DRAFT  
SUPPLEMENTAL ENVIRONMENTAL ASSESSMENT



Proposed Wastewater Treatment System for  
Bay Point and Saddlebunch Keys,
Florida Keys Aqueduct Authority,
Monroe County, Florida



 






Prepared for
Federal Emergency Management Agency
Region IV
3003 Chamblee-Tucker Rd.
Atlanta, GA 30341



Prepared by
URS Group, Inc.
200 Orchard Ridge Drive, Suite 101
Gaithersburg, MD 20878

700 South Royal Poinciana Blvd. Suite 1000
Miami Springs, FL 33166


November 18, 2003



ABSTRACT	Ab-1
SECTION 1 	INTRODUCTION	1-1
1.1	PROJECT AUTHORITY	1-1
1.2	RELATED ENVIRONMENTAL DOCUMENTS	1-1
1.3	PROJECT LOCATION	1-1
1.4	PURPOSE AND NEED	1-3
SECTION 2 	ALTERNATIVES ANALYSIS	2-1
2.1	ALTERNATIVE 1 – NO ACTION ALTERNATIVE	2-1
2.2	ALTERNATIVE 2 – NEW WASTEWATER TREATMENT PLANT CONSTRUCTION 
(PROPOSED ACTION)	2-1
2.2.1	Wastewater Collection and Transmission System	2-3
2.2.1.1	Collection System	2-3
2.2.1.2	Transmission System Components	2-3
2.2.2	Wastewater Treatment Plant	2-5
2.2.2.1	Site Description	2-5
2.2.2.2	System Components	2-5
2.2.2.3	System Operation	2-6
2.2.2.4	Effluent Disposal	2-8
2.2.3	Construction Activities	2-8
2.2.4	Operation and Maintenance	2-9
2.3	ALTERNATIVE 3 – EXISTING PLANT UPGRADE AND EXPANSION AND NEW 
WASTEWATER TRANSMISSION SYSTEM CONSTRUCTION (ACTION ALTERNATIVE)	2-9
2.3.1	Wastewater Collection and Transmission System	2-9
2.3.1.1	Collection System	2-9
2.3.1.2	Vacuum Pump Station	2-10
2.3.1.3	Transmission System Components	2-12
2.3.2	Existing Key West Resort Utilities Wastewater Treatment Plant	2-12
2.3.3	Construction Activities	2-13
2.3.4	Operation and Maintenance	2-14
2.4	ALTERNATIVES CONSIDERED BUT ELIMINATED FROM FURTHER CONSIDERATION	2-14
SECTION 3 	AFFECTED ENVIRONMENT AND ENVIRONMENT CONSEQUENCES	3-1
3.1	TOPOGRAPHY, SOILS, AND GEOLOGY	3-1
3.1.1	Topography	3-1
3.1.2	Soils	3-1
3.1.3	Geology	3-3
3.2	WATER RESOURCES AND WATER QUALITY	3-4
3.2.1	Groundwater	3-4
3.2.2	Inland, Nearshore, and Offshore Waters	3-6
3.2.2.1	Inland Waters	3-6
3.2.2.2	Nearshore and Offshore Marine Waters	3-6
3.2.2.3	Stormwater	3-7
3.2.3	Floodplains and Wetlands	3-8
3.2.3.1	Floodplains	3-8
3.2.3.2	Wetlands	3-9
3.3	BIOLOGICAL RESOURCES	3-11
3.3.1	Terrestrial Environment	3-12
3.3.1.1	Pine Rocklands and Tropical Hardwood Hammocks	3-14
3.3.1.2	Mangrove Forests and Salt Marshes	3-14
3.3.1.3	Freshwater Systems	3-14
3.3.1.4	Dunes and Coastal Ridges	3-14
3.3.2	Aquatic Ecosystem	3-14
3.3.2.1	Seagrass Beds and Sand Flats	3-15
3.3.2.2	Coral Reefs	3-16
3.3.2.3	Hardbottom	3-16
3.3.2.4	Sandy Bottom	3-16
3.3.2.5	Alternative 1 – No Action Alternative	3-16
3.3.2.6	Alternative 2 – New Wastewater Treatment Plant Construction	3-17
3.3.2.7	Alternative 3 – Existing Plant Upgrade and Expansion and New Wastewater Transmission 
System Construction	3-17
3.3.3	Special Status Species	3-18
3.4	AIR QUALITY	3-19
3.5	CULTURAL RESOURCES	3-20
3.6	SOCIOECONOMIC RESOURCES	3-22
3.6.1	Tourism	3-22
3.6.2	Fishing Industry	3-23
3.6.3	Local Fees and Taxes	3-23
3.6.3.1	Existing Wastewater Management Costs in the Bay Point Service Area	3-24
3.6.4	Public Health	3-26
3.7	DEMOGRAPHICS AND ENVIRONMENTAL JUSTICE	3-27
3.7.1	Population and Race	3-27
3.7.2	Income and Poverty	3-27
3.7.3	Wastewater Fees and Affordability for Keys Low-income Residents	3-28
3.8	HAZARDOUS MATERIALS AND WASTES	3-31
3.9	INFRASTRUCTURE	3-32
3.9.1	Traffic and Circulation	3-32
3.9.2	Utilities and Services	3-33
3.10	LAND USE AND PLANNING	3-33
3.11	NOISE AND VISUAL RESOURCES	3-35
3.11.1	Noise	3-35
3.11.2	Visual Resources	3-36
SECTION 4 	CUMULATIVE IMPACTS	4-1
4.1	TOPOGRAPHY, SOILS, AND GEOLOGY	4-1
4.2	WATER RESOURCES AND WATER QUALITY	4-1
4.3	BIOLOGICAL RESOURCES	4-1
4.4	AIR QUALITY	4-1
4.5	CULTURAL RESOURCES	4-1
4.6	SOCIOECONOMICS	4-2
4.7	DEMOGRAPHICS AND ENVIRONMENTAL JUSTICE	4-2
4.8	HAZARDOUS MATERIALS	4-2
4.9	INFRASTRUCTURE	4-2
4.10	LAND USE AND PLANNING	4-2
4.11	NOISE AND VISUAL RESOURCES	4-3
SECTION 5 	PUBLIC PARTICIPATION	5-1
SECTION 6 	 MITIGATION MEASURES AND PERMITS	6-1
6.1	MITIGATION	6-1
6.2	PERMITS AND LICENSES	6-1
SECTION 7 	REFERENCES	7-1
SECTION 8 	LIST OF PREPARERS	8-1



Tables
Table 1-1	Service Area Characteristics by Parcel Type
Table 2-1 	Estimated Service Area Water Use
Table 2-2	Treatment Plant Influent and Effluent Wastewater Conceptual Design Criteria
Table 3-1	FDEP Injection Well Forms
Table 3-2	Observed Plant Species
Table 3-3	Service Area Vegetation
Table 3-4	Service Area Businesses
Table 3-5	Fiscal Year 2003 – HUD’s Low-Income and Very Low-Income Limits, Monroe 
County, Florida
Table 3-6	Alternative 2 Low-Income and Very Low-Income Funding Assistance for the 
System Capital Cost of $4,259
Table 3-7	Alternative 3 Low-Income and Very Low-Income Funding Assistance for the 
System Capital Cost of $4,500
Figures
Figure 1-1	Project Vicinity Map
Figure 2-1	Proposed Bay Point and Saddlebunch Key New WWTP Site Location and Service 
Area Map
Figure 2-2	Typical Building Connection 
Figure 2-3	Proposed WWTP Site
Figure 2-4	Proposed Bay Point and Saddlebunch Keys WWTP Preliminary Drawings
Figure 2-5	Existing Plant Upgrade and Expansion and New Wastewater Transmission 
System Site Location Map
Figure 2-6	Proposed VPS Preliminary Drawings
Figure 3-1	Project Area Soils
Figure 3-2	Project Area Floodplains 
Figure 3-3	Project Area Vegetation
Figure 3-4	Project Area Benthic Habitats 
Figure 3-5	Service Area Land Uses 
Appendices
Appendix A	Acronyms and Abbreviations
Appendix B	Agency Coordination Letters
Appendix C	Site Photographs
Appendix D	Public Notice
Appendix E	Public Comments
Appendix F	Regulated Keys Fisheries Species
Appendix G	Best Available Treatment Wastewater Analysis
Appendix H	Bay Point Key Cultural Resources Assessment Survey Report
Appendix I	Monroe County Housing Authority Assistance Implementation Plan


In response to damages and losses from Hurricane Georges, Congress enacted Public Law 106-
31, Emergency Supplemental Appropriations Act for Fiscal Year 1999, to fund long-term 
disaster recovery projects in Florida counties with needs that were unmet through primary 
disaster relief funds. The counties eligible for “Unmet Needs” funding included Monroe County, 
which requested that wastewater management improvement projects be considered for this 
funding since many existing wastewater facilities in the county are not storm-resistant. 
Since then, the Federal Emergency Management Agency (FEMA) has received a grant 
application from the Florida Keys Aqueduct Authority (FKAA), requesting Federal assistance to 
construct a new wastewater treatment facility to service Bay Point and Saddlebunch Keys. 
FEMA prepared this draft Supplemental Environmental Assessment (SEA) to address the likely 
effects of implementing three alternatives in Bay Point and Saddlebunch Keys. The alternatives 
evaluated in this document include:
Alternative 1 – No Action Alternative
Under this alternative, FEMA would not fund the proposed wastewater treatment project for Bay 
Point and Saddlebunch Keys. Alternate funding sources would need to be located to finance the 
large capital costs of constructing a wastewater treatment system to meet the Florida Statutory 
Treatment Standards by 2010. Until alternate funding is secured, environmental degradation 
would continue. Depending on the amount of alternative funding secured, increased wastewater 
management costs and the potential for significant economic impacts would be likely, 
particularly to service recipients who currently have cesspits or septic systems.  The likely 
increase in wastewater management costs could cause a disproportionately high and adverse 
economic effect on low-income service recipients.
Alternative 2 – New Wastewater Treatment Plant Construction (Proposed)
The FKAA would use FEMA funding to construct a new community wastewater treatment plant 
(WWTP) on the ocean side of U.S. Route 1 (US-1) at Mile Marker (MM) 15. The proposed plant 
site is an 80-foot wide by 130-foot long (0.31 acre) open space. The WWTP would collect 
wastewater effluent through vacuum pumping. Following Best Available Technology (BAT) 
treatment, the WWTP would dispose of wastewater effluent through shallow injection wells. The 
FKAA would be responsible for facility construction, operation, and maintenance.
Alternative 3 – Existing Plant Upgrade and Expansion and New Wastewater Transmission 
System Construction
The FKAA would use FEMA funding to construct a new wastewater transmission system on the 
ocean side of US-1 between MM 15 and MM 5. The proposed Vacuum Pump Station (VPS) site 
is an 80-foot wide by 130-foot long (0.31 acre) open space on the ocean side of US-1 at MM 15. 
Key West Resort Utility (KWRU) would expand existing plant capacity and improve treatment 
systems to meet Advanced Wastewater Treatment (AWT) standards. Wastewater would be 
disposed of through reuse-land application and shallow injection wells. Wastewater collection 
would be the same as under Alternative 2. FKAA would be responsible for collection and 
transmission system construction, operation, and maintenance. KWRU would be responsible for 
WWTP upgrade construction, operation, and maintenance. 
Alternatives 2 and 3
For both Alternative 2 and Alternative 3, potential project effects on topography, soils, geology; 
wetlands and floodplains; hazardous materials and wastes; infrastructure; land use and planning; 
and noise and visual resources within the project area are expected to be minimal. Appropriate 
mitigation measures would reduce any potential adverse effects of the project alternatives on 
these resources. Effects on water resources and water quality; biological resources; and public 
health are anticipated to be beneficial. Effects on air quality and cultural resources would be 
negligible.  
Under Alternative 2, socioeconomic effects would be mitigated with the use of FEMA grant 
funding, and capital costs would be affordable to service recipients. To reduce economic effects, 
an assistance program has been developed to ensure that costs do no have a disproportionately 
high or adverse effect on low-income service recipients.  
Under Alternative 3, the capital costs are unreasonable and would have a substantially adverse 
effect on low-income recipients.  The assistance program would mitigate these effects to ensure 
that the capital costs would not have disproportionately high or adverse effects on low-income 
service recipients.  


1.0	Section 1 ONE	Introduction
1.1	PROJECT AUTHORITY
In 1998, after Hurricane Georges, Congress enacted Public Law 106-31, Emergency 
Supplemental Appropriations Act for Fiscal Year 1999, to provide additional monies for long-
term disaster recovery projects in the State of Florida. Congress allocated the funds to assist 
counties with needs that were not met through allocation of primary disaster relief funds. The 
Federal Emergency Management Agency (FEMA) earmarked this Unmet Needs money for the 
counties most impacted by Hurricane Georges, including Monroe County. FEMA, the State of 
Florida, and the impacted counties determined funding priorities.
Monroe County requested that FEMA consider wastewater management improvement projects 
for disaster funding since many existing wastewater facilities in Monroe County are not storm-
resistant, do not provide adequate wastewater treatment, and contribute to degraded water quality 
in the Keys. Since then, the Florida Keys Aqueduct Authority (FKAA), through the State of 
Florida Department of Community Affairs (DCA), has applied for Federal funding assistance 
from FEMA for construction of a wastewater treatment system that would service Bay Point and 
Saddlebunch Keys, improve wastewater treatment and ultimately water quality in the Florida 
Keys, and assist residents in meeting State-mandated water quality targets as set forth in the 
Florida Statutory Treatment Standards of 2010. Specifically, wastewater treatment systems must 
treat discharge to advanced wastewater treatment (AWT) or best available technology (BAT) 
standards. For facilities that treat over 100,000 gallons per day (gpd), the AWT standards are 5 
milligrams per liter (mg/L) Biological Oxygen Demand (BOD), 5 mg/L Total Suspended Solids 
(TSS), 3 mg/L Total Nitrogen (TN), 1 mg/L Total Phosphorus (TP); and for facilities treating 
less than 100,000 gpd, the BAT standards are 10, 10, 10, and 1, respectively.
1.2	RELATED ENVIRONMENTAL DOCUMENTS
URS Group Inc. (URS) prepared a Programmatic Environmental Assessment (PEA) for FEMA 
in accordance with the National Environmental Policy Act (NEPA), the Council on 
Environmental Quality (CEQ) regulations implementing NEPA (40 Code of Federal Regulations 
[CFR] 1500-1508), and FEMA regulations (44 CFR Part 10, Environmental Considerations). 
These laws and regulations require FEMA to take into account environmental considerations 
when funding any Federal action. The PEA, which URS finalized on December 23, 2002, 
provides a framework to address impacts associated with a range of wastewater treatment 
projects in the Florida Keys. PEA Section 1.7 (Water Quality Protection Measures at the Local, 
State, and Federal Levels) provides a complete discussion of water quality protection measures at 
Federal, State, and local levels.
This Supplemental Environmental Assessment (SEA) tiers from the PEA for Wastewater 
Management Improvements in the Florida Keys (URS, 2002) as proposed by FEMA and hereby 
incorporates the PEA by reference, in accordance with 40 CFR Part 1508.28. 
1.3	PROJECT LOCATION
The service area includes the subdivisions of Bay Point, Saddlebunch Shores, and the Bluewater 
RV Park, which are located on Bay Point and Saddlebunch Keys near Mile Marker (MM) 15, in 
the southern portion of the Florida Keys chain known as the Lower Keys. Proposed wastewater 
improvements would service a total of 438 occupied and vacant land parcels on Bay Point and 
Saddlebunch Keys, for a total wastewater service area of about 90 acres located within Sections 
8 and 17, Township 67, Range 27 (Table 1-1). The service area is mostly developed (78.8 
percent), with 93 parcels of vacant land.
 
[Figure 1-1. Project Vicinity Map
Figure 1-1 shows the proposed proejct location on Bay Point and Saddlebunch in realtionship to the
Florida Keys and South Florida.]

Table 1-1. Service Area Characteristics by Parcel Type (FKAA, 2002)

Mobile Homes
Bay Point Key 98
Saddlebunck Key 0
Total 98
Single Family
BaYPoint Key 97
Saddlebunck Key 27
Total 124
Multi-Family
Bay Point Key 28
Saddlebunch Key 4
Total 32
Commercial
Bay Point Key 8
Saddlebunch Key 2
Total 10
Vacant Lots
Bay Point Key 74
Saddlebunch Key 19
Total 93
RV Lots
Bay Point Key 0
Saddlebunch Key 81
Total 81
Total
Bay Point Key 305
Saddlebunck Key 133
Total 438

1.4	PURPOSE AND NEED
PEA Section 1.9 (Purpose and Need for Action) describes the purpose and need for action. In 
particular, the purpose of the FKAA project is to reduce wastewater nutrient loading at selected 
Monroe County “hot spots,” thereby improving water quality. These “hot spots” are believed to 
contribute to water quality degradation. 
As described in PEA Section 2.1 (Alternative Development Background), “hot spots” represent 
priority areas where the high concentration of people and poor existing wastewater treatment 
practices justify the installation of a more advanced wastewater treatment system within that 
area. The Monroe County Sanitary Wastewater Master Plan (MCSWMP; Monroe County, 2001) 
ranked Bay Point Key as the 3rd most critical “hot spot” in the Lower Keys and the 6th most 
critical “hot spot” Keys-wide (PEA Appendix C [Hot Spot Locations]). The “hot spot” ranking is 
linked to the use of on-site septic systems as a main wastewater treatment system for the majority 
of residences and businesses in Bay Point and Saddlebunch Keys.


2.0	Section 2 TWO	Alternatives Analysis
NEPA, CEQ regulations implementing NEPA, and FEMA regulations for NEPA compliance 
direct FEMA to investigate and evaluate practical project alternatives. FEMA evaluated 
alternatives identified in the MCSWMP (2000) and the PEA for the proposed Bay Point and 
Saddlebunch Key wastewater management system. In the following sections, FEMA considered 
and evaluated three alternatives in detail: No Action, New Wastewater Treatment Plant 
Construction, and New Wastewater Transmission System Construction.
2.1	ALTERNATIVE 1 – NO ACTION ALTERNATIVE
As discussed in PEA Section 2.3.1 (No Action Alternative), FEMA would not provide funding 
assistance to the FKAA for the proposed action. In order to meet Florida Statutory Treatment 
Standards of 2010, FKAA and service area residents and businesses would need to identify 
another funding source for upgrading currently inadequate wastewater treatment systems.
2.2	ALTERNATIVE 2 – NEW WASTEWATER TREATMENT PLANT CONSTRUCTION 
(PROPOSED ACTION)
PEA Section 2.3.2 (Centralized Wastewater Treatment Plant Alternative) describes Alternative 
2. FKAA would use FEMA funding to build a new wastewater collection system, vacuum pump 
station, and wastewater treatment plant (WWTP) on Bay Point Key (Figure 2-1). FKAA would 
design the proposed WWTP to meet the Florida Statutory Treatment Standards of 2010 for 
effluent disposal to shallow injection wells for treatment systems of less than 100,000 gpd 
(BAT). This alternative would establish new wastewater service for Bay Point and Saddlebunch 
Keys service area residents and business owners currently using on-site septic systems. FKAA 
calculated the design parameters for this alternative using wastewater flows and peaking factors 
for the service area. FKAA used wastewater flow rates for residences and businesses in the 
service area to estimate the number of equivalent dwelling units (EDUs), as summarized in Table 
2-1. The new system would serve about 391 EDUs (FKAA, 2002).
Based on the estimated numbers of EDUs, the estimated annual average day collection system 
design flow (AADF) would be 65,300 gpd. Assuming a treatment plant recycle flow of 10 
percent of the estimated collection system flow, the estimated AADF for the treatment plant 
would be about 72,000 gpd (FKAA, 2002). 
About 320 existing on-site septic systems would be removed from residences and businesses in 
the service area. Pursuant to the Florida Department of Health (DOH) requirements, each 
property owner would be responsible for decommissioning and abandoning his/her existing on-
site system (FKAA, 2001).

 
	[Figure 2-1. Proposed Bay Point and Saddlebunch Key New WWTP Site Location and Service Area 
Map
Figure 2-1 shows the location of the new proposed WWTP on Bay Point Key and the Proposed Service Area
on Bay Point and Saddlebunch Keys with the direction of Wastewater Flow.]



Table 2-1. Estimated Service Area Water Use (FKAA, 2002)





Mobile Homes:
Current Average 
Water Use (gpd) 
per parcel type 167

Number of 
EDUs per 
parcel type 1

Total number 
of parcels 98

Total estimated 
EDUs 98

Single Family:

Current Average 
Water Use (gpd) 
per parcel type 167

Number of 
EDUs per 
parcel type 1

Total number 
of parcels 124

Total estimated 
EDUs 124

Multi-Family
Current Average 
Water Use (gpd) 
per parcel type 167

Number of 
EDUs per 
parcel type 1

Total number 
of parcels 32

Total estimated 
EDUs 32

Commercial

Current Average 
Water Use (gpd) 
per parcel type 334

Number of 
EDUs per 
parcel type 2

Total number 
of parcels 10

Total estimated 
EDUs 20

Vacant Lots

Current Average 
Water Use (gpd) 
per parcel type N/A

Number of 
EDUs per 
parcel type 1*

Total number 
of parcels 93

Total estimated 
EDUs 93

RV Lots:

Current Average 
Water Use (gpd) 
per parcel type 50

Number of 
EDUs per 
parcel type 0.3

Total number 
of parcels 81

Total estimated 
EDUs 24

Total
Current Average 
Water Use (gpd) 
per parcel type ---

Number of 
EDUs per 
parcel type ---

Total number 
of parcels 438

Total estimated 
EDUs 391

* estimated future EDU. 

2.2.1	Wastewater Collection and Transmission System
The proposed collection system would consist of a vacuum sewer system with a VPS. The 
vacuum sewer system would consist of gravity collection mains and/or service laterals, sewage 
holding sumps and vacuum valve pits, vacuum collection mains, and a VPS building, as 
described in PEA Section 2.3.2.1.1 (Vacuum Pumping). 
2.2.1.1	Collection System
Separate collection systems would serve the service area on Bay Point and Saddlebunch Keys. 
FKAA would place wastewater collection mains within the limits of public road rights-of-way 
(ROW) throughout the service area in front of the residences and businesses to be served. FKAA 
would site collection mains to maintain horizontal separation from the existing potable water 
mains, and provide service laterals consisting of polyvinyl chloride (PVC) pipe up to the ROW 
line (Figures 2-2a and b). Property owners would be responsible for constructing individual 
connections to the service laterals. Special plumbing fixtures or electrical connections would not 
be required at houses or mobile homes, because the current fittings are adequate.
Residential sewage would flow by gravity into a vacuum valve pit, the lower portion of which 
would be a fiberglass holding sump and the upper portion of which includes a vacuum valve. 
One vacuum valve pit would service two or more homes. When wastewater in the holding sump 
rises to a preset level, a sensor extending from the valve chamber into the holding sump would 
detect the liquid level in the sump, and the system would pneumatically open the vacuum 
interface valve. Differential air pressure would propel the sewage from the sump through the 
valve and into 3-inch or larger PVC vacuum wastewater collection mains. FKAA would build 
vacuum mains 3 feet below existing elevation throughout the service area. The system would 
then transport sewage from the collection mains to the wastewater collection tank at the VPS by 
the introduction of air into the collection main from successive open/close cycles of the vacuum 
valves in the system.
2.2.1.2	Transmission System Components
A 0.75-mile transmission main would transport wastewater from Saddlebunch Key to the 
WWTP on Bay Point Key. FKAA would install this transmission main along the south ROW of 
U.S. Route 1 (US-1) within an abandoned 18-inch FKAA steel pipe (Figure 2-1). This pipe was 
previously used as a potable water transmission main and subsequently abandoned in place. The 
abandoned main would act as a sleeve or casing for a collection main up to an outer diameter of 
about 12 inches (FKAA, 2002). 
The Saddlebunch-Bay Point transmission force main would also require a 700-foot bridge 
crossing over the Saddlebunch No. 2 causeway at MM 14.5. FKAA would slipline the force 
main within the abandoned 18-inch steel water main attached to the old bridge and replace the 
fittings and hardware that attach the existing 18-inch water main.




 

[Figure 2-2(a). Typical Building Connection (Plan View) (FKAA, 2002)

 
Figure 2-2(b). Typical Building Connection (Profile Detail) (FKAA, 2002)

Figures 2-2 a and be shows plan and profile views of typical building connections to the 
wastewater collection system in the service areas.]

2.2.2	Wastewater Treatment Plant
2.2.2.1	Site Description
FKAA would build the WWTP on currently vacant Monroe County lands, on the ocean side of 
Bay Point Key at MM 15 (Figure 2-3). The proposed plant site is an 80-foot wide by 130-foot 
long (0.31 acre) open space that contains invasive exotic plants and grass cover. The northern 
property boundary is located along US-1, and the western property boundary is along West 
Circle Drive. Private residences are located about 150 feet (0.03 mile) south of the site. The 
closest water body to the site is Lower Sugarloaf Sound, about 158 feet (0.03 mile) northwest of 
the site. The Florida Straits are about 264 feet (0.05 mile) southwest of the site.

 
[Figure 2-3. Proposed WWTP Site (URS Site Visit; August 1, 2002)
Figure 2-3 is a photo of the propose WWTP site]

2.2.2.2	System Components
Design elements at the site include the new WWTP; vacuum station; storage facilities for 
maintenance equipment, treatment chemicals, and other operations materials; parking; paved 
access roads; and landscaping. The WWTP itself would have two aeration tanks, odor control 
equipment, two chlorine tanks, two Class V injection wells, and an equipment container for all 
pumps and blowers (Figure 2-4). A VPS, located within the treatment plant site, would generate 
the negative pressure necessary on the vacuum collection mains. The station would draw raw 
sewage through the collection mains and pump it to the treatment plant. The vacuum station 
would be located next to the WWTP and would contain vacuum pumps, sewage pumps, a 
collection tank, and controls. The vacuum collection tank in the vacuum station would be made 
of either steel or fiberglass.
The station would consist of a 40-foot by 30-foot slab-on-grade building containing air blowers, 
discharge pumps, a collection tank, and an emergency generator. Discharge pumps connected to 
the vacuum collection tank would transfer sewage to the treatment plant. A separate concrete pad 
external to the station would accommodate odor control equipment (either a vapor phase 
activated carbon filter or a biological filter) for the treatment of air discharged from the 
collection tank by the VPS blowers.

 
[Figure 2-4. Proposed Bay Point and Saddlebunch Keys WWTP Preliminary Drawings (FKAA, 2002)
Figure 2-4 show the preliminary design of the Proposed Bay Point Wastewater Treatment Plant.]

2.2.2.3	System Operation
The WWTP would provide primary treatment, biological treatment, solids removal, phosphorus 
removal, filtration, effluent disinfection, and disposal to shallow injection wells (Figure 2-4). An 
in-line magnetic flowmeter would measure, record, and total raw sewage flow from the VPS into 
the treatment plant. Automatic screening, using either a mechanical bar screen or rotary screen, 
of the influent wastewater would remove large particulate matter. The system would discharge 
pretreatment screenings to a collection hopper or trash receptacle for collection and hauling to a 
Florida Department of Environmental Protection (FDEP) permitted sanitary landfill facility for 
disposal (FKAA, 2002). If necessary, the system would buffer the alkalinity of the influent 
wastewater using sodium hydroxide but would not discharge excess sodium hydroxide to the 
environment (Garcia, Pers. Comm., 2003). Components of the sodium hydroxide feed system 
would include storage drums, metering pumps, small diameter PVC piping and valves, and a 
small containment area with a concrete slab and curb, electrical power, and controls.
The system would likely treat wastewater using the sequencing batch reactor with aluminum 
sulfate (alum) addition and conventional filters, or the upflow sludge blanket filter process with 
alum addition and conventional filters. Other possible methods of treatment include the modified 
Ludzak-Ettinger process, Bardenpho process, and the immersed membrane bioreactor. The 
WWTP would use two parallel process trains, each with two equal-sized biological reactor 
systems, so that if one system were out of service, the remaining train would be capable of 
treating the system design flow. FKAA would design the WWTP to meet BAT standards as 
specified by the Florida Statutory Treatment Standards of 2010. Table 2-2 shows design criteria 
for influent and effluent characteristics. 

Table 2-2. Treatment Plant Influent and Effluent Wastewater Conceptual Design 
Criteria (FKAA, 2002)


Parameter BOD5
Influent (mg/L) 250
Effluent (mg/L) 10

Parameter TSS
Influent (mg/L) 250
Effluent (mg/L) 10

Parameter TN
Influent (mg/L) 40
Effluent (mg/L) 10

Parameter TP
Influent (mg/L) 8
Effluent (mg/L) 1

Parameter Disinfection
Influent (mg/L) N/A
Effluent (mg/L) 200 colonies per 100 ml of sample (basic-level)


Additional treatment would include the addition of metal salts, such as alum, sodium aluminate, 
ferric chloride, ferrous chloride, ferric sulfate, or ferrous sulfate to reduce the total phosphorus of 
the wastewater to 1 mg/L. The system would use alum to coagulate excess phosphorus and 
dispose of the alum with the decanted sludge (Garcia, Pers. Comm., 2003). Components of a 
liquid metal salt feed system would include storage drums, metering pumps, small diameter PVC 
piping and valves, a containment area with a concrete slab and curb, electrical power, and 
controls. The system may need filtration to produce effluent with total suspended solids of not 
more than 10 mg/L, remove soluble effluent phosphorus concentrations in excess of 1 mg/L, and 
remove unsettled phosphorus precipitate discharged from the settling tank. The system would 
need two automatic backwashing filter units. FKAA would size the units such that, with one 
filter out of service, the remaining unit would have sufficient capacity to receive flow equal to 
not less than 75 percent of the design capacity of the treatment plant.
Effluent disinfection would occur in a disinfection contact tank using one of three methods: 
calcium hypochlorite tablets or briquettes; commercial grade or on-site generated sodium 
hypochlorite; or ultraviolet radiation. The system would dissolve calcium hypochlorite and 
sodium hypochlorite in the effluent stream to render potential biological pathogens harmless. 
The fate of this material would be in the form of dissolved hypochlorite, sodium, and calcium 
ions in the effluent stream. Ultraviolet radiation disinfection is a passive treatment means and 
would not result in the addition of materials to the effluent.
2.2.2.4	Effluent Disposal
The system would dispose of effluent by gravity flow into two on-site 8-inch diameter shallow 
injection wells, cased and cement grouted to 60 feet below land surface (bls), with a gravel-
packed open hole section from 60 feet to 90 feet bls (PEA Section 2.3.2.2 [Wastewater 
Treatment Plant Effluent Disposal Options]). FKAA would build shallow injection wells located 
at the treatment plant site in accordance with Chapter 62-528, Florida Administrative Code 
[F.A.C.]. FKAA would also build one 3-inch groundwater monitoring well, 10 feet bls cased 
depth and 30 feet bls total depth. The total number of injection wells would be sufficient to 
dispose of effluent peak hour flows with any disposal well out of service. The system would 
direct recycle flows, including filter backwash and digester decant, back to the head of the 
treatment plant for processing.
Stabilization of residual bio-solids would occur via the aerobic digestion process. FKAA would 
equip the aerobic digester with an aeration system used to mix and aerate the residual bio-solids. 
The system would return decanted sludge residuals to the plant for treatment, remove settled 
solids from the digester, and load the solids into a tank truck through a draw-off pipe located 
near the base of the tank. FKAA would locate the fill station to provide easy access by tanker 
trucks. FKAA would temporarily store decanted sludge in an aerated holding tank on-site and 
haul the liquid sludge by truck to one of three Monroe County Solid Waste Transfer Stations. 
Several neighboring municipalities have the capacity to accommodate the expanded waste 
quantity from Monroe County (e.g., Miami-Dade South District WWTP or Florida City). FKAA 
would enter into an agreement with the accepting municipality prior to WWTP startup 
(Shimokubo, Pers. Comm., 2003). FKAA would haul one 5,000-gallon capacity tanker truck of 
sludge per month. This is based on the estimated volume of excess bio-solids generated by the 
wastewater treatment process and a maximum thickened sludge concentration of 2.0 percent in 
the aerobic digester.
2.2.3	Construction Activities
Construction of the WWTP would require installation of treatment tanks, in-ground and 
aboveground pipes, pumping stations, and sand or fabric filtration facilities. Other related 
activities at the site would include the construction of storage facilities for maintenance 
equipment, treatment chemicals, and other operations materials, as well as construction of an 
administrative building, parking lot, and paved access road. Removal of septic systems and 
pipeline trenching activities would occur throughout the service area.
Excavation for the collection system and WWTP site development, pipelines, and removal of 
septic tanks and cesspools would require a backhoe, trenching machine, bulldozer, crane, drilling 
rig, front-end loader, street sweeper, boring machine, and several dump trucks to haul material, 
equipment, and construction debris. Temporary construction traffic would likely increase in the 
vicinity of the proposed facility for about 12 months. The proposed site would also contain an 
area that FKAA would use as a temporary staging area for construction equipment and building 
materials.
Because the proposed WWTP and service areas are located in the 100-year floodplain, the design 
provisions of the Monroe County’s Floodplain Ordinance would apply. Furthermore, because of 
Federal funding, per Executive Order 11988 (Floodplain Management), as implemented in 
FEMA’s regulations at 44 CFR Part 9, wastewater treatment facilities are critical facilities 
(actions) and therefore subject to more stringent construction requirements.  Specifically, FKAA 
would floodproof the WWTP and its critical operating components to the 500-year flood, as 
outlined in 44 CFR Part 9.11.
2.2.4	Operation and Maintenance
The FKAA would operate and maintain the finished WWTP. The WWTP lifespan would be 
between 30 and 50 years.
2.3	ALTERNATIVE 3 – EXISTING PLANT UPGRADE AND EXPANSION AND NEW 
WASTEWATER TRANSMISSION SYSTEM CONSTRUCTION (ACTION 
ALTERNATIVE) 
Alternative 3, construction of a new transmission system with service at an existing facility, is 
generally described in PEA Section 2.3.2 (Centralized Wastewater Treatment Plant Alternative). 
FKAA would apply FEMA funding to the construction of a wastewater collection system on Bay 
Point and Saddlebunch Keys, a VPS on Bay Point Key; and a wastewater transmission system 
extending from the VPS on Bay Point Key to the existing Key West Resort Utilities (KWRU) 
WWTP off Front Street on south Stock Island, between MM 15 and MM 5 (Figure 2-5); and 
expansion and treatment upgrades to the KWRU WWTP.  This alternative would require FKAA 
to execute a beneficial use agreement with KWRU, a private utility, to accept the Bay Point 
service area wastewater flow.
The basis of design for the collection system is similar to that used for Alternative 2. The total 
estimated AADF for the service area would be about 72,000 gpd. KWRU would expand capacity 
of the WWTP to accommodate the increased flow from the service area.  The capacity expansion 
would include a treatment upgrade to meet AWT requirements. As in Alternative 2, about 320 
on-site septic systems currently utilized by property owners on Bay Point and Saddlebunch Keys 
would be removed. Pursuant to the Florida DOH requirements, each property owner would be 
responsible for decommissioning and abandoning his/her existing on-site septic systems.
2.3.1	Wastewater Collection and Transmission System
2.3.1.1	Collection System
The collection system would be similar to that utilized under Alternative 2 described in Section 
2.2.1.1. Separate collection systems would serve Bay Point and Saddlebunch Keys (Figure 2-1). 
As in Alternative 2, the system would require a force main bridge crossing of about 700 linear 
feet across Saddlebunch No. 2 causeway, between Saddlebunch and Bay Point Keys, at MM 
14.5. FKAA would slipline the force main inside the existing 18-inch FKAA abandoned pipeline 
attached to the bridge and replace the fittings and hardware used to attach the 18-inch main to the 
bridge. 
Use of a vacuum sewer system would require construction of a VPS on Bay Point Key (Figure 2-
5). FKAA would site this facility at the proposed Alternative 2 treatment plant site. Section 
2.3.1.2 further describes the VPS. FKAA would provide service laterals, for connection to the 
collection system by residents, up to the property ROW line (Figure 2-2a and b). As in 
Alternative 2, connection to the collection system would be the responsibility of the property 
owner. The system would not require special plumbing fixtures or electrical connections because 
the current fittings are adequate.
 
[Figure 2-5. Existing Plant Upgrade and Expansion and New Wastewater Transmission System Site Location 
Map*
*Arrows represent direction of wastewater flow.
Figure 2-5 show the the Existing KWRU Plant (proposed capacity expansion and treatment upgrades) and the 
and the New wastewater transmission system from the Service areas to Stock Island/]

2.3.1.2	Vacuum Pump Station
The VPS would be located at the treatment plant site as described in Alternative 2 (Section 
2.2.2.2; Figure 2-1). Design elements at the site would include the new pump station, influent 
vacuum mains, discharge yard piping, site access, parking, and landscaping. The size of the 
building would be between 1,000 and 1,300 square feet (Figure 2-6). The final building area 
would depend upon the number of air blowers, the number and volume of collection tanks, and 
the size of the emergency generator required to maintain service in case of power outages. 
Vacuum blowers would create a vacuum of about 16 to 20 inches of mercury or 0.53 to 0.67 
atmospheres, capable of extracting wastewater from the vacuum valve pits through the collection 
mains into the tank. The tank would provide adequate storage to allow the sewage pumps to 
operate.
FKAA would house two submersible-type discharge pumps in the station, each capable of 
pumping about 180 gallons per minute (gpm) peak hour wastewater flow rate. One pump would 
be operational at peak hour flow and one pump as a backup. The pumps would have the 
capability of being increased to 20 horsepower as total head conditions increase in the 
transmission force main due to flows from future wastewater projects identified in the 
MCSWMP (Monroe County, 2000). 

 
[Figure 2-6. Proposed VPS Preliminary Drawings (FKAA, 2003)
Figure 2-6 shows the preliminary drawings of the proposed VPS on Bay Point Key.]

Wastewater discharge pumps would direct flow accumulated in the vacuum collection tank to the 
force main transmission system and ultimately to the KWRU WWTP on southern Stock Island. 
Each pump would be capable of about 72 gpm peak hour wastewater flow. Since the pumps 
would be susceptible to inundation, FKAA would use submersible units. One wastewater pump 
and one vacuum blower would be operational while an additional wastewater pump and an 
additional vacuum blower would provide backup. To minimize odors, air discharged from the 
blower exhaust at the VPS would run through a filter, such as an in-ground wood chip bed or 
packaged iron filings bed, before emission. A separate concrete pad external to the station would 
accommodate odor control equipment for the treatment of air discharged from the collection tank 
by the VPS blowers.
As with Alternative 2, because the VPS and service areas are located in the 100-year floodplain, 
the design provisions of the Monroe County Floodplain Ordinance would apply. Furthermore, 
because of Federal funding, per Executive Order 11988 (Floodplain Management), as 
implemented in FEMA’s regulations at 44 CFR Part 9; wastewater treatment facilities are 
considered critical facilities (action) and therefore are subject to more stringent construction 
requirements.  Specifically, FKAA would floodproof the VPS and its critical operating 
components to the 500-year flood, as outlined at 44 CFR Part 9.11.
2.3.1.3	Transmission System Components
The transmission main would commence at the pump station and travel along US-1 through an 
existing abandoned FKAA 18-inch water main for a portion of the distance to the KWRU 
WWTP (refer to Figure 2-4). The abandoned main would act as a casing for a pipe up to an outer 
diameter of about 12 inches. The system would require about 11 miles of transmission force 
main. Due to the long distance that the sewage must be pumped, the force main would be slightly 
oversized to maintain pump discharge pressures within acceptable limits. In addition, FKAA 
would oversize portions of this force main to receive and transport future flows from the Boca 
Chica Community Service Area to the KWRU treatment plant as described in the MCSWMP. 
FKAA would install the proposed force main inside the portion of the abandoned 18-inch 
pipeline that lies within the southern US-1 ROW at the most favorable locations (i.e., straight 
portions of pipeline). Two portions of the abandoned main would likely be available and in 
acceptable condition for use as a sleeve or casing for the transmission force main:
*	From Bay Point Key (MM 15) to Rockland Drive (MM 9) on Rockland Key, about 6 miles; 
and
*	From the west end of Boca Chica (MM 6.25) to Stock Island (MM 5.0), about 1.25 miles.
Between MM 9 and the Boca Chica Bridge (MM 6.75), FKAA would build and trench a new 
force main. The system would need a force main bridge crossing of about 2,700 linear feet to 
cross the Boca Chica Channel, from MM 6.75 to MM 6.25. The design of this crossing would 
require Florida Department of Transportation approval of the method by which the force main 
would attach to the bridge. Beginning at the west end of the bridge crossing, FKAA would 
slipline the force main west to Stock Island, about MM 5.0. FKAA would build and trench a new 
force main from about MM 5.0 to the existing KWRU WWTP, about MM 4.0. FKAA would 
butt-fuse weld the lengths of the force main at 50-foot intervals, while sliplining the force main 
into the 18-inch abandoned pipe, and seal the pipeline at the beginning and end of each extension 
to prevent infiltration of water and soil.
2.3.2	Existing Key West Resort Utilities Wastewater Treatment Plant
The KWRU WWTP was built in 1982, refurbished in 1993, and expanded to its current 
permitted capacity of 499,000 gpd in 1996 with a 20/20 (TSS/BOD in mg/L) effluent disposal 
requirement. The facility is sited on about 2 acres. The current treatment process at the WWTP 
includes influent screening, flow equalization aeration, secondary clarification, tertiary filtration, 
chlorine disinfection, aerobic digestion, sludge drying beds, and both a reuse land application 
and a shallow injection well disposal system. The system treats effluent at the WWTP to basic 
level disinfection and then directs effluent to off-site reuse storage/equalization ponds, where 
further treatment reduces TSS to 5 mg/L or less. KWRU currently disposes of the irrigation-
quality treated effluent by slow-rate land application reuse (i.e., spray irrigation) at the Key West 
Golf Club (KWGC), the Monroe County Detention Center, and the Sheriff’s Office. KWGC, the 
Monroe County Detention Center, and the Sheriff’s Office have a capacity of 838,000 gpd for 
reuse land application at a maximum allowable rate of 2 inches per acre per week. Class V 
shallow injection wells provide full plant capacity backup effluent disposal; these wells are used 
during periods when KWRU cannot perform land application. The shallow injection wells could 
also accommodate disposal of effluent flow in excess of the reuse land application capacity. 
These disposal wells have a cased depth of 60 feet bls, and a total depth of 90 feet bls; KWRU 
upgraded them in 1997 to meet current FDEP regulations. KWRU would continue to transport 
sludge from the WWTP out of the Keys to the Florida mainland for disposal at an appropriately 
permitted facility (FKAA, 2003, LBFH, 2003). Adjacent land uses to the WWTP facility include 
a solid waste transfer station and commercial fishing boat marina.
The existing treatment plant does not have sufficient reserve capacity to receive additional 
wastewater flows from the Bay Point and Saddlebunch Keys service area. Increasing the 
facility’s capacity would also require upgrade to AWT standards. Further, because FKAA would 
pump the wastewater flow from the service area directly to the KWRU treatment plant site via an 
independent transmission force main, the existing KWRU wastewater collection and 
transmission system would not require modifications or improvements.  
2.3.3	Construction Activities
KWRU WWTP capacity expansion and treatment upgrades are outlined by consulting engineers 
LBFH in their “Boca Chica Community Service Area Wastewater Feasibility and Cost Analysis 
Study” (2003) prepared for FKAA. Expansion would include conversion of the current extended 
aeration process to the Upflow Sludge Blanket Filtration (USBF) treatment process to meet 
AWT standards.  The AWT Florida Statutory Treatment Standards 5 mg/L BOD, 5mg/L TN and 
1 mg/L Total Phosphorus. Although other treatment processes meeting AWT standards are 
available, USBF was evaluated for this Alternative. The main components of the USBF system 
would include a surge tank, anoxic tank, aeration tank, clarifier tanks, sludge storage tank, 
mixers, blowers, disinfection system and contact chamber, chemical feed systems for ferric 
sulfate (for phosphorus removal) and sodium hypochlorite (for disinfection), screens and filters. 
All tanks would be concrete (Figure 2-7).
The WWTP expansion work may also require one additional shallow injection well to 
accommodate Bay Point flows. The existing site can accommodate these expansion components 
that would require about 0.4 acre.  
Construction of the new collection and transmission system would require installation of in-
ground and aboveground pipes and pumping stations.  Onsite system removal and pipeline 
trenching activities would occur throughout the service area.
Excavation for the collection system and VPS site development, pipelines, and removal of septic 
tanks and cesspools would require a backhoe, trenching machine, bulldozer, crane, pile driver, 
drilling rig, front-end loader, street sweeper, and several dump trucks to haul material, 
equipment, and construction debris. Temporary construction traffic would likely increase in the 
vicinity of the proposed facility for about 12 months. The proposed site would also contain an 
area that FKAA would use as a temporary staging area for construction equipment and building 
materials.

[Figure 2-7 Alternative 3 - Treatment Upgrade and Capacity Expansion for the Key West Resort
Utility WWTP.

Figure 2-7 is a drawing showing the KWRU WWTP as it exists plus the proposed treatment updrage
and capacity expansion]

As with Alternative 2, because the VPS and service areas are located in the 100-year floodplain, 
the design provisions of the Monroe County’s Floodplain Ordinance will apply. Furthermore, 
because of Federal funding, per Executive Order 11988 (Floodplain Management), as 
implemented in FEMA regulations at 44 CFR Part 9, wastewater treatment facilities are critical 
facilities (actions) and therefore are subject to more stringent construction requirements. 
Specifically, FKAA must floodproof the VPS and its critical operating components to the 500-
year flood, as outlined at 44 CFR Part 9.11.
2.3.4	Operation and Maintenance
FKAA would operate and maintain the transmission system. KWRO would operate and maintain 
the WWTP.
2.4	ALTERNATIVES CONSIDERED BUT ELIMINATED FROM FURTHER 
CONSIDERATION
FKAA considered other project technology alternatives but eliminated these from further 
consideration in PEA Section 2.4 (Alternatives Considered but Dismissed). FKAA considered 
six additional sites on Bay Point Key for the placement of the WWTP or pump station but 
eliminated these from consideration due to market availability issues as described in PEA 
Section 2.4 (Alternatives Considered but Dismissed). FKAA determined that the proposed action 
site was the only viable option.



3.0	Section 3 THREE	Affected Environment and Environment Consequences
This section describes environmental consequences of the No Action Alternative and the two 
action alternatives, and details the potential effects on the project area’s physical, natural, and 
socioeconomic resources. Discussion in this document includes direct, indirect, and cumulative 
effects.
3.1	TOPOGRAPHY, SOILS, AND GEOLOGY
3.1.1	Topography
Affected Environment
The existing environment is similar to that described in PEA Section 3.1.1.1 (Topography; 
Affected Environment). The Bay Point service area generally lies about 3.0 to 5.0 feet above 
mean sea level (amsl) National Geodetic Vertical Datum (NGVD). Ground elevation rises 
towards US-1 to a maximum of about 12.0 feet amsl NGVD (FKAA, 2002). Elevations decrease 
with increasing distance from US-1. Slope throughout the proposed WWTP/pump station site is 
relatively flat.
Environmental Consequences
Under the No Action Alternative, FKAA would not receive FEMA funds for wastewater 
management. Service area residents of Bay Point and Saddlebunch Keys would still need to 
comply with Florida Statutory Treatment Standards of 2010. Once FKAA secures funding, 
effects to topography would likely be similar to those under Alternatives 2 and 3.
Topographic effects of Alternatives 2 and 3 would be limited to temporary surface disturbances 
during construction of the wastewater collection and transmission systems. The WWTP/pump 
station site would require site clearing, grubbing, and possible minor increase in surface 
elevation to construction grade with clean, suitable fill for the proposed building. Grading 
requirements would permanently change the surface topographic elevation of the subject 
properties, but this effect is minor because it would not significantly alter the existing flat surface 
topography of the Bay Point and Saddlebunch Keys service area.
3.1.2	Soils
Affected Environment
The existing soil conditions are similar to those described in PEA Section 3.1.2.1 (Soils; 
Affected Environment). The project sites’ soil type is the Udorthents-Urban Land Complex, a 
moderately well-drained soil consisting mostly of crushed oolitic limestone and/or coral bedrock 
(Figure 3-1). This soil type is generally found in constructed upland areas next to water bodies 
throughout the Keys (U.S. Department of Agriculture [USDA], 1995). The seasonal high water 
table is at a depth of about 2 to 4 feet and the soil permeability is variable (Nutting Engineers, 
2003). Houses and other urban structures cover most areas with this soil type. Other soil types 
present in the general vicinity of the project area include Cudjoe Marl Tidal and Rock Outcrop-
Cudjoe Complex Tidal; neither of these soils types is present within the project sites. Per the 
Farmland Protection Policy Act, there are no prime farmlands in Monroe County. 
 
[Figure 3-1a. Project Area Soils (Alternative 2) (USDA, 1995)
Figure 3-1 show the soil sytes in the Proiject Area from the USDA Soil Survey for Monroe County, FL.]

Environmental Consequences
Under the No Action Alternative, FKAA would not receive FEMA funds for wastewater 
management. Bay Point and Saddlebunch Keys service area residents would still need to comply 
with Florida Statutory Treatment Standards of 2010. Once FKAA secures funding, effects to 
soils would likely be similar to those under Alternatives 2 and 3.
Under Alternatives 2 and 3, soils would be disturbed during wastewater treatment 
construction/improvements and collection system installation.
For Alternative 2, FKAA would use about 3 to 5 feet of clean, suitable fill to achieve the final 
elevation at the proposed WWTP site. Fill would consist of fine sand that is free of rubble, 
organics, clay, debris, and any other unsuitable material. In addition, FKAA would excavate 
about 200 cubic yards of soil material to install sewer mains, vacuum pits, buffer tanks, gravity 
service laterals, and lift stations. FKAA would use most of the excess excavated material for 
backfill and dispose of the remainder offsite.
For Alternative 3, capacity expansion and treatment upgrades would minimally disturb soils 
because the KWRU site is already graded. VPS and transmission system construction would 
disturb soils. FKAA would excavate about 2,500 cubic yards of soil material to install sewer 
mains, vacuum pits, buffer tanks, gravity service laterals, and lift stations. FKAA would use 
most of the excess excavated material for backfill and dispose of the remainder offsite.
FEMA recommends implementation of appropriate Best Management Practices (BMPs), 
development of an approved Erosion and Sediment Control Plan, and use of conventional site 
preparation techniques prior to and during construction to protect area water bodies and canals.  
Planned measures to control sediment from discharge to nearshore surface waters may include, 
but are not limited to, silt dams, barriers, and straw bales placed at the foot of sloped surfaces. 
Planned measures to control soil erosion may include, but are not limited to, grassing, mulching, 
watering, and seeding of on-site surfaces. Site preparation may include grubbing of vegetative 
roots and topsoil materials, followed by surface compaction and fill placement to attain the 
required construction elevation.
Applying BMPs and appropriate erosion mitigation measures would limit adverse soil effects 
during construction of the treatment system. The Udorthents-Urban Land Complex is well suited 
for urban development, and losses of soil productivity or fertility are not of concern because this 
soil type generally does not support vegetation. Overall, no long-term adverse effects on soils 
would likely occur if FKAA manages site soil excavation, disposal, and erosion potential in 
accordance to State standards and applicable BMP and erosion control guidelines.  
3.1.3	Geology
Affected Environment
The existing geologic environment is similar to that described in PEA Section 3.1.3.1 (Geology). 
At the project areas, the upper stratum of bedrock is Miami Oolite, a very porous, solution-
riddled, carbonate rock. Results of geotechnical test borings conducted at the proposed 
Alternative 2 WWTP site revealed a surface layer of limestone with sand in the upper 2 feet, 
underlain by intermixing layers of loose sand and medium hard limestone to a depth of 7 feet bls 
(Nutting Engineers, 2003). Test borings encountered medium hard to very hard limestone with 
tan sand, below the 7-foot depth, to a depth of 20 feet bls. One soil boring encountered a layer of 
soft brown silty peat between 2 and 6 feet bls.
Environmental Consequences
Under the No Action Alternative, FKAA would not receive FEMA funds for wastewater 
management. Bay Point and Saddlebunch Keys service area residents would still need to comply 
with Florida Statutory Treatment Standards of 2010. Once FKAA secures funding, effects to 
geology would likely be similar to those under Alternatives 2 and 3.
Alternative 2, new WWTP construction, would have minor effects on geology. FKAA would 
excavate to install the sewer mains at elevation 1-foot to 2-feet amsl NGVD along service area 
roads and to remove cesspits and septic systems. 
WWTP construction would require installation of one groundwater monitoring well and two 
shallow wells to dispose of treated wastewater effluent. FKAA would case and grout the shallow 
injection wells to 60 feet bls, with a gravel-packed open hole section from 60 feet to 90 feet bls 
(PEA Section 2.3.2.2 [Wastewater Treatment Plant Effluent Disposal Options]). The shallow 
wells’ effects on project site geology would likely be minor; PEA Section 3.1.3.2.2 (Centralized 
Wastewater Treatment Plant Alternative) discusses these effects. The applicant is responsible for 
obtaining all applicable FDEP permits for Class V shallow injection wells (Table 3-1).

Table 3-1.	FDEP Injection Well Forms


Form Title: Application to Construct/Operate/Abandon Class I, III, or V Injection Well Systems
Form Number: 62-528.900(1)

Form Title: Certification of Class V Well Construction Completion
Form Number: 62-528.900(4)

Form Title: Certification of Monitor Well Completion
Form Number: 62-528.900(10)

As discussed in PEA Section 3.1.3.2.2 (Alternative 2), aside from the potential effects from 
injection well use, WWTP construction would not likely adversely affect the project site 
geology. The use of shallow injection wells would likely introduce relatively fresh effluent into 
brackish-to-saline water aquifers, which could affect the rate of limestone solution (dissolving). 
In mainland Florida, sinkhole development, especially in areas of declining water tables, has 
been a severe engineering problem. However, in the Bay Point and Saddlebunch Keys service 
area, the water table is about 2 to 4 feet bls (Nutting Engineers, 2003) and water tables have not 
been declining. Therefore, new and/or expanded sinkholes are not likely to result from this 
alternative.
Alternative 3 would have minor geological effects from construction of the collection and 
transmission system and the removal of cesspits and septic systems, as discussed in Alternative 2 
above. Capacity expansion and treatment upgrades at the KWRU WWTP would have minor 
geological effects. KWRU uses six backup disposal Class V shallow injection wells at the 
WWTP, and the potential for sinkhole development at this facility is as described under 
Alternative 2.  However, one additional Class V shallow injection wells may be installed to 
accommodate Bay Point effluent flows. Construction of additional wells is not anticipated to 
increase the risk of sinkhole development or the rate of limestone dissolution. No long-term 
geological effects are anticipated under Alternative 3.
3.2	WATER RESOURCES AND WATER QUALITY
3.2.1	Groundwater
Affected Environment
The affected environment for groundwater is described in PEA Section 3.2.2.1 (Groundwater). 
Throughout the project areas, the water of the upper water bearing zone of the Biscayne Aquifer 
ranges from brackish to saline and is of little potential utility except as input for desalination 
systems. Freshwater lenses have not been documented for the Bay Point or Saddlebunch Keys 
areas.
The seasonal high water table at the Alternative 2 treatment plant site occurs about 2 to 4 feet bls 
(Nutting Engineers, 2003). Two shallow Class V injection wells are located in the service area; 
both are on the ocean side of US-1 (U.S. Army Corps of Engineers, 2001). These wells discharge 
relatively fresh water and effluents into the upper water bearing zone of the Biscayne Aquifer 
within the service area.
Environmental Consequences
Under the No Action Alternative, FEMA funding would not be available for this wastewater 
management project. Although residents of the service area would still need to comply with 
Florida Statutory Treatment Standards of 2010, removal of nutrient and pathogen inputs to the 
shallow groundwater of Bay Point Key would not occur until a funding source is secured. 
Therefore, local groundwater quality would continue to degrade until Florida Statutory 
Treatment Standards of 2010 are implemented. Once the Florida Statutory Treatment Standards 
of 2010 are implemented, the effects to groundwater would be similar to Alternatives 2 and 3.
Under Alternative 2, FKAA would design and build a new WWTP to meet the BAT 
requirements of the Florida Statutory Treatment Standards of 2010. Treated effluent would still 
contain some nutrients even under conditions that meet the 2010 standards. However, by 
removing the septic and cesspool systems in the Bay Point and Saddlebunch Keys service area, 
the system would reduce the overall nutrient and pathogen inputs to the shallow groundwater of 
the island, and overall local groundwater quality would improve. An analysis performed in a 
representative service area of the Keys demonstrated that these improvements would be on the 
order of 73 and 86 percent reductions in TN and TP loadings using the BAT treatment standards, 
respectively (Appendix G). Construction of the transmission system and WWTP would have 
minimal impact on groundwater resources.
Implementation of Alternative 3 would remove septic and cesspool systems and FKAA would 
construct a collection system, pump station, and transmission system to collect and transport 
wastewater to the KWRU WWTP for treatment and disposal. Consequently, discharged 
wastewater would be eliminated in the Bay Point Key and Saddlebunch Key service areas, and 
the groundwater benefits would be better than Alternative 2 because there would be no project 
disposal wells in the service area. Although the KWRU WWTP is currently permitted to 20/20 
(TSS/BOD in mg/L) effluent disposal requirements, the WWTP treats effluent to high-level 
disinfection (water with fecal coliform values below detectable limits per 100 milliliters [ml] of 
sample) in accordance with 62-600 F.A.C., Regulations of Domestic Wastewater Facilities. This 
alternative includes treatment upgrades to meet the AWT requirements of the Florida Statutory 
Treatment Standards. Although KWRU would primarily dispose of treated effluent through reuse 
land application, six Class V shallow injection wells are the backup. One additional backup well 
may be required to accommodate Bay Point flows. Consequently, groundwater in the Stock 
Island area may improve when injection wells are used because the effluent would be treated to 
AWT. Current KWRU WWTP facility discharge TN and TP concentration data were not 
available for analysis. However, because AWT standards require a greater degree of nutrient 
removal, TN and TP effluent concentrations would expected to be lower than that of the current 
permit requirements. Effluent disposal through land application would not significantly affect 
groundwater in terms of quality or quantity, as described in PEA Section 3.2.2.2.2.3 
(Groundwater; Environmental Consequences; Disposal Option 2 – Wastewater Reuse). KWRU 
would dispose of treated effluent in excess of reuse land application capacity in Class V shallow 
injection wells at the WWTP site. KWRU currently utilizes six Class V shallow injection wells 
for this purpose. KWRU would add at least two additional wells to provide full backup to reuse 
land application. Alternative 3 would have similar impacts to groundwater as those described 
under Alternative 2. Construction of the transmission system and KWRU WWTP improvements 
would have minimal effects on groundwater. 
3.2.2	Inland, Nearshore, and Offshore Waters
Affected Environment
Project area surface water resources include: (1) canals for boat access to marinas and residential 
developments; (2) stormwater runoff to ditches and drainage systems in developed areas; and (3) 
nearshore and offshore marine waters. 
3.2.2.1	Inland Waters
Project area inland waters include artificial ponds, canals, and boat basins as described in PEA 
Section 3.2.3.1.1 (Inland Waters). Three canals and one boat basin are scattered throughout 
developed areas on Bay Point and Saddlebunch Keys. The artificial ponds are on Rockland Key 
and are the result of mining.
Canals and other confined water bodies showing signs of eutrophication during a review of 
Outstanding Florida Waters in the Florida Keys were listed as “hot spots” (refer to PEA 
Appendix C [Hot Spot Locations]). Monroe County (2000) ranked Bay Point Key as the third 
and sixth most critical “hot spots” believed to contribute to water quality degradation in the 
Lower Keys and Florida Keys, respectively.
3.2.2.2	Nearshore and Offshore Marine Waters
Kruczynski (1999) and Szmant and Forrester (1996) determined that, in general, nutrient 
pollution emanating from the Keys has greater nearshore effects than offshore effects due to 
dilution by tides and currents. Offshore areas in the Middle Keys that had higher nutrient levels 
than offshore areas in the Upper Keys were attributed to the relatively high nutrient content of 
Florida Bay (Kruczynski 1999; Szmant and Forrester, 1996). 
Project area nearshore and offshore marine waters are described in PEA Section 3.2.3.1.2 
(Nearshore and Offshore Marine Waters). Although Florida DOH collects beach water quality 
data from various monitoring stations, none were close enough to the Bay Point service area to 
gauge poor water quality public health risks in the vicinity. 
The Water Quality Monitoring Project for the Florida Keys National Marine Sanctuary’s Water 
Quality Protection Program maintains a monitoring station (Station 268, Saddlebunch Keys) near 
Bay Point and Saddlebunch Keys, southeast of the proposed project area. Established by the U.S. 
Environmental Protection Agency (EPA) in 1995, the Project goal is to characterize status and 
trends in Florida Keys’ water quality. Station 268 is about 3 miles southeast of the project area in 
Hawk Channel (Southeast Environmental Research Center [SERC], 2003). Although surface TN 
levels recorded at Station 268 from 1995 to 2003 fluctuate, they have averaged 0.187 parts per 
million (ppm); these levels are 6.4 percent higher than the average TN reading taken from all 
monitoring stations over this period of time, Keys-wide (0.176 ppm). Surface TP levels recorded 
at Station 268 also fluctuate, but they have averaged 0.007 ppm from 1995 to 2003. These levels 
are comparable to the Keys-wide average (0.007 ppm) recorded over the same time period. It is 
difficult to correlate these trends directly with nutrient loads from the Bay Point and 
Saddlebunch Key service area because of the distance from Station 268 from the service area and 
because there is no direct outlet for nearshore waters to reach Station 268 in Hawk Channel. 
The Water Quality Monitoring Project for the Florida Keys National Marine Sanctuary’s Water 
Quality Monitoring Protection Program maintains a monitoring station (Station 274, Boca Chica 
Channel) near the KWRU WWTP. Station 274 is about 2.04 miles southwest of KWRU WWTP 
in Hawk Channel (SERC, 2003).  Although surface TN levels recorded at Station 274 from 1995 
to 2003 fluctuate, they have averaged 0.177 ppm. These levels are comparable to the Keys-wide 
average of 176 ppm recorded over the same period. Surface TP levels recorded at Station 274 
also fluctuate, but they have averaged .007 ppm from 1995 to 2003. These levels are comparable 
to the Keys-wide average of 0.007 ppm recorded over the same time period. It is difficult to 
correlate these trends directly with nutrient loads from the KWRU WWTP because of the 
distance from Station 274 from the facility. Furthermore, KWRU primarily disposes its effluent 
through land application, so there would be limited nearshore water quality effects. Monitoring 
station results are likely more attributable to other WWTPs such as in the City of Key West.
3.2.2.3	Stormwater
Monroe County represents US-1 as the topographic divide for each island, whereby lands to the 
bay side of US-1 drain mainly toward Florida Bay, and lands on the ocean side of US-1 drain 
mainly toward the Florida Straits (Monroe County, 2000). Stormwater runoff from roads, 
bridges, driveways and yards, and parking lots contribute to nearshore water nutrient loading.  
On-site wastewater treatment systems overflow during storm events and contribute nutrient 
pollution and fecal contamination of stormwater runoff. Stormwater improvement projects have 
not been conducted within the project area.
Environmental Consequences
Under the No Action Alternative, effects on surface water quality near Bay Point and 
Saddlebunch Keys would likely continue due to nutrient and pathogen inputs from the islands’ 
on-site septic systems. Under this alternative FEMA would not fund this wastewater 
management project. Service area residents would still need to comply with Florida Statutory 
Treatment Standards of 2010. Once FKAA secures funding, effects on surface waters would 
likely be similar to those under Alternatives 2 and 3.
Under Alternative 2, BAT treatment would reduce TN and TP loading in canal and nearshore 
waters on the order of 73 percent and 86 percent, respectively (Appendix G). FKAA would 
dispose of treated effluent in class V shallow injection wells located at the facility.  
Under Alternative 3, water quality in Bay Point canal and nearshore waters would improve 
because wastewater inputs would be completely eliminated in the service area. FKAA would 
transmit untreated wastewater from the Bay Point Key and Saddlebunch Key service areas to the 
KWRU WWTP on Stock Island. KWRU would dispose of treated effluent primarily through 
reuse land application on the KWGC and the Monroe County Sheriff’s Office Detention Center. 
Uptake by plants, precipitation, and adsorption on contact with limestone bedrock would largely 
remove remaining nutrients in treated effluent as described in PEA section 3.2.3.2.2 (Inland, 
Nearshore and Offshore Waters; Environmental Consequences; Alternative 2  – Centralized 
Wastewater Treatment Plant Alternative – Disposal Option 2 – Reuse). KWRU would dispose of 
treated effluent in excess of reuse land disposal capacity in Class V shallow injection wells 
located at the KWRU WWTP.  The higher level effluent treatment under this alternative would 
indirectly benefit Stock Island’s canals and nearshore waters when injection wells are used for 
disposal.
Both Alternative 2 and 3 eliminate the nutrient pollution and fecal contamination of canal and 
nearshore waters caused by overflowing on-site wastewater treatment systems during storm 
events. Other effects on inland, nearshore, and offshore water quality are similar for Alternatives 
2 and 3. These effects are expected to be beneficial and are discussed in PEA Section 3.2.3.2.2 
(Environmental Consequences; Inland, Nearshore and Offshore Waters). 
FEMA recommends implementation of appropriate BMPs, development of an approved Erosion 
and Sediment Control Plan, and use of conventional site preparation techniques prior to and 
during construction to protect area water bodies and canals. Planned measures to control 
sediment from discharge to nearshore surface waters may include, but are not limited to, silt 
dams, barriers, and straw bales placed at the foot of sloped surfaces. Planned measures to control 
soil erosion may include, but are not limited to, grassing, mulching, watering, and seeding of on-
site surfaces. Site preparation may include grubbing of vegetative roots and topsoil materials, 
followed by surface compaction and fill placement to attain the required construction elevation.
3.2.3	Floodplains and Wetlands
Affected Environment
3.2.3.1	Floodplains
Executive Order (EO) 11988 (Floodplain Management) requires Federal agencies to minimize 
floodplain occupancy and alteration. Application of the EO 11988 Eight-Step Decision-Making 
Process, per 44 CFR Part 9, ensures that Federally funded projects comply with EO 11988. By 
its nature, the NEPA compliance process involves the same basic decision-making methods to 
meet its objectives as the Eight-Step Decision-Making Process. Therefore, FEMA has applied 
the Eight-Step Decision-Making Process through implementation of the NEPA process. 
The entire area of Stock Island, Bay Point Key, and Saddlebunch Key is located within the 
designated 100-year floodplain Zone AE (Figure 3-2; Flood Insurance Rate Map panel 
12087C1733H and 12087C1728H) (See PEA Section 3.2.4.1.1 [Floodplains] for a description of 
the Zones). Zone VE is located along the shoreline of Bay Point and Saddlebunch Keys, on the 
ocean side and bay side, seaward of Zone AE. 
 
[Figure 3-2. Project Area Floodplains (FEMA, 1999)
Figure 3-2 show the location and extent of the regulatexd flooplains in the project area.]

3.2.3.2	Wetlands
PEA Section 3.2.4.1.2 (Floodplains and Wetlands; Affected Environment-Wetlands) discusses 
wetland communities. Under EO 11990 (Wetland Protection), Federal agencies must minimize 
the destruction, loss, or degradation of wetlands and preserve and enhance their natural and 
beneficial values. FEMA applies the same EO 11990 Eight-Step Decision-Making Process, 
required by 44 CFR Part 9, to comply with EO 11990, as described above.
Two URS biologists conducted field investigations on August 1, 2002, and February 19, 2003, to 
identify wetlands within the project sites. Wetlands communities in the project areas consist of 
mangroves, salt marshes, and salt pans. Marine seagrass meadows also fall under the definition 
of wetland communities. The biologists qualitatively assessed all sites during the field 
investigations and identified no freshwater wetlands within the Bay Point site or at KWRU 
WWTP, although they identified wetlands along the south margin of the periodically mowed US-
1 ROW (Figure 3-3).
A narrow mangrove fringe is located along the south margin of the US-1 ROW between Bay 
Point Key and Shark Channel, and between Rockland Key and Key Haven. Dominant species 
comprising the mangrove fringe include Brazilian pepper (Schinus terebinthifolius), red 
mangrove (Rhizophora mangle), black mangrove (Avicennia germinans), white mangrove 
(Laguncularia racemosa), buttonwood (Conocarpus erectus), bushy seaside oxeye (Borrichia 
frutescens), and seagrape (Coccoloba uvifera). In addition, the biologists identified four fringing 
mangrove wetlands and one freshwater depressional wetland south of the maintained US-1 ROW 
on Big Coppitt Key. The mangrove wetlands were similar to those identified elsewhere along the 
US-1 corridor. The biologists observed dominant species within the freshwater wetland, located 
at MM 10.6, include cattail (Typha sp.), Brazilian pepper, buttonwood, lead tree (Leucaena 
leucocephala), rusty flat sedge (Cyperus odoratus), and saltgrass (Distichlis spicata). Field 
investigation photographs are located in Appendix C.
Environmental Consequences
Under the No Action Alternative, effects on floodplains and wetlands would be similar to those 
of Alternatives 2 and 3. The No Action Alternative would have no notable effect on the 
floodplain. Without FEMA funding, water quality degradation in the above described wetlands 
would continue, until FKAA upgrades systems with another funding source. However, there 
would be no notable effect to wetland communities. In the absence of Federal funding, EO 
11988 and 11990 would not apply; meaning wastewater system designs would only have to 
comply with Monroe County’s Floodplain Ordinance and be protected to the 100-year flood 
level. PEA Section 3.2.4.2.1 further describes specific floodplain ordinance provisions. 
As discussed in PEA Section 3.2.4.2.2 (Centralized Wastewater Treatment Plant Alternative) 
implementation of Alternatives 2 and 3 would not have notable effects on floodplains. Since 
WWTPs are considered critical facilities, KWRU and FKAA would protect the plants and  
critical operating components to the 500-year flood, through elevation or floodproofing, to 
protect the Federal investment from flood damages, per EO 11988 as outlined at 44 CFR Part 
9.11.  Because much of the Keys is in the 100-year floodplain, there are no practicable 
alternatives to siting these facilities in the floodplain. 
Under Alternative 3, although FKAA would build the collection system, pump station, and 
transmission system within the floodplain and next to mangrove wetlands, construction would 
not notably affect any wetlands or floodplains. FKAA would site sliplining work areas outside of 
jurisdictional wetlands using appropriate BMPs and an Erosion and Sediment Control Plan, as 
stated in Alternative 2, to ensure no effects on wetland resources. As with Alternative 2, FKAA 
would protect the collection system’s critical operating components, such as the VPS, to the 500-
year flood, per EO 11988 and 44 CFR Part 9.11.
There is public concern that the proposed WWTP under Alternative 2 and WWTP improvements 
under Alternative 3 would lead to further floodplain development in the project area by 
introducing key infrastructure, which is often linked to additional development. However, Keys 
development is not controlled by the addition of key infrastructure but, instead, by Monroe 
County’s Rate of Growth Ordinance (ROGO) permit allocation system, as described further in 
PEA Section 3.10 (Land Use and Planning). FKAA proposes to build a wastewater treatment 
system in the Keys to effectively treat existing wastewater flows, not as a way to introduce or 
support floodplain development. Therefore, if growth and development in the floodplain occur 
after implementation of either alternative, they are the result of established county planning and 
are not directly related to this proposed wastewater project. Given the above points, FEMA did 
not conduct an evaluation of secondary effects on floodplains with regard to the potential for 
increased development under the alternatives. It should be noted per Table 1-1, Bay Point and 
Saddlebunch Keys are mostly developed.
Under Alternatives 2 and 3, no direct effects on wetlands are anticipated on Bay Point or 
Saddlebunch Keys because no wetlands exist at the proposed WWTP site or along service area 
roads. FKAA would site sliplining work areas outside of wetlands using appropriate BMPs and 
an Erosion and Sediment Control Plan to minimize negative effects on nearby wetlands.
As stated in PEA Section 3.2.2.2 (Inland, Nearshore and Offshore Waters; Environmental 
Consequences), FEMA recommends the use of appropriate BMPs and development and full 
implementation of an FDEP- and South Florida Water Management District-approved Erosion 
and Sediment Control Plan prior to and during construction to protect area water bodies and 
wetlands. Planned measures to control sediment from discharge to nearshore surface waters 
include, but are not limited to, silt dams, barriers, and hay bales placed at the foot of sloped 
surfaces.
3.3	BIOLOGICAL RESOURCES
As in much of the Keys, humans have significantly altered the land within the project area 
through urban development activities, including clearing and filling. Of the six major native 
terrestrial communities (pine rocklands, tropical hardwood hammocks, mangroves, salt marsh, 
freshwater systems, and dunes/coastal ridges) that are Keys-wide and further described in PEA 
Section 3.3.1.1 (Terrestrial Environment), two types (mangroves and salt marsh) are found near 
the project areas. All of the four marine communities (seagrasses, coral reefs, hardbottom, and 
sandy bottom) that are in the Keys are found near the project areas. The following two sections 
discuss terrestrial and aquatic ecosystems separately. PEA Section 3.3 (Biological Resources) 
describes the existing ecosystem on a region-wide basis.
Two URS biologists conducted field investigations on August 1, 2002 and February 19, 2003, to 
verify preliminary terrestrial community type boundaries established from office literature 
reviews and photo interpretation. A composite list of plant species identified within the project 
sites is in Table 3-2. Section 3.3.3 describes the potential for special status species to exist in the 
project area. Field investigation photographs are in Appendix C (Site Photographs).

Table 3-2. Observed Plant Species (URS site visit; August 1, 2002)

Common Name Yellow joyweed

Scientific Name Alternanthera flavescens
Common Name Bluestem grasses

Scientific Name Andropogon sp.
Common Name Black mangrove

Scientific Name Avicennia germinans
Common Name Beggarticks

Scientific Name Bidens alba var. radiata
Common Name Bushy seaside oxeye
Borrichia frutescens
Common Name Australian pine

Scientific Name Casuarina equisetifolia
Common Name Seagrape

Scientific Name Coccoloba uvifera
Common Name Buttonwood

Scientific Name Conocarpus erectus
Common Name Rusty flat sedge

Scientific Name Cyperus odoratus
Common Name Durban crowfoot grass

Scientific Name Dactyloctenium aegyptium
Common Name Saltgrass

Scientific Name Distichlis spicata
Common Name White mangrove

Scientific Name Laguncularia racemosa
Common Name White leadtree

Scientific Name Leucaena leucocephala
Common Name Capeweed

Scientific Name Phyla nodiflora
Common Name Red mangrove

Scientific Name Rhizophora mangle
Common Name Australian umbrella tree

Scientific Name Schefflera actinophylla
Common Name Brazilian pepper

Scientific Name Schinus terebinthifolius
Common Name Common wireweed

Scientific Name Sida acuta
Common Name Indian hemp

Scientific Name Sida rhombifolia
Common Name Potatotree

Scientific Name Solanum erianthum
Common Name Shrubby false buttonweed

Scientific Name Spermacoce verticillata
Common Name Creeping oxeye, wedelia

Scientific Name Sphagneticola trilobata
Common Name West Indian dropseed

Scientific Name Sporobolus indicus var. pyramidalis
Common Name Cattail

Scientific Name Typha sp.

Affected Environment
3.3.1	Terrestrial Environment
Exotic species, as characterized by the Florida Keys Advance Identification of Wetlands (ADID) 
mapping project, dominate the project area, although limited areas of mangroves exist 
(McNeese, 1998; Figure 3-3; Table 3-3).

Table 3-3. Service Area Vegetation (McNeese 1998)


Habitat Type Developed
Acres 80
Habitat Type Canals and other surface waters
Acres 0
Habitat Type Tropical hardwood hammock
Acres 0
Habitat Type Mangroves and Salt Marsh
Acres 2.6
Habitat Type Exotic vegetation
Acres 7.7
Habitat Type Total
Acres 90.3 

 
[Figure 3-3. Project Area Vegetation (McNeese, 1998)
Figure 3-3 Show the vegetation types in the Bay Point and Saddlebunch Keys Project Area]

The proposed WWTP (Alternative 2) and VPS (Alternative 3) sites, located on the ocean side of 
US-1 on Bay Point Key, have invasive exotic plants and grass cover (Figure 3-3). Vegetation 
includes Australian pine (Casuarina equisetifolia), Brazilian pepper, several umbrella trees 
(Schefflera actinophylla), and potatotrees (Solanum erianthum). Vegetation dominant in the 
western portion of the site of the site includes yellow joyweed (Alternanthera flavescens), 
beggarticks (Bidens alba var. radiata), false buttonweed (Spermacoce verticillata), Indian hemp 
(Sida rhombifolia), common wireweed (Sida acuta), wedelia (Sphagneticola trilobata), 
capeweed (Phyla nodiflora), West Indian dropseed (Sporobolus indicus var. pyramidalis), 
bluestem grasses (Andropogon spp.), and crowfoot grass (Dactyloctenium aegyptium).
Upland areas within the periodically mowed and maintained US-1 ROW between Bay Point 
Key, Saddlebunch Key, and Stock Island are primarily vegetated with grasses and weeds grading 
south to a forested fringe of coastal wetland vegetation with an open connection to the Atlantic 
Ocean. Vegetation within the maintained ROW consists of Bermuda grass (Cynodon dactylon), 
St. Augustine grass (Stenotaphrum secundatum), and crowfoot grass. A few planted ornamentals 
consisting mainly of coconut palms (Cocos nucifera) were also present along portions of the 11-
mile corridor.
During the field investigations, the biologists observed mockingbirds (Mimus polyglottos), 
Eurasian collared doves (Streptopelia decaocto), and mourning doves (Zenaida macroura) near 
the proposed WWTP site. They also observed various sea birds such as gulls, terns, cormorants, 
and pelicans during the site visit. Additionally, biologists heard unidentified bird species calling 
or singing near the proposed construction sites.
The biologists observed brown anoles (Anolis sagrei) near the proposed construction sites. They 
observed no other reptiles, amphibians, or mammals during the field investigation nor nests, 
burrows, or other roosting means near the proposed work or construction sites.
A discussion of individual habitat types is below.
3.3.1.1	Pine Rocklands and Tropical Hardwood Hammocks
Pine rocklands and tropical hardwood hammocks are limited in distribution throughout the 
Lower Keys but are not present in the project sites (Figure 3-3). 
3.3.1.2	Mangrove Forests and Salt Marshes
Throughout the Keys, mangroves form the predominant coastal vegetation community. 
Mangroves exist along the edges of shorelines, bays, and lagoons and on overwash areas 
throughout the Keys. PEA Section 3.3.1.1.2 discusses mangroves and salt marshes.
Fringing mangroves dominate shorelines near the project sites. Three mangrove tree species—
red mangrove (Rhizophora mangle), black mangrove (Avicennia germinans), and white 
mangrove (Laguncularia racemosa)—are the dominant components. The service area has about 
2.65 acres of mangrove habitat (Figure 3-3). There is no salt marsh habitat in the service area 
(Figure 3-3).
3.3.1.3	Freshwater Systems
There are no freshwater wetlands in the project sites (Figure 3-3).
3.3.1.4	Dunes and Coastal Ridges
Dune systems form along sandy beaches where wind and wave-borne sand is trapped and 
accumulated by extremely salt-tolerant, low-lying beach vegetation. Dunes and coastal ridges are 
not present within the project sites (Figure 3-3).
3.3.2	Aquatic Ecosystem
Marine habitats are present within the human-made canals and marine waters surrounding Bay 
Point and Saddlebunch Keys and Stock Island. Seagrasses and hardbottom communities 
dominate marine habitats near the Bay Point and Saddlebunch Key project site, and bare 
substrate (sandy bottom), seagrass communities dominate near the KWRU site on Stock Island. 
Areas of coral reefs and hardbottom/seagrass are also present within 2 to 3 miles of the project 
sites. (Figure 3-4). A discussion of individual marine community types is below.
 
[Figure 3-4. Project Area Benthic Habitats (Florida Marine Research Institute [FMRI], 1992)
Figure 3-4 shows the types of marine benthic habitat inthe Bay Point and Saddlebunch Keys area and
the Stock Island Area.]

As described in PEA Section 3.3.3 (Special Status Species), essential fish habitat (EFH) present 
near the project sites consists of estuarine seagrass, marine live/hard bottom, mangrove 
communities, and marine water column. In the Keys, the Gulf of Mexico Fishery Management 
Council (GMFMC) and South Atlantic Fishery Management Council (SAFMC) manage 
federally regulated fisheries. A compiled list of fishery species under GMFMC and SAFMC 
management is in Appendix F.
All four of the marine communities (seagrasses, coral reefs, hardbottom and sandy bottom) that 
exist in the Keys are found near the project sites. 
3.3.2.1	Seagrass Beds and Sand Flats
Seagrass communities are the most abundant sea bottom community type in the Keys. Interacting 
factors, including sediment depth, water quality, water depth, and current velocity, influence 
distribution of seagrass communities (FMRI, 2000). Turtle-grass (Thalassia testudinum) and 
manatee-grass (Syringodium filiforme) dominate seagrass communities, with shoal-grass 
(Halodule wrightii) becoming dominant in more eutrophic areas (Fonseca et al., 1998). 
Near the Bay Point and Saddlebunch Key project sites, seagrass communities dominate the 
bayside nearshore areas between Bay Point and Saddlebunch Keys and throughout the artificial 
waterways in Bay Point Key (Figure 3-4). This community type also exists on the south and 
southeast sides of these islands in combination with hardbottom communities. Near the Stock 
Island project site, seagrass communities dominate the oceanside area to the south of the KWRU 
WWTP. PEA Section 3.3.1.2.1 (Seagrass Beds and Sand Flats) describes the affected 
environment for seagrass beds and sand flats.
3.3.2.2	Coral Reefs
In the Lower Keys, the reef tract extends from the south side of Hawk Channel from Looe Key 
Reef to Cosgrove Shoal, south of the Marquesas. The reef tract is about 5 to 8 miles south of the 
project sites.  However, patch reefs occur near the Bay Point and Saddlebunch Keys project sites, 
about 2 miles to the south and near the Stock Island project site, about 2 miles to the southeast.  
Both reef sites occur along the inshore side of Hawk Channel (FMRI, 2000). PEA Section 
3.3.1.2.2 (Coral Reefs) describes the affected environment for coral reef communities.
3.3.2.3	Hardbottom
Hardbottom habitats are solid, flat, low-relief, rock substrate composed of rock and/or rubble that 
is exposed or covered with a thin layer of sediment (FMRI, 2000). Nearshore hardbottom is the 
dominant marine ecological community throughout the Keys. Low-relief hardbottom 
communities are characterized by their proximity to shore, shallow depth, and visual dominance 
of octocorals (Chiappone and Sullivan, 1994). These communities occur within 1.25 miles of 
shore on either side of the Keys at depths of about 3 to 16 feet (Chiappone and Sullivan, 1996). 
Near the Bay Point and Saddlebunch Key project sites, hardbottom communities are present on 
the west side of Saddlebunch Key and in areas south of this island (Figure 3-4).  Near the Stock 
Island project site, hardbottom communities are present southwest and southeast of KWRU 
WWTP. PEA Section 3.3.1.2.3 (Hardbottom) describes the affected environment for hardbottom 
communities. 
3.3.2.4	Sandy Bottom
Bare bottom communities, over either calcareous muds or calcareous sand, lack algae and 
seagrasses. The associated flora and fauna is sparse and typically dominated by sponges, small 
corals, and calcareous algae (Chiappone, 1996).
Near the project areas, sandy bottom communities are present throughout the artificial waterways 
in the project sites (see Figure 3-4). PEA Section 3.3.1.2.4 (Sandy Bottom) describes the affected 
environment for sandy bottom communities.
Environmental Consequences
3.3.2.5	Alternative 1 – No Action Alternative
Under the No Action Alternative, FKAA would implement improved wastewater management 
activities to meet the Florida Statutory Treatment Standards of 2010. Implementation of a 
WWTP that meets Florida Statutory Treatment Standards of 2010 would reduce nutrient loading 
in nearshore marine waters and result in a corresponding improvement of long-term ecological 
health. However, without FEMA funding, the FKAA would need to get alternate financing, 
which would delay wastewater treatment improvements. As discussed in PEA Section 3.3.2.1 
(Alternative 1 – No Action Alternative), while mangrove swamps could benefit slightly from 
higher TP concentrations, coral reefs prefer nutrient-poor environments with clear waters and 
low turbidity. Adverse effects on nearshore marine habitats would continue as a result of septic 
tank and cesspools effluents, which lead to increased eutrophication of nearshore marine waters. 
Therefore, area reefs would continue to be adversely affected by high nutrient levels until Florida 
Statutory Treatment Standards of 2010 are implemented.
3.3.2.6	Alternative 2 – New Wastewater Treatment Plant Construction
Proposed WWTP construction would directly affect about 0.31 acre of exotic vegetation. Force 
main installation within the existing 18-inch FKAA abandoned pipeline would require 
construction in sliplining work areas and possibly several small pump stations. This would 
require temporarily clearing an approximately 4-foot by 4-foot area (for pipe access) covered 
with grass. No additional work space would be necessary, and FKAA would allow the grass to 
naturally revegetate the cleared area. Individual homeowners’ landscape plants may be directly, 
but temporarily, affected by connection of individual residences to the collection system.  
No direct effects on marine biological resources would likely occur from construction of the 
collection system and treatment plant because FKAA has proposed construction activities along 
the roads in front of service area residences and businesses. Although there would be no direct 
effects on marine resources, wastewater improvements would indirectly affect the nearshore 
marine waters near Bay Point and Saddlebunch Keys. An analysis performed in a representative 
service area of the Keys demonstrated that these improvements would be on the order of 73 and 
86 percent reductions in TN and TP loadings using the BAT treatment standards, respectively 
(Appendix G).  Similar results would likely occur in the Bay Point and Saddlebunch Keys 
service area. Although treated to Florida Statutory Treatment Standards of 2010, the effluent 
would have a higher level of nutrients than ambient concentrations.  
In general, as discussed in PEA Section 3.3.2.1 (Alternative 1 – No Action Alternative), while 
mangrove swamps could benefit slightly from high TP levels (i.e., high nutrient environment), 
coral reefs prefer oligotrophic (low nutrient) environments with clear waters and low turbidity 
and therefore are adversely affected by higher nutrient levels. Although there is little available 
research that specifically assesses the effect of effluent treated to BAT standards on biological 
resources, there is much available research that supports the basic principle that reducing nutrient 
loading in nearshore marine waters would probably result in a corresponding incremental 
improvement to long-term ecological health (if all other factors do not change, e.g., no increased 
nutrient loading from other sources.).
3.3.2.7	Alternative 3 – Existing Plant Upgrade and Expansion and New Wastewater 
Transmission System Construction
The effect of Alternative 3 on terrestrial and marine biological resources would be similar to 
those of Alternative 2. Individual homeowner connection effects on biological resources would 
be as discussed above for Alternative 2. No notable terrestrial or aquatic ecosystem effects would 
be associated with the transmission system. Trenching from MM 4 to MM 5 would be done in 
the ROW. No notable terrestrial or marine biological resource effects are expected from 
disposing of an additional 72,000 gpd of treated effluent through reuse-land application on the 
golf course and Sheriff’s Office Detention Center. Uptake by plants, precipitation, and 
adsorption on contact with limestone bedrock would largely remove remaining nutrients in 
treated effluent as described in PEA section 3.2.3.2.2 (Inland, Nearshore and Offshore Water; 
Environmental Consequences; Alternative 2  – Centralized Wastewater Treatment Plan 
Alternative – Disposal Option 2 – Reuse).  Capacity and AWT upgrades to the KWRU WWTP 
would result in reduced nutrient discharge to Stock Island area groundwater (when backup cells 
are used), which would indirectly improve nearshore water quality. Although treated to Florida 
Statutory Treatment Standards of 2010, the well effluent would have a higher level of nutrients 
than ambient concentrations. Under Alternative 3, long-term aquatic ecosystem health from 
better water quality in the service and Stock Island area would be eliminated on Bay Point and 
Saddlebunch. Specific beneficial effects on marine ecological communities would be as 
described under Alternative2.
3.3.3	Special Status Species
Affected Environment
The Endangered Species Act (ESA) of 1973 requires Federal agencies to consider effects of their 
actions on threatened and endangered species and their designated critical habitats, and to take 
steps to conserve and protect these species and habitats. Federal agencies must also comply with 
the Magnuson-Stevens Fishery Conservation and Management Act (MSA) (16 U.S.C. 1801 et 
seq.) that requires EFH identification for Federally managed fishery species and implementation 
of measures to conserve and enhance this habitat per the Sustainable Fisheries Act (SFA) Public 
Law 104-297. PEA Section 3.3.3.1 (Special Status Species; Affected Environment) describes 
special status species.
Two URS biologists conducted a site visit on August 1, 2002 and February 19, 2003, 
concurrently with vegetation and wildlife investigations, to investigate the potential presence of 
Federally protected species and suitable habitat for these species in the project area and sites. The 
biologists observed no State- or Federally listed species in any of the proposed construction sites 
and very little habitat that could support Federally listed terrestrial threatened and endangered 
species that potentially live in or use this part of the Florida Keys. Vegetated portions of the 
proposed construction sites consist of disturbed weedy and landscape plants; therefore, no 
portions of the proposed construction sites are likely to provide nesting, roosting, or foraging 
habitat for any special status species that live in or use this part of the Florida Keys. The fringing 
coastal mangrove wetlands, located around the project area, provide feeding habitat for the 
osprey (Pandion haliaetus), listed as a Species of Special Concern in Monroe County.
Environmental Consequences
Under the No Action Alternative, FEMA would not fund these wastewater management 
improvements. As such, FEMA would not be required to undertake activities related to 
compliance with ESA Section 7 and EFH. Bay Point and Saddlebunch Key residents would still 
need to comply with Florida Statutory Treatment Standards of 2010. Effects on special status 
species, once FKAA secures funding, would likely be similar to those under Alternatives 2 
and 3.
FEMA consulted the U.S. Fish and Wildlife Service (USFWS) and the National Marine Fisheries 
Service (NMFS) regarding the potential effects of Alternatives 2 and 3. URS biologists 
conducted site investigations and, based on information collected, found that the proposed 
alternatives would not likely adversely affect special status species. In a letter dated May 6, 
2003, FEMA initiated informal consultation with USFWS and NMFS, provided its findings, and 
requested determination concurrence. On May 19 and September 17, NMFS and USFWS, 
respectively, concurred with FEMA’s ESA ‘no effect’ determinations for Federally listed species 
and their critical habitat. Therefore, ESA Section 7(a)(2) requires no further action. Similarly, on 
May 29, 2003, NMFS concurred with FEMA’s finding that neither alternative would be likely to 
affect EFH; therefore, no further action is required under MSA and SFA. Agency coordination 
letters for this SEA are in Appendix B.
A letter, dated May 6, 2003, was sent to the Florida Fish and Wildlife Conservation Commission 
(FFWCC) concerning State listed species. No project comments were provided in FFWCC’s 
response on July 11, 2003, via the Florida State Clearinghouse.
3.4	AIR QUALITY
Affected Environment
Air pollution within the project area has not been extensively documented; however, motor 
vehicles are usually the main source of emissions. The FDEP has designated Monroe County as 
an air quality attainment area, which means that air quality standards set by both FDEP and the 
EPA are maintained countywide (Monroe County, 1995). Air quality in the Florida Keys is 
generally excellent, and data from FDEP’s two ambient air monitoring stations in Key West and 
Marathon indicate that particulate matter concentrations remain well below State standards. The 
affected environment for air quality is similar to that described in PEA Section 3.4.1 (Air 
Quality; Affected Environment).
Environmental Consequences
Under the No Action Alternative, FEMA would not fund the wastewater management 
improvements. Bay Point and Saddlebunch Key residents would still need to comply with 
Florida Statutory Treatment Standards of 2010. Effects on air quality, once FKAA secures 
funding, would likely be similar to those under Alternatives 2 and 3.
Under Alternatives 2 and 3, minor temporary adverse effects on air quality would occur during 
construction as a result of increased exhaust pollutants and fugitive dust. FKAA would mitigate 
these temporary effects through standard construction practices, including decreased idle time 
and watering down construction areas. WWTP operational effects on air quality would be similar 
to those discussed in PEA Section 3.4.2.2 (Environmental Consequences, Alternative 2 – 
Centralized Wastewater Treatment Plant).
During WWTP operation, atmospheric air used for transport within the collection system would 
enter through 4-inch screened air intakes on the gravity lines. It is unlikely that odor would come 
from these air inlets due to the small volume of sewage (10 gallons) and short detention times in 
the sumps. The system would provide odor control at the treatment plant headworks, where 
screens and screenings press would eliminate odors. Therefore, no notable long-term adverse 
effects on air quality would likely occur.
3.5	CULTURAL RESOURCES
Affected Environment
PEA Section 3.5.1 (Cultural Resources; Affected Environment) provides an overview of Monroe 
County’s cultural history. In addition to review under NEPA, consideration of effects on cultural 
resources is mandated under Section 106 of the National Historic Preservation Act (NHPA), as 
amended, and implemented by the regulations in 36 CFR Part 800. These regulations include a 
process of identifying significant historic properties that proposed projects may affect. For the 
purposes of Section 106, historic properties are archaeological sites, buildings, structures, 
districts, or sites that are listed in or are eligible for listing in the National Register of Historic 
Places (NRHP) (36 CFR 60.4). 
As defined in 36 CFR Part 800.16(d), the Area of Potential Effect (APE) “is the geographic area 
or areas within which an undertaking may directly or indirectly cause changes in the character or 
use of historic properties, if any such properties exist.” The Alternative 2 APE consists of the 
proposed construction site for the combined WWTP and VPS, and the wastewater force main 
that would be sliplined within an existing abandoned FKAA water main from Saddlebunch Key 
to Bay Point (Figure 2-1). The Alternative 3 APE consists of a small area within the Alternative 
2 WWTP site (for the VPS) and a wastewater conveyance corridor from Bay Point and 
Saddlebunch Key to the existing KWRU WWTP on south Stock Island, a distance of about 11 
miles. FKAA would slipline portions of the force main within the existing FKAA abandoned 
water main. FKAA would install the force main portions not sliplined within the abandoned 
water main by trench excavation within the US-1 ROW. 
In addition to identifying historic properties that may exist in the proposed project’s APE, the 
Federal agency must also determine, in consultation with the Florida State Historic Preservation 
Officer (SHPO), what effect, if any, the action would have on historic properties. Moreover, if 
the project would have an adverse effect on these properties, then the Federal agency must also 
consult with the SHPO on ways to avoid, minimize, or mitigate the adverse effect.
A URS archaeologist conducted a Cultural Resources Assessment of Alternative 2 and 3 on 
August 1, 2002, to assist FEMA’s project planning, ensure NEPA and NHPA compliance, and 
provide the SHPO with information on potential cultural resource effects. The assessment 
included a records search at the Florida Master Site File Preservation Office, and a 100 percent 
pedestrian reconnaissance survey of the APE, which consisted of the proposed WWTP and VPS 
location on Bay Point, and the force main from Saddlebunch Key to Bay Point. The SHPO’s site 
files did not list any archaeological sites within or next to the APE. However, the archaeologist 
noted six aboveground resources that may be eligible for NRHP listing. These are all bridges, 
and may be part of the Overseas Highway Railroad Bridge (OHRB) system. The soils varied 
throughout the APE. At the proposed WWTP and VPS site on Bay Point, soils appear to consist 
of 3 to 6 inches of turf grass Udrothents-Urban Land Complex; overlying limestone bedrock; 
and, within the proposed force main alignment between Saddlebunch Key and Bay Point, fill 
material from OHRB and FKAA water main (abandoned) construction. A walking survey of the 
proposed WWTP and VPS site identified no artifacts or cultural features within the project’s 
APE. For Alternative 2, reconnaissance survey identified one aboveground cultural resource in 
the APE, the concrete arch OHRB over Saddlebunch No. 2 Channel. This OHRD may be eligible 
for listing in the NRHP. For Alternative 3, five additional potential OHRBs are located along the 
transmission corridor. 
The results of the assessment indicate a low potential for archaeological resources to be present 
within the APE for both Alternatives. Both Alternatives may affect OHRB bridges. No other 
aboveground cultural resources were identified within or near the APE.
Environmental Consequences
Under the No Action Alternative, FEMA would not fund the wastewater management project. 
Bay Point and Saddlebunch Keys residents would still need to comply with Florida Statutory 
Treatment Standards of 2010. If Bay Point and Saddlebunch Keys obtain funding through non-
Federal entities to comply with Florida Statutory Treatment Standards, the locality would not be 
required to comply with Section 106 of the NHPA. Effects on cultural resources, once FKAA 
secures funding, would likely be similar to those under Alternatives 2 and 3.
Both Alternatives 2 and 3 may affect aboveground resources, i.e., parts of the OHRBs, by 
changing brackets that attach the water main to the bridges. In consultation with SHPO, FEMA 
found neither undertaking would effect historic properties. On November 10, 2003, the SHPO 
concurred with FEMA’s determination for archaeological resources and the bridges. Changing 
the hardware that mounts the water main on the bridges would not adversely affect the OHRBs’ 
historic character-defining features.
In addition, if FKAA finds any historic or archeological items during project work, FKAA would 
immediately stop all activities on the site and consult with FEMA, SHPO, and other appropriate 
agencies for further actions to fully comply with NHPA Section 106 and other applicable 
requirements. Furthermore, if FKAA discovers human remains, FKAA would implement 
Florida’s unmarked human burial law (Florida Statute Title XLVI, 872.05 Unmarked human 
burials), specifically:
When an unmarked human burial is discovered…all activity that may disturb the 
unmarked human burial shall cease immediately, and the district medical 
examiner shall be notified. Such activity shall not resume unless specifically 
authorized by the district medical examiner or the State Archaeologist. If the 
district medical examiner finds that the unmarked human burial may be involved 
in a legal investigation or represents the burial of an individual who has been dead 
less than 75 years, the district medical examiner shall assume jurisdiction over 
and responsibility for such unmarked human burial, and no other provisions of 
this section shall apply. The district medical examiner shall have 30 days after 
notification of the unmarked human burial to determine if he or she shall maintain 
jurisdiction or refer the matter to the State Archaeologist. If the district medical 
examiner finds that the unmarked human burial is not involved in a legal 
investigation and represents the burial of an individual who has been dead 75 
years or more, he or she shall notify the State Archaeologist, and the division may 
assume jurisdiction over and responsibility for the unmarked human burial 
pursuant to subsection (6) [of Florida Statute 872.05]. When the division assumes 
jurisdiction over an unmarked human burial, the State Archaeologist shall consult 
a human skeletal analyst who shall report within 15 days as to the cultural and 
biological characteristics of the human skeletal remains and where such burial or 
remains should be held prior to a final disposition [Florida Statute Title XLVI, 
Chapter 872.05]. 
3.6	SOCIOECONOMIC RESOURCES
3.6.1	Tourism
Affected Environment
Tourist facilities near the project sites are concentrated along the US-1 corridor. However, other 
than two public boat ramps, there are no tourist facilities within the service area. According to 
U.S. Census results (2000), 13 percent of the housing units in the Bay Point Key and 
Saddlebunch Key areas (an area larger than the service area) are seasonal residences, rentals, or 
other occasional use. Tourist populations and activities are mostly west of the service area, in 
Key West.

Table 3-4.	 Service Area Businesses


Business Name Baby’s Coffee
Location MM 14.8 Overseas Highway
Business Name Bluewater Key RV Resort
Location MM 14 Overseas Highway

Environmental Consequences
Under the No Action Alternative, FEMA would not fund the proposed wastewater management 
project. Local sources may fund this wastewater project, which may increase local taxes. These 
costs could be passed on to Keys tourists through higher costs for hotels, food, and other goods 
and services. In addition, economic losses from decreased water quality, such as area beach 
advisories and storm damage of the existing wastewater infrastructure, would continue until 
wastewater improvements were implemented.
Under Alternative 2, adverse construction effects on tourism in the Bay Point and Saddlebunch 
Keys service area would be short-term and minimal, because this area is not a tourism focal 
point. Collection system installation would temporarily hinder, but not obstruct, traffic 
movement throughout residential areas in Bay Point and Saddlebunch Keys. Appropriate signage 
and traffic management (as described in PEA Section 3.9.1, Traffic and Circulation) would 
reduce this effect. For Alternative 2, installation and operation of the treatment plant, or pump 
station, would not likely affect tourism beyond those effects described in PEA Section 3.6.1.2.1 
(Socioeconomic Resources; Tourism; Environmental Consequences – Alternative 2).  Tourism 
effects and mitigation measures for Alternative 3 would be similar to those of Alternative 2.  
Transmission system installation along the US-1 ROW and connection to the KWRU WWTP on 
Stock Island would cause temporary, minor traffic interruptions.    
3.6.2	Fishing Industry
Affected Environment
The Lower Keys’ north-south alignment creates long channels between the islands, with 
numerous well-protected shallow bays, flats, and mangrove islands. The flats usually have the 
best tarpon, bonefish, permit, barracuda, and shark fishing, whereas the channels usually have 
the best grouper, snapper, and jack fishing. During the spring, tarpon feed in the churning waters 
caused by tidal currents flowing through the bridge pilings in the passes. Species recreationally 
harvested offshore in the Gulf of Mexico include grouper, snapper, permit, cobia, and shark. 
Species recreationally harvested offshore in the Atlantic Ocean include dolphin, sailfish, blue 
and white marlin, wahoo, king mackerel, blackfin tuna, and barracuda. Inshore reef fishing 
targets large groupers; snapper including lane, gray, and yellowtail; king mackerel; jacks; cobia; 
and barracuda. Commercially harvested species that may occupy Bay Point and Saddlebunch 
Key nearshore waters include spiny lobster, white mullet, gray snapper, various flounder, 
shrimp, and stone crab.
Environmental Consequences
Under the No Action Alternative, FEMA would not fund the proposed wastewater management 
project. Service area residents would still need to comply with Florida Statutory Treatment 
Standards of 2010. The MSA and the SFA would not apply because Federal funds are not being 
used. Effects on the fishing industry, once FKAA secures funding, would likely be similar to 
those under Alternatives 2 and 3. 
Under Alternatives 2 and 3, FEMA would fund construction of a wastewater treatment system. 
Either alternative would improve nearshore water quality, which, in turn, would incrementally 
benefit commercial and recreational species currently being adversely affected by poor water 
quality in the Bay Point area. PEA Section 3.6.2.2 (Environmental Consequences) describes 
beneficial effects on commercial fishing. Furthermore, FEMA consulted the NMFS regarding 
potential fishery effects of Alternatives 2 and 3. The NMFS stated in its letter of May 19, 2003, 
that neither alternative would likely affect EFH; therefore, MSA and SFA require no further 
action. Agency coordination letters for this SEA are in Appendix B.
3.6.3	Local Fees and Taxes
Affected Environment
Monroe County residents must pay county, State, and Federal taxes. The average property tax 
rate for all Monroe County districts is 13.4 percent of the appraised property value, excluding 
property tax deductions such as the homestead exemption (Monroe County, 2001b). Several 
governmental agencies within Monroe County affect the total property tax rate. Additional 
details on local taxes are in PEA Section 3.6.3.1 (Local Fees and Taxes, Affected Environment).
3.6.3.1	Existing Wastewater Management Costs in the Bay Point Service Area
For the purpose of this SEA, wastewater management cost discussions include reference to: 
1) system capital costs, which include expenses associated with planning, designing, 
engineering, purchasing, building, and installing a wastewater treatment system, and the required 
wastewater conveyance piping in public ROWs and selected effluent disposal method; 
2) abandonment and lateral costs, which include the expenses associated with removal and 
disposal of the existing wastewater treatment system and piping on service recipients’ property 
for connection to a new system; and 3) operation and maintenance (O&M) costs for the new 
system.
Five basic types of wastewater systems are presently used in Monroe County: cesspits, septic 
tanks, on-site ATUs, OWNRS, and centralized WWTPs. Septic systems collect sewage in a tank 
and allow the liquid waste to filter through the drainfield into shallow soils and subsurface 
limestone. For septic systems in working condition, pumping to remove solid waste is needed 
only about every 6 to 10 years (D and D Enterprises, Inc., Pers. Comm., 2001). The cost to pump 
a standard 1,000-gallon septic tank, presently about $300, would average about $38 a year or a 
little over $3 a month if pumped once every 8 years.
Almost all Keys’ cesspits are at residences built before 1970. From discussions with wastewater 
service companies in the Keys, “properly” functioning cesspits (i.e., those that drain and leach 
out effluent into the surrounding soil and subsurface limestone) do not need to be pumped out, 
and consequently have little or no associated operation and maintenance costs. As most of them 
were installed more than 30 years ago, there are also currently no associated system capital costs. 
Cesspits are currently illegal to install in Monroe County and are being removed as part of the 
Monroe Cesspit Identification and Elimination Grant Program (discussed in detail in PEA 
Section 3.6.3.2.1 [Local Fees and Taxes, Environmental Consequences]). 
For comparison, the average monthly wastewater rates for customers that currently use non-
compliant WWTP systems in other parts of Monroe County are $56, $64, and $55 per month for 
customers of Key Haven Utilities, Ocean Reef Club, and KWRU, respectively. 
There are two commercial businesses in the Bay Point service area, Baby’s Coffee and 
Bluewater RV Resort, and six vacant commercial parcels. Bluewater RV Resort is the only 
business within the service area that is using a small wastewater treatment plant. This system 
serves 81 RV sites and is commercially serviced on a monthly basis by a wastewater treatment 
company in the Keys. Unlike Bay Point Key and Saddlebunch Key residents who are using 
septic systems and cesspits, the RV Resort is meeting current wastewater treatment standards, 
though the business is paying much higher monthly wastewater costs than the service area 
residents (Jones, 2003).  
Additional information related to local fees and taxes is in PEA Section 3.6.3 (Local Fees and 
Taxes).
Environmental Consequences
Under the No Action Alternative, FEMA would not fund the Bay Point service area’s wastewater 
management improvements. To achieve compliance with Florida Statutory Treatment Standards, 
residents and businesses would have to use other funding for improvements.
Economic effects of the No Action Alternative on local wastewater fees or taxes are difficult to 
quantify, as they would depend on the final costs of the 2010-compliant systems chosen, the 
amount of State and Federal grants and contributions, and the details of the chosen financing 
options, including applicable repayment terms. Based upon information in PEA Section 3.6.3.2.1 
(Local Fees and Taxes), the No Action Alternative may result in higher wastewater management 
costs for the Bay Point and Saddlebunch Keys service area than would likely occur from either 
FEMA-funded Alternative 2 or 3.
Under Alternative 2, the estimated system capital cost to service recipients, after FKAA has 
applied grant funding, would be about $4,259 per EDU. In addition, property owners would pay 
for their abandonment and lateral costs, estimated to be between $1,500 and $5,000 per 
residence, depending on the type of existing on-site system and the amount of work needed to 
remove or abandon the system. The estimated monthly O&M fee for the new WWTP would be 
about $53 per EDU, with no capital cost included (Reynolds, 2003). Under Alternative 3, the 
estimated system capital costs to service recipients, after FKAA has applied grant funding, 
would be about $7,059 per EDU. Under Alternative 3, property owners would also be 
responsible for their abandonment and lateral costs. The estimated monthly O&M fee with 
service at KWRU would be about $61 per EDU, with no capital cost included (Reynolds, 2003).  
Under both Alternatives 2 and 3, businesses in the service area would be assessed wastewater 
fees in the same manner as residential service recipients, with system capital costs following the 
rates outlined above and monthly service operation and maintenance fees following a flow-based 
rate structure. The flow-based rate structure would follow the same per EDU cost as residential 
service recipients, with one EDU worth of flow being equivalent to 167 gallons per day. 
Businesses that used more than one EDU worth of water would be charged accordingly. As an 
example, under Alternative 2, a business that generated 417 gallons of wastewater per day would 
be charged $162.50 or 2.5 times the residential rate of $65, because 417 gallons per day is 2.5 
times the 1-EDU flow of 167 gallons per day (Shimokubo, Pers. Comm., 2003).  Those 
businesses that do not generate as much wastewater as they use potable water (e.g., those that 
make ice and ship it out) would have the option to petition for a wastewater flow analysis to 
determine wastewater generation.
Also, under both Alternatives 2 and 3, property owners unable to pay their system capital cost in 
full at the time of availability of service would be able to make amortized annual payments of 
principal plus interest (currently estimated at 5.0%) under a 20-year, non-ad valorem special 
assessment, which would be included on their annual property taxes (FKAA, 2002). Under 
Alternative 2 this assessment would be about $342.00 a year for 20 years, and for Alternative 3, 
it would be about $566.00 a year for 20 years.   
Under both Alternatives 2 and 3, wastewater costs would be considered reasonable if near the 
affordability threshold of approximately 2% of Median Household Income ($75 per month), and 
within the O&M ($30 to $60 per month) and system capital cost ranges ($3,000 to $4,500, as 
spread over a 20-year term) set forth in PEA Section 3.6.3. Alternative 2 is currently within these 
ranges; therefore no substantial adverse economic effects to service recipients are expected.  
Alternative 3 exceeds the PEA-described cost reasonableness ranges, and therefore service 
recipients may incur substantial adverse economic effects if this Alternative is implemented as 
proposed.  It should be noted that the Monroe County Board of County Commissioners 
established a wastewater costs reasonableness policy with Resolution 306-2002, which stated a 
connection fee of $2,700 and monthly O&M fee of $35 were reasonable. At the time of 
publication, Monroe County had not taken any specific action with respect to achieving these 
objectives for the Bay Point service area. With additional funding, the FKAA may further reduce 
current costs estimates to service recipients in view of achieving these objectives.
3.6.4	Public Health
Affected Environment
As mentioned in Section 3.2.2.2. (Nearshore and Offshore Marine Waters), the Florida DOH has 
collected beach water quality data since August 2000, from the Smather’s Beach monitoring 
station on Key West (MM 4.0). On six separate occasions, these data indicated elevated levels of 
fecal coliform and Enterococcus sp. near the monitoring station that could potentially pose a 
health risk and resulted in the issuance of a health advisory. On 14 other occasions between 
August 2000 and May 2003, water at this site received a poor or a moderate water quality rating, 
although no health advisories were issued. The Smather’s Beach monitoring station, located 
about 11 miles west, is the closest monitoring station to the service area. PEA Section 3.6.4.1 
(Public Health, Affected Environment) further describes public health consequences from 
contaminated water.
Environmental Consequences
Under the No Action Alternative, it is likely that nearshore and offshore water quality conditions 
affecting public health would improve, but the rate of improvement depends on local funding to 
implement wastewater improvements. Available Keys data do not conclusively demonstrate 
instances of infection or health problems specifically related to groundwater or offshore 
contamination caused by current sewage treatment practices. However, as described in PEA 
Section 3.6.4.1 (Affected Environment), the presence of enteric microbes in canals and nearshore 
marine waters can pose a health risk through ingestion (e.g., while swimming), inhaling 
contaminated water spray (e.g., while boating), or eating contaminated seafood (Paul et al., 1995; 
Caffry, Pers. Comm., 2001). Therefore, public health risks likely exist and would likely continue 
under the No Action Alternative until the Florida Statutory Treatment Standards of 2010 are 
implemented. Once the Florida Statutory Treatment Standards are implemented, public health 
effects would be similar to those under Alternatives 2 and 3.
Under Alternatives 2 and 3, project area residents would benefit from implementation of 
improved wastewater treatment facilities. PEA Section 3.6.4.2.2 (Alternative 2 – Centralized 
Wastewater Treatment Plant) discusses the environmental consequences of Alternatives 2 and 3.
The installation of systems that meet Florida Statutory Treatment Standards, under any of the 
alternatives, would improve water quality in shallow aquifers, canals, and near-shore marine 
waters, and to a lesser extent, off-shore marine waters. The resulting reduced fecal contamination 
and nutrient pollution would likely reduce adverse effects on public health. Low-income and 
minority populations are expected to benefit from these wastewater management improvements 
to the same degree as other Keys demographic populations.
3.7	DEMOGRAPHICS AND ENVIRONMENTAL JUSTICE
Executive Order 12898 (Environmental Justice), entitled “Federal Action to Address 
Environmental Justice in Minority Populations,” directs Federal agencies “to make achieving 
environmental justice part of its mission by identifying and addressing, as appropriate, 
disproportionately high and adverse human health or environmental effects of its programs, 
policies, and activities on minority populations and low-income populations in the United 
States…” EO 12898 also requires Federal agencies to ensure that public notifications regarding 
environmental issues are concise, understandable, and easily accessible. Accordingly, FEMA 
examined the socioeconomic and demographic conditions in the service area, including 
alternative impacts. 
Affected Environment
3.7.1	Population and Race
The Baypoint Key and Saddlebunch Key service area is a moderate-income residential area.  
Census tract 9716, block group 2 includes the service area but encompasses a much larger area 
including Bay Point, Saddlebunch, and Lower Sugarloaf Keys, running from Upper Sugarloaf 
Sound to Shark Channel. The 2000 census tract population includes 1,373 year-round residents.  
The population is listed as 96% white and 4% other ethnic groups (U.S. Census, 2000).
3.7.2	Income and Poverty
As discussed in PEA Section 3.7 (Socioeconomics), a common indicator of income level used by 
government agencies is the county-specific estimated family income. U.S. Census (2000) data 
for census tract 9716 indicates that about 24% of families had family income less than $35,000 
per year and about 43% had family income between $35,000 and $74,999 per year. The 
remaining 23% had family income greater than $75,000. The corresponding average family size 
was 2.63 people. In 2003, the U.S. Department of Housing and Urban Development (HUD) 
estimated the annual Median Family Income (MFI) for Monroe County at $56,500 (HUD, see 
citation below Table 3-3.). HUD set the indicator known as the “poverty threshold” for the entire 
nation and, with the exception of Alaska and Hawaii, did not adjust this for local cost-of-living 
differences. For the year 2003, HUD set the poverty threshold at an annual income of $15,250 
for a household of three people (U.S. Census, 2003). In areas like the Keys, where the cost of 
living is higher than the national average, $15,250 consequently buys less, effectively making a 
household near the poverty threshold in the Keys poorer than similar households in areas where 
the cost of living is lower. The Monroe County Housing Authority currently uses the first two 
tiers of HUD’s MFI-based income levels to administer its low-income assistance programs. To 
administer its programs fairly, HUD makes annual projections of MFI by county and adjusts for 
family size. HUD sets the first two tiers of low- and very low-income levels as percentages of the 
county MFI. In 2003, the income limits for a family of three in Monroe County were $40,700 for 
the low-income level and $25,450 for the very low-income level. Table 3-3 below shows HUD’s 
FY 2003 low and very low-income levels for various family sizes in Monroe County.

Table 3-5. Fiscal Year 2003 – HUD’s Low-Income and Very Low-Income Limits, Monroe 
County, Florida – Median Family Income = $56,500
Number of People in Household

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

3.7.3	Wastewater Fees and Affordability for Keys Low-Income Residents
The installation of systems that meet Florida Statutory Treatment Standards, under any of the 
alternatives, would improve water quality in shallow aquifers, canals, and nearshore marine 
waters, and to a lesser extent, offshore marine waters. The resulting reduced fecal contamination 
and nutrient pollution would likely reduce adverse effects on public health. Low-income and 
minority populations would likely benefit from these wastewater management improvements to 
the same degree as other Keys demographic populations.
Environmental Consequences
Under the No Action Alternative, FEMA would not fund the Bay Point wastewater management 
improvements. To comply with Florida Statutory Treatment Standards of 2010, residents and 
businesses would have to use other funding for improvements. As described in PEA Section 
3.6.3 (Local Fees and Taxes), the No Action Alternative may result in higher wastewater 
management costs for Bay Point and Saddlebunch Keys residents and businesses than would 
likely occur with the benefit of FEMA funding. Although EO 12898 would not apply, the 
Monroe County Board of County Commissioners passed Resolution 471-2003, which would 
implement a low-income assistance program that would meet the intent of the EO. No 
disproportionately high or adverse effects on minority populations are expected, unless they are 
also low-income.
Under the No Action Alternative, households at or below the low-income level would incur 
financial hardship if their wastewater management costs increase to levels near or above the 
affordability threshold cited in PEA Section 3.6.3.1.2, of  2% of Median Household Income 
(approximately $75/month). Increased wastewater management costs would disproportionately 
and adversely affect low-income populations, as the increased financial burden would represent a 
higher percentage of their discretionary income. If wastewater costs were consistent with the cost 
reasonableness objectives established in Monroe County’s Resolution 306-2002 ($2,700) and 
low-income assistance provisions established in Resolution 471-2003 (described below), service 
area low-income residents would not likely be disproportionately adversely economically 
affected by the No Action Alternative.
Under Alternative 2, the estimated system capital cost to service recipients, after FKAA has 
applied grant funding, would be about $4,259 per EDU with a monthly O&M fee of $53 per 
EDU. In addition, property owners would pay for their abandonment and lateral costs, estimated 
to be between $1,500 and $5,000 per residence, depending on the type of existing on-site system 
and the amount of work needed to remove or abandon the system.
Under Alternative 3, the estimated system capital costs to service recipients would be $7,070 per 
EDU with a monthly O&M fee of $61 per EDU. Like Alternative 2, property owners would pay 
for their abandonment and lateral costs (Reynolds, 2003).  
Under Alternatives 2 and 3, financial assistance guidelines have been developed to reduce costs 
(presented in Section 3.6.3 – Environmental Consequences) to low-income and very low-income 
service recipients in compliance with EO 12898. As described in PEA Section 3.7 and in Section 
3.7.1.3, Table 3-6 shows the estimated amount of assistance available to cover the system capital 
costs for homestead-exempt low- and very low-income property owners under Alternative 2. 
Low-income property owners would receive assistance with at least 70 percent of their system 
capital cost and 70 percent of their existing system abandonment and lateral costs, up to $3,000. 
Very low-income property owners would receive assistance with at least 90 percent of their 
system capital cost and 90 percent of their existing system abandonment and lateral costs, up to 
$3,000.
Under Alternative 2, which has a capital cost of $4,259, for low-income property owners, the 
estimated resulting system capital cost after assistance would be about $1,278 in one payment, or 
about $103.00 a year for 20 years (about $2,060.00 total). For very low-income property owners, 
the estimated resulting system capital cost after assistance would be about $426.00 in one 
payment, or about $34.00 a year for 20 years (about $680.00 total).

Table 3-6. Alternative 2 Low-Income and Very Low-Income Funding Assistance for the 
System Capital Cost of $4,259




Low-Income
Qualified Family:

Amount of Assistance - 
% of Capital Cost 
Covered 70%

Estimated System 
Capital Cost After 
Assistance $1,278.00

Estimated Annual 
Payment Assessed 
with Property Tax* $103.00

Very Low-Income
Qualified Family:

Amount of Assistance - 
% of Capital Cost 
Covered 90%

Estimated System 
Capital Cost After 
Assistance $426.00

Estimated Annual 
Payment Assessed 
with Property Tax* $34.00

*Amortized annual payment of principal plus interest at 5.0% under a 20-year non-ad valorem special assessment.

Because the Alternative 3 capital cost estimate ($7,059) is much higher than the cost 
reasonableness range established in the PEA ($3,000 to $4,500), the low-income provisions 
described in the PEA Section 3.7 must be adjusted for this alternative to meet the PEA’s goals 
for assisting low-income service recipients and comply with E.O. 12898. Applying 70 percent 
and 90 percent assistance levels to the estimated $7,059 capital costs would still result in a 
disproportionately high and adverse economic effect to low-income service recipients. To 
calculate low-income assistance levels, a value of $4,500 (the high value in the PEA reasonable 
range) was used for the Alternative 3 capital costs. The estimated resulting system capital cost to 
qualifying low-income service recipients, after assistance, would be about $1,350.00 in one 
payment or about $108.00 a year for 20 years (about $2160.00 total). For very low-income 
property owners, the estimated resulting system capital cost after assistance would be about 
$450.00 in one payment, or about $36.00 a year for 20 years (about $720 total).

Table 3-7. Alternative 3 Low-Income and Very Low-Income Funding Assistance for the 
System Capital Cost of $4,500



Low-Income 
Qualified Family:

Amount of Assistance - 
% of Capital Cost 
Covered 70%

Estimated System 
Capital Cost After 
Assistance $1,350

Estimated Annual 
Payment Assessed
with Property Tax* $108.00

Very Low-Income 
Qualified Family:

Amount of Assistance - 
% of Capital Cost 
Covered 90%

Estimated System 
Capital Cost After 
Assistance $450.00

Estimated Annual 
Payment Assessed
with Property Tax* $36.00

*Amortized annual payment of principal plus interest at 5.0% under a 20-year non-ad valorem special assessment.

Because the property owner’s total cost for abandonment and lateral costs would vary from one 
property to the next, it is not possible to estimate the final cost with the assistance program. 
Nevertheless, the assistance program would be as described above. At this time, no programs 
would be available to help low- and very low-income populations pay the monthly O&M fees. 
Under both Alternative 2 and 3, property owners unable to pay their system capital cost in full at 
the time of availability of service would be able to make amortized annual payments of principal 
plus interest (at 5.0%) under a 20-year, non-ad valorem special assessment, which would be 
included on their annual property taxes (FKAA, 2002).
In Resolution 471-2003, Monroe County adopted an Implementation Plan that is consistent with 
the above provisions, to assist Bay Point and Saddlebunch Keys’ low-income service recipients.  
This assistance will likely be funded through a Community Development Block Grant (CDBG). 
In fact, Monroe County is preparing a CDBG Economic Development application for the Bay 
Point area. If awarded, this grant would further reduce system capital costs (Bell, 2003).  
The Community Development Program Administrator in the Special Programs Office of the 
Monroe County Housing Authority would administer the low-income assistance program for Bay 
Point. The Implementation Plan would be administered according to the County’s Housing 
Assistance Plan (HAP) (Amended). In part, the HAP states that all funds awarded would be in 
the form of grants to the homeowners and loans to property owners providing rentals to qualified 
beneficiaries. The process for selecting, accepting, reviewing, and approving requests for 
assistance is outlined in Appendix I. (Monroe County Housing Authority, 2003)
FEMA does not have specific requirements under EO 12898 to assist low-income renters. The 
County has committed to provide such assistance to homeowners who rent to income-eligible 
tenants. The County intends to provide the same level of assistance to this renting population, as 
described above.  
FEMA would require Monroe County/FKAA to meet the above guidelines during project 
implementation in order for the FKAA to receive grant funding. With the implementation of the 
FEMA assistance program and the use of grant funding, low-income or very-low income property 
owners would incur no highly disproportionate or adverse economic effects under either 
alternative.
3.8	HAZARDOUS MATERIALS AND WASTES
Affected Environment
Environmental Consulting & Technology, Inc. (ECT, 2003) performed a Phase I Environmental 
Site Assessment in the service area in November 2002, in accordance with American Society of 
Testing and Materials (ASTM) Practice E-1527. ECT performed the assessment on the 
approximately 100-foot by 130-foot site at the intersection of West Circle Drive and US-1. The 
site is a vacant lot partially covered with medium to dense vegetation. ECT noted no areas of 
distressed or discolored vegetation, which would be attributed to obvious discharge of 
environmental contaminants. Based on a review of the information collected during the 
investigation, ECT determined that the subject property was historically vacant and vegetated 
land prior to 1964 until present. The Phase I Environmental Site Assessment results indicated no 
evidence of recognized environmental conditions in connection with the site.
Environmental Consequences
Under the No Action Alternative, hazardous material and waste impacts would likely be similar 
to Alternatives 2 and 3 described below.
For Alternative 2 and 3, based on the results of the above-described Phase I ESA, no notable 
environmental effects or hazardous materials abatement would likely occur for construction at 
this site. 
Under Alternatives 2 and 3, the system would treat wastewater as described in Section 2.2.2.4 of 
this document (Effluent Disposal). PEA Section 3.8.2.2 (Alternative 2 – Centralized Wastewater 
Treatment Plant Alternative) discusses additional environmental consequences of this alternative. 
The most common hazardous materials that enter the systems are grease and typical household 
cleaning products (Rios, Pers. Comm., 2001). The effects of an inadvertent disposal of hazardous 
wastes into wastewater effluent is more likely to affect smaller plants like the WWTP proposed 
for Alternative 2 than larger plants, because the materials are usually more diluted in the larger 
plants. However, the frequency of these incidents at a smaller facility should be correspondingly 
lower, so that there would likely be no net increase in potential concern. Hazardous material that 
would enter the WWTP may kill the biological component that treats the wastewater. Such 
material would have to be pumped out and sent to a larger treatment plant for reprocessing. 
The system would add treatment chemicals at various points in the treatment process. The 
WWTP may adjust influent wastewater pH by adding sodium hydroxide, a buffering agent. The 
sodium hydroxide would immediately dissolve, and the system would consume it in a reaction, 
raising wastewater pH and rendering it inactive. In order to remove phosphorus from the 
wastewater, the system may add metal salts to coagulate the excess phosphorus. FKAA would 
collect the resultant sludge and dispose of it at facilities in neighboring municipalities (e.g., 
Miami-Dade South District WWTP or Florida City) with whom FKAA has reached an 
agreement for sludge disposal. FKAA would dispose of the metal salts with this material and 
would not release it to the aquifer or aquatic environment. The system may add disinfectants, 
such as sodium hypochlorite or calcium hypochlorite, as the wastewater effluent is released to 
the environment to kill remaining biologic pathogens. In the process of disinfection, by-products 
may be formed through the interaction of chlorine with dissolved organic carbon in the 
wastewater. When the treated effluent is discharged these by-products may be diluted, volatized, 
or absorbed by nearby sediments and would not represent a potential hazard (U.S. Geological 
Survey, 2003).
Under Alternative 3, KWRU would treat wastewater as described in Section 2.3.2 of this 
document (KWRU Wastewater Treatment Plant). Alternative 2 discusses additional 
environmental consequences of this alternative.
3.9	INFRASTRUCTURE
3.9.1	Traffic and Circulation
Affected Environment
Traffic capacity limitations exist along four segments of US-1 in the Keys. As discussed in PEA 
Section 3.9.1.1 (Affected Environment), the conditions of the roadway are based on levels of 
service (LOS). The 1985 Highway Capacity Manual defines LOS as a qualitative measure 
describing operational conditions within a traffic stream, and their perception of motorists. This 
manual ranks roadway LOS from A (the best) to F (the worst), with C being the average. Stock 
Island and Boca Chica Key have been ranked LOS A. Big Coppit Key has been ranked LOS B.  
Bay Point and Saddlebunch Keys have been ranked as LOS C (Monroe County, 1997)
Service area streets consist of paved roads with platted ROW widths between 30 to 50 feet 
(FKAA, 2002).
Environmental Consequences
Under the No Action Alternative, FKAA would not use FEMA funds for wastewater 
management projects in Bay Point and Saddlebunch Keys. Service area residents would still 
need to comply with Florida Statutory Treatment Standards of 2010. Effects on traffic and 
circulation, once FKAA secures funding, would likely be similar to those under Alternatives 2 
and 3. 
Under Alternatives 2 and 3, temporary construction traffic would increase near the proposed 
facility and would likely last up to 12 months from the start of construction. Construction would 
not interrupt vehicular traffic or scheduled transportation services on US-1.  Collection system 
installation would temporarily hinder, but not obstruct, service area traffic movement. Treatment 
plant installation and operation would temporarily increase traffic to each facility depending on 
facility capacity and operations.
Public service disruptions from construction would likely be brief and infrequent. FKAA would 
develop and implement a traffic control plan as required by FEMA funding and/or permitting 
agencies. This plan would include specific information about temporary traffic control, alternate 
routes, staging area locations, and optimal working times to minimize traffic disruption. 
Construction in the ROW would not be subject to Monroe County Land Development 
Regulations since development, as defined by the Monroe County Comprehensive Plan (Monroe 
County, 1995), excludes roads. The Florida Department of Transportation would require 
permitting for work in the US-1 ROW, including bridges.
3.9.2	Utilities and Services
Affected Environment
Electricity, gas, and potable water services for the project areas are detailed in PEA Section 
3.9.2.1 (Public Utilities and Services, Affected Environment). The main types of wastewater 
treatment within the project area include septic tanks and cesspools. 
Environmental Consequences
Under the No Action Alternative, FEMA would not fund the proposed wastewater management 
project. Service area residents would still need to comply with Florida Statutory Treatment 
Standards of 2010. Effects on utilities and service, once FKAA secures funding, would likely be 
similar to those under Alternatives 2 and 3. 
Under Alternatives 2 and 3, there would likely be temporary utility and service disruptions 
during construction. Bay Point and Saddlebunch Keys are mostly developed and currently 
receive all services, which support the proposed wastewater improvement alternatives. The 
FKAA would contact the diggers/excavation utility hotline at the Sunshine State One-Call Center 
at least two business days before construction to identify underground utilities that may be near 
the project site. Short-term adverse effects, such as temporary interruption of water and 
wastewater service, would occur as residents and businesses hook up to the new wastewater 
system. Long-term adverse effects on utilities and services would not likely occur, provided that 
proper utility notification and construction practices are implemented. Long-term positive effects 
would occur as current wastewater methods are switched out and improved methods are 
implemented.
For both Alternatives 2 and 3, FKAA would install sewer collection mains with a 10-foot 
horizontal separation from the existing FKAA water system as FDEP requires. Proposed rule 
changes may require the separation of water and vacuum sewer collection mains to change to a 
3-foot horizontal separation and 12-inch vertical separation. However, FKAA would apply the 
current applicable rule requirements at the time of construction. No water service interruptions 
would likely occur.
3.10	LAND USE AND PLANNING
Affected Environment
Bay Point and Saddlebunch Keys are in unincorporated Monroe County. The proposed 
WWTP/pump station site is zoned suburban commercial (Figure 3-5; First American Real Estate, 
1999). The service area is a mostly developed medium-density residential area, with most 
undeveloped parcels already platted in subdivisions. PEA Section 3.10.1 (Land Use and 
Planning, Affected Environment) further discusses the affected land use and planning.
There are no State-identified Conservation and Recreation Lands (CARL) in the service area. 
One county park is about 350 feet east of the proposed WWTP site. No other conservation lands 
are on Bay Point and Saddlebunch Keys. The Florida Keys National Marine Sanctuary surrounds 
the island seaward from the mean high water line; the Great White Heron National Wildlife 
Refuge is on the bay side of the project area and includes 200,000 acres of open water and 
islands north from the mean high water line. Bay Point and Saddlebunch Keys are not in a 
Coastal Barrier Resource System (CBRS) unit.

 
[Figure 3-5. Service Area Land Uses
(Monroe County Property Appraiser’s Database, 2001)
Figure 3-5 shows the land use types in the Bay Point Key and Saddlebunch Key Service areas and 
Stock Island.]

Environmental Consequences
Under the No Action Alternative, FEMA would not fund the proposed wastewater management 
project. Service area residents would still need to comply with Florida Statutory Treatment 
Standards of 2010. Effects on land use and planning, once FKAA secures funding, would likely 
be similar to those under Alternatives 2 and 3. 
Effects on land use and planning are similar for Alternatives 2 and 3 and are discussed in PEA 
Section 3.10.2.2 (Land Use and Planning; Environmental Consequences – Alternative 2). Under 
Alternatives 2 and 3, the proposed WWTP or proposed pump station would be on Monroe 
County property. In accordance with the Monroe County Comprehensive Plan (Sections 9.5-
257.4 and 9.5-257.5), construction of a new treatment plant or pump station would not require 
amendments to the land uses permitted in areas zoned either Suburban Commercial or Suburban 
Residential (Buckley, Pers. Comm., 2003). There would not be any direct effects on other 
conservation lands or CBRS units because there are none in the project area.
As described in PEA Section 3.10 (Land Use and Planning), development in the Keys is not 
controlled by addition of critical infrastructure, but instead by Monroe County’s ROGO permit 
allocation system. The construction of new wastewater treatment infrastructure in the Keys is 
essential to effectively treat existing wastewater flows, and would not introduce or support 
increased development. Therefore, if growth and development occur following implementation 
of this alternative, it is the result of established county planning and of the proposed wastewater 
management project.
FEMA consulted Florida DCA on potential project effects. Florida DCA stated in its response on 
July 11, 2003, that based on the information provided, Alternatives 2 and 3 are consistent with 
the State’s comprehensive coastal management program (Appendix B).
3.11	NOISE AND VISUAL RESOURCES
3.11.1	Noise
Affected Environment
Project area noise is not well documented but is primarily associated with traffic. Sensitive noise 
receptors are areas that sustain greater effects from noise sources than other areas (such as 
industrial areas). Sensitive receptors to noise typically include churches, schools, homes and 
residential areas, hospitals, and public facilities. URS documented all potential noise receptors in 
the project area on August 1, 2002, and February 19, 2003.
A park east of the proposed project site and a dense stand of vegetation between the site and the 
park would provide some buffering of noise generated from the proposed facility. A 75-foot 
wide vacant lot exists between the site and the nearest home. The lot is sparsely vegetated and 
provides little to no buffer for noise. URS observed no other natural or artificial noise buffers 
between the project areas and the sensitive noise receptors identified.
The proposed site is part of a mixed urban commercial/residential area along a major roadway. 
As discussed in PEA Section 3.11.1 (Noise), the overall noise level for this type of classification 
is moderately loud. Most noise here is from:
*	General vehicle operation along US-1;
*	Nearby commercial activities along US-1; 
*	Activities in the adjacent park and tennis courts about 20 feet south and about 50 feet 
southwest, respectively, of the site;
*	Private air strip activities on the bay side of US-1 about 2,000 feet north of the site; and
*	Jet training from the Naval Air Station on Boca Chica, about 6 miles west of the site.
Observed noise receptors near the project areas include:
*	Residents along Bay Drive (the closest occupied home is about 150 feet south of the site); 
and
*	A park about 20 feet south of the site.  
URS identified no other noise receptors in the project areas.
Environmental Consequences
Under the No Action Alternative, FEMA would not fund the proposed wastewater management 
project. Bay Point and Saddlebunch Keys residents would still need to comply with Florida 
Statutory Treatment Standards of 2010. Effects on noise quality, once FKAA secures funding, 
would likely be similar to those under Alternatives 2 and 3.
Given that Alternatives 2 and 3 would involve a range of construction activities, the effects 
related to construction and noise within the project area would be similar. PEA Section 3.11.1.2 
(Environmental Consequences) discusses these effects. An increase in noise levels would occur 
at various locations for about 12 months during construction (FKAA, 2002). Service area 
residents may endure annoying and disruptive noises during allowable construction work hours, 
as cited in the current Monroe County Code (Article III, Sections 13-51 to 13-55). However, the 
potential for residents to experience hearing damage or loss due to construction noises is low.
To mitigate noise effects on residents, FKAA may build vegetative barriers around construction 
areas. Construction workers would comply with the established noise ordinance, Article III, 
Sections 13-51 to 13-55 of Monroe County Code, to reduce annoying and disruptive noises in 
adjacent areas. 
To mitigate noise effects on laborers, workers would comply with applicable occupational safety 
regulations and implement appropriate noise control measures, such as wearing hearing 
protection (e.g., earplugs, earmuffs, a helmet, or canal caps) and limiting exposure times. If 
FKAA properly implements these measures during construction and operations, no adverse 
effects on workers should occur.
3.11.2	Visual Resources
Affected Environment
As discussed in PEA Section 3.11.2 (Visual Resources), visual resources refer to the landscape 
character (what is seen), visual sensitivity (human preferences and values regarding what is 
seen), scenic integrity (degree of intactness and wholeness of landscape character), and 
landscape visibility (relative distances of seen areas) of a geographically defined “viewshed.” 
URS conducted a project area visual resources assessment URS on August 1, 2002, and February 
19, 2003.
The proposed WWTP or proposed pump station site is a vacant lot that is part of a mixed urban 
commercial/residential area along a major roadway. The site has mowed grasses and a small 
stand of trees along its eastern boundary. The existing vegetation acts as an aesthetic buffer for 
commercial businesses to the east. No other natural aesthetic buffers exist between the site and 
adjacent lots. Dominant project viewshed features include:
*	US-1;
*	Residential homes and landscaping;
*	Marine waters;
*	Commercial structures;
*	Residential park and tennis courts; and
*	Natural coastal communities, including mangroves and salt marsh.
Environmental Consequences
Under the No Action Alternative, FEMA would not fund the proposed wastewater improvements 
project. Bay Point and Saddlebunch Keys residents would still need to comply with Florida 
Statutory Treatment Standards of 2010. Effects on visual resources, once FKAA secures funding, 
would likely be similar to those under Alternatives 2 and 3. 
Under Alternatives 2 and 3, construction of a WWTP or a pump station would not adversely 
affect the service area’s scenic quality because the island is mostly developed and does not have 
unique natural communities, high quality and unique views, or natural areas. The facility may 
have a negative aesthetic effect for nearby residents. To mitigate this effect, FKAA may 
landscape the areas surrounding the site with vegetative screens to obscure views from US-1 and 
nearby residences.


4.0	Section 4 FOUR	Cumulative Impacts
Under the No Action Alternative, FEMA would not fund the proposed wastewater management 
project. The County (Monroe County, cities, utilities, private wastewater utility operators, 
business owners, and homeowners) would have to obtain alternate funding to finance the large 
capital costs to improve its wastewater treatment systems to meet the Florida Statutory 
Treatment Standards of 2010. Communities that currently use on-site systems, such as cesspools 
and septic systems, to manage wastes would have to construct either community or regional 
WWTPs, install on-site wastewater nutrient reduction systems, and/or upgrade or rebuild 
existing WWTPs. As a result, the cumulative effects on physical, biological, and socioeconomic 
resources would be similar across all alternatives, and are discussed below. Currently there are 
no proposed projects planned or underway in the Bay Point Key area that would contribute to 
environmental effects within the project area (Buckley, Pers. Comm., 2003).
4.1	TOPOGRAPHY, SOILS, AND GEOLOGY
Implementation of new wastewater treatment services on Bay Point and Saddlebunch Keys 
would cumulatively increase the impervious surface area due to wastewater treatment system 
construction; however, the actual land area required for these activities is small (0.31 acre) 
relative to the extent of the surface area of these islands. Construction would temporarily disturb 
soils, but the implementation of construction BMPs would decrease the potential for long-term 
surface soil erosion. No cumulative effects would likely occur for topography and geology.
4.2	WATER RESOURCES AND WATER QUALITY
PEA Section 4.2.2 (Water Resources and Water Quality) discusses cumulative effects on water 
resources, including surface waters and wetlands, and water quality for the Florida Keys. 
Considering Keys-wide wastewater and stormwater management activities and the 
Comprehensive Everglades Restoration Program (CERP), cumulative water quality 
improvements would likely occur in the service area, in the canals and nearshore marine waters, 
and, to a lesser extent, in offshore marine waters.
4.3	BIOLOGICAL RESOURCES
Cumulative effects on biological resources and special species status would likely be beneficial 
due to improved marine water quality. PEA Section 4.2.3 (Biological Resources) discusses 
cumulative effects on biological resources.
4.4	AIR QUALITY
Potential cumulative effects on air quality would likely be minimal; PEA Section 4.2.4 (Air 
Quality) discusses these impacts. 
4.5	CULTURAL RESOURCES
Under the No Action Alternative, potential cumulative effects on historic and cultural resources 
may occur. Coordination and project review with the SHPO and Monroe County Historic 
Preservation Society would reduce the effects on cultural resources from ground-disturbing 
activities associated with wastewater projects. PEA Section 4.2.5 (Cultural Resources) discusses 
cumulative effects on cultural resources.
4.6	SOCIOECONOMICS
The implementation of improved wastewater services would cumulatively improve ground and 
nearshore water quality and would help reduce the number of Keys beach and canal health 
advisories. This would likely increase the number of visitors to beaches that formerly posted 
health advisories, and/or reduce visitor pressure on alternate beaches and recreational activities. 
Water quality improvements would also benefit recreational and commercial fisheries to the 
extent that nutrient and biological pollution are currently adversely affecting them. Generally, 
harvested species that occur in nearshore waters, such as spiny lobster, white mullet, gray 
snapper, various flounder, shrimp, and stone crab, would benefit from improved water quality. 
Benefits may range from relatively minor to potentially substantial improvements in harvest rates 
thus benefiting the fishing industry, related industries, and consumers. With the use of FEMA 
funding to reduce Bay Point wastewater system capital costs, no significant cumulative 
economic impacts on service recipients would likely occur. 
4.7	DEMOGRAPHICS AND ENVIRONMENTAL JUSTICE
The wastewater facilities siting would not likely have any cumulative adverse effects on minority 
and/or low-income populations, although implementation of any of the alternatives would 
generally result in increased wastewater disposal costs for service recipients.  These costs would 
be substantially reduced for qualifying low-income homeowners through implementation of the 
PEA financial assistance guidelines. The No Action Alternative would not require these 
provisions, consequently economic impacts to low-income homeowners would depend on the 
chosen wastewater system and sponsor’s rate structure.  
4.8	HAZARDOUS MATERIALS
Potential cumulative effects from hazardous materials and wastes would not likely occur, as 
discussed further in PEA Section 4.2.8 (Hazardous Materials).
4.9	INFRASTRUCTURE
The construction of wastewater facilities proposed in Alternatives 2 or 3, in combination with 
other wastewater activities throughout the Keys, would lead to an overall centralization of 
wastewater treatment systems compared to individual septic tanks and cesspits. This should 
improve the maintenance and servicing of wastewater systems and improve overall water quality 
throughout the Keys. Implementation of Alternative 2 or 3 would partially offset adverse 
cumulative effects on Monroe County’s utility infrastructure from other activities and normal 
aging.
4.10	LAND USE AND PLANNING
The installation of new wastewater facilities would not likely change the County’s existing 
growth pattern. Since the proposed facilities are outside of conservation areas, CARL lands, and 
CBRS units, adverse cumulative effects on these special status lands would not likely occur. The 
Florida Keys Tidal Restoration Project, a part of the CERP, is north of Bay Point Key; no 
cumulative effects on this project would occur. PEA Section 4.2.10 further discusses the 
cumulative effects of the alternatives on land use and planning.
4.11	NOISE AND VISUAL RESOURCES
Potential cumulative effects on noise and visual resources would likely be minimal, as PEA 
Section 4.2.11 (Noise and Visual Resources) discusses further.



5.0	Section 5 FIVE	Public Participation
FEMA’s public involvement activities related to the proposed Bay Point and Saddlebunch Keys 
wastewater system began with the publication of a Notice of Intent (NOI) (Appendix D) to 
prepare this SEA. FEMA published the NOI in The Reporter on May 30, 2003, the Key West 
Keynoter on May 24, 2003, and in the Key West Citizen on May 27, 2003. 
In addition to FEMA’s public involvement, the FKAA held a project-specific public meeting on 
May 14, 2003 and November 13, 2003, and proposed the Bay Point and Saddlebunch Keys 
wastewater system. The project has also been discussed at numerous Monroe County Board of 
County Commissioners monthly public meetings.  Similarly, Monroe County held a series of 
public meeting throughout the Keys during the development of the MCSWMP as described in 
PEA Section 5 (Public Involvement).
FEMA will release this Draft SEA on November 26, 2003 for a 15-day intergovernmental review 
and public comment period. FEMA will send it to the agencies listed in Appendix B, and two 
copies will be available for public review at the Marathon Branch of the Monroe County Public 
Library (3251 Overseas Highway). This Draft SEA is also available on the FEMA 
(www.fema.gov/ehp/docs.shtm) website. FEMA will hold a public meeting on the proposed 
project on December 4, 2003, at the Harvey Government Center, 2nd Floor, 1200 Truman 
Avenue, Key West, Florida. As part of its NEPA process, FEMA will review comments from the 
public and government agencies, and will address these comments in the Final SEA.





6.0	Section 6 SIX	Mitigation Measures and Permits
6.1	MITIGATION
To mitigate effects from the chosen alternative, the project applicant would have to:
*	Implement appropriate BMPs during construction;
*	Develop an approved Erosion and Sediment Control Plan;
*	Use conventional site preparation techniques before and during construction; 
*	Build vegetative barriers around the WWTP site to reduce construction noise and obscure 
views from US-1 and adjacent residences;
*	Ensure that construction workers comply with the established noise ordinance and all 
applicable occupational safety regulations;
*	Charge residential service recipients system capital costs no more than those presented in 
PEA Section 3.6.3.2.2 ([Centralized Wastewater Treatment Plant Alternative] $4,500 per 
EDU after grant funding has been applied);
*	Provide wastewater service (inclusive of any amortized system capital costs) at a cost that 
falls below or near the affordability threshold described in PEA Section 3.6.3.2.2 
([Centralized Wastewater Treatment Plant] $75/month); and.
*	Implement financial assistance for qualifying low-income and very low-income residents for 
system capital, and service lateral and on-site abandonment costs, consistent with guidelines 
and definitions described in the PEA.
6.2	PERMITS AND LICENSES
PEA Appendix E (Applicable Permit Information) lists permits required to build and operate the 
Bay Point and Saddlebunch Keys Wastewater Treatment System. These permits may include an 
Application for a Domestic Wastewater Facility; Application to Construct/Operate/Abandon 
Class V Injection Well Systems; a Construction/Clearance Permit; a Certification of 
Construction Completion; an Authorization for Use; an Application for Plugging and 
Abandonment Permit; a Notification to the FDEP of Ownership; and a Certification of Monitor 
Well Completion. Construction activities would also require authorization in the form of two 
Environmental Resource Permits (ERPs), one from the FDEP and one from the Monroe County 
Growth Management Division.  For Alternative 3, existing FDEP or DOH permits may require 
amending. Siting the wastewater treatment system in the 100-year floodplain will require 
compliance with Monroe County’s Floodplain Ordinance.  Moreover, because it is a critical 
action under EO 11988, FKAA must protect the plant and its critical operating components to the 
500-year flood, per 44 CFR Part 9.11.




7.0	Section 7 SEVEN	References

Buckley, Jerry. 2003. Monroe County Planning Department. Personal communication 
with Laura Cherney, URS Group, Inc.
Caffry, W. 2001. Medical Technologist, Lower Keys Medical Center. Personal 
communication with Jonathan Randall, URS Group, Inc.
Chiappone, M. 1996. Marine Benthic Communities of the Florida Keys. In: Site 
Characterization for the Florida Keys National Marine Sanctuary and Environs, 
Volume 4. The Preserver, Zenda, Wisconsin.
Chiappone, M. and K. M. Sullivan. 1994. Ecological structure and dynamics of nearshore 
hard-bottom communities in the Florida Keys. Bulletin of Marine Science 
54(3):747-756.
Chiappone, M. and K. M. Sullivan. 1996. Functional ecology and ecosystem 
trophodynamics. In: Site Characterization for the Florida Keys National Marine 
Sanctuary and Environs, Volume 8. The Preserver, Zenda, Wisconsin.
Environmental Consulting & Technology, Inc. (ECT). 2002. Phase I Environmental Site 
Assessment Report Bay Point Key Property.
Federal Emergency Management Agency (FEMA). 1999. National Flood Insurance 
Program, Consolidated CBRA Q3 Electronic Flood Hazard Data. Diskette 4. 
Florida and Georgia.
First American Real Estate Solutions. 1999. Realty Atlas. Monroe County, Florida.
Florida Keys Aqueduct Authority (FKAA). 2002. Wastewater Management System for 
the Bay Point Key and Saddlebunch Key, Monroe County, Florida. Basis of 
Conceptual Design Report.
Florida Keys Aqueduct Authority (FKAA). 2003. Alternative Wastewater Management 
System option to serve the Bay Point Community Service Area, Monroe County, 
Florida. Basis of Conceptual Design Report.
Florida Marine Research Institute (FMRI) Technical Report TR-4. 2000. Benthic 
Habitats of the Florida Keys. In association with the National Oceanic and 
Atmospheric Administration and the Florida Fish and Wildlife Conservation 
Commission. 
Florida Marine Research Institute (FMRI). 1992. Benthic Habitats of the Florida Keys 
CD-ROM, ARC\INFO Coverage. National Oceanic and Atmospheric 
Administration. 
Fonseca, A.S., W. J. Kenworthy, and G.W. Thayer. 1998. Guidelines for the conservation 
and restoration of seagrasses in the United States and adjacent waters. NOAA 
Coastal Ocean Program Decision Analysis Series No. 12. NOAA Coastal Ocean 
Office, Silver Spring, Maryland.
Garcia, Carlos, 2003. Senior Hazardous Waste Specialist, URS Group, Inc. Personal 
Communication with Ramon Mendieta, URS Group, Inc.
Kruczynski, W. 1999. Water Quality Concerns in the Florida Keys: Sources, Effects, and 
Solutions. Florida Keys National Marine Sanctuary Water Quality Protection 
Program, National Oceanic and Atmospheric Administration.
LBFH, Inc., 2003.  Boca Chica Community Service Area Wastewater Feasibility Study 
and Cost Analysis for the FKAA.
McNeese, P. 1998. Florida Keys Advance Identification of Wetlands (ADID) Project 
Technical Summary Document.
Monroe County Board of County Commissioners.  2003. Resolution 306-2002, ‘passed 
and adopted,’ July.
Monroe County Board of County Commissioners.  2003. Resolution 471-2003, ‘passed 
and adopted,’ 10/15/03.
Monroe County Housing Authority.  2003.  Baypoint Income Assistance Implementation 
Plan.  September.
Monroe County Property Appraiser’s Database. 2001.
Monroe County. 2001. Stormwater Management Master Plan. Prepared by Camp, 
Dresser and McKee, Inc.; Keith & Schnars, P.A. in association with 
Environmental Consulting Systems; Glen Boe and Associates; Mote Marine 
Laboratories; The Market Share Company; and Valerie Settles, Esq. Vol. 1 
(February) 2 (August).
Monroe County. 2000. Monroe County Sanitary Wastewater Master Plan. Volume 1. 
Submitted by CH2MHILL. June.
Monroe County. 1995. Monroe County Year 2010 Comprehensive Plan. Technical 
Document. Monroe County Planning Department. Key West, Florida.
Nutting Engineers of Florida, Inc., 2003. Report of Geotechnical Exploration, Proposed 
Waste Water Treatment Plant and Vacuum Pump Station Mile Marker 15 for the 
FKAA.
Paul, J.P., J.B. Rose, S. Jiang, X. Zhou, P. Cochran, C. Kellogg, J. Kang, D. Griffin, S. 
Farrah, and J. Lukasik. 1997. Evidence for groundwater and marine water 
contamination by waste disposal wells in the Florida Keys. Water Research 
31:1448-1454.
Reynolds, James C.  2003. FKAA, Personal correspondence with William Straw, Ph.D, 
10/22/2003.
Rios, Gus. 2001. Florida Department of Environmental Protection, Marathon District. 
Personal communication with Sonya Krogh, URS Group, Inc., September 10.
Shimokubo, Ray, 2003. Wastewater Engineer, FKAA. Personal Communication with 
Ramon Mendieta, URS Group, Inc.
Southeast Environmental Research Center (SERC). 2003. Water Quality Monitoring 
Project for the Water Quality Protection Program of the Florida Keys National 
Marine Sanctuary. http://serc.fiu.edu/wqmnetwork/FKNMS-
CD/Sites/226_files/Site268.htm
State of Florida, Department of Health (DOH). 2003. Florida Healthy Beaches Program. 
http://apps3.doh.state.fl.us/env/beach/webout/default.cfm
Szmant, A.M. and A. Forrester. 1996. Water column and sediment Nitrogen and 
Phosphorus distribution patterns in the Florida Keys. Coral Reefs. 15: 21-41.
URS Group, Inc. 2002. Final Programmatic Environmental Assessment on Wastewater 
Management Improvements in the Florida Keys. Prepared for Federal Emergency 
Management Agency Region IV, Atlanta, Georgia.
U.S. Army Corps of Engineers and Florida Department of Community Affairs (USACE/FDCA).  
2001.  Florida Keys Carrying Capacity Study. First Draft. Prepared by URS Corporation 
under USACE Contract Number DACW17-99-D-0058, Delivery Order #11, Test 
CCAM.
U.S. Census. 2000. DP-1. Profile of General Demographic Characteristics. Geographic 
Area: Block Group 2, Census Tract 9716, Monroe County, Florida. 
www.factfinder.census.gov/servlet/BasicFactsServlet 
U.S. Geological Survey (USGS).  2003.  Fate of Disinfection By-Products in the 
Subsurface. http://water.usgs.gov/ogw/pubs/ofr0289/cr_fatedisinfect.htm
U.S. Department of Agriculture (USDA). 1995. Soil Survey of Monroe County, Keys 
Area, Florida. United States Department of Agriculture/National Resources 
Conservation Division in cooperation with the University of Florida, Institute of 
Food and Agricultural Sciences, Agricultural Experiment Stations, and Soil and 
Water Science Department; and the Florida Department of Agriculture and 
Consumer Services.



8.0	Section 8 EIGHT	List of Preparers

URS Project Management and Technical Research

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

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

Justin Patton, Archaeologist. Lead archaeologist and document author.

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

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


Technical Peer Review

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

Angela Chaisson, URS Senior Ecologist and NEPA Group Leader. Document peer reviewer.

Science Kilner, M.S., FEMA Region IV Lead Environmental-Historic Preservation 
Specialist. Document peer reviewer.

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



Appendix A
Acronyms and Abbreviations


AADF		Annual average daily wastewater flow
ADID		Florida Keys Advance Identification of Wetlands
alum		aluminum sulfate
amsl		above mean sea level
APE		Area of Potential Effect
ASTM		American Society of Testing and Materials
AWT		Advanced Wastewater Treatment

BAT		Best available technology
bls		below land surface
BMPs		Best management practices
BOD		Biochemical Oxygen Demand

CARL		Conservation and Recreation Lands
CBRS		Coastal Barrier Resource System
CDBG		Community Development Block Grant
CEQ		Council on Environmental Quality
CERP		Comprehensive Everglades Restoration Program
CFR		Code of Federal regulations

DCA		Department of Community Affairs
DOH		Department of Health

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

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


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

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

KWGC	Key West Golf Club
KWRU	Key West Resort Utilities

LOS		level of service

MCSWMP	Monroe County Stormwater Master Plan
MFI		Median Family Income
mg/L		milligrams per liter
ml		milliliter
MM		Mile marker
MSA		Magnuson-Stevens Fishery Conservation and Management Act

NEPA		National Environmental Policy Act
NGVD		National Geodetic Vertical Datum
NHPA		National Historic Preservation Act
NMFS		National Marine Fisheries Service
NOI		Notice of Intent
NRHP		National Register of Historic Places


OHRB		Overseas Highway and Railroad Bridge
O&M		Operation and Maintenance

PBSJ		Post Buckley Shuh and Jernigan
PEA		Programmatic Environmental Assessment
Plan		Monroe County Year 2010 Comprehensive Plan
ppm		parts per million
PVC		polyvinyl chloride

ROGO		Rate of Growth Ordinance
ROW		Right-of-way

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

TN		Total Nitrogen
TP		Total Phosphorus
TSS		Total Suspended Solids

URS		URS Group, Inc.
US-1		U.S. Route 1
USBF		Upflow Sludge Blanket Filtration
USDA		U. S. Department of Agriculture
USFWS	U.S. Fish and Wildlife Service

VPS		Vacuum pump station

WWTP 	Wastewater treatment plant



Appendix B
Agency Coordination Letters

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

Appendix C
Site Photographs

 
Photo 1: View of eastern portion of Alternative 2 site showing Pizzeria 
adjacent to the east – facing southeast

 
Photo 2: View of Alternative 2 site showing US 1 – facing northeast
 
Photo 3: View of Alternative 2 site from US 1 showing W. Circle Drive
adjacent to the west – facing southwest


Appendix D
Public Notice


FEMA NOTICE OF INTENT TO PREPARE A
SUPPLEMENTAL ENVIRONMENTAL ASSESSMENT FOR THE PROPOSED
BAY POINT WASTEWATER PROJECT
The Federal Emergency Management Agency (FEMA) has received a grant application from the Florida 
Keys Aqueduct Authority (FKAA) to fund construction of a wastewater treatment system for the Bay Point 
service area encompassing Saddlebunch and Bay Point Keys, Florida.  The proposed project would be 
funded through FEMA 1249-DR Post Disaster - Unmet Needs funds, as noticed on August 6, 1999, in Vol. 
64 No. 151 of the Federal Register.  Matching funds will be provided through the Florida Division of 
Emergency Management and the FKAA.  The purpose of the project is to improve this service area’s 
wastewater treatment to meet State requirements (Chapter 99-395 Laws of Florida) by 2010, per the 
Monroe County Year 2010 Comprehensive Plan.
FEMA has completed a Programmatic Environmental Assessment (PEA) for Wastewater Management 
Improvements in the Keys, for various wastewater projects including Bay Point.  A Programmatic Finding 
of No Significant Impact has been issued for the PEA.  These documents can be obtained by writing to the 
point of contact below or may be viewed and downloaded at the following website: 
http://www.fema.gov/ep/assess.shtm.   
FEMA hereby publishes its notice of intent to prepare a Supplemental Environmental Assessment (SEA) of 
the proposed action serving Bay Point, pursuant to the National Environmental Policy Act (PL 91-190) and 
associated environmental statutes, as implemented by FEMA’s regulations 44 CFR Part 10; and in 
accordance with Presidential Executive Order 11988 (Floodplain Management); as implemented in 44 CFR 
Part 9.  This SEA will address the purpose and need of the proposed project, project alternatives 
considered, the affected environment, project and site-specific environmental consequences, and impact 
mitigation measures.  Once completed, the Draft SEA will be available for public review and comment; 
and a public meeting will be scheduled.
Project Alternatives: 
Alternatives to be considered in the SEA include:
1) No Action Alternative:  The Bay Point service area continues to use its existing wastewater 
treatment systems and obtains funding from other sources to meet the State 2010 requirements and 
the Comprehensive Plan deadline;
2) Action Alternative 1:  Per the Monroe County Sanitary Wastewater Master Plan, install a new 
wastewater collection system throughout the Bay Point service area and build a vacuum pump 
station to convey wastewater to a treatment plant sited on Bay Point Key oceanside;  
3) Action Alternative 2:  Install a new wastewater collection system throughout the Bay Point 
service area and build a vacuum pump station on Bay Point Key to convey wastewater to the 
existing Key West Resort Utilities wastewater treatment plant located on Stock Island, subject to 
FKAA/Monroe County acquiring ownership or beneficial use of the existing treatment plant from 
its current private owner.
Comment Period:
Comments will be accepted from the affected public; local, state and federal agencies; and other interested 
parties in order to consider and appropriately scope and evaluate the likely effects of the proposed Bay 
Point project alternatives on the physical, biological, and social/built environment.  Comments should be in 
writing, sent to the FEMA point of contact listed below, and postmarked no later than May 12, 2003.
Point of Contact:
Ms. Science Kilner, Lead Environmental Specialist
FEMA Region IV
3003 Chamblee Tucker Road
Atlanta, Georgia 30341
Fax: (770) 220-5440
science.kilner@dhs.gov


Appendix E
Public Comments


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


Appendix F
Regulated Keys Fisheries Species



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


Appendix G
Best Available Treatment Wastewater Analysis


Comparison of Nutrient Contributors from Islamorada Service Area to Groundwater and 
Marine Waters under Present Conditions versus Wastewater Systems that Meet BAT 
Standards for Effluent Disposal (10 mg/L BOD, 10 mg/L TSS, 10 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 BAT for TN, TP Islamorada (2001a, p. 18), and disposal of 
BAT 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.
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	= 72,000 gpd x 3.785 L/gal
	= 272,520 L/d
2.	Total nutrient loading in raw sewage:
TN = 38.4 mg/L x 272,520 L/d = 10,464,768 mg/day
	x 0.002204 lbs/mg = 23,441 lbs/day
TP = 8.39 mg/L x 272,520 L/d = 2,286,443 mg/day
	x 0.002204 lbs/mg = 5,039 lbs/day
3.	Reduction of nutrients by septic systems:


Raw Sewage
Septic 
System 
Removal
Septic System 
Effluent
GW 
Removal
To 
Seawater
TN
23,441 lbs/d
4%
22,503 lbs/d
0%
22,503 lbs/d
TP
5,039 lbs/d
15%
4283 lbs/d
0%
4283 lbs/d

4.	Reduction of nutrients by BAT system:


Raw Sewage
Effluent Concentration
TN
23,441 lbs/d
10 mg/L x 272,520 L/d = 2,725,200 mg/d
x .002204 lbs/mg = 6006.3 lbs/day
TP
5,039 lbs/d
1 mg/L x 272,520 L/d = 272,520 mg/d
x .002204 lbs/mg = 600.6 lbs/day

5.	Reduction of nutrients in groundwater transit to marine discharge from BAT:


Septic System 
Loading
Removal Efficiency
To Seawater
TN
6006.3 lbs/day
0%
6006.3 lbs/day
TP
600.6 lbs/day
0%
600.6 lbs/day

Conclusion:

Replacement of existing OWTS (assumed all septic systems) with wastewater management 
systems that meet BAT treatment standards would result in 73% reduction in TN input to 
groundwater (22,503 lbs/day to 6006.3 lbs/day), and 86% reduction in TP input to groundwater 
(4283 lbs/day to 600.6 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 BAT systems in terms of nutrient removal would be 
in form of 73% reduction in TN; and an 86% removal of TP. 




Appendix H
Bay Point Cultural Resources Assessment Survey Report


For copies of of the Bay Point Cultrual Resources Assessment Survey Report, please contact:
	Ms. Science Kilner, Lead Environmental Specialist
	FEMA Region IV
	3003 Chamble Tucker Road
	Atlanta, Georgia  30341
	Fax (770) 330-5440
	Science.Kilner@dhs.gov




Appendix I
Monroe County Housing Authority Assistance Implementation Plan


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