Given these unique resources, their particular vulnerability, and 

 the multiple, "increasing human pressures on the area, assurance of long 

 term preservation for Looe Key requires (a) a management framework that 

 will monitor, assess and act on information about the cumulative effects 

 of human uses, (b) a mechanism to coordinate and encourage research that 

 will lead to necessary management decisions, and (c) efforts to educate 

 the public about the value and the fragility of the reefal system. The 

 no action alternative appears to meet none of these requirements. 



Existing statutes, including the Outer Continental Shelf Lands Act, 

 the Clean Water Act, and the Marine Mammal Protection Act, are directed 

 either at the accomplishment of a single purpose or the regulation of a 

 single activity, such as the extraction of oil and gas resources, the 

 preservation of water quality, and the conservation of marine mammals. 

 These authorities do not provide a comprehensive management mechanism. 

 These statutes also do not address all aspects of human threats to the 

 area. To take one example, the regulations controlling ocean discharge 

 and dumping do not consider all shipboard wastes. For example. Federal 

 regulation of sewage wastes from marine sanitation devices does not 

 extend beyond State waters (see the January 30, 1980 amendment to the 

 Clean Water Act in Section IV F). The discharge of oil beyond the ter- 

 ritorial sea (3 nm) from tankers under 150 gross tons and other vessels 

 under 500 gross tons is unregulated, and regulations pertaining to dis- 

 charges from machinery space bilges require that the activity must take 

 place as far as practical from nearest land, while in route, and must 

 not exceed 60 liters per mile or have oil content exceeding 100 parts 

 per million. Finally, there are no regulations to control the disposal 

 of trash and litter in high seas areas. 



In addition, the status quo provides no programmatic mechanism to 

 promote and coordinate research on coral reef ecology and ecosystem re- 

 covery or to provide information to the direct and indirect user public. 

 There are currently no programs to provide education and information aimed 

 at increasing long-term protection of these areas by increasing public 

 awareness of the distinctive resources and their susceptibility to distur- 

 bance. 



The regulatory regime closest in purpose and scope to the marine 

 sanctuary program is that provided by the Fishery Conservation and Man- 

 agement Act of 1976 (FCMA). Even that regime, however, does not satisfy 

 all of the management requirements described above. Under the FCMA, 

 Regional Fishery Management Councils propose and implement necessary 

 regulations for the management of selected commercial and recreational 

 fisheries which are in need of management pursuant to Fishery Management 

 Plans (FMP). These FMP's will provide for some protection of selected 

 Fishery resources at Looe Key but will not likely focus on the site spe- 

 cific ecosystem management. FMP's do not necessarily consider elements 

 of the ecosystem which are not harvested, nor do they address the entire 

 range of threats to which an ecosystem may be subject. Moreover, none of 

 the FMPs is final and projected time schedules are uncertain. 



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