DRAFT  
SUPPLEMENTAL ENVIRONMENTAL 
ASSESSMENT



Proposed Wastewater Treatment System for  
Key Largo Park and Key Largo Trailer Village
Key Largo Wastewater Treatment District,
Monroe County, Florida



 




Prepared for
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


November 20, 2003

TABLE OF CONTENTS
Abstract	iv
Section 1 	Introduction	1-1
1.1	Project Authority	1-1
1.2	Related Environmental Documents	1-1
1.3	Project Location	1-2
1.4	Purpose and Need	1-2
Section 2 	Alternatives Analysis	2-1
2.1	Alternative 1  No Action Alternative	2-1
2.2	Alternative 2  New Wastewater Treatment Plant on Northern Site (Proposed)	2-1
2.2.1	Wastewater Collection System	2-4
2.2.2	Wastewater Treatment Plant	2-8
2.3	Alternative 3  New Wastewater Treatment Plant on Southern Site	2-12
2.3.1	Wastewater Collection System	2-12
2.3.2	Vacuum Pump Station	2-13
2.3.3	Wastewater Transmission System	2-14
2.3.4	Wastewater Treatment Plant Southern Site	2-15
2.4	Alternatives Considered but Eliminated from Further Consideration	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
3.1.2	Soils	3-1
3.1.3	Geology	3-3
3.2	Water Resources and Water Quality	3-4
3.2.1	Groundwater	3-4
3.2.2	Inland, Nearshore, and Offshore Waters	3-5
3.2.2.1	Inland Waters	3-5
3.2.2.2	Nearshore and Offshore Marine Waters	3-5
3.2.2.3	Stormwater	3-6
3.2.3	Floodplains and Wetlands	3-7
3.2.3.1	Floodplains	3-7
3.2.3.2	Wetlands	3-8
3.3	Biological Resources	3-10
3.3.1	Terrestrial Ecosystem	3-11
3.3.1.1	Pine Rocklands and Tropical Hardwood Hammocks	3-12
3.3.1.2	Mangrove Forests and Salt Marshes	3-12
3.3.1.3	Freshwater Systems	3-13
3.3.1.4	Dunes and Coastal Ridges	3-13
3.3.2	Aquatic Ecosystem	3-13
3.3.2.1	Seagrass Beds and Sand Flats	3-13
3.3.2.2	Coral Reefs	3-14
3.3.2.3	Hardbottom	3-15
3.3.2.4	Sandy Bottom	3-15
3.3.2.5	Alternative 1  No Action Alternative	3-15
3.3.2.6	Alternative 2  New Wastewater Treatment Plant on Northern Site	3-15
3.3.2.7	Alternative 3  New Wastewater Treatment Plant on Southern Site	3-16
3.3.3	Special Status Species	3-17
3.3.3.1	Alternative 2  New Wastewater Treatment Plant on Northern Site	3-18
3.3.3.2	Alternative 3  New Wastewater Treatment Plant on Southern Site	3-19
3.4	Air Quality	3-20
3.5	Cultural Resources	3-20
3.6	Socioeconomic Resources	3-23
3.6.1	Tourism	3-23
3.6.2	Fishing Industry	3-25
3.6.3	Local Fees and Taxes	3-25
3.6.3.1	Existing Wastewater Management Costs in the KLTV and KLP Service Area	3-25
3.6.4	Public Health	3-27
3.7	Demographics and Environmental Justice	3-28
3.7.1	Population and Race	3-28
3.7.2	Income and Poverty	3-29
3.8	Hazardous Materials and Wastes	3-32
3.9	Infrastructure	3-33
3.9.1	Traffic and Circulation	3-33
3.9.2	Utilities and Services	3-34
3.10	Land Use and Planning	3-34
3.11	Noise and Visual Resources	3-38
3.11.1	Noise	3-38
3.11.2	Visual Resources	3-40
Section 4 	Cumulative Effects	4-1
4.1	Topography, Soils and Geology	4-1
4.2	Water Resources and Water Quality	4-1
4.3	Biological Resources	4-1
4.4	Air Quality	4-2
4.5	Cultural Resources	4-2
4.6	Socioeconomics	4-2
4.7	Demographics and Environmental Justice	4-2
4.8	Hazardous Materials and wastes	4-3
4.9	Infrastructure	4-3
4.10	Land Use and Planning	4-3
4.11	Noise and Visual Resources	4-3
Section 5 	Public Participation	5-1
Section 6 	Mitigation Measures and Permits	6-1
6.1	Mitigation	6-1
6.2	Permits and Licenses	6-1
Section 7 	Consultations and References	7-1
Section 8 	List of Preparers	8-1



Tables
Table 2-1	Service Area Flow & Equivalent Dwelling Units (EDU) Estimates
Table 3-1 	FDEP Injection Well Forms 
Table 3-2	Observed Plant Species
Table 3-3	Project Area Businesses
Table 3-4	Fiscal Year 2003  HUDs Low-Income and Very Low-Income Limits, Monroe 
County, Florida
Table 3-5	Alternatives 2 and 3 Low-Income and Very Low-Income Funding Assistance for 
the System Capital Cost 

Figures
Figure 1-1	Project Vicinity Map
Figure 2-1	Key Largo Wastewater Service District
Figure 2-2	Alternative 2 Wastewater Treatment Plant (WWTP) Site Location Map
Figure 2-3	Typical Building Construction
Figure 2-4	Alternative 2 WWTP Site
Figure 2-5	Proposed Key Largo WWTP Site Preliminary Drawings
Figure 2-6	Alternative 3 WWTP Site Location Map
Figure 2-7	Vacuum Pump Station Preliminary Drawings
Figure 2-8	Alternative 3 WWTP Site
Figure 3-1	Project Area Soils
Figure 3-2	Project Area Floodplains
Figure 3-3	Project Area Vegetation
Figure 3-4	Project Area Benthic Habitats
Figure 3-5	Project Area Land Use

Appendices
Appendix A	Acronyms and Abbreviations
Appendix B	Agency Coordination Letters
Appendix C	Site Photographs
Appendix D	Public Notice
Appendix E	Public Comments
Appendix F	Regulated Keys Fisheries Species
Appendix G	Key Largo Cultural Resources Consultation Correspondence
Appendix H	Biological Assessment for the Wastewater Treatment Plant Site  Mile Marker 
100.5, Key Largo, Florida
Appendix I	U.S. Fish and Wildlife Service Biological Opinion
Appendix J	Key Largo Wastewater Treatment District Low Income Assistance 
Program


ABSTRACT
In response to damages and losses from Hurricane Georges, Congress enacted Public Law 106-
31, Emergency Supplemental Appropriations Act for Fiscal Year 1999, to fund long-term 
disaster recovery projects in Florida counties whose needs were unmet through primary disaster 
relief funds. Monroe County was included among the counties eligible for Unmet Needs 
funding and requested that wastewater management improvement projects be considered for this 
funding since many existing wastewater facilities in the county are not storm-resistant. 
Since then, the Federal Emergency Management Agency (FEMA) has received a grant 
application from the Florida Keys Aqueduct Authority, prepared in coordination with Monroe 
County and the Key Largo Wastewater Treatment District (KLWTD), requesting Federal 
assistance to build a new wastewater treatment plant (WWTP) to service two communities, Key 
Largo Trailer Village and Key Largo Park, in Key Largo in the Upper Keys. FEMA prepared this 
draft Supplemental Environmental Assessment to address the likely effects of implementing 
three alternatives proposed in Key Largo. The alternatives evaluated in this document include:
Alternative 1  No Action Alternative
FEMA would not fund any wastewater treatment project within Key Largo. Alternate funding 
sources (such as other grants) would be needed to finance the large capital costs of constructing a 
wastewater treatment system to meet the Florida Statutory Treatment Standards by 2010. Until 
alternate funding is secured, environmental degradation would continue.
Alternative 2  Centralized Wastewater Treatment Plant, Northern Site Alternative 
(Proposed)
The KLWTD would use FEMA funding to install a wastewater collection system and build a 
new community WWTP on the ocean side of U.S. Route 1 at about Mile Marker (MM) 100.5. 
This site is about 2.6 acres. Wastewater effluent would be collected through a vacuum pump 
system. Following tertiary treatment, wastewater effluent would be disposed through two 
shallow injection wells. KLWTD would be responsible for facility construction, operation, and 
maintenance.
Alternative 3  Centralized Wastewater Treatment Plant, Southern Site Alternative
The KLWTD would use FEMA funding to install a wastewater collection system, build a 
vacuum pump station (VPS) at MM 100.5, install a wastewater transmission system between the 
VPS and WWTP, and build a new community WWTP at MM 98. This site is about 3 acres. 
Following tertiary treatment, wastewater effluent would be disposed through two shallow 
injection wells. The KLWTD would be responsible for facility construction, operation, and 
maintenance.
Alternatives 2 and 3
For both Alternative 2 and Alternative 3, potential project effects on topography, soils, and 
geology; wetlands and floodplains; hazardous materials and wastes; infrastructure; land use and 
planning, noise and visual resources within the project areas are expected to be minor. 
Appropriate mitigation measures would reduce any potential adverse effects of the project 
alternatives on these resources. Effects on water resources and water quality, marine biological 
resources, and public health are anticipated to be beneficial. Effects on air quality and cultural 
resources would be negligible. Adverse socioeconomic effects would be mitigated with the use 
of FEMA grant funding, making the system capital costs associated with Alternatives 2 and 3 
affordable to service recipients. Moreover, to further reduce adverse economic effects to low-
income service recipients, an assistance program has been developed to ensure wastewater costs 
are not disproportionately high or adverse to this population.
Under Alternative 2, adverse effects on terrestrial biological resources and special status species 
from WWTP construction would be mitigated through a conservation easement on 19 acres of 
high-quality hardwood hammock; tree transplanting plans; restoring 2.6 acres of hardwood 
hammock; and compliance with Florida Department of Environmental Protection Environmental 
Resource Permits, Monroe County Land Development regulations, and with the U.S. Fish and 
Wildlife Service Biological Opinion.
Under Alternative 3, effects on terrestrial biological resources are expected to be minor. 
Appropriate mitigation measures would reduce any potential adverse effects.



Section 1 Introduction
1.1	PROJECT AUTHORITY
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. Congress allocated the funds to assist 
counties whose needs were not met through allocation of primary disaster relief funds. The 
Federal Emergency Management Agency (FEMA) earmarked this Unmet Needs money for the 
counties most impacted by Hurricane Georges, including Monroe County. FEMA, the 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 wastewater treatment, and contribute to degraded water quality 
in the Keys. Since then, the Florida Keys Aqueduct Authority (FKAA), through the State of 
Florida Department of Community Affairs (DCA), has applied for FEMA funding assistance to 
build a wastewater treatment system that would service Key Largo Trailer Village (KLTV). It 
should be noted that although the FKAA initiated the funding request, the Key Largo 
Wastewater Treatment District (KLWTD) would implement the project, as it is now the 
wastewater authority for Key Largo. Moreover, the FEMA-funded wastewater treatment plant 
(WWTP) would also provide service to Key Largo Park (KLP), whose wastewater collection 
system is being funded by the Florida Department of Environmental Protection (FDEP). The 
project is intended to improve wastewater treatment and ultimately water quality in the Florida 
Keys, and assist residents in meeting State-mandated water quality targets as set forth in the 
Florida Statutory Treatment Standards of 2010. Specifically, wastewater treatment systems must 
treat discharge to advanced wastewater treatment (AWT) or best available technology (BAT) 
standards. For facilities that treat over 100,000 gallons per day (gpd), the AWT standards are 5 
mg/L Biological Oxygen Demand (BOD), 5 mg/L Total Suspended Solids (TSS), 3 mg/L Total 
Nitrogen (TN), 1 mg/L Total Phosphorus (TP); and for facilities treating less than 100,000 gpd 
the BAT standards are 10 mg/L, 10 mg/L, 10 mg/L, and 1 mg/L, respectively.
1.2	RELATED ENVIRONMENTAL DOCUMENTS
URS Group, Inc. (URS) prepared a Programmatic Environmental Assessment (PEA) for FEMA 
in accordance with the National Environmental Policy Act (NEPA), the Council on 
Environmental Quality (CEQ) regulations implementing NEPA (40 Code of Federal Regulations 
[CFR] 1500-1508), and FEMA regulations (44 CFR Part 10, Environmental Considerations). 
These laws and regulations require FEMA to take into account environmental considerations 
when funding any Federal actions. The PEA, finalized on December 23, 2002, provides a 
framework to address impacts associated with a range of wastewater treatment projects in the 
Florida Keys. PEA Section 1.7 (Water Quality Protection Measures at the Local, State, and 
Federal Levels) provides a more detailed discussion of water quality protection measures at 
Federal, State, and local levels.
This Supplemental Environmental Assessment (SEA) tiers from the PEA for Wastewater 
Management Improvements in the Florida Keys (URS, 2002a) and hereby incorporates the PEA 
by reference, in accordance with 40 CFR Part 1508.28.
1.3	PROJECT LOCATION
The project areas encompass the neighborhoods of KLTV and the KLP (the service area), 
portions of the U.S. Route 1 (US-1) right-of-way (ROW), the proposed wastewater treatment 
plant (WWTP) site at Mile Marker (MM) 100.5, and the alternate site at MM 98, which are all 
located in the central portion of Key Largo, in part of the Florida Keys chain known as the Upper 
Keys (Figure 1-1). US-1, the main thoroughfare in the Keys, bisects Key Largo into the ocean 
side and the bay side. Although artificial waterways have been constructed on both sides of the 
island, most of the land is on the ocean side (Figure 1-1). The project areas are located in 
Sections 33, 32, 28, 29, and 6; Township 61 South; and Range 39 East.
1.4	PURPOSE AND NEED
PEA Section 1.9 (Purpose and Need for Action) describes the purpose and need for action. In 
particular, the purpose of the KLWTD project is to reduce wastewater nutrient loading at 
selected Monroe County hot spots, thereby improving water quality. These hot spots are 
believed to contribute to water quality degradation. 
As described in PEA Section 2.1 (Alternative Development Background), hot spots represent 
priority areas where the high concentration of people and poor existing wastewater treatment 
practices justify the installation of a more advanced wastewater treatment system within that 
area. In 2000, the Monroe County Sanitary Wastewater Master Plan (MCSWMP) ranked the 
KLTV as the second most critical hot spot in the Upper Keys, and the fourth most critical hot 
spot Keys-wide. KLP is ranked 15th in the Upper Keys and 27th Keys-wide (PEA Appendix C, 
Hot Spot Locations). The hot spot ranking is linked to the use of cesspools and septic systems 
as the primary wastewater treatment systems at KLP and KLTV.


 
[Figure 1-1. Project Vicinity Map
Figure 1-1 shows the proposed and alternate project location sites on Key Largo.]


Section 2 Alternatives Analysis
NEPA, CEQ regulations implementing NEPA (40 CFR Parts 1500 to 1508), and FEMA 
regulations for environmental compliance (44 CFR Part 10) direct FEMA to investigate and 
evaluate project alternatives. FEMA evaluated alternatives identified in the Monroe County 
Sanitary Wastewater Master Plan (2000) and in the PEA for the proposed Key Largo Wastewater 
Management System. In the following sections, FEMA considered and evaluated three 
alternatives in detail: No Action, New Wastewater Treatment Plant on Northern Site (MM 
100.5), and New Wastewater Treatment Plant on Southern Site (MM 98). While FEMA funding 
would be applied only to the KLTV collection system and WWTP construction, this document 
considers the effects to the KLP service area as well because it will be served by the same 
WWTP. These are viewed as connected actions under NEPA, despite separate funding. FDEP 
will fund the KLP collection system.  
2.1	ALTERNATIVE 1  NO ACTION ALTERNATIVE
As discussed in PEA Section 2.3.1 (No Action Alternative), FEMA would not provide funding 
assistance to the KLWTD for the proposed action. In order to meet Florida Statutory Treatment 
Standards of 2010, KLWTD and service area residents and businesses would need to identify 
another funding source for upgrading currently inadequate wastewater treatment systems.
2.2	ALTERNATIVE 2  NEW WASTEWATER TREATMENT PLANT ON NORTHERN 
SITE (PROPOSED)
PEA Section 2.3.3 (Centralized Wastewater Treatment Plant Alternative) describes Alternative 
2. KLWTD would use FEMA funds to build a wastewater collection system, vacuum pump 
station (VPS), and wastewater treatment plant (WWTP) in Key Largo (Figure 2-1). 
 
[Figure 2-1. Key Largo Wastewater Service District (Boyle, 2003)
Figure 2-1 shows the Key Largo wastewater service district, including the Key Largo Trailer 
Village and Key Largo Park service areas.]


Table 2-1. Service Area Flow and EDU Estimates (Boyle, 2003)
Design Parameter
Units
Key Largo Park Flow 
Contribution1
Key Largo Trailer Village Flow Contribution

Total



Residential
Commercial
Subtotal



Developed
Future
Subtotal
Developed
Future
Developed
Future


No. of Equivalent 
Dwelling Units (EDUs)
N/A
226
57
283
445
5
61
56
567
850
Flow Contribution per 
EDU @ Maximum Month 
Average Daily Flow 
(MMADF)
gpd/EDU
232.5
232.5
N/A
201
201
232.5
232.5
N/A
216
MMADF/Annual 
Average Daily Flow 
(AADF) Factor
N/A
1.5
1.5
N/A
1.5
1.5
1.5
1.5
N/A
1.5
Flow Contribution per 
EDU @ AADF
gpd/EDU
155
155
N/A
134
134
155
155
N/A
144
MMADF
gpd
52,545
13,253
65,798
89,445
1,005
14,183
13,020
117,653
183,450

gallons per 
minute (gpm)
36
9
46
62
1
10
9
63
127
AADF
gpd
35,030
8,835
43,865
59,630
670
9,455
8,680
78,435
122,300

gpm
24
6
30
41
0
7
6
42
85
Peak Hour/AADF 
Peaking Factor for Peak 
Hour
N/A
3.75
3.75
N/A
3.75
3.75
3.75
3.75
N/A
3.75
Peak Hour without 
Equalization
gpd
131,363
33,131
164,000
223,613
2,513
35,456
32,550
226,000
459,000

gpm
91
23
114
155
2
25
23
157
319
Flow Contribution per 
EDU @ Peak Hour
gpd
581
581
N/A
503
503
581
581
N/A
540
1 Key Largo Park EDU count total includes 23 EDUs (20 developed + 3 future) from the Sunset Waterways subdivision.


The VPS and WWTP would be built at MM 100.5. KLWTD would design the proposed WWTP 
to meet the Florida Statutory Treatment Standards of 2010 for effluent disposal to shallow 
injection wells.  The new system would serve about 426 mobile homes, single family homes, 
multi-family homes, commercial buildings, and vacant lots (parcels) (FKAA, 2002).
KLWTD would implement the proposed Key Largo WWTP in two phases. Phase I would have a 
design capacity of about 150,000 gpd and would provide new service to residents and business 
owners in KLTV and KLP (FKAA, 2002). Wastewater flows for residences and businesses in the 
Phase I service area, obtained from the MCSWMP (Monroe County, 2000; Boyle, 2003), were 
used to estimate the number of equivalent dwelling units (EDUs), as summarized in Table 2-1. 
The 426 parcels equal about 850 EDUs. Based on estimates of the developed and future EDUs 
within the Phase I service area, the total estimated annual average daily flow (AADF) was 
calculated as 122,300 gpd (Boyle, 2003). The flow from the developed EDUs is about 104,000 
gpd or 69 percent of the plants Phase I capacity. Consequently, about 46,000 gpd AADF, or 31 
percent of the WWTP capacity, is available for future connections. The plant capacity available 
for future connections is not strictly allocated to the KLTV and/or KLP service areas and could 
be available to other areas.
KLWTD designed the Phase I WWTP with the potential for expansion in modular increments to 
the Phase II capacity of 2.25 million gallons per day (MGD). Should funding become available, 
the Phase II WWTP would be capable of serving the entire Key Largo Wastewater Service 
District that extends from about MM 91 to MM 106.5 (Figure 2-1) (FKAA, 2002).
Build-out flow estimates for the entire Key Largo Wastewater Service District are:
	EDUs	2,430 units
	AADF	377,000 gpd
	MMADF	565,000 gpd
	Peak Hour Flow 	1,413,750 gpd
About 467 cesspools and septic systems currently utilized by property owners in the Key Largo 
Phase I service area would be removed (FKAA, 2002). Pursuant to the Florida Department of 
Health (DOH) requirements, each property owner would be responsible for decommissioning 
and abandoning his/her existing on-site system.
2.2.1	Wastewater Collection System
KLWTD would place wastewater collection mains within the limits of public road rights-of-way 
(ROW) throughout the service area in front of the residences and businesses to be served (Figure 
2-2). The streets within the KLTV subdivision consist of paved roads with platted ROW widths 
between 40 and 50 feet (FKAA, 2002). Most construction would be done on one side of the road, 
reducing traffic disruption. In some cases, KLWTD would place the wastewater collection mains 
on the opposite side of the ROW from an existing potable water main. Separate collection 
systems would serve KLTV and KLP. KLWTD would provide vacuum collection main stub-outs 
to the existing residential side streets on the bay side (west) of US-1 to facilitate the future 
extension of wastewater collection and transmission services to the KLP and Sunset Waterways 
subdivisions.

  
[Figure 2-2. Alternative 2 Wastewater Treatment Plant (WWTP) Site Location Map
Figure 2-2 shows the location of the Alternative 2 wastewater treatment plant, including the 
plant site and collection system.]  


A transmission main about 4,800 feet long would convey wastewater from the KLTV to the 
WWTP. KLWTD would install the transmission main along the northern ROW of US-1 and 
would also serve existing commercial property along US-1. Service laterals consisting of 
polyvinyl chloride (PVC) pipe would be provided up to the ROW line (Figures 2-3a and b). 
Property owners would be responsible for constructing individual connections to the service 
laterals. Special plumbing fixtures or electrical connections would not be required at houses or 
mobile homes; existing fittings are adequate. KLWTD would excavate about 1,800 cubic feet of 
soil for the installation of vacuum sewer mains, vacuum pits, buffer tanks, and gravity service 
laterals. The majority of the excavated material would be used as backfill material for pipe and 
vacuum pit excavations. Excess excavated material would be used for foundations and grading at 
the treatment plant site.

 
[Figure 2-3a. Typical Building Connection (Plan View)
Figure 2-3a is a plan view of a typical service lateral connection from residence to wastewater 
collection system.]
 
[Figure 2-3b. Typical Building Connection (Profile Detail)
Figure 2-3b is a profile view of a typical service lateral connection from residence to wastewater collection system.]


The proposed collection system would consist of a vacuum sewer system with gravity collection 
mains and/or service laterals, sewage holding sumps and vacuum valve pits, vacuum collection 
mains and a VPS building, as described in PEA Section 2.3.2.1.1 (Vacuum Pumping). 
Residential sewage would flow by gravity into a vacuum valve pit, the lower portion of which is 
a fiberglass holding sump and the upper portion of which includes a vacuum valve. Two or more 
homes would be serviced by one vacuum valve pit. When wastewater in the holding sump rises 
to a preset level, a sensor extending from the valve chamber into the holding sump detects the 
liquid level in the sump, and the vacuum interface valve is pneumatically opened. Differential air 
pressure propels the sewage from the sump through the valve and into 3-inch or larger PVC 
vacuum wastewater collection mains. 
KLWTD would build vacuum mains about 3 feet below existing surface elevation throughout the 
service area. The system would transport wastewater from the collection mains to the wastewater 
collection tank at the VPS by the introduction of air into the collection main from successive 
open/close cycles of the vacuum valves in the system.
A VPS, located within the treatment plant site, would generate the negative pressure necessary 
for the vacuum collection mains. The station would draw raw sewage through the collection 
mains and pump it to the treatment plant. The station would be built as a slab-on-grade building, 
between 1,000 to 3,000 square feet in area, and would have two 430-cubic feet per minute (cfm) 
vacuum pumps, two 320-gpm discharge pumps, a 6,300-gallon collection tank, and an 
emergency generator. Discharge pumps connected to the vacuum collection tank would transfer 
sewage to the treatment plant. The vacuum pumps, operating at about 15 horsepower, could be 
increased to 75 horsepower as total head conditions increase in the transmission force main due 
to flows from future wastewater projects in the Key Largo Wastewater Service District. A 
separate concrete pad external to the station would accommodate odor control equipment (either 
a vapor phase activated carbon filter or a biological filter) for the treatment of air discharged 
from the collection tank by the VPS blowers. Initially the station would have capacity for the 
Phase I service area. Additional equipment (vacuum and discharge pumps) may be added in the 
future to expand service to the entire Key Largo Wastewater Service District.



2.2.2	Wastewater Treatment Plant
KLWTD would build the WWTP on currently undeveloped Monroe County lands, on the ocean 
side of Key Largo at MM 100.5 (Figures 2-2 and 2-4). The proposed plant site is a 1,200-foot by 
1,600-foot by 2,000-foot, triangular, 22-acre open space containing mostly high-quality 
hardwood hammock habitat. KLWTD would build the WWTP on about 2.6 acres, in a roughly 
L-shaped configuration. The remaining 19.4 acres would remain in an undeveloped conservation 
easement. The northwestern property boundary borders US-1, and the southern property 
boundary is adjacent to an existing FKAA facility and undeveloped lands. Private residences are 
about 350 feet west of the site. The Florida Straits are the closest water body to the site, about 
1,500 feet east. Florida Bay is about 2,500 feet west of the site (FKAA, 2002).
 

[Figure 2-4. Alternative 2 WWTP Site
Figure 2-4 is a photograph of the southern edge of the Alternative 2 WWTP site.]
 

The WWTP would provide primary treatment, biological treatment, solids removal, nitrogen and 
phosphorus removal, filtration, effluent disinfection and disposal to shallow injection wells 
(Figure 2-5). Effluent discharged would meet the 2010 Florida Statutory Treatment Standards for 
AWT of 5 mg/L BOD, 5 mg/L TSS, 3 mg/L TN, and 1 mg/L TP. An in-line magnetic flow meter 
would measure, record, and total the amount of raw sewage flow from the pump station into the 
WWTP. Influent wastewater screening (either manual or automatic) would remove large 
particulate matter prior to entering WWTP. KLWTD would collect pretreatment screenings in a 
collection hopper or trash receptacle for collection and hauling to an FDEP-permitted sanitary 
landfill facility for disposal (FKAA, 2002). If necessary, alkalinity of the influent wastewater 
would be buffered using sodium hydroxide. 


[Figure 2-5. Proposed Key Largo WWTP Preliminary Drawings
Figure 2-5 is a site plan of the Alternative 2 WWTP.]


The buffering process would use all available sodium hydroxide; the system would not discharge 
excess sodium hydroxide to the environment. The sodium hydroxide would immediately dissolve 
and be consumed and would no longer be an active compound in the environment (Garcia, Pers. 
Comm., 2003). Components of the sodium hydroxide feed system, if needed, would include 
storage drums, metering pumps, small diameter PVC piping and valves, and a small containment 
area with a concrete slab and curb, electrical power, and controls (FKAA, 2002).
The WWTP would likely treat wastewater using the sequencing batch reactor with aluminum 
sulfate (alum) addition and conventional filters, or the upflow sludge blanket filter process with 
alum addition and conventional filters. Other possible methods of treatment include the modified 
Ludzak-Ettinger process, the Bardenpho process, and the immersed membrane bioreactor. The 
WWTP would use two or three parallel process trains, each with equal-sized biological reactor 
systems, so that if one system were out of service, the remaining train(s) would be capable of 
treating the system design flow (FKAA, 2002).
Additional treatment would include the addition of metal salts, such as alum, sodium aluminate, 
ferric chloride, ferrous chloride, ferric sulfate, or ferrous sulfate to reduce the total phosphorus of 
the wastewater to 1 mg/L. The alum would coagulate excess phosphorus and would be disposed 
of with the decanted sludge (Garcia, Pers. Comm., 2003). KLWTD would dispose of sludge at 
landfills or apply it to designated lands in compliance with local, State, and Federal laws. 
Components of a liquid metal salt feed system would include storage drums, metering pumps, 
small diameter PVC piping and valves, a containment area with a concrete slab and curb, 
electrical power, and controls. The system may also need filtration to produce effluent with TSS 
of not more than 5 mg/L, remove soluble effluent phosphorus concentrations in excess of 1 
mg/L, and remove unsettled phosphorus precipitate discharged from the settling tank. The 
system would need two automatic backwashing filter units. KLWTD would size the units such 
that, with one filter out of service, the remaining unit would have sufficient capacity to receive 
flow equal to not less than 75 percent of the design capacity of the treatment plant (FKAA, 
2002).
Effluent disinfection would occur in a disinfection contact tank using one of three methods: 
calcium hypochlorite tablets or briquettes, commercial grade or on-site generated sodium 
hypochlorite, or ultraviolet radiation. The system would dissolve calcium hypochlorite, and 
sodium hypochlorite dissolved in the effluent stream to render potential biological pathogens 
harmless. The fate of this material would be in the form of dissolved hypochlorite, sodium, and 
calcium ions in the effluent stream. Ultraviolet irradiation, a passive disinfection treatment 
process, does not add materials to the effluent. The system would maintain a minimum 
concentration of 0.5 mg/L total chlorine residual after 15 minutes of contact time at peak hourly 
flow. In recent years, ultraviolet irradiation has become the preferred method of disinfection due 
to the hazards associated with the handling and storage of chlorine (Weiler Engineering, 2003). 
The system would dispose of effluent by gravity flow into two 8-inch-diameter shallow disposal 
wells, cased and grouted to 60 feet below land surface (bls), with a gravel-packed open hole 
section from 60 feet to 90 feet bls. Shallow wells would have a capacity of 400 gpm each. 
KLWTD would also build one 3-inch groundwater monitoring well with a 10-foot bls cased 
depth and a 30-foot bls total depth. The system would direct recycle flows, including filter 
backwash and digester decant, back to the head of the treatment plant for processing (FKAA, 
2002).
Stabilization of residual bio-solids would occur via the aerobic digestion process. An aeration 
system in the aerobic digester would mix and aerate the residual bio-solids. Residual bio-solids 
would return to the plant for treatment. A draw-off pipe located near the base of the tank would 
remove settled bio-solids and sludge from the digester, and the bio-solids and sludge would be 
loaded into tanker trucks for disposal. KLWTD would haul the bio-solids and sludge to one of 
three Monroe County Solid Waste Transfer Stations. The waste would subsequently be trucked 
from the Transfer Station to the Miami-Dade Water and Sewer Department South District 
WWTP, in Florida City. KLWTD would enter into an agreement with the accepting municipality 
prior to WWTP start-up (Shimokubo, Pers. Comm., 2003). Based on the estimated volume of 
excess bio-solids generated by the wastewater treatment process and a maximum thickened 
sludge concentration of 2.0 percent in the aerobic digester, sludge hauling is estimated to be 
required once per month using a 5,000-gallon capacity tanker truck (FKAA, 2002).
The specific solids handling system for the WWTP has not yet been determined. However, 
evaluation and cost comparison for solids handling systems and disposal alternatives typically 
favor belt filter press dewatering, Class B lime stabilization, and truck hauling of cake to land 
application sites as the most favorable treatment and disposal method. Lime stabilization would 
occur at facilities with capacities less than 0.5 MGD as a batch process using bagged lime. 
Facilities with capacities greater than 0.5 MGD would integrate automatic lime storage and feed 
systems (Weiler Engineering, 2003).
In addition to the new treatment plant, other site design elements would include parking and 
paved access roads, as well as storage space for maintenance equipment, treatment chemicals, 
and other operations materials. KLWTD would floodproof or elevate the finished floor elevation 
of buildings subject to occupancy, as well as structures containing electrical equipment or 
process equipment. KLWTD would operate the facility on a permanent basis and would 
automate the system based on pre-set vacuum and collection tank levels. The facility would have 
station controls that are resistant to fire, wind, and flood (FKAA, 2002).
Because the proposed WWTP and service areas are located in the 100-year floodplain, the design 
provisions of the Monroe County Floodplain Ordinance would apply. Furthermore, because of 
Federal funding, per Executive Order 11988 (Floodplain Management), as implemented in 
FEMAs regulations at 44 CFR Part 9, wastewater treatment facilities are considered critical 
facilities and therefore subject to more stringent flood protection requirements. Specifically, 
KLWTD would floodproof the WWTP and its critical operating components to the 500-year 
flood, as outlined at 44 CFR Part 9.11.
KLWTD would construct the WWTP, including sewer line placement, in about 12 months. 
Construction equipment would likely include a backhoe, trenching machine, bulldozer, crane, 
pile driver, drilling rig, front-end loader, street sweeper, boring machine, and paving machine. 
Construction would also require trucks to transport equipment and materials to and from the 
project sites. The proposed site would also have an area that would be used as a temporary 
staging area for construction equipment and building materials. The lifespan of the treatment 
plant would be between 30 and 50 years (FKAA, 2002). 
2.3	ALTERNATIVE 3  NEW WASTEWATER TREATMENT PLANT ON SOUTHERN 
SITE
Alternative 3 is described in PEA Section 2.3.2 (Centralized Wastewater Treatment Plant 
Alternative). KLWTD would apply FEMA funding to build a VPS at MM 100.5, and a 
wastewater transmission system (WTS) extending from the VPS to a new community WWTP at 
MM 98.0 (Figure 2-6).
 

[Figure 2-6. Alternative 3 WWTP Site Location Map
Figure 2-6 shows the layout of the Alternative 3 wastewater treatment system, including the WWTP 
site, the VPS site and the collection system.]  

The basis of design for this alternative is similar to that used for Alternative 2. The total 
estimated AADF for the Phase I service area would be 122,300 gpd, with an ultimate plant 
capacity of 2.25 MGD. As in Alternative 2, about 467 on-site septic systems currently utilized by 
property owners in KLTV and KLP would be removed. Pursuant to the Florida DOH 
requirements, each property owner would be responsible for decommissioning and abandoning 
his/her existing on-site septic systems (FKAA, 2003).
Construction of the WWTP, including sewer line replacement, would take about 12 months. 
Construction equipment would likely include a backhoe, trenching machine, bulldozer, crane, 
pile driver, drilling rig, front-end loader, and street sweeper. Trucks would also be used to 
transport equipment and materials to and from work sites. The lifespan of the treatment plant 
would be between 30 and 50 years (FKAA, 2002).
2.3.1	Wastewater Collection System
The collection system would be similar to the one described in Section 2.2.1. Separate collection 
systems would serve the KLTV and KLP areas. (Figure 2-6). As in Alternative 2, a force main of 
about 4,800 linear feet would convey wastewater from the KLTV to the pump station. KLWTD 
would locate the pump station at the proposed Alternative 2 treatment plant site, as described 
further in Section 2.2.2 of this document. KLWTD would provide service laterals, for connection 
to the collection system by residents, up to the property ROW line (Figures 2-3a and b). As in 
Alternative 2, connection to the collection system would be the responsibility of the property 
owner. The wastewater collection system would not require special plumbing fixtures or 
electrical connections because existing fittings are adequate.
2.3.2	Vacuum Pump Station
KLWTD would locate the VPS in the southwest corner of the WWTP site as described in 
Alternative 2 (Section 2.2.1; Figure 2-6). Site design elements would include the new pump 
station, influent vacuum mains, and discharge yard piping, site access, parking, and landscaping. 
The building size would be about 500 square feet. Equipment housed in the VPS would include 
two 430-cfm vacuum pumps, two 320-gpm discharge pumps, a 6,300-gallon collection tank, and 
an emergency generator (Figure 2-7). Vacuum blowers would create a vacuum of about 16 to 20 
inches of mercury or 0.53 to 0.67 atmospheres, capable of extracting wastewater from the 
vacuum valve pits through the collection mains into the tank. The tank would provide adequate 
storage to allow the sewage pumps to operate. Vacuum pumps, operating at about 15 
horsepower, would be capable of pumping about a 320-gpm peak hour wastewater flow rate, 
with one pump operational at peak hour flow and the second pump serving as a backup. The 
vacuum pumps could be increased to 75 horsepower as total head conditions increase in the 
transmission force main due to flows from future wastewater projects in the Key Largo 
Wastewater Service District. 
 

[Figure 2-7. Vacuum Pump Station Preliminary Drawings
Figure 2-7 is a diagram of the Vacuum Pump Station components.]


Wastewater discharge pumps would direct flow accumulated in the vacuum collection tank to the 
force main transmission system and ultimately to the new WWTP at MM 98.0. Each pump 
would be capable of about a 320-gpm peak hour wastewater flow. The VPS would utilize 
submersible pumps since they would be susceptible to inundation. To minimize odors, air 
discharged from the blower exhaust at the VPS would run through a filter such as an in-ground 
wood chip bed or packaged iron filings bed before emission. A separate concrete pad external to 
the station would accommodate odor control equipment for the treatment of air discharged from 
the collection tank by the VPS blowers. Initially the station would have the capacity for the 
Phase I service area; additional equipment (vacuum and discharge pumps) may be added in the 
future to expand service to the entire Key Largo Wastewater Service District.
The building that would permanently house the VPS would consist of a fixed slab-on-grade 
building. KLWTD would floodproof or elevate the finished floor elevation of buildings subject 
to occupancy, as well as structures containing electrical equipment or process equipment to 
provide protection to the 500-year flood. KLWTD would operate the facility on a permanent 
basis and would automate the system based on pre-set vacuum and collection tank levels. The 
facility would have station controls that are resistant to fire, wind, and flood (FKAA, 2002).
2.3.3	Wastewater Transmission System
The transmission main would begin at the pump station and run along US-1 to the new WWTP 
at MM 98.0 (Figure 2-6). The WTS would require about 13,200 linear feet of transmission force 
main, wastewater pumps, 8-inch force mains, transmission main valving, and appurtenances. 
Installation of the force main would require excavation of about 158,400 cubic feet of soil. The 
force main would be located a minimum of 5 feet from the shoulder of the roadway on the 
southern side of US-1. KLWTD would maintain a minimum separation of 10 feet between the 
wastewater force main and potable water mains per FDEP regulations, and clearance from other 
utilities or structures of at least 3 feet would be maintained to avoid interference during 
construction or maintenance. The force main would have isolation valves (plug valves) placed 
about 1,000 to 1,500 feet apart for maintenance and troubleshooting. KLWTD would install air 
release and vacuum valves at high points in the line and downstream of large elevation 
differences, as needed.
Force main routing is expected to be routine (at least 5 feet from the shoulder and consistent line 
and grade); however, the US-1 corridor is well developed, and most utilities are routed along this 
corridor either underground or aboveground on poles. Where necessary, conflicts with existing 
utilities and structures would be avoided by deflecting the pipeline route. Deflections and 
adjustments would require additional pipeline fittings, conflict structures, and use of US-1 which 
would include additional traffic control and roadway restoration. Approvals for working within 
the US-1 ROW would be obtained from the Florida Department of Transportation. Pipeline 
construction would follow the ROW of US-1 between MM 100.5 and MM 98. Pipelines would 
be installed pursuant to typical underground utility installation that includes well-bedded high-
grade PVC pipe with at least 36 inches of properly compacted select fill. 
2.3.4	Wastewater Treatment Plant Southern Site
Assuming successful acquisition, the wastewater treatment plant would be constructed on 
currently developed land on the ocean side of Key Largo at MM 98.0 (Figure 2-8). The proposed 
plant site is about 3.8 acres, and about 200 feet wide by 900 feet long, and is cleared of native 
vegetation.  The site has been developed for boat and vehicle storage and miscellaneous usage. 
The western property boundary is along US-1; the northern and southern property boundaries 
border on undeveloped hardwood hammock habitat. The closest private residence is located 
about 100 feet west of the site. The closest water body to the site is the Straits of Florida, 
immediately to the east. Florida Bay is about 1,350 feet west of the site.
 

[Figure 2-8. Alternative 3 WWTP Site
Figure 2-8 is a photo of the Alternative 3 WWTP site, showing the cleared area used for boat and 
vehicle storage.]


The basis of design and activities for building the alternate WWTP would be the same as those 
detailed for the northern WWTP site (Section 2.2.2). 
2.4	ALTERNATIVES CONSIDERED BUT ELIMINATED FROM FURTHER 
CONSIDERATION
Other technology alternatives were considered but eliminated from further consideration in PEA 
Section 2.4 (Alternatives Considered but Dismissed). In 2000, Monroe County evaluated a total 
of 15 sites on Key Largo for the WWTP and VPS and determined that the proposed site (MM 
100.5) was most viable, with the MM 98 site as an alternate.  Other site options were eliminated 
from consideration due to market availability issues as described in PEA Section 2.4 
(Alternatives considered but Dismissed). 



Section 3 Affected Environment and Environmental Consequences
This section describes environmental consequences of the No Action Alternative and the two 
action alternatives, and details the potential effects on the project areas physical, natural, 
cultural, and socioeconomic resources. Discussion in this document includes direct, indirect, and 
cumulative effects. 
3.1	TOPOGRAPHY, SOILS, AND GEOLOGY
3.1.1	Topography
Affected Environment
The existing environment is similar to that described in PEA Section 3.1.1.1 (Topography; 
Affected Environment). The highest elevations in the Upper Keys are about 16 to 18 feet above 
mean sea level (amsl) National Geodetic Vertical Datum (NGVD). Elevation in the service areas 
is about 3 to 4 feet amsl. The ground elevation is generally flat with a slight increase near US-1 
(FKAA, 2002). The WWTP sites are relatively flat with little slope.
Environmental Consequences
Under the No Action Alternative, KLWTD would not receive FEMA funds for wastewater 
management. KLTV and KLP residents would still need to comply with Florida Statutory 
Treatment Standards of 2010. It is anticipated that once funding is secured, effects on topography 
would be similar to those under Alternatives 2 and 3.
Topographic effects of Alternatives 2 and 3 would be limited to temporary surface disturbances 
during the wastewater collection and transmission system construction. The Alternative 2 site 
would require site clearing, grubbing, and a possible minor increase elevation to achieve the final 
building grade. The Alternative 3 site may also require placement of clean suitable fill to achieve 
the final building grade. 
Grading, including stormwater management collection, transmission, and retention requirements, 
would permanently change the surface topographic elevation of the sites, but this impact is minor 
because it would not significantly alter the existing flat surface topography of Key Largo.
3.1.2	Soils
Affected Environment
The existing soil conditions are similar to those described in PEA Section 3.1.2.1 (Soils; 
Affected Environment). Per the Farmland Protection Policy Act, there are no prime farmland 
soils on Key Largo. The project sites soil type is the Pennekamp gravelly muck (Figure 3-1). 
Pennekamp Gravelly muck is a well-drained soil found on tropical hammocks in the Upper 
Keys. About 10 percent of the surface of this soil is covered with stones that are predominantly 
10 to 20 inches in diameter. The seasonal high water table is at a depth of about 3.5 to 5.0 feet 
and the soils have a moderately rapid permeability (USDA, 1995). This soil type supports the 
growth of native vegetation. Another soil type in the project areas is the Udorthents-Urban Land 
Complex, which dominates the KLTV project area and coastal portions of KLP. 


[Figure 3-1. Project Area Soils
Figure 3-1 is the soils map for the project area.]


It is moderately well drained, consisting mostly of crushed oolitic limestone or coral rock. 
Udorthents are generally found in constructed upland areas next to water bodies throughout the 
Keys (USDA, 1995). Houses and other urban structures cover most areas with this soil type.
Environmental Consequences
Under the No Action Alternative, KLWTD would not receive FEMA funds for wastewater 
management. KLTV and KLP residents would still need to comply with Florida Statutory 
Treatment Standards of 2010. It is anticipated that once funding is secured, effects on soils 
would be similar to those under Alternatives 2 and 3.
Under both Alternatives 2 and 3, construction would disturb soils. KLWTD would use clean 
suitable fill to achieve the final elevation at the proposed Alternative 2 WWTP site. Fill would 
consist of fine sand, free of rubble, organics, clay, debris, and any other unsuitable material. In 
addition, KLWTD would excavate about 1,800 cubic feet of soil material to install vacuum 
sewer mains, vacuum pits, buffer tanks, and gravity service laterals. Under Alternative 3, 
KLWTD would excavate an additional 158,400 cubic feet of material for the installation of the 
WTS. Most of the excess excavated material would be used for backfill, and the remainder 
would be disposed of in suitable locations off-site.
FEMA recommends the implementation of appropriate best management practices (BMPs), 
development of an approved Erosion and Sediment Control Plan, and use of conventional site 
preparation techniques prior to and during construction to protect area water bodies and canals. 
Planned measures to control sediment from discharge to nearshore surface waters may include, 
but are not limited to, silt dams, barriers, and straw bales placed at the foot of sloped surfaces. 
Planned measures to control soil erosion may include, but are not limited to, grassing, mulching, 
watering, and seeding of on-site surfaces. Site preparation may include grubbing of vegetative 
roots and topsoil materials, followed by surface compaction and fill placement to attain the 
required construction elevation. 
Applying BMPs and appropriate erosion mitigation measures would limit adverse soil effects 
during treatment system construction. Pennekamp gravelly muck and Udorthents-Urban land 
complex soils are well suited for urban development. Overall, no long-term adverse effects on 
soils are anticipated if site soil excavation, disposal, and erosion potential are managed in 
accordance with State standards and applicable BMP and erosion control guidelines.
3.1.3	Geology
Affected Environment
The existing geologic environment is similar to that described in PEA Section 3.1.3.1 (Geology). 
At the project areas, the upper stratum of bedrock is Miami Oolite, a very porous, solution-
riddled, carbonate rock. Results of geotechnical test borings conducted at the proposed 
Alternative 2 WWTP site revealed a surface layer of fine sand with limestone fragments in the 
upper 1 to 5 feet bls, underlain by light tan medium- to well-cemented limestone to a depth of 25 
feet bls. In one soil boring, a layer of peat was encountered at a depth of 2 feet bls. In another 
soil boring, a 1-foot thick layer of red silty clay was encountered at a depth of 2 feet bls. In 
addition, a layer of asphalt was encountered at the surface during another soil boring (Nutting 
Engineers, 2002).  Geotechnical investigations have not been conducted at the Alternative 3 site; 
however, the site geology is expected to be similar.
Environmental Consequences
Under the No Action Alternative, KLWTD would not receive FEMA funds for wastewater 
management. KLTV and KLP residents would still need to comply with Florida Statutory 
Treatment Standards of 2010. It is anticipated that once funding is secured, effects on geology 
would be similar to those under Alternatives 2 and 3.
Both Alternative 2 and 3, with new WWTP construction, would have minor effects on geology. 
KLWTD would excavate soil to install the sewer mains at elevations 0- to 1-foot amsl NGVD 
along service area roads, and to remove existing cesspits and septic systems. 
WWTP construction would require installation of one groundwater monitoring well and two 
shallow wells to dispose of treated wastewater effluent. The shallow injection wells would be 
cased and grouted to 60 feet bls, with a gravel-packed, open-hole section from 60 feet to 90 feet 
bls (PEA Section 2.3.2.2 [Wastewater Treatment Plant Effluent Disposal Options]). The shallow 
wells effects on project site geology are expected to be minor and are discussed in PEA Section 
3.1.3.2.2 (Centralized Wastewater Treatment Plant Alternative). The applicant is responsible for 
obtaining all applicable FDEP permits for Class V shallow injection wells (Table 3-1). 

Table 3-1. FDEP Injection Well Forms
Form Title
Form Number
Application to Construct/Operate/Abandon Class I, III, or V Injection well Systems
62-528.900(1)
Certification of Class V Well Construction Completion
62-528.900(4)
Certification of Monitor Well Completion
62-528.900(10)

As discussed in PEA Section 3.1.3.2.2 (Alternative 2), aside from the potential impacts from 
injection well use, WWTP construction is not expected to adversely affect the project sites 
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 (dissolving). 
In mainland Florida, sinkhole development, especially in areas of declining water tables, has 
been a severe engineering problem. However, on Key Largo, the water table is usually about 5 
feet below the ground surface, and water tables have not been declining (Nutting Engineers, 
2002). Therefore, new and/or expanded sinkholes are not likely to result from either Alternative 
2 or 3.
3.2	WATER RESOURCES AND WATER QUALITY
3.2.1	Groundwater
Affected Environment
The affected groundwater is described in PEA Section 3.2.2.1 (Groundwater). Throughout the 
project areas, the water of the Biscayne Aquifer ranges from brackish to saline and is of little 
potential utility except as input for desalination systems. Freshwater lenses have not been 
documented for the Key Largo area. Groundwater levels at the treatment plant site are usually 
about 5 feet below the existing ground surface (Nutting Engineers, 2002).  Key Largo has 111 
active shallow Class V injection wells throughout the island (U.S. Army Corps of 
Engineers/Florida DCA, 2003). The existing shallow injection wells are for on-site wastewater 
nutrient reduction systems (OWNRS). 
Environmental Consequences
Under the No Action Alternative, KLWTD would not receive FEMA funding for wastewater 
management. Although service area residents would still need to comply with Florida Statutory 
Treatment Standards by 2010, removal of nutrient and pathogen inputs to the shallow 
groundwater of Key Largo would not occur until a funding source is secured. Therefore, local 
groundwater quality improvements would be delayed under the No Action Alternative.
Under both Alternatives 2 and 3, KLWTD would build a new WWTP to meet Florida Statutory 
Treatment Standards of 2010. Treated effluent would still have some nutrients, even under 
conditions that meet the Florida Statutory Treatment Standards. However, by removing the septic 
and cesspool systems, Alternatives 2 and 3 would reduce the overall nutrient and pathogen inputs 
to the shallow groundwater of the island, and overall local groundwater quality would improve. 
An analysis performed for a representative service area of the Keys demonstrated that 
wastewater treated to AWT standards would reduce the TN and TP concentrations in treated 
effluent by about 92 and 86 percent, respectively (PEA Appendix D [Water Quality 
Improvements Analysis]). In comparison, wastewater treated by septic systems reduces TN and 
TP concentrations by only 4 and 15 percent, respectively (Kruczynski, 1999).
3.2.2	Inland, Nearshore, and Offshore Waters
Affected Environment
The project area surface water resources include (1) canals for boat access to marinas and 
residential developments; (2) stormwater runoff to ditches and drainage systems in developed 
areas; and (3) nearshore and offshore marine waters.
3.2.2.1	Inland Waters
Inland waters in the project areas include artificial canals and enclosed water bodies, as 
described in PEA Section 3.2.3.1.1 (Inland Waters). About 10 artificial water bodies are in the 
KLTV project area. No artificial water bodies are in the KLP project area. 
During a review of Outstanding Florida Waters in the Florida Keys, canals and other confined 
water bodies showing signs of eutrophication were listed as Hot Spots (refer to PEA Appendix 
C [Hot Spot Locations]). Monroe County (2000) ranked the KLTV as the second and fourth most 
critical hot spots believed to contribute to water quality degradation in the Upper Keys and 
Keys-wide, respectively. KLP is ranked 15th in the Upper Keys and 27th Keys-wide.
3.2.2.2	Nearshore and Offshore Marine Waters
Kruczynski (1999) and Szmant and Forrester (1996) determined that, in general, nutrient 
pollution emanating from the Keys has greater nearshore effects than offshore effects due to 
dilution by tides and currents. Offshore areas in the Middle Keys had higher nutrient levels than 
offshore areas in the Upper Keys.  The higher nutrient levels were attributed to the relatively 
high nutrient-content of Florida Bay (Kruczynski, 1999; Szmant and Forrester, 1996). 
Nearshore and offshore marine waters are described in PEA Section 3.2.3.1.2 (Nearshore and 
Offshore Marine Waters). The Florida DOH collects beach water quality data from the John 
Pennekamp State Park water quality monitoring station on the ocean side of Key Largo (MM 
105). Located about 2.4 miles northeast of the proposed WWTP site, it is the closest monitoring 
station to the service areas. Since August 2000, five health advisories/warnings have been issued 
(DOH, 2003). Health advisories are issued by DOH when sampling results indicate that contact 
with the water at that site may pose increased risk of infectious disease, particularly for 
susceptible individuals. A poor rating is measured as 104 or greater of Enterococcus sp. or 400 
or greater fecal coliform organisms per 100 milliliters of marine water (DOH, 2003). A poor 
rating requires re-sampling before issuing a health advisory. On six other occasions between 
August 2000 and June 2003, water at this site received a poor water quality rating, although a 
health advisory was not issued (DOH, 2003). No trends were observed regarding correlation with 
a particular time of year, or with poor water quality ratings for either fecal coliform or 
Enterococcus sp. categories. 
The Water Quality Monitoring Project for the Florida Keys National Marine Sanctuarys Water 
Quality Protection Program maintains a monitoring station (Station 220) about 3 miles northeast 
of Key Largo, in Hawk Channel (Southeast Environmental Research Center [SERC], 2003). 
Established by the Environmental Protection Agency (EPA) in 1995, the project objective is to 
characterize Keys water quality status and trends. Although surface TN concentrations recorded 
at Station 220 between 1995 and 2003 fluctuate, they averaged 0.146 parts per million (ppm); 
these levels are less than the Keys-wide average of 0.176 ppm recorded over the same period. 
Surface TP concentrations recorded at Station 220 from 1995 to 2003 also fluctuate, but they 
averaged 0.007; these levels are comparable to the Keys-wide average 0.007 ppm recorded over 
the same time period (SERC, 2003). It is difficult to correlate these trends directly with nutrient 
loads from KLTV and KLP because of the distance of Station 220 from the service areas.
3.2.2.3	Stormwater
US-1 represents the topographic divide for each island, whereby lands on the bay side of US-1 
drain mainly toward Florida Bay and lands on the ocean side of US-1 drain toward the Florida 
Straits (Monroe County, 2001). Stormwater runoff from roadways, bridges, driveways and yards, 
rooftops, and parking lots contributes to nearshore water nutrient loading. On-site wastewater 
treatment systems overflow during storm events and contribute nutrient pollution and fecal 
contamination to stormwater runoff. Stormwater management and water quality improvement 
projects have not been conducted within the project areas.  However, a project to eliminate 
nuisance flooding is being planned for KLTV.
Environmental Consequences
Under the No Action Alternative, effects on surface water quality near Key Largo would likely 
continue due to nutrient and pathogen inputs from the islands on-site septic systems. Under this 
alternative, FEMA would not fund this wastewater management project. Service area residents 
would still need to comply with Florida Statutory Treatment Standards of 2010. Once FKAA 
secures funding, effects on surface waters would likely be similar to those under Alternatives 2 
and 3.
Under both Alternatives 2 and 3, KLWTD would build a new WWTP to meet Florida Statutory 
Treatment Standards of 2010. Alternatives 2 and 3 would remove septic and cesspool systems 
from the service areas and would reduce the overall nutrient and pathogen inputs to inland, 
nearshore and offshore waters near the project area.  Local water quality would improve. As 
described in PEA Section 3.2.3.2.2 (Environmental Consequences; Inland, Nearshore and 
Offshore Waters), improvements to water quality under Alternatives 2 and 3 would 
incrementally reduce wastewater TN and TP loadings on the order of 92 and 86 percent, 
respectively (PEA Appendix D). The effluent would be treated to the AWT standard, but would 
still contain some nutrients.  
Alternatives 2 and 3 eliminate the nutrient pollution and fecal contamination of canal and 
nearshore waters caused by onsite systems in the service areas overflowing during storm events. 
Implementation of either alternative would not adversely affect stormwater flow quantity or 
quality, and is expected to have generally positive effects on the stormwater quality. 
Under Alternatives 2 and 3, KLWTD would prepare and fully implement a Stormwater Pollution 
Prevention Plan (SWPPP).  The SWPPP would include the use of appropriate BMPs, as required 
by FDEP National Pollutant Discharge Elimination System (NPDES) requirements to protect the 
project areas surface waters. Planned measures and BMPs to control sediment from discharge to 
surface waters include, but are not limited to, silt dams, barriers, and straw bales placed at the 
foot of sloped surfaces.
3.2.3	Floodplains and Wetlands
Affected Environment
3.2.3.1	Floodplains
Executive Order (EO) 11988 (Floodplain Management) requires Federal agencies to minimize 
floodplain occupancy and alteration. Application of the EO 11988 Eight-Step Decision-Making 
Process, per 44 CFR Part 9, ensures that Federally funded projects comply with EO 11988. By 
its nature, the NEPA compliance process involves the same basic decision-making methods to 
meet its objectives as the Eight-Step Decision-Making Process. Therefore, FEMA has applied 
the Eight-Step Decision-Making process through implementation of the NEPA process. 
PEA Section 3.2.4.1.1 (Floodplains) describes the affected environment related to floodplains. 
According to the National Flood Insurance Program Flood Insurance Rate Map, KLTV and KLP 
are in the FEMA-designated Zones AE and VE (a storm-surge hazard zone) (12087C1006G, 
FEMA 1995). The Alternative 2 WWTP site is located in the FEMA-designated Zones AE and X 
(12087C1006G; FEMA 1995). The Alternative 3 WWTP site is entirely in the FEMA-designated 
Zone AE (12087C1004G, FEMA 1995) (Figure 3-2). The highest elevation within the project 
areas is the centerline of US-1; the remainder of the land is at elevations less than 10 feet NGVD. 
 

[Figure 3-2 Project Area Floodplains
Figure 3-2 is the Flood Insurance Rate Map for the project area. The map shows that the 
Alternative 2 WWTP site is located in FEMA-designated Zones AE and X, and that the Alternative 3 
site is located in the FEMA-designated Zone AE.]


3.2.3.2	Wetlands
PEA Section 3.2.4.1.2 (Floodplains and Wetlands; Affected Environment-Wetlands) discusses 
wetland communities. Under EO 11990 (Wetland Protection), Federal agencies must minimize 
the destruction, loss, or degradation of wetlands and preserve and enhance their natural and 
beneficial values. FEMA applies the Eight-Step Decision-Making Process, required by 44 CFR 
Part 9, to comply with EO 11990, as described above. 
A Biological Assessment (BA) was completed on October 25, 2000, by URS and the Monroe 
County Department of Marine Resources for the Alternative 2 site at MM 100.5. Field 
investigations were conducted by two URS biologists on April 24, 2003, to identify wetlands 
within the Alternative 3 project site at MM 98. No freshwater wetlands were identified within the 
WWTP project sites (Figure 3-3). The nearest wetland area to the Alternative 2 proposed WWTP 
site consists of mangroves bordering the ocean side, about 0.25 mile to the east. Fringing 
mangroves may occur along small ditches or swales extending into upland forests, but no 
wetland species extend near the vicinity of the site. The Alternative 3 site is completely 
developed but is bordered on its northern and southern sides by undeveloped lands that have 
coastal fringe wetlands. Field investigation photographs are in Appendix C.
 

[Figure 3-3 Project Area Vegetation (McNeese, 1998)
Figure 3-3 shows vegetative communities located in the project area. The map shows that Key 
Largo is mostly developed with pockets of tropical hardwood hammocks.]
  

Environmental Consequences
Under the No Action Alternative, effects on floodplains and wetlands would ultimately be 
similar to Alternative 2 and 3. The No Action Alterative would have no notable effect on the 
floodplain. Without FEMA funding, water quality degradation would likely continue until 
KLWTD upgrades systems with another funding source; however, there would be negligible 
effects to coastal wetlands. In the absence of Federal funding, EO 11988 and 11990 would not 
apply. Wastewater system design would have to comply only with the Monroe Countys 
Floodplain Ordinance and be protected to the 100-year-flood level. Specific floodplain ordinance 
provisions are further described in PEA Section 3.2.4.2.1.
As discussed in PEA Section 3.2.4.2.2 (Centralized Wastewater Treatment Plant Alternative), 
implementation of Alternatives 2 and 3 would not have notable effects on floodplains. Since 
WWTPs are considered critical facilities, KLWTD would protect the plants and critical operating 
components to the 500-year flood, through elevation or floodproofing, to protect the federal 
investment from flood damages, per EO 11988 as outlined at 44 CFR Part 9.11. Because much 
of the Keys is in the 100-year floodplain, there are usually no practicable alternatives to siting 
wastewater facilities outside the floodplain. There is public concern that the proposed WWTP 
under Alternatives 2 and 3 would lead to further floodplain development by introducing key 
infrastructure, which is often linked to additional development. However, Keys development is 
not controlled by the addition of key infrastructure, but instead by Monroe Countys Rate of 
Growth Ordinance (ROGO) permit allocation system, as described further in PEA Section 3.10 
(Land Use and Planning). KLWTD proposes to build a wastewater treatment system in the Keys 
to effectively treat existing wastewater flows and comply with the Florida Statutory Treatment 
Standards of 2010; the improvements are not intended to introduce or support floodplain 
development. If growth and development in the floodplain occurring after implementation of 
either alternative, it would be the result of established county planning and would not be directly 
related to the proposed wastewater project. Given the above points, FEMA did not conduct an 
evaluation of secondary effects on floodplains with regard to the potential for increased 
development under the alternatives. It should be noted that KLP and KLTV are mostly built out, 
so additional development is unlikely (refer to Table 2-1).
No direct impacts on wetlands are anticipated, since there are no wetlands at either proposed 
WWTP site or along service area roads. Accordingly, coastal wetlands near the project sites 
would not be notably affected by construction.
As stated in PEA Section 3.2.2.2 (Inland, Nearshore and Offshore Waters; Environmental 
Consequences) the use of appropriate construction BMPs and development and full 
implementation of an FDEP- or South Florida Water Management District -approved Erosion 
and Sediment Control Plan are recommended prior to and during construction to protect area 
water bodies and wetlands. Planned measures to control sediment from discharge to nearshore 
surface waters include, but are not limited to, silt dams, barriers, and hay bales placed at the foot 
of sloped surfaces.
3.3	BIOLOGICAL RESOURCES
As in much of the Keys, humans have significantly altered the lands and waters within the Key 
Largo project area through development activities, including clearing, grading, dredging, and 
filling. Of the six major Keys-wide native (natural) terrestrial communities (i.e., pine rocklands, 
tropical hardwood hammocks, mangroves, salt marsh, freshwater systems, and dunes/coastal 
ridges) (further described in PEA Section 3.3.1.1, Terrestrial Environment), only one natural 
community (habitat) type, tropical hardwood hammocks, exists within the project sites. Two 
other habitat types, mangroves and salt marshes, exist near the proposed service areas. Of the 
four natural marine communities (seagrass beds and sand flats, coral reefs, hardbottom, and 
sandy bottom) that exist in the Keys, only coral reefs are not present near the project sites. 
Section 3.3.1 of this document and PEA Section 3.3 (Biological Resources) further discuss these 
terrestrial and marine habitats.
Per the Endangered Species Act (ESA) of 1973, URS completed a BA on October 25, 2000, in 
coordination with Monroe County, for the Alternative 2 WWTP site at MM 100.5. The BA 
fieldwork was done between June 29 and October 11, 2000. Although the MM 100.5 parcel 
covers about 22 acres, only 2.6 acres are needed for WWTP siting. Consequently, the study 
focused on the proposed construction area. The study included a census of all trees over 4 inches 
in diameter at breast height (DBH), all individuals (including seedlings) of State- or Federal-
listed threatened or endangered plant species, and all woody plants protected under Monroe 
Countys Land Development Regulations (Section 9.5) to determine presence and habitat 
suitability of special status species. The MM 100.5 site BA is in Appendix H.
On December 18, 2000, FEMA requested a formal consultation with the U.S. Fish and Wildlife 
Service (USFWS) under Section 7 of the ESA because of the potential to impact Federally listed 
species. Based on the BA information provided, on June 11, 2001, the USFWS issued a 
Biological Opinion (BO) for the proposed construction on the Alternative 2 WWTP site. The BO 
is provided in Appendix I.
Similarly, URS completed a reconnaissance-level field survey of the Alternative 3 WWTP site at 
MM 98.0 on March 24, 2003, to verify vegetation type boundaries based on reviews of literature 
and photographs.  The field survey photographs are in Appendix C. 
Affected Environment
3.3.1	Terrestrial Ecosystem
Key Largo is highly developed. Pockets of tropical hardwood hammocks are scattered 
throughout the island. The Florida Keys Wetlands Advance Identification (ADID) mapping 
project shows the KLTV and KLP service areas as a developed land use cover; managed and 
ornamental vegetation dominate the service areas (McNeese, 1998; Figure 3-3).
The 2.6-acre construction area for the Alternative 2 WWTP is roughly L-shaped and is located at 
the southwest end of the 22-acre triangular parcel of undeveloped, Monroe County-owned land. 
This site is on the ocean side of Key Largo at MM 100.5 (Figure 2-2 and 2-4). The northwestern 
property boundary is along US-1, and the southern property boundary is north of an existing 
FKAA maintenance facility and undeveloped land. The 22-acre parcel has a hardwood hammock 
that qualifies as high-quality hammock under the Monroe County Land Development 
Regulations Environmental Design Criteria (URS, 2000). The proposed construction area is the 
most disturbed portion of the 22-acre parcel, showing evidence of clearing, debris dumping, and 
invasion by exotic (non-indigenous) plant species. 
The Alternative 3 WWTP site is rectangular and covers about 3.8 acres. It is bounded by US-1 to 
the northwest, the Florida Straits to the southeast, and hardwood hammock to the northeast and 
southwest. The site is cleared, grubbed, and developed; it is presently used for boat and vehicle 
storage and miscellaneous uses. Boat repairs are done on site. Weedy vegetation is along the 
maintained US-1 ROW next to the property and areas along the property boundary. Access to the 
property shoreline was restricted due to dense mangrove growth on adjacent properties.
The roughly 2.5-mile Alternative 3 WTS corridor is within and/or next to the US-1 ROW, on the 
east (ocean) side of the roadway. FKAA would locate the force main a minimum of 5 feet from 
the shoulder of the roadway. Much of the vegetation next to the roadway consists primarily of 
grasses and weeds typical of maintained Keys ROWs. Lands next to the ROW are primarily 
developed with commercial or residential uses. From Atlantic Avenue (MM 99.5) to the service 
areas, the WTS corridor consists of dense commercial development. Vegetation on these parcels 
consists of common landscape plants and trees. An 8-foot wide bicycle/pedestrian trail is located 
along the transmission corridor, extending from Atlantic Boulevard (MM 99.5) past Central 
Avenue (MM 100.5), the southern boundary of the VPS site.
A discussion of several habitat types within or near the project areas follows.
3.3.1.1	Pine Rocklands and Tropical Hardwood Hammocks
PEA Section 3.3.1.1.1 discusses pine rocklands and tropical hardwood hammocks.  Pine 
rocklands are limited in distribution throughout the Upper and Middle Keys and are not present 
within the project sites (Figure 3-3). Tropical hardwood hammocks exist on the Alternative 2 
WWTP site. In addition, tropical hardwood hammocks border the Alternative 3 VPS, WTS, and 
WWTP site.
The Alternative 2 WWTP site is part of a 22-acre hardwood hammock that the Florida 
Department of Environmental Protection Conservation and Recreation Lands (CARL) Program 
had targeted for acquisition. Gumbo limbo (Bursera simaruba), poisonwood (Metopium 
toxiferum), pigeon plum (Coccoloba diversifolia) and willow bustic (Bumelia salicifolia) 
dominate the canopy vegetation at this site. Exotic vegetation, including white leadtree 
(Leucaena leucocephala), Brazilian pepper (Schinus terebinthifolius), and sapodilla (Manilkara 
zapota) dominate approximately 0.41 acre along the southern fringe of the proposed 2.6-acre 
construction area. This fringe is about 500-feet along the common property line with the FKAA 
maintenance facility, which was previously cleared for a road and fence easement. The 
remaining 2.2 acres are higher quality hardwood hammock habitat with fewer exotic plants. The 
BA (Appendix H) provides a more detailed discussion of this site and a full listing of vegetation 
observed.
As stated above, the hardwood hammocks at the Alternative 2 WWTP site qualify as high-
quality hammock under the Monroe Countys Land Development Regulations Environmental 
Design Criteria (see attachment to the BA, Appendix H). These county regulations require that 
80 percent of the hardwood hammock within a proposed construction site be protected in its 
natural state (URS and Monroe County, 2000). 
The Alternative 3 WWTP site is completely developed, and no hardwood hammock habitat is on 
site. However, the site is bordered on the northeast and southwest by low quality hardwood 
hammock altered by vegetation removal, and to the south by a forested fringe of coastal wetland 
vegetation with an open connection to the Florida Straits. Exotic plant species, such as Brazilian 
pepper and white leadtree are limited to roadside margins and a few individuals in the interior of 
the property. 
Undeveloped lands next to the Alternative 3 WTS corridor are characterized as a degraded 
hardwood hammock affected by habitat fragmentation and infestation by invasive, exotic plant 
species. Species observed in these areas included gumbo limbo, pigeon plum, poisonwood, and 
Brazilian pepper. The Alternative 3 VPS was previously described under Alternative 2. 
3.3.1.2	Mangrove Forests and Salt Marshes
Throughout the Keys, mangroves dominate most coastal vegetation communities. Mangroves 
exist along the edges of shorelines, bays, and lagoons, and on overwash areas throughout the 
Keys. PEA Section 3.3.1.1.2 (Mangroves) further discusses mangroves. 
Mangroves and salt marshes are not present within the project sites (Figure 3-3). However, 
fringing mangroves dominate shorelines near the Alternative 2 and 3 WWTP sites, and large 
mangrove communities border both the KLP and KLTV service areas (Figure 3-3). Three 
mangrove tree species?red mangrove (Rhizophora mangle), black mangrove (Avicennia 
germinans) and white mangrove (Laguncularia racemosa)?are the dominant components. 
A small salt marsh is located near the KLP service area (Figure 3-3). Salt marshes, which are not 
well developed in most of the Keys, usually consist of mostly single-species stands of black 
needlerush (Juncus roemerianus) and salt marsh cordgrass (Spartina alterniflora). Other 
common Keys salt marsh species 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 zone may have sea ox-eye (Borrichia arborescens), saltwort (Batis maritima), seablight 
(Suaeda linearis), and sea lavender (Argusia gnaphalodes). 
3.3.1.3	Freshwater Systems
There are no freshwater wetlands at the project sites (Figure 3-3).
3.3.1.4	Dunes and Coastal Ridges
Dunes and coastal ridges are not present within the project sites (Figure 3-3).
3.3.2	Aquatic Ecosystem
Marine habitats are present within the artificial canals and marine waters around the Key Largo 
project sites. Seagrasses and hardbottom communities mixed with seagrasses dominate marine 
habitats near the project sites (Figure 3-4). A discussion of individual marine community types is 
below.
As described in PEA Section 3.3.3.1 (Special Status Species), essential fish habitat (EFH) 
present near the project sites consists of estuarine seagrass, marine live/hardbottom, mangrove, 
and marine water column. In the Keys, the Gulf of Mexico (GMFMC) and South Atlantic 
(SAFMC) Fishery Management Councils regulate fisheries. A compiled list of the fishery 
species under GMFMC and SAFMC management is in Appendix F.
3.3.2.1	Seagrass Beds and Sand Flats
Seagrass communities are the most common Keys marine community type. Interacting factors, 
including sediment depth, water quality, water depth, and current velocity, influence distribution 
of seagrass communities (Florida Marine Research Institute [FMRI], 2000). When seagrass 
meadows in low-energy environments are disturbed by high energy influences, seagrass growth 
can become patchy with areas of sandflats (FMRI, 2000).  Keys seagrass communities are 
dominated by turtle-grass (Thalassia testudinum) and manatee-grass (Syringodium filiforme), 
with shoal-grass (Halodule wrightii) becoming dominant in areas with high nutrient loads 
(Fonseca et al., 1998). 
Seagrass communities dominate both the western, bay side of the island and the eastern, ocean 
side near the project sites (Figure 3-4). This community type exists alone or in combination with 
hardbottom communities. PEA Section 3.3.1.2.1 (Seagrass Beds and Sand Flats) further 
describes the affected environment for seagrass beds and sand flats
 

[Figure 3-4. Project Area Benthic Habitats 
Figure 3-4 is a map of benthic habitats in the project area.  Seagrass communities dominate marine 
areas near the project area.]


3.3.2.2	Coral Reefs
In the Upper Keys, the reef tract forms an almost continuous community that extends from the 
south side of Hawk Channel at Caryfort Reef to Crocker Reef in the south. The reef tract is about 
7 miles southwest of the proposed service areas and WWTP project sites. This area also has 
many patch reefs and well-developed bank reefs (FMRI, 2000). Patch reefs exist seaward of 
Hawk Channel and inshore of the bank reefs, at depths of about 6 to 30 feet (Myers and Ewel, 
1990).  The closest patch reef to the proposed service areas and the Alternative 2 WWTP site is 
Mosquito Bank, about 3.7 miles to the southwest. The closest patch reef to the Alternative 3 
WWTP site is in an unnamed area about 3.3 miles to the southwest (FMRI, 2000).
3.3.2.3	Hardbottom 
Hardbottom habitats are solid, flat to low-relief, rock substrate composed of rock and/or rubble 
that is either exposed or covered with a thin layer of sediment (FMRI, 2000). Nearshore 
hardbottom is the dominant marine community throughout the Keys. Hardbottom communities 
are characterized by their proximity to shore, shallow depth, and visual dominance of octocorals 
(Chiappone and Sullivan, 1994). These communities exist within 1.25 miles of shore on either 
side of the Keys at depths of about 3 to 16 feet (Chiappone and Sullivan, 1996). 
Hardbottom habitat is mixed with seagrass communities on both the bay and ocean sides of Key 
Largo near the project sites (Figure 3-4). PEA Section 3.3.1.2.3 (Hardbottom) further describes 
the affected environment for hardbottom communities. 
3.3.2.4	Sandy Bottom
Bare bottom communities, over either calcareous muds and/or sands, lack algae and seagrasses. 
The associated flora and fauna is sparse and typically dominated by sponges, small corals, and 
calcareous algae (Chiappone, 1996). 
Sandy bottom communities exist throughout the artificial waterways on Key Largo (see Figure 
3-4). PEA Section 3.3.1.2.4 (Sandy Bottom) further describes the affected sandy bottom.
Environmental Consequences
3.3.2.5	Alternative 1  No Action Alternative
Under the No Action Alternative, KLWTD would not use FEMA funds to implement improved 
wastewater management activities to meet the new Florida Statutory Treatment Standards of 
2010. Without FEMA funds, the KLWTD would have to get other financing, which would delay 
wastewater treatment improvements. Adverse effects on nearshore marine ecosystems would 
continue as a result of septic tank and cesspools effluents, which continue to contribute to the 
eutrophication of nearshore marine waters. Once comprehensive wastewater treatment 
improvements are made, nearshore marine ecosystem benefits would be similar to those of 
Alternatives 2 or 3. Effects on upland ecosystems would depend mostly on the chosen WWTP 
locations.
3.3.2.6	Alternative 2  New Wastewater Treatment Plant on Northern Site
Site preparation, including clearing and grubbing, would eliminate up to 2.6 acres of hardwood 
hammock at the proposed WWTP construction site. No other areas of this 22-acre parcel would 
be cleared. Construction activities would require authorization in the form of two Environmental 
Resource Permits (ERPs): one from the FDEP for stormwater-related features, and one from the 
Monroe County Growth Management Division.
Section 9.5-345 of Monroe Countys Land Development Regulations and the USFWS 
overlapping BO for the Alternative 2 WWTP site, which require minimizing development 
environmental effects, would regulate proposed construction on the Alternative 2 site. The 
following outlines adverse effect minimization measures mandatory for legal compliance (see 
BA in Appendix H and BO in Appendix I for further conservation and mitigation measure 
details). WWTP construction would be clustered into the lowest-quality portion of hardwood 
hammock on the 22-acre parcel. The undeveloped portion of the parcel would serve as a 
mitigation area for transplanting protected species, planting hardwood hammock species, and 
removing exotic and nuisance vegetation. The KLWTD would restore 2.6 acres of hardwood 
hammock and conserve the parcels remaining 19.4 acres in an undeveloped conservation 
easement in perpetuity. Native hardwood hammock tree species, with a DBH greater than 3.5 
inches would be transplanted or replaced within the remaining 19.4 acres or into landscaped 
areas. Finally, siting the WWTP next to the existing FKAA facility also serves as a hardwood 
hammock mitigation measure. Alternative 2 project implementation, as proposed, along with 
ERP, Monroe County Land Development Regulation, and USFWS BO compliance, before and 
during construction activities, is not expected to result in significant adverse effects to terrestrial 
ecosystems. 
Although no direct effects on aquatic ecosystems would occur under Alternative 2, wastewater 
treatment improvements would indirectly affect the nearshore marine waters near KLTV and 
KLP.  Treating wastewater to meet Florida Statutory Treatment Standards of 2010 would 
improve nearshore marine waters by reducing TN and TP loadings by about 82 and 86 percent, 
respectively (see PEA Appendix D [Water Quality Improvement Analysis]).  Accordingly, 
reducing nutrient and pathogen loading would incrementally benefit all aquatic communities in 
the marine ecosystem dependent on good water quality; as further described in PEA Sections 
3.2.3.1.2 (Nearshore and Offshore Marine Waters); 3.3.1.2 (Aquatic Environment); and 3.3.2 
(Environmental Consequences). Coral reefs are located over 3 miles from the service areas and 
the Alternative 2 WWTP site in Hawk Channel. Removal of septic and cesspool systems would 
not directly benefit these coral reef systems due to the location of the service areas on the 
bayside of Key Largo and to the distance to the reefs. Likewise, the construction and operation of 
a WWTP at the Alternative 2 site would not have an effect on the coral reefs due to the distance 
between them. As further described in PEA Section 3.2.3.1.2 (Nearshore) and Offshore Marine 
Waters, recent studies have found a decreasing gradient in nutrients from nearshore to off-shore 
waters.
3.3.2.7	Alternative 3  New Wastewater Treatment Plant on Southern Site
The effects of Alternative 3 on aquatic ecosystems would be similar to those of Alternative 2. 
The Alternative 3 WWTP site is completely developed, and WWTP construction would not 
require additional clearing or grubbing. Trenching activities from the proposed MM 100.5 VPS 
to the proposed WWTP site would occur in the mowed grass areas of US-1 ROW. After 
construction, this area would be seeded with grass and allowed to revegetate. The VPS would be 
sited in the southwest corner of the Alternative 2 WWTP site, immediately next to the FKAA 
facility. Construction would require clearing and grubbing of a small exotic plant -dominated 
vegetation area, as described under Alternative 2. Monroe County Land Development 
Regulations may require some hardwood hammock mitigation measures similar to those 
described under Alternative 2.
3.3.3	Special Status Species
The ESA requires Federal agencies to consider effects of their actions on Federally threatened 
and endangered species and their designated critical habitats, and to take steps to conserve and 
protect these species and their habitat. Federal agencies must also comply with the Magnuson-
Stevens Fishery Conservation and Management Act (MSA) (16 U.S.C. 1801 et seq.), which 
requires the EFH identification for Federally managed fishery species and the implementation of 
measures to conserve and enhance this habitat per the Sustainable Fisheries Act (SFA) Public 
Law 104-297. PEA Section 3.3.3.1 (Special Status Species, Affected Environment) describes 
special status species.
In the State of Florida, wildlife and plants are regulated by two separate agencies. The Florida 
Fish and Wildlife Conservation Commission (FFWCC) regulates wildlife within the jurisdiction 
of the State of Florida under Chapter 68A-1.004, Florida Administrative Code (FAC). The 
Florida Department of Agriculture and Consumer Services regulates protected plant species 
under the Preservation of Native Flora of Florida Act (Chapter 5B-40, FAC). 
Monroe County, through its Land Development Regulations, protects wildlife and protected 
plant species by requiring conservation and enhancement of environmentally sensitive lands. 
Hardwood hammocks are protected under Monroe Countys Land Development Regulation 
Section 9.5-345 (Environmental Design Criteria), which is an attachment to the Biological 
Assessment in Appendix H. Monroe County has designated several plant species as Regionally 
Important (RI) plants. 
Affected Environment
URS did biological investigations for both Alternative WWTP sites. As reported in the BA, 
biologists did not observe any plant or animal species listed as endangered or threatened by the 
USFWS on the Alternative 2 WWTP site (Appendix H), although hardwood hammock is 
suitable habitat for the Schaus swallowtail butterfly (Heraclides aristodemus ponceanus), Stock 
Island tree snail (Orthalicus reses), and eastern indigo snake (Drymarchon corais couperi) (URS 
and Monroe County, 2000.) USFWS has listed both the Stock Island tree snail and the eastern 
indigo snake as threatened and the Schaus swallowtail butterfly as endangered.
Biologists observed several State-listed threatened or endangered species at the Alternative 2 
WWTP site. The threatened plant species included spicewood (Calyptranthes pallens), prickly 
pear (Opuntia stricta), blackbead (Pithecellobium keyensis), red ironwood (Reynosia 
septentrionalis), and spiny greenbrier (Smilax havanensis). The endangered species included 
cinnamon bark (Canella winterana), milkbark (Drypetes diversifolia), princewood (Exostema 
caribaeum), white ironwood (Hypelate trifoliata), white flower passion flower (Passiflora 
multiflora), hammock snout pea (Rhynchosia swartzii), mahogany (Swietenia mahogani) and 
thatch palm (Thrinax radiata.). Additional State-listed plant species are known to exist in the 
nearby Newport Hammock CARL site and may also exist at the Alternative 2 WWTP site, per 
the FFWCC. These include yellowwood (Schaefferia frutescens, endangered), Simpsons prickly 
apple (Harrisia simpsonii, endangered), banded wild pine (Tillandsia flexuosa, endangered), 
wild cotton (Gossypium hirsutum, endangered), joewood (Jacquinia keyensis, threatened), wild 
dilly (Manilkara bahamensis, threatened), and golden leather fern (Acrostichum aureum, 
threatened). The Alternative 2 WWTP site hardwood hammock is suitable habitat for the white-
crowned pigeon (Columba leucocephala), Florida tree snail (Liguus fasciatus), and Miami black-
headed snake (Tantilla oolitica). FFWCC has listed the white-crowned pigeon and Miami black-
headed snake are threatened and the Florida tree snail is a Species of Special Concern. The State 
also lists Schaus swallowtail butterfly and Stock Island tree snail as endangered.
In addition to State- and Federal-listed threatened and endangered species, Monroe County has 
listed several plant species observed on the Alternative 2 WWTP site as RI (Regionally 
Important) species. RI species observed include inkwood (Exothea paniculata), black ironwood 
(Kruigiodendron ferreum), lancewood (Nectandra coriacea), capeweed (Phyla nodiflora), 
paradise tree (Simarouba glauca) and tallowwood (Ximenia americana). In addition, Monroe 
County has listed tropical hardwood hammock habitat itself for protection. Further Alternative 2 
WWTP site special status species details are in the BA and BO in Appendices H and I, 
respectively. 
Two URS biologists conducted a site visit on March 24, 2003, concurrently with vegetation and 
wildlife investigations, to evaluate the potential presence of protected species and suitable habitat 
for these species on the Alternative 3 WWTP site. The biologists did not observe any State- or 
Federal-listed threatened or endangered species in the proposed Alternative 3 WWTP and WTS 
construction sites. Vegetated portions of these proposed sites consist of disturbed weedy and 
landscape plants; therefore, no portions of the proposed construction sites are likely to provide 
nesting, roosting, or feeding habitat for any special status species that could exist in the Key 
Largo area. The Alternative 3 VPS would be built on a small portion of the Alternative 2 WWTP 
site. As noted above no Federally listed plant species were observed on the Alternative 2 site. 
Several State- and county-listed plant species may be present in the pest- and exotics- dominated 
construction area at the southwestern fringe of the parcel. This small area could support some 
State- or Federally listed threatened or endangered animal species, as described above. 
Environmental Consequences
Under the No Action Alternative, FEMA would not fund the proposed wastewater management 
improvements in Key Largo, and KLTV and KLP residents would still need to comply with 
Florida Statutory Treatment Standards of 2010. As such, ESA Section 7 and EFH compliance 
would not be required unless there is other Federal funding. Effects on special status species, 
once funding is secured would likely be similar to those under Alternatives 2 and 3.
3.3.3.1	Alternative 2  New Wastewater Treatment Plant on Northern Site
Per ESA Section 7, FEMA consulted the USFWS and the National Marine Fisheries Service 
(NMFS) regarding the potential effects of Alternative 2. On July 7, 2000, FEMA initiated 
informal consultation with the USFWS, then completed a draft BA and sent it to USFWS on 
October 30, 2000. On December 18, 2000, FEMA requested the informal consultation be 
elevated to a formal consultation because of the potential for incidental take of Federally listed 
species, including the Schaus swallowtail butterfly, eastern indigo snake, and Stock Island tree 
snail. In this situation, take means harm through loss of 2.6 acres of direct habitat and by 
harassment to these species. Based on the BA information provided, on June 11, 2001, the 
USFWS issued a BO for the proposed construction on the Alternative 2 WWTP site. The 
USFWS concluded that Alternative 2 would not likely jeopardize the continued existence of 
either the Stock Island tree snail or the Schaus swallowtail butterfly and would not likely 
adversely affect the eastern indigo snake. In addition, since the USFWS has not designated 
critical habitat for these species, none will be affected.
The USFWSs conclusions are based upon two reasonable and prudent measures to minimize 
take, during Alternative 2 construction, of the Stock Island tree snail and Schaus swallowtail 
butterfly. These measures include restoring 2.6 acres of hardwood hammock habitat and placing 
the undeveloped 19.4 acres of hardwood hammock habitat under a conservation easement. Under 
the ESA, these are viewed as non-discretionary terms and conditions, which FEMA will 
require of the KLWTD for funding approval. Additional implementation details are in the BO 
(Appendix I). FEMA consulted the NMFS regarding the potential effects of Alternative 2 under 
ESA Section 7. In a letter dated June 5, 2003, FEMA initiated informal consultation with NMFS, 
provided its findings, and requested determination concurrence.   NMFS concurred on November 
19, 2003 that Alternative 2 would not likely affect threatened or endangered species under their 
jurisdiction.   Similarly, on June 24, 2003, NMFS concurred with FEMAs finding that 
Alternative 2 would not likely affect EFH; therefore, no further action is required under the 
MSA and the SFA. Agency coordination letters for this SEA are in Appendix B. 
Several State special status species are known to exist or may exist at the Alternative 2 WWTP 
site. The FFWCC sent a letter to FEMA, dated July 14, 2000, stating opposition to building a 
WWTP on the proposed Alternative 2 site, due to the presence of important hardwood hammock 
habitat and State-listed plants and animals, and providing a copy of their comments to a separate 
Monroe County environmental assessment. The FFWCC sent this letter before FEMA had 
completed formal consultation with USFWS. On January 23, 2001, a copy of FEMAs BA was 
provided to FFWCC for comment, and no comments were received. The mitigation measures 
outlined in the BA and the reasonable and prudent measures and implementing terms and 
conditions identified in the USFWS BO would minimize the loss of hardwood hammock habitat 
and State-listed plants and animals. On June 5, 2003, FEMA requested comment from the 
FFWCC on its intent to prepare this SEA. On July 1, 2003, the FFWCC reiterated its opposition 
to construction on the Alternative 2 site. Agency coordination letters are in Appendix B. 
Adverse effects to Monroe Countys RI-listed plant species from construction of Alterative 2 
would be mitigated through KLWTD compliance with the Countys Land Development 
Regulations and the mitigation measures identified in the BA and BO. Accordingly, Alternative 
2 WWTP site construction as proposed, with Monroe County Land Development Regulation, 
and USFWS BA and BO compliance before construction activities, is not expected to result in 
significant adverse effects to special status species.
3.3.3.2	Alternative 3  New Wastewater Treatment Plant on Southern Site
On June 5 and July 22, 2003, FEMA initiated consultation per ESA Section 7, with USFWS and 
NMFS, regarding Alternative 3 potential effects. As noted above, URS completed a biological 
evaluation of the WWTP site on April 24, 2003, and no State or Federally listed species were 
observed. The Alternative 3 VPS will be located on a small pest- and exotic plant-dominated 
portion of the Alternative 2 WWTP site. The USFWS concurred with FEMAs finding of no 
effect for this alternative (Hobgood, Pers. Com., 2003). 
NMFS stated in a June 24, 2003 response, that neither the construction nor operation of 
Alternative 3 would affect EFH; therefore, MSA and the SFA require no further action. NMFS 
concurred on November 19, 2003 that Alternative 2 would not likely affect threatened or 
endangered species under their jurisdiction.   
On June 5, FEMA requested review of the project alternatives by FFWCC. On July 1, 2003, the 
FFWCC encouraged use of the Alternative 3 WWTP site because the potential for adverse 
effects on threatened and endangered species would be less at this site. Monroe Countys Land 
Development Regulations may require some mitigation measures for protection of County RI-
listed plant species at the Alternative 3 VPS Site. Accordingly, no notable adverse effects to 
special status species are anticipated for Alternative 3. 
3.4	 AIR QUALITY
Affected Environment
Air pollution within the project areas has not been extensively documented; however, motor 
vehicles are usually the primary source of air emissions. The FDEP has designated Monroe 
County as an air quality attainment area, meaning that air quality standards set by both FDEP 
and the EPA are maintained countywide (Monroe County, 1995). Air quality in the Florida Keys 
is generally excellent, and data from FDEPs two ambient air monitoring stations in Key West 
and Marathon indicate that particulate matter concentrations remain well below the State 
standards. The affected environment for air quality is similar to that described in PEA Section 
3.4.1 (Air Quality, Affected Environment).
Environmental Consequences
Under the No Action Alternative, FEMA would not fund the proposed wastewater management 
improvements. KLTV and KLP residents would still need to comply with Florida Statutory 
Treatment Standards of 2010. It is anticipated that effects on air quality, once funding is secured, 
would be similar to those under Alternatives 2 and 3. 
Under both Alternative 2 and 3, minor temporary adverse effects on air quality would occur 
during construction from increased exhaust pollutants and fugitive dust. These temporary effects 
could be mitigated through standard construction BMPs, including decreasing vehicle idle times 
and watering down construction areas. WWTP operations effects on air quality would be similar 
to those discussed in PEA Section 3.4.2.2 (Environmental Consequences, Alternative 2  
Centralized Wastewater Treatment Plant). The pump station minimizes odors by controlling air 
emissions from equipment. The only release of air occurs from the blower exhaust at the pump 
station, which passes through a biofilter before emission. In addition, an odor control system, 
such as an in-ground wood chip bed or packaged iron fillings bed, would be implemented to 
minimize odors. No long-term effects on air quality are anticipated.
3.5	CULTURAL RESOURCES
Affected Environment
PEA Section 3.5.1 (Cultural Resources, Affected Environment) provides an overview of Monroe 
Countys cultural history. In addition to review under NEPA, consideration of effects on cultural 
resources is mandated under Section 106 of the National Historic Preservation Act (NHPA), as 
amended, and as implemented by 36 CFR Part 800. Requirements include identification of 
significant historic properties that may be affected by the proposed project. For the purposes of 
Section 106, historic properties are defined as archaeological sites, buildings, structures, districts, 
or sites that are listed in or are eligible for listing in the National Register of Historic Places (36 
CFR 60.4). 
As defined in 36 CFR Part 800.16(d), the Area of Potential Effect (APE) is the geographic area 
or areas within which an undertaking may directly or indirectly cause changes in the character or 
use of historic properties, if any such properties exist. 
The APE for Alternatives 2 and 3 differ, and are described in Sections 2.2 and 2.3 respectively. 
However, the KLTV and KLP service areas are the same for both WWTP site alternatives. In 
addition to identifying historic properties that may exist in the proposed projects APE, the 
Federal agency must also determine, in consultation with the appropriate State Historic 
Preservation Officer (SHPO), what effect, if any, the action would have on historic properties. 
Moreover, if the project would have an adverse effect to these properties, the Federal agency 
must consult with the SHPO on ways to avoid, minimize, or mitigate the adverse effect.
Cultural Resources Assessments of Alternatives 2 and 3 were done by URS archaeologists. The 
purpose of these assessments was to assist FEMAs project planning, ensure NEPA and NHPA 
compliance, and provide the Florida SHPO at the Florida Division of Historic Resources (DHR) 
with information on potential cultural resource effects. The assessments included a search of the 
Florida Master Site File, maintained by the DHR. Files indicate that there are nine known 
historic properties near the APE for Alternative 2. The Florida Master File indicates that there 
are no known historic properties within or near the APE of Alternative 3.
DHR sites 8MO26, 8MO27, and 8MO1258 are located north of the proposed WWTP site for 
Alternative 2, across US1, and between KLP and KLTV, in the Calusa Campground. DHR Site 
8MO1258, a rock mound and midden, is a National Register-listed archaeological site. The two 
other DHR sites north of US-1, 8MO26 and DHR 8MO27, have been nominated to the National 
Register, but were not listed (Rock Mound National Register Nomination 1974). Both of these 
two sites are rock mounds with associated middens dating from the Glades period. Remains of 
these resources were observed and documented during a November 14, 2003 URS site visit in 
the Calusa Campground (see Appendix G). 
Four of the other sites are likely related and are located northeast of the Alternative 2 proposed 
WWTP site. They are DHR sites 8MO2057 and 8MO2058, historic cisterns; 8MO2060, a 
historic pioneer domestic site; and 8MO2067, a historic cistern and home site, all of which are 
probably associated with the settlement of Newport Village. The two remaining prehistoric DHR 
sites, 8MO2061 and 8MO2066 are shell middens. A site-visit was conducted at the Alternative 2 
WWTP site on January 10, 2001 by a URS archaeologist. The purpose of this survey was to 
identify visible cultural resources and to assess the necessity for a more detailed archaeological 
survey. URS staff conducted a pedestrian survey of the WWTP APE, noting soil conditions, 
signs of disturbance, and any visible evidence of cultural resources. No historic properties were 
observed during survey and the site conditions suggested a low probability for presence of 
significant cultural resources. The results of this survey were submitted to the DHR (See 
Appendix G, Cultural Resources Correspondence).
A site visit was conducted by URS staff at the Alternative 3 site on April 24, 2003. The proposed 
WWTP site is about 200 feet wide by 900 feet long, covering 3.8 acres. The site has been 
cleared, grubbed, and developed. It is presently used for boat and vehicle storage. US-1 runs 
along the western property boundary; the northern and southern property boundaries border on 
undeveloped hardwood hammock habitat. The closest private residence is located about 100 feet 
(0.02 mile) west of the site. The closest water body to the site is the Straits of Florida, 
immediately east of the site. Florida Bay is located about 1,350 feet (0.26 mile) west of the site. 
Boats, trailers, lumber, and other construction debris are strewn about the entire property. 
There is no source of potable water and no vegetation across most of the parcel. No historic 
features or historic properties were noted during the survey, and it is apparent that the area has 
been intensively used during the second half of the 20th century. The results of this survey were 
submitted to the Florida DHR (See Appendix G, Cultural Resources Assessment Survey).
Environmental Consequences
Under Alternative 1, the No Action Alternative, FEMA would not provide funds for wastewater 
management improvements. Key Largo residents would still need to comply with Florida 
Statutory Treatment Standards of 2010. It is anticipated that once funding is secured, effects on 
cultural resources would be similar to those under Alternatives 2 and 3. 
The APEs for Alternatives 2 and 3 have been affected by modern disturbances. This coupled 
with the absence of visible cultural resources, the highly depleted or absent soils, and the lack of 
potable water, indicates that there is a very low probability of significant cultural resources 
occurring within the WWTP sites. The service areas are similarly disturbed from residential 
construction and road work. Therefore, no effect on historic, archaeological, or cultural resources 
is anticipated from either Alternative. In letters dated May 16, 2001, and August 18, 2003, 
respectively, the Florida DHR concurred with the findings that no historic properties were likely 
to be located within either the Alternative 2 or 3 WWTP sites (see Appendix G). Although the 
Calusa Campground is not incorporated in the currently proposed service areas, the above-
described historic properties may be adversely affected if the KLWTD connects this facility to 
the KLTV or KLP collection system. The KLWTD would be advised to avoid sensitive 
archaeological features, have professional on-site archaeological monitoring during collection 
system work, and further coordinate activities with the SHPO.
Should any unanticipated historic or archeological materials be discovered during project work, 
however, all activities on the site shall be halted immediately and the KLWTD shall consult with 
FEMA, SHPO, and other appropriate agencies for further guidance. In addition, if human 
remains are discovered, Floridas unmarked human burial law will be implemented (Florida 
Statute Title XLVI, 872.05 Unmarked human burials), specifically: 
When an unmarked human burial is discoveredall activity that may disturb the 
unmarked human burial shall cease immediately, and the district medical examiner 
shall be notified. Such activity shall not resume unless specifically authorized by the 
district medical examiner or the State Archaeologist. If the district medical examiner 
finds that the unmarked human burial may be involved in a legal investigation or 
represents the burial of an individual who has been dead less than 75 years, the 
district medical examiner shall assume jurisdiction over and responsibility for such 
unmarked human burial, and no other provisions of this section shall apply. The 
district medical examiner shall have 30 days after notification of the unmarked human 
burial to determine if he or she shall maintain jurisdiction or refer the matter to the 
State Archaeologist. If the district medical examiner finds that the unmarked human 
burial is not involved in a legal investigation and represents the burial of an individual 
who has been dead 75 years or more, he or she shall notify the State Archaeologist, 
and the division may assume jurisdiction over and responsibility for the unmarked 
human burial pursuant to subsection (6) [of Florida Statute 872.05]. When the 
division assumes jurisdiction over an unmarked human burial, the State Archaeologist 
shall consult a human skeletal analyst who shall report within 15 days as to the 
cultural and biological characteristics of the human skeletal remains and where such 
burial or remains should be held prior to a final disposition [Florida Statute Title 
XLVI, Chapter 872.05].
3.6	SOCIOECONOMIC RESOURCES
3.6.1	Tourism
Affected Environment
Tourist facilities on Key Largo are located on both the bay and ocean sides of the island and are 
concentrated along the US-1 corridor. Facilities include a dive shop, hotels and resorts, marina 
and boat ramp, and commercial businesses. Since about the 1950s, Key Largo shifted its 
economic focus to tourism and is now known as the diving capital of the world 
(FloridaKeys.com, 2003).  Tourism is an important component of Key Largos economy, and 
many facilities take advantage of natural areas such as John Pennekamp State Park (ecotourism) 
and local marine resources. Table 3-3 lists tourist and commercial businesses located near the 
project sites and service areas.

Table 3-3. Project Area Businesses
Business Name
Location
Scottys Hardware
Key Largo Park
PYM Marine
Key Largo Park
Auto Doctor
Key Largo Park
Als Wrecker Service
Key Largo Park
Unique Marine
MM 100 Overseas Highway
Enterprise Car Rental
MM 99.5 Overseas Highway
Franks Key Cafe
MM 99.5 Overseas Highway
Le Shoppe Hair Salon
MM 99 Overseas Highway
Tropical Cleaners
MM 99 Overseas Highway
Shell Gas Station
MM 99 Overseas Highway
Ramada Hotel 
MM 99 Overseas Highway
Holiday Inn
MM 99 Overseas Highway
Citgo Gas Station
MM 99 Overseas Highway
Hess Gas Station
MM 99 Overseas Highway
TIB Bank
MM 99 Overseas Highway
DJs Diner
MM 99 Overseas Highway
Key Largo Travel Lodge
MM 99 Overseas Highway
Yesterdays Consignment
MM 99 Overseas Highway
Pink Juntique
98725 Overseas Highway
Joyce Bennet School of Dance
MM 98.5 Overseas Highway
Thom Thumb Gas Station
MM 98.5 Overseas Highway
Papa Johns Pizza
MM 98.5 Overseas Highway
Key Largo Boating Center
MM 98.5 Overseas Highway
Sea Trail Hotel
98620 Overseas Highway
Taco Bell
MM 98.5 Overseas Highway
Kentucky Fried Chicken
MM 98.5 Overseas Highway
Mermaid Marine Ship Store
MM 98.5 Overseas Highway
Discount Auto Parts
MM 98.5 Overseas Highway
NAPA Auto Parts
MM 98.5 Overseas Highway
Mel Harriss Boat Yard
MM 98 Overseas Highway
Ballyhoo Seafood Restaurant
MM 98 Overseas Highway
Tom Thumb Gas Station
MM 98 Overseas Highway

Environmental Consequences
Under the No Action Alternative, FEMA would not fund the proposed wastewater management 
improvements. Wastewater projects may be funded by local sources, which may increase local 
taxes. These costs could be passed on to Keys tourists through higher costs for hotels, food, and 
other goods and services. In addition, economic losses from decreased water quality, such as area 
beach advisories and storm damage of the existing wastewater infrastructure, would continue 
until wastewater improvements were implemented. It is anticipated that once funding is secured, 
effects to tourism would be similar to those under Alternatives 2 or 3.
Under Alternatives 2 and 3, adverse construction effects on Key Largo tourism would be short-
term and minor. Collection system installation would temporarily hinder, but not obstruct, 
service area traffic movement. Appropriate signage and traffic management, as described in PEA 
Section 3.9.1 (Traffic and Circulation), would reduce the degree of this impact. Installation and 
operation of the treatment plant is not expected to impact tourism beyond those effects described 
in PEA Section 3.6.1.2.1 (Socioeconomic Resources; Tourism; Environmental Consequences 
Alternative 2). Additionally, improved water quality in the Key Largo area may benefit the 
tourism industry by incrementally increasing tourist enjoyment of activities listed in PEA Section 
3.6.1.1 (Tourism, Affected Environment).
3.6.2	Fishing Industry
Affected Environment
Key Largo ranks as one of the best sport-fishing areas in the world (FloridaKeys.com, 2003). 
Species recreationally harvested around Key Largo include tarpon, bonefish, kingfish, dolphin, 
sailfish, wahoo, snapper, grouper, shark, and barracuda. Several fishing tournaments are held in 
Key Largo throughout the year (Keys Technologies, 2003). Commercially harvested species that 
may occupy the Key Largo nearshore waters include spiny lobster, white mullet, gray snapper, 
various flounder, shrimp and stone crab. In the 2000 Census, over 100 individuals in Key Largo 
listed their occupation as fisherman (U.S. Census, 2000) The affected environment for the 
fishing industry is described further in PEA Section 3.6.2.1 (Fishing Industry, Affected 
Environment).
Environmental Consequences
Under the No Action Alternative, FEMA would not fund wastewater management 
improvements. Any environmental benefits to the fishing industry would be delayed until 
funding was obtained for wastewater management improvements on Key Largo (as described in 
PEA Section 3.6.2.2.1, [No Action Alternative]).
Under both Alternatives 2 and 3, FEMA would provide funding to build a WWTP and or 
collection system. This project is expected to improve nearshore water quality, which in turn 
would incrementally benefit nearshore commercial and recreational species that are currently 
being adversely affected by poor water quality in the Key Largo area. Beneficial effects on 
commercial fishing are described in PEA Section 3.6.2.2 (Environmental Consequences). 
Furthermore, FEMA consulted the NMFS regarding the potential effects of Alternatives 2 and 3 
on fisheries resources. The NMFS stated in their June 24, 2003, letter that neither alternative 
would be likely to affect EFH; therefore, no further action is required under MSA and SFA. 
Agency coordination letters for this SEA are in Appendix B.
3.6.3	Local Fees and Taxes
Affected Environment
Monroe County residents must pay county, State, and Federal taxes. The average property tax 
rate for all Monroe County districts is 13.4 percent of the appraised property value, excluding 
property tax deductions such as the homestead exemption (Monroe County, 2001b). Several 
governmental agencies within Monroe County affect the total property tax rate to provide 
revenue for local services. Additional details on local taxes are in PEA Section 3.6.3.1 (Local 
Fees and Taxes, Affected Environment).
3.6.3.1	Existing Wastewater Management Costs in the KLTV and KLP Service Area
For the purpose of this SEA, wastewater management cost discussions include reference to: 
1)	system capital costs, which include expenses associated with planning, designing, 
engineering, purchasing, building, and installing a wastewater treatment system, and 
the required wastewater conveyance piping in public ROWs and selected effluent 
disposal method; 
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 new system.
Five basic types of wastewater systems are presently used in Monroe County: cesspits, septic 
tanks, on-site aerobic treatment unit (ATU), OWNRS, and centralized WWTPs. On Key Largo, 
cesspools and septic systems are currently utilized by property owners. Septic systems collect 
sewage in a tank and allow the liquid waste to filter through a drainfield into shallow soils and 
subsurface limestone. For septic systems in working condition, pumping to remove solid waste is 
needed only about every 6 to 10 years (D and D Enterprises, Inc., Pers. Comm., 2001). The cost 
to pump a standard 1,000-gallon septic tank, presently about $300, would average about $38 a 
year or a little over $3 a month if pumped once every 8 years.
Almost all cesspits in the Keys are at residences built before 1970. From discussions with 
wastewater service companies in the Keys, it was found 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 have little or no associated operation and maintenance 
costs. As most of them were installed more than 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 the Monroe Cesspit Identification and Elimination Grant Program 
(discussed in detail in PEA Section 3.6.3.2.1 [Local Fees and Taxes, Environmental 
Consequences]). 
For comparison, the average monthly wastewater rates for customers that currently use non-
compliant WWTP systems in other parts of Monroe County are $56, $64, and $55 per month for 
customers of Key Haven Utilities, Ocean Reef Club, and K W Resort Utilities, respectively. 
As noted above in Table 3-3 and Section 3.6.1, there are numerous commercial businesses in the 
KLTV and KLP service areas. Like the residences in the service areas, most of these businesses 
currently use septic systems (Sheets, Pers. Comm., 2003b) Some of the larger hotels in Key 
Largo have their own advanced wastewater treatment systems, and would not require additional 
services.
Additional information related to local fees and taxes is in PEA Section 3.6.3 (Local Fees and 
Taxes).
Environmental Consequences
Under the No Action Alternative, FEMA would not fund the proposed wastewater management 
improvements. To achieve compliance with Florida Statutory Treatment Standards, residents and 
businesses would have to use other funding for improvements.
Economic effects of the No Action Alternative on local wastewater fees or taxes are difficult to 
quantify, as they will depend on the final costs of the 2010-compliant systems chosen, the 
amount of State and Federal grants and contributions, and the details of the chosen financing 
options, including applicable repayment terms. Based upon information in PEA Section 3.6.3.3, 
the No Action Alternative may result in higher wastewater management costs for KLTV and 
KLP service area residents and businesses than would be expected from either FEMA-funded 
Alternative 2 or 3. However, it should be noted that the KLWTD has adopted wastewater cost 
reasonableness goals (Resolution 2003-6) of $2,700 per EDU for system capital costs and $35 a 
month for O&M fees (KLWTD, 2003).
Under Alternatives 2 and 3, the estimated system capital cost and monthly O&M fee to service 
recipients after grant funding has been applied, is as noted above; $2,700 per EDU and $35 per 
month (with no capital costs included) for system capital costs and O&M fee, respectively. In 
addition, all property owners would be assessed a yearly tax of $35 per $100,000 of appraised 
property value (Sheets, Pers. Comm., 2003). Service area property owners would also pay for 
their on-site system abandonment and lateral connection costs, estimated between $1,500 and 
$5,000 per EDU depending on the type of existing on-site system and the amount of work 
needed to remove or abandon the system (PEA Section 3.6.3.2.2). 
Under both Alternatives 2 and 3, businesses in the service areas would be assessed wastewater 
fees in the same manner as residential service recipients, with system capital costs following the 
rates outlined above and monthly O&M fees following a flow-based rate structure. The flow-
based rate structure would follow the same per EDU cost as residential service recipients. 
Businesses that used more than one EDU worth of water would be charged accordingly. As an 
example, under Alternative 2, a business that generated 2.5 times the residential EDU amount 
would be charged 2.5 times the residential O&M rate or $87.50. Those businesses whose 
wastewater discharge rates are less than their clean water consumption rates or businesses that 
operate under extenuating circumstances will have the opportunity to discuss their situation with 
the KLWTD and will have the option to petition for a wastewater flow analysis to determine 
wastewater generation (Sheets, Pers. Comm., 2003). 
Also, under both Alternatives 2 and 3, service recipients unable to pay their system capital cost 
in full at the time of availability of service would be able to make amortized annual payments of 
principal plus interest (currently estimated at 5 percent) under a 20-year, non-ad valorem special 
assessment, which would be included on their annual property taxes (Sheets, Pers. Comm., 
2003). Under Alternatives 2 and 3, this assessment would be about $216.65 a year for 20 years. 
Under both Alternatives 2 and 3, wastewater costs would be required to be within near the 
affordability threshold of 2 percent of Median Household Income ($75 per month) and within the 
per EDU O&M ($30-60 per month) and system capital cost ranges set forth in PEA Section 3.6.3 
($3,000 to $4,500, as spread over a 20-year term).  Alternatives 2 and 3 are currently within 
these ranges. With the use of FEMA grant funding towards wastewater system costs for KLTV 
and KLP, no significant economic impacts to service recipients are expected.
3.6.4	Public Health
Affected Environment
As discussed in Section 3.2.2.2 (Nearshore and Offshore Marine Waters), beach water quality 
data has been collected since August 2000 by Florida DOH from the John Pennekamp State Park 
monitoring station on Key Largo (MM 105). On 11 separate occasions, these data indicated 
elevated levels of fecal coliform and Enterococcus sp. in the vicinity of the monitoring station 
that could potentially pose a health risk. Consequently, the Florida DOH issued five health 
advisories/warnings (DOH, 2003). The John Pennekamp State Park monitoring station is about 
2.4 miles northeast of the Key Largo project site and is the closest monitoring station to the 
service area. Public health consequences from contaminated water are described further in PEA 
Section 3.6.4.1 (Public Health, Affected Environment).
Environmental Consequences
Under the No Action Alternative, it is likely that nearshore and offshore water quality conditions 
affecting public health would improve, but the rate of improvement depends on funding to 
implement wastewater management improvements. Available Keys data do not conclusively link 
instances of infection or health problems to groundwater or offshore contamination caused by 
current sewage treatment practices. However, as described in PEA Section 3.6.4.1 (Affected 
Environment), the presence of enteric microbes in canals and nearshore marine waters can pose a 
health risk through ingestion (e.g., while swimming), inhalation contaminated water spray (e.g., 
while boating), or eating contaminated seafood (Paul et al., 1995; Caffry, Pers. Comm., 2001). 
Therefore, it may be reasonably assumed that public health risks related to the presence of 
enteric microbes exist and would continue to exist under this No Action alternative.
Under Alternatives 2 and 3, project area residents would benefit from the reduction of sewage 
discharges that would result from implementation of improved wastewater treatment facilities. 
The environmental consequences of both Alternatives 2 and 3 are discussed further in PEA 
Section 3.6.4.2.2 (Alternative 2  Centralized Wastewater Treatment Plant).
3.7	DEMOGRAPHICS AND ENVIRONMENTAL JUSTICE
Executive Order (EO) 12898 (Environmental Justice), entitled Federal Action to Address 
Environmental Justice in Minority Populations, directs Federal agencies to make achieving 
environmental justice part of its mission by identifying and addressing, as appropriate, 
disproportionately high and adverse human health or environmental effects of its programs, 
policies, and activities on minority populations and low-income populations in the United 
States EO 12898 also requires Federal agencies to ensure that public notifications regarding 
environmental issues are concise, understandable, and easily accessible. Accordingly, the 
socioeconomic and demographic conditions in the service area were examined, including 
alternative effects. 
Affected Environment
3.7.1	Population and Race
Results from the U.S. Census (2000) were obtained for the Key Largo census designated place 
(CDP), which includes the project areas (KLTV and KLP, and WWTP sites). CDPs are 
delineated cooperatively by State and local officials and the U.S. Census Bureau, following 
Bureau guidelines. The total population of the Key Largo CDP is 11,886. The population is listed 
as 94 percent white and 2 percent other ethnic groups (U.S. Census, 2000). 
3.7.2	Income and Poverty
U.S. Census (2000) data for the Key Largo CDP indicates that about 31 percent of families had 
incomes less than $35,000 per year, and about 32 percent had incomes between $35,000 and 
$59,999 per year. The remaining 37 percent had incomes greater than $60,000. The 
corresponding average family size for the Key Largo CDP was 2.8 people. 
As discussed in PEA Section 3.7 (Socioeconomics), a common indicator of income level used by 
government agencies is the county-specific estimated Median Family Income (MFI). In 2003, the 
annual MFI for Monroe County was estimated at $56,500 (U.S. Department of Housing and 
Urban Development [HUD], see citation below Table 3-4.). The indicator known as the poverty 
threshold is set for the entire nation and, with the exception of Alaska and Hawaii, is not 
adjusted for local cost-of-living differences. For the year 2003, the poverty threshold was set at 
an annual income of $15,250 for a household of three people (U.S. Census, 2003). In areas like 
the Keys, where the cost of living is higher than the national average, $15,250 consequently buys 
less, effectively making a household near the poverty threshold in the Keys poorer than similar 
households in areas where the cost of living is lower. The Monroe County Housing Authority 
currently uses the first two tiers of HUDs MFI-based income levels to administer its low-income 
assistance programs. To administer their programs fairly, HUD makes annual projections of MFI 
by county and adjusts for family size. The first two tiers of low- and very low-income levels are 
set as percentages of the county MFI. In 2003, the income limits for a family of three in Monroe 
County were $40,700 for the low-income level and $25,450 for the very low-income level. Table 
3-4 below shows HUDs FY 2003 low and very low-income levels for various family sizes in 
Monroe County.
Table 3-4. Fiscal Year 2003  HUDs Low-Income and Very Low-Income Limits, Monroe County, 
Florida  Median Family Income = $56,500
Number of People in Household

1 
2 
3 
4 
5 
6 
7 
8 
Low-
Income
$31,650
$36,150
$40,700
$45,200
$48,800
$52,450
$56,050
$59,650
Very Low-
Income
$19,800
$22,600
$25,450
$28,250
$30,000
$32,750
$35,050
$37,300
http://204.29.171.80/framer/navigation.asp?charset=utf-8&cc=US&frameid=1565&lc=en-
us&providerid=112&realname=HUD&uid=2318084&url=http%3A%2F%2Fwww.hud.gov%2F
Published annually by U.S. Department of Housing and Urban Development. 
MFI figures are projected from the most recent county-level census data.

Although no service area-specific statistics have been compiled to date, based on the above 
statistics and for project planning purposes, it is estimated that up to 25 percent of homestead-
exempt homeowners in KLTV and KLP may be considered low and very low-income. As 
described in PEA Section 3.7, it has been determined that low- and very low-income service 
recipients would incur a financial hardship if their wastewater management costs increased. 
Environmental Consequences
The installation of wastewater systems that meet Florida Statutory Treatment Standards, under 
any of the alternatives, would improve water quality in shallow aquifers, canals, and nearshore 
marine waters, and, to a lesser extent, offshore marine waters. The resulting reduced 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 Keys demographic populations.
Under the No Action Alternative, FEMA would not fund the proposed Key Largo wastewater 
management project. To comply with Florida Statutory Treatment Standards of 2010, KLTV and 
KLP residents and businesses would have to use other funding for improvements. As described 
in PEA Section 3.6.3 (Local Fees and Taxes), the No Action Alternative may result in higher 
wastewater management costs for KLTV and KLP residents and businesses than would be 
expected with the benefit of FEMA funding. Households at or below the low-income level would 
incur financial hardship if their wastewater management costs increase to levels that approximate 
the affordability threshold cited in PEA Section 3.6.3.1.2, of near 2 percent of Median 
Household Income (about $75 per month) or even the KLWTDs adopted wastewater cost goals 
(Resolution 2003-6). Furthermore, all property owners are responsible for the costs to abandon 
their onsite system and connect to a WWTP collection system, estimated between $1,500 and 
$5,000. On October 15, 2003, the Monroe County Board of County Commissioners passed 
Resolution 471-2003, which included low income assistance provisions for wastewater projects. 
KLWTD has endorsed these provisions and developed a Low-Income Assistance Plan 
(Appendix J). If the KLWTD adheres to the above affordability and low-income assistance 
resolutions for the No Action Alternative, no disproportionately high or adverse effects on low-
income populations are expected.
As described in Section 3.6.3.1, for Alternatives 2 and 3, the estimated per EDU system capital 
cost and monthly O&M fee to service recipients, after grant funding has been applied, would be 
about $2,700 and $35, respectively. There would also be the yearly tax of $35 per $100,000 of 
appraised property value. In addition, property owners would pay for their on-site system 
abandonment and lateral connection costs ($1,500 to $5,000). 
Under Alternatives 2 and 3, the above costs would be reduced for low-income and very low-
income service recipients in compliance with EO 12898. As described in PEA Section 3.7, the 
estimated amount of assistance available to cover the system capital costs for homestead-exempt 
low- and very low-income property owners under Alternatives 2 and 3 is shown in Table 3-5. 
Low-income property owners would receive assistance with at least 70 percent of their system 
capital cost and 70 percent of their existing system abandonment and lateral connection costs, up 
to $3,000. Very low-income property owners would receive assistance with at least 90 percent of 
their system capital cost and 90 percent of their existing system abandonment and lateral 
connection costs, up to $3,000. For low-income property owners, the estimated resulting system 
capital cost after assistance would be about $810 in one payment or about $65 a year for 20 years 
(about $1,299.93 total). For very low-income property owners, the estimated resulting system 
capital cost after assistance would be about $270 in one payment, or about $21.67 a year for 20 
years (about $433.31 total).

Table 3-5. Alternatives 2 and 3 Low-Income and Very Low-Income Funding Assistance for the 
System Capital Cost 

Amount of Assistance - 
% of Capital Cost 
Covered
Estimated System 
Capital Cost After 
Assistance
Estimated Annual 
Payment Assessed 
with Property Tax*
Low-Income 
Qualified Family
70%
$810.00
$67.78
Very Low-Income 
Qualified Family
90%
$270.00
$22.59
*Amortized annual payment of principal plus interest at 5% under a 20-year non-ad valorem special assessment.

Because the property owners total cost for on-site system abandonment and lateral connection 
costs will vary from one property to the next, it is not possible to estimate the actual final costs to 
property owners with the assistance program. Nevertheless, the assistance program would cover 
at least 90 percent of this cost for very low-income property owners (up to $3,000 total) and at 
least 70 percent of this cost for low-income property owners (up to $3,000 total).
At this time, no programs would be available to help low- and very low-income populations to 
pay the monthly O&M fees. 
Under Alternatives 2 and 3, property owners unable to pay their system capital cost in full at the 
time of availability of service would be able to make amortized annual payments of principal 
plus interest (at 5 percent) under a 20-year, non-ad valorem special assessment, which would be 
included on their annual property taxes (Sheets, Pers. Comm., 2003).
In resolution 471-2003, Monroe County adopted an Implementation Plan that is consistent with 
the above provisions, to assist Key Largos low-income service recipients. This assistance will 
likely be funded through a Community Development Block Grant (KLWTD, 2003).
The Community Development Program Administrator in the Special Programs Office of the 
Monroe County Housing Authority would administer the low-income assistance program for Key 
Largo. The Implementation Plan would be administered according to the Countys Housing 
Assistance Plan (HAP) (Amended). In part, the HAP states that all funds awarded would be in 
the form of grants to homeowners and loans to property owners providing rentals to qualified 
beneficiaries. The process for selecting, accepting, reviewing and approving requests for 
assistance is outlined in Appendix J (KLWTD, 2003). 
FEMA does not have specific requirements under EO 12898 to assist low-income renters. 
KLWTD has committed to provide such assistance to homeowners who rent their property to 
income-eligible tenants. KLWTD intends to provide the same level of assistance to this renting 
population, as described above.
FEMA would require Monroe County/KLWTD to meet the above guidelines during project 
implementation in order for the KLWTD to receive grant funding. With the implementation of 
the FEMA assistance program and the use of grant funding, low-income or very low-income 
property owners would incur no highly disproportionate or adverse economic effects under either 
alternative.
3.8	HAZARDOUS MATERIALS AND WASTES
Affected Environment
A Phase I Environmental Site Assessment was done by Environmental Consulting & 
Technology, Inc. (ECT) to evaluate possible hazardous materials and wastes at the Alternative 2 
WWTP site. Phase I results indicated a low potential for site chemical contamination from onsite 
sources; little potential for offsite contamination from onsite sources; and little potential for site 
impact from offsite contaminant migration in surface and/or groundwater from adjacent sites 
within a 0.25-mile radius of the property (ECT, 2000). 
Environmental Consequences
Under the No Action Alternative, effects related to hazardous materials and wastes are expected 
to be similar to Alternatives 2 and 3 described below. Wastewater sludge from the Keys would 
continue to be hauled to a transfer facility and taken to a wastewater facility in Miami-Dade 
County for treatment.
Under Alternatives 2 and 3, wastewater would be treated as described in Section 2.2.2 (Waste 
Water Treatment Plant). Additional environmental consequences of these alternatives are 
discussed in PEA Section 3.8.2.2 (Alternative 2  Centralized Wastewater Treatment Plant 
Alternative). 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, for eventual disposal at the Miami-Dade wastewater facility. 
The most common hazardous materials that enter the wastewater systems are grease and typical 
household cleaning products (Rios, Pers. Comm., 2001). The effects of an inadvertent disposal of 
hazardous wastes into wastewater effluent is more likely to affect smaller plants than larger 
plants like that proposed under Alternatives 2 and 3, because the materials are usually more 
diluted in the larger plants. However, the frequency of these incidents at a smaller facility should 
be correspondingly lower, so there would likely be no net increase in potential concern. 
Hazardous materials that would enter the WWTP may kill the biological component that treats 
the wastewater. Wastewater contaminated with hazardous materials would have to be pumped 
out and sent to a larger treatment plant for reprocessing.
Treatment chemicals would be added at various points in the treatment process. Influent 
wastewater pH may be adjusted by adding sodium hydroxide, a buffering agent. The sodium 
hydroxide would immediately dissolve, raising and neutralizing the wastewater pH. To remove 
phosphorus from the wastewater, metal salts may be added to coagulate the excess phosphorus. 
The resultant sludge would be collected and disposed, as previously described, at a Miami-Dade 
wastewater facility. The metal salts would be disposed with this material and would not be 
released to the aquifer or aquatic environment. Disinfectants, such as sodium hypochlorite or 
calcium hypochlorite, may be added to kill remaining biologic pathogens as the wastewater 
effluent is released to the environment. These materials would dissolve and disinfect the organic 
materials. In the process of disinfection, by-products may be formed through the interaction of 
chlorine with dissolved organic in the wastewater. When the treated effluent is discharged, these 
by-products may be diluted, volatized, or absorbed by nearby sediments and would not represent 
a potential hazard (U.S. Geological Survey, 2003).
Because no recognized environmental conditions were found at the Alternative 2 WWTP site, no 
notable environmental effects or hazardous materials abatement are anticipated for construction. 
If the Alternative 3 WWTP site is selected, a Phase I Environmental Property Assessment would 
be conducted in accordance with American Society of Testing and Materials (ASTM E)-1527 
before work begins, to identify site hazardous material contamination concerns.  If contamination 
is found, abatement would be required before site work would begin. Since the Alternative 3 
VPS is located on a portion of the Alternative 2 WWTP site, no hazardous materials concerns are 
anticipated for VPS construction.
3.9	INFRASTRUCTURE
3.9.1	Traffic and Circulation
Affected Environment
The project area is within the Tavenier Highway capacity segment (MM 91.5 to MM 99.5) and 
the Key Largo Highway capacity segment (MM 99.5 to MM 106). The 2001 level of service 
(LOS) for both segments of US-1 in the project area is Class A, classified as good, with a 
travel speed criteria of 51 mph or greater; median speed through the segment was 54 mph (URS, 
2002b). This LOS is above the LOS C standard (45.0 mph to 47.9 mph) adopted for Monroe 
County. County roads, such as those in KLP and KLTV, are subject to a lower standard (LOS D) 
than US-1. Based on the analysis found in the Technical Document of the Monroe County Year 
2001 Comprehensive Plan, all County roads are operating at or above LOS D (Monroe County, 
2002).
Environmental Consequences
Under the No Action Alternative, FEMA would not fund the proposed Key Largo wastewater 
management project. Therefore traffic and circulation effects would be delayed until funding is 
secured for system upgrades to the Florida Statutory Treatment Standards of 2010. Nonetheless, 
it is anticipated that effects would be similar to those under Alternatives 2 and 3.
Under Alternatives 2 and 3, construction traffic would temporarily increase during wastewater 
project implementation. Temporary construction traffic would increase near the proposed 
WWTP facility and would last for about 8 months from the start of construction. Construction 
activities are not expected to interrupt vehicular traffic on US-1. Collection system installation 
would temporarily hinder, but not obstruct, traffic movement to and from local businesses and 
residences in KLTV or KLP. Under Alternative 3, pipeline trenching activities for building the 
transmission system would not obstruct the access roads to US-1.
Public service disruptions from construction are expected to be brief and infrequent. During 
construction, minor detours may be needed to allow homeowners access to their property 
(FKAA, 2002). A traffic control plan would be developed and implemented as required by 
funding and/or permitting agencies. This plan would include specific information about 
temporary traffic control, alternate routes, staging area locations, and optimal working times to 
minimize traffic disruption. Construction activities in roadway ROWs would not be subject to 
Monroe County Land Development Regulations since development, as defined by the Monroe 
County Comprehensive Plan (Monroe County, 1995), excludes roads. Florida Department of 
Transportation permitting may be required for work in the US-1 ROW.
3.9.2	Utilities and Services
Affected Environment
Electricity, gas, and potable water services are discussed in PEA Section 3.9.2.1 (Public Utilities 
and Services, Affected Environment). There is an existing 12-inch water main in the east ROW 
of US-1 situated immediately adjacent to the Alternative 2 proposed WWTP site at MM 100.5. 
The main types of wastewater treatment systems in the service areas are septic tanks and 
cesspools. There are about 467 of these systems in the service areas (FKAA, 2003)
Environmental Consequences
Under the No Action Alternative, the KLWTD would not receive FEMA funds for wastewater 
management. However, KLTV and KLP residents would still be required to comply with the 
Florida Statutory Treatment Standards of 2010. Once an alternate funding source has been 
secured, it is anticipated that effects on services and utilities would be similar to those under 
Alternatives 2 and 3.
Under Alternatives 2 and 3, there would likely be temporary utility and service disruptions 
during construction. Key Largo is largely developed and has all utilities/services that would 
support the proposed wastewater treatment improvements. The KLWTD would contact the 
diggers/excavation utility hotline at the Sunshine State One Call Center at least 2 business days 
before construction to identify underground utilities that may be near the project sites and to 
ensure that there are minimal disruptions to services during wastewater project construction. 
Brief disruption to wastewater service will occur as residents and businesses connect to the new 
wastewater system. If proper utility notification and construction practices are observed, adverse 
long-term effects on service area utilities and services are not expected. Long-term beneficial 
effects from increased service reliability and uniform maintenance are expected as current 
wastewater treatment methods are discontinued and wastewater treatment becomes centrally 
operated. For both Alternatives 2 and 3, sewer collection mains would be installed with a 10-foot 
horizontal separation from the existing FKAA water system as required by FDEP. Proposed rule 
changes may revise the required separation of water and vacuum sewer collection mains to a 3-
foot horizontal separation and 12-inch vertical separation. However, the current applicable rule 
requirements would be applied at the time of construction. No water service interruptions are 
expected. 
3.10	LAND USE AND PLANNING
Affected Environment
Key Largo is part of unincorporated Monroe County. Zoning for the proposed Alternative 2 
WWTP site is Suburban Commercial. Permitted land uses for the island include mobile homes, 
detached dwellings, vacation rentals, and commercial fishing uses.  Figures 3-5a and 3-5b 
illustrates project site/area land uses. Zoning for the proposed Alternative 3 WWTP site is Urban 
Residential Mobile Home. The affected environment for land use and planning is further 
discussed in PEA Section 3.10.1 (Land Use and Planning, Affected Environment).

 
[Figure 3-5a. Project Area Land Use. (Service Areas and Alternative 2 WWTP site)
Figure 3-5a is a land use map of the area around the Alternative 2 WWTP site. The Alternative 2 
site is zoned Suburban Commercial.] 

[Figure 3-5b. Project Area Land Use. (Alterative 3 WWTP site)
Figure 3-5b is a land use map of the area around the Alternative 3 WWTP site. The Alternative 3 
site is zoned Urban Residential Mobile Home.] 


State-identified CARL is not present in the service area. However, there are CARL lands near 
the Alternatives 2 and 3 sites. The Alternative 2 site borders the Newport Hammock site. The 
Newport Hammock site is a 191-acre high-quality hardwood hammock habitat parcel (FDEP, 
2003).  The FDEP considered purchase of the Alternative 2 site under the CARL program before 
Monroe County purchased it (FFWCC 2000, USFWS 2000). The Point Charles Hammock site is 
located next to the Alternative 3 WWTP site. The Port Charles Site is of lesser quality than the 
Newport Hammock site (FDEP, 2003). Two Coastal Barrier Resource System (CBRS) units 
(Coastal Barrier Resource Area Zones), FL-37 and FL-36P are located near the project sites 
(Reisinger, Pers. Comm., 2003). FL-37 is located near MM 96 and FL-36 is located near MM 
102. 
The portion of Key Largo associated with the project sites is located within a larger Planning 
Area Enumeration District 21 (located from approximately MM 99.5 to MM 112.5; Monroe 
County, 2002).
Environmental Consequences
Under the No Action Alternative, KLWTD would not receive FEMA funds for wastewater 
management. KLTV and KLP residents would still need to comply with Florida Statutory 
Treatment Standards of 2010. It is anticipated that once funding is secured, effects on land use 
and planning would be similar to those under Alternatives 2 and 3.
Under Alternative 2, the proposed WWTP would be on Monroe County property, which may be 
deeded to the KLWTD. In accordance with the Monroe County Comprehensive Plan (Sections 
9.5-257.4 and 9.5-257.5), construction of a new treatment plant or pump station would not 
require amendments to the permitted land uses in areas zoned either Suburban Commercial or 
Suburban Residential as discussed in PEA Section 3.10.2.1 (Land Use and Planning  
Environmental Consequences  Alternative 1).
Effects on land use and planning for Alternative 2 are further discussed in PEA Section 3.10.2.2 
(Land Use and Planning, Environmental Consequences). Construction and operation of the 
WWTP would be consistent with the current land use at the adjacent FKAA maintenance 
facility. 
Under Alternative 3, the property would have to be purchased by Monroe County or the 
KLWTD. In accordance with the Monroe County Comprehensive Plan (Sections 9.5-257.4 and 
9.5-257.5), construction of a new treatment plant or pump station would not require amendments 
to the permitted land uses in areas zoned Urban Residential Mobile Home as discussed in PEA 
Section 3.10.2.1 (Land Use and Planning  Environmental Consequences  Alternative 1). Under 
this alternative, the VPS would be constructed at the Alternative 2 site. The effects on land use 
and planning would be similar to those previously stated. 
Effects on land use and planning for Alternative 3 are further discussed in PEA Section 3.10.2.2 
(PEA Section 3.10.2.2 (Land Use and Planning, Environmental Consequences). Construction 
and operation of the WWTP would be consistent with the current land use at this property.
As described in PEA Section 3.10 (Land Use and Planning), development within the Keys is not 
controlled by addition of key infrastructure, but instead by Monroe Countys ROGO permit 
allocation system. Installing new wastewater treatment infrastructure in the Florida Keys is 
essential to effectively treat existing wastewater flows, and would introduce or support increased 
development. Therefore, growth and development occurring after implementation of either 
alternative would be the result of established county planning and not of the proposed 
wastewater management improvements. 
Construction activities would be limited to the project sites and would not directly impact CARL 
lands. However, under Alternative 2, about 19 acres of the 22-acre parcel for the WWTP would 
be preserved in perpetuity under a conservation easement. Nearby CBRS units, would not be 
affected by either alternative or served by the proposed WWTP.
FEMA consulted the Florida DCA on potential project effects. In a letter dated August 5, 2003, 
the Florida Office of Intergovernmental Programs, on behalf of DCA, FDEP and the South 
Florida Regional Planning Council, stated that for Alternatives 2 and 3, water quality 
improvement in the Keys was an agency priority and that it supports the proposed projects and 
they are consistent with the States comprehensive coastal management program (Appendix B).
3.11	NOISE AND VISUAL RESOURCES
3.11.1	Noise
Affected Environment
Noise within the project areas has not been well documented but is associated primarily with 
traffic. Sensitive noise receptors are considered to be areas that sustain greater effects from noise 
sources than other areas (such as industrial areas). Sensitive receptors to noise typically include 
churches, schools, homes and residential areas, hospitals, and public facilities. 
Potential noise receptors in the project areas were documented by URS on April 24, 2003. As 
discussed in PEA Section 3.11.1.1 (Noise), the KLTV and KLP service areas are urban 
residential and the overall noise level for this type of classification is moderately loud along a 
major roadway (US-1). These service area residents would be the noise receptors. The proposed 
Alternative 2 WWTP site consists of a 22-acre tropical hardwood hammock parcel, of which 
only 2.6 acres would be developed. This forested natural site may be considered a mixed urban 
commercial/residential area. The lots located north of the proposed project site are vegetated and 
provide a level of noise buffering for these properties. An existing FKAA facility and 
commercial businesses occur south of the proposed project site. Most of the noise at the 
proposed project site is from:
*	General vehicle operation along US-1, about 20 feet west of the project site;
*	FKAA facilities immediately south and adjacent to the site;
*	The Keys sanitation waste transfer facility about 50 feet east of the site (across Central 
Avenue);
*	Commercial businesses on the west side of US-1, about 100 feet from the site; and
*	Commercial businesses about 880 feet south of the site.
Observed noise receptors near the project site include:
*	Residents near of Central Avenue (the closest home is about 300 feet east of the site parcel); 
*	The Church of Christ at 100695 Overseas Highway, about 350 feet north of the site;
*	Key Largo Church of the Nazarene, about 100 feet west of the site, on the west side of US-1;
*	Key Largo Seventh Day Adventist Church, about 100 feet west of the site, on the west side 
of US-1; and 
The Alternative 3 WWTP site consists of developed commercial land. Natural undeveloped 
lands, characterized as hardwood hammock habitat, border the site to the northeast and 
southwest. The site is bordered by the Atlantic Ocean on the east and US-1 to the west. The 
vegetation currently provides some noise buffering north and south of the site. The site may be 
considered a commercial area along a major roadway. As discussed in PEA Section 3.11.1 
(Noise), the overall noise level for this type of classification is moderately loud. Noise 
characteristics at the Alternative 3 VPS site are as described under Alternative 2. Most noise at 
the WWTP site is from:
*	General vehicle operation along US-1 about 20 feet west of the site;
*	Commercial businesses adjacent to the site;
*	A marina about 1,000 feet south of the site; and
*	Commercial businesses adjacent to the WTS along US-1.
The only observed noise receptors near the project site are residents, the closest home is about 
500 feet west of the project site on the west side of US-1.
Environmental Consequences
Under the No Action Alternative, the KLWTD would not receive FEMA funds for wastewater 
management projects. Service area residents would still need to comply with Florida Statutory 
Treatment Standards of 2010. It is anticipated that effects on noise levels, once funding is 
secured, would be similar to those under Alternatives 2 and 3.
Alternatives 2 and 3 would involve a similar range of construction activities and, the noise 
effects within the project areas would be similar as discussed in PEA Section 3.11.1.2 
(Environmental Consequences). An increase in localized noise levels would occur at various 
locations throughout the approximate 8-month construction period (Teague, Pers. Comm., 2001). 
KLP and KLTV residents may experience disruptive noises during construction work hours, but 
these are permissible under current Monroe County Code (Article III, Sections 13-51 to 13-55). 
The potential for residents to experience hearing damage or loss due to construction noises is 
considered low.
Under Alternatives 2 and 3, construction and operation of the WWTP would have little impact 
on sensitive receptors due to their distance from the construction area. However, construction 
personnel would be required to observe the established noise ordinance of Monroe County Code 
to reduce disruptive noises to adjacent areas. For Alternative 2, it is anticipated that the FKAA 
maintenance facility to the south and the undeveloped 19-acre parcel to the north and east of the 
site would provide adequate noise buffering from both plant construction and operation. For 
Alternative 3, it is anticipated that US-1 to the, vegetative areas on parcels to the north and south, 
and the Atlantic Ocean to the east would provide adequate noise buffering from both plant 
construction and operation. Should the adjacent lots be developed in the future, vegetative 
buffering may be required to mitigate potential noise pollution. 
To protect against noise effects, construction workers and plant operators would be required to 
comply with applicable occupational safety regulations and implement appropriate noise control 
measures, such as wearing hearing protection (e.g., earplugs, ear muffs, a helmet, or canal caps) 
and limiting exposure times. If these measures are implemented during construction and 
operations, no adverse noise effects on workers are anticipated.
3.11.2	Visual Resources
Affected Environment
As discussed in PEA Section 3.11.2 (Visual Resources), visual resources refer to the landscape 
character (what is seen), visual sensitivity (human preferences and values regarding what is 
seen), scenic integrity (degree of intactness and wholeness of landscape character), and 
landscape visibility (relative distances of seen areas) of a geographically defined viewshed. A 
visual resources assessment was conducted for the project areas by URS on April 24, 2003.
Key Largo is largely developed and is dominated by residential areas, roadways, canals, and 
commercial structures. Remaining vegetation on Key Largo has many native plant species, 
although habitat fragmentation and invasion by exotic species is a problem. There are areas of 
mangrove fringe along both sides of the island.  
The Alternative 2 WWTP site is a forested natural parcel that is designated a mixed urban 
commercial/residential land use along a major roadway. The site consists of undeveloped high-
quality hardwood hammock habitat. Only 2.6 acres located on the southern boundary of the site 
are proposed for WWTP construction. The hardwood hammock habitat would offer natural 
buffering for aesthetics to the north, east, and west. No other natural aesthetic buffers exist 
between the project area and adjacent commercial properties to the south. Dominant features of 
the project site viewshed include:
*	Overseas Highway (US-1);
*	FKAA facility buildings and a large parking area;
*	Commercial structures; and
*	Undeveloped lands, including hardwood hammock. 
The Alternative 3 WWTP site is a developed commercial area along a major roadway. The site is 
an open area with forested parcels to the north and south. The Atlantic Ocean and US-1 border 
the site on the east and west, respectively. The surrounding area consists of a mix between 
commercial areas, single-family homes, and undeveloped natural lands (predominantly 
hardwood hammock habitat). Dominant features of the project site viewshed include:
*	Overseas Highway (US-1);
*	Commercial structures;
*	Marine waters;
*	Undeveloped lands, including hardwood hammock.
Environmental Consequences
Under the No Action Alternative, the KLWTD would not receive FEMA funds for wastewater 
improvement projects. Service area residents would still need to comply with Florida Statutory 
Treatment Standards of 2010. It is anticipated that effects on visual resources, once funding is 
secured, would be similar to those under Alternatives 2 and 3. 
Under Alternatives 2 and 3, WWTP or pump station siting would not affect the service areas 
scenic quality because both proposed sites are located away from the service areas. The facility 
may have a negative effect on the aesthetic values of the adjacent forested sites and marine 
waters. To mitigate this effect, the areas surrounding the site may be landscaped with fences or 
vegetative screens to obscure views from US-1, the forested areas, and marine waters. 




Section 4 Cumulative Effects
Under the No Action Alternative, FEMA would not fund the proposed wastewater management 
improvements. The County (Monroe County, private wastewater utility operators, business 
owners, and homeowners) would have to obtain alternate funding to finance the large capital 
costs to improve their wastewater treatment systems to meet the Florida Statutory Treatment 
Standards of 2010. Communities that currently use on-site systems, such as cesspools and septic 
systems to manage wastes would have to build community or regional WWTPs, install and 
OWNRS. As a result, the cumulative effects on physical, biological, and socioeconomic 
resources would be similar for all alternatives, as discussed below. The Monroe County Planning 
Department provided the following list of infrastructure projects recently completed, under 
construction, or planned near the project area (Buckley, Pers. Comm., 2003):
*	Tradewinds Hammocks-Phase I: 68-unit affordable housing project at MM 101.5; recently 
completed construction;
*	Tradewinds Hammocks-Phase II: 52-unit affordable housing project at MM 101.5; in the 
planning phase; and
*	KLTV Stormwater Management Project: installation of about 6,720 linear feet of vegetated, 
roadside swales to reduce nuisance flooding (in the planning phase - construction expected in 
fiscal year 2004).
4.1	TOPOGRAPHY, SOILS AND GEOLOGY
Construction of new wastewater treatment services on Key Largo would cumulatively increase 
the impervious surface area; however, the actual land area required for these activities is small 
(maximum of 2.6 acres) relative to the total surface area of the island. Soils would be temporarily 
disturbed during construction, but the implementation of standard construction BMPs for erosion 
and sedimentation control would decrease the potential for long-term surface soil erosion. No 
cumulative effects are anticipated for topography and geology. 
4.2	WATER RESOURCES AND WATER QUALITY
Cumulative effects on water resources, including surface waters and wetlands, and water quality 
for the Florida Keys are discussed in PEA Section 4.2.2 (Water Resources and Water Quality). 
Considering Keys-wide wastewater and stormwater management activities and the 
Comprehensive Everglades Restoration Program (CERP), cumulative water quality 
improvements are expected in the service area, in the canals and nearshore marine waters and, to 
a lesser extent, in offshore marine waters. The KLTV stormwater project is an example of these 
actions.
4.3	BIOLOGICAL RESOURCES
Cumulative effects on marine biological resources are expected to be beneficial due to improved 
groundwater, surface water, and marine water quality and are further discussed in PEA Section 
4.2.3 (Biological Resources). Implementation of Alternative 2 would eliminate about 2.6 acres of 
hardwood hammock habitat. This, combined with other development pressure in the Key Largo 
area, would have a negative cumulative effect on terrestrial biological resources in the area. 
Mitigation measures include: USFWS review of Monroe County Building Permits through a 
previous formal consultation with FEMA for compliance with ESA and the implementation of 
Monroe Countys tiering system whereby land use is mapped into three categories (Tier I 
Conservation, Restoration, Protection; Tier II Transition, Reduce Sprawl; and Tier III 
Redevelopment, Infill Development) and development is steered away from Tier I and II lands. 
4.4	AIR QUALITY
Potential cumulative effects on air quality are expected to be minor and are discussed in PEA 
Section 4.2.4 (Air Quality). 
4.5	CULTURAL RESOURCES
Because non-Federally funded wastewater projects under the No Action Alternative would not 
be subject to Section 106 review for potential effects on cultural resources, potential cumulative 
effects on historic and cultural resources may occur. Coordination and project review with the 
SHPO and the Monroe County Historic Preservation Society would reduce the effects on cultural 
resources from ground-disturbing activities associated with wastewater projects. Cumulative 
effects on cultural resources are not anticipated and are discussed in PEA Section 4.2.5 (Cultural 
Resources).
4.6	SOCIOECONOMICS
The implementation of improved wastewater services from the proposed and future projects 
would cumulatively improve ground and nearshore water quality and would help reduce the 
number of Keys beach and canal health advisories. This would likely increase the number of 
visitors to beaches that formerly posted health advisories and/or reduce visitor pressure on 
alternate beaches and recreational activities, consequently having a positive effect on tourism. 
The cumulative effects of a strong tourism sector on the Keys economy would be positive, with a 
resulting increase in demand for goods and services. Water quality improvements would also 
benefit commercial and recreational fisheries to the extent they are currently being adversely 
affected by nutrient and biological 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 stone crab, would benefit from improved water quality. Benefits may 
range from relatively minor to potentially substantial improvements in harvest rates, thus 
benefiting the fishing industry, related industries, and consumers. With the use of FEMA funding 
to reduce the Key Largo wastewater project capital costs, no significant cumulative economic 
impacts on service recipients are expected. 
4.7	DEMOGRAPHICS AND ENVIRONMENTAL JUSTICE
The wastewater facility siting is not expected to have any cumulative adverse effects on minority 
and/or low-income populations. Although implementation of any of the alternatives would 
generally result in increased wastewater disposal costs for service recipients, these costs would 
be substantially reduced for qualifying low-income homeowners through implementation of the 
PEA financial assistance guidelines. No significant adverse cumulative economic effects on low-
income service recipients are expected from Alternatives 2 or 3. The PEA provisions would not 
be required for the No Action Alternative; consequently, cumulative economic effects on low-
income homeowners would depend on the chosen system and sponsors rate structure. 
Cumulative effects on demographics and environmental justice are further discussed in PEA 
Section 4.2.7 (Demographics and Environmental Justice).
4.8	HAZARDOUS MATERIALS AND WASTES
Potential cumulative effects from hazardous materials and wastes are not expected under any of 
the alternatives, as discussed in PEA Section 4.2.8 (Hazardous Materials and Wastes).
4.9	INFRASTRUCTURE
Building wastewater facilities as proposed in Alternatives 2 or 3, in combination with other 
wastewater improvement activities throughout the Keys, would lead to an overall centralization 
of wastewater treatment systems as opposed to individual septic tanks and cesspits. This should 
improve the maintenance and servicing of wastewater systems and improve overall water quality 
throughout the Keys. 
4.10	LAND USE AND PLANNING
The installation of new wastewater facilities is not expected to change the Countys existing 
growth pattern. Since the proposed facilities are outside of conservation areas, CARL lands, and 
CBRS units, adverse cumulative effects on these special status lands are not anticipated. The 
Florida Keys Tidal Restoration Project, a component of the CERP, is located south of Key 
Largo; so no cumulative effects with this project would occur. PEA Section 4.2.10 (Land Use 
and Planning) further discusses the cumulative effects of the alternatives on land use and 
planning.
4.11	NOISE AND VISUAL RESOURCES
Potential cumulative effects from noise and on visual resources are expected to be minor and are 
discussed in PEA Section 4.2.11 (Noise and Visual Resources).


Section 5 Public Participation
FEMAs public involvement activities for the proposed Key Largo wastewater project began 
with the publication of a Notice of Intent (NOI) (Appendix D) to prepare this Draft SEA. The 
NOI was published in The Upper Keys Reporter on May 30 2003 and in the Key West Citizen on 
May 27, 2003. 
In addition to FEMAs public involvement, the FKAA, KLWTD, and Monroe County Board of 
County Commissioners have discussed this project during some of their regularly scheduled 
monthly public meetings over the past year. Similarly, Monroe County held a series of public 
meetings throughout the Keys during the development of the MCSWMP, as described in PEA 
Section 5 (Public Involvement).
The Draft SEA is being released November 21, 2003, for a 30-day intergovernmental review and 
public comment period. The Draft SEA is being sent to the agencies and organizations listed in 
Appendix B and will be available to the public at the Key Largo Branch of the Monroe County 
Public Library (101485 Overseas Highway, Key Largo, FL 33047). It is also available on the 
FEMA (www.fema.gov) website. Comments received to date are included in Appendix B. 
FEMA will hold a public meeting on the proposed project on December 4, 2003, at the Monroe 
County Key Largo Branch Library. 
As part of its NEPA process, FEMA will review comments from the public and government 
agencies and will address these comments in the Final SEA. Monroe County held a series of 
public meetings throughout the Keys during the development of the MCSWMP, as described in 
PEA Section 5 (Public Involvement).



Section 6 Mitigation Measures and Permits
6.1	MITIGATION
To mitigate effects of the chosen alternative, the project applicant would be required to:
*	Develop an approved Erosion and Sediment Control Plan;
*	Implement appropriate BMPs during construction;
*	Use conventional site preparation techniques before and during construction;
*	Plant appropriate vegetative barriers around the WWTP site to reduce construction noise and 
obscure views from US-1 and adjacent residences;
*	Develop and fully implement a Stormwater Pollution Prevention Plan, under FDEP NPDES 
requirements; 
*	Ensure that construction workers comply with the established noise ordinances and with all 
applicable occupational safety regulations;
*	For Alternative 2, the WWTP site design must minimize construction effects to the hardwood 
hammock and to threatened and endangered species consistent with the BA and BO, 
including executing a conservation easement for 19.4 acres, restoring 2.6 acres of hammock, 
and transplanting key tree species from the construction area to the conservation area (See 
Appendices H and I);
*	For Alternative 2, KLWTD would comply with Monroe County Land Development 
Regulations Environmental Design Criteria for High Hammock (see Appendix H);
*	Limit residential service recipients system capital costs to no more than those presented in 
the PEA Section 3.6.3.2.2 ([Centralized Wastewater Treatment Plant Alternative] $4,500 per 
EDU after grant funding has been applied);  
*	Provide wastewater service (inclusive of any amortized system capital costs) at a cost that 
falls near the affordability threshold described in PEA Section 3.6.3.2.2 ([Centralized 
Wastewater Treatment Plant] $75/month); and 
*	Implement financial assistance, for qualifying low-income and very low-income service 
recipients,, for system capital and service lateral and onsite system abandonment costs 
consistent with guidelines and definitions as described in PEA Section 3.7.1.5 (Centralized 
Wastewater Treatment Plant Alternative).
6.2	PERMITS AND LICENSES
Permits required to build and operate the Key Largo Wastewater Treatment System are listed in 
PEA Appendix E (Applicable Permit Information). These permits may include an Application 
for a Domestic Wastewater Facility; Application to Construct/Operate/Abandon Class V 
Injection Well Systems; a Construction/Clearance Permit; a Certification of Construction 
Completion; an Authorization for Use; an Application for Plugging and Abandonment Permit; a 
Notification to the FDEP of Ownership; and a Certification of Monitor Well Completion. 
Construction activities would also require authorization in the form of two Environmental 
Resource Permits (ERPs); one from the FDEP and one from the Monroe County Growth 
Management Division NPDES permit for stormwater discharges from construction activities. 
Siting the wastewater treatment system in the 100-year floodplain will require compliance with 
Monroe Countys Floodplain Ordinance. Moreover, because it is considered a critical action 
under EO 11988, the plant and its critical operating components must be protected to the 500-
year flood per 44 CFR Part 9.11.


Section 7 Consultations and References
Boyle Engineering Corporation (Boyle). 2003. Key Largo Wastewater Treatment 
District. Key Largo Trailer Village Wastewater System. Preliminary Design 
Report.
Buckley, Jerry. 2003. Monroe County Planning Department. Personal communication 
with Laura Cherney, URS Group, Inc.
Caffry, Wendy. 2001. Medical Technologist, Lower Keys Medical Center. Personal 
communication with Jonathan Randall, URS Group, Inc.
Chiappone, M. 1996. Marine Benthic Communities of the Florida Keys. In: Site 
Characterization for the Florida Keys National Marine Sanctuary and Environs, 
Volume 4. The Preserver, Zenda, Wisconsin.
Chiappone, M. and K.M. Sullivan. 1994. Ecological Structure and Dynamics of 
Nearshore Hardbottom Communities in the Florida Keys. Bulletin of Marine 
Science 54(3):747-756.
_______. 1996. Functional Ecology and Ecosystem Trophodynamics. In: Site 
Characterization for the Florida Keys National Marine Sanctuary and Environs, 
Volume 8. The Preserver, Zenda, Wisconsin. 
Department of Health (DOH). 2002. Florida Healthy Beaches Program. 
http://apps3.doh.state.fl.us/env/beach/webout/default.cfm.
Environmental Consulting & Technology, Inc. (ECT). 2000. Phase I Environmental Site 
Assessment Report, Key Largo Property. 
Federal Emergency Management Agency (FEMA). 1995 Flood Insurance Rate Maps, 
Monroe County, Florida. Panels, 1004 and 1006. 
Florida Department of Environmental Protection (FDEP). 2003. Florida Forever Five 
Year Plan. http://www.dep.state.fl.us/lands.
Florida Fish and Wildlife Conservation Commission (FFWCC). 2003. Letter to FEMA 
regarding MM 100.5 parcel.
Florida Keys Aqueduct Authority (FKAA). 2003. Conceptual Design Report, Alternate 
Wastewater Management System for the Key Largo Trailer Village, Key Largo, 
Florida.
_______. 2002. Wastewater Management System for the Key Largo Trailer Village Area, 
Monroe County, Florida. Basis of Conceptual Design Report.
FloridaKeys.com. 2003. Key Largo Tourism. http://www.fla-keys.com/keylargo/.
Florida Marine Research Institute (FMRI). 2000. Benthic Habitats of the Florida Keys. 
Technical Report TR-4. In association with the National Oceanic and 
Atmospheric Administration (NOAA) and the Florida Fish and Wildlife 
Conservation Commission. 
_______. 1992. Benthic Habitats of the Florida Keys CD-ROM, ARC\INFO Coverage. 
NOAA. 
Fonseca, A.S., W.J. Kenworthy, and G.W. Thayer. 1998. Guidelines for the Conservation 
and Restoration of Seagrasses in the United States and Adjacent Waters. NOAA 
Coastal Ocean Program Decision Analysis Series No. 12. NOAA Coastal Ocean 
Office, Silver Spring, Maryland. 222 pp.
Garcia, Carlos. 2003. Senior Hazardous Waste Specialist, URS Group, Inc. Personal 
Communication with Ramon Mendieta, URS Group, Inc.
Hobgood, Winston. 2003.  Personal Communication with Science Kilner of FEMA 
Region VI on November 19.
Key Largo Wastewater Treatment District. 2003. Resolution 2003-6. Passed and 
Adopted, January 22.
Key Largo Wastewater Treatment District. 2003a. Key Largo Wastewater Low-Income 
Affordability Implementation Plan.
Keys Technologies. 2003. Key Largo Tourism. http://www.pennekamp.com/fish/.
Kruczynski, W. 1999. Water Quality Concerns in the Florida Keys: Sources, Effects, and 
Solutions. Florida Keys National Marine Sanctuary Water Quality Protection 
Program, NOAA.
McNeese, P. 1998. Florida Keys Advance Identification of Wetlands (ADID) Project 
Technical Summary Document.
Monroe County. 2002. Monroe County Public Facilities Capacity Assessment Report, 
Department of Planning and Environmental Resources. July.
_______. 2000. Monroe County Sanitary Wastewater Master Plan. Volume 1. Submitted 
by CH2MHILL. June.
_______. 2001. Stormwater Management Master Plan. Prepared by Camp, Dresser and 
McKee, Inc.; Keith and Associates, Inc. in association with Environmental 
Consulting Systems; Glen Boe and Associates; Mote Marine Laboratories; The 
Market Share Company; and Valerie Settles, Esq. Vol. 1 (February), Vol. 2 
(August).
_______. 1995. Monroe County Year 2010 Comprehensive Plan. Technical Document. 
Monroe County Planning Department. Key West, Florida.
Monroe County Property Appraiser database. 2001. 
Meyers, R.L. and J.J. Ewel (Eds.). 1990. Ecosystems of Florida. University of Central 
Florida Press. Orlando, Florida.
Nutting Engineers, Inc. 2002. Report of Preliminary Geotechnical Exploration. Proposed 
Waste Water Treatment Plant MM 100.5 Key Largo, Key Largo, Florida. Project 
# 204.6. 
Paul, J.P., J.B. Rose, J. Brown, E.A. Shinn, S. Miller and S.R. Farrah. 1995. Viral Tracer 
Studies Indicate Contamination of Marine Waters by Sewage Disposal Practices 
in Key Largo, Florida. Applied Environmental Microbiology 61:2230-2234.
Reisinger, Nico. 2003. Monroe County Department of Planning and Environmental 
Resources. Personal communication with Ramon Mendieta, URS Group, Inc.
Rios, Gus. 2001. Florida Department of Environmental Protection, Marathon District. 
Personal communication with Sonya Krogh, URS Group, Inc.
Sheets, Bob. 2003. Key Largo Wastewater Treatment District. Personal communication with 
Joyce Friedenberg, URS Group, Inc.
Sheets, Bob, 2003a. Key Largo Wastewater Treatment District. Personal communication with 
Stephen Carruth, URS Group, Inc.
Shimokubo, Ray, 2003. Wastewater Engineer, FKAA. Personal communication with 
Ramon Mendieta, URS Group, Inc.
Southeast Environmental Research Center (SERC). 2003. Florida International 
University Water Quality Monitoring Network, as supported by South Florida 
Water Management District/SERC Cooperative Agreements #C-10244 and #C-
13178 as well as EPA Agreement #X994621-94-0. March 1995present. 
http://serc.fiu.edu/wqmnetwork/FKNMS-CD/2001FKNMS.pdf, 
http://serc.fiu.edu/wqmnetwork/FKNMS-CD/DataDL.htm.
Szmant, A.M. and A. Forrester. 1996. Water Column and Sediment Nitrogen and 
Phosphorus Distribution Patterns in the Florida Keys. Coral Reefs. 15: 21-41.
Teague, Jack 2001. Wastewater Programs Administrator, Florida Keys Aqueduct 
Authority. Personal communication with Sonya Krogh and Jonathan Randall, 
URS Group, Inc.
U.S. Army Corps of Engineers and Florida Department of Community Affairs 
(USACE/FDCA). 2001. Florida Keys Carrying Capacity Study. First Draft. 
Prepared by URS Corporation under USACE Contract Number DAW17-99-D-
0058, Delivery Order #11, Test CCAM.
U.S. Census. 2000. DP-1. Profile of General Demographic Characteristics. Geographic 
Area: Key Largo CDP, Florida. www.factfinder.census.gov/servlet/ 
BasicFactsServlet. 
U.S. Department of Agriculture (USDA). 1995. Soil Survey of Monroe County, Keys 
Area, Florida. USDA/National Resources Conservation Division in cooperation 
with the University of Florida, Institute of Food and Agricultural Sciences, 
Agricultural Experiment Stations, and Soil and Water Science Department; and 
the Florida Department of Agriculture and Consumer Services. 72 pp.
U.S. Geological Survey (USGS). 2003. Fate of Disinfection By-Products in the 
Subsurface. http://water.usgs/gov/ogw/pubs/ofro289/cr_fatedisinfect.htm.
URS Corporation (URS) and Monroe County Department of Marine Resources. 2000. 
Biological Assessment for the Wastewater Treatment Plant Site  MM 100.5 Key 
Largo, Florida.
URS. 2002a. Final Programmatic Environmental Assessment on Wastewater 
Management Improvements in the Florida Keys. Prepared for Federal Emergency 
Management Agency Region IV, Atlanta, Georgia.
_______. 2002b. Arterial and Travel Time/Delay Study. Prepared for Monroe County.
Weiler Engineering Corporation. 2003. Comments to September 9, 2003, Preliminary 
Draft Supplemental Environmental Assessment for Key Largo Trailer Village and 
Key Largo Park Wastewater Projects. October. 



Section 8 List of Preparers
Project Management and Technical Research

Stephen Carruth, M.S., Project Environmental Planner. Project Director, technical 
researcher and document author.

Ramon Mendieta, Environmental Scientist. Technical researcher and document author.

Justin Patton, Archaeologist. Lead archaeologist and document author.

Joyce Friedenberg, M.S., Economist. Technical researcher and document author.

Brian Richards, GIS Analyst. Lead GIS analyst and document author.

Technical Peer Review

Roger Gunther, M.S., Ecological Services Program Director. Document peer reviewer.

Janet Frey, Senior Geologist. Document peer reviewer.

FEMA Technical and Editorial Review

Science Kilner, M.S., Region IV Lead Environmental and Historical Preservation 
Specialist. Document peer reviewer.

William Straw, Ph.D., Region IV Environmental Officer. Document peer reviewer.




Appendix A
Acronyms and Abbreviations


AADF		Annual Average Daily Flow
ADID		Florida Keys Advance Identification of Wetlands
alum		aluminum sulfate
amsl	above mean sea level
APE		Area of Potential Effect
ATU		Aerobic Treatment Unit
AWT		Advanced Wastewater Treatment

BA		Biological Assessment
BAT		Best Available Technology
bls		below land surface
BMP	Best Management Practice
BO		Biological Opinion
BOD		Biochemical Oxygen Demand

CARL		Conservation and Recreation Lands
CBRS		Coastal Barrier Resource System
CDP		Census Designated Place
CEQ		Council on Environmental Quality
CERP		Comprehensive Everglades Restoration Program
cfm		cubic feet per minute
CFR		Code of Federal Regulations

DBH		Diameter at breast height
DCA		Department of Community Affairs
DHR		Division of Historical Resources
DOH		Department of Health

ECT		Environmental Consulting & Technology, Inc.
EDU		Equivalent dwelling unit
EFH		Essential Fish Habitat
EO		Executive Order
EPA		Environmental Protection Agency
ERP		Environmental Resource Permit
ESA		Endangered Species Act

FAC		Florida Administrative Code
FDEP		Florida Department of Environmental Protection
FEMA		Federal Emergency Management Agency
FFWCC	Florida Fish and Wildlife Conservation Commission
FKAA		Florida Keys Aqueduct Authority
FMRI		Florida Marine Research Institute

GMFMC	Gulf of Mexico Fishery Management Council
gpd		gallons per day
gpm		gallons per minute

HAP		Housing Assistant Plan
HUD		U.S. Department of Housing and Urban Development 

KLP		Key Largo Park
KLTV		Key Largo Trailer Village
KLWTD	Key Largo Wastewater Treatment District

LOS		Level of Service

MCSWMP 	Monroe County Sanitary Wastewater Master Plan 
MGD		Million Gallons per Day
mg/L		milligrams per liter
MFI		Median Family Income
ml		milliliters
MM		Mile Marker
MMADF	maximum month average daily flow
MSA		Magnuson-Stevens Fishery Conservation and Management Act

NEPA		National Environmental Policy Act
NGVD		National Geodetic Vertical Datum
NHPA		National Historic Preservation Act
NMFS		National Marine Fisheries Service
NOAA		National Oceanographic and Atmospheric Administration
NOI		Notice of Intent
NPDES	National Pollutant Discharge Elimination System

O&M		Operation and Maintenance
OWNRS	On-site wastewater nutrient reduction systems

PEA		Programmatic Environmental Assessment
ppm		parts per million
PVC		Polyvinyl Chloride

RI		Regionally Important
ROGO		Rate of Growth Ordinance
ROW		Right-of-Way

SAFMC	South Atlantic Fishery Management Council
SEA		Supplemental Environmental Assessment
SERC		Southeast Environmental Research Center
SFA		Sustainable Fisheries Act
SHPO		State Historic Preservation Officer
SWPPP	Stormwater Pollution Prevention Plan

TN		Total Nitrogen
TP		Total Phosphorus
TSS		Total Suspended Solids

URS		URS Corporation
US-1		U.S. Route 1
USFWS	U.S. Fish and Wildlife Service

VPS		Vacuum Pump Station

WTS		Wastewater Transmission System
WWTP 	Wastewater Treatment Plant


Appendix B
Agency Coordination Letters


List of Agencies Contacted




Jay Slack, Field Supervisor
USFWS
South Florida Ecological Services Office
1339 20th Street
Vero Beach, FL 32960
cc: Phil Frank, Biologist
U.S. Fish and Wildlife Service
Winn-Dixie Plaza
Big Pine Key, FL 33043

Georgia Cranmore, Acting Assistant 
Regional Administrator
NMFS, Southeast Region
Protective Resources Division
9721 Executive Center Drive North
St. Petersburg, FL 33702

Jocelyn Karazsia, Fishery Biologist
National Marine Fisheries Service
11420 N. Kendall Drive, Suite 103
Miami, FL 33176
cc: Rickey N. Ruebsamen, Acting Assistant 

Regional Administrator
NMFS, Southeast Region
Habitat Conservation Division
9721 Executive Center Drive North, Suite 
201
St. Petersburg, FL 33702

Dr. Janet Matthews, Director
State Historic Preservation Officer
Division of Historical Resources
R.A. Gray Building, Room 305
500 South Bronough Street
Tallahassee, FL 32399-0250
cc: Laura Kammerer, Section Administrator
Compliance and Review Section

Florida State Clearinghouse 
Department of Community Affairs 
2555 Shumard Oak Blvd. 
Tallahassee, Florida 32399-2100 

Mark Robson, Regional Director
Florida Fish and Wildlife Conservation 
Commission
South Region
8535 North Lake Blvd. 
West Palm Beach, FL 33412

Gus Rios, Branch Manager
FDEP, South District - Marathon Branch
2796 Overseas Highway, Suite 221
Marathon, FL 33050
cc: Richard Cantrell, South District Director
FDEP  South District Office
2295 Victoria Avenue, Suite 364 
Fort Myers, FL 33902-2549

Cecilia Weaver, Acting Director
South Florida Water Management District
Florida Keys Service Center
80431 Old Hwy. 
Islamorada, FL 33036

John Studt, South Permits Branch Chief
U.S. Army Corps of Engineers
Regulatory Permits Division
4400 PGA Blvd., Suite 500
Palm Beach Gardens, FL 33410
cc: Vic Anderson 

U.S. Army Corps of Engineers
Marathon Regulatory Office 
2796 Overseas Highway, Suite 221
Marathon, FL 33050-4276

Heinz J. Mueller, Chief
US EPA, Region 4
Office of Environmental Assessment 
Sam Nunn Atlanta Federal Center 
61 Forsyth Street, SW 
Atlanta, GA 30303

Gerald Briggs, Chief
Florida Department of Health
Bureau of Onsite Sewage, HSES
4052 Bald Cypress Way, Bin #A08
Tallahassee, FL 32399-1713

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

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

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


For copies of agency coordination letters, please contact:
	Ms. Science Kilner, Lead Environmental Specialist
	FEMA Region IV
	3003 Chamblee Tucker Road
	Atlanta, Georgia  30341
	Fax:  (770) 330-5440
	science.kilner@dhs.gov



Appendix C
Site Photographs




 
View of proposed Alternative 2 WWTP site  Southern edge along fence  facing East



 
View of FKAA facility from Alterative 2 WWTP site  facing South East


 
View from South edge of Alternative 2 site  facing North



 
View of Southern interior of Alterative 2 WWTP site  facing north


 
View of one of two wells located along fence 
adjacent to the south of Alternative 2 WWTP site  facing West


 
View of Commercial businesses adjacent to the southwest  facing Southwest



 
View of western interior of Alternative 2 WWTP site  facing east


 
View of western interior of Alternative 2 WWTP site  facing East


Appendix D
Public Notice


FEMA NOTICE OF INTENT TO PREPARE A
SUPPLEMENTAL ENVIRONMENTAL ASSESSMENT FOR THE PROPOSED
KEY LARGO TRAILER VILLAGE AND KEY LARGO PARK WASTEWATER PROJECTS
The Federal Emergency Management Agency (FEMA) has received a grant application from the Florida Keys 
Aqueduct Authority, in coordination with Monroe County and the Key Largo Wastewater Board; to fund 
construction of a wastewater plant and collection system serving Key Largo Trailer Village, Monroe County, 
Florida.  The proposed project would be funded through FEMA 1249-DR Post Disaster - Unmet Needs funds, as 
noticed on August 6, 1999, in Vol. 64 No. 151 of the Federal Register. Matching funds will be provided through the 
Florida Division of Emergency Management (FDEM) and local sources. Additionally, the Florida Department of 
Environmental Protection (FDEP) is considering grant funding to the Board for construction of a wastewater 
collection system serving Key Largo Park, Monroe County, Florida. The FEMA funded wastewater plant noted 
above would also provide wastewater treatment for the Key Largo Park service area. The purpose of the projects is 
to improve nearshore water quality in the Key Largo area through higher wastewater treatment; consistent with the 
Monroe County Sanitary Wastewater Master Plan and to meet State requirements (Chapter 99-395 Laws of Florida) 
by 2010 per the Monroe County Year 2010 Comprehensive Plan.
FEMA has completed a Programmatic Environmental Assessment (PEA) for Wastewater Management 
Improvements in the Keys, for various wastewater projects including Key Largo. A Programmatic Finding of No 
Significant Impact has been issued for the PEA. These documents can be obtained by writing to the point of contact 
below or may be viewed and downloaded at the following website: http://www.fema.gov/ehp/eaarchives.shtm.
FEMA hereby publishes its notice of intent to prepare a Supplemental Environmental Assessment (SEA) of the 
proposed actions on Key Largo, pursuant to the National Environmental Policy Act (PL 91-190) (NEPA) and 
associated environmental statutes, as implemented by FEMAs regulations 44 CFR Part 10; and in accordance with 
Presidential Executive Order 11988 (Floodplain Management); as implemented in 44 CFR Part 9. Although there is 
no FEMA funding in the FDEP funded Key Largo Park project, it is considered a connected action to the Key Largo 
Trailer Village project under NEPA; consequently the scope of the SEA will include both projects. This SEA will 
address the purpose and need of the proposed projects, project alternatives considered, the affected environment, 
project and site-specific environmental consequences, and impact mitigation measures. Once completed, the Draft 
SEA will be available for public review and comment; and a public meeting will be scheduled.
Project Alternatives: 
Alternatives to be considered in the SEA include:
1) No Action Alternative: No FEMA/FDEM grant funding would be applied to the Key Largo service 
areas, which would continue to use their existing wastewater treatment systems, and funding would have to 
be obtained from other sources to meet the State 2010 requirements and deadline;
2) Action Alternative 1 (preferred): FEMA/FDEM grant funding is applied towards construction of a 
community wastewater collection system and treatment plant serving Key Largo Trailer Village; with the 
plant sited on the oceanside at Mile Marker 100.5 immediately northeast of Atlantic Drive, FDEP funding 
would be applied towards construction of a collection system serving Key Largo Park;
3) Action Alternative 2: FEMA/FDEM/FDEP grant funding would be applied as described under 
Alternative 2, but the treatment plant would be sited on the oceanside near Mile Marker 98 at 97951 
Overseas Highway.
Comment Period:
Comments will be accepted from the affected public; local, state and federal agencies; and other interested parties in 
order to consider and appropriately scope and evaluate the likely effects of the proposed Key Largo project 
alternatives on the physical, biological, and social/built environment. Comments should be in writing, sent to the 
FEMA point of contact listed below, and postmarked within 15 days of publication of this notice.
Point of Contact:
Ms. Science Kilner, Lead Environmental Specialist
FEMA Region IV
3003 Chamblee Tucker Road
Atlanta, Georgia 30341
Fax: (770) 220-5440
science.kilner@dhs.gov


Appendix E
Public Comments



Public comments resulting from the public comment period and public meeting will be 
summarized in the Final Supplemental Environmental Assessment.


Appendix F 
Regulated Keys Fisheries Species 


Species Common Name
Scientific Name
Managed By
Almaco Jack
Seriola rivoliana
SAFMC, GMFMC
Albacore
Thunnus alalunga
GMFMC
Anchor Tilefish
Caulolatilus intermedius
GMFMC
Atlantic Angel shark
Squatina dumeril
GMFMC
Atlantic Bonito
Sarda sarda
GMFMC
Atlantic Sharpnose
Rhizoprionodon terraenovae
GMFMC
Banded Rudderfish
Seriola zonata
SAFMC, GMFMC
Bank Sea Bass
Centropristis ocyurus
SAFMC
Basking Shark
Cetorhinus maximus
GMFMC
Bigeye Sixgill Shark
Hexanchus nakamurai
GMFMC
Bigeye Sand Tiger Shark
Odontaspis noronhai
GMFMC
Bigeye Tresher
Alopias superciliosus
GMFMC
Bigeye Tuna
Thunnus obesus
GMFMC
Bignose Shark
Carcharhinus altimus
GMFMC
Black Grouper
Mycteroperca bonaci
SAFMC, GMFMC
Black Margate
Anisotremus surinamensis
SAFMC
Black Snapper
Apsilus dentatus
SAFMC
Black Sea Bass
Centropristis striatus
SAFMC
Blackfin Snapper
Lutjanus buccanella
SAFMC, GMFMC
Blackfin Tuna
Thunnus attanticus
GMFMC 
Blackline Tilefish
Caulolatilus cyanops
GMFMC
Blue Marlin
Makaira nigicans
GMFMC
Bluefin Tilefish
Caulolatilus microps
SAFMC
Bluefin Tuna
Thunnus orientalis
GMFMC
Blueline Tilefish
Caulotatilus microps
GMFMC
Blue Stripe Grunt
Haemulon sciurus
SAFMC
Caribbean Reef Shark
Carcharhinus perezi
GMFMC
Caribbean Sharpnose Shark
Rhizoprionodon porosus
GMFMC
Cero
Scomberomorus regalis
SAFMC
Cobia
Rachycentron canadum
SAFMC, GMFMC
Coney
Epinephelus fulvus
SAFMC
Cubera Snapper
Lutjanus cyanopterus
SAFMC, GMFMC
Dog Snapper
Lutjanus jocu
SAFMC, GMFMC
Dolphin Fish
Coryphaena hippurus
SAFMC
Dusky Shark
Carcharhinus obscurus
GMFMC
French grunt
Haemulon flavolineatum
SAFMC
Gag
Mycteroperca microlepis
SAFMC, GMFMC
Galapagos shark
Carcharhinus galapagensis
GMFMC
Golden Crab
Chaceon fenneri
SAFMC
Golden Tilefish
Lopholatilus chamaeleonticeps
SAFMC
Goliath Grouper
Epinephelus itajara
SAFMC
Goldface Tilefish
Caulolatilus chrysops
SAFMC
Graysby
Epinephelus cruentatus
SAFMC
Gray Snapper
Lutjanus griseus
SAFMC, GMFMC
Gray Triggerfish
Balistes capriscus
SAFMC, GMFMC
Greater Amberjack
Seriola dummerili
SAFMC, GMFMC
Hogfish
Lachnolaimus maximus
SAFMC, GMFMC
Jewfish Grouper
Epinephelus itajara
GMFMC
Jolthead Porgy
Calamus bajonado
SAFMC
King Mackerel
Scomberomorus cavalla
SAFMC, GMFMC
Knobbed Porgy
Calamus nodosus
SAFMC
Lane Snapper
Lutjanus synagris
SAFMC, GMFMC
Lesser Amberjack
Seriola fasciata
SAFMC, GMFMC
Longbill Spearfish
Tetrapturus pfluegeri
GMFMC
Little Tunny
Euthynnus alletteratus
SAFMC
Mahogany Snapper
Lutjanus mahogoni
SAFMC, GMFMC
Margate
Haemulon album
SAFMC
Misty Grouper
Epinephelus mystacinus
SAFMC, GMFMC
Mutton Snapper
Lutjanus analis
SAFMC, GMFMC
Narrowtooth Shark
Carcharhinus brachyurus
GMFMC
Nassau Grouper
Epinephelus striatus
SAFMC
Night Shark
Carcharhinus signatus
GMFMC
Ocean Triggerfish
Canthidermis sufflamen
SAFMC
Penaeid Shrimp
Penaeus sp.
SAFMC
Queen Snapper
Etelis oculatus
SAFMC, GMFMC
Queen Triggerfish
Balistes vetula
SAFMC
Red Drum
Sciaenops ocellatus
SAFMC, GMFMC
Red Grouper
Epinephelus morio
SAFMC, GMFMC
Red Hind
Epinephelus guttatus
SAFMC, GMFMC
Red Porgy
Pagrus pagrus
SAFMC
Red Snapper
Lutjanus campechanus
SAFMC
Rock Hind
Epinephelus adscensionis
SAFMC, GMFMC
Rock Sea Bass
Centropristis philadelphicus
SAFMC
Rock Shrimp
Sicyonia brevirostris
SAFMC
Sailfish
Istiophorus playpteras
GMFMC
Sand Tiger Shark
Carcharhinus taurus
GMFMC
Sevengill Shark
Notorynchus cepedianus
GMFMC
Sixgill Shark
Hexanchus griseus
GMFMC
Smalltail Shark
Carcharhinus porosus
GMFMC
Saucereye Porgy
Calamus calamus
SAFMC
Scamp
Mycteroperca phenax
SAFMC, GMFMC
Schoolmaster
Lutjanus apodus
SAFMC, GMFMC
Scup 
Stenotomus chrysops
SAFMC
Sheepshead
Archosargus probatocephalus
SAFMC
Silk Snapper
Lutjanus vivanus
SAFMC, GMFMC
Skipjack Tuna
Katsuwonus pelamis
GMFMC
Snowy Grouper
Epinephelus niveatus
SAFMC, GMFMC
Spadefish
Chaetodipterus faber
SAFMC
Spanish Mackerel
Scomberomorus maculatus
SAFMC, GMFMC
Speckled Hind
Epinephelus drummondhayi
SAFMC, GMFMC
Spiny Lobster
Panulirus argus
SAFMC, GMFMC
Swordfish
Xiphas gladius
GMFMC
Tiger Grouper
Mycteroperca tigris
SAFMC
Tilefish
Lopholatilus chamaeleonticeps
GMFMC
Tomtate
Haemulon aurolineatum
SAFMC
Vermilion Snapper
Rhomboplites aurorubens
SAFMC, GMFMC
Wahoo
Acanthocybium solanderi
SAFMC
Warsaw Grouper
Epinephelus nigritus
SAFMC, GMFMC
Wenchman Snapper
Pristipomoides aquilonaris
GMFMC
Whale Shark
Rhincodon typus
GMFMC
Whitebone Porgy
Calamus leucosteus
SAFMC
White Grunt
Haemulon plumieri
SAFMC
White Marlin
Tetrpturus albidus
GMFMC
White Shark
Alosa sapidissima
GMFMC
Wreckfish
Polyprion americanus
SAFMC
Yellowedge Grouper
Epinephelus flavolimbatus
GMFMC
Yellowfin Grouper
Mycteroperca venenosa
SAFMC, GMFMC
Yellowfin Tuna
Thunnus albacares
GMFMC
Yellowmouth Grouper
Mycteroperca interstilitialis
SAFMC, GMFMC
Yellowtail Snapper
Ocyrus chrysurus
SAFMC, GMFMC



Appendix G
Key Largo Cultural Resources Consultation Correspondence


For copies of Key Largo cultural resources consultation correspondence, please contact:
	Ms. Science Kilner, Lead Environmental Specialist
	FEMA Region IV
	3003 Chamblee Tucker Road
	Atlanta, Georgia  30341
	Fax:  (770) 330-5440
	science.kilner@dhs.gov


Appendix H
Biological Assessment for the Wastewater Treatment Plant Site  Mile Marker 
100.5, Key Largo, Florida


For copies of the Biological Assessment for the Wastewater Treatment Plant Site  Mile Marker 100.5, please 
contact:
	
      	Ms. Science Kilner, Lead Environmental Specialist
	FEMA Region IV
	3003 Chamblee Tucker Road
	Atlanta, Georgia  30341
	Fax:  (770) 330-5440
	science.kilner@dhs.gov


Appendix I
U.S. Fish and Wildlife Service Biological Opinion


For copies of the U.S. Fish and Wildlife Service Biological Opinion, please contact:
	
      	Ms. Science Kilner, Lead Environmental Specialist 
	FEMA Region IV
	3003 Chamblee Tucker Road
	Atlanta, Georgia  30341
	Fax:  (770) 330-5440
	science.kilner@dhs.gov


Appendix J
Key Largo Wastewater Treatment District Low Income Assistance 
Program

Key Largo Wastewater Treatment District 
Low Income Assistance Program Per EO 12898 (Environmental Justice)
The following summarizes the Monroe County Housing Authority's (HA)
Implementation Plan for financial assistance to qualifying low- and very-low income Bay
Point service recipients.
The HA will conduct a survey to collect relevant demographic data from the Bay Point
service area residents. The data will help determine the number of assistance program
applicants and the funding level needed to meet the FEMA environmental justice
compliance requirements. This survey will also provide an advanced funding availability
announcement to qualified service recipients.
The application process will begin after WWTP construction has been contracted. The
process will be based on Monroe County's Housing Assistance Plan. Assistance
Program availability will be advertised in local papers; along with other outreach
activities such as press releases, public meeting announcements, and pertinent non-profit
organization notifications. There will be a minimum sixty (60) day application period.
The application will consist of a cover letter, application instructions, an application form
(for information on address, household composition, income level, and status [owner
occupied, primary residence or owner renting to eligible tenant]), a release form, a
resident income certification form, a social security consent for release of information
form, and a statement of no tax return form. The HA's Special Programs Office (SPO)
will work with each applicant to ensure application sufficiency. After the application
period has closed and all applications are completed, the SPO will send a letter to each
applicant informing them whether they have or have not met the eligibility requirements.
The HA's Assistance Program primary eligibility criteria are as following:
* Priority #1
    Single family
    Owner occupied
    Primary residence
    Contain Housing Code violations, Housing Quality Standards violations,
    Health/Safety violations, or has sewer connection requirements.
* Priority #2
    Property owners
    Single family or multifamily rental property occupied by qualified
beneficiaries
    Has sewer connection requirements
Applications received within the application period which meet the primary criteria
above will be prioritized based on the scoring system outlined below. Funding will be
distributed starting with applicants having the greatest priority score, followed by lower
priority scores until all available funding has been expended.
Priorities and associated points:
* Elderly (one owner greater than 62 years old) 10
* Disabled household member 10
* Documented Multiple Housing Code violations 10
* Very low income 5
* Children in household (greater than 2) 5
* Length of ownership between 0 and 5 years 0
* Length of ownership between 6 and 10 years 2
* Length of ownership between 11 and 15 years 3
* Length of ownership greater than 15 years 5
* Single head of household (2 or more persons) 5
Note: In the event of tie scores, very low-income households will receive priority.
The Assistance Program will fund sewer connection and on-site system
abandonment/removal costs. Priority #1 applicants will receive assistance in the form of
a grant. Priority #2 applicants would receive assistance in the form of a loan.
Applicants would execute a note secured by a mortgage on the subject property. The
term of the note will be for five (5) years at zero (0) percent interest and will require no
regular payments. The principal balance will be forgiven by 1/5th annually on the
anniversary date. The mortgage will contain affordability covenants that require that
during the term of the loan, the property shall be rented on an annual lease to very lowand
low-income households subject to annual income certification. The SPO will
coordinate all payments through the County.
An order-of-merit listing with qualified applicants will be prepared for approval by the
CATF and forwarded to the BOCC for conflict of interest resolution and approval. Based
on available funding and the number of listed applicants, a household dollar amount will
be awarded to each applicant.
When the funding allocation for each household is known, the SPO will send a
commitment letter to the household, including instructions on plumber contracting. The
SPO will work with the applicant to ensure plumber work is completed appropriately (i.e.
permits obtained, county inspections made, DOH certifications received for system
abandonment, etc.) and that services are paid in a timely manner. The Assistance
Program will be funded through funding requests to DCA for a combination of the
individual funding amount awarded to the eligible household and the plumbing contractor
costs.