Final Programmatic Environmental Assessment -Appendices Wastewater Management Improvements in the Florida Keys, Florida Prepared For The Federal Emergency Management Agency Region IV 3003 Chamblee-Tucker Rd. Atlanta, GA 30341 Prepared By URS Group, Inc. 200 Orchard Ridge Drive, Suite 101 Gaithersburg, MD 20878 700 South Royal Poinciana Blvd. Suite 1000 Miami Springs, FL 33166 December 23, 2002 Appendix A Acronyms Appendix A List of Acronyms ABF Anoxic biofilter AIDS Acquired Immune Deficiency Syndrome AIRFA American Indian Religious Freedom Act ARPA Archaeological Resources Protection Act ASTM American Society of Testing and Materials ATU Aerobic Treatment Units AWT Advanced Wastewater Treatment levels BAT Best Available Technology BFE Base flood elevation BMPs Best management practices BOCC Board of County Commissioners BOD Biochemical oxygen demand BP Before present BPAS Building Permit Allocation System CARL Conservation and Recreation Lands CATEX Categorical Exclusion CBRA Coastal Barrier Resources Act CBRS Coastal Barrier Resource System CEQ Council on Environmental Quality CERP Comprehensive Everglades Restoration Plan CES Key West City Electric Services CFCRS Continuous Feed Cyclic Reactor System CFR Code of Federal Regulations CFV Commercial Fishing Village CIEGP Cesspit Identification and Elimination Grant Program CO Carbon monoxide CPU Chemical precipitation unit CWA Clean Water Act CZMA Coastal Zone Management Act dBA Decibel DCA Department of Community Affairs EA Environmental Assessment I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ A-1 Appendix A List of Acronyms EDU Equivalent Dwelling Unit EFH Essential Fish Habitat EIS Environmental Impact Statement EO Executive Order EPA U.S. Environmental Protection Agency ERP Environmental Resource Permit ESA Endangered Species Act F.A.C. Florida Administrative Code FAST Fixed Activated Sludge Treatment FDEP Florida Department of Environmental Protection FDH Florida Department of Health FDOT Florida Department of Transportation FEMA Federal Emergency Management Agency FKAA Florida Keys Aqueduct Authority FKEC Florida Keys Electric Cooperative FKNMS Florida Keys National Marine Sanctuary F.L. Florida Law FMSF Florida Master Site File FPSC Florida Public Service Commission GIS Geographical Information System GMFMC Gulf of Mexico Fishery Management Council gpd Gallons per day Ha Hectares HHS Department of Health and Human Services HUD U.S. Department of Housing and Urban Development Hz Hertz IMB Immersed Membrane Bioreactor IS Improved Subdivision Ldn Day-Night Sound Level LOS Levels of Service M.C.C. Monroe County Code MCSWMP Monroe County Sanitary Wastewater Master Plan I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ A-2 Appendix A List of Acronyms MFI Median family income Mgal Million gallons mgd Million gallons per day µg/m3 Micrograms per cubic meter MHI Median household income MOU Memorandum of understanding MSA Magnuson-Stevens Fishery Conservation and Management Act NAAQS National Ambient Air Quality Standards NAGPRA Native American Graves Protection and Repatriation Act NEPA National Environmental Policy Act of 1969 NGVD National Geodetic Vertical Datum NHPA National Historical Preservation Act NMFS National Marine Fisheries Service NO2 Nitrogen dioxide NO3 Nitrate NOAA National Oceanic and Atmospheric Administration NOI Notice of Intent NPDES National Pollution Discharge Elimination System NRHP National Register of Historic Places O&M Operations and Maintenance O3 Ozone OFW Outstanding Florida Waters OSHA Occupational Safety and Health Administration OSTDS On-site sewage treatment and disposal system OWNRS On-site wastewater nutrient reduction systems OWTS On-site wastewater treatment systems PATA Key West Port and Transit Authority Pb Lead PEA Programmatic Environmental Assessment PM 10 Particulate matter less than 10 microns ppm Parts per million RBC Rotating Biological Contactor I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ A-3 Appendix A List of Acronyms RCRA Resource Conservation and Recovery Act ROGO Rate of Growth Ordinance RSF Recirculating sand filter SAFMC South Atlantic Fishery Management Council SDGS Small diameter gravity sewers SDI Subsurface Drip Irrigation system SEA Supplemental Environmental Assessment SER Supplemental Environmental Review SFWMD South Florida Water Management District SMMP Stormwater Management Master Plan SO2 Sulfur dioxide STEP Septic tank effluent pump SWMP TAC Sanitary Wastewater Master Plan Technical Advisory Committee THM Trihalomethane TN Total nitrogen TON Total organic nitrogen TP Total phosphorus TSS Total Suspended Solids TTHM Total trihalomethane UIC Underground Injection Control URM Urban Residential Mobile Home USACE U.S. Army Corps of Engineers USDW Underground source of drinking water USFWS U.S. Fish and Wildlife Service USGS U.S. Geological Survey UV Ultraviolet WQPP Water Quality Protection Program WWTP Wastewater Treatment Plants I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ A-4 Appendix B Definitions Appendix B Definitions Abandonment costs – These include the expenses associated with removal and disposal of an existing wastewater treatment system. Adsorption – Adhesion of molecules of gases or of ions or molecules to the surfaces of solid bodies with which they are in contact. Advanced Wastewater Treatment (AWT) – Also known as tertiary treatment, AWT follows Secondary Treatment. Removal of soluble nitrogen and phosphorus compounds is a common application of AWT. AWT may involve chemical addition, filtration, or activated carbon processes. As referred to in the MCSWMP, effluent treated to AWT standards meets 5 mg/L BOD, 5 mg/L TSS, 3 mg/L TN, and 1 mg/L TP. Anthropogenic – Relating to humans and their impact on the natural environment Belt Filter Press Dewatering – A process used to remove water from sludge thereby producing dewatered biosolids that contain equal to or greater than 20% dry solids. Benthic Algae – Algae relating to the bottom of a water body. Best Available Technology (BAT) – The level to which wastewater treatment systems are designed. As referred to in the MCSWMP effluent treated to BAT standards that 10 mg/L BOD, 10 mg/L TSS, 10 mg/L TN, and 1 mg/L TP. Best Management Practices (BMP) – A set of minimum practices developed and implemented to improve the physical, chemical, and biological integrity of the nation’s waters. Examples include installation of silt fencing at a construction site to prevent eroded soils from entering a nearby waterway. Biochemical Oxygen Demand/Biological Oxygen Demand (BOD) – The oxygen that is needed and used by aerobic organisms living in water that is rich in organic material (such as waters polluted by sewage). Boulder Zone – A very permeable, cavernous zone in the lower Floridian Aquifer System that is about 2800 to 3300 feet below ground surface. Calcareous – Containing calcium carbonate. As applied to rock, the predominant percentage of the rock is calcium carbonate. Cesspool/Cesspit – An unregulated and unpermitted effluent disposal method that consists of an excavated area (100 to 1000 cubic feet, 4 to 8 feet deep) into the ground surface. The area is covered with a slab of concrete, and untreated sewage is then deposited into the pit. Liquid wastes are discharged through the porous limestone formations and ultimately to the nearshore areas. Solid wastes are retained in the pit, which is often abandoned after it becomes full. Class B Lime Stabilization – The process used to reduce harmful bacteria and odors in sludge or biosolids. Lime is added to untreated sludge in sufficient quantity to raise the pH to 12 or higher. The high pH creates an environment that is not conducive to the survival of microorganisms. Class B Lime Stabilization refers to the EPA classification for the safe treatment, beneficial use, and disposal of biosolids that contain pathogen concentrations levels low enough for some beneficial uses, such as land application with restrictions. Class I Injection Well – The first of five well classifications developed by the U.S. Environmental Protection Agency under their underground disposal control program to categorize the injection of various types of liquid wastes. Class I wells are typically used by I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ B-1 Appendix B Definitions hazardous waste generators and operators, as well as industrial and municipal disposal systems, to inject fluids into a geologic formation that is beneath the lower-most formation containing an underground source of drinking water within ¼ mile of the well bore. A Class I Well must meet siting, construction, operation, and maintenance criteria specific to this well class, as established by the U.S. Environmental Protection Agency and the Florida State regulating agency. Class V Injection Well – Similar to a Class I Injection Well, the U.S. Environmental Protection Agency established this well category for a broad range of specialty applications to dispose liquid wastes, which are not categorized under the other four injection well classes. For example, a Class V well could be used to drain stormwater runoff into an aquifer. Cluster System (of OWNRS) – An OWNRS that serves multiple homes. Clusters can be composed of small groups (such as 2 homes), which share one treatment system, or of large groups (50 homes), which use low-pressure sewers to connect the cluster to a centralized OWNRS. Effluent – The waste stream from a wastewater treatment system collection unit. Enteric – Relating to the intestines. Over 100 different human enteric pathogens, including viruses, parasites, and bacteria may be found in municipal wastewater and surface runoff. Enterococci – A bacterium whose presence indicates Fecal Coliform. Environmental Impact Statement (EIS) – A public document prepared pursuant to NEPA containing a detailed analysis and evaluation of all the impacts of a proposed major federal action and all its reasonable alternatives that has the potential to significantly affect the quality of the human environment. This is a more rigorous analysis than an Environmental Assessment and provides for formal public involvement. Epiphyte – A plant growing on another plant but getting little nutrition from its host. Equivalent Dwelling Unit (EDU) – A household of 2.3 persons generating about 168 gallons of effluent per day. Eutrophication – The process by which a body of water becomes nutrient-rich and oxygen- deficient. Executive Order (EO) – A Presidential mandate that directs a federal agency to consider certain issues as an agency plans their actions. For example, former President Jimmy Carter directed all agencies to “minimize the destruction and loss or degradation of wetlands” under EO 11990, “Protection of Wetlands.” Fecal Coliform – A bacterium used as an indicator of total sewage biological contamination. Florida Statutory Treatment Standards – Quality standards for discharged wastewater effluent as promulgated in F.A.C. 99-395. Treated effluent generated by sewage facilities with design capacities greater than 100,000 gpd must meet 5 mg/L TP. Sewage facilities with design capacities less than 100,000 gpd must meet 10 mg/L BOD, 10 mg/L TSS, 10 mg/L TN, and 1 mg/L TP. On-site sewage treatment and disposal systems must meet 10 mg/L BOD, 10 mg/L TSS, 10 mg/L TN, and 1 mg/L TP. Hydraulic Communication – Water movement from one area to another (such as from the Boulder Zone to the ocean). Hydraulic Conductivity – An aquifer’s water transmission rate; similar to transmissivity. I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ B-2 Appendix B Definitions Hydraulic Head – The driving force influencing groundwater movement, water’s total energy at a given location. Injection Well (shallow and deep) – An underground well designed to pump treated effluent (or other materials) into shallow (e.g., 90 feet) or deep (e.g., 2,100 feet) geologic locations. Injection wells are designed to account for physical and chemical characteristics of the injection matrix, and require monitoring to ensure mechanical integrity of the well. Lateral costs – These include the expenses associated with installing wastewater piping on the service recipient’s property for connection to the conveyance piping in the street for a new wastewater system. Lithologic – A rock’s descriptive characteristics, including color, structure, mineral composition, and grain size. Median Family Income (MFI) – as defined by the U.S. Census Bureau, refers to the income of a family where a family is defined as two or more people (one of whom is the householder) related by birth, marriage, or adoption residing in the same housing unit. Median Household Income (MHI) – as defined by the U.S. Census Bureau, refers to the income of a household where a household is defined as all people who occupy a housing unit regardless of relationship. A household may consist of a person living alone or multiple unrelated individuals or families living together. Microkarst – Karst features on the scale of millimeters. Karst is a type of landform developed over limestone, dolomite, or gypsum through solution of the rock, typified by closed depressions, caves, and underground drainages. National Environmental Policy Act (NEPA) – A congressional act established in 1969 that directs all federal agencies to consider the environmental effects of their programs, projects, and funding decisions. NEPA considers the effects on all resources of natural and built environments and includes compliance requirements with all other applicable federal laws, such as the Endangered Species Act and the Environmental Justice Executive Order. Norwalk Virus - Norwalk viruses (and related caliciviruses) are important causes of sporadic and epidemic gastrointestinal disease in the United States, and have typically been associated with eating contaminated shellfish. Water and ice are other sources of infection. Symptoms of Norwalk virus infection include nausea, vomiting, diarrhea, headache, low-grade fever, and abdominal cramps. Persons with this infection usually recover within 2-3 days without serious or long-term health effects. Oligotrophic – A body of water that is nutrient-poor. On-Site Wastewater Nutrient Reduction System (OWNRS) – An on-site wastewater treatment system that meets a minimum level of BAT treatment, or 10 mg/L BOD, 10 mg/L TSS, 10 mg/L TN, and 1 mg/L TP. On-Site Wastewater Treatment System (OWTS) – Any of several wastewater treatment types that are located on the property they serve. Examples include septic systems, cesspools, aerobic treatment units (ATU), and On-Site Wastewater Nutrient Reduction Systems (OWNRS). Oolites – Rocks consisting mostly of small, spherical calcium carbonate grains. I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ B-3 Appendix B Definitions Operation and maintenance (O&M) costs – These include the monthly or annual costs incurred by service recipients for long-term operation and maintenance of the wastewater management system. Permeability – The capacity of porous material to transmit water or other fluid. In bedded sediments, horizontal permeability is measured parallel to the bedding direction, and vertical permeability is measured transverse to the bedding. Phytoplankton -Plant plankton, which float or weakly swim, are often microscopic (e.g., many algae species), and are the primary food source in most aquatic and marine ecosystems. Primary Treatment – The first level of wastewater treatment that removes solids, greases, oils and other floatable solids from the waste stream, partially clarifying the effluent. Suspended solids, dissolved organic materials, and other pollutants are not removed from the effluent. Programmatic Environmental Assessment (PEA) – A concise public document prepared pursuant to NEPA. It contains sufficient analysis to determine the likely significance of a group of similar proposed actions (projects) and alternatives’ impacts, to aid decision making as to whether or not to prepare an EIS. A project- and site-specific effects evaluation document supplements the PEA, generically called a Supplemental Environmental Review (SER), (described below). Secondary Treatment – Used in concert with Primary Treatment. This second level of treatment removes dissolved organic materials and more suspended solids, however nutrients such as nitrogen and phosphorus remain in the effluent. Septic Tank – An OWTS using a tank and drainfield to capture waste, separate solids from liquids, and drain liquid to adjacent soils. Significantly – In the NEPA context, this term is used to describe both the context and intensity (severity) of impacts. For a detailed description of this term, see Section 1508.27 of the President’s Council on Environmental Quality’s regulations implementing NEPA. Slurry – Mixture of coarsely ground solids and liquid. Specific Gravity – Ratio of a given mass to the mass of an equal volume of water at a specified temperature. Subsurface Drip Irrigation (SDI) – A form of clarified effluent disposal with discharge into soils via subsurface piping. Supplemental Environmental Assessment (SEA) – A secondary NEPA public document that references relevant data presented in the PEA and presents site- and project- specific details and evaluation of effects. Supplemental Environmental Review (SER) – A generic phrase used herein for referencing the site- and project-specific NEPA document that would be prepared following issuance of a final PEA. This document would be either an SEA or EIS depending on the significance of the specific project impacts. System capital costs – These include expenses associated with planning, designing, engineering, purchasing, building, and installing a wastewater treatment system, and its wastewater conveyance piping in public right-of-ways and selected effluent disposal method (e.g., injection wells, SDI, reuse). I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ B-4 Appendix B Definitions Total Nitrogen/Nitrogen (TN/N) – Nitrogen is a common element found in nature and in wastewater. Nitrogen is an essential nutrient for plants, but contributes to water body eutrophication when more abundant. “Total nitrogen” describes nitrogen in four oxidation states: organic nitrogen, ammonia nitrogen, nitrite nitrogen, and nitrate nitrogen. Removal or reduction of TN from wastewater effluent involves nitrification (where organic N and ammonia N are converted to nitrite N, which easily converts to nitrate N) and denitrification (where nitrate N is converted to nitrogen gas). Total Phosphorus/Phosphorus (TP/P) – Phosphorus is a natural element, however most phosphorus enters waterways via human activities (i.e., untreated wastewater or fertilizer runoff). Similar to nitrogen, phosphorus is an essential nutrient for plants, but eutrophication occurs when phosphorus is more abundant. “Total phosphorus” is in organic and inorganic forms and can occur in solution, particles, or micro-organisms (such as polyphosphates, which account for 70% of wastewater phosphorus). TP removal or reduction from wastewater effluent typically involves biological treatment (to convert P to the orthophosphate forms), which are then removed via chemical processes. Total Suspended Solids (TSS) – TSS are solids in water, such as silt, decaying plant and animal matter, and sewage, that can be trapped by a filter. High concentrations of suspended solids can cause many problems for water body health and aquatic life. For example, high TSS can block light from reaching submerged vegetation. Transmissivity – An aquifer’s ability to transmit water, proportional to the aquifer’s saturated thickness; similar to Hydraulic Conductivity. Turbidity – A measure of the water clearness as a function of suspended sediment. Vector Attraction Reduction – Decreasing the characteristic of sewage sludge that attracts rodents, flies, mosquitoes or other organisms that transmit infectious agents. Wastewater Treatment Plant (WWTP) – An effluent collection, treatment, and disposal system that collects waste from homes and businesses, and transports collected waste through a series of sewers to a centralized treatment plant. Physical, chemical, and biological processes clarify the effluent at the WWTP so that the treated water can be safely released into the environment via water reuse, deep or shallow well injection, or other permitted methods. I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ B-5 Appendix C Hot Spot Locations Appendix C Hot Spot Locations I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ C-1 Appendix C Hot Spot Locations I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ C-2 Appendix D Water Quality Improvement Analysis Appendix D Water Quality Improvement Analysis Comparison of Nutrient Contributors from Islamorada Service Area to Groundwater and Marine Waters under Present Conditions versus Wastewater Systems that Meet AWT Standards for Effluent Disposal (5 mg/L BOD, 5 mg/L TSS, 3 mg/L TN, 1 mg/L TP) Sources of Information: 1. Average daily flow (gpd): Islamorada (2001a) Design/Build/Operate Wastewater Management System(s), Islamorada, Village of Islands. 2. Raw sewage nutrient concentration: Ayres Associates (1998). 3. Nutrient removal by septic systems (TN 4%, TP 15%) Kruczynski (1999, Table 7). 4. Removal of TP from groundwater by chemical reaction with aquifer limestone Kruczynski (1999, p. 22) 5. Removal efficiency of AWT for TN, TP Islamorada (2001a, p. 18), and disposal of AWT effluent to Class V shallow wells Islamorada (2001a, p. 26). Assumptions: 1. Currently all sewage disposal is by onsite septic systems; no cesspit/cesspool systems; and inflows total – AWT system average daily flow. 2. TP is not removed from groundwater by reaction with aquifer limestones. This is a conservative assumption. 3. Raw sewage nutrient concentrations are the same as Big Pine field experiments (Ayres Associates, 1998, p. 5-1). Calculations: 1. Total wastewater flow = 911,000 gpd x 3.785 gal/L = 3,448,135 L/d 2. Total nutrient loading in raw sewage: TN = 38.4 mg/L x 3,488,135 = 132,408 mg/day x .002204 = 292 lbs/day TP = 8.39 mg/L x 3,448,135 = 28,930 mg/day x .002204 = 64 lbs/day I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ D-1 Appendix D Water Quality Improvement Analysis 3. Reduction of nutrients by septic systems: TN TP Raw Sewage 292 lbs/d 64 lbs/d Septic System Removal 4% 15% Septic System Effluent GW Removal 280 lbs/d 0% 54 lbs/d 0% To Seawater 280 lbs/d 54 lbs/d 4. Reduction of nutrients by AWT system: Raw Sewage Effluent Concentration TN 292 lbs/d 3 mg/L x 3,448,135 L/d = 10,344 gm/d x .002204 lbs/gm = 22.8 lbs/day TP 64 lbs/d 1 mg/L x 3448,135 L/d = 3,448 gm/d x .00224 lbs/gm = 7.6 lbs/day 5. Reduction of nutrients in groundwater transit to marine discharge from AWT: Septic System Loading Removal Efficiency To Seawater TN 22.8 lbs/day 0% 22.8 lbs/day TP 7.6 lbs/day 0% 7.6 lbs/day Conclusion: Replacement of existing OWTS (assumed all septic systems) with wastewater management systems that meet AWT treatment standards would result in 92% reduction in TN input to groundwater (280 lbs/day to 22.8 lbs/day), and 86% reduction in TP input to groundwater (54 lbs/day to 7.6 lbs/day). In groundwater transit to discharge to the sea negligible TN reduction occurs, and it is assumed here that no TP is removed by chemical reaction with carbonate rocks of aquifer. Thus, benefit of AWT systems in terms of nutrient removal would be in form of 92% reduction in TN; and an 86% removal of TP. I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ D-2 Appendix E Applicable Permit Information Appendix E Applicable Permit Information I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ E-1 1. Forms needed for Injection Well Permits: ADMINISTERING AGENCY FORM TITLE FORM # FDEP Application to Construct/Operate/Abandon Class I, III, or V Injection well Systems 62-528.900(1) FDEP Certification of Plugging Completion Class I, III, or V Well 62-528.900(2) FDEP Construction/Clearance Permit Application for Class V Well 62-528.900(3) FDEP Certification of Class V Well Construction Completion 62-528.900(4) FDEP Authorization for Class V Well Use 62-528.900(5) FDEP Application for Class V Well Plugging and Abandonment Permit 62-528.900(6) FDEP General Permit Form for Closed-Loop Air Conditioning Return Flow Class V Injection well 62-528.900(7) FDEP Notification to the Florida Department of Environmental Protection of Class V Well Ownership 62-528.900(8) FDEP Certification of Monitor Well Completion 62-528.900(10) 2. Forms needed for Collection System Permits: ADMINISTERING AGENCY FORM TITLE FORM # FDEP Application to Construct Domestic Wastewater Collection/Transmission System 62-604.300(7)(a) FDEP Domestic Wastewater Collection/Transmission Systems Certification of Completion of Construction 62-604.300(7)(b) FDEP Notice of Intent to Use General Permit for Wastewater Collection/Transmission System 62-604.300(7)(c) Appendix E Applicable Permit Information I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ E-2 3. Forms needed for Wastewater Rinse Permits: ADMINISTERING AGENCY FORM TITLE FORM # FDEP Notice of Intent to Use General Permit For Addition of a Major User of Reclaimed Water 62-610.300(4)(a)1 FDEP Annual Reclaimed Water Utilization Report 62-610.300(4)(a)2 FDEP Application for Permission To Place A Public Access Reuse System In Operation 62-610.300(4)(a)3 FDEP Wastewater Permit Application – Form 1 General Information 62-620.910(1) FDEP Reclaimed Water of Effluent Analysis Report 62-620.910(15) 4. Forms needed for Treatment Plant Construction & Operation Permits: ADMINISTERING AGENCY FORM TITLE FORM # FDEP Application for a Domestic Wastewater Facility Permit -Form 2A 62-620.910(2) FDEP Discharge Monitoring Report 62-620.910(10) FDEP Notification of Completion of Construction for Wastewater Facilities 62-620.910(12) FDEP Notification of Availability of Record Drawings and Final Operation and Maintenance Manuals 62-620.910(13) FDEP (Application For Permit to Operate a Non- Discharge/Closed Loop Recycle System Form 2CR14) 62-620.910 FDEP Dedicated Disposal Site Plan 62-640.210(2) (b) FDEP Standard Domestic Wastewater Residuals Record Keeping Form 62-640.210(2) (c) 5. Forms needed for Stormwater Permits: ADMINISTERING AGENCY FORM TITLE FORM # FDEP Discharge Monitoring Report 62-620.910(10) Appendix E Applicable Permit Information I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ E-3 6. Forms needed for Onsite Sewage Treatment and Disposal Systems ADMINISTERING AGENCY FORM TITLE FORM # FDH Innovative OSTDS Temporary Permit Application DH 3143 FDH Homeowner Acknowledgement of Installation of Innovative OSTDS DH 3144 FDH Innovative OSTDS Review Information DH 3145 FDH Application for Onsite Sewage Treatment and Disposal System Construction Permit - Application DH 4015 Page 1 FDH Application for Onsite Sewage Treatment and Disposal System Construction Permit – Site Plan DH 4015 Page 2 FDH Site Evaluation and System Specifications DH 4015 Page 3 FDH Existing System and System Repair Evaluation Dh 4015 Page 4 FDH Construction Permit DH 4016 Page 1 FDH System Repair Certification DH4016 Page 3 FDH Application for Onsite Sewage Treatment and Disposal System Operating Permit (includes DH 4081A – Assessment of Waste Handling and Business Activities DH 4081 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species Appendix F Federally and State-Listed Species in Monroe County and Fishery Species Federally Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency2 Habitat Likelihood of occurrence in Florida Keys 3 TERRESTRIAL MAMMALS Key Largo woodrat Neotoma floridana smalli E USFWS Tropical hardwood hammock Likely Key deer Odocoileus virginianus clavium E USFWS Tropical hardwood hammock, Mesic temperate hammock, Pine rockland, Mesic pine flatwoods, Hydric pine flatwoods, Freshwater marsh, Mangrove, Saltmarsh Likely Lower Keys silver rice rat (=silver rice rat) Oryzomys palustris natator(=O. argentatus) E (CH) USFWS Freshwater marsh, Mangrove, Saltmarsh Likely Key Largo cotton mouse Peromyscus gossypinus allapaticola E USFWS Tropical hardwood hammock Likely Florida panther Puma (=Felis) concolor coryi E USFWS High pine, Tropical hardwood hammock, Scrub, Maritime hammock, Mesic temperate hammock, Pine rockland, Scrubby flatwoods, Mesic pine flatwoods, Hydric pine flatwoods, Dry prairie, Wet prairie, Freshwater marsh, Seepage swamp, Pond swamp, Mangrove Not Likely Lower Keys marsh rabbit Sylvilagus palustris hefneri E USFWS Beach dune/Coastal strand, Freshwater marsh, Mangrove, Saltmarsh Likely Florida black bear Ursus americana floridanus C USFWS High pine, Tropical hardwood hammock, Scrub, Maritime hammock, Mesic temperate hammock, Pine rockland, Scrubby flatwoods, Mesic pine flatwoods, Hydric pine flatwoods, Dry prairie, Wet prairie, Freshwater marsh, Seepage swamp, Pond swamp, Mangrove Not Likely I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-1 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species Federally Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency2 Habitat Likelihood of occurrence in Florida Keys 3 MARINE MAMMALS West Indian manatee Trichechus manatus E (CH) USFWS/NMFS Mangrove, Seagrass, Nearshore reef Likely blue whale Balaenoptera musculus E NMFS Offshore marine Not Likely finback whale Balaenoptera physalus E NMFS Offshore marine Not Likely humpback whale Megaptera novaeangliae E NMFS Offshore marine Not Likely right whale Eubalaena glacialis E NMFS Offshore marine Not Likely Sei whale Balaenoptera borealis E NMFS Offshore marine Not Likely sperm whale Physeter macrocephalus E NMFS Offshore marine Not Likely FISH Alabama shad Alosa alabamae C NMFS Large flowing rivers Not Likely shortnose sturgeon Acipenser brevirostrum E NMFS Coastal rivers Not Likely Gulf sturgeon Acipenser oxyrhynchus desotoi C NMFS Coastal rivers and offshore marine waters Possible Atlantic sturgeon Acipenser oxyrhynchus oxyrhynchus C NMFS Coastal rivers, estuarine waters Not Likely dusky shark Carcharhinus obscurus C NMFS Coastal surf zone to offshore marine Likely I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-2 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species Federally Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency2 Habitat Likelihood of occurrence in Florida Keys 3 night shark Carcharinus signatus C NMFS Deep offshore marine Likely speckled hind Epinephelus drummondhayi C NMFS Hard bottom reefs Likely jewfish / goliath grouper Epinephelus itajara C NMFS Nearshore reefs to shallow offshore waters Possible Warsaw grouper Epinephelus nigritus C NMFS Deepwater reefs Possible Nassau grouper Epinephelus striatus C NMFS Nearshore reefs Likely saltmarsh topminnow Fundulus jenkensi C NMFS Saltmarsh and brackish water Likely Key silverside Menidia conchorum C NMFS Isolated lagoons; shallow, protected waters Likely opposum pipefish Microphis brachyurus lineatus C NMFS Freshwater associated with panic grass and smart weed Likely sand tiger shark Odontaspis taurus C NMFS Nearshore and offshore marine Likely smalltooth sawfish Pristis pectinata C NMFS Shallow coastal waters Possible mangrove rivulus Rivulus marmoratus C NMFS Land-crab burrows, mangrove forests, mosquito ditches Likely BIRDS Cape Sable seaside sparrow Ammodramus(=Am mospiza) maritimus mirabilis E (CH) USFWS Wet prairie, Freshwater marsh Possible piping plover Charadrius melodus T USFWS Beach dune/Coastal strand, Nearshore reef Likely Kirtland's warbler Dendroica kirtlandii E USFWS Upland pine, mesic hammock, rockland hammock, xeric scrub Not Likely I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-3 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species Federally Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency2 Habitat Likelihood of occurrence in Florida Keys 3 peregrine falcon Falco peregrinus E USFWS Disturbed/Cultivated land, Freshwater marsh, Saltmarsh., Prairie, Ponds/Lakes, Streams/Rivers, Swamp Possible bald eagle Haliaeetus leucocephalus T USFWS High pine, Scrubby high pine, Maritime hammock, Mesic temperate hammock, Pine rockland, Scrubby flatwoods, Mesic pine flatwoods, Hydric pine flatwoods, Dry prairie, Wet prairie, Freshwater marsh, Seepage swamp, Flowing water swamp, Pond swamp, Mangrove, Saltmarsh, Seagrass Possible wood stork Mycteria americana E USFWS Hydric pine flatwoods, Wet prairie, Freshwater marsh, Seepage swamp, Flowing water swamp, Pond swamp, Mangrove, Saltmarsh, Seagrass Possible red-cockaded woodpecker Picoides (= Dendrocopos) borealis E USFWS High pine, Mesic pine flatwoods, Hydric pine flatwoods Not Likely Audubon's crested caracara Polyborus plancus audubonii T USFWS Mesic temperate hammock, Mesic pine flatwoods, Hydric pine flatwoods, Dry prairie, Wet prairie Possible Everglade snail kite Rostrhamus sociabilis plumbeus E (CH) USFWS Hydric pine flatwoods, Freshwater marsh, Pond swamp Possible roseate tern Sterna dougallii dougallii T USFWS Beach dune/Coastal strand, Saltmarsh, Seagrass, Nearshore reef Likely REPTILES American alligator Alligator mississippiensis T (S/A) USFWS Hydric pine flatwoods, Wet Prairie, Freshwater marsh, Seepage swamp, Pond Swamp, Mangrove, Hydric pine flatwoods, Wet prairie, Seepage swamp, Flowing water swamp, Pond swamp Likely I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-4 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species Federally Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency2 Habitat Likelihood of occurrence in Florida Keys 3 Atlantic loggerhead turtle Caretta caretta T NMFS Beach dune/Coastal strand, Seagrass, Nearshore reef Likely Atlantic green turtle Chelonia mydas mydas E NMFS Beach dune/Coastal strand, Seagrass, Nearshore reef Likely American crocodile Crocodylus acutus E (CH) USFWS Mangrove, Coastal marsh Likely leatherback turtle Dermochelys coriacea E NMFS Offshore marine Possible eastern indigo snake Drymarchon corais couperi T USFWS High pine, Tropical hardwood hammock, Scrubby high pine, Beach dune/Coastal strand, Maritime hammock, Mesic temperate hammock, Pine rockland, Scrubby flatwoods, Mesic pine flatwoods, Hydric pine flatwoods, Dry prairie, Cutthroat grass, Freshwater marsh, Seepage swamp, Flowing water swamp, Pond swamp, Mangrove Possible Atlantic hawksbill (=carey) turtle Eretmochelys imbricata E NMFS Beach dune/Coastal strand, Seagrass, Nearshore reef Likely Kemp’s ridley turtle Lepidochelys kempii E NMFS Marine coastal waters with sandy or muddy bottoms and shorelines of red mangrove Possible INVERTEBRATES Schaus' swallowtail butterfly Heraclides (= Papilio) aristodemus ponceanus E USFWS Tropical hardwood hammock Likely I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-5 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species Federally Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency2 Habitat Likelihood of occurrence in Florida Keys 3 Stock Island tree snail Orthalicus reses reses T USFWS Tropical hardwood hammock Likely PLANTS Blodgett's wild- mercury Arygythamnia blodgettii C USFWS Tropical hardwood hammock, Pine rockland Likely Big Pine partridge pea Chamaecrista lineata var. keyensis C USFWS Pine rockland Likely deltoid spurge Chamaesyce (=Euphorbia) deltoidea ssp. deltoidea E USFWS Pine rockland, Beach dune/Coastal strand Not Likely Garber's spurge Chamaesyce garberi T USFWS Pine rockland, Rockland hammocks, Coastal rock barrens, Salt flats, Grass prairies, Beach ridges Likely Porter’s sandmat (spurge) Chamaesyce porteriana C USFWS Pine rockland, Rockland hammock, Coastal rock barrens, Marl prairie Possible Cape Sable thoroughwort Chromolaena (=Eupatorium) frustrata C USFWS Tropical hardwood hammock, Pine rockland Likely Johnson’s seagrass Halophila johnsonii T NMFS Intertidal waters to 3 meters depth Not Likely sand f lax Linum arenicola C USFWS Pine rockland, Marl prairie, Adjacent disturbed areas Possible semaphore cactus Opuntia corallicola C USFWS Tropical hardwood hammock, Beach dune/Coastal strand Possible I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-6 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species Federally Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency2 Habitat Likelihood of occurrence in Florida Keys 3 Key tree-cactus Pilosocereus (=Cereus) robinii E USFWS Tropical hardwood hammock Likely 1 E=Endangered, T=Threatened, S/A=Similarity of Appearance, CH=Critical Habitat, C=Candidate 2 USFWS=U.S. Fish and Wildlife Service, NMFS=National Marine Fisheries Service 3 Expressed as Likely, Possible, Not Likely Sources: Chafin 2000, EnviroTools 1998, FGFC 1997, FCREPA a, b and c 1992, Hipes et al. 2000, Kale and Maehr 1990, Long and Lakela 1971, Nelson 1994, Nelson 1996, Scurlock 1987, USDA 2001, Wunderlin and Hansen 2000. I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-7 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency 2 Habitat Likelihood of occurrence in Florida Keys 3 TERRESTRIAL MAMMALS southern mink, (South Florida population) Mustela vison mink ( = M. v. evergladensis T FFWCC Salt marsh, Freshwater marsh, Cypress swamp, Hardwood swamp Not Likely Key Largo woodrat Neotoma floridana smalli E FFWCC Tropical hardwood hammock Likely Key deer Odocoileus virginianus clavium E FFWCC Tropical hardwood hammock, Mesic temperate hammock, Pine rockland, Mesic pine flatwoods, Hydric pine flatwoods, Freshwater marsh, Mangrove, Saltmarsh Likely Lower Keys silver rice rat (= silver rice rat) Oryzomys palustris natator (= O. argentatus) E FFWCC Freshwater marsh, Mangrove, Saltmarsh Likely Key Largo cotton mouse Peromyscus gossypinus allapaticola E FFWCC Tropical hardwood hammock Likely Florida panther Puma (= Felis) concolor coryi E FFWCC High pine, Tropical hardwood hammock, Scrub, Maritime hammock, Mesic temperate hammock, Pine rockland, Scrubby flatwoods, Mesic pine flatwoods, Hydric pine flatwoods, Dry prairie, Wet prairie, Freshwater marsh, Seepage swamp, Pond swamp, Mangrove Not Likely mangrove fox squirrel Sciurus niger avicennia T FFWCC Pine flatwoods, Cypress swamp, Hardwood hammock Not Likely Lower Keys marsh rabbit Sylvilagus palustris hefneri E FFWCC Beach dune/Coastal strand, Freshwater marsh, Mangrove, Saltmarsh Likely I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-8 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency 2 Habitat Likelihood of occurrence in Florida Keys 3 Florida black bear Ursus americana floridanus T FFWCC High pine, Tropical hardwood hammock, Scrub, Maritime hammock, Mesic temperate hammock, Pine rockland, Scrubby flatwoods, Mesic pine flatwoods, Hydric pine flatwoods, Dry prairie, Wet prairie, Freshwater marsh, Seepage swamp, Pond swamp, Mangrove Not likely MARINE MAMMALS West Indian manatee Trichechus manatus E FFWCC Mangrove, Seagrass, Nearshore reef Likely Sei whale Balaenoptera borealis E FFWCC Offshore marine Not Likely blue whale Balaenoptera musculus E FFWCC Offshore marine Not Likely finback whale Balaenoptera physalus E FFWCC Offshore marine Not Likely right whale Eubalaena glacialis E FFWCC Offshore marine Not Likely humpback whale Megaptera novaeangliae E FFWCC Offshore marine Not Likely sperm whale Physeter macrocephalus E FFWCC Offshore marine Not Likely FISH Key silverside Menidia conchorum T FFWCC Isolated lagoons; shallow, protected waters Likely mangrove rivulus Rivulus marmoratus SSC FFWCC Land-crab burrows, mangrove forests, mosquito ditches Likely Key blenny Starksia starcki SSC FFWCC Surge channels between rows of coral Likely I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-9 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency 2 Habitat Likelihood of occurrence in Florida Keys 3 BIRDS roseate spoonbill Ajaia ajaja SSC FFWCC Mangrove islands, Dredge spoil islands, Willow heads, Tidal flats and ponds, Coastal marshes, Freshwater sloughs and marshes Likely Cape Sable seaside sparrow Ammodramus (=Ammospiza) maritimus mirabilis E FFWCC Wet prairie, Freshwater marsh Possible limpkin Aramus guarauna SSC FFWCC Mangroves, Freshwater marsh, Swamps, Margins of ponds, lakes, and rivers, Sloughs, Impoundments Possible snowy plover Charadrius alexandrinus T FFWCC Beach dune/Coastal strand Possible piping plover Charadrius melodus T FFWCC Beach dune/Coastal strand, Nearshore reef Likely white-crowned pigeon Columba leucocephala T FFWCC Mangrove islands, Tropical hardwood hammock Likely Kirtland's warbler Dendroica kirtlandii E USFWS Upland pine, Mesic hammock, Rockland hammock, Xeric scrub Not Likely little blue heron Egretta caerula SSC FFWCC Shallow freshwater, brackish, and saltwater habitats Likely reddish egret Egretta rufescens SSC FFWCC Marine tidal flats and shorelines, Salt evaporation pools and lagoons, Coastal mangrove islands, Dredge spoil islands Likely snowy egret Egretta thula SSC FFWCC Permanently and seasonally flooded wetlands, Streams, Lakes, Swamps Likely tricolored heron Egretta tricolor SSC FFWCC Permanently and seasonally flooded wetlands, Mangrove swamps, Tidal creeks and ditches, Edges of ponds and lakes Likely I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-10 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency 2 Habitat Likelihood of occurrence in Florida Keys 3 white ibis Eudocimus albus SSC FFWCC Freshwater and brackish marshes, Salt flats, Saltmarsh, Forested wetlands, Wet prairies, Swales, Seasonally inundated fields and ditches Likely peregrine falcon Falco peregrinus E FFWCC Disturbed/Cultivated land, Freshwater marsh, Saltmarsh., Prairie, Ponds/Lakes, Streams/Rivers, Swamp Possible southeastern American kestrel Falco sparverius paulus T FFWCC Open pine habitat, Woodland edges, Prairies, Pasture land Possible Florida sandhill crane Grus canadensis pratensis T FFWCC Prairies, Freshwater marsh, Pasture land Not Likely American oystercatcher Haematopus palliatus SSC FFWCC Beach dune/Coastal strand, Sandbars, Mudflats, Shellfish beds Possible bald eagle Haliaeetus leucocephalus T FFWCC High pine, Scrubby high pine, Maritime hammock, Mesic temperate hammock, Pine rockland, Scrubby flatwoods, Mesic pine flatwoods, Hydric pine flatwoods, Dry prairie, Wet prairie, Freshwater marsh, Seepage swamp, Flowing water swamp, Pond swamp, Mangrove, Saltmarsh, Seagrass Possible wood stork Mycteria americana E FFWCC Hydric pine flatwoods, Wet prairie, Freshwater marsh, Seepage swamp, Flowing water swamp, Pond swamp, Mangrove, Saltmarsh, Seagrass Possible osprey Pandion haliaetus SSC FFWCC Large lakes, Rivers, Coastal areas Likely brown pelican Pelecanus occidentalis SSC FFWCC Shallow estuarine waters, Sandbars, Sandspits, Mangrove islands Likely I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-11 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency 2 Habitat Likelihood of occurrence in Florida Keys 3 red-cockaded woodpecker Picoides (= Dendrocopos) borealis T FFWCC High pine, Mesic pine flatwoods, Hydric pine flatwoods Not Likely Audubon's crested caracara Polyborus plancus audubonii T FFWCC Mesic temperate hammock, Mesic pine flatwoods, Hydric pine flatwoods, Dry prairie, Wet prairie Possible Everglade snail kite Rostrhamus sociabilis plumbeus E FFWCC Hydric pine flatwoods, Freshwater marsh, Pond swamp Not Likely black skimmer Rynchops niger SSC FFWCC Coastal waters, Large lakes, Sandy beaches, Small islands, Dredge spoil islands Likely Florida burrowing owl Speotyto(=Athene)c unicularia floridana SSC FFWCC High, sparsely vegetated, sandy ground, Ruderal areas such as pastures, airports, parks, school grounds, road rights-of-way, and other vacant spaces Likely least tern Sterna antillarum T FFWCC Beach dune/Coastal strand Likely roseate tern Sterna dougallii dougallii T FFWCC Beach dune/Coastal strand, Saltmarsh, Seagrass, Nearshore reef Likely REPTILES American alligator Alligator mississippiensis SSC FFWCC Hydric pine flatwoods, Wet Prairie, Freshwater marsh, Seepage swamp, Pond Swamp, Mangrove, Hydric pine flatwoods, Wet prairie, Seepage swamp, Flowing water swamp, Pond swamp Likely Atlantic loggerhead turtle Caretta caretta T FFWCC Beach dune/Coastal strand, Seagrass, Nearshore reef Likely Atlantic green turtle Chelonia mydas mydas E FFWCC Beach dune/Coastal strand, Seagrass, Nearshore reef Likely I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-12 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency 2 Habitat Likelihood of occurrence in Florida Keys 3 American crocodile Crocodylus acutus E FFWCC Mangrove, Coastal marsh Likely leatherback turtle Dermochelys coriacea E FFWCC Offshore marine Possible Big Pine Key ringneck snake Diadophis punctatus acricus T FFWCC Pine rockland, Tropical hardwood hammock Likely eastern indigo snake Drymarchon corais couperi T FFWCC High pine, Tropical hardwood hammock, Scrubby high pine, Beach dune/Coastal strand, Maritime hammock, Mesic temperate hammock, Pine rockland, Scrubby flatwoods, Mesic pine flatwoods, Hydric pine flatwoods, Dry prairie, Cutthroat grass, Freshwater marsh, Seepage swamp, Flowing water swamp, Pond swamp, Mangrove Possible red rat snake Elaphe guttata SSC 4 FFWCC Pine, hardwood, mangrove forested habitats, Disturbed habitats Likely Atlantic hawksbill (=carey) turtle Eretmochelys imbricata E FFWCC Beach dune/Coastal strand, Seagrass, Nearshore reef Likely Florida Keys mole skink Eumeces egregius egregius SSC FFWCC Beach dune/Coastal strand, Coastal berm, Coastal scrub Likely gopher tortoise Gopherus polyphemus SSC FFWCC Sandhills, Scrub, Xeric oak hammock, Dry pine flatwoods, Pasture land, Oldfields, Road shoulders Not Likely Key mud turtle Kinosternum bauri E 4 FFWCC Small, usually temporary freshwater to slightly brackish ponds and ditches Likely Kemp’s ridley turtle Lepidochelys kempii E FFWCC Marine coastal waters with sandy or muddy bottoms and shorelines of red mangrove Possible I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-13 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency 2 Habitat Likelihood of occurrence in Florida Keys 3 Lower Keys brown snake Storeria dekayi victa T 4 FFWCC Pine rockland, Tropical hardwood hammock Likely Rim rock crowned snake Tantilla oolitica T FFWCC Tropical hardwood hammock, Pine rockland, Vacant lots, Pastures Likely Florida ribbon snake Thamnophis sauritus sackenii T 4 FFWCC Mangrove, Spartina marsh, Freshwater depressions and ditches Likely INVERTEBRATES pillar coral Dendrogyra cylindris E FFWCC Coral reef Likely Schaus' swallowtail butterfly Heraclides ( = Papilio) aristodemus ponceanus E FFWCC Tropical hardwood hammock Likely Florida tree snail Liguus fasciatus matecumbensii SSC FFWCC Tropical hardwood hammock Likely Stock Island tree snail Orthalicus reses reses T FFWCC Tropical hardwood hammock Likely PLANTS tamarindillo Acacia choriophylla E FDPI Rockland hammock, Mangrove swamp, Coastal berm Likely barbed-wire cactus Acanthocereus tetragonus (=Cereus pentagonus) T FFWCC Maritime hammock Likely paurotis palm Acoelorraphe wrightii T FFWCC Pine rockland, Rockland hammock Possible I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-14 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency 2 Habitat Likelihood of occurrence in Florida Keys 3 golden leather fern Acrostichum aureum T FFWCC Mangrove swamp, Saltmarsh, Hydric hammock Likely fragrant maidenhair fern Adiatum melanoleucum E FFWCC Rockland hammock Possible meadow jointvetch Aeschynomene pratensis E FFWCC Marl prairie, Cypress domes, Swales Not Likely Cape Sable whiteweed Ageratum littorale E FFWCC Maritime hammock Likely bracted colicroot Aletris bracteata E FFWCC Marl prairie, Pine rockland Possible pineland allamanda Angadenia beteroi T FFWCC Pine rockland Likely sea lavender Argusia gnaphalodes E FFWCC Beach dune/Coastal strand Likely Blodgett's wild- mercury Arygythamnia blodgettii E FFWCC Tropical hardwood hammock, Pine rockland Likely bird’s nest spleenwort Asplenium serratum E FFWCC Cypress swamp, Tropical rockland hammock Possible Carter’s orchid Basiphyllaea corallicola E FFWCC Pine rockland, Rockland hammock Possible pine-pink orchid Bletia purpurea T FFWCC Wet pine flatwoods, Cypress strand Not Likely pineland strongbark Bourreria cassinifolia E FFWCC Pine rockland Likely rough strongbark Bourreria radula E FFWCC Rockland hammock, Pine rockland Likely I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-15 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency 2 Habitat Likelihood of occurrence in Florida Keys 3 pigeon-berry Bourreria succulenta E FFWCC Rockland hammock, Pine rockland Likely spider orchid Brassia caudata E FFWCC Hammocks Not Likely Keys locustberry Byrsonima lucida T FFWCC Rockland hammock, Pine rockland Likely yellow nicker Caesalpinia major E FFWCC Upland hammock Likely fewflower holdback Caesalpinia pauciflora E FFWCC Pine rockland Likely myrtle-of-theriver Calyptranthes zuzygium E FFWCC Rockland hammock, maritime hammock Likely narrow strap fern Campyloneurum angustifolium E FFWCC Tropical hardwood hammock, Cypress swamp Not Likely wild cinnamon Canella winteriana E FFWCC Rockland hammock, maritime hammock Likely small-flowered lilythorn Catesbaea parviflora E FFWCC Pine rockland, Coastal strand Likely powdery catopsis Catopsis berteroniana E FFWCC Rockland hammock, Mangrove swamp Not Likely many-flowered catopsis Catopsis floribunda E FFWCC Tropical hardwood hammock, Cypress swamp Not Likely West Indian cock’s-comb Celosia nitida E FFWCC Beach dune/Coastal strand, Upland hammock Likely slimbristle sandbur Cenchrus brownii E FFWCC Disturbed/Cultivated open land, Hammocks Likely Big Pine partridge pea Chamaecrista lineata var. keyensis E FFWCC Pine rockland Likely I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-16 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency 2 Habitat Likelihood of occurrence in Florida Keys 3 Garber's spurge Chamaesyce garberi E FFWCC Pine rockland, Rockland hammocks, Coastal rock barrens, Salt flats, Grass prairies, Beach ridges Likely rocklands spurge Chamaesyce pergamena T FFWCC Pine rockland Likely Porter’s sandmat (spurge) Chamaesyce porteriana T FFWCC Pine rockland, Rockland hammock, Coastal rock barrens, Marl prairie Possible southern lip fern Cheilanthes microphylla E FFWCC Shell mounds, Pine rockland, Maritime hammock, Mesic hammock Not Likely Cape Sable thoroughwort Chromolaena frustrata (=Eupatorium frustratum) E FFWCC Tropical hardwood hammock, Pine rockland Likely satin leaf Chrysophyllum oliviforme T FFWCC Pine rockland, upland hammock Likely Yucatan flymallow Cienfuegosia yucataniensis E FFWCC Coastal rock barrens, Coastal hammock, Saltmarsh Likely silver palm Coccothrinax argentata E FFWCC Pine rockland, upland hammock Likely Cuban snakebark Colubrina cubensis var. floridana E FFWCC Rockland hammock, Pine rockland Likely soldierwood Colubrina elliptica E FFWCC Rockland hammock Likely white geiger Cordia globosa E FFWCC Upland hammock Likely Christmas berry Crossopetalum ilicifolium T FFWCC Rockland hammock, Pine rockland Likely I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-17 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency 2 Habitat Likelihood of occurrence in Florida Keys 3 rhacoma Crossopetalum rhacoma E FFWCC Rockland hammock, Pine rockland, coastal scrub Likely pepperbush croton Croton humilis E FFWCC Upland hammock Possible cupania Cupania glabra E FFWCC Rockland hammock Likely Blodgett’s swallow-wort Cynanchum blodgettii T FFWCC Rockland hammock, Upland hammock Likely Florida flatsedge Cyperus floridanus E FFWCC Coastal berm, Pine rockland Likely limestone flatsedge Cyperus fuligineus E FFWCC Rockland hammock Likely cowhorn orchid Cyrtopodium punctatum E FFWCC Cypress swamp, Coastal hammock, Pine rockland, Marl prairies Possible Brown’s Indian rosewood Dalbergia brownii E FFWCC Mangrove swamp, Hammocks Likely Florida prairie- clover Dalea carthagenensis var. floridana E FFWCC Pine rockland, Rockland hammock, Coastal uplands, Marl prairie Likely Caribbean crab grass Digitaria dilichophylla T FFWCC Pine rockland Likely Keys hopbush Dodonaea elaeagnoides E FFWCC Rockland hammock, pine rockland Likely milkbark Drypetes diversifolia E FFWCC Tropical hammock Likely Guiana plum Drypetes lateriflora T FFWCC Tropical hammock Likely dollar orchid Encyclia boothiana var. erythronioides E FFWCC Rockland hammock, Coastal buttonwood forest Possible I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-18 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency 2 Habitat Likelihood of occurrence in Florida Keys 3 clamshell orchid Encyclia cochleata var. triandra E FFWCC Rockland hammock, Cypress swamp Not Likely dingy-flowered star orchid Epidendrum anceps E FFWCC Rockland hammock, Cypress swamp Not Likely umbelled star orchid Epidendrum difforme E FFWCC Upland hammock Not Likely night-scented orchid Epidendrum nocturnum E FFWCC Rockland hammock, Cypress swamp Not Likely stiff-flowered star orchid Epidendrum rigidum E FFWCC Rockland hammock, Cypress swamp Not Likely black torch Erithralis fruticosa T FFWCC Beach dune/Coastal strand, maritime hammock Likely Coker’s beach creeper Ernodea cokeri E FFWCC Pine rockland Possible redberry stopper Eugenia confusa E FFWCC Rockland hammock Likely red stopper Eugenia rhombea E FFWCC Rockland hammock Likely dwarf bindweed Evolvulus convolvuloides E FFWCC Upland hammock Likely Grisebach’s bindweed Evolvulus grisebachii E FFWCC Pine rockland Likely princewood Exostema caribaeum E FFWCC Rockland hammock, Pine rockland Likely wild cotton Gossypium hirsutum E FFWCC Coastal berm, Shell mounds, Maritime hammock Likely lignum vitae Guaiacum sanctum E FFWCC Rockland hammock Likely Fuch’s bromeliad Guzmania monostachia E FFWCC Strand swamp, Rockland hammock Not Likely false boxwood Gyminda latifolia E FFWCC Tropical hardwood hammock Likely I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-19 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency 2 Habitat Likelihood of occurrence in Florida Keys 3 west coast prickly apple Harrisia aboriginum (=Cereus gracilis var. aboriginum E FFWCC Shell mounds, Rockland hammock, Maritime hammock Not Likely Simpson’s prickly apple Harrisia simpsonii (=Cereus gracilis var. simpsonii) E FFWCC Rockland hammock Likely manchineel Hippomane mancinella E FFWCC Coastal berm, Coastal hammock Likely white ironwood Hypelate trifoliata E FFWCC Rockland hammock, Pine rockland Likely Florida Keys indigo Indigofera mucronata var. keyensis E FFWCC Coastal berm, Coastal rock barrens, Rockland hammock Likely delicate ionopsis Ionopsis utricularioides E FFWCC Rockland hammock, Strand swamp Not Likely rockland morning glory Ipomoea tenuissima E FFWCC Pine rockland Possible pineland jacquemontia Jacquemontia curtissii T FFWCC Pine flatwoods, Pine rockland, Marl prairie, spoil banks Likely Havana jacquemontia Jacquemontia havanensis E FFWCC Hardwood hammock Likely skyblue clustervine Jacquemontia pentanthos E FFWCC Pine rockland, Rockland hammock, Coastal rock barren Likely joewood Jacquina keyensis T FFWCC Coastal salt flat, Coastal scrub, Maritime hammock, Pine rockland Likely white fen Kosteletzkya depressa E FFWCC Maritime hammock, Mangrove swamp Not Likely I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-20 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency 2 Habitat Likelihood of occurrence in Florida Keys 3 pineland lantana Lantana depressa var. depressa E FFWCC Pine rockland, Coastal strand, Coastal grassland, Coastal berm, Marl prairie Possible ghost plant Leiphaimos parasitica E FFWCC Upland hammock Likely sand flax Linum arenicola E FFWCC Pine rockland, Marl prairie, Adjacent disturbed areas Likely wild dilly Manilkara jaimiqui T FFWCC Upland hammock Likely mayten Maytenus phyllanthoides T FFWCC Upland hammock, Coastal dune Likely small-leaved melanthera Melanthera parviflora T FFWCC Pine rockland, Marl prairie Possible climbing vine fern Microgramma heterophylla E FFWCC Rockland hammock Not Likely Simpson’s stopper Myrcianthes fragrans T FFWCC Upland hammock Likely giant sword fern Nephrolepis biserrata T FFWCC Mesic hammock, Swamps Not Likely ribbon fern Neurodium lanceolatum E FFWCC Rockland hammock, Mangrove swamp, Upland hammock Likely wild basil Ocimum campechianum E FFWCC Upland hammock, Pine rockland Likely beach peanut Okenia hypogaea E FFWCC Beach dune/Coastal strand Likely mule-eared orchid Oncidium undulatum (=luridum E FFWCC Hardwood hammock, Cypress swamp, Buttonwood forest Possible I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-21 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency 2 Habitat Likelihood of occurrence in Florida Keys 3 hand fern Ophioglossum palmatum E FFWCC Maritime hammock, Hydric hammock, strand swamp Not Likely semaphore cactus Opuntia corallicola (=spinosissima) E FFWCC Tropical hardwood hammock, Beach dune/Coastal strand Likely prickly-pear cactus Opuntia stricta T FFWCC Tropical hardwood hammock, Beach dune/Coastal strand Likely Keys Joe- jumper Opuntia triacantha E FFWCC Coastal rockland, rockland hammock Likely white-flowered passionvine Passiflora multiflora E FFWCC Tropical hardwood hammock Likely pineland passionvine Passiflora pallens E FFWCC Rockland hammock, Coastal berm, Strand swamp Not Likely swampbush Pavonia paludicola E FFWCC Saltmarsh, Mangrove swamp Possible widespread polypody Pecluma dispersa E FFWCC Hydric hammock, upland hammock, pine rockland Likely plume polypody Pecluma plumula E FFWCC Hardwood hammock Likely reddish peperomia Peperomia humilis E FFWCC Mesic hammock, Coastal berm, Cypress swamp, Maritime hammock Not Likely Florida peperomia Peperomia obtusifolia E FFWCC Rockland hammock, Hydric hammock, Strand swamp Not Likely mahogany mistletoe Phoradendron rubrum E FFWCC Rockland hammock Likely Bahama tree cactus Pilosocereus bahamensis E FFWCC Rockland hammock Likely I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-22 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency 2 Habitat Likelihood of occurrence in Florida Keys 3 Key tree-cactus Pilosocereus (=Cereus) robinii E FFWCC Tropical hardwood hammock Likely devil’s smooth claws Pisonia rotundata E FFWCC Pine rockland, Rockland hammock Likely blackbead Pithecellobium keyense T FFWCC Rockland hammock Likely Everglades poinsettia Poinsettia pinetorum E FFWCC Pine rockland Likely ghost orchid Polyradicion lindenii E FFWCC Maritime hammock, Swamps Not Likely buccaneer palm Pseudophoenix sargetii E FFWCC Rockland hammock Likely long-stalked stopper Psidium longipes T FFWCC Pine rockland, Rockland hammock Likely Bahama wild coffee Psychotria ligustrifolia E FFWCC Rockland hammock Mesic flatwoods, Scrubby flatwoods, Wet flatwoods Likely Bahama ladder brake Pteris bahamensis T FFWCC Pine rockland, Upland hammock Likely Darling plum Reynosia septentrionalis T FFWCC Upland hammock Likely mistletoe cactus Rhipsalis baccifera E FFWCC Rockland hammock, Mangrove swamp Not Likely Swartz’ snoutbean Rhynchosia swartzii T FFWCC Upland hammock Likely Florida royal palm Roystonea elata E FFWCC Rockland hammock, Strand swamp, Shell mounds Possible I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-23 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency 2 Habitat Likelihood of occurrence in Florida Keys 3 Bahama sachsia Sachsia bahamensis (=polycephala) E FFWCC Pine rockland Likely maiden bush Savia bahamensis E FFWCC Coastal thickets, Maritime hammock Likely yellow wood Schaefferia frutescens E FFWCC Upland hammock Likely silky bluestem Schizachyrium sericatum E FFWCC Pine rockland Likely Keys’ nutrush Scleria lithosperma E FFWCC Rockland hammock Likely Havana skullcap Scutellaria havanensis E FFWCC Pine rockland Likely Eaton’s spike- moss Selaginella eatonii E FFWCC Rockland sinkholes Not Likely Chapman’s sensitive-plant Senna mexicana var. chapmanii T FFWCC Beach dune, Rockland hammock, Pine rockland Likely coral panic grass Setaria chapmanii (=Panicum chapmanii E FFWCC Shell mounds, Cropland, Upland hammock, Prairies Likely Everglades greenbrier Smilax havanensis T FFWCC Upland hammock, Pine rockland Likely potato tree Solanum donianum T FFWCC Upland hammock Likely false buttonweed Spermacoce terminalis T FFWCC Pine rockland, Flatwoods Likely wedgelet fern Sphenomeris (=Odontosoria) clavata E FFWCC Pine rockland, Sinkholes Likely I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-24 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency 2 Habitat Likelihood of occurrence in Florida Keys 3 Tall neottia Spiranthes elata (=Mesadenus elatus) E FFWCC Rockland hammock, Sinkholes Not Likely lace-lip ladies’tresses Spiranthes laciniata T FFWCC Flatwoods, Marshes, Swamps Not Likely southern ladies’tresses Spiranthes torta E FFWCC Pine rockland, Marl prairie, Rockland hammock Likely pride-of-Big- Pine Strumpfia maritima E FFWCC Coastal strand, Coastal rock barren, Pine rockland Likely Everglades pencil-flower Stylosanthes calicola E FFWCC Pine rockland, Marl prairie Likely West Indies mahogany Swietenia mahagoni E FFWCC Rockland hammock, Maritime hammock Likely least halberd fern Tectaria fimbriata E FFWCC Rockland hammock, Sinkholes Not Likely tetrazygia Tetrazygia bicolor T FFWCC Rockland hammock, Pine rockland Likely abrupt-tipped maiden fern Thelypteris augescens T FFWCC Calcareous hammock, Limestone rockland Likely brittle thatch palm Thrinax morrisii E FFWCC Rockland hammock, Pine rockland Likely Florida thatch palm Thrinax radiata E FFWCC Maritime hammock, Upland hammock, Coastal scrub Likely inflated wildpine Tillandsia balbisiana T FFWCC Flatwoods, Hammocks, Swamps Likely twisted air plant Tillandsia flexuosa E FFWCC Hammocks, Pine rockland, Swamps, Shell Mounds Likely I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-25 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency 2 Habitat Likelihood of occurrence in Florida Keys 3 giant wildpine Tillandsia utriculata E FFWCC Flatwoods, Hammocks, Pine rockland, Swamps Likely soft-leaved wildpine Tillandsia valenzuelana T FFWCC Hammocks, Swamps Likely bay lavender Tournefortia gnaphalodes E FFWCC Beach dune, Coastal rockland Likely chiggery-grapes Tournefortia hirsutissima E FFWCC Upland hammock Likely rocklands noseburn Tragia saxicola T FFWCC Pine rockland Likely West Indian trema Trema lamarkianum E FFWCC Upland hammock, Dry prairie, Disturbed areas Likely winged filmy fern Trichomanes holopterum E FFWCC Strand swamps Not Likely hoop vine Trichostigma octandrum E FFWCC Upland hammock, Disturbed areas Likely Florida gamagrass Tripsacum floridanum T FFWCC Pine rockland Likely pearl berry Vallesia antillana E FFWCC Maritime hammock Likely wormvine orchid Vanilla barbellata E FFWCC Rockland hammock, Mangrove swamp Likely coastal vervain Verbena (=Glandularia) maritima E FFWCC Beach dune, Coastal scrub, Pine rockland Likely Blodgett’s ironweed Vernonia blodgettii E FFWCC Pine rockland, Mesic flatwoods Likely I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-26 Appendix F Federally and State-Listed Species in Monroe County and Fishery Species State-Listed Species with the Potential to Occur in Monroe County and along the Atlantic Coast and Gulf of Mexico Common Name Scientific Name Status 1 Jurisdictional Agency 2 Habitat Likelihood of occurrence in Florida Keys 3 yellowheart Zanthoxylum flavum E FFWCC Tropical coastal hammock Likely 1 E=Endangered, T=Threatened, SSC=Species of Special Concern, PE=Proposed Endangered, PT=Proposed Threatened, PS=Proposed Species of Special Concern 2 FFWCC = Florida Fish and Wildlife Conservation Commission, FDPI = Florida Department of Agriculture and Consumer Services, Division of Plant Industry 3 Expressed as Likely, Possible, Not Likely 4 Lower Keys population only Sources: Chafin 2000, EnviroTools 1998, FGFC 1997, FCREPA a, b and c 1992, Hipes et al. 2000, Kale and Maehr 1990, Long and Lakela 1971, Nelson 1994, Nelson 1996, Scurlock 1987, USDA 2001, Wunderlin and Hansen 2000. I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ F-27 Appendix G Federal and State Agency Correspondence Appendix G Agency Coordination Letters Coordination Letters were sent to the following: Jay Slack, Field Supervisor South Florida Ecological Services Field Office U.S. Fish and Wildlife Service 1339 20th Street Vero Beach, FL 32960 cc: Phil Frank, Biologist Dr. Janet Matthews, Director Division of Historical Resources Florida State Historic Preservation Office R.A. Gray Building, Room 305 500 South Bronough Street Tallahassee, FL 32399-0250 cc: Laura Kammerer, Head of Compliance and Review Georgia Cranmore Acting Assistant Regional Admin. Protective Resources Division National Marine Fisheries Service 0721 Executive Center Drive North St. Petersburg, FL 33702 cc: Mike Johnson, Fisheries Biologist Heinz Mueller, Chief Office of Environmental Assessment U.S. Environmental Protection Agency Sam Nunn Atlanta Federal Center 61 Forsyth Street S.W. Atlanta, GA 30303 Andy Mager, Chief Habitat Conservation Division National Marine Fisheries Service NOAA, Southeast Region 9721 Executive Center Drive North, Suite St. Petersburg, FL 33702 Gus Rios, Director Florida Department of Environmental Protection 2796 Overseas Highway, Suite 221 Marathon, FL 33050 Joe May Florida Department of Environmental Protection Southeast District Office 400 North Congress Ave West Palm Beach, FL 33401 Rhonda Haag, Director South Florida Water Management District Florida Keys Service Center P.O. Box 24680 West Palm Beach, FL 33416 Gerald Briggs, Chief Bureau of Onsite Sewage, HSES Florida Department of Health 4052 Bald Cypress Way Bin #A08 Tallahassee, Fl 32399-1713 Bart Bibler, Chief, Bureau of Water Programs, HSEW 4042 Bald Cypress Way Tallahassee, FL 32311 Bob Paulson, Acting Branch Chief Regulatory Permits Division U.S. Army Corps of Engineers 400 North Congress Avenue, Suite 130 West Palm Beach, FL 33401 I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ G-1 Appendix G Federal and State Agency Correspondence Vic Anderson U.S. Army Corps of Engineers Field Office 2796 Overseas Highway Marathon, FL 33050 Allan L. Egbert Executive Director Florida Fish and Wildlife Conservation Commission Office of the Executive Director 620 S. Meridian Street Tallahassee, FL 32399-1600 Roger Braun Executive Director Florida Keys Aqueduct Authority P.O. Box 1479 1100 Kennedy Drive Key West, FL 33040 Bill Causey Superintendent Florida Keys National Marine Sanctuary P.O. Box 500368 Marathon, FL 33050 Tim McGarry Monroe County Growth Management Director 2798 Overseas Highway Marathon, FL 33052 Rebecca Jetton Planning Manager Marathon Regional Service Center 2796 Overseas Highway, Suite 212 Marathon, FL 33050 Bradley J. Hartman, Director Office of Environmental Services Florida Fish and Wildlife Conservation Commission 620 South Meridian Street Tallahassee, FL 32399-1600 Teresa Tinker Policy Coordinator Growth Management and Strategic Planning Office of the Governor 1501 Capitol Tallahassee, FL 32399-0001 Miles Anderson Division of Emergency Management Florida Department of Community Affairs 2555 Shumand Oak Blvd. Tallahassee, FL 32399-2100 David B. Struhs Florida Department of Environmental Protection Douglas Bldg, RM 1041a 3900 Commonwealth Blvd., MS10 Tallahassee, FL 32399-0001 I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ G-2 Appendix H Funding and Financing Options Appendix H Funding and Financing Options Funding and Financing Options for Wastewater Management Activities in the Florida Keys The funding and financing options contained in this Appendix identify, in general terms, the range of sources that may be used to fund wastewater treatment activities in the Keys as identified in the MCSWMP and by project applicants (Monroe County, 2000a). The actual funding and financing vehicles used by the project applicant would be project-specific and evaluated in the project-specific SER. As noted in Section 3.6.3, Local Fees and Taxes, the availability of funding and the specific types of financing affect the rates charged to wastewater users. In general, the various wastewater funding and financing options fall into one of the following categories: • User fees and charges • Taxes and assessments • Grants and contributions • Redirection of existing Programs or funding • Financial assistance for low and fixed income users • Doing more with less The following describes various funding and financing options associated with each of these categories. I. USER FEES AND CHARGES User fees and charges are collected for the provision of the services that provide a specific benefit to a user. Various types of user fees and charges are described below. Wastewater Rates and Charges For most utilities, their primary source of revenue is the rate charged to customers. Publicly owned utilities are typically operated as “Enterprise Funds” within the local government’s organization. Enterprise funds are intended to be managed like a business, and are typically expected to be self-supporting, although many utilities do receive additional funds from the city or county’s general fund. In addition to paying for on going operation and maintenance (O&M) costs, portion of a utility’s rate-generated revenues is used to directly fund minor capital programs, as well as to repay the debt service on any outstanding bonds or loans. Rate revenues may be dedicated to a capital reserve account and used to fund annual capital improvements, or may be accumulated until sufficient to fund larger projects. This is the most common method used for funding equipment renewal and replacement requirements. Wastewater may include a minimum or fixed charge that does not vary from billing period to billing period (most frequently month to month), and/or a volume charge that may be based on the user’s water consumption or metered wastewater flows. I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ H-1 Appendix H Funding and Financing Options Miscellaneous Fees and Charges Most utilities also charge customers miscellaneous fees for services that the utility may provide, or to provide incentives, such as for prompt payment of bills. These fees are typically designed to recover the utility’s costs incurred to provide these specific services, or to recover the costs the utility incurs because of the customers’ actions (service line clean outs, lost interest income, etc.). Connection Fees Hook-up, tap, or connection fees are charges collected for the new connections to a community wastewater system. In many communities, connection fees are designed to recover just the cost the utility incurs to install the service connection to the sewer main. Impact Fees Impact fees, like connection fees, are collected at the time a user connects to the wastewater system. Impact fees are intended to recover the costs the utility incurs to oversize its transmission, treatment, and disposal facilities to provide capacity to serve new users. The intent of these charges is to avoid charging existing customers for the costs the utility is incurring to serve future customers. Line Extension Fees Some utility companies charge a fee for extending collection and or transmission lines to serve a new customer’s property. This charge, which is generally based on the number of feet that the collection or transmission line must be extended to serve the property, may be collected in addition to the connection and impact fees. Service Availability Fees Community water and wastewater utilities frequently require development properties to connect to the system once service is available (i.e., when a collection line has been constructed along their property). In some communities, where the local government has opted not to require a connection to the system, service availability fees have been implemented. The service availability fees are typically designed to recover capital costs that the utility has incurred to make service available to user, which the user is choosing not to exercise. These types of fees are currently being challenged in Florida courts. II. TAXES AND ASSESSMENTS Taxes are used to fund activities that do not provide a specific benefit, but provide a more general benefit to the community; the user may not be able to avoid paying the tax. Assessments must show a benefit to the property owned by the user. The various forms of a common taxes and assessments are described in the following section. I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ H-2 Appendix H Funding and Financing Options Local Improvement District Assessments The extension of lines to serve existing development is frequently accomplished through the creation of a local improvement district (LID). LIDs are created for the specific purpose of financing capital improvements (e.g. roads, water lines, sewer lines, street lighting, and/or storm water improvements) to serve a specific area. Once the LID has been created, special assessments bonds can be issued, which are secured by liens on the properties located within the LID. Debt service on the bonds issued to finance the improvements is recovered through annual assessments on the property located in the LID. For the sewer line improvements, a property owner’s share of cost of the improvements is frequently based on the front footage of the property along which the sewer line is being laid. For improvements involving more than laying the sewer lines, other bases for the assessment are generally collected in the user’s annual property tax bill. Sales Tax/Local Option Tax A 1-cent (1-percent) sales tax is used frequently to provide funding for a variety of projects and activities, from schools to highways. Monroe County currently receives revenues from a local option sales tax to fund grants for its cesspool replacement program. Residents, tourist, and businesses all pay a sales tax on purchases made in the County. Property Tax Property taxes are assessments charged to real property owners based on a percentage (millage rate) of the assessed property value. These taxes generally support the majority of a county’s non-enterprise fund activities. However, the revenues from property taxes can also be used for enterprise fund projects, and have been used in many communities to pat debt service on general obligation bonds issued to finance wastewater system improvements. Because communities are limited in the total of millage rate, use of property taxes to fund wastewater management improvements could limit the county’s ability to raise funds for other activities. Municipal Services Taxing/Benefit Unit Municipal services Taxing Units (MSTUs) and Municipal service Benefit Units (MSBUs) can be established through annual property taxes or assessments to generate funds for projects. Unlike LIDs, MSTUs and MSBUs can be used to fund both capital and annual O&M costs. Ad valorem taxes are generated from MSTUs; special assessments generate funds in MSBUs. The taxes and assessments are levied on property owners. Unlike the process required for raising the millage rate on property taxes, no referendum is required to levy taxes or assessments in an MSBU or MSTU, unless the revenues are used for leveraging bonds. The taxes associated with MSTUs are subjected to the cap on the total millage rate. Therefore, use of MSTU to generate funds would constrain the future taxing ability of the County. Bed Tax The bed tax generates revenues from tourists’ expenditures at hotels, motels, and short-term lodging. Like a sales tax, a bed is usually based on a percentage of expenditures, however, the I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ H-3 Appendix H Funding and Financing Options tax would be limited to expenditures at a hotel or a motel for lodging, and therefore has little or no direct impact on residents. Monroe County currently collects a 4-percent bed tax, out of which 1% goes to the county land development authority, and the other 3% goes to the county’s Tourist Development Council. Real Estate Transfer Tax A real estate transfer tax is collected from all sales of real estate in a county. The tax is levied at the time of transfer of real property. These types of taxes may be based on a percentage of assessed value or may be a flat deed registration fee, or both. New property owners would be responsible for paying the real estate transfer tax. Tax Increment Financing In areas where publicly financed redevelopment is raising property values, tax increment financing (TIF) can be used to fund new projects. With TIF, the incremental increase in ad valorem tax revenues that are a consequence of rising property values (which in turn results from the planned improvements) is dedicated to repaying the debt that financed the capital projects in that area. This approach to funding projects is applicable only in areas undergoing redevelopment. III. BONDS AND LOANS Revenue Bonds Revenue bonds are bonds that are secured by a pledge of the revenues of the utility. The utility issuing bond pledges to generate sufficient revenues annually to cover the systems operating costs, plus meets the annual debt service requirements (principal and interest payment) times a factor, termed the coverage factor, which is designed to provide additional protection to the bondholders. The coverage factor generally ranges from 110 to 150% of the utility’s annual or maximum annual debt service requirement in the present or any future year. General Obligation Bonds Cities, counties, and special districts generally are able to issue general obligation (GO) bonds that are secured by the full faith and credit of entity. In this case, the local government issuing the bonds pledges to raise its property taxes or use any other source of revenue, to generate sufficient revenues to make the debt service payments on the bonds. A general obligation pledge is stronger pledges than a revenue pledge, and thus must carry a lower interest rate than a revenue bond. Frequently, when local government issue GO bonds for utility improvements, the utility will make the debt service payments on the GO bonds with revenues generated though the utility’s rates and charges. However, if those rate revenues are insufficient to make the debt payment, the local government is obligated to raise taxes or use other sources of revenue to make the payments. I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ H-4 Appendix H Funding and Financing Options Local Improvements District Bonds LID bonds are secured by a lien on the property in the LID. Debt services payments on these bonds are funded through annual assessments to the property owners in the LID, as discussed previously. State Revolving Fund Loans The State of Florida, like most states, operates a state revolving fund (SRF) loan program that offers qualified local governments/utilities below-market-rate loans for wastewater projects. The State Revolving Loan Fund in Florida is administered by FDEP through the Water Facilities Funding Program. It makes low-interest loans available for construction, rehabilitation, and replacement of facilities needed to collect, treat, dispose of, or reuse municipal wastewater. It is a revolving fund because loan repayments are used to make additional loans. Loans are made for a 20-year term, with interest rates set at about 60% of the present market interest rate. SRF loans are generally limited to $10 million per entity per year State Bond Loan Program The FDEP and the Division of Bond Finance of the Department of General services jointly administer the State Bond Loan Program. The program generally issues bonds that are sized to provide sufficient funds to meet the capital financing needs of several communities or entities participating in the program. The state will then loan the bond proceeds to these entities at an interest rate slightly higher than the interest rate that the state is paying on bonds. Frequently, the entities participating in the program are smaller communities or entities without the credit history or capability to enter the bond market on their own. These entities get the benefit of being able to gain lower interest rate than they would be able to obtain on their own. Commercial Loans Banks and other financial institutions may make commercial loans to local governments to fund capital projects. For utilities, these loans are typically secured by a pledge of a utility’s revenues, but may also carry a general obligation pledge. IV. GRANTS AND CONTRIBUTION A number of state and federal grant programs are available to provide funding support for local governments and/or utilities to implement specific aspects of their wastewater management program. Grant monies may also be available to qualified homeowners. At the time of the release of the PEA, the Village of Islamorada and the FKAA have applied for various federal and state grants for wastewater projects. The program, funding agency, and estimated value of these grants are listed in Table H-1. Additional information about the types of grant programs is described below. I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ H-5 Appendix H Funding and Financing Options Table H-1: Potential Federal and State Assistance Programs Identified by Project Applicants for Wastewater Projects Program Funding Agency Local Recipient Estimated Value Unmet Needs Grant Program FDCA/FEMA Village of Islamorada $2,300,000 requires local match of $329,000 Water Advisory Panel Funding Program FDEP Village of Islamorada $900,000 requires local match of $225,000 Wastewater Project Assistance Program SFWMD Village of Islamorada $75,000 Unmet Needs Grant Program FDCA/FEMA FKAA $11,350,906 Source: FEMA Region IV, Village of Islamorada, FKAA Cesspool Identification and Elimination Grant Program Monroe County has implemented a grant program to assist homeowners with replacing cesspools. This program provides a grant for at least 62% of the capital cost of an OWNRS. Homeowners whose homes have an assessed value of between $100,000 and $200,000 receive an additional grant of $1,000 over the 62-percent grant amount, or 69% of the total capital costs of these systems. This program is funded through revenues generated from grants from the Florida Department of Environmental Protection and the Florida Department of Community Affairs, as well as from funds from Monroe County’s infrastructure sales tax (Monroe County, 2001a). Water Advisory Panel Grants The State of Florida created a water advisory panel in Fiscal Year 1999, which administers a grant program that provides funds for projects that: reduce recurring violations of state water quality standards; resolve a public health threat; reduce discharges of pollutants into an impaired water bod; and reduce discharges into groundwater supplies. Each project must be sponsored by a local governmental entity, including, but not limited to, a city, county, water and sewer district, or a water management district. The project must be identified in an approved local, water management district, or Department of Environmental Protection water management plans as part of a surface water restoration effort. Priority is given to projects that address an area to be served with a population of less than 7,500 and a median household income of less than the statewide median household income. The project sponsor or grant recipient must provide for at least a 50-percent match of the total project cost. Matches may include funds from other local, state, and federal sources and in-kind contributions. Reductions in the match requirement may be considered, based on a demonstration by the project sponsor of inability to provide the match, to the satisfaction of the panel. I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ H-6 Appendix H Funding and Financing Options Federal Agencies A number of federal agencies, in addition to FEMA, have programs that can provide funding to assist in improvements to wastewater management in the Keys. Potential grant funding sources include the Environmental Protection Agency, Department of Interior, Department of Housing and Urban Development, Department of Transportation, and Department of Agriculture. Potential federal grant funding programs are identified in the following table. Table H-2: Potential Federal and State Assistance Programs Related to Wastewater Program Funding Agency Program Objective Range and Type of Financial Assistance Water Quality Cooperative Agreements (Clean Water Act, Section 104(b)(3), Public Law 92-500, as amended; 33 U.S.C. 1254(b)(3)) http://www.cfda.gov/st atic/p66463.htm EPA To assist in developing, implementing, and demonstrating innovative approaches relating to the causes, effects, extent, prevention, reduction, and elimination of water pollution. Project Grants $5,000 to $500,000 Wastewater Operator Training Grant Program (Federal Water Pollution Control Act as amended, Section 104(g)(1); 33 U.S.C. 1251 et seq.) http://www.cfda.gov/st atic/p66467.htm EPA To substantially enhance the proficiency of personnel engaged in the operations and maintenance of treatment works and related activities by financing pilot programs Project Grants $35,000 for State-wide assistance Capitalization Grants for State Revolving Funds (Clean Water Act, Public Law 95-217, as amended; Water Quality Act of 1987, Sections 601 through 607, 205(m), Public Law 100-4.) http://www.cfda.gov/p ublic/viewprog.asp EPA To create State Revolving Funds (SRFs) through a program of capitalization grants to States which will provide a long term source of State financing for construction of wastewater treatment facilities and implementation of other water quality management activities (see 66.418). Formula Grants $10,000,000 to $216,000,000; average $30,000,000 I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ H-7 Appendix H Funding and Financing Options Program Funding Agency Program Objective Range and Type of Financial Assistance Construction Grants for Wastewater Treatment Works Clean Water Act, Public Law 92-500, as amended; Public Laws 97-117 and 95-217; Water Quality Act of 1987, Public Law 1004; Public Law 96-483; and Public Law 101144 http://www.cfda.gov/st atic/p66418.htm EPA To assist and serve as an incentive in construction of municipal wastewater treatment works which are required to meet State and/or Federal water quality standards and improve the water quality in the waters of the United States. Project Grants $10,000 to $10,000,000; average $3,000,000. Water Pollution Control State and Interstate Program Support (Clean Water Act, Section 106, as amended, Public Law 95-217, 33 U.S.C. 1251 et seq) http://www.cfda.gov/st atic/p66419.htm EPA To assist in establishing and maintaining adequate measures for prevention and control of surface and ground water pollution. Formula Grants $60,000 to $9,000,000 Water Reclamation and Reuse Program Reclamation Wastewater and Groundwater Study and Facilities Act, Title XVI, Public Law 102575, as amended http://www.cfda.gov/st atic/p15504.htm Department of the Interior This Title gives Reclamation general authority to conduct appraisal and feasibility studies on water reclamation and reuse projects. It also provides general authority for research and demonstration programs to test water reclamation and reuse technologies. Formula Grants Construction funding is limited to 25% of the construction cost or $20 million per project. I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ H-8 Appendix H Funding and Financing Options Program Funding Agency Program Objective Range and Type of Financial Assistance Community Development Block Grants/State's Program Housing and Community Development Act of 1974, Title I, as amended, Public Law 93-383, 88 Stat. 633, 42 U.S.C. 53 http://www.cfda.gov/st atic/p14228.htm HUD The primary objective of this program is the development of viable urban communities by providing decent housing, a suitable living environment, and expanding economic opportunities, principally for persons of low and moderate income. Formula Grants Community Services Block Grant – Discretionary Awards Community Opportunities, Accountability, Training, and Educational Services Act of 1998, Title II, Section 680, Public Law 105-285. http://www.cfda.gov/st atic/p93570.htm HHS To support program activities of national or regional significance to alleviate the causes of poverty in distressed communities which promote: (among other things) a better standard of living for rural low-income individuals in terms of water and waste water treatment Project Grants $75,000 to $500,000 Direct Federal Funding For projects with national significance, Congress can appropriate federal funds for certain uses. The Florida Keys Water Quality Improvement Act (FKWQIA) was authorized by U.S. Congress to fund water quality improvements in the Keys through the Water Resources Development Act of 2000. This bill authorized $100 million to be administered through USACE; however, the funding has not yet been appropriated and its future availability remains uncertain. VI. FINANCIAL ASSISTANCE FOR LOW AND/OR FIXED INCOME USERS Several programs are designed to reduce the cost of providing wastewater services to users of limited means, including: I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ H-9 Appendix H Funding and Financing Options • Lifeline Rates • Cesspool Replacement Grants • Assessment Deferral Programs Lifeline Rates Some communities provide discounts on the monthly wastewater bills to users who are below certain income levels. A more common practice is to set rates that have a low minimum charge and/or use fee for a minimum (“lifeline”) level of service. Higher rates are then collected from users with higher levels of water consumption (and thereby higher estimated wastewater flows). Cesspool Identification and Elimination Grant Program. The Cesspool Replacement Program described previously is available to users at 62 to 84% of the cost of the installation of an OWNRS on-site system, based on improved property values. Assessment Deferral Programs A program could be established to allow low-income and/or fixed-income users who are required to connect to a community wastewater system to defer their costs of connecting to the wastewater system and/or LID assessments until such time as their property is sold. The interest expense on the deferred assessments or connection fees could be paid through a fund established for this purpose. The deferred assessments and connection fees would constitute a lien on the property, which would need to be satisfied upon the sale of the property. External funding would be needed to establish the fund for providing the interest subsidy for these low-income users. I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ H-10 Appendix I Notice of Intent to Prepare Environmental Assessment Public Notice Appendix I Public Notice PUBLIC NOTICE The Federal Emergency Management Agency (FEMA) has received grant applications to fund the construction of several wastewater treatment systems in Monroe County, Florida. Much of the proposed project funding would be provided through FEMA 1249-DR Post Disaster - Unmet Needs funds. Matching funds will be provided through the Florida Division of Emergency Management and local government applicants. FEMA hereby publishes notice of intent to prepare an Environmental Assessment (EA) for these actions, pursuant to the National Environmental Policy Act (PL 91-190) and associated environmental statutes, as implemented in FEMA’s regulations 44 CFR Part 10. This EA will address the purpose and need of the proposed projects, project alternatives considered, affected environment, environmental consequences, and impact mitigation measures. Once completed, the Draft EA will be available for public review and comment. Notice is also published in accordance with Executive Order 11988, Floodplain Management; as implemented in 44 CFR Part 9, since these actions may affect the floodplain. Grant Applicants: • Florida Keys Aqueduct Authority • Islamorada, Village of Islands Proposed Actions: Florida Keys Aqueduct Authority: One grant application proposes a regional wastewater treatment plant on Key Largo. The proposed treatment capacity of this facility is 2.5 million gallons a day. The applicant’s preferred project site alternative is located at Mile Marker 100.5, Oceanside. Two additional grant applications are being developed for small wastewater treatment facilities elsewhere in Monroe County. The details will be published as they become available. Islamorada, Village of Islands: The grant application does not specify the scope of work or project locations. These details are scheduled to be developed in 2001, and will be published as they become available. Comment Period: Comments concerning the proposed projects will be accepted from the affected public; local, state and federal agencies; and other interested parties in order to consider and evaluate the environmental impacts of the proposed projects. Comments should be made in writing, sent to the FEMA point of contact listed below, and postmarked within 30 days of publication of this notice. Points of Contact: • Ms. Science Kilner, Lead Environmental Specialist – Unmet Needs, FEMA Region IV Mitigation Division, 3003 Chamblee Tucker Road, Atlanta, GA 30341-4130 Telephone: (770) 220-5422 Fax: (770) 220-5440 • Mr. Miles Anderson, Planning Manager – Unmet Needs, Florida Division of Emergency Management, 2555 Shumard Oak Boulevard, Tallahassee, FL 32399-2100 Telephone: (850) 922-4442 Fax: (850) 922-0325 • Mr. Roger Braun, Executive Director, Florida Keys Aqueduct Authority, P.O. Box 1239, Key West, FL 33041-1239 Telephone: (305) 296-2454 Fax: (305) 296-3521 • Ms. Zully Williams, Project Manager, Islamorada, Village of Islands, P.O. Box 568, Islamorada, FL 33036 Telephone: (305) 664-2345 Fax: (305) 664-2399 [The above public notice was posted in the Key West Citizen, the Keys Keynoter, and Reporter in August and/or September 2000.] I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ I-1 Appendix J Supporting Information for the Low-Income Demographic Appendix J Supporting Information for the Low-Income Demographic Table J-1: Examples of Costs to Service Recipients Using FEMA’s Assistance Guidelines SYSTEM CAPITAL COSTS $2,500 $3,000 $3,500 $4,000 $4,500 Very-low-income Assistance Amount (90%) $2,250 $2,700 $3,150 $3,600 $4,050 Very-low-income Pays this Amount $250 $300 $350 $400 $450 Low-income Assistance Amount (70%) $1,750 $2,100 $2,450 $2,800 $3,150 Low-income Pays this Amount $750 $900 $1,050 $1,200 $1,350 EXISTING SYSTEM ABANDONMENT/NEW LATERAL INSTALLATION COSTS $1,500 $2,000 $3,000 $4,000 $5,000 Very-low-income Assistance Amount (90%) $1,350 $1,800 $2,700 $3,000 $3,000 Very-low-income Pays this Amount $150 $200 $300 $1,000 $2,000 Low-income Assistance Amount (70%) $1,050 $1,400 $2,100 $2,800 $3,000 Low-income Pays this Amount $450 $600 $900 $1,200 $2,000 *Note: 90% and 70% abandonment and lateral installation assistance is up to an allowance of $3,000. Table J-2: Fiscal Year 2002 – HUD’s Low and Very Low-Income Limits Monroe County, Florida Median Family Income = $55,100 1 person 2 person 3 person 4 person 5 person 6 person 7 person 8 person Low- income $30,850 $35,250 $39,650 $44,100 $47,600 $51,150 $54,650 $58,200 Very- Low- Income $19,300 $22,050 $24,800 $27,550 $29,750 $31,950 $34,150 $36,350 http://204.29.171.80/framer/navigation.asp?charset=utf-8&cc=US&frameid=1565&lc=enus& providerid=112&realname=HUD&uid=2318084&url=http%3A%2F%2Fwww.hud.gov%2F Published annually by HHS. MFI figures are projected from the most recent county level census data. I:\GAITHERSBURG\89-FR954414.00\DRAFT PEA\GTB PEA\DRAFT\DRAFT PEA11.DOC\ J-1 Appendix K Comments on the Draft PEA and Responses APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES TABLE OF CONTENTS 1.0 Introduction.................................................................................................................................K-2 2.0 List of Commenters K-3 2.1 STATE AGENCIES.......................................................................................................K-3 2.2 GROUPS AND INDIVIDUALS....................................................................................K-3 2.3 WORKSHOP PARTICIPANTS.....................................................................................K-3 3.0 COMMENTS AND RESPONSES............................................................................................K-3 3.1 STATE AGENCIES.......................................................................................................K-3 3.2 GROUPS AND INDIVIDUALS....................................................................................K-3 3.3 WORKSHOP PARTICIPANTS.....................................................................................K-9 3.4 WEBSITE.....................................................................................................................K-14 4.0 COMMENT LETTERS ..........................................................................................................K-16 4.1 Letters from Federal, State, and Local Government Representatives and Agencies K-16 4.2 Public Response Letters K-17 APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES 1.0 INTRODUCTION The Draft PEA was made available for public comment during the period of. September 20, 2002 to October 18, 2002, inclusive. Additionally, to further solicit public comments on the Draft PEA, FEMA held two workshops on October 8th and 9th. FEMA received comments from state agencies as well as individuals. Section 2.0 of this Appendix presents a list of those individuals and agencies that submitted comments on the Draft PEA. Section 3.0 of this Appendix includes summaries of comments received on the Draft PEA and responses to those comments. Any comments received after October 18, 2002, will be considered prior to any FEMA action; however, those comments are not included in Appendix K. Copies of all letters received are part of the public record for this project, and are available for viewing on the FEMA Internet Web site at http://www.fema.gov/ep/assess.shtm. Draft Programmatic Environmental Assessment -Appendices Wastewater Management Improvements in the Florida Keys, Florida Prepared For The Federal Emergency Management Agency Region IV 3003 Chamblee-Tucker Rd. Atlanta, GA 30341 Prepared By URS Group, Inc. 200 Orchard Ridge Drive, Suite 101 Gaithersburg, MD 20878 700 South Royal Poinciana Blvd. Suite 1000 Miami Springs, FL 33166 September 20, 2002 APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES 2.0 List of Commenters 2.1 State Agencies Agency Commenter Title ID Florida Division of Historical Resources Janet Snyder Matthews, PhD Director and State Historic S1 Preservation Officer 2.2 Groups and Individuals Commenter Affiliation Title ID Bacchus Sydney, PhD Hydroecologist G1 Niebler-Spare Luciann G2 Wilkinson Jerry G3 2.3 Workshop Participants Commenter Affiliation Title ID October 8th W1 Workshop Participants October 9th W2 Workshop Participants 2.4 Website Commenter Affiliation Title ID Anonymous WS1 Anonymous WS2 Anonymous WS3 Bloding Alison Bio-Microbics Regulatory Affairs Coordinator WS4 Casey Richard Monroe County Housing Programs Administrator WS5 Authority 3.0 Comments and Responses State Agencies S1 Florida Division of Historical Resources (11-Oct-02) Comment Summary S1: The nature and location of some proposed activities in undisturbed areas are such that they could impact historic properties. In accordance with Section 106, the proposed project activities should be submitted to the Division of Historical Resources for review and comment to determine any potential impact on historic properties. Response S1: Comment noted. During the Supplemental Environmental Review (SER) process, proposed project activities would be submitted to the Florida Division of Historical Resources for review and comment prior to the release of FEMA funds. Groups and Individuals G1 Sydney Bacchus, PhD (17-Oct-02) Comment Summary G1-1: Subsection numbers in the Table of Contents do not correspond to the Report, making it difficult to locate information in the Draft PEA Response G1-1: Section references throughout the report have been revised to match the document’s Table of Contents. APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES Comment Summary G1-2: The Draft PEA does not adequately answer the questions posed on the Web site soliciting comments regarding the Draft PEA. There is no scientific basis to support the use of “Improvements” in the Draft PEA title. Response G1-2: As described in the Draft PEA, there are a number of analyses that demonstrate that septic tanks and cesspits contribute to degraded water quality in inland, nearshore and offshore waters of the Keys. These include Lapointe et al. (1990), Lapointe and Clark (1992), Paul et al. (1995a), Paul et al. (1997), Shinn et al. (1994), and EPA (1993a) referenced in Sections 1.4, 1.5, 1.9 and 3. It is generally accepted that the implementation of more stringent water quality standards for discharged effluent would improve water quality by reducing loadings of nitrogen, phosphorus, and fecal coliform bacteria. As described in Section 3.2.2.2.1, these improvements were demonstrated by Ayres and Associates (1998) in the Big Pine Key Demonstration Project. As of result of treating effluent to Florida Statutory Treatment Standards, there was a 92% reduction in Total Nitrogen and 86% reduction in Total Phosphorus to groundwater. Comment Summary G1-3: Extensive comments sent by Lesley Blackner on March 26, 2001 were not considered in the preparation of the Draft PEA. Response G1-3: Although the comments sent by Lesley Blackner were received more than one year prior to the public comment period for the Draft PEA, they were taken into consideration when drafting the PEA. Highlights of Ms. Blackner’s comments include NEPA compliance, concern of wastewater injection into Florida’s aquifers, and consultation with the U. S. Fish and Wildlife Service (USFWS) per the Endangered Species Act (ESA). FEMA published its intent to prepare an Environmental Assessment in Monroe County newspapers in August of 2000. Future notices will be released as FEMA prepares the project and site-specific SERs. The Draft PEA is developed in accordance with NEPA, and includes consultation with USFWS and several other local, regional, state and federal agencies. The list of agencies contacted is located in Appendix G of the Draft PEA. Project and site-specific ESA consultations will be completed as part of the SERs. FEMA completed a formal ESA Section 7 consultation with the USFWS in June of 2001 for a proposed Key Largo wastewater project, the details of which will be released in the SER for that project. Ms. Blackner’s letter also outlines 10 points of concern related to the injection of wastewater effluent. The following sections of the Draft PEA address each point: 1) wastewater movement in Florida’s aquifers (Section 3.1.3); 2) “confining zones” in aquifer layers (Section 3.1.3); 3) flow path of injected effluent (Section 3.1.3); 4) speed of effluent movement into nearshore surface waters (Sections 3.2.2.1 and 3.2.2.2.2); 5) effect of Florida Bay on surface waters (Sections 1.4 and 4.2); 6) effect of Florida Bay on surface waters (Section 1.4 and 4.2); 7) nutrient levels of injected effluent (Sections 1.7, 2.3.2, and 2.3.3); 8) availability of comprehensive studies on fate of aquifer-injected effluent (Sections 3.2.2 and 3.2.3); 9) opinion related to inadequacy of state permitting process (comment noted); 10) opinion related to inadequacy of state permitting process (comment noted). The project- and site- specific effects of this alternative will be analyzed and presented in the SERs. Comment Summary G1-4: Local-government officials are only considering “highly-engineered alternatives without any regard to the direct, indirect, and cumulative environmental impacts of the pre-selected alternatives.” “Islamorada had already published Requests for Proposals (RFP) to convert to the highly-engineered alternatives” being analyzed in the PEA, to which URS submitted a bid (subsequently withdrawn). URS bidding on a FEMA funded project and subsequently recommending to FEMA, as its consultant, this is the preferred alternative, appears to be a conflict of interest. Response G1-4: Pursuant to NEPA, FEMA only requires its applicants to consider one relevant, practicable project alternative, in addition to no action and the preferred alternative. If the APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES commenter is referring to the RFP issued by the Village of Islamorada on March 4, 2000, for a company to design, build and operate a community wide wastewater treatment system, the three firms that submitted proposals were UEM, Inc., Ogden Water Systems and Florida Water Services. The Village has since elected not to pursue this proposal for FEMA funding. The PEA presents alternatives listed in the Monroe County Sanitary Wastewater Master Plan, of which FEMA’s applicants proposed specific alternatives for funding. URS has been tasked to analyze the effects of the projects proposed by Monroe County applicants; it has not been tasked to recommend alternatives. Comment Summary G1-5: “Pre-disposed bias of URS to support and select alternatives that involve injection of waste into Florida’s aquifer system can be found in the background of their ‘Preparers’, who have developed the State of Florida’s rule that allows aquifer-injection of waste.” Response G1-5: FEMA’s applicants selected the project alternatives, including underground injection of wastewater. The preparers of the document were not involved in the State of Florida’s rule on aquifer injected wastewater; however, selected technical peer reviewers of the PEA so have this experience and were chosen due to their subject matter expertise. FEMA independently verified the information and analyses in the PEA, and made its own conclusions. Also note response to G1-4 above. . Comment Summary G1-6: FEMA should obtain an opinion from the Department of Justice regarding whether it is legal for a firm such as URS, (which previously attempted to secure contracts for activities they later selected as ‘recommended alternatives’ for the funding agency’s Draft EA), to be hired by federal agencies to prepare EAs or related documents, particularly since they will provide additional contract opportunities for their firm in the future.” Response G1-6: Refer to response G1-4. Comment Summary G1-7: In a previous project for the SunCoast Parkway, URS has admitted to “falsifying and fabricating information that was contained in their review document.” FEMA should obtain an opinion from the Department of Justice whether it is legal for a firm such as URS, which has admitted to falsifying and fabricating information, should continue to prepare evaluation documents. Response G1-7: The URS staff who prepared much of this PEA were not involved in the case in question. FEMA independently verified the information and analyses in the PEA, and drew its own conclusions. Comment Summary G1-8: “Page Ab-1 of the Draft Problematic EA Abstract states that a ‘supplemental environmental review (SER) document (i.e., Supplemental Environmental Assessment of the Environmental Impact Statement) would be prepared for each individual project covered by this draft PEA’. This piecemeal approach of ‘assessment’ ensures that the full direct, indirect, and cumulative impacts on the environment of the ‘Unmet Needs’ funding cannot and will not occur. As only one example, the entire EA focuses solely on the Keys (Monroe County). In reality, the water that is combined with human excrement, to create the so-called ‘wastewater’, is imported into the Keys. The invaluable water resource that is converted into ‘waste’ in the Keys is extracted from the aquifer that supports the Florida Everglades. Therefore, the proposed alternative would result in significant adverse impacts to all of the counties associated with the Everglades, as well as the entire national and international tourist industry associated with the Everglades. Those factors are not addressed in the Draft Problematic EA. The enclosed copy of the 1/97 Report describes the types of Cumulative Impacts considered under NEPA and the protocol for conducting a Cumulative Impacts Analysis.” APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES Response G1-8: The intent of the PEA is to examine the effects of Keys wastewater treatment alternatives directly, and indirectly where appropriate, and when combined with past, present, and foreseeable future projects affecting the same resources. Section 4 of the DPEA examines cumulative effects. Section 1.4 of the DPEA introduces the sources of nearshore water quality degradation in the Keys, followed by a more detailed discussion in Section 3.2.3. Regardless of how the wastewater is treated, water usage will not change as a result of the proposed alternatives. Comment Summary G1-9: “The abstract of the EA clearly illustrates that only highly-engineered alternatives were considered. A comprehensive Environmental Impact Statement (EIS) and Cumulative Impact Analysis need to be conducted by knowledgeable scientists (e.g. National Academy of Sciences) without a pre-disposition to highly-engineered alternatives.” Response G1-9: As discussed in Section 2.2 of the PEA, the alternatives presented in the document parallel alternatives studied and approved for consideration by Monroe County in their Sanitary Wastewater Master Plan. The purpose of the PEA is to evaluate the environmental impact of alternatives, not to formulate project alternatives. The decision-making process for wastewater management began in 1997 with the preparation of the Master Plan, involved a comprehensive evaluation and prioritization of many variables, and included considerable public participation opportunities. Representatives from a citizens task force, a technical advisory committee, Board of County Commissioners, and community representatives developed models and considered the alternatives in terms of cost, technical feasibility, performance, environmental impacts, potential for service disruption, reliability, implementation, and strength and weaknesses in order to evaluate alternatives. The results of this model were used to recommend the most appropriate alternatives for implementation in Monroe County. These alternatives are also presented in this PEA as proposed alternatives for FEMA funding, and for evaluation under NEPA. The alternatives discussed in this document support established Federal, State, and county objectives by presenting and evaluating alternate methods of wastewater collection and disposal. Comment Summary G1-10: “Under ‘Topography, Soils, and Geology’: sinkholes are referenced to as a potential effect of aquifer injection, but no reference to the extensive dissolution of the aquifer matrix, a near-certain response, is mentioned.” Response G1-10: Although the text does not use the term aquifer matrix, it describes the dissolution of carbonate rock, which, as discussed in Section 3.1.3.1, is the predominant rock type underlying the Florida Keys, and hence, comprising the aquifer. The impact and potential extent of dissolution would be addressed in the site specific SERs once the projects’ location and magnitude of these projects are determined. As stated in Section 3.1.3.2.2, “to mitigate the potential effects of limestone dissolution on shallow well design and function, appropriate geotechnical studies would be conducted by the applicant prior to design and construction to adequately characterize the geological and geotechnical environment. The SER would incorporate the data, results, and design measures as appropriate to fully discuss effects on geology.” Comment Summary G1-11: “There is no scientific basis for the claim under the Water Resources & Quality section.” Response G1-11: Information contained Section 3.2, Water Resources and Water Quality, was obtained from scientific articles, technical advisors, state and local government agencies, and websites such as: APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES Florida Keys National Marine Sanctuary (FKNMS). 2001. Water Quality Protection Program Overview. Accessed from www.fknms.nos.noaa.gov/research_monitoring/wqpp.html on August 9, 2001. Halley, R.B., Vacher, H.L., and Shinn, E.A., 1997, Geology and hydrology of the Florida Keys in Geology and Hydrology of Carbonate Islands, Developments in Sedimentology 54, pp. 217-248. Elsevier Science B.V., Amsterdam. Kruczynski, William. 1999. Water Quality Concerns in the Florida Keys: Sources Effects, and Solutions. Florida Keys National Marine Sanctuary Water Quality Protection Program, National Oceanographic and Atmospheric Administration. Jones, Ronald and Joseph Boyer. 2001. Water Quality Monitoring Project: FY 2000 Annual Report. Published by the Southeast Environmental Research Center, Florida International University under contract to the EPA. Leckler, Kurt. 2001. Permit Compliance Specialist, South Florida Water Management District. Personal communication with Jonathan Randall, URS Group, Inc. Monroe County. 1997. Monroe County Year 2010 Comprehensive Plan. Adopted by the Monroe County Board of County Commissioners, Department of Community Affairs and Administration Commission of the State of Florida. September. Comment Summary G1-12: “There is no scientific basis for the claim under the first two sentences of the Biological Resources section in the Abstract. The claim in the third sentence of this subsection regarding activities occurring on developed, disturbed areas with low habitat values is without basis. Proposed sites in Key Largo and Islamorada, in addition to the withdrawal sites, all involve direct, indirect, and cumulative impacts to a myriad of federally and state listed species.” Response G1-12: The scientific basis for the claims in the Abstract is provided in detail in Section 3.3.2. Biological Resources. Habitat values and concerns with state and federal listed species for individual sites, including impact minimization measures, will be further addressed during the SER process. Comment Summary G1-13: “The ‘Air Quality’ section fails to consider impacts from phtyotoxins released into the air after planktonic algal blooms that can be triggered by induced discharge of injected effluent surface waters.” Response G1-13: The research indicates that toxins generated by planktonic algae, such as the primary toxin found in the Florida Red Tide, can act as eye and throat irritants when the toxins become aerosols as a result of wave action. Algal blooms are formed from a variety of contributing factors such as temperature, salinity, currents, and nutrients1. A major function of the projects proposed in this Draft PEA is to bring presently inadequate wastewater systems (e.g., septic tanks and cesspits) into compliance with Florida Statutory Treatment Standards. It is expected that this would greatly reduce the nutrients entering nearshore and offshore waters. Comment Summary G1-14: “The ‘Demographic and Environmental Justice’ section fails to consider direct, indirect, and cumulative adverse impacts on surrounding, low-income areas where sludge (generated by the selected alternative) would be dumped and groundwater mining is continued.” 1 National Oceanic and Atmospheric Administration (NOAA). 2002. Algae Info. Accessed from http://www.chbr.noaa.gov/CoastalResearch/algaeInfo.htm on December 16, 2002. APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES Response G1-14: Comment noted. As described in Response G1-8, none of the alternatives are expected to increase groundwater mining. Section 2.3.2 of the Draft PEA outlines the anticipated disposal methods of sludge created by the proposed projects. Sludge would likely be hauled to a regional wastewater treatment facility in Miami-Dade County for treatment and then used for fertilizer. The Key West WWTP dewaters partially stabilized secondary solids, which are disposed of via private hauler at an agricultural land application site near Okeechobee, Florida. The disposal of sludge in this manner is not anticipated to result in adverse and disproportionate impacts to low income or minority populations. Comment Summary G1-15: The Hazardous Materials section fails to consider nonylphenol, an endocrine disrupter hazardous to animals, creation by the AWT process. Response G1-15: The research indicates that nonylphenol is a degradation product of a surfactant widely used for commercial and industrial purposes such as detergents, herbicides and cosmetics and the manufacturing of plastics, textiles, agricultural chemicals and paper. Nonylphenol formation can occur through wastewater treatment and in natural environments. In wastewater treatment processes, it may be formed regardless of whether the waste stream is processed by AWT2. The EPA is currently in the process of developing aquatic life criteria for nonylphenol3. Once the criteria is finalized, proposed wastewater systems would be required to comply with State processing and monitoring standards, as applicable. Before formal rules are established, the project applicant would be required to coordinate with FDEP to implement any monitoring protocols that were deemed necessary. Section 3.8 of the Draft PEA has been updated to include this information and coordination/monitoring requirement. Comment Summary G1-16: Letters sent to the EPA and publications from 1996-2002 documents my assertions above that the PEA is “grossly inadequate and a comprehensive EIS and Cumulative Impacts Analysis need to be conducted by knowledgeable scientists (e.g., National Academy of Scientists) prior to the release of federal funds from your agency for wastewater- related activities in Monroe County.” Response G1-16: Section 1.2 of the PEA outlines FEMA’s NEPA review process. In determining the appropriate level of NEPA review for the proposed actions, FEMA’s criteria for when to prepare an Environmental Impact Statement (EIS) were applied, and are found in its NEPA implementing regulations at 44 C.F.R Part 10.8(b). At that time, FEMA determined there was insufficient information about the group of projects to satisfy the criteria for an EIS level of analysis, and elected to prepare a PEA to determine if the group of projects required an EIS. Comment Summary G1-17: “No zero-discharge alternatives were considered in the PEA…Practicable, economical, readily-available alternatives to the generation of sludge were not considered in the Draft Problematic EA.” Response G1-17: FEMA’s applicants may legally propose any practicable project alternatives. As noted in Response G1-9 and discussed in Section 2.1 of the PEA, the alternatives considered come from the Monroe County Sanitary Wastewater Master Plan. FEMA’s applicants may need to be contacted regarding alternatives reconsideration. Comment Summary G1-18: “In situ, phyto-treatment systems also were not considered. Likewise, economical, practical, and readily-available alternatives for reducing pollution from stormwater (e.g. in-line filters) also were not considered.” 2 Maguire, James R. 1999. Water Quality Research Journal of Canada. 3 U.S. Environmental Protection Agency (EPA). 2002. Water Quality Criteria: Nonylphenol. Accessed from http://www.epa.gov/waterscience/criteria/aqlife.html on December 16, 2002. APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES Response G1-18: See Responses G1-17 and G1-8. The projects under consideration are for wastewater management only and not for stormwater management. None of the proposed projects include combined injection of treated wastewater and stormwater. The cumulative effects to water quality from improved stormwater and wastewater management practices are discussed in Section 4 of the PEA. Comment Summary G1-19: “Figures 1-2 and 2-5 are an overly simplistic and highly misleading graphic of the aquifer where effluent is proposed to be injected. In reality, the aquifer is characterized by both dissolution features and fractures that result in a highly permeable matrix with many preferential flow-paths for the migration of injected effluent and other contaminants such as stormwater.” Response G1-19: The intent of Figures 1-2 and 2-5 is to simply illustrate the wastewater treatment process for each alternative; it is not intended to illustrate aquifer characteristics. Section 3.1.3 discusses the aquifers’ characteristics in detail and has several figures illustrating their characteristics, including Figures 3-2 to 3-5. Comment Summary G1-20: “Figure 3-6 illustrates that the Study Areas are confined to the exposed land form of the Keys, excluding coastal waters such as the Marine Sanctuary and the peninsular of Florida, both of which would be affected by the implementation of the Proposed Alternative.” Likewise, the PEA does not consider water quality degradation factors exterior to the Study Area. Response G1-20: Figure 3-6 represents stormwater study areas and not wastewater study areas. The scope of the PEA’s study area has been clarified in Section 1.2 and is represented in Figure 1-1. Project and site-specific study areas and areas of effect would be more clearly delineated in the SER process. As noted in Response G1-8 water quality degradation factors external to the Key are discussed in Sections 1-4 and 3-2-3. Comment Summary G1-21: “No figures (or other information) were included to show the location of all of the existing and proposed shallow and deep injection wells in south Florida, or even Monroe and the adjacent counties…Likewise, there were no figures indicating the location and nature of the supply wells for the Key’s waste water.” Groundwater mining has been described and documented in published literature, but was not addressed in the Draft PEA. Response G1-21: The Florida Department of Environmental Protection’s Underground Injection Control Program and county health departments maintain information on permitted shallow and deep injection wells. As described in Section 3.2.2.1 and Kruczynski (1999), there are about 750 Class V wells currently permitted in the Keys. Including a graphic in the PEA delineating the location of all permitted wells in the Keys is not practical considering the number of wells. The SERs will include information on existing permitted wells within their service area and may include a graphic showing their distribution. Please refer to Response G1-8 for groundwater mining comment. Comment Summary G1-22: A large percentage of the references are personal communications. Many of the references in this PEA are documents other than publications in recognized, peer- review journals. Consequently, the References section is severely lacking in both the nature and number of references. Response G1-22: It is the nature of the NEPA process to draw from a number of acceptable sources, including peer-reviewed academic journals, government reports, and communication with experts knowledgeable in their field, commensurate with an ‘Environmental Assessment’ level of analysis. FEMA’s NEPA implementing regulations at 44 CFR Part 10.9 outline preparation of EAs. The reference section in the PEA is explicitly designed to present the source of information that is referenced in the body of the document. APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES G2 Luciann Niebler-Spare Comment Summary G2-1: “What effluent is going to be going down the shallow wells and then into Florida’s Outstanding Waters? Also, how much fresh water effluent will be moving up vertically into the saline waters of the oceans, bays, and canals?” Response G2-1: The amount of effluent will depend on the site location and disposal alternative chosen for each site. Therefore, this concern will be further analyzed in the SER process. Comment Summary G2-2: “Maybe there should be an experiment between septic systems in the area and injection wells. That might be interesting and worthwhile.” Response G2-2: For clarification, it should be noted that many septic systems in the Keys currently use injection wells for disposing of untreated wastewater effluent. An alternative to the use of injection wells is the use of septic drain fields. As described in Section 2.4.2, the problem with installing septic tanks with drain fields in the Keys is that very little or no natural soils exist over the ancient coral/limestone rock, and soil must be imported to construct these systems. The limited soils in the Keys thus reduce the treatment effectiveness of these systems, especially for nutrients. Appendix D of the Draft PEA includes a comparison of the quality of effluent treated to Florida Statutory Treatment Standards as compared to a septic system. Comment Summary G2-3: “There are 554 shallow injection wells in Monroe County. They are permitted and then they are on their own, as there is no single map that shows the location of these wells.” Response G2-3: The available research indicates that there are about 750 shallow injection wells in the Keys [Section 3.2.2 of the Draft PEA and Kruczynski (1999)]. Comment noted with respect to the single map that shows the location of the wells. Comment Summary G2-4: “There needs to be some overall management of the wells regarding their placement and the results of each project.” Response G2-4: Please refer to Response G1-21 for injection well management. In approving project funding, FEMA plans to strongly encourage its applicants to implement a water quality monitoring program for each project (see Sections 3.2.2.2.2 and 3.2.2.2.3). Comment Summary G2-5: Please look into the possibility of reuse with ultra-violet disinfection. Response G2-5: Comment noted. Also, please see Response G1-9. Comment Summary G2-6: “In Islamorada, we are very concerned with the potential price tag of a sewage treatment plant for the whole island (Four islands are involved). There are many worried citizens who feel that the village manager and council are trying to move too quickly and are not making a realistic effort to show the true costs involved or to investigate all possible solutions.” Response G2-6: The currently proposed Islamorada project only serves one neighborhood. The economic effects of the project will be presented in the project and site specific SER, however the costs per EDU are expected to be within the range presented in Section 3.6.3.2. G3 Jerry Wilkinson (4-Oct-02) Comment Summary G3-1: Problem with the degrading of terrestrial environment at the expense of a small potential enhancement of the marine environment. Land should be used for conservation purposes only. APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES Response G3-1: The project and site-specific SER will evaluate effects to both the terrestrial and marine environments, including impact mitigation measures. Comment Summary G3-2: “The proposed and purchased 20 acres is about pristine of Key Largo hammock as exists today. It has been on the CARL acquisition list and is contiguous to a flyway area to its east. All suggestions for the use of the state and federal lands to the north have been rejected. Does private ownership make this parcel any less qualified for preservation?” Response G3-2: Land decisions are made at the county level, and county representatives should be contacted regarding site selection. FEMA’s applicants may propose any relevant, practicable project alternatives, including site selection. FEMA cannot require applicants to propose additional alternatives if they have already proposed enough relevant, practicable alternatives. Comment Summary G3-3: “The present day stated four acres is only hypothetical as if the FKAA proposed Request for Proposals is approved to construct a community WWTP on 2 acres, the expansion to the future 2.25 mgd regional WWTP will be either impossible or additional acreage must be cleared.” Response G3-3: This concern would be further analyzed during the SER process, when the location and magnitude of individual projects would be specified. Comment Summary G3-4: “I suggest this parcel be accepted as mitigation for some other lesser violation. Other parcels of land can be found. To follow chapter 7 of the Monroe County Sanitary Master Plan, 10 to 12 other parcels must be acquired on Key Largo; therefore, if only one is available, we might as well throw in the towel.” Response G3-4: The County’s site selection process will be presented in the project and site- specific SER. Workshop Participants W1 Workshop Participants (8-Oct-02) Comment Summary W1-1: Status of mile marker 100.5? What about FEMA funding relative to this project's sunset date? Response W1-1: This concern relates specifically to the Key Largo project and would be further considered at the SER level. Comment Summary W1-2: How can we get both projects in Key Largo moved up so that we do not lose funding for both? Response W1-2: Funding timelines are at the discretion of state and federal funding agencies. Comment Summary W1-3: Could FEMA environmental requirements stop this project after the "road to nowhere" has been built? Response W1-3: Federal environmental compliance and state and local permitting requirements for specific projects would be outlined during the SER process. Receipt of federal funding is conditioned on the applicants implementing all required impact mitigation measures and obtaining applicable permits before starting work. . Comment Summary W1-4: The project footprint for the project keeps changing. Where will the project be (the 3-acre site)? I have seen three different footprints for it. Monroe County code lets you clear 20% of the site, and I have seen various numbers for that too – 4.6% etc. because we are now looking at some private property. The footprint seems to have changed since we got the information from Fish and Wildlife. APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES Response W1-4: The size and siting of projects would be specified during the SER process. Comment Summary W1-5: Is the environmental assessment comprehensive enough that if we want to expand this project to more than three acres, we do not have to do another environmental assessment? Response W1-5: Yes, as far as the alternatives presented in the PEA are concerned. However, the SER process evaluates a specific scope of work and its alternatives; and prescribes impact mitigation measures. If a scope of work changes substantially, the environmental analysis must be revised. Comment Summary W1-6: Many people still question the science of central treatment, especially when you consider the cost. Is there any plan to do follow-up studies so that at the conclusion of this 20-year project we can say, "we spent the money, we did what we were supposed to do, and it worked"? Response W1-6: The Draft PEA recommends water quality monitoring be conducted following implementation of the proposed projects in Sections 3.2.2.2.2 and 3.2.2.2.3. Comment Summary W1-7: Will there be interim studies so that if we get to a point at which we have several plants in populated areas, we can say, "It doesn't really make sense to continue this process – on a cost-benefit basis we have solved the problem – and on-site systems are okay for the rest of the Keys"? Response W1-7: No such interim studies have been planned at this time. Implementation of the Monroe County Sanitary Wastewater Master Plan is the responsibility of the Florida Keys Aqueduct Authority and Key Largo Wastewater District, along with determining if Plan goals have been accomplished by mandated deadlines. Comment Summary W1-8: What median household income was used in the economic part of the study? The census says $36,000 and some. With 42% of children in Largo school system on the free lunch program, how do we justify an extra $58/month? This is a serious economic impact to the average family. Response W1-8: The median household income (MHI) figure of $42,283 as cited in Section 3.6 was taken from the 2000 census (Table DP-3. Profile of Selected Economic Characteristics: 2000 – Geographic Area: Monroe County Florida). Comment Summary W1-9: How does your study try to prove this is an acceptable impact? Response W1-9: Sections 3.6.3 and 3.7.1.2 of the PEA detail the economic impacts and supports the claim that the impact is acceptable in two ways. First, 2% of MHI is cited as the affordability threshold for wastewater costs as established by the U.S. Environmental Protection Agency and by the National Consumer Law Center. Second, an assessment of the estimated average monthly costs for household expenses in the Keys (see Section 3.6.3.1.2) was done to calculate discretionary income and it was determined that 2% of MHI constituted approximately 7% of discretionary income for households at the median income. As 2% of MHI was only 7% of discretionary income, for median and higher level income households, the 2% figure was concluded to be affordable. The analysis of low-income and very-low-income households showed that the impact was indeed unacceptable and therefore assistance guidelines were developed. The low-income assistance program provides 70% assistance for System Capital Costs; and 70% of assistance for Existing System Abandonment and lateral costs up to an allowance amount of $3,000. The very-low-income assistance program provides 90% assistance for System Capital Costs; and 90% assistance of Existing System Abandonment and lateral costs up to an allowance amount of $3,000. Comment Summary W1-10: Where did your income and average cost figures come from? APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES Response W1-10: Income figures were obtained from the 2000 U.S. Census: Profile of Selected Economic Characteristics for Monroe County, Florida, Poverty 2000, and Money Income in the United States: 2000, Current Population Reports and also from HUD: Fiscal Year 2002 Low and Very Low Income Limits. Average cost figures came from the sources cited in Table 3-6, as described in the paragraph below the table, with the details of each source listed in the corresponding citation in Section 7: References. Comment Summary W1-11: Will this study be the basis for us to support the assistance we are going to seek? Response W1-11: The low income assistance guidelines presented in the PEA apply only to the FEMA funded projects. Comment Summary W1-12: Does operation and maintenance cover all administrative costs? Response W1-12: For the purposes of the PEA, yes, it covers all administrative costs. Comment Summary W1-13: What if the applicants do not provide low-income assistance? Response W1-13: To be eligible for FEMA funding, the applicants will be required to, at a minimum, provide the assistance levels outlined in the PEA (Section 3.7.1.5) for low-income and very-low income qualified families. If the applicants do not comply, they would not receive for FEMA funding. Comment Summary W1-14: Where do the FEMA dollars for this come from? Response W1-14: Under the Emergency Supplemental Appropriations Act for Fiscal Year 1999, funding for long-term disaster recovery projects in Florida counties whose needs were unmet through primary disaster relief funds, was made available. As a result, Monroe County is eligible for “Unmet Needs” funding from FEMA. Comment Summary W1-15: Will low-income assistance be subtracted from the grant money? How much of a reduction will that be? Response W1-15: Yes, the low income assistance would come from the grant funds. The proportion of grant funding earmarked for low income assistance will depend how many project service area households qualify for assistance. Comment Summary W1-16: Tell us about the Key Largo project specifics, if you have any information. Response W1-16: The project specifics will be provided during the SER process. Comment Summary W1-17: How many dollars do we have and how much money is needed to meet the needs of low-income families? Is there enough to take care of the number of people who need it? Response W1-17: The exact figures of how much funding will be required for low-income families will be determined in the SER process. Using very liberal estimates on percentages of low-income and very-low-income households, based on census data for Monroe County, preliminary estimates indicate that there is enough grant funding to assist low-income households at the prescribed levels. Comment Summary W1-18: If applicants have to provide this level of assistance in order to get FEMA dollars, who determines the level of assistance? Response W1-18: The required levels of assistance were determined by FEMA. Please see Section 3.7.1.5 in the PEA. APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES Comment Summary W1-19: How do assets play into the income qualification criteria? Are there any limits on assets? Response W1-19: As per HUD’s policy, only the interest made on assets is counted as income. The actual value of the asset is not counted and has no bearing on income qualification. Comment Summary W1-20: I do not agree that $75/month is an acceptable or affordable price, no matter what your median income. It is too high. Response W1-20: As noted in Response W1-9, the Environmental Protection Agency, Department of Housing and Urban Development, and the National Consumer Law Center all use a percentage of median household income as their measure of affordability. Establishing affordability thresholds is also at the discretion of local authorities, in fact the Monroe County Board of County Commissioners has previously passed resolutions addressing this. Accordingly, FEMA applicants may increase the level of assistance per EDU, however, the amount of FEMA grant funding is limited to the amount in the respective original grant applications. Comment Summary W1-21: Does the $75 include all components of the cost – capital, operations and maintenance, and lateral and abandonment? Response W1-21: Yes, it includes all of those components, but the $75 is not a final figure for every project area. It is a general estimate pertaining to all of the project areas and the final figure could be slightly lower or slightly higher for the individual sites. Comment Summary W1-22: Can you tell us about funding sources other than this FEMA grant? What funding is available for all proposed projects? Response W1-22: Please see Appendix H: Funding and Financing Options in the PEA. Comment Summary W1-23: Why should we borrow money from FEMA at 6%? It would be cheaper from the state revolving fund at 3% for non-assisted hook-up costs. Response W1-23: FEMA funding is a grant, rather than a loan. Comment Summary W1-24: Why not reduce the boundary of the project and have no hook-up fees – only operations and maintenance costs – within the parameters of FEMA funding. Why don't we do just what the FEMA grant will allow us to do? Response W1-24: The scopes of the various projects are determined by the applicant, not by FEMA. The question would need to be raised with the applicant. Comment Summary W1-25: Equity is a big issue and concern – the cost impacts to citizens. Response W1-25: Issues of equity and cost impacts to service recipients have been outlined in detail in Sections 3.6.3 and 3.7.1.2. Comment Summary W1-26: Does the report (the DPEA) address which option or system is better for the project? If it is not in this report, is there some sort of consumer report about which system is better than others? Response W1-26: The question of which wastewater system is better for the project is beyond the scope of the PEA. The alternatives are derived from the Monroe County Sanitary Wastewater Master Plan, which does evaluate which system alternatives are most suitable. Comment Summary W1-27: There is a concern about the fact that the assessment is based on County's master plan. The information may be old and inaccurate. We need an independent analysis to verify the assumptions used in the PEA. APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES Response W1-27: The PEA is based on the County’s Sanitary Wastewater Master Plan that was published in June 2000, and is the most current wastewater planning document available for Monroe County. However, it is the applicant’s discretion to sponsor further study of alternatives. Comment Summary W1-28: Regarding operations and maintenance costs, we need to evaluate which system is less expensive and more efficient to operate to help make good decisions. Response W1-28: That is beyond the scope of this PEA. NEPA requires evaluation of the impacts to the environment of the three project alternatives proposed, but not of which is most efficient or cost-effective; also see Responses G1-9 and W1-27. Comment Summary W1-29: We don't have a wide choice in systems. The RFP has limited our choices. Response W1-29: The system alternatives in RFP packages are consistent with the FEMA funding grant application scope of work. Comment Summary W1-30: Candidates for the Wastewater Board should study the science in order to prepare themselves to sit on the Technical Evaluation Panel (TEP). Response W1-30: Comment noted. Comment Summary W1-31: Regarding the proposed site at mile marker 100.5, we are trading adverse impacts on the terrestrial environment for benefits to the marine environment. Even considering that the site was probably scarified at one particular time, it is still what we would now call high quality hammock land. We need to consider the terrestrial environment to the same degree as the marine environment. Response W1-31: This concern would be further analyzed during the SER process, when project locations would be specified. Comment Summary W1-32: When will the public meetings be for the site-specific projects? Response W1-32: Dates would be determined based upon the completion of each individual draft SER. Comment Summary W1-33: Will a statement be made relative to the overall environmental improvements (i.e., that the benefit to water quality is more important than the adverse effects on wood rats)? Response W1-33: Impacts on both biological resources and water quality will be considered at the SER level. As part of its obligations under Section 7 of the Endangered Species Act, FEMA will consider impacts to special status species and make efforts to avoid and/or minimize impacts to these species. Note that it is beyond the scope of the NEPA documents to make statements of opinion regarding the acceptability or relative value of environmental tradeoffs. APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES W2 Workshop Participants (9-Oct-02) Comment Summary W2-1: When a treatment plant is put in on Conch Key, will residents be able to get a septic or cesspit credit? Response W2-1: No, septic/cesspit credits would not be used in project areas. Comment Summary W2-2: Given our topography and geology, will effluent (which is freshwater) placed in shallow wells come back up in canals, ocean, etc.? Is this a concern? Will this be tracked? Response W2-2: If shallow injection is identified as an alternative method of wastewater disposal for a specific wastewater treatment facility, the effects of this alternative will be analyzed and presented in the SER for that specific facility. Sections 3.1.3 and 3.2.2.1 provide a detail discussion on the Keys geology and the effects of injecting treated effluent, in terms of hydraulic conductivity. Injected treated effluent will eventually surface in nearshore waters, including canals, as it currently does; although it would be treated to much more stringent standards than present. Comment Summary W2-3: How will variation in operations and maintenance costs among possible technologies that may be proposed are taken account of in bid evaluation process? I see this as a huge issue for a small community system as is being proposed for Conch Key. Response W2-3: This issue would need to be addressed by the applicant. Comment Summary W2-4: Where can we get more information about possible technologies? Response W2-4: Please refer to Response G1-9 and information on various wastewater treatment systems can be found on the internet, at the library or obtained from technical experts (e.g., wastewater engineers). Comment Summary W2-5: Purestream literature suggests a large difference in operations and maintenance costs between upflow sludge blanket filter systems and sequencing batch reactor systems. Response W2-5: Technology alternatives should be brought to the attention of the applicant. Comment Summary W2-6: Will the government require three separate bids when you get to site specific steps? Response W2-6: Yes, projects must be competitively bid. . Comment Summary W2-7: What role does FEMA play in overseeing projects once funding is provided? We have seen projects in the Keys with significant management problems. If FEMA is providing funding, is there any additional assurance for those of us on projects with FEMA funding that costs etc. will be managed better for us? Response W2-7: Applicants are responsible for project facility maintenance. FEMA has no long-term oversight in project facility maintenance. Comment Summary W2-8: We need sewage treatment. Response W2-8: Comment noted. Comment Summary W2-9: Is there a sampling point anywhere near Conch Key for fecal coliform? Where is the closest monitoring point? APPENDIX K COMMENTS ON THE DRAFT PEA AND RESPONSES Response W2-9: The closest monitoring site is maintained by Florida International University (No. 244) just northeast of Conch Key, off US 1 (http://serc.fiu.edu/wqmnetwork/FKNMSCD/ midkeys.htm). However, fecal coliform is not monitored at this station. Comment Summary W2-10: Has there been any interest here in ultraviolet ray disinfection? Water returned after this treatment would be less harmful to corals. Response W2-10: The purpose of the PEA is only to evaluate alternatives, not develop alternatives. Please see Response G1-9. The specific disinfection alternatives will be presented in the SER process. Website Comment Summary WS1-1: The only question we have concerns the choice to dismiss the STEP system as an alternative. The fact that each home has a pump should not be something that would eliminate it from consideration. When combining these types of systems with responsible management entities (RMEs) as described in EPA's management guidelines for onsite systems, they can be cost effective and reliable systems. We ask that you reconsider this decision. Response WS1-1: Please see Response G1-9. Comment Summary WS1-2: Overall, a very well written, informative document. Response WS1-2: Comment noted. Comment Summary WS1-4: The ER establishes very low-income as incomes less than 50% of Median Family Income (MFI) and low-income as up to 80% of MFI. Further, the ER establishes Monroe County MFI at $55,100. This is consistent with the most recent annual estimate published by US HUD. Based on these definitions, Monroe County's very low-income households would be those earning no more than $27,550 and low would be earning no more than $44,080. I believe that the ER miscalculates these income maximums as $24,800 and $39,650 respectively. Response WS1-4: The Monroe County MFI of $55,100 is the average figure published by HUD and covers all family sizes. HUD publishes the adjusted values of MFI for each family size and you are correct in noting that the figures of 50% and 80% do not calculate directly from the $55,100. The income maximums of $24,800 for very-low-income and $39,650 for low-income come directly from HUD’s table of adjusted figures for a family of 3 and are not calculated in the PEA. In response to your comment, we have clarified this point in the document.