hydric 
pine flatwoods, Dry prairie, Wet prairie, 
Freshwater marsh, Seepage swamp, Flowing water 
swamp, Pond swamp, Mangrove, Saltmarsh, 
Seagrass 
Possible 
wood stork Mycteria americana E USFWS Hydric pine flatwoods, Wet prairie, Freshwater 
marsh, Seepage swamp, Flowing water swamp, 
Pond swamp, Mangrove, Saltmarsh, Seagrass 
Possible 
red-cockaded 
woodpecker 
Picoides (= 
Dendrocopos) 
borealis 
E USFWS High pine, Mesic pine flatwoods, Hydric pine 
flatwoods 
Not Likely 
Audubon's 
crested caracara 
Polyborus plancus 
audubonii 
T USFWS Mesic temperate hammock, Mesic pine flatwoods, 
Hydric pine flatwoods, Dry prairie, Wet prairie 
Possible 
Everglade snail 
kite 
Rostrhamus 
sociabilis plumbeus 
E (CH) USFWS Hydric pine flatwoods, Freshwater marsh, Pond 
swamp 
Possible 
roseate tern Sterna dougallii 
dougallii 
T USFWS Beach dune/Coastal strand, Saltmarsh, Seagrass, 
Nearshore reef 
Likely 
REPTILES 
American 
alligator 
Alligator 
mississippiensis 
T (S/A) USFWS Hydric pine flatwoods, Wet Prairie, Freshwater 
marsh, Seepage swamp, Pond Swamp, Mangrove, 
Hydric pine flatwoods, Wet prairie, Seepage 
swamp, Flowing water swamp, Pond swamp 
Likely 


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Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

Federally Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
Atlantic 
loggerhead 
turtle 
Caretta caretta T NMFS Beach dune/Coastal strand, Seagrass, Nearshore 
reef 
Likely 
Atlantic green 
turtle 
Chelonia mydas 
mydas 
E NMFS Beach dune/Coastal strand, Seagrass, Nearshore 
reef 
Likely 
American 
crocodile 
Crocodylus acutus E (CH) USFWS Mangrove, Coastal marsh Likely 
leatherback 
turtle 
Dermochelys 
coriacea 
E NMFS Offshore marine Possible 
eastern indigo 
snake 
Drymarchon corais 
couperi 
T USFWS High pine, Tropical hardwood hammock, Scrubby 
high pine, Beach dune/Coastal strand, Maritime 
hammock, Mesic temperate hammock, Pine 
rockland, Scrubby flatwoods, Mesic pine 
flatwoods, Hydric pine flatwoods, Dry prairie, 
Cutthroat grass, Freshwater marsh, Seepage 
swamp, Flowing water swamp, Pond swamp, 
Mangrove 
Possible 
Atlantic 
hawksbill 
(=carey) turtle 
Eretmochelys 
imbricata 
E NMFS Beach dune/Coastal strand, Seagrass, Nearshore 
reef 
Likely 
Kemps ridley 
turtle 
Lepidochelys kempii E NMFS Marine coastal waters with sandy or muddy 
bottoms and shorelines of red mangrove 
Possible 
INVERTEBRATES 
Schaus' 
swallowtail 
butterfly 
Heraclides (= 
Papilio) 
aristodemus 
ponceanus 
E USFWS Tropical hardwood hammock Likely 


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Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

Federally Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
Stock Island tree 
snail 
Orthalicus reses 
reses 
T USFWS Tropical hardwood hammock Likely 
PLANTS 
Blodgett's wild- 
mercury 
Arygythamnia 
blodgettii 
C USFWS Tropical hardwood hammock, Pine rockland Likely 
Big Pine 
partridge pea 
Chamaecrista 
lineata var. keyensis 
C USFWS Pine rockland Likely 
deltoid spurge Chamaesyce 
(=Euphorbia) 
deltoidea ssp. 
deltoidea 
E USFWS Pine rockland, Beach dune/Coastal strand Not Likely 
Garber's spurge Chamaesyce garberi T USFWS Pine rockland, Rockland hammocks, Coastal rock 
barrens, Salt flats, Grass prairies, Beach ridges 
Likely 
Porters 
sandmat 
(spurge) 
Chamaesyce 
porteriana 
C USFWS Pine rockland, Rockland hammock, Coastal rock 
barrens, Marl prairie 
Possible 
Cape Sable 
thoroughwort 
Chromolaena 
(=Eupatorium) 
frustrata 
C USFWS Tropical hardwood hammock, Pine rockland Likely 
Johnsons 
seagrass 
Halophila johnsonii T NMFS Intertidal waters to 3 meters depth Not Likely 
sand f lax Linum arenicola C USFWS Pine rockland, Marl prairie, Adjacent disturbed 
areas 
Possible 
semaphore 
cactus 
Opuntia corallicola C USFWS Tropical hardwood hammock, Beach dune/Coastal 
strand 
Possible 


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Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

Federally Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
Key tree-cactus Pilosocereus 
(=Cereus) robinii 
E USFWS Tropical hardwood hammock Likely 

1 E=Endangered, T=Threatened, S/A=Similarity of Appearance, CH=Critical Habitat, C=Candidate 
2 USFWS=U.S. Fish and Wildlife Service, NMFS=National Marine Fisheries Service 
3 Expressed as Likely, Possible, Not Likely 

Sources: Chafin 2000, EnviroTools 1998, FGFC 1997, FCREPA a, b and c 1992, Hipes et al. 2000, Kale and Maehr 1990, Long and Lakela 1971, Nelson 1994, 
Nelson 1996, Scurlock 1987, USDA 2001, Wunderlin and Hansen 2000. 


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Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency 2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
TERRESTRIAL MAMMALS 
southern mink, 
(South Florida 
population) 
Mustela vison mink ( 
= M. v. 
evergladensis 
T FFWCC Salt marsh, Freshwater marsh, Cypress swamp, 
Hardwood swamp 
Not Likely 
Key Largo 
woodrat 
Neotoma floridana 
smalli 
E FFWCC Tropical hardwood hammock Likely 
Key deer Odocoileus 
virginianus clavium 
E FFWCC Tropical hardwood hammock, Mesic temperate 
hammock, Pine rockland, Mesic pine flatwoods, 
Hydric pine flatwoods, Freshwater marsh, Mangrove, 
Saltmarsh 
Likely 
Lower Keys 
silver rice rat (= 
silver rice rat) 
Oryzomys palustris 
natator (= O. 
argentatus) 
E FFWCC Freshwater marsh, Mangrove, Saltmarsh Likely 
Key Largo 
cotton mouse 
Peromyscus 
gossypinus 
allapaticola 
E FFWCC Tropical hardwood hammock Likely 
Florida panther Puma (= Felis) 
concolor coryi 
E FFWCC High pine, Tropical hardwood hammock, Scrub, 
Maritime hammock, Mesic temperate hammock, Pine 
rockland, Scrubby flatwoods, Mesic pine flatwoods, 
Hydric pine flatwoods, Dry prairie, Wet prairie, 
Freshwater marsh, Seepage swamp, Pond swamp, 
Mangrove 
Not Likely 
mangrove fox 
squirrel 
Sciurus niger 
avicennia 
T FFWCC Pine flatwoods, Cypress swamp, Hardwood hammock Not Likely 
Lower Keys 
marsh rabbit 
Sylvilagus palustris 
hefneri 
E FFWCC Beach dune/Coastal strand, Freshwater marsh, 
Mangrove, Saltmarsh 
Likely 


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Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency 2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
Florida black 
bear 
Ursus americana 
floridanus 
T FFWCC High pine, Tropical hardwood hammock, Scrub, 
Maritime hammock, Mesic temperate hammock, Pine 
rockland, Scrubby flatwoods, Mesic pine flatwoods, 
Hydric pine flatwoods, Dry prairie, Wet prairie, 
Freshwater marsh, Seepage swamp, Pond swamp, 
Mangrove 
Not likely 
MARINE MAMMALS 
West Indian 
manatee 
Trichechus manatus E FFWCC Mangrove, Seagrass, Nearshore reef Likely 
Sei whale Balaenoptera 
borealis 
E FFWCC Offshore marine Not Likely 
blue whale Balaenoptera 
musculus 
E FFWCC Offshore marine Not Likely 
finback whale Balaenoptera 
physalus 
E FFWCC Offshore marine Not Likely 
right whale Eubalaena glacialis E FFWCC Offshore marine Not Likely 
humpback 
whale 
Megaptera 
novaeangliae 
E FFWCC Offshore marine Not Likely 
sperm whale Physeter 
macrocephalus 
E FFWCC Offshore marine Not Likely 
FISH 
Key silverside Menidia conchorum T FFWCC Isolated lagoons; shallow, protected waters Likely 
mangrove 
rivulus 
Rivulus marmoratus SSC FFWCC Land-crab burrows, mangrove forests, mosquito 
ditches 
Likely 
Key blenny Starksia starcki SSC FFWCC Surge channels between rows of coral Likely 


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Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency 2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
BIRDS 
roseate 
spoonbill 
Ajaia ajaja SSC FFWCC Mangrove islands, Dredge spoil islands, Willow heads, 
Tidal flats and ponds, Coastal marshes, Freshwater 
sloughs and marshes 
Likely 
Cape Sable 
seaside sparrow 
Ammodramus 
(=Ammospiza) 
maritimus mirabilis 
E FFWCC Wet prairie, Freshwater marsh Possible 
limpkin Aramus guarauna SSC FFWCC Mangroves, Freshwater marsh, Swamps, Margins of 
ponds, lakes, and rivers, Sloughs, Impoundments 
Possible 
snowy plover Charadrius 
alexandrinus 
T FFWCC Beach dune/Coastal strand Possible 
piping plover Charadrius melodus T FFWCC Beach dune/Coastal strand, Nearshore reef Likely 
white-crowned 
pigeon 
Columba 
leucocephala 
T FFWCC Mangrove islands, Tropical hardwood hammock Likely 
Kirtland's 
warbler 
Dendroica kirtlandii E USFWS Upland pine, Mesic hammock, Rockland hammock, 
Xeric scrub 
Not Likely 
little blue heron Egretta caerula SSC FFWCC Shallow freshwater, brackish, and saltwater habitats Likely 
reddish egret Egretta rufescens SSC FFWCC Marine tidal flats and shorelines, Salt evaporation pools 
and lagoons, Coastal mangrove islands, Dredge spoil 
islands 
Likely 
snowy egret Egretta thula SSC FFWCC Permanently and seasonally flooded wetlands, Streams, 
Lakes, Swamps 
Likely 
tricolored heron Egretta tricolor SSC FFWCC Permanently and seasonally flooded wetlands, 
Mangrove swamps, Tidal creeks and ditches, Edges of 
ponds and lakes 
Likely 


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Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency 2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
white ibis Eudocimus albus SSC FFWCC Freshwater and brackish marshes, Salt flats, Saltmarsh, 
Forested wetlands, Wet prairies, Swales, Seasonally 
inundated fields and ditches 
Likely 
peregrine falcon Falco peregrinus E FFWCC Disturbed/Cultivated land, Freshwater marsh, 
Saltmarsh., Prairie, Ponds/Lakes, Streams/Rivers, 
Swamp 
Possible 
southeastern 
American 
kestrel 
Falco sparverius 
paulus 
T FFWCC Open pine habitat, Woodland edges, Prairies, Pasture 
land 
Possible 
Florida sandhill 
crane 
Grus canadensis 
pratensis 
T FFWCC Prairies, Freshwater marsh, Pasture land Not Likely 
American 
oystercatcher 
Haematopus 
palliatus 
SSC FFWCC Beach dune/Coastal strand, Sandbars, Mudflats, 
Shellfish beds 
Possible 
bald eagle Haliaeetus 
leucocephalus 
T FFWCC High pine, Scrubby high pine, Maritime hammock, 
Mesic temperate hammock, Pine rockland, Scrubby 
flatwoods, Mesic pine flatwoods, Hydric pine 
flatwoods, Dry prairie, Wet prairie, Freshwater marsh, 
Seepage swamp, Flowing water swamp, Pond swamp, 
Mangrove, Saltmarsh, Seagrass 
Possible 
wood stork Mycteria americana E FFWCC Hydric pine flatwoods, Wet prairie, Freshwater marsh, 
Seepage swamp, Flowing water swamp, Pond swamp, 
Mangrove, Saltmarsh, Seagrass 
Possible 
osprey Pandion haliaetus SSC FFWCC Large lakes, Rivers, Coastal areas Likely 
brown pelican Pelecanus 
occidentalis 
SSC FFWCC Shallow estuarine waters, Sandbars, Sandspits, 
Mangrove islands 
Likely 


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Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency 2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
red-cockaded 
woodpecker 
Picoides (= 
Dendrocopos) 
borealis 
T FFWCC High pine, Mesic pine flatwoods, Hydric pine 
flatwoods 
Not Likely 
Audubon's 
crested caracara 
Polyborus plancus 
audubonii 
T FFWCC Mesic temperate hammock, Mesic pine flatwoods, 
Hydric pine flatwoods, Dry prairie, Wet prairie 
Possible 
Everglade snail 
kite 
Rostrhamus 
sociabilis plumbeus 
E FFWCC Hydric pine flatwoods, Freshwater marsh, Pond swamp Not Likely 
black skimmer Rynchops niger SSC FFWCC Coastal waters, Large lakes, Sandy beaches, Small 
islands, Dredge spoil islands 
Likely 
Florida 
burrowing owl 
Speotyto(=Athene)c 
unicularia floridana 
SSC FFWCC High, sparsely vegetated, sandy ground, Ruderal areas 
such as pastures, airports, parks, school grounds, road 
rights-of-way, and other vacant spaces 
Likely 
least tern Sterna antillarum T FFWCC Beach dune/Coastal strand Likely 
roseate tern Sterna dougallii 
dougallii 
T FFWCC Beach dune/Coastal strand, Saltmarsh, Seagrass, 
Nearshore reef 
Likely 
REPTILES 
American 
alligator 
Alligator 
mississippiensis 
SSC FFWCC Hydric pine flatwoods, Wet Prairie, Freshwater marsh, 
Seepage swamp, Pond Swamp, Mangrove, Hydric pine 
flatwoods, Wet prairie, Seepage swamp, Flowing water 
swamp, Pond swamp 
Likely 
Atlantic 
loggerhead 
turtle 
Caretta caretta T FFWCC Beach dune/Coastal strand, Seagrass, Nearshore reef Likely 
Atlantic green 
turtle 
Chelonia mydas 
mydas 
E FFWCC Beach dune/Coastal strand, Seagrass, Nearshore reef Likely 


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Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency 2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
American 
crocodile 
Crocodylus acutus E FFWCC Mangrove, Coastal marsh Likely 
leatherback 
turtle 
Dermochelys 
coriacea 
E FFWCC Offshore marine Possible 
Big Pine Key 
ringneck snake 
Diadophis punctatus 
acricus 
T FFWCC Pine rockland, Tropical hardwood hammock Likely 
eastern indigo 
snake 
Drymarchon corais 
couperi 
T FFWCC High pine, Tropical hardwood hammock, Scrubby high 
pine, Beach dune/Coastal strand, Maritime hammock, 
Mesic temperate hammock, Pine rockland, Scrubby 
flatwoods, Mesic pine flatwoods, Hydric pine 
flatwoods, Dry prairie, Cutthroat grass, Freshwater 
marsh, Seepage swamp, Flowing water swamp, Pond 
swamp, Mangrove 
Possible 
red rat snake Elaphe guttata SSC 4 FFWCC Pine, hardwood, mangrove forested habitats, Disturbed 
habitats 
Likely 
Atlantic 
hawksbill 
(=carey) turtle 
Eretmochelys 
imbricata 
E FFWCC Beach dune/Coastal strand, Seagrass, Nearshore reef Likely 
Florida Keys 
mole skink 
Eumeces egregius 
egregius 
SSC FFWCC Beach dune/Coastal strand, Coastal berm, Coastal 
scrub 
Likely 
gopher tortoise Gopherus 
polyphemus 
SSC FFWCC Sandhills, Scrub, Xeric oak hammock, Dry pine 
flatwoods, Pasture land, Oldfields, Road shoulders 
Not Likely 
Key mud turtle Kinosternum bauri E 4 FFWCC Small, usually temporary freshwater to slightly 
brackish ponds and ditches 
Likely 
Kemps ridley 
turtle 
Lepidochelys kempii E FFWCC Marine coastal waters with sandy or muddy bottoms 
and shorelines of red mangrove 
Possible 


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Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency 2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
Lower Keys 
brown snake 
Storeria dekayi victa T 4 FFWCC Pine rockland, Tropical hardwood hammock Likely 
Rim rock 
crowned snake 
Tantilla oolitica T FFWCC Tropical hardwood hammock, Pine rockland, Vacant 
lots, Pastures 
Likely 
Florida ribbon 
snake 
Thamnophis sauritus 
sackenii 
T 4 FFWCC Mangrove, Spartina marsh, Freshwater depressions and 
ditches 
Likely 
INVERTEBRATES 
pillar coral Dendrogyra 
cylindris 
E FFWCC Coral reef Likely 
Schaus' 
swallowtail 
butterfly 
Heraclides ( = 
Papilio) aristodemus 
ponceanus 
E FFWCC Tropical hardwood hammock Likely 
Florida tree snail Liguus fasciatus 
matecumbensii 
SSC FFWCC Tropical hardwood hammock Likely 
Stock Island tree 
snail 
Orthalicus reses 
reses 
T FFWCC Tropical hardwood hammock Likely 
PLANTS 
tamarindillo Acacia choriophylla E FDPI Rockland hammock, Mangrove swamp, Coastal berm Likely 
barbed-wire 
cactus 
Acanthocereus 
tetragonus (=Cereus 
pentagonus) 
T FFWCC Maritime hammock Likely 
paurotis palm Acoelorraphe 
wrightii 
T FFWCC Pine rockland, Rockland hammock Possible 


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Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency 2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
golden leather 
fern 
Acrostichum aureum T FFWCC Mangrove swamp, Saltmarsh, Hydric hammock Likely 
fragrant 
maidenhair fern 
Adiatum 
melanoleucum 
E FFWCC Rockland hammock Possible 
meadow 
jointvetch 
Aeschynomene 
pratensis 
E FFWCC Marl prairie, Cypress domes, Swales Not Likely 
Cape Sable 
whiteweed 
Ageratum littorale E FFWCC Maritime hammock Likely 
bracted colicroot 
Aletris bracteata E FFWCC Marl prairie, Pine rockland Possible 
pineland 
allamanda 
Angadenia beteroi T FFWCC Pine rockland Likely 
sea lavender Argusia 
gnaphalodes 
E FFWCC Beach dune/Coastal strand Likely 
Blodgett's wild- 
mercury 
Arygythamnia 
blodgettii 
E FFWCC Tropical hardwood hammock, Pine rockland Likely 
birds nest 
spleenwort 
Asplenium serratum E FFWCC Cypress swamp, Tropical rockland hammock Possible 
Carters orchid Basiphyllaea 
corallicola 
E FFWCC Pine rockland, Rockland hammock Possible 
pine-pink orchid Bletia purpurea T FFWCC Wet pine flatwoods, Cypress strand Not Likely 
pineland 
strongbark 
Bourreria 
cassinifolia 
E FFWCC Pine rockland Likely 
rough 
strongbark 
Bourreria radula E FFWCC Rockland hammock, Pine rockland Likely 


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Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency 2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
pigeon-berry Bourreria 
succulenta 
E FFWCC Rockland hammock, Pine rockland Likely 
spider orchid Brassia caudata E FFWCC Hammocks Not Likely 
Keys 
locustberry 
Byrsonima lucida T FFWCC Rockland hammock, Pine rockland Likely 
yellow nicker Caesalpinia major E FFWCC Upland hammock Likely 
fewflower 
holdback 
Caesalpinia 
pauciflora 
E FFWCC Pine rockland Likely 
myrtle-of-theriver 
Calyptranthes 
zuzygium 
E FFWCC Rockland hammock, maritime hammock Likely 
narrow strap 
fern 
Campyloneurum 
angustifolium 
E FFWCC Tropical hardwood hammock, Cypress swamp Not Likely 
wild cinnamon Canella winteriana E FFWCC Rockland hammock, maritime hammock Likely 
small-flowered 
lilythorn 
Catesbaea 
parviflora 
E FFWCC Pine rockland, Coastal strand Likely 
powdery 
catopsis 
Catopsis 
berteroniana 
E FFWCC Rockland hammock, Mangrove swamp Not Likely 
many-flowered 
catopsis 
Catopsis floribunda E FFWCC Tropical hardwood hammock, Cypress swamp Not Likely 
West Indian 
cocks-comb 
Celosia nitida E FFWCC Beach dune/Coastal strand, Upland hammock Likely 
slimbristle 
sandbur 
Cenchrus brownii E FFWCC Disturbed/Cultivated open land, Hammocks Likely 
Big Pine 
partridge pea 
Chamaecrista 
lineata var. keyensis 
E FFWCC Pine rockland Likely 


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Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency 2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
Garber's spurge Chamaesyce garberi E FFWCC Pine rockland, Rockland hammocks, Coastal rock 
barrens, Salt flats, Grass prairies, Beach ridges 
Likely 
rocklands 
spurge 
Chamaesyce 
pergamena 
T FFWCC Pine rockland Likely 
Porters sandmat 
(spurge) 
Chamaesyce 
porteriana 
T FFWCC Pine rockland, Rockland hammock, Coastal rock 
barrens, Marl prairie 
Possible 
southern lip fern Cheilanthes 
microphylla 
E FFWCC Shell mounds, Pine rockland, Maritime hammock, 
Mesic hammock 
Not Likely 
Cape Sable 
thoroughwort 
Chromolaena 
frustrata 
(=Eupatorium 
frustratum) 
E FFWCC Tropical hardwood hammock, Pine rockland Likely 
satin leaf Chrysophyllum 
oliviforme 
T FFWCC Pine rockland, upland hammock Likely 
Yucatan 
flymallow 
Cienfuegosia 
yucataniensis 
E FFWCC Coastal rock barrens, Coastal hammock, Saltmarsh Likely 
silver palm Coccothrinax 
argentata 
E FFWCC Pine rockland, upland hammock Likely 
Cuban 
snakebark 
Colubrina cubensis 
var. floridana 
E FFWCC Rockland hammock, Pine rockland Likely 
soldierwood Colubrina elliptica E FFWCC Rockland hammock Likely 
white geiger Cordia globosa E FFWCC Upland hammock Likely 
Christmas berry Crossopetalum 
ilicifolium 
T FFWCC Rockland hammock, Pine rockland Likely 


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Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency 2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
rhacoma Crossopetalum 
rhacoma 
E FFWCC Rockland hammock, Pine rockland, coastal scrub Likely 
pepperbush 
croton 
Croton humilis E FFWCC Upland hammock Possible 
cupania Cupania glabra E FFWCC Rockland hammock Likely 
Blodgetts 
swallow-wort 
Cynanchum 
blodgettii 
T FFWCC Rockland hammock, Upland hammock Likely 
Florida flatsedge Cyperus floridanus E FFWCC Coastal berm, Pine rockland Likely 
limestone 
flatsedge 
Cyperus fuligineus E FFWCC Rockland hammock Likely 
cowhorn orchid Cyrtopodium 
punctatum 
E FFWCC Cypress swamp, Coastal hammock, Pine rockland, 
Marl prairies 
Possible 
Browns Indian 
rosewood 
Dalbergia brownii E FFWCC Mangrove swamp, Hammocks Likely 
Florida prairie-
clover 
Dalea 
carthagenensis var. 
floridana 
E FFWCC Pine rockland, Rockland hammock, Coastal uplands, 
Marl prairie 
Likely 
Caribbean crab 
grass 
Digitaria 
dilichophylla 
T FFWCC Pine rockland Likely 
Keys hopbush Dodonaea 
elaeagnoides 
E FFWCC Rockland hammock, pine rockland Likely 
milkbark Drypetes diversifolia E FFWCC Tropical hammock Likely 
Guiana plum Drypetes lateriflora T FFWCC Tropical hammock Likely 
dollar orchid Encyclia boothiana 
var. erythronioides 
E FFWCC Rockland hammock, Coastal buttonwood forest Possible 


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Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency 2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
clamshell orchid Encyclia cochleata 
var. triandra 
E FFWCC Rockland hammock, Cypress swamp Not Likely 
dingy-flowered 
star orchid 
Epidendrum anceps E FFWCC Rockland hammock, Cypress swamp Not Likely 
umbelled star 
orchid 
Epidendrum 
difforme 
E FFWCC Upland hammock Not Likely 
night-scented 
orchid 
Epidendrum 
nocturnum 
E FFWCC Rockland hammock, Cypress swamp Not Likely 
stiff-flowered 
star orchid 
Epidendrum rigidum E FFWCC Rockland hammock, Cypress swamp Not Likely 
black torch Erithralis fruticosa T FFWCC Beach dune/Coastal strand, maritime hammock Likely 
Cokers beach 
creeper 
Ernodea cokeri E FFWCC Pine rockland Possible 
redberry stopper Eugenia confusa E FFWCC Rockland hammock Likely 
red stopper Eugenia rhombea E FFWCC Rockland hammock Likely 
dwarf bindweed Evolvulus 
convolvuloides 
E FFWCC Upland hammock Likely 
Grisebachs 
bindweed 
Evolvulus 
grisebachii 
E FFWCC Pine rockland Likely 
princewood Exostema caribaeum E FFWCC Rockland hammock, Pine rockland Likely 
wild cotton Gossypium hirsutum E FFWCC Coastal berm, Shell mounds, Maritime hammock Likely 
lignum vitae Guaiacum sanctum E FFWCC Rockland hammock Likely 
Fuchs 
bromeliad 
Guzmania 
monostachia 
E FFWCC Strand swamp, Rockland hammock Not Likely 
false boxwood Gyminda latifolia E FFWCC Tropical hardwood hammock Likely 


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Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency 2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
west coast 
prickly apple 
Harrisia aboriginum 
(=Cereus gracilis 
var. aboriginum 
E FFWCC Shell mounds, Rockland hammock, Maritime 
hammock 
Not Likely 
Simpsons 
prickly apple 
Harrisia simpsonii 
(=Cereus gracilis 
var. simpsonii) 
E FFWCC Rockland hammock Likely 
manchineel Hippomane 
mancinella 
E FFWCC Coastal berm, Coastal hammock Likely 
white ironwood Hypelate trifoliata E FFWCC Rockland hammock, Pine rockland Likely 
Florida Keys 
indigo 
Indigofera 
mucronata var. 
keyensis 
E FFWCC Coastal berm, Coastal rock barrens, Rockland 
hammock 
Likely 
delicate ionopsis Ionopsis 
utricularioides 
E FFWCC Rockland hammock, Strand swamp Not Likely 
rockland 
morning glory 
Ipomoea tenuissima E FFWCC Pine rockland Possible 
pineland 
jacquemontia 
Jacquemontia 
curtissii 
T FFWCC Pine flatwoods, Pine rockland, Marl prairie, spoil banks Likely 
Havana 
jacquemontia 
Jacquemontia 
havanensis 
E FFWCC Hardwood hammock Likely 
skyblue 
clustervine 
Jacquemontia 
pentanthos 
E FFWCC Pine rockland, Rockland hammock, Coastal rock 
barren 
Likely 
joewood Jacquina keyensis T FFWCC Coastal salt flat, Coastal scrub, Maritime hammock, 
Pine rockland 
Likely 
white fen Kosteletzkya 
depressa 
E FFWCC Maritime hammock, Mangrove swamp Not Likely 


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Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency 2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
pineland lantana Lantana depressa 
var. depressa 
E FFWCC Pine rockland, Coastal strand, Coastal grassland, 
Coastal berm, Marl prairie 
Possible 
ghost plant Leiphaimos 
parasitica 
E FFWCC Upland hammock Likely 
sand flax Linum arenicola E FFWCC Pine rockland, Marl prairie, Adjacent disturbed areas Likely 
wild dilly Manilkara jaimiqui T FFWCC Upland hammock Likely 
mayten Maytenus 
phyllanthoides 
T FFWCC Upland hammock, Coastal dune Likely 
small-leaved 
melanthera 
Melanthera 
parviflora 
T FFWCC Pine rockland, Marl prairie Possible 
climbing vine 
fern 
Microgramma 
heterophylla 
E FFWCC Rockland hammock Not Likely 
Simpsons 
stopper 
Myrcianthes 
fragrans 
T FFWCC Upland hammock Likely 
giant sword fern Nephrolepis 
biserrata 
T FFWCC Mesic hammock, Swamps Not Likely 
ribbon fern Neurodium 
lanceolatum 
E FFWCC Rockland hammock, Mangrove swamp, Upland 
hammock 
Likely 
wild basil Ocimum 
campechianum 
E FFWCC Upland hammock, Pine rockland Likely 
beach peanut Okenia hypogaea E FFWCC Beach dune/Coastal strand Likely 
mule-eared 
orchid 
Oncidium 
undulatum 
(=luridum 
E FFWCC Hardwood hammock, Cypress swamp, Buttonwood 
forest 
Possible 


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Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency 2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
hand fern Ophioglossum 
palmatum 
E FFWCC Maritime hammock, Hydric hammock, strand swamp Not Likely 
semaphore 
cactus 
Opuntia corallicola 
(=spinosissima) 
E FFWCC Tropical hardwood hammock, Beach dune/Coastal 
strand 
Likely 
prickly-pear 
cactus 
Opuntia stricta T FFWCC Tropical hardwood hammock, Beach dune/Coastal 
strand 
Likely 
Keys Joe-
jumper 
Opuntia triacantha E FFWCC Coastal rockland, rockland hammock Likely 
white-flowered 
passionvine 
Passiflora multiflora E FFWCC Tropical hardwood hammock Likely 
pineland 
passionvine 
Passiflora pallens E FFWCC Rockland hammock, Coastal berm, Strand swamp Not Likely 
swampbush Pavonia paludicola E FFWCC Saltmarsh, Mangrove swamp Possible 
widespread 
polypody 
Pecluma dispersa E FFWCC Hydric hammock, upland hammock, pine rockland Likely 
plume polypody Pecluma plumula E FFWCC Hardwood hammock Likely 
reddish 
peperomia 
Peperomia humilis E FFWCC Mesic hammock, Coastal berm, Cypress swamp, 
Maritime hammock 
Not Likely 
Florida 
peperomia 
Peperomia 
obtusifolia 
E FFWCC Rockland hammock, Hydric hammock, Strand swamp Not Likely 
mahogany 
mistletoe 
Phoradendron 
rubrum 
E FFWCC Rockland hammock Likely 
Bahama tree 
cactus 
Pilosocereus 
bahamensis 
E FFWCC Rockland hammock Likely 


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Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency 2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
Key tree-cactus Pilosocereus 
(=Cereus) robinii 
E FFWCC Tropical hardwood hammock Likely 
devils smooth 
claws 
Pisonia rotundata E FFWCC Pine rockland, Rockland hammock Likely 
blackbead Pithecellobium 
keyense 
T FFWCC Rockland hammock Likely 
Everglades 
poinsettia 
Poinsettia pinetorum E FFWCC Pine rockland Likely 
ghost orchid Polyradicion 
lindenii 
E FFWCC Maritime hammock, Swamps Not Likely 
buccaneer palm Pseudophoenix 
sargetii 
E FFWCC Rockland hammock Likely 
long-stalked 
stopper 
Psidium longipes T FFWCC Pine rockland, Rockland hammock Likely 
Bahama wild 
coffee 
Psychotria 
ligustrifolia 
E FFWCC Rockland hammock Mesic flatwoods, Scrubby 
flatwoods, Wet flatwoods 
Likely 
Bahama ladder 
brake 
Pteris bahamensis T FFWCC Pine rockland, Upland hammock Likely 
Darling plum Reynosia 
septentrionalis 
T FFWCC Upland hammock Likely 
mistletoe cactus Rhipsalis baccifera E FFWCC Rockland hammock, Mangrove swamp Not Likely 
Swartz 
snoutbean 
Rhynchosia swartzii T FFWCC Upland hammock Likely 
Florida royal 
palm 
Roystonea elata E FFWCC Rockland hammock, Strand swamp, Shell mounds Possible 


I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-23 


Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency 2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
Bahama sachsia Sachsia bahamensis 
(=polycephala) 
E FFWCC Pine rockland Likely 
maiden bush Savia bahamensis E FFWCC Coastal thickets, Maritime hammock Likely 
yellow wood Schaefferia 
frutescens 
E FFWCC Upland hammock Likely 
silky bluestem Schizachyrium 
sericatum 
E FFWCC Pine rockland Likely 
Keys nutrush Scleria lithosperma E FFWCC Rockland hammock Likely 
Havana skullcap Scutellaria 
havanensis 
E FFWCC Pine rockland Likely 
Eatons spike-
moss 
Selaginella eatonii E FFWCC Rockland sinkholes Not Likely 
Chapmans 
sensitive-plant 
Senna mexicana var. 
chapmanii 
T FFWCC Beach dune, Rockland hammock, Pine rockland Likely 
coral panic grass Setaria chapmanii 
(=Panicum 
chapmanii 
E FFWCC Shell mounds, Cropland, Upland hammock, Prairies Likely 
Everglades 
greenbrier 
Smilax havanensis T FFWCC Upland hammock, Pine rockland Likely 
potato tree Solanum donianum T FFWCC Upland hammock Likely 
false 
buttonweed 
Spermacoce 
terminalis 
T FFWCC Pine rockland, Flatwoods Likely 
wedgelet fern Sphenomeris 
(=Odontosoria) 
clavata 
E FFWCC Pine rockland, Sinkholes Likely 


I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-24 


Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency 2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
Tall neottia Spiranthes elata 
(=Mesadenus 
elatus) 
E FFWCC Rockland hammock, Sinkholes Not Likely 
lace-lip ladiestresses 
Spiranthes laciniata T FFWCC Flatwoods, Marshes, Swamps Not Likely 
southern ladiestresses 
Spiranthes torta E FFWCC Pine rockland, Marl prairie, Rockland hammock Likely 
pride-of-Big-
Pine 
Strumpfia maritima E FFWCC Coastal strand, Coastal rock barren, Pine rockland Likely 
Everglades 
pencil-flower 
Stylosanthes 
calicola 
E FFWCC Pine rockland, Marl prairie Likely 
West Indies 
mahogany 
Swietenia mahagoni E FFWCC Rockland hammock, Maritime hammock Likely 
least halberd 
fern 
Tectaria fimbriata E FFWCC Rockland hammock, Sinkholes Not Likely 
tetrazygia Tetrazygia bicolor T FFWCC Rockland hammock, Pine rockland Likely 
abrupt-tipped 
maiden fern 
Thelypteris 
augescens 
T FFWCC Calcareous hammock, Limestone rockland Likely 
brittle thatch 
palm 
Thrinax morrisii E FFWCC Rockland hammock, Pine rockland Likely 
Florida thatch 
palm 
Thrinax radiata E FFWCC Maritime hammock, Upland hammock, Coastal scrub Likely 
inflated 
wildpine 
Tillandsia 
balbisiana 
T FFWCC Flatwoods, Hammocks, Swamps Likely 
twisted air plant Tillandsia flexuosa E FFWCC Hammocks, Pine rockland, Swamps, Shell Mounds Likely 


I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-25 


Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency 2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
giant wildpine Tillandsia utriculata E FFWCC Flatwoods, Hammocks, Pine rockland, Swamps Likely 
soft-leaved 
wildpine 
Tillandsia 
valenzuelana 
T FFWCC Hammocks, Swamps Likely 
bay lavender Tournefortia 
gnaphalodes 
E FFWCC Beach dune, Coastal rockland Likely 
chiggery-grapes Tournefortia 
hirsutissima 
E FFWCC Upland hammock Likely 
rocklands 
noseburn 
Tragia saxicola T FFWCC Pine rockland Likely 
West Indian 
trema 
Trema lamarkianum E FFWCC Upland hammock, Dry prairie, Disturbed areas Likely 
winged filmy 
fern 
Trichomanes 
holopterum 
E FFWCC Strand swamps Not Likely 
hoop vine Trichostigma 
octandrum 
E FFWCC Upland hammock, Disturbed areas Likely 
Florida 
gamagrass 
Tripsacum 
floridanum 
T FFWCC Pine rockland Likely 
pearl berry Vallesia antillana E FFWCC Maritime hammock Likely 
wormvine 
orchid 
Vanilla barbellata E FFWCC Rockland hammock, Mangrove swamp Likely 
coastal vervain Verbena 
(=Glandularia) 
maritima 
E FFWCC Beach dune, Coastal scrub, Pine rockland Likely 
Blodgetts 
ironweed 
Vernonia blodgettii E FFWCC Pine rockland, Mesic flatwoods Likely 


I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-26 


Appendix F 
Federally and State-Listed Species in Monroe County and Fishery Species 

State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico 

Common Name Scientific Name Status 1 Jurisdictional 
Agency 2 
Habitat Likelihood of 
occurrence in 
Florida Keys 3 
yellowheart Zanthoxylum flavum E FFWCC Tropical coastal hammock Likely 

1 E=Endangered, T=Threatened, SSC=Species of Special Concern, PE=Proposed Endangered, PT=Proposed Threatened, PS=Proposed Species of Special 

Concern 
2 FFWCC = Florida Fish and Wildlife Conservation Commission, FDPI = Florida Department of Agriculture and Consumer Services, Division of Plant Industry 
3 Expressed as Likely, Possible, Not Likely 
4 Lower Keys population only 

Sources: Chafin 2000, EnviroTools 1998, FGFC 1997, FCREPA a, b and c 1992, Hipes et al. 2000, Kale and Maehr 1990, Long and Lakela 1971, Nelson 1994, 
Nelson 1996, Scurlock 1987, USDA 2001, Wunderlin and Hansen 2000. 


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Appendix G 
Federal and State Agency Correspondence



 Appendix G 
Agency Coordination Letters 

Coordination Letters were sent to the following: 

Jay Slack, Field Supervisor 
South Florida Ecological Services Field 
Office 

U.S. Fish and Wildlife Service 
1339 20th Street 
Vero Beach, FL 32960 
cc: Phil Frank, Biologist 
Dr. Janet Matthews, Director 
Division of Historical Resources 
Florida State Historic Preservation Office 

R.A. Gray Building, Room 305 
500 South Bronough Street 
Tallahassee, FL 32399-0250 
cc: Laura Kammerer, Head of Compliance 
and Review 
Georgia Cranmore 
Acting Assistant Regional Admin. 
Protective Resources Division 
National Marine Fisheries Service 
0721 Executive Center Drive North 
St. Petersburg, FL 33702 

cc: Mike Johnson, Fisheries Biologist 
Heinz Mueller, Chief 
Office of Environmental Assessment 

U.S. Environmental Protection Agency 
Sam Nunn Atlanta Federal Center 
61 Forsyth Street S.W. 
Atlanta, GA 30303 
Andy Mager, Chief 
Habitat Conservation Division 
National Marine Fisheries Service 
NOAA, Southeast Region 
9721 Executive Center Drive North, Suite 

St. Petersburg, FL 33702 

Gus Rios, Director 
Florida Department of Environmental 
Protection 
2796 Overseas Highway, Suite 221 
Marathon, FL 33050 

Joe May 
Florida Department of Environmental 
Protection 
Southeast District Office 
400 North Congress Ave 
West Palm Beach, FL 33401 

Rhonda Haag, Director 
South Florida Water Management District 
Florida Keys Service Center 

P.O. Box 24680 
West Palm Beach, FL 33416 
Gerald Briggs, Chief 
Bureau of Onsite Sewage, HSES 
Florida Department of Health 
4052 Bald Cypress Way Bin #A08 
Tallahassee, Fl 32399-1713 

Bart Bibler, Chief, 
Bureau of Water Programs, HSEW 
4042 Bald Cypress Way 
Tallahassee, FL 32311 

Bob Paulson, Acting Branch Chief 
Regulatory Permits Division 

U.S. Army Corps of Engineers 
400 North Congress Avenue, Suite 130 
West Palm Beach, FL 33401 
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Appendix G 
Federal and State Agency Correspondence 

Vic Anderson 

U.S. Army Corps of Engineers 
Field Office 
2796 Overseas Highway 
Marathon, FL 33050 
Allan L. Egbert 
Executive Director 
Florida Fish and Wildlife Conservation 
Commission 
Office of the Executive Director 
620 S. Meridian Street 
Tallahassee, FL 32399-1600 

Roger Braun 
Executive Director 
Florida Keys Aqueduct Authority 

P.O. Box 1479 
1100 Kennedy Drive 
Key West, FL 33040 
Bill Causey 
Superintendent 
Florida Keys National Marine Sanctuary 

P.O. Box 500368 
Marathon, FL 33050 
Tim McGarry 
Monroe County Growth Management 
Director 
2798 Overseas Highway 
Marathon, FL 33052 

Rebecca Jetton 
Planning Manager 
Marathon Regional Service Center 
2796 Overseas Highway, Suite 212 
Marathon, FL 33050 

Bradley J. Hartman, Director 
Office of Environmental Services 
Florida Fish and Wildlife Conservation 
Commission 
620 South Meridian Street 
Tallahassee, FL 32399-1600 

Teresa Tinker 
Policy Coordinator 
Growth Management and Strategic Planning 
Office of the Governor 
1501 Capitol 
Tallahassee, FL 32399-0001 

Miles Anderson 
Division of Emergency Management 
Florida Department of Community Affairs 
2555 Shumand Oak Blvd. 
Tallahassee, FL 32399-2100 

David B. Struhs 
Florida Department of Environmental 
Protection 
Douglas Bldg, RM 1041a 
3900 Commonwealth Blvd., MS10 
Tallahassee, FL 32399-0001 


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Appendix H 
Funding and Financing Options



 Appendix H 
Funding and Financing Options 

Funding and Financing Options for Wastewater Management Activities in the Florida Keys 

The funding and financing options contained in this Appendix identify, in general terms, the 
range of sources that may be used to fund wastewater treatment activities in the Keys as 
identified in the MCSWMP and by project applicants (Monroe County, 2000a). The actual 
funding and financing vehicles used by the project applicant would be project-specific and 
evaluated in the project-specific SER. As noted in Section 3.6.3, Local Fees and Taxes, the 
availability of funding and the specific types of financing affect the rates charged to wastewater 
users. 

In general, the various wastewater funding and financing options fall into one of the following 
categories: 

 User fees and charges 
 Taxes and assessments 
 Grants and contributions 
 Redirection of existing Programs or funding 
 Financial assistance for low and fixed income users 
 Doing more with less 
The following describes various funding and financing options associated with each of these 
categories. 

I. USER FEES AND CHARGES 
User fees and charges are collected for the provision of the services that provide a specific 
benefit to a user. Various types of user fees and charges are described below. 

Wastewater Rates and Charges 

For most utilities, their primary source of revenue is the rate charged to customers. Publicly 
owned utilities are typically operated as Enterprise Funds within the local governments 
organization. Enterprise funds are intended to be managed like a business, and are typically 
expected to be self-supporting, although many utilities do receive additional funds from the city 
or countys general fund. In addition to paying for on going operation and maintenance (O&M) 
costs, portion of a utilitys rate-generated revenues is used to directly fund minor capital 
programs, as well as to repay the debt service on any outstanding bonds or loans. Rate revenues 
may be dedicated to a capital reserve account and used to fund annual capital improvements, or 
may be accumulated until sufficient to fund larger projects. This is the most common method 
used for funding equipment renewal and replacement requirements. Wastewater may include a 
minimum or fixed charge that does not vary from billing period to billing period (most 
frequently month to month), and/or a volume charge that may be based on the users water 
consumption or metered wastewater flows. 


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 Appendix H 
Funding and Financing Options 

Miscellaneous Fees and Charges 

Most utilities also charge customers miscellaneous fees for services that the utility may provide, 
or to provide incentives, such as for prompt payment of bills. These fees are typically designed to 
recover the utilitys costs incurred to provide these specific services, or to recover the costs the 
utility incurs because of the customers actions (service line clean outs, lost interest income, 
etc.). 

Connection Fees 

Hook-up, tap, or connection fees are charges collected for the new connections to a community 
wastewater system. In many communities, connection fees are designed to recover just the cost 
the utility incurs to install the service connection to the sewer main. 

Impact Fees 

Impact fees, like connection fees, are collected at the time a user connects to the wastewater 
system. Impact fees are intended to recover the costs the utility incurs to oversize its 
transmission, treatment, and disposal facilities to provide capacity to serve new users. The intent 
of these charges is to avoid charging existing customers for the costs the utility is incurring to 
serve future customers. 

Line Extension Fees 

Some utility companies charge a fee for extending collection and or transmission lines to serve a 
new customers property. This charge, which is generally based on the number of feet that the 
collection or transmission line must be extended to serve the property, may be collected in 
addition to the connection and impact fees. 

Service Availability Fees 

Community water and wastewater utilities frequently require development properties to connect 
to the system once service is available (i.e., when a collection line has been constructed along 
their property). In some communities, where the local government has opted not to require a 
connection to the system, service availability fees have been implemented. The service 
availability fees are typically designed to recover capital costs that the utility has incurred to 
make service available to user, which the user is choosing not to exercise. These types of fees are 
currently being challenged in Florida courts. 

II. TAXES AND ASSESSMENTS 
Taxes are used to fund activities that do not provide a specific benefit, but provide a more 
general benefit to the community; the user may not be able to avoid paying the tax. Assessments 
must show a benefit to the property owned by the user. The various forms of a common taxes 
and assessments are described in the following section. 


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 Appendix H 
Funding and Financing Options 

Local Improvement District Assessments 

The extension of lines to serve existing development is frequently accomplished through the 
creation of a local improvement district (LID). LIDs are created for the specific purpose of 
financing capital improvements (e.g. roads, water lines, sewer lines, street lighting, and/or storm 
water improvements) to serve a specific area. Once the LID has been created, special 
assessments bonds can be issued, which are secured by liens on the properties located within the 
LID. Debt service on the bonds issued to finance the improvements is recovered through annual 
assessments on the property located in the LID. For the sewer line improvements, a property 
owners share of cost of the improvements is frequently based on the front footage of the 
property along which the sewer line is being laid. For improvements involving more than laying 
the sewer lines, other bases for the assessment are generally collected in the users annual 
property tax bill. 

Sales Tax/Local Option Tax 

A 1-cent (1-percent) sales tax is used frequently to provide funding for a variety of projects and 
activities, from schools to highways. Monroe County currently receives revenues from a local 
option sales tax to fund grants for its cesspool replacement program. Residents, tourist, and 
businesses all pay a sales tax on purchases made in the County. 

Property Tax 

Property taxes are assessments charged to real property owners based on a percentage (millage 
rate) of the assessed property value. These taxes generally support the majority of a countys 
non-enterprise fund activities. However, the revenues from property taxes can also be used for 
enterprise fund projects, and have been used in many communities to pat debt service on general 
obligation bonds issued to finance wastewater system improvements. Because communities are 
limited in the total of millage rate, use of property taxes to fund wastewater management 
improvements could limit the countys ability to raise funds for other activities. 

Municipal Services Taxing/Benefit Unit 

Municipal services Taxing Units (MSTUs) and Municipal service Benefit Units (MSBUs) can be 
established through annual property taxes or assessments to generate funds for projects. Unlike 
LIDs, MSTUs and MSBUs can be used to fund both capital and annual O&M costs. Ad valorem 
taxes are generated from MSTUs; special assessments generate funds in MSBUs. The taxes and 
assessments are levied on property owners. Unlike the process required for raising the millage 
rate on property taxes, no referendum is required to levy taxes or assessments in an MSBU or 
MSTU, unless the revenues are used for leveraging bonds. The taxes associated with MSTUs are 
subjected to the cap on the total millage rate. Therefore, use of MSTU to generate funds would 
constrain the future taxing ability of the County. 

Bed Tax 

The bed tax generates revenues from tourists expenditures at hotels, motels, and short-term 
lodging. Like a sales tax, a bed is usually based on a percentage of expenditures, however, the 


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 Appendix H 
Funding and Financing Options 

tax would be limited to expenditures at a hotel or a motel for lodging, and therefore has little or 
no direct impact on residents. Monroe County currently collects a 4-percent bed tax, out of 
which 1% goes to the county land development authority, and the other 3% goes to the countys 
Tourist Development Council. 

Real Estate Transfer Tax 

A real estate transfer tax is collected from all sales of real estate in a county. The tax is levied at 
the time of transfer of real property. These types of taxes may be based on a percentage of 
assessed value or may be a flat deed registration fee, or both. New property owners would be 
responsible for paying the real estate transfer tax. 

Tax Increment Financing 

In areas where publicly financed redevelopment is raising property values, tax increment 
financing (TIF) can be used to fund new projects. With TIF, the incremental increase in ad 
valorem tax revenues that are a consequence of rising property values (which in turn results from 
the planned improvements) is dedicated to repaying the debt that financed the capital projects in 
that area. This approach to funding projects is applicable only in areas undergoing 
redevelopment. 

III. BONDS AND LOANS 
Revenue Bonds 

Revenue bonds are bonds that are secured by a pledge of the revenues of the utility. The utility 
issuing bond pledges to generate sufficient revenues annually to cover the systems operating 
costs, plus meets the annual debt service requirements (principal and interest payment) times a 
factor, termed the coverage factor, which is designed to provide additional protection to the 
bondholders. The coverage factor generally ranges from 110 to 150% of the utilitys annual or 
maximum annual debt service requirement in the present or any future year. 

General Obligation Bonds 

Cities, counties, and special districts generally are able to issue general obligation (GO) bonds 
that are secured by the full faith and credit of entity. In this case, the local government issuing 
the bonds pledges to raise its property taxes or use any other source of revenue, to generate 
sufficient revenues to make the debt service payments on the bonds. A general obligation pledge 
is stronger pledges than a revenue pledge, and thus must carry a lower interest rate than a 
revenue bond. Frequently, when local government issue GO bonds for utility improvements, the 
utility will make the debt service payments on the GO bonds with revenues generated though the 
utilitys rates and charges. However, if those rate revenues are insufficient to make the debt 
payment, the local government is obligated to raise taxes or use other sources of revenue to make 
the payments. 


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 Appendix H 
Funding and Financing Options 

Local Improvements District Bonds 

LID bonds are secured by a lien on the property in the LID. Debt services payments on these 
bonds are funded through annual assessments to the property owners in the LID, as discussed 
previously. 

State Revolving Fund Loans 

The State of Florida, like most states, operates a state revolving fund (SRF) loan program that 
offers qualified local governments/utilities below-market-rate loans for wastewater projects. The 
State Revolving Loan Fund in Florida is administered by FDEP through the Water Facilities 
Funding Program. It makes low-interest loans available for construction, rehabilitation, and 
replacement of facilities needed to collect, treat, dispose of, or reuse municipal wastewater. It is a 
revolving fund because loan repayments are used to make additional loans. Loans are made for a 
20-year term, with interest rates set at about 60% of the present market interest rate. SRF loans 
are generally limited to $10 million per entity per year 

State Bond Loan Program 

The FDEP and the Division of Bond Finance of the Department of General services jointly 
administer the State Bond Loan Program. The program generally issues bonds that are sized to 
provide sufficient funds to meet the capital financing needs of several communities or entities 
participating in the program. The state will then loan the bond proceeds to these entities at an 
interest rate slightly higher than the interest rate that the state is paying on bonds. Frequently, the 
entities participating in the program are smaller communities or entities without the credit history 
or capability to enter the bond market on their own. These entities get the benefit of being able to 
gain lower interest rate than they would be able to obtain on their own. 

Commercial Loans 

Banks and other financial institutions may make commercial loans to local governments to fund 
capital projects. For utilities, these loans are typically secured by a pledge of a utilitys revenues, 
but may also carry a general obligation pledge. 

IV. GRANTS AND CONTRIBUTION 
A number of state and federal grant programs are available to provide funding support for local 
governments and/or utilities to implement specific aspects of their wastewater management 
program. Grant monies may also be available to qualified homeowners. 

At the time of the release of the PEA, the Village of Islamorada and the FKAA have applied for 
various federal and state grants for wastewater projects. The program, funding agency, and 
estimated value of these grants are listed in Table H-1. Additional information about the types of 
grant programs is described below. 


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 Appendix H 
Funding and Financing Options 

Table H-1: Potential Federal and State Assistance Programs Identified by 
Project Applicants for Wastewater Projects 


Program Funding Agency Local Recipient Estimated 
Value 
Unmet Needs Grant 
Program 
FDCA/FEMA Village of 
Islamorada 
$2,300,000 
requires local 
match of 
$329,000 
Water Advisory Panel 
Funding Program 
FDEP Village of 
Islamorada 
$900,000 
requires local 
match of 
$225,000 
Wastewater Project 
Assistance Program 
SFWMD Village of 
Islamorada 
$75,000 
Unmet Needs Grant 
Program 
FDCA/FEMA FKAA $11,350,906 

Source: FEMA Region IV, Village of Islamorada, FKAA 

Cesspool Identification and Elimination Grant Program 

Monroe County has implemented a grant program to assist homeowners with replacing 
cesspools. This program provides a grant for at least 62% of the capital cost of an OWNRS. 
Homeowners whose homes have an assessed value of between $100,000 and $200,000 receive 
an additional grant of $1,000 over the 62-percent grant amount, or 69% of the total capital costs 
of these systems. This program is funded through revenues generated from grants from the 
Florida Department of Environmental Protection and the Florida Department of Community 
Affairs, as well as from funds from Monroe Countys infrastructure sales tax (Monroe County, 
2001a). 

Water Advisory Panel Grants 

The State of Florida created a water advisory panel in Fiscal Year 1999, which administers a 
grant program that provides funds for projects that: reduce recurring violations of state water 
quality standards; resolve a public health threat; reduce discharges of pollutants into an impaired 
water bod; and reduce discharges into groundwater supplies. Each project must be sponsored by 
a local governmental entity, including, but not limited to, a city, county, water and sewer district, 
or a water management district. The project must be identified in an approved local, water 
management district, or Department of Environmental Protection water management plans as 
part of a surface water restoration effort. Priority is given to projects that address an area to be 
served with a population of less than 7,500 and a median household income of less than the 
statewide median household income. The project sponsor or grant recipient must provide for at 
least a 50-percent match of the total project cost. Matches may include funds from other local, 
state, and federal sources and in-kind contributions. Reductions in the match requirement may be 
considered, based on a demonstration by the project sponsor of inability to provide the match, to 
the satisfaction of the panel. 


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 Appendix H 
Funding and Financing Options 

Federal Agencies 

A number of federal agencies, in addition to FEMA, have programs that can provide funding to 
assist in improvements to wastewater management in the Keys. Potential grant funding sources 
include the Environmental Protection Agency, Department of Interior, Department of Housing 
and Urban Development, Department of Transportation, and Department of Agriculture. 
Potential federal grant funding programs are identified in the following table. 

Table H-2: Potential Federal and State Assistance Programs Related to Wastewater 

Program Funding Agency Program Objective Range and Type of 
Financial Assistance 
Water Quality 
Cooperative 
Agreements 
(Clean Water Act, 
Section 104(b)(3), 
Public Law 92-500, as 
amended; 33 U.S.C. 
1254(b)(3)) 
http://www.cfda.gov/st 
atic/p66463.htm 
EPA To assist in developing, 
implementing, and 
demonstrating innovative 
approaches relating to the 
causes, effects, extent, 
prevention, reduction, and 
elimination of water 
pollution. 
Project Grants 
$5,000 to $500,000 
Wastewater Operator 
Training Grant 
Program 
(Federal Water 
Pollution Control Act 
as amended, Section 
104(g)(1); 33 U.S.C. 
1251 et seq.) 
http://www.cfda.gov/st 
atic/p66467.htm 
EPA To substantially enhance 
the proficiency of 
personnel engaged in the 
operations and 
maintenance of treatment 
works and related 
activities by financing 
pilot programs 
Project Grants 
$35,000 for State-wide 
assistance 
Capitalization Grants 
for State Revolving 
Funds 
(Clean Water Act, 
Public Law 95-217, as 
amended; Water 
Quality Act of 1987, 
Sections 601 through 
607, 205(m), Public 
Law 100-4.) 
http://www.cfda.gov/p 
ublic/viewprog.asp 
EPA To create State Revolving 
Funds (SRFs) through a 
program of capitalization 
grants to States which will 
provide a long term 
source of State financing 
for construction of 
wastewater treatment 
facilities and 
implementation of other 
water quality management 
activities (see 66.418). 
Formula Grants 
$10,000,000 to 
$216,000,000; average 
$30,000,000 


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 Appendix H 
Funding and Financing Options 

Program Funding Agency Program Objective Range and Type of 
Financial Assistance 
Construction Grants 
for Wastewater 
Treatment Works 
Clean Water Act, 
Public Law 92-500, as 
amended; Public Laws 
97-117 and 95-217; 
Water Quality Act of 
1987, Public Law 1004; 
Public Law 96-483; 
and Public Law 101144 
http://www.cfda.gov/st 
atic/p66418.htm 
EPA To assist and serve as an 
incentive in construction 
of municipal wastewater 
treatment works which are 
required to meet State 
and/or Federal water 
quality standards and 
improve the water quality 
in the waters of the United 
States. 
Project Grants 
$10,000 to 
$10,000,000; 
average $3,000,000. 
Water Pollution 
Control State and 
Interstate Program 
Support 
(Clean Water Act, 
Section 106, as 
amended, Public Law 
95-217, 33 U.S.C. 
1251 et seq) 
http://www.cfda.gov/st 
atic/p66419.htm 
EPA To assist in establishing 
and maintaining adequate 
measures for prevention 
and control of surface and 
ground water pollution. 
Formula Grants 
$60,000 to $9,000,000 
Water Reclamation and 
Reuse Program 
Reclamation 
Wastewater and 
Groundwater Study 
and Facilities Act, Title 
XVI, Public Law 102575, 
as amended 
http://www.cfda.gov/st 
atic/p15504.htm 
Department of the 
Interior 
This Title gives 
Reclamation general 
authority to conduct 
appraisal and feasibility 
studies on water 
reclamation and reuse 
projects. It also provides 
general authority for 
research and 
demonstration programs 
to test water reclamation 
and reuse technologies. 
Formula Grants 
Construction 
funding is limited 
to 25% of the 
construction cost or 
$20 million per 
project. 


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 Appendix H 
Funding and Financing Options 

Program Funding Agency Program Objective Range and Type of 
Financial Assistance 
Community 
Development Block 
Grants/State's Program 
Housing and 
Community 
Development Act of 
1974, Title I, as 
amended, Public Law 
93-383, 88 Stat. 633, 
42 U.S.C. 53 
http://www.cfda.gov/st 
atic/p14228.htm 
HUD The primary objective of 
this program is the 
development of viable 
urban communities by 
providing decent housing, 
a suitable living 
environment, and 
expanding economic 
opportunities, principally 
for persons of low and 
moderate income. 
Formula Grants 
Community Services 
Block Grant  
Discretionary Awards 
Community 
Opportunities, 
Accountability, 
Training, and 
Educational Services 
Act of 1998, Title II, 
Section 680, Public 
Law 105-285. 
http://www.cfda.gov/st 
atic/p93570.htm 
HHS To support program 
activities of national or 
regional significance to 
alleviate the causes of 
poverty in distressed 
communities which 
promote: 
(among other things) a 
better standard of living 
for rural low-income 
individuals in terms of 
water and waste water 
treatment 
Project Grants 
$75,000 to $500,000 

Direct Federal Funding 

For projects with national significance, Congress can appropriate federal funds for certain uses. 
The Florida Keys Water Quality Improvement Act (FKWQIA) was authorized by U.S. Congress 
to fund water quality improvements in the Keys through the Water Resources Development Act 
of 2000. This bill authorized $100 million to be administered through USACE; however, the 
funding has not yet been appropriated and its future availability remains uncertain. 

VI. FINANCIAL ASSISTANCE FOR LOW AND/OR FIXED INCOME USERS 
Several programs are designed to reduce the cost of providing wastewater services to users of 
limited means, including: 


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 Appendix H 
Funding and Financing Options 

 Lifeline Rates 
 Cesspool Replacement Grants 
 Assessment Deferral Programs 
Lifeline Rates 

Some communities provide discounts on the monthly wastewater bills to users who are below 
certain income levels. A more common practice is to set rates that have a low minimum charge 
and/or use fee for a minimum (lifeline) level of service. Higher rates are then collected from 
users with higher levels of water consumption (and thereby higher estimated wastewater flows). 

Cesspool Identification and Elimination Grant Program. 

The Cesspool Replacement Program described previously is available to users at 62 to 84% of 
the cost of the installation of an OWNRS on-site system, based on improved property values. 

Assessment Deferral Programs 

A program could be established to allow low-income and/or fixed-income users who are required 
to connect to a community wastewater system to defer their costs of connecting to the 
wastewater system and/or LID assessments until such time as their property is sold. The interest 
expense on the deferred assessments or connection fees could be paid through a fund established 
for this purpose. The deferred assessments and connection fees would constitute a lien on the 
property, which would need to be satisfied upon the sale of the property. External funding would 
be needed to establish the fund for providing the interest subsidy for these low-income users. 


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Appendix I 
Notice of Intent to Prepare Environmental Assessment 
Public Notice 



 Appendix I 
Public Notice 

PUBLIC NOTICE


The Federal Emergency Management Agency (FEMA) has received grant applications to fund the construction of 
several wastewater treatment systems in Monroe County, Florida. Much of the proposed project funding would be 
provided through FEMA 1249-DR Post Disaster - Unmet Needs funds. Matching funds will be provided through the 
Florida Division of Emergency Management and local government applicants. 

FEMA hereby publishes notice of intent to prepare an Environmental Assessment (EA) for these actions, pursuant to 
the National Environmental Policy Act (PL 91-190) and associated environmental statutes, as implemented in 
FEMAs regulations 44 CFR Part 10. This EA will address the purpose and need of the proposed projects, project 
alternatives considered, affected environment, environmental consequences, and impact mitigation measures. Once 
completed, the Draft EA will be available for public review and comment. Notice is also published in accordance 
with Executive Order 11988, Floodplain Management; as implemented in 44 CFR Part 9, since these actions may 
affect the floodplain. 

Grant Applicants: 

 Florida Keys Aqueduct Authority 
 Islamorada, Village of Islands 
Proposed Actions: 

Florida Keys Aqueduct Authority: 
One grant application proposes a regional wastewater treatment plant on Key Largo. The proposed treatment 
capacity of this facility is 2.5 million gallons a day. The applicants preferred project site alternative is located at 
Mile Marker 100.5, Oceanside. Two additional grant applications are being developed for small wastewater 
treatment facilities elsewhere in Monroe County. The details will be published as they become available. 

Islamorada, Village of Islands: 

The grant application does not specify the scope of work or project locations. These details are scheduled to be 
developed in 2001, and will be published as they become available. 

Comment Period: 

Comments concerning the proposed projects will be accepted from the affected public; local, state and federal 
agencies; and other interested parties in order to consider and evaluate the environmental impacts of the proposed 
projects. Comments should be made in writing, sent to the FEMA point of contact listed below, and postmarked 
within 30 days of publication of this notice. 

Points of Contact: 

 Ms. Science Kilner, Lead Environmental Specialist  Unmet Needs, FEMA Region IV 
Mitigation Division, 3003 Chamblee Tucker Road, Atlanta, GA 30341-4130 
Telephone: (770) 220-5422 
Fax: (770) 220-5440 
 Mr. Miles Anderson, Planning Manager  Unmet Needs, Florida Division of Emergency 
Management, 2555 Shumard Oak Boulevard, Tallahassee, FL 32399-2100 
Telephone: (850) 922-4442 
Fax: (850) 922-0325 
 Mr. Roger Braun, Executive Director, Florida Keys Aqueduct Authority, P.O. Box 1239, 
Key West, FL 33041-1239 
Telephone: (305) 296-2454 
Fax: (305) 296-3521 
 Ms. Zully Williams, Project Manager, Islamorada, Village of Islands, P.O. Box 568, 
Islamorada, FL 33036 
Telephone: (305) 664-2345 
Fax: (305) 664-2399 
[The above public notice was posted in the Key West Citizen, the Keys Keynoter, and Reporter in August and/or 
September 2000.] 


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Appendix J 
Supporting Information for the Low-Income Demographic



 Appendix J 
Supporting Information for the Low-Income Demographic 

Table J-1: Examples of Costs to Service Recipients Using FEMAs Assistance Guidelines 

SYSTEM CAPITAL COSTS $2,500 $3,000 $3,500 $4,000 $4,500 
Very-low-income Assistance Amount (90%) $2,250 $2,700 $3,150 $3,600 $4,050 
Very-low-income Pays this Amount $250 $300 $350 $400 $450 
Low-income Assistance Amount (70%) $1,750 $2,100 $2,450 $2,800 $3,150 
Low-income Pays this Amount $750 $900 $1,050 $1,200 $1,350 

EXISTING SYSTEM ABANDONMENT/NEW 
LATERAL INSTALLATION COSTS $1,500 $2,000 $3,000 $4,000 $5,000 
Very-low-income Assistance Amount (90%) $1,350 $1,800 $2,700 $3,000 $3,000 
Very-low-income Pays this Amount $150 $200 $300 $1,000 $2,000 
Low-income Assistance Amount (70%) $1,050 $1,400 $2,100 $2,800 $3,000 
Low-income Pays this Amount $450 $600 $900 $1,200 $2,000 

*Note: 90% and 70% abandonment and lateral installation assistance is up to an allowance of $3,000. 

Table J-2: Fiscal Year 2002  HUDs Low and Very Low-Income Limits 
Monroe County, Florida 
Median Family Income = $55,100 

1 person 2 person 3 person 4 person 5 person 6 person 7 person 8 person 
Low-
income $30,850 $35,250 $39,650 $44,100 $47,600 $51,150 $54,650 $58,200 
Very-
Low-
Income 
$19,300 $22,050 $24,800 $27,550 $29,750 $31,950 $34,150 $36,350 

http://204.29.171.80/framer/navigation.asp?charset=utf-8&cc=US&frameid=1565&lc=enus&
providerid=112&realname=HUD&uid=2318084&url=http%3A%2F%2Fwww.hud.gov%2F 

Published annually by HHS.
MFI figures are projected from the most recent county level census data. 



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Appendix K 
Comments on the Draft PEA and Responses



APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES 


TABLE OF CONTENTS


1.0 Introduction.................................................................................................................................K-2 


2.0 List of Commenters K-3 

2.1 STATE AGENCIES.......................................................................................................K-3 


2.2 GROUPS AND INDIVIDUALS....................................................................................K-3 


2.3 WORKSHOP PARTICIPANTS.....................................................................................K-3 


3.0 COMMENTS AND RESPONSES............................................................................................K-3 


3.1 STATE AGENCIES.......................................................................................................K-3 


3.2 GROUPS AND INDIVIDUALS....................................................................................K-3 


3.3 WORKSHOP PARTICIPANTS.....................................................................................K-9 


3.4 WEBSITE.....................................................................................................................K-14 


4.0 COMMENT LETTERS ..........................................................................................................K-16 


4.1 Letters from Federal, State, and Local Government Representatives and Agencies K-16 

4.2 Public Response Letters K-17 


APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES 


1.0 INTRODUCTION 
The Draft PEA was made available for public comment during the period of. September 20, 2002 to 
October 18, 2002, inclusive. Additionally, to further solicit public comments on the Draft PEA, FEMA 
held two workshops on October 8th and 9th. FEMA received comments from state agencies as well as 
individuals. Section 2.0 of this Appendix presents a list of those individuals and agencies that submitted 
comments on the Draft PEA. Section 3.0 of this Appendix includes summaries of comments received on 
the Draft PEA and responses to those comments. Any comments received after October 18, 2002, will be 
considered prior to any FEMA action; however, those comments are not included in Appendix K. Copies 
of all letters received are part of the public record for this project, and are available for viewing on the 
FEMA Internet Web site at http://www.fema.gov/ep/assess.shtm. 


Draft Programmatic Environmental Assessment


-Appendices 


Wastewater Management Improvements 
in the Florida Keys, Florida 


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 


APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES 


2.0 List of Commenters 
2.1 State Agencies 
Agency Commenter Title ID 

Florida Division of Historical Resources Janet Snyder Matthews, PhD Director and State Historic S1

Preservation Officer 

2.2 Groups and Individuals 
Commenter Affiliation Title ID 

Bacchus Sydney, PhD Hydroecologist G1 
Niebler-Spare Luciann G2
Wilkinson Jerry G3 


2.3 Workshop Participants 
Commenter Affiliation Title ID 
October 8th W1
Workshop 
Participants 
October 9th W2
Workshop 
Participants 


2.4 Website 
Commenter Affiliation Title ID 
Anonymous WS1 
Anonymous WS2 
Anonymous WS3 
Bloding Alison Bio-Microbics Regulatory Affairs Coordinator WS4 
Casey Richard Monroe County Housing Programs Administrator WS5 

Authority 

3.0 Comments and Responses 
State Agencies 

S1 Florida Division of Historical Resources (11-Oct-02) 

Comment Summary S1: The nature and location of some proposed activities in undisturbed areas 
are such that they could impact historic properties. In accordance with Section 106, the proposed 
project activities should be submitted to the Division of Historical Resources for review and 
comment to determine any potential impact on historic properties. 

Response S1: Comment noted. During the Supplemental Environmental Review (SER) process, 
proposed project activities would be submitted to the Florida Division of Historical Resources for 
review and comment prior to the release of FEMA funds. 

Groups and Individuals 

G1 Sydney Bacchus, PhD (17-Oct-02) 

Comment Summary G1-1: Subsection numbers in the Table of Contents do not correspond to the 
Report, making it difficult to locate information in the Draft PEA 

Response G1-1: Section references throughout the report have been revised to match the 
documents Table of Contents. 


APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES 


Comment Summary G1-2: The Draft PEA does not adequately answer the questions posed on the 
Web site soliciting comments regarding the Draft PEA. There is no scientific basis to support the 
use of Improvements in the Draft PEA title. 

Response G1-2: As described in the Draft PEA, there are a number of analyses that demonstrate 
that septic tanks and cesspits contribute to degraded water quality in inland, nearshore and 
offshore waters of the Keys. These include Lapointe et al. (1990), Lapointe and Clark (1992), 
Paul et al. (1995a), Paul et al. (1997), Shinn et al. (1994), and EPA (1993a) referenced in 
Sections 1.4, 1.5, 1.9 and 3. It is generally accepted that the implementation of more stringent 
water quality standards for discharged effluent would improve water quality by reducing 
loadings of nitrogen, phosphorus, and fecal coliform bacteria. As described in Section 3.2.2.2.1, 
these improvements were demonstrated by Ayres and Associates (1998) in the Big Pine Key 
Demonstration Project. As of result of treating effluent to Florida Statutory Treatment 
Standards, there was a 92% reduction in Total Nitrogen and 86% reduction in Total Phosphorus 
to groundwater. 

Comment Summary G1-3: Extensive comments sent by Lesley Blackner on March 26, 2001 
were not considered in the preparation of the Draft PEA. 

Response G1-3: Although the comments sent by Lesley Blackner were received more than one 
year prior to the public comment period for the Draft PEA, they were taken into consideration 
when drafting the PEA. Highlights of Ms. Blackners comments include NEPA compliance, 
concern of wastewater injection into Floridas aquifers, and consultation with the U. S. Fish and 
Wildlife Service (USFWS) per the Endangered Species Act (ESA). FEMA published its intent to 
prepare an Environmental Assessment in Monroe County newspapers in August of 2000. Future 
notices will be released as FEMA prepares the project and site-specific SERs. The Draft PEA is 
developed in accordance with NEPA, and includes consultation with USFWS and several other 
local, regional, state and federal agencies. The list of agencies contacted is located in Appendix 
G of the Draft PEA. Project and site-specific ESA consultations will be completed as part of the 
SERs. FEMA completed a formal ESA Section 7 consultation with the USFWS in June of 2001 
for a proposed Key Largo wastewater project, the details of which will be released in the SER for 
that project. Ms. Blackners letter also outlines 10 points of concern related to the injection of 
wastewater effluent. The following sections of the Draft PEA address each point: 1) wastewater 
movement in Floridas aquifers (Section 3.1.3); 2) confining zones in aquifer layers (Section 
3.1.3); 3) flow path of injected effluent (Section 3.1.3); 4) speed of effluent movement into 
nearshore surface waters (Sections 3.2.2.1 and 3.2.2.2.2); 5) effect of Florida Bay on surface 
waters (Sections 1.4 and 4.2); 6) effect of Florida Bay on surface waters (Section 1.4 and 4.2); 7) 
nutrient levels of injected effluent (Sections 1.7, 2.3.2, and 2.3.3); 8) availability of 
comprehensive studies on fate of aquifer-injected effluent (Sections 3.2.2 and 3.2.3); 9) opinion 
related to inadequacy of state permitting process (comment noted); 10) opinion related to 
inadequacy of state permitting process (comment noted). The project- and site- specific effects of 
this alternative will be analyzed and presented in the SERs. 

Comment Summary G1-4: Local-government officials are only considering highly-engineered 
alternatives without any regard to the direct, indirect, and cumulative environmental impacts of 
the pre-selected alternatives. Islamorada had already published Requests for Proposals (RFP) 
to convert to the highly-engineered alternatives being analyzed in the PEA, to which URS 
submitted a bid (subsequently withdrawn). URS bidding on a FEMA funded project and 
subsequently recommending to FEMA, as its consultant, this is the preferred alternative, appears 
to be a conflict of interest. 

Response G1-4: Pursuant to NEPA, FEMA only requires its applicants to consider one relevant, 
practicable project alternative, in addition to no action and the preferred alternative. If the 


APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES 


commenter is referring to the RFP issued by the Village of Islamorada on March 4, 2000, for a 
company to design, build and operate a community wide wastewater treatment system, the three 
firms that submitted proposals were UEM, Inc., Ogden Water Systems and Florida Water 
Services. The Village has since elected not to pursue this proposal for FEMA funding. The PEA 
presents alternatives listed in the Monroe County Sanitary Wastewater Master Plan, of which 
FEMAs applicants proposed specific alternatives for funding. URS has been tasked to analyze 
the effects of the projects proposed by Monroe County applicants; it has not been tasked to 
recommend alternatives. 

Comment Summary G1-5: Pre-disposed bias of URS to support and select alternatives that 
involve injection of waste into Floridas aquifer system can be found in the background of their 
Preparers, who have developed the State of Floridas rule that allows aquifer-injection of 
waste. 

Response G1-5: FEMAs applicants selected the project alternatives, including underground 
injection of wastewater. The preparers of the document were not involved in the State of 
Floridas rule on aquifer injected wastewater; however, selected technical peer reviewers of the 
PEA so have this experience and were chosen due to their subject matter expertise. FEMA 
independently verified the information and analyses in the PEA, and made its own conclusions. 
Also note response to G1-4 above. . 

Comment Summary G1-6: FEMA should obtain an opinion from the Department of Justice 
regarding whether it is legal for a firm such as URS, (which previously attempted to secure 
contracts for activities they later selected as recommended alternatives for the funding agencys 
Draft EA), to be hired by federal agencies to prepare EAs or related documents, particularly since 
they will provide additional contract opportunities for their firm in the future. 

Response G1-6: Refer to response G1-4. 

Comment Summary G1-7: In a previous project for the SunCoast Parkway, URS has admitted to 
falsifying and fabricating information that was contained in their review document. FEMA 
should obtain an opinion from the Department of Justice whether it is legal for a firm such as 
URS, which has admitted to falsifying and fabricating information, should continue to prepare 
evaluation documents. 

Response G1-7: The URS staff who prepared much of this PEA were not involved in the case in 
question. FEMA independently verified the information and analyses in the PEA, and drew its 
own conclusions. 

Comment Summary G1-8: Page Ab-1 of the Draft Problematic EA Abstract states that a 
supplemental environmental review (SER) document (i.e., Supplemental Environmental 
Assessment of the Environmental Impact Statement) would be prepared for each individual 
project covered by this draft PEA. This piecemeal approach of assessment ensures that the full 
direct, indirect, and cumulative impacts on the environment of the Unmet Needs funding cannot 
and will not occur. As only one example, the entire EA focuses solely on the Keys (Monroe 
County). In reality, the water that is combined with human excrement, to create the so-called 
wastewater, is imported into the Keys. The invaluable water resource that is converted into 
waste in the Keys is extracted from the aquifer that supports the Florida Everglades. Therefore, 
the proposed alternative would result in significant adverse impacts to all of the counties 
associated with the Everglades, as well as the entire national and international tourist industry 
associated with the Everglades. Those factors are not addressed in the Draft Problematic EA. The 
enclosed copy of the 1/97 Report describes the types of Cumulative Impacts considered under 
NEPA and the protocol for conducting a Cumulative Impacts Analysis. 


APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES 


Response G1-8: The intent of the PEA is to examine the effects of Keys wastewater treatment 
alternatives directly, and indirectly where appropriate, and when combined with past, present, 
and foreseeable future projects affecting the same resources. Section 4 of the DPEA examines 
cumulative effects. Section 1.4 of the DPEA introduces the sources of nearshore water quality 
degradation in the Keys, followed by a more detailed discussion in Section 3.2.3. Regardless of 
how the wastewater is treated, water usage will not change as a result of the proposed 
alternatives. 

Comment Summary G1-9: The abstract of the EA clearly illustrates that only highly-engineered 
alternatives were considered. A comprehensive Environmental Impact Statement (EIS) and 
Cumulative Impact Analysis need to be conducted by knowledgeable scientists (e.g. National 
Academy of Sciences) without a pre-disposition to highly-engineered alternatives. 

Response G1-9: As discussed in Section 2.2 of the PEA, the alternatives presented in the 
document parallel alternatives studied and approved for consideration by Monroe County in their 
Sanitary Wastewater Master Plan. The purpose of the PEA is to evaluate the environmental 
impact of alternatives, not to formulate project alternatives. The decision-making process for 
wastewater management began in 1997 with the preparation of the Master Plan, involved a 
comprehensive evaluation and prioritization of many variables, and included considerable public 
participation opportunities. Representatives from a citizens task force, a technical advisory 
committee, Board of County Commissioners, and community representatives developed 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. 

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 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. 
Comment Summary G1-10: Under Topography, Soils, and Geology: sinkholes are referenced 
to as a potential effect of aquifer injection, but no reference to the extensive dissolution of the 
aquifer matrix, a near-certain response, is mentioned. 

Response G1-10: Although the text does not use the term aquifer matrix, it describes the 
dissolution of carbonate rock, which, as discussed in Section 3.1.3.1, is the predominant rock 
type underlying the Florida Keys, and hence, comprising the aquifer. The impact and potential 
extent of dissolution would be addressed in the site specific SERs once the projects location and 
magnitude of these projects are determined. As stated in Section 3.1.3.2.2, 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. 

Comment Summary G1-11: There is no scientific basis for the claim under the Water Resources 
& Quality section. 

Response G1-11: Information contained Section 3.2, Water Resources and Water Quality, was 
obtained from scientific articles, technical advisors, state and local government agencies, and 
websites such as: 


APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES 


Florida Keys National Marine Sanctuary (FKNMS). 2001. Water Quality Protection Program 
Overview. Accessed from www.fknms.nos.noaa.gov/research_monitoring/wqpp.html on 
August 9, 2001. 

Halley, R.B., Vacher, H.L., and Shinn, E.A., 1997, Geology and hydrology of the Florida Keys in 
Geology and Hydrology of Carbonate Islands, Developments in Sedimentology 54, pp. 
217-248. Elsevier Science B.V., Amsterdam. 

Kruczynski, William. 1999. Water Quality Concerns in the Florida Keys: Sources Effects, and 
Solutions. Florida Keys National Marine Sanctuary Water Quality Protection Program, 
National Oceanographic and Atmospheric Administration. 

Jones, Ronald and Joseph Boyer. 2001. Water Quality Monitoring Project: FY 2000 Annual 
Report. Published by the Southeast Environmental Research Center, Florida 
International University under contract to the EPA. 

Leckler, Kurt. 2001. Permit Compliance Specialist, South Florida Water Management District. 
Personal communication with Jonathan Randall, URS Group, Inc. 

Monroe County. 1997. Monroe County Year 2010 Comprehensive Plan. Adopted by the Monroe 
County Board of County Commissioners, Department of Community Affairs and 
Administration Commission of the State of Florida. September. 

Comment Summary G1-12: There is no scientific basis for the claim under the first two 
sentences of the Biological Resources section in the Abstract. The claim in the third sentence of 
this subsection regarding activities occurring on developed, disturbed areas with low habitat 
values is without basis. Proposed sites in Key Largo and Islamorada, in addition to the 
withdrawal sites, all involve direct, indirect, and cumulative impacts to a myriad of federally and 
state listed species. 

Response G1-12: The scientific basis for the claims in the Abstract is provided in detail in 
Section 3.3.2. Biological Resources. Habitat values and concerns with state and federal listed 
species for individual sites, including impact minimization measures, will be further addressed 
during the SER process. 

Comment Summary G1-13: The Air Quality section fails to consider impacts from phtyotoxins 
released into the air after planktonic algal blooms that can be triggered by induced 
discharge of injected effluent surface waters. 

Response G1-13: The research indicates that toxins generated by planktonic algae, such as the 
primary toxin found in the Florida Red Tide, can act as eye and throat irritants when the toxins 
become aerosols as a result of wave action. Algal blooms are formed from a variety of 
contributing factors such as temperature, salinity, currents, and nutrients1. A major function of 
the projects proposed in this Draft PEA is to bring presently inadequate wastewater systems (e.g., 
septic tanks and cesspits) into compliance with Florida Statutory Treatment Standards. It is 
expected that this would greatly reduce the nutrients entering nearshore and offshore waters. 

Comment Summary G1-14: The Demographic and Environmental Justice section fails to 
consider direct, indirect, and cumulative adverse impacts on surrounding, low-income areas 
where sludge (generated by the selected alternative) would be dumped and groundwater mining is 
continued. 

1 National Oceanic and Atmospheric Administration (NOAA). 2002. Algae Info. Accessed from 
http://www.chbr.noaa.gov/CoastalResearch/algaeInfo.htm on December 16, 2002. 


APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES 


Response G1-14: Comment noted. As described in Response G1-8, none of the alternatives are 
expected to increase groundwater mining. Section 2.3.2 of the Draft PEA outlines the anticipated 
disposal methods of sludge created by the proposed projects. Sludge would likely be hauled to a 
regional wastewater treatment facility in Miami-Dade County for treatment and then used for 
fertilizer. The Key West WWTP dewaters partially stabilized secondary solids, which are 
disposed of via private hauler at an agricultural land application site near Okeechobee, Florida. 
The disposal of sludge in this manner is not anticipated to result in adverse and disproportionate 
impacts to low income or minority populations. 

Comment Summary G1-15: The Hazardous Materials section fails to consider nonylphenol, an 
endocrine disrupter hazardous to animals, creation by the AWT process. 

Response G1-15: The research indicates that nonylphenol is a degradation product of a 
surfactant widely used for commercial and industrial purposes such as detergents, herbicides and 
cosmetics and the manufacturing of plastics, textiles, agricultural chemicals and paper. 
Nonylphenol formation can occur through wastewater treatment and in natural environments. In 
wastewater treatment processes, it may be formed regardless of whether the waste stream is 
processed by AWT2. The EPA is currently in the process of developing aquatic life criteria for 
nonylphenol3. Once the criteria is finalized, proposed wastewater systems would be required to 
comply with State processing and monitoring standards, as applicable. Before formal rules are 
established, the project applicant would be required to coordinate with FDEP to implement any 
monitoring protocols that were deemed necessary. Section 3.8 of the Draft PEA has been 
updated to include this information and coordination/monitoring requirement. 

Comment Summary G1-16: Letters sent to the EPA and publications from 1996-2002 documents 
my assertions above that the PEA is grossly inadequate and a comprehensive EIS and 
Cumulative Impacts Analysis need to be conducted by knowledgeable scientists (e.g., National 
Academy of Scientists) prior to the release of federal funds from your agency for wastewater-
related activities in Monroe County. 

Response G1-16: Section 1.2 of the PEA outlines FEMAs NEPA review process. In determining 
the appropriate level of NEPA review for the proposed actions, FEMAs criteria for when to 
prepare an Environmental Impact Statement (EIS) were applied, and are found in its NEPA 
implementing regulations at 44 C.F.R Part 10.8(b). At that time, FEMA determined there was 
insufficient information about the group of projects to satisfy the criteria for an EIS level of 
analysis, and elected to prepare a PEA to determine if the group of projects required an EIS. 

Comment Summary G1-17: No zero-discharge alternatives were considered in the 
PEAPracticable, economical, readily-available alternatives to the generation of sludge were not 
considered in the Draft Problematic EA. 

Response G1-17: FEMAs applicants may legally propose any practicable project alternatives. 
As noted in Response G1-9 and discussed in Section 2.1 of the PEA, the alternatives considered 
come from the Monroe County Sanitary Wastewater Master Plan. FEMAs applicants may need 
to be contacted regarding alternatives reconsideration. 

Comment Summary G1-18: In situ, phyto-treatment systems also were not considered. 
Likewise, economical, practical, and readily-available alternatives for reducing pollution from 
stormwater (e.g. in-line filters) also were not considered. 

2 Maguire, James R. 1999. Water Quality Research Journal of Canada. 

3 U.S. Environmental Protection Agency (EPA). 2002. Water Quality Criteria: Nonylphenol. Accessed 
from http://www.epa.gov/waterscience/criteria/aqlife.html on December 16, 2002. 


APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES 


Response G1-18: See Responses G1-17 and G1-8. The projects under consideration are for 
wastewater management only and not for stormwater management. None of the proposed 
projects include combined injection of treated wastewater and stormwater. The cumulative effects 
to water quality from improved stormwater and wastewater management practices are discussed 
in Section 4 of the PEA. 

Comment Summary G1-19: Figures 1-2 and 2-5 are an overly simplistic and highly misleading 
graphic of the aquifer where effluent is proposed to be injected. In reality, the aquifer is 
characterized by both dissolution features and fractures that result in a highly permeable matrix 
with many preferential flow-paths for the migration of injected effluent and other contaminants 
such as stormwater. 

Response G1-19: The intent of Figures 1-2 and 2-5 is to simply illustrate the wastewater 
treatment process for each alternative; it is not intended to illustrate aquifer characteristics. 
Section 3.1.3 discusses the aquifers characteristics in detail and has several figures illustrating 
their characteristics, including Figures 3-2 to 3-5. 

Comment Summary G1-20: Figure 3-6 illustrates that the Study Areas are confined to the 
exposed land form of the Keys, excluding coastal waters such as the Marine Sanctuary and the 
peninsular of Florida, both of which would be affected by the implementation of the Proposed 
Alternative. Likewise, the PEA does not consider water quality degradation factors exterior to 
the Study Area. 

Response G1-20: Figure 3-6 represents stormwater study areas and not wastewater study 
areas. The scope of the PEAs study area has been clarified in Section 1.2 and is represented in 
Figure 1-1. Project and site-specific study areas and areas of effect would be more clearly 
delineated in the SER process. As noted in Response G1-8 water quality degradation factors 
external to the Key are discussed in Sections 1-4 and 3-2-3. 

Comment Summary G1-21: No figures (or other information) were included to show the 
location of all of the existing and proposed shallow and deep injection wells in south Florida, or 
even Monroe and the adjacent countiesLikewise, there were no figures indicating the location 
and nature of the supply wells for the Keys waste water. Groundwater mining has been 
described and documented in published literature, but was not addressed in the Draft PEA. 

Response G1-21: The Florida Department of Environmental Protections Underground Injection 
Control Program and county health departments maintain information on permitted shallow and 
deep injection wells. As described in Section 3.2.2.1 and Kruczynski (1999), there are about 750 
Class V wells currently permitted in the Keys. Including a graphic in the PEA delineating the 
location of all permitted wells in the Keys is not practical considering the number of wells. The 
SERs will include information on existing permitted wells within their service area and may 
include a graphic showing their distribution. Please refer to Response G1-8 for groundwater 
mining comment. 

Comment Summary G1-22: A large percentage of the references are personal communications. 
Many of the references in this PEA are documents other than publications in recognized, peer-
review journals. Consequently, the References section is severely lacking in both the nature and 
number of references. 

Response G1-22: It is the nature of the NEPA process to draw from a number of acceptable 
sources, including peer-reviewed academic journals, government reports, and communication 
with experts knowledgeable in their field, commensurate with an Environmental Assessment 
level of analysis. FEMAs NEPA implementing regulations at 44 CFR Part 10.9 outline 
preparation of EAs. The reference section in the PEA is explicitly designed to present the source 
of information that is referenced in the body of the document. 


APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES 


G2 Luciann Niebler-Spare 

Comment Summary G2-1: What effluent is going to be going down the shallow wells and then 
into Floridas Outstanding Waters? Also, how much fresh water effluent will be moving up 
vertically into the saline waters of the oceans, bays, and canals? 

Response G2-1: The amount of effluent will depend on the site location and disposal alternative 
chosen for each site. Therefore, this concern will be further analyzed in the SER process. 

Comment Summary G2-2: Maybe there should be an experiment between septic systems in the 
area and injection wells. That might be interesting and worthwhile. 

Response G2-2: For clarification, it should be noted that many septic systems in the Keys 
currently use injection wells for disposing of untreated wastewater effluent. An alternative to the 
use of injection wells is the use of septic drain fields. As described in Section 2.4.2, the problem 
with installing septic tanks with drain fields in the Keys is that very little or no natural soils exist 
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. Appendix D of the Draft PEA includes a comparison of the quality of effluent treated to 
Florida Statutory Treatment Standards as compared to a septic system. 

Comment Summary G2-3: There are 554 shallow injection wells in Monroe County. They are 
permitted and then they are on their own, as there is no single map that shows the location of 
these wells. 

Response G2-3: The available research indicates that there are about 750 shallow injection wells 
in the Keys [Section 3.2.2 of the Draft PEA and Kruczynski (1999)]. Comment noted with respect 
to the single map that shows the location of the wells. 

Comment Summary G2-4: There needs to be some overall management of the wells regarding 
their placement and the results of each project. 

Response G2-4: Please refer to Response G1-21 for injection well management. In approving 
project funding, FEMA plans to strongly encourage its applicants to implement a water quality 
monitoring program for each project (see Sections 3.2.2.2.2 and 3.2.2.2.3). 

Comment Summary G2-5: Please look into the possibility of reuse with ultra-violet disinfection. 

Response G2-5: Comment noted. Also, please see Response G1-9. 

Comment Summary G2-6: In Islamorada, we are very concerned with the potential price tag of 
a sewage treatment plant for the whole island (Four islands are involved). There are many 
worried citizens who feel that the village manager and council are trying to move too quickly and 
are not making a realistic effort to show the true costs involved or to investigate all possible 
solutions. 

Response G2-6: The currently proposed Islamorada project only serves one neighborhood. The 
economic effects of the project will be presented in the project and site specific SER, however the 
costs per EDU are expected to be within the range presented in Section 3.6.3.2. 

G3 Jerry Wilkinson (4-Oct-02) 

Comment Summary G3-1: Problem with the degrading of terrestrial environment at the expense 
of a small potential enhancement of the marine environment. Land should be used for 
conservation purposes only. 


APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES 


Response G3-1: The project and site-specific SER will evaluate effects to both the terrestrial and 
marine environments, including impact mitigation measures. 

Comment Summary G3-2: The proposed and purchased 20 acres is about pristine of Key Largo 
hammock as exists today. It has been on the CARL acquisition list and is contiguous to a flyway 
area to its east. All suggestions for the use of the state and federal lands to the north have been 
rejected. Does private ownership make this parcel any less qualified for preservation? 

Response G3-2: Land decisions are made at the county level, and county representatives should 
be contacted regarding site selection. FEMAs applicants may propose any relevant, practicable 
project alternatives, including site selection. FEMA cannot require applicants to propose 
additional alternatives if they have already proposed enough relevant, practicable alternatives. 

Comment Summary G3-3: The present day stated four acres is only hypothetical as if the 
FKAA proposed Request for Proposals is approved to construct a community WWTP on 2 acres, 
the expansion to the future 2.25 mgd regional WWTP will be either impossible or additional 
acreage must be cleared. 

Response G3-3: This concern would be further analyzed during the SER process, when the 
location and magnitude of individual projects would be specified. 

Comment Summary G3-4: I suggest this parcel be accepted as mitigation for some other 
lesser violation. Other parcels of land can be found. To follow chapter 7 of the Monroe County 
Sanitary Master Plan, 10 to 12 other parcels must be acquired on Key Largo; therefore, if only 
one is available, we might as well throw in the towel. 

Response G3-4: The Countys site selection process will be presented in the project and site-
specific SER. 

Workshop Participants 

W1 Workshop Participants (8-Oct-02) 

Comment Summary W1-1: Status of mile marker 100.5? What about FEMA funding relative to 
this project's sunset date? 

Response W1-1: This concern relates specifically to the Key Largo project and would be further 
considered at the SER level. 

Comment Summary W1-2: How can we get both projects in Key Largo moved up so that we do 
not lose funding for both? 

Response W1-2: Funding timelines are at the discretion of state and federal funding agencies. 

Comment Summary W1-3: Could FEMA environmental requirements stop this project after the 
"road to nowhere" has been built? 

Response W1-3: Federal environmental compliance and state and local permitting requirements 
for specific projects would be outlined during the SER process. Receipt of federal funding is 
conditioned on the applicants implementing all required impact mitigation measures and 
obtaining applicable permits before starting work. . 

Comment Summary W1-4: The project footprint for the project keeps changing. Where will the 
project be (the 3-acre site)? I have seen three different footprints for it. Monroe County code 
lets you clear 20% of the site, and I have seen various numbers for that too  4.6% etc. because 
we are now looking at some private property. The footprint seems to have changed since we got 
the information from Fish and Wildlife. 


APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES 


Response W1-4: The size and siting of projects would be specified during the SER process. 

Comment Summary W1-5: Is the environmental assessment comprehensive enough that if we 
want to expand this project to more than three acres, we do not have to do another environmental 
assessment? 

Response W1-5: Yes, as far as the alternatives presented in the PEA are concerned. However, 
the SER process evaluates a specific scope of work and its alternatives; and prescribes impact 
mitigation measures. If a scope of work changes substantially, the environmental analysis must 
be revised. 

Comment Summary W1-6: Many people still question the science of central treatment, 
especially when you consider the cost. Is there any plan to do follow-up studies so that at the 
conclusion of this 20-year project we can say, "we spent the money, we did what we were 
supposed to do, and it worked"? 

Response W1-6: The Draft PEA recommends water quality monitoring be conducted following 
implementation of the proposed projects in Sections 3.2.2.2.2 and 3.2.2.2.3. 

Comment Summary W1-7: Will there be interim studies so that if we get to a point at which we 
have several plants in populated areas, we can say, "It doesn't really make sense to continue this 
process  on a cost-benefit basis we have solved the problem  and on-site systems are okay for 
the rest of the Keys"? 

Response W1-7: No such interim studies have been planned at this time. Implementation of the 
Monroe County Sanitary Wastewater Master Plan is the responsibility of the Florida Keys 
Aqueduct Authority and Key Largo Wastewater District, along with determining if Plan goals 
have been accomplished by mandated deadlines. 

Comment Summary W1-8: What median household income was used in the economic part of 
the study? The census says $36,000 and some. With 42% of children in Largo school system on 
the free lunch program, how do we justify an extra $58/month? This is a serious economic 
impact to the average family. 

Response W1-8: The median household income (MHI) figure of $42,283 as cited in Section 3.6 
was taken from the 2000 census (Table DP-3. Profile of Selected Economic Characteristics: 2000 

 Geographic Area: Monroe County Florida). 
Comment Summary W1-9: How does your study try to prove this is an acceptable impact? 

Response W1-9: Sections 3.6.3 and 3.7.1.2 of the PEA detail the economic impacts and supports 
the claim that the impact is acceptable in two ways. First, 2% of MHI is cited as the affordability 
threshold for wastewater costs as established by the U.S. Environmental Protection Agency and 
by the National Consumer Law Center. Second, an assessment of the estimated average monthly 
costs for household expenses in the Keys (see Section 3.6.3.1.2) was done to calculate 
discretionary income and it was determined that 2% of MHI constituted approximately 7% of 
discretionary income for households at the median income. As 2% of MHI was only 7% of 
discretionary income, for median and higher level income households, the 2% figure was 
concluded to be affordable. The analysis of low-income and very-low-income households 
showed that the impact was indeed unacceptable and therefore assistance guidelines were 
developed. The low-income assistance program provides 70% assistance for System Capital 
Costs; and 70% of assistance for Existing System Abandonment and lateral costs up to an 
allowance amount of $3,000. The very-low-income assistance program provides 90% assistance 
for System Capital Costs; and 90% assistance of Existing System Abandonment and lateral costs 
up to an allowance amount of $3,000. 

Comment Summary W1-10: Where did your income and average cost figures come from? 


APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES 


Response W1-10: Income figures were obtained from the 2000 U.S. Census: Profile of Selected 
Economic Characteristics for Monroe County, Florida, Poverty 2000, and Money Income in the 
United States: 2000, Current Population Reports and also from HUD: Fiscal Year 2002 Low and 
Very Low Income Limits. Average cost figures came from the sources cited in Table 3-6, as 
described in the paragraph below the table, with the details of each source listed in the 
corresponding citation in Section 7: References. 

Comment Summary W1-11: Will this study be the basis for us to support the assistance we are 
going to seek? 

Response W1-11: The low income assistance guidelines presented in the PEA apply only to the 
FEMA funded projects. 

Comment Summary W1-12: Does operation and maintenance cover all administrative costs? 

Response W1-12: For the purposes of the PEA, yes, it covers all administrative costs. 

Comment Summary W1-13: What if the applicants do not provide low-income assistance? 

Response W1-13: To be eligible for FEMA funding, the applicants will be required to, at a 
minimum, provide the assistance levels outlined in the PEA (Section 3.7.1.5) for low-income and 
very-low income qualified families. If the applicants do not comply, they would not receive for 
FEMA funding. 

Comment Summary W1-14: Where do the FEMA dollars for this come from? 

Response W1-14: Under the Emergency Supplemental Appropriations Act for Fiscal Year 1999, 
funding for long-term disaster recovery projects in Florida counties whose needs were unmet 
through primary disaster relief funds, was made available. As a result, Monroe County is eligible 
for Unmet Needs funding from FEMA. 

Comment Summary W1-15: Will low-income assistance be subtracted from the grant money? 
How much of a reduction will that be? 

Response W1-15: Yes, the low income assistance would come from the grant funds. The 
proportion of grant funding earmarked for low income assistance will depend how many project 
service area households qualify for assistance. 

Comment Summary W1-16: Tell us about the Key Largo project specifics, if you have any 
information. 

Response W1-16: The project specifics will be provided during the SER process. 

Comment Summary W1-17: How many dollars do we have and how much money is needed to 
meet the needs of low-income families? Is there enough to take care of the number of people who 
need it? 

Response W1-17: The exact figures of how much funding will be required for low-income 
families will be determined in the SER process. Using very liberal estimates on percentages of 
low-income and very-low-income households, based on census data for Monroe County, 
preliminary estimates indicate that there is enough grant funding to assist low-income households 
at the prescribed levels. 

Comment Summary W1-18: If applicants have to provide this level of assistance in order to get 
FEMA dollars, who determines the level of assistance? 

Response W1-18: The required levels of assistance were determined by FEMA. Please see 
Section 3.7.1.5 in the PEA. 


APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES 


Comment Summary W1-19: How do assets play into the income qualification criteria? Are 
there any limits on assets? 

Response W1-19: As per HUDs policy, only the interest made on assets is counted as income. 
The actual value of the asset is not counted and has no bearing on income qualification. 

Comment Summary W1-20: I do not agree that $75/month is an acceptable or affordable price, 
no matter what your median income. It is too high. 

Response W1-20: As noted in Response W1-9, the Environmental Protection Agency, 
Department of Housing and Urban Development, and the National Consumer Law Center all use 
a percentage of median household income as their measure of affordability. Establishing 
affordability thresholds is also at the discretion of local authorities, in fact the Monroe County 
Board of County Commissioners has previously passed resolutions addressing this. 
Accordingly, FEMA applicants may increase the level of assistance per EDU, however, the 
amount of FEMA grant funding is limited to the amount in the respective original grant 
applications. 

Comment Summary W1-21: Does the $75 include all components of the cost  capital, 
operations and maintenance, and lateral and abandonment? 

Response W1-21: Yes, it includes all of those components, but the $75 is not a final figure for 
every project area. It is a general estimate pertaining to all of the project areas and the final figure 
could be slightly lower or slightly higher for the individual sites. 

Comment Summary W1-22: Can you tell us about funding sources other than this FEMA 
grant? What funding is available for all proposed projects? 

Response W1-22: Please see Appendix H: Funding and Financing Options in the PEA. 

Comment Summary W1-23: Why should we borrow money from FEMA at 6%? It would be 
cheaper from the state revolving fund at 3% for non-assisted hook-up costs. 

Response W1-23: FEMA funding is a grant, rather than a loan. 

Comment Summary W1-24: Why not reduce the boundary of the project and have no hook-up 
fees  only operations and maintenance costs  within the parameters of FEMA funding. Why 
don't we do just what the FEMA grant will allow us to do? 

Response W1-24: The scopes of the various projects are determined by the applicant, not by 
FEMA. The question would need to be raised with the applicant. 

Comment Summary W1-25: Equity is a big issue and concern  the cost impacts to citizens. 

Response W1-25: Issues of equity and cost impacts to service recipients have been outlined in 
detail in Sections 3.6.3 and 3.7.1.2. 

Comment Summary W1-26: Does the report (the DPEA) address which option or system is 
better for the project? If it is not in this report, is there some sort of consumer report about 
which system is better than others? 

Response W1-26: The question of which wastewater system is better for the project is beyond 
the scope of the PEA. The alternatives are derived from the Monroe County Sanitary Wastewater 
Master Plan, which does evaluate which system alternatives are most suitable. 

Comment Summary W1-27: There is a concern about the fact that the assessment is based on 
County's master plan. The information may be old and inaccurate. We need an independent 
analysis to verify the assumptions used in the PEA. 


APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES 


Response W1-27: The PEA is based on the Countys Sanitary Wastewater Master Plan that was 
published in June 2000, and is the most current wastewater planning document available for 
Monroe County. However, it is the applicants discretion to sponsor further study of alternatives. 

Comment Summary W1-28: Regarding operations and maintenance costs, we need to evaluate 
which system is less expensive and more efficient to operate to help make good decisions. 

Response W1-28: That is beyond the scope of this PEA. NEPA requires evaluation of the 
impacts to the environment of the three project alternatives proposed, but not of which is most 
efficient or cost-effective; also see Responses G1-9 and W1-27. 

Comment Summary W1-29: We don't have a wide choice in systems. The RFP has limited our 
choices. 

Response W1-29: The system alternatives in RFP packages are consistent with the FEMA 
funding grant application scope of work. 

Comment Summary W1-30: Candidates for the Wastewater Board should study the science in 
order to prepare themselves to sit on the Technical Evaluation Panel (TEP). 

Response W1-30: Comment noted. 

Comment Summary W1-31: Regarding the proposed site at mile marker 100.5, we are trading 
adverse impacts on the terrestrial environment for benefits to the marine environment. Even 
considering that the site was probably scarified at one particular time, it is still what we would 
now call high quality hammock land. We need to consider the terrestrial environment to the 
same degree as the marine environment. 

Response W1-31: This concern would be further analyzed during the SER process, when project 
locations would be specified. 

Comment Summary W1-32: When will the public meetings be for the site-specific projects? 

Response W1-32: Dates would be determined based upon the completion of each individual draft 
SER. 

Comment Summary W1-33: Will a statement be made relative to the overall environmental 
improvements (i.e., that the benefit to water quality is more important than the adverse effects on 
wood rats)? 

Response W1-33: Impacts on both biological resources and water quality will be considered at 
the SER level. As part of its obligations under Section 7 of the Endangered Species Act, FEMA 
will consider impacts to special status species and make efforts to avoid and/or minimize impacts 
to these species. Note that it is beyond the scope of the NEPA documents to make statements of 
opinion regarding the acceptability or relative value of environmental tradeoffs. 


APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES 


W2 Workshop Participants (9-Oct-02) 

Comment Summary W2-1: When a treatment plant is put in on Conch Key, will residents be 
able to get a septic or cesspit credit? 

Response W2-1: No, septic/cesspit credits would not be used in project areas. 

Comment Summary W2-2: Given our topography and geology, will effluent (which is 
freshwater) placed in shallow wells come back up in canals, ocean, etc.? Is this a concern? Will 
this be tracked? 

Response W2-2: If shallow injection is identified as an alternative method of wastewater disposal 
for a specific wastewater treatment facility, the effects of this alternative will be analyzed and 
presented in the SER for that specific facility. Sections 3.1.3 and 3.2.2.1 provide a detail 
discussion on the Keys geology and the effects of injecting treated effluent, in terms of hydraulic 
conductivity. Injected treated effluent will eventually surface in nearshore waters, including 
canals, as it currently does; although it would be treated to much more stringent standards than 
present. 

Comment Summary W2-3: How will variation in operations and maintenance costs among 
possible technologies that may be proposed are taken account of in bid evaluation process? I see 
this as a huge issue for a small community system as is being proposed for Conch Key. 

Response W2-3: This issue would need to be addressed by the applicant. 

Comment Summary W2-4: Where can we get more information about possible technologies? 

Response W2-4: Please refer to Response G1-9 and information on various wastewater treatment 
systems can be found on the internet, at the library or obtained from technical experts (e.g., 
wastewater engineers). 

Comment Summary W2-5: Purestream literature suggests a large difference in operations and 
maintenance costs between upflow sludge blanket filter systems and sequencing batch reactor 
systems. 

Response W2-5: Technology alternatives should be brought to the attention of the applicant. 

Comment Summary W2-6: Will the government require three separate bids when you get to site 
specific steps? 

Response W2-6: Yes, projects must be competitively bid. . 

Comment Summary W2-7: What role does FEMA play in overseeing projects once funding is 
provided? We have seen projects in the Keys with significant management problems. If FEMA is 
providing funding, is there any additional assurance for those of us on projects with FEMA 
funding that costs etc. will be managed better for us? 

Response W2-7: Applicants are responsible for project facility maintenance. FEMA has no 
long-term oversight in project facility maintenance. 

Comment Summary W2-8: We need sewage treatment. 

Response W2-8: Comment noted. 

Comment Summary W2-9: Is there a sampling point anywhere near Conch Key for fecal 
coliform? Where is the closest monitoring point? 


APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES 


Response W2-9: The closest monitoring site is maintained by Florida International University 
(No. 244) just northeast of Conch Key, off US 1 (http://serc.fiu.edu/wqmnetwork/FKNMSCD/
midkeys.htm). However, fecal coliform is not monitored at this station. 

Comment Summary W2-10: Has there been any interest here in ultraviolet ray disinfection? 
Water returned after this treatment would be less harmful to corals. 

Response W2-10: The purpose of the PEA is only to evaluate alternatives, not develop 
alternatives. Please see Response G1-9. The specific disinfection alternatives will be presented in 
the SER process. 

Website 

Comment Summary WS1-1: The only question we have concerns the choice to dismiss the 
STEP system as an alternative. The fact that each home has a pump should not be something that 
would eliminate it from consideration. When combining these types of systems with responsible 
management entities (RMEs) as described in EPA's management guidelines for onsite systems, 
they can be cost effective and reliable systems. We ask that you reconsider this decision. 

Response WS1-1: Please see Response G1-9. 

Comment Summary WS1-2: Overall, a very well written, informative document. 

Response WS1-2: Comment noted. 

Comment Summary WS1-4: The ER establishes very low-income as incomes less than 50% of 
Median Family Income (MFI) and low-income as up to 80% of MFI. Further, the ER establishes 
Monroe County MFI at $55,100. This is consistent with the most recent annual estimate 
published by US HUD. Based on these definitions, Monroe County's very low-income households 
would be those earning no more than $27,550 and low would be earning no more than $44,080. 
I believe that the ER miscalculates these income maximums as $24,800 and $39,650 respectively. 

Response WS1-4: The Monroe County MFI of $55,100 is the average figure published by HUD 
and covers all family sizes. HUD publishes the adjusted values of MFI for each family size and 
you are correct in noting that the figures of 50% and 80% do not calculate directly from the 
$55,100. The income maximums of $24,800 for very-low-income and $39,650 for low-income 
come directly from HUDs table of adjusted figures for a family of 3 and are not calculated in the 
PEA. In response to your comment, we have clarified this point in the document.