Final Programmatic Environmental Assessment 

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 


TABLE OF CONTENTS

Abstract ................................................................................................................................................................ Ab-1

Section 1 Introduction....................................................................................................................................... 1-1

1.1 DISASTER BACKGROUND AND FEMA REGULATORY GUIDANCE.............................................. 1-1
1.2 THE PROGRAMMATIC ENVIRONMENTAL ANALYSIS PROCESS ................................................. 1-1
1.3 THE IMPACTS OF WATER QUALITY DEGRADATION IN THE FLORIDA KEYS.......................... 1-3
1.4 SOURCES OF KEYS WATER QUALITY DEGRADATION.................................................................. 1-4
1.5 FOCUSING ON WASTEWATER MANAGEMENT IN THE FLORIDA KEYS .................................... 1-5
1.6 WATER QUALITY DEGRADATION AND LONG-TERM RECOVERY.............................................. 1-7
1.7 WATER QUALITY PROTECTION MEASURES AT THE LOCAL, STATE, AND FEDERAL 
LEVELS..................................................................................................................................................... 1-8 
1.8 PURPOSE AND SCOPE OF THE PEA DOCUMENT.............................................................................. 1-9
1.9 PURPOSE OF AND NEED FOR ACTION ..............................................................................................1-10
1.10 PUBLIC PARTICIPATION PROCESS AND REGULATORY FRAMEWORK ....................................1-10
Section 2 Alternatives Evaluated...................................................................................................................... 2-1

2.1 ALTERNATIVE DEVELOPMENT BACKGROUND.............................................................................. 2-1
2.2 DECISION MODELS FOR WASTEWATER MANAGEMENT ALTERNATIVE 
DEVELOPMENT ...................................................................................................................................... 2-1 
2.3 ALTERNATIVES EVALUATED.............................................................................................................. 2-5
2.3.1 Alternative 1  No Action Alternative .......................................................................................... 2-7
2.3.2 Alternative 2  Centralized Wastewater Treatment Plant Alternative .......................................... 2-7
2.3.2.1 Wastewater Treatment Plant Collection Options:.................................................................. 2-8
2.3.2.1.1 Collection Option 1  Vacuum Pumping .................................................................... 2-8
2.3.2.1.2 Collection Option 2  Low-Pressure Grinder Pump Sewer System............................ 2-9
2.3.2.2 Wastewater Treatment Plant Effluent Disposal Options:....................................................... 2-9
2.3.2.2.1 Disposal Option 1  Shallow Injection Wells ............................................................. 2-9
2.3.2.2.2 Disposal Option 2 - Wastewater Reuse......................................................................2-12
2.3.3 Alternative 3  On-Site Treatment Upgrades...............................................................................2-13
2.4 ALTERNATIVES CONSIDERED BUT DISMISSED.............................................................................2-13
2.4.1 Collection Options under Alternative 2 .......................................................................................2-14
2.4.2 On-site Treatment Options under Alternative 3 ...........................................................................2-15
Section 3 Affected Environment and Environmental Consequences............................................................ 3-1

3.1 TOPOGRAPHY, SOILS, AND GEOLOGY .............................................................................................. 3-1
3.1.1 Topography.................................................................................................................................. 3-1
3.1.1.1 Affected Environment............................................................................................................3-1
3.1.1.2 Environmental Consequences................................................................................................ 3-2
3.1.2 Soils ............................................................................................................................................. 3-2
3.1.2.1 Affected Environment............................................................................................................3-2
3.1.2.2 Environmental Consequences................................................................................................ 3-4
3.1.3 Geology........................................................................................................................................ 3-4
3.1.3.1 Affected Environment............................................................................................................3-4
3.1.3.1.1 Upper Water-Bearing Zone......................................................................................... 3-7
3.1.3.1.2 Floridan Aquifer System ............................................................................................. 3-8
3.1.3.2 Environmental Consequences.............................................................................................. 3-10
3.1.3.2.1 Alternative 1  No Action Alternative .......................................................................3-10
3.1.3.2.2 Alternative 2  Centralized Wastewater Treatment Plant Alternative .......................3-10
3.1.3.2.3 Alternative 3  On-Site Treatment Upgrades.............................................................3-12
3.2 WATER RESOURCES AND WATER QUALITY ..................................................................................3-13
3.2.1 Regulatory Setting........................................................................................................................3-13
3.2.2 Groundwater ...............................................................................................................................3-15
3.2.2.1 Affected Environment.......................................................................................................... 3-15
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3.2.2.2 Environmental Consequences.............................................................................................. 3-17
3.2.2.2.1 Alternative 1  No Action Alternative .......................................................................3-17
3.2.2.2.2 Alternative 2  Centralized Wastewater Treatment Plant Alternative .......................3-18
3.2.2.2.3 Alternative 3  On-Site Treatment Upgrades.............................................................3-19
3.2.3 Inland, Nearshore, and Offshore Waters......................................................................................3-21
3.2.3.1 Affected Environment.......................................................................................................... 3-21
3.2.3.1.1 Inland Waters .............................................................................................................3-21
3.2.3.1.2 Nearshore and Offshore Marine Waters.....................................................................3-22
3.2.3.1.3 Stormwater.................................................................................................................3-24
3.2.3.2 Environmental Consequences.............................................................................................. 3-27
3.2.3.2.1 Alternative 1  No Action Alternative .......................................................................3-27
3.2.3.2.2 Alternative 2  Centralized Wastewater Treatment Plant Alternative .......................3-27
3.2.3.2.3 Alternative 3  On-Site Treatment Upgrades.............................................................3-29
3.2.4 Floodplains and Wetlands............................................................................................................3-29
3.2.4.1 Affected Environment.......................................................................................................... 3-29
3.2.4.1.1 Floodplains.................................................................................................................3-29
3.2.4.1.2 Wetlands.....................................................................................................................3-32
3.2.4.2 Environmental Consequences.............................................................................................. 3-32
3.2.4.2.1 Alternative 1  No Action Alternative .......................................................................3-32
3.2.4.2.2 Alternative 2  Centralized Wastewater Treatment Plant Alternative .......................3-33
3.2.4.2.3 Alternative 3  On-Site Treatment Upgrades.............................................................3-34
3.3 BIOLOGICAL RESOURCES ...................................................................................................................3-35
3.3.1 Affected Environment..................................................................................................................3-35
3.3.1.1 Terrestrial Environment....................................................................................................... 3-35
3.3.1.1.1 Pine Rocklands and Tropical Hardwood Hammocks.................................................3-35
3.3.1.1.2 Mangrove Forests and Salt Marshes ..........................................................................3-36
3.3.1.1.3 Freshwater Systems....................................................................................................3-37
3.3.1.1.4 Dunes and Coastal Ridges..........................................................................................3-37
3.3.1.2 Aquatic Environment........................................................................................................... 3-38
3.3.1.2.1 Seagrass Beds and Sand Flats ....................................................................................3-38
3.3.1.2.2 Coral Reefs.................................................................................................................3-38
3.3.1.2.3 Hardbottom ................................................................................................................3-40
3.3.1.2.4 Sandy Bottom.............................................................................................................3-40
3.3.2 Environmental Consequences ......................................................................................................3-40
3.3.2.1 Alternative 1  No Action Alternative................................................................................. 3-40
3.3.2.2 Alternative 2  Centralized Wastewater Treatment Plant Alternative ................................. 3-42
3.3.2.3 Alternative 3  On-Site Treatment Upgrades....................................................................... 3-43
3.3.3 Special Status Species..................................................................................................................3-43
3.3.3.1 Affected Environment.......................................................................................................... 3-43
3.3.3.2 Environmental Consequences.............................................................................................. 3-45
3.3.3.2.1 Alternative 1  No Action Alternative .......................................................................3-45
3.3.3.2.2 Alternative 2  Centralized Wastewater Treatment Plant Alternative .......................3-45
3.3.3.2.3 Alternative 3  On-Site Treatment Upgrades.............................................................3-46
3.4 AIR QUALITY .........................................................................................................................................3-47
3.4.1 Affected Environment..................................................................................................................3-47
3.4.2 Environmental Consequences ......................................................................................................3-48
3.4.2.1 Alternative 1No Action Alternative................................................................................. 3-48
3.4.2.2 Alternative 2  Centralized Wastewater Treatment Plant.................................................... 3-48
3.4.2.3 Alternative 3  On-Site Treatment Upgrades....................................................................... 3-49
3.5 CULTURAL RESOURCES......................................................................................................................3-50
3.5.1 Affected Environment..................................................................................................................3-50
3.5.1.1 Paleo-Indian Period (ca. 12,000 to 10,000 BP).................................................................... 3-50
3.5.1.2 Archaic Period (ca. 10,000 to 3,000 BP) ............................................................................. 3-51
3.5.1.3 Glades Period (ca. 2,500 BP to AD 1500) ........................................................................... 3-51
3.5.1.4 Historic Period (ca. Mid-1500s to 1951).............................................................................. 3-51
3.5.1.5 Monroe County Cultural Resources..................................................................................... 3-52
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3.5.2 Environmental Consequences ......................................................................................................3-53
3.5.2.1 Alternative 1  No Action Alternative................................................................................. 3-53
3.5.2.2 Alternative 2  Centralized Wastewater Treatment Plant Alternative ................................. 3-53
3.5.2.3 Alternative 3  On-Site Treatment Upgrades....................................................................... 3-54
3.6 SOCIOECONOMIC RESOURCES...........................................................................................................3-55
3.6.1 Tourism.......................................................................................................................................3-55
3.6.1.1 Affected Environment.......................................................................................................... 3-55
3.6.1.2 Environmental Consequences.............................................................................................. 3-56
3.6.1.2.1 Alternative 1  No Action Alternative .......................................................................3-56
3.6.1.2.2 Alternative 2  Centralized Wastewater Treatment Plant Alternative .......................3-57
3.6.1.2.3 Alternative 3  On-Site Treatment Upgrades.............................................................3-57
3.6.2 Fishing Industry ...........................................................................................................................3-57
3.6.2.1 Affected Environment.......................................................................................................... 3-57
3.6.2.2 Environmental Consequences.............................................................................................. 3-59
3.6.2.2.1 Alternative 1  No Action Alternative .......................................................................3-59
3.6.2.2.2 Alternative 2  Centralized Wastewater Treatment Plant Alternative .......................3-59
3.6.2.2.3 Alternative 3  On-Site Treatment Upgrades.............................................................3-59
3.6.3 Local Fees and Taxes...................................................................................................................3-59
3.6.3.1 Affected Environment.......................................................................................................... 3-59
3.6.3.1.1 Existing Wastewater Management Costs in Monroe County.....................................3-60
3.6.3.1.2 Wastewater Management Costs and Affordability for Florida Keys Residents.........3-62
3.6.3.1.3 Wastewater Management Costs and Affordability for Keys Businesses ...................3-64
3.6.3.2 Environmental Consequences.............................................................................................. 3-65
3.6.3.2.1 Alternative 1  No Action Alternative .......................................................................3-65
3.6.3.2.2 Alternative 2  Centralized Wastewater Treatment Plant Alternative .......................3-66
3.6.3.2.3 Alternative 3  On-Site Treatment Upgrades.............................................................3-68
3.6.4 Public Health...............................................................................................................................3-69
3.6.4.1 Affected Environment.......................................................................................................... 3-69
3.6.4.2 Environmental Consequences.............................................................................................. 3-71
3.6.4.2.1 Alternative 1No Action Alternative .......................................................................3-71
3.6.4.2.2 Alternative 2  Centralized Wastewater Treatment Plant ..........................................3-72
3.6.4.2.3 Alternative 3  On-Site Treatment Upgrades.............................................................3-72
3.7 DEMOGRAPHICS AND ENVIRONMENTAL JUSTICE.......................................................................3-73
3.7.1 Affected Environment..................................................................................................................3-73
3.7.1.1 Population and Race ............................................................................................................ 3-73
3.7.1.2 Income and Poverty ............................................................................................................. 3-74
3.7.1.3 Wastewater Management Costs and Affordability for Keys Lower-Income Residents....... 3-76
3.7.1.4 Alternative 1  No Action Alternative................................................................................. 3-77
3.7.1.5 Alternative 2  Centralized Wastewater Treatment Plant Alternative ................................. 3-78
3.7.1.6 Alternative 3  On-Site Treatment Upgrades....................................................................... 3-80
3.8 HAZARDOUS MATERIALS AND WASTES .........................................................................................3-81
3.8.1 Affected Environment..................................................................................................................3-81
3.8.2 Environmental Consequences ......................................................................................................3-82
3.8.2.1 Alternative 1  No Action Alternative................................................................................. 3-82
3.8.2.2 Alternative 2  Centralized Wastewater Treatment Plant Alternative ................................. 3-82
3.8.2.3 Alternative 3  On-Site Treatment Upgrades....................................................................... 3-83
3.9 INFRASTRUCTURE................................................................................................................................3-84
3.9.1 Traffic and Circulation.................................................................................................................3-84
3.9.1.1 Affected Environment.......................................................................................................... 3-84
3.9.1.1.1 Alternative 1  No Action Alternative .......................................................................3-85
3.9.1.1.2 Alternative 2  Centralized Wastewater Treatment Plant ..........................................3-85
3.9.1.1.3 Alternative 3  On-Site Treatment Upgrades.............................................................3-86
3.9.2 Utilities and Services ...................................................................................................................3-86
3.9.2.1 Affected Environment.......................................................................................................... 3-86
3.9.2.2 Environmental Consequences.............................................................................................. 3-87
3.9.2.2.1 Alternative 1  No Action Alternative .......................................................................3-87
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TABLE OF CONTENTS

3.9.2.2.2 Alternative 2  Centralized Wastewater Treatment Plant ..........................................3-87
3.9.2.2.3 Alternative 3  On-Site Treatment Upgrades.............................................................3-88
3.10 LAND USE AND PLANNING .................................................................................................................3-89
3.10.1 Affected Environment..................................................................................................................3-89
3.10.1.1 Future Land Use and Planning............................................................................................. 3-90
3.10.1.2 Land Use, Planning, and Wastewater Management............................................................. 3-93
3.10.1.3 Conservation and Recreation Lands .................................................................................... 3-94
3.10.1.4 Coastal Zone ........................................................................................................................ 3-94
3.10.1.5 Barrier Island Resources...................................................................................................... 3-94
3.10.2 Environmental Consequences ......................................................................................................3-96
3.10.2.1 Alternative 1  No Action Alternative................................................................................. 3-96
3.10.2.3 Alternative 3  On-Site Treatment Upgrades....................................................................... 3-98
3.11 NOISE AND VISUAL RESOURCES.....................................................................................................3-100
3.11.1 Noise .........................................................................................................................................3-100
3.11.1.1 Affected Environment........................................................................................................ 3-100
3.11.1.2 Environmental Consequences............................................................................................ 3-101
3.11.1.2.1 No Action Alternative, Centralized WWTP Alternative, and OWNRS 
Alternative................................................................................................................3-102 
3.11.2 Visual Resources.......................................................................................................................3-105
3.11.2.1 Affected Environment........................................................................................................ 3-105
3.11.2.2 Environmental Consequences............................................................................................ 3-105
Section 4 Cumulative Impacts.......................................................................................................................... 4-1

4.1 CONCURRENT PROJECTS...................................................................................................................... 4-1
4.1.1 Comprehensive Wastewater Management Activities.................................................................... 4-1
4.1.2 Comprehensive Stormwater Management Activities.................................................................... 4-1
4.1.3 Everglades Restoration ................................................................................................................. 4-1
4.2 CUMULATIVE IMPACTS ........................................................................................................................ 4-2
4.2.1 Topography, Soils, and Geology................................................................................................... 4-2
4.2.2 Water Resources and Water Quality ............................................................................................. 4-2
4.2.3 Biological Resources..................................................................................................................... 4-3
4.2.4 Air Quality ................................................................................................................................... 4-3
4.2.5 Cultural Resources ........................................................................................................................ 4-4
4.2.6 Socioeconomics ............................................................................................................................ 4-4
4.2.7 Demographics and Environmental Justice .................................................................................... 4-4
4.2.8 Hazardous Materials ..................................................................................................................... 4-4
4.2.9 Infrastructure................................................................................................................................ 4-5
4.2.10 Land Use and Planning ................................................................................................................. 4-5
4.2.11 Noise and Visual Resources.......................................................................................................... 4-5
Section 5 Public Involvement............................................................................................................................ 5-1

Section 6 Conclusions........................................................................................................................................ 6-1

Section 7 List of Preparers................................................................................................................................ 7-1

Section 8 References.......................................................................................................................................... 8-1

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List of Tables, Figures, Maps, and Appendices 

Tables Page 

Table 1-1 Recent Chronology of Regulatory Milestones of Regulatory Milestones of 

Wastewater Management in the Florida Keys.....................................................1-9 
Table 2-1 Quality Standards for Discharged Effluent........................................................ 2-12 
Table 3-1 Big Pine Key Treatment System Nutrient Removal Rates ................................ 3-20 
Table 3-2 Year 2000 Maximum Recorded Criteria Pollutant Levels for Monroe and 

Neighboring Counties in Florida ....................................................................... 3-47 
Table 3-3 Trends in Monroe County Fishery.....................................................................3-58 
Table 3-4 Connection Fees and Monthly Sewer Charges for Non-2010 Compliant 

Monroe County WWTPs per EDU....................................................................3-61 
Table 3-5 Estimated Monthly Charges for Non-Compliant Wastewater Systems per 

EDU ................................................................................................................... 3-62 
Table 3-6 Estimated Average Monthly Expenses for Households in the Florida Keys..... 3-63 
Table 3-7 Selection of Monthly Wastewater Rates for Cities in Florida and Across 

the U.S................................................................................................................ 3-64 
Table 3-8 Approximate Monthly Charges for Existing 2010 Compliant Wastewater 

Systems per EDU...............................................................................................3-65 
Table 3-9 Approximate Centralized WWTP Costs............................................................3-67 
Table 3-10 Enteric Disease Counts of Monroe and Neighboring Counties (1999) ............. 3-70 
Table 3-11 Functional Population of Monroe County (1990-2015) .................................... 3-73 
Table 3-12 Discretionary Income of Low-Income Residents  2001/2002 ......................... 3-77 
Table 3-13 Existing Land Use Classification for Monroe County....................................... 3-90 
Table 3-14 Approximate Noise Levels in Decibels Based on Land Uses (representing 

project sites).....................................................................................................3-101 
Table 3-15 Addition of Decibels........................................................................................3-102 
Table 3-16 Noise Levels Associated with Common Construction Activities.................... 3-104 
Table 3-17 Noise Levels Associated with Wastewater Treatment Plant Operations......... 3-104 

Figures 

Figure 1-1 Vicinity Map ........................................................................................................ 1-2 
Figure 1-2 Process Schematics for Wastewater Treatment Options for the Florida 

Keys ..................................................................................................................... 1-6 
Figure 2-1 Upper Keys Wastewater Management and Hot Spots.........................................2-2 
Figure 2-2 Middle Keys Wastewater Management and Hot Spots ....................................... 2-3 
Figure 2-3 Lower Keys Wastewater Management and Hot Spots ........................................ 2-4 

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List of Tables, Figures, Maps, and Appendices 

Figure 2-4 Decision-Making Process for Wastewater Management Alternatives ................ 2-6 
Figure 2-5 Shallow Injection Wells.....................................................................................2-10 
Figure 3-1 Tidal Movement in the Florida Keys...................................................................3-3 
Figure 3-2 Submarine Topography........................................................................................ 3-5 
Figure 3-3 Floridan Aquifer................................................................................................... 3-6 
Figure 3-4 Boulder Zone of Southern Florida ....................................................................... 3-9 
Figure 3-5 Groundwater Circulation in the Floridan Aquifer System................................. 3-11 
Figure 3-6 Stormwater Retrofit and Rehabilitation Projects ............................................... 3-26 
Figure 3-7 Monroe County Floodplain................................................................................ 3-31 
Figure 3-8 Monroe County Minority Status ........................................................................ 3-75 
Figure 3-9 Map of Coastal Barrier Resource System Units ................................................ 3-95 

Appendices 

Appendix A Acronyms 
Appendix B Definitions* 
Appendix C Hot Spot Locations 
Appendix D Water Quality Improvement Analysis 
Appendix E Applicable Permit Information 
Appendix F Federally Listed Species in Monroe County and Fishery Species 
Appendix G Federal and State Agency Correspondence 
Appendix H Funding and Financing Options 
Appendix I Public Notice 
Appendix J Supporting Information for the Low-Income Demographic 
Appendix K Comments on the Draft PEA and Responses 

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

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SECTIONONE Introduction 

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

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

1.2 THE PROGRAMMATIC ENVIRONMENTAL ANALYSIS PROCESS 
FEMA is considering the provision of funding assistance related to several proposed 
alternatives, which are designed to improve wastewater treatment, and ultimately water quality, 
in the Keys. The National Environmental Policy Act of 1969 (NEPA), Council on 
Environmental Quality (CEQ) regulations implementing NEPA (40 Code of Federal 
Regulations [CFR] Parts 1500 to 1508), and FEMA regulations for NEPA compliance (44 CFR 
Part 10) direct FEMA to fully understand and take into consideration during decision making, 
the environmental consequences of proposed Federal actions (projects). Accordingly, FEMA 
prepared this Programmatic Environmental Assessment (PEA) on the effects of 
implementation of a range of wastewater collection, treatment, and disposal alternatives 
proposed in the Keys. The study area for the PEA encompasses the Florida Keys and its 
nearshore waters (Figure 1-1). 

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

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SECTIONONE Introduction 

FIGURE 1-1, VICINITY MAP

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SECTIONONE Introduction 

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

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

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

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SECTIONONE Introduction 

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

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

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

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

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

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SECTIONONE Introduction 

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

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

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

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

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

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SECTIONONE Introduction 

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

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SECTIONONE Introduction 

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

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

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

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SECTIONONE Introduction 

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

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

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

To meet regulatory requirements and achieve water quality improvements, Monroe County 
prepared the Sanitary Wastewater Master Plan (MCSWMP) (Monroe County, 2000a) that 
defines specific planning areas for the entire developed areas of the Keys (except for the cities of 
Key West and Key Colony Beach). The MCSWMP also addresses wastewater management 
alternatives including the construction of new treatment plants, conversion of on-site 
wastewater treatment systems (OWTS) to on-site wastewater nutrient reduction systems 
(OWNRS), use of cluster systems (i.e., OWNRS that accommodate multiple homes), effluent 
disposal, and wastewater collection. The MCSWMP identifies preferred alternatives to 

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SECTIONONE Introduction 

improving wastewater treatment in the Keys via an extensive decision model process, which is 
detailed in Section 2, Alternatives Evaluated, in this document. The alternatives evaluated in this 
PEA parallel the preferred alternatives identified in the MCSWMP. 

Additionally, in 1998 the Florida Legislature amended the enabling legislation of the FKAA 

(F.L. 76-441) to reinforce the FKAAs involvement in wastewater for Monroe County. The 
FKAA is the main potable water supplier for the Keys. A Memorandum of Understanding 
(MOU) between Monroe County and the FKAA was signed to request that the FKAA exercise 
its authority to purchase, finance, construct, and otherwise acquire and to improve, extend, 
enlarge, and reconstruct a wastewater collection, transmission, treatment, and disposal system or 
systems in the Florida Keys. 
Table 1-1 - Recent Chronology of Regulatory Milestones of 
Wastewater Management in the Florida Keys 

1993  Initial adoption of Monroe County Year 2010 Comprehensive Plan. 
1997  Monroe County Comprehensive Plan Amended to comply with Florida Statutes. 
 Administration Commission adopts amendments to Monroe County Year 2010 Comprehensive 
Plan and established Five-year Work Program (Rule 28-20.100). 
 MCSWMP begins. 
 Monroe County established original Identification and Elimination of Cesspools Ordinance, 031997; 
this ordinance was unsuccessful and was later rescinded. 
1998  Governors Executive Order 98-309 (State and Local Agency Participation in Carrying Out 
Monroe County Year 2010 Plan). 
 Florida Legislature amends the enabling legislation of the FKAA (F.L. 76-441) to reinforce the 
FKAAs involvement in wastewater for Monroe County 
 Monroe County enters into a Memorandum of Understanding with the FKAA requesting that the 
FKAA exercises its authority to finance, construct, and operate wastewater systems in the Keys 
1999  Governor Bush and his cabinet amend the 1997 Five-Year Work Program (Rule 28-20.100) to 
accelerate pace of program, identify Hot Spots, and initiate cesspool identification outside of 
Hot Spot areas. 
 Monroe County passes ordinance 031-1999 (Revised Identification and Elimination of Cesspools) 
to comply with the Governors revised Five-Year Work Program. 
 F.L. 99-395 passed (New requirements for all sewage treatment, reuse and disposal facilities, and 
all on-site systems Monroe County; prohibits new or expanded discharges into surface waters, 
and require existing surface water discharges be eliminated before July 1, 2006). 
Source: Modified from Monroe County, 2000a 

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

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SECTIONONE Introduction 

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

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

1.10 PUBLIC PARTICIPATION PROCESS AND REGULATORY FRAMEWORK 
The topic of wastewater management improvements and water quality degradation in the Keys is 
of particular public interest to agencies and citizens alike. For this reason, public participation 
throughout the PEA and SER processes is of high concern not only in terms of upholding the 
intent of NEPA and other applicable environmental statutes, but also to ensure that FEMA 
conducts studies with the knowledge that public and agency opinions were gathered and 
considered, ensuring a well-documented and well-represented study. FEMA has specific 
requirements for public participation in compliance with its implementing regulations for NEPA, 
EO 11988 (Floodplain Management) and EO 11990 (Wetland Protection) and EO 12898 
(Environmental Justice). Furthermore, as described in Section 5, Monroe County has conducted 
public involvement in relation to the development and issuance of the MCSWMP that guides 
future wastewater management activities in the Keys. Additional information on FEMAs public 
involvement activities, as of PEA release, and the environmental review process is further 
detailed in Section 5. 

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

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

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

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

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FIGURE 2-1 UPPER KEYS 

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FIGURE 2-2 MIDDLE KEYS 

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FIGURE 2-3 LOWER KEYS 

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SECTIONTWO Alternatives Evaluated 

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

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

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

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

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FIGURE 2-4 DECISION-MAKING MODEL 

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SECTIONTWO Alternatives Evaluated 

2.3.1 Alternative 1  No Action Alternative 
FEMA would not provide funds to the project applicants for wastewater management 
improvements. The county is presently pursuing several State and Federal sources of funding to 
finance the large capital costs associated with improving their wastewater treatment systems to 
meet the compliance requirements established by the State of Florida for treatment standards by 
2010. FKAA or Islamorada would not have the benefit of FEMA assistance under the No Action 
Alternative. Communities currently utilizing on-site systems, such as cesspools and septic 
systems, to manage wastes would have to construct either community or regional WWTPs or on-
site wastewater nutrient reduction systems to effectively manage waste nutrients to levels that 
meet the Florida Statutory Treatment Standards of 2010. 

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

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

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

The WWTP design, size, location, and construction methods would be identified and studied in 
the respective SERs. In general, WWTP acreage for the average regional WWTP in Monroe 
County is about 3 acres, while community and interim community WWTPs would use smaller 

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sites. The construction time for a WWTP in the Keys has been estimated to be about 18 months 
(Teague, Pers. Comm., 2001). Regional facilities would process 0.5 mgd to 6.0 mgd of effluent 
and community facilities would process about .004 mgd to 0.5 mgd. Avoidance of sensitive 
locations (such as residential or natural areas) would be preferred when conducting site selection, 
however, available land in the Keys is limited and siting may occur within these areas due to lack 
of options. As a requirement of NEPA, FEMAs implementing regulations with respect to 
NEPA, and other applicable Federal, State, and local environmental regulations, appropriate 
mitigation measures to reduce the adverse effects associated with sensitive locations would be 
implemented. 

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

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

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

2.3.2.1 Wastewater Treatment Plant Collection Options: 
2.3.2.1.1 Collection Option 1  Vacuum Pumping 
A vacuum sewer system consists of one or more vacuum stations, collection system piping, and 
vacuum sewer services. Vacuum stations provide both vacuum pumping to draw wastewater to 
the station, and discharge pumping to pump wastewater through a pressure force main to a 

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

2.3.2.1.2 Collection Option 2  Low-Pressure Grinder Pump Sewer System 
Grinder pump systems use a small grinder pump station at each wastewater source (such as a 
residence or business) and small-diameter, low-pressure sewers for transmission either to lift 
stations or directly to a WWTP. The grinder pump station accepts the entire wastewater stream 
from the residence or business and is not used in conjunction with a septic tank. All solids in the 
waste stream are ground to slurry and pumped through pressure sewers. Low-pressure grinder 
pump systems would typically include the use of either centrifugal grinder pumps or progressive 
cavity grinder pumps. Centrifugal grinder pumps are generally designed for lower pressure 
applications and require larger water pipe sizes in comparison to progressive gravity pumps. 
Construction activities associated with the implementation of the low-pressure grinder pump 
sewer system could include excavation of fill and installation of new sewer lines and/or the 
removal of existing water pipe. The installation of gravity grinder pumps at individual residences 
and other wastewater sources would require the excavation of several cubic feet of soil, along 
with the establishment of new sewer connections. 

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

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SECTIONTWO Alternatives Evaluated 

FIGURE 2-5 SHALLOW INJECTION WELL 

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SECTIONTWO Alternatives Evaluated 

Permitting Class I and Class V Injection Wells 

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

Class I injection wells are defined as wells that inject fluids beneath the lowermost formation 
containing, within one quarter mile of the well bore, an underground source of drinking water 
(USDW). Under F.A.C. 62-528, applicants for Class I injection wells must demonstrate that 
the hydrogeologic environment is suitable for waste injection and without modifying the 
ambient water quality of other aquifers overlying the injection zone. Additional requirements 
of Class I injection wells include casing and cementing to prevent the movement of fluids to 
maintain the ground water quality in aquifers above the injection zone, exploratory pilot holes, 
monitoring well, and alternate disposal method for emergency events. Under F.A.C. 62600.540, 
Ground Water Disposal by Underground Injection, all facilities using Class I wells 
discharging domestic effluent into G-IV waters (i.e., non-potable water use, ground water in 
confined aquifers, which has a total dissolved solids content of 10,000 mg/L or greater such as 
those in the Keys) must meet secondary treatment and pH limitations. Additional information 
related to the permitting requirements of Class I injection wells for domestic wastewater is in 
FDEPs regulations for domestic wastewater facilities (F.A.C. 62-600) and underground 
injection control (F.A.C. 62-528). 

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

In addition to the standards promulgated under Sections 62-600 and 62-528 of F.A.C., F.L. 99395 
specifies design standards and effluent water quality standards for Class V wastewater 
injection wells as follows: 

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SECTIONTWO Alternatives Evaluated 

Table 2-1: Quality Standards for Discharged Effluent 

BOD 
(mg/L) 
TSS 
(mg/L) 
TN 
(mg/L) 
TP 
(mg/L) 
Sewage facilities 
with design 
capacities greater 
than 100,000 gpd 
5 5 3 1 
Sewage facilities 
with design 
capacities less 
than 100,000 gpd 
10 10 10 1 
On-site sewage 
treatment and 
disposal systems 
10 10 10 1 

2.3.2.2.2 Disposal Option 2 - Wastewater Reuse 
Treated wastewater may be reused for various purposes in compliance with FDEP regulations 
governing wastewater reuse. Present uses of treated effluent in Florida include the irrigation of 
landscaped areas such as golf courses, parks, highway medians, and residential properties; urban 
uses such as toilet flushing, car washing, dust control, and decorative fountains; irrigation of 
edible food crops such as citrus, corn and soybeans; wetlands creation, restoration, and 
enhancement; recharging ground water; and industrial uses such as plant wash down, processing 
water, and cooling water purposes. 

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

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

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SECTIONTWO Alternatives Evaluated 

2.3.3 Alternative 3  On-Site Treatment Upgrades 
Project applicants would use FEMA funds to convert OWTS, such as cesspools and septic tanks 
with drainfields, to OWNRS to improve wastewater management in the Keys (Figure 1-2). 
OWNRS are engineered treatment systems that, at a minimum, meet BAT treatment standards 
and require routine maintenance and service from an approved maintenance entity. OWNRS that 
dispose of 10,000 gpd of wastewater or less are regulated by FDH; OWNRS that process more 
than 10,000 gpd of wastewater are governed by FDEP and operate under operating permits 
monitored by the Monroe County Health Department. A biological nitrogen removal system 
coupled with physical/chemical phosphorus removal system, disinfection (through chlorination 
or other means), and disposal through either subsurface drip irrigation systems (SDI) or 
shallow injection wells are proposed under this alternative. Under this alternative, a cluster 
system would be designed such that multiple homes would use one OWNRS system. 

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

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

2.4 ALTERNATIVES CONSIDERED BUT DISMISSED 
Several alternative approaches to wastewater collection and disposal were evaluated towards 
selecting the most appropriate alternatives to meet the purpose and need for improving 
wastewater management methods in the Keys. Alternate actions to those proposed under 
Alternatives 2 and 3, which were considered for detailed evaluation but ultimately dismissed, are 

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SECTIONTWO Alternatives Evaluated 

summarized below. It should be noted that all disposal options under Alternative 2 were retained 
for further detailed study, and for this reason, no disposal options are discussed in this section. 

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

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

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

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

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SECTIONTWO Alternatives Evaluated 

2.4.2 On-site Treatment Options under Alternative 3 
Conventional OWTS consist of a septic tank and a subsurface wastewater infiltration system, or 
drainfield, and rely on naturally occurring soils to provide wastewater treatment. The drainfield 
and unsaturated underlying soils are the most critical components of the conventional OWTS and 
provide most of the treatment. The problem with installing OWTS in the Keys is that very little 
or no natural soils exists over the ancient coral/limestone rock, and soil must be imported to 
construct these systems. The limited soils in the Keys thus reduce the treatment effectiveness of 
these systems, especially for nutrients. Since a majority of the present water quality issues stem 
from these types of on-site systems, they do not meet the purpose and need and were dismissed 
from further study. 

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

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

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SECTIONTHREE Affected Environment and Environmental Consequences 

Topography, Soils, and Geology 

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

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

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

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

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

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SECTIONTHREE Affected Environment and Environmental Consequences 

Topography, Soils, and Geology 

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

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

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

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

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

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SECTIONTHREE Affected Environment and Environmental Consequences 

Topography, Soils, and Geology 

FIGURE 3-1: TIDAL FLOW 

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SECTIONTHREE Affected Environment and Environmental Consequences 

Topography, Soils, and Geology 

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

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

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

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

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

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SECTIONTHREE Affected Environment and Environmental Consequences 

Topography, Soils, and Geology 

INSERT FIGURE 3-2: SUBMARINE TOPOGRAPHY 

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SECTIONTHREE Affected Environment and Environmental Consequences 

Topography, Soils, and Geology 

INSERT FIGURE 3-3: FLORIDAN AQUIFER 

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SECTIONTHREE Affected Environment and Environmental Consequences 

Topography, Soils, and Geology 

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

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

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

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

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

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

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SECTIONTHREE Affected Environment and Environmental Consequences 

Topography, Soils, and Geology 

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

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

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

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

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SECTIONTHREE Affected Environment and Environmental Consequences 

Topography, Soils, and Geology 

 INSERT FIGURE 3-4: BOULDER ZONE 

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SECTIONTHREE Affected Environment and Environmental Consequences 

Topography, Soils, and Geology 

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

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

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

3.1.3.2 Environmental Consequences 
3.1.3.2.1 Alternative 1  No Action Alternative 
The project applicant would not receive FEMA funding to help meet Florida Statutory Treatment 
Standards by the year 2010. The construction of WWTPs, clustered OWNRS, and other 
wastewater management activities would likely be delayed until adequate funding becomes 
available. 

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

3.1.3.2.2 Alternative 2  Centralized Wastewater Treatment Plant Alternative 
Aside from potential impacts related to the use of injection wells, the construction of a WWTP is 
not expected to result in adverse effects on geology. The environmental consequences to the 
geologic environment with shallow injection well use are expected to be limited to the effects of 
injection of relatively fresh effluent into brackish to saline water aquifers, which could affect the 
rate of limestone solution. 

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SECTIONTHREE Affected Environment and Environmental Consequences 

Topography, Soils, and Geology 

INSERT FIGURE 3-5: CIRCULATION 

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SECTIONTHREE Affected Environment and Environmental Consequences 

Topography, Soils, and Geology 

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

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

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

3.1.3.2.3 Alternative 3  On-Site Treatment Upgrades 
Aside from potential impacts related to the use of injection wells, the construction of clustered 
OWNRS is not expected to result in adverse effects on geology. For disposing of treated effluent, 
clustered OWNRS may employ either SDI or shallow injection wells. As described in Section 
3.1.3.2.2, if disposal of relatively fresh wastewater and effluent from existing on-site systems 
through shallow injection wells has resulted in accelerated limestone dissolution, the effect has 
not been observed as an engineering issue in this case. To mitigate the potential effects of 
limestone solution OWNRS design and function, appropriate geotechnical studies would be 
conducted by the applicant prior to design and construction to adequately characterize the 
geological and geotechnical environment. 

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SECTIONTHREE Affected Environment and Environmental Consequences 

Water Resources and Water Quality 

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

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

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

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

 New direct pollutant discharges must not lower existing ambient water quality. 
 New indirect pollutant discharges (discharges to waters that influence OFWs, although not 
placed directly into an OFW) must not significantly degrade nearby OFWs. 
New project activities receiving FDEP permits must also be clearly in the public interest. 
Existing legal discharges are grandfathered and may continue without any new OFW 
requirements. 

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

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SECTIONTHREE Affected Environment and Environmental Consequences 

Water Resources and Water Quality 

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

State of Florida water quality standards are promulgated in Chapter 62-302 F.A.C. Rule 62

302.400 classifies surface waters of the State according to designated uses that include: Class I, 
Potable Water Supplies; Class II, Shellfish Propagation or Harvesting; Class III, Recreation, 
Propagation and Maintenance of a Healthy, Well-Balanced Population of Fish and Wildlife; 
Class IV, Agricultural Water Supplies; and Class V, Navigation Utility and Industrial Uses. 
Marine waters in the Keys are classified as Class III Marine Waters and include criteria levels for 
89 potential pollutants under Rule 62-302.530. 
Both the EPA and NOAA have direct mandates to conduct monitoring in FKNMS. 
Comprehensive, long-term monitoring program was begun by Florida International University 
under contract to the EPA as part of the WQPP in 1995. These monitoring efforts include 42 
fixed stations throughout the Keys to monitor coral population dynamics, 154 fixed stations from 
Key Largo to the Dry Tortugas that monitor water quality parameters such as nutrients, salinity, 
turbidity, and phytoplankton biomass, and 51 sites throughout the FKNMS to monitor seagrass 
dynamics (FKNMS, 2001). Some recent results of this monitoring program are presented in 
Section 3.2.3.1.2 of the PEA. 

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

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

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

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SECTIONTHREE Affected Environment and Environmental Consequences 

Water Resources and Water Quality 

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

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

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

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

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

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SECTIONTHREE Affected Environment and Environmental Consequences 

Water Resources and Water Quality 

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

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

7.2 mgd (Fernandez, Pers. Comm., 2001). 
The EPA (1996) estimates that nutrient loading from the Keys to nearshore marine waters total 
2,377 lbs/day of TN and 544 lbs/day of TP. Of these totals, about 80% of TN (1,900 lbs/day) and 
56% of TP (305 lbs/day) were attributed to wastewater disposal; the remaining 20% (475 
lbs/day) of TN and 44% (239 lbs/day) of TP were allocated to stormwater runoff from the Keys. 
These loading estimates assume that all wastewater nutrients, including groundwater sources, 
reach nearshore marine waters. Of the total loading cited above, 13.5% (321 lbs/day) of TN and 
6.6% (36 lbs/day) of TP were attributed to municipal outfall discharges chiefly of the City of 
Key West, which replaced their ocean outfall with a deep injection well in September 2001. Live 
aboard boats discharging sewage directly to marine waters account for 3.5% (84.1 lbs/day) of TN 
loading and 5.5% (30 lbs/day) of TP loading. Deducting the direct nutrient contributions from 
outfalls, boats, and stormwater runoff results in about 1,497 lbs/day of TN and 239 lbs/day of TP 
as the groundwater contribution to the total nutrient loading of the nearshore marine waters. 
These data suggest that nutrient-rich groundwater accounts for about 79% of TN and about 78% 
of TP loading from the Keys to the nearshore marine waters (EPA, 1996). At present, these 
numbers may be slightly lower because State waters within the Florida Keys National Marine 
Sanctuary became designated as a No Discharge Zone for sewage from all vessels in June 2002. 
Monroe County, 2002). As described in Section 1.4, nutrient levels in these nearshore marine 
waters are also influenced by external sources, such as the Gulf of Mexico and Florida Bay. 

Long, continued waste disposal into the Upper Water-Bearing Zone has led to major 
groundwater quality changes in the developed areas. While the wastewater is of lower salinity 
than that of the natural groundwater, the wastewater is enriched in the nutrients nitrogen and 
phosphorous, as well as fecal coliform bacteria, and it is oxygen-depleted. As groundwater is 
minimally used in the Keys, this groundwater quality degradation has been of little direct 
concern. However, the Upper Water-Bearing Zone is in direct communication with the nearshore 
marine waters, and the degraded groundwater can discharge into the marine environment within 
hours to days. Because of the high groundwater salinity in the Upper-Water Bearing Zone, there 
has been little testing of its hydraulic characteristics. However, Halley et al. (1997) estimate the 

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SECTIONTHREE Affected Environment and Environmental Consequences 

Water Resources and Water Quality 

hydraulic conductivity of the Miami Oolite to be about 120 meters per day, and of the Key Largo 
Limestone to be about 1,400 meters per day. This pattern of rapid groundwater discharge to 
nearshore marine waters is exacerbated by the 700 or so dead-end canals constructed over the 
past several decades, for the purposes of providing boat access to residences and dredge material 
for landfilling. Generally, these canals were excavated to 10 to 20 feet to maximize the amount 
of material available for landfilling. These deep dead-end canals in residential areas served by 
on-site sewage disposal systems have the general effect of speeding the groundwater discharge to 
marine waters. The water quality effects are described Section 3.2.3. 

3.2.2.2 Environmental Consequences 
3.2.2.2.1 Alternative 1  No Action Alternative 
As described in Section 2.3.1, FEMA funding would not be available for the wastewater 
management projects, but individual property owners and/or communities would still comply 
with the Florida Statutory Treatment Standards by 2010. 

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

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

Expected Water Quality Benefits of Meeting Florida Statutory Treatment Standards 

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

As part of preparation of this PEA, an analysis was conducted to estimate the extent of water 
quality improvements that might be expected by improving wastewater management within an 
existing service area in the Keys (Appendix D). The analysis focused on a proposal for four 
small WWTPs in the Village of Islamorada that had average daily flow capacities of 0.534 mgd, 

0.062 mgd, 0.186 mgd, and 0.129 mgd, respectively with effluent treated to AWT standards (i.e., 
5 mg/L BOD, 5 mg/L TSS, 3 mg/L TN, 1 mg/L TP), (Islamorada, 2001a). The analysis assumes 
that currently all sewage disposal is by on-site septic systems (i.e., no cesspools/cesspits), and 
that the wastewater inflow is the average daily flow of the proposed plants (i.e., 0.911 mgd). The 
assumption that all on-site systems are septic tanks is a conservative estimate of existing nutrient 
loadings because the existing cesspools typically generate higher nutrient loadings than septic 
tanks. Additionally, the analysis assumes that raw sewage nutrient concentrations are the same as 
those estimated in the Big Pine Key Demonstration Project (Ayres Associates, 1998), and that 
TP is not removed from groundwater by reaction with aquifer limestones. The results of the 
analysis found that the replacement of existing OWTS (assumed all septic systems) with 
WWTPs that meet AWT standards result in a 92% reduction in TN input to groundwater (i.e., 
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SECTIONTHREE Affected Environment and Environmental Consequences 

Water Resources and Water Quality 

280 lbs/day decreased to 22.8 lbs/day), and a 86% reduction in TP input to groundwater (50 
lbs/day to 7.6 lbs/day). In groundwater transit to discharge to marine waters, negligible TN 
reduction occurs, and it is assumed that TP is not removed from water by chemical reaction with 
the aquifers carbonate rocks. Thus, the benefit of AWT systems in terms of nutrient removal 
would be in the form of 92% reduction in TN and 86% removal of TP. Please see Appendix D of 
this PEA for additional details pertaining to the results of this analysis. 

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

3.2.2.2.2 Alternative 2  Centralized Wastewater Treatment Plant Alternative 
This alternative would involve the construction or upgrade of WWTP systems with the 
assistance of FEMA funding. Effects on groundwater would be similar to those described under 
the No Action Alternative. The water quality improvements expected under this alternative 
would be on the order of those described in the No Action Alternative and further outlined in 
Appendix D (i.e., 92 and 86% reductions in TN and TP loadings, respectively). However, it is 
difficult to determine the exact extent of these improvements due to a number of unknown 
variables. These include the length of time it would take to flush out present levels of nutrients 
and other pollutants presently in the groundwater, local variations of hydrogeologic 
characteristics, and the extent to which limestone substrates remove phosphorus from injected 
effluent. It is recommended that the project applicants implement a water quality monitoring 
program following the installation of a WWTP to assess the resulting changes in nearshore and 
offshore water quality. 

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

3.2.2.2.2.1 Collection Options: Vacuum Pumping (Option 1) and Low-Pressure Grinder 
Pump Sewer System (Option 2) 
Assuming proper design and reasonable operating conditions, neither the use of vacuum 
pumping nor low-pressure grinder pump sewer system would involve significant effects on 
groundwaters. Establishment of the collection system as part of new treatment plant construction 
would require the FDEP permits identified in Appendix E. 

3.2.2.2.2.2 Disposal Option 1 Shallow Injection Wells 
Most WWTPs in the Keys currently dispose their treated effluent into shallow injection wells 
(cased 0 to 60 feet, open hole 60-90 feet). The effluent represents recharge to the highly 

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SECTIONTHREE Affected Environment and Environmental Consequences 

Water Resources and Water Quality 

permeable Upper Water-Bearing Zone limestones. As further described in Section 2.3.2.2.1, such 
wells are considered as Class V wells and at plants of less than 100,000 gpd capacity are required 
to meet BAT limitations (i.e., 10 mg/L BOD, 10 mg/L TSS, 10 mg/L TN, and 1 mg/L TP). 
Plants of larger than 100,000-gpd capacity are required to meet more stringent AWT effluent 
limitations (i.e., 5 mg/L BOD, 5 mg/L TSS, 3 mg/L TN, and 1 mg/L TP). 

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

3.2.2.2.1. 
Present Federal requirements prohibit any injection activity that may endanger USDW (40 CFR 
Part 144). Similarly, present Federal regulations require all owners and operators of Class V 
injection wells to provide inventory information to FDEP, the State UIC authority. Construction 
of new wells or upgrade of existing shallow Class V injection wells would require compliance 
with joint EPA/FDEP UIC regulations and the FDEP-administered permits referenced in 
Appendix E. As further explained in Section 3.6.4, Public Health, effluent would be disinfected 
to reduce the health risk of fecal contamination through such techniques as biological treatment 
and/or chlorination. 

3.2.2.2.2.3 Disposal Option 2  Wastewater Reuse 
Under present State regulations, effluent reuse is authorized for various purposes of which land 
application for irrigation is the principal reuse practiced in Florida. However, in the Keys, land 
application has not been widely used, owing to the absence of agricultural demand and the high 
cost of effluent reuse due to stringent treatment standards, which is not competitive with the cost 
of fresh water imported from the mainland via pipeline. Under continuation of present policies 
and conditions, it is not expected that effluent reuse would significantly affect groundwater in 
terms of quality or quantity. 

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

E. 
3.2.2.2.3 Alternative 3  On-Site Treatment Upgrades 
FEMA funding would be used to assist in the conversion of OWTS to clustered OWNRS. New 
OWNRS would be required to meet BAT standards of 10 mg/L BOD, 10 mg/L TSS, 10 mg/L 
TN, 1 mg/L TP. 

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

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

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

1. Conventional septic tank coupled with a recirculating sand filter (RSF) and ABF. 
2. Conventional septic tank coupled with SDI in porous media irrigation beds. 
3. Fixed Activated Sludge Treatment (FAST), (proprietary). 
4. Continuous Feed Cyclic Reactor System (CFCRS), (proprietary). 
5. Rotating Biological Contactor (RBC), (proprietary). 
Additional unit processes were tested for nitrogen and phosphorus removal as add-ons to the 
above methods. These included a chemical precipitation unit (CPU), engineered porous media 
intermittent filter beds with SDI, and a carbon tablet feeder/ABF for de-nitrification. 

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

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

System Number BOD 
(mg/L) 
TSS 
(mg/L) 
TN 
(mg/L) 
TP 
(mg/L) 
10 10 10 1 
1 2.18 2.25 20.76 1.76 
2 2.81 4.09 21.15 0.6 
3 2.63 4.63 10.97 5.38 
4 3.19 6.85 15.46 6.24 
5 1.68 5.75 12.52 4.67 

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

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

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

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

3.2.3.1.1 Inland Waters 
Degraded water quality within canals throughout the Keys has been documented since the early 
1970s. Barada and Partington (1972) concluded that excavating artificial canals causes serious 
environmental degradation within the canals themselves and in waters adjacent to canals. Deep, 
narrow, box-cut canals with dead-end configurations gradually accumulate oxygen-demanding and 

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toxic sediments and organic wastes, causing low dissolved oxygen, objectionable odors (hydrogen 
sulfide), and floating sludge that can result in fish kills and undesirable conditions. Eutrophication 
often occurs in canals with poor circulation and is accelerated by a heavy pollution load, which is 
related to population density and shoreline length (Barada and Partington, 1972; Kruczynski, 
1999). 

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

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

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

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

Several recent studies have found a connection between fecal contamination and eutrophication of 
nearshore waters and septic tanks. Lapointe and Clark (1992) found a gradient in nutrients from 
nearshore to offshore waters with canals having elevated soluble reactive phosphorus (0.3 
micromole (M)) compared to seagrass meadows (0.1 M), patch reefs (0.05 M), and offshore 
reef banks (0.05 M). The results of the study concluded that the widespread use of septic tanks 
increases the nutrient contamination of groundwaters that discharge into shallow nearshore waters, 

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resulting in coastal eutrophication. In a later study, Lapointe et al. (1994) found that nutrient 
enrichment from land-based sewage inputs can significantly affect seagrass productivity for 
considerable distances from shore (3 to 4 miles). Paul et al. (1997) used an active shallow Class V 
disposal well in the Middle Keys and a simulated injection well in Key Largo to understand the 
transport and fate of wastewater. In both areas, viral tracers appeared after short periods in marine 
waters (10 hours and 53 hours for Key Largo and the Middle Keys, respectively). 

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

In addition to directed scientific research, water quality monitoring has been conducted by Florida 
International University as part of the WQPP since 1995 as introduced in Section 3.2.1. Of the 
several water quality parameters that have been monitored, the program has revealed significant 
trends in TP, nitrate (NO3), and total organic nitrogen (TON). According to the Fiscal Year 2000 
Annual Report, trend analysis showed statistically significant increases in TP for the Tortugas, 
Marquesas, Lower Keys, and portions of the Middle and Upper Keys over the 5-year sampling 
period. The trends were identified as linear increases with little seasonality. No TP trends were 
observed in Florida Bay or in those FKNMS sites most influenced by transport of Florida Bay 
waters. Concentrations of NO3 increased over the period with most of the increases occurring in 
the Shelf, Tortugas, Marquesas, Lower Keys, and Upper Keys. TON decreased over the 5-year 
sampling period. The monitoring program speculates that regional circulation patterns arising 
from the Loop and Florida Currents were responsible for the decreases in TON (Jones and Boyer, 
2001). It should be noted that several other studies, including Cook (1997) and Rudnick et al. 
(1999), identify Florida Bay and the Gulf of Mexico as significant contributors of nutrients to the 
marine waters of the Keys. Additional research is needed to identify the relative contributions of 
the various sources of water quality degradation in the nearshore and offshore waters of the Keys. 

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

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SECTIONTHREE Affected Environment and Environmental Consequences 
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3.2.3.1.3 Stormwater 

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

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

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

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

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SECTIONTHREE Affected Environment and Environmental Consequences 

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for addressing stormwater management throughout the Keys that includes proposed management 
alternatives (Monroe County, 2001a). 

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

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

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

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

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

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INSERT FIGURE 3-6: STORMWATER 

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SECTIONTHREE Affected Environment and Environmental Consequences 

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3.2.3.2 Environmental Consequences 
3.2.3.2.1 Alternative 1  No Action Alternative 
The project applicant would not receive FEMA funding to help meet Florida Statutory Treatment 
Standards by the year 2010. As described in Section 3.2.2.2.1, the installation and upgrading of 
WWTPs and conversion of OWTS to clustered OWNRS are expected to lead to incremental 
improvements to canal and nearshore marine waters (i.e., 92 and 86% reductions in TN and TP 
loadings, respectively, Appendix D). Although treated to significantly higher BAT or AWT 
standards, depending on the quantity of wastewater treated, the input of nutrients to the shallow 
groundwater body would continue, but at reduced rates. In order to quantify the extent of water 
quality improvements more specifically, a comprehensive evaluation of the present water quality 
situation would be required. This would include an extensive series of test wells and monitoring 
throughout the Keys. In order to evaluate the timing of water quality improvements both onshore 
and offshore, it would be necessary to carry out simulation modeling of the groundwater systems 
and the effect of nutrient contamination on nearshore and offshore waters. 

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

3.2.3.2.2 Alternative 2  Centralized Wastewater Treatment Plant Alternative 
This alternative would involve the construction or upgrade of WWTP systems with the 
assistance of FEMA funding. The environmental consequences to inland, nearshore, and offshore 
water are closely related to those described under groundwater because of the connectedness 
between groundwaters and canal and nearshore waters (Sections 3.1.3 and 3.2.2). 

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

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

The project applicant would be required to develop and implement a stormwater management 
plan as part of its WWTP engineering and operation designs in order to adequately accommodate 
stormwater flows on site. Construction activities of the WWTP would require a NPDES permit 

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SECTIONTHREE Affected Environment and Environmental Consequences 

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from the SFWMD if the facility results in ground disturbance in excess of 5 acres, as well as a 
general stormwater permit for the operation of the facility, itself. The implementation of a 
stormwater management plan would include specific measures such as storm inlets, swales, 
and/or drain wells to control stormwater runoff and prevent effects on stormwater quality. 

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

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

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

Disposal Option 1  Shallow Injection Wells 

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

Disposal Option 2  Wastewater Reuse 

Under this alternative, treated effluent would be available for irrigation, dust control, car washes, 
lawns, laundry, ponds, and other accepted uses. FDEP regulates the reuse of treated wastewater 
through its Domestic Wastewater and Water Reuse Programs in accordance with Florida State 
objectives in Section 373.250 and Section 403.064 Florida Statutes of encouraging and 
promoting reuse. For the reuse of reclaimed water, wastewater must be treated to secondary 
treatment, with basic disinfection and pH control for non-edible agricultural and land application. 
Additional levels of preapplication treatment, such as high level disinfection, is required by 
FDEP as a result of: the method of reclaimed water or effluent application/ distribution, the 
extent of intended public access, the characteristics of the potential receiving nearshore water or 
ground protection pursuant to reuse or effluent disposal provisions of Chapter 62-610, F.A.C. 
Definitions of high level and basic disinfection are in Section 3.6.4.2.1. These uses would not 
likely adversely affect inland, nearshore or offshore waters provided that required permitting is 
obtained and effluent standards are met. The application of treated effluent for irrigation 
purposes, such as maintaining lawns and landscaping, is not expected to have a significant 
negative impact on marine or terrestrial resources. The relatively low level of TP in treated 

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SECTIONTHREE Affected Environment and Environmental Consequences 

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effluent would be largely removed by precipitation or adsorption on contact with limestone 
bedrock (Corbett et al., 1999). TN in treated effluent would be largely taken up by terrestrial 
plant biomass (e.g., lawn grasses and other landscape plants). Although some fraction of these 
nutrients could be re-released as the biomass decays, the fraction of TN returned to the system is 
expected to be negligible. Further details regarding the application method and required effluent 
treatment standards would be included in the project-specific SER. 

3.2.3.2.3 Alternative 3  On-Site Treatment Upgrades 
As the shallow groundwaters of the Keys discharge nutrients to nearshore marine waters, the 
environmental consequences of the alternative mirror those described under Section 3.2.2, 
Groundwater. The principal differences are that part of the TP loading to groundwater probably 
is removed by adsorption on limestone of the aquifer (Kruczynski, 1999), and direct discharges 
to marine waters by outfalls and boats do not apply to groundwater. These latter nutrient 
contributions as of 1996 (Ayres Associates, 1998) comprised 320 lbs/day and 84 lbs/day of TN 
and 36 lbs/day and 30 lbs/day of TP, respectively. 

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

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

3.2.4 Floodplains and Wetlands 
3.2.4.1 Affected Environment 
3.2.4.1.1 Floodplains 
EO 11988, Floodplain Management, requires Federal agencies to take action to minimize 
occupancy and modification of floodplains. Furthermore, EO 11988 requires that Federal 
agencies proposing to site a project in the 100-year floodplain consider alternatives to avoid 
adverse effects and incompatible development in the floodplain. According to 44 CFR Part 9, 

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

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

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

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

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

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

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

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

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INSERT FIGURE 3-7: FLOODPLAIN 

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

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

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

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

3.2.4.2 Environmental Consequences 
3.2.4.2.1 Alternative 1  No Action Alternative 
Monroe County wastewater system owners/operators would likely undertake a number of 
WWTP and clustered OWNRS projects to meet Florida Statutory Treatment Standards by 2010. 
Given the fact that most of the Keys lie within the regulated 100-year floodplain, siting of 
individual projects outside of the floodplain would be difficult. While floodplain locations 
should be selected as project sites only if no reasonable alternative exists, it is expected that most 
selected sites would affect floodplains either partially or wholly given the predominance of 
floodplain designated areas in the Keys. Monroe County Ordinance Sections 9.5-315, 9.5-316, 
and 9.5-317 specify that public facilities such as water and gas main, electric, telephone and 

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sewer lines, and streets and bridges be protected from high flood hazards. For non-residential 
structures, instead of elevating the structure to the base flood elevation (BFE), the structure may 
be designed such that structure below the BFE is watertight, with walls substantially 
impermeable to the passage of water and with structural components having the capability of 
resisting hydrostatic and hydrodynamic loads and effects of buoyancy. 

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

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

3.2.4.2.2 Alternative 2  Centralized Wastewater Treatment Plant Alternative 
As with the No Action Alternative, it is expected that most selected sites would affect 
floodplains given the predominance of floodplain designated areas in the Keys. If structures 
associated with the wastewater treatment alternatives (e.g., WWTPs, pump stations, etc.) are 
constructed in the floodplain, they must be floodproofed or elevated with fill or solid walls to 
prevent operational failure and structure damage during storms and flooding. Standards and 
regulations pertaining to construction in the floodplain in Monroe County are promulgated in 
amendments to Monroe County Ordinance. These amendments specify design features required 
for structures proposed in the floodplain and vary depending on the level of flood hazard. As 
specified in 44 CFR 9, structures must be elevated such that the lowest floor of the structures is 
at or above the level of the base flood. For non-residential structures, instead of elevating to 
BFE, the structure may be designed such that structure below the BFE is water tight, with walls 
substantially impermeable to the passage of water and with structural components having the 
capability of resisting hydrostatic and hydrodynamic loads and effects of buoyancy. 

Additionally, there is a public concern that the proposed WWTP would lead to further 
development of the floodplain within the project area by introducing key infrastructure, which is 
often linked to additional development. However, development within the Keys is not controlled 
by addition of key infrastructure, but instead by Monroe Countys ROGO permit allocation 
system as described in Section 3.10. The construction of new wastewater treatment infrastructure 
in the Keys is essential to effectively treat existing wastewater flows, and is not proposed as a 
way to introduce or support increased development. Therefore, if growth and development in the 
floodplain occurs following implementation of this alternative, it is a function of established 

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county planning and is not directly related to proposed projects for wastewater management 
improvements. Given the above points, an evaluation of secondary effects on floodplains with 
regard to the potential for increased development under the alternatives was not conducted. 

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

Collection Option 1  Vacuum Pumping 

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

Collection Option 2  Low-Pressure Grinder Pump Sewer System 

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

Disposal Option 1  Shallow Injection Wells 

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

Disposal Option 2  Wastewater Reuse 

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

3.2.4.2.3 Alternative 3  On-Site Treatment Upgrades 
The conversion of OWTS to clustered OWNRS may require the importation, movement, and/or 
excavation of a limited amount fill used in grading activities. Effects on floodplains are similar to 
those described under the Section 3.2.4.2.2, Centralized Wastewater Treatment Plant Alternative. 
Effects on wetland areas as a result of this alternative would be evaluated in the site- and project-
specific SER. 

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

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

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

Tropical hardwood hammocks occur on slightly higher elevations not exposed to saltwater 
flooding and have a better-developed soil layer of largely organic matter. Along with pinelands, 
tropical hardwood hammocks represent the climax upland community type in the Keys and are 
second in terms of biodiversity (Ross et al., 1992). Tropical hardwood hammocks in the Keys are 

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

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

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

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

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fixation does occur, so that productivity is usually limited by other nutrients. Carbon export to 
marine systems is a major function of the mangrove community. 

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

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

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

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

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limited primarily by natural patterns of sand movement associated with wind and waves, 
construction of coastal structures, and human and vehicular traffic. 

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

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

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

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

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

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

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

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Keys complex, where the islands act as barriers to the transport of silts and other materials from 
Florida Bay. 

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

 Shallow spur and groove, which are well developed, actively accreting, platform margin 
reefs found on the fore reef of the reef tract. 
 Drowned spur and groove, which are older platform margin reefs that are not actively 
growing and are often buried in sand that has migrated. 
 Remnant  low profile reefs lack the distinctive spur and groove characteristics. The vertical 
relief of these reefs varies from 1.5 to 6.5 feet. 
 Back reef, which is the landward section of the spur and grove type platform margin reefs. 
This is typically a rubble zone, colonized by heartier corals. 
 Reef rubble areas, where unstable pieces of the reef fractured from wave action exist in these 
areas with little or no visible colonization. 
In the Upper Keys, the reef tract is located about 6 miles offshore, forming an almost continuous 
community that parallels the Keys from Carysfort Reef at the north end to Crocker Reef at the 
south (FMRI, 2000). This area has a large abundance of patch reefs and well-developed bank 
reefs. The Middle Keys, which are smaller and separated by numerous wide channels connecting 
with Florida Bay, have limited reef development, largely due to a lack of protection from the 
variations in temperature, salinity and clarity of water coming from the Gulf of Mexico and 
Florida Bay (FMRI, 2000). In the Lower Keys, the reef tract extends from Looe Key Reef to 
Cosgrove Shoal, south of the Marquesas (FMRI, 1998). 

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

Relatively abundant food fish species occur on nearshore and midshelf reefs. These include the 
sheepshead (Archosargus probatocephalus), the porkfish (Anisotremus virginicus), black 
margate (Anisotremus surinamensis), mutton snapper (Lutjanus analis), gray snapper (Lutjanus 
analis), black sea bass (Centropristis striata), flounder (Paralichthys dentatus), and gray 
triggerfish (Balistes capriscus). Juveniles of commercial importance include the gag grouper 
(Mycteroperca microlepis), red grouper (Epinephelus morio), and black grouper (Mycteroperca 
bonaci). Another abundant predator on the reefs is the sport and food fish, the common snook. 
Many other species are collected for aquariums. These include angelfish (Pomacanthidae), 
butterflyfish (Chaetodontidae), wrasses (Labridae), damselfish (Pomacentridae), and doctorfish 
(Acanthuridae). The smaller tropical fish are important ecologically as prey for grouper, snook, 

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SECTIONTHREE Affected Environment and Environmental Consequences 

Biological Resources 

and other piscivores (fish eaters). Other important prey would include the silver porgy (Diplodus 
argenteus) and at least two species of mojarra (Eucimostomus sp.). 

Recent assessments of the conditions of the Florida Reef Tract have indicated accelerating 
degradation. Bleaching, sedimentation, salinity, light availability, heavy rainfall, drought, 
temperature (winter cold fronts), algal overgrowth, coral diseases, and pollution from point and 
nonpoint sources contribute to the declining health of reefs (Dustan, 1999; Jaap, 1984). Recent 
research by Patterson et. al (2002), have linked white pox , a coral disease which causes 
irregularly shaped white lesions on elkhorn coral, to an enterobacterium, Serratia marcescens. 
Enterobacterium commonly inhabits the gastrointestinal tract of humans and other animals, and 
can also be free-living in soil and water. In addition to S. marcescens, other bacteria associated 
with human fecal matter, hasve been found to be concentrated on the mucoid surface layers of 
corals in the Florida Keys (Lipp et al, 2002, as cited in Paterson et. al, 2002). 

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

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

3.3.2 Environmental Consequences 
3.3.2.1 Alternative 1  No Action Alternative 
Improved wastewater management activities would be implemented to meet the new Florida 
Statutory Treatment Standards. However, without FEMA funding, the rate at which wastewater 
treatment improvements are made would be slower than under Alternatives 2 and 3, while 
project applicants identify additional financing options. Adverse effects on nearshore marine 
environments, such as coral reefs, would continue as a result of inadequate septic tanks and 
cesspools/cesspits potentially releasing high levels of nutrients into shallow groundwater. 

Once funding is identified and necessary permits obtained, construction would begin. 
Construction of new facilities or additions to existing facilities could result in vegetation or 
habitat loss of about 1 to 5 acres for each facility depending on specific site design. Since most 
facilities are expected to be located near highly developed areas, many potential sites may be 
degraded and have reduced habitat value. If no other suitable sites are available, some loss to 

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SECTIONTHREE Affected Environment and Environmental Consequences 

Biological Resources 

high quality habitat areas could result from construction. The potential for effects to high quality 
upland habitat (e.g., tropical hardwood hammocks) is higher for the Upper Keys project area. 

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

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

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

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

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

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

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SECTIONTHREE Affected Environment and Environmental Consequences 

Biological Resources 

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

Collection Option 1  Vacuum Pumping and Collection Option 2  Low-Pressure Grinder Pump 
System 

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

Disposal Option 1  Shallow Injection Wells 

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

Disposal Option 2  Wastewater Reuse 

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

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SECTIONTHREE Affected Environment and Environmental Consequences 

Biological Resources 

nutrients could be re-released as the biomass decays, the fraction of TN returned to the system is 
expected to be negligible. 

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

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

In addition to the requirements of ESA, Federal agencies must also comply with the 1996 
amendments to the Magnuson-Stevens Fishery Conservation and Management Act (MSA) (16 

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

Biological Resources 

Federal action agency may decide which process to use for any given EFH consultation (NMFS, 
2001). 

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

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

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

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

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

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

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SECTIONTHREE Affected Environment and Environmental Consequences 

Biological Resources 

3.3.3.2 Environmental Consequences 
3.3.3.2.1 Alternative 1  No Action Alternative 
FEMA would not be the Federal action agency; therefore, FEMA would not be required to 
undertake activities related to compliance with Section 7 of ESA and EFH. However, specific 
effects on special status species would be considered in the SER following issuance of the final 
PEA. Because this alternative may involve construction of WWTPs and/or clustered OWNRS, 
effects on special status species would likely be similar to those under Alternatives 2 and 3 
discussed below. 

3.3.3.2.2 Alternative 2  Centralized Wastewater Treatment Plant Alternative 
Assessing effects on special status species depends on the specific siting of WWTPs as well as 
their design component details; therefore, effects on protected species and their habitats would be 
considered as part of the project-specific SER (including all collection and disposal options 
proposed under this Alternative). In compliance with Section 7 of ESA, FEMA would conduct 
appropriate consultation, including seeking concurrence for findings of effect, with USFWS 
and/or NMFS with regards to proposed projects and their potential to impact protected species 
and their habitats. Mitigation measures developed in consultation with USFWS and/or NMFS 
during the Section 7 process would become applicant conditions for project implementation. 

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

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

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

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

Questions have been raised regarding a possible connection between chemicals (such as chlorine, 
by-products, and daughter compounds) and nutrients and a marked increase of 
Fibropapillomatosis (FP) in sea turtles. The disease is generally characterized by multiple lobe-

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SECTIONTHREE Affected Environment and Environmental Consequences 

Biological Resources 

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

3.3.3.2.3 Alternative 3  On-Site Treatment Upgrades 
Effects on special status species, and consultation requirements, would be similar to those 
described in Alternative 2 and would be further developed in preparation of the project-specific 
SER. 

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SECTIONTHREE Affected Environment and Environmental Consequences 

Air Quality 

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

The EPA Office of Air Quality Planning and Standards has set NAAQS for six principal 
pollutants, known as criteria pollutants: carbon monoxide (CO), nitrogen dioxide (NO2), ozone 
(O3), lead (Pb), particulate matter less than 10 microns (PM 10), and sulfur dioxide (SO2). The 
FDEP has two Special Purpose Monitoring stations in Monroe County, one on Stock Island at JR 
College Road and US Highway 1 and the other in Marathon at 2796 Overseas Highway (FDEP, 
1999). These stations only monitor PM 10. The average of the 1-hour maximum recordings in 
the last 4 years was 46 micrograms per cubic meter (g/m3) with no exceedances in any year. 
This is well below the NAAQS 24-hour average standard value of 150 g/m3. 

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

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

County 
Pollutant (in parts per million [ppm]) 
SO2 
Max 
24-hr. 
(.14 
ppm*) 
Lead 
Max 
Quarterly 
Mean 
(1.5 g/m3) 
CO 
Max 1-hr. 
(35 ppm) 
CO 
Max 8-hr. 
(9 ppm) 
NO2 
Max 
Annual 
Average 
(.053 ppm) 
Ozone 
Max 1-hr. 
(.12 ppm) 
PM 10 
Max 24-hr 
(150 g/m3) 
Monroe N/A N/A N/A N/A N/A N/A 59 g/m3 
Broward .031 
ppm 05 g. /m3 7.5 ppm 4.1 ppm .010 ppm .092 ppm 47 g/m3 
Collier N/A N/A N/A N/A N/A N/A 42 g/m3 
Miami-
Dade 
.004 
ppm N/A 8.7 ppm 4.8 ppm .016 ppm .100 ppm 54 g/m3 
Source: FDEP, 2000  EPA Aerometric Information Retrieval System (AIRS). 

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SECTIONTHREE Affected Environment and Environmental Consequences 

Air Quality 

3.4.2 Environmental Consequences 
3.4.2.1 Alternative 1No Action Alternative 
Monroe County grant applicants would not receive FEMA funds for wastewater management but 
would still have to meet Florida Statutory Treatment Standards by 2010. The systems upgrades 
would likely require the operation of heavy equipment during construction and would result in 
minor temporary adverse effects on air quality from increased exhaust pollutants. Windblown 
soil and dust may also occur during the construction phase as a result of equipment movement 
over exposed soil areas. Fugitive dust can be greatly minimized by appropriate dust control 
measures such as wetting the surfaces, mulch, and by re-vegetating disturbed areas as soon as 
possible following construction. 

3.4.2.2 Alternative 2  Centralized Wastewater Treatment Plant 
Minor, temporary, and localized adverse effects on air quality may result from the construction 
or upgrade of WWTPs. The operation of heavy equipment during construction would result in 
minor temporary adverse impacts on air quality from increased exhaust pollutants. The new 
wastewater treatment facilities would result in the ingress and egress of maintenance equipment. 
Windblown soil and dust may also occur, as described in Section 3.4.2.1, No Action Alternative. 

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

Collection Option 1  Vacuum Pumping 

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

Collection Option 2  Low-Pressure Grinder Pump Sewer System 

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

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Air Quality 

Disposal Option 1  Shallow Injection Wells 

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

Disposal Option 2  Wastewater Reuse 

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

3.4.2.3 Alternative 3  On-Site Treatment Upgrades 
Impacts related to construction activities would be similar to those described in Section 3.4.2.1, 
No Action Alternative. The installation of clustered OWNRS systems would require periodic 
maintenance and subsequently result in a minor increase in the number of vehicles traveling 
through the area. 

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

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Cultural Resources 

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

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

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

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

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

 Where erosion has exposed deeper and earlier strata or sediments 
 Where sediment accumulation has occurred at a slower rate 
 Near sinkholes where deep sediments are exposed to the present surface 
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 Along the central Gulf Coast, where sea-level rise has exposed Pleistocene limestone 
outcroppings (FSHPO, 1993) 
The Florida State Historic Preservation Offices Master Site Files database of archaeological 
sites has only one known Paleo-Indian site, Grass Key Rock Pit site (8MO1297), within the Keys 
region. Though located some distance from the Keys, the Cutler Fossil Site (8DA2001) in Dade 
County is considered a significant Paleo-Indian manifestation in the Everglades cultural area. 

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

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

3.5.1.3 Glades Period (ca. 2,500 BP to AD 1500) 
From about 2,500 BP to European contact during the 16th century, the development of diverse 
cultural traditions occurred throughout Florida. In south Florida, the Glades tradition is divided 
into many sub-periods based primarily on differences in ceramic decoration styles. Lithic 
artifacts are sparse in south Florida; chert outcrops are rare, so other materials such as wood, 
bones, and shells were used to configure tools. Ceramics during the pre-Glades period (ca. 
2500 BP to AD 1) are normally undecorated (Glades Plain and Goodland Plain) (FDHR, 2001). 
The Glades I early period (AD 1-500) ceramic type is characterized by quartz sand and grit 
temper. Later Glades periods (AD 500-1700) included the appearance of punctated, incised, and 
stamped decoration on pottery, as well as European artifacts during the Glades IIIc period 
(FDHR, 2001). 

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

3.5.1.4 Historic Period (ca. Mid-1500s to 1951) 
Spaniards in search of gold, silver, and other natural resources first arrived in Florida in the mid1500s, 
marking the beginning of contact that would forever change, and virtually eradicate, 
Floridas native cultures. Once the Spanish realized that the riches of South and Central America 

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were not to be found in Florida, their focus turned to converting the native population to 
Christianity. Relations with the Timucua, the Guale, and the Apalachee were tumultuous at best, 
and aspects of this adversarial relationship are reflected in the archaeological record. The 
building, burning, and rebuilding of missions occurred with confusing frequency (FSHPO, 
1993). Chaotic relations between Native populations and Europeans were common throughout 
the southeast. European trade interests exacerbated difficulties and boundary squabbles. Florida 
eventually became home to the Seminole Indians, who were comprised of Creek Indians from 
the north who were fleeing British encroachment in that region. In the Keys, the Tequestas and 
Calusas, two early south Florida tribes, disappeared before the new Seminole population arrived. 
The Seminoles continue to inhabit parts of Florida today. 

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

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

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

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3.5.2 Environmental Consequences 
3.5.2.1 Alternative 1  No Action Alternative 
FEMA would not provide funds to Monroe County grant applicants for wastewater management 
improvements. Thus, the project would not be subject to FEMA Section 106 review for potential 
effects to cultural resources. Nevertheless, because Alternative 1 would consist of a combination 
of Alternatives 2 and 3, effects on cultural resources would be similar to those discussed in 
Sections 3.5.2.2 and 3.5.2.3. 

3.5.2.2 Alternative 2  Centralized Wastewater Treatment Plant Alternative 
Under this alternative, cultural resources may be adversely affected in areas where new treatment 
facilities or modifications to existing facilities are made. Adverse effects to historic architectural 
resources within view of wastewater facilities are unlikely since there are no known historic 
structures within the viewshed of any of the currently known WWTP sites. Furthermore, 
buffering around the facilities would likely preclude potential adverse effects of actions proposed 
under this Alternative. 

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

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

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

Collection Options 1 and 2  Vacuum Pumping and Low Pressure Grinder Pump 

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

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Disposal Option 1  Shallow Injection Wells 

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

Disposal Option 2  Wastewater Reuse 

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

3.5.2.3 Alternative 3  On-Site Treatment Upgrades 
Existing on-site systems would be upgraded or replaced with a clustered OWNRS, which 
requires a relatively small area for each unit. Depending upon the scale of modification required 
to upgrade these systems and the need for new subsurface pipes, adverse effects to 
archaeological resources may occur in areas of previously undisturbed ground. Since OWNRS 
do not involve significant building retrofits and are mostly installed below ground, it is unlikely 
that historic buildings and viewsheds would be affected. Potential effects of the clustered 
OWNRS systems on cultural resources would be evaluated further at the project specific SER 
level. 

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Socioeconomic Resources 

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

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

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

Some of the more popular tourist activities include sightseeing and attractions, swimming and 
beach activities, snorkeling, visiting museums and historic sites, wildlife observation, and, to a 
lesser extent, personal watercraft use, fishing, scuba diving, and camping (Leeworthy and Wiley, 

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1996). There is a strong connection between the abundance and diversity of natural resources in 
the Keys and the value of the tourism industry (Leeworthy and Bowker, 1997). 

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

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

3.6.1.2 Environmental Consequences 
3.6.1.2.1 Alternative 1  No Action Alternative 
No FEMA funds would be provided to Monroe County grant applicants or applied to wastewater 
management projects. Alternative funding would be needed to improve wastewater management 
so that it would comply with Florida Statutory Treatment Standards by 2010. 

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

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

Construction activities associated with the implementation of wastewater management projects 
proposed in the MCSWMP have the potential to result in localized and temporary, adverse 
effects on tourism. Depending on the location of these projects, traffic may be re-routed or 

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tourist attractions may be temporarily closed. Temporary construction activities associated with 
wastewater management upgrades would be short-term and generally considered part of routine 
maintenance of facilities. With effective mitigation, such as timing the construction in the offseason, 
the effects would be negligible. 

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

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

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

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

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

Spiny Lobster represents the largest Keys fishery harvest, at about $25,600,000 per year based 
on an average of 1995 to 2000 harvest-value figures. Established in the late 1940s, the Tortugas 
pink shrimp industry is the second largest fishery business, at about $6,150,000 annually 
(NOAA, 1999 and Brown, Pers. Comm., 2001). Large stone crab is the third largest at 
$3,860,000 annually (Brown, Pers. Comm., 2001). It is likely the high value of commercial 
fishing in the Keys is due to the high profitability of the three main harvests: lobster, crab, and 

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shrimp. Statistically, fin fishes, such as grouper, tuna, snapper, ballyhoo, and flounder, have 
fluctuated in harvest, but generally declined by an average of about 9% between the years 1995 
and 2000, with an uncharacteristic increase in fin fish in 1999. Harvesting of live rock and live 
sand, used in decorative aquariums, has also declined, however this is likely due to a ban on 
harvesting live rock and live sand in Florida State waters (Table 3-3). 

Table 3-3: Trends in Monroe County Fishery 

Year 1995 1996 1997 1998 1999 2000 

Fish (in pounds) 
Fin Fish 7,759,793 7,125,859 6,413,043 6,010,078 6,373,180 5,410,236 
Invertebrates1 9,719,450 10,116,097 10,060,710 8,839,995 10,610,628 7,858,628 
Shrimp 5,313,128 6,388,154 3,695,231 6,156,735 3,968,242 3,425,180 
Bait Shrimp 70,597 218,448 86,565 102,190 92,695 117,667 
Marine Life Fin 
Fish2 
123,001 99,930 108,463 119,690 110,199 98,201 
Marine Life 
Invertebrates3 
1,089,559 1,041,728 965,442 1,519,671 1,827,976 2,165,134 
Plants 18,908 7,871 9,103 7,911 11,243 10,720 
Live Rock/Sand 493,548 119,622 68,114 16,512 21,325 28,406 
Total 24,587,984 25,117,709 21,406,671 22,772,782 23,015,488 19,114,172 

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

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

3Marine Life Invertebrates include conchs, crabs, jellyfish, lobsters, anemones, snails, stars, urchins, 

and sanddollars. 

Source: Florida Fish and Wildlife Conservation Commission 

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

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

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3.6.2.2 Environmental Consequences 
3.6.2.2.1 Alternative 1  No Action Alternative 
Keys Communities would not receive FEMA funds for wastewater management and still would 
have to meet Florida Statutory Treatment Standards by the year 2010. Keys nearshore marine 
waters would likely improve as planned wastewater management activities reduce the amount of 
nutrients and other pollutants entering the marine waters. Because detailed studies related to the 
impact of septic tanks and cesspit systems on commercial fisheries have not been completed for 
the Keys, it is difficult to quantify the expected improvement to fisheries associated with meeting 
the Florida Statutory Treatment Standards. As described in the Water Quality Section 3.2.2.2.1, 
the replacement of existing cesspits and septic systems with OWNRS systems and centralized 
WWTPs would greatly reduce the overall nutrient and pathogen inputs to the shallow 
groundwater of the Keys. Generally, it may be predicted that harvested species that occur in 
nearshore waters such as spiny lobster, white mullet, gray snapper, various flounder, shrimp, and 
stonecrab would benefit from improved water quality. In consideration of the cumulative effect 
of on-going stormwater management activities and other wastewater management activities in 
the Keys, the benefits may range from relatively insignificant to potentially substantial 
improvements in harvest rates. These effects cannot account for pollutants from Florida Bay, 
which would continue to adversely affect commercial fisheries regardless of wastewater 
treatment improvements in the Keys. As described in Section 4, the Everglades restoration 
activities would likely assist in decreasing nutrient inputs to Florida Bay. 

3.6.2.2.2 Alternative 2  Centralized Wastewater Treatment Plant Alternative 
FEMA would provide funding to aid in the construction or upgrade of community and regional 
WWTPs throughout the Keys. Effects on commercial fishing due to the use of WWTPs are 
similar to those described in Section 3.6.2.2.1. None of the collection or disposal options is 
expected to impact fisheries beyond the effects described in Section 3.6.2.2.1. 

3.6.2.2.3 Alternative 3  On-Site Treatment Upgrades 
FEMA would provide funding to Monroe County grant applicants to upgrade OWTS to OWNRS 
to improve wastewater management in the Keys. Effects on commercial fishing due to the use of 
clustered OWNRS are similar to those described under Alternative 1 in Section 3.6.2.2.1. 

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

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projects that provide watershed management and water supply protection for the Keys potable 
water resources. 

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

3.6.3.1.1 Existing Wastewater Management Costs in Monroe County 
For the purpose of this PEA, wastewater management cost discussions may include reference to: 
1) system capital costs which include expenses associated with planning, designing, 
engineering, purchasing, building, and installing a wastewater treatment system, and its needed 
wastewater conveyance piping in public right-of-ways and selected effluent disposal method 

(e.g. injection wells, SDI, reuse); 2) abandonment and lateral costs which include the expenses 
associated with removal and disposal of the existing wastewater treatment system, and piping on 
service recipients property for connection to a new system; and 3) operation and maintenance 
(O&M) costs for the system. Each of the above costs may be combined into a monthly rate 
structure, where the system is administered by a utility, which would include amortization of 
some costs, as detailed in the discussion. 
Five basic types of wastewater systems are presently used in Monroe County: cesspits, septic 
tanks, on-site ATUs, OWNRS, and centralized WWTPs. The OWNRS and some of the WWTPs 
are already compliant with Florida Statutory Treatment Standards. Wastewater costs associated 
with them are addressed in Section 3.6.3.2, which discusses the consequences of implementing 
wastewater management improvements that meet Florida Statutory Treatment Standards. 

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

3.6.3.2.1. 
Septic systems are prevalent in Monroe County, for both homes and small businesses. Septic 
systems collect sewage in a tank and allow the liquid waste to filter through the drainfield into 
shallow soils and subsurface limestone. For septic systems in working condition, pumping to 
remove solid waste is only needed about every six to ten years (D and D Enterprises, Inc., Pers. 
Comm., 2001). The cost to pump a standard size septic tank of 1,000 gallons is about $300, 
equating to an approximate annual cost of $38 or a little over $3 a month (assuming pumping 
every 8 years). 

Many new or recently built homes and some large residential wastewater generators (e.g., 
resorts, motels, RV parks, trailer parks) in Monroe County use non-compliant ATUs to treat 

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waste. Currently, these systems handle only a very small percentage of the total amount of 
wastewater generated in the Keys. Non-compliant ATUs clarify the waste stream, but do not 
meet the Florida Statutory Treatment Standards; therefore, they are consequently only approved 
for use until 2010. ATUs require either an injection well or an SDI for disposal of the treated 
wastewater and the FDH requires that users hold an active maintenance contract. 

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

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

Table 3-4: Average Monthly Operation and Maintenance Costs and Total Rates for Non2010 Compliant Monroe County WWTPs Per EDU 

Utility Company 
System Capital 
Cost 
Average Monthly 
O&M 
Wastewater Cost 
Average Total 
Monthly 
Wastewater Rate 1 
Key Haven Utilities $1,215 $48 $56 
Ocean Reef Club $2,400 $46 $64 
K W Resort Utilities $2,700 $35 $55 

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

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

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

Wastewater 
System 
System Capital 
Cost 
Operation and 
Maintenance Cost 
per Month 
Total Cost per 
Month 1 Source 
Cesspit $0 2 $ 0 - $3 $0 - $3 Mitchell Enos Septic Tank 
Corp., 2002 
Sears Aerobic Service, 
2002 
Septic System $0 2 $3 - $4 $3 - $4 Synagro and Accurate 
Enterprises of South 
Florida, Inc., 2001 
Interim ATU approx. $7,800 approx. $17 approx. $73 Sears Aerobic Service, 
2002 
WWTP $1,215 - $2,7003 $35 - $48 $55 - $64 Pers. Comm. with Key 
Haven Utilities, Ocean 
Reef Club, and K W 
Resort Utilities 

1 including system capital costs amortized at 6% interest over 20 years; March 2002 figures 
2 assumed to be already paid for 
3 includes abandonment and lateral costs 

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

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

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

Average Monthly Expenses 
(Household of Two) 
Estimated Cost 
per Month Source 
Rent / Mortgage $1,248 Census, 2000 
Food $356 USDA, 2001 
Electricity $95 City Electric, 2001 
Water $30 FKAA, 2001b 
Telephone $21 Bell South, 2001 
Wind and Flood Insurance $200 Johnsons Insurance Company, 2002 
Incidentals (clothing, medical, etc.) $100 Assumed Cost for Purpose of Analysis 
Total $2,050 

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

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

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

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

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

City and State Average Monthly 
Sewer Bill 2001 
% of county 
monthly 2001 
MHI 
Source 
Sanibel, FL $31.52 1.00% FKAA, 2002 
Marco Island, FL $31.52 0.84% FKAA, 2002 
San Diego, CA $29.81 0.82% http://www.sannet.gov 
Rochester Hills, MI $10.88 0.20% http://www.rochesterhills.org 
Aiken, SC $20.63 0.59% http://www.aiken.net 
Fairbanks, AK $39.98 0.93% http://www.state.ak.us 
Cocoa, FL $17.51 0.52% http://www.cocoafl.org 
Amarillo, TX $6.21 0.24% http://www.ci.amarillo.tx.us 
Kent, WA $19.75 0.42% http://www.southcountyjournal.com 
Silverton, OR $44.03 1.30% http://www.silverton.or.us 
Settler's Bay, AK $10.85 0.23% http://www.state.ak.us 

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

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

3.6.3.1.3 Wastewater Management Costs and Affordability for Keys Businesses 
Commercial wastewater management rates are often slightly higher than domestic rates for the 
same area. This is because utility rate regulators generally assume that businesses are for profit 
and are able to bear more financial burden than residents. When determining wastewater cost 
affordability for commercial businesses, a number of questions arise. How much of an increase 

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in cost can an individual business withstand? Can the business pass on the increased cost of 
wastewater to the consumers of its goods or services? Will the increased cost threaten the 
existence of the business? If so, what will be the impact on the local community if the business 
goes out of service? The answers to these questions depend on what type of business is being 
examined, the labor and economic conditions of the community that the business serves, the 
quantity of effluent produced, and the financial condition of the business in question. 

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

3.6.3.2 Environmental Consequences 
3.6.3.2.1 Alternative 1  No Action Alternative 
No FEMA funds would be used for wastewater management projects in Monroe County. In 
order to become compliant with Florida Statutory Treatment Standards, wastewater system 
owners would have to use alternative funding sources to upgrade or construct community or 
regional WWTPs, and/or install OWNRS. 

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

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

Wastewater 
System 
System Capital 
Cost 
Operation and 
Maintenance Cost 
per Month 1 
Total Cost per 
Month 2 
Source 
WWTP3 
Key West 
Key Colony 
Beach 
$1,600 
$4,550 
$36 
$30 
$46 
$68 
Key West, 2002 
Key Colony 
Beach, 2002 
OWNRS4 $2,5005  $8,2006 $455 - $596 $63 - $118 
Sears Aerobic 
Service, 2002, 
Monroe County, 
2000a 

1 March 2002 figures 
2 Including system capital costs amortized at 6% interest, over 20 years; March 2002 figures 
3 Does not include abandonment and lateral costs. Does include cost of new piping up to property edge and 
connection to WW system4 Includes abandonment costs. Assumes 4 EDUs on system. Does not include purchase cost of the land on 
which the system would reside. 
5 Cost estimated by Sears Aerobic Service, 2002 
6 Cost taken from Monroe County, 2000a for Four Home Shared OWNRS 

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

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

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

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

3.6.3.2.2 Alternative 2  Centralized Wastewater Treatment Plant Alternative 
FEMA would provide funding for the construction of new community and regional WWTPs, and 
treatment upgrades to existing centralized systems at selected locations in the Lower, Middle, 
and Upper Keys. As described in Section 1.4, Monroe County has an obligation to meet more 
stringent treatment standards regardless of proposed FEMA funding. However, the availability of 

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FEMA funds to reduce capital costs of proposed WWTPs would reduce the financial burden to 
the Monroe County government and service recipients. Although discussed below, FEMA funds 
would not be applied towards the long-term monthly O&M costs, which would be the 
responsibility of service recipients. 

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

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

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

Table 3-9: Approximate Centralized WWTP Costs 

System Capital 
Costs 
Abandonment 
and Lateral Costs 
O&M Costs Total Monthly 
Costs 
Initial Costs $3,000 - $4,500 $1,500 - $5,000 n/a n/a 
Monthly Cost at 
6% over 20 yrs 
$22 - $32 $11 - $36 $30 - $60 $63 - $128 

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

Collection Options 1 and 2 

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

Disposal Option 1  Wastewater Injection wells 

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

Disposal Option 2  Wastewater Reuse 

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

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

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

3.6.3.2.3 Alternative 3  On-Site Treatment Upgrades 
FEMA would provide funding assistance to project applicants for the conversion of OWTS to 
clustered OWNRS, thereby reducing the financial burden to service recipients. 

As shown in Table 3-8, if an OWNRS system is shared by four EDUs, the cost would range from 
$2,500 to $8,200 with a monthly cost of $63 to $118, which includes operation and maintenance 
costs and amortized system capital costs. Under Alternative 3, FEMA would help fund the use of 

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these systems in clustered arrangements with the actual number of EDUs per cluster to be 
determined at the project-specific level. In addition, costs to larger wastewater generators, such 
as businesses, would potentially be reduced from those shown in the table, by the purchase of 
larger capacity systems, thus benefiting from economy of scale. 

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

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

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

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

The influx of polluted water from on-site systems to groundwater, canal, and nearshore marine 
waters varies seasonally. In one study, nutrient concentrations of groundwaters were twice as 
high during the winter compared to summer, while nutrient concentrations of surface waters 

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SECTIONTHREE Affected Environment and Environmental Consequences 

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were twice as high during the summer. The increased pollution to inland and nearshore waters 
was attributed to the higher maximum tides and increased hydraulic head during the summer, 
wet season, which increases the rate of exchange between groundwaters and inland and 
nearshore waters (Lapointe et al., 1990). The movement of microbes is expected to follow this 
pattern of increased flow from groundwater to nearshore water during the summer months and 
decreased flow during the winter months. 

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

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

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

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

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3.6.4.2 Environmental Consequences 
3.6.4.2.1 Alternative 1No Action Alternative 
Without FEMA funds for wastewater management, Monroe County project applicants would still 
have to reach Florida Statutory Treatment Standards by 2010. It is likely that water quality 
conditions nearshore and offshore, as this relates to public health, would improve but at a slower 
rate than with FEMA funding. The available data does not conclusively demonstrate instances of 
infection or health problems specifically related to groundwater or offshore contamination 
caused by present sewage treatment practices. However, as described in Section 3.6.4.1, studies 
indicate the presence of viruses and bacteria associated with human sewage; therefore, it may be 
assumed that public health risks exist. 

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

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

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3.6.4.2.2 Alternative 2  Centralized Wastewater Treatment Plant 
FEMA would provide funding for upgrade or construction of new community and regional 
WWTPs at select locations throughout the Keys. With FEMA funding, the project applicant 
would likely be able to improve wastewater conditions at a more efficient rate. 

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

Collection Options 1 and 2 

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

Disposal Option 1  Wastewater Injection wells 

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

Disposal Option 2  Wastewater Reuse 

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

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

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

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

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

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

Year Functional 
Population 
Numerical 
Change Percent Change 
1990 149,348 * * 
1995 154,255 4,907 3.29% 
2000 159,113 4,857 3.15% 
2005 162,041 2,929 1.84% 
2010 164,769 2,727 1.68% 
2015 165,366 597 0.36% 
Source: (Monroe County, 2000b) 

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

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

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

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

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

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FIGURE 3.8  MINORITY STATUS 

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

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

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

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

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

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

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

MFI for family of three 
Yearly 
Income Monthly Net 
Income1. 
Estimated Average 
Monthly Expenses2 
Monthly 
Discretionary 
Income 
Low-Income $39,650 $2,808 $2,050 $758 
Very-Low-Income $24,792 $1,756 $2,050 $0 
1 Net income incorporates 15% Federal tax rate 
2 See Table 3-6 

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

Environmental Consequences 

3.7.1.4 Alternative 1  No Action Alternative 
The project applicants would not receive FEMA funding to help meet Florida Statutory 
Treatment Standards by the year 2010. As described in Section 3.6.3, Local Fees and Taxes, 
implementation of the No Action Alternative has the potential to result in higher wastewater 
management costs than would be expected with the benefit of FEMA funding. 

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

Monroe County came to this same conclusion when analyzing the impact of increased 
wastewater management costs on the community of Little Venice. Given the FKAAs future 
estimated monthly costs for wastewater service, Monroe County concluded that the cost increase 
would cause a major financial hardship on low-income and very-low-income households. In order 
to help mitigate the impacts of this cost increase, the Housing Authority has applied for and 
received Federal grant money through HUDs Community Development Block Grants. To 
determine how best to allocate the money among low-and very-low-income service recipients, 

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the Housing Authority will be conducting a door-to-door survey of household income levels in 
the Little Venice community. As of March 2002, survey results were not complete, and no 
allocation formula had been decided upon (Berard, Pers. Comm., 2002). 

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

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

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

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

3.7.1.5 Alternative 2  Centralized Wastewater Treatment Plant Alternative 
The project applicant would construct new or upgrade existing WWTPs at selected locations in 
the Keys. As described in Section 3.6.3, Local Fees and Taxes, implementation of the 
Centralized Wastewater Treatment Plant Alternative has the potential to result in higher 
wastewater management costs. Potential effects on low-income and minority populations would 
be similar to those described under the No Action Alternative. No disproportionately high and 
adverse effects to minority populations are anticipated. This alternative would similarly affect 
the entire service area population, regardless of demographics, unless minorities are also low-
income, which is discussed above. The physical siting of WWTP and other wastewater facilities 

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is not expected to cause highly disproportionate or adverse effects to minority and/or low-income 
populations in the Keys. Noise and visual resources impacts associated with the siting of 
WWTPs are expected to be negligible as discussed further in Section 3.11. Unmitigated 
increased wastewater management costs to low-income service recipients as a result of this 
alternative would cause disproportionately high adverse effects. 

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

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

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

The qualifications for the assistance guidelines are: 

 Property Owner(s) must verify ownership of the residential property. 
 Property Owner(s) must verify that the property has qualified (or application made) for 
eligibility for Floridas Homestead Exemption for declaration of primary residence. 
 Property Owner(s) must verify qualified family income is within the established HUD MFI 
as either very-low-income (0 to 50% of MFI) or low-income (50 to 80% of MFI). 
Assistance Guidelines 

Income Levels Amount of Assistance 
Very-low-income Qualified Family 90% of System Capital Costs 
Very-low-income Qualified Family 90% of Existing System Abandonment costs 
and private property lateral installation up to an 
allowance amount of $3,000 
Low-income Qualified Family 70% of System Capital Costs 
Low-income Qualified Family 70% of Existing System Abandonment costs 
and private property lateral installation up to an 
allowance amount of $3,000 

It should be noted that the above guidance is a minimum level of assistance that FEMA 
applicants would be required to achieve to mitigate adverse effects on low-income households. 
The applicants, at their own discretion, may further reduce these costs. Additionally, where 

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extreme conditions exist related to abandonment costs and/or private property lateral installation 
costs create extraordinary hardship for qualifying low-income households, the FEMA applicants 
shall establish a contingency fund to further reduce costs. 

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

3.7.1.6 Alternative 3  On-Site Treatment Upgrades 
The project applicants would upgrade the selected service areas existing on-site wastewater 
treatment systems by installing clustered OWNRS serving multiple EDUs. This alternative also 
would require compliance with EO 12898 because of FEMA funding. As with Alternative 2, no 
disproportionately high adverse effects to minority populations are anticipated since service 
recipients would be similarly affected, regardless of demographics. However, if minority 
populations are also low-income, they could incur disproportionately high adverse effects if costs 
are unmitigated. The physical siting of clustered OWNRS is also not expected to cause highly 
disproportionate or adverse effects to minority and/or low-income populations in the Keys. Noise 
and visual resources impacts associated with the siting of clustered OWNRS are expected to be 
negligible as discussed further in Section 3.11. 

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

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SECTIONTHREE Affected Environment and Environmental Consequences 

Hazardous Materials and Wastes 

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

Hazardous materials and wastes are regulated in Florida via a combination of federally mandated 
laws and region-specific laws developed by FDEP Division of Waste Management, Bureau of 
Solid and Hazardous Waste. The hazardous waste statutes are part of the Florida Public Health 
section, Chapter 403, Resource Recovery and Management. Portions of Title 40 CFR Parts 260271 
are incorporated into F.A.C. Rule 62-730. 

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

New State regulations pertaining to all forms of wastewater solids disposal, except landfilling, 
took effect in 1998. These regulations mirror the 40 CFR Part 503 Sewage Sludge Regulation 
published in 1995 by the EPA. Both sets of regulations address pathogen reduction, vector 
attraction reduction, and heavy metal limits. The regulations specify two alternative levels of 
pathogen reduction: Class A or Class B. Class A biosolids (i.e., WWTP residual solids that have 
been stabilized and made into a product that can be beneficially recycled) can be applied via bulk 
application to public access areas, including private lawns and home gardens; Class B biosolids 
are prohibited from such application. Both Class A and Class B biosolids can be applied to 
agricultural land, but more stringent site restrictions are imposed when Class B biosolids are 
applied. Phase I Environmental Site Assessments would be completed at each project site to 
characterize the recognized environmental conditions before construction activities ensue. For 
WWTP project sites, a Phase I Environmental Site Assessment would be conducted in 
accordance with American Society of Testing and Materials (ASTM) standard E 1527-97. The 
Phase I Environmental Site Assessment is to visually identify and record any obvious existing, 
potential, or suspect conditions resulting from the use, handling, and disposal of hazardous 
substances at the site or adjacent site(s), which may pose an environmental liability to, or restrict 
the use of, the subject property. A Phase I Environmental Site Assessment would be conducted 
for each site as part of the SER, and the presence and risk of hazardous materials would be 
evaluated based on specific site conditions and proposed designs. 

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SECTIONTHREE Affected Environment and Environmental Consequences 

Hazardous Materials and Wastes 

3.8.2 Environmental Consequences 
3.8.2.1 Alternative 1  No Action Alternative 
No hazardous waste impacts are expected because hazardous waste is not allowed in the sewage 
waste stream. However, there may be environmental conditions (e.g., leaking underground 
storage tanks) at the sites selected for WWTP construction or OWNRS upgrades that could result 
in adverse effects if not remediated prior to ground-disturbing construction activities. The 
potential for this impact is unknown. Wastewater sludge waste from the Keys would continue to 
be hauled to a transfer facility and taken to a wastewater treatment facility in Miami-Dade 
County for treatment. 

3.8.2.2 Alternative 2  Centralized Wastewater Treatment Plant Alternative 
FEMA would provide funding to aid in the construction of new community and regional 
WWTPs throughout the Keys. With the help FEMA funding, the project applicant would likely 
be able to improve wastewater conditions at a more efficient rate. 

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

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

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

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

One chemical compound associated with wastewater effluent that has been of recent concern is 
nonylphenol. 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 from nonlyphenol ethoxylates can 
occur through wastewater treatment and in natural environments (Maguire, 1999). The EPA is currently 

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SECTIONTHREE Affected Environment and Environmental Consequences 

Hazardous Materials and Wastes 

in the process of developing aquatic life criteria for nonylphenol (EPA, 2002). 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. 

Collection Options 1 and 2 

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

Disposal Option 1 - Shallow Injection Wells 

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

Disposal Option 2 - Wastewater Reuse 

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

3.8.2.3 Alternative 3  On-Site Treatment Upgrades 
OWTS such as cesspits and septic tanks with drainfields would be converted to clustered 
OWNRS to improve wastewater management. This system proposes biological nitrogen removal 
coupled with a physical/chemical phosphorus removal system and either a shallow injection well 
or SDI. The potential effects of inadvertent hazardous materials disposal are discussed under the 
environmental consequences of Alternative 2 in Section 3.8.2.2. 

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

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SECTIONTHREE Affected Environment and Environmental Consequences 

Infrastructure 

3.9 INFRASTRUCTURE 
3.9.1 Traffic and Circulation 
3.9.1.1 Affected Environment 
The Keys consist of many islands connected by 42 bridges along over 100 miles of US Highway 

1. This is the main road in the Keys and functions as an arterial, collector, and Main Street. US 1 
is the most important road in Monroe County but there are several smaller roads serving the local 
communities. US 1 is about 112.5 miles long in Monroe County, with about 19 miles of bridges, 
extending from Dade County border to Fleming Street in Key West. About 108 miles and 41 
bridges of US 1 run through areas that are unincorporated. US 1 and South Roosevelt Boulevard 
are the only State-maintained roads in Monroe County. The county maintains about 450 miles of 
secondary roads, including 1.6 miles of bridges that link US 1 to the residential areas. The 
Florida Department of Transportation (FDOT) classifies all public roads based on the type of 
service the road provides, found in Chapter 335.04 of the Florida Statutes. The roads are 
classified into three categories: arterial, collector, and local (Monroe County, 1997). 
Traffic capacity limitations are found along four segments of US 1. The conditions of the 
roadway are based on levels of service (LOS). This is defined by the 1985 Highway Capacity 
Manual as a qualitative measure describing operational conditions within a traffic stream, and 
their perception of motorists. Roadway LOS is ranked from A (the best) to F (the worst), with C 
being the average. Plantation, Upper Matecumbe Key, Lower Matecumbe Key, and Big Pine 
Key did not meet LOS C and are considered to be critical growth constraints. The improvements 
needed vary and include: widening roads, restriping to provide more left lanes, traffic signal re-
timing, fencing to control Key deer crossing, and highway overpasses and underpasses to 
facilitate safe Key deer movement (Monroe County, 1997). A reconstruction of an 18-mile 
stretch of US 1 starting in Miami-Dade to Monroe County has been planned (Molins, Pers. 
Comm., 2001). Also along US 1, the Jewfish Creek Drawbridge will be replaced with a high-
level fixed-span bridge and the installation of culverts to improve the tidal flow to the 
surrounding wetlands (Monroe County, 2001a). 

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

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

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SECTIONTHREE Affected Environment and Environmental Consequences 

Infrastructure 

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

Environmental Consequences 

3.9.1.1.1 Alternative 1  No Action Alternative 
Construction traffic would temporarily increase during the implementation of wastewater 
management projects; however, any impacts would be minimal since improvements would likely 
take place on a small scale and over a long period of time. Although FEMA does not have 
regulatory responsibility over non-FEMA funded projects, it would be expected that funding 
and/or permitting agencies would require the development and implementation of traffic control 
plans. These plans would include specific information about temporary traffic control, alternate 
routes, staging area locations, and optimal working times to minimize traffic disruption. With the 
transition to new wastewater systems that meet Florida Statutory Treatment Standards, the water 
quality of canal waters would be expected to improve thereby benefiting the owners and users of 
canal boating facilities. Other impacts from Alternative 1 would be similar to those explained 
below in Alternatives 2 and 3. 

3.9.1.1.2 Alternative 2  Centralized Wastewater Treatment Plant 
The new wastewater treatment facilities would temporarily increase the traffic to and from each 
facility due to construction depending on capacity and operations. Due to temporary and/or 
partial road closures, traffic would increase near the proposed facility and would be expected to 
last up to 18 months, depending on the scope of work, from the start of construction. It would be 
expected that a traffic control plan would probably be developed and implemented as described 
in Alternative 1. Any traffic and circulation effects are expected to be short-term in nature and 
minimal. Additional information related to traffic and circulation would be in the project-specific 
SER. 

Collection Options 1 and 2 

The installation of pumping systems would have temporary, localized adverse impacts on traffic 
in the Keys. Trenches for piping would be up to 5 feet wide along road right-of-ways, detours of 
one or two blocks or temporary road closings are expected. FDOT permitting is necessary where 
road cuts are to be made, but authorization can be obtained locally. During construction 
activities, vehicular traffic would increase in some areas with the ingress and egress of 
construction equipment. 

The WWTP facility would require piping over navigable waterways (such as along the underside 
of existing bridges) to connect to residences. Any impacts associated with the construction of the 
piping, however, would likely be minimal and temporary for waterway traffic because boats 
would still be able to pass under bridges during construction, where applicable. 

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SECTIONTHREE Affected Environment and Environmental Consequences 

Infrastructure 

Disposal Option 1 -- Shallow Injection Wells 

The installation of new shallow wastewater injection wells is not expected to have notable 
impacts on transportation network in the Keys, as the wells would likely be built next to the 
WWTP to minimize piping costs. Traffic may temporarily increase in some areas due to 
temporary partial road closures requiring two lanes of traffic to use one lane of a road during 
well construction, but the impact should be minimal. 

Disposal Option 2  Wastewater Reuse 

Possible adverse effects of Disposal Option 2 on traffic and circulation would be the 
aforementioned delays due to the laying of new pipe as discussed above under collection options. 
The specific details of the impacts of installing reused-water pipes for transport to points of use 
would be discussed in the project specific SER. 

3.9.1.1.3 Alternative 3  On-Site Treatment Upgrades 
Construction traffic would temporarily increase during the upgrade from OWTS to OWNRS; 
however, impacts would be minimal since improvements would likely be on a smaller scale. 
Though local roads would primarily be impacted by on-site treatment upgrades, it is expected 
that the development and implementation of a traffic control plan would be necessary as 
described in Alternative 1. 

3.9.2 Utilities and Services 
3.9.2.1 Affected Environment 
The Monroe County Division of Public Works provides service in solid waste, public facilities 
maintenance, engineering, fleet management, and county road and bridge maintenance. Monroe 
County Public Works does not provide utility services but works closely with utility companies 
when planning, designing, constructing, or inspecting projects (Monroe County, 1997). 

The Florida Keys Electric Cooperative (FKEC) purchases electricity from Florida Power and 
Light and supplies it to residents of Monroe County east and north of the Seven-Mile Bridge 
(Monroe County, 1997). During the year 2000, FKEC had 30,034 accounts at a density of 38.15 
customers per square mile (FKEC, 2000). This translates to about 788 miles of linear power 
lines. There are six substations and 126 employees (FKEC, 2000). The average monthly electric 
bill is $80.58, and equates to about 1,000 kilowatt-hours (FKEC, 2000). Key West City Electric 
Services (CES) generates electricity and supplies it to residents west and south of the Seven-Mile 
Bridge (Monroe County, 1997). The major gas companies in the Keys include Suburban, 
Amerigas, and Homestead Gas. These companies all provide primarily propane gas to businesses 
and homes (Monroe County, 1997). Propane gas systems have pipes underground that run from a 
tank on the property up to the business or home. 

In 1937, the Florida State Legislature created the FKAA. The FKAA is the provider of potable 
water for all Keys residents, and the average monthly water cost is $20 per household. Potable 
water is transported to the Keys from the mainland through a 130-mile transmission pipeline, 
with an additional 649 miles of distribution pipelines that deliver water to the customer's 
property (FKAA, 2001). The potable water supply resources used by Monroe County are 
obtained from wells tapping the Biscayne aquifer in Miami-Dade County, entirely outside of 

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SECTIONTHREE Affected Environment and Environmental Consequences 

Infrastructure 

Monroe Countys jurisdiction. No new wells have been permitted in the Keys since 1986, which 
would limit utilization of underground brackish/saline resources in the Keys as a potential 
potable water resource. The FKAA has primarily focused on potable water until environmental 
concerns started to arise regarding wastewater issues (FKAA, 2001). The 2010 Comprehensive 
Plan required that Monroe County complete a Sanitary Wastewater Master Plan for the entire 
unincorporated area of the county. The FKAA has an agreement with Monroe County to identify 
priority areas and establish treatment plant sites (FKAA, 2001). The FKAA then has legal 
jurisdiction to purchase, construct, manage, and operate sewage collection, treatment, and 
disposal services to any entity or area of the county (Monroe County, 1997). The cities of Key 
West and Key Colony Beach also operate their own regional wastewater systems independent of 
the FKAA. Islamorada plans to implement its own wastewater infrastructure. 

3.9.2.2 Environmental Consequences 
3.9.2.2.1 Alternative 1  No Action Alternative 
Long-term adverse effects to utilities and services are not expected. With the coordination of 
wastewater management activities with public utilities, there should be minimal effects on 
stormwater, gas, or electric service. The establishment of WWTPs would increase reliability of 
the wastewater service area on a regional basis as these systems would be centrally controlled 
and maintained by an independent utility. OWNRS are generally more difficult to monitor than 
WWTPs because they are decentralized, which may place an operational burden on responsible 
monitoring and enforcement agencies. 

3.9.2.2.2 Alternative 2  Centralized Wastewater Treatment Plant 
There would likely be temporary adverse effects on utilities and services during the construction 
phase. The SER would evaluate effects on individual utilities, although no long-term impacts 
would occur if proper utility notification and construction practices are observed. The project 
applicant would be required to contact the diggers/excavation utility hotline at the Sunshine State 
One Call Center at least two business days prior to construction. Installation of WWTP piping 
could disturb existing drinking water piping, among other utilities. In this case, the pipes for 
either the WWTP or drinking water would be rerouted, depending on which is more feasible 
(Teague, Pers. Comm., 2001). This action would mitigate effects, though there may be 
temporary interruptions in water supply services. 

Collection Option 1  Vacuum Pumping 

Aside from the impacts discussed above in Alternative 2, the selection of this collection option is 
not expected to result in long-term adverse effects on public utilities and services. Vacuum 
pumping systems do not require electric power at each residence; however, electric power at a 
central vacuum station is necessary. Vacuum valves have a shorter life than pumps, have a 
higher rate of energy consumption, have the potential to emit unpleasant odors at the vacuum 
facility, and require more frequent repair (Head et al., 2001). The project applicant would be 
required to develop backup power plans in the event that main power is lost to the vacuum 
pumping station. 

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SECTIONTHREE Affected Environment and Environmental Consequences 

Infrastructure 

Collection Option 2  Low-Pressure Grinder Pump Sewer System 

Aside from the impacts discussed above in Alternative 2, the selection of this collection option is 
not expected to result in long-term adverse effects on public utilities and services. The low-
pressure grinder pump sewer system requires less power than the vacuum system; however, 
power outages shut down the system. Periodic pumping of tanks at residences and businesses 
would be required, as would effluent pumps and grinder pumps needed at each residence (Head 
et al., 2001). 

Disposal Options 1 and 2 

It is not expected that impacts related to disposal options would occur beyond those discussed in 
Section 3.9.2.2.2. 

3.9.2.2.3 Alternative 3  On-Site Treatment Upgrades 
Aside from the impacts discussed above in the No Action Alternative, the selection of this 
alternative is not expected to result in long-term adverse effects on Public Utilities and Services. 
An OWNRS demonstration project in Big Pine Key indicated that the systems provided BAT 
treatment levels as required by Florida Statutory Treatment Standards. As described in the No 
Action Alternative, the use of clustered OWNRS is more difficult to monitor because they are 
decentralized. To mitigate this effect, the project applicant proposing the clustered OWNRS 
would be required to establish a monitoring, compliance, and enforcement plan to help ensure 
that clustered OWNRS meet water quality and service reliability standards on a consistent basis. 

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SECTIONTHREE Affected Environment and Environmental Consequences 

Land Use and Planning 

3.10 LAND USE AND PLANNING 
3.10.1 Affected Environment 
About 90% of Monroe County is on mainland Florida. This portion of the county is located 
within either the Everglades National Park or Big Cypress National Preserve. While mainland 
Monroe County is almost uninhabited and consists almost entirely of federally owned and 
managed parklands, the majority of the countys development is located in the Keys (Monroe 
County, 1997). 

Residential land uses, including single-family detached homes, mobile homes, multi-family 
apartments, and mixed-use residential areas are found on almost every one of the 38 Keys along 
US Highway 1. Residential uses account for 10,790 acres, or 17.6% of the total area of the Keys. 
Single-family detached homes are the predominant residential type in the Keys, and account for 
about 8,379, or 78% of the residential land use category. Mobile homes occupy the second 
largest residential land area, and include 1,063 acres. Multi-family residential development, 
including apartments, condominiums and cooperatives, account for 638 acres, or 6% of the 
developed residential land area. Mixed residential areas include about 711 acres, representing 
about 7% of the residential land use category (Monroe County, 1997). 

Commercial land uses can broadly be defined as those uses associated with the buying and 
selling of goods and/or services. Commercial uses account for 2,270 acres, or 3.7% of the land 
area for the Keys portion of unincorporated Monroe County. Commercial land uses include 
general commercial, commercial fishing, and tourist commercial land uses. General commercial 
uses include retail and office uses oriented toward the resident population and represent the 
majority of commercial uses. Most of the commercial land uses are found along US 1 in the 
more populated areas of Key Largo, Marathon, and Upper Matecombe. Commercial fishing uses 
include land uses such as commercial marinas and landing areas, processing plants, boat repair 
and maintenance, and equipment and trap storage areas. Commercial fishing is heavily 
concentrated in the Lower Keys. Tourist commercial uses represent about 45% of the total 
commercial land use category, and are more heavily concentrated in the Upper and Middle Keys 
than the Lower Keys (Monroe County, 1997). 

Conservation lands include lands that have been acquired by public agencies and private 
organizations for conservation purposes. This is the single largest land use category after vacant 
lands, and accounts for about 20,696 acres or 34% of the total land area of the Keys. These 
conservation lands are primarily located in the Upper and Lower Keys and indicate that the 
Federal and State governments have been actively acquiring environmentally sensitive lands and 
habitats of rare, threatened and endangered species. This category includes such conservation 
lands as Crocodile Lake National Wildlife Refuge, the National Key Deer Refuge, and the John 
Pennekamp Coral Reef State Park (Monroe County, 1997). 

Vacant lands are the largest land classification in the Keys, and include an area of about 21,127 
acres, or 34% of the total area of the unincorporated portion of the Keys. Vacant lands are 
heavily concentrated in the Lower Keys, as about 44% of the Lower Keys are classified as 
vacant (Monroe County, 1997). 

Existing land uses are summarized in Table 3-13. 

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SECTIONTHREE Affected Environment and Environmental Consequences 

Land Use and Planning 

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

Land Use 
Classification 
Acreage 
(approx.) 
Percentage of 
Total Land Area Description 
Vacant Land 21,127 34.0 Concentration in Lower Keys, about 44% 
Conservation Land 20,696 34.0 Heavy concentration in Upper and Lower Keys 
Residential 10,790 17.6 Single-family detached homes account for 78% 
of this category 
Military Land 3,300 5.0 Located entirely in Lower Keys 
Commercial 2,270 3.7 This category includes general commercial, 
commercial fishing, and tourist commercial 
Recreation Land 1,791 3.0 Both public and private 
Public Facilities 539 1.0 Land owned by public utilities and service 
providers 
Industrial Land 515 <1.0 Concentration in Lower Keys; about 73% 
Institutional Land 116 <1.0 Includes hospitals, churches, cemeteries and 
service clubs 
Public Building/ 
Grounds 61 <1.0 Includes all government offices; local, State and 
Federal 
Source: Monroe County Comprehensive Plan, Technical Document, 1997. 

Military lands account for about 5% of the total land area. The Keys have long been recognized 
as strategically significant by the U.S. military forces, and military operations still play an 
important role in the economy of the Keys (Monroe County, 1997). To a much lesser extent, land 
uses in the Keys include industrial, agricultural/ maricultural, institutional, educational, public 
buildings/grounds, public facilities, historic, recreation, conservation, and vacant lands (Monroe 
County, 1997). 

According to the Monroe County Comprehensive Plan, Monroe County has about 37,128 lots 
zoned Improved Subdivision (IS), Urban Residential Mobile Home (URM), and Commercial 
Fishing Village (CFV). 

3.10.1.1 Future Land Use and Planning 
According to the Monroe County Comprehensive Plan, existing and future land use development 
in Monroe County is guided by three central principles: carrying capacity limitations, natural 
resource protection, and enhancement of community character. According to recent revisions of 
the Monroe County Comprehensive Plan, one goal of the countys comprehensive planning is to 
shift residential growth towards lower density single-family development and away from multifamily 
condominium and hotel/motel resort development, and toward the construction of new 
residential growth as infill development. Generally, this concept encourages development within 
established subdivisions and discourages growth within undeveloped subdivisions, acreage 
tracts, and areas that have sensitive natural resources or natural hazards (Monroe County, 1997). 

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SECTIONTHREE Affected Environment and Environmental Consequences 

Land Use and Planning 

Due to Monroe Countys development constraints, the Comprehensive Plan provides for a level 
of growth based on the countys carrying capacity, rather than matching growth to projected 
population based on estimated future demand. According to the Monroe County Comprehensive 
Plan, carrying capacity refers to the capability of a natural and built environment to 
accommodate additional population growth within the parameters of an acceptable environment 
(Monroe County, 1997). 

In 1974, the State designated the Keys as an Area of Critical State Concern, a legal distinction 
authorizing extraordinary development controls and growth limits. However, unregulated growth 
continued until the Monroe County BOCC adopted the ROGO in 1992. ROGO was developed as 
a response to the inability of the road system to accommodate a large-scale hurricane evacuation 
in a timely manner. This ROGO system is used to distribute the number of permits for new 
dwelling units both geographically and over time, based on hurricane evacuation capacity of the 
road system. Each ROGO planning sub-area of unincorporated Monroe County and several 
incorporated areas receive a set number of allocations for new residential permits, which can be 
issued during that particular ROGO year. The total number of ROGO allocations that can be 
issued in a ROGO year is a maximum of 255 for unincorporated Monroe County, the Village of 
Islamorada, and City of Marathon, unless reduced by the Florida Administration Commission 
under its rule making authority. The number of allocations available to a particular area is based 
upon the supply of vacant developable, platted subdivision lots that could potentially be 
developed located in that area prior to the start of the ROGO system. The Director of Planning 
has 30 days to sort, evaluate, and rank applications by Upper, Middle, or Lower Keys sub-areas. 
Applications are placed in a sub-area according to their building locations (McGarry, Pers. 
Comm., 2002). 

Under this permit allocation system, potential residential development proposals compete based 
on explicit performance criteria developed by the County. Criteria are assigned points (positive 
or negative) based on whether they support or detract from Monroe Countys future land use 
concept and its three central development principles of carrying capacity, resource protection, 
and maintaining or enhancing community character (Monroe County, 1997). These categories 
that have scored criteria include habitat protection, affordable housing, coastal high hazards, 
water conservation, and energy conservation among others. Through the point system, 
development located and designed to provide the greatest public benefit have the strongest 
chance of receiving a ROGO allocation award that authorizes the issuance of a building permit. 
Wastewater management improvements are not included among the scored criteria. 

In conjunction with the ROGO permitting system, Monroe County also implements a nutrient 
reduction credit program required by Policy 101.2.13 of the Monroe County Year 2010 
Comprehensive Plan. The nutrient reduction credit program requires that each ROGO allocation 
award must be matched with a nutrient reduction credit. Nutrient reduction credits are generated 
through the elimination of cesspools/substandard wastewater treatment systems and their 
upgrading to an approved wastewater treatment system. Building permit applicants are eligible to 
receive or purchase nutrient reduction credits once their approved building permit application has 
been entered in the ROGO system (Stankiewicz, Pers. Comm., 2001). The Monroe County 
Health Department administers the nutrient reduction program and is responsible for the tracking 
of these credits through a unique number of identifying systems. A nutrient reduction credit is 
issued when a cesspit or non-compliant wastewater treatment system is replaced with a 
wastewater treatment system compliant with Florida Statutory Treatment Standards in 

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accordance with Table 3.1-1 of Policy 101.2.13 in the Monroe County Year 2010 
Comprehensive Plan. A ROGO allocation award will not be made until a nutrient reduction 
credit is available in that same ROGO planning sub-area (e.g., Upper, Middle, or Lower Keys). 
As non-compliant systems are replaced and the new systems receive final inspections, nutrient 
reduction credits become available. Except for nutrient reduction credits that are purchased, 
credits are issued in the order that the ROGO applications were ranked. Nutrient reduction 
credits are divided between market rate residential units and affordable housing residential units 
in an 80:20 proportion. Thus, the first four market rate applications receive nutrient reduction 
credits and then the first affordable housing application and so forth. 

A ROGO applicant has the option of purchasing his/her nutrient reduction credit rather than 
waiting for it to become available independently. The nutrient reduction credit will be reserved 
with the Monroe County Health Department until the quarter in which the ROGO applicant 
receives a ROGO allocation ranking sufficiently high enough to otherwise receive a building 
permit. An applicant must be in the ROGO system before a nutrient reduction credit can be 
reserved. 

Development is also constrained to maintain a balance of land uses. The Comprehensive Plans 
Policy 101.3.1 states: 

Monroe County shall maintain a balance between residential and non-residential 

growth by limiting gross square footage of non-residential development over the 

15 year planning horizon in order to maintain a ratio of about 239 square feet of 

non-residential development for each new residential unit permitted through the 

Permit Allocation System 

There has been a de facto moratorium on non-residential growth since January 4, 1996 because 
the amount of non-residential floor area exceeded the 239-foot ratio established by the Monroe 
County Comprehensive Plan. Residential development has continued and by December 2000 had 
equaled the non-residential permits. A draft Non-residential Rate of Growth Ordinance 
adopted by Monroe County on July 18, 2001 proposes to maintain a ratio of about 239 square 
feet of non-residential floor area for each new residential permit issued through ROGO. 

The Monroe County Planning and Environmental Resources Department is required to prepare 
an annual assessment of public facilities capacity mandated by Section 9.5-292 of the Monroe 
County Land Development Regulations. Furthermore, the State of Florida requires all local 
jurisdictions to adopt regulations to ensure the public facilities and services which are needed to 
support development are available concurrent with the impacts of development in addition to 
maintaining the adopted Level of Service (Chapter 9J-5 of the F.A.C.). 

According to the Monroe County Comprehensive Plan, population growth over the next 10 years 
in Monroe County (unincorporated and incorporated) will correspond to the number of building 
permits that will be issued for new residential units. This is because development is based on 
maintaining hurricane evacuation clearance times at or below 24 hours as required by the 
Monroe County Comprehensive Plan (McGarry, Pers. Comm., 2002). The use of the ROGO 
permit allocation system as the guiding policy that limits population growth in the Keys suggests 
that population growth is not directly based on accommodating market demand for development, 
matching development to available or planned public facilities and services, responding to 

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competing factors outside of the community such as growth in adjoining Miami-Dade County, or 
unilaterally maintaining past rates of growth. 

Separate from the Monroe Countys Comprehensive Plan, the Village of Islamorada has its own 
Comprehensive Plan which became effective on December 6, 2001. As part of the plan, the 
Village adopted a Building Permit Allocation System (BPAS), which is similar to and replaces 
ROGO within Islamorada. The BPAS regulates both residential and non-residential growth 
through the year 2020 and the residential allocations include the same nutrient reduction 
requirements as Monroe County. During the period from 2001-2020 the BPAS allows a total of 
302 residential unit, an average of 15 per year. These allocations are comprised of 171 market 
rate and 131 affordable. Non-residential floor area is limited to 28,680 square feet over the same 
period or an average of approximately 1400 square feet per year (Tindle, 2002). 

3.10.1.2 Land Use, Planning, and Wastewater Management 
Wastewater flow and customer projections were developed from the FKAA water use records for 
each of the 27 study areas outlined in the MCSWMP for the baseline year 1998 and for the 10year 
and 20-year planning horizons, 2008 and 2018, respectively. This included residential (i.e., 
residential single unit, senior citizens, and residential multi-units) and non-residential 
components (i.e., remaining sources such as restaurants, laundry facilities, etc.). Total residential 
flow is estimated to increase from 31,847 EDUs (4.5986 Mgal) to 34,613 EDUs (5.0183 Mgal) 
between 1998 and 2008, or an approximately 8.7% increase. Total non-residential wastewater 
flow is estimated to increase from 17,004 EDUs (2.5475 Mgal) to 17,594 EDUs (2.6341 Mgal) 
between the same period, or an approximately 3.5% increase. For the 20-year planning horizon, 
total residential and non-residential flows are estimated to increase approximately 17% and 7% 
between 1998 and 2018, respectively. Increases in residential EDUs for the 10- and 20-year 
planning periods were determined from historical ROGO allocations, estimated future ROGO 
allocations, and the number of future units in each study area that have development potential 
and were vested or exempt from ROGO. Future residential flow projects for the study areas were 
calculated by multiplying the increase in EDUs by the average flow per EDU within each study 
area. Increases in non-residential flow within the study areas were estimated by assuming the 
commercial development would resume in 1999 under Commercial ROGO allocations 
described in Monroe County Year 2010 Comprehensive Plan and that this commercial growth 
would be within the 239 square foot ratio distributed in proportion to residential growth. 

The Keys have very little industrial and agricultural activity; however, permits are required for 
non-residential development such as industrial, commercial, non-profit, and public buildings. 
The predominant form of non-residential development is commercial. Commercial entities 
cannot be placed on vacant land unless it is permitted (referred to as commercial moratorium), 
however wastewater treatment facilities can be located in any land use district other than 
residential land use districts (Garrett, Pers. Comm., 2001). In addition, once a plant is placed in a 
certain land use district, zoning does not change. The Monroe County BOCC is considering 
allowing wastewater treatment facilities to be placed in residential land use districts. The BOCC 
is currently reviewing changes to the land development regulation in the Monroe County Code, 
and it is certain if and when they will make their decision (Reisinger, Pers. Comm., 2001). 

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3.10.1.3 Conservation and Recreation Lands 
The Conservation and Recreation Lands (CARL) acquisition program, or Forever Florida 
program, seeks to protect and conserve environmentally, archaeologically, historically, or 
naturally significant lands in Florida. Properties acquired by CARL are purchased by the State 
under FDEP, and management of the land is performed by other State agencies having an interest 
in the operation of the land. The program emphasizes the acquisition of lands from willing 
landowners that contribute to the program voluntarily. Although anyone may propose a certain 
project for acquisition, The Acquisition and Restoration Council perform the ultimate selection 
and ranking of projects by significance each year. The entire acquisition program is supervised 
by the Governor and Cabinet, and they retain the authority to approve the recommended 
acquisition list, approve specific purchases, and declare eminent domain for the purposes of 
preserving lands that are significantly rare, sensitive, or threatened. Within Monroe County, 
about 34% of the land area is designated with a land use classification termed Conservation 
Land, which includes CARL lands. These areas are concentrated in the Upper and Lower Keys 
and comprise about 20,696 acres in Monroe County. 

3.10.1.4 Coastal Zone 
The Coastal Zone Management Act (CZMA) was passed by Congress to encourage coastal states 
to develop programs that would comprehensively manage activities having coastal impacts. 
States with an approved coastal zone management program have the authority to review Federal 
actions for program consistency. Floridas DCA, which serves as the lead coastal agency, 
implements the regulations of the CZMA. 

In Monroe County, coastal zone protection is provided under the Monroe County Code of 
Ordinances (Ordinance Number 2-1980) and incorporated into the Monroe County 
Comprehensive Plan. 

3.10.1.5 Barrier Island Resources 
Areas of Monroe County are designated as Coastal Barrier Resource System (CBRS) units or 
undeveloped coastal barriers along the Keys. These coastal barriers provide protection for 
diverse aquatic habitats and serve as a defense against the impacts of severe coastal storms and 
erosion. The Coastal Barrier Resources Act (CBRA) of 1982 prohibits Federal funding for any 
project that could result in an increase in development in the CBRS units. Monroe County 
policies regarding protection of the CBRS units are included under Objective 102.8 of the Year 
2010 Comprehensive Plan Policy Document. This objective specifies that Monroe County would 
discourage the extension of facilities and services such as electricity and telephone service to 
CBRS units. Additionally, the objective discourages developments, and construction of access 
via bridges, causeways, paved roads, or commercial marinas to or on CBRS units. In early 2002, 
Monroe County adopted an Overlay Zoning District for 14 of the CBRS units, which implements 
the policies and objectives of the Comprehensive Plan. A map of CBRS units is included as 
Figure 3-9. 

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FIGURE 3-9 CBRS MAP 

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3.10.2 Environmental Consequences 
3.10.2.1 Alternative 1  No Action Alternative 
Given the similarity of impacts across all land uses, the following discussions pertain to all land 
uses designated above. Effects on a particular land use are specified where appropriate. 

 The construction of new WWTPs and/or installation OWNRS is not expected to result in 
major changes to existing land uses. New wastewater treatment systems would likely be 
located on vacant land, and occupy between 1 and 5 acres depending on the size of the 
system. According to the Monroe County Planning Department (Tummini, Pers. Comm., 
2001), wastewater treatment systems may be placed on land zoned in the following 
categories: 
 Urban Residential 
 Urban Residential Mobile 
 Suburban Community District 
 Urban Residential Mobile Home Limited 
 Suburban Residential District 
 Sparsely Settled Urban Residential District 
 Native Area District 
 Improved Subdivision 
 Improved Subdivision Vacation Rental District 
 Mixed Use District 
 Industrial District 
 Airport District 
 Suburban Commercial 
The installation of new WWTPs, upgrading of WWTPs, and conversion of OWTS to OWNRS is 
not expected to cause changes in growth. The capacity of wastewater treatment alternatives 
proposed in the MCSWMP are based on accommodating a 17% increase in residential 
wastewater use and 7% increase in non-residential use over a 20-year planning period (1998 to 
2018). As is typical for capital-intensive projects that have project lives in excess of 10 years, the 
capacity of proposed wastewater management projects take into account future demand for 
wastewater disposal. As described in Section 3.10 above, these growth projections are based on 
the present ROGO permitting system that limits growth in Monroe County. This analysis 
assumes the ROGO system will continue as it has historically. The project-specific SER would 
consider change to ROGO should they occur. 

Under the No Action Alternative, wastewater management improvements would be done at a 
slower rate without FEMA funding. As described in Section 3.10.1.1, the release of ROGO 
permits is based on the availability of nutrient reduction credits. Credits become available when 
inadequate on-site wastewater systems are replaced with systems that meet Florida Statutory 

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Treatment Standards. Accordingly, if wastewater management improvements occur at a slower 
rate, the availability of nutrient reduction credits is also slowed; therefore, growth rates and 
patterns may be altered from those initially set forth by the Monroe County planning department. 
It should be noted that regardless of the availability of nutrient reduction credits, the number of 
new buildings allowed in unincorporated Monroe County is set forth by the ROGO system that is 
established by the Monroe County BOCC. 

The impact of wastewater management projects on CARL lands and conservation lands, areas 
managed under the CZMA, and CBRS units in the Keys would depend on the siting of individual 
projects in relation to these lands. Although projects that do not receive Federal funding are not 
obligated to comply with CZMA or CBRA, they may result in cumulative effects on these 
special status lands in relation to other Federal actions considered in the PEA. Local land 
development regulations promulgated by the Monroe County Comprehensive Plan also set forth 
requirements related to CARL, CBRS, and conservation lands that would be adhered to. 

In terms of the positive impacts on ground and nearshore waters identified in Section 3.2 of this 
PEA, the proposed WWTP should result in generally positive effects on the natural resource 
value of CARL and conservation lands, CBRS units, and coastal areas that derive their natural 
resource value from good water quality; although these benefits would likely occur later in time 
with FEMA funding assistance. 

3.10.2.2 Alternative 2  Centralized Wastewater Treatment Plant Alternative 
The construction or upgrading of new WWTPs is not expected to result in major changes to 
existing land uses. New wastewater treatment systems would likely be located on vacant land, 
and occupy between 1 and 5 acres depending on the size of the system. According to the Monroe 
County Planning Department (Tummini, Pers. Comm., 2001), wastewater treatment systems may 
be placed on land zoned in the categories referenced above in Section 3.10.2.1. Depending on the 
specific siting location, the construction of a new WWTP may have the effect of establishing a 
precedent for more industrial or non-residential land uses in the project area. Because the effect 
on land use is both project and site specific, these impacts would be further developed in the SER 
prepared for the individual project. 

The installation or upgrading of new WWTPs is not expected to cause changes in growth. The 
capacity of wastewater treatment alternatives proposed in the MCSWMP, the plan from which 
FEMA-funded projects would be selected, are based on accommodating a 17% increase in 
residential wastewater use and a 7% increase in non-residential use between 1998 and 2018. As 
is typical for capital-intensive projects that have project lives in excess of 10 years, the capacity 
of proposed wastewater management projects take into account future demand for wastewater 
disposal. These growth projections are based on the present ROGO permitting system that limits 
growth in Monroe County. 

Because of the Federal funding assistance, implementation of this alternative would likely result 
in a quicker availability of nutrient reduction credits in the service area. This could result in an 
apparent short-term, increase in growth in the area where the credits are made available. 
However, the growth rate would be constrained by ROGO, as described in Section 3.10.1.1. The 
site-specific SER would contain a more detailed discussion of nutrient reduction credits, as 
appropriate. 

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The impact of wastewater management projects on CARL lands and conservation lands in the 
Keys would depend on the siting of individual projects in relation to these lands. Because these 
impacts are both project and site specific, the individual SER prepared for a subject project 
would evaluate effects on CARL lands. 

As part of the SER, FEMA would determine whether proposed project is located within the 
jurisdictional area of the CZMA. If this is the case, the Florida DCA would be required to review 
the plans of the WWTP for consistency with its comprehensive coastal management program. As 
described in Section 3.10.1.5, CBRA prohibits Federal funding for any project that could result 
in an increase in development in the CBRS units. Accordingly, no FEMA funding would be 
granted to project alternatives that site a WWTP in or serve CBRS units. In terms of the positive 
effects on ground and nearshore waters identified in Section 3.2 of this PEA, the proposed 
WWTP should result in generally positive effects on the natural resource value of CARL and 
conservation lands, CBRS units, and coastal areas that derive their natural resource value from 
good water quality. 

Collection Option 1  Vacuum Pumping 

The selection of vacuum pumping alternative would require the siting of one or more vacuum 
pumping stations. Land use and planning effects associated with this alternative would be similar 
to those described in Section 3.10.2.2. 

Collection Option 2  Centrifugal Grinder Pump System 

Since this system operates underground, there would be no notable effects to land use and zoning 
other than those described for the WWTP itself in Section 3.10.2.2. 

Disposal Options 1 and 2 

Both disposal options would have impacts similar to those described in Section 3.10.2.2. 

3.10.2.3 Alternative 3  On-Site Treatment Upgrades 
On-site treatment system upgrades to clustered OWNRS that remain in the same geographic 
location are expected to have a minimal effect on land use and planning. Clustered OWNRS that 
would be sited at new locations are expected to result in minimal effects on existing land use 
because they would be presumably sited on vacant lands. According to the Monroe County 
Planning Department (Tummini, Pers. Comm., 2001), wastewater treatment systems may be 
placed on land zoned in the categories referenced in Section 3.10.2.1. Because the effect on land 
use is both project and site specific, these impacts would be further developed in the SER. 

The conversion of OWTS to OWNRS is not expected to cause changes in growth. OWNRS are 
generally constructed for existing development or in light of short (1 to 5 year) planning horizon. 
This is because they serve limited numbers of households (1 to 50 households possible), 
(Monroe County, 2000a). As with Alternative 2, implementation of this alternative would likely 
result in a quicker availability of nutrient reduction credits in the service area. This could result 
in an apparent short-term, increase in growth in the area where the credits are made available. 
However, the growth rate would be constrained by ROGO, as described in Section 3.10.1.1. The 
site-specific SER would contain a more detailed discussion of nutrient reduction credits, as 
appropriate. 

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The impact of OWNRS on CARL lands and conservation lands in the Keys would depend on the 
siting of individual projects in relation to these lands. Because these impacts are both project and 
site specific, the individual SER prepared for a subject project would evaluate effects on CARL 
lands. Effects on CZMA, CBRA, and CARL would be similar to those described in Section 

3.10.2.2. 
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Noise and Visual Resources 

3.11 NOISE AND VISUAL RESOURCES 
3.11.1 Noise 
3.11.1.1 Affected Environment 
Noise, or unwanted sound, was originally managed at the Federal level by the Noise Control Act 
of 1972, which was administered by the EPA. Under this Act, Congress tasked the EPA with 
determining the extent and effects of different qualities and quantities of noise and to define 
acceptable levels of noise towards public health and safety (NPC, 2001). Since 1982, the 
responsibility of noise abatement and control has been delegated to the State and local 
governments, but the noise levels and exposure recommendations developed by EPA under the 
Noise Control Act are still relevant. The EPA describes sound in terms of its amplitude 
(loudness), frequency (pitch), and time pattern (continuous, fluctuating, intermittent, 
impulsiveness). A decibel (dBA) is a unit of sound amplitude, whereas a hertz (Hz) is a unit of 
sound frequency. For the purpose of discussing noise levels in this PEA, sound will be measured 
and discussed in units of decibels. 

The State of Florida achieves noise control through a State noise statute (Title XXIX, Public 
Health, Chapter 403) that outlines general and specific prohibitions relative to noise levels. 
Additionally, Article III, Sections 13-51 to 13-55 of Monroe County Code has the Monroe 
County noise ordinance regulations. Noise effects are discussed in terms of public hazards, 
where the focus is on the effects to community citizens and adjacent land uses, and in terms of 
occupational hazards, which focuses on effects on laborers (as mandated in 29 CFR 1910.5, 
Occupational Noise Exposure, administered by the Occupational Safety and Health 
Administration [OSHA]). Under the proposed alternatives, it is likely that both public and 
occupational noise impacts would occur. 

Sensitive noise receptors in the Keys could include schools, residential areas, hospitals, churches, 
and public facilities, such as parks and recreational areas. Sensitive receptors are considered 
areas that sustain greater impacts from noise sources than other areas (such as industrial areas). 
An evaluation of sensitive receptors in the specific project areas would be conducted as part of 
the SER. 

Ambient noise levels (background sound) at the proposed project sites would vary depending on 
noise sources present in the areas. For the purpose of discussing impacts, existing noise levels at 
the sites are represented by land uses and their corresponding average noise levels, since specific 
sites are yet unknown. Table 3-14 presents estimated outside noise levels associated with certain 
land uses and locations measured in dBAs (Day-Night Sound Level [Ldn]). The presented noise 
levels serve as baseline noises, from which impacts will be discussed. As point of reference, a 
consistent level of 70 dBAs is identified for all areas in order to prevent hearing loss (EPA, 
1974). 

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

Land Use Decibel Similar Sound 
(Point of Reference) 
Overall Noise Level 
Wilderness Area 35 Library (37-42 dBA) Quiet 
Rural Residential 
Area 
39 Library (37-42 dBA) Quiet 
Agricultural Crop 
Land 
44 Bird calls (38-52 dBA) Quiet 
Wooded Residential 
Area 
51 Rainfall (31-55 dB) Quiet 
Old Urban 
Residential Area 
59 Sewing Machine (57-63 dBA) Quiet to Moderately 
Loud 
Urban Housing on 
Major Avenue 
68 Vacuum cleaner (65-82 dBA) Moderately Loud 
Freeway Traffic 70 Vacuum cleaner (65-82 dBA) Moderately Loud 
Downtown Area with 
Some Construction 
Activity 
79 Ringing Telephone (78-82 
dBA) 
Moderately Loud 
Heavy Traffic 85 Handsaw (83-87 dBA) Moderately Loud 
Sources: Noise Center of the League, 2001; NCP, 2001; and Branch et al., 1970. 

As a final distinction between noise levels and land use, it is preferable that areas associated with 
hospitals and schools measure less than 45 dBAs, and areas that allow outdoor human activities 
(such as a park) should measure less than 55 dBAs. These noise thresholds allow spoken 
conversation, sleeping, work, and recreation activities without interference or annoyance (EPA, 
1974). 

3.11.1.2 Environmental Consequences 
For the purposes evaluating consequences, noise impacts are considered in terms of a baseline 
ambient noise for a given area (represented in this document by land uses) combined with noises 
generated by the alternatives. When adding noise levels (when several different noises occur at 
the same time), the decibels associated with a noise are combined on a logarithmic scale 
(decibels cannot be added or subtracted in the usual arithmetical way). The table below 
illustrates a simplified manner in which to combine noise levels. As an example, if one machine 
emits a noise of 90 dBA, and a second identical machine is placed beside the first, the combined 
sound level is 93 dBA, not 180 dBA. Adding a noise that is less than the ambient noise results in 
no numerical change because the additional noise would be imperceptible. Adding noise that is 
10 dBAs or higher than the ambient noise would result in a new noise level of the louder noise. 
For example if your workplace noise is 80 dBA and you add a machine measuring 95 dBA, the 
overall noise level would equal 95 dBA (CCOHS, 2001). 

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Table 3-15: Addition of Decibels 

Numerical Difference Between the Two 
Noise Levels (dBA) 
Amount to be Added to the Highest of the 
Two Noise Levels (dB or dBA) 
0 3.0 
0.1  0.9 2.5 
1.0  2.4 2.0 
2.4  4.0 1.5 
4.1  6.0 1.0 
6.1  10 0.5 
10 0.0 
Source: CCOHS, 2001 

3.11.1.2.1 No Action Alternative, Centralized WWTP Alternative, and OWNRS Alternative 
Given that the activities under each of these alternatives would involve a range of 
construction activities, the impacts related to construction and noise at the project sites would 
similar for all alternatives; therefore, this discussion pertains to all alternatives. Following this 
discussion, an analysis of noise and WWTP operations is presented, but pertains only to the 
Centralized WWTP alternative. It should be noted that business and residential citizens 
located adjacent to project sites and laborers working at the sites will incur different levels of 
impact due primarily to distance and noise reduction of buildings. For these reasons, effects 
on citizens and laborers are discussed separately. 

Effects on Citizens 

All construction activities under all alternatives would have some noise impacts. Noise levels 
at all project sites are expected to rise above typical day-night averages, which in this 
document are represented by land uses since the specific sites are yet undetermined (refer to 
Table 3-13: Approximate Noise Levels in Decibels Based on Land Uses). Land use noises are 
defined by noise levels that are generally quiet or moderately quiet. Construction noises 
would typically occur at decibels over those associated with project site noise levels. 
Therefore, noise level increases could be substantial when compared with existing ambient 
noise levels. However, even though the change in sound energy associated with construction 
noise is substantial, the overall decibel level may not be significant in terms of adverse health 
effects. 

While the overall decibel increase at project sites would likely be substantial over present 
ambient levels, the distance between residents and business owners and the construction 
activity, as well as noise reduction offered by buildings (where these populations would likely 
be most of the time) would dilute the level of sound actually reaching most citizens adjacent 
to the construction sites. The contribution of outdoor noise to indoor noise is usually small, 

0.5 to 1.5 dB (NPC, 2001). The intensity of a source, the distance of that sound, and the sound 
level reduction afforded by a building influence the amount of sound that ultimately enters a 
building and disturbs citizens located inside. Buildings constructed in cold climates offer 
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greater sound reduction than those constructed in warm climates, although the difference is 
minimal, 0.5 to 1.0 dB. Given the warm climate of the Keys, it is assumed that a building can 
reduce outside sounds by 12 dBA s when windows are opened, and by 24 dBAs when 
windows are closed (NPC, 2001). This reduction represents a substantial change in overall 
noise levels entering a residence, business, or school. 

Additional reductions can be assumed when factoring in distance and buffering materials 
located between the citizen and the construction activity. According to Marsh (1991), the 
magnitude of sound from a source decreases at a rate of 3 to 6 dBA with each doubling of 
travel distance. Further, vegetation in the path of sound can absorb and divert some sound. 
Vegetative buffers are most effective when a topographic barrier (berm or embankment) is 
used alongside plantings. 

Overall, effects on citizen groups would vary from site to site, depending on the type of 
construction activity, the distance between the site and population affected, and whether 
windows are opened or closed. An increase in localized noise levels is expected during 
construction at various locations over the course of about 18 months (Teague, Pers. Comm., 
2001), and area populations may endure annoying and disruptive noises during allowable 
construction work hours, as cited in the applicable noise ordinance. The potential for a 
population to experience hearing damage or loss due to construction noises is considered low, 
however the SER would evaluate site-specific characteristics to adequately evaluate risks. To 
mitigate noise impacts, the applicant would implement measures such as use of vegetative 
barriers and would obey the established noise ordinance, Article III, Sections 13-51 to 13-55 
of Monroe County Code in order to reduce annoying and disruptive noises to adjacent areas. 
Citizens can mitigate indoor noise by keeping windows closed for the duration of 
construction. Impacts related to noise would be further evaluated in the SER that would also 
include project-specific mitigation measures. 

Impacts on Workers 

All alternatives would have some noise levels that may adversely affect workers at the 
construction sites and in the WWTP facilities. Construction noise levels can damage human 
hearing abilities depending on the sound and exposure levels (Table 3-16). It is expected 
workers would not have the noise reduction benefits of distance, vegetative buffers, or 
buildings. Once construction of WWTPs is complete, noises associated with typical WWTP 
operations may adversely affect the workers (Table 3-17). 

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

Construction 
Activity 
Associated 
Decibels 
Risk from Exposure 
(representative of range 
of decibels) 
Permissible Exposure Limits 
(minute/hour at maximum 
level; no protective equipment 
worn) 
Rock Drilling Up to 115 Chance of Hearing loss to 
Harmful to Hearing 
15 minutes 
Heavy Equipment 
Operation 
95  110 Chance of Hearing loss to 
Harmful to Hearing 
30 minutes 
Jack Hammer 102  111 Chance of Hearing loss to 
Harmful to Hearing 
26 minutes 
Concrete Joint 
Cutter 
99  102 Chance of Hearing Loss 1 hour, 30 minutes 
Skilsaw 88  102 Chance of Hearing Loss 1 hour, 30 minutes 
Bulldozer 93  96 Chance of Hearing Loss 3 hours, 30 minutes 
Earth Tamper 90  96 Chance of Hearing Loss 3 hours, 30 minutes 
Crane 90  96 Chance of Hearing Loss 3 hours, 30 minutes 
Backhoe 84 - 93 Chance of Hearing Loss 5 hours, 18 minutes 
Gradeall 87 - 94 Chance of Hearing Loss About 4 hours 
Source: Marsh, 1991. 

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

WWTP Operating Area Estimated Noise Level (dBA) 
Generator Room 77-91 
Pump Room 77-100 
Vacuum Pump Trucks 74-92 
Sludge Thickening Rooms 63-98 
Source: State of New Jersey, 2001 

To mitigate noise impacts, workers would comply with applicable occupational safety 
regulations and implement appropriate noise control measures, such as wearing hearing 
protection (e.g., ear plugs, ear muffs, a helmet, or canal caps) and limiting exposure times, as 
appropriate. If these measures are implemented during construction and operations, no adverse 
effects on workers should occur. Impacts related to noise would be further evaluated in the SER 
that would also include project-specific mitigation measures. 

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SECTIONTHREE Affected Environment and Environmental Consequences 

Noise and Visual Resources 

3.11.2 Visual Resources 
3.11.2.1 Affected Environment 
Visual resources refer to the landscape character (i.e., what is seen), visual sensitivity (i.e., 
human preferences and values regarding what is seen), scenic integrity (i.e., degree of intactness 
and wholeness of landscape character), and landscape visibility (i.e., relative distances of seen 
areas) of a geographically defined viewshed. The Keys viewshed is presented below in general 
terms, and the viewsheds of each project site would be described in the specific SER. 

Keys visual resources vary greatly depending on the location. The Keys has dense urban 
development dominated by roadways, boating canals, boat marinas, and residential, industrial, 
and commercial structures. In general, even the urban areas support many vegetation types, 
providing a lush setting for the communities. The Keys support many natural areas, which 
provide vistas of coastal communities consisting of mangrove forests and salt marshes; upland 
communities consisting of tropical hardwood hammocks and pine rockland communities, both 
on slightly higher elevations; and marine habitats including beaches and nearshore waters. 

In order to assess the viewshed of a given project area, a visual resource assessment may be 
conducted that integrates the benefits, values, desires, and preferences regarding aesthetics and 
scenery for all levels of land management planning. A visual resource assessment would assess 
and evaluate landscape character, scenic integrity, constituent information, landscape visibility, 
and scenic class of the viewshed relative to each project site. The purpose of this assessment is to 
create a numeric value score for each project site relative to each of the parameters based on 
accepted methodology, and to use the numeric score to interpret the degree of visual impacts. 

3.11.2.2 Environmental Consequences 
Depending on the existing visual quality of a proposed site, FEMA would assess impacts related 
to visual resources in the project-specific SER. This assessment would examine viewshed effects 
in terms of the scenic quality, unique natural communities, high quality and unique views, and 
the proximity of project activities to developed and natural areas. 

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SECTIONFOUR Cumulative Impacts 

Cumulative impacts, in the NEPA context, are the environmental impacts that result from the 
incremental impacts of the proposed action when added to other past, present, and reasonably 
foreseeable future actions, regardless of what agency (Federal or non-Federal), business, or 
person undertakes such other actions. Cumulative impacts can result from individually minor but 
collectively significant actions taking place over a period of time. 

In order to adequately address the cumulative impacts of a given wastewater management 
improvement project, it is necessary to examine project-specific details. As such, the cumulative 
impact discussion of the projects proposed for FEMA funding assistance would be focused at the 
project-specific SER level. However, due to the wide array of projects concerned with water 
quality currently planned or underway in the Keys and South Florida, the below discussion 
focuses on the cumulative impacts of these regional projects as related to the proposed FEMA-
funded projects. 

4.1 CONCURRENT PROJECTS 
4.1.1 Comprehensive Wastewater Management Activities 
As a result of declining nearshore water quality in the Keys, a number of Federal, State, and local 
laws and regulations have been implemented to improve wastewater and stormwater 
management, monitor water quality, assist in financing water quality improvements, and 
establish new water quality monitoring standards. In particular, the Monroe County Year 2010 
Comprehensive Plan, as well as, Florida EO 98-309 and F.A.C. 99-395, mandate that nutrient 
loading levels be reduced in the marine ecosystem of the Keys by the year 2010. Specific actions 
include eliminating cesspits, failing septic systems and other substandard on-site sewage 
systems, and requiring that all wastewater discharge be treated to Florida Statutory Treatment 
Standards. In response to the mandated wastewater treatment improvements, Monroe County 
prepared the MCSWMP, which has recommendations for a number of wastewater management 
projects that would improve water quality throughout the Keys. In total, the MCSWMP 
recommends 12 community WWTPs and 5 regional WWTPs. Five of the 12 community 
WWTPs feature interim WWTPs that, over time, will be phased into larger regional systems. 

4.1.2 Comprehensive Stormwater Management Activities 
In addition to developing a comprehensive wastewater management plan, Monroe County has 
prepared a comprehensive stormwater management plan to address the detrimental effect to 
water quality of stormwater flow emanating from developed areas. Recent estimates attribute 
about 20% of the nearshore nitrogen loading and about 45% of the phosphorous loading 
emanating from the Keys to stormwater (EPA, 1993a; Kruczynski, 1999). Released in August 
2001, the SMMP recommends 24 site-specific stormwater management projects (e.g., vegetated 
berms and porous pavement), to reduce sediment loading. 

4.1.3 Everglades Restoration 
The Everglades ecosystem extends from the Chain of Lakes south of Orlando to the reefs 
surrounding Fort Jefferson southwest of the Keys. The natural system has been severely 
degraded by flood control and water distribution systems, growth and development, and 

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SECTIONFOUR Cumulative Impacts 

agriculture. High levels of phosphorus, mercury, and other contaminants have occurred in the 
water system from urban stormwater and agricultural runoff (FDEP, 2002). In an effort to restore 
the Everglades ecosystem, the Comprehensive Everglades Restoration Plan (CERP) was 
developed with USACE and SFWMD as the lead agencies. The CERP includes a broad range of 
projects including the examination of aquifer storage and recovery; in-ground reservoir 
technology; levee seepage management technology adjacent to Everglades National Park; and 
advanced wastewater treatment technology to determine the feasibility of using reuse water for 
ecological restoration. Additionally, components of the CERP include the Arthur R. Marshall 
Loxahatchee National Wildlife Refuge internal canal structures, the Lake Okeechobee watershed 
water quality treatment facilities, and the Keys Tidal Restoration Project. There have been 
concerns that the large-scale environmental restoration projects in the Everglades will increase 
the freshwater flow to Florida Bay and, subsequently, increase nutrient loading. 

4.2 CUMULATIVE IMPACTS 
4.2.1 Topography, Soils, and Geology 
The cumulative effects on topography and soils as result of the concurrent, region-wide projects 
are expected to be minimal. The implementation of new wastewater treatment alternatives 
throughout the Keys would result in the cumulative increase in the impervious surface area due 
to the construction of WWTPs and clustered OWNRS systems; however, the actual land area 
required for these activities is limited relative to the extent of the Keys surface area. Given the 
flat topography of the Keys, wastewater projects are not expected to change surface topography. 
As described in Section 3.1.1.3, the reduction of nutrients inputs as a result of wastewater and 
stormwater management projects would likely benefit coral reefs; thereby, reducing the potential 
for wave erosion during storms. Soils would be temporarily disturbed during stormwater and 
wastewater management projects; however, the implementation of the comprehensive SMMP 
would decrease the potential for long-term surface soil erosion. With respect to geology, the 
potential cumulative effects of wastewater management projects are expected to be minimal as 
described in Section 3.1.3.2.2. This section discusses sinkhole development, limestone solution, 
and pressure buildup as they relate to the hydrogeology of the Keys. 

4.2.2 Water Resources and Water Quality 
In light of concurrent wastewater and stormwater management activities and the CERP, 
improvements to the water quality of canal, nearshore, and offshore waters are expected. Water 
quality sampling, such as that being conducted through the WQPP as described in Section 

3.2.3.1.2 would assist in quantifying the extent of these improvements. As further detailed in 
Section 3.2.2.2.1 and Appendix D, the conversions of cesspits and septic tanks to systems that 
meet Florida Statutory Treatment Standards are expected to result in about 92% reduction in TN 
input to groundwater and 86% reduction in TP input to groundwater attributed to wastewater 
sources in the Keys. Reduced groundwater nutrient loading would also reduce nearshore nutrient 
loading because of groundwater movement. Wastewater has been estimated to account for 80% 
of the TN and 55 to 56% of the TP loading to nearshore waters. Similarly, it is estimated 
untreated stormwater runoff accounts for 20% of the TN and 44 to 45% of the TP loads to 
nearshore waters (EPA, 1996; Kruczynski, 1999). Accordingly, successfully implementing both 
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SECTIONFOUR Cumulative Impacts 

the MCSWMP and MCSMMP should substantially reduce nutrient loading from the Keys, 
resulting in a cumulative benefit to at least nearshore water quality. 

Additionally, there have been concerns that the large-scale Everglades restoration projects will 
increase freshwater flow to Florida Bay and, subsequently, increase nutrient loading. In an 
analysis of how changing freshwater inflow to the southern Everglades is likely to change the 
input of nutrients to Florida Bay, Rudnick et al. (1999) found that TP inputs from the Everglades 
are not likely to increase; however, an increase in TN may be expected. Despite these results, the 
study found that nitrogen and phosphorus inputs from the Gulf of Mexico greatly exceeded 
inputs from the Everglades. The freshwater Everglades were identified as contributing less than 
3% of all phosphorus inputs and less than 12% of all nitrogen inputs to Florida Bay. These 
nutrients were primarily attributed to runoff from agricultural and residential areas, natural 
nutrient levels, and atmospheric deposition (Rudnick, et al., 1999). 

4.2.3 Biological Resources 
The overall cumulative effects to biological resources as a result of the concurrent projects 
identified in Section 4.1 are expected to be beneficial. As described in Section 3.3.2.1, positive 
effects to nearshore marine habitats including seagrass meadows and coral reefs would likely 
occur due to the reduction of TSS, nutrients, and pathogens released to the nearshore waters that 
would be expected as a result of wastewater improvement activities; as well as stormwater 
improvements and the CERP. Corals typically thrive in an oligotrophic (nutrient-poor) 
environment with the assistance of specialized symbiotic algae (i.e., zooxanthellae); these algae 
derive their nutrients from the waste products of their coral hosts and, as such, are not typically 
limited by the availability of free nutrients from the water column (Hallock et al., 1993). Other 
benefits of decreased TSS and nutrient release may include increased growth of seagrasses due to 
increased light penetration. Algal blooms may also become less frequent, pervasive and 
damaging as a result of the reduced TP and TN concentrations. 

The project activities associated with the wastewater and stormwater programs in the Keys have 
the potential to result in the loss of habitat; however, most activities would occur in developed, 
disturbed areas with low habitat value. Appropriate site selection and mitigation measures would 
minimize the cumulative impacts of these programs. Any potential loss in terrestrial habitat 
would need to be considered in terms of the improved water quality that would result from 
wastewater and stormwater management activities and subsequent benefits to aquatic habitats, 
such as seagrasses and coral reefs communities. 

Cumulative effects to special status species would be similar to those described for biological 
resources, in general. Site selection, the implementation of appropriate mitigation measures, and 
coordination with responsible agencies such as USFWS and NMFS would minimize potential, 
cumulative adverse impacts. 

4.2.4 Air Quality 
Potential cumulative effects on air quality as they relate to the projects described in Section 4.1 
are expected to be minimal. 

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SECTIONFOUR Cumulative Impacts 

4.2.5 Cultural Resources 
The wastewater and stormwater programs, as well as the CERP, may result in ground disturbing 
activities that may impact historical and archaeological resources if present. However, these 
impacts are expected to be minimal because most work would be done at previously disturbed 
sites. The implementation of mitigation measures, appropriate site selection, and coordination 
with the FSHPO would minimize these potential cumulative impacts. 

4.2.6 Socioeconomics 
The implementation of the wastewater and stormwater programs would cumulatively improve 
ground and nearshore water quality and presumably reduce or eliminate the number of health 
advisories in beaches and canals in the Keys. This would likely increase the number of visitors to 
beaches that formerly posted advisories, and/or reduce visitor pressure on alternate beaches and 
recreational activities. These water quality improvements would also benefit commercial 
fisheries to the extent they are currently being adversely impacted by nutrient pollution. 
Generally, it may be predicted that harvested species that occur in nearshore waters such as spiny 
lobster, white mullet, gray snapper, various flounder, shrimp, and stonecrab would benefit from 
improved water quality. In consideration of the cumulative effect of on-going stormwater 
management activities, wastewater management activities in the Keys, and the CERP, the 
benefits may range from relatively insignificant to potentially substantial improvements in 
harvest rates thus benefiting the fishing industry. 

4.2.7 Demographics and Environmental Justice 
In terms of Demographics and Environmental Justice, no adverse cumulative economic impacts 
are expected as a result of the comprehensive stormwater program or the CERP. However, as 
described in Sections 3.8 and 1.2.6, implementation of the MCSWMP throughout the Keys 
would generally increase wastewater management costs for residents. Based on the information 
in Section 3.8.1.3, it was determined that the low-income population could not afford an increase 
in wastewater management costs over present costs. When combined with the high cost of living 
in the Keys, the cumulative impact of implementing the wastewater program may result in 
disproportionate adverse economic effects on low-income populations. These impacts would 
depend on system costs, the grant funding and financing options related to the capital costs of 
wastewater improvement projects, and the availability of funding from assistance programs 
targeted to low-income service recipients. 

The siting of WWTP and other wastewater facilities is not expected to cause cumulative adverse 
effects to minority and/or low-income populations in the Keys, when combined with the above 
concurrent projects. 

4.2.8 Hazardous Materials 
Potential cumulative effects on hazardous materials as they relate to the projects described in 
Section 4.1 are expected to be minimal. 

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SECTIONFOUR Cumulative Impacts 

4.2.9 Infrastructure 
WWTP construction or upgrade and OWTS conversion to clustered OWNRS as part of the 
MCSWMP implementation, along with implementation of the MCSMMP would result in a 
cumulative increase of the infrastructure required for these projects. However, adverse 
cumulative effects on Monroe Countys overall infrastructure, as described in Section 4.1, are 
expected to be minimal. 

4.2.10 Land Use and Planning 
The installation of new WWTPs, upgrading of WWTPs, and conversion of OWTS to OWNRS as 
part of comprehensive wastewater management is not expected to cause changes in the existing 
growth pattern of the region. The capacity of wastewater treatment alternatives proposed in the 
MCSWMP are based on accommodating a 17% increase in residential wastewater use and 7% 
increase in non-residential use over a 20-year planning period (1998 to 2018). As is typical for 
capital-intensive projects that have project lives in excess of 10 years, the capacity of proposed 
wastewater management projects take into account future demand for wastewater disposal. As 
described in Section 3.10, these growth projections are based on the present ROGO permitting 
system that limits growth in Monroe County. Changes to the rate of growth and building permit 
allocation system are at the discretion of the Monroe County BOCC and the Florida DCA. 

The impact of improved wastewater and stormwater management and CERP on CARL lands and 
conservation lands, and areas managed under the CZMA would depend on the siting of 
individual projects in relation to these lands. Conscientious siting of projects outside of these 
lands, compliance with CZMA, and the implementation of mitigation measures would assist in 
reducing adverse cumulative effects on these special status lands. Proposed projects identified in 
this PEA are not eligible for FEMA funding if sited in or serving areas that are CBRS units; 
therefore there would be no cumulative impacts on CBRS units. In terms of the positive effects 
on ground water and nearshore waters identified in Section 3.2 of this PEA, the proposed WWTP 
should result in generally positive effects on the natural resource value of CARL and 
conservation lands, CBRS units, and coastal areas that derive their natural resource value from 
good water quality. 

4.2.11 Noise and Visual Resources 
Potential cumulative effects on noise and visual resources as they relate to the projects described 
in Section 4.1 are expected to be minimal. 

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SECTIONFIVE Public Involvement 

The topic of wastewater management improvements and water quality degradation in the Keys is 
of particular public interest to agencies and citizens alike. For this reason, public participation 
throughout the PEA and SER processes is of high concern not only in terms of upholding the intent 
of NEPA and other applicable environmental statutes, but also to ensure that FEMA conducts 
studies with the knowledge that public and agency opinions were gathered and considered, 
ensuring a well-documented and well-represented study. FEMA has specific requirements for 
public participation in compliance with its implementing regulations for NEPA, EO 11988 
(Floodplain Management) and EO 11990 (Wetland Protection); and EO 12898 (Environmental 
Justice). 

FEMAs public involvement activities began with notification of the PEA preparation as part of 
the scoping process. Public notification was issued via a Notice of Intent (NOI) published in the 
Key West Keynoter, the Key West Citizen, and The Reporter newspapers from the end of August 
through September 10, 2000 (Appendix G). Since publication of the NOI, FEMA has received 
comments from interested parties pertaining to the proposed wastewater improvement projects. 
FEMA has considered these concerns during preparation of the PEA as they relate to NEPA and 
the environmental review process. 

In addition to initiating public involvement, FEMA has notified relevant Federal, State and local 
agencies of preparation of this PEA through a agency coordination letters sent on August 15, 2001. 
The letters provided brief descriptions of FEMAs funding mechanism, the NEPA review process, 
proposed project alternatives; and invited agencies to provide preliminary comments on the 
information therein. To date, only four agencies responded to this letter; their responses are in 
Appendix G. 

In accordance with FEMA procedures and NEPA public noticing requirements, a draft version of 
the PEA was advertised in local newspapers and available at local repositories for a 30-day 
comment period from September 20 to October 18, 2002. A copy of the public notice is contained 
in Appendix I. During this review period, two public meetings were held on October 8 and 
October 9, 2002 at the Key Largo Branch Library and Marathon Government Center, respectively. 
The meetings were administered by FEMA to outline FEMAs environmental review process, 
provide an overview of draft PEA conclusions, and provide an opportunity to discuss, comment on 
and suggest refinements to the draft PEA. Representatives from DCA, Monroe County, FKAA, 
Village of Islamorada, USACE, and URS Group presented information and were available to 
respond to questions from the public. 

Interested parties had the opportunity to submit comments on the draft PEA by mail, in-person at 
the public meetings, by fax, and electronically on the PEA website. A total of three individuals 
and one agency submitted letters by mail. Five individuals submitted comments through the PEA 
website. At the public meetings on October 8 and 9, there were six and seven participants, 
respectively. Public comments submitted to FEMA during the 30-day review period were 
reviewed and addressed, as appropriate, in this PEA document. A compilation of all comments 
and responses are contained in Appendix K. In total, 76 individual comments were received, 
analyzed, and addressed. 

Similar to this PEA, preparation of the project-specific SERs will include a public outreach 
component. Draft versions of the SER will be made available for public comment before issuance 
of the final document. Additional forms of public outreach may include public meetings, the 

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SECTIONFIVE Public Involvement 

posting of notices and other relevant information via the Internet, as well as project information 
disseminated through local media outlets. 

Public involvement has also been an integral element of Monroe Countys wastewater planning 
process and the development of the MCSWMP. Public involvement activities conducted as part of 
the MCSWMP included over 30 meetings with key stakeholders and the public hosted by the 
FKAA and the County held between 1998 and 2000; public forums in the Upper, Middle, and 
Lower Keys; press releases to the media; distribution of fact sheets outlining key project 
milestones and other project-related information; presentations at Monroe County BOCC 
meetings; radio talk show appearances; project video presentations; and a school-based outreach 
program among other modes of public involvement. Participants providing comments generally 
expressed concerns regarding implementation costs, extent of improved water quality, 
implementation approaches, alternative conveyance/treatment technologies, measuring project 
performance, and County responsiveness to public input. Additional details on the public 
involvement associated with the development of Monroe Countys wastewater management 
planning, including the decision analysis for alternatives, can be found in the MCSWMP (Monroe 
County, 2000a). 

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SECTIONSIX Conclusions 

The construction and operation of the wastewater treatment projects, as proposed in this PEA, 
would result in some limited adverse impacts and long-term positive impacts to the human 
environment. The majority of adverse impacts would be short-term and construction-related. 
Effects to topography, soils, and geology; air quality; cultural resources; hazardous materials and 
wastes; infrastructure; land use and planning; and noise and visual resources are expected to be 
negligible. 

Impacts to water resources and water quality are expected to be positive with the improvement of 
inland, nearshore, and offshore water quality. The implementation of the proposed projects 
would result in increased wastewater management costs, particularly to service recipients who 
currently have cesspits or septic tanks. The increase in wastewater management costs could have 
a highly disproportionate and adverse economic effect on low-income service recipients. 
However, grant funding assistance is expected to reduce the capital costs so that the wastewater 
service would be affordable for service recipients. Assistance guidelines have been outlined to 
further reduce the economic impact of wastewater projects to qualified low-income service 
recipients for FEMA-funded projects. 

With the implementation of the mitigation measures and conditions outlined in this PEA, along 
with the applicable permitting, impacts to the human environment are expected to be less than 
significant. This conclusion is based on the analyses, conditions, and assumptions contained in 
the PEA. To assess the project- and location-specific impacts, FEMA will prepare an SER for 
each individual project. The project applicants would be required to follow the conditions and 
mitigation measures outlined in this PEA in addition to any project- and location-specific 
requirements. 

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SECTIONSEVEN List of Preparers 

Project Management and Technical Research 

Erica Zamensky, URS Group, Inc., Project Manager, Project Environmental Scientist. Ms. 
Zamensky has 10 years of experience in Natural Resources Management and Planning, with 8 of 
those years in managing NEPA documentation projects of varying scopes. Project experience 
includes stormwater, construction of dams and reservoirs, floodwalls, retention and detention 
ponds, and hydraulic improvements to river and streams, as well as in construction of public 
housing, schools, and pump stations. Ms. Zamensky has experience in managing small and large 
teams in fieldwork operations, technical topic research, and document writing relative to NEPA 
and other natural resource planning and management tasks. Ms. Zamensky serves as Project 
Manager, technical researcher, and document author. 

Jonathan Randall, URS Group, Inc., Senior Environmental Scientist. Mr. Randall has more 
than 5 years of experience, with specialized expertise in NEPA compliance studies, Section 7 
Endangered Species Act biological assessments, ecological field surveys and natural resource 
studies, quantitative policy analyses, and technical writing and editing. In compliance with 
FEMAs implementing regulations, he has prepared a broad range of NEPA documentation, 
including assessments for natural hazard mitigation projects such as school building relocations, 
stream bank stabilizations, detention basins, and fuels modification and management. He serves 
as assistant project manager, technical researcher, and document author. 

George H. Davis, P.G., URS Group, Inc., Principal Hydrogeologist. Mr. Davis is a 
hydrogeologist who has been with URS (formerly Woodward Clyde Consultants) since 1985 
following a 32-year career with the U.S. Geological Survey. His USGS career culminated with 3 
years service as Assistant Director of the agency. His more than 40 years of experience 
comprises groundwater and surface water hydrology, water supply studies, and water 
contamination investigations; and includes field investigations, remedial investigations, and 
feasibility studies of contaminated sites, regulatory agency interactions, and siting and permitting 
of radioactive, hazardous, and municipal waste projects. He has had extensive experience at 
public and regulatory hearings, and as an expert witness in court proceedings. His extracurricular 
activities include service on International and National Research Council committees, and as 
managing editor of Water Resources Research and Journal of Hydrology. Mr. Davis serves as 
technical researcher and document author. 

Thomas W. Bodor, URS Group, Inc., Senior Archeologist. Mr. Bodor has 12 years of 
experience in cultural resource management, with a focus on prehistoric and historical 
archaeology. He has completed all levels of archaeological investigations for Federal, State, and 
local clients in the Mid-Atlantic, Midwest, Southeast, and Southwest regions of the United 
States. A majority of recent projects includes the preparation of documents in compliance with 
Section 106 of the National Historic Preservation Act, and other Federal regulations. Mr. Bodor 
serves as technical researcher and document author. 

Joyce Friedenberg, URS Group, Inc., Economist. Joyce Friedenberg recently joined URS after 
having worked as a production economist for four years at a multinational corporation. She has 
worked overseas as an advisor and extension agent in community economic development and in 
the mid-west as a small business researcher, specializing in project profitability assessment. Prior 
to her training and experience as an economist, Ms. Friedenberg worked as a water resource 
engineer, analyzing agricultural, domestic and commercial water use efficiency for the U.S. 

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SECTIONSEVEN List of Preparers 

Department of Agriculture and for the Colorado Water Resources Research Institute. Ms. 
Friedenberg serves as lead economic analyst and document author. 

Sonya Krogh, URS Group, Inc., GIS Analyst/NEPA Research Assistant. Sonya Krogh has 4 
years experience in Geographic Information Systems (GIS), environmental geography, natural 
resource management, environmental justice, water resources management, conservation, and 
ecology. Ms. Krogh serves as lead GIS Analyst, technical researcher, and document author. 

Technical Peer Review 

Colin Vissering, AICP, URS Group, Inc., Master Planner and Environmental Resource 
Management Department Head. Mr. Vissering is a senior planner with experience in 
environmental and urban planning, policy, and emergency management and hazard mitigation 
programs. He has managed environmental and cultural resource compliance activities for Federal 
disaster programs, providing oversight for numerous NEPA Environmental Assessments and 
related natural resource studies. His experience includes development of hazard mitigation plans 
and related planning guidance, environmental training, Federal environmental regulatory and 
policy development, and drafting and implementation of National Historic Preservation Act 
(NHPA) agreement documents. Mr. Vissering is currently the department head of the 
Environmental Resource Management Group for URS in Gaithersburg, Maryland. This group is 
comprised of the landscape architecture/planning, cultural resource management, and NEPA and 
natural resource management teams. Mr. Vissering serves as document peer reviewer. 

Daniel M. Savercool, URS Group, Inc., Senior Ecologist and Ecological Resources Group 
Manager. Mr. Savercool has over 19 years experience in the ecology, restoration and creation of 
freshwater and estuarine marshes, mangrove forests, seagrass meadows and adjacent upland 
habitats. Over 15 years of this experience is focused on coastal plant and estuarine benthic 
communities of peninsular Florida, with particular expertise in the Everglades and the Keys. He 
has studied plant and animal colonization of recently restored or impacted coastal habitats, 
experimental revegetation of wetlands utilizing both marine and freshwater species and 
management techniques for the control of undesirable exotic vegetation. Mr. Savercool's 
published research includes artificial reefs, estuarine benthic communities and control of exotic 
vegetation in Florida. He serves as technical peer reviewer for the biological resources sections 
of the PEA. 

Michael S. Knapp, P.G., L.S. Sims and Associates, Inc., Consulting Geologist. Mr. Knapp is 
a hydrogeologist with over 27 years of specialized experience in well site geological evaluations, 
Underground Injection Control permitting, aquifer performance tests, and geophysical log 
interpretation with the majority of his experience in the State of Florida. Prior to joining L.S. 
Sims and Associates, Mr. Knapp served as President of HydroDesigns, Inc., Senior 
Hydrogeologist for the SFWMD, and District Geologist for the Florida Geological Survey. He 
has worked extensively with FDEP in the permitting aspects of underground injection wells, and 
is considered an expert on Florida Stratigraphy. Mr. Knapp serves as a technical peer reviewer of 
the topography, geology, and soils, and water quality and water resources sections of the PEA. 

Thomas Kwader, Ph.D., P.G., URS Group, Inc., Hydrogeologist and Vice President. Dr. 
Kwader has worked extensively as a hydrogeologist in the Southeastern Coastal Plain of the 
United States in his over 25 years of experience. In the early 1980s, he was one of the 12 
members appointed by the Florida Department of Environmental Regulation (now FDEP) to 
serve on the Technical Advisory Committee to develop the Underground Injection Control rule 

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SECTIONSEVEN List of Preparers 

for primacy in the State of Florida to address the underground injection of wastewater in Florida. 
Dr. Kwader is considered an expert in most all types of well construction and borehole 
geophysical logging, having personally logged a wide range of sewage effluent and high-
pressure industrial injection wells. He is technical editor of the professional journal, 
Groundwater, and a member of the committee that developed the hydrostratigraphic units 
currently used in Florida. Dr. Kwader serves as a technical peer reviewer of the topography, 
geology, and soils, and water quality and water resources sections of the PEA. 

FEMA Technical and Editorial Review 

William Straw, Ph.D., FEMA Region IV, Regional Environmental Officer. Dr. Straw has 
managed and conducted FEMA regional environmental and cultural resource operations, 
reviews, field surveys, project planning and design, regulatory coordination and compliance, 
document preparation, public involvement, and other actions for a wide variety of construction, 
repair, restoration, reconstruction, elevation, upgrade, demolition, and other projects for 10 years. 
He has also developed and helped develop new and revised agency regional and national 
policies, procedures, publications, and training courses; helped State emergency management 
agencies develop their environmental operations capabilities; and managed Disaster Field Office 
environmental operations throughout the Southeastern U.S. His 27-year career in the earth and 
environmental sciences also includes seven years with the U.S. Army, three years in academia, 
and six years with a major architecture and engineering firm. He has degrees in earth sciences, 
geography, and ecology. Dr. Straw serves as senior overall peer, technical, and editorial 
reviewer for this document, and as the FEMA environmental determination authority for the 
proposed projects. 

Science Kilner, FEMA Region IV, Lead Environmental Specialist and Project Monitor. 

Ms. Kilner has managed and conducted FEMA environmental and cultural resource reviews, 
field surveys, regulatory coordination and compliance, documentation, public involvement, and 
other actions for a wide variety of construction, repair, restoration, reconstruction, elevation, 
upgrade, demolition, and other projects for five years. She has also managed Disaster Field 
Office environmental operations in Florida and other southeastern states; and helped develop and 
revise agency environmental and cultural resource policies, procedures, and training courses at 
the regional and national levels. Her 10-year career includes five years as a cultural resources 
consultant in the Southeastern U.S. Ms. Kilner holds a bachelors degree in archaeology and a 
graduate degree in environmental planning. Her specialized experience includes managing and 
preparing NEPA, ESA Section 7, and NHPA Section 106 regulatory compliance documents. 
Ms. Kilner serves as overall peer, technical, and editorial reviewer for this document; and as aide 
and advisor to the Regional Environmental Officer. 

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Carney, Patricia. 2001. Consulting Engineer. Post, Buckley, Schuh, and Jernigan. Personal 
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English, D.B.K., W. Kriesel, V.R. Leeworthy, and P. Wiley. 1996. Economic contribution of 
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Fernandez, E. David. 2001. Utilities Director, Utilities Department, City of Key West. Personal 
communication with Jonathan Randall, URS Group, Inc. 

Fleisher, J. et al. 1998. Estimates of the Severity of Illnesses Associated with Bathing in Marine 
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Florida Committee on Rare and Endangered Plants and Animals (FCREPA). 1992a. Rare and 
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_______. 1992b. Rare and Endangered Biota of Florida, Volume II. Fishes. University Press of 
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_______. 1992c. Rare and Endangered Biota of Florida, Volume III. Amphibians and Reptiles. 
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Florida Department of Environmental Protection (FDEP). 2002. Everglades Restoration 
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_______. 2001a. Wastewater: Underground Injection Control Program. Accessed from 
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_______. 2001b. Drinking Water: Miscellaneous Contaminants. September 25. Assessed from 
http://www.dep.state.fl.us/water/ drinkingwater/st_misc.htm on March 13, 2002. 

_______. 2001c. Wastewater: UV Disinfection of Wastewater. October 10. Assessed from 
http://www.dep.state.fl.us/water/wastewater/dom/domuv.htm on March 15, 2002. 

_______. Division of Air Resource Management. 2000. EPA Aerometric Information Retrieval 
System (AIRS), Air Quality Subsystem, Quick Look Report. Accessed from 
http://www.dep.state.fl.us/air/info/allsum/all00.htmon September 14, 2001. 

_______. 1999. Air Monitoring Report, Division of Air Resource Management. Accessed from 
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Florida Department of Health (FDH). 2001a. Florida Administrative Code, Chapter 64E-5, 
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Florida Department of Health (FDH). 2001b. Public Health Indicators System. Accessed from 
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Florida Department of Historic Resources (FDHR). 2001. Florida Historical Context. Accessed 
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Florida Keys Aqueduct Authority (FKAA). 2001a. System Overview. Accessed from 
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______.2001b. Personal communication with Joyce Friedenberg, URS Group, Inc. November 2. 

______2002. Project Feasibility Report Regarding The Marathon Central Wastwater Facilities 
Program . Faxed to Joyce Friedenberg by Jack Teague, July 1. 

Florida Keys Electric Cooperative (FKEC). Information, 2000. Accessed from 
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Florida Keys National Marine Sanctuary (FKNMS). 2001. Water Quality Protection Program 
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_______. 1998. Ocean Planning and Governance Geographic Information System. National 
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Garrett, George. 2001. Director of Marine Resources, Monroe County. Personal communication 
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Griffin, Dale W., Gibson III, Charles J., Lipp, Erin K., Riley, Kelley, Paul III, John H., and Rose, 
Joan B. 1999. Detection of Viral Pathogens by Reverse Transcriptase PCR and Microbial 
Indicators by Standard Methods in the Canals of the Florida Keys. Applied and 
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Halley, R.B., Vacher, H.L., and Shinn, E.A., 1997, Geology and hydrology of the Florida Keys 
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Hallock, P., Muller-Karger, F.E., Halas, J.C. 1993. Coral Reef Decline. National Geographic 
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Islamorada, Village of. 2001c. Wastewater Treatment System Conceptual Design Report  
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Jaap, W.C. 1984. The ecology of the south Florida coral reefs: a community profile. U.S. Fish 
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Jetton, Rebecca. 2001. Planning Manager, Marathon Regional Service Center, Florida 
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Johnson, A.F. and M.B. Barbour. 1990. Dunes and maritime forests. Pp 429-480 In: R.L. Myers 
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Johnsons Insurance 2002. Customer service representative. Personal correspondence with Joyce 
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Jones, Ronald and Joseph Boyer. 2001. Water Quality Monitoring Project: FY 2000 Annual 
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Key Haven Utilities. 2002. Personal communication with Joyce Friedenberg of URS Group, Inc. 
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Key West, The City of. 2002. David Fernandez, Utilities Director. Personal communication with 
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The Key West Citizen. 2001. Classified page. http://keysnews.com Accessed November 2, 2001. 

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Kozma, Danah. 2001. Representative, Monroe County Tourist Development Council. Personal 
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Kruczynski, William. 1999. Water Quality Concerns in the Florida Keys: Sources Effects, and 
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Lazar, Ann. 2001. Department of Community Affairs. Personal communication with Sonya 
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Leckler, Kurt. 2001. Permit Compliance Specialist, South Florida Water Management District. 
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Leeworthy, V.R. and P. Wiley. 1996. Importance and Satisfaction Ratings by Recreating Visitors 
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Miller, J.A. 1986. Hydrogeologic Framework of the Floridian Aquifer Systemin Florida and in 
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Molins, Delphin. 2001. Florida Department of Transportation, Community Awareness Program 
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_______. 2001b. District-level data on property taxes. Monroe County Property Appraiser. 

_______. 2000a. Monroe County Sanitary Wastewater Master Plan. Volume 1. Submitted by 
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_______. 2000b. Monroe County Population, Estimates and Forecasts 1990 to 2015. Published 
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_______. 1997. Monroe County Year 2010 Comprehensive Plan. Adopted by the Monroe 
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_______. 1999. Commercial Fishing in the Florida Keys. Accessed from 
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Nelson, G. 1994. The Trees of Florida: A Reference and Field Guide. Pineapple Press, Sarasota, 
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Nobles, Robert E., Perry Brown, Joan Rose, Erin Lipp. 2000. The Investigation and Analysis of 
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Noise Center of the League. 2001. Noise Levels in Our Environment Fact Sheet. Updated 
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Noise Pollution Clearinghouse (NPC). 2001. Protective Noise Levels. Accessed from 
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Ocean Reef Club, The. 2002. Personal communication with Joyce Friedenberg of URS Group, 
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