DRAFT COMPREHENSIVE CONSERVATION PLAN 

AND ENVIRONMENTAL ASSESSMENT 

LOWER FLORIDA KEYS NATIONAL WILDLIFE REFUGES 

National Key Deer Refuge 

Key West National Wildlife Refuge 

Great White Heron National Wildlife Refuge 

Monroe County, Florida 

U.S. Department of the Interior 

Fish and Wildlife Service 

Southeast Region 

Atlanta, Georgia 

May 2008 

Table of Contents i 

TABLE OF CONTENTS 

SECTION A. DRAFT COMPREHENSIVE CONSERVATION PLAN 

I. BACKGROUND ................................................................................................................................. 1

Introduction ................................................................................................................................... 1

Purpose And Need For The Plan .................................................................................................1

Fish and Wildlife Service .............................................................................................................. 4

National Wildlife Refuge System .................................................................................................. 4

Legal and Policy Context .............................................................................................................. 6

National and International Conservation Plans and Initiatives ..................................................... 6

II. REFUGE OVERVIEW ........................................................................................................................ 9

Introduction ................................................................................................................................... 9

description of refuges and History of their Establishment ............................................................ 9

Key West National Wildlife Refuge ..................................................................................... 9

Great White Heron National Wildlife Refuge ....................................................................... 9

National Key Deer Refuge ................................................................................................ 10

Refuge Purposes ........................................................................................................................ 10

Key West National Wildlife Refuge ................................................................................... 11

Great White Heron National Wildlife Refuge ..................................................................... 11

National Key Deer Refuge ................................................................................................ 11

Special Designations .................................................................................................................. 12

Ecosystem Context and Regional Conservation Plans and Initiatives ....................................... 16

Physical Resources .................................................................................................................... 17

Climate .............................................................................................................................. 17

Geology ............................................................................................................................. 17

Soils .................................................................................................................................. 17

Physiograpy ...................................................................................................................... 17

Hydrology and freshwater Resources ............................................................................... 17

Water Quality and Quanity ................................................................................................ 18

Air Quality .......................................................................................................................... 18

Biological Resources .................................................................................................................. 19

Flora – habitat characteristics of native vegetation/Plant Communities ............................ 19

Fauna – fish and Wildlife ................................................................................................... 23

Cultural Resources ..................................................................................................................... 31

Socioeconomic Environment ...................................................................................................... 31

III. PLAN DEVELOPMENT .................................................................................................................. 39

Summary of Issues, Concerns, and Opportunities ..................................................................... 39

Priority Resource Issues ............................................................................................................. 39

Overarching Issue (applies to all refuges across most program areas) ..................................... 39

Visitor Services ................................................................................................................. 40

Habitat Management ......................................................................................................... 40

Fish and Wildlife Population Management ........................................................................ 41

Refuge Administration ....................................................................................................... 43
ii Lower Florida Keys National Wildlife Refuges 

IV. MANAGEMENT DIRECTION ....................................................................................................... 45

Introduction ................................................................................................................................ 45

Vision ......................................................................................................................................... 45

Goals, Objectives, and Strategies .............................................................................................. 45

Habitat Management......................................................................................................... 47

V. PLAN IMPLEMENTATION ............................................................................................................ 67

Introduction ................................................................................................................................ 67

Proposed Projects ...................................................................................................................... 67

Fish And Wildlife Population Management ....................................................................... 67

refuge administration and Resource Protection ................................................................ 71

Visitor Services, Wildlife-Dependent recreation, and Environmental Education ............... 72

Staffing and Funding .................................................................................................................. 73

Partnership Opportunities........................................................................................................... 73

Monitoring and Evaluation .......................................................................................................... 80

Plan Review and Revision.......................................................................................................... 80

SECTION B. ENVIRONMENTAL ASSESSMENT ............................................................................. 81

I. BACKGROUND .............................................................................................................................. 81

Purpose and need ...................................................................................................................... 81

Proposed Action ......................................................................................................................... 81

II. AFFECTED ENVIRONMENT .......................................................................................................... 83

III. DESCRIPTION OF ALTERNATIVES ............................................................................................. 85

Formulation and description of Alternatives ............................................................................... 85

Alternative A - (Current Management - No Action) ........................................................... 85

Alternative b - (Proposed Alternative) ............................................................................... 86

Alternative c ...................................................................................................................... 87

Features Common to all Alternatives ......................................................................................... 88

IV. ENVIRONMENTAL CONSEQUENCES ..................................................................................... 105

Overview .................................................................................................................................. 105

Effects on the Physical Environment ........................................................................................ 105

Soils ................................................................................................................................ 105

Hydrology ........................................................................................................................ 105

Water Quality .................................................................................................................. 105

Air Quality ....................................................................................................................... 106

Noise Pollution ................................................................................................................ 106

Aesthetics ....................................................................................................................... 106

Facilities .......................................................................................................................... 107

Effects on the biological Environment ...................................................................................... 107

Native Habitats Affected By The Plan ............................................................................. 108
Table of Contents iii 

Wildlife and Protected Species ................................................................................................. 110

Research and monitoring ......................................................................................................... 111

Fire Impacts ..............................................................................................................................112

Fishing ............................................................................................................................. 113

Wildlife Observation and Photography ............................................................................ 113

Environmental Education and interpretation ................................................................... 113

Other Permitted Activities ................................................................................................ 114

Ecotourism ...................................................................................................................... 114

Tax Revenue ...................................................................................................................114

Regulatory ....................................................................................................................... 115

Environmental Justice ..................................................................................................... 115

Climate Change .............................................................................................................. 115

Cultural Resources .......................................................................................................... 116

Revenue Sharing ............................................................................................................ 116

Cumulative Impacts .................................................................................................................. 116

User Group Conflicts ....................................................................................................... 117

Water Quality from Soil Disturbance and Use of Herbicides ........................................... 117

Vegetation Disturbance ................................................................................................... 118

Wildlife Disturbance ........................................................................................................ 118

Effects on Adjacent Landowners ..................................................................................... 118

Land Ownership .............................................................................................................. 118

Site Development ............................................................................................................ 118

Short-term Uses versus Long-term Productivity ....................................................................... 119

Summary statement ................................................................................................................. 119

V. COORDINATION AND CONSULTATION .................................................................................... 121

Overview ................................................................................................................................... 121

Biological Review: ........................................................................................................... 121

Visitor Services and Public Use Review ......................................................................... 121

Wilderness Review .......................................................................................................... 121

Fire Management Program Review ................................................................................ 122

Planning Team ................................................................................................................ 122

Tribal Coordination .......................................................................................................... 122

APPENDICES 

APPENDIX A. GLOSSARY AND ACRONYMS ............................................................................... 123

APPENDIX B. REFERENCES AND LITERATURE CITED .............................................................. 133

APPENDIX C. RELEVANT LEGAL MANDATES AND EXECUTIVE ORDERS .............................. 137

APPENDIX D. PUBLIC INVOLVEMENT ........................................................................................... 149

APPENDIX E. APPROPRIATE USE DETERMINATIONS............................................................... 153

APPENDIX F. COMPATIBILITY DETERMINATIONS ..................................................................... 163

APPENDIX G. INTRA-SERVICE SECTION 7 BIOLOGICAL EVALUATION .................................. 187

APPENDIX H. WILDERNESS REVIEW ............................................................................................ 203
iv Lower Florida Keys National Wildlife Refuges 

APPENDIX I. REFUGE BIOTA ........................................................................................................ 205

APPENDIX J. BUDGET REQUESTS ............................................................................................... 245

APPENDIX K. LIST OF PREPARERS .............................................................................................. 247

Planning Team ................................................................................................................ 247

Biological Review ............................................................................................................ 247

Visitor Services and Public Use Review ......................................................................... 248

Wilderness Review ......................................................................................................... 248

Fire Management Program Review ................................................................................ 248

APPENDIX L. LIST OF PARTNERSHIPS ........................................................................................ 249
Table of Contents v 

LIST OF FIGURES 

FIGURE 1. FLORIDA KEYS REFUGES .............................................................................................. 2

FIGURE 2. REFUGE BOUNDARIES LOWER FLORIDA KEYS ......................................................... 3

FIGURE 3. FLORIDA REFUGES ......................................................................................................... 5

FIGURE 4. SPECIAL DESIGNATIONS ............................................................................................. 13

FIGURE 5. WILDERNESS AREA ...................................................................................................... 15

FIGURE 6. LAND COVER .................................................................................................................. 20

FIGURE 7. LOWER FLORIDA KEYS REFUGES VISITOR SERVICES FACILITIES ....................... 36

FIGURE 8. LOWER KEYS TRAILS ................................................................................................... 37

FIGURE 9. BOATING – ZONES AND RESTRICTIONS .................................................................... 38

FIGURE 10. PROPOSED ORGANIZATION STRUCTURE FOR THE MANAGEMENT OF THE 

LOWER FLORIDA KEYS REFUGES .......................................................................... 76

LIST OF TABLES 

TABLE 1 - FEDERALLY LISTED ENDANGERED (E), THREATENED (T), AND 

CANDIDATE (C)SPECIES OF THE LOWER FLORIDA KEYS REFUGES ...................... 27

TABLE 2 - MONROE COUNTY – POPULATION, HOUSING UNITS, AREA AND DENSITY ........... 32

TABLE 3 - INCOME AND POPULATION STATISTICS ..................................................................... 33

TABLE 4 - MONROE COUNTY DEMOGRAPHY STATISTICS ......................................................... 33

TABLE 5. SUMMARY OF PROJECT COSTS (IN 2007 DOLLARS) 

* DENOTES < 14 YEAR COST ........................................................................................ 74

TABLE 6. APPROXIMATE ANNUAL COSTS OF PROPOSED STAFF POSITIONS 

IN 2007 DOLLARS ........................................................................................................... 75

TABLE 7. LOWER FLORIDA KEYS NATIONAL WILDLIFE REFUGES STEP-DOWN 

MANAGEMENT PLANSAND COMPLETION DATES ..................................................... 79

TABLE 8. COMPARISON OF ALTERNATIVES BY MANAGEMENT ISSUES FOR THE 

LOWER FLORIDA KEYS REFUGES .............................................................................. 89
vi Lower Florida Keys National Wildlife Refuges 
Section A. Draft Comprehensive Conservation Plan 1 

SECTION A. DRAFT COMPREHENSIVE CONSERVATION PLAN 

 

I. Background 

INTRODUCTION 

The Florida Keys National Wildlife Refuges Complex is comprised of four refuges situated in the Florida 

Keys (Figure 1). Crocodile Lake National Wildlife Refuge (NWR) is located at the northern end of the 

Florida Keys near Key Largo, Florida. The Lower Florida Keys Refuges are physically separated from 

Crocodile Lake NWR. This group of three refuges, National Key Deer Refuge, Key West National Wildlife 

Refuge (NWR), and Great White Heron National Wildlife Refuge (NWR), is situated between the city of 

Marathon and the Marquesas Keys, which are located west of Key West, Florida (Figure 2). The U.S. 

Fish and Wildlife Service (Service) developed the Lower Florida Keys Refuges’ Draft Comprehensive 

Conservation Plan and Environmental Assessment (Draft CCP/EA) to guide management and resource 

conservation for these three refuges over the next 15 years. The refuge complex is managed as a whole 

with administrative headquarters at National Key Deer Refuge on Big Pine Key, Florida. One Draft 

CCP/EA document has been prepared for the three Lower Florida Keys Refuges. This Draft CCP/EA 

contains background information on the refuges and presents a description of the planning process and 

the desired future conditions. The Draft CCP/EA states the refuges’ vision, goals, and management 

actions necessary to achieve these goals and conditions. 

Guiding the development of the Draft CCP/EA is Part 602 (National Wildlife Refuge System Planning) 

of the Fish and Wildlife Service Manual and the National Wildlife Refuge System Improvement Act of 

1997. An overriding consideration reflected in this Draft CCP/EA is that fish and wildlife conservation 

has first priority in refuge management. All public use of refuges must be compatible with the 

purposes for which each refuge was established. The Improvement Act specifies six priority wildlifedependent uses: hunting, fishing, wildlife observation, wildlife photography, and environmental 

education and interpretation. Except for hunting, these uses are allowed in specified areas of the 

Lower Florida Keys Refuges. 

The major issues addressed in the Draft CCP/EA include the complexity of managing geographically 

scattered islands and lands with mixed ownership and jurisdiction; changing public attitudes, needs 

and demands; habitat fragmentation; climate change; fire management; lack of ecological 

inventorying and monitoring; recovery of imperiled species; invasive exotic species; and staffing and 

facility needs. Based on these issues, three alternatives were identified for managing the refuges as 

outlined in the EA. From these alternatives, the Service selected a proposed alternative, which is 

described in Chapter IV of this Draft CCP/EA. Implementation of the proposed management action is 

discussed in Chapter V. 

PURPOSE AND NEED FOR THE PLAN 

The purposes of this Draft CCP/EA are to identify the role these refuges will have in support of the 

mission of the National Wildlife Refuge System and to provide guidance in refuge management and 

public use activities. This Draft CCP/EA describes the Service’s management direction (i.e., goals, 

objectives, and strategies) for the next 15 years. 
2 Lower Florida Keys National Wildlife Refuges 

Figure 1. Florida Keys Refuges 
Section A. Draft Comprehensive Conservation Plan 3 

Figure 2. Boundaries of Lower Florida Keys NWRs 
4 Lower Florida Keys National Wildlife Refuges 

The CCP is needed to: 

y Provide a clear statement regarding management of the refuges; 

y Provide refuge neighbors, visitors, and government officials and other stakeholders with an 

understanding of the Service’s management actions on and around the refuges; 

y Ensure that refuge management actions are consistent with the purposes of the refuges and 

the mandates of the National Wildlife Refuge System; 

y Provide long-term guidance and continuity for refuge management; and 

y Provide a basis for the development of budget requests relative to the refuges’ operational, 

maintenance, and capital improvement needs. 

FISH AND WILDLIFE SERVICE 

The U.S. Fish and Wildlife Service is the primary federal agency responsible for conserving, 

protecting, and enhancing the Nation’s fish and wildlife populations and their habitats. Although the 

Service shares this responsibility with other federal, state, tribal, local, and private entities, it has 

specific trustee responsibilities for migratory birds, federally listed threatened and endangered 

species, anadromous fish, certain marine mammals, and the lands and waters administered by the 

Service for the management and protection of these resources. 

NATIONAL WILDLIFE REFUGE SYSTEM 

As part of its mission, the Service operates 547 national wildlife refuges covering over 100 million 

acres. These areas comprise the National Wildlife Refuge System (Refuge System), the world’s 

largest network of lands and waters specifically managed for fish and wildlife. Most of these lands 

are in Alaska, with only about 20 percent situated within the other 49 states and several island 

territories. The Service manages 28 national wildlife refuges in Florida (Figure 3) that comprise 

approximately 964,992 land and water acres (Florida Natural Areas Inventory 2005). 

The mission of the Refuge System, as defined by the National Wildlife Refuge System Improvement 

Act of 1997, is “to administer a national network of lands and waters for the conservation, 

management, and where appropriate, restoration of the fish, wildlife, and plant resources and their 

habitats within the United States for the benefit of present and future generations of Americans.” The 

Improvement Act establishes wildlife conservation as the primary mission of the Refuge System. 

National wildlife refuges provide important habitat for native plants and many species of mammals, 

birds, fish, amphibians, reptiles, insects, and other invertebrates. They also play a vital role in the 

recovery of threatened and endangered species. Refuges offer a wide variety of wildlife-dependent 

recreational opportunities, and many have visitor centers, interpretive trails, and environmental 

education programs. In 2006, approximately 87 million people hunted, fished, or observed wildlife, 

and spent $120 billion pursing those activities (U.S. Fish and Wildlife Service 2007). 
Section A. Draft Comprehensive Conservation Plan 5 

Figure 3. Florida refuges 
6 Lower Florida Keys National Wildlife Refuges 

LEGAL AND POLICY CONTEXT 

Legal Mandates and Administrative and Policy Guidelines 

Administration of national wildlife refuges is guided by the mission and goals of the Refuge System, 

congressional legislation, executive orders, and international treaties. Policies for management options of 

refuges are further refined by administrative guidelines established by the Secretary of the Interior and by 

policy guidelines established by the Director of the Fish and Wildlife Service. Select legal summaries of 

laws relevant to administration of the Refuge System and management of the Lower Florida Keys 

Refuges are provided in Appendix C. 

Biological Integrity, Diversity, and Environmental Health Policy 

The Improvement Act directs the Service to ensure that the biological integrity, diversity, and 

environmental health of the Refuge System are maintained for the benefit of present and future 

generations of Americans. The policy is an additional directive for refuge managers to follow 

while achieving refuge purpose(s) and the Refuge System’s mission. It provides for the 

consideration and protection of the broad spectrum of fish, wildlife, and habitat resources found 

on refuges and associated ecosystems. When evaluating the appropriate management direction 

for refuges, refuge managers will use sound professional judgment to determine their refuges’ 

contribution to biological integrity, diversity, and environmental health at multiple landscape 

scales. Sound professional judgment incorporates field experience, knowledge of refuge 

resources, ecosystem management, applicable laws, and best available science, including 

consultation with others both inside and outside the Service. 

NATIONAL AND INTERNATIONAL CONSERVATION PLANS AND INITIATIVES

National American Bird Conservation Initiative 

Begun in 1999, the National American Bird Conservation Initiative is a coalition of government 

agencies, private organizations, academic institutions, and industry leaders in the United States, 

Canada, and Mexico, working to ensure the long-term health of North America’s native bird 

populations by fostering an integrated approach to bird conservation to benefit all birds in all 

habitats. The Lower Florida Keys Refuges support the following: North American Waterfowl 

Management Plan; Partners in Flight Bird Conservation Plan; Southeastern Coastal Plain and 

Caribbean Region Shorebird Conservation Plan; and Southeastern Coastal Plain Colonial 

Waterbird Conservation Regional Plan. 

North American Waterfowl Management Plan 

Since the first European settlers arrived, more than 53 percent of the contiguous United States’ 

original 221 million acres of wetlands have been destroyed, causing dramatic declines in waterfowl 

populations. Recognizing the importance of waterfowl and wetlands to North Americans, and the need 

for international cooperation to help in the recovery of this shared resource, the United States and 

Canadian governments developed a strategy to restore waterfowl populations to levels of the 1970s 

through habitat protection, restoration, and enhancement. The strategy was documented in the North 

American Waterfowl Management Plan, signed in 1986 by the Secretary of the Interior and the Canadian 

Minister of the Environment. With an update in 1994, Mexico became a signatory to the plan. 
Section A. Draft Comprehensive Conservation Plan 7 

The plan identified important waterfowl habitat areas and established habitat and population goals. It 

developed interstate/international partnerships called Joint Ventures to implement plan goals. In 

1997, the Atlantic Coast Joint Venture added Florida as its seventeenth state partner. 

Partners in Flight Bird Conservation Plan 

The Partners in Flight initiative was launched in 1990, in response to growing concerns about declines in 

the populations of many land bird species, particularly migratory passerines, for which no coordinated 

management was in place. It addresses the conservation of birds not covered by other conservation 

programs. The central premise of Partners in Flight is that the resources of public and private 

organizations in North and South America must be combined, coordinated, and increased in order to 

achieve success in conserving bird populations in this hemisphere. The Service is a member of the 

cooperative effort to promote research, land protection, and education about migratory birds. Other 

participants include federal, state, and local government agencies, philanthropic foundations, professional 

organizations, conservation groups, industry, the academic community, and private individuals. 

The Partners in Flight initiative focuses on species that breed in the Nearctic (North America) and 

spend the winter in the Neotropics (Central and South America). These species are commonly 

known as neotropical migratory birds. Partners in Flight coordinates international conservation efforts 

for all neotropical migratory land birds in the United States and the Western Hemisphere. The goal of 

the initiative is to keep common birds common. 

Southeastern Coastal Plain and Caribbean Region Shorebird Conservation Plan 

The Southeastern Coastal Plain and Caribbean Region Shorebird Conservation Plan correlates 

roughly to the Partners in Flight initiative. It identifies priority species, outlines potential and present 

threats to shorebirds and their habitats, reports gaps in knowledge relevant to shorebird conservation, 

and makes recommendations for addressing identified problems. General habitat goals for the region 

are to: (1) provide optimal breeding habitat for priority species; (2) provide high-quality managed 

habitat that supports the requirements of species migrating through or spending winter in the region; 

and (3) maintain human disturbances at tolerable levels for shorebirds throughout the year. 

Southeastern Coastal Plain Colonial Waterbird Conservation Plan 

The Southeastern Coastal Plain Colonial Waterbird Conservation Plan follows the same format as the 

previous two bird conservation plans, with a focus on herons, ibises, storks, seabirds, and their habitats. 

Through public use area closures and habitat protection, the Service provides important wintering 

habitat for 22 priority conservation species included in the plan. The refuges have regionally important 

habitats, such as intertidal seagrass, algal and mudflats, salt ponds, and beaches. 

Globally Important Bird Area 

All three refuges are designated as Globally Important Bird Areas (GIBA). Worldwide, there are 

3,500 sites. The American Bird Conservancy identified the top 500 sites within the United States. 

For a site to be designated, it must, for at least part of a year, contain habitat that supports one of the 

following criterions: (1) a major population of a threatened and/or endangered; (2) a notable 

population of watch list species; (3) a population of a species with a limited range; or (4) large 

aggregations of breeding, migrating, or wintering birds, including waterfowl, seabirds, wading birds, 

raptors, or landbirds. The goal of the GIBA program is to create public awareness of these sites and 

to obtain resources to protect them. 
8 Lower Florida Keys National Wildlife Refuges 
Section A. Draft Comprehensive Conservation Plan 9 

II. Refuge Overview 

INTRODUCTION 

DESCRIPTION OF REFUGES AND HISTORY OF THEIR ESTABLISHMENT 

KEY WEST NATIONAL WILDLIFE REFUGE 

Key West National Wildlife Refuge (Key West NWR) is west of Key West, Florida and accessible only 

by boat or plane. Key West NWR consists of the Marquesas Keys and 13 other keys distributed across 

over 375 square miles of open water (Figure 2). Key West NWR is among the first refuges established 

in the United States. President Roosevelt created the refuge in 1908 as a preserve and breeding 

ground for colonial nesting birds and other wildlife. The refuge encompasses 208,308 acres of land 

and water, with only one percent (2,019 acres) being land. Most islands are dominated by mangrove 

plant communities. Exceptions are the hardwood hammock in the Marquesas Keys, and the beaches 

and dunes there and on Boca Grande and Woman Keys. All islands lack fresh water and native, 

terrestrial mammals are absent. 

Key West NWR provides habitat and protection for federally listed species, including piping plover and 

roseate terns. The refuge harbors the largest wintering population of piping plovers and the largest colony 

of white-crowned pigeons in the Florida Keys. It is a haven for over 250 species of birds, including ten 

wading bird species that nest in the refuge. Other notable imperiled species include sea turtles. More 

loggerhead and green sea turtle nests are found each year in Key West NWR than any area of the Florida 

Keys except for the Dry Tortugas. Waters within the refuge’s administrative boundaries are important 

developmental hapitat for sea turtles, as well as hawksbills and Kemp’s ridley sea turtles. 

In 1975, Public Law 93-632 designated all islands in Key West NWR (except Ballast Key, which is 

privately owned) as a part of the National Wilderness Preservation System. Wilderness areas are 

managed to minimize human impacts and influences and to let natural processes occur without 

intervention. The refuge limits human use and influence in order to preserve the quality, character, 

and integrity of these protected wilderness lands. The Service co-manages the open water and 

submerged lands owned by the State of Florida through a Management Agreement for Submerged 

Lands within Boundaries of the Key West and Great White Heron NWRs (Management Agreement). 

Adopted in 1992, the Management Agreement prohibits the use of personal watercraft, airboats, 

waterskiing, hovercrafts, and the landing of seaplanes within the administrative boundary of the 

refuge, and it restricts public access in certain locations in order to protect sensitive wildlife resources. 

GREAT WHITE HERON NATIONAL WILDLIFE REFUGE 

Great White Heron NWR was established in 1938, by Executive Order 7993 signed by President 

Roosevelt, as a haven for great white herons, migratory birds, and other wildlife. The refuge 

encompasses 117,683 acres of land and water with 6,500 acres of land (Figure 2), the latter of which 

1,900 acres were designated Wilderness in 1975 under Public Law 93-632. The islands are primarily 

mangroves. Some of the larger islands contain pine rockland and tropical hardwood hammock 

habitats. This vast area, known locally as the “backcountry,” provides critical nesting, feeding, and 

resting areas for more than 250 species of birds. As noted above, the Service co-manages the open 

water and submerged lands owned by the State of Florida through a Management Agreement. 
10 Lower Florida Keys National Wildlife Refuges 

Great white herons are a white color-phase of great blue herons. In the United States, nesting is 

restricted to extreme south Florida, including the Florida Keys. The refuge was created to protect great 

white herons from extinction since the population was decimated by the demand for feathered hats. 

Protection of great white herons was successful, and these magnificent birds can be observed 

feeding on tidal flats throughout the refuge. The refuge islands are also used for nesting by ten 

wading bird species, including the reddish egret, and by many neotropical migratory bird species. 

Three species of sea turtles rely on the backcountry for feeding and nesting. Green and loggerhead 

sea turtles successfully nest in the refuge. Hawksbill sea turtles are known to feed in seagrass beds 

throughout the refuge, but nesting has not been observed. 

NATIONAL KEY DEER REFUGE 

National Key Deer Refuge was established on August 22, 1957 to protect and conserve Key deer and 

other wildlife resources. It comprises nearly 8,983 acres of land on several islands within the approved 

acquisition boundary, as well as additional parcels located outside the boundary administered by the 

refuge (Figure 2). These lands host diverse habitats, most notably globally endangered tropical hardwood 

hammocks and pine rocklands. The refuge provides habitat for hundreds of endemic and migratory 

species, including 21 federally listed species, such as Key deer, Lower Keys marsh rabbit, and silver rice 

rat. It contains a variety of plants endemic to the Florida Keys. 

When the refuge was established, the Key deer was nearing extinction. Less than 50 deer remained 

as a result of uncontrolled hunting. Establishment of the refuge, along with habitat acquisition and 

law enforcement efforts, has allowed the deer population to increase and stabilize. Today, there are 

about 600 Key deer located on Big Pine and No Name Keys, with around 100 more located on 

surrounding islands. Key deer continute to be classified as endangered because the population is 

isolated and confined to a small geographic area, which could allow a disease outbreak or hurricane 

to wipe out the entire species. 

The refuge is an important stopping point for thousands of migrating birds each year and an important 

wintering ground for many North American bird species. Notable species include the piping plover and the 

peregrine falcon. The mosaic of upland and wetland habitats found in the Florida Keys is critical breeding 

and feeding ground for birds, and refuge land acquisition efforts strive to add to the lands already protected. 

Loggerhead, green, hawksbill, and Kemp’s ridley sea turtles forage in the waters surrounding National Key 

Deer Refuge, but nesting is limited to refuge lands on Ohio Key, where a small number of loggerhead turtle 

nests are laid annually. 

REFUGE PURPOSES 

The purposes of the refuges come from the executive orders and subsequent laws Congress passed 

as it established each refuge. There are also specific purposes Congress designated for managing 

the Refuge System as a whole. Each of the three refuges has different enabling legislation and 

purposes. This Draft CCP/EA has been designed with consideration of the distinct purposes of each 

refuge. The purposes of the refuges are as follows: 
Section A. Draft Comprehensive Conservation Plan 11 

KEY WEST NATIONAL WILDLIFE REFUGE 

y “... a preserve and breeding ground for native birds.” Executive Order 923 dated August 8, 

1908. 

y “... particular value in carrying out the national migratory bird management program.” 16 

U.S.C. 667b (An Act authorizing the transfer of certain real property for wildlife, or other 

purposes). 

y “...so as to provide protection of these areas...and to ensure...the preservation of their 

wilderness character...” (Wilderness Act of 1964, Public Law 88-577.) 

GREAT WHITE HERON NATIONAL WILDLIFE REFUGE 

y “... as a refuge and breeding ground for great white herons [white phase of the great blue 

heron], other migratory birds and other wildlife.” Executive Order 7993, dated Oct 27, 1938. 

y “... for use as an inviolate sanctuary, or for any other management purpose, for migratory 

birds.” 16 U.S.C. 715d (Migratory Bird Conservation Act). 

y “... to conserve (A) fish or wildlife which are listed as endangered species or threatened 

species .... or (B) plants ...” 16 U.S.C. 1534 (Endangered Species Act of 1973). 

y “... suitable for— (1) incidental fish and wildlife-oriented recreational development, (2) the 

protection of natural resources, (3) the conservation of endangered species or threatened 

species ...” 16 U.S.C. 460k-1 “... the Secretary ... may accept and use ... real ... property. 

Such acceptance may be accomplished under the terms and conditions of restrictive 

covenants imposed by donors ...” 16 U.S.C. 460k-2 [Refuge Recreation Act (16 U.S.C. 460k460k-4), as amended]. 

y “...so as to provide protection of these areas...and to ensure...the preservation of their 

wilderness character...” (Wilderness Act of 1964, Public Law 88-577.) 

NATIONAL KEY DEER REFUGE 

y “... to protect and preserve in the national interest the Key deer and other wildlife 

resources in the Florida Keys.” 71 Stat. 412, dated Aug. 22, 1957. 

y “... to conserve (A) fish or wildlife which are listed as endangered species or threatened 

species .... or (B) plants ...” 16 U.S.C. 1534 (Endangered Species Act of 1973). 

y “... suitable for— (1) incidental fish and wildlife-oriented recreational development, (2) the 

protection of natural resources, (3) the conservation of endangered species or threatened 

species ...” 16 U.S.C. 460k-1 “... the Secretary ... may accept and use ... real ... property. 

Such acceptance may be accomplished under the terms and conditions of restrictive 

covenants imposed by donors ...” 16 U.S.C. 460k-2 [Refuge Recreation Act (16 U.S.C. 460k460k-4), as amended]. 

y “... for the development, advancement, management, conservation, and protection of fish and 

wildlife resources ...” 16 U.S.C. 742f(a)(4) “... for the benefit of the United States Fish and 
12 Lower Florida Keys National Wildlife Refuges 

Wildlife Service, in performing its activities and services. Such acceptance may be subject to 

the terms of any restrictive or affirmative covenant, or condition of servitude ...” 16 U.S.C. 

742f(b)(1) (Fish and Wildlife Act of 1956). 

y “... conservation, management, and ... restoration of the fish, wildlife, and plant resources 

and their habitats ... for the benefit of present and future generations of Americans...” 16 

U.S.C. 668dd(a)(2) (National Wildlife Refuge System Administration Act). 

y “...so as to provide protection of these areas...and to ensure...the preservation of their 

wilderness character...” (Wilderness Act of 1964, Public Law 88-577.) 

These purposes and the mission of the Refuge System are fundamental to determining the 

compatibility of proposed uses of the refuge, including public recreation. The compatibility of these 

uses is discussed in Appendix F. 

SPECIAL DESIGNATIONS 

Outstanding Florida Waters Designation 

Section 403.061(27), Florida Statutes, grants the Department of Environmental Protection (FDEP) the 

power to “Establish rules which provide for a special category of water bodies within the state, to be 

referred as ‘Outstanding Florida Waters,’ which shall be worthy of special protection because of their 

natural attributes.” Among other public conservation lands within state and federal ownership, all 

waters in national wildlife refuges are designated as Outstanding Florida Waters (OFWs). Each of 

the Lower Florida Keys Refuges was designated in 1986 (Figure 4), with modifications made in 1988 

and 1994. A Special Waters OFWs designation was made for the Florida Keys in 1985. The 

regulatory significance of the OFWs statute is to prevent the FDEP from issuing permits for direct or 

indirect pollutant discharges into OFWs, which would lower or degrade their existing water quality. 

Permits for new dredge and fill activities must clearly be in the public interest. 

Marine Protected Areas 

Executive Order 13158 on Marine Protected Areas (MPAs) was issued May 26, 2000. It directs 

federal agencies to work with government and non-governmental partners to increase protection and 

sustainable use of ocean resources by strengthening and expanding a national system of MPAs. The 

definition of MPAs provided in the President’s Executive Order is “any area of the marine environment 

that has been reserved by federal, state, territorial, tribal, or local laws or regulations to provide 

lasting protection for part or all of the natural and cultural resources therein.” Each of the Lower 

Florida Keys Refuges is classified as an MPA by virtue of being in the Refuge System. All actions 

concerning the management of MPAs are left to the discretion of the local, state, or federal authorities 

that currently have those powers. 

For more information on MPAs see: http://mpa.gov/national_system/national_system.html. 

Coastal and Estuarine Land Conservation Program 

The Coastal and Estuarine Land Conservation Program (CELCP) was established in 2002 to protect 

coastal and estuarine lands considered important for their ecological, conservation, recreational, 

historical, or aesthetic values. The program is administered by the National Oceanographic and 

Atmospheric Administration (NOAA). It provides state and local governments with matching funds to 

purchase important coastal and estuarine lands, or conservation easements on such lands, from 
Section A. Draft Comprehensive Conservation Plan 13 

Figure 4. Special designations 
14 Lower Florida Keys National Wildlife Refuges 

willing sellers. Lands or conservation easements acquired with CELCP funds are protected in 

perpetuity so that they may be enjoyed by future generations. Within the refuges’ administrative 

boundaries, CELCP goals are as follows: acquire 124 parcels (50 acres) on Big Pine Key and 55 

parcels (79 acres) on Cudjoe Key. 

Federal Wilderness Designation and Stewardship 

Congress designated wilderness areas in the Lower Florida Keys Refuges on January 3, 1975 

(Public Law 93-632) to be managed under the Wilderness Act of 1964 (78 Stat. 890.892: 16 U.S.C. 

1132). The wilderness areas include 1,990 acres in Great White Heron NWR, 2,019 acres in Key 

West NWR and 2,278 in National Key Deer Refuge. They are portrayed in Figure 5. 

Under the Wilderness Act, wilderness areas “...shall be administered for the use and enjoyment of 

the American people in such a manner as will leave them unimpaired for future use and enjoyment as 

wilderness, and so as to provide for the protection of these areas, the preservation of their wilderness 

character, and for the gathering and dissemination of information regarding their use and enjoyment 

as wilderness.” 

Sixteen principles of wilderness stewardship are derived from the Wilderness Act of 1964. They are: 

y Manage wilderness as a distinct resource with inseparable parts; 

y Manage the use of other resources and activities within wilderness in a manner compatible 

with the wilderness resource; 

y Allow natural processes to operate freely within wilderness; 

y Attain the highest level of primeval wilderness character within legal constraints; 

y Preserve wilderness air and water quality; 

y Produce human values and benefits while preserving wilderness; 

y Preserve outstanding opportunities for solitude or a primitive and unconfined recreation 

experience in each wilderness; 

y Control and reduce the adverse physical and social impacts of human use in wilderness 

through education or minimum regulation; 

y Favor wilderness-dependent activities when managing wilderness use; 

y Exclude the sight, sound, and other tangible evidence of motorized or mechanical transport 

wherever possible within wilderness; 

y Remove existing structures and terminate uses and activities not essential to wilderness 

management or not provided for by law; 

y Accomplish necessary wilderness management work with the minimum tool; 

y Establish specific management direction with public involvement in a management plan for 

each wilderness; 

y Harmonize wilderness and adjacent land management activities; 

y Manage wilderness with interdisciplinary scientific skills; and 

y Manage special provisions provided for by wilderness legislation with minimum impact on the 

wilderness resource. 
Section A. Draft Comprehensive Conservation Plan 15 

Figure 5. Wilderness areas 
16 Lower Florida Keys National Wildlife Refuges 

ECOSYSTEM CONTEXT AND REGIONAL CONSERVATION PLANS AND INITIATIVES 

South Florida Multi-Species Recovery Plan 

Several species known to occur in the refuges are listed under the Endangered Species Act as 

threatened or endangered (Appendix I). To be endangered means that a species is in danger of 

extinction throughout all or a major portion of its range, while threatened means that a species is likely 

to become endangered within the foreseeable future. Under the Act, all federal agencies must use their 

authorities to conserve listed species and make sure that their actions do not jeopardize the continued 

existence of listed species. They must protect these species and conserve their habitats. Recovery 

plans are developed for each of the federally listed threatened or endangered species with the objective 

of restoring the species to a healthy population. For the South Florida Ecosystem, the South Florida 

Multi-Species Recovery Plan was adopted by the Service in 1999. It is available online at: 

http://www.fws.gov/verobeach/Programs/Recovery/vbms5.html. All refuge plans, management actions, 

and operations affecting listed species must be in accordance with this recovery plan and only 

undertaken after consultation with the Service’s Ecological Services’ Office. 

Florida Keys National Marine Sanctuary Management Plan 

To protect the diverse marine ecosystem of the Florida Keys, Congress passed the Florida Keys 

National Marine Sanctuary (FKNMS) and Protection Act in 1990. The FKNMS Management Plan 

was approved in 1997 by the Florida Governor and Cabinet and Congress. Since the FKNMS 

encompasses both state and federal waters (Figure 4), it is managed cooperatively between the 

NOAA and the FDEP. The primary purpose of the FKNMS is to protect the unique marine habitats of 

the Florida Keys, especially the world’s third largest coral reef system. Copies of this plan are 

available online at: http://floridakeys.noaa.gov/regs/welcome.html. 

Coastal Resources Barrier Act 

The Coastal Resources Barrier Act of 1982 designated many islands within the Florida Keys, 

including parts of the refuges, for inclusion within the John H. Chaffee Coastal Barrier Resources 

System. Areas so designated are not eligible for federal financial assistance that might support 

development. This law requires agencies that propose using federal expenditures within the Coastal 

Barrier Resources System to consult with the Service’s Ecological Services’ Office for consistency 

with the Coastal Barrier Resources Act. 

State Aquatic Preserves 

The state has established a system of Aquatic Preserves throughout Florida, including Coupon Bight in 

the Lower Florida Keys in 1969 (Figure 4). Management intent is defined in the Florida Aquatic Preserve 

Act of 1975: “for such preserves possessing ...exceptional biological, aesthetic and scientific value...to be 

set aside forever as aquatic preserves or sanctuaries for the benefits of future generations.” (Section 

258.36, Florida Statutes). Coupon Bight is located south of Big Pine Key and encompasses 4,600 acres 

of seagrass meadows, hardbottom communities, mangrove wetlands, and coral patch reefs. For more 

information, visit this web page: http://www.dep.state.fl.us/coastal/sites/coupon.info.htm. 

Florida Comprehensive Wildlife Conservation Strategy 

Florida’s Comprehensive Wildlife Conservation Strategy (Strategy) is an action plan for conserving all of 

the state’s wildlife and vital natural areas for future generations. It identifies which native wildlife and 

habitat are in need of conservation and proposes management strategies to address this need. The 

Strategy is part of a nationwide conservation program. To qualify for federal funding, each state and trust 

territory must develop an action plan. In Florida, the State Wildlife Grants Program provides funding. For 

more information, see: http://myfwc.com/wildlifelegacy/strategy.html. 

 
Section A. Draft Comprehensive Conservation Plan 17 

PHYSICAL RESOURCES 

CLIMATE 

The climate of the Lower Florida Keys is tropical (Jordan l99l), with a mean annual temperature of 

about 77 degrees Fahrenheit (F). The coldest average monthly temperature, 70 degrees F, occurs 

during January, and the warmest mean monthly temperature, 84 degrees F, occurs in August 

(Thomas l974). Temperatures below 39 degrees F are unusual due to the moderating effects of the 

warm marine waters and the coastal Gulf Stream. Freezing temperatures and frost have never been 

recorded. The mean annual rainfall is 39 inches, of which 80 percent falls from May through October 

(Hanson l980). Compared to other seasons, winters are usually dryer, with most rainfall occurring 

during passing cold fronts. Prevailing wind direction is east to southeast, with an annual average of 

about 11 knots. Winds are strongest during the winter months (December through March), when cold 

fronts from the north move through the area. The mean annual sunshine is 3,300 hours, ten percent 

more than the Florida Peninsula to the north. 

GEOLOGY 

The geology of the Lower Florida Keys (Big Pine Key west to Key West) has been described in detail 

by Hoffmeister (l974). Marine carbonate sediments nearly 20,000 feet in depth underlie the Keys. 

Along this submerged platform, coral reefs developed in a band from present day Miami to the Dry 

Tortugas. Two limestone formations of marine origin are found in the Lower Florida Keys. Miami 

oolite, a medium-to-hard limestone, overlies the Key Largo limestone formation. The latter is 

exposed only in a narrow band on the extreme southeast end of Big Pine Key. Elsewhere, it is 

overlain by Miami oolite, a limestone formed during the Pleistocene era in a high energy, shallow 

water environment containing an abundance of calcium carbonate. 

SOILS 

Physical and chemical properties of soils in Monroe County have been detailed by the U.S. 

Department of Agriculture (1989). Saddlebunch marl is the dominant soil in tropical hardwood 

hammocks. In some hardwood hammock areas, humus may be present to a depth greater than 3 

feet. Key Vaca, a very gravelly loam, is the dominant soil in the pine rocklands. Soil types in the 

freshwater wetlands are of the Rock-Outcrop-Cudjoe Complex consisting of 55 percent rock outcrop 

and 45 percent Cudjoe marl. Soils within the fire-dependent pine rocklands are very thin; burning 

removes vegetative litter and exposes the bare oolitic caprock. Cracks and crevices in the exposed 

limestone cap rock form pockets of soil. 

PHYSIOGRAPY 

Refuge islands range from less than a quarter-acre (e.g., Hurricane Key) to nearly 6,919 acres (Big 

Pine Key, partial Service ownership). Taken as a whole, the refuge has relatively few islands larger 

than 99 acres. Elevation ranges from sea level on inundated mangrove islands (e.g., Little Crane 

Key) to 13 feet above sea level (Big Pine Key). A complex network of narrow tidal creeks dissects 

small mangrove islands in some areas (e.g., between Snipe Point and Outer Narrows). 

HYDROLOGY AND FRESHWATER RESOURCES 

Freshwater, other than limited shallow pooling following a rainstorm, is absent from the whole of Key 

West NWR and from nearly all backcountry islands (islands not linked by U.S. Highway 1) in the other 

refuges. A notable exception is Little Pine Key, which is underlain by a freshwater lens. 
18 Lower Florida Keys National Wildlife Refuges 

The distribution of surface freshwater on refuge islands has been mapped and described in detail by Folk 

et al., 1991. Refuge lands on Cudjoe, No Name, Upper Sugarloaf, Big Torch, Little Pine, Howe, and Big 

Pine Keys contain freshwater wetlands year-round. Freshwater wetlands reach their greatest extent and 

distribution on Big Pine Key. Rain water collects and is held chiefly in shallow, impermeable limestone 

basins and solution holes within this islands’ tropical hardwood hammocks and/or pine rocklands. At 

slightly lower elevations amidst these habitats are freshwater wetland communities. 

Big Pine Key is underlain by two distinct freshwater lenses. The largest one is north of Watson 

Boulevard; the other is south of this road (Hanson 1980). In both lenses, freshwater floats on the 

underlying saltwater with areal, tidal, and rainfall-dependent changes occurring seasonally. During 

the highest spring tides, freshwater may be discharged above ground level (Folk et al., 1991). 

Extensive canals dug to create waterfront property accelerated the natural discharge from freshwater 

lenses, decreasing the size of the lens by 20 percent (Levington et al., 1998). The freshwater layers 

are narrow for both lenses (20 to 23 feet), with only a 5- to 10-foot transition zone between fresh and 

salt water (Wightman 1990). Additionally, there are more than 60 miles of ditches dug to drain 

freshwater wetlands for mosquito control. 

WATER QUALITY AND QUANITY 

Four studies of surface and nearshore water quality (Florida Department of Environmental Regulation 

1985; 1987; Lapointe and Clark 1990; and Kruczynski 1999) have been performed in the Florida 

Keys; none were specific to the refuges. 

Both the surface and subterranean freshwater resources of refuge lands on Big Pine are vulnerable 

to contamination (Wightman 1990) because of sea level rise, the runoff of fertilizers, herbicides and 

pesticides from lawns, and the outflow from septic tanks. The latter are inherently a constant source 

of pollution (Paul et al., 1991) because of the referenced geological characteristics of the Lower 

Florida Keys (Lapointe and Clark 1992). Septic tank densities in subdivisions adjacent to refuge 

lands greatly exceed the normally accepted national benchmark of 40 tanks per square mile. This 

benchmark was set for areas unlike Big Pine Key where suitable soils are present (Saarinen 1989). 

AIR QUALITY 

Air quality is a global concern. The U.S. Environmental Protection Agency (EPA) has lead responsibility 

for the quality of air. Through the 1990 Clean Air Act, EPA set limits on the amount of pollutants that 

can be legally discharged into the air. Nationally, more than 170 million tons of pollution is emitted into 

the air annually within U.S. borders, through either stationary sources (e.g., industrial and power plants) 

or mobile sources (e.g., automobiles, planes, trucks, buses, and trains). There are also natural sources 

of air pollution, such as fires, dust storms, volcanic activity, and other natural processes. EPA has 

identified six principal pollutants that are the focus of its national regulatory program: lead, carbon 

monoxide, ozone, nitrogen dioxide, sulfur dioxide, and particulate matter. 

Air pollution causes damage to the environment and property and affects human health. Both federal 

and state governments track air quality and visibility impairment, through a system of 5,200 monitors 

at 3,000 locations across the United States. Florida has 227 monitors at 141 sites. Carbon 

monoxide is from combustion or fire sources and is a problem mainly in cold weather climates. Lead 

has not been detected above standard levels, except in places that have a smelter source. Nitrogen 

dioxide is only monitored in large metropolitan areas, but Florida has never approached the standard. 

Sulfur dioxide is emitted from power plants and paper mills. None of these four principal pollutants 

are monitored near the refuges since they are not considered problem pollutants in this area. The 
Section A. Draft Comprehensive Conservation Plan 19 

Clean Air Act provides for the protection of visibility in national parks and wilderness areas, also 

known as Class 1 areas; however, there are no monitoring stations within the refuges. 

BIOLOGICAL RESOURCES 

FLORA – HABITAT CHARACTERISTICS OF NATIVE VEGETATION/PLANT COMMUNITIES 

The refuges harbor a very diverse assemblage of plants, with 423 native and 88 non-native species 

recorded (Appendix I computed from Gann et al., 2007a,b,c). Native plant diversity is greatest in 

National Key Deer Refuge (410 species), followed by Key West NWR (182 species), and Great White 

Heron NWR (128 species). These data come from Gann et al., 2007a,b,c. Federally listed species 

include Key tree cactus (endangered) and Garber’s spurge (threatened), with six candidate species 

under consideration for listing. 

Because of the small size of the refuge islands, their flat topography and low elevation, and their 

proximity to the sea, very slight differences in elevation cause marked differences in plant 

communities. A controlling factor is the amount, duration, and frequency of tidal inundation. The pine 

rocklands, for example, are intolerant of saltwater, with tidal flooding occurring only during hurricanes. 

In the wake of hurricanes in 1998 (Georges) and 2005 (Wilma), many slash pines were killed by 

saltwater intrusion. 

Major community types include pine rockland, tropical hardwood hammock, freshwater marsh, 

buttonwood transition zone, salt marsh, inland salt ponds, beach ridge hammock, beach/dune and 

mangrove forest (Figure 6). Small but important plant communities on Big Pine Key include the Long 

Beach berm and Cactus Hammock on the southeast end of the island and a marl prairie on the 

island’s north tip. Upland vegetation is primarily of West Indian origin (Dickson 1955, Weiner 1979). 

Pine Rocklands 

A globally imperiled habitat, pine rocklands are a fire-dependent community consisting of an open 

canopy of slash pines with a patchy understory/groundcover of tropical and temperate shrubs, palms, 

grasses, and herbs (Folk 1991). Pine rocklands occur at an elevation 6.5 to 10 feet above mean sea 

level and are usually underlain by a freshwater lens. Pine rocklands contain significant freshwater 

resources, in the form of natural waterholes that are important to Key deer. 

Pine rocklands have the highest plant diversity of all plant communities in the Florida Keys. Ross 

(1989) reported that a typical 16.5-by-16.5-foot area contains up to 30 individual plant species. Pine 

rocklands harbor a number of rare or endemic plant (e.g., Big Pine partridge pea, wedge spurge, 

sand flax) and animal taxa (e.g., Big Pine Key ringneck snake), including two rare butterfly species – 

Bartram’s hairstreak and Florida leafwing. Common plants associated with pinelands include longstalked stopper, blackbead, Keys thatch palm, silver palm, locustberry and poisonwood. 

Pine rocklands are intolerant of saltwater. Of all refuge plant communities, sea-level rise poses the 

greatest risk for the pine rocklands. Ross et al., (1994) reported that a half-foot rise in sea level over 

a 70-year period reduced the size of the pine rocklands on Upper Sugarloaf Key by 66 percent. 

Without periodic fires to check the growth of competing hardwood species, pine rocklands will 

succeed to hardwood hammock. Because anthropogenic barriers, such as roads and houses, have 

fragmented the once contiguous pineland on Big Pine Key, the natural fire regime has been altered to 

the detriment of this habitat. 
20 Lower Florida Keys National Wildlife Refuges 

Figure 6. Land cover 
Section A. Draft Comprehensive Conservation Plan 21 

Tropical Hardwood Hammock 

Tropical hardwood hammocks are the climax terrestrial plant community in the Florida Keys. 

Occurring on uplands 6.5 to 10 feet above sea level, hammocks are hardwood forests consisting of a 

wide diversity of evergreen and semi-deciduous tree and shrubs, many of West Indian origin, 

including paradise tree, gumbo limbo, Jamaican dogwood, pigeon plum, blolly, and wild dilly. Except 

during extreme storm events, these areas are not inundated by sea water. Although not firemaintained communities, fire may periodically enter tropical hardwood hammocks from a nearby 

pineland wildfire, particularly during extreme drought conditions. 

Tropical hardwood hammocks serve as important stopover areas for neotropical migratory birds, 

particularly during inclement weather. Human development has severely reduced and 

fragmented this habitat in the Florida Keys (Bancroft 1996), deleteriously affecting forest nesting 

birds (Bancroft et al., 1995). For example, the state-listed white-crowned pigeon is inextricably 

tied to hammock fruit production. 

Beach Ridge Hammocks 

These hardwood hammocks occur on high sand berms, 3 to 20 feet above sea level, created by 

storm events. Although some of the plants found there are also found in tropical hardwood 

hammocks, this habitat is sufficiently different to warrant a separate classification (Folk et al., 1991). 

Trees in this habitat type grow on a sand substrate with low freshwater retention and are usually 

nearer to the sea–sometimes mere feet–than a typical tropical hardwood hammock. Beach ridge 

hammocks normally have relatively low plant diversity with a sparse understory, which may contain 

limber caper, Bahama nightshade, and blackbead. However, the latter may serve as the dominant 

species over a large area in some beach ridge hammocks. A nearly pure, four-acre stand on Boca 

Grande Key provides an example. Of all berm hammocks in the refuge, elevation is highest (6.5 to 

10 feet) and size greatest on the northwest side of the Marquesas Keys. Within this hammock is the 

only viable population of yellowheart trees in the United States. 

Freshwater Marsh 

Freshwater marshes occur in shallow basins or lowlands either surrounded by higher upland forests 

or between upland areas and transition zones. They have standing freshwater levels that persist for 

extended periods. The average marsh elevation is 3 to 6.5 feet above mean sea level, with size 

varying up to 247 acres (Folk 1991). Wetland plant species include sawgrass, buttonwood, white-top 

sedge, and leather fern. These wetlands are important to amphibians, reptiles, insects, mammals, 

birds, and crustaceans. Freshwater wetlands are absent in Key West NWR. Ephemeral puddling 

occurs on a very small scale where limestone caprock is exposed on Boca Grande Key. 

Buttonwood Transition Zone 

The buttonwood transition zone occurs between mangrove forests and upland forests and consists of 

open scrub (e.g., sea oxeye) and buttonwood forest. Common plants include joewood, mayten, 

saffron plum, key grass, Christmas berry, sea purslane and buttonwood. Average elevation is less 

than three feet above mean sea level, with occasional saltwater inundation during spring high tides 

and/or coastal storms. 
22 Lower Florida Keys National Wildlife Refuges 

Salt marsh 

Refuge salt marshes lack trees and usually occur in the interface between buttonwood transition and 

mangrove zones. The plants in this habitat type are halophytic, that is, able to tolerate periodic tidal 

inundation (e.g., spring high tides) and fluctuating salinity. Common plant species include cord grass, 

sea oxeye, saltgrass, saltwort, and glasswort. Salt marshes are used by a variety of resident and 

transient organisms, notably the endangered Lower Keys marsh rabbit and silver rice rat. 

Inland Salt Pond 

Salt ponds are high salinity, non-vegetated, shallow-water areas of at least an acre that occur 

landward of salt marshes or mangroves. Large salt ponds (greater than 3 acres) are found on Big 

Pine, Barracouta, Cudjoe, and Boca Grande Keys. High numbers of wading birds may gather in such 

areas depending on water depths and fish density. Of special note is the salt pond on Boca Grande 

Key, which is used year-round by wading birds and seasonally by piping plovers; white pelicans; 

black-necked stilts; and least, royal and sandwich terns. This island and Barracouta Key harbor the 

largest known mangrove terrapin populations in the refuge. 

Mangrove 

More than half of the acreage in the three Lower Keys refuges is covered by dense, low mangrove 

forests. Elevation ranges from sea level to four inches above sea level. Dominant plant species are 

red and black mangrove. The roots of these trees are usually either constantly submerged or 

inundated daily by the tides. Lugo and Snedaker (1974) described six mangrove forest types, four of 

which occur in the Florida Keys: overwash, basin, scrub (dwarf), and fringe forests. The latter are the 

most prominent type in the refuges. 

Mangrove forests are some of the most biologically productive ecosystems in the world. These 

forests are a vital component of the estuarine and marine environment, providing a major detrital 

base to organic food chains, important habitat for arboreal, intertidal and subtidal organisms, nesting 

sites, cover and foraging grounds for birds, and habitat for some reptiles and mammals. Mangrove 

wetlands are excellent filters of runoff and are found along coastlines. Mangrove communities 

produce much of the essential nutrients to support the organisms comprising the food chain and 

provide nursery areas for many commercially valuable marine fish. 

Beach and Dune 

Beaches and associated dunes are rare in the Lower Florida Keys Refuges. Except for a narrow 

beach on the extreme southeast side of Big Pine Key, this habitat is absent in National Key Deer 

Refuge. Short, narrow beaches are found on east Sawyer Key and Snipe Point in Great White Heron 

NWR. Beach and associated dunes are a prominent part of the Key West NWR, occurring on Man, 

Woman, Marquesas (7 separate beaches) and Boca Grande Keys. Beach length varies from 164 to 

8,530 feet. All refuge beaches are narrow and coarse-grained, formed primarily of calcareous 

remains from various shallow water marine organisms. Green and loggerhead sea turtles nest on 

refuge beaches; hawksbills nest occasionally on Key West NWR. The beaches also afford important 

foraging and loafing habitat for a variety of shorebirds, including the threatened piping plover. 

Dunes occur landward of the beaches and reach their greatest size and have the highest plant 

diversity on refuge islands in Key West NWR. The beach-dune interface is an important ecological 

front that produces sustained levels of biological activity (Carter et al., 1990). The beach and dune 

may function homeostatically with the nearshore system and alteration of one of these elements may 
Section A. Draft Comprehensive Conservation Plan 23 

affect the others (Carter et al., 1990). Narrow dunes are the most vulnerable to overwash. On Boca 

Grande Key, for example, a small portion (about 165 feet) of the narrow dune on the extreme 

northwest side of the island is inundated during exceptional spring high tides. 

Dunes are a fragile habitat easily damaged by humans, even when very low levels of use are 

involved (Nickerson and Thibodeau 1983). The vulnerability of a dune to any given human activity 

will vary according to local conditions, such as dune size and profile, quantity, and type of flora, 

beach characteristics, and surrounding water depth. Liddle and Greig-Smith (1975) found that 

human activity on dunes alters plant distribution and species diversity, and concluded that impacts 

were equal to that of natural factors. McDonnel (1981) reported that trampling dune vegetation 

altered the width of the fore-dune plant community, and reduced the interdune community to a narrow 

strip at the base of the back-dune community. 

Exotic Plant Species 

Exotic, invasive plant species cause habitat loss by disrupting natural communities on the refuges. 

They displace native species and alter ecosystem functions. There are at least 25 terrestrial exotic, 

invasive plant species known to occur on the refuges. The most widespread and problematic species 

include Brazilian pepper, Australian pine, Asiatic columbrina, seaside majoe, lead tree, and nonnative grasses. Continual monitoring and treatment maintenance are required to keep exotics under 

control in order to prevent new infestations. 

The treatment of invasive exotic pest plants is extremely difficult for both Great White Heron NWR 

and Key West NWR. On these refuges, affected areas are located on the uplands of remote, 

offshore islands, many of which are designated Wilderness areas. Treatment is also problematic on 

National Key Deer Refuge because infestations on private lands, the Overseas Highway, and other 

road rights-of-way serve as seed sources that may re-infest refuge lands. The use of non-native, 

invasive plants in landscaping causes the introduction of exotics to refuge lands. Hurricanes can 

wipe out native plants allowing for the invasion of exotics on disturbed sites. The Service has 

invested substantial time and money in removing exotics and participates as a member on the Florida 

Keys Invasives Exotics Task Force. 

For information on distributions of particular species by county, visit the Atlas of Florida Vascular 

Plants website, www.plantatlas.usf.edu. For additional information on exotic plant species, visit the 

Florida Exotic Pest Plant Council website, www.fleppc.org. 

FAUNA – FISH AND WILDLIFE 

For a listing of the wildlife known to occur in the Lower Florida Keys Refuges, see Appendix I. 

Fish 

The refuges have a high diversity of aquatic habitats. Marine waters within the refuges’ 

administrative boundary are under state jurisdiction. Although marine fishes in the Florida Keys have 

been studied extensively (Bohnsack et al., 1998), those inhabiting fresh and brackish water wetlands 

on refuge lands have received little attention. The few published works have been species-specific 

and narrowly focused (Travel et al., 1990; Turner 1992). A simple inventory of fishes occurring on the 

refuges is needed. 

 
24 Lower Florida Keys National Wildlife Refuges 

Birds 

More than 250 bird species have been observed in the refuges (Appendix I). Avian species that are 

listed under the provisions of the Endangered Species Act and documented on the refuges include 

the roseate tern and piping plover. The red knot is a candidate species. State-listed species include 

the aforementioned species, as well as the least tern, peregrine falcon, snowy plover, bald eagle, and 

white-crowned pigeon. 

The refuges provide important breeding, wintering, and stopover habitat for neotropical migratory 

birds, including songbirds, shorebirds, and raptors. Through the Partners in Flight initiative, federal, 

state, and private agencies are developing and implementing a comprehensive approach for 

managing selected species of migratory nongame birds (Appendix I, Priority Birds in Need of 

Conservation Attention for Subtropical Florida Physiographic Area BCR 31). In an attempt to prevent 

the listing of most of these birds as threatened or endangered species, these trust species are given 

high priority in management decisions. Nesting bald eagles, wading birds, white-crowned pigeons, 

and some terns are also surveyed annually. 

Waterfowl 

Waterfowl do not nest in the Florida Keys. Apart from small numbers of overwintering red-breasted 

mergansers and blue-winged teal, other migratory waterfowl are rarely observed. 

Resident land birds 

Red-bellied woodpeckers, red-winged blackbirds, gray kingbird, black-whiskered vireo, and whitecrowned pigeon are among the more common resident breeding birds. The only warbler species 

known to breed in the Lower Florida Keys Refuges are Cuban yellow and prairie warblers. Both are 

common breeders in the backcountry islands. 

Shorebirds, Waterbirds, and Marshbirds 

The Lower Florida Keys Refuges contain extensive mangrove and shallow water habitats that are 

important loafing and foraging sites for local wading birds and migratory shorebirds. The refuges 

harbor all species of Florida wading birds—excepting the wood stork—as either nesters or vagrants. 

Known nesters include all Florida herons and egrets, as well as the white ibis. The refuges are 

important to nesting great white herons. A peak of 336 nests was documented in 1998 (Wilmers 

2003a), but thereafter nesting declined yearly, with only 83 nests in 2005 and 102 in 2006. 

Roseate tern nesting in the United States is rare and limited by a lack of suitable nesting sites. 

Nesting in the Florida Keys occurred annually outside refuge boundaries on Pelican Shoals, an 

oceanic island obliterated by hurricanes in 2004 and 2005. For the first time on record in 2006, terns 

nested within the administrative boundaries of the Key West NWR at a site close to Boca Grande 

Key. This small sand island was created by Hurricane Wilma and is under state jurisdiction. 

Although three of four nesting attempts were successful, disturbance by dogs and humans was 

observed. The island is eroding and may prove to be ephemeral. In 2005 the south beach on Boca 

Grande Key was washed landward of the dune by Hurricane Wilma. This created a large expanse of 

sand on the island’s interior that may be marginally suitable for roseate tern nesting. Since the island 

is closed to public access, this site may provide a less transitory option for nesting. In July 2007, 82 

non-nesting roseate terns were observed in this area. 
Section A. Draft Comprehensive Conservation Plan 25 

Other birds that nest in the refuges include the brown pelican and double-crested cormorant. Brown 

pelican nesting has declined progressively since 1987. By 2003, there were with only two rookeries, each 

producing less than 20 fledglings, active in 2003 (Wilmers 2003b). In 2007, only one rookery was active 

and no young were produced. Non-nesting, fish-eating birds include various tern and gull species. 

Neotropical Migratory Birds 

A primary purpose of the refuges is conservation of migratory birds. This includes neotropical 

migratory birds, which are defined as shorebirds, waterbirds, and landbirds that are listed in the 

most recent American Ornithologists Union checklist (1983). They are distinguished by having 

separate breeding and wintering ranges, with at least part of the winter range being south of the 

Tropic of Cancer. Where separate populations of a species exhibit differing breeding and 

wintering behavior, an effort has been made to include only those local species that spend the 

winter in the tropics. These species are of keen public and conservation interest because they 

migrate remarkable distances in all weather conditions. Many are experiencing range-wide 

declines due to the destruction and fragmentation of breeding and wintering habitat, poisoning by 

pesticides, collisions with towers and large buildings, and feral cat predation. 

Raptors (Hawks and Allies) 

The Lower Florida Keys Refuges are situated along a major migratory pathway for raptors. Sixteen 

migratory species have been observed in the refuges. Migration begins in late August with the 

passage of American swallow-tailed kites and ends in November with Swainson’s hawks. Broadwinged and sharp-skinned hawks are the most abundant migratory birds. More peregrine falcons 

pass over the Keys than any other hawk observation sites in North America (Lott 2006). While most 

of the migratory raptors use the refuges as a resting and feeding stopover enroute to the tropics, 

significant numbers of certain species overwinter, such as the broad-winged and short-tailed hawks. 

Bald eagle nesting has been monitored annually since 1985 with four to six active nests sighted 

yearly. Some islands were used for nesting for over 20 years and others for only a few years, with 

pairs moving elsewhere. Osprey and red-shouldered hawks are also nesters in the refuges. 

Osprey, red-shouldered hawks, and bald eagles are nesters. Sixteen migratory raptor species have 

been observed in the refuges. Migration begins in August with the transiting of American swallowtailed kites and ends in November with the passage of Swainson’s hawks. Broad-winged and sharpskinned hawks and American kestrels are the most common migratory birds. 

 

Mammals 

As with many island chains, few land-dwelling species occur in the Florida Keys. Except for the 

introduced black rat, mammals are absent from Key West NWR. Key deer and raccoons are the most 

commonly seen mammals in the Lower Florida Keys Refuges. Marsh rabbits and silver rice rats are 

rarely seen. “In 1991 there was a high of 300 individual rabbits and by 1993 the population decreased 

to only 100 individuals (Forys and Humphrey 1994).” According to the South Florida Multi-Species 

Recovery Plan, the “...estimated population sizes for silver rice rats from nine islands range from 0 to 

16 individuals, with an average of approximately 5 per island.” Bottlenose dolphins are the most 

common sea-dwelling mammal in refuge waters. The Florida manatee is a rare, transient visitor. 

Maintaining Key deer numbers at carrying capacity, a level that promotes herd health, is a paramount 

need. The population increased markedly during the 1990s and now exceeds carrying capacity on No 

Name Key and parts of Big Pine Key. The result has been degradation of native plant communities and 
26 Lower Florida Keys National Wildlife Refuges 

loss of habitat diversity, with probable, but as yet unstudied, impacts on other wildlife species. Several 

once-common plant species highly palatable to deer, such as black torch, have disappeared or been 

greatly reduced over large areas of Big Pine and No Name Keys. Deer at high densities may exist at a 

lowered nutritional plane and are more susceptible to epizootic diseases. 

For many years, Key deer aggregations have been particularly high near subdivisions, such as Port Pine 

Heights and Koehn, their numbers burgeoned collectively by the reproductive output of a large number of 

resident does, feeding on ornamental plants, and illicit feeding of deer by tourists and residents. After the 

mid-1990s, deer roadkill numbers increased markedly, with annual numbers sometimes exceeding 100 

animals. Despite this elevated mortality, deer numbers have remained high and were offset by annual 

population recruitment. For this reason, and because Key deer have no natural predators and cannot be 

hunted, immuno-contraception is the only means to control herd numbers. 

Paradoxically, as deer population increased on No Name and Big Pine Keys, there was a reduction 

or extirpation in other parts of the deer’s range, including Johnson, Cudjoe, and Sugarloaf Keys. 

Because substantial suitable deer habitat existed on Sugarloaf and Cudjoe Keys, more than 30 Key 

deer were translocated several years ago to these islands from No Name and Big Pine Keys. The 

fate of these populations must be monitored over time to assess the efficacy of translocation as a 

long-term management strategy for these areas. 

Nutritional indices of the deer herd as a whole can be effectively assessed by performing necropsies 

of all dead animals. Detection of some epizootic diseases, however, cannot be confirmed without a 

battery of laboratory tests. 

Amphibians 

Amphibians require freshwater and are therefore absent in Key West NWR and most of the islands in 

the Lower Florida Keys Refuges. They occur mostly on National Key Deer Refuge, most notably in 

water holes and mosquito ditches on Big Pine Key. The most common amphibians are the southern 

leopard frog and two introduced species: the greenhouse and Cuban tree frogs. At least seven 

native and three non-native species (e.g., marine toad) of amphibians occur on the refuge. 

Inventories are underway in 2007 in the National Key Deer Refuge to establish baseline data on the 

status and distribution of amphibians. 

Reptiles 

A comprehensive survey of reptilian species in the Lower Florida Keys Refuges is lacking and a 

precise number of species is not known. Eleven species of lizards, nine species of snakes, and 

eleven species of turtles have been documented, many of which are non-native. The American 

alligator, crocodile, and eastern indigo snake are noteworthy species. The green, loggerhead, and 

hawksbill sea turtles are nesting species, while the Kemp’s ridley is a forager in waters surrounding 

the refuges. Inventories began in 2007 in the National Key Deer Refuge to establish baseline data on 

the status and distribution of reptiles as only sea turtles have had regular specific monitoring. 

 

Invertebrates 

No attempt has been made to catalogue the plethora of invertebrates on the refuge, although some 

outside researchers have studied certain species or groups. The refuge is compiling a list of moths 

and butterflies. At least three federal candidate species of butterflies occur in the refuges: Bartram’s 

hairstreak, Florida leafwing, and Miami blue. Both the Bartram’s hairstreak and Florida leafwing 

butterflies are restricted to slash pine rocklands that contain pineland croton, the only known host 
Section A. Draft Comprehensive Conservation Plan 27 

plant for both species. The Miami blue is present on six islands (eight discrete beach/dune areas) in 

Key West NWR where it occupies narrow berm hammocks, fronted by dunes, where its host plant, 

blackbead, is present. Both the range and populations of these three species are but a fraction of 

their historical distribution and numbers. Given their rarity and small populations, illicit collection and 

future hurricane damage warrant concern. Aerial application of Naled (aka Dibrom) to control 

mosquitoes is known to deleteriously impact butterfly populations (Emmel 1991, Salvato 2002). 

Naled drift into non-target refuge areas on Big Pine Key warrants concern. 

Exotic Animal Species 

The distribution and impact of exotic and feral animals on native plants and wildlife within the refuge 

are poorly known. Feral cats are predators of the endangered Lower Keys marsh rabbit, silver rice 

rat, and other animals. Imported fire ants attack young sea turtles and endangered endemic 

mammals. Black rats may eat bird eggs and the young of endangered rodents and out-compete the 

latter for habitat. Non-native reptiles and amphibians may be impacting their native counterparts. No 

substantive research has been performed, but it is warranted. Perhaps the most common exotic 

animal is the green iguana, the population of which has increased greatly over the past decade. 

Other exotic animals include the Cuban treefrog and imported fire ant; their impacts have not been 

studied but could be substantial. Shiny cowbirds, now present in Key West NWR, and the Gambian 

pouch rat, established some 30 miles from refuge boundaries, are notable species to monitor. 

Threatened, Endangered, and Candidate Species 

Table 1 depicts species that are federally listed as threatened or endangered, as well as candidate 

species. Many of these species are declining or experiencing severe population losses due to 

alteration and/or degradation of their habitats. By perpetuating intact natural communities, restoring 

degraded natural communities and processes and eliminating adverse human impacts, the refuge 

can contribute to species recovery goals and benefit other plants and animals dependent on these 

endangered ecosystems. Monitoring efforts of sufficient intensity and duration to determine refugespecific status and trends of federally listed species are needed. 

Table 1 - Federally Listed Threatened (T), Endangered (E), and Candidate (C) Species of the 

Lower Florida Keys Refuges 

NKDR GWH KW SPECIES LATIN NAME FEDERAL 

STATUS 

MAMMALS * = occurs at this refuge (CH) = critical habitat

* * Key deer Odocileus 

virginianus clavium 

E 

* * Lower Keys marsh rabbit Sylvilagus palustris 

hefneri 

E 

* * Silver rice rat Oryzomys palustris 

natator 

E (CH) 

* * * West Indian manatee Trichecus manatus E (CH) 
28 Lower Florida Keys National Wildlife Refuges 

NKDR GWH KW SPECIES LATIN NAME FEDERAL 

STATUS 

BIRDS

possible possible possible Kirtland’s warbler Dendroica kirtlandii E 

* * * (CH) Piping plover Charadrius melodus T (CH) 

possible possible * Roseate tern Sterna dougallii 

dougallii 

T 

* * * Red knot Calidris canutus 

rufa 

C 

REPTILES

* * American Alligator Alligator 

mississippiensis 

T (S/A) 

* American crocodile Crocodylus acutus T (CH) 

* Eastern indigo snake Dymarchon corais 

couperi 

T 

 * Green sea turtle Chelonia mydas E (CH) 

 * Hawksbill sea turtle Eretmochelys 

imbricata 

E (CH) 

 * Kemp’s ridley sea turtle Lepidochelys kempii E 

 * Leatherback sea turtle Dermochelys 

coriacea 

E (CH) 

 * Loggerhead sea turtle Caretta caretta T 

FISH

* * * Smalltooth sawfish (United 

States Distinct Population 

Segment) 

Pristis pectinata E, NMFS 

INVERTEBRATES

* Stock Island tree snail Orthalicus reses T 
Section A. Draft Comprehensive Conservation Plan 29 

NKDR GWH KW SPECIES LATIN NAME FEDERAL 

STATUS 

(not including

nesodryas) 

* Possible Possible Bartram’s hairstreak 

butterfly 

Strymon acis 

bartrami 

C 

* Possible Possible Florida Leafwing Anaea troglodyta 

floridalis 

C 

* Possible * Miami blue butterfly Cyclargus 

(=Hemiargus) 

thomasi 

bethunebakeri) 

C 

 Staghorn coral Acropora 

cervicornis 

T, NMFS – 

Listed May 9, 

2006 (71 FR 

26852)

 Elkhorn coral Acropora palmata T, NMFS – 

Listed May 9, 

2006 (71 FR 

26852)

PLANTS

* Blodgett’s silverbush Argythamnia 

blodgettii 

C 

* Big Pine partridge pea Chamaecrista 

lineata keyensis 

C 

* Wedge spurge Chamaesyce 

deltoidea serpyllum 

C 

* * Garber’s spurge Chamaesyce 

garberi 

T 

 * Cape Sable thoroughwort Chromolaena 

frustrata 

C 

* Sand flax Linum arenicola C 

* Florida semaphore cactus Consolea corallicola C 

* Key tree cactus Pilosocereus robinii E 
30 Lower Florida Keys National Wildlife Refuges 

The South Florida Multi-Species Recovery Plan referenced in Chapter I provides a description of all 

imperiled species located within the Lower Florida Keys Refuges. A brief description of selected 

federally listed threatened and endangered species follows. 

Endangered Species 

Key deer. The Key deer is the smallest subspecies of the North American white-tailed deer. It 

historically ranged from Key Vaca to Key West, but the current range includes approximately 26 

islands from Big Pine Key to Sugarloaf Key, with the center of its population on Big Pine and NoName Keys. Most lands within its current range, including privately owned lands, lie within the 

administrative boundaries of National Key Deer Refuge. Key deer utilize all habitats within their 

range, including pine flatwoods, pine rocklands, hardwood hammocks, buttonwood, mangrove, and 

freshwater wetlands. They also use residential and commercial areas extensively where they feed on 

ornamental plants and grasses and seek freshwater. The Key deer remains federally listed due to its 

restricted range, continued loss of habitat, and high human-related mortalities and disturbances. 

 

Lower Keys marsh rabbit. The Lower Keys marsh rabbit is a subspecies of the marsh rabbit, a 

species widespread in the southeastern United States. While this species originally ranged 

throughout the Lower Florida Keys, the marsh rabbit is known from only thirteen sites on Lower 

Sugarloaf, Welles, Annette, Hopkins, Geiger, Boca Chica, and Big Pine Keys. Its habitat includes 

coastal and freshwater marshes. 

Silver rice rat. The silver rice rat is a small, primarily nocturnal, wetland rodent with large home 

ranges that are adapted to the unique island habitats of the Lower Florida Keys. Critical habitat 

includes areas containing contiguous mangrove swamps, saltmarsh flats, and buttonwood transition 

vegetation. Populations are found at extremely low densities on twelve islands and were listed as 

endangered because their wetland habitat has been destroyed by development. 

Florida manatee. Manatees are rare in the Lower Florida Keys. The refuge staff provides logistical 

assistance to local and state wildlife agencies, as needed, if sick, injured, or dead animals are found. 

Kemp’s ridley sea turtle. This is a small to medium-sized turtle with a nearly circular shell. Primarily 

a Gulf of Mexico species, it inhabits marine coastal waters with sand or mud bottoms. Juveniles 

frequent bays. Nesting occurs on Gulf beaches in south Texas and northern Mexico, 

although a few nests have been confirmed in Florida. 

Green sea turtle. This large sea turtle inhabits marine coastal and oceanic waters and occurs in 

Florida year-round. Nesting occurs on four beaches: Boca Grande Key, Sawyer Key, and two 

beaches in the Marquesas Keys. The number of nests in the Marquesas Keys has doubled since 

1998, with as many as 20 nests recorded in a single year. Nest numbers have been stable on Boca 

Grande and Sawyer Keys since 1990, despite progressive degradation of nesting habitat. 

 

Threatened Species 

Piping plover. The piping plover is found on open, sandy beaches and on tidal mudflats and sand 

flats, and winters along both coasts of Florida. Piping plovers have been observed on four refuge 

islands – Boca Grande, Woman, Marquesas, and Ohio Keys. A peak of 29 piping plovers was 

observed on Woman Key in February 1998. 

Loggerhead sea turtle. This large sea turtle inhabits marine coastal and oceanic waters and is 

present in Florida year-round. Nesting has been monitored annually since 1990 and occurs yearly in 
Section A. Draft Comprehensive Conservation Plan 31 

Key West NWR on Woman, Boca Grande, and the Marquesas Keys and on Sawyer Key in Great 

White Heron NWR. A peak of 70 nests was found in Key West NWR in 1995, but has declined 

sharply since then (Wilmers 2003). Only 18 and 26 nests were found during the 2005 and 2006 

nesting seasons. Begun in 2003, an ongoing project by the Inwater Research Group is assessing the 

genetic origin, health, demographics, and species composition of the sea turtle populations in 

developmental habitats and adult turtle wintering areas of Key West NWR. 

In Great White Heron NWR, annual nesting on the 200-meter beach at Sawyer Key has been low 

both for loggerhead nests (0-9) and green sea turtle nests (0-7) since 1990. This beach was severely 

eroded during a March 1993 storm and is being overtaken by encroaching mangrove trees. 

 

Hawksbill sea turtle. This is a small-to-medium-sized sea turtle that is found throughout Key West 

NWR in hard-bottomed and reef habitats containing sponges. Nesting is rare and has only been 

documented once on Boca Grande Key and several times in the Marquesas Keys. On the latter 

island, nesting has been restricted to the fall and winter months. 

Eastern indigo snake. This large, stout-bodied, shiny black snake can be up to 8 feet long. It is 

docile, non-poisonous, and occurs throughout Florida, but is rare in the Lower Keys. It is a habitat 

generalist inhabiting the pine rocklands, tropical hardwood hammocks and buttonwood transition 

zones. It requires large tracts (over 5,000 acres) to survive. The status of the eastern indigo snake 

in the Lower Florida Keys has not been assessed. Since there have been no confirmed sightings in 

numerous years, they may be extirpated throughout the Lower Florida Keys. 

 

Stock Island tree snail. The Stock Island tree snail is an arboreal snail found in hardwood 

hammocks in the Florida Keys. The snail historically occurred on Stock Island and Key West where it 

is virtually extirpated. Habitat loss and a major decline in the original Stock Island population led snail 

collectors to move snails to other hammocks throughout the Keys. The translocation of snails 

successfully prevented extinction of the species, but several of the few remaining populations are at 

risk due to continuing habitat loss to development. The National Key Deer Refuge contains one of 

the last established populations of this snail. Strategies for hardwood hammock habitat restoration 

will benefit the Stock Island Tree Snail. 

CULTURAL RESOURCES 

A detailed description of the history and cultural heritage of Monroe County is found in Section II of 

The Florida Keys Environmental Story: A Panorama of the Environment, Culture and History of 

Monroe County, Florida (Gallagher 1997). 

SOCIOECONOMIC ENVIRONMENT 

Purpose 

The purpose of this section is to provide information on (1) the social and economic status of Monroe 

County and its residents; (2) the economic value of wildlife-dependent recreation; and (3) the 

Service’s recreation opportunities and environmental education programs in the Lower Florida Keys. 
32 Lower Florida Keys National Wildlife Refuges 

Background 

Monroe County includes the Florida Keys and a small section of the south west tip of the Everglades. 

This report is only concerned with the socioeconomics of the Florida Keys. According to the U.S. 

Census Bureau, for the year 2000, compared to the state as a whole, the county represents only a 

half percent of the state population and has less than a percent (0.7 percent) of the state’s housing. 

The Keys represent only 5.6 percent of Monroe County’s total area, 1.8 percent of the state’s land 

area, and 23 percent of the state’s waters. The Florida Keys are sparsely populated compared to 

Florida as a whole. Many of the islands are semi-rural though there are several large, developed 

islands - Islamorada, Marathon, and Key West. 

There is still much undeveloped land that is in private ownership. The county has restricted development 

to prevent the human population from exceeding the carrying capacity of the water, electric, and sewage 

services. There is a concern for hurricane evacuations of the current resident and tourist populations with 

the present road and bridge infrastructure. With many private lands in the Lower Florida Keys containing 

threatened or endangered species, habitat loss from development is also a concern. 

The economy of the Keys is supported primarily by tourism. There is extensive service support for the 

tourist industry and local resident needs. Almost every island accessible by U.S. Highway 1 has one or 

more developments, trailer parks, RV parks, and/or campgrounds. Water-based sports (e.g., sport fishing, 

diving, and kayaking) and the night life of Key West have also become a major draw to the area with their 

associated economic gains. Also important to the economy of the Keys is real estate—the renting, selling, 

and buying of homes, many of them to seasonal residents. 

 

Regional Demographics and Economy 

Information for 2000 is available for Monroe County from the following websites: 

http://www.census.gov/main/www/cen2000.html and 

http://www.census.gov/census2000/states/fl.html. 

Table 2 compares the population, housing units, land area, and density of the Florida Keys to that of 

the State of Florida. The population density of the Keys is approximately one-quarter of the rest of 

Florida, and the housing unit density is approximately one-third of the rest of Florida. 

Table 2 - Monroe County – population, housing units, area, and density 

 Area in Square Miles Density per square 

mile of land area 

Population Housing 

Units 

Total Area Water Area Land Area Population Housing 

Units 

FLORIDA 

15,982,378 7,302,947 65,754.59 11,827.77 53,926.82 296.4 135.4 

MONROE COUNTY 

79,589 51,617 3,737.15 2,740.24 996.91 79.8 51.8 

Source: U.S. Census Bureau, 2005 American Community Survey, page 1. 
Section A. Draft Comprehensive Conservation Plan 33 

Monroe County residents enjoy a higher average income than other areas of the United States and 

Florida; however, income figures may be inflated due to a higher percentage of very wealthy 

residents. The overall cost of living is higher with housing costs in particular being very high for 

working class residents. 

Table 3 - Income and population statistics 

*Median Family Income (2005) Percent of Population over 65 

United States $55,832 United States 12.1% 

Florida $50,465 Florida 16.6% 

Monroe County $62,638 Monroe County 15.6% 

Source: U.S. Census Bureau, 2005 American Community Survey, page 1. 

Table 4 - Monroe County demography statistics 

CHARACTERISTICS 2000 2005 PERCENT 

CHANGE 

Population 79,589 75,074 - 6.0%

Age 18 – 65 65,984 62,178 - 5.8%

Age 65+ 11,648 11,740 + 0.8%

Median family income $ 50,734 $62,638 + 19.0%

Per capita income $ 26,102 $36,963 + 29.0%

Families below poverty level 1,403 N/A N/A

Median value of homes $241,200 

N/A Not applicable 

Source: U.S. Census Bureau, 2000 and http://enwikipedia.org./wikiMonroe County, Florida 

The average age of residents over 65 living in the Florida Keys is higher than the U.S. average; there 

has been a decline in population of residents between the ages of 18 to 65. The Florida Keys are 

experiencing a decline of local residents who grew-up with the knowledge of the intrinsic and 

economic value of the Keys’ natural resources. This is pertinent to the refuges in terms of the 

continuing effort needed to educate the public about natural resources and the needs of endangered 

and imperiled species, especially with a large, seasonal influx of visitors. 
34 Lower Florida Keys National Wildlife Refuges 

Economic Contribution of Recreating Visitors to the Florida Keys/Key West

The tourist industry activities of boating, fishing, scuba diving/snorkeling, and sightseeing generate 

$147 million per year. All of these activities are available on the three refuges. The Monroe County 

Tourist Development Council conducted a survey of over 3,000 visitors from March 2005 – February 

2006. Visitors were asked to choose among 10 categories of activities as reasons for their visit to the 

Keys. Thirty-six percent of respondents indicated that diving, snorkeling, wildlife viewing, and boating 

as their primary visitor activities. 

Recreation Use and Visitor Services 

The National Survey of Fishing, Hunting, and Wildlife-Associated Recreation has been conducted 

about every five years since 1955. It provides information on the number of participants in fishing, 

hunting, and wildlife watching (observing, photographing, and feeding wildlife), and the amount of 

time and money spent on these activities. The 2006 survey report should be available by 2008. 

The 2001 survey found that over 82 million U.S. residents 16 years old and older fished, hunted, or 

watched wildlife in 2001: 34 million people fished, 13 million hunted, and 66 million participated in at 

least one type of wildlife-watching activity. Wildlife recreators' avidity was reflected in their spending, 

which totaled $108 billion in 2001, and amounted to 1.1 percent of the gross domestic product. 

Wildlife watchers spent $38 billion on trips, equipment, and other items. 

The 2007 Banking on Nature report states, “Recreational visits to national wildlife refuges generate 

substantial economic activity. In Fiscal Year 2006, more than 34.8 million people visited refuges in 

the lower 48 states for recreation. Their spending generated more than $1.7 billion of sales in 

regional economies. As this spending flowed through the economy, nearly 27,000 people were 

employed and $542.8 million in employment income were generated. About 82 percent of total 

expenditures were by non-consumptive activities on the refuges.” 

According to the Monroe County Tourist Development Council, the Florida Keys receive 

approximately 1.9 to 2 million visits by car annually. An important part of the revenue income in the 

Lower Florida Keys is related to the three refuges, which collectively receive about 861,750 visits 

annually: National Key Deer Refuge--139,000 visits; Key West NWR--436,500 visits; and Great White 

Heron NWR--286,250 visits. The estimate for National Key Deer Refuge is based on actual counts 

taken with an electronic counter. About 10,000 visits are at the Visitors Center in the Big Pine Key 

Plaza. The estimates for Key West and Great White Heron NWRs are estimated from a decade-old, 

unofficial survey and in-house estimates of customers to the diving, snorkeling, fishing, and kayaking 

industries. 

The Improvement Act of 1997 established six priority wildlife-dependent public uses on national 

wildlife refuges if they are compatible with the purpose of each refuge: hunting, fishing, wildlife 

observation, wildlife photography, and environmental education and interpretation. Hunting is 

prohibited both in the refuges and Monroe County. Collectively, the three refuges provide 

opportunities for the other five wildlife-dependent activities. The refuge areas that are open to public 

access are free of charge and open seven days a week. Hours are from a half-hour before sunrise to 

a half-hour after sunset. 

Much of National Key Deer Refuge is on the mainline keys (islands that are accessible by vehicles) 

and open to the public access via fire roads and other trails. These lands are located on the following 

keys-- Ohio, No Name, Big Pine, Middle Torch, Big Torch, Cudjoe, and Upper and Lower Sugarloaf 
Section A. Draft Comprehensive Conservation Plan 35 

Keys. The backcountry refuge islands that have Key deer are designated as wilderness and are only 

open to public access with a special use permit. 

Environmental education opportunities are provided for local students on Big Pine and Sugarloaf 

Keys, though teachers can bring students elsewhere on the refuge. The refuge provides extensive 

interpretive information on Big Pine Key (Figure 7) at the Visitors Center, the Blue Hole, the 2/3-mile 

Watson and the 1/8-mile Mannillo nature trails, the latter of which is accessible for persons using 

wheel chairs. The Blue Hole is an old quarry with an observation deck and partial trail that provides 

viewing of a variety of turtles, fish, nesting green herons and other birds, insects, Key deer, raccoons, 

invasive exotic iguanas, and the occasional alligator. Throughout the refuge, opportunities are 

provided to view wildlife and wildlife habitat and for photography. Many visitors come to the refuge to 

see the endangered Key deer; most of the population is found on Big Pine and No Name Keys. 

There are other designated wildlife viewing areas on Big Pine Key off Long Beach Road, and the 

newly designated Buttonwood Marsh Trail at the north end of Key Deer Boulevard. Other trails are 

open on Cudjoe and Lower and Upper Sugarloaf Keys (Figure 8). Ohio Key also has beach access. 

Fishing on any of the three refuges is not listed as a permitted activity in the Code of Federal 

Regulations. This activity occurs along the shoreline and in state-owned marine waters adjacent to 

refuge lands on Ohio Key and occasionally in marine canals on No Name Key. Some non-priority 

uses have been allowed on the refuge, for example, horseback riding has been permitted on the 

refuge for over 15 years. 

Key West and Great White Heron NWRs contain over 300,000 acres of marine waters, dozens of 

mangrove islands, and several islands with pristine undeveloped beaches that are designated as 

wilderness. The marine waters are some of the best waters for saltwater sport fishing in the North 

America. Visitors come from all over the world to fish these waters and numerous tournaments are 

held to catch and release these sport fish. The dozens of mangrove islands and shallow waters are 

home for nesting, feeding, and resting birds, such as pelicans, cormorants, herons, egrets, plovers, 

and frigate birds, to name a few. Due to an abundance of birds, the refuges are a haven for birders. 

Boaters travel to the pristine beaches of Woman and Boca Grande Keys to enjoy a leisurely day in a 

secluded beach setting. 

Management of the marine waters is limited as they are state-owned waters. This limited authority is 

granted by the State via the Management Agreement, which allows the Service to regulate access 

within 300 feet of specifically mentioned islands, to enforce boating speed zones and no-entry areas, 

and to prohibit the use of personal water craft, seaplane landings, hovercraft, airboats, and 

waterskiing within the administrative boundaries of the two refuges (Figure 9). All other marine 

activities (e.g., fishing) are controlled by the State. 

The visitor services’ park ranger is involved in several organizations and/or sites and their activities 

including, but not limited to, the Monroe County Environmental Education Advisory Council, the 

Florida Keys Birding and Wildlife Festival, the Florida Keys Scenic Highway Initiative, and the 

interagency Florida Keys Eco-Discovery Center. Volunteers continue to be a major contributor to the 

success of the National Wildlife Refuge System. In 2005, nearly 38,000 volunteers contributed 1.4 

million hours on refuges nationwide, a service valued at more than $25 million. The Lower Florida 

Keys Refuges depend on a volunteer base of about 80 individuals, work-campers, and inerrant 

workers from alternative spring breaks (e.g., colleges) and other organized programs, who 

contributed almost 4,000 volunteer hours in 2006. 
36 Lower Florida Keys National Wildlife Refuges 

Figure 7. Lower Florida Keys Refuges visitor services facilities 
Section A. Draft Comprehensive Conservation Plan 37 

Figure 8. Lower Keys trails 
38 Lower Florida Keys National Wildlife Refuges 

Figure 9. Boating zones and restrictions 
Section A. Draft Comprehensive Conservation Plan 39 

III. Plan Development 

SUMMARY OF ISSUES, CONCERNS, AND OPPORTUNITIES 

This Draft CCP/EA was prepared in compliance with the National Environmental Policy Act of 1969. 

This law requires the Service to include public involvement in environmental planning. A public notice 

announcing that the comprehensive planning process had begun was published in the Federal 

Register on May 9, 2003, with the initiation of the Crocodile Lake NWR CCP. In 2003, a Visitor Services’ 

program review was conducted for National Key Deer Refuge. In 2005, a review of the Service’s 

biological programs and resources was conducted for the Lower Florida Keys Refuges. A wilderness 

review of these refuges was conducted in 2006. These professional reviews were done to determine 

issues of importance to be addressed in the long-term plan. A list of experts from the Service and 

partnering agencies that participated in the reviews is included in Section B, Chapter V. The 

information garnered from the reviews helped the Service’s planning team analyze and develop 

recommendations for the Draft CCP/EA. 

In preparation for the Draft CCP/EA, public scoping meetings for the Lower Florida Keys Refuges 

were conducted in March 2005. The March 8 meeting was held on Big Pine Key at the local 

charter school with approximately 40 people in attendance. The March 9 meeting was held in 

Key West at the Board of County Commissioners’ meeting room with approximately 20 people in 

attendance. Meeting notices were published in the local newspapers and flyers were displayed at 

several locations, such as the post office and supermarkets. The public provided comments on 

issues that should be addressed in the 15-year CCP. A summary of the comments from these 

meetings is included in Appendix D. 

In June 2006, a core CCP planning team of Service staff started meeting regularly to develop the 

Draft CCP/EA for the Lower Florida Keys Refuges. The team considered all public and 

interagency comments. The team prioritized the most critical issues to be addressed by the 

refuges over the 15-year life of the CCP. 

PRIORITY RESOURCE ISSUES 

OVERARCHING ISSUE (APPLIES TO ALL REFUGES ACROSS MOST PROGRAM AREAS) 

1. Managing a complex of islands. 

A unique challenge to the management and operation of the Lower Florida Keys Refuges results from 

their geography. The three refuges are comprised of islands that are scattered across an expanse of 

water extending from the Seven Mile Bridge nearly 75 miles north of the Marquesas Keys. The 

refuges’ approved acquisition boundaries cover vast amounts of land and water. Road access is 

limited to only a few mainline islands connected by U.S. Highway 1. Boat access to the majority of 

islands is dependent on weather and tides and requires local knowledge and planning. 

This complex of islands creates jurisdictional challenges as well. All of the Lower Florida Keys Refuges 

fall within the boundary of the FKNMS administered by NOAA, and all of the waters and submerged lands 

below mean high tide are owned by the State of Florida. The Service has limited authority over certain 

state waters in Key West and Great White Heron NWRs under its Management Agreement with the State 

of Florida, which restricts public access to protect wildlife. Additionally, within the administrative boundary 

of National Key Deer Refuge, there is a patchwork of conservation lands owned and managed by multiple 
40 Lower Florida Keys National Wildlife Refuges 

agencies and groups, interspersed with vacant private lands, residential subdivisions, and commercial 

zones. In addition to refuge-owned lands, the National Key Deer Refuge has management authority over 

select parcels owned by the state or county under lease agreements. 

VISITOR SERVICES 

2. Changing public use attitudes, needs, and demands. 

There is a need to continually educate the public about the needs and management of imperiled 

species and their habitats in the Lower Florida Keys Refuges. Seasonal residents, mostly retired 

individuals, comprise approximately 35 percent of the population. Tourists make up the bulk of 

visitors inquiring about the refuges. A unique and varied approach for environmental education and 

awareness programs is necessary to reach an ever-changing public audience. New residents and 

tourists are often unaware or unconcerned about the illegality of feeding Key deer or the problems 

associated with exotic invasive species. 

Changes in public use attitudes, needs, and demands constrain the refuges’ ability to ensure quality, 

appropriate, and compatible wildlife-dependent recreational opportunities and facilities. The priority 

wildlife-dependent public uses for the Lower Florida Keys Refuges are fishing, wildlife observation, 

wildlife photography, and environmental education and interpretation. Hunting is prohibited in 

Monroe County. Equally important are efforts to curtail inappropriate and non-compatible recreation 

in order to maintain resource protection and integrity. In particular, there is an increasing demand for 

non-priority public and commercial uses of the few beaches in the Key West and Great White Heron 

NWRs, which also provide critical habitat for sea turtles and migratory birds. Management strategies 

implemented 10 to 20 years ago when there were fewer people using the backcountry may no longer 

be adequate to protect wildlife or preserve the wilderness character today with more users. The 

impacts of visitor use on wildlife, plants, and habitats, and the human carrying capacity in specific 

areas of the refuges have not been assessed. These impacts need to be evaluated and appropriate 

measures developed and implemented to minimize adverse impacts. 

Violations that occur from public use on the Lower Florida Keys Refuges include trespassing in 

closed areas, personal watercraft use in the backcountry, dumping of garbage on refuge lots, drug 

and immigrant smuggling, digging for antiquities, vandalism, poaching, and feeding wildlife. The 

refuges currently have two full-time law enforcement officers to patrol all the refuge islands situated 

across 545 square miles of land and water. Law enforcement is crucial to prevent and investigate 

illegal activities, in addition to ensuring visitor and employee safety and protecting the refuges’ wildlife 

resources, wilderness values, cultural resources, and government facilities. 

HABITAT MANAGEMENT 

3. Habitat fragmentation. 

A primary threat to upland habitats in the Florida Keys is loss and fragmentation of habitats and the 

resultant loss of ecosystem function due to residential and commercial development. Canals, 

mosquito ditches, surface fill, and roads have altered natural hydrologic processes on islands 

connected by the road system. Residential development has impacted management capabilities for 

fire-adapted pine rockland habitats by expanding the wildland-urban interface. The result has been 

an alteration of natural fire processes and a demand for fire suppression. While there has been 

substantial restoration of freshwater wetlands, which are critical for native mammals, birds and 

reptiles within the National Key Deer Refuge, more is needed. Wetland and upland restoration is 

needed to help mitigate habitat loss elsewhere. 
Section A. Draft Comprehensive Conservation Plan 41 

4. Climate change. 

Meteorological and climatological events, such as hurricanes (e.g., Wilma 2005) and sea level rise, 

also pose challenges for refuge management. Low-lying islands, such as the Florida Keys, will face 

substantial impacts from global climate change, particularly rising sea level and coastal storms. Such 

effects have already been experienced in the past; however, these events may become more 

frequent and severe within the 15-year time period covered by this CCP based on recent projections 

by the Intergovernmental Panel on Climate Change. 

Saline intrusion into the subsurface freshwater lens from sea level rise and saltwater inundation of 

surface freshwaters from storm surges can alter pine rocklands and freshwater marshes resulting in 

more salt-tolerant plant communities. Species that are found only in pine rockland may consequently 

disappear as the pine forests die out. Storm events can cause considerable physical damage to 

beach berms and native vegetation in the vulnerable coastal habitats. The most immediate action 

that the Service can take is to gather the best scientific data possible for understanding natural 

processes in their current state, modeling possible impacts and subsequent changes from sea level 

rise, and developing adaptive management strategies for future conservation needs. 

5. Fire management. 

National Key Deer Refuge protects the majority of globally imperiled pine rocklands, a fire-adapted 

habitat that requires periodic burning to maintain an open understory and diversity of herbaceous 

plants. Fire is also an appropriate habitat management tool to maintain and restore grassland and 

saltmarsh habitats. As land use patterns changed and development intensified along refuge borders, 

the wildland-urban interface became more of a consideration for both prescribed fire management 

and wildfire suppression given the inherent risk that a fire could escape to a populated area and 

threaten lives and property. Further, there are aesthetic concerns among residents along refuge 

boundaries due to fuel management projects. While smoke exposure for residents is an issue, the 

benefit to them is substantial in that reduced fuel loads will lessen the threat of wildfires. 

The lack of a consistent burn regime in the fire-dependent pine rockland community increases fuel 

loads and undesirably alters natural species composition and community processes. Prescribed fire 

is the primary tool for effectively managing and restoring pine rocklands. Prescribed fire is also an 

appropriate tool to manage the encroachment of overstory vegetation and to restore open habitat 

features of coastal salt marsh and freshwater marsh habitats. To date, prescribed burns in the 

National Key Deer Refuge have focused on pine rocklands yielding differing results; however, there 

has been no comprehensive post-burn monitoring to quantify whether habitat management objectives 

were achieved. Future habitat management strategies need to include measures of the effectiveness 

of prescribed fire treatments. Such monitoring is essential for an adaptive management process to 

maintain and restore habitat. A continued outreach effort will also be needed to increase the public’s 

awareness and understanding about this management technique. 

FISH AND WILDLIFE POPULATION MANAGEMENT 

6. Lack of inventorying and monitoring. 

Wildlife populations need to be adequately inventoried and monitored to establish baseline data, 

determine population trends, identify management needs, set priorities, and evaluate the impacts of 

management actions. There are many imperiled species and a small staff dedicated to biological 

work. Past emphasis has been placed primarily on studying the Key deer and monitoring nesting sea 

turtles, white-crowned pigeons, and key wading bird species. As a result, baseline data are lacking 
42 Lower Florida Keys National Wildlife Refuges 

for many species that now require attention. The Service needs to prioritize its work allocation to 

carefully choose indicator species representative of all habitat types and to establish monitoring 

protocols that will document and quantify data for these species over the long-term. 

At a minimum, baseline inventory data of flora and fauna are needed at a level to detect changes 

from catastrophic wildfires, hurricanes, and other events in order to determine if a management 

response is necessary. Hurricane effects are generally being assessed for some species of interest, 

such as great white herons, white-crowned pigeons, and sea turtles. Long-term ecological monitoring 

is essential to properly determine population trends, identify management needs, set priorities, and 

evaluate if management actions have the desired results, such as prescribed fire, wetland restoration, 

and exotic species control. 

7. Recovery of imperiled species. 

The Lower Florida Keys Refuges provide habitat for 21 threatened and endangered species, as well 

as a growing number of candidate species being considered annually for listing under the 

Endangered Species Act. The Service has limited financial resources to address all imperiled 

species, therefore establishing baseline inventories and setting priorities is essential. Key deer in 

particular have long been protected as an umbrella species and consequently benefited from habitat 

management programs since the establishment of National Key Deer Refuge. Today, the Key deer 

population is currently at or above the habitat’s carrying capacity in the core areas of Big Pine and No 

Name Keys, increasing the likelihood of density-dependent disease transmission and over-browsing 

of native plants. The Service needs to evaluate the effects of over-browsing on native plant 

communities, reestablish viable populations of Key deer on other islands, and consider other 

strategies to protect both the Key deer and their habitats. More emphasis is also needed for other 

imperiled species, such as the Lower Keys marsh rabbit, Key tree cactus, other rare plants, and 

butterflies. The effects of pesticide applications to control nuisance mosquitoes on non-target 

species, such as butterflies and insect-pollinated plants, needs to be fully evaluated. The refuges 

must balance the need for single species management to enhance recovery of imperiled species with 

an overall landscape approach to maintain and restore habitats that support biological diversity and 

ecological integrity. 

8. Controlling injurious, invasive, and exotic species. 

Exotic, invasive plant species cause habitat loss by disrupting natural communities on the refuge. 

They displace native species and alter ecosystem functions. There are at least 25 terrestrial exotic 

invasive plant species known to occur on the refuges. The most widespread and problematic species 

include Brazilian pepper, Australian pine, Asiatic colubrina, seaside mahoe, lead tree, and non-native 

grasses. The Service has invested substantial time and money in removing exotics. Continual 

monitoring and maintenance treatment is required to keep exotics under control, prevent new 

infestations, and detect new species invasions. The refuges must remain vigilant since adjacent 

private lands and the Overseas Highway and other road rights-of-way serve as seed sources that 

may re-infest refuge lands. The use of non-native, invasive plants in landscaping causes the 

introduction of exotics to refuge lands. Hurricanes can wipe out native plants, allowing for the 

invasion of exotics on disturbed sites. 

The distribution and impact of exotic and feral animals on native plants and wildlife within the refuge 

are poorly known. Feral and free-roaming domestic cats are a predator of the endangered Lower 

Keys marsh rabbit, silver rice rat, and native birds and reptiles. Free-roaming dogs can attack and 

injure or kill Key deer. There are several other exotic species of concern that need to be monitored 
Section A. Draft Comprehensive Conservation Plan 43 

and controlled. Public education, awareness, and cooperation on the topics of exotic species 

management and control are needed. 

REFUGE ADMINISTRATION 

9. Administrative resources. 

Resources are needed to fulfill the refuges’ missions and purposes and to implement the vision for 

these refuges over the next 15 years. Refuge management is increasingly dependent on 

partnerships and the use of volunteer labor to carry out essential refuge functions. Establishing 

partnerships with universities, other government agencies, and non-governmental organizations is 

critical for assessing and monitoring resources and for evaluating wildlife habitat and population 

management techniques over time. More coordinated effort is needed to work with Monroe County, 

the FDEP, and the FKNMS to cooperatively address shared issues, such as marine debris and 

declining water quality in Florida Bay. Maintaining and training a steady, active volunteer corps is 

necessary, but challenging for a small staff without a designated volunteer coordinator position. 

Wilderness Review 

Refuge planning policy requires a wilderness review as part of the comprehensive conservation 

planning process. The Service inventoried other refuge lands within the planning area and found no 

areas that meet the eligibility criteria for a wilderness study area as defined by the Wilderness Act. 

Therefore, the suitability of refuge lands for wilderness designation is not further analyzed in the Draft 

CCP/EA. The results of the wilderness review are included in Appendix H. 
44 Lower Florida Keys National Wildlife Refuges 
Section A. Draft Comprehensive Conservation Plan 45 

IV. Management Direction 

INTRODUCTION 

This section outlines the provisions of the Draft CCP/EA for managing the three refuges for the next 

15 years. According to the Service’s mission for wildlife refuges, this Draft CCP/EA places wildlife 

conservation first as its priority for management of the refuges. This Draft CCP/EA contains the 

goals, objectives, and strategies that will be used to achieve the collective vision of the refuges. 

VISION 

The Lower Florida Keys Refuges are a collection of low-lying, subtropical islands between the Gulf of 

Mexico and the Atlantic Ocean that protect all the vital habitats representative of the Florida Keys 

ecosystem, including globally imperiled pine rockland and tropical hardwood hammock. These 

geologically and climatically distinct islands provide a haven for a diversity of flora and fauna, including 

endemic, and threatened and endangered species. The refuges provide unique opportunities for 

research and wildlife-dependent public uses. We will protect, enhance, and restore the natural diversity 

and integrity of the refuges, in cooperation with our partners, for present and future generations. 

GOALS, OBJECTIVES, AND STRATEGIES 

Refuge Goals 

Goal 1. Wildlife Habitat and Population Management 

Maintain, restore, and enhance a natural diversity and abundance of habitats for native plants 

and animals. 

Goal 2. Threatened, Endangered, Rare, and Imperiled Species 

Protect, restore, and enhance populations of threatened, endangered, rare, and imperiled plants and 

animals and their native habitats. 

Goal 3. Migratory Birds 

Provide, protect, and enhance essential habitat for nesting, resting, and wintering migratory birds. 

Goal 4. Visitor Services 

Promote an understanding and appreciation of natural and cultural resources and provide visitors 

with a quality, safe, and enjoyable experience compatible with wildlife and wildland conservation. 

Goal 5. Cultural Resource Management and Protection 

Protect archaeological, cultural, and historic resources for future generations as examples of human 

interaction with the natural environment. 
46 Lower Florida Keys National Wildlife Refuges 

Goal 6. Wilderness 

Protect and preserve the wilderness character of those refuge lands designated by Congress as part 

of the National Wilderness Preservation System. 

Goal 7. Refuge Administration 

Provide administrative support and sufficient funding to ensure that the goals and objectives for refuge 

habitats, fish and wildlife populations, land conservation, visitor services, and partnerships are achieved. 

SUMMARY 

This Draft CCP/EA assumes a slow-to-moderate growth of refuge resources over the next 15 years. It 

proposes a management direction for the enhancement of wildlife populations by promoting a natural 

diversity and abundance of habitats for native plants and animals, especially Keys’ endemic, trust, and 

keystone imperiled species. Many of the objectives and strategies are designed to maintain and restore 

native communities, particularly the globally imperiled pine rocklands, saltmarsh and freshwater wetlands, 

and the island beach berm communities. Research and monitoring will provide essential information for 

implementing an adaptive management approach to ecosystem conservation. This Draft CCP, when 

final, would provide for obtaining baseline data for ecosystem health. 

Current ongoing and proposed programs and efforts focus on threatened, endangered, rare, and 

imperiled species of plants and animals. The need for more comprehensive inventorying and 

monitoring for baseline data is addressed in this plan, particularly for priority imperiled species and 

their habitats within the refuges. Habitat carrying capacity for Key deer, by island, would be 

determined and the feasibility of population management would be considered within the realm of the 

South Florida Multi-Species Recovery Plan in accordance with the Endangered Species Act. 

Habitat enhancement for critically imperiled species, such as the Lower Keys marsh rabbit and Key 

tree-cactus, would occur to ensure the long-term sustainability of these species. Opportunities for 

land acquisition from willing sellers will focus on protecting more marsh rabbit habitat. Off-refuge 

nursery propagation of the Key tree-cactus would be implemented for later translocation to suitable 

refuge habitats. Research would be initiated to identify causal reasons for the marked, long-term 

decline in the great white heron nesting population. 

Since a primary purpose of the refuges is to provide sanctuary for nesting and migratory birds, 

greater protection from human disturbance would be provided, particularly at colonial nesting bird 

rookeries and at beach habitats in the backcountry islands. Additional limitations to public use may 

be implemented in sensitive beach areas important for shorebirds, terns, sea turtles, and butterflies. 

Strategies are proposed to improve the fire-dependent pine rocklands and to enhance habitat 

features in saltmarsh and freshwater wetlands that benefit priority species in the National Key Deer 

Refuge. Prescribed fire and mechanical or manual vegetation treatments would be used as habitat 

management tools to reduce wildland fuels and benefit priority species and habitats where 

appropriate. Predictive modeling and fire effects monitoring would be used on all prescribed-fire 

treatments in an adaptive management approach to develop site-specific burn prescriptions and to 

determine whether objectives were met. The National Key Deer Refuge habitat and fire management 

plans would be revised and implemented accordingly. 

Exotic plant control would continue as an ongoing operation within the refuges in order to maintain 

habitats and prevent new infestations. Cooperative efforts would be sought to control seed sources 
Section A. Draft Comprehensive Conservation Plan 47 

from private lands and to increase coordinated mapping and monitoring of areas with known 

infestations. Management of non-native and exotic animals would be implemented as directed by the 

South Florida Multi-Species Recovery Plan for the benefit of threatened and endangered species. 

A primary focus of the visitor services program, as proposed, is to enhance environmental education 

and outreach efforts substantially to reach larger numbers of students, educators, and visitors. This 

plan also focuses on increasing public awareness, understanding, and support for the refuges’ 

conservation mission. It places priority on wildlife-dependent uses, such as photography and wildlife 

observation; the details of these allowable uses are specified in appropriate use and compatibility 

determinations (Appendices E and F). A Visitor Services’ step-down plan will specify program details 

consistent with the Service’s visitor service program standards. Non-wildlife dependent forms of 

recreation would be limited or restricted in sensitive areas and awareness efforts would be steppedup to inform visitors about protecting wilderness areas. 

The basic administrative and operational needs of the refuges have been addressed. Essential new 

staffing is proposed through the addition of six permanent staff. Daily operation of the refuge would 

be guided by the CCP through the development and implementation of 11 step-down management 

plans. Wilderness and cultural resource protection objectives and strategies would be incorporated 

within the appropriate step-down management plans. The modest growth in resources would be 

used for wildlife monitoring and habitat enhancement to better serve the refuges’ purposes and the 

CCP’s vision. Existing facilities and vehicles would be maintained with the exception of the new 

visitor services’ facility that is proposed. 

HABITAT MANAGEMENT 

Goal 1. Maintain, restore, and enhance a natural diversity and abundance of habitats for 

native plants and animals. 

Discussion: Ecosystem and landscape habitat management would be emphasized in order to maximize 

the biological diversity, natural integrity, and environmental health of various habitat types in the Lower 

Florida Keys Refuges. The restoration and management of native plant communities would support 

genetically diverse populations of native wildlife. The first objective addresses habitat management 

actions that apply generally to all plant communities, for example, the removal of exotic species. The 

subsequent objectives address actions that are specific or unique to each of the major community types in 

the Lower Florida Keys: pine rockland, tropical hardwood hammock, freshwater marsh, saltmarsh/ 

buttonwood transition, beach, dunes, and mangroves, as well as the marine environment. 

An ecosystem approach may not always be possible or warranted because of the special needs of 

acutely endangered species, such as the Lower Keys marsh rabbit and Key tree-cactus, which may 

require species-specific habitat management actions to ensure their survival. Therefore, where 

necessary, habitat management objectives and strategies may be geared to a single species, as detailed 

in Goal 2, imperiled species. For all habitat management actions, the possible impacts to federally listed 

threatened, endangered, or candidate species would be evaluated before an action is taken. 

With continual threats to native wildlife and their habitats, both within and beyond the refuges’ 

boundaries, strategies for preserving the integrity of the refuges through the acquisition or cooperative 

management of adjacent lands within the refuges’ boundaries are also presented in the final objective. 

Objective 1: Implement habitat management actions that foster biological diversity, natural integrity, 

and environmental health while perpetuating viable populations of rare, threatened, and endangered 

plant and animal species. 
48 Lower Florida Keys National Wildlife Refuges 

Strategies:

y Develop and implement a habitat management step-down plan that will guide all habitat 

management activities on the refuge, including habitat management and restoration and 

exotic and invasive plant control. 

y Update and implement the National Key Deer Refuge’s fire management step-down plan. 

y Obtain baseline information on species composition and vertical structure of plant 

communities within each habitat type to document current conditions. 

y Define as specifically as possible the future desired conditions and management endpoints for 

all major habitat types. 

y Design and implement a habitat monitoring program to document changes in species 

composition and vertical structure of plant communities over time. 

y Document the distribution and location of listed, rare, or keystone species that are most likely 

to be impacted by habitat management actions. 

y Apply adaptive management strategies, including pre- and post-monitoring and evaluation, to 

all habitat management activities. 

y Consider the applicability and feasibility of available research findings and recommendations 

in formulating habitat management actions. 

y Continue participation in the Florida Keys Invasive Exotics Task Force to share treatment 

strategies and to leverage funding for exotics’ removal and native plant restoration. 

y Work with landowners and communities to eradicate exotic plants on adjacent private lands 

and prevent their spread to public lands. 

y Eradicate and control infestations of non-indigenous and invasive plants as categorized by the 

Florida Exotic Pest Plant Council on all refuge-owned and refuge-managed lands. 

y Replant native species, as circumstances warrant and funds allow, after the removal of 

exotics have been performed to restore native plant communities. 

y Maintain current relationships and encourage new partnerships with nationally recognized 

organizations, universities and colleges, and other agencies to provide valuable scientific data 

that will enhance the protection and restoration of native species and habitats in the Florida 

Keys. 

y Develop partnerships to contribute seed sources for potential seed banks to ensure genetic 

diversity of top-priority plant species. 

y Cooperate with partners in developing models to predict the effects of sea level rise and 

coastal storms on refuge habitats, using various scenarios. 

Objective 2: Manage pine rocklands for a future desired condition to foster biological diversity and to 

conserve rare and endangered species. 

Strategies: 

y Refine current prescribed burning practices through adaptive management processes based 

on pre- and post-burn monitoring and evaluation in order to improve subsequent burns. Data 

collection would include species composition and vertical structure, hardwood and slash pine 

density, litter depth, pine diameter-at-breast-height (DBH) and tree height, and post-fire pine 

survival by size classes. 

y Delineate areas that will be actively maintained as pine rocklands as opposed to areas that 

will be allowed to transition into hardwood hammock due to management constraints or 

species-specific population management needs. 
Section A. Draft Comprehensive Conservation Plan 49 

y Identify alternative treatments for maintaining stands of pine rocklands and reducing organic 

fuels where prescribed burning is no longer feasible due to adjacent urban development (highdensity neighborhoods). 

y Update the National Key Deer Refuge fire management plan and conduct prescribed burns, 

accordingly. 

y Reduce the density of palms, where warranted, to maintain a high density and diversity of 

herbaceous ground cover. 

y Assess the merits and feasibility of restoring hurricane-damaged slash pine communities by 

burning, reseeding or replanting, mechanical treatment, and/or other management tools. 

y Continue monitoring changes in distribution and condition of pine rocklands resulting from sea 

level rise and hurricane events. 

y Collect peat and sediment cores to sample for fossilized pollen and charcoal to determine past 

fire frequency and species composition compared to pine rockland habitats present today. 

y Maintain all firebreaks as necessary to ensure safe and efficient prescribed burning projects 

and to protect adjacent, residential areas. 

y Maintain the organic fuels in the wildland-urban interface at a level which precludes the 

danger of a wildfire spreading to nearby residences or threatening native habitats. 

y Continue participation in the Lower Florida Keys Wildfire Hazard Reduction Initiative and the 

Community Wildfire Protection Plan Working Group. 

Objective 3: Manage hardwood hammock communities to protect rare and endangered species. 

Strategies: 

y Protect hammock stands that support populations of Stock Island tree snails and Keys tree 

cactus. 

y Maintain public closure to Watson and Cactus Hammocks (National Key Deer Refuge) and 

allow limited access by researchers or other Service partners by special use permit. 

y Enhance regeneration of plants that have become rare because of deer herbivory. 

y Reintroduce rare and endemic plant species that have been lost due to hurricanes, such as 

inkwood and cupania on Big Pine Key (National Key Deer Refuge). 

y Maintain the policy of prohibiting the spraying of adulticides used for mosquito control over 

tropical hardwood hammocks in Watson and Cactus hammocks and on No Name Key 

(National Key Deer Refuge). 

Objective 4: Protect and where appropriate restore natural freshwater marsh for the benefit of native 

wildlife with an emphasis on priority imperiled species. 

Strategies: 

y Initiate long-term monitoring of all freshwater resources within National Key Deer Refuge to 

gauge salinity and other water chemistry parameters in order to document changes in water 

quality and quantity. 

y Evaluate the impacts of landscape alterations, such as abandoned roads, canals, and 

mosquito ditches, on freshwater wetlands and conduct restoration where feasible. 

y Delineate areas where prescribed burning would be an appropriate tool for maintaining and 

enhancing freshwater marsh vegetation. 

y Evaluate the distribution and movements of the American alligator and its role in maintaining 

open freshwater marshes in National Key Deer Refuge. 
50 Lower Florida Keys National Wildlife Refuges 

Objective 5: Manage saltmarsh/buttonwood communities to benefit native wildlife, with an emphasis 

on recovery actions for the Lower Florida Keys marsh rabbit. 

Strategies: 

y Evaluate the impacts of landscape alterations, such as abandoned roads, canals, and 

mosquito ditches, on saltmarsh habitat and conduct restoration where feasible. 

y Evaluate selectively removing buttonwoods to create and maintain optimal habitat conditions 

for marsh rabbits. 

y Delineate areas where prescribed burning would be an appropriate tool for maintaining and 

enhancing saltmarsh vegetation and reducing woody encroachment. 

 

Objective 6: Maintain mangrove communities for the benefit of nesting and wintering migratory birds 

and forage fish. 

Strategies: 

y Continue cooperative effort with Friends and Volunteers of Refuges (FAVOR), the Florida 

Keys National Marine Sanctuary program, Monroe County, and volunteer groups to remove 

and reduce the source, if possible, of marine debris, such as traps, lines, monofilament, 

plastic products, and abandoned boats. 

y Coordinate with partners on outreach and education efforts to reduce dumping practices and 

to prevent marine debris and oil spills. 

y Encourage research and monitoring regarding the role of mangrove habitats in serving as 

critical nurseries for fish. 

Objective 7: Protect, maintain, and restore beach and dune habitats for the benefits of sea turtles, 

shorebirds, and rare butterflies and their associated plant communities. 

Strategies: 

y Restrict public use to minimize trampling in sensitive dune habitats. 

y Restore damaged dune habitats through closures, plantings, or other protective measures. 

Objective 8: Cooperatively manage marine habitats in coordination with the State of Florida and Florida 

Keys National Marine Sanctuary for the purpose of protecting marine wildlife and wilderness resources. 

Discussion: Key West and Great White Heron NWRs are important components of the nation’s 

network of marine protected areas. The administrative boundaries of both refuges encompass nearly 

395,000 acres of submerged lands and waters owned by the State of Florida. In 1992, the Service 

entered into a Management Agreement with the State of Florida for Submerged Lands within the 

Boundaries of the Key West and Great White Heron National Wildlife Refuges, authorizing certain 

measures to be implemented within the state-owned waters to minimize wildlife disturbance and habitat 

destruction from non-wildlife-dependent recreational activities. This agreement is also known as the 

Backcountry Management Agreement. These measures included the prohibition on the use of personal 

watercraft, airboats, water skiing, and hovercraft and aircraft landing within the majority of Key West 

and Great White Heron NWRs. Several areas were also identified where idle speed, no motor, and no 

access buffer zones were established near critical wildlife habitats. These zones were subsequently 

incorporated as Wildlife Management Areas in the FKNMS’s General Management Plan. 
Section A. Draft Comprehensive Conservation Plan 51 

Strategies: 

y Review and revise the Backcountry Management Plan to address current resource impacts 

and public use issues. 

y Work collaboratively with the State of Florida, FKNMS, Monroe County, and marine 

conservation organizations on shared interests in studying and managing marine habitats 

within the boundaries of the Lower Florida Keys Refuges. 

y Encourage research and monitoring on the status and distribution of important marine habitats 

and unique features (e.g., patch reefs) found in the backcountry in support of the Florida Reef 

Resiliency Program. 

y Continue participation on the FKNMS’s Advisory Council and Water Quality Protection 

Program Steering Committee to provide technical assistance and ensure that the refuges’ 

trust resources and establishment purposes are considered in decision-making. 

y Continue coordination with the FKNMS, FWC, U.S. Coast Guard, U.S. Customs and Border 

Patrol, and the Monroe County Sheriff’s Office on law enforcement patrols and investigations 

in marine waters within the refuges’ administrative boundaries. 

y Develop and distribute information to the public regarding proper etiquette for marine wildlife 

viewing and wilderness recreation. 

y Participate in regional and national planning and conservation initatives for the seamless 

network of marine protected areas. 

 

Objective 9: Continue priority land acquisitions, working with willing sellers, to ensure conservation of 

quality wildlife habitats in the Lower Florida Keys Refuges in perpetuity and work with partners in 

administering jointly managed areas. 

Strategies: 

y Update and implement the land protection step-down plan by continuing to seek willing sellers 

to acquire fee title to lands within the approved acquisition boundary of the three refuges 

whenever funds are appropriated through the Land and Water Conservation Fund. 

y Continue to work with and advise the State of Florida and Monroe County on their 

conservation land acquisition programs, such as the Florida Forever Program, to strategically 

identify high-quality parcels and to prioritize land acquisition efforts to benefit wildlife and to 

foster habitat conservation. 

y For state and local conservation land purchases, accept management authority for parcels 

that contribute to the mission and objectives of National Key Deer Refuge. 

y Continue to work with partners to use appropriate conservation tools, such as conservation 

easements, partnership agreements, and technical assistance to protect, restore, and manage 

the highest priority habitats within the Florida Keys Ecosystem. 

Goal 2. Protect, restore, and enhance populations of threatened, endangered, rare, and 

imperiled plants and animals and their native habitats. 

Discussion: Management would seek to protect and enhance state and federally listed species and 

trust species as a priority. The refuge and surrounding waters host a number of federal and state 

listed threatened and endangered species of plants and animals, candidate species, and rare or 

declining species considered “species of special concern.” Many of these species are declining due 

to alteration and/or degradation of their habitat. By restoring and maintaining natural communities 

and eliminating adverse human impacts, the plight of many of these species will improve dramatically. 
52 Lower Florida Keys National Wildlife Refuges 

Other species may require additional attention and management to increase their population and 

improve their long-term viability. All plans and actions are in accordance with Federal Recovery 

Plans for each species and they are subject to consultation with the Ecological Services’ Field Office 

under Section 7 of the Endangered Species Act to ensure that there are no adverse impacts to 

federally listed species. 

Objective 1: Implement necessary measures to ensure the viability of all imperiled species 

and their habitats. 

Strategies: 

y Develop an inventorying and monitoring step-down plan to address research needs for all 

imperiled species. 

y Conduct rapid ecological assessments and emergency response strategies as needed. 

y Include protection of imperiled species and their habitats in environmental education, marine 

science, and interpretive programs and literature offered by the refuge. 

y Develop and implement an animal control plan to control non-native and predator species. 

y Maintain a sufficient law enforcement presence to prevent illegal take and disturbance of 

imperiled species. 

y Adopt a mosquito management step-down plan according to Service policy guidance that will 

reduce or eliminate impasts to non-target species from mosquito control operations on and 

adjacent to refuge lands. 

y Work with partners to evaluate the potential effects of climate change, especially sea level rise 

and storm events, on imperiled species and their habitats, and develop adaptive management 

strategies as feasible. 

Mammals

Objective 2: Marsh rabbit – Recover and enhance the population viability of the Lower Keys 

marsh rabbit. 

Strategies: 

y Maintain, restore, or enhance Lower Keys marsh rabbit habitat through all appropriate means, 

including prescribed burning and mechanical or manual clearing. 

y Compile acreages, produce a GIS map, and prioritize (by suitability and importance) possible 

areas for restoration or creation of marsh rabbit habitat. Where possible, increase 

connectivity between patches of suitable marsh rabbit patches, including transient-use areas. 

y Continue reintroductions and translocations of marsh rabbits and implement strategies to 

protect source populations. 

y Implement an integrated predator management plan to reduce predation by feral and freeroaming cats on marsh rabbits. 

y Determine the status and distribution of raccoons in relation to marsh rabbit habitat, and 

evaluate the significance of raccoon predation on the productivity and survivorship of rabbits. 

y Work cooperatively with Monroe County, State of Florida, and other stakeholders to address 

feral cat issues, vehicle mortality, and habitat alteration pursuant to the Habitat Conservation 

Plan for Big Pine and No Name Keys and the species recovery plan. 

y Work closely and cooperatively with appropriate personnel at the U.S. Naval Air Station Key 

West at Boca Chica Key to share mutually beneficial findings and promote management 

actions that benefit the Lower Keys marsh rabbit. 
Section A. Draft Comprehensive Conservation Plan 53 

y Initiate restoration of contaminated refuge lands to eliminate known lead deposits in marsh 

rabbit habitat on Boca Chica Key. 

y Continue range-wide population surveys annually, or sooner in the wake of a hurricane that 

causes significant flooding of occupied marsh rabbit habitat. 

y Develop a detailed step-down, pre- and post-emergency response strategy for marsh rabbits 

in the event of a Category 3 or higher hurricane. 

y Consider creation and maintenance of a mainland facility to establish a captive population of 

sufficient size and genetic variability to ensure against extinction. 

Objective 3: Key deer – Maintain the population viability of the Key deer. 

Strategies: 

y Continue a partnership with Southeast Cooperative Wildlife Disease Study (SCWDS) 

personnel to conduct periodic checks for epizootic diseases, particularly Johne’s disease, and 

use refuge personnel to augment the effort by performing necropsies of all deer for which the 

cause of death is unknown. As warranted, send tissue samples or entire carcasses to 

SCWDS for laboratory examination. 

y Annually perform necropsies on at least half of all Key deer mortalities (of any cause) on Big 

Pine and No Name Keys and all deer mortalities on other islands to obtain body fat indices to 

assess the herds’ nutritional plane. 

y Develop a detailed step-down, pre- and post-emergency response strategy for Key deer in the 

event of a Category 3 or higher hurricane. 

y Formulate an in-house hurricane contingency/response plan for Key deer. 

y Continue historical population deer surveys on Big Pine and No Name Keys. 

y Continue to monitor recently established deer populations on other islands. If, over time, insitu population growth creates a greater localized hazard to motorists, then formulate a longterm, deer-road-kill strategy to enhance motorist safety. 

y Assess habitat conditions for Key deer on undeveloped parcels and identify contiguous 

important parcels to acquire that would serve as potential corridors for transient deer among 

islands. 

y Assess the effect of deer herbivory on native habitats. 

y Sample the composition and structure of plant communities to determine a carrying capacity 

for Key deer on all occupied islands. Repeat this work at five-year intervals. 

y Manage the Key deer herd at or below its carrying capacity to reduce degradation of native 

plant communities and to diminish the spread of density-dependent diseases, particularly an 

epizootic outbreak. 

y Assess the efficacy of using immuno-contraceptives to reduce high deer density on No Name 

Key and parts of Big Pine Key, particularly the Port Pine Heights and Koehn subdivisions. 

y Continue, as warranted, translocation efforts of deer from the core areas on Big Pine and No 

Name Keys to Sugarloaf and Cudjoe Keys and other suitable islands as determined by 

ongoing studies. 

y Maintain and restore, as necessary, freshwater holes on islands inhabited by deer. 

y Continue to send Key deer too injured for release to approved captive facilities in mainland 

Florida as currently authorized. 

y Assess the captive group for its potential and suitability as reproductive surrogates for 

replenishing the wild population in the event of a catastrophic hurricane or disease outbreak. 

y Through environmental education and law enforcement, discourage the public’s feeding of 

Key deer. 
54 Lower Florida Keys National Wildlife Refuges 

Objective 4: Silver rice rat – Maintain the population viability of the silver rice rat. 

Discussion: Prior to Hurricane Wilma in 2005, the population of silver rice rats was stable. Its status 

since the hurricane is unknown. 

Strategy: 

y Initiate trapping surveys and habitat evaluation to determine a population status and recovery 

requirements. 

Objective 5: Florida manatee – Assist in the recovery of the Florida manatee according to the 

recovery plan for this species. 

Discussion: While the numbers of manatees in the Lower Florida Keys are small and there is no 

established population, just transient animals, the Service has an obligation to protect this animal and 

its seagrass habitat. 

Strategy: 

y Cooperate on an as-needed basis with the FWC and its contractor, the Dolphin Research 

Center, on any manatee stranding events within the refuges. 

Birds

Objective 6: Piping plover – Protect wintering piping plovers from human disturbance on beaches 

designated as critical habitat. 

Strategies: 

y Increase law enforcement patrols to eliminate chronic human trespass and resulting 

disturbance to piping plovers within areas closed to public access on Boca Grande and 

Woman Keys, islands designated as critical habitat for this species. 

y Expediently replace missing, worn, or marred signs delineating the area closed for piping 

plovers. On Woman Key, replace missing buoys within one week of discovery. 

y Continue to conduct piping plover surveys during the winter in Key West NWR. Institute 

monthly winter piping plover surveys on Ohio Key, with special attention to observations of 

human disturbance. Take warranted proactive measures to curtail distance. 

y Work cooperatively with state and other federal agencies to protect piping plover wintering 

sites from disturbance by humans and pets in areas within the refuges’ administrative 

boundaries, but not under refuge jurisdiction. The unnamed, sand island near Boca Grande 

Key is an example. The storm-created islands favored by this species should have priority. 

Objective 7: Roseate tern – Contribute to the conservation of roseate tern population of Key West NWR. 

Strategies: 

y Assess the potential for attracting a roseate tern nesting colony on the interior of Boca Grande 

Key using tools, such as decoys and nest boxes for chick shelters, at the site one month in 

advance of the nesting season (March). 
Section A. Draft Comprehensive Conservation Plan 55 

y If this area is used for tern nesting, rigorously enforce the existing no-entry zone to curtail 

trespass to prevent disturbance by humans. 

y Work cooperatively with the FWC to protect nesting terns from human disturbance on stateowned sand islands within the refuge’s administrative boundary. 

Objective 8: Red knots – Provide red knots with roosting and feeding areas that are free from 

human disturbance. 

Discussion: Red knots are rarely observed on the refuges, with only an occasional vagrant(s) 

observed in Key West NWR since 1986. 

Strategies: 

y Enforce no-entry zones on the beaches of Woman and Boca Grande Keys.

y As part of the piping plover survey, continue to search for red knots and document any 

instances of human disturbance. Record observations in a GIS database.

Reptiles

Objective 9: Sea Turtles – Maintain a viable nesting population of green and loggerhead sea turtles 

according to the recovery plans for these species. 

 

Strategies: 

y Increase law enforcement patrols to Woman, Boca Grande, Marquesas, and Sawyer Keys to 

protect nesting sea turtles and to eliminate poaching of nests in the Marquesas Keys. 

y Reduce disturbance to nesting turtles by eliminating human trespass at night on nesting 

beaches, particularly in the Marquesas Keys. Work cooperatively with all appropriate 

agencies (e.g., Customs and Border Patrol) to curtail or minimize the night arrival on beaches 

of human refugees and reduce attendant large-scale littering, which can deter or impede 

nesting turtles. 

y Continue sea turtle nesting surveys to the referenced islands to gauge the nesting population 

trend, with special attention on the marked decline of nesting loggerhead turtles. 

y Remove mangroves that, due to an anthropogenic cause, have taken over the west portion of 

the 200-meter sea turtle nesting beach on Sawyer Key, the only site where green turtles nest 

in Great White Heron NWR. 

y Prior to the annual sea turtle nesting season, assess the need to remove debris that entangle 

sea turtles or interfere with their nesting. 

y Continue to cooperate with the Inwater Research Group and support researchers’ field 

surveys of free-ranging sea turtles in Key West NWR. 

y Cooperate on an as-needed basis with the FWC on any sea turtle stranding events within the 

refuges. 

Objective 10: Other reptiles – Determine the local population status of endemic snake and turtle 

species and develop appropriate management strategies to ensure their viability. 

 
56 Lower Florida Keys National Wildlife Refuges 

Invertebrates

Objective 11: Lepidopterans – Maintain or restore refuge populations of lepidopterans of 

conservation concern, particularly Bartram’s hairstreak, Florida leafwing, and Miami blue butterflies. 

Discussion: A number of butterfly species has declined or disappeared from the Florida Keys in recent 

decades, likely due to a number of factors, such as habitat loss and fragmentations, climate change, 

and pesticide use. Fire suppression and inconsistent use of prescribed burning may have reduced the 

abundance of pine rockland butterfly larval-host species, such as pine croton. The Florida Keys 

Mosquito Control District conducts a comprehensive surveillance program to monitor, research, and 

control mosquito populations on National Key Deer Refuge and Great White Heron NWR. The 

integrated pest management program includes the application of broad-spectrum adulticides, such as 

Naled, in concert with the expanded use of the larvicide Bacillus thuringiensis israelensis (BTI). By 

identifying and treating all mosquito-breeding areas with BTI in the backcountry, the Mosquito Control 

District has reduced rates of aerial applications of Naled on the refuges. Broad-spectrum pesticides are 

highly toxic and present a major risk for non-target terrestrial invertebrates. The Service must continue 

to monitor permit compliance and to coordinate with the Mosquito Control District in an effort to further 

reduce or eliminate the use of broad-spectrum aldulticides on refuge lands in accordance with the 

national policy on mosquito management. 

Strategies: 

y Cooperate with the Mosquito Control District in developing improved methods of mosquito 

control that reduces the need for broad-spectrum aldulticides and minimizes impacts to 

natural resources of the area. 

y Perform refuge-wide surveys of butterflies, including Bartram’s hairstreak, Florida leafwing, 

and Miami blue. 

y Restore and enhance foraging and host plant habitat to benefit imperiled Lepidopterans. 

y Prevent the illicit collection of butterflies. 

Objective 12: Stock Island tree snails – Actively manage Stock Island tree snail habitat, including 

nesting, resting, and foraging areas for the long-term survival of the species. 

Strategies: 

y Within 10 years of adoption of the CCP, develop a nesting, nest production, and population 

trends monitoring plan for the Stock Island tree snail. 

y Continue to prohibit the Mosquito Control District’s use of broad-spectrum adulticides on the 

southern half of No Name Key to control mosquitoes. 

y Cooperate with the District in developing improved methods of mosquito control that reduce 

the need for broad-spectrum adulticides and minimizes impacts to natural resources of the 

area. 

y Coordinate with other cooperative agencies, organizations, and groups to develop and 

conduct population surveys of the Stock Island tree snail to determine distribution, abundance, 

and trends, and to determine the effectiveness of management programs and actions. 
Section A. Draft Comprehensive Conservation Plan 57 

Fish

Objective 13: Assess freshwater fish assemblages in the Lower Florida Keys Refuges. 

Discussion: The current species composition and relative abundance of freshwater fishes in refuge 

wetlands is poorly understood. Non-native, invasive freshwater fish may reduce the abundance and 

genetic integrity of native fish species and may require management attention. 

Strategies: 

y Sample freshwater wetlands, including mosquito ditches, to determine the composition and 

relative abundance of native and non-native fish species. Gauge the threat posed by the 

latter to native fish populations and assess available management options. 

y Maintain partnerships with the Keys Environmental Restoration Fund to implement restoration 

and monitoring projects of benefit to native fish species. 

Plants

Objective 14: Key tree cactus – Prevent the extirpation of the Key tree cactus on refuge lands by 

maintaining self-sustaining populations on National Key Deer Refuge and and Great White Heron 

NWR. 

 

Discussion: In 2007, the Service’s Ecological Services’ Office contracted a study of the ecological 

factors associated with the presence of the extant Key tree cactus populations. 

Strategies: 

y Continue partnering with private holders of genetically pure Key tree cactus to grow and 

provide propagules from their stock for reintroduction to restored refuge lands. 

y Create, maintain, and/or restore Key tree cactus habitat and initiate reintroductions as 

appropriate. 

Objective 15: Wedge spurge and Big Pine partridge pea – Maintain current populations. 

Strategies: 

y Evaluate management options for maintaining open pine rockland habitats that support these 

plants. 

y Monitoring and evaluation associated with habitat management actions should include 

information on species distribution (presence/absence before and after burns), quantitative 

assessment of abundance condition, and demographic information on individual plants. 

Objective 16: Garber’s spurge – Determine status and distribution of Garber’s spurge and evaluate 

the use of habitat management options for maintaining open pine rockland and coastal beach berm 

habitats that support this plant. 

Discussion: This species is most abundant in open coastal dune/berm habitats, but has been found 

in relatively small numbers in pine rocklands. In August 2007, the Institute of Regional Conservation 

completed distributional surveys in Key West NWR where this species was found growing on four 

remote islands. 
58 Lower Florida Keys National Wildlife Refuges 

Strategies: 

y Apply the findings of the Institute of Regional Conservation’s 2007 study to refuge 

management. 

y Monitoring and evaluation associated with prescribed burning should include information on 

species distribution (presence/absence before and after burns), quantitative assessment of 

abundance or condition, and demographic information on individual plants. 

GOAL 3. Provide, protect, and enhance essential habitat for nesting, resting, and wintering 

migratory birds. 

Objective 1: Prevent human trespass on backcountry islands to protect sensitive nesting areas, 

particularly colonial bird rookeries, white-crowned pigeon nesting colonies, bald eagle nests, and 

wintering areas for piping plovers and shorebirds. 

Strategies: 

y Increase law enforcement patrols throughout the backcountry islands. 

y Encourage prompt public reporting of instances of human trespass through public service 

announcements in available media outlets. 

Objective 2: Ensure that the needs of nesting, foraging, and roosting birds are considered when 

formulating prescriptions for prescribed fires. 

Strategies: 

y Augment the effort above by initiating point-count sampling of birds during nesting (spring, 

summer) and migratory (fall, winter) periods. 

y Use point-count data to highlight areas of special concern for birds. 

Objective 3: Great white herons – Expand survey efforts to determine the cause of decline in 

nesting population of great white herons and assess potential recovery efforts. 

Discussion: Long-term, annual nesting surveys have shown that the nesting population has declined 

throughout the refuges since 1998, but causal reasons have not yet been identified. 

Strategies: 

y Continue aerial surveys of the great white heron nesting population. Add three additional 

aerial surveys to gauge nesting during non-peak months. 

y Seek funding for a study to determine causal factors for the decline in the nesting population, 

using radio telemetry to focus on productivity, foraging energetics, and adult and juvenile 

dispersal and survival. 

Objective 4: Reddish egret – Continue and expand ongoing monitoring efforts. 

Strategies: 

y Secure funding to institute a multi-year, year-round nesting survey of reddish egrets to assess 

the number and distribution of nesting pairs. 
Section A. Draft Comprehensive Conservation Plan 59 

y Implement protective measures as research findings warrant. Revise, as necessary, the 

Management Agreement with the State of Florida to protect important reddish egret foraging 

and nesting areas from boater disturbance in waters under state jurisdiction. 

Objective 6: Brown pelican – Continue and expand ongoing monitoring efforts of brown pelicans. 

Discussion: Brown pelican nesting has declined markedly in Key West NWR since 1986. In 2007, for 

the first time since 1986, no brown pelican young were produced at the sole active rookery on Cottrell 

Key. The historic (1986-2005) nesting colony in the Marquesas Keys was abandoned in 2005, with 

no sign of nesting activity in 2006 or 2007. 

Strategies: 

y Obtain permission from the State of Florida to create a 100-meter buffer zone in state waters 

surrounding any newly established brown pelican rookeries within the refuges’ boundaries. 

y Continue to monitor brown pelican nesting at Cottrell Key and any newly established rookery 

in the refuges. 

Objective 7: White-crowned pigeon – Continue current monitoring efforts of the nesting population 

of white-crowned pigeons and determine winter migratory destinations of birds that nest on refuge 

lands. Promote range-wide recovery efforts through international partnerships. 

 

Strategies: 

y Monitor the nesting population, with emphasis on islands that harbored high-density colonies 

prior to the 2005 hurricane season. 

y Participate in international cooperative efforts (i.e., with Caribbean countries) to formulate 

range-wide conservation strategies. Provide technical assistance to foster initiation of 

population monitoring and assessment of harvest levels in Caribbean countries. 

y Identify, map, and quantify the size and distribution of white-crowned pigeon foraging sites. 

 

Objective 8: Least tern – Protect roosting and nesting least terns from human disturbance. 

Discussion: A lack of suitable nesting habitat is the limiting factor for least terns in the Lower Keys 

refuges. In 2005, Hurricane Wilma created nesting habitat on Boca Grande Key (Key West NWR) 

and for the first time on record, in 2006, least terns nested on refuge lands. The potential exists to 

create a man-made nesting structure on a former gravel pit on Big Pine Key (National Key Deer 

Refuge). 

Objective 9: Bald eagle – Monitor the nesting population and limit disturbances. 

Strategies: 

y Continue to monitor bald eagle productivity annually throughout the refuge complex.

y Examine islands for bald eagle nesting activity according to the refuges’ bald eagle inventory 

protocol.

y Prevent trespass on islands where eagles nest.
60 Lower Florida Keys National Wildlife Refuges 

Objective 10: Other priority land birds – Establish point counts for nesting mangrove and tropical 

hardwood breeding land birds and transects for surveying migratory land birds at least on National 

Key Deer Refuge. 

 

Strategy: 

y Establish a minimum of 25 point counts in representative mangrove and tropical hardwood 

stands across the refuge to sample breeding bird populations. 

GOAL 4. Promote an understanding and appreciation of natural and cultural resources and 

provide visitors with a quality, safe, and enjoyable experience compatible with wildlife and 

wildland conservation. 

Discussion: The public will be provided with opportunities for quality and compatible wildlifedependent recreational activities. As identified in the Improvement Act of 1997, there are six priority 

wildlife-dependent activities. Of these, five – fishing, wildlife observation, wildlife photography, and 

environmental education and interpretation – are conceptually compatible, appropriate, and occur in 

the Lower Florida Keys Refuges. Hunting is probibited in Monroe County. The Lower Florida Keys 

Refuges will promote outreach opportunities that lead to a greater understanding and enjoyment of 

the refuges’ fish and wildlife and their habitats and cultural resources. Appropriate use and 

compatibility determinations for allowable public uses are addressed in Appendices E and F. 

 

To ensure a quality, compatible wildlife-dependent recreational experience, certain management 

tools and restrictions may be used. For example, some uses may be restricted to certain areas of the 

refuge and other restrictions might be used to prevent conflicts among users. Commercial uses 

occurring on the refuges were previously addressed in a Draft Commercial Use Management Plan of 

1997, which needs to be updated to reflect current uses. 

Objective 1: Develop a visitor services’ step-down plan. 

Objective 2: Conduct an in-depth assessment of current visitor use to document impacts on refuge 

resources and to predict future uses and impacts in order to determine a carrying capacity for the 

refuge. 

Objective 3: Environmental education – Enhance student, teacher, and parent awareness and 

understanding of the refuge’s ecology, native flora and fauna, wildlife and habitat management, and 

environmental history. 

Strategies: 

y Continue environmental education with students as a multi-faceted, curriculum, and FCATbased program for use on and off the refuges. 

y Institute offsite programs at the Big Pine Key Elementary Academy (grades K-4) and onsite 

programs at the National Key Deer Refuge. 

y Continue hosting the Key Kids in Nature program at the Sugarloaf Elementary School 

(National Key Deer Refuge). 

y Seek ways to expand the environmental education program to other schools and to bring 

more students to the refuge as staffing and facilities allow. 
Section A. Draft Comprehensive Conservation Plan 61 

y Establish environmental education at a new proposed visitor center and use designated sites 

at National Key Deer Refuge for environmental education activities. 

y Use volunteers and develop partnerships in order to expand current environmental education 

programs for the Lower Florida Keys Refuges. 

Objective 4: Environmental interpretation and outreach – Increase the public’s awareness and 

understanding of the refuges’ ecology, native flora and fauna, wildlife and habitat management, and 

cultural resources. 

Strategies: 

y Develop additional interpretive information as needed at the refuges’ visitor center and 

continually improve refuge brochures. 

y Annually participate in the Florida Keys Birding and Wildlife Festival. 

y Seek a new location on U.S. Highway 1 on Big Pine Key to relocate the refuges’ visitor center 

operations. 

y Provide multimedia programs about the refuges to various community venues and events, 

such as homeowners associations, civic groups, and environmental organizations. 

y Devise a planning matrix to address how the Service can weave key messages into facility 

development, visitor center renovations, interpretive signs replacement efforts, and its 

environmental education programs. 

y Attend off-refuge events with appropriate themes that are related to refuge issues and provide 

a refuge booth and interpretive information. 

y Create two kiosks describing Key deer biology and behavior and to discourage illegal feeding. 

The displays would be installed at the Watson/Mannillo Nature Trail parking lot and on the 

west side of Key Deer Boulevard at the edge of the field at Port Pine Heights. 

y Develop a tear-sheet map for visitors to better orient them to National Key Deer Refuge lands 

from Ohio to Sugarloaf Keys. The map will also depict the Big Pine area and the Key Deer 

Boulevard corridor, and it will emphasize visitor facilities as well as the side trails used mainly 

by residents. 

y Concurrent with the objectives of Goal 5, the Service will create an interpretive program 

focusing on cultural and historic resources and their protection. 

y The Service will create an interpretive program focusing on wilderness areas and their 

protection in order to implement the objectives of Goal 6. 

Objective 5: Fishing – Promote resource protection by providing information on proper saltwater 

fishing and boating etiquette and enforcement of the State of Florida’s saltwater fishing regulations. 

Objective 6: Wildlife and habitat observations and photography – Continue to provide quality 

opportunities and facilities for wildlife observation and photography in different habitats of the refuges. 

 

Strategies: 

y Install a kiosk with interpretive information at the edge of the field along Key Deer Boulevard 

buffering the community of Port Pine Heights to educate visitors about Key deer and their 

habitat. 

y Install a kiosk with interpretive information at the north end of Key Deer Boulevard to educate 

visitors about the wildlife and habitat found along the trail in the buttonwood and saltmarsh 

habitats. 
62 Lower Florida Keys National Wildlife Refuges 

y Build a wildlife observation platform on National Key Deer Refuge at a site that meets 

approval with the community. 

y Construct a hiking trail linking the Blue Hole to the Mannillo and Watson Trails. 

y Install a wildlife basking area in the Blue Hole to increase wildlife viewing opportunities for 

visitors. 

Objective 7: Other public uses and recreation – Non-wildlife-dependent uses, such as horseback 

riding, beach use, and bicycling, that are compatible with the refuges’ missions and purposes, will be 

allowed on the refuges, provided that they do not negatively impact wildlife and habitats. See 

Appendices E and F for a list and discussion of appropriate and compatible public uses allowed on 

the refuges. Certain stipulations for the uses may be necessary to in order to allow them. 

 

Objective 8: Volunteers – Increase and promote the use of volunteers for visitor services’ programs. 

 

Strategies: 

y Seek a volunteer to assist in coordinating the Service’s volunteer program. 

y Continue to recruit, train, and motivate volunteers to staff the visitor center, the front desk, and 

the outreach booth at shows, events, and fairs. 

y Improve recruitment and orientation procedures for orienting the volunteers. 

y Develop a table-top display with information on volunteering that can be taken to various 

outreach events for recruitment purposes. 

 

Objective 9: Partnerships – Continue partnerships with appropriate organizations that promote the 

key interpretive messages of the refuges. 

Strategies: 

y Continue supporting and encouraging FAVOR, a refuge friends group that provides financial 

and in-kind support of refuge program. 

y Partner with the Chamber of Commerce regarding opportunities to promote the refuges’ 

mission through ecotourism. 

y Continue to provide refuge staff support to the Monroe County Environmental Education 

Advisory Council, Seagrass Outreach Partnership, Florida Keys Birding and Wildlife Festival, 

Florida Keys Scenic Highway Plan, and Florida Keys Eco-Discovery Center (interagency 

visitor center). 

GOAL 5. Protect archaeological, cultural, and historic resources for future generations as 

examples of human interaction with the natural environment. 

Discussion: With the enactment of the Antiquities Act of 1906, the Federal Government recognized 

the importance of cultural resources and sought to protect archaeological sites and historic structures 

on those lands owned, managed, or controlled by the United States. The body of historic 

preservation laws has grown dramatically since 1906. Several themes recur in the laws and the 

promulgating regulations. They include: (1) each agency is to systematically inventory the historic 

properties on its holdings and to scientifically assess each property’s eligibility for the National 

Register of Historic Places; (2) federal agencies are to consider the effects of management actions on 

cultural resources and seek to avoid or mitigate adverse effects; (3) cultural resources are to be 

protected from looting and vandalism via informed management, law enforcement efforts, and public 
Section A. Draft Comprehensive Conservation Plan 63 

education; and (4) groups, such as Native American tribes and African American communities, should 

be consulted to address how a project or management activity may impact specific archaeological 

sites and landscapes deemed important to those groups. The objectives and strategies below outline 

the Service’s plan to achieve its mandated historic preservation responsibilities. 

Objective 1: The Service will integrate cultural resource preservation concepts and practices into 

refuge programs, operations, and management plans to protect cultural resources in perpetuity. 

Strategies: 

y The Regional Archaeologist will complete a cultural resources overview for all refuges. 

y Beginning immediately, prior to any non-emergency, ground-disturbing activity, the Service 

will complete the Request for Cultural Review Compliance form and forward it to the Regional 

Archaeologist for review and subsequent action pursuant to Section 106 of the National 

Historic Preservation Act. 

y A section addressing cultural resource management will be included in all step-down 

management plans. 

Objective 2: Protect the refuges’ cultural resources and diminish site destruction due to looting and 

vandalism. 

Strategies: 

y Beginning immediately, the Service will routinely submit Listing of Outlaw Treachery (LOOT) 

forms to the Regional Archaeologist. Past archaeological violations, including un-permitted 

collecting cited in 50 CFR, will be entered into the LOOT system. 

y Establish and implement a regular system of patrolling and monitoring known cultural sites. 

y Law enforcement officers will participate in cultural resource protection training at annual law 

enforcement refresher courses. 

Objective 3: Maintain museum property. 

Strategies: 

y The Service will scan historic photographs, maps, and documents and archive originals at the 

Service’s National Conservation Training Center. 

y The Regional Archaeologist will arrange for the permanent curation of historic and/or 

archaeological collections and associated documentation derived from cultural resources 

investigations on the refuges. 

y Identify potential partnerships on archaeological and historic investigations and museum 

property curation, and promote interdisciplinary research. 

y Coordinate with the Seminole Tribe of Florida, the Seminole Nation of Oklahoma, the 

Muscogee (Creek) Nation of Oklahoma, the Poarch Band of Creek Indians of Alabama, and 

the Miccosukee Indian Tribe for information on and input into the management of important 

cultural and sacred sites located within the refuges on an as-needed basis. 

Objective 4: Enhance public understanding and appreciation of the refuges’ ecology in relation to 

the historic human influence on the region’s ecosystems. 
64 Lower Florida Keys National Wildlife Refuges 

Strategies: 

y Develop an interpretive display and related brochures and educational materials that convey 

the refuges’ cultural history to the public. 

y Incorporate information that promotes responsible use of culturally important areas into the 

Service’s education and outreach programs. 

GOAL 6. Protect and preserve the wilderness character of those refuge lands designated by 

Congress as part of the National Wilderness Preservation System. 

Discussion: Refuge planning policy requires a Wilderness Review concurrent with the 

comprehensive conservation planning process. The Service inventoried other refuge lands within the 

planning area and found no additional areas that met the eligibility criteria for a Wilderness Study 

Area as defined by the Wilderness Act. Therefore, the suitability of additional refuge lands for 

designation as wilderness areas is not analyzed further in this plan. The results of the wilderness 

review are included in Appendix H. 

Objective 1: Minimize non wildlife-dependent human activities on wilderness areas that are open to 

public use in the Lower Florida Keys Refuges. 

Strategies: 

y Enforce existing regulations regarding non-wildlife dependent uses on refuge wilderness 

areas by providing a consistent law enforcement presence at Boca Grande Key, Woman Key, 

and the Marquesas Kkeys, as well as islands in Great White Heron NWR (e.g., East Harbor 

Key) to minimize disturbance to resources and to maintain the wilderness character of these 

islands. 

y Review and update, as needed, the 1992 Management Agreement for Submerged Lands 

within the Boundaries of Key West and Great White Heron NWRs for collaboration with the 

State and the FKNMS to determine if existing protective measures are adequate to protect 

wildlife resources and wilderness values. 

y Institute weekend/holiday closure of Boca Grande Key to reduce overcrowding, minimize 

impacts on beach dune habitats and enhance wilderness experience. Consider full closure of 

this Key if short-term closures are not enough to minimize impacts to an acceptable level. 

y At other periods, at this and other beaches in Key West NWR, carrying capacities will be 

established to curtail overcrowding and loss of wilderness character. If these measures prove 

ineffective or unfeasible to enforce, more stringent measures (seasonal or year-round closure) 

would be considered on a beach-by-beach basis as a necessary measure to protect the 

sensitive dune areas, reduce disturbance to wildlife, and preserve wilderness character. 

Objective 2: Convey an understanding and appreciation of the value and character of the refuges’ 

designated wilderness areas. 

Strategies: 

y Develop an interpretive display and related brochures and educational materials that convey 

their wilderness areas and allowable public uses for visitors. 

y Incorporate information that promotes responsible use and management of wilderness areas 

into all step-down management plans. 
Section A. Draft Comprehensive Conservation Plan 65 

GOAL 7. Provide administrative resources to ensure that the goals and objectives for 

refuge habitats, fish and wildlife populations, land conservation, visitor services, and 

partnerships are achieved. 

Discussion: The administrative functions associated with the refuges include a wide array of activities that 

are critical to the mission of the National Wildlife Refuge System and the purposes of the refuges. These 

functions include staffing, training, budgeting, planning, and partnering, as well as law enforcement, 

community relations, facilities construction, and maintenance. Protecting the natural resources of the 

refuges and ensuring the safety of visitors are fundamental responsibilities of the Service. 

The refuges are currently managed by 12 permanent and 1 temporary position based at the complex 

headquarters on National Key Deer Refuge. The permanent personnel include a project leader, a 

deputy project leader, 2 law enforcement officers, an administrative support assistant, 2 biologists, a 

public use specialist, a prescribed fire specialist, a laborer, and 2 maintenance workers. The 

temporary position is a facility operations specialist overseeing several construction projects that will 

be completed by 2010. In Fiscal Year 2007, the Lower Florida Keys Refuges had a budget of 

$1,291,500 for payroll, utilities, operational and maintenance needs, and special funding to address 

the maintenance backlog. 

Objective 1: Secure resources necessary to complete projects and tasks as outlined in the Refuge 

Annual Performance Plan in support of the Service’s Strategic Plan and the Lower Florida Keys 

Refuges CCP. 

Strategies: 

y Identify and secure funding through grants and other cost-sharing sources to supplement 

annual operating funds in support of research, monitoring, and visitor services’ projects that 

enhance the conservation of ecosystem functions of native species and their habitats. 

y Enhance and maintain an active, dynamic volunteer and student intern program to assist in all 

refuge operations, including public outreach, environmental education, wildlife interpretation, 

biological monitoring, habitat restoration, and facilities maintenance. 

y Construct, rehabilitate, and/or maintain an appropriate suite of refuge complex facilities to 

support its programs and to ensure safe and efficient operations. Facilities include the 

administrative headquarters office and marina, maintenance shop, visitor center, itinerant 

bunkhouse, and employee quarters, as well as signs, gates, kiosks, trails, and boardwalks. 

y Procure and maintain equipment and vehicles needed to perform refuge operations and to 

ensure adequate maintenance of grounds, buildings, facilities, and vehicles. 

y To fulfill the workload need identified in this Draft CCP/EA, increase permanent staff by a total 

of 6 new positions, and use temporary (seasonal) employees as operating funds allow. 

Objective 2: Maintain a safe environment for staff and visitors. 

Strategies: 

y Regularly review and revise the safety, hurricane, and emergency contingency plans as 

necessary. 

y Ensure that Service personnel meet all annual, mandatory training requirements. 

y Provide continuing education, training, and professional development opportunities to all staff 

to ensure a highly competent and motivated team and to ensure safe work conditions. 
66 Lower Florida Keys National Wildlife Refuges 

y Procure and maintain safe and efficient equipment and vehicles to perform operations and 

maintenance. 

Objective 3: Maintain a law enforcement program that will ensure the safety, security, and/or 

protection of employees, visitors, real property, equipment, and the natural and cultural resources of 

the refuge. 

Strategies: 

y Review and update the law enforcement step-down plan as needed. 

y Continue to enhance law enforcement capabilities through collaboration, partnerships, and 

cooperative agreements with local, state, and federal enforcement agencies in the Florida 

Keys, including, but not limited to, the FWC, the FKNMS, the National Park Service, and the 

Monroe County Sheriff’s Office. 

y For matters of homeland security and illegal migrant landings, continue to provide support to 

the U.S. Customs and Border Patrol and the U.S. Coast Guard. 

y Continue to provide emergency response for natural disasters (e.g. hurricane details) or other 

response and recovery activities (e.g., oil spills), and search and rescue efforts. 

y Work cooperatively with the Service’s Office of Law Enforcement to protect against illegal 

trade, unlawful commercial exploitation, habitat destruction, and environmental hazards. 

Objective 4: Continue developing internal Service and external partnerships to share equipment, 

manpower, and expertise in all aspects of refuge administration. 

Strategies: 

y Maintain current relationships and encourage new partnerships with conservation 

organizations, academic institutions, and other agencies to provide scientific data that will 

enhance the management, protection, and restoration of native species and habitats in the 

Florida Keys. See Appendix L for a listing of current and potential partners. 

y Continue participation in the Service’s South Florida Ecosystem Team, which is a partnership 

of the following Service offices: Refuges, Ecological Services, Migratory Birds, Fisheries, and 

Law Enforcement. 

y Use cooperative agreements and memorandums of understanding to facilitate collaborative 

research and management activities to meet refuge objectives. 

y Expand cooperative efforts with state and local agencies, civic groups, homeowners 

associations, and other stakeholders to appropriately manage the complex of public lands that 

are intermixed with private lands in order to effectively eliminate prohibited uses of public 

parcels. The phohibited uses include trash disposal, camping, arson fies, equipment storage, 

and habitat damage. 
Section A. Draft Comprehensive Conservation Plan 67 

V. Plan Implementation 

INTRODUCTION 

The future of this and most national wildlife refuges is dependent upon a public constituency that is 

knowledgeable of refuge resources and mandates, as well as environmental issues, and that is willing 

to support the Service’s work. To build and maintain this needed constituency, this Draft CCP/EA not 

only provides actions to protect, restore, and conserve wildlife habitat, but it also expands wildlifedependent recreational opportunities. Promoting the refuge as an asset to local communities, Monroe 

County, and the State of Florida will enhance the refuge’s image and help to expand local support. To 

achieve the proposed management plan for these refuges, this section identifies 19 projects; proposes 

increased staffing, equipment, and funding needs; lists partnership opportunities; describes step-down 

management plans; and proposes biological monitoring and evaluation. 

PROPOSED PROJECTS 

Listed below are the proposed project summaries and their associated costs for wildlife habitat and 

population management, resource management, visitor services, and refuge administration over the 

next 15 years. This proposed project list reflects the priority needs identified by the public, planning 

team, and refuge staff based upon available information. These projects were generated for the 

purpose of achieving the refuges’ objectives and strategies as identified in Chapter IV, the proposed 

management direction. The primary linkages of these projects to the goals, objectives, and strategies 

identified in Chapter IV are noted in parenthesis at the end of each summary. 

The cost of each project is shown in Table 5. The approximate annual cost of each proposed staff 

position is shown in Table 6. Cost estimates were made when this Draft CCP/EA was first drafted 

and reflect 2008 dollars. Costs will vary during the 15-year implementation period of the CCP and 

inflation will need to be taken into consideration. 

FISH AND WILDLIFE POPULATION MANAGEMENT 

1. Fire Management Program – Biological Evaluations 

 Fire is a natural part of the Lower Keys ecosystem and is necessary to maintain the globally 

imperiled pine rockland ecosystem. The role and application of fire in maintaining hardwood 

hammocks, freshwater marshes, and salt marshes in the Lower Keys are not as well understood, 

but are considered to be important components of the disturbance regime. Baseline inventorying 

and monitoring data must be obtained for all fire-maintained habitat types. The project cost is 

estimated at $50,000. Research on the response of listed, rare, or keystone species will 

contribute to an adaptive management approach as implemented through National Key Deer 

Refuge’s fire management plan. Fire response studies for taxonomic groups likely impacted by 

fire management actions will be supported by a forestry technician (GS-7/9) ($50,690), which 

would be part of the position’s duties. The annual operational cost for fire-related research and 

monitoring activities is $10,000. The first-year cost is estimated at $110,690, and the estimated 

annual recurring cost is $60,690. (Linkages: Goal 1, Objectives 1, 2, 4, and 5; Goal 2, 

Objectives 1, 2, 11, 15, and 16; and Goal 7, Objective 1.) 
68 Lower Florida Keys National Wildlife Refuges 

2. Fire Management Program – Operations 

Prescribed fire implementation on National Key Deer Refuge is currently conducted during the 

summer wet months, which is the wildfire season elsewhere. Reliance upon burn crews from 

outside the Lower Florida Keys Refuges is difficult as full-time fire crews are not often available. 

Implementation of a prescribed fire program on National Key Deer Refuge will require additional, 

in-house operational support, including fire training and personal protective equipment for refuge 

biologists, biological technicians, law enforcement officers, maintenance personnel, and 

management staff. This project will also enhance partnerships with the Florida Division of 

Forestry, Monroe County Fire Department, and the Nature Conservancy to enhance local 

capabilities for conducting safe prescribed burns and for responding to wildlfires. The estimated 

first-year cost for this project is $50,000, with a recurring cost of $5,000 per year. (Linkages: Goal 

1, Objectives 1, 2, 4 and 5; Goal 2, Objectives 1, 2, 11, 15, and 16; and Goal 7, Objective 1.) 

3. Eradicate or Control Invasive and Exotic Plants and Animals 

In order to eliminate or control populations of exotic or invasive plant and animal species, more 

emphasis must be placed on detecting and monitoring the presence, spread, and damage caused 

by these species, particularly upon listed native plant and wildlife species and their habitats. This 

project combines a biological technician (GS-5/7/9, RONS 97004: $39,405 first-year and annual 

recurring costs) with funding for invasive exotic plant control and native plant restoration (RONS 

97004: $364,000 first-year cost/$95,000 recurring cost). The first-year cost of this project is 

$403,405, with an annual recurring cost of $134,405 per year. (Linkages: Goal 1, Objective 1; 

Goal 7, Objective 1.) 

4. Hydrologic Monitoring and Restoration 

Development, including dredge and fill activities and road building, has altered the natural 

hydrology of many islands in the National Key Deer Refuge. The project will develop predictive 

models and collect long-term data on the level and extent of tidal habitats and freshwater lenses 

to detect changes froom sea level rise due to climate change. The results from hydrologic studies 

will be used to design and implement projects to restore hydrologic conditions to maintain 

freshwater wetlands, improve water flows abd tidal connections, and reduce impacts associated 

with hurricane storm surges. The first-year cost of this project is $199,405. This project will be 

supported by a biological technician (RONS 00006, GS-5/7/9 - $39,405) and an annual recurring 

operation budget of $10,000. The annual cost is $49,405. (Linkages: Goal 1, Objectives 1, 4 and 

5; Goal 2, Objectives 1-4, 15 and 16.) 

5. Science-based Inventorying and monitoring of Plant and Animal Populations

Science-based inventorying and monitoring of plant and animal populations are critical to 

ensuring the biological integrity of the refuge. The information collected through a systematic 

inventorying and monitoring program forms the basis for developing, implementing, revising, and 

evaluating management actions; enables informed decisions; and guides all refuge management 

activities. To date, comprehensive inventories have not been completed for any of the Lower 

Keys Refuges and only a few of the refuges’ important trust species are adequately monitored. 

This project will address this shortfall by expanding the inventorying and monitoring of top-priority 

species through the addition of biological staffing and the funding of several important surveys. 

As a result, the refuges will improve management and provide valuable long-term contributions to 

national and regional objectives for endangered and imperiled species, shorebirds, wading birds, 

and neotropical migratory birds. 
Section A. Draft Comprehensive Conservation Plan 69 

The project consists of employing a supervisory biologist (RONS 00007, GS-11/12 - $75,020 

first-year and $75,020 annual recurring costs) and sharing the biological technician GS-5/7/9 

(RONS 00006) position. Operational expenses (e.g., field supplies and data analysis software) are 

estimated at an annual cost of $10,000. Contractual studies for priority or imperiled species will be 

used to supplement refuge efforts at an annual cost of $50,000. The yearly estimated cost is 

$135,020. (Linkages: Goal 1, Objectives 1-7; Goal 2, Objectives 1-4, 6-16; Goal 7, Objective 1.) 

6. Ensure the Population Viability of the Lower Keys Marsh Rabbit 

This project will aim to recover the population of the Lower Keys marsh rabbit to substainable 

levels. Now one of the rarest mammals in the United States, this species exists in scattered, 

disjunct populations. Numbers have plummeted drastically over the past several decades and its 

population viability rests on a concerted effort to manage currently occupied sites and enhance 

formerly occupied sites using all appropriate measures, and, to control its primary predators, feral 

and free-roaming cats. Ongoing translocation of Lower Keys marsh rabbits to backcountry 

islands devoid of feral cats must be bolstered. Following habitat restoration, re-introduction of 

rabbits to formerly occupied habitats is needed to enhance connectivity and genetic flow among 

the scattered populations. 

This project includes sharing the biological technician position (RONS 00006, GS-5/7/9) to 

monitor the population, plan and implement habitat restoration efforts, and evaluate the 

effectiveness of management measures. In-situ breeding to provide a translocation source 

population will be evaluated as a recovery strategy. Predation by feral and free-roaming cats has 

been identified in the recovery plan and published literature as a probable causal factor for 

extinction of the marsh rabbit. Therefore, $50,000 per year will be allocated annually for predator 

trapping. Habitat enhancement is needed in both formerly and currently occupied sites to 

promote connectivity, dispersal, and genetic exchange. To this end, $100,000 will be allocated 

annually. Further actions include a prioritization, by suitability and importance, of possible areas 

for restoration or creation of patches of suitable marsh rabbit habitat, including transient use 

areas. (Linkages: Goal 1, Objectives 1, 4 and 5; Goal 2, Objective 2.) The first-year costs for this 

project are $150,000, with annual recurring costs. 

7. Maintain the Population Viability of the Key Deer 

This project includes several field components to evaluate and implement complementary 

strategies for maintaining the population viability of Key deer and conserving the natural integrity 

of native habitats throughout their suitable range in the Lower Florida Keys Refuges. 

Translocated deer on Cudjoe and Sugarloaf Keys would be monitored intensively for a 3-year 

period to guage herd growth and demographics, evaluate habitat condition and carrying capacity, 

and determine the need for continued translocation efforts to achieve recovery objectives. The 

costs total $150,000 ($50,000 per annum). In addition, a 3-year project will be conducted to 

evaluate the efficacy of using a wildlife immuno-contraceptive vaccine to manage deer 

overabundance on No Name Key, as well as selected areas of Big Pine Key, in order to avoid 

catashrophic disease outbreaks and reduce excessive herbivory on the native plant community. 

Initial costs for this 3-year project will be $250,000 with a recurring cost of $30,000 per annum if 

the pilot project warrants full implementation. Futher, the Southeast Cooperative Wildlife Disease 

Study Group will be contracted to perform 5 herd health checks at 3-year intervals to monitor for 

the presense of epizootic diseases, particularly Joyne’s disease, for a total cost of $50,000. This 

project includes one-time costs of $450,000 for the initial 3-year project with annual recurring 

costs of $30,000. (Linkages: Goal 1, Objectives 1 -3; Goal 2, Objective 3.) 
70 Lower Florida Keys National Wildlife Refuges 

8. Silver Rice Rat 

Prior to Hurricane Wilma in 2005, the population of silver rice rats was stable, but its status since 

the hurricane is unknown. This project provides $100,000 to perform trapping surveys spread 

over two years to determine population trends. Once the initial 2-year survey is complete, an 

additional $200,000 will be allocated for two additional 2-year replicates of these surveys 

($100,000 each), conducted at successive 5-year intervals or within one year of the passage of a 

major hurricane (Category 2 or higher). The total cost of this project is $300,000. (Linkages: 

Goal 1, Objectives 1, 5, 6, and 9; Goal 2, Objective 4.) 

9. Lepidopterans 

Both the Bartram’s hairstreak and Florida leafwing butterflies are restricted to slash pine 

rocklands in National Key Deer Refuge that contain pine croton, the only known host plant for 

both species. The Miami blue is present on six islands in Key West NWR, where it occupies 

narrow beach ridge hammocks. Both the range and populations of these three species are but a 

fraction of their historical distribution and numbers. Further, the numbers and distribution of other 

tropical lepidopteran species are poorly understood, but thought to be declining due to various 

factors, including habitat loss, hurricanes, collecting, and pesticides. 

The project includes $150,000 to assess presence and numbers of rare butterflies throughout 

refuge lands and to formulate management measures to enhance their numbers. During the 15-

year span of the CCP, three 1-year surveys ($50,000 each) will be conducted at either 5-year 

intervals or within a year of the passage of a major hurricane (Category 2 or higher). (Linkages: 

RONS 00011, Goal 1, Objectives 1-3, 7 and 9; Goal 2, Objective 11). 

10. Sea Turtles 

Refuge islands provide some of the last remaining nesting habitat for green, loggerhead, and 

hawksbill sea turtles in the Florida Keys. Loggerhead turtle nesting has declined dramatically over 

the past 10 years, and beach profiles were greatly altered by Hurricane Wilma in 2005. Saltwater 

inundation of nests on the narrow beaches from sea level rise and greater storm intensity is a growing 

concern in light of climate change. Poaching, while infrequent, occurs in the Key West NWR. Annual 

monitoring of nesting sea turtles in Key Wesr NWR has contributed to understanding regional trends 

in turtle numbers and population health. This project allocates $10,000 per year for surveys of 

nesting turtles and assessment of factors associated with nesting and productivity. The total 

project cost is $150,000. (Linkages: RONS 00006, 00007, and 00009; Goal 1, Objectives 1, 7, 

and 8; Goal 2, Objective 9.) 

11. Garber’s Spurge, Wedge Spurge, and Big Pine Partridge Pea 

Refuge-wide surveys are needed to assess the status of these rare plants. Ecological factors 

associated with the presence of these plants need to be assessed to implement management 

measures that will increase their populations. The use of prescribed fire or other habitat 

management options for maintaining open pine rockland habitats that support these plants 

must be evaluated. 

Funding ($40,000 for one year) will be provided to assess distribution and habitat characteristics 

associated with the presence and habitat characteristics of these plants. At 5-year intervals or 

within one year of the passage of a major hurricane (Category 2 or higher), funding would be 

provided for replication of the initial survey ($40,000 for each of two, additional, one-time 

contracts). (Linkages: Goal 1, Objectives 1, 2, and 7; Goal 2, Objectives 15-16.) 
Section A. Draft Comprehensive Conservation Plan 71 

12. Great White Heron 

Long-term aerial surveys (1986-2006) of nesting great white herons show the population declined 

precipitously after 1998. Compared with a peak of 338 nests in 1998, only 82 (24 percent) and 

103 (31 percent) were found in 2005 and 2006, respectively. Survey efforts need to be expanded 

to include the months of September, October, and March. A study, using radio-tagged juvenile 

and adult herons, was implemented in 2007 to determine the causal factors for the decline. An 

allocation of $35,000 per annum is needed to survey the nesting population with a helicopter. 

(Linkages: Goal 1, Objectives 1, 3, 6, and 8; Goal 3, Objectives 1-3). 

13. White-crowned Pigeon 

Most white-crowned pigeons that nest in the United States are migratory and spend winters on 

Caribbean islands. The United States’ nesting population is confined to the Florida Keys. 

Nesting occurs on uninhabited, mangrove islands in the Florida Keys backcountry, but to obtain 

forage, these fruit-eating birds must fly to tropical hardwood hammocks on mainline keys (linked 

by U.S. Highway 1). Long-term refuge studies (2000-2006) of nesting white-crowned pigeons 

revealed a peak of 4,830 nests in 2004, with a substantial decline after Hurricanes Dennis and 

Wilma (July and October 2005, respectively). Both storms severely damaged nesting and/or 

foraging areas. Recovery to pre-storm numbers has not yet occurred: only 2,866 nests (decline 

of 41 percent compared to 2004) were recorded during the 2006 nesting season. An allocation of 

$10,500 per year is needed to continue population monitoring. The total cost of this project is 

$157,500. (Linkages: Goal 1, Objectives 1, 3, 6, and 9; Goal 3, Objectives 1, 2, and 7.) 

REFUGE ADMINISTRATION AND RESOURCE PROTECTION 

14. Land Protection 

The National Key Deer Refuge is composed of hundreds of parcels of land that have been 

acquired in fee simple or leased through management agreements with the State of Florida or 

Monroe County. These properties need to be posted to facilitate the public’s understanding of the 

lands that make up the refuge. Gates and barriers are needed to control problems from 

prohibited activities, such as vehicular access, trash dumping, personal property storage, 

camping, and destruction of habitat. This project will fund posting and gate-locking of various lots 

and supports annual maintenance and enforcement activities (RONS 00010; $70,000 first-year 

cost, with recurring costs of $10,000). The total cost of the project is $210,000. (Linkages: Goal 

1, Objective 9; Goal 7, Objective 4.) 

This project also includes hiring a refuge operations specialist (RONS 00008, GS-9/11) to assume 

responsibility for property and facilities management, recurring reporting and administrative 

requirements, and coordinating with county government and homeowners associations to address 

trash dumping, trespass, encroachment, habitat damage, and exotic species issues on public lots 

intermixed with private lands in the refuge. This position will free up time for the project and 

deputy project leaders to address more complex wildlife and habitat management issues, to foster 

partnerships, and to enhance community relations. The first-year cost is $62,040, with an annual 

recurring cost of $62,040. (Linkages: Goal 7, Objective 4.) 

The total first-year cost is 15 is $132,040, with an annual recurring cost of $72,040. 

15. Land Acquisition 

Many land in-holdings of vacant parcels with high quality wildlife habitat remain within the 

acquisition boundaries for National Key Deer Refuge and Great White Heron NWR. These 

refuges consistently rank high in the Service’s Land Acquisition Priority System and thus qualify 

for Land and Water Conservation funds. The Service would like to acquire all available in-
72 Lower Florida Keys National Wildlife Refuges 

holdings from willing sellers to enhance its ability to manage large tracts of habitat and reduce 

habitat fragmentation for the recovery of threatened and endangered species. Land values 

change rapidly in the Florida Keys, thus the estimated costs will vary. Given consistently rising 

property values, the faster the vacant properties can be acquired from willing sellers, the lower the 

costs will be. The current estimated cost is $2 million annually. (Linkage: Goal 1, Objective 9.) 

VISITOR SERVICES, WILDLIFE-DEPENDENT RECREATION, AND ENVIRONMENTAL 

EDUCATION 

16. Visitor Use Survey 

Before implementing additions to the current visitor services’ programs and facilities, an in-depth 

assessment of current visitor use and its impacts is desired, particularly for some of the remote 

islands. This study would document the current impacts of recreational and public uses on 

refuge resources and predict future use impacts in order to determine carrying capacities for 

various sites on the refuges. This study will guide enhancements and improvements to the 

visitor services program and facilities. The estimated one-time cost is $25,000. (Linkage: Goal 

4, Objectives 1-2.) 

17. Visitor Center and Environmental Education 

The National Key Deer Refuge’s visitor center presently occupies leased, commercial space on a 

roadside on Big Pine Key. Plans are underway to acquire existing real property along U.S. 

Highway 1 on Big Pine Key in order to redevelop and operate a federally owned visitor center. 

Most refuge visitors are unable to find the current visitor center and proceed directly to the Blue 

Hole, consequently, this location will provide better access to visitors and is expected to capture 

about five times the current annual rate of visitation—from 10,000 to 50,000 persons. The center 

will contain a meet-and-greet desk and state-of-the-art interactive exhibits. The center will also 

be the hosting site for increased environmental education efforts and community events. 

Outdoor education would be planned on the site in conjunction with the visitor center site and 

elsewhere on the refuge. The project includes purchasing environmental education supplies and 

equipment to provide outdoor education programs to students. The first-year cost for this project 

is $2 million, with an annual recurring cost of $50,000. (Linkages: Goal 4, Objectives 1, 8 and 9.) 

The project also includes the hiring of a supervisory park ranger (RONS 99010, GS-11) to 

oversee a more comprehensive visitor services’ and education program to accommodate 

increasing demands and changing demographics and public attitudes. The position will 

coordinate all aspects of the visitor services’ program, including environmental education and 

outreach, recreation and visitor facilities, partnerships, visitor center operations, media, and the 

volunteer program. The supervisory refuge ranger position will have a first-year cost of $75,020 

and an annual recurring cost of $75,020 each year. (Linkages: Goal 4, Objectives 1-9.) 

 The total first-year cost for this project will be $2,075,020, with annual recurring costs of $125,020. 

18. Outdoor Facility Improvements 

Several projects are proposed for National Key Deer Refuge as follows: 

y The construction of a new hiking trail linking the Blue Hole area to the Watson and 

Mannillo Nature Trails to provide refuge hikers a more natural area than the bicycle path 

on Key Deer Boulevard. Construction and maintenance is planned by use of volunteers. 

y Install an interpretive trail sign with a brochure box and maps at one of the refuge fire 

roads on No Name Key. 

y Construct a wildlife-observation platform with interpretive signs on the refuge (site to be 

determined) to provide an elevated view of the refuge’s habitats and nearby waters. 
Section A. Draft Comprehensive Conservation Plan 73 

y Construct wildlife photography blind and a wildlife resting perch for birds at the Blue Hole. 

y Install three new interpretive and regulatory signs regarding fishing on the refuge with one 

spare, one at Ohio Key, and two on the Long Beach Trail. 

y Install interpretive signs about the refuge on the planned Florida Keys Scenic Highway 

foot and bicycle path adjacent to U. S. Highway 1. The signs will be installed at areas 

that offer a view of the Lower Florida Keys Refuges. 

y Construct two kiosks, one at the field in Port Pine Heights and one at the north end of 

Key Deer Boulevard. 

The initial project costs associated with these projects are $80,000 and the annual recurring cost 

for replacement and maintenance is $2,000. (Linkages: Goal 4, Objectives 3-6, and 8). 

 

STAFFING AND FUNDING 

The refuge is currently (2008) managed by 12 permanent and 1 temporary position. The staff 

needed to implement the proposed management action includes 6 new positions as follows: 1 refuge 

operations specialist, 1 supervisory park ranger, 1 forestry technician, 2 biological technicians, and 1 

supervisory biologist. See Figure 6 for an organization chart of current and proposed staff. 

PARTNERSHIP OPPORTUNITIES 

To achieve the goals and objectives of this Draft CCP/EA, maintaining existing partnerships and 

developing new ones with a variety of resource agencies, organizations, and individuals are 

essential. For a list of existing and potential partnerships, see Appendix L. The use of partnerships 

not only helps the refuge complex achieve its vision and carry out various programs, but it also can 

lessen refuge operation costs considerably. Partnerships are necessary to implement the CCP via 

the development and implementation of the various step-down management plans and projects. 

Refuge personnel need to develop memoranda of understanding or agreements with various partners 

(e.g., FDEP, FWC, and Monroe County) to enhance coordination and cooperation on resource 

management issues. 

PROPOSED PROJECT COSTS 

The initial project cost is either a one-time or a first-year project cost. The asterisk (*) denotes 

projects that have recurring costs for less than 14 years. For the grand total of annual recurring 

costs, the highest-year cost was used to compute the total. Regarding the proposed positions, some 

will have multiple responsibilities, but they are listed in the first project that the position is referenced 

in the project descriptions. The salaries for these positions are only listed once in the project costs 

since they are shared positions. The supervisory biologist and supervisory park ranger will have 

responsibilities for all aspects of their programs, including their respective projects 1 through 14 and 

17 through 20 below. The forestry technician and two biological technician positions will share 

responsibility for multiple projects on this list. 
74 Lower Florida Keys National Wildlife Refuges 

Table 5. Summary of project costs (in 2008 dollars) 

 

Projects Proposed to Implement Management Plan 

Initial 

Project 

Cost ($) 

Annual 

Recurring 

Costs ($) * 

Staffing 

FTEs 

(6) 

 1. Fire Management Program – Biological Evaluations 110,690 60,690 Forestry 

Technician 

 2. Fire Management Program – Operations 50,000 5,000 

3. Eradicate or Control Invasive and Exotic Plants and 

 Animals 403,405 134,405 Biological Technician 

 4. Hydrologic Monitoring and Restoration 199,405 49,405 Biological 

Technician 

5. Science-based Inventorying and monitoring of Plant 

and 

 Animal Populations 

135,020 135,020 Supervisory 

Biologist 

6. Ensure the Population Viability of the Lower Keys 

 Marsh Rabbit 150,000 150,000 

 7. Maintain the Population Viability of the Key Deer. 450,000 30,000 

 8. Silver Rice Rat 100,000 100,000* 

 (2 years) 

 9. Lepidopterans 50,000 50,000 

(2 years) 

10. Sea Turtles 10,000 10,000 

11. Garber’s Spurge, Wedge Spurge, Big Pine Partridge 

 Pea 40,000

 

 40,000* 

 (2 years) 

12. Great White Herons 35,000 35,000 

13. White-crowned Pigeon 10,500 10,500 

14. Land Protection 132,040 72,040 

Refuge 

Operations 

Specialist 

15. Land Acquisition 2,000,000 2,000,000 
Section A. Draft Comprehensive Conservation Plan 75 

Projects Proposed to Implement Management Plan 

Initial 

Project 

Cost ($) 

Annual 

Recurring 

Costs ($) * 

Staffing 

FTEs 

(6) 

16. Visitor Use Survey 25,000 

17. Visitors’ Center and Environmental Education 2,075,020 125,020 

Supervisory 

Park 

Ranger 

18. Outdoor Facility Improvements 80,000 2,000 

Grand Totals: 6,056,080 3,009,080 

Grand Total Without Land Acquisition: 4,056,080 1,009,080 

Table 6. Approximate annual costs of proposed staff positions in 2008 dollars 

Title Responsibility 

RONS 

Project 

Number 

Grade Annual 

Cost 

Supervisory Biologist Habitat Management and 

Inventorying and monitoring 00007 GS-11/12 $75,020

Biological Technician Wildlife Inventorying and 

monitoring 00006 GS-5/7/9 $39,405

Biological Technician Exotic and Invasive Species 

Control 97004 GS-5/7/9 $39,405

Forestry Technician Prescribed Fire Management GS-7/9 $50,690

Refuge Operations 

Specialist Refuge Operations 00008 GS-9/11 $62,040

Supervisory Park Ranger Visitor Services 99010 GS-11 $75,020

 Total yearly cost: $341,580 

Note: These figures have been incorporated into the project descriptions and their associated costs 

in Table 5. They are not additional costs to Table 5. 
76 Lower Florida Keys National Wildlife Refuges 

Figure 10. Proposed organization structure for the management of the Lower Florida Keys 

Refuges 
Section A. Draft Comprehensive Conservation Plan 77 

Step-Down Management Plans 

A comprehensive conservation plan is a strategic plan that guides the direction of the refuge. A stepdown management plan provides more details and specific guidance on certain refuge program areas 

or activities, such as habitat, prescribed fire, and visitor services management. As implementation 

strategies in the CCP, step-down plans are also developed in accordance with the National 

Environmental Policy Act. Each of these plans will further address the priority issues raised during 

the comprehensive conservation planning process, the recommendations of the CCP review teams, 

and comments made by the public and other interested parties. 

 

The refuge proposes to initiate, update, revise, and/or implement 11 step-down plans within the 15-year 

time frame of the comprehensive conservation plan. A list of these plans and their associated completion 

dates is presented in Table 7. The following section describes the proposed step-down plans. 

Backcountry Management Plan 

The Service and the State of Florida signed a Management Agreement for Submerged Lands within 

the Boundaries of the Key West and Great White Heron National Wildlife Refuges. It established 

several special management areas where public access is restricted or prohibited to minimize 

disturbance to wildlife. The Management Agreement was completed in 1992 and provides for jointly 

reviewing and updating the plan every five years as necessary. The life of the original Management 

Agreement is 25 years and it is due to be renewed in 2012. Since refuge personnel commonly refer 

to the Management Agreement as the Backcountry Management Plan, the step-down plan and legal 

documents to update the Management Agreement will have this name in the formal title. 

Biological Inventorying and monitoring Plan 

A priority issue and critical need is for data collecting in order to guide wildlife habitat management on 

the refuge. Wildlife populations need to be adequately monitored to properly determine population 

trends, identify management needs, and evaluate the impacts of management actions. This plan will 

describe inventorying and monitoring techniques and methodologies for surveys of priority species or 

species groups. Priority will be set considering trust and listed species. Plant communities will also 

be addressed. The plan will designate key species to be inventoried and their population trends or 

habitats to be monitored. A timetable for inventorying and monitoring will be developed. 

Commercial Use Monitoring Plan 

The plan will address commercial uses on the four refuges in the Florida Keys National Wildlife Refuge 

Complex, inculiding National Key Deer Refuge, Great White Heron NWR, and Key West NWR. 

Fire Management Plan 

The purpose of this plan is to implement the policies, objectives, and standards for fire management 

presented in the Fire Management Handbook (621 FW 1-5), Department Manual (620 DM), and 

Service Manuals (095 FW 3, 232 FW6, 241 FW 3, and 241 FW 7). It will provide guidance for 

achieving the resource management objectives defined in refuge resource management plans and 

the comprehensive conservation plan. Guidance will be provided to staff for carrying-out fire 

management operations, including the conduct or prescribed burning for habitat improvement and 

fuel reduction, as well as wildfire suppression activities. 

Habitat Management Plan 

This plan will guide all habitat management activities on the refuge, including habitat management 

and restoration, wetland restoration, and exotic and invasive plant control. The plan will identify the 

wildlife habitat needs and outline the appropriate application of management tools, such as 

prescribed fire, herbicide and pesticide treatments, and mechanical or hand removal of vegetation. 
78 Lower Florida Keys National Wildlife Refuges 

Wildlife and habitat monitoring will be incorporated into the plan. It will include parameters for using 

adaptive management principles to fine-tune management and to improve results for targeted, priority 

wildlife species, species groups, and habitat. 

Integrated Predator Management Plan 

Native and non-native animal species on the refuge may require direct management strategies 

and intervention to control their abundance, distribution, and effect upon refuge resources, 

particularly predation of endangered species at risk of extinction. Examples of non-native animal 

species this plan will focus on include: feral and stray cats and dogs, green iguanas, black rats, 

pythons/boas, and potential future invaders, such as the marine toad, monitor lizard, and 

Gambian pouch rat. Management of native raccoon populations may also be addressed to 

reduce high concentrations or densities of raccoons due to artificial food sources, such as 

garbage and feeling. The Integrated Predator Management Plan will outline management 

strategies incorporating the most practicable and humane techniques to monitor and control pest 

species, including trapping and removing targeted animals, eliminating unauthorized feeding and 

watering stations, reducing animal access to garbage, actively enforcing refuge regulations and 

local ordinances, and conducting coordinated public outreach and education campaigns. Annual 

plan evaluation and revision will allow for the assessment of new or emerging threats. 

Land Protection Plan 

A Land Protection Plan (LPP) for National Key Deer Refuge was completed in 1985. In the past 20 

years, major progress has been made by the Service, State of Florida, and Monroe County in 

acquiring lands for conservation purposes. The LPP will be updated in 2010 to strategically identify 

available vacant parcels in all three refuges that should be acquired from willing sellers to achieve the 

refuge’s purposes and to recover threatened and endangered species. This plan would describe the 

affected environment within and adjacent to the refuges and threats to refuge resources. It would 

provide alternatives for land protection, including various levels of fee simple acquisition, leases, 

cooperative agreements, and conservation easements. 

Law Enforcement Plan 

This plan will provide a ready reference to Service, regional, and local law enforcement resources 

regarding refuge policies, procedures, and programs concerning refuge law enforcement. It will 

describe the objectives of the law enforcement function on the refuge. It will address the type of 

jurisdiction, active memoranda of understanding, and authorities of refuge officers both on and off the 

refuge. It will describe current assets that are available (e.g., vehicles, boats). This plan will discuss 

the procedures for addressing crimes on refuge lands. This will include patrols, traffic control, plain 

clothes operations, surveillance, and investigations. This plan will include procedures for 

documentation of both serious and routine incidents, warnings, and violation notices. It will outline 

procedures for custodial arrests, execution of warrants, intrusion alarm responses, searches and 

rescues, medical emergencies, and crowd control. The plan will show procedures for physical 

security of refuge personnel and assets. This plan is currently in draft and will be implemented by 

2010 and reviewed every 5 years. 

Mosquito Management Plan 

Currently, the Service allows the Florida Keys Mosquito Control District to conduct mosquito 

population control on portions of National Key Deer Refuge and Great White Heron NWR under an 

annual special use permit. Refuge lands are interspersed with private property and development 

making it impossible to develop separate mosquito spraying programs for both public and private 

lands. Control of mosquitos in developed areas of the Keys requires that some refuge lands be 

treated. A new mosquito management plan would be developed to evaluate the current mosquito 

control program in relation to forthcoming Service policy that would allow populations of native 
Section A. Draft Comprehensive Conservation Plan 79 

mosquito species to exist unimpeted unless they pose a specific wildlife or human health threat. 

Mosquito control measure on refuge lands will comply with federal laws and must be compatible with 

the purposes and mission of the refuges. The mosquito management plan would be developed in 

coordination with federal, state and local public health aurtorities that have expertise in vectorn-borne 

diseases, vector control agencies, and state fish and wildlife agencies. The plan will identify the 

specific conditions under which mosquito populations would be managed on the refuge, taking into 

account the local environment, as well as current and historical mosquito-associated health threats. 

Safety and Emergency Preparedness Plan 

This plan will address all procedures required by law or policy, or as otherwise needed, to provide for 

the personal safety of employees and visitors and to protect property from loss due to accidents. It 

will address staff responsibilities for safe operations, employee training requirements, required safety 

equipment, and industrial hygiene. While the plan emphasizes prevention of accident or injury, it will 

also include special response procedures and contact information for a number of specific threats, 

problems, or incidents, such as hurricanes, fires, spills of hazardous chemicals, and responses to 

serious accidents. 

Visitor Services’ Management Plan 

This plan will guide the Visitor Services’ program on the refuges. The plan will also address wildlife 

and habitat needs, trail development, five wildlife-dependent recreation priorities, recreation in the 

wilderness area and valuable cultural resources. It will provide quality visitor opportunities for present 

and future visitors. Specific emphasis will be placed on assessing and enhancing the environmental 

education program, authorizing fishing within the refuge, and developing the new visitors’ center. As 

a part or appendix to this plan, a sign plan will be written conforming to Service policy. As part of an 

annual inspection report, the sign plan will contain a photo, the message, GPS location, and condition 

of all refuge signs currently installed. The sign plan will specify signage needed to improve 

communication of information and regulations to the visitor. 

Table 7. Lower Florida Keys National Wildlife Refuges step-down management plans and 

completion dates 

Plan (Year Written) Revision or 

Completion Date 

Backcountry Management Plan (update 1992 Management Agreement 

with the State of Florida) 2012 

Biological Inventorying and monitoring Plan (new) 2009 

Commercial Use Management Plan (drafted 1997) 2009 

Fire Management Plan (2008) 2013 
80 Lower Florida Keys National Wildlife Refuges 

Plan (Year Written) Revision or 

Completion Date 

Habitat Management Plan (2008) 2013 

Integrated Predator Management Plan (2008) 2013 

Land Protection Plan (1985) 2010 

Law Enforcement Plan (2006) 2011 

Mosquito Management Plan (new) 2010 

Safety and Emergency Preparedness Plan (2006) Annually 

Visitor Services Management Plan (including a Sign Plan) (new) 2011 

MONITORING AND EVALUATION 

Adaptive management is a flexible approach to long-term management of biotic resources directed 

over time by the results of ongoing monitoring activities and other information. To apply adaptive 

management, specific survey, inventorying and monitoring protocols will be adopted by the refuge. 

Habitat management strategies will by systematically evaluated to determine management effects on 

wildlife populations. This information will be used to refine approaches and to determine how 

effectively the management objectives are being accomplished. Evaluations will include the use of 

ecosystem team and other appropriate partner participation. 

PLAN REVIEW AND REVISION 

The CCP will be reviewed every year as the refuges’ annual work plans and budgets are developed. 

A revision will occur if and when substantive information becomes available, ecological conditions 

change, or there is a major refuge expansion. The CCP will be augmented by detailed step-down 

management plans to address the completion of specific strategies in support of the refuges’ goals 

and objectives. Revisions to the CCP and the step-down management plans are subject to public 

review and compliance with the National Environmental Policy Act. 
Section B. Environmental Assessment 81 

SECTION B. ENVIRONMENTAL ASSESSMENT 

I. Background 

PURPOSE AND NEED 

As directed by the National Wildlife System Improvement Act of 1997, Comprehensive Conservation 

Plans (CCPs) are to be adopted for all national wildlife refuges by 2012. These CCPs identify the 

role individual refuges will have in support of the mission of the National Wildlife Refuge System. 

CCPs provide long-term guidance regarding the refuges’ management direction and operations. A 

Draft Comprehensive Conservation Plan and Environmental Assessment (Draft CCP/EA) for the 

Lower Florida Keys Refuges has been developed to address important natural and cultural 

resources, wildlife-dependent recreation, and administrative and law enforcement needs. 

The purpose of the proposed action is to establish and implement a management direction for the 

Lower Florida Keys Refuges for the next 15 years. The action is needed because adequate, longterm, comprehensive planning does not exist. Management is currently guided by general policies, 

federal mandates, and specific step-down plans, the latter which are in need of drafting or revision. 

The action is needed to address current priority management issues. 

In accordance with the guidelines of the National Environmental Policy Act, the Service identified a 

number of issues, concerns, and needs through discussions with the public, agency managers, and 

partnering agencies. For a description of the issues and concerns, refer to Section A, Chapter III. To 

address these issues and concerns, the Service’s planning team devised three alternatives, 

evaluated the consequences of implementing each alternative, and selected Alternative B as the 

proposed management action. 

PROPOSED ACTION 

Based on the environmental effects’ analysis of the proposed action, also known as Alternative B or 

the proposed alternative, and public comments concerning the significance of these effects, the 

Service must decide whether or not the proposed action would significantly impact the environment. 

If so, then an Environmental Impact Statement would be prepared. If the proposed action is not 

found to be significant, then a Finding of No Significant Impact would be issued, which would be 

followed by the preparation of a final CCP. 
 Lower Florida Keys National Wildlife Refuges 82
Section B. Environmental Assessment 83 

II. Affected Environment 

For a description of the affected environment, see Section A, Chapter II, Refuge Overview. 
 Lower Florida Keys National Wildlife Refuges 84
Section B. Environmental Assessment 85 

III. Description of Alternatives 

FORMULATION AND DESCRIPTION OF ALTERNATIVES 

Alternatives are different approaches or combinations of management objectives and strategies 

designed to achieve the refuges' purposes and vision and the seven goals identified in Section A, 

Chapter IV. Each alternative is designed to achieve the priorities and goals of the South Florida 

Ecosystem Team, the goals of the National Wildlife Refuge System, and the mission of the Fish 

and Wildlife Service. 

The three alternatives represent different approaches for managing and operating the Lower Florida 

Keys Refuges over a 15-year time frame. The alternatives would provide protection, restoration, and 

management of the refuges’ fish, wildlife, plants, habitats, and other resources, as well as provide 

appropriate and compatible wildlife-dependent uses. Each alternative was evaluated based on how it 

would address the priority management issues and concerns identified by the Service and the public 

during public scoping as detailed in Section A, Chapter III. A summary of each alternative is given. 

Table 8 follows the summary. It presents a comparison of how each alternative addresses the priority 

issues. The table is grouped by each of the seven goals as outlined in Section A, Chapter IV. 

ALTERNATIVE A - (CURRENT MANAGEMENT - NO ACTION) 

The Lower Florida Keys Refuges have a high diversity of community types and endemic species, with 

many threatened, endangered, rare, and imperiled species. The primary mission of these refuges is 

to provide habitat for wildlife. The refuges currently have a small staff and funding source for the 

inventorying and monitoring of natural resources. Much effort has been put into some resources, 

such as Key deer and their habitat (pine rocklands), as a result of cooperative partnerships with 

academic and other research organizations. Certain species, such as great white herons, whitecrowned pigeons, reddish egrets, and sea turtles, have been studied over time by refuge biological 

staff and academic partners. Under this alternative, these studies would continue. 

 

Baseline data has yet to be established for some protected species, species suites, habitats, and 

cultural resources. The effects of natural catastrophes (e.g., Hurricane Wilma in 2005) on the 

refuges’ resources have not been assessed and the effect of climate change (e.g., sea level rise) is 

not known. 

Threatened and endangered species are protected through a variety of management tools, such as 

area closures, law enforcement, exotic plant control, etc. Limited research and monitoring of focal 

species, such as Key deer and Lower Keys marsh rabbit and some migratory birds (e.g., reddish 

egrets), would continue with existing refuge staff and partnerships. The National Key Deer Refuge’s 

prescribed fire management program would continue with the objectives to reduce fuels and to 

sustain the pine rockland ecosystem. 

The Service would continue habitat conservation through land acquisition within the approved 

acquisition boundary and cooperative agreements with other agencies for non-refuge lands that 

support the refuges’ missions. Partnerships exist to promote land conservation. Exotic plant control 

to protect and maintain current habitat would occur at existing levels. Currently, exotic plants are 

controlled through partnerships with the Nature Conservancy, the State, and Monroe County. A 

predator management program has been initiated on National Key Deer Refuge to reduce the effects 

of feral cat and raccoon predation on the endangered Lower Keys marsh rabbit. 
 Lower Florida Keys National Wildlife Refuges 86

Ecologically sensitive areas and living resources are protected from disturbance or degradation 

through the use of closure areas, law enforcement, and the implementation of the Management 

Agreement for Submerged Lands within the Key West and Great White Heron NWRs. The effects of 

commercial activities and public uses (both wildlife-dependent and non-wildlife-dependent) have not 

been fully evaluated and carrying capacities are unknown. 

The Service has an active volunteer program to assist in all facets of refuge management. 

Partnerships for these purposes and for research are encouraged and maintained. Under this 

alternative, the existing level of administrative resources (staffing, facilities and assets, funding, and 

partnerships) would be maintained. This means some positions may not be filled when vacated if 

funds need to be reallocated to meet rising costs or new priorities. 

ALTERNATIVE B - (PROPOSED ALTERNATIVE) 

This alternative assumes a slow-to-moderate growth of refuge resources over the 15-year 

implementation period of the CCP. It proposes a management direction for the enhancement of 

wildlife populations by promoting a natural diversity and abundance of habitats for native plants and 

animals, especially Keys’ endemic, trust, and keystone imperiled species. Many of the objectives and 

strategies are designed to maintain and restore native communities, particularly the globally imperiled 

pine rocklands, saltmarsh, and freshwater wetlands, as well as the island beach berm communities. 

Research and monitoring will provide essential information for implementing an adaptive 

management approach to ecosystem conservation. This alternative would provide for obtaining 

baseline data for ecosystem health. 

Current ongoing and proposed programs and efforts focus on threatened, endangered, rare and 

imperiled species of plants and animals. The need for more comprehensive inventorying and 

monitoring for baseline data is addressed in this alternative, particularly for priority imperiled species 

and their habitats within the refuges. Habitat carrying capacity for Key deer, by island, would be 

determined and the feasibility of population management would be considered within the realm of the 

South Florida Multi-Species Recovery Plan in accordance with the Endangered Species Act. 

Habitat enhancement for critically imperiled species, such as the Lower Keys marsh rabbit and Key 

tree cactus would occur to ensure the long-term sustainability of these species. Opportunities for 

land acquisition from willing sellers would focus on protecting more marsh rabbit habitat. Off-refuge 

nursery propagation of the Key tree cactus would be implemented for later translocation to suitable 

refuge habitats. Research would be initiated to identify causal reasons for the marked, long-term 

decline in the great white heron nesting population. 

Since a primary purpose of the refuges is to provide sanctuary for nesting and migratory birds, 

greater protection from human disturbance would be provided, particularly at colonial nesting bird 

rookeries and at beach habitats in the backcountry islands. Additional limitations to public use may 

be implemented in sensitive beach areas important for shorebirds, terns, sea turtles, and butterflies. 

Strategies are proposed to improve the fire-dependent pine rocklands and to enhance habitat 

features in saltmarsh and freshwater wetlands that benefit priority species in the National Key Deer 

Refuge. Prescribed fire and mechanical or manual vegetation treatments would be used as habitat 

management tools to reduce wildland fuels and benefit priority species and habitats where 

appropriate. Predictive modeling and fire effects monitoring would be used on all prescribed-fire 

treatments in an adaptive management approach to develop site-specific burn prescriptions and to 

determine whether objectives were met. The National Key Deer Refuge habitat and fire management 

plans would be revised and implemented accordingly. 
Section B. Environmental Assessment 87 

Exotic plant control would continue as an ongoing operation within the refuges in order to maintain 

habitats and prevent new infestations. Cooperative efforts would be sought to control seed sources 

from private lands and to increase coordinated mapping and monitoring of areas with known 

infestations. Management of non-native and exotic animals would be implemented as directed by the 

South Florida Multi-Species Recovery Plan for the benefit of threatened and endangered species. 

A primary focus of the visitor services program, as proposed, is to enhance environmental education 

and outreach efforts substantially to reach larger numbers of students, educators, and visitors. This 

alternative also focuses on increasing public awareness, understanding, and support for the refuges’ 

conservation mission. It places priority on wildlife-dependent uses, such as photography and wildlife 

observation; the details of these allowable uses are specified in appropriate use and compatibility 

determinations (Appendices E and F). A Visitor Services’ step-down plan will specify program details 

consistent with the Service’s visitor service program standards. Non-wildlife dependent forms of 

recreation would be limited or restricted in sensitive areas and awareness efforts would be steppedup to inform visitors about protecting wilderness areas. 

The basic administrative and operational needs of the refuges have been addressed. Essential new 

staffing is proposed through the addition of six permanent employees. Daily operation of the refuge 

would be guided by the CCP through the development and implementation of 11 step-down 

management plans. Wilderness and cultural resource protection objectives and strategies would be 

incorporated within the appropriate step-down management plans. The modest growth in resources 

would be used for wildlife monitoring and habitat enhancement to better serve the refuges’ purposes 

and the CCP’s vision. Existing facilities and vehicles would be maintained with the exception of the 

new Visitor Services’ facility that is proposed. 

ALTERNATIVE C 

This alternative assumes a moderate-to-substantial growth of refuge resources from internal or 

external sources. It would more fully realize the refuges’ missions and address the huge number of 

imperiled species and habitat types. While Alternative C contains many of the provisions to protect 

and restore habitats similar to Alternative B, it emphasizes a broader suite of priority species. The 

long-term ecological inventorying and monitoring plan would be expanded to cover more species and 

species suites. Additional studies on some species would be undertaken and additional biological 

staffing would be required. The use of captive, off-refuge sources of some species facing potential 

extirpation (e.g., Lower Keys marsh rabbits) would be explored for reintroduction after a natural 

catastrophe, such as a major hurricane. In certain habitats, some alternative habitat management 

techniques would be studied and applied. Education and outreach programs on alternative habitat 

management tools and strategies are proposed. Studies to monitor the immediate and/or long-term 

effects of natural, catastrophic events (e.g., hurricanes) and global climate change, particularly sea 

level rise, would be initiated. 

Under this alternative, the CCP anticipates shifts in the Visitor Services’ program if visitation and 

public use increase. Positions are proposed to add another refuge ranger position to coordinate and 

enhance volunteerism and to foster relationships with FAVOR and other partners for environmental 

education and outreach programs. 

Resource protection and visitor safety would be greatly enhanced through this alternative with the 

addition of two law enforcement officers. This would allow for more patrol and enforcement of closure 

and sensitive area protection, especially of wilderness areas or cultural resource sites. A cultural 

resources inventory would be conducted. 
 Lower Florida Keys National Wildlife Refuges 88

The operation of the refuges for meeting their goals and purposes is more optimally realized under 

this alternative. Implementation of the CCP, including details of refuge operations, would also occur 

through the development of 11 step-down management plans. New staffing is proposed through the 

addition of seven permanent full-time employees. The positions would be in addition to the six fulltime positions proposed in Alternative B, for a total of thirteen full-time positions in Alternative C. New 

maintenance and staff housing facilities are proposed along with new vehicles and boats to 

accommodate the staff increases. 

FEATURES COMMON TO ALL ALTERNATIVES 

Although the alternatives differ in many ways, there are some similarities among them. All three 

alternatives maintain existing partnerships and increase others. Partnerships would be sought with 

academia, other government and non-governmental organizations, private institutions, and the public 

for the following: inventorying and monitoring, private lands conservation, public land protection, and 

outreach and environmental education. The use of volunteers to supplement existing staff and 

resources is proposed for most facets of refuge operation and maintenance, with special emphasis 

on the Visitor Services’ programs. All alternatives are based on best available and professionally 

sound science; Endangered Species Act requirements; and compliance with all Service laws, 

policies, directives, and guidelines. 
Section B. Environmental Assessment 

Table 8. Comparison of alternatives by management issues for the Lower Florida Keys Refuges 

Priority Issues 

Alternative A 

(Current ManagementNo Action Alternative) Alternative B (Proposed Alternative) 

OVERARCHING ISSUE 1. Managing a Complex of Islands Changes in land use Purchase priority lands within 

the approved acquisition boundaries as money is appropriated by Congress. Continue to accept management responsibility for state- and county-owned lands that fulfill the mission and purposes of the refuges. 

Work cooperatively with state, county, and private organizations to identify existing conservation lands outside the current acquisition boundaries that are critical to the management of refuge resources or protected (trust) species. Continue to participate in Monroe County Land Use Plan efforts. 

Shift eacquisrestoralands. 

Jurisdiction – Existing agreements add responsibility to law enforcement (LE) staff to cover more areas than refuge lands. 

Maintain current management agreements at existing level and review as required. 

Institute any new agreement(s) that support the Visitor Services’ program. Conserve and protect critical habitat though land and water lease agreements with local and state agencies. 

Same 
90 Lower Florida Key

Priority Issues 

Alternative A 

(Current ManagementNo Action Alternative) Alternative B (Proposed Alternative) 

Wildland-urban interface (WUI)/fuel loads 

Continue cooperative efforts with Monroe County, TNC, and Florida Division of Forestry to identify and treat refuge owned and managed lands with elevated fuel levels that pose a threat to lives, property and habitat from catastrophic wildfires. 

Same as alternative A. Also, use prescribed fire and mechanical methods to reduce fuel load in the WUI. Work with National Fire Lab to develop fuel models and burn prescriptions specific to National Key Deer Refuge for proper application of fire to achieve fuel reduction and habitat management goals. Expand education and outreach efforts on the role of prescribed fire for habitat management and promote FireWise practices among homeowners. 

Same determmanaghabitat 

VISITOR SERVICES 2. Changing Public Use Attitudes, Needs, and Demands Illegal activities – law enforcement 

With two LE officers, continue to manage for illegal activities with the existing level of visitor activity and access restrictions. 

Undertake a study of refuge resources to assess impacts from recreational refuge users. Determine which changes in the visitor services program should be implemented to curtail any illegal activity(ies). 

Increaspresenareas (supporuse of workfopilots) refuge 
Section B. Environmental Assessment 

Priority Issues 

Alternative A 

(Current ManagementNo Action Alternative) Alternative B (Proposed Alternative) 

Marine debris Encourage current efforts by 

FAVOR, FKNMS, and Monroe County to address removal of marine debris from refuge lands on an opportunistic basis. 

Work cooperatively with FAVOR, FKNMS, and Monroe County to remove marine debris from refuge lands on a regular basis. 

Increaswith otorganizentities of mara coordcampa

Prescribed and wildfire management 

Maintain current level of outreach to keep the public and media informed about the fire management program and specific events. 

Increase the level of outreach efforts through targeted education programs, public workshops and designation of a fire information officer onsite at prescribed burns or wildfires to keep the public and media informed about the fire management program. Coordinate outreach efforts with other fire response agencies for a consistent message. 

Same 

Public perception of the Service’s role in endangered species management. 

Maintain current level of outreach efforts to keep the public and media informed about endangered species management and to encourage activities to enhance species and their habitat. 

With a second park ranger position, expand outreach and partnership efforts and create exhibits in the new visitor center to address this issue. 

More epartnethe Ecto addr
92 Lower Florida Key

Priority Issues 

Alternative A 

(Current ManagementNo Action Alternative) Alternative B (Proposed Alternative) 

Visitor Services – maintaining wildlife dependent public uses and preventing degradation and disturbance to resources from overuse by public and commercial use. 

Maintain existing wildlifedependent activities and opportunities where appropriate and compatible. 

Research the impact of visitor use on resources and determine a carrying capacity for sensitive areas or resources. Take corrective actions to prevent resource degradation and overuse problems. Marginally increase appropriate and compatible wildlife-dependent public use activities and opportunities on the refuges in areas that are not resource sensitive (e.g., add nature trails, facilities, and programs on and off the refuges). Draft a Visitor Services’ step-down plan. 

Same 

Visitor Services – Address demand for non-priority public uses from the public and commercial vendors. 

Continue to allow some historic non-wildlife-dependent public uses that do not cause disturbance to wildlife and are not detrimental to their habitat and natural resources. Revise and implement the 1997 Draft Commercial Use Management Plan. 

Same as Alternative A. Same 

Cultural resources Some areas are permanently 

closed to visitors because they are ecologically sensitive. Some cultural sites (unknown) may benefit from this policy. 

Provide general, interpretive information on cultural resource themes at the visitor center. Address cultural resource protection in all applicable step-down plans. 

Inventorefugeclosure deemenot appIncreas
Section B. Environmental Assessment 

Priority Issues 

Alternative A 

(Current ManagementNo Action Alternative) Alternative B (Proposed Alternative) 

Controlling public access in important migratory bird areas 

Enforce current area closures through LE patrols. 

Increase LE patrol and presence to prevent trespass and minimize disturbance. Seek supplemental assistance from local, state, and other federal agencies. 

Increaspresenand mi

Illegal activities and controlling public access 

Enforce current area closures through LE patrols. Two fulltime officers currently patrol three refuges spread over a great expanse of water. 

With assistance from state and other federal agencies, supplement current refuge enforcement of area closures. 

Increaspresenareas (supporuse of (e.g., pobserv

Impacts of visitor use on wilderness/backcountry Islands 

Monitor and patrol the wilderness as LE and biological staff are available. 

Evaluate the feasibility of limiting public uses of the Marquesas Keys to protect its unique wilderness and ecological values. Incorporate wilderness protection measures in all applicable step-down management plans. Update the management agreement as needed. 

Same Reseause andetermtake coMarginof apprwildlifethat ar
94 Lower Florida Key

Priority Issues 

Alternative A 

(Current ManagementNo Action Alternative) Alternative B (Proposed Alternative) 

HABITAT AND WILDLIFE POPULATION MANAGEMENT3. Habitat Loss and Fragmentation Habitat loss and fragmentation 

Continue protection of the Lower Florida Keys Refuges and county and state lands managed by the Service. 

Complete priority land acquisitions to ensure conservation of quality habitats in the Lower FLorida Keys in perpetuity. Work with partners in administering jointly managed areas. Expand wetland and upland restoration to mitigate habitat loss. 

Same secure source county the mathe ref
Section B. Environmental Assessment 

Priority Issues 

Alternative A 

(Current ManagementNo Action Alternative) Alternative B (Proposed Alternative) 

4. Climate Change Catastrophic events Continue to map pine kills 

resulting from storm surge events and record burned acreages due to wildfires. Continue to assess hurricane effects on indicator species, such as great white herons, white-crowned pigeons, sea turtles, and Miami blue butterflies. 

Same as Alternative A. Also work with partners to develop a predictive model to guide land acquisition and management strategies in light of existing and predicted changes in baseline conditions due to climate change. 

Obtain ecosysimmedof cataevents synergof multfor exaby a sewildfireContragauge HurricahurricaparticuFormuaccounby natu
96 Lower Florida Key

Priority Issues 

Alternative A 

(Current ManagementNo Action Alternative) Alternative B (Proposed Alternative) 

Climate change Continue consulting with 

academic partners on a study of sea level rise effects on globally imperiled pine rocklands. 

Focus management efforts on upland areas as coastal areas become inundated or submerged. 

Obtain environglobal sea levclimate hydroloof projeits arealands. managconseracquis
Section B. Environmental Assessment 

Priority Issues 

Alternative A 

(Current ManagementNo Action Alternative) Alternative B (Proposed Alternative) 

5. Fire Management Prescribed fire and fire effects management 

Continue to use prescribed fire primarily for fuel reduction and to benefit Key deer. The refuge fire management program is currently under review. 

Use prescribed fire for maintaining and restoring fire-adapted habitats. Clearly define habitat management objectives to reflect management for a variety of imperiled species, as well as fuel reduction. Use inventorying and monitoring plan to determine areas suitable for prescribed fire, to define objectives, and to evaluate the use of prescribed fire. Implement adaptive management and revise fire management plan accordingly. Expand education and outreach efforts on the use of prescribed fire as a habitat management tool. 

Use mclearinthe effefire-adinventodata to for altestrategimplemmanageducaton the strategmanag
98 Lower Florida Key

Priority Issues 

Alternative A 

(Current ManagementNo Action Alternative) Alternative B (Proposed Alternative) 

6. Lack of Inventorying and monitoringWildlife surveys, inventorying and monitoring 

As biological staff and outside researchers are available, continue wildlife and plant surveys on a few priority species. 

Through partnerships, new staff and the use of existing staff, conduct more extensive monitoring of priority, endemic plant (e.g., Garber’s spurge) and animal (e.g., reddish egrets) species and species groups (e.g. butterflies) and habitats. Write long-term ecological inventorying and monitoring plan to support an adaptive management approach. 

Same add to increashabitatand bir
Section B. Environmental Assessment 

Priority Issues 

Alternative A 

(Current ManagementNo Action Alternative) Alternative B (Proposed Alternative) 

7. Recovery of Imperiled Species Key deer - Species habitat relationships 

Continue population monitoring efforts of Key deer. Continue partnerships with universities to understand Key deer population dynamics and ecology, and browsing effects on native plant communities. 

Initiate a study to determine the carrying capacity of Key deer in core and outer populations. Evaluate the feasibility of population control strategies compatible with protection of Key deer under the Endangered Species Act to maintain herd health and habitat quality. Increase education and outreach efforts to foster an understanding of Key deer ecology. Curtail public feeding of deer. 

Allow a populadisastedrough

Potential extinction of the Lower Keys marsh rabbit (LKMR) 

Monitor the extant population. Continue to translocate LKMRs to suitable, uninhabited refuge islands free of feral cat predation. Reduce abundance of free-roaming and feral cats in LKMR habitat as resources allow. 

Same as Alternative A. Also, maintain, restore and enhance occupied and potentially suitable LKMR habitat. Maximize connectivity among suitable habitats. Consider establishing a genetically diverse LKMR population of 100 animals on the Florida mainland as a source for reintroduction in the event of a catastrophic hurricane. Implement an integrated predator control program. 

EstabliLKMR animalas a sothe evehurricafeasibibreedinpopula
100 Lower Florida Key

Priority Issues 

Alternative A 

(Current ManagementNo Action Alternative) Alternative B (Proposed Alternative) 

Extirpation of the Key tree cactus 

Maintain closed areas to protect extant Key tree cactus population on refuge lands. Continue partnerships to establish a nursery-grown population as a source for reintroduction or translocation to refuge lands identified as suitable release sites. 

Same as Alternative A. Also restore or create suitable habitat for nurserygrown tree cactus. 

Same initiate factors presencactus 
Section B. Environmental Assessment 

Priority Issues 

Alternative A 

(Current ManagementNo Action Alternative) Alternative B (Proposed Alternative) 

8. Controlling Injurious, Invasive and Exotic Species Exotic and invasive plants 

Continue cooperative efforts with Monroe County, TNC, and the State to re-treat areas with known invasive species problems. Work with USGS to develop a predictive model of which species and what habitats are likely for new invasions. 

Same as Alternative A. Also expand cooperative efforts to increase mapping and monitoring of areas with known infestations, particularly on private lands and public rights-of-way which serve as seed sources for refuge lands. 

Use extreatmobtain source exotics 

Exotic and invasive animals 

Reduce abundance of freeroaming and feral cats in marsh in LKMR habitat as resources allow. Monitor other exotic species and remove individuals if problematic. 

Implement an integrated control program in cooperation with Monroe County and other stakeholders to reduce the abundance of feral and free-roaming cats and dogs on the refuges, including trapping and removal, and public education. Establish a rapid response protocol to detect and remove new exotic animal infestations. 

Same evaluaof greeinvasivaccord
102 Lower Florida Key

Priority Issues 

Alternative A 

(Current ManagementNo Action Alternative) Alternative B (Proposed Alternative) 

REFUGE ADMINISTRATION 9. Administrative Resources Staffing Maintain existing staff position. 

Fulfill mandatory staff training requirements. 

Hire six permanent full-time employees and use operational funds to hire seasonal staff to enhance capability to achieve priority refuge objectives for habitat protection, biological inventorying and monitoring, marine resource management, adaptive management, species recovery, and public outreach. 

Same hire an perma(13 totprotectimprovconduceducatpromotthe fire and to climate weathemanag

Partnerships—using volunteers to supplement refuge staff 

Maintain the existing volunteer program. 

Hire a second Visitor Services’ employee whose duties would include serving as a volunteer coordinator to increase volunteering in the outreach and environmental education areas. 

Hire a allow tplace mvolunte
Section B. Environmental Assessment 

Priority Issues 

Alternative A 

(Current ManagementNo Action Alternative) Alternative B (Proposed Alternative) 

Facility and asset needs 

Maintain existing assets—five employee quarters, administrative headquarters, boats and heavy equipment to support refuge operations; and manage the bunkhouse and trailer as itinerant quarters for seasonal staff, volunteers, and researchers. 

Same as Alternative A. Also construct new visitor center on U.S. Highway 1. 

Same expand develoquartestaff. Amainte

Funding Expend annual operations and 

maintenance funds as allocated. 

Expend annual operations and maintenance funds as allocated, and actively pursue non-traditional funding sources through partnerships and grant writing to expand capacity to accomplish refuge objectives. 

Same 

Partnerships Maintain existing partnerships. Foster internal (Service) and external 

partnerships with local, state, and federal agencies; conservation organizations; and non-profit groups and support FAVOR and volunteers. 

Same 

Partnerships for ecological studies 

Continue cooperative research agreements with universities that address priority species on refuge lands. 

Same as Alternative A. Greatly expand cooperative collaboration to examine ecological processes of the refuge lands as a whole. Pursue challenge cost-share grants to achieve this. 

Initiate privateagency researgroups 
104 Lower Florida Key

Priority Issues 

Alternative A 

(Current ManagementNo Action Alternative) Alternative B (Proposed Alternative) 

Partnerships for studies and inventories of refuge programs 

Maintain existing partnerships and cooperative efforts in the Visitor Services’ program. Partner with a university to determine potential numbers of visitors to a new visitor center on Highway U.S. 1. 

Strengthen current partnerships that will enhance priority wildlife-dependent public uses and institute new partnerships where there are none (e.g., fishing and fishing clinics, new visitors’ center, and law enforcement.) 

Same 

Partnerships for cultural resource assessment 

While there has been no comprehensive inventory of cultural resources, use existing data and studies to best manage for cultural resources protection. 

The regional archaeologist will prepare a cultural resources overview of the refuges and obtain state mapped site data. All applicable step-down plans will include provisions for protection of cultural resource sites. 

Conduresoursites. archaepotentiarchaeinvestiinterdis
Section B. Environmental Assessment 105 

IV. Environmental Consequences 

OVERVIEW 

This section analyzes and discusses the potential environmental effects or consequences that can be 

reasonably expected by the implementation of each of the three alternatives described in Chapter III. 

 

EFFECTS ON THE PHYSICAL ENVIRONMENT 

To assist in this analysis, the impacts on the physical environment were divided into the categories of 

soils, hydrology, water quality, air quality, noise, aesthetics, and facilities. 

SOILS 

Soils are thin to absent in the pine rocklands and would not be significantly affected by any of the 

alternatives. This is a fire-dependent habitat and the effects of prescribed burning on soils would not 

differ substantially from that of a fire ignited by lightening. 

Under Alternative A, there are no proposed actions that would degrade soils anywhere in the refuge. 

Under Alternative B, burning in coastal salt marshes and freshwater marshes is advocated to 

enhance Lower Keys marsh rabbit habitat. The historic and ecological role of fire in this habitat is 

currently being studied. Temporary changes in soil characteristics may occur after a fire, but would 

be negligible and more than offset by potential benefits conferred on marsh rabbit habitat. 

Under Alternative C, mechanical and hand clearing is proposed to achieve the fuel reduction effects 

of prescribed burning in pine rocklands and coastal salt marshes. Effects on soils in pine rocklands 

would be negligible. Foot traffic may cause minor rutting and compaction of soils in the latter habitat. 

HYDROLOGY 

Under Alternatives A and B, wetland restoration would continue to occur as funds and cooperative 

mitigation projects allow. Alternative B proposes a hydrological study and associated work to restore 

altered areas to a more natural hydrology. Under all alternatives, procurement of additional lands 

from willing sellers would confer protection in perpetuity to acquired wetlands, would enhance the 

protection of the freshwater lenses underlying Big Pine Key, and, in the case of upland acquisitions, 

would serve as a buffer for adjacent wetlands. These acquisitions would have a beneficial effect on 

hydrological resources. Expansion of wetland restoration efforts would allow restorative work to be 

expedited, rather than delayed. Under Alternative C, securing a permanent funding source for 

management of county and state-owned lands under refuge management would facilitate restorative 

efforts that would benefit natural wetland processes. 

WATER QUALITY 

Under all alternatives, the cumulative effects of long-term herbicide use for exotic plant control could 

result in a slight decrease in water quality in localized areas, specifically in wetland transition areas 

prone to exotic plant infestation. With proper application, no leaching of chemicals into water bodies 

would be expected. Under all alternatives, since exotic plant infestation areas would be discovered 
106 Lower Florida Keys National Wildlife Refuges 

and treated while still relatively small, a reduced amount of herbicide would be needed for treatment, 

lessening the impact of herbicides and mechanical treatment that may affect local water quality. 

Alternative C would allow baseline information to be obtained on the long-term effects of catastrophic 

hurricane and fire events on water quality, as well as monitor the consequences of gradual 

climatological changes, such as sea level rise on freshwater resources. Alternative C would confer 

the additional advantage of working with partners to develop predictive models to guide management 

strategies in light of existing and predicted changes in baseline data. 

AIR QUALITY 

No change in air quality would occur under Alternative A. Under all alternatives, air quality would be 

temporarily degraded during fire management operations. However, wildfires tend to consume 

considerably more biomass per acre and occur under weather conditions outside the planning 

window of fire managers. Prescribed burning, while temporarily degrading air quality, is done under 

more predictable circumstances and generally under conditions where fuel consumption, the primary 

factor in determining particulate emissions, is less than wildfires. No major differences in air quality 

relative to prescribed fire are anticipated under the three alternatives. 

Under Alternative C, allowing fire-prone pine rockland habitats in the wildland urban interface to 

revert to hammocks would reduce the need for prescribed burning and diminish the threat of wildfires. 

Increased vehicular use with associated emissions is likely under all three alternatives due to a 

growing local and regional population and increased refuge visitation. However, this might be offset 

by reduced vehicle or residential emissions that could result from protecting existing or purchasing 

new lands that might otherwise have been developed. Compared to other land uses, all of the 

alternatives for the refuges would provide greater protection against degradation of daily ambient air 

quality over the long term. 

NOISE POLLUTION 

Under all alternatives, moderate increases in noise from automobile traffic are expected as are slight 

increases in road kill, particularly of reptiles, amphibians, and small mammals. However, Alternatives 

B and C would provide additional refuge staff, partners, and research availability to monitor these 

negative impacts and adjust refuge management where appropriate to reduce these impacts. Under 

all alternatives, temporary noise and minor traffic increases would be by-products of fire control and 

fuel reduction where a helicopter, mechanized machinery, or fire trucks were used. Exotic species 

control, which often involves the use of a chipper, would generate temporary increases in noise for all 

alternatives. 

On some weekends, high numbers of visitors to Boca Grande Key, and to a lesser extent, Woman 

Key, create a serious noise pollution problem. Under Alternative A, noise pollution would continue to 

be a problem at such periods on both islands. Under Alternative B, Boca Grande Key would be 

closed during holiday weekends to prevent overcrowding. Under Alternative C, carrying capacities 

would be set for these islands to reduce overcrowding and noise pollution, which may necessitate 

additional enforcement or beach closures. 

AESTHETICS 

Under all alternatives, aesthetics are expected to be positively impacted through the acquisition 

or other protection of adjacent lands from urban and suburban fringe development. Prescribed 
Section B. Environmental Assessment 107 

fire may to some have a temporary, negative aesthetic impact until new growth appears. Over 

the longer term, negative impacts would be offset as more refuge pine rockland areas are brought 

into an uneven-aged condition, resulting in greater plant diversity in the understory and a more 

visually appealing forest. 

Exotic plant control would have temporary negative aesthetic impacts with easily observable dead 

and dying vegetation along roadsides in high use areas in particular. However, under all 

alternatives, these actions would result in a net benefit to aesthetics by preventing establishment 

of exotic plant monocultures. 

Under Alternatives B and C, construction of a visitor center would have a temporary negative 

effect on aesthetics during the construction stages. However, since the facility would be sited on 

U.S. Highway 1 on an already developed site and where commercial use is prevalent, the 

completed facility would complement, rather than degrade, the aesthetics. The center would be 

built to Service standards, conform to local building codes, and be compatible with adjacent 

construction and landscaping standards. 

FACILITIES 

Under Alternative A, there would be no change to the current facilities. Under Alternatives B and C, 

construction of a new visitor center, with offices and storage space, would result in a safer, more 

efficient work environment for staff. It would also provide a larger area, improved exhibits, and 

greater environmental education opportunities for visitors. Because the new Visitor Center would be 

sited on lands previously developed, there would be no loss of native habitat. Under Alternatives B 

and C, enhanced trailhead parking/information kiosks, a wildlife photography blind, and an elevated 

wildlife observation platform would greatly enhance visitor opportunities for environmental education. 

EFFECTS ON THE BIOLOGICAL ENVIRONMENT 

EXOTIC PLANT SPECIES 

Under Alternative A, aggressive but irregular control of exotic plants would continue as time and 

funds are available. Currently, exotic plants are controlled through partnerships with the Nature 

Conservancy, the State of Florida, and Monroe County. To date, the majority of control has occurred 

with State funding, which may or may not continue to be available. Existing funds may or may not be 

sufficient to treat state and county lots managed by the Service, to treat newly acquired lots or to retreat previously treated infestations. Untreated infestations will likely serve as seed sources and 

gains achieved would be gradually lost again. The cost of control projects would continue to rise as 

large areas of exotic plants may spread without timely detection. 

Under Alternatives B and C, exotic plant control would become a focus of ongoing operation within 

refuges in order to maintain habitats and prevent new infestations. In Alternative C, existing 

infestation and treatment data would be used to obtain permanent funding for a refuge-based exotics 

treatment program. Cooperative efforts and partnerships with the State, County, and TNC would be 

expanded to increase mapping, monitoring and treatment of areas with known infestations, 

particularly on private lands and public rights-of-way, which serve as seed sources for refuge lands. 

Alternatives B and C would positively affect the native plant communities. 
108 Lower Florida Keys National Wildlife Refuges 

EXOTIC ANIMAL SPECIES 

Under Alternative A, a control program is being instituted for feral and free-roaming cats and possibly 

raccoons; both are known predators of the endangered Lower Keys marsh rabbit. Immediate and 

extensive predator control is necessary to protect remnant Lower Keys marsh rabbits occupying 

refuge lands. Free-roaming dogs are occasionally found on the refuge, particularly near houses 

adjoining the refuge boundary. The impacts of free-ranging dogs on overall refuge wildlife are 

considered relatively small. Free-ranging cats can have a devastating impact on small bird, reptile, 

and mammal populations. 

Except for free-roaming dogs and cats, the impacts of other, non-native species have not been 

determined for the refuges. Considering documented impacts of non-native species on other 

natural areas, impacts to native wildlife in the Lower Florida Keys are also likely. Impacts will 

continue and infestations are likely to spread without the development and implementation of an 

exotic animal control program. 

Under Alternatives B and C, exotic animal control would become a focus of ongoing operations within 

the refuges in order to protect native species and to prevent new invasions. Exotic animal control 

programs would continue or expand as needed to protect top-priority species under Alternative B and 

all priority species under Alternative C. Increased exotic animal control efforts would greatly improve 

the persistence of numerous threatened and endangered species and imperiled habitats. 

NATIVE HABITATS AFFECTED BY THE PLAN 

Pine Rocklands 

Under Alternative A, pine rockland habitats will continue to be lost due to numerous extrinsic threats, 

including habitat succession towards hammock from the lack of prescribed fire, and potentially 

catastrophic wildfires from the associated elevation in fuel loads. Pine rocklands will continue being 

impacted by the endangered Key deer herd, which is currently believed to be above carrying 

capacity, particularly on Big Pine and No Name Keys. The impacts of non-native herbivores, such as 

the green iguana, are not known but are likely to be detrimental; impacts will continue without 

implementation of an appropriate control strategy. Agency and academic partnerships will continue 

to explore the impacts of sea-level rise on this globally imperiled ecosystem. Continued land 

acquisition of priority uplands sites will provide additional protection. 

Under Alternative B, an inventorying and monitoring plan would establish baseline data on the extent and 

health of the pine rockland ecosystem and top-priority species associated with this habitat type. 

Prescribed fire would be implemented as an adaptive habitat management tool with emphasis on top 

priority species. Data obtained from fire management and sea-level rise studies would be used to 

prioritize protection and restoration efforts. Impacts to pine rocklands from Key deer browsing would be 

reduced by appropriate herd management. Establishing a seed bank or nursery to restore the pine 

rocklands’ flora lost due to sea-level rise, storm surges, and catastrophic wildfires would be evaluated. 

Under Alternative C, mechanical management would be implemented to mimic prescribed fire and to 

determine impacts of fire suppression and increased fuel loads. Mechanical and hand-clearing 

treatments may reduce or slow successional processes; however, fire-dependent habitats and faunas 

may ultimately be lost. All priority species associated with pine rocklands would be addressed in the 

inventorying and monitoring plan and associated step-down plans. 
Section B. Environmental Assessment 109 

Hardwood Hammock 

Tropical hardwood hammocks are considered to be a climax ecosystem and therefore, do not require 

active management. Two federally protected species are located within hardwood hammocks on 

refuge lands, the Key tree cactus and Stock Island tree snail. Under Alternative A, both would 

continue to be protected through closure of Watson and Cactus Hammocks. Mosquito-control 

spraying of adulticides is prohibited in both areas. Continued fire suppression in pine rocklands 

habitat would likely increase the amount of hardwood hammocks due to successional processes. 

Hardwood hammocks would continue to be impacted by over-browsing by the endangered Key deer 

herd, and potentially non-native herbivores, such as the green iguana. Without implementation of an 

appropriate management strategy, these impacts would continue. 

Under Alternative B, an inventorying and monitoring plan would establish baseline data on the extent and 

health of the hardwood hammock ecosystem and top-priority species associated with this habitat type. 

Implementation of a prescribed fire program in adjoining pine rockland habitats could result in the loss of 

hardwood hammock species along the transitional margin where fire may creep into the hammock. 

Impacts to hardwood hammock species from Key deer browsing would be reduced by appropriate herd 

management. Establishing a seed bank or nursery to restore the hardwood hammock flora lost due to 

over-browsing, sea-level rise, wind storms, and storm surges would be evaluated. 

The environmental consequences associated with Alternative B would be the same for Alternative C; 

however, more of the priority species associated with hardwood hammocks would be addressed in 

the inventorying and monitoring plan and associated step-down plans. The impacts of sea level rise 

on this habitat type would be documented. 

Freshwater Marsh 

Under Alternative A, freshwater marsh would continue to be impacted by fire suppression, storm 

surges and sea-level rise, as well as hydrological changes associated with roads, canals, mosquito 

ditches, and the use of fill to elevate existing areas. Continued loss of freshwater marsh will decrease 

the long-term persistence of Lower Keys marsh rabbits on refuge lands. 

Under Alternative B, an inventorying and monitoring plan would establish baseline data on the extent 

and health of the freshwater marsh ecosystem and focal species associated with this habitat type. 

Research on freshwater resources, including water quality and quantity and impacts of landscape 

alternations, would be conducted. Freshwater habitats would be restored and protected accordingly. 

The use of prescribed fire would be implemented and evaluated as a habitat management strategy 

for maintaining vegetation structure of freshwater marshes favored by Lower Keys marsh rabbits. 

The environmental consequences associated would Alternative B would be the same for 

Alternative C; however, more of the priority species associated with freshwater marsh would be 

addressed in the inventorying and monitoring plan and associated step-down plans. The use of 

mechanical and hand-clearing of vegetation would be evaluated as a habitat management 

strategy to maintain freshwater wetlands in the absence of prescribed fire. The impacts of sea 

level rise on this habitat type would be documented. 
110 Lower Florida Keys National Wildlife Refuges 

Salt Marsh 

Under Alternative A, salt marshes would continue to be impacted by hurricanes, storm surges, and 

sea-level rise. The role of prescribed fire as a management tool to mimic the effect of natural 

disturbance regimes on maintaining coastal salt marsh would not be evaluated. Continued loss of 

salt marshes would greatly decrease the long-term persistence of Lower Keys marsh rabbits on 

refuge lands. 

Under Alternatives B and C, an inventorying and monitoring plan would establish baseline data on the 

extent and health of salt marshes and top priority species associated with this habitat type. The use 

of prescribed fire would be implemented and evaluated as a habitat management strategy for 

maintaining vegetation structure of salt marshes favored by Lower Keys marsh rabbits. 

Under Alternative C, the use of mechanical and hand-clearing of encroaching over-story vegetation 

would be evaluated as a habitat management strategy to maintain coastal salt marshes in the 

absence of prescribed fire. The impacts of sea level rise on this habitat type would be documented. 

WILDLIFE AND PROTECTED SPECIES 

Under all alternatives, population monitoring of certain priority wildlife species would continue. 

Free-roaming cats would be trapped in or near Lower Keys marsh rabbit habitat to lessen the 

impact of this non-native predator. Translocation of Lower Keys marsh rabbits and Key deer 

would continue as warranted. Exotic pest plants would be eradicated or controlled to protect 

native plant and animal communities. 

Under Alternative A, the endangered Key tree cactus would remain in only a tiny area of the refuge 

that was severely flooded by storm surges from two recent hurricanes. The critically endangered 

Lower Keys marsh rabbit population would remain suppressed at an extremely low level—extirpation 

on Big Pine Key and other islands may occur. Assessment of the health and nutritional plane of the 

Key deer herd would be performed only irregularly and be insufficient to ensure that epizootic 

diseases are not proliferating. No measures would be taken to manage the Key deer at carrying 

capacity; at the current levels, high deer densities on Big Pine and No Name Key are impacting plant 

communities and thwarting natural ecological processes. Wildlife surveys would continue to be 

limited to only a few priority vertebrate species, thus knowledge of the biological community as a 

whole would remain limited. Assessment of the long-range impacts of sea level rise and the recent 

and future impacts of hurricanes on wildlife and their habitats would be limited to only a few species. 

Partnerships with academic, private, and government entities would continue at current levels. 

Under Alternative B, wildlife populations are expected to benefit from increased integration of their 

habitat needs into management. Wetland and upland restoration would be increased and priority 

lands would be acquired from willing sellers. The Key deer would be managed at carrying capacity 

using proven immuno-contraceptive practices on No Name and Big Pine Keys. This would foster 

natural plant community processes, increase plant diversity, and allow plant communities to recover 

from the adverse effects of the recurring high deer density of the past ten years. Nutritional indices 

would be monitored year-round by field necropsies of dead deer, with annual herd health checks by 

the Southeast Cooperative Wildlife Disease Study. Blood serum samples from selected dead and 

live deer would be collected for laboratory analyses. 

Key tree cactus habitat would be created in widely separated upland areas on Big Pine Key that are 

less vulnerable to flooding than that of the extant refuge population. Cactus would be propagated and 

planted in these sites to increase population size and distribution. Removal of encroaching buttonwood 
Section B. Environmental Assessment 111 

and prescribed burning would be implemented to enhance Lower Keys marsh rabbit habitat and 

maximize connectivity among restored habitats. These measures would be monitored to evaluate their 

effectiveness for increasing marsh rabbit numbers and to assess possible impacts on other wildlife 

species, as well as allow for adaptive management to occur. 

Prescribed burning in pine rockland tracts would be performed according to a fire management plan 

for National Key Deer Refuge, with pre- and post-burn monitoring performed to gauge plant and 

animal responses, particularly priority plant species, neotropical migratory birds, and rare butterflies. 

In areas too dangerous to burn because of nearby residences, mechanical clearing would be 

performed and results evaluated from both ecological and fire-safety perspectives. Throughout the 

refuge, greater monitoring of plant and associated animal communities would occur, with an 

emphasis on ecological processes and priority species. 

The monitoring of target species would provide important feedback to identify habitat needs and 

evaluate and improve management actions. Partnerships with academic, private, and government 

researchers would be expanded to better understand holistic plant/animal relationships in the refuge. 

Under all alternatives, the acquisition and protection of additional lands would provide important 

habitat for a diverse array of plant and animal species, including rare butterflies, Key deer, and 

reptiles. With an extremely limited land base and continued loss of habitat to development, this 

measure is critical for the long-term welfare of wildlife and plant species. Under Alternatives B and C, 

obtaining baseline information on ecosystem health would allow immediate and long-term effects of 

catastrophic events, such as hurricanes, to be more fully understood. Completion of an extensive 

biological and inventory monitoring plan would allow adaptive management processes to be practiced 

to benefit wildlife. Partnerships with private, academic, and other government agencies would 

increase under both alternatives. These partnerships would allow application of an interdisciplinary 

approach to addressing resource issues; something that cannot be achieved by the refuge alone. 

Mechanical clearing would be utilized in the wildland-urban interface to reduce the risk of wildfire 

spreading to residences. 

Under Alternative C, a permanent funding source would be sought for management of state- and 

county-owned lands managed by the refuge to reduce the financial and manpower burdens on limited 

refuge monetary and manpower resources. Currently, such lands cannot reach their management 

potential. As with Alternative A, the Key deer population would be regulated only by natural 

processes, such as diseases and hurricanes. As a result, plant communities would be adversely 

affected whenever carrying capacity is exceeded. 

Fire-prone habitats (pine rocklands) within the wildlife-urban interface would be allowed to naturally 

transition to a less flammable hardwood hammock. A study would be implemented to determine the 

ecological factors associated with the presence of extant Key tree-cactus on the refuge. Through a 

contractual partnership, a genetically diverse Lower Key marsh rabbit population numbering 100 or 

more animals would be established outside the Florida Keys to serve as a source for reintroduction in 

the wake of a catastrophic hurricane in the refuge. 

RESEARCH AND MONITORING 

As discussed in the previous section, research and monitoring provides information needed to 

conduct effective management of refuge habitats for the benefit of a diverse array of associated 

wildlife. Under Alternative A, little monitoring and almost no refuge-sponsored research would take 

place, thus providing little data to evaluate and improve management actions. 
112 Lower Florida Keys National Wildlife Refuges 

Alternative B provides for monitoring of priority species and species groups, thus providing the critical 

element to evaluate and improve management actions. As a result, the populations of these key 

species and species groups should respond assuming adequate habitat is available on the refuges. 

Under Alternative C, additional biological positions and contracts would greatly increase the 

monitoring of wildlife, especially mammals and priority birds not monitored under Alternative B. 

FIRE IMPACTS 

The refuge’s wildland and prescribed fire management program would perpetuate natural resources 

and their associated processes. The issues related to fire management are hazardous fuels, air 

quality, noxious weed response to prescribed burning, effects of prescribed fire on listed sensitive 

species, and escape of fire onto adjacent private lands. 

Under Alternative A, the prescribed fire management program would continue to be implemented 

sporadically as a habitat management tool in pine rockland habitats. Manual and mechanical fuel 

treatments have been initiated to accomplish hazardous fuel reduction on refuge property to provide 

defensible space around structures and bordering private lands. This is for the protection of both 

parties should a wildfire occur on private or refuge land in the wildland-urban interface. 

Fire-dependent habitats, including the globally imperiled pine rocklands, freshwater wetlands, and the 

saltmarsh/buttonwood transition community, would continue to be lost to successional processes. 

Numerous federally protected species, including but not limited to, Key deer, Lower Keys marsh 

rabbit, and several species of butterflies and plants which are candidates for federal protection are 

dependent upon these habitat types and their associated fire processes. 

Under Alternative B, prescribed fire would be used as a habitat management tool in various habitats 

with emphasis on benefiting priority species. Pine rocklands and coastal saltmarsh are dependent on 

disturbance regimes, such as fire, to maintain their specific habitat characteristics. Predictive 

modeling for fire management would be used. Adaptive management, using prescribed fire, would 

focus on top priority habitats and species. 

Under Alternative C, the prescribed fire program would continue to be implemented as a habitat 

management tool in pine rocklands. Mechanical- and hand-clearing would allow the Service to mimic 

the effects of fire or other disturbance while simultaneously reducing fuel levels. 

Under Alternatives B and C, education and outreach efforts would be greatly expanded to enhance 

the public’s understanding and awareness about the role of fire and fuel-reduction treatments in 

habitat management. 

Effects on Wilderness 

Under all alternatives, non-native plant species would continue to be controlled year-round. 

Incompatible uses in wilderness have been addressed through the proposed revisions to the 

compatibility determinations (Appendix F). 
Section B. Environmental Assessment 113 

Under Alternative A, overcrowding, non-wildlife dependent uses, and loss of wilderness character 

would continue to be a serious problem on Boca Grande Key. Over time, this would likely worsen 

there and increase at other beach sites in Key West NWR. With no limits set on visitation, 

trampling and degradation of dune vegetation would continue to occur--and likely increase--

promoting death or displacement of native species, including the endangered Garber’s spurge, by 

non-native grasses and forbs. Such damage would impact sea turtle nesting habitat and Miami 

blue butterfly foraging and nesting areas. 

Under Alternative B, during peak use holiday weekends (e.g., Memorial and Labor Days, July 4th) 

overcrowding on Boca Grande Key would be curtailed by closure of the beach. At other periods, at 

this and other refuge beaches in Key West NWR, carrying capacities would be established to curtail 

overcrowding and loss of wilderness character. If these measures prove ineffective or unfeasible to 

enforce, more stringent measures (seasonal or year-round closure) would be considered on a beachby-beach basis as a necessary measure to protect the sensitive dune areas, reduce disturbance to 

wildlife, and preserve wilderness character. 

Environmental education outreach efforts would be increased under Alternatives B and C to target 

wilderness area users and inform them about the importance and fragility of dune vegetation and to 

convey the tenets of responsible visitation to wilderness areas. 

Without inventories of natural resources, specific management for threatened and imperiled species 

cannot take place. Alternatives B and C would increase the refuges’ capability to protect and 

manage biological, wilderness, and cultural resources through increased inventorying and monitoring 

of habitats, species, and species groups. Increased law enforcement presence under both 

alternatives would be a deterrent to resource violations. 

EFFECTS ON RECREATION AND ENVIRONMENTAL EDUCATION AND INTERPRETATION 

FISHING 

Under all alternatives, the Service would promote resource protection by providing information on 

proper boating safety and fishing etiquette and through promotion and enforcement of the State’s 

saltwater fishing regulations. 

WILDLIFE OBSERVATION AND PHOTOGRAPHY 

Under Alternatives A and C, visitor facilities would continue to improve, including upgrading existing 

sites. Under Alternative B, existing facilities would be expanded and enhanced by linking the two 

trails in the Blue Hole area with a new trail. A wildlife observation platform and photography blind 

would be constructed at the Blue Hole. Under all alternatives, additional restrictions on beach access 

would be instituted in Key West NWR to protect turtle nesting areas, to reduce beach loss, to reduce 

conflicts among beach users, and to ensure that public use conforms to wilderness laws and policies. 

ENVIRONMENTAL EDUCATION AND INTERPRETATION 

Under Alternatives B and C, the new visitor center on U.S. Highway 1 would be open most days 

during the peak winter season and closed 2 to 4 days per week during the spring through fall 

season. Additional interpretive signs would be installed at a few other selected sites. With the 

new visitor center expecting to generate a 500 percent increase in annual visitation from 10,000 

visits to 50,000 visits, it is estimated that the Blue Hole visitation would double from 90,000 visits 

(taken from trail counter) to 180,000, and nature trail visits doubling from 60,000 (taken from trail 
114 Lower Florida Keys National Wildlife Refuges 

counter) to 120,000. The visitor center is not expected to generate additional vehicle traffic on U. 

S. Highway 1; the increased visitation is expected from existing traffic stopping at the facility. 

Since the existing parking area at the Watson and Mannilo Nature Trail is larger than current and 

projected demand, half of the lot would be restored to native habitat. 

Under Alternative B, the new visitor center would offer programs and extended hours during the peak 

visitor winter season. It would be open five days per week during the off season. Kiosks would be 

installed at a few selected trail sites. A program would be developed on the refuge on Big Pine Key. 

More outreach to Florida Keys communities would be offered. 

OTHER PERMITTED ACTIVITIES 

Under all alternatives, at National Key Deer Refuge there would be no decrease in horseback riding, 

walking, day hiking, rollerblading, and jogging. At Key West NWR, opportunities for sunbathing, fishing, 

and walking on the beaches would be reduced slightly due to more restrictions on holiday weekends. 

EFFECTS ON THE SOCIOECONOMIC ENVIRONMENT 

ECOTOURISM 

Visitors to national wildlife refuges bring substantial benefits to the local economy (Laughlin and Caudhill 

1997). Ecotourism generates millions of dollars from lodging, meals, gasoline, and ancillary purchases. 

Under Alternatives B and C, a new visitor center on U.S. Highway 1 would increase ecotourism to Big 

Pine Key, creating more revenue for local businesses, including the FAVOR Key deer book store. There 

would be more visitor traffic on the major island roads (Key Deer and Watson Boulevards) and a minor 

increase on community roads. The difference is due to staff and volunteers at the center encouraging 

visitors to stay on the main roads and not travel into communities. This could generate as much as 

30,000 more vehicles annually on Key Deer and Watson Boulevards. During the peak winter season, this 

may mean an additional 166 vehicles daily. The substantial increase in visitation to the Blue Hole and 

Nature Trails could degrade the quality of the visit. Under Alternative B, the new visitor center, with 

extended hours, might facilitate an increase in ecotourism revenue for the local businesses. 

TAX REVENUE 

Tax revenue is generated by the Florida Keys National Wildlife Refuges’ visitor center bookstore, 

which is operated by the non-profit FAVOR. During 2006, $1,766 in state sales revenue was 

generated. A newer, larger visitor center with extended hours, as proposed in Alternative B, would be 

likely to generate increases in sales and state tax revenue. 

UNAVOIDABLE IMPACTS 

Under Alternative A, exotic plants and animals would continue to reduce the biological function of 

natural communities. Biological and physical resources would not receive optimal protection. 

Declines in species diversity and population could result. Many would go unmonitored. 

There are certain impacts that are inherent to fire and would be present under all alternatives. 

Whether fires are wildland or prescribed, there is always an impact to air quality, although it may be 

temporary. The impacts vary due to the amount of fuels consumed and the time of year, but it should 

be minimal in all alternatives. 
Section B. Environmental Assessment 115 

EFFECTS COMMON TO ALL ALTERNATIVES

A few potential effects will be the same under each alternative and are summarized under these 

categories: health and safety, environmental justice, climate change, cultural resources, and refuge 

revenue sharing. 

HEALTH AND SAFETY 

Wildfires could have a negative effect on human health and safety. There is a chance of increased 

health effects associated with smoke from prescribed fire under all alternatives. Any increase in time 

for fire staff to be in the field increases the possibility of health effects or injuries to staff. 

REGULATORY 

As indicated in Section A, the Service must comply with a number of federal laws, executive and 

administrative orders, and policies in the development and implementation of management actions 

and programs. The alternatives would be in furtherance of these laws and orders. 

ENVIRONMENTAL JUSTICE 

Executive Order 12898, “Federal Actions to Address Environmental Justice in Minority Populations 

and Low-Income Populations” was signed by President Clinton on February 11, 1994, to focus 

federal attention on the environmental and human health conditions of minority and low-income 

populations, with the goal of achieving environmental protection for all communities. The order 

directed federal agencies to develop environmental justice strategies to aid in identifying and 

addressing disproportionately high and adverse human health or environmental effects of their 

programs, policies, and activities on minority and low-income populations. The order is also intended 

to promote nondiscrimination in federal programs substantially affecting human health and the 

environment, and to provide minority and low-income communities with access to public information 

and opportunities for participation in matters relating to human health or the environment. 

None of the management alternatives described in this environmental assessment will 

disproportionately place any adverse environmental, economic, social, or health impacts on minority 

and low-income populations. Implementation of any action alternative that includes public use and 

environmental education is anticipated to provide a benefit to the residents residing in the 

surrounding communities. 

CLIMATE CHANGE 

The U.S. Department of the Interior issued an order in January 2001 requiring federal agencies under 

its direction that have land management responsibilities to consider potential climate change impacts 

as part of long-range planning endeavors. 

The increase of carbon within the earth’s atmosphere has been linked to the gradual rise in surface 

temperatures commonly referred to as global warming. In relation to comprehensive planning for 

national wildlife refuges, carbon sequestration constitutes the primary climate-related impact to be 

considered in planning. The U.S. Department of Energy’s Carbon Sequestration Research and 

Development (U.S. Department of Energy 1999) defines carbon sequestration as “...the capture and 

secure storage of carbon that would otherwise be emitted to or remain in the atmosphere.” 
116 Lower Florida Keys National Wildlife Refuges 

The land is a tremendous force in carbon sequestration. Terrestrial biomes of all sorts—grasslands, 

forests, wetlands, tundra, perpetual ice, and desert—are effective both in preventing carbon emissions 

and in acting as a biological “scrubber” of atmospheric carbon monoxide. The conclusions of the 

Department of Energy’s report noted that ecosystem protection is important to carbon sequestration and 

may reduce or prevent the loss of carbon currently stored in the terrestrial biosphere. 

Conserving natural habitat for wildlife is the heart of any long-range plan for national wildlife refuges. 

The actions proposed in Alternatives B and C would conserve or restore land and water, and would 

thus enhance carbon sequestration. This, in turn, contributes positively to efforts to mitigate humaninduced global climate changes. 

CULTURAL RESOURCES 

All alternatives afford additional land protection and low levels of development, thereby producing little 

negative effect on the refuge’s cultural and historic resources. Potentially negative effects could be 

caused by the construction of new trails or facilities if they were inadvertently sited at a historic or 

archaeologic site. In most cases, these management actions would require review by the Service’s 

Regional Archaeologist in consultation with the State of Florida’s Historic Preservation Office, as 

mandated by Section 106 of the National Historic Preservation Act. Therefore, the determination of 

whether a particular action within an alternative has the potential to affect cultural resources is an ongoing process that would occur during the planning stages of every project. 

Service acquisition of land with known or potential archaeological or historical sites provides two 

major types of protection for these resources: protection from damage by federal activity and 

protection from vandalism or theft. The National Historic Preservation Act requires that any actions 

by a Federal agency which may affect archaeological or historical resources be reviewed by the State 

Historic Preservation Office, and that the identified effects must be avoided or mitigated. The 

Service’s policy is to preserve these cultural, historic, and archaeological resources in the public trust, 

and avoid any adverse effects wherever possible. 

REVENUE SHARING 

All refuge lands are within Monroe County Florida. Federal lands are not subject to state or local 

taxes or assessments; however, under the Revenue Sharing Act (16 USC 715s), the Service 

makes annual payments to counties to offset the loss of property tax revenues. In 2006, the 

Revenue Sharing check issued to Monroe County totaled $86,358--$70,967 for National Key 

Deer Refuge and $15,291 for Great White Heron NWR. 

CUMULATIVE IMPACTS 

A cumulative impact is defined as an impact on the natural or human environment, which results from 

the incremental impact of the proposed action when added to other past, present, and reasonably 

foreseeable future actions regardless of which agency (federal or non-federal) or person undertakes 

such other actions (40 CFR 1508.7). 

Cumulative impacts are the overall, net effects on a resource that arise from multiple actions. 

Impacts can “accumulate” spatially, when different actions affect different areas of the same 

resource. They can also accumulate over the course of time, from actions in the past, the 

present, and the future. Occasionally, different actions counterbalance one another, partially 

canceling out each other’s effect on a resource. But more typically, multiple effects add up, with 

each additional action contributing an incremental impact on the resource. In addition, 
Section B. Environmental Assessment 117 

sometimes the overall effect is greater than merely the sum of the individual effects, such as 

when one more reduction in a population crosses a threshold of reproductive sustainability, and 

threatens to extinguish the population. 

A thorough analysis of impacts always considers their cumulative aspects, because actions do not 

take place in a vacuum: there are virtually always some other actions that have affected that 

resource in some way in the past, or are affecting it in the present, or will affect it in the reasonably 

foreseeable future. So any assessment of a specific action’s effects must in fact be made with 

consideration of what else has happened to that resource, what else is happening, or what else will 

likely happen to it. 

The Service is not aware of any past, present, or future planned actions that would result in 

significant cumulative impacts when added to the refuge’s proposed actions, as outlined in the 

proposed alternative. 

MITIGATION MEASURES

The following are proposed to mitigate and minimize potential adverse effects resulting from the 

implementation of the proposed action: 

USER GROUP CONFLICTS 

Compatibility determinations are proposed for all compatible wildlife-dependent uses (Appendix F). 

As public use increases, unanticipated conflicts between different user groups could occur. If this 

should happen, the refuge will adjust its programs, as needed, to eliminate or minimize any public 

use issues. The refuge will use methods that have proven to be effective in reducing or eliminating 

public use conflicts. These methods include establishing separate use areas, different use periods, 

and limits on the numbers of users in order to provide safe, quality, appropriate, and compatible 

wildlife-dependent recreational opportunities. 

WATER QUALITY FROM SOIL DISTURBANCE AND USE OF HERBICIDES 

Soil disturbance and siltation due to road and trail maintenance; and the construction of observation 

platform, maintenance and staff quarters, and a visitor center is expected to be minor and of short 

duration. To further reduce potential impacts, the refuge will use best management practices to 

minimize the erosion of soils into water bodies. 

Foot traffic on new and extended foot trails is expected to have a negligible impact on soil 

erosion. Effects on soils in pine rocklands would be negligible since soils are largely absent. 

Foot traffic may cause minor rutting and compaction of soils in coastal marsh habitat, although 

this is not where trails are typically sited. To minimize the impacts from public use, the refuge will 

include informational signs that request trail users to remain on the trails, in order to avoid 

causing potential erosion problems. 

Long-term herbicide use for exotic plant control could result in a slight decrease in water quality 

in areas prone to exotic plant infestation. Through the proper application of herbicides, however, 

this is expected to have a minor impact on the environment, with the benefit of reducing or 

eliminating exotic plant infestations. 
118 Lower Florida Keys National Wildlife Refuges 

VEGETATION DISTURBANCE 

Negative impacts could result from the creation, extension, and maintenance of trails that 

require the clearing of non-sensitive vegetation along their length. This is expected to be a 

minor short-term impact. 

Increased visitor use may increase the potential for the introduction of new exotic species into areas 

when visitors do not stay on trails. The refuge will minimize this impact by installing informational 

signs that request users to stay on the trails. 

WILDLIFE DISTURBANCE 

Disturbance to wildlife is an unavoidable consequence of any public use program, regardless of the 

activity involved. While some activities, such as wildlife observation, may be less disturbing than 

others, all of the public use activities proposed under the proposed alternative will be planned to 

avoid unacceptable levels of impact. 

The known and anticipated levels of disturbance from the proposed alternative are not considered to 

be significant. Nevertheless, the refuge will manage public use activities to reduce impacts. 

Providing access for fishing opportunities allows the use of a renewable natural resource without 

adversely impacting other resources. General wildlife observation may result in minimal disturbance 

to wildlife. If the refuge determines that impacts from the expected additional visitor uses are above 

the levels that are anticipated, those uses will be discontinued, restricted, or rerouted to other less 

sensitive areas. 

EFFECTS ON ADJACENT LANDOWNERS 

Implementation of the proposed alternative is not expected to negatively affect the owners of private 

lands adjacent to the refuge. Positive impacts that would be expected include higher property values, 

less intrusion of invasive exotic plants, and increased opportunities for viewing more diverse wildlife. 

However, some negative impacts that may occur include a higher frequency of trespass onto 

adjacent private lands, and noise associated with increased traffic. To minimize these potential 

impacts, the refuge will provide informational signs that clearly mark refuge boundaries, maintain the 

refuge’s existing parking facilities, use law enforcement, and provide increased educational efforts at 

the visitor center. 

LAND OWNERSHIP 

Land acquisition efforts by the Service could lead to changes in land use and recreational use 

patterns. However, most of the non-Service-owned lands within the refuge’s approved acquisition 

boundary are currently undeveloped. If these lands are acquired as additions to the refuge, they 

would be maintained in a natural state, managed for native wildlife populations, and opened to 

wildlife-compatible public uses, where feasible. 

SITE DEVELOPMENT 

Potential development of the buildings, trails, and other improvements could lead to minor short-term 

negative impacts on plants, soil, and some wildlife species. New construction will use recycled and 

environmentally sensitive materials as much as possible. The new visitor center and proposed 
Section B. Environmental Assessment 119 

wildlife observation platform will be constructed with materials that fit into the local architectural 

scheme. All construction will conform to applicable federal and state law and county ordinances. 

SHORT-TERM USES VERSUS LONG-TERM PRODUCTIVITY 

The habitat protection and management actions proposed under the proposed alternative are 

dedicated to maintaining the long-term productivity of refuge habitats. The benefits of this plan for 

long-term productivity far outweigh any impacts from short-term actions, such as the construction of 

observation towers and a visitor center, or creation of new trails. While these activities would cause 

short-term negative impacts, the educational values and associated public support gained from the 

improved visitor experience would produce long-term benefits for the refuge’s entire ecosystem. 

The key to protecting and ensuring the refuges’ long-term productivity is to find the threshold where 

public uses do not degrade or interfere with the refuges’ natural resources. The proposed alternative 

has been carefully conceived to achieve that threshold. Therefore, implementing the proposed 

alternative would lead to long-term benefits for wildlife protection and land conservation that far 

outweigh any short-term effects. 

SUMMARY STATEMENT 

Beneficial, but no significant effects are expected for refuge resources with the implementation of the 

proposed alternative. 
120 Lower Florida Keys National Wildlife Refuges 
Section B. Environmental Assessment 121 

V. Coordination and Consultation 

OVERVIEW 

This chapter summarizes the consultation and coordination that has occurred to date in 

identifying the issues and alternatives, which are represented in this Draft CCP/EA. It lists the 

meetings that have been held with various agency representatives and the individuals who were 

involved in writing the Draft CCP/EA. Several teams and advisory groups were involved in the 

CCP planning process with representation from the Service, the Florida Fish and Wildlife 

Conservation Commission, and others as listed below. 

BIOLOGICAL REVIEW 

A biological review was conducted in 2005. It consisted of Service and State employees and invited 

research experts. The team provided recommendations for management actions based on the most 

current knowledge of refuge resources. Members of the team included: 

Chuck Hunter, Chief, Division of Planning and Resource Management, FWS, Region 4 

Dean Demarest, former Assistant Migratory Birds Coordinator, FWS, Region 4 

Steve Earsom, former Regional Refuge Ecologist, FWS, Region 4 

Ken Meyer, Ph.D., Researcher, Avian Research and Conservation Institute, Gainesville, FL 

Phil Frank, Ph.D., former Project Leader, Florida Keys NWR Complex 

Steve Klett, Refuge Manager, Crocodile Lake NWR 

Van Fischer, former Natural Resources Planner, Florida Keys NWR Complex 

Randy Grau, Manager, Florida Keys Wildlife and Environmental Areas, FWC 

Chris Bergh, Director, Florida Keys Program, The Nature Conservancy 

William Miller, former Deputy Refuge Manager, Florida Keys NWR Complex 

Tom Wilmers, Wildlife Biologist, Florida Keys NWR Complex 

Neil Perry, Graduate Student, TAMU 

VISITOR SERVICES AND PUBLIC USE REVIEW 

A public use review was conducted in 2003. The team consisted of the following Service regional 

staff, and current and former staff: 

Garry Tucker, Visitor Services Coordinator, FWS, Region 4 

Dorn Whitmore, Assistant Refuge Manager, Merritt Island NWR 

Jane Whaley, former Park Ranger, Piedmont NWR 

James Bell, Park Ranger/Visitor Services, Florida Keys NWR Complex 

Phil Frank, Ph.D., former Project Leader, Florida Keys NWR Complex 

Van Fischer, former Natural Resources Planner, Florida Keys NWR Complex 

WILDERNESS REVIEW 

A review of the refuges’ wilderness areas and potential wilderness study areas was conducted by the 

CCP planning team on August 21, 2006, and included the following team members: 

Mary Morris, Natural Resources Planner, St. Marks NWR 

Anne Morkill, Project Leader, Florida Keys NWR Complex 
122 Lower Florida Keys National Wildlife Refuges 

Lester Pulley, Zone Officer, former Lead Refuge Law Enforcement Officer, 

Florida Keys NWR Complex 

James Bell, Park Ranger/Visitor Services, Florida Keys NWR Complex 

Thomas Wilmers, Wildlife Biologist, Florida Keys NWR Complex 

Paige Schmidt, Wildlife Biologist Trainee, Florida Keys NWR Complex 

FIRE MANAGEMENT PROGRAM REVIEW 

In February 2007 an interagency team was convened to discuss the Service’s fire management 

program for National Key Deer4 Refuge. The following persons attended: 

Thomas Wilmers, Wildlife Biologist, Florida Keys NWR Complex 

David Brownlie, Regional Fire Ecologist, FWS, Region 4, Tallahassee, FL 

Kathy O’Reilly-Doyle, Partners for Fish and Wildlife, FWS, Florida Panther NWR 

Jim Durwachter, former Fire Management Officer, FWS 

Jon Wallace, Prescribed Fire Specialist, FWS, Loxahatchee NWR 

Josh O’Conner, Forestry Fire Technician, FWS, Florida Panther NWR 

Mary Morris, Natural Resources Planner, St. Marks NWR 

Anne Morkill, Project Leader, Florida Keys NWR Complex 

Paige Schmidt, Wildlife Biologist Trainee, Florida Keys NWR Complex 

Phillip Hughes, Endangered Species Biologist, FWS, Ecological Services’ Office 

PLANNING TEAM 

The Comprehensive Conservation Planning Team (Planning Team) met regularly between August 

2006 and July 2007, and was comprised of the following staff and former staff: 

Mary Morris, Natural Resources Planner and Planning Team Leader 

Anne Morkill, Project Leader 

Jim Wigginton, Deputy Project Leader 

Thomas Wilmers, Wildlife Biologist 

Lester Pulley, Zone Officer, former Lead Refuge Law Enforcement Officer until summer 2007 

Steven Berger, Law Enforcement Officer 

James Bell, Park Ranger/Visitor Services 

Paige Schmidt, Wildlife Biologist Trainee 

Phillip Hughes, Endangered Species Biologist, FWS, Ecological Services 

Paul Stevko (Forestry Fire Technician, participated on Planning Team during the fall of 2006) 

TRIBAL COORDINATION 

The Miccosukee and Seminole Tribes were notified in of the comprehensive conservation planning 

process in 2003, with the announcement of planning for the Crocodile Lake NWR CCP and were 

given the opportunity to participate and comment. The Tribal Chief of the Miccosukee Tribe asked to 

have two copies of any CCP report sent to his two liaisons. 
Appendices 123 

APPENDICES 

Appendix A. Glossary and Acronyms 

A & M or TAMU Texas Agricultural and Mechanical University 

Adaptive management The rigorous application of management, research, and 

monitoring to gain information and experience necessary to 

assess and modify management activities. A process that uses 

feedback from refuge research and monitoring and evaluation of 

management actions to support or modify objectives and 

strategies at all planning levels. 

Alternative A set of objectives and strategies needed to achieve refuge 

goals and the desired future condition. 

Arboreal Of or like a tree or adapted for living in trees. 

Areal A measurement relating to the extent of an area across a 

surface plane, such as the earth. 

Anadromous Fish that move from salt water to fresh water for reproduction. 

Approved acquisition boundary A project boundary which the Director of the Fish and Wildlife 

Service approves upon completion of the detailed planning and 

environmental compliance process. 

Backcountry Management Plan Common name for the Management Agreement for Submerged 

Lands within Boundaries of the Key West and Great White 

Heron National Wildlife Refuges, which gives the Service certain 

authorities within state-owned water surrounding island refuges. 

BMP Best Management Practice – land use practices that prevent or 

minimize pollution or soil erosion. 

Bio-accumulation The process in which industrial waste, toxic chemicals or 

pesticides gradually accumulates in living tissue, or in the food 

web/chain. 

Biomass The total mass, or the amount of living material, in a particular 

area. 

Biological diversity The variety of life forms and its processes, including the variety 

and relative abundances of living organisms, the genetic 

differences among them, and the communities and ecosystems 

in which they occur. 
124 Lower Florida Keys National Wildlife Refuges 

Biological integrity The biotic composition, structure, and functioning at genetic, 

organism, and community levels comparable with historic 

conditions, including the natural biological processes that shape 

genomes, organisms, and communities. 

Biota The plant and animal life of a region. 

BTI Bacillus thuringiensis Israelis, a selective, microbial insecticide 

applied in breeding areas to be ingested by larval mosquitoes as 

a control agent. 

Buffer A multi-use transitional area designed and managed to protect 

core reserves and critical corridors from increased development 

and human activities that are incompatible with habitat and/or 

wildlife values. In this document, agricultural lands are also 

considered buffer lands. 

Canopy A layer of foliage; generally the upper-most layer in a forest 

stand. It can be used to refer to mid- or under-story vegetation 

in multi-layered stands. Canopy closure is an estimate of the 

amount of overhead tree cover (also canopy cover). 

Category I The Florida Exotic Pest Plant Council has developed ranking 

categories to classify the threat of exotic plants to the natural 

environment. Category I species are those that have caused 

ecological damage by invading and disrupting native plant 

communities in Florida. 

Category II Invasive exotics that have increased in abundance or frequency, 

but have not yet altered Florida plant communities to the extent 

shown by Category I species. 

CFR Code of Federal Regulations 

Commensal species A close union or relationship between organisms or species 

where one is benefited by the relationship and the other is 

neither benefited nor harmed. 

Compatible use An appropriate, wildlife-dependent recreational use or any other 

use on a refuge that is within the mandates laid down in the 

National Wildlife Refuge System Improvement Act of 1997. The 

refuge manager may also determine if an activity will or will not 

materially interfere with or detract from the fulfillment of the 

mission of the Refuge System or the purposes of the refuge. 

Comprehensive Conservation Plan A document that describes the desired future conditions 

CCP of a refuge or other planning unit. It provides long-range 

guidance and management direction in order to promote the 

purposes of the refuge, contribute to the mission of the refuge 

system and to meet other relevant mandates. 
Appendices 125 

Conservation Easement A legal agreement between a landowner and a land trust (a 

private, nonprofit conservation organization) or government 

agency that permanently limits the use of a property in order to 

protect its conservation value. 

Cooperative Agreement A legal instrument used when the principle purpose of the 

transaction is the transfer of money, property, services or 

anything of value to a recipient in order to accomplish a public 

purpose authorized by federal statute. 

Cultural resources The physical remains of human activity (e.g., artifacts, ruins and 

burial mounds) and conceptual content or context (as a setting 

for legendary, historic, or prehistoric events, such as a sacred 

area of native peoples) of an area. It includes historically, 

archaeologically, and/or architecturally significant resources. 

Diameter at Breast Height The diameter of a tree at breast height (4.5 feet above ground). 

DBH 

Detrital Debris; material originating from debris. 

District Monroe County Mosquito Control District 

Ecosystem A dynamic and interrelated complex of plant and animal 

communities and their associated non-living environment. 

Ecosystem management The practice of wildlife and habitat management in the context of 

the natural ecosystem or ecosystems being managed, with the 

goal of conserving or restoring the system to its natural state. 

Management of an ecosystem that includes all ecological, 

social, and economic components which make up the whole of 

the system. 

Endangered species Any species of plant or animal defined through the federal 

Endangered Species Act as being in danger of extinction 

throughout all or a significant portion of its range. The State of 

Florida has its own designation and list under the Florida Wildlife 

Code Title 68A, Florida Administrative Code. 

Endemic species Plants or animals that occur naturally in a certain region and 

whose distribution is relatively limited to a particular locality. 

Environmental Assessment A systematic analysis to determine if proposed 

EA actions would result in a significant effect on the quality of the 

environment. 

Environmental health The composition, structure and functioning of soil, water, air and 

other abiotic (non-living) features compared with historic 

conditions, including the natural abiotic processes that shape 

the environment. 
126 Lower Florida Keys National Wildlife Refuges 

Ephemeral Short lived or transitory. 

Episodic Divided into episodes or periods. 

Estuarine Pertaining to an estuary, a semi-enclosed body of water with a 

significant freshwater source and a free connection with the 

ocean. 

Extant Still in existence. 

Executive Order - EO A legally binding edict issued by the executive branch of the 

government. 

Extirpation The abolishment or extermination of a species. 

Exotic species A non-indigenous or alien plant or animal species, or one 

introduced to this state, either purposefully (horticulture trade) or 

accidentally that escaped into the wild where it reproduces on its 

own, either sexually or asexually. Any introduced plant or 

animal species that is not native to the area and may be 

considered a nuisance. 

FAVOR The refuges non-profit support organization, Friends and 

Volunteers of Refuges 

FCAT Florida Comprehensive Assessment Test 

FDEP Florida Department of Environmental Protection 

FWC Florida Fish and Wildlife Conservation Commission 

Fee title acquisition The acquisition of most or all of the rights to a tract of land. 

There is a total transfer of property rights with the formal 

conveyance of a title. While a fee title acquisition involves most 

rights to a property, certain rights may be reserved or not 

purchased, including water rights, mineral rights, or use 

reservation (the ability to continue using the land for a specified 

time period, or the remainder of the owner’s life). 

Feral A wild, free-roaming domestic animal which has become 

established as a breeding population. 

Finding of No Significant Impact - A document prepared in compliance with the 

FONSI National Environmental Policy Act, supported by an 

environmental assessment that describes why a federal action 

will have no significant effect on the human environment. 

FKNMS Florida Keys National Marine Sanctuary – a marine protection 

program jointly administered by the federal and state 

governments, i.e., the National Oceanic and Atmospheric 

Administration and the FDEP. 
Appendices 127 

Forbs Broad-leafed, flowering plants as distinguished from the grasses 

and sedges. 

FPS Florida Park Service, part of the FDEP 

Fragmentation The process of reducing the size and connectivity of habitat 

areas. The disruption of extensive habitats into small and/or 

isolated patches 

FTE Full-time equivalent; relating to an employment position 

FWS The U. S. Fish and Wildlife Service also known as the Service or 

FWS. 

Fuel Living and dead plant material that is capable of burning. 

Geographic Information System - A computer based system for the collection, processing and 

GIS managing of spatially referenced data. GIS allows for the 

overlay of many data layers and provides a valuable tool for 

addressing resource management issues.

Goal A descriptive, open-ended and often broad statement of desired 

future conditions that conveys a purpose, but does not define 

measurable units. 

Habitat The native environment of a plant or animal. 

Herbicide A chemical agent used to kill plants or inhibit plant growth. 

Homeostatically Maintaining the status of equilibrium. 

Hydric A term used to define a habitat based on soil moisture 

conditions. Hydric habitats are those which regularly flood for at 

least a portion of a typical year. 

Hydrological Involving water flows or their distributions as related to 

evaporation, or flow to wetlands, springs, aquifers, seas, 

estuaries, etc. 

Hydrology The scientific study of the properties, distribution, and effects of 

water in the atmosphere, on the earth’s surface, and in soil and 

rocks. 

Hydroperiod The seasonal pattern of the water level typical for a given 

wetland. The residence (retention) time that water spends in a 

wetland. 

Improvement Act of 1997 The National Wildlife System Improvement Act of 1997 (see 

Appendix C. Legal Mandates) 
128 Lower Florida Keys National Wildlife Refuges 

Indicator species A species which, in the context of the surrounding landscape, or 

in comparison with related communities, seems to be most 

indicative of the particular community. 

In-holding Privately owned land inside the boundary of the refuge. 

Intertidal The area of shoreline between low and high tides. 

In-situ In position; it its original place. 

Invasive exotic species Non-native species which have been introduced into an 

ecosystem, and, because of their aggressive growth habits and 

lack of natural predators, displace native species. 

Keystone species A species whose presence is important to the health and proper 

functioning of a biotic community or ecosystem. 

LE Law Enforcement 

Listed species Any species of fish, wildlife, or plant that has been determined to 

be at risk by a state or the federal government. In this 

document, at risk may include threatened, endangered, species 

of special concern, species of management concern, or species 

included in the Convention on International Trade in 

Endangered Species. 

LKMR Lower Keys marsh rabbit, a native, highly-endangered species 

LOOT LOOT is the acronym for the Listing of Outlaw Treachery 

Information Clearinghouse which is maintained by the National 

Park Service. It contains voluntarily submitted summary records 

of prosecuted cases in hardcopy files and computerized 

database formats. Any federal agency may adopt the LOOT 

form as part of their program to comply with Section 14 (c) of the 

Archaeological Resources Protection Act. 

Management Agreement Management Agreement for Submerged Lands within 

Boundaries of the Key West and Great White Heron National 

Wildlife Refuges, also known as the Backcountry Management 

Plan. 

Marshbirds A term that encompasses non-colonial, non-waterfowl aquatic 

species including loons, bitterns, non-colonial grebes, rails, 

gallinules, coots, limpkin and cranes. They are often secretive 

and feed primarily in fresh waters. 

Memorandum of Understanding - A voluntary agreement between two partnering 

MOU agencies. 
Appendices 129 

Mesic Pertaining to habitat requiring moderate amounts of moisture in 

the soil. Moisture is readily available for use by vegetation and 

the sites may flood in short durations. 

Midden A slightly elevated mound composed of shell fragments and 

other debris left as waste by indigenous people; shell mounds 

found throughout the ecosystem constructed by indigenous 

people. 

Migrant passerine Of or relating to the order of Passeriformes of small or mediumsized, chiefly perching songbirds having grasping feet with the 

first toe directed backwards. 

Migration The seasonal movement of an animal from one area to another 

and back. 

Mitigation or to mitigate Avoiding or minimizing the impacts of an action. 

Monitoring The process of collecting information to track changes of 

selected parameters over time. 

National Environmental Policy Act - Requires all federal agencies, including the 

NEPA Service, to examine the environmental impacts of their actions, 

incorporate environmental information, and use public 

participation in the planning and implementation of all actions. 

Federal agencies must integrate this Act with other planning 

requirements, and prepare appropriate policy documents to 

facilitate better environmental decision making. 

National Wildlife Refuge - NWR A designated area of land or water, or and interest in land or 

water, within the National Wildlife Refuge System. 

National Wildlife Refuge System A national network of lands and waters 

or System administered for the conservation, management and, where 

appropriate, restoration of the fish, wildlife, and plant resources 

and their habitats within the United States for the benefit of 

present and future generations of Americans. 

Native Species A species already occurring in Florida at the time of European 

contact (1500 AD). With respect to a particular ecosystem, a 

species that, other than as a result of an introduction, historically 

occurred or currently occurs in that ecosystem. 

Naturalized exotic species An exotic that sustains itself outside cultivation. 

Neotropical migratory birds Birds that migrate from North America back and forth to South or 

Central America. These birds usually breed in the United States 

or Canada and winter in Mexico, the Caribbean, or Central or 

South America. 
130 Lower Florida Keys National Wildlife Refuges 

Objective A concise statement of what we want to achieve, how much we 

want to achieve, when and where we want to achieve it, and 

who is responsible for the work. Objectives derive from goals 

and provide the basis for determining strategies, monitoring 

refuge accomplishments and evaluating the success of 

strategies. 

OSHA Federal Occupational Safety and Health Administration 

Partnership A mutually beneficial, joint relationship between two agencies or 

an agency and a landowner, etc. 

Prescribed fire A planned or intentional fire set by resource land managers to 

improve or restore wildlife habitat and reduce potentially 

dangerous fire fuel loads. It is also known as a controlled burn. 

Priority public uses As identified in the National Wildlife Refuge System 

Improvement Act of 1997, these are the six priority public uses 

allowed on a refuge when compatible with the purposes of the 

refuge, the mission of the Refuge System and each other: 

hunting, fishing, wildlife observation, wildlife photography, and 

environmental education and interpretation. 

Proposed alternative The Service’s alternative identified in an environmental 

assessment that best achieves the refuge purpose and vision, 

contributes to the Refuge System mission, addresses 

significant issues, and is consistent with sound wildlife and 

habitat management. 

Refuge Operating Needs A national database which contains the unfunded 

System - RONS operational needs of each refuge. Projects included are those 

required to implement approved plans and meet goals, 

objectives, and legal mandates. 

Refuge Purposes The purposes specified in or derived from the laws, 

proclamations, executive orders or administrative 

memorandums establishing, authorizing or expanding a refuge. 

Restoration Management actions to return a vegetative community or 

ecosystem to its original, natural condition. To bring a disturbed 

site or an area changed from its native state back to its historic 

structure, including water regimes, plant community, and wildlife 

components. In this document, restoration can refer to exotic 

plant removal, planting native plants, and/or reintroductions of 

native plants or animals. 

RV A recreational vehicle that can be lived in, such as a motor 

coach or camper. 
Appendices 131 

Scoping or Public Scoping A process for determining the scope of issues to be addressed 

by a comprehensive conservation plan and for identifying priority 

issues. Involved in the scoping process are federal, state, and 

local agencies, private organizations, and individuals. 

Service Asset Maintenance and A national database and accounting system used 

Management Systems - SAMMS by refuges to document expenditures for the maintenance and 

management of facilities and equipment. 

Service or FWS U.S. Fish and Wildlife Service; the federal agency, under the 

Department of the Interior, which guides the management of the 

refuge. 

Shorebirds Any of a large group of birds commonly called sandpipers and 

plovers, but also including others, such as gulls, terns, 

skimmers, oystercatchers, avocets and stilts. Typically found 

along the shorelines of oceans, rivers and lakes, they are 

commonly characterized by long bills, legs and toes. 

Species A group of organisms all of which have a high degree of physical 

and genetic similarity, generally interbreed only among 

themselves, and show persistent differences from members of 

allied groups of organisms. Species have an independent 

evolutionary lineage. 

Step-down management plans Specific, program-area plans which provide the details 

necessary to implement management strategies and projects 

identified in the comprehensive conservation plan. 

Strategy A specific action, tool, technique or combination of these used to 

meet objectives. 

Subtidal An area of shoreline below the tides. 

Threatened species Those plant or animal species listed under the federal 

Endangered Species Act that are likely to become endangered 

throughout all or a significant portion of their range within the 

foreseeable future. The State of Florida has its own designation 

and list under Chapters 68A-27 (animals) and 5B-40 (plants), 

Florida Administrative Code. 

Trust species Animal and plant species that are federal responsibility and 

include migratory birds, threatened and endangered species, 

anadromous fish, and certain marine mammals. The term is 

broadly used in this document to include federal, state, and 

internationally listed species, including threatened and 

endangered species, species of special concern, and species of 

management concern. 

USF University of South Florida located in Tampa, Florida. 
132 Lower Florida Keys National Wildlife Refuges 

Vegetation Plants in general, or the sum total of the plant life in an area. 

Wading birds Long-legged birds that wade in fresh or brackish water in search 

of food, including herons, egrets, bitterns, ibis, storks, 

spoonbills, flamingos, and cranes. 

Waterfowl Ducks, geese, and coots. 

Wetland Areas such as lakes, marshes, and streams that are 

inundated by surface or ground water for a long enough 

period of time each year to support, and do support under 

natural conditions, plants and animals that require saturated 

or seasonally saturated soils. 

Wilderness Area Congress defined Wilderness in the Wilderness Act as “...an 

area where the earth and its community of life are 

untrammeled by man, where man himself is a visitor who 

does not remain....an area without permanent improvements 

or human habitation, which is protected and managed so as 

to preserve its natural conditions and which (1) generally 

appears to have been affected primarily by the forces of 

nature, with the imprint of man’s work substantially 

unnoticeable; (2) has outstanding opportunities for solitude or 

a primitive and unconfined type of recreation...”. 

Wildfire An uncontrolled fire started naturally by lightning or 

accidentally/intentionally by man. 

Wildlife-dependent recreation The public uses of hunting, fishing, wildlife observation, wildlife 

photography, and environmental education and interpretation.

 

Wildlife management The art and science of producing, maintaining, benefiting, and/or 

enhancing wildlife populations and their associated habitats. 

Wildland-urban Interface - WUI The condition that develops as residential development expands 

into rural (primarily forested) landscapes, creating special fire 

hazards and fire management problems. 
Appendices 133 

Appendix B. References and Literature Cited 

Alexander, Taylor R. and John H. Dickson, III. 1970. Vegetational Changes in the National Key Deer 

 Refuge. Quarterly Journal of the Florida Academy of Sciences 33(2):81-89. 

Alexander, Taylor R. and John H. Dickson, III. 1972. Vegetational Changes in the National Key Deer 

 Refuge-II. Quarterly Journal of the Florida Academy of Sciences 35(2):85-96. 

Bancroft, G. T. and Reed Bowman. 1994. Temporal Patterns in the Diet of Nestling 

 White-crowned Pigeons: Implications for Conservation of frugivorous 

 Columbids. Auk 111: 844-852. 

Bancroft, T.G., A.M. Strong, and M. Carrington. 1995. Deforestation and its Effect on 

 Forest-nesting Birds in the Florida Keys. Conservation Biology 9: 835-844. 

Bohnsack, J.A., et al., 1998. Baseline Data for Evaluating Reef Fish Populations in the 

 Florida Keys, 1979 – 1998, NOAA Technical Memorandum NMFS-SEFC-427. 

Carter, R.W. et al. 1990a. The Study of Coastal Dunes. In Coastal Dunes, Form and 

 Process. K.N. Nordstrum, et al. (eds.) John Wiley and Sons, New York, New York. 

Caudill, James and Erin Henderson. September 2005. Banking on Nature: The Economic Benefits 

 to Local Communities of National Wildlife Refuge Visitation, Arlington, Virginia. 

Cooley, Hillary C. 2004. Palm fuel dynamics in fire-sustained pine forests in the Florida Keys. 

 Masters Thesis, Florida International University, Miami, Florida. 

Dickson, John D. III. 1955. An Ecological Study of the Key Deer. Technical Bulletin #3, Federal Aid 

 Project W-34-R. Florida Game and Freshwater Fish Commission. 

Faulhaber, Craig A., et al., 2006. Reintroduction of Lower Keys Marsh Rabbits. 

Wildlife Society Bulletin. 34(4): 1198-1202. 

Florida Department of Environmental Regulation (now Environmental Protection). 1985. 

 Proposed Designation of the Waters in the Florida Keys as Outstanding Florida 

 Waters. DER, Tallahassee, Florida. 

Florida Department of Environmental Regulation. 1987. Florida Keys Monitoring Study, 

 Water Quality Assessment of Five Selected Pollutant Sources in Marathon, Florida 

 Department of Environmental Regulation (now Protection), Marathon, Florida. 

Folk, M. L. 1991. Habitat of the Key Deer. Dissertation, Southern Illinois University, 

 Carbondale, Illinois. 

Folk, M. L. et al. 1991. Habitat Evaluation: National Key Deer Refuge. Florida Game 

 and Fresh Water Fish Commission Final Report NG88-015. 

Gallagher, D. 1997. The Florida Keys Environmental Story. Seacamp Association, Inc. 

 Marathon, Florida. 
134 Lower Florida Keys National Wildlife Refuges 

Gann, G. D. et al. 2001-2007. 2007a. National Key Deer Refuge in the Floristic 

 Inventory of South Florida Database Online. The Institute for Regional Conservation, Miami. 

Viewed February 16, 2007. Internet: 

http://www.regionalconservation.org/ircs/database/plants/ByConsArea.asp?SiteID=698&SN=

National%20Key%20Deer%20Refuge. 

Gann, G. D. et al. 2001-2007. 2007b. Great White Heron National Wildlife Refuge 

 In The Floristic Inventory of South Florida Database Online. The Institute for 

 Regional Conservation, Miami. Viewed February 16, 2007. Internet: 

http://www.regionalconservation.org/ircs/database/plants/ByConsArea.asp?SiteID=394&SN= 

 Great%20White%20Heron%20National%20Wildlife%20Refuge. 

Gann, G. D. et al. 2001-2007 .2007c. Key West National Wildlife Refuge in The 

 Floristic Inventory of South Florida Database Online. The Institute for Regional 

 Conservation, Miami. Viewed February 16, 2007. Internet: 

http://www.regionalconservation.org/ircs/database/plants/ByConsArea.asp?Site

 ID=544&SN=Key%20West%20National%20Wildlife%20Refuge. 

Hoffmeister, J. E. 1974. Land from the Sea, the Geologic Story of South Florida. 

 University of Miami Press, Coral Cables, Florida. 

Jordan, B. 1991. Weather and Climate of the Florida Keys. In The Monroe County 

 Environmental Story. Gato, J. and Gallagher, D. eds. Seacamp Association, Inc. 

 Marathon, Florida. 

Kimmerer, R. W. and F. K. Lake. 2001. Maintaining the Mosaic: The Role of Indigenous Burning in 

 Land Management. Journal of Forestry 99:36-41. 

Klimstra, W. D. 1986. Controlled Burning in Habitat Management: Some Observations. National 

Key Deer Refuge. 

Kruczynski, W.L. 1999. Water Quality Concerns in the Florida Keys: Sources, Effects 

 and Solutions. Report to the Florida Environmental Regulatory Commission. 

 Tallahassee, Florida. 

Langevin, C. D. et al. 1998. Effects of Sea Water Canals on Fresh Water Resources: An 

 Example from Big Pine Key, Florida. Ground Water 36(3): 503-513. 

 

Lapointe, B. E. and M. W. Clark. 1990. Final report: Spatial and Temporal Variability in 

 Tropic State of Surface Waters in Monroe County During 1989-1990. Florida 

 Keys Land and Sea Trust, Marathon, Florida. 

Lapointe, B. E. and M. W. Clark. 1992. Nutrient Inputs from the Watershed and Coastal 

 Eutrophication in the Florida Keys. Estuaries 15: 465-476. 

Laughland, Andrew and James Caudill. 1997. Banking on Nature: The Economic Benefits to Local 

 Communities of National Wildlife Refuge Visitation. Division of Economics, U.S. Fish and 

 Wildlife Service, Washington D.C.. 
Appendices 135 

Leeworthy, Vernon R. and Wiley, Peter C. 1997. Economic Contributions of Recreating Visitors to 

the Florida Keys/Key West. 

Liddle, M. .J. and R. A. Scorgie. 1980. The Effects of Recreation on Freshwater Plants 

 and Animals: a Review. Biological Conservation 17: 183-206. 

Lugo, A. E. and S. C. Snedaker. 1974. The Ecology of Mangroves. Annual Review of 

 Ecological Systems 5:39-64. 

McDonnel, M. J. l98l. Trampling Effects on Coastal Dune Vegetation in the Parker 

 River National Wildlife Refuge, Massachusetts, U.S.A. Biological Conservation 6: 289-30l. 

Monroe County Tourist Development County, Florida. 2006. Monroe County and the 

 Florida Keys. Visitor Profile Survey. http://www.monroecountyfl.gov/Pages/index 

Nickerson, N. H. and F. R. Thibodeau. 1983. Destruction of Ammophila breviligulata by 

 Pedestrian Traffic. Biological Conservation 27: 277-287. 

Paul, H. J. et al. 1995. Viral Tracer Studies Indicate Contamination of Marine Waters by 

 Sewage Disposal Practices in Key Largo, Florida. Applied and Environmental 

 Microbiology 6: 2230-2234. 

Pyne. S. J. 1995. World Fire: The Culture of Fire on Earth. New York: Henry Holt and Co. 

Ross, M. J. et al. 1994. Sea-level Rise and the Reduction in Pine Forests in the Florida 

 Keys. Ecological Applications 4: 44-156. 

Saarinen, Jr., A. W. 1989. The Use of Septic Systems and Their Effects on the 

 Freshwater Resources on Big Pine Key. In Freshwater and Surface Water 

 Resources of Big Pine Key, Monroe County, Florida. M. L. Robertson and J. M. 

 Young, eds. The Nature Conservancy Florida Field Office. Winter Park, Florida. 

Sah, Jay P. et al. 2006. Fuel Loads, Fire Regimes, and Post-fire Fuel Dynamics in Florida Keys Pine 

 Forests. International Journal of Wildland Fire 15:463-478. 

Sah, Jay P., et al. 2004. Estimating Above Ground Biomass of Broadleaved Woody Plants in the 

 Understory of Florida Keys Pine Forests. Forest Ecology and Management 2003: 319-329. 

Snyder, James R. et al. Developing Ecological Criteria for Prescribed Fire in South Florida Pine 

 Rockland Ecosystems. USGS Open File Report of 2006-1062. 

Sperling’s Best Places, 2006, Key West, Florida Cost of Living 

 http://www.bestplaces.net/city/profile 

Strong, A. M. and G. T. Bancroft. 1994. Post-fledgling Dispersal of White-crowned 

 Pigeons: Implications for Conservation of Deciduous Seasonal Forest in the 

 Upper Florida Keys. Conservation Biology 8: 770-779. 

Travis J. et al., 1990. Multiple Paternity and its Correlates in Female Poecilia latipinna. 

 Copeia 3:722-729. 
136 Lower Florida Keys National Wildlife Refuges 

Turner, et al., 1992. Extreme Clonal Diversity and Divergence in Populations of Selfing 

 Hermathoditic Fish. National Academy of Sciences 89:10643-10647. 

U.S. Census Bureau. 2005. Monroe County, Florida – General Demographic 

 Characteristics – 2005. http://factfinder.census.gov 

U.S. Census Bureau. 2005. Monroe County, Florida – Fact Sheet – American Fact 

 Finder 2005 American Community Survey. http://factfinder.census.gov 

U.S. Census Bureau. 2000. Monroe County, Florida – Fact Sheet – American Fact 

 Finder 2000 American Community Survey. http://factfinder.census.gov 

U.S. Census Bureau. 2005. R2002 Median Family income (in 2005 Inflation-Adjusted 

 Dollars) http://factfinder.census.gov 

U.S. Department of Agriculture. 1989. Classification and Correlation of the Soils of 

 Monroe County. 

U.S. Fish and Wildlife Service. March 2006. Annual Report of Lands under Control of 

 U.S. Fish and Wildlife Service as of September 30, 2005. 

U.S. Fish and Wildlife Service. June 1995. South Florida Ecosystem Team Ecosystem 

 Management Plan. Vero Beach, Florida. 

U.S. Fish and Wildlife Service. 1999. South Florida Multi-Species Recovery Plan. 

 Atlanta, Georgia. 

Vogl, R.J. 1974. Effects of Fires on Grasslands. In Fire and Ecosystems. T. T. Kozolowski and C. E. 

 Ahlgren (eds). Academic Press, New York, New York. 

Wade, D et al. 1980. Fire in South Florida Ecosystems. U.S. Department of Agriculture Forest 

 Service General Technical Report S E- I7. 

Weiner, A. 1979. The Hardwood Hammocks of the Florida Keys: an Ecological Study. 

 National Audubon Society and the Florida Keys Land Trust. 

Wightman, M. J., 1990. Geophysical Analysis and Dupuit-Ghyben-Herzberg Modeling of 

 Freshwater Lenses on Big Pine Key, Florida. M.S. Thesis, University of South 

 Florida. Tampa, Florida. 

Wilmers, T. J. 2003. Distribution and Population Trends of Nesting Great White Herons 

 (Ardea herodias occidentalis) in the Florida Keys National Wildlife Refuges, 1986-2001. 

Unpublished report to the refuge. 

 
Appendices 137 

Appendix C. Relevant Legal Mandates and Executive 

Orders 

NATIONAL WILDLIFE REFUGE SYSTEM AUTHORITIES 

The mission of the Fish and Wildlife Service is to conserve, protect, and enhance the nation’s fish 

and wildlife and their habitats for the continuing benefit of the American people. The Service is the 

primary Federal agency responsible for migratory birds, endangered plants and animals, certain 

marine mammals, and anadromous fish. This responsibility to conserve our nation’s fish and wildlife 

resources is shared with other Federal agencies and State and Tribal governments. 

As part of this responsibility, the Service manages the National Wildlife Refuge System. The 

mission of the National Wildlife Refuge System is to administer a national network of lands and 

waters for the conservation, management, and where appropriate, restoration of the fish, wildlife, 

and plant resources and their habitats within the United States for the benefit of present and 

future generations of Americans. 

The Lower Florida Keys Refuges are managed as part of this system in accordance with the National 

Wildlife Refuge System Administration Act of 1966, as amended by the National Wildlife Refuge 

System Improvement Act of 1997, the Refuge Recreation Act of 1962, Executive Order 12996 

(Management and General Public Use of the National Wildlife Refuge System), and other relevant 

legislation, executive orders, regulations, and policies. 

FEDERAL LAWS AND MANDATES 

The following list includes statutes and executive orders that are relevant to the acquisition, 

administration, and management of national wildlife refuges. The brief descriptions provided highlight 

some aspects of these laws and policies that are relevant to comprehensive conservation planning; 

however, they are not legal interpretations. The entire act or executive order should be referenced 

for additional detail. Further information can be obtained from the following website: 

http://laws.fws.gov/lawsdigest. 

STATUE DESCRIPTION 

American Antiquities 

Act of 1906 

Provides penalties for unauthorized collection, excavation, or 

destruction of historic or prehistoric ruins, monuments, or objects of 

antiquity on lands owned or controlled by the United States. The Act 

authorizes the President to designate as national monuments objects or 

areas of historic or scientific interest on lands owned or controlled by the 

Unites States. 

American Indian 

Religious Freedom Act 

of 1978 

Protects the inherent right of Native Americans to believe, express, and 

exercise their traditional religions, including access to important sites, 

use and possession of sacred objects, and the freedom to worship 

through ceremonial and traditional rites. 
138 Lower Florida Keys National Wildlife Refuges 

STATUE DESCRIPTION 

Americans With 

Disabilities Act of 1990 

Intended to prevent discrimination of and make American society more 

accessible to people with disabilities. The Act requires reasonable 

accommodations to be made in employment, public services, public 

accommodations, and telecommunications for persons with disabilities. 

Anadromous Fish 

Conservation Act of 

1965, as amended 

Authorizes the Secretaries of Interior and Commerce to enter into 

cooperative agreements with states and other non-federal interests for 

conservation, development, and enhancement of anadromous fish and 

contribute up to 50 percent as the federal share of the cost of carrying 

out such agreements. Reclamation construction programs for water 

resource projects needed solely for such fish are also authorized. 

Archaeological 

Resources Protection 

Act of 1979, as 

amended. 

Strengthens and expands the protective provisions of the Antiquities Act 

of 1906 regarding archaeological resources. It also revised the 

permitting process for archaeological research. 

Architectural Barriers 

Act of 1968 

Requires that buildings and facilities designed, constructed, or altered 

with federal funds, or leased by a federal agency, must comply with 

standards for physical accessibility. 

Bald and Golden Eagle 

Protection Act of 1940, 

as amended 

Prohibits the possession, sale or transport of any bald or golden eagle, 

alive or dead, or part, nest, or egg except as permitted by the Secretary 

of the Interior for scientific or exhibition purposes, or for the religious 

purposes of Indians. 

Clean Air Act of 1970 Regulates air emissions from area, stationary, and mobile sources. This 

Act and its amendments charge federal land managers with direct 

responsibility to protect the “air quality and related values” of land under 

their control. These values include fish, wildlife, and their habitats. 

Clean Water Act of 

1974, as amended 

This Act and its amendments have as its objective the restoration and 

maintenance of the chemical, physical, and biological integrity of the 

Nation’s waters. Section 401 of the Act requires that federally permitted 

activities comply with the Clean Water Act standards, state water quality 

laws, and any other appropriate state laws. Section 404 charges the 

U.S. Army Corps of Engineers with regulating discharge of dredge or fill 

materials into waters of the United States, including wetlands. 

Coastal Barrier 

Resources Act of 1982 

(CBRA) 

Identifies undeveloped coastal barriers along the Atlantic and Gulf 

Coasts and included them in the John H. Chafee Coastal Barrier 

Resources System (CBRS). The objectives of the Act are to minimize 

loss of human life, reduce wasteful federal expenditures, and minimize 

the damage to natural resources by restricting most federal 

expenditures that encourage development within the CBRS. 
Appendices 139 

STATUE DESCRIPTION 

Coastal Barrier 

Improvement Act of 

1990 

Reauthorized the Coastal Barrier Resources Act (CBRA), expanded the 

CBRS to include undeveloped coastal barriers along the Great Lakes 

and in the Caribbean, and established “Otherwise Protected Areas 

(OPAs).” The Service is responsible for maintaining official maps, 

consulting with federal agencies that propose spending federal funds 

within the CBRS and OPAs, and making recommendations to Congress 

about proposed boundary revisions. 

Coastal Zone 

Management Act of 

1972, as amended 

Established a voluntary national program within the Department of 

Commerce to encourage coastal states to develop and implement 

coastal zone management plans and requires that “any federal activity 

within or outside of the coastal zone that affects any land or water use 

or natural resource of the coastal zone” shall be “consistent to the 

maximum extent practicable with the enforceable policies” of a state’s 

coastal zone management plan. The law includes an Enhancement 

Grants Program for protecting, restoring, or enhancing existing coastal 

wetlands or creating new coastal wetlands. It also established the 

National Estuarine Research Reserve System, guidelines for estuarine 

research, and financial assistance for land acquisition. 

Emergency Wetlands 

Resources Act of 1986 

Authorized the purchase of wetlands from Land and Water Conservation 

Fund moneys, removing a prior prohibition on such acquisitions. The 

Act requires the Secretary to establish a National Wetlands Priority 

Conservation Plan, required the states to include wetlands in their 

Comprehensive Outdoor Recreation Plans, and transfers to the 

Migratory Bird Conservation Fund amounts equal to import duties on 

arms and ammunition. It also established entrance fees at national 

wildlife refuges. 

Endangered Species 

Act of 1973, as 

amended 

Provides for the conservation of threatened and endangered species of 

fish, wildlife, and plants by federal action and by encouraging the 

establishment of state programs. It provides for the determination and 

listing of threatened and endangered species and the designation of 

critical habitats. Section 7 requires refuge managers to perform internal 

consultation before initiating projects that affect or may affect 

endangered species. 

Environmental 

Education Act of 1990 

Established the Office of Environmental Education within the U.S. 

Environmental Protection Agency to develop and administer a federal 

environmental education program in consultation with other federal 

natural resource management agencies, including the Fish and Wildlife 

Service. 
140 Lower Florida Keys National Wildlife Refuges 

STATUE DESCRIPTION 

Estuary Protection Act 

of 1968 

Authorized the Secretary of the Interior, in cooperation with other federal 

agencies and the states, to study and inventory estuaries of the United 

States, including land and water of the Great Lakes, and to determine 

whether such areas should be acquired for protection. The Secretary is 

also required to encourage state and local governments to consider the 

importance of estuaries in their planning activities relative to federal 

natural resource grants. In approving any state grants for acquisition of 

estuaries, the Secretary was required to establish conditions to ensure 

the permanent protection of estuaries. 

Estuaries and Clean 

Waters Act of 2000 

Creates a federal interagency council that includes the Director of the 

Fish and Wildlife Service, the Secretary of the Army for Civil Works, the 

Secretary of Agriculture, the Administrator of the Environmental 

Protection Agency and the Administrator for the National Oceanic and 

Atmospheric Administration. The council is charged with developing a 

national estuary habitat restoration strategy and providing grants to 

entities to restore and protect estuary habitat to promote the strategy. 

Federal Noxious Weed 

Act of 1990, as 

amended 

The Secretary of Agriculture was given the authority to designate plants 

as noxious weeds and to cooperate with other federal, State and local 

agencies, farmers’ associations, and private individuals in measures to 

control, eradicate, prevent, or retard the spread of such weeds. The Act 

requires each Federal land-managing agency, including the Fish and 

Wildlife Service, to designate an office or person to coordinate a 

program to control such plants on the agency’s land and implement 

cooperative agreements with the states, including integrated 

management systems to control undesirable plants. 

Fish and Wildlife Act of 

1956 

Establishes a comprehensive national fish, shellfish, and wildlife 

resources policy with emphasis on the commercial fishing industry but 

also includes the inherent right of every citizen and resident to fish for 

pleasure, enjoyment, and betterment and to maintain and increase 

public opportunities for recreational use of fish and wildlife resources. 

Among other things, it authorizes the Secretary of the Interior to take 

such steps as may be required for the development, advancement, 

management, conservation, and protection of fish and wildlife resources 

including, but not limited to, research, development of existing facilities, 

and acquisition by purchase or exchange of land and water or interests 

therein. 

Fish and Wildlife 

Conservation Act of 

1980, as amended 

Requires the Service to monitor non-gamebird species, identify species 

of management concern, and implement conservation measures to 

preclude the need for listing under the Endangered Species Act. 
Appendices 141 

STATUE DESCRIPTION 

Fish and Wildlife 

Coordination Act of 

1958 

Promotes equal consideration and coordination of wildlife conservation 

with other water resource development programs by requiring 

consultation with the Fish and Wildlife Service and the state fish and 

wildlife agencies where the “waters of a stream or other body of water 

are proposed or authorized, permitted or licensed to be impounded, 

diverted...or otherwise controlled or modified” by any agency under 

federal permit or license. 

Improvement Act of 

1978 

Passed to improve the administration of fish and wildlife programs and 

amends several earlier laws, including the Refuge Recreation Act, the 

National Wildlife Refuge System Administration Act, and the Fish and 

Wildlife Act of 1956. It authorizes the Secretary to accept gifts and 

bequests of real and personal property on behalf of the United States. It 

also authorizes the use of volunteers on Service projects and 

appropriations to carry out volunteer programs. 

Freedom of 

Information Act, 1966 

Requires all federal agencies to make available to the public for 

inspection and copying administrative staff manuals and staff 

instructions; official, published and unpublished policy statements; final 

orders deciding case adjudication; and other documents. Special 

exemptions have been reserved for nine categories of privileged 

material. The Act requires the party seeking the information to pay 

reasonable search and duplication costs. 

Land and Water 

Conservation Fund Act 

of 1948 

Provides funding through receipts from the sale of surplus federal land, 

appropriations from oil and gas receipts from the outer continental shelf, 

and other sources for land acquisition under several authorities. 

Appropriations from the fund may be used for matching grants to states 

for outdoor recreation projects and for land acquisition by various 

federal agencies, including the Fish and Wildlife Service. 

Marine Mammal 

Protection Act of 1972, 

as amended 

Established a federal responsibility to conserve marine mammals with 

management vested in the Department of the Interior for sea otter, 

walrus, polar bear, dugong, and manatee. The Department of 

Commerce is responsible for cetaceans and pinnipeds, other than the 

walrus. With certain specified exceptions, the Act establishes a 

moratorium on the taking and importation of marine mammals, as well 

as products taken from them. 

Migratory Bird 

Conservation Act of 

1929 

Established a Migratory Bird Conservation Commission to approve 

areas recommended by the Secretary of the Interior for acquisition with 

Migratory Bird Conservation Funds. The role of the commission was 

expanded by the North American Wetland Conservation Act to include 

approving wetlands acquisition, restoration, and enhancement 

proposals recommended by the North American Wetlands Conservation 

Council. 
142 Lower Florida Keys National Wildlife Refuges 

STATUE DESCRIPTION 

Migratory Bird Hunting 

and Conservation 

Stamp Act of 1934 

Also commonly referred to as the “Duck Stamp Act,” requires waterfowl 

hunters 16 years of age or older to possess a valid federal hunting 

stamp. Receipts from the sale of the stamp are deposited into the 

Migratory Bird Conservation Fund for the acquisition of migratory bird 

refuges. 

Migratory Bird Treaty 

Act of 1918, as 

amended 

Implements various treaties and conventions between the United States 

and Canada, Japan, Mexico, and the former Soviet Union for the 

protection of migratory birds. Except as allowed by special regulations, 

this Act makes it unlawful to pursue, hunt, kill, capture, possess, buy, 

sell, purchase, barter, export, or import any migratory bird, part, nest, 

egg, or product. 

National Environmental 

Policy Act of 1969 

Requires analysis, public comment, and reporting for environmental 

impacts of federal actions. It stipulates the factors to be considered in 

environmental impact statements, and requires that federal agencies 

employ an interdisciplinary approach in related decision-making and 

develop means to ensure that unqualified environmental values are 

given appropriate consideration, along with economic and technical 

considerations. 

National Historic 

Preservation Act of 

1966, as amended 

Established a National Register of Historic Places and a program of 

matching grants for preservation of significant historical features. 

Federal agencies are directed to take into account the effects of their 

actions on items or sites listed or eligible for listing in the National 

Register. 

National Trails System 

Act (1968), as 

amended 

Established the National Trails System to protect the recreational, 

scenic, and historic values of some important trails. National recreation 

trails may be established by the Secretaries of Interior or Agriculture on 

land wholly or partly within their jurisdiction, with the consent of the 

involved state(s), and other land managing agencies, if any. National 

scenic and national historic trails may only be designated by Congress. 

Several national trails cross units of the National Wildlife Refuge 

System. 

National Wildlife 

Refuge System 

Administration Act of 

1966 

Prior to 1966, there was no single federal law that governed the 

administration of the various national wildlife refuges that had been 

established. This Act defines the National Wildlife Refuge System and 

authorizes the Secretary of the Interior to permit any use of a refuge 

provided such use is compatible with the major purposes(s) for which 

the refuge was established. 
Appendices 143 

STATUE DESCRIPTION 

National Wildlife 

Refuge System 

Improvement Act of 

1997 

Amends the National Wildlife Refuge System Administration Act of 

1966. This Act defines the mission of the National Wildlife Refuge 

System, establishes the legitimacy and appropriateness of six priority 

wildlife-dependent public uses, establishes a formal process for 

determining compatible uses of Refuge System lands, identifies the 

Secretary of the Interior as responsible for managing and protecting the 

Refuge System, and requires the development of a comprehensive 

conservation plan for all refuges outside of Alaska. 

Native American 

Graves Protection and 

Repatriation Act of 

1990 

Requires federal agencies and museums to inventory, determine 

ownership of, and repatriate certain cultural items and human remains 

under their control or possession. The Act also addresses the 

repatriation of cultural items inadvertently discovered by construction 

activities on lands managed by the agency. 

Neotropical Migratory 

Bird Conservation Act 

of 2000 

Establishes a matching grant program to fund projects that promote the 

conservation of neotropical migratory birds in the united States, Latin 

America, and the Caribbean. 

North American 

Wetlands Conservation 

Act of 1989 

Provides funding and administrative direction for implementation of the 

North American Waterfowl Management Plan and the Tripartite 

Agreement on wetlands between Canada, the United States, and 

Mexico. The North American Wetlands Conservation Council was 

created to recommend projects to be funded under the Act to the 

Migratory Bird Conservation Commission. Available funds may be 

expended for up to 50 percent of the United States’ share cost of 

wetlands conservation projects in Canada, Mexico, or the United States 

(or 100 percent of the cost of projects on federal lands). 

Refuge Recreation Act 

of 1962, as amended 

Authorized the Secretary of the Interior to administer refuges, 

hatcheries, and other conservation areas for recreational use, when 

such uses do not interfere with the area’s primary purposes. It 

authorizes construction and maintenance of recreational facilities and 

the acquisition of land for incidental fish and wildlife-oriented 

recreational development or protection of natural resources. It also 

authorizes the charging of fees for public uses. 

Partnerships for 

Wildlife Act of 1992 

Established a Wildlife Conservation and Appreciation Fund to receive 

appropriated funds and donations from the National Fish and Wildlife 

Foundation and other private sources to assist the state fish and game 

agencies in carrying out their responsibilities for conservation of nongame species. The funding formula is no more that 1/3 federal funds, at 

least 1/3 foundation funds, and at least 1/3 state funds. 
144 Lower Florida Keys National Wildlife Refuges 

STATUE DESCRIPTION 

Refuge Revenue 

Sharing Act of 1935, 

as amended 

Provided for payments to counties in lieu of taxes from areas 

administered by the Fish and Wildlife Service. Counties are required to 

pass payments along to other units of local government within the 

county, which suffer losses in tax revenues due to the establishment of 

Service areas. 

Rehabilitation Act of 

1973 

Requires nondiscrimination in the employment practices of federal 

agencies of the executive branch and contractors. It also requires all 

federally assisted programs, services, and activities to be available to 

people with disabilities. 

Water Resources 

Planning Act of 1965 

Established Water Resources Council to be composed of Cabinet 

representatives, including the Secretary of the Interior. The Council 

reviews river basin plans with respect to agricultural, urban, energy, 

industrial, recreational, and fish and wildlife needs. The Act also 

established a grant program to assist States in participating in the 

development of related comprehensive water and land use plans. 

Wild and Scenic Rivers 

Act of 1968, as 

amended 

Selects certain rivers of the nation possessing remarkable scenic, 

recreational, geologic, fish and wildlife, historic, cultural, or other similar 

values; preserves them in a free-flowing condition; and protects their 

local environments. 

Wilderness Act of 

1964, as amended 

Directs the Secretary of the Interior to review every roadless area of 

5,000 acres or more and every roadless island regardless of size within 

the National Wildlife Refuge System and to recommend suitability of 

each such area. The Act permits certain activities within designated 

wilderness areas that do not alter natural processes. Wilderness values 

are preserved through a “minimum tool” management approach, which 

requires refuge managers to use the least intrusive methods, 

equipment, and facilities necessary for administering the areas. 
Appendices 145 

EXECUTIVE ORDERS DESCRIPTIONS 

EO 923 (1908) Established the Key West NWR on August 8, 1908 as 

a breeding ground for native birds. 

EO 7993 (1938) President Roosevelt established Great White Heron 

NWR on October 27, 1938. 

EO 11593, Protection and Enhancement 

of the Cultural Environment (1971) 

States that if the Service proposes any development 

activities that may affect the archaeological or historic 

sites, the Service will consult with Federal and State 

Historic Preservation Officers to comply with Section 

106 of the National Historic Preservation Act of 1966, 

as amended. 

EO 11644, Use of Off-road Vehicles on 

Public Land (1972) 

Established policies and procedures to ensure that the 

use of off-road vehicles on public lands will be 

controlled and directed so as to protect the resources 

of those lands, to promote the safety of all users of 

those lands, and to minimize conflicts among the 

various uses of those lands. 

EO 11988, Floodplain Management 

(1977) 

The purpose of this Executive Order is to prevent 

federal agencies from contributing to the “adverse 

impacts associated with occupancy and modification 

of floodplains” and the “direct or indirect support of 

floodplain development.” In the course of fulfilling 

their respective authorities, federal agencies “shall 

take action to reduce the risk of flood loss, to minimize 

the impact of floods on human safety, health and 

welfare, and to restore and preserve the natural and 

beneficial values served by floodplains.” 

EO 11989 (1977), Amends Section 2 of 

EO 11644 

Directs agencies to close areas negatively impacted 

by off-road vehicles. 

EO 11990, Protection of Wetlands (1977) Federal agencies are directed to provide leadership 

and take action to minimize the destruction, loss, or 

degradation of wetlands, and to preserve and 

enhance the natural and beneficial values of wetlands. 

EO 12372, Intergovernmental Review of 

Federal Programs (1982) 

Seeks to foster intergovernmental partnerships by 

requiring federal agencies to use the state process to 

determine and address concerns of state and local 

elected officials with proposed federal assistance and 

development programs. 
146 Lower Florida Keys National Wildlife Refuges 

EXECUTIVE ORDERS DESCRIPTIONS 

EO 12898, Environmental Justice (1994) Requires federal agencies to identify and address 

disproportionately high and adverse effects of their 

programs, policies, and activities on minority and lowincome populations. 

EO 12906, Coordinating Geographical 

Data Acquisition and Access (1994), 

Amended by EO 13286 (2003). 

Amendment of EOs and other actions in 

connection with transfer of certain 

functions to Secretary of DHS. 

Recommended that the executive branch develop, in 

cooperation with state, local, and tribal governments, 

and the private sector, a coordinated National Spatial 

Data Infrastructure to support public and private 

sector applications of geospatial data. Of particular 

importance to comprehensive conservation planning 

is the National Vegetation Classification System 

(NVCS), which is the adopted standard for vegetation 

mapping. Using NVCS facilitates the compilation of 

regional and national summaries, which in turn, can 

provide an ecosystem context for individual refuges. 

EO 12962, Recreational Fisheries (1995) Federal agencies are directed to improve the quantity, 

function, sustainable productivity, and distribution of 

U.S. aquatic resources for increased recreational 

fishing opportunities in cooperation with states and 

tribes. 

EO 13007, Native American Religious 

Practices (1996) 

Provides for access to, and ceremonial use of, Indian 

sacred sites on federal lands used by Indian religious 

practitioners and direction to avoid adversely affecting 

the physical integrity of such sites. 

EO 13061, Federal Support of 

Community Efforts Along American 

Heritage Rivers (1997) 

Established the American Heritage Rivers initiative for 

the purpose of natural resource and environmental 

protection, economic revitalization, and historic and 

cultural preservation. The Act directs Federal 

agencies to preserve, protect, and restore rivers and 

their associated resources important to our history, 

culture, and natural heritage. 

EO 13084, Consultation and 

Coordination With Indian Tribal 

Governments (2000) 

Provides a mechanism for establishing regular and 

meaningful consultation and collaboration with tribal 

officials in the development of federal policies that 

have tribal implications. 
Appendices 147 

EXECUTIVE ORDERS DESCRIPTIONS 

EO 13112, Invasive Species (1999) Federal agencies are directed to prevent the 

introduction of invasive species, to detect and to 

respond rapidly to control populations of such species 

in a cost effective and environmentally sound manner, 

accurately monitor invasive species, provide for 

restoration of native species and habitat conditions, 

conduct research to prevent introductions and to 

control invasive species, and promote public 

education on invasive species and the means to 

address them. This EO replaces and rescinds EO 

11987, Exotic Organisms (1977). 

EO 13186, Responsibilities of Federal 

Agencies to Protect Migratory Birds. 

(2001) 

Instructs federal agencies to conserve migratory birds 

by several means, including the incorporation of 

strategies and recommendations found in Partners in 

Flight Bird Conservation plans, the North American 

Waterfowl Plan, the North American Waterbird 

Conservation Plan, and the United States Shorebird 

Conservation Plan, into agency management plans 

and guidance documents. 

PRIMARY STATE WILDLIFE REGULATIONS 

The primary state wildlife regulations are found in Chapter 327.072, Florida Statutes and Chapter 

68A-27, Florida Administrative Code (FAC). The Florida Fish and Wildlife Conservation Commission 

maintains the state list of animals designated as threatened, endangered, or species of special 

concern, in accordance with Rules 68A-27.003 to .005, FAC. See also http://fac.dos.state.fl.us/. This 

list is also found on the Commission’s website: http://myfwc.com. The state list of plants, which are 

designated as threatened, endangered, and commercially exploited, are administered and maintained 

by the Florida Department of Agriculture and Consumer Services via Chapter 5B-40, FAC. This list of 

plants can be obtained at the Department’s website: http://www.doacs.state.fl.us/~pi/index.html. 
148 Lower Florida Keys National Wildlife Refuges 
Appendices 149 

Appendix D. Public Involvement 

SUMMARY OF CCP PUBLIC SCOPING 

Two public scoping meetings for the Lower Florida Keys Comprehensive Conservation Plan were 

conducted on the March 8 and 9, 2005. About 40 persons attended the March 8 meeting held on Big 

Pine Key at the local charter school. Roughly 20 persons attended the March 9 meeting at the Key 

West Board of County Commissioners’ meeting room. Public comments centered on several topics 

including: support for the mission of the Service; public uses in wildlife refuges; commercial uses of 

wildlife refuges; refuge law enforcement/curtailing of illegal activities; and species and habitat 

protection. The comments received by the public during the scoping period are summarized below by 

these categories. 

Support for the mission of wildlife refuges – wildlife first: 

y Wildlife needs should trump human desires for recreation. 

y Wildlife should always be given priority and preference over human recreation in national 

wildlife refuges. Layering on additional human disturbance to appease the recreational 

industry runs counter to the refuge mission. 

y The CCP should seek to reduce pressure on the refuges from all sources and dismiss 

proposals for increased use that do not benefit wildlife. 

y Wildlife must come first in the CCP. Growing human disturbance in the Keys is killing wildlife 

in the Keys. 

y Protection of animals and their habitats should be first and foremost. 

Public uses in wildlife refuges: 

y Maintain the ban on personal watercraft (PWC) in Great White Heron and Key West NWRs. 

y Allow PWC into the backcountry. 

y Ban PWC from the entire Keys. 

y Strengthen the ban on PWC, airboats, and aircraft. 

y Human activities on beaches should be absolutely prohibited between sunset and sunrise, 

except for absolute emergencies. 

y Ban waterskiing, towed activities, airboats, PWC, seaplane landings, ultra-light planes, and 

hovercraft in the refuges. 

y Develop criteria to prohibit excessively noisy aircraft and watercraft from entering the refuges. 

y Each refuge should have a sizable designated “no motor zone” for exclusive use by kayaks, 

canoes, rowboats, sailboats, poled skiffs, and other watercraft with no motors. 

y Water sports should be allowed in the refuges in reasonable areas. 

y A speed limit (e.g. 35 mph) should be established for the backcountry refuges. 

y No rental boats should be allowed in the refuges without a guide on board. 

y Make it a goal to provide refuge visitors the opportunity to enjoy compatible forms of 

recreation while visiting the refuge. The refuge should survey existing recreational activities to 

determine those that are not compatible. 

y Re-open Watson hammock to limited public use (permit should be required). 
150 Lower Florida Keys National Wildlife Refuges 

Commercial uses of wildlife refuges: 

y Commercial uses in refuges should be strictly limited and absolutely confined to those with 

clear educational merit and minimal environmental impact. 

y Any commercial activities within the refuges should require a free license that requires 

licensees to follow established rules for commercial use. Violations of the license rules would 

result in termination of the license. 

y Prohibit all commercial operators from using high-capacity vessels or vehicles from operating 

within refuge areas. 

Law Enforcement Issues: 

y Establish a communications base of operations where local aircraft pilots can report boat 

groundings, intrusion into closed areas, poaching, and illegal activities in the refuges. 

y Establish a communications base with fishing guides, commercial fisherman, Coast Guard, 

and state FWC officers. 

y Assign all office-based personnel at least one day of field work each week. 

y Enforcement efforts should be increased, especially for motor vehicle speeding on Big Pine 

Key (National Key Deer Refuge). 

y There needs to be stronger enforcement of refuge regulations prohibiting feeding of Key deer 

and other wildlife. 

y Increase the amount of education and interpretive signage in the Keys refuges. 

y Increase education efforts to the public regarding the restrictions on interaction with Key deer. 

y Install “No feeding” signs at the Port Pine Heights subdivision. 

y Install “No feeding” signs on No Name Key to notify visitors it is a crime. 

y Increase the number of signs on the refuge that explain the negative effects of feeding wildlife. 

y More attention needs to be paid to illegal feeding of Key deer, alligators and other wildlife. 

y On Cudjoe and Sugarloaf Keys (National Key Deer Refuge) some deer crossing signs should 

be requested from the Florida DOT to help make people aware of translocated deer. 

y Increasing enforcement of 500,000 acres is difficult, so general prohibitions that are easy to 

comprehend are, as a practical matter, much easier to enforce than complex regulations full of 

loopholes and exceptions. 

y Organized powerboat racing in Turkey Basin (Great White Heron NWR) should be stopped 

immediately since boats racing at 50+ miles per hour are a hazard to other boaters and 

wildlife. 

y Islands in Key West and Great White Heron NWRs need more law enforcement attention. 

Species and habitat protection: 

y The path around the rear of the Blue Hole (National Key Deer Refuge) should be closed to 

protect alligators. 

y Extend boundaries and increase numbers of closed areas (e.g., Boca Grande on Great White 

Heron NWR, nesting areas). 

y Prescribed fire burns need to be evaluated more closely with regards to timing and method of 

burning. Habitat and wildlife needs should drive the burns, not the cost of a burn. 

y An overarching goal of the CCP must be that in 2021, the conditions of the refuge are no 

worse than in 2005. 

y Land acquisition needs to be accelerated since costs are rising at such a rapid rate in the 

Keys. 
Appendices 151 

y Bait fish and other food for upland species needs to be as strongly protected as the upland 

species themselves. 

y Work with Monroe County to promote the use of native plants for landscaping. 

y Establish an invasive exotic control plan to deal with dangerous invasive animals and plants. 

y Continue with the great invasive exotics eradication programs. 

y Iguanas must be monitored and studied to evaluate any negative impacts to refuge lands prior 

to just exterminating iguanas because they are an exotic species. 

y The impact of feral cats and iguanas needs to be addressed. 

y Consider adding additional islands to the Florida Keys Wilderness Area. 

y Habitat for the Lower Keys marsh rabbit needs to be protected with adequate buffer zones. 

Other comments: 

y Offer classes in responsible boating, new fishing techniques, bird watching, emergency motor 

repairs, ecotourism, biological field work, ecology, native plants, weather, dangerous wildlife 

and plants, wildlife management, nature photography, etc. 

y The Service should provide leadership by using the most energy efficient vehicles available. 

All boats should use the cleanest burning motors available. 

y Augment education programs in Monroe County public and private schools. 
152 Lower Florida Keys National Wildlife Refuges 
Appendices 153 

Appendix E. Appropriate Use Determinations 

Lower Florida Keys Refuges Appropriate Use Determinations 

An appropriate use determination is the initial decision process a refuge manager follows when first 

considering whether or not to allow a proposed use on a refuge. The refuge manager must find that 

a use is appropriate before undertaking a compatibility review of the use. This process clarifies and 

expands on the compatibility determination process by describing when refuge managers should 

deny a proposed use without determining compatibility. If a proposed use is not appropriate, it will 

not be allowed and a compatibility determination will not be undertaken. 

Except for the uses noted below, the refuge manager must decide if a new or existing use is an 

appropriate refuge use. If an existing use is not appropriate, the refuge manager will eliminate or 

modify the use as expeditiously as practicable. If a new use is not appropriate, the refuge manager 

will deny the use without determining compatibility. Uses that have been administratively determined 

to be appropriate are: 

y Six wildlife-dependent recreational uses - As defined by the National Wildlife Refuge System 

Improvement Act of 1997, the six wildlife-dependent recreational uses (hunting, fishing, 

wildlife observation, wildlife photography, and environmental education and interpretation) are 

determined to be appropriate. However, the refuge manager must still determine if these uses 

are compatible. 

y Take of fish and wildlife under state regulations - States have regulations concerning take of 

wildlife that includes hunting, fishing, and trapping. The Service considers take of wildlife 

under such regulations appropriate. However, the refuge manager must determine if the 

activity is compatible before allowing it on a refuge. 

Statutory Authorities for this policy: 

National Wildlife Refuge System Administration Act of 1966, as amended by the National 

Wildlife Refuge System Improvement Act of 1997, 16 U.S.C. §668dd-668ee. This law provides 

the authority for establishing policies and regulations governing refuge uses, including the authority to 

prohibit certain harmful activities. The Act does not authorize any particular use, but rather authorizes 

the Secretary of the Interior to allow uses only when they are compatible and “under such regulations 

as he may prescribe.” This law specifically identifies certain public uses that, when compatible, are 

legitimate and appropriate uses within the Refuge System. The law states “. . . it is the policy of the 

United States that . . .compatible wildlife-dependent recreation is a legitimate and appropriate general 

public use of the System . . .compatible wildlife-dependent recreational uses are the priority general 

public uses of the System and shall receive priority consideration in refuge planning and 

management; and . . . when the Secretary determines that a proposed wildlife-dependent recreational 

use is a compatible use within a refuge, that activity should be facilitated . . . the Secretary shall . . . 

ensure that priority general public uses of the System receive enhanced consideration over other 

general public uses in planning and management within the System . . . .” The law also states “in 

administering the System, the Secretary is authorized to take the following actions: . . . issue 

regulations to carry out this Act.” This policy implements the standards set in the Act by providing 

enhanced consideration of priority general public uses and ensuring other public uses do not interfere 

with our ability to provide quality, wildlife-dependent recreational uses. 
154 Lower Florida Keys National Wildlife Refuges 

Refuge Recreation Act of 1962, 16 U.S.C. 460k. The Act authorizes the Secretary of the Interior to 

administer refuges, hatcheries, and other conservation areas for recreational use, when such uses do 

not interfere with the area’s primary purposes. It authorizes construction and maintenance of 

recreational facilities and the acquisition of land for incidental fish and wildlife oriented recreational 

development or protection of natural resources. It also authorizes the charging of fees for public uses. 

Other Statutes that Establish Refuges, including the Alaska National Interest Lands 

Conservation Act of 1980 (ANILCA) (16 U.S.C. §410hh - 410hh-5, 460 mm - 460mm-4, 539-539e, 

and 3101 - 3233; 43 U.S.C. 1631 et seq.). 

Executive Orders. The Service must comply with Executive Order 11644 when allowing use of offhighway vehicles on refuges. This order requires the Service to designate areas as open or closed to offhighway vehicles in order to protect refuge resources, promote safety, and minimize conflict among the 

various refuge users; monitor the effects of these uses once they are allowed; and amend or rescind any 

area designation as necessary based on the information gathered. Furthermore, Executive Order 11989 

requires the Service to close areas to off-highway vehicles when it is determined that the use causes or 

will cause considerable adverse effects on the soil, vegetation, wildlife, habitat, or cultural or historic 

resources. Statutes, such as ANILCA, take precedence over executive orders. 

Definitions: 

Appropriate Use

A proposed or existing use on a refuge that meets at least one of the following four conditions. 

1) The use is a wildlife-dependent recreational use as identified in the Improvement Act. 

2) The use contributes to fulfilling the refuge purpose(s), the Refuge System mission, or goals 

or objectives described in a refuge management plan approved after October 9, 1997, the 

date the Improvement Act was signed into law. 

3) The use involves the take of fish and wildlife under state regulations. 

4) The use has been found to be appropriate as specified in Section 1.11. 

Native American. American Indians in the conterminous United States and Alaska Natives (including 

Aleuts, Eskimos, and Indians) who are members of federally recognized tribes. 

Priority General Public Use. A compatible wildlife-dependent recreational use of a refuge involving 

hunting, fishing, wildlife observation, wildlife photography, and environmental education and 

interpretation. 
Appendices 155 

Quality. The criteria used to determine a quality recreational experience include: 

y Promotes safety of participants, other visitors, and facilities; 

y Promotes compliance with applicable laws and regulations and responsible behavior; 

y Minimizes or eliminates conflicts with fish and wildlife population or habitat goals or objectives 

in a plan approved after 1997; 

y Minimizes or eliminates conflicts with other compatible wildlife-dependent recreation; 

y Minimizes conflicts with neighboring landowners; 

y Promotes accessibility and availability to a broad spectrum of the American people; 

y Promotes resource stewardship and conservation; 

y Promotes public understanding and increases public appreciation of America’s natural 

resources and the Service’s role in managing and protecting these resources; 

y Provides reliable/reasonable opportunities to experience wildlife; 

y Uses facilities that are accessible and blend into the natural setting; and 

y Uses visitor satisfaction to help define and evaluate programs. 

Wildlife-Dependent Recreational Use. As defined by the Improvement Act, a use of a refuge 

involving hunting, fishing, wildlife observation, wildlife photography, and environmental education and 

interpretation. 
156 Lower Florida Keys National Wildlife Refuges 

FINDING OF APPROPRIATENESS OF A REFUGE USE 

Refuge Name: Key West NWR, Great White Heron NWR, National Key Deer Refuge

Use: Public Use on Wilderness and Backcountry Islands

This form is not required for wildlife-dependent recreational uses, take regulated by the State, or uses already described 

in a refuge CCP or step-down management plan approved after October 9, 1997. 

Decision Criteria: YES NO

(a) Do we have jurisdiction over the use? X 

(b) Does the use comply with applicable laws and regulations (Federal, State, tribal, and local)? X 

(c) Is the use consistent with applicable executive orders and Department and Service policies? X 

(d) Is the use consistent with public safety? X 

(e) Is the use consistent with goals and objectives in an approved management plan or other 

document? 

X 

(f) Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? 

X 

(g) Is the use manageable within available budget and staff? X 

(h) Will this be manageable in the future within existing resources? X 

(i) Does the use contribute to the public’s understanding and appreciation of the refuge’s natural 

or cultural resources, or is the use beneficial to the refuge’s natural or cultural resources? 

X 

(j) Can the use be accommodated without impairing existing wildlife-dependent recreational uses 

or reducing the potential to provide quality (see section 1.6D, 603 FW 1, for description), 

compatible, wildlife-dependent recreation into the future? 

X 

Where we do not have jurisdiction over the use [“no” to (a)], there is no need to evaluate it further as we cannot control the 

use. Uses that are illegal, inconsistent with existing policy, or unsafe [“no” to (b), (c), or (d)] may not be found appropriate. 

If the answer is “no” to any of the other questions above, we will generally not allow the use. 

If indicated, the refuge manager has consulted with State fish and wildlife agencies. Yes ___ No ___

When the refuge manager finds the use appropriate based on sound professional judgment, the refuge manager must justify 

the use in writing on an attached sheet and obtain the refuge supervisor’s concurrence. 

Based on an overall assessment of these factors, my summary conclusion is that the proposed use is: 

 Not Appropriate_____ Appropriate_X__ 

Refuge Manager:____________________________________________ Date:_____________________ 

If found to be Not Appropriate, the refuge supervisor does not need to sign concurrence if the use is a new use. 

If an existing use is found Not Appropriate outside the CCP process, the refuge supervisor must sign concurrence. 

If found to be Appropriate, the refuge supervisor must sign concurrence. 

Refuge Supervisor:___________________________________________ Date:_____________________ 

A compatibility determination is required before the use may be allowed.
Appendices 157 

FINDING OF APPROPRIATENESS OF A REFUGE USE 

Refuge Name: National Key Deer Refuge

Use: Beach Use

This form is not required for wildlife-dependent recreational uses, take regulated by the State, or uses already described 

in a refuge CCP or step-down management plan approved after October 9, 1997. 

Decision Criteria: YES NO

(a) Do we have jurisdiction over the use? X 

(b) Does the use comply with applicable laws and regulations (Federal, State, tribal, and local)? X 

(c) Is the use consistent with applicable executive orders and Department and Service policies? X 

(d) Is the use consistent with public safety? X 

(e) Is the use consistent with goals and objectives in an approved management plan or other 

document? 

X 

(f) Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? 

X 

(g) Is the use manageable within available budget and staff? X 

(h) Will this be manageable in the future within existing resources? X 

(i) Does the use contribute to the public’s understanding and appreciation of the refuge’s natural 

or cultural resources, or is the use beneficial to the refuge’s natural or cultural resources? 

X 

(j) Can the use be accommodated without impairing existing wildlife-dependent recreational uses 

or reducing the potential to provide quality (see section 1.6D, 603 FW 1, for description), 

compatible, wildlife-dependent recreation into the future? 

X 

Where we do not have jurisdiction over the use [“no” to (a)], there is no need to evaluate it further as we cannot control the 

use. Uses that are illegal, inconsistent with existing policy, or unsafe [“no” to (b), (c), or (d)] may not be found appropriate. 

If the answer is “no” to any of the other questions above, we will generally not allow the use. 

If indicated, the refuge manager has consulted with State fish and wildlife agencies. Yes ___ No ___

When the refuge manager finds the use appropriate based on sound professional judgment, the refuge manager must justify 

the use in writing on an attached sheet and obtain the refuge supervisor’s concurrence. 

Based on an overall assessment of these factors, my summary conclusion is that the proposed use is: 

 Not Appropriate_____ Appropriate_X__ 

Refuge Manager:____________________________________________ Date:_____________________ 

If found to be Not Appropriate, the refuge supervisor does not need to sign concurrence if the use is a new use. 

If an existing use is found Not Appropriate outside the CCP process, the refuge supervisor must sign concurrence. 

If found to be Appropriate, the refuge supervisor must sign concurrence. 

Refuge Supervisor:___________________________________________ Date:_____________________ 

A compatibility determination is required before the use may be allowed.
158 Lower Florida Keys National Wildlife Refuges 

FINDING OF APPROPRIATENESS OF A REFUGE USE 

Refuge Name: National Key Deer Refuge

Use: Bicycling

This form is not required for wildlife-dependent recreational uses, take regulated by the State, or uses already described 

in a refuge CCP or step-down management plan approved after October 9, 1997. 

Decision Criteria: YES NO

(a) Do we have jurisdiction over the use? X 

(b) Does the use comply with applicable laws and regulations (Federal, State, tribal, and local)? X 

(c) Is the use consistent with applicable executive orders and Department and Service policies? X 

(d) Is the use consistent with public safety? X 

(e) Is the use consistent with goals and objectives in an approved management plan or other 

document? 

X 

(f) Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? 

X 

(g) Is the use manageable within available budget and staff? X 

(h) Will this be manageable in the future within existing resources? X 

(i) Does the use contribute to the public’s understanding and appreciation of the refuge’s natural 

or cultural resources, or is the use beneficial to the refuge’s natural or cultural resources? 

X 

(j) Can the use be accommodated without impairing existing wildlife-dependent recreational uses 

or reducing the potential to provide quality (see section 1.6D, 603 FW 1, for description), 

compatible, wildlife-dependent recreation into the future? 

X 

Where we do not have jurisdiction over the use [“no” to (a)], there is no need to evaluate it further as we cannot control the 

use. Uses that are illegal, inconsistent with existing policy, or unsafe [“no” to (b), (c), or (d)] may not be found appropriate. 

If the answer is “no” to any of the other questions above, we will generally not allow the use. 

If indicated, the refuge manager has consulted with State fish and wildlife agencies. Yes ___ No ___

When the refuge manager finds the use appropriate based on sound professional judgment, the refuge manager must justify 

the use in writing on an attached sheet and obtain the refuge supervisor’s concurrence. 

Based on an overall assessment of these factors, my summary conclusion is that the proposed use is: 

 Not Appropriate_____ Appropriate_X__ 

Refuge Manager:____________________________________________ Date:_____________________ 

If found to be Not Appropriate, the refuge supervisor does not need to sign concurrence if the use is a new use. 

If an existing use is found Not Appropriate outside the CCP process, the refuge supervisor must sign concurrence. 

If found to be Appropriate, the refuge supervisor must sign concurrence. 

Refuge Supervisor:___________________________________________ Date:_____________________ 

A compatibility determination is required before the use may be allowed.
Appendices 159 

FINDING OF APPROPRIATENESS OF A REFUGE USE 

Refuge Name: National Key Deer Refuge

Use: Hiking/Daypacking, Jogging, and Walking 

This form is not required for wildlife-dependent recreational uses, take regulated by the State, or uses already described 

in a refuge CCP or step-down management plan approved after October 9, 1997. 

Decision Criteria: YES NO

(a) Do we have jurisdiction over the use? X 

(b) Does the use comply with applicable laws and regulations (Federal, State, tribal, and local)? X 

(c) Is the use consistent with applicable executive orders and Department and Service policies? X 

(d) Is the use consistent with public safety? X 

(e) Is the use consistent with goals and objectives in an approved management plan or other 

document? 

X 

(f) Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? 

X 

(g) Is the use manageable within available budget and staff? X 

(h) Will this be manageable in the future within existing resources? X 

(i) Does the use contribute to the public’s understanding and appreciation of the refuge’s natural 

or cultural resources, or is the use beneficial to the refuge’s natural or cultural resources? 

X 

(j) Can the use be accommodated without impairing existing wildlife-dependent recreational uses 

or reducing the potential to provide quality (see section 1.6D, 603 FW 1, for description), 

compatible, wildlife-dependent recreation into the future? 

X 

Where we do not have jurisdiction over the use [“no” to (a)], there is no need to evaluate it further as we cannot control the 

use. Uses that are illegal, inconsistent with existing policy, or unsafe [“no” to (b), (c), or (d)] may not be found appropriate. 

If the answer is “no” to any of the other questions above, we will generally not allow the use. 

If indicated, the refuge manager has consulted with State fish and wildlife agencies. Yes ___ No ___

When the refuge manager finds the use appropriate based on sound professional judgment, the refuge manager must justify 

the use in writing on an attached sheet and obtain the refuge supervisor’s concurrence. 

Based on an overall assessment of these factors, my summary conclusion is that the proposed use is: 

 Not Appropriate_____ Appropriate_X__ 

Refuge Manager:____________________________________________ Date:_____________________ 

If found to be Not Appropriate, the refuge supervisor does not need to sign concurrence if the use is a new use. 

If an existing use is found Not Appropriate outside the CCP process, the refuge supervisor must sign concurrence. 

If found to be Appropriate, the refuge supervisor must sign concurrence. 

Refuge Supervisor:___________________________________________ Date:_____________________ 

A compatibility determination is required before the use may be allowed.
160 Lower Florida Keys National Wildlife Refuges 

FINDING OF APPROPRIATENESS OF A REFUGE USE 

Refuge Name: National Key Deer Refuge

Use: Horseback Riding

This form is not required for wildlife-dependent recreational uses, take regulated by the State, or uses already described 

in a refuge CCP or step-down management plan approved after October 9, 1997. 

Decision Criteria: YES NO

(a) Do we have jurisdiction over the use? X 

(b) Does the use comply with applicable laws and regulations (Federal, State, tribal, and local)? X 

(c) Is the use consistent with applicable executive orders and Department and Service policies? X 

(d) Is the use consistent with public safety? X 

(e) Is the use consistent with goals and objectives in an approved management plan or other 

document? 

X 

(f) Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? 

X 

(g) Is the use manageable within available budget and staff? X 

(h) Will this be manageable in the future within existing resources? X 

(i) Does the use contribute to the public’s understanding and appreciation of the refuge’s natural 

or cultural resources, or is the use beneficial to the refuge’s natural or cultural resources? 

X 

(j) Can the use be accommodated without impairing existing wildlife-dependent recreational uses 

or reducing the potential to provide quality (see section 1.6D, 603 FW 1, for description), 

compatible, wildlife-dependent recreation into the future? 

X 

Where we do not have jurisdiction over the use [“no” to (a)], there is no need to evaluate it further as we cannot control the 

use. Uses that are illegal, inconsistent with existing policy, or unsafe [“no” to (b), (c), or (d)] may not be found appropriate. 

If the answer is “no” to any of the other questions above, we will generally not allow the use. 

If indicated, the refuge manager has consulted with State fish and wildlife agencies. Yes ___ No ___

When the refuge manager finds the use appropriate based on sound professional judgment, the refuge manager must justify 

the use in writing on an attached sheet and obtain the refuge supervisor’s concurrence. 

Based on an overall assessment of these factors, my summary conclusion is that the proposed use is: 

 Not Appropriate_____ Appropriate_X__ 

Refuge Manager:____________________________________________ Date:_____________________ 

If found to be Not Appropriate, the refuge supervisor does not need to sign concurrence if the use is a new use. 

If an existing use is found Not Appropriate outside the CCP process, the refuge supervisor must sign concurrence. 

If found to be Appropriate, the refuge supervisor must sign concurrence. 

Refuge Supervisor:___________________________________________ Date:_____________________ 

A compatibility determination is required before the use may be allowed.
Appendices 161 

FINDING OF APPROPRIATENESS OF A REFUGE USE 

Refuge Name: Great White Heron NWR and National Key Deer Refuge

Use: Mosquito Management

This form is not required for wildlife-dependent recreational uses, take regulated by the State, or uses already described 

in a refuge CCP or step-down management plan approved after October 9, 1997. 

Decision Criteria: YES NO

(a) Do we have jurisdiction over the use? X 

(b) Does the use comply with applicable laws and regulations (Federal, State, tribal, and local)? X 

(c) Is the use consistent with applicable executive orders and Department and Service policies? X 

(d) Is the use consistent with public safety? X 

(e) Is the use consistent with goals and objectives in an approved management plan or other 

document? 

X 

(f) Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? 

X 

(g) Is the use manageable within available budget and staff? X 

(h) Will this be manageable in the future within existing resources? X 

(i) Does the use contribute to the public’s understanding and appreciation of the refuge’s natural 

or cultural resources, or is the use beneficial to the refuge’s natural or cultural resources? 

X 

(j) Can the use be accommodated without impairing existing wildlife-dependent recreational uses 

or reducing the potential to provide quality (see section 1.6D, 603 FW 1, for description), 

compatible, wildlife-dependent recreation into the future? 

X 

Where we do not have jurisdiction over the use [“no” to (a)], there is no need to evaluate it further as we cannot control the 

use. Uses that are illegal, inconsistent with existing policy, or unsafe [“no” to (b), (c), or (d)] may not be found appropriate. 

If the answer is “no” to any of the other questions above, we will generally not allow the use. 

If indicated, the refuge manager has consulted with State fish and wildlife agencies. Yes ___ No ___

When the refuge manager finds the use appropriate based on sound professional judgment, the refuge manager must justify 

the use in writing on an attached sheet and obtain the refuge supervisor’s concurrence. 

Based on an overall assessment of these factors, my summary conclusion is that the proposed use is: 

 Not Appropriate_____ Appropriate_X__ 

Refuge Manager:____________________________________________ Date:_____________________ 

If found to be Not Appropriate, the refuge supervisor does not need to sign concurrence if the use is a new use. 

If an existing use is found Not Appropriate outside the CCP process, the refuge supervisor must sign concurrence. 

If found to be Appropriate, the refuge supervisor must sign concurrence. 

Refuge Supervisor:___________________________________________ Date:_____________________ 

A compatibility determination is required before the use may be allowed.
162 Lower Florida Keys National Wildlife Refuges 

FINDING OF APPROPRIATENESS OF A REFUGE USE 

Refuge Name: Key West NWR, Great White Heron NWR, National Key Deer Refuge

Use: Research and Monitoring

This form is not required for wildlife-dependent recreational uses, take regulated by the State, or uses already described 

in a refuge CCP or step-down management plan approved after October 9, 1997. 

Decision Criteria: YES NO

(a) Do we have jurisdiction over the use? X 

(b) Does the use comply with applicable laws and regulations (Federal, State, tribal, and local)? X 

(c) Is the use consistent with applicable executive orders and Department and Service policies? X 

(d) Is the use consistent with public safety? X 

(e) Is the use consistent with goals and objectives in an approved management plan or other 

document? 

X 

(f) Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? 

X 

(g) Is the use manageable within available budget and staff? X 

(h) Will this be manageable in the future within existing resources? X 

(i) Does the use contribute to the public’s understanding and appreciation of the refuge’s natural 

or cultural resources, or is the use beneficial to the refuge’s natural or cultural resources? 

X 

(j) Can the use be accommodated without impairing existing wildlife-dependent recreational uses 

or reducing the potential to provide quality (see section 1.6D, 603 FW 1, for description), 

compatible, wildlife-dependent recreation into the future? 

X 

Where we do not have jurisdiction over the use [“no” to (a)], there is no need to evaluate it further as we cannot control the 

use. Uses that are illegal, inconsistent with existing policy, or unsafe [“no” to (b), (c), or (d)] may not be found appropriate. 

If the answer is “no” to any of the other questions above, we will generally not allow the use. 

If indicated, the refuge manager has consulted with State fish and wildlife agencies. Yes ___ No ___

When the refuge manager finds the use appropriate based on sound professional judgment, the refuge manager must justify 

the use in writing on an attached sheet and obtain the refuge supervisor’s concurrence. 

Based on an overall assessment of these factors, my summary conclusion is that the proposed use is: 

 Not Appropriate_____ Appropriate_X__ 

Refuge Manager:____________________________________________ Date:_____________________ 

If found to be Not Appropriate, the refuge supervisor does not need to sign concurrence if the use is a new use. 

If an existing use is found Not Appropriate outside the CCP process, the refuge supervisor must sign concurrence. 

If found to be Appropriate, the refuge supervisor must sign concurrence. 

Refuge Supervisor:___________________________________________ Date:_____________________ 

A compatibility determination is required before the use may be allowed.
Appendices 163 

Appendix F. Compatibility Determinations 

National Key Deer Refuge (NKDR), Great White Heron (GWHNWR) and Key West National 

Wildlife Refuges (KWNWR) Compatibility Determinations 

Uses: The following uses were evaluated to determine their compatibility with the Refuge System’s 

mission and the purpose of the Lower Keys refuges: (1) environmental education and interpretation; 

(2) hiking/daypacking, jogging, and walking (National Key Deer Refuge only); (3) bicycling (National 

Key Deer Refuge only); (4) wildlife observation and photography; (5) fishing; (6) beach use (National 

Key Deer Refuge only); (7) public use on Wilderness and Backcountry Islands; (8) research and 

monitoring; (9) mosquito management (National Key Deer Refuge and Great White Heron NWR 

only); and (10) horseback riding (National Key Deer Refuge only). A description of each use and its 

anticipated biological impacts is presented in this Compatibility Determination. 

Refuge Names/(Date Established): 

National Key Deer Refuge (August 22, 1957) 

Great White Heron National Wildlife Refuge (October 27, 1938) 

Key West National Wildlife Refuge (August 8, 1908) 

Establishing and Acquisition Authorities: 

Executive Order 923 established Key West NWR 

Executive Order 7993 established Great White Heron NWR 

71 Statute 412 established National Key Deer Refuge 

Refuge Purposes: These purposes and the mission of the National Wildlife Refuge System are 

fundamental to determining the compatibility of proposed uses of the refuge. The purposes of the 

refuges are as follows: 

National Key Deer Refuge

“... to protect and preserve in the national interest the Key deer and other wildlife resources in 

the Florida Keys.” 71 Stat. 412, dated Aug. 22, 1957. 

“... to conserve (A) fish or wildlife which are listed as endangered species or threatened species .... 

or (B) plants ...” 16 U.S.C. 1534 (Endangered Species Act of 1973). 

 “... suitable for— (1) incidental fish and wildlife-oriented recreational development, (2) the protection 

of natural resources, (3) the conservation of endangered species or threatened species ... 

” 16 U.S.C. 460k-1 “... the Secretary ... may accept and use ... real ... property. Such acceptance may 

be accomplished under the terms and conditions of restrictive covenants imposed by donors ... 

” 16 U.S.C. 460k-2 (Refuge Recreation Act (16 U.S.C. 460k-460k-4), as amended). 

“... for the development, advancement, management, conservation, and protection of fish and 

wildlife resources ...” 16 U.S.C. 742f(a)(4) “... for the benefit of the United States Fish and 

Wildlife Service, in performing its activities and services. Such acceptance may be subject to 

the terms of any restrictive or affirmative covenant, or condition of servitude ... 

” 16 U.S.C. 742f(b)(1) (Fish and Wildlife Act of 1956). 
164 Lower Florida Keys National Wildlife Refuges 

 “... conservation, management, and ... restoration of the fish, wildlife, and plant resources and their 

habitats ... for the benefit of present and future generations of Americans...” 16 U.S.C. 668dd(a)(2) 

(National Wildlife Refuge System Administration Act). 

Key West National Wildlife Refuge 

 “... a preserve and breeding ground for native birds.” Executive Order 923 dated August 8, 1908. 

“... particular value in carrying out the national migratory bird management program.” 16 U.S.C. 667b 

(An Act Authorizing the Transfer of Certain Real Property for Wildlife, or other purposes). 

to provide protection of these areas... and to ensure"...the preservation of their wilderness 

character..." Wilderness Act of 1964 (Public Law 88-577) 

Great White Heron National Wildlife Refuge 

 “... as a refuge and breeding ground for great white herons [white phase of the great blue heron], 

other migratory birds and other wildlife.” Executive Order 7993, dated October 27, 1938. 

 “... for use as an inviolate sanctuary, or for any other management purpose, for migratory birds. 

” 16 U.S.C. 715d (Migratory Bird Conservation Act). 

 “... to conserve (A) fish or wildlife which are listed as endangered species or threatened species .... 

or (B) plants ...” 16 U.S.C. 1534 (Endangered Species Act of 1973). 

 “... suitable for— (1) incidental fish and wildlife-oriented recreational development, (2) the protection 

of natural resources, (3) the conservation of endangered species or threatened species ... 

” 16 U.S.C. 460k-1 “... the Secretary ... may accept and use ... real ... property. Such acceptance may 

be accomplished under the terms and conditions of restrictive covenants imposed by donors ... 

” 16 U.S.C. 460k-2 [Refuge Recreation Act (16 U.S.C. 460k-460k-4), as amended]. 

National Wildlife Refuge System Mission: 

The mission of the System, as defined by the National Wildlife Refuge System Improvement 

Act of 1977, is: 

... to administer a national network of lands and waters for the conservation, 

management, and where appropriate, restoration of the fish, wildlife, and plant 

resources and their habitats within the United States for the benefit of present and 

future generations of Americans. 

Other Applicable Laws, Regulations, and Policies: 

Compatibility determinations for each description listed were considered separately. Although the 

preceding sections from Uses through Other Applicable Laws, Regulations and Policies are only 

written once within the plan, they are part of each descriptive use and become part of that 

compatibility determination if considered apart from the comprehensive conservation plan. 

 

Antiquities Act of 1906 (34 Stat. 225) 

Migratory Bird Treaty Act of 1918 (15 U.S.C. 703-711; 40 Stat. 755) 

Migratory Bird Conservation Act of 1929 (16 U.S.C. 715r; 45 Stat. 1222) 
Appendices 165 

Migratory Bird Hunting Stamp Act of 1934 (16 U.S.C. 718-178h; 48 Stat. 451) 

Criminal Code Provisions of 1940 (18 U.S.C. 41) 

Bald and Golden Eagle Protection Act (16 U.S.C. 668-668d; 54 Stat. 250) 

Refuge Trespass Act of June 25, 1948 (18 U.S.C. 41; 62 Stat. 686) 

Fish and Wildlife Act of 1956 (16 U.S.C. 742a-742j; 70 Stat.1119) 

Refuge Recreation Act of 1962 (16 U.S.C. 460k-460k-4; 76 Stat. 653) 

Wilderness Act (16 U.S.C. 1131; 78 Stat. 890) 

Land and Water Conservation Fund Act of 1965 

National Historic Preservation Act of 1966, as amended (16 U.S.C. 470, et seq.; 80 Stat. 915) 

National Wildlife Refuge System Administration Act of 1966 (16 U.S.C. 668dd, 668ee; 80 Stat. 927) 

National Environmental Policy Act of 1969, NEPA (42 U.S.C. 4321, et seq; 83 Stat. 852) 

Use of Off-Road Vehicles on Public Lands (Executive Order 11644, as amended by 

Executive Order 10989) 

Endangered Species Act of 1973 (16 U.S.C. 1531 et seq; 87 Stat. 884) 

Refuge Revenue Sharing Act of 1935, as amended in 1978 (16 U.S.C. 715s; 92 Stat. 1319) 

National Wildlife Refuge Regulations (50 CFR Subchapter C; 43 CFR 3101.3-3) 

Emergency Wetlands Resources Act of 1986 (S.B. 740) 

North American Wetlands Conservation Act of 1990 

Food Security Act (Farm Bill) of 1990 as amended (HR 2100) 

The Property Clause of the U.S. Constitution Article IV 3, Clause 2 

The Commerce Clause of the U.S. Constitution Article 1, Section 8 

The National Wildlife Refuge System Improvement Act of 1997 (Public Law 105-57, U.S.C.668dd) 

Executive Order 12996, Management and General Public Use of the National Wildlife Refuge 

System, March 25, 1996 

Title 50, Code of Federal Regulations, Parts 25-33 

Archaeological Resources Protection Act of 1979 

Native American Graves Protection and Repatriation Act of 1990 

Compatibility determinations for each description listed were considered separately. Although for 

brevity, the preceding sections from “Uses” through “Other Applicable Laws, Regulations and 

Policies” and the succeeding sections, “Literature Cited,” “Public Review,” and the “Approval of 

Compatibility Determinations” are only written once in the CCP, they are part of each descriptive use 

and become part of that compatibility determination if considered outside of the CCP. 

Description of Use: 

Environmental Education and Interpretation 

Environmental education and interpretation comprise a variety of activities, mediums, and facilities 

that seek to increase the public’s knowledge and understanding of wildlife and to promote wildlife 

conservation. These are tools used to inform the public of resource values and issues. Examples of 

environmental education activities include staff or teacher-led events, student and teacher workshops 

and nature studies. Interpretive programs and facilities include special events, visitor center displays, 

interpretive trails, visitor contact stations, brochures and signs. Most activities, programs, and 

facilities are located on National Key Deer Refuge. 

 

Availability of Resources: Facilities, such as visitor centers, trails and kiosks require funding to 

build and staff to operate and maintain, but they are a necessary expense to carry-out the refuges’ 

mission. The management of a volunteer program is essential to implement the environmental 

education and interpretive programs. A full-time refuge ranger position is allocated to this and the 

other visitor services tasks. 
166 Lower Florida Keys National Wildlife Refuges 

Anticipated Impacts of the Use: The use of the refuge for on-site, hands-on, action-oriented 

activities by groups to accomplish environmental education objectives may impose short-term 

impacts on the sites used for the activities. Impacts include trampling of vegetation and temporary 

disturbance to wildlife species in the immediate use area. Group activities would not be done where 

impacts would be permanent or long-lasting. Most of the interpretive activities occur on hardened 

surfaces and existing trails and pose a minimal threat to wildlife and habitat. 

Public Review Comment: This compatibility determination is being made available for public review 

and comment in conjunction with the 30-day public review and comment period for the Draft 

Comprehensive Conservation Plan and Environmental Assessment. 

Determination (check one below): 

___ Use is Not Compatible 

 X Use is Compatible with Following Stipulations 

Stipulations Necessary to Ensure Compatibility: Activities should be held on hardened sites 

where minimal impact will occur. Periodic evaluation of the sites and program activities should be 

done to assess whether the program objectives are being met and whether resources are being 

degraded. If adverse impacts become evident, environmental education and interpretive activities 

may need to be rotated, moved, reduced, or eliminated. Certain areas of the refuge may be 

restricted seasonally to avoid disturbance of breeding or nesting wildlife or to protect sensitive habitat. 

Justification: Environmental education and interpretation are priority public uses under the National 

Wildlife Refuge System Improvement Act. The refuge uses environmental education and 

interpretation to motivate citizens of all ages to support and practice wildlife and wild lands 

stewardship. Environmental education and interpretation can have positive outcomes, such as 

instilling a land preservation ethic in visitors, developing support for the refuge, and lessening 

vandalism, poaching and littering. Through these combined activities, the refuge reaches a diverse 

group of more than 90,000 visits annually, primarily at NKDR. Refuge outreach also occurs on Key 

West and Great White Heron refuges through occasional public contacts in the field, at public events, 

and through the Florida Keys EcoDiscovery Center in Key West. 

Mandatory 15-year Re-evaluation Date:__________________

Description of Use: 

Hiking/daypacking, jogging and walking (NKDR only) 

Refuge roads, firebreaks, and developed trails on the mainline islands of National Key Deer Refuge 

are commonly used by local residents and visitors for walking, hiking, daypacking, and jogging. This 

activity is intended for foot traffic only by individuals and small groups. 

Availability of Resources: The roads, firebreaks, and trails are maintained for refuge purposes and 

therefore do not constitute additional cost for these public activities. All are maintained by a 

combination of volunteers and refuge staff. 

Anticipated Impacts of the Use: Impacts from these activities could include wildlife disturbance, 

collecting, poaching, plant removal, littering, and vandalism 
Appendices 167 

Public Review Comment: This compatibility determination is being made available for public review 

and comment in conjunction with the 30-day public review and comment period for the Draft 

Comprehensive Conservation Plan and Environmental Assessment. 

Determination (check one below): 

___ Use is Not Compatible 

 X Use is Compatible with Following Stipulations 

Stipulations Necessary to Ensure Compatibility: Hiking, jogging, and walking are restricted to 

daylight hours. Certain areas of the refuge may be restricted seasonally to avoid disturbance of 

breeding or nesting wildlife or to protect sensitive habitat. These activities are prohibited in all posted 

closed areas, including (but not limited to) Watson Hammock and Cactus Hammock on Big Pine Key 

and the wetland area on Ohio Key. Non-refuge sponsored groups of more than 10 persons must 

apply for a special use permit. Athletic races and other non-wildlife dependent organized events are 

prohibited. All trash must be packed out and properly disposed off-site. Pets must be kept on a 

leash at all times. 

Justification: These activities are low impact and considered to be wildlife-oriented. Observation of 

wildlife is enhanced by using the many trails offered at the refuge. 

Mandatory 10-year Re-evaluation Date:__________________

Description of Use: 

Bicycling (National Key Deer Refuge) 

Refuge roads, firebreaks, and trails on the mainline islands of National Key Deer Refuge are often 

used by local residents and visitors for bicycling. 

Availability of Resources: The roads, firebreaks, and trails are maintained for refuge purposes and 

do not incur any additional costs for allowing bicycling. 

Anticipated Impacts of the Use: Minor impacts may occur, such as wildlife disturbance, collecting, 

poaching, soil compaction, vegetation trampling, littering, and vandalism. Bicyclists may occasionally 

compete for trail use with other visitors traveling on foot or horseback. Refuge law enforcement 

officers patrol regularly and volunteers and refuge staff regularly pick-up litter. 

Public Review Comment: This compatibility determination is being made available for public review 

and comment in conjunction with the 30-day public review and comment period for the Draft 

Comprehensive Conservation Plan and Environmental Assessment. 

Determination (check one below): 

___ Use is Not Compatible 

 X Use is Compatible with Following Stipulations 
168 Lower Florida Keys National Wildlife Refuges 

Stipulations Necessary to Ensure Compatibility: Bicycling is not allowed in Great White Heron or 

Key West NWRs. Bicycling is restricted to refuge-maintained roads, firebreaks, and trails on the 

mainline islands of National Key Deer Refuge, with the exception of the Blue Hole, Watson, and 

Mannilo interpretive trails on Big Pine Key (Figure 1). Bicycling is prohibited in all posted closed areas, 

including (but not limited to) Watson Hammock and Cactus Hammock on Big Pine Key and the wetland 

area on Ohio Key. Off-road and off-trail biking is prohibited. Non-refuge sponsored groups of more 

than 10 cyclists must apply for a special use permit. Athletic and competitive (e.g., extreme sport) 

events are prohibited. Bicycling is restricted to daylight hours. Certain areas of the refuge may be 

restricted seasonally to avoid disturbance of breeding or nesting wildlife or to protect sensitive habitat. 

All trash must be packed out and properly disposed off-site. Pets must be kept on a leash at all times. 

Justification: Bicycling on refuge-maintained roads and trails is considered a low impact, wildlifeoriented use. Some parts of the refuge, such as Upper and Lower Sugarloaf Keys, are more easily 

accessed by bicycle since distances are too great for access by foot for some persons. 

Mandatory 10-year Re-evaluation Date: __________________

Description of Use: 

Research and monitoring 

This includes scientific research, baseline inventory, long-term monitoring, and scientific collecting 

conducted by non-refuge personnel on refuge lands. Research and monitoring are used to help 

increase knowledge and understanding of animals, plants, habitats, and ecosystem processes found 

on the refuge. This activity will allow both short- and long-term research projects by other resource 

agencies, universities, non-profit organizations, and other research entities. Results of research and 

monitoring allow refuge managers to evaluate management activities and adapt those activities to be 

more effective. All researchers shall be required to obtain special use permits from the refuge. The 

research is very wide-ranging in nature and includes activities such as animal radio tracking, 

biological studies, vegetation surveys, animal trapping, and disease monitoring. 

Availability of Resources: Other than administration of associated special use permits, no refuge 

resources above general operational costs are required for this use. Researchers typically provide all 

the materials needed and, depending on the project, the refuge may provide support with office 

space, housing (bunkhouse), boats, and/or vehicles. 

Anticipated Impacts of the Use: Generally, impacts from research and monitoring are minimal. 

There may be some slight or temporary disturbance to wildlife or habitats, such as minor trampling of 

vegetation or flushing of birds. These impacts are not significant or permanent. A small number of 

individual plants or animals might be collected for further scientific study, but these collections are 

anticipated to have minimal impact on the populations from which they came. The collection or 

monitoring of field data during a research project may cause mortality to some target species. Minor 

habitat and temporary wildlife disturbance may also occur. Research project impacts are minimized 

by applying stipulations on research activities under the special use permit by refuge personnel. 

Interim and final reports are required under the special use permits. The activity is a Categorical 

Exclusion per 516 DM Appendix 1, section 1.5. 
Appendices 169 

Public Review Comment: This compatibility determination is being made available for public review 

and comment in conjunction with the 30-day public review and comment period for the Draft 

Comprehensive Conservation Plan and Environmental Assessment. 

Determination (check one below): 

___ Use is Not Compatible 

 X Use is Compatible with Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

Special use permits will stipulate any specific restrictions that apply to the study, proposed methods, or 

study area. These are done on a case-by-case basis. Interim and final reports are required. In 

applying for special use permits, researchers are required to show proof that they have fulfilled all other 

applicable permitting requirements, such as state collecting permits and endangered species permits. 

Justification: Research and monitoring can provide important benefits to the refuge and the natural 

resources supported by the refuge. Research conducted on the refuge can lead to new discoveries, 

new facts, verified information, and better management decisions. Research and monitoring is vital 

for furthering knowledge and understanding of refuge resources. The refuge is the largest landowner 

in the Lower Florida Keys and, in conjunction with refuge-managed state and county lands, provides 

the most available research opportunities. 

Mandatory 10-year Re-evaluation Date:__________________

Description of Use: 

Wildlife observation and photography 

Wildlife observation is the viewing of fish, wildlife, plants, or their habitats by refuge visitors. 

Photography is defined as refuge visitation for the purpose of photographing refuge natural or cultural 

resources or public uses of those resources for personal use. Photography conducted for 

commercial, news, or educational purposes are allowed only as authorized in a special use permit. 

Non-consumptive wildlife observation uses include bird watching and nature photography by walking 

or using motorized vehicles, boats, bicycles, or horses. Foot travel is generally allowed on refuge 

roads, firebreaks, and trails. 

Availability of Resources: Trails are maintained and patrolled for refuge purposes and recreational 

use and require no additional maintenance costs for wildlife observation and photography. Additional 

platforms, photography blinds, or towers to encourage these uses on the refuge would involve new 

construction and maintenance costs. 

Anticipated Impacts of the Use: Some violations of refuge regulations are anticipated, such as 

wildlife disturbance, collecting, poaching, plant removal, littering, and vandalism. 

Public Review Comment: This compatibility determination is being made available for public review 

and comment in conjunction with the 30-day public review and comment period for the Draft 

Comprehensive Conservation Plan and Environmental Assessment. 
170 Lower Florida Keys National Wildlife Refuges 

Determination (check one below): 

___ Use is Not Compatible 

 X Use is Compatible with Following Stipulations 

Stipulations Necessary to Ensure Compatibility: Law enforcement patrol of public use areas 

should continue to minimize violations of refuge regulations. The refuge is closed overnight. Some 

areas may be closed to the public seasonally to protect wildlife from disturbance or to protect habitat. 

Public use is prohibited in all posted closed areas, including (but not limited to) Watson Hammock 

and Cactus Hammock on Big Pine Key, the wetland area on Ohio Key, and designated beaches and 

whole islands in Key West and Great White Heron NWRs. Refuge access is restricted to daylight 

hours. A special use permit would be required for after-hours use or for commercial photography. 

Justification: Wildlife observation and photography are priority public uses under the National 

Wildlife Refuge System Improvement Act. 

Mandatory 15-year Re-evaluation Date:__________________

Description of Use: 

Fishing 

Fishing refers to traditional, recreational, and saltwater fishing with a hook and line. Saltwater fishing 

occurs in state-managed waters on all three refuges. At National Key Deer Refuge, there are two 

areas with accessible shoreline at Ohio Key and Long Beach trail. Key West and Great White Heron 

NWRs have huge expanses of fishing in state-managed marine waters and some fishing occurs on 

island shorelines. Fishing is prohibited in the Blue Hole on Big Pine Key. 

Availability of Resources: Staff resources are adequate for allowing this use. This is an 

established part of law enforcement officer duties in coordination with Florida Fish and Wildlife 

Conservation Commission officers. Litter control is handled by refuge staff and volunteers. 

Anticipated Impacts of the Use: The primary impacts of this use are disturbance to and the taking 

of non-target wildlife species, littering, vegetation and dune trampling, and water pollution from boat 

motors. Secondary impacts may include wildlife injury or death by entanglement or ingestion of 

discarded fishing line and hooks. 

Public Review Comment: This compatibility determination is being made available for public review 

and comment in conjunction with the 30-day public review and comment period for the Draft 

Comprehensive Conservation Plan and Environmental Assessment. 

Determination (check one below): 

___ Use is Not Compatible 

 X Use is Compatible with Following Stipulations 

Stipulations Necessary to Ensure Compatibility: All fishing activities must adhere to state fishing 

laws and regulations. Fishing from shorelines on the refuge is restricted to refuge hours (i.e., daylight 

use). No improvements to fishing areas, such as docks and piers, will be developed. 
Appendices 171 

Justification: Fishing is a priority public use under the National Wildlife Refuge System 

Improvement Act and a wildlife-dependent activity that is compatible with refuge purposes. 

Mandatory 15-year Re-evaluation Date:__________________

Description of Use: 

Beach Use (Picnicking, Shelling, Swimming, or Snorkeling from shore) (National Key Deer Refuge) 

There are currently no designated picnic sites within the refuge; however, informal picnicking is 

allowed on the beaches. Entry to and from the water for shelling, swimming, and snorkeling is 

allowed from the refuge, excepted in posted closed areas. 

Availability of Resources: The beaches are maintained by refuge staff and volunteers. 

Anticipated Impacts of the Use: No significant impacts are anticipated from informal picnicking. 

Some littering, vandalism, plant removal, and feeding/disturbance of wildlife may occur. Violations 

would be infrequent and confined to the small areas. Litter is controlled through the waste pickup by 

refuge and contracted staff and by volunteers. Informal picnicking at other non-designated sites 

should not result in significant impacts. 

Public Review Comment: This compatibility determination is being made available for public review 

and comment in conjunction with the 30-day public review and comment period for the Draft 

Comprehensive Conservation Plan and Environmental Assessment. 

Determination (check one below): 

___ Use is Not Compatible 

 X Use is Compatible with Following Stipulations 

Stipulations Necessary to Ensure Compatibility: Law enforcement patrol of the beach areas 

should minimize any violations of refuge regulations. Shelling is restricted to the collection of 

uninhabited shells. No taking of shells with live animals (mollusks or hermit crabs) is allowed. 

The following are prohibited on refuge beaches: beach games (e.g., volleyball, frisbee, 

badminton, football, and catch); blaring of radios, stereos, music players or excessive noise 

(screaming and yelling); pets; use of grills, barbeques, smokers, or firepits; campfires and 

camping; use of portable generators; and littering or dumping of trash. All trash must be carried 

out. Umbrellas, tents, and chairs may not be set-up, left behind, or used. All posted closed areas 

are prohibited from these activities. All trash must be packed out and properly disposed off-site. 

Pets must be kept on a leash at all times. 

Justification: While none of these uses are wildlife-dependent, the beaches give refuge visitors a 

place to walk, swim from shore or rest and observe wildlife with minimal disturbance to wildlife. 

Mandatory 10-year Re-evaluation Date:__________________
172 Lower Florida Keys National Wildlife Refuges 

Description of Use: 

Public Use of Wilderness Islands (Key West NWR) 

In 1975, Wilderness designation (Public Law 93-632) was conferred on all islands in Key West NWR. 

This designation applied only to the islands themselves, not the State of Florida waters surrounding 

them. Because nearly all wilderness islands are dominated by mangrove forests, they afford no 

opportunity for public use and are closed to public entry. The exceptions are the seven, distinct 

beaches on the Marquesas Keys and the beaches on Woman and Boca Grande Keys. The discussion 

that follows and this compatibility determination apply only to the island beaches of these three keys. 

The islands are remote; the nearest, Woman Key, is about 16 km west of Key West and the most 

distant, the Marquesas Keys, is about 40 km from this town. One-half of the beaches on Woman and 

Boca Grande Keys, islands harboring threatened piping plovers, were closed to human visitation in 

1992 to protect wildlife from human-caused disturbance. All refuge beaches are narrow and 

inundated at high tide. With the exception of the northwest part of Boca Grande Key, all are bordered 

by extensive tidal flats, including substantial seagrass beds. During high use periods, typical beach 

use on Boca Grande Key includes partying, sunbathing, and picnicking. 

Availability of Resources: Two refuge law enforcement officers are charged with patrolling land 

and water areas in the four distinct refuges comprising the Florida Keys National Wildlife Refuges. 

One of the officers has been designated for patrol in the Key West National Wildlife Refuge. 

Anticipated Impacts of the Use: Dune vegetation is fragile and sensitive to trampling by humans 

(McConnel 1981). On Boca Grande Key and three islands in the Marquesas Keys (Bradley 1999 

a,b,c,d), the vegetation includes the endangered Garber’s spurge. Landward of the narrow beaches 

are intricate networks of dunes and salt tolerant shrubs. Plants adapted to the dune environment 

form a fragile network holding the sand in place (McDonnell 1981, Carter et al., 1990a). Dune 

cohesion is increased by plant roots, without which undercutting of the dune can be continuous 

during storms (Carter et al., 1990b). Erosion can be so severe as to remove the protective beach, 

scarp the dune, and completely shift the dune crest (Carter et al., 1990a). 

On some summer weekends—especially the Memorial Day weekend—acute overcrowding has been 

a long-term problem on Boca Grande Key on the island’s northwest side, which has the only deep 

water access to the beach. During some peak-use weekends, scores of boats and hundreds of 

people are concentrated in a 600-foot-long area, where the beach is either very narrow or fully 

inundated by tides. As a result, dune vegetation is damaged, destabilizing the beach and fostering 

erosion. Signs informing visitors not to enter the dunes are often ignored when visitor numbers are 

high. Some visitors ascend dune-bordered scarps and further destabilize these highly erosion-prone 

areas. The endangered Garber’s spurge can be damaged or killed by visitors entering the dunes. 

When this and other species of dune vegetation are damaged, the disturbed conditions may spur the 

invasion of non-native grasses or forbs, which may then displace native species. 

 

Two trust species may be adversely affected by public use of the islands - green sea turtles and 

Miami blue butterflies. All green turtle nesting since 1990 on Boca Grande Key has occurred on 

the island’s northwest side, nearly always in the dune vegetation. The dune’s width has been 

progressively shrinking; its now-extreme narrowness looms increasingly as a threat to successful 

turtle nesting. Inadvertent walking above sea turtle nests can cause collapse and kill hatchlings 

(Dutton et al., 1994); compaction of sand from foot traffic can preclude the emergence of 

hatchlings (Mann 1977); pedestrian tracks and litter can impede movements by hatchlings 

(Hosier et al., 1981; Dutton et al., 1994). Sun umbrellas, chairs, towels, and other beach 

accessories—all observed on refuge beaches—can cause shading of nests and alter incubation 
Appendices 173 

temperatures (Arianoutsou 1988). Protection of nesting beaches is considered one of the highest 

priorities for perpetuation of sea turtles (Dodd 1988; Dodd 1992; Ehrhart 1992; NMFS and 

USFWS 1991a,b; Meylan et al., 1995; McClenachan et al., 2006). 

Boca Grande Key and five islands in the Marquesas Keys harbor the State-endangered Miami blue 

butterfly. Once thought to be extinct in the United States, only a tiny population (<100 individuals) 

occurs outside the refuge. The refuge population numbered more than 1,000 individuals during 

recent surveys (November 2006—April 2007), where it was found only in dunes and low shrubs 

bordering refuge beaches. During the surveys, damage to beach vegetation by human visitors was 

documented on Boca Grande Key and three of the Marquesas beaches. Negative impacts to the 

habitat of the Miami blue butterfly and threatened and endangered nesting sea turtles would occur if 

the recommended restrictions are not implemented. 

Conflicts among user groups are inevitable when large numbers of visitors are present in a confined 

area. Those seeking wildlife-dependent recreational activities are stymied in their pursuit because of 

the sheer density of people. Alcohol consumption is prevalent on holiday weekends, escalating the 

risk of violent behavior. In 2006, a fight among a number of visitors on Boca Grande Key required 

multiple agency law enforcement intervention to curtail the problem. Because the beaches on Boca 

Grande and Woman Keys are extremely narrow, visitors walking on the beach pass within mere feet 

of other visitors on the island. The presence of a large number of people on such a tiny island 

deprives all visitors of any opportunity for, as stated in the Wilderness Act of 1964, "...opportunities for 

solitude or a primitive or unconfined type of recreation." 

Natural areas are influenced by both the extent and concentration of human activities (Jacobson and 

Lopez 1994). The concept of visitor carrying capacity, defined here as the threshold where public use 

degrades the resource base and excessive visitor numbers debase the wilderness experience, is a 

relevant concept to the problem of overcrowding on wilderness islands. The Service recognizes that 

public use of wilderness areas may lead to serious damage of the wilderness resource (6 RM 8.9A). 

Specific reference is made to public use in sensitive areas or tracts of small size (6 RM 8.9A), both of 

which would be applicable to the beaches in Key West NWR: "Excessive public use of sensitive areas or 

small units, particularly those located in populated areas, may warrant special regulations to limit the 

number of visitors or the duration of visits." Further, “Wilderness areas may be closed to all public use if 

such use is determined to be incompatible with refuge purposes” (6 RM 8.9A). 

Although visitor carrying capacity in protected areas is a subjective matter (see Moore and Polley 

2007), it is inherently very low on refuge beaches because: (1) the stabilizing dune vegetation is 

easily damaged by trampling; (2) the beaches are short and extremely narrow, thereby concentrating 

visitors; (3) all refuge beaches are designated as federal wilderness—overcrowding is contrary to 

federal wilderness management guidelines; (4) overcrowding ruins the experience of visitors seeking 

a wilderness experience in a site designated for that purpose; (5) Miami blue butterfly nesting and 

foraging areas and sea turtle nesting habitat can be degraded by visitors walking on the dune 

vegetation; and (6) access to some beaches is limited by shallow water, thereby concentrating 

arriving visitors at deeper water access points. 

Key West NWR was established as “a preserve and breeding ground for native birds and other 

wildlife. ”To meet this mandate, and the mandates of preserving wilderness character (Wilderness 

Act of 1964) and promoting wildlife dependent public uses (National Wildlife Refuge Improvement Act 

of 1997), it is necessary to establish and enforce carrying capacities for visitor use on all refuge 

beaches, particularly during holiday weekends. Carrying capacities would reflect known differences 

among beaches and dunes, including access to boaters, public use patterns, wildlife populations, and 

habitat concerns. During holiday weekends, on Boca Grande Key, it may prove necessary to close 
174 Lower Florida Keys National Wildlife Refuges 

this beach in its entirety. This action may lead to severe overcrowding on Woman Key (although this 

area has poor beach access), or have the highly undesirable effect of shunting visitors to the more 

distant and pristine islands in the Marquesas Keys. Currently, enforcement personnel are inadequate 

to enforce carrying capacities or a holiday beach closure at Boca Grande Key. If instituted, these 

measures would demand careful scrutiny to ensure that intended purposes are achieved, with 

changes instituted to achieve the referenced refuge mandates. 

Public Review Comment: This compatibility determination is being made available for public review 

and comment in conjunction with the 30-day public review and comment period for the Draft 

Comprehensive Conservation Plan and Environmental Assessment. 

Determination (check one below) 

___ Use is Not Compatible 

 X_ Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility: Beach use should be deemed compatible only if 

damage by visitors to adjacent dune vegetation is curtailed. A cogent, persistent message to the 

public should be purveyed about the necessity of not walking on dune vegetation. Given that all 

beaches are under water at high tide, visitors must be urged to remain in their boats at such time to 

avoid trampling of the dune vegetation. Damaged areas should be placed off limits and a wooden 

dune fence erected to effect habitat restoration. 

The impact of beach visitors on Boca Grande Key must be monitored, particularly on the northwest 

side of the island. If dune habitat integrity cannot be maintained by setting and enforcing visitor 

carrying capacities in this area, as well as in other refuge beach/dune areas, and by implementing a 

holiday beach closure, then it should be closed to protect the dwindling nesting habitat for the 

endangered green sea turtle and the Miami blue butterfly. 

Without setting carrying capacities or instituting beach closures, as circumstances dictate, beach and 

associated dune areas in the refuge may be subjected to levels of visitor use that are contrary to 

stated mandates for the refuge. 

Law enforcement patrol of the beach areas should minimize any violations of refuge regulations. 

Shelling is restricted to the collection of uninhabited shells. No taking of shells with live animals (e.g., 

mollusks or hermit crabs) is allowed. The following are prohibited on refuge beaches: beach games 

(e.g., volleyball, frisbee, badminton, football, and catch); blaring of radios, stereos, music players, or 

excessive noise (e.g., screaming and yelling); pets; use of grills, barbeques, smokers, or firepits; 

campfires and camping; use of portable generators; and littering or dumping of trash. Trash must be 

carried out. Umbrellas, tents, and chairs may not be set-up, used, or left behind. 

Justification: While not a priority public use or wildlife-dependent use, beach use is popular among 

residents and tourists alike and, as sand beaches are rare in the Florida Keys, demand is high. 

Beaches are a major attraction for Monroe County’s tourism-based economy. To the extent that the 

refuge can accommodate passive beach uses that encourage wildlife viewing with minimal impacts 

and disturbance to habitat and wildlife, it will. 

Mandatory 10-year Re-evaluation Date:__________________
Appendices 175 

Description of Use: 

Mosquito Control Operations (National Key Deer Refuge and Great White Heron NWR) 

The Florida Keys Mosquito Control District (District) conducts a program to monitor, research, and 

control mosquito populations on the National Key Deer Refuge and Great White Heron NWR. Due to 

the diversity of the mosquito fauna in the Keys, the subtropical climate, and the proximity of the Keys 

to the Caribbean, where active transmission of several disease organisms is ongoing, the District 

believes that a potential exists for the transmission and spread of mosquito-borne diseases. These 

diseases include malaria, St. Louis encephalitis, eastern equine encephalitis, and West Nile virus. 

The District’s work is performed under a refuge-issued special use permit. 

The District and the refuges have developed an integrated pest management program that includes 

the use of both larvicide (Bacillus thuringiensis israelensis or BTI) and adulticide (Naled) to control 

mosquitoes. BTI is a selective microbial insecticide targeting mosquito larvae and some other nontarget dipterans, with minimal impact to other non-target species. By treating mosquito breeding 

areas on the backcountry keys with BTI, the District has demonstrated that it can dramatically reduce 

the need to use broad-spectrum adulticides on the mainline keys to control mosquitoes. Refuge sites 

to be treated with larvicide include all areas within the National Key Deer Refuge and Great White 

Heron NWR that are serviced by primary and secondary roads. In addition, islands not connected by 

roads (e.g., Annette, Mayo, Porpoise, Johnson, Horseshoe, Howe, Raccoon, Pumpkin, Johnston, 

Little Pine Keys, Johnson Keys, and Water Keys) may be aerially treated with BTI. 

Naled has been used as a mosquito adulticide in the Keys for more than 30 years. Refuge lands are 

interspersed with private property and development, making it impossible to develop separate 

mosquito spraying programs for both public and private lands. Control of mosquitoes in developed 

areas of the Keys requires that some refuge lands be treated. Areas to be treated will consist of all 

refuge lands adjacent to and interspersed within existing human development and serviced by 

primary and secondary roads. This includes refuge lands on Big Pine, No Name, Middle Torch, and 

Big Torch Keys, consisting of 6,000 acres; however, Naled will not be applied in the Watson 

Hammock or Cactus Hammock areas on Big Pine Key or on the southern half of No Name Key. On 

more isolated refuge lands of Cudjoe, Sugarloaf, and Boca Chica Keys, as well as the Saddlebunch 

Keys, only privately owned and developed areas will be sprayed; therefore, refuge properties on 

these Keys will not be affected by mosquito spraying. 

The District and Service continue to collaboratively assess the effectiveness of mosquito control 

activities and evaluate impacts on priority species; consequently, operations will continue to be 

reviewed and adjusted as necessary. 

Availability of Resources: 

All aspects of this mosquito spraying program will be financed and administered by the Florida Keys 

Mosquito Control District. Refuge and Ecological Services’ staffs will participate in the annual review 

and evaluation of mosquito control operations and special use permit compliance, and oversee field 

studies on biological impacts of mosquito spraying on non-target species. 

Anticipated Impacts of the Use: 

Naled is a broad-spectrum adulticide that can kill a wide variety of insects, fish, and wildlife. Naled is 

characterized as highly toxic to bees and aquatic invertebrates, moderately to highly toxic to fish, 

moderately to highly toxic to birds, and moderately toxic to mammals; however, the Environmental 

Protection Agency has determined that Naled used in mosquito control programs according to label 
176 Lower Florida Keys National Wildlife Refuges 

directions does not pose unreasonable risks to wildlife or the environment. With the exception of the 

Stock Island tree snail (Orthalicus reses reses), the South Florida Multi-Species Recovery Plan does 

not list mosquito spraying as an identified threat to any federally listed threatened or endangered 

species in the Lower Keys. 

Environmental risk assessments conducted on the Key deer, silver rice rat, eastern indigo snake, and 

Lower Keys marsh rabbit suggest that Naled is not likely to cause acute or chronic poisoning given 

the application rates and application frequencies proposed by the District with stipulations under the 

refuge special use permit. Because the Level of Concern standards for endangered species are 

much higher than those set for other wildlife, it can be assumed that the aerial application of Naled is 

not likely to result in acute or chronic toxicity in other resident and nonresident wildlife species. As a 

result of pesticide drift, some Naled may inadvertently contaminate aquatic environments; however, 

aerially applied Naled will reach the water surface at reduced concentrations and degrade rapidly, 

thus posing little or no risk to fish populations in the Keys. 

Laboratory studies have shown that Naled is highly toxic to bees and estuarine/marine 

invertebrates. It can be assumed that terrestrial invertebrates, including butterflies and tree 

snails, are also highly susceptible to Naled poisoning. Any adverse effects of Naled to vertebrate 

and invertebrate communities would be minimized through the application of the pesticide in 

concert with an expanded use of BTI throughout the Lower Keys. Reduced application 

frequencies would minimize the numbers of invertebrates directly poisoned by Naled. Reduced 

applications would also result in applications being spaced farther apart in time. This would allow 

unaffected eggs, larvae, pupae, and adult’s time to complete their life cycles, allowing for a rapid 

buildup of invertebrate populations to pre-application levels. 

BTI is a microbial larvicide that is applied to aquatic habitats where mosquito larvae occur since it 

must be ingested to be effective. Because it must be ingested by the mosquito larvae, it is largely 

species-specific and poses a minimal threat to non-target vertebrate and invertebrate species. This 

bacterium produces a crystal-containing spore that causes fragment toxicity when ingested by the 

mosquito larvae. It is species-specific and affects the larvae of mosquitoes, black flies, and midges. 

Of these, only mosquitoes are found in the Keys in any numbers. Experimental testing has shown no 

demonstrated effect against other aquatic insects, including dragonflies, damselflies, mayflies, 

stoneflies, caddis flies, and water beetles. Other invertebrates, such as Daphnia, cyclops, rotifers 

and crustaceans, are also not susceptible to BTI. A summary review of mammalian toxicity studies 

has revealed no known mammalian health effects resulting from BTI. It is not a phytotoxic and has 

shown no effect on seed germination or plant vigor. 

Public Review Comment: This compatibility determination is being made available for public review 

and comment in conjunction with the 30-day public review and comment period for the Draft 

Comprehensive Conservation Plan and Environmental Assessment. 

Determination (check one below): 

___ Use is Not Compatible 

 X Use is Compatible with Following Stipulations 
Appendices 177 

Stipulations Necessary to Ensure Compatibility:

y Areas to be treated with Naled will be limited to refuge lands on Big Pine, No Name, Middle 

Torch, and Big Torch Keys. 

y Naled will be aerially applied at rates of 0.0785 pounds active ingredient/acre or less. 

y Naled will be applied at the optimal droplet size of 22-29 microns using ultra-light volume 

spray equipment. 

y All applications of Naled will be made during favorable weather conditions for maximum 

effectiveness against mosquitoes and to avoid drift. 

y The application of Naled is prohibited in Watson Hammock and Cactus Hammock on Big Pine 

Key, as well as all areas on No Name Key south of Watson Boulevard. 

y Naled will be applied in concert with the expanded use of BTI to reduce the number of 

applications of Naled to nine per season with applications spaced no closer than 5 days apart. 

This will minimize the adverse effects to invertebrates from this broad-spectrum adulticide. 

y Refuge sites to be treated with BTI include all areas within the National Key Deer Refuge and 

Great White Heron NWR serviced by primary and secondary roads. Treatment of 

backcountry islands with BTI will be limited to Annette, Mayo, Porpoise, Horseshoe, Howe, 

Raccoon, Pumpkin, Johnston, and Little Pine Keys, Water Keys, and Johnson Keys,. 

 

Justification: Refuge lands are tightly interspersed with private property and residential and 

commercial development, making it impossible to separate mosquito control programs for the two 

areas. Controlling mosquitoes in developed areas of the Keys requires that some refuge lands also 

be treated. It is the desire of the refuges to ensure that the required control of mosquitoes be 

conducted with as little use of the adulticide Naled as possible. The District believes much of the 

Naled applied on refuge lands is the result of mosquitoes migrating from large hatches on adjacent 

backcountry islands; therefore, the Service has agreed to allow larvicide application on backcountry 

wilderness islands for an anticipated reduction in the overall application of Naled. 

Mosquito control is necessary to protect the general public from the threat of mosquito-borne 

diseases in the Florida Keys. Furthermore, a mosquito control program which reduces nuisance 

pests is vital in supporting the ability of the Florida Keys to remain a tourist destination, as well as 

maintaining a comfortable environment for both residents and tourists alike. The Service must strive 

to be a good neighbor and develop management programs that not only protect its trust resources 

but that also do not adversely affect the communities that surround them. 

Mandatory 10-year Re-evaluation Date:__________________

Description of Use: 

Horseback Riding (National Key Deer Refuge only) 

Horseback riding is an existing use on National Key Deer Refuge that facilitates wildlife observation. 

As proposed, horseback riding would occur only on refuge roads and firebreak trails. There is no 

designated parking for horse trailers, which limits use on the refuge mainly to nearby residential 

users. Use is light and sporadic, occurring mostly by local residents. 
178 Lower Florida Keys National Wildlife Refuges 

Availability of Resources: Based on existing refuge expenditures for managing visitor use, funding 

is adequate to ensure compatibility and to administer and manage the recreational use listed. 

Anticipated Impacts of Use: A literature review was conducted to evaluate the potential effects of 

horseback riding on wildlife, habitat, human health, cultural resources, and other refuge uses. 

Although wildlife disturbance from horseback riding is not well-documented, some studies suggest 

that many wildlife species are habituated to livestock and that horseback wildlife observers can 

approach wildlife at closer distances than by other forms of travel. Any form of approach is expected 

to cause some disturbance, which will vary according to the species affected and the type, level, 

frequency, and duration of disturbance, as well as the time of day or year that it occurs. 

Horseback riding has both direct and indirect effects on habitat. Trampling causes mortality of plant 

and animal species. Indirect effects result when soil is compacted and plants cannot re-establish. 

Grazing can reduce vegetation. There is a debate over whether horse hair or feces can spread 

exotic weed seed. Any trail or road can be a conduit for the introduction of exotic plants, since 

exposed soil and abundant sunlight provide favorable conditions for establishment. 

Compacting and loosening of soils occur from stock riding, more so in moist or wet soils. Therefore, 

trails should be established in well-drained, upland sites. Roads and trails for public access affect 

hydrologic drainage patterns. 

While it is possible for horses to transmit parasitic diseases, particularly Cryptosporidium parvum and 

Giardia duodenalis, to humans via the water supply, these diseases are usually spread by pregnant 

mares and foals under 6 months old, not through adult horse guts. Horse manure is not harmful to 

human health, although it can cause conflicts with other trail users since it can be odorous, 

unaesthetic, and a nuisance. 

While there can be user group conflicts or safety issues resulting from hikers, cyclists, and horseback 

riders using the same roads and trails, there have not been such conflicts or issues, nor are they 

anticipated effects due to the current levels of use. Horseback travel on the designated roads and 

fire breaks is considered safe under current conditions and levels of use. 

 

Public Review Comment: This compatibility determination is being made available for public review 

and comment in conjunction with the 30-day public review and comment period for the Draft 

Comprehensive Conservation Plan and Environmental Assessment. 

 

Determination (check one below): 

___ Use is Not Compatible 

 X Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility: Horseback travel to facilitate priority public use 

is allowed only on National Key Deer Refuge roads and firebreaks on Big Pine Key (Figure 1). 

Horses are not allowed on foot or interpretive trails, such as the nature trails at Blue Hole, Watson 

and Mannilo Nature Trails, Watson Hammock, and the proposed links to these trails. Horseback 

riding is not allowed on No Name Key, Crane Boulevard, and the fire breaks on Cudjoe and Sugarloaf 

Keys. Riding is only allowed on the refuge during daylight hours. Group size is limited to a maximum 

of six riders who travel no more than two abreast. All roads will be monitored annually to determine if 

they meet the compatibility criteria. Monitoring will be designed to assess the long-term effects of 

horse riding on refuge resources, visitor use, and route maintenance needs. Law enforcement 

patrols will be conducted throughout the year. The patrols will promote compliance with refuge 
Appendices 179 

regulations, monitor public use patterns and public safety, and document visitor interactions. Some 

areas may be closed seasonally or as needed to all visitor use, including horseback riding, to prevent 

wildlife disturbance or habitat impacts. 

Justification: While not listed as a primary, wildlife-dependent recreational use under the 

National Wildlife Refuge System Improvement Act, horseback riding by a small number of local 

residents has been a non-traditional use for a couple of decades. If limited to present-day levels 

of use, horseback riding is believed to be a compatible public use under the stipulations outlined 

in this compatibility determination. Primary reasons for this determination include the following: 

wildlife observation can be an element of horseback riding; horseback riding allows us to reach a 

target audience we would not otherwise reach; horseback riders are potential partners and a 

potential source of support for the wildlife refuge; and impacts associated with horseback riding 

are not believed to exceed impacts already caused by other public use activities. This nonwildlife dependent use is being allowed since it is a minimal amount of use by a small number of 

local riders. It will be curtailed if impacts are discovered to wildlife or habitat or if problems occur 

due to littering or trampling. No trail or facility improvements will be made on the refuge to 

encourage use over present-day levels or as a tourist attraction. Trail maintenance will take 

lesser priority than interpretive and walking trails, which are smaller and easier to maintain with a 

limited number of maintenance staff and volunteers. 

Mandatory 10-year Re-evaluation Date:__________________

Other Uses - The Management Agreement for Submerged Lands within Boundaries of the Key West 

and Great White Heron NWRs prohibits the use of airboats, personal watercraft, and air-cushioned 

hovercraft from State of Florida waters and restricts motorboat access in certain areas designated 

around refuge islands to minimize wildlife disturbance. 
180 Lower Florida Keys National Wildlife Refuges 

References 

Public Use in Wilderness Areas: 

Arianoutsou, M. 1988. Assessing the Impacts of Human Activities on Nesting of Loggerhead 

 Turtles (Caretta caretta L.) on Zakynthos Island, Western Greece. Environmental 

 Conservation (15:327-334). 

Bradley, K. 1996a. Observations of Vascular Plants Found on Boca Grande Key, Monroe 

County, Florida. The Institute for Regional Conservation. Miami, Florida, Unpublished 

Data Provided to the Refuge April 17, 1996. 

Bradley, K. 1996b. Observations of Vascular Plants Found on Snook Beach, Monroe 

County, Florida. The Institute for Regional Conservation. Miami, Florida, Unpublished 

Data Provided to the Refuge April 17, 1996. 

Bradley, K. 1996c. Observations of Vascular Plants Found on Snook Beach, Monroe 

County, Florida. The Institute for Regional Conservation. Miami, Florida, Unpublished 

Data Provided to the Refuge April 17, 1996. 

Bradley, K. 1996d. Observations of Vascular Plants Found on Long Beach, Monroe 

County, Florida. The Institute for Regional Conservation. Miami, Florida, Unpublished 

Data Provided to the Refuge April 17, 1996. 

Carter, R. W. G. et al. 1990a. The Study of Coastal Dunes in N. Nordstrum, N. Psuty and B. 

Carter. (eds.) Coastal Dunes, Form and Process. John Wiley and Sons, 

New York. pp 1 – 14. 

Carter, R. W. G., P.A. Hesp, and K. L. Nordstrom 1990b. Erosional Landforms in Coastal 

 Dunes. Pages 217-225 in K.N. Nordstrum, N. Psuty and B. Carter. (eds.) Coastal 

Dunes, Form and Process. John Wiley and Sons, New York. 

Clark, J. R. 1996. Coastal Management Handbook. Lewis Publishers. Boca Raton, Florida. 

Dodd, K. C., Jr. 1988. Synopsis of the Biological Data on the Loggerhead Sea Turtle Caretta 

 caretta (Linnaeus 1758). U.S. Fish and Wildllife Service Biological Report 88(14). 

Dodd, K. C. 1992. Loggerhead Turtle. Pages 128-134 in P.E. Moler, ed. Rare and Endangered 

Biota of Florida. University of Florida Press, Gainesville, Florida. 

 

Dutton, P., R. McDonald, and R. Boulon. 1994. Tagging and Nesting Research on Leatherback 

Turtles (Dermochelys coriacea) on Sandy Point, St. Croix, Virgin Islands, 1994. 

Unpublished. Annual Report, U.S. Fish and Wildlife Service, 

Contract Number PC-P&NR-287-94. 

Ehrhart, L. M. 1992. Green Turtle. Pages 90-94 in P.E. Moler, ed. Rare and Endangered Biota 

 Of Florida. University of Florida Press, Gainesville, Florida. 

Hosier, P. E. M. Kochar, and V. Thayer. 1981. Off-road Vehicle and Pedestrian Track Effects on 

the Sea Approach of Hatchling Loggerhead Turtles. Environmental Conservation 8:151-161. 
Appendices 181 

Jacobson, S. K., and A. F. Lopez. 1994. Biological Impacts of Ecotourism: Tourists and 

 Nesting Turtles in Tortuguero National Park, Costa Rica. Wildlife Society Bulletin 

 (22:414-419). 

Mann, T. M. 1977. Impact of Developed Coastline Nesting and Hatching Sea Turtles in 

Southeastern Florida. M.S. Thesis, Florida Atlantic University. Boca Raton, Florida. 

McClenachan, L, J. Jackson. and M. Newman. 2006. Conservation Implications of Historic Sea 

Turtle Nesting Beach Loss. Frontiers in Ecology and Environment 4:290–296. 

McDonnel, M. J. l98l. Trampling Effects on Coastal Dune Vegetation in the Parker River 

National Wildlife Refuge, Massachusetts, U. S. A. Biological Conservation (6:289-30l). 

Meylan, A., B. Schroeder, and A. Mosher. 1995. Sea Turtle Nesting Activity in the State of 

Florida 1979-92. Florida Marine Resources. Published. 52, St. Petersburg, Florida. 

Moore, S. A., and A. Polley. 2007. Defining indicators and standards for tourism impacts in 

 Protected areas: Cape Range National Park, Australia. Journal of Environmental 

Management (39: 291-300). 

National Marine Fisheries and U.S. Fish and Wildlife Service. 1991a. Recovery Plan for U.S. 

Population of Loggerhead Turtle. National Marine Fisheries Service, Washington, D.C. 

 

National Marine Fisheries and U. S. Fish and Wildlife Service. 1991b. Recovery Plan for U. S. 

 Population of Atlantic Green Turtle, Chelonia mydas. National Marine Fisheries Service, 

Washington, D.C. 

National Marine Manufacturers Association. 2005. U. S. Recreational Boat Registration 

 Statistics Report. 

National Oceanic and Atmospheric Administration. 1995. Florida Keys National Marine 

Sanctuary. Draft Management Plan/Environmental Impact Statement. National Oceanic 

and Atmospheric Administration, Silver Springs, Maryland. 

Ross, C. L., K. Leone de Nie, and J. Barringer. 2006. A Time for Leadership: Growth 

Management and Florida 2060. Center for Quality Growth and Regional Development, at 

the Georgia Institute of Technology. 

Mosquito Control Operations: 

Agriculture Canada, Food Production and Inspection Branch. 1982. Report of new registration: 

 Bacillus thuringiensis serotype H14. Ottowa, Ontario, Canada. 

Ali, A. 1981. Bacillus thuringiensis serovar. israelensis (ABG-6180) against chironomids and 

 some non-target aquatic invertebrates. Journal of Invertebrate Pathology (38:264-272). 

Cornell University. 1983. Naled (Dibrom) Chemical Fact Sheet 6/83. Cornell University, 

Ithaca, New York. 

http://pmep.cce.cornell.edu/profiles/insect-mite/mevinphospropargite/naled/insect-prof-naled.html. 
182 Lower Florida Keys National Wildlife Refuges 

Cornell University. 1985. Bacillus thuringiensis (var. Israelensis) Chemical Profile 4/85. Cornell 

 University, Ithaca, New York. 

http://pmep.cce.cornell.edu/profiles/insectmite/abamectinbufencarb/btisraelensis/

bt_israelensis_reg_298.html

Emmell, T. C. and J. C. Tucker, Ed. 1991. Mosquito Control Pesticides: Ecological Impacts and 

 Management Alternatives. Conference Proceedings. Scientific Publishers, Inc. 

Gainesville, Florida. 

Environmental Protection Agency. 1995. EFED List A Summary Report for Naled (Chemical 

 #034401) Case #0092. United States Environmental Protection Agency, Office of 

 Prevention, Pesticides and Toxic Substances. Washington, D.C. 

Environmental Protection Agency. 2000. For Your Information, Naled for Mosquito Control. 

 United States Environmental Protection Agency, Office of Prevention, Pesticides and 

 Toxic Substances, Washington, D.C. 

Forys, E. A., P. A. Frank, and R. S. Kautz. 1996. Recovery Actions for the Lower Keys Marsh 

 Rabbit, Silver Rice Rat, and Stock Island Tree Snail. Final Report, Cooperative 

Agreement #1448-0004-94-9164, Florida Game and Fresh Water Fish Commission, 

(now FWC), Tallahassee, Florida. 

George, D. A. 1985. Results and Conclusions of Using Pesticides With the Alfalfa Leafcutting 

Bee in the Production of Alfalfa Seed. Journal of Agricultural Entomology (2(1):93-97). 

Hennessey, M. K, and D. H. Habeck. 1991. Effects of Mosquito Adulticides on Populations of 

 Non-target Terrestrial Arthropods in the Florida Keys. University of Florida Cooperative 

 Wildlife Research Unit, Gainesville, Florida. Unpublished final report. 

Hennessey, M. K., H. N. Nigg, and D. H. Habeck. 1992. Mosquito (Diptera: Culicidae) 

Adulticide Drift into Wildlife Refuges of the Florida Keys. Environmental Entomology 

((4):714-721). 

McClintock, J. T., C. R. Shaffer and R. D. Snoblad. 1995. A Comparative Review of the 

Mammalian Toxicity of Bacillus Thuringiensis-based Pesticides. Pesticide Science 

(45:95-105). 

Molloy, D. P. 1992. Impact of the Black Fly (Diptera: Simulidae) Control Agent Bacillus 

 Thuringiensis var. Israeliensis on Chironomids (Diptera: Chironomidae) and Other 

 Non-target Insects: Results of Ten Field Trials. Journal of American Mosquito Control 

 Association (8(1):24-31). 

Provost, M. 1952. The Dispersal of Aedes Taeniorhynchus: I. Preliminary Studies. Mosquito 

News (12(3):233-247). 

Provost, M. 1957. The Dispersal of Aedes Taeniorhynchus: II. The Second Experiment. 

 Mosquito News (17(4):148-161). 

Reinhold, R. 1978. On the Persistence of Naled in Small Natural Bodies of Water (Mosquito 

 Breeding Areas). Z. Gesamte Hyg. Greszgeb (24(2):119-122). 
Appendices 183 

Salvato, M.H. 2001. Influence of Mosquito Control Chemicals on Butterflies (Nymphalidae, 

 Lycaenidae, Hesperiidae) of the Lower Florida Keys. J. Lepidopterists’ Society 

(55(1):8-14). 

Tietze, N. S et al. 1991. Journal of the American Mosquito Control Association (7(2):290-293). 

URS. 2002. Draft Naled Risk Assessment for Endangered and Threatened Species of 

Concern. Prepared for Florida Keys Mosquito Control District and U. S. Fish and Wildlife 

Service. URS, Franklin, Tennessee. 

USFWS. 1999. South Florida Multi-Species Recovery Plan. U. S. Fish and Wildlife Service, 

 Ecological Services Office, Vero Beach, Florida. 

Horseback Riding: 

Atwill, E. R., N. K. McDougald, L. Perea. 2000. Cross-sectional Study of Fecal Shedding of Giardia 

duodenalis and Cryptosporidium parvum Among Packstock in the Sierra Nevada Range. 

Equine Veterinary Journal (32(3):247-252). 

Atwill, Edward, R. 1995. Microbial Pathogens Excreted by Livestock and Potentially Transmitted to 

Humans Through Water. 

Atwill, Edward R. et al. 2002. Transport of Cryptosporidium parvum Oocysts Through Vegetated 

Buffer Strips and Established Filtration Efficiency. Applied and Environmental Microbiology. 

November 2002: 5517-5527. 

Benninger-Truax, Mary. et al. 1992. Trail Corridors as Habitat and Conduits for Movement of Plant 

Species in Rocky Mountain National Park, Colorado, United States of America. Landscape 

Ecology (6: 269-278). 

Cook, Haven B. Personal Communication with Haven B. Cook, U. S. Forrest Service, Apalachicola 

National Forest, June 3, 2003. 

Dehring, Faith J. and Frank J. Mazzoti. 1997. Impacts of Equestrian Trails on Natural Areas. 

University of Florida, Wildlife Ecology and Conservation Department, publication WEC-122, 

Gainesville, Florida. 

DeLong, Anita K. and Janet T. Schmidt. 2000. Draft Literature Review: Effects of Human 

Disturbance on Wildlife with Emphasis on Wildlife-Dependent Recreation Relevant to 

Stillwater National Wildlife Refuge. 

Fio, Laurie and Atwill, Rob. 1998. Cryptosporidium in the Water- Are Horses to Blame? The Horse 

Report (16(4):1,4-7, 12). 

Hendee, John C. et al. Wilderness Management, Chapter 16, 457-462. 

Johnson, E. et al. 1997. The Prevalence of Shedding of Cryptosporidium and Giardia spp. Based on 

a Single Fecal Sample Collection From Each of 91 Horses Used for Backcountry Recreation. 

Veterinary Diagnostic Investigation (9:56-60). 
184 Lower Florida Keys National Wildlife Refuges 

Quinn, Adda. 2000. Does Horse Manure Pose a Risk to Human Health? Bay Area Equestrian 

Network. Http://www.bayquest.com/horsetalk/manure/htm. 

Quinn, Adda. Horse Trails and Other Environmental Issues. EnviroHorse. 

Http://californiastatehorsemen.com/enviro-oth-envro.htm. 

Quinn, Adda. Environmental Aspects of Horses on Trails. EnviroHorse. 

Http://californiastatehorsemen.com/enviro_aspects.htm. 

U. S. Fish and Wildlife Service, Horseback Riding Compatibility Determinations for Canaan Valley, 

Arthur R. Marshall Loxahatchee, Stillwater and Little Pend Orielle National Wildlife Refuges. 

Weir, Donald V. 2000. Impacts of Non-motorized Trail Use. Edmonton, Alberta, Canada. 
Appendices 185 

Approval of Compatibility Determinations: 

The signature of approval covers all the compatibility determinations considered within the 

Comprehensive Conservation Plan for National Key Deer Refuge and Great White Heron and Key 

West National Wildlife Refuges. If one of the described uses is considered for compatibility outside of 

the plan, the approval signature becomes part of that determination. 

Refuge Manager: ________________________________________________ 

 (Signature/Date) 

Regional Compatibility 

Coordinator: ________________________________________________ 

 (Signature/Date) 

Refuge Supervisor: ________________________________________________ 

 (Signature/Date) 

Regional Chief, National 

Wildlife Refuge System, 

Southeast Region: ________________________________________________ 

 (Signature/Date) 
186 Lower Florida Keys National Wildlife Refuges 
Appendices 187 

Appendix G. Intra-Service Section 7 Biological 

Evaluation 
188 Lower Florida Keys National Wildlife Refuges 
Appendices 189 
190 Lower Florida Keys National Wildlife Refuges 
Appendices 191 
192 Lower Florida Keys National Wildlife Refuges 
Appendices 193 
194 Lower Florida Keys National Wildlife Refuges 
Appendices 195 
196 Lower Florida Keys National Wildlife Refuges 
Appendices 197 
198 Lower Florida Keys National Wildlife Refuges 
Appendices 199 
200 Lower Florida Keys National Wildlife Refuges 
Appendices 201 
202 Lower Florida Keys National Wildlife Refuges 
Appendices 203 

Appendix H. Wilderness Review 

Wilderness Review for the Lower Florida Keys Refuges - August 21, 2006 

The project leader and staff met at National Key Deer Refuge on August 21, 2006, to gather 

information and discuss the wilderness review. The review team included: 

Anne Morkill, Project Leader; 

Mary Morris, CCP Planning Team Leader; 

Tom Wilmers, Wildlife Biologist; 

Lester Pulley, Lead Law Enforcement Officer; 

James Bell, Park Ranger; and 

Paige Schmidt, SCEP biologist trainee. 

The wilderness review is a required component of the CCP. The Wilderness Act defines a wilderness 

area as an area of federal land retaining its primeval character and influence, without permanent 

improvements or human habitation, which is managed so as to preserve its natural conditions and (1) 

generally appears to have been affected primarily by the forces of nature, with the imprint of man’s 

work substantially unnoticeable; (2) has outstanding opportunities for solitude or primitive and 

unconfined type of recreation; (3) has at least 5,000 contiguous roadless acres or is of sufficient size 

to make practicable its preservation and use in an unimpaired condition; (4) does not substantially 

exhibit the effects of logging, farming, grazing, or other extensive development or alteration of the 

landscape, or its wilderness character could be restored through appropriate management, at the 

time of review; (5) is a roadless island; and (6) may contain ecological, geological, or other features of 

scientific, education, scenic, or historic value. 

During the inventory phase of the wilderness review, the emphasis is on an assessment of wilderness 

character within the inventory unit. Special values (i.e., ecological, geological, scenic, and historical) 

should be identified. The determination to recommend (or not recommend) a wilderness study area 

to Congress for wilderness designation will be made through the CCP decision-making process. 

The areas designated as wilderness are described in Section A, Chapter II, and portrayed in Figure 5. 

Since all of the refuge-owned islands within Key West National Wildlife Refuge are designated as 

wilderness, this refuge was not included in the discussion. Likewise, those parts of Great White 

Heron NWR (west part) and parts of National Key Deer Refuge that are designated as wilderness 

were also omitted from the discussion. 

Wilderness Management 

The wilderness management policy and regulations allow motorized access and use of mechanized 

equipment for administrative purposes only if such uses are the minimum necessary to accomplish 

wilderness objectives. For the purpose of analysis in Draft CCP/EA, managers should assume that 

authorization of such uses would be temporary and rare in a wilderness area. If such restrictions 

would significantly limit the Service’s ability to accomplish other resource management objectives, 

these impacts should be fully described in Section B, Chapter IV, and would obviously be a factor for 

consideration in selecting a preferred alternative. 
204 Lower Florida Keys National Wildlife Refuges 

Resource Management Issues 

Fire Management 

Prescribed burning is implemented primarily on the mainline islands of Big Pine, No Name, 

Cudjoe, and Upper Sugarloaf Keys for habitat management and restoration purposes and to 

reduce fuel loads. Unintentional wildfires are suppressed on all mainline islands to minimize risk 

to human safety and property. 

Endangered Species 

There are 21 federally listed species on these islands and 10 candidate species. 

See Section A, Chapter II. 

Public Use 

All mangrove islands are closed to public use. Visitors are permitted only on three islands, all 

containing beaches: Marquesas, Boca Grande, and Woman Keys. One-half of the beaches on 

Woman and Boca Grande Keys are closed to allow an undisturbed area for wildlife. Shallow waters 

border all or parts of some beaches, limiting direct access by larger boats. Acute overcrowding, 

particularly during peak use periods, such as the Memorial Day weekend, has been a recurring 

problem for years on Boca Grande Key and to a lesser extent on Woman Key. Non-wildlifedependent activities prevail during such periods and a party atmosphere pervades the sites. Waters 

adjacent to refuge beaches are used for fishing, swimming, and diving. 

Navigable Waters 

All of the inventory units are bounded by navigable waters of the Gulf of Mexico and the Florida 

Bay. All navigable waters and submerged lands within the refuges’ boundaries are owned by the 

State of Florida. Under a management agreement with the State of Florida, in-water buffer zones 

(i.e., idle speed, no motor, or no access) have been created around some refuge islands to 

reduce boater disturbance to wildlife. 

Summary of Wilderness Inventory Findings 

No new lands will be proposed as wilderness study areas as part of the comprehensive conservation 

planning process. The wilderness review inventory team looked at mainline islands (i.e., those linked 

by the Overseas Highway and islands within the refuges acquisition boundary) that were not already 

designated as wilderness. Because the mainline islands are not roadless and they are bisected by a 

highway, they do not meet the criterion for naturalness. There are no real opportunities for solitude. 

Therefore, they were not considered for further study as wilderness study areas. 

In National Key Deer Refuge and Great White Heron NWR, there are several refuge-owned islands 

that have not been designated as wilderness. No areas were considered suitable for further study as 

wilderness study areas. All of the islands met the criterion for a wilderness study area of being a 

roadless island of any size. However, they could not be practicably managed as wilderness because 

of their location. Being proximal to suburban areas and to heavy motor boating activity, opportunities 

for solitude are not likely. As undeveloped islands, while they have a primitive nature, the lights and 

structures from the developed islands and the Overseas Highway are visible. Some of the islands 

are in shallow waters, which prohibit or greatly limit access. The dense mangrove forests dominating 

these islands are not conducive to visitation by most people. Further, human visitation would disturb 

nesting birds, particularly colonial wading birds. The heavy public use of motor-boating in the waters 

around the islands, combined with the small size of some of the islands, limits the opportunities for 

individuals to enjoy solitude or a primitive and unconfined recreational experience. 
Appendices 205 

Appendix I. Refuge Biota 

Legend for Lower Florida Keys Bird List- June 2006: 

SP Spring, March – May a = abundant (a common species which is very numerous) 

S Summer, June – August c = common (certain to be seen in suitable habitat) 

F Fall, September – November u = uncommon (present but not certain to be seen) 

W Winter, December – February o = occasional (seen only a few times during a season) 

 r = rare (seen at intervals of 2 to 5 years) 

* = known or suspected to have nested on the refuges or known to nest locally 

Lower Florida Keys Bird List
206 Lower Florida Keys National Wildlife Refuges 
Appendices 207 
208 Lower Florida Keys National Wildlife Refuges 
Appendices 

Final IR Draft Subtropical Florida Bird Conservation Table Priority Birds in need of conservation attention for Subtropical Florida Physiographic Area (BCR 31).* 

Immediate ManagementMangroves/ Tropical Hardwoods 

Forested Wetlands/ Hammocks

Open Pine Woodlands/ Rocklands

Shrub-scrub Transient 

Landbirds

Grassland, Prairie, Savanna, Pasture

Emergent Wetlands

Colonial Waders and Pelicans

Colonial gulls, terns, skimmers

Shorebirds (beaches)

Swallowtailed Kite (I b) 

Swallowtailed Kite (I b) 

Redcockaded Woodpecker (I a) 

Florida Scrub-Jay (I a) 

Bicknell’s Thrush (I a) 

Bachman’s Sparrow (I a) 

Yellow Rail (I a; w) 

Great White Heron (I a) 

Gull-billed Tern (I b) 

Snowy Plover  (I a) 

Short-tailed Hawk (Florida pops.; II b) 

Short-tailed Hawk (Florida pops.; II b) 

Bachman’s Sparrow (I a) 

Painted Bunting (I b; w) 

 Henslow’s 

Sparrow (I a; w) 

Black Rail (I a; w) 

Magnificent Frigatebird (I c) 

Roseate Tern  (I b) 

Piping Plover (I a; w) 

 Henslow’s 

Sparrow (I a; w) 

Smoothbilled Ani (II b) 

 Swallowtailed Kite 

(I b) 

King Rail (I a) 

Reddish Egret (I c) 

Least Tern (I b) 

American Oystercatcher (I b) 

 Red-headed 

Woodpecker (I b) 

 Grasshopper 

Sparrow (Florida subsp.; II b) 

Mottled Duck (FL subsp.; I c) 

Wood Stork (southeast U.S. breeding pop. II a) 

Black Skimmer (I b) 

Red Knot (I c; w) 

 Brownheaded 

Nuthatch (I b) 

 Seaside 

Sparrow (Cape Sable subsp.; I c) 

 Carolina 

Chickadee (II a) 

 Snail Kite 

(Everglades pop.; II b) 

 American 

Kestrel (Southeastern subsp.; II b) 

 Summer 

Tanager (II b) 
210 Lower Florida Keys Nati

Management Attention Mangroves/ Tropical Hardwoods 

Forested Wetlands/ Hammocks

Open Pine Woodlands/ Rocklands

Shrub-scrub Transient 

Landbirds

Grassland, Prairie, Savanna, Pasture

Emergent Wetlands

Colonial Waders and Pelicans

Colonial gulls, terns, skimmers

Shorebirds (beaches)

Whitecrowned Pigeon (I b) 

Prothonotary Warbler (I b) 

Northern Bobwhite (II a) 

American Woodcock (I b; w) 

Baybreasted Warbler (I b; t) 

Short-eared Owl (Greater Antillean subsp; I b; nb) 

Wilson’s Snipe (I b; w) 

Little Blue Heron (I b) 

Masked Booby (I b; LR) 

Sanderling (I b; nb) 

Mangrove Cuckoo (I b) 

Rusty Blackbird (I b; w) 

Chuck-will’swidow (II a) Brown Thrasher 

(II a) 

Mississippi Kite (II a; t) 

Northern Harrier (II a; w) 

Pied-billed Grebe (breeding pops.; II a) 

Great Blue Heron (II a) 

Bridled Tern (I c; LR) 

Wilson’s Plover (I c) 

Prairie Warbler (Florida subsp.; I b) 

Limpkin (Florida pops.; II a) 

Northern Flicker (II a) 

Eastern Towhee (II a) 

Connecticut Warbler (II a) 

Northern Bobwhite (II a) 

Least Bittern (II a) 

Great Egret (II a) 

 Ruddy 

Turnstone (II a; nb) 

Clapper Rail (II a) 

Yellowbilled Cuckoo (II a) 

Bald Eagle (II b) 

 Common 

Nighthawk (II a) 

American Bittern (II a; w) 

Tricolored Heron (II a) 

 

Blackwhiskered Vireo (II a) 

Chimney Swift (II a) 

 Loggerhead 

Shrike (II a) 

American Coot (breeding pops.; II a) 

Green Heron (II a) 

 

Bald Eagle (II b) 

Bald Eagle (II b) 

 Field 

Sparrow (II a) 

Limpkin (Florida pops.; II a) 

Blackcrowned Night-Heron  (II a) 

 

Yellow Warbler (Cuban subsp.; II b) 

 Vesper 

Sparrow (II a) 

Purple Gallinule (II b) 

White Ibis (II a) 

 

 Grasshoppe

r (eastern subsp.; II a; w) 

 Glossy Ibis 

(II a) 

 
Appendices 

Mangroves/ Tropical Hardwoods 

Forested Wetlands/ Hammocks

Open Pine Woodlands/ Rocklands

Shrub-scrub Transient 

Landbirds

Grassland, Prairie, Savanna, Pasture

Emergent Wetlands

Colonial Waders and Pelicans

Colonial gulls, terns, skimmers

Shorebirds (beaches)

 Le Conte’s 

Sparrow (II a; w) 

 Roseate 

Spoonbill (II a) 

 

 Bobolink 

(II a; t) 

 Yellowcrowned 

Night-Heron (II b) 

 

 Eastern 

Meadowlark (II a) 

 Greater 

Flamingo (II b, nb) 

 

 Barn Owl 

(II b) 

 

 Burrowing 

Owl (II b) 

 

 Sedge Wren 

(II b; w) 

 

Planning and ResponsibilityGray Kingbird (II c) 

Wood Duck (II c) 

Pine Warbler (II c) 

White-eyed Vireo (II c) 

Cape May Warbler (II c; nb) 

Antillean Nighthawk (I c) 

Nelson’s Sharptailed Sparrow (I c; w) 

Brown Pelican (II c) 

Royal Tern (II c) 

Willet (II a) 

 Northern 

Parula (II c) 

 Blackthroated 

Warbler (II c; nb) 

Sandhill Crane (Florida subsp.; II c) 

 Sandwich 

Tern (II c) 

 

 Yellowthroated 

Warbler (II c) 

 Blackpoll 

Warbler (II c; t) 

 Sooty Tern 

(II c) 

 

 Brown 

Noody (Tier II c) 

 
212 Lower Florida Keys Nati

* Immediate Management = needed to reverse or stabilize significant, long-term population declines in species with small populations, o

the smallest populations for which trends are poorly known. Lack of action may lead to extirpations or extinction. Management Attention = on-the-ground conservation actions needed to reverse or stabilize significant, long-term population declines in srelatively abundant. Planning and Responsibility = long-term Planning and Responsibility needed for species to ensure that sustainable populations are main

which a region has high responsibility for that species. w=winter, nb=non-breeding, t=transient; otherwise species are breeding (seasonal as well as resident species); LR (low responsibility fo

All species receive total scores (TOT), i.e., sum of all seven factors (max.=35) used , along with Action Level and Tier to help folks to de

species best fits for conservation planning at Planning Region/Bird Conservation Region/Physiographic Area., and in the West Indies isla

Tier I. Continental Conservation Concern (Continental WatchList):  (a) Species with multiple causes for concern across their entire range;  (b) Moderately abundant or widespread species with declines or high threats, and  (c) Species with restricted distributions or low population size. For Regional and smaller scales, species for which local relative density to the best of our understanding has always been low (i.e, AI =2

as of “low responsibility” when compared to species with AI>3 (“high responsibility”) for the area of interest (this would not apply to speci

and TB and/or TN > 4 as this indicates former higher relative densities and therefore former higher responsibility). 

WatchList score used for Continental Scoring (PIF Approach); species with WL SUBTOT combined scores of (1) 15 or more, (2) 14 with 

in the West Indies for now, also may become important when including Mexico, but has no effect on species presently covered in the CPand Canada}, or (3) with 13 with PT=5 are identified using formula: Combined Score = PT + PS + maximum of (BD or ND) + maximum of (TB or TN) Species with multiple causes for concern across their entire range: These species are considered by many to be of highest continental cpriority for conservation actions at national and international scales. A majority of these are legally listed as Endangered or Threatened 

Canada, and as such have recovery plans in place. Notable in this group, however, are several species without legal status, including B

Saltmarsh Sharp-tailed Sparrow. Moderately abundant or widespread species with declines or high threats: These species are on the Watch List primarily because they athreatened throughout their range, though still fairly widespread or with moderately large populations. Many of these species still numbe

Dickcissel, Wood Thrush), but are threatened with serious reductions in population or geographic range in the future. Several other specKite, Mangrove Cuckoo, Elegant Trogon) are fairly widespread outside the U.S. and Canada, but are threatened in the U.S. portion of thare afforded U.S. federal legal status in part of their range or for a particular recognized subspecies. This group also includes four resideseriously declining populations. 
Appendices 

Species with restricted distributions or low population size: These species are on the Watch List because they are restricted to a small ra

populations (often both). Many of these species are not known to be declining or seriously threatened at present, but many others are, (

Montezuma Quail, Bendire’s Thrasher, Rufous-winged Sparrow, Audubon’s Oriole). We recognize that these species with small populat

are particularly vulnerable to relatively minor changes from current conditions, whether or not their populations are currently in decline. 

Tier II. Regional Conservation Interest (non-WatchList; TOT>19, AI>2): 

 (a) high regional concern with TOT >22 not otherwise identified in Tier I* and TOT=19-21 with(AI+PT>8); 

 (b) high regional threats (TB+TN>7, or TB or TN=5), including taxa (subspecies and populations) of regional conservation intere

 total score (but previously identified), not otherwise included in categories above;  (c) high regional responsibility (as measured by percent of global, continental, or regional populations). 
 Lower Florida Keys National Wildlife Refuges 214

Vertebrate List – source: Phillip Hughes, Ecological Services 2-16-07 

Common Name (Latin Name) Value 

Greenhouse Frog (Eleutherodactylus planirostris planirostris) Non-Native 

Narrow-mouthed Toad (Gastrophrynae carolinensis) Native 

Green Treefrog (Hyla cinerea) Native 

Squirrel Treefrog (Hyla squirella) Native 

Cuban Treefrog (Osteopilus septentrionalis) Non-Native 

Southern Leopard Frog (Rana spenocephala) Native 

Eastern Spadefoot Toad (Scaphiopus holbrooki holbrooki) Native 

Giant Toad (Bufo marinus) Exotic, established 

Oak Toad (Bufo quercicus) Native 

Southern Toad (Bufo terrestris) Native 

American Alligator (Alligator mississippiensis) Native 

American Crocodile (Crocodylus acutus) Native 

Yellowhead Gecko (Gonatodes albogularis fuscus) Exotic, established 

Ocellated Gecko (Sphaerodactylus argus argus) Exotic, established 

Indo-Pacific Gecko (Hemidactylus garnotii) Exotic, established 

Green Bark Anole (Anolis distichus dominicensis) Exotic, established 

Green Anole (Anolis carolinensis carolinensis) Native 

Brown Anole (Anolis sagrei) Non-Native 

Six-lined Racerunner (Cnemidophorus sexlineatus sexlineatus) Native 

Keys Mole Skink (Eumeces egregius egreguis) Native 

Southeastern Five-lined Skink (Eumeces inexpectatus) Native 

Mediterranean Gecko (Hemidactylus turcicus turcicus) Non-Native 

Florida Reef Gecko (Sphaerodactylus notatus notatus) Native 

Ashy Gecko (Sphaerodactylus elegans) Non-Native 

Crested Anole (Anolis cristatellus) Non-Native 

Ground Skink (Scincella lateralis) Native 
Appendices 215 

Common Name (Latin Name) Value 

Atlantic Loggerhead (Caretta caretta caretta) Native 

Atlantic Green Turtle (Chelonia mydas mydas) Native 

Atlantic Leatherback (Dermochelys coriacea coriacea) Native 

Atlantic Ridley (Lepidochelys kempii) Native 

Atlantic Hawksbill (Eretmochelys imbricata imbricata) Native 

Southern Black Racer (Coluber constrictor priapus) Native 

Eastern Diamondback Rattlesnake Native 

Key Ringneck Snake (Diadophis punctatus acricus) Native 

Eastern Indigo Snake (Drymarchon corais couperi) Native 

Corn Snake (Elaphe guttata guttata) Native 

Rosy Rat Snake (Elaphe guttata rosacea) Native 

Mangrove Water Snake (Nerodia fasciata compressicauda) Native 

Rough Green Snake (Opheodrys aestivus) Native 

Florida Brown Snake (Storeria dekayi victa) Native 

Peninsula Ribbon Snake (Thamnophis sauritus sackeni) Native 

Scarlet Kingsnake (Lampropeltis triangulum elapsoides) Status "not 

confirmed" potential 

range expansion 

Florida Cottonmouth (Agkistrodon piscivorus conanti) Status "not 

confirmed" potential 

range expansion 

Mangrove Terrapin (Malaclemys terrapin rhizophorarum) Native 

Chicken Turtle (Deirochelys reticularia) Native, potential 

range expansion or 

release 

Snapping Turtle (Chelydra serpentina) Native, potential 

range expansion or 

release 

Peninsula Cooter (Pseudemys floridana peninsularis) Native, potential 

range expansion or 

release 
 Lower Florida Keys National Wildlife Refuges 216

Common Name (Latin Name) Value 

Key Mud Turtle (Kinosternon baurii baurii) Native 

Florida Box Turtle (Terrapene carolina bauri) Native 

Florida Water Rat (Neofiber alleni) Status "not 

confirmed" 

Key Deer (Odocoileus virginianus clavium) Native 

Keys Raccoon (Procyon lotor auspicatus) Native 

Florida Pipistrelle (Pipistrellus subflavus floridanus) Native 

Free-tailed Bat (Tadarida brasiliensis) Native 

Evening Bat (Nycticeius humeralis) Status "not 

confirmed" 

Marsh Rabbit (Sylvilagus palustris paludicola) Native 

Silver Rice Rat (Oryzomys argentatus) Native 

Lower Keys Cotton Rat (Sigmodon hispidus exsputus) Native 

Black Rat (Ratttus rattus) Non-Native 

Norway Rat (Rattus norvigicus) Non-Native 

House Mouse (Mus musculus) Non-Native 

Eastern Woodrat (Neotoma floridana) Status "not 

confirmed" 

West Indian Manatee (Trichechus manatus) Native 

Opossum (Didelphis marsupialis) Status "not 

confirmed" 
Appendices 217 

Butterflies List – Source: compiled by Phillip Hughes, Ecological Services and 

circulated to others for review 2-16-07. 

Butterflies and Moths of Monroe County, Florida 

Brush-footed Butterflies (Nymphalidae) 

Admirals and Relatives (Limenitidinae) 

 Antillean Daggerwing (Marpesia eleuchea) 

 Cramer's Eighty-eight (Diaethria clymena) 

 Dingy Purplewing (Eunica monima) 

 Florida Purplewing (Eunica tatila) 

 Many-banded Daggerwing (Marpesia chiron) 

 Pale Cracker (Hamadryas amphichloe) 

 Ruddy Daggerwing (Marpesia petreus) 

 Viceroy (Limenitis archippus) 

Emperors (Apaturinae) 

 Tawny Emperor (Asterocampa clyton) 

Leafwings (Charaxinae) 

 Florida Leafwing (Anaea troglodyta floridalis) 

Longwings (Heliconiinae) 

 Banded Orange Heliconian (Dryadula phaetusa) 

 Gulf Fritillary (Agraulis vanillae) 

 Julia Heliconian (Dryas iulia) 

 Variegated Fritillary (Euptoieta claudia) 

 Zebra Heliconian (Heliconius charithonia) 

Milkweed Butterflies (Danainae) 

 Monarch (Danaus plexippus) 

 Queen (Danaus gilippus) 

 Soldier (Danaus eresimus) 

Satyrs and Wood-Nymphs (Satyrinae) 

 Carolina Satyr (Hermeuptychia sosybius) 

 Georgia Satyr (Neonympha areolatus) 

Snouts (Libytheinae) 

 American Snout (Libytheana carinenta) 

True Brushfoots (Nymphalinae) 

 American Lady (Vanessa virginiensis) 

 Caribbean Peacock (Anartia chrysopelea) 

 Common Buckeye (Junonia coenia) 

 Cuban Crescent (Anthanassa frisia) 

 Malachite (Siproeta stelenes) 

 Mangrove Buckeye (Junonia evarete) 

 Mimic (Hypolimnas misippus) 

 Painted Lady (Vanessa cardui) 

 Pearl Crescent (Phyciodes tharos) 

 Phaon Crescent (Phyciodes phaon) 
 Lower Florida Keys National Wildlife Refuges 218

 Red Admiral (Vanessa atalanta) 

 Tropical Buckeye (Junonia genoveva) 

 White Peacock (Anartia jatrophae) 

Gossamer-wing Butterflies (Lycaenidae) 

Blues (Polyommatinae) 

 Cassius Blue (Leptotes cassius) 

 Ceraunus Blue (Hemiargus ceraunus) 

 Eastern Pygmy-Blue (Brephidium pseudofea) 

 Miami Blue (Cyclargus thomasi) 

 Nickerbean Blue (Cyclargus ammon) 

Hairstreaks (Theclinae) 

 Amethyst Hairstreak (Chlorostrymon maesites) 

 Atala (Eumaeus atala) 

 Bartram's Scrub-Hairstreak (Strymon acis) 

 Disguised Scrub-Hairstreak (Strymon limenia) 

 Fulvous Hairstreak (Electrostrymon angelia) 

 Gray Hairstreak (Strymon melinus) 

 Gray Ministreak (Ministrymon azia) 

 Mallow Scrub-Hairstreak (Strymon istapa) 

 Martial Scrub-Hairstreak (Strymon martialis) 

 Red-banded Hairstreak (Calycopis cecrops) 

 Ruddy Hairstreak (Electrostrymon sangala) 

 Silver-banded Hairstreak (Chlorostrymon simaethis) 

 Southern Hairstreak (Satyrium favonius) 

Metalmarks (Riodinidae) 

 Little Metalmark (Calephelis virginiensis) 

Parnassians and Swallowtails (Papilionidae) 

Swallowtails (Papilioninae) 

 Bahaman Swallowtail (Papilio andraemon) 

 Black Swallowtail (Papilio polyxenes) 

 Eastern Tiger Swallowtail (Papilio glaucus) 

 Giant Swallowtail (Papilio cresphontes) 

 Palamedes Swallowtail (Papilio palamedes) 

 Pipevine Swallowtail (Battus philenor) 

 Polydamas Swallowtail (Battus polydamas) 

 Schaus' Swallowtail (Papilio aristodemus) 

 Spicebush Swallowtail (Papilio troilus) 

 Zebra Swallowtail (Eurytides marcellus) 

Prominents (Notodontidae) 

 Nystalea indiana (Nystalea indiana) 

 Nystalea ebalea (Nystalea ebalea) 

 Litodonta hydromeli (Litodonta hydromeli) 

 Heterocampa cubana (Heterocampa cubana) 

 Heterocampa zayasi (Heterocampa zayasi) 

 Unicorn Caterpillar Moth (Schizura unicornis) 
Appendices 219 

Skippers (Hesperiidae) 

 Grass Skippers (Hesperiinae) 

 Aaron's Skipper (Poanes aaroni) 

 Baracoa Skipper (Polites baracoa) 

 Berry's Skipper (Euphyes berryi) 

 Brazilian Skipper (Calpodes ethlius) 

 Byssus Skipper (Problema byssus) 

 Clouded Skipper (Lerema accius) 

 Delaware Skipper (Anatrytone logan) 

 Eufala Skipper (Lerodea eufala) 

 Fiery Skipper (Hylephila phyleus) 

 Meske's Skipper (Hesperia meskei) 

 Monk (Asbolis capucinus) 

 Neamathla Skipper (Nastra neamathla) 

 Obscure Skipper (Panoquina panoquinoides) 

 Ocola Skipper (Panoquina ocola) 

 Palatka Skipper (Euphyes pilatka) 

 Palmetto Skipper (Euphyes arpa) 

 Sachem (Atalopedes campestris) 

 Salt Marsh Skipper (Panoquina panoquin) 

 Southern Broken-Dash (Wallengrenia otho) 

 Southern Skipperling (Copaeodes minima) 

 Swarthy Skipper (Nastra lherminier) 

 Tawny-edged Skipper (Polites themistocles) 

 Three-spotted Skipper (Cymaenes tripunctus) 

 Twin-spot Skipper (Oligoria maculata) 

 Violet-banded Skipper (Nyctelius nyctelius) 

 Whirlabout (Polites vibex) 

Spread-wing Skippers (Pyrginae) 

 Common Checkered-Skipper (Pyrgus communis) 

 Dorantes Longtail (Urbanus dorantes) 

 Florida Duskywing (Ephyriades brunnea) 

 Funereal Duskywing (Erynnis funeralis) 

 Hammock Skipper (Polygonus leo) 

 Hayhurst's Scallopwing (Staphylus hayhurstii) 

 Long-tailed Skipper (Urbanus proteus) 

 Mangrove Skipper (Phocides pigmalion) 

 Manuel's Skipper (Polygonus savigny) 

 Silver-spotted Skipper (Epargyreus clarus) 

 Tropical Checkered-Skipper (Pyrgus oileus) 

 Zarucco Duskywing (Erynnis zarucco) 

 Zestos Skipper (Epargyreus zestos) 

Sphinx Moths, Hawkmoths (Sphingidae) 

 Macroglossinae (Macroglossinae) 

 Achemon sphinx (Eumorpha achemon) 

 Alope sphinx (Erinnyis alope) 

 Banded sphinx (Eumorpha fasciatus) 

 Cramer's sphinx (Erinnyis crameri) 

 Ello sphinx (Erinnyis ello) 
 Lower Florida Keys National Wildlife Refuges 220

 False-windowed sphinx (Madoryx pseudothyreus) 

 Fig sphinx (Pachylia ficus) 

 Gaudy sphinx (Eumorpha labruscae) 

 Grote's sphinx (Cautethia grotei) 

 Nessus sphinx (Amphion floridensis) 

 Obscure sphinx (Erinnyis obscura) 

 Pluto sphinx (Xylophanes pluto) 

 Tantalus sphinx (Aellopos tantalus) 

 Tersa sphinx (Xylophanes tersa) 

 Tetrio sphinx (Pseudosphinx tetrio) 

 Vine sphinx (Eumorpha vitis) 

 White-lined sphinx (Hyles lineata) 

Sphinginae (Sphinginae) 

 Carolina sphinx (Manduca sexta) 

 Carter's sphinx (Protambulyx carteri) 

 Giant sphinx (Cocytius antaeus) 

 Occult sphinx (Manduca occulta) 

 Pink-spotted hawkmoth (Agrius cingulata) 

 Streaked sphinx (Protambulyx strigilis) 

Tiger Moths and Lichen Moths (Arctiidae) 

Lichen Moths (Lithosiinae) 

 Neoplynes eudora (Neoplynes eudora) 

 Mouse-Colored Lichen Moth (Pagara simplex) 

 Subject Lichen Moth (Cisthene subjecta) 

Pericopine Moths (Pericopinae) 

 Faithful Beauty (Composia fidelissima) 

Syntomine Moths (Syntominae) 

 Edwards' Wasp Moth (Lymire edwardsii) 

 Lesser Wasp Moth (Pseudocharis minima) 

 Polka-Dot Wasp Moth (Syntomeida epilais) 

Tiger Moths (Arctiinae) 

 Streaked Calidota (Calidota laqueata) 

 Yellow-Winged Pareuchaetes (Pareuchaetes insulata) 

Whites and Sulphurs (Pieridae) 

Sulphurs (Coliadinae) 

 Barred Yellow (Eurema daira) 

 Boisduval's Yellow (Eurema boisduvaliana) 

 Cloudless Sulphur (Phoebis sennae) 

 Dainty Sulphur (Nathalis iole) 

 Dina Yellow (Pyrisitia dina) 

 Large Orange Sulphur (Phoebis agarithe) 

 Little Yellow (Pyrisitia lisa) 

 Lyside Sulphur (Kricogonia lyside) 

 Mimosa Yellow (Pyrisitia nise) 

 Orange Sulphur (Colias eurytheme) 
Appendices 221 

 Orange-barred Sulphur (Phoebis philea) 

 Orbed Sulphur (Aphrissa orbis) 

 Sleepy Orange (Abaeis nicippe) 

 Southern Dogface (Zerene cesonia) 

 Statira Sulphur (Aphrissa statira) 

 Yellow Angled-Sulphur (Anteos maerula) 

Whites (Pierinae) 

 Cabbage White (Pieris rapae) 

 Checkered White (Pontia protodice) 

 Florida White (Appias drusilla) 

 Great Southern White (Ascia monuste) 

Wild Silk Moths (Saturniidae) 

Buck and Io Moths (Hemileucinae) 

 Io moth (Automeris io) 

Royal Moths (Citheroniinae) 

 Consular oakworm moth (Anisota consularis) 

 Imperial moth (Eacles imperialis) 

 Pink-striped oakworm moth (Anisota virginiensis) 
 Lower Florida Keys National Wildlife Refuges 222

Plants of Lower Keys National Wildlife Refuges 

Source: The Institute for Regional Conservation (IRC), Floristic Inventory of South 

Florida database 

February 12, 2007 

Gann, G.D., K.A. Bradley and S.W. Woodmansee. 2001-2007. 

The Floristic Inventory of South Florida Database Online. 

The Institute for Regional Conservation, Miami. 

Superscript (I or II) in scientific name column: FLEPPC (Florida Exotic Pest Plant Council) = Category I or II

Native Status: N = Native, NN = Not Native, NA = Naturalized, CO = Cultivated Only

IRC Status: CI = Critically Imperiled, E = Extirpated

State Status: T = Threatened, E = Endangered, C = Species of special concern 

Federal Status: T= Threatened, E= Endangered, C = Candidate species

Refuges: KD = Key Deer, KW = Key West, GWH = Great White Heron

Scientific Name Common Name Native

Status 

IRC

Status 

State

Status 

Federal 

Status Refuges 

Abelmoschus esculentus Okra NN, NA KD 

Abildgaardia ovata Flatspike sedge N KD 

Abutilon permolle 

Coastal Indian 

mallow N KD 

Acacia farnesiana Sweet acacia N KD, KW 

Acacia pinetorum Pineland acacia N KD 

Acalypha chamaedrifolia 

Three-seeded 

mercury, Bastard 

copperleaf 

N KD 

Acanthocereus tetragonus 

Barbwire cactus, 

Dildoe cactus N T KD, KW, GWH 

Acrostichum aureum Golden leather fern N T KD 

Acrostichum danaeifolium Giant leather fern N KD 

Agalinis fasciculata Beach false foxglove N CI KD 

Agalinis maritima 

Saltmarsh false 

foxglove N KD 

Agalinis obtusifolia 

Tenlobe false 

foxglove N CI KD 

Agave americana Century plant NN, NA KD 

Agave decipiens False-sisal N KD, KW, GWH 

Agave sisalana II Sisal-hemp NN, NA KD, KW, GWH 

Ageratum littorale 

Keys ageratum, Cape 

Sable Whiteweed N E KD 

Albizia lebbeck I Woman's tongue, 

Rattlepod NN, NA KD 
Appendices 223 

Scientific Name Common Name Native

Status 

IRC

Status 

State 

Status 

Federal 

Status Refuges 

Aletris bracteata 

White colic-root, 

bracted colic-root N E KD 

Aloe vera Aloe NN, CO KD, KW 

Alternanthera flavescens Yellow joyweed N KD, KW, GWH 

Alternanthera maritima Seaside joyweed N KW 

Amaranthus hybridus 

Common pigweed, 

slim amaranth NN, NA KD 

Amaranthus spinosus Spiny amaranth NN, NA KD 

Ambrosia artemisiifolia Common ragweed N KD, KW 

Ambrosia hispida 

Beach ragweed, 

Coastal ragweed N KD, KW 

Ammannia latifolia 

Pink redstem, 

Toothcup N 

Amyris elemifera 

Common torchwood, 

Sea torchwood N KD, KW, GWH 

Andropogon glomeratus 

var. pumilus 

Common bushy 

bluestem N KD, KW 

Andropogon longiberbis Hairy bluestem N KD 

Andropogon ternarius Splitbeard bluestem N KD 

Andropogon virginicus 

Broomsedge 

bluestem N KD 

Anemia adiantifolia 

Pine fern, Maidenhair 

pineland fern N KD 

Angadenia berteroi 

Pineland-allamanda, 

Pineland golden 

trumpet 

N T KD 

Annona glabra Pond-apple N KD 

Ardisia escallonioides Marlberry N KD, GWH 

Argusia gnaphalodes 

Sea-lavender, Searosemary 

N E KD, KW 

Argythamnia blodgettii 

Blodgett's wild 

mercury, Blodgett's 

silverbush 

N E C KD 

Aristida purpurascens 

Arrowfeather 

threeawn N KD, KW 

Arundo donax Giant reed NN, CO KD 

Asclepias viridis Green antelopehorn N KD 

Asparagus densiflorus I Sprenger's 

asparagus-fern NN, NA KD 

Asparagus officinalis Garden asparagus NN, CO KD 
 Lower Florida Keys National Wildlife Refuges 224

Scientific Name Common Name Native

Status 

IRC

Status 

State

Status 

Federal 

Status Refuges 

Asparagus setaceus 

Common asparagusfern NN, NA KD 

Aster adnatus 

Clasping aster, 

Scaleleaf aster N KD 

Aster bracei Brace's aster N KD, KW 

Aster concolor Eastern silver aster N KD 

Aster dumosus Rice button aster N KD 

Aster subulatus 

Annual saltmarsh 

aster N KD 

Atriplex pentandra 

Beach orach, 

Crested saltbush N KD, KW, GWH 

Avicennia germinans Black mangrove N KD, KW, GWH 

Ayenia euphrasiifolia Eyebright ayenia N KD 

Baccharis angustifolia 

Narrowleaved 

groundsel, Saltwater 

Falsewillow 

N KD 

Baccharis halimifolia 

Saltbush, Groundsel 

tree, Sea-myrtle N KD, GWH 

Bacopa monnieri 

Water hyssop, Herbof-grace N KD 

Basiphyllaea corallicola Carter's orchid N CI E KD 

Batis maritima Saltwort, Turtleweed N KD, KW, GWH 

Bidens alba var. radiata Spanish-needles N KD, KW, GWH 

Blechum pyramidatum II Green shrimpplant, 

Browne's blechum NN, NA GWH 

Bletia purpurea Pinepink N T KD 

Blutaparon vermiculare Samphire, Silverhead N KD, KW, GWH 

Boerhavia diffusa 

Red spiderling, 

wineflower N KD, KW, GWH 

Boerhavia erecta Erect spiderling N KD 

Borrichia arborescens 

Green sea-oxeyedaisy, Tree seaside 

oxeye 

N KD, KW, GWH 

Borrichia frutescens 

Silver sea-oxeyedaisy, Bushy seaside 

oxeye 

N KD, KW, GWH 

Borrichia xcubana 

Cuban sea-oxeyedaisy N KD 

Bothriochloa pertusa 

Pitted bluestem, 

Pitted beardgrass NN, NA KD 

Bourreria cassinifolia Pineland strongback N CI E KD 
Appendices 225 

Scientific Name Common Name Native

Status 

IRC

Status 

State 

Status 

Federal 

Status Refuges 

Bourreria succulenta 

Smooth strongback, 

Bahama strongbark N E KD 

Buchnera americana American bluehearts N KD 

Bursera simaruba Gumbo-limbo N KD, KW, GWH 

Byrsonima lucida Locustberry N T KD, KW, GWH 

Caesalpinia bonduc Gray nicker-bean N KD, KW, GWH 

Caesalpinia major Yellow nicker-bean N CI E GWH 

Caesalpinia pauciflora Fewflower holdback N CI E KD 

Cajanus cajan Pigeonpea NN, NA KD 

Cakile lanceolata Coastal searocket N KD, KW 

Callisia fragrans II Basketplant NN, NA GWH 

Callisia repens 

Basket plant, 

Creeping inchplant NN, NA GWH 

Calyptranthes pallens 

Spicewood, Pale 

lidflower N T KD 

Canavalia rosea 

Beach-bean, 

Baybean, Seaside 

jackbean 

N KD, KW, GWH 

Canella winterana 

Cinnamon bark, 

Pepper cinnamon N E KD, GWH 

Capparis cynophallophora Jamaica caper-tree N KD, KW, GWH 

Capparis flexuosa 

Limber caper, 

Bayleaf capertree N KD, KW, GWH 

Capraria biflora Goatweed N KD, KW 

Capsicum annuum var. 

glabriusculum 

Bird pepper, 

Cayenne pepper N KD 

Carica papaya Papaya NN, NA KD, KW 

Carissa macrocarpa Natal-plum NN, NA KD 

Cassytha filiformis Lovevine, Devil's gut N KD 

Casuarina equisetifolia I Australian-pine, 

Horsetail casuarina NN, NA KD, KW, GWH 

Catesbaea parviflora Smallflower lilythorn NN CI E KD 

Catharanthus roseus 

Madagascarperiwinkle NN, NA KD 

Cenchrus echinatus Southern sandbur N KD, KW, GWH 

Cenchrus gracillimus Slender sandbur N KD 

Cenchrus incertus Coastal sandbur N KD, KW 
 Lower Florida Keys National Wildlife Refuges 226

Scientific Name Common Name Native

Status 

IRC

Status 

State

Status 

Federal 

Status Refuges 

Cenchrus tribuloides Sanddune sandbur N KW, GWH 

Centella asiatica Coinwort, Spadeleaf N KD 

Centrosema virginianum Spurred butterfly-pea N KD, KW 

Ceratophyllum muricatum 

subsp. australe Prickly hornwort N, E E KD 

Chamaecrista lineata var. 

keyensis 

Keys partidge-pea, 

Narrowpod sensitive 

pea 

N E C KD, KW, GWH 

Chamaecrista nictitans 

var. aspera 

Hairy sensitive-pea, 

Hairy partridge-pea N KD, KW 

Chamaesyce blodgettii Limestone sandmat N KD, KW 

Chamaesyce conferta 

Everglades key 

sandmat N KD 

Chamaesyce cordifolia Heartleaf sandmat N KD 

Chamaesyce deltoidea 

subsp. serpyllum 

Florida Keys wedge 

sandmat N CI E C KD 

Chamaesyce garberi Garber's sandmat N E T KD, KW 

Chamaesyce hirta 

Hairy spurge, Pillpod 

sandmat N KD 

Chamaesyce hypericifolia 

Eyebane, Graceful 

sandmat N KD, KW, GWH 

Chamaesyce hyssopifolia 

Eyebane, Hyssopleaf 

sandmat N KD 

Chamaesyce 

mesembrianthemifolia 

Seaside spurge, 

Coastal beach 

sandmat 

N KD, KW, GWH 

Chamaesyce pergamena 

Southern Florida 

sandmat N T KD 

Chamaesyce porteriana Porter's sandmat N E KD 

Chiococca alba 

Common snowberry, 

Milkberry N KD 

Chiococca parvifolia Pineland snowberry N KD, GWH 

Chromolaena frustrata 

Cape Sable 

thoroughwort N CI E C KW 

Chromolaena odorata Jack-in-the-bush N KD 

Chrysobalanus icaco Coco-plum N KD 

Chrysophyllum oliviforme Satinleaf N T KD 

Cirsium horridulum Purple thistle N KD 

Cissus trifoliata 

Marinevine, 

Sorrelvine N KD 
Appendices 227 

Scientific Name Common Name Native

Status 

IRC

Status 

State 

Status 

Federal 

Status Refuges 

Citharexylum spinosum Florida fiddlewood N KD, KW 

Citrus aurantifolia Key lime NN, NA KD 

Cladium jamaicense 

Saw-grass, Jamaica 

swamp sawgrass 

N KD, GWH 

Clitoria ternatea Asian pigeonwings NN, NA KD 

Clusia rosea Pitch-apple NN, NA KD 

Cnidoscolus stimulosus 

Tread-softly, Fingerrot, 7-minute-itch N KD 

Coccoloba diversifolia 

Pigeonplum, 

Tietongue N KD, KW, GWH 

Coccoloba uvifera Seagrape N KD, KW, GWH 

Coccothrinax argentata Florida silver palm N T KD, KW, GWH 

Cocos nucifera Coconut palm NN, NA KD, KW, GWH 

Colubrina arborescens 

Coffee colubrina, 

Greenheart N E KD, KW 

Colubrina asiatica I Latherleaf, Asian 

nakedwood NN, NA KD, KW, GWH 

Commelina erecta 

Whitemouth 

dayflower N KD, KW, GWH 

Conocarpus erectus Buttonwood N KD, KW, GWH 

Conoclinium coelestinum Blue mistflower N KD 

Conyza canadensis var. 

pusilla 

Dwarf Canadian 

horseweed N KD, KW 

Cordia globosa 

Butterflybush, 

Curacao bush N E KD 

Cordia sebestena 

Orange geigertree, 

Largeleaf geigertree NN, NA KD, KW, GWH 

Coreopsis leavenworthii 

Leavenworth's 

tickseed N KD 

Crossopetalum ilicifolium 

Quailberry, 

Christmasberry N T KD 

Crossopetalum rhacoma 

Rhacoma, 

Maidenberry N T KD, GWH 

Crotalaria incana Shakeshake NN, NA KD 

Crotalaria pumila Low rattlebox N KD 

Crotalaria rotundifolia Rabbitbells N KD 

Croton linearis 

Pineland croton, 

Grannybush N KD 

Cupania glabra American toadwood N CI E KD, GWH 
 Lower Florida Keys National Wildlife Refuges 228

Scientific Name Common Name Native

Status 

IRC

Status 

State

Status 

Federal 

Status Refuges 

Cynanchum angustifolium 

Vine milkweed, Gulf 

Coast swallowwort N KD, KW, GWH 

Cynanchum blodgettii 

Blodgett's 

swallowwort N T KD 

Cynanchum northropiae 

Vine milkweed, 

Fragrant 

swallowwort 

N KD, KW, GWH 

Cynanchum scoparium 

Hairnetvine, Leafless 

swallowwort N KD 

Cynodon dactylon Bermuda grass NN, NA KD, KW, GWH 

Cyperus compressus Poorland flatsedge N KD 

Cyperus elegans Royal flatsedge N KD 

Cyperus fuligineus Limestone flatsedge N CI E KD 

Cyperus ligularis Swamp flatsedge N KD 

Cyperus odoratus Fragrant flatsedge N KD 

Cyperus planifolius Flatleaf flatsedge N KD, KW, GWH 

Cyperus polystachyos Manyspike flatsedge N KD 

Cyperus retrorsus Pinebarren flatsedge N KD 

Cyperus squarrosus Bearded flatsedge N CI KD 

Cyperus tetragonus Fourangle flatsedge N KD 

Dactyloctenium aegyptium 

Crow's-foot grass, 

Durban 

crowfootgrass 

NN, NA KD, KW, GWH 

Dalbergia ecastaphyllum Coinvine N GWH 

Delonix regia 

Royal poinciana, 

Flamboyant NN, NA KD 

Desmanthus virgatus Wild tantan N KD, KW 

Desmodium incanum Beggar's-ticks N KD, GWH 

Desmodium tortuosum Dixie ticktrefoil NN, NA KD 

Desmodium triflorum 

Threeflower 

ticktrefoil NN, NA KD 

Dichanthelium 

dichotomum Cypress witchgrass N KD 

Dicliptera sexangularis 

False-mint, Sixangle 

foldwing N KD, KW 

Digitaria bicornis Asia crabgrass NN, NA KD, KW, GWH 

Digitaria ciliaris Southern crabgrass N KD, KW, GWH 
Appendices 229 

Scientific Name Common Name Native

Status 

IRC

Status 

State 

Status 

Federal 

Status Refuges 

Digitaria filiformis var. 

dolichophylla Caribbean crabgrass N T KD 

Digitaria insularis Sourgrass N KD 

Diospyros virginiana 

Persimmon, 

Common persimmon N KD 

Distichlis spicata Saltgrass N KD, KW, GWH 

Dodonaea elaeagnoides Smallfruit varnishleaf N E KD 

Drypetes diversifolia Milkbark, Whitewood N E KD, GWH 

Drypetes lateriflora Guiana-plum N T KD 

Dyschoriste angusta 

Rockland twinflower, 

Pineland snakeherb N KD 

Echites umbellata 

Devil's-potato, 

Rubbervine N KD, GWH 

Eleocharis cellulosa Gulf Coast spikerush N KD 

Eleocharis geniculata Canada spikerush N KD 

Eleusine indica Indian goose grass NN, NA KD 

Emilia fosbergii Florida tasselflower NN, NA KD 

Encyclia tampensis 

Florida butterfly 

orchid N C KD, KW, GWH 

Eragrostis amabilis Feather love grass NN, NA KD 

Eragrostis ciliaris 

Gophertail love 

grass NN, NA KD, KW 

Eragrostis elliottii Elliott's love grass N KD 

Eriochloa michauxii 

Longleaf cup grass, 

Michaux's cup grass N KD 

Erithalis fruticosa Blacktorch N T KD, KW, GWH 

Ernodea littoralis 

Beach-creeper, 

Golden-creeper, 

Coughbush 

N KD, KW, GWH 

Erythrina herbacea 

Coralbean, Cherokee 

bean N KD, KW 

Eugenia axillaris White stopper N KD, KW, GWH 

Eugenia foetida 

Spanish stopper, 

Boxleaf stopper N KD, KW, GWH 

Eupatorium capillifolium Dog-fennel N KD 

Euphorbia lactea Mottled spurge NN, CO KD 

Euphorbia tirucalli 

Pencil-cactus, Pencil 

tree, Indian tree 

spurg 

NN, CO KD 
 Lower Florida Keys National Wildlife Refuges 230

Scientific Name Common Name Native

Status 

IRC

Status 

State

Status 

Federal 

Status Refuges 

Euphorbia trichotoma Sanddune spurge N KW 

Eustachys glauca 

Prairie fingergrass, 

Saltmarsh 

fingergrass 

N KD, KW 

Eustachys petraea 

Common 

fingergrass, 

Pinewoods 

fingergrass 

N KD, KW, GWH 

Eustoma exaltatum 

Seaside gentian, 

Marshgentian N KD, KW, GWH 

Evolvulus alsinoides 

Slender dwarf 

morningglory NN, NA KD, KW 

Evolvulus convolvuloides 

Bindweed dwarf 

morningglory N E KD 

Evolvulus grisebachii 

Grisebach's Dwarf 

morningglory N CI E KD 

Evolvulus sericeus 

Silver dwarf 

morningglory N KD 

Exostema caribaeum 

Caribbean 

princewood N CI E KD 

Exothea paniculata 

Inkwood, 

Butterbough N KD, GWH 

Ficus aurea 

Strangler fig, Golden 

fig N KD, KW, GWH 

Ficus citrifolia 

Short-leaf fig, Wild 

banyan tree N KD, KW 

Fimbristylis cymosa 

Hurricane sedge, 

Hurricanegrass NN,NA KD, KW, GWH 

Fimbristylis spadicea Marsh fimbry N KD, KW 

Flaveria linearis 

Narrowleaf 

yellowtops N KD, KW 

Flaveria trinervia 

Annual yellowtops, 

Clustered yellowtops N KD 

Forestiera segregata 

Florida privet, 

Florida swampprivet N KD 

Gaillardia pulchella 

Blanketflower, 

Firewheel NN,NA KD 

Galactia striata 

Florida hammock 

milkpea N KD, KW, GWH 

Galactia volubilis Downy milkpea N KD, KW, GWH 

Galium hispidulum Coastal bedstraw N KD 

Gaura angustifolia 

Southern gaura, 

Southern 

beeblossum 

N KD 
Appendices 231 

Scientific Name Common Name Native

Status 

IRC

Status 

State 

Status 

Federal 

Status Refuges 

Genipa clusiifolia Sevenyear apple N KD, KW, GWH 

Gossypium hirsutum 

Wild cotton, Upland 

cotton N E KD, KW, GWH 

Guapira discolor Blolly, Beeftree N KD, KW, GWH 

Guettarda elliptica 

Everglades 

velvetseed, 

Hammock velvetseed 

N KD 

Guettarda scabra Rough velvetseed N KD, GWH 

Gyminda latifolia 

West Indian false 

boxwood N E KD, KW 

Gymnanthes lucida 

Crabwood, 

Oysterwood N KD, KW, GWH 

Habenaria quinqueseta 

Longhorn false 

reinorchid N KD 

Halodule wrightii 

Shoal-grass, 

Shoalweed N KD, KW 

Hamelia patens Firebush N KD 

Harrisia simpsonii 

Simpson's 

pricklyapples, 

Simpson's 

applecactus 

N E KD 

Hedyotis nigricans var. 

floridana 

Florida diamond 

flowers NN KD 

Helianthus annuus 

Annual sunflower, 

Common sunflower NN,NA KD 

Heliotropium 

angiospermum Scorpionstail N KD, KW, GWH 

Heliotropium 

curassavicum 

Seaside heliotrope, 

Salt heliotrope N KD, KW, GWH 

Heliotropium polyphyllum Pineland heliotrope N KD 

Herissantia crispa Bladdermallow N KD, KW, GWH 

Hibiscus poeppigii 

Poeppig's 

rosemallow N E KD 

Hibiscus rosa-sinensis 

Garden rosemallow, 

Shoe-back-plant NN, NA KD 

Hibiscus tiliaceus II Seaside mahoe, Sea 

hibiscus, mahoe NN, NA KD 

Hippomane mancinella Manchineel N E KD 

Hymenocallis latifolia 

Mangrove spiderlily, 

Perfumed spiderlily N KD, KW, GWH 

Hypelate trifoliata 

White-ironwood, 

Inkwood N CI E KD 
 Lower Florida Keys National Wildlife Refuges 232

Scientific Name Common Name Native

Status 

IRC

Status 

State

Status 

Federal 

Status Refuges 

Hypoxis wrightii 

Bristleseed yellow 

stargrass N KD 

Indigofera miniata var. 

florida 

Florida coastal 

indigo N KD 

Indigofera tinctoria True indigo NN, NA KD 

Ipomoea alba 

Common 

moonflowers, 

Moonflowers 

N KD, KW 

Ipomoea batatas Sweetpotato NN, NA KD 

Ipomoea indica var. 

acuminata 

Ocean-blue 

morningglory N KD, KW, GWH 

Ipomoea pes-caprae 

subsp. brasiliensis 

Railroadvine, 

Bayhops N KD, KW, GWH 

Ipomoea sagittata 

Everglades 

morningglory N KD 

Ipomoea triloba 

Three-lobed 

morningglory, 

Littlebell 

NN, NA KD, GWH 

Ipomoea violacea 

Coastal 

morningglory N KD, KW, GWH 

Iresine diffusa 

Bloodleaf, Juba's 

bush N KD 

Iva imbricata 

Beach-elder, 

Seacoast marshelder N KD, KW, GWH 

Jacquemontia pentanthos Skyblue clustervine N E KD 

Jacquinia keyensis Joewood N T KD, KW, GWH 

Juncus roemerianus 

Black needle rush, 

Needle rush, Black 

rush 

N KD 

Kalanchoe daigremontiana Devil's-backbone NN, NA KD, KW 

Kalanchoe tubiflora Chandelier plant NN, NA KD 

Kosteletzkya virginica 

Virginia saltmarsh 

mallow N KW 

Krugiodendron ferreum Black ironwood N KD, KW 

Laguncularia racemosa White mangrove N KD, KW, GWH 

Lantana camara I Shrubverbena NN, NA KD 

Lantana involucrata 

Wild-sage, 

Buttonsage N KD, KW, GWH 

Lasiacis divaricata 

Smallcane, Florida 

tibisee, Wild-bamboo N KD, KW, GWH 

Launaea intybacea Achicoria azul NN, NA KD 
Appendices 233 

Scientific Name Common Name Native

Status 

IRC

Status 

State 

Status 

Federal 

Status Refuges 

Lepidium virginicum 

Poor-man's-pepper, 

Virginia pepperweed N KD 

Leptochloa dubia 

Green spangletop, 

Green sprangletop N KD, GWH 

Leptochloa fascicularis 

Bearded spangletop, 

Bearded sprangletop N KD 

Leucaena leucocephala II White leadtree NN, NA KD, KW 

Liatris tenuifolia Shortleaf gayfeather N KD 

Licania michauxii Gopher-apple N KD 

Limonium carolinianum 

Saltmarsh-rosemary, 

Carolina sealavender N KD, KW 

Linum arenicola Sand flax N E C KD 

Livistona chinensis II Chinese fan palm NN, NA KD 

Lobelia glandulosa Glade lobelia N KD 

Ludwigia curtissii 

Curtiss's 

primrosewillow N KD 

Ludwigia microcarpa 

Smallfruit 

primrosewillow N KD 

Ludwigia repens 

Creeping 

primrosewillow N KD 

Lycium carolinianum 

Christmasberry, 

Carolina desertthorn N KD, KW, GWH 

Lycopersicon esculentum 

Tomato, Garden 

tomato NN, NA KD 

Lysiloma latisiliquum 

Wild-tamarind, False 

tamarind N KD, KW 

Lythrum lineare Wand loosestrife N KD 

Macroptilium lathyroides 

Wild-bean, Wild 

bushbean NN, NA KD 

Malvastrum 

corchorifolium False mallow N KD 

Malvaviscus arboreus var. 

drummondii Texas waxmallow NN, NA KD 

Manilkara jaimiqui subsp. 

emarginata Wild dilly N T KD, KW, GWH 

Manilkara zapota I Sapodilla NN, NA KD, KW 

Maytenus phyllanthoides Florida mayten N T KD, KW, GWH 

Mecardonia acuminata 

subsp. peninsularis Axilflower N KD 

Melaleuca quinquenervia I Punktree NN, NA KD 
 Lower Florida Keys National Wildlife Refuges 234

Scientific Name Common Name Native

Status 

IRC

Status 

State

Status 

Federal 

Status Refuges 

Melanthera nivea Snow squarestem N KD, KW, GWH 

Melanthera parvifolia 

Pineland 

blackanthers N T KD 

Melia azedarach II Chinaberrytree NN, NA KD 

Melicoccus bijugatus Spanish lime NN, NA KD 

Melothria pendula Creeping-cucumber N KD 

Metopium toxiferum 

Poisonwood, Florida 

poisontree N KD, KW, GWH 

Mikania scandens 

Climbing hempweed, 

Climbing hempvine N KD 

Mitreola petiolata 

Miterwort, Lax 

hornpod N KD 

Mitreola sessilifolia 

Mitrewort, Swamp 

hornpod N KD 

Momordica charantia 

Wild balsam-apple, 

Balsampear NN, NA KD 

Monanthochloe littoralis 

Shoregrass, 

Keygrass N KD, KW, GWH 

Morinda royoc 

Yellowroot, Redgal, 

Mouse's pineapple N KD, KW, GWH 

Muhlenbergia capillaris 

Muhlygrass, 

Hairawnmuhly N KD 

Musa x paradisiaca Common banana NN, NA KD 

Myrica cerifera 

Wax myrtle, 

Southern Bayberry N KD 

Nephrolepis exaltata Wild Boston fern N KD 

Neptunia pubescens Tropical-puff N KD 

Nerium oleander Oleander NN, NA KD 

Nicotiana tabacum 

Tobacco, Cultivated 

tobacco NN, NA KD 

Ocimum campechianum 

Wild basil, Wild 

sweet basil N E KD 

Odontosoria clavata Wedgelet fern N E KD 

Opuntia corallicola 

Semaphore 

pricklypear N CI E C KD 

Opuntia cubensis Bullsuckers N CI KD 

Opuntia humifusa Pricklypear N KD 

Opuntia stricta Erect pricklypear N T KD, KW, GWH 

Opuntia triacanthos Jumping cactus N CI E KD 
Appendices 235 

Scientific Name Common Name Native

Status 

IRC

Status 

State 

Status 

Federal 

Status Refuges 

Panicum amarum 

Beachgrass, Bitter 

panicgrass N KD, KW 

Panicum dichotomiflorum 

var. bartowense Hairy fall panic grass N KD 

Panicum maximum II Guineagrass NN, NA KD, KW 

Panicum rigidulum Redtop panicum N KD 

Panicum virgatum Switchgrass N KD 

Parietaria floridana Florida pellitory N KD 

Parkinsonia aculeata 

Mexican palo verde, 

Jerusalam thorn NN, NA KD 

Parthenocissus 

quinquefolia 

Virginia-creeper, 

Woodbine N KD 

Paspalidium chapmanii Coral panicum N E KD, KW 

Paspalum blodgettii 

Coral paspalum, 

Blodgett's 

crowngrass 

N KW 

Paspalum caespitosum 

Blue paspalum, Blue 

crowngrass 

N KD, KW 

Paspalum distichum Knot grass N KD, KW 

Paspalum laxum Coconut paspalum N KD 

Paspalum monostachyum Gulfdune paspalum N KD 

Paspalum notatum Bahia grass NN, NA KD 

Paspalum setaceum Thin paspalum N KD, KW, GWH 

Paspalum vaginatum Seashore paspalum N KD, KW, GWH 

Passiflora suberosa 

Corkystem 

passionflower N KD, KW, GWH 

Pectis glaucescens 

Tea-blinkum, 

Sanddune 

cinchweed 

N KD, KW 

Pedilanthus tithymaloides 

subsp. smallii 

Jacob's ladder, 

Devil's backbone NN, NA KW 

Pentalinon luteum 

Wild-allamanda, 

Hammock viperstail N KD, KW, GWH 

Persea americana Avocado NN, NA KD 

Persea palustris Swamp bay N KD 

Phlebodium aureum Golden polypody N KD 

Phoenix dactylifera 

Commercial date 

palm, Date NN, NA KD, KW 

Phoenix reclinata II Senegal date palm NN, NA KD, KW 
 Lower Florida Keys National Wildlife Refuges 236

Scientific Name Common Name Native

Status 

IRC

Status 

State

Status 

Federal 

Status Refuges 

Phyla nodiflora 

Frogfruit, Turkey 

tangle fogfruit, 

Capeweed 

N KD, GWH 

Phyllanthus amarus 

Gale-of-wind, Carryme-seed NN, NA KD 

Phyllanthus pentaphyllus 

var. floridanus 

Florida five-petalled 

leafflower N KD 

Physalis angulata Cutleaf groundcherry N KD 

Physalis angustifolia 

Coastal 

groundcherry N KD 

Physalis pubescens Husk tomato N KD 

Physalis walteri 

Walter's 

groundcherry N GWH 

Pilea herniarioides Caribbean clearweed N KD 

Pilea microphylla 

Artillery plant, 

Rockweed N KD 

Pilosocereus robinii Key tree cactus N CI E E KD 

Pinguicula pumila Small butterwort N KD 

Pinus elliottii var. densa 

South Florida slash 

pine N KD, GWH 

Piriqueta caroliniana Pitted stripeseed N KD 

Piscidia piscipula 

Jamaica-dogwood, 

Florida fishpoison 

tree 

N KD, KW, GWH 

Pisonia aculeata 

Devil's claws, 

Pullback N KD, KW, GWH 

Pisonia rotundata 

Smooth devilsclaws, 

Blolly N E KD 

Pithecellobium keyense 

Florida Keys 

blackbead N T KD, KW, GWH 

Pithecellobium unguis-cati 

Cat's-claw, Catclaw 

blackbead N KD, KW 

Pityopsis graminifolia Narrowleaf silkgrass N KD 

Pityrogramma trifoliata Goldenrod fern N KD 

Pleopeltis polypodioides 

var. michauxiana Resurrection fern N KD 

Pluchea carolinensis Cure-for-all N KD 

Pluchea odorata Sweetscent N KD 

Pluchea rosea Rosy camphorweed N KD 

Poinsettia cyathophora 

Paintedleaf, Fire-onthe-mountain N KD, KW, GWH 
Appendices 237 

Scientific Name Common Name Native

Status 

IRC

Status 

State 

Status 

Federal 

Status Refuges 

Poinsettia heterophylla 

Fiddler's spurge, 

Mexican fireplant N KD, KW 

Poinsettia pinetorum 

Pineland poinsettia, 

Pineland spurge N E KD, KW 

Polygala balduinii Baldwin's milkwort N KD 

Polygala boykinii Boykin's milkwort N KD 

Polygala grandiflora 

Candyweed, Showy 

milkwort N KD 

Polypremum procumbens 

Rustweed, 

Juniperleaf N KD 

Portulaca oleracea 

Purslane, Little 

hogweed N KD, KW, GWH 

Portulaca rubricaulis 

Stalked purslane, 

Redstem purslane N KD, KW 

Proserpinaca palustris 

Mermaid weed, 

Marsh mermaidweed N KD 

Psidium guajava I Guava NN, NA KD 

Psidium longipes Longstalked-stopper N T KD, GWH 

Psilotum nudum Whisk-fern N KD 

Psychotria nervosa 

Shiny-leaved wild 

coffee N KD 

Pteridium aquilinum var. 

caudatum Lacy bracken fern N KD, GWH 

Pteris bahamensis Bahama ladder brake N T KD 

Pteris vittata II China brake NN, NA KD 

Pterocaulon 

pycnostachyum Blackroot N KD 

Punica granatum Pomegranate NN, CO KD 

Randia aculeata White indigoberry N KD, KW, GWH 

Rapanea punctata Myrsine, Colicwood N KD, KW, GWH 

Rayjacksonia 

phyllocephala Camphor daisy N KD, GWH 

Reynosia septentrionalis Darlingplum N T KD, KW, GWH 

Rhabdadenia biflora 

Mangrove 

rubbervine, 

Mangrovevine 

N KD 

Rhizophora mangle Red mangrove N KD, KW, GWH 

Rhus copallinum Winged sumac N KD 

Rhynchelytrum repens I Rose Natalgrass NN, NA KD 
 Lower Florida Keys National Wildlife Refuges 238

Scientific Name Common Name Native

Status 

IRC

Status 

State

Status 

Federal 

Status Refuges 

Rhynchosia cinerea 

Brownhair 

snoutbean N KD 

Rhynchosia minima Least snoutbean N KD 

Rhynchosia parvifolia Small-leaf snoutbean N T KD 

Rhynchospora colorata Starrush whitetop N KD 

Rhynchospora divergens 

Spreading 

beaksedge N KD 

Rhynchospora floridensis Florida whitetop N KD 

Rhynchospora microcarpa Southern beaksedge N KD 

Ricinus communis II Castor-bean NN, NA KD 

Rivina humilis Rougeplant N KD, KW, GWH 

Roystonea regia 

Royal palm, Florida 

royal palm N E KW 

Ruellia ciliatiflora 

Hairyflower wild 

petunia NN, NA KD 

Ruellia succulenta 

Thickleaf wild 

petunia N KD 

Ruppia maritima Wigeon-grass N KD 

Sabal palmetto Cabbage palm N KD, KW 

Sabatia stellaris Rose-of-Plymouth N KD 

Saccharum officinarum Sugarcane NN, NA KD 

Sachsia polycephala Bahama sachsia N T KD 

Sagittaria lancifolia 

Bulltongue 

arrowhead, lanceleaved arrowhead 

N KD 

Salicornia bigelovii Annual glasswort N KD, GWH 

Salicornia perennis Perennial glasswort N KD, KW, GWH 

Salvia serotina Sage, Littlewoman N KW 

Samolus ebracteatus 

Water pimpernel, 

Limewater 

brookweed 

N KD 

Samolus valerandi subsp. 

parviflorus 

Pineland pimpernel, 

Seaside brookweed N KD 

Sansevieria hyacinthoides 

II

Bowstring-hemp, 

Mother-in-laws 

tongue 

NN, NA KD, KW, GWH 

Sarcostemma clausum 

Whitevine, White 

twinevine N KD, KW, GWH 

Savia bahamensis 

Maidenbush, 

Bahama maidenbush N E KD, GWH 
Appendices 239 

Scientific Name Common Name Native

Status 

IRC

Status 

State 

Status 

Federal 

Status Refuges 

Scaevola plumieri 

Inkberry, 

Beachberry, Gullfeed N T KW 

Scaevola sericea I Beach napuka NN, NA KW 

Schinus terebinthifolius I Brazilian-pepper NN, NA KD, KW, GWH 

Schizachyrium gracile Wire bluestem N KD, KW 

Schizachyrium 

rhizomatum 

Rhizomatous 

bluestem N KD 

Schizachyrium 

sanguineum Crimson bluestem N KD, KW 

Schoenus nigricans 

Black sedge, Black 

bogrush N KD 

Scleria lithosperma Florida Keys nutrush N E KD, KW 

Scleria verticillata Low nutrush N KD 

Scutellaria havanensis Havana skullcap N E KD 

Senna ligustrina 

Privet senna, Privet 

wild sensitive plant N KD 

Senna mexicana var. 

chapmanii 

Bahama senna, 

Chapman's wild 

sensitive plant 

N T KD 

Serenoa repens Saw palmetto N KD, KW 

Sesbania herbacea Danglepod N KD 

vSesbania sericea Silky sesban NN, NA KD 

Sesuvium maritimum 

Annual sea-purslane, 

Slender seapurslane N KD 

Sesuvium portulacastrum 

Perennial seapurslane, Shoreline 

seapurslane 

N KD, KW, GWH 

Setaria macrosperma 

Coastal foxtail, Coral 

bristlegrass N KD, KW, GWH 

Setaria magna Giant bristlegrass N KD 

Setaria parviflora 

Knotroot foxtail, 

Yellow bristlegrass N KD, KW 

Setaria pumila 

Yellow bristlegrass, 

Yellow foxtail NN, NA KD 

Sida abutifolia Spreading fanpetals N KD 

Sida acuta 

Common wireweed, 

Common fanpetals N KD, GWH 

Sida ciliaris 

Bracted fanpetals, 

Fringed fanpetals N KD, KW, GWH 

Sida elliottii Elliott's fanpetals N KD 
 Lower Florida Keys National Wildlife Refuges 240

Scientific Name Common Name Native

Status 

IRC

Status 

State

Status 

Federal 

Status Refuges 

Sida rhombifolia 

Cuban jute, Indian 

hemp N KD 

Sideroxylon celastrinum Saffronplum N KD, KW, GWH 

Sideroxylon reclinatum Recline Florida bully N KD 

Sideroxylon salicifolium 

Willow-bustic, White 

bully N KD, GWH 

Simarouba glauca Paradisetree N KD, KW, GWH 

Sisyrinchium 

angustifolium 

Narroleaf blueeyedgrass 

N KD 

Smilax auriculata Earleaf greenbrier N KD 

Smilax havanensis 

Havana greenbrier, 

Everglades 

greenbrier 

N T KD, KW, GWH 

Solanum americanum 

Common 

nightshade, 

American black 

nightshade 

N KD, GWH 

Solanum bahamense Bahama nightshade N KD, KW, GWH 

Solanum donianum Mullein nightshade N T KD, KW 

Solanum erianthum Potatotree N KD 

Solidago stricta 

Narrow-leaved 

goldenrod, Wand 

goldenrod 

N KD 

Sonchus oleraceus Common sowthistle NN, NA KD 

Sophora tomentosa var. 

truncata Yellow necklacepod N KD, KW 

Sorghastrum secundum 

Lopsided Indian 

grass 

N KD 

Spartina bakeri Sand cordgrass N KD 

Spartina patens 

Marshhay cordgrass, 

Saltmeadow 

cordgrass 

N KD, KW, GWH 

Spartina spartinae Gulf cordgrass N KD, KW 

Spermacoce floridana 

Florida false 

buttonweed N KD 

Spermacoce prostrata 

Prostrate false 

buttonweed N KD 

Spermacoce terminalis 

Everglades Keys 

false buttonweed N T KD 

Spermacoce tetraquetra 

Pineland false 

buttonweed N KD 
Appendices 241 

Scientific Name Common Name Native

Status 

IRC

Status 

State 

Status 

Federal 

Status Refuges 

Spermacoce verticillata 

Shrubby false 

buttonweed NN, NA KD 

Spigelia anthelmia West Indian pinkroot N KD 

Spiranthes torta 

Southern lady'stresses N CI E KD 

Sporobolus domingensis Coral dropseed N KD, KW, GWH 

Sporobolus indicus var. 

pyramidalis 

West Indian 

dropseed NN, NA KD 

Sporobolus virginicus Seashore dropseed N KD, KW, GWH 

Stachytarpheta 

jamaicensis 

Blue porterweed, 

Joee N KD 

Stenotaphrum 

secundatum St. Augustine grass NN, NA KD, GWH 

Strumpfia maritima Pride-of-Big-Pine N CI E KD 

Stylosanthes calcicola 

Everglades key 

pencilflower N E KD 

Stylosanthes hamata 

Pencilflower, 

Cheesytoes N KD 

Suaeda linearis 

Sea-blite, Annual 

seepweed N KD, KW, GWH 

Suriana maritima Baycedar N KD, KW, GWH 

Swietenia mahagoni 

West Indian 

mahogany N T KD 

Syringodium filiforme Manatee-grass N KD, KW, GWH 

Tamarindus indica Tamarind NN, NA KD, GWH 

Terminalia catappa II Tropical-almond, 

West Indian-almond NN, NA KD 

Thalassia testudinum Turtle-grass N KD, KW, GWH 

Thelypteris kunthii Southern shield fern N KD 

Thespesia populnea I Portiatree NN, NA KD, KW, GWH 

Thrinax morrisii 

Silver thatch palm, 

Brittle thatch palm N E KD, KW, GWH 

Thrinax radiata 

Green thatch palm, 

Florida thatch palm N E KD, KW, GWH 

Tillandsia balbisiana 

Reflexed wild-pine, 

Northern needleleaf N T KD 

Tillandsia fasciculata var. 

densispica 

Stiff-leaved wildpine, Cardinal 

airplant 

N E KD, GWH 

Tillandsia flexuosa 

Banded wild-pine, 

Twisted airplant N T KD, KW 
 Lower Florida Keys National Wildlife Refuges 242

Scientific Name Common Name Native

Status 

IRC

Status 

State

Status 

Federal 

Status Refuges 

Tillandsia paucifolia 

Twisted wild-pine, 

Potbelly airplant N KD, KW, GWH 

Tillandsia recurvata Ball-moss N KD 

Tillandsia usneoides Spanish-moss N KD 

Tillandsia utriculata 

Giant wild-pine, 

Giant airplant N E KD 

Tournefortia volubilis Twining soldierbush N KD 

Toxicodendron radicans Eastern poison-ivy N KD 

Tradescantia spathacea I Oysterplant, Mosesin-the-cradle, Boatlily NN, NA GWH 

Tragia saxicola 

Florida Keys 

noseburn N T KD 

Trema micranthum 

Florida trema, 

Nettletree N KD 

Trianthema 

portulacastrum 

Desert 

horsepurslane N KD 

Tribulus cistoides II

Punctureweed, 

Burrnut, Jamaican 

feverplant 

NN, NA KD 

Tridax procumbens 

Brittleweed, 

Coatbuttons NN, NA KD 

Tripsacum floridanum Florida gamagrass N T KD 

Turnera ulmifolia 

Yellow alder, 

Ramgoat dashalong NN, NA KD 

Typha domingensis Southern cat-tail N KD 

Uniola paniculata Sea-oats N KD, KW, GWH 

Urochloa adspersa 

Dominican 

signalgrass N KD 

Urochloa fasciculata var. 

reticulata 

Browntop 

signalgrass NN, NA KD 

Vallesia antillana 

Pearlberry, 

Tearshrub N CI E KD 

Vanilla barbellata Wormvine orchid N E KD 

Vernonia blodgettii Florida ironweed N KD 

Vigna luteola 

Cow-pea, Hairypod 

cowpea 

N KD 

Vitis rotundifolia 

Muscadine, 

Muscadine grape N KD 

Vittaria lineata Shoestring fern N KD 

Waltheria indica Sleepy morning N KD, KW, GWH 
Appendices 243 

Scientific Name Common Name Native

Status 

IRC

Status 

State 

Status 

Federal 

Status Refuges 

Washingtonia robusta II Desert palm, 

Washington fan palm 

Not Native, 

Naturalized KD 

Ximenia americana 

Hog-plum, 

Tallowwood N KD, KW, GWH 

Youngia japonica 

Rocketweed, Oriental 

false hawksbeard 

Not Native, 

Naturalized KD 

Yucca aloifolia 

Spanish-bayonet, 

Aloe yucca N KW 

Zanthoxylum fagara 

Wild-lime, Lime 

prickly-ash N KD 

Zanthoxylum flavum 

West Indian 

satinwood, 

Yellowwood 

N 

CI 

E KW 

Zeuxine strateumatica 

Soldier's orchid, 

Lawn orchid 

Not Native, 

Naturalized KD 
 Lower Florida Keys National Wildlife Refuges 244
Appendices 245 

Appendix J. Budget Requests 

Note - This section will be completed with the final CCP to include: 

Refuge Operating Needs System 

Maintenance Management Needs 
 Lower Florida Keys National Wildlife Refuges 246
Appendices 247 

Appendix K. List of Preparers

PLANNING TEAM 

The Comprehensive Conservation Plan Team (aka Planning Team) met regularly between August 

2006 and July 2007 and was comprised of the following staff, former staff and regional staff. Except 

as noted, all team members are based at Florida Keys NWR Complex headquarters: 

Mary Morris, Natural Resources Planner and Planning Team Leader, St. Marks NWR 

Anne Morkill, Project Leader 

Jim Wigginton, Deputy Project Leader 

Thomas Wilmers, Wildlife Biologist 

Lester Pulley, Zone Officer, former Lead Refuge Law Enforcement Officer 

Steven Berger, Law Enforcement Officer 

James Bell, Park Ranger/Visitor Services 

Paige Schmidt, Wildlife Biologist Trainee 

Phillip Hughes, Endangered Species Biologist, FWS Ecological Services 

Paul Stevko (Forestry Fire Technician, participated on CCP team during the fall of 2006). 

Mary Morris developed the document based on the input of the team, technical advisors, reviewers, 

and public comment. Primary contributors of text include Mary Morris, Thomas Wilmers, Paige 

Schmidt, James Bell, and Anne Morkill. Mary Morris edited the document through all drafts. Evelyn 

Nelson of the Regional Office will edit the Draft and Final CCP documents. 

BIOLOGICAL REVIEW 

A biological review was conducted in 2005. It consisted of Service and state employees and invited 

research experts. The team provided recommendations for management actions based on the most 

current knowledge of refuge resources. Members of the team included: 

Chuck Hunter, Chief, Division of Planning and Resource Management, FWS, Region 4 

Dean Demarest, former Assistant Migratory Birds Coordinator, FWS, Region 4 

Steve Earsom, former Regional Refuge Ecologist, FWS, Region 4 

Ken Meyer, Ph.D., Researcher, Avian Research and Conservation Institute, Gainesville, FL 

Phil Frank, Ph.D., former Project Leader, Florida Keys NWR Complex 

Steve Klett, Refuge Manager, Crocodile Lake NWR 

Van Fischer, former Natural Resources Planner, Florida Keys NWR Complex 

Randy Grau, Manager, Florida Keys Wildlife and Environmental Areas, Florida FWC 

Chris Bergh, Director, Florida Keys Program of The Nature Conservancy 

William Miller, former Deputy Refuge Manager, Florida Keys NWR Complex 

Tom Wilmers, Wildlife Biologist, Florida Keys NWR Complex 

Neil Perry, graduate student, TAMU 
 Lower Florida Keys National Wildlife Refuges 248

VISITOR SERVICES AND PUBLIC USE REVIEW 

A visitor services and public use review was conducted in 2003. The team consisted of staff from the 

Service’s Regional Office and current and former field staff: 

Garry Tucker, Visitor Services Coordinator, FWS, Region 4 

Dorn Whitmore, Assistant Refuge Manager, Merritt Island NWR 

Jane Whaley, former Park Ranger, Peidmont NWR 

James Bell, Park Ranger/Visitor Services, Florida Keys NWR Complex 

Phil Frank, Ph.D., former Project Leader, Florida Keys NWR Complex 

Van Fischer, former Natural Resources Planner, Florida Keys NWR Complex 

WILDERNESS REVIEW 

A review of the refuges’ wilderness areas and potential wilderness study areas was conducted by the 

CCP planning team on August 21, 2006 and included the following team members: 

Mary Morris, Natural Resources Planner, Region 4, St. Marks NWR 

Anne Morkill, Project Leader, Florida Keys NWR Complex 

Lester Pulley, Zone Officer, former Lead Refuge Law Enforcement Officer, Florida Keys NWR 

Complex 

James Bell, Park Ranger/Visitor Services, Florida Keys NWR Complex 

Thomas Wilmers, Wildlife Biologist, Florida Keys NWR Complex 

Paige Schmidt, Wildlife Biologist Trainee, Florida Keys NWR Complex 

FIRE MANAGEMENT PROGRAM REVIEW 

In February 2007 an interagency team was convened to discuss the Services’ fire management 

program for NKDR. The following persons attended: 

Thomas Wilmers, Wildlife Biologist, Florida Keys NWR Complex 

David Brownlie, Regional Fire Ecologist, FWS, Region 4 - Tallahassee 

Kathy O’Reilly-Doyle, Partners for Fish and Wildlife, FWS, Florida Panther NWR 

Jim Durwachter, former Fire Management Officer, FWS 

Jon Wallace, Prescribed Fire Specialist, FWS, Loxahatchee NWR 

Josh O’Conner, Forestry Fire Technician, FWS, Florida Panther NWR 

Mary Morris, Natural Resources Planner, St. Marks NWR 

Anne Morkill, Project Leader, Florida Keys NWR Complex 

Paige Schmidt, Wildlife Biologist Trainee, Florida Keys NWR Complex 

Phillip Hughes, Endangered Species Biologist, FWS, Ecological Services Office 
Appendices 249 

Appendix L. List of Partnerships 

Existing Partnerships 

Federal Agencies: 

Federal Protective Service – U.S. Marshal’s Service 

National Oceanic and Atmospheric Administration (NOAA) 

 Florida Keys National Marine Sanctuary (FKNMS) and Eco-Discovery Center 

National Marine Fisheries Service 

National Wildlife Health Center 

United State Coast Guard 

United States Coast Guard Auxiliary 

United States Department of Agriculture 

 Animal and Plant Health Inspection Service, Wildlife Services 

 Forest Service 

United States Department of Defense 

 Naval Air Station Key West 

 Army Corps of Engineers 

United States Department of Homeland Security 

 Immigration and Customs Enforcement 

 United States Coast Guard, Key West Sector 

 United States Coast Guard Auxilliary 

United States Customs and Border Protection 

United States Department of Interior 

 National Park Service – Everglades, Biscayne Bay, and Dry Tortugas National Parks 

– Archaeological Center 

United States Geological Survey 

 Florida Integrated Science Center 

State Agencies: 

Florida Department of Agriculture 

 Division of Forestry 

Florida Department of Environmental Protection (DEP) 

 Division of State Lands 

 Bureau of Invasive Plant Management 

Division of Parks and Recreation 

Florida Park Service 

Florida Department of Highway Safety and Motor Vehicles 

Florida Highway Patrol 

Florida Department of Transportation 

Florida Fish and Wildlife Conservation Commission (FWC) 

 Division of Habitat and Species Conservation 

 Division of Law Enforcement 

 Wildlife and Environmental Areas 

South Florida Water Management District (Regional Office) 
 Lower Florida Keys National Wildlife Refuges 250

Local Government Agencies: 

Monroe County 

 Department of Marine Resources 

 Department of Planning and Environmental Services 

 Division of Community Services (Animal Control) 

 Land Authority 

 Mosquito Control District 

 Sheriff’s Office 

Regional Agencies, Events or Programs: 

Earth Day, Bahia Honda State Park 

Florida Keys Birding and Wildlife Festival, Inc. 

Florida Keys Exotic Species Task Force 

Florida Keys Scenic Highway 

Other Organizations and Academia: 

Avian Research and Conservation Institute 

Dolphin Research Center 

Fairchild Tropical Botanic Garden 

Florida Keys Exotic Species Task Force 

Florida Keys National Marine Sanctuary Advisory Council 

Florida Keys National Marine Sanctuary Water Quality Protection Program Steering Committee 

Florida International University 

Friends and Volunteer of Refuges (FAVOR) 

Institute for Regional Conservation 

Inwater Research Group 

Key Deer Protective Alliance 

Key West Tropical Forest and Botanical Garden 

Lower Keys Wildfire Hazard Reduction Initiative 

Monroe County Environmental Education Advisory Council 

National Audubon Society 

Coral Reef Initiative 

 Keys Environmental Restoration Fund 

 Tavenier Science Center 

Florida Keys Chapter of National Audubon Society 

Seagrass Outreach Partnership 

Southeast Cooperative Wildlife Disease Study (SECDS) 

South Florida Ecosystem Restoration Task Force Land Acquisition Task Team 

South Florida Pine Rockland Working Group 

Texas Agricultural and Mechanical University 

Texas State University, San Marcos 

The Nature Conservancy 

University of Georgia, SECDS 

University of Tennessee 
Appendices 251 

Potential Partnerships 

Ducks Unlimited 

Green Living Environmental Expo 

National Association for Interpretation 

North American Association of Environmental Educators (NAAEE) 

Reef Relief