invertebrates, and other species which are interrelated in the ecosystem. 

 In lieu of sufficient evidence to warrant preparation of a Tropical or 

 "Ornamental" Reef Fish FMp, the SAFMC and the GMFMC are considering preparing 

 a profile or description of the fishery and resource. 



The effectiveness of the draft plans to mitigate the adverse physical 

 and ecological impacts of commercial and recreational fishing on the Looe 

 Key reef cannot be assessed at the present time. However, it should be 

 noted that there are distinct differences between managing fisheries for 

 optimum yield with special reference to food production and recreational 

 opportunities, and managing an ecological system for the protection and 

 maintenance of a coral reef with emphasis on enhancing public awareness 

 and wise use of reef systems, public education, research and assessment. 

 While the measures adopted for each purpose are likely to be complementary, 

 they may not be identical in this situation. 



In addition to these more direct threats, the disposal of sewage 

 and trash, primarily by recreational boaters, could threaten the resources. 

 These threats are not considered in any FMP and regulation under other 

 laws is limited as detailed below. Finally the protection of a shipwreck, 

 the HMS Looe , found in the area is desirable and not currently provided. 



Pollution from dredging and dredge spoil disposal, ocean outfalls 

 and other point source discharges and from any ocean dumping activities 

 does not appear to pose a realistic threat at least at the present time. 

 The Environmental Protection Agency and the Corps of Engineers have authority 

 under the Clean Water Act and Ocean Dumping Act to address these activities 

 on a case-by-case basis. 



Surveillance and enforcement duties for the previously mentioned 

 laws and implementing regulations have been assigned, for the most part, 

 to three government agencies in the Florida region; the U.S. Coast Guard, 

 the NMFS Division of Law Enforcement and the Florida Marine Patrol. This 

 existing enforcement framework patrols the Fishery Conservation Zone, defined 

 as those waters "Seaward of the 3 mile territorial sea boundary to 200 

 miles." Detailed information on these enforcement agencies is found in 

 Section C— Enforcement (Dennis, 1979). 



Eighty percent of Coast Guard missions in Florida deal with search 

 and rescue. The Group Key West Coast Guard ranges along the entire coastline 

 of the Florida Keys with their number one enforcement activity, at the 

 present time, being drug interdiction. Distances between stations and the 

 large territory to be covered makes their patrols for all missions intermittent 

 and infrequent (Dennis, 1979). 



The extent to which the Coast Guard, patrolling the Florida Keys, 

 might be able to assist in the enforcement of the marine sanctuary at Looe 

 Key can be judged by the number of personnel and the number and complexity 

 of their present missions. From interviews with Commander Dave Russell, 

 Coast Guard 7th District in Miami, and Lt. Commander Sam Dennis, Commander 

 of Group Key West, it appears that the Coast Guard does not presently have 

 adequate time or personnel to enforce effectively a marine sanctuary at 

 Looe Key. 



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