GENERIC RESPONSE #3 



During review of the DEIS and at the public hearings two issues were raised 

 focused on 1) the basis for selection of Looe Key as a sanctuary proposal and 

 2) the size of the proposal area. With regard to the first issue, certain 

 reviewers stated that in their opinion Looe Key is not a unique area and there- 

 fore sanctuary designation is not justified. The uniqueness of the Looe Key 

 area is indeed not measured in terms of new and different species assemblages. 

 It is true that the species found on Looe Key are also found all along the 

 Florida Reef tract. The special nature of Looe Key is measured, instead, in 

 terms of the spectacular beauty of the spur and groove system, the value of 

 this small area to local biological productivity (see commercial fishing 

 statistics) and the ease of accessibility to the user public. Looe Key is 

 located only 6.7 nm offshore and can be easily located in a relatively short 

 period of time. The shallow water portions of the reef in combination with the 

 deeper areas make it attractive to both novice and highly experienced swimmers, 

 snorklers and divers. Public charter boat operations, dive boats, recreational 

 divers and fishermen, a major non-profit organization (the Newfound Harbor 

 Marine Institute) and established commercial fishermen utilize the reef. The 

 area is currently experiencing intensive public use which based on population 

 and tourist projections is expected to increase. All of these factors 

 taken together contribute to the special nature of Looe Key. While it 

 is true that it is not the only beautiful section of the reef tract and that 

 it is but one of the several shelf margin reefs in the lower keys, NOAA 

 believes that, without question, the combination of factors discussed above 

 qualify Looe Key for sanctuary status and that given user pressures, this small 

 section of the reef tract must be comprehensively managed if its long-term 

 viability is to be assured. 



The proposed 5 sq nm boundary was criticized during the review both as 

 being too large and as being much too small. It was felt by several commentors 

 that the proposed 1 sq nm HAPC presents an appropriate size for a sanctuary. 

 Protection of an area of this size will provide for prohibitions of physical 

 damage to the Fore Reef and associated organisms. It will not likely provide 

 an adequate area for assuring biological integrity of the system. In the marine 

 environment protection of any core area (Fore Reef) requires identification and 

 protection of even large areas (buffers) where essential processes for the 

 stability of the core take place. NOAA does not believe that 1 sq nm offers a 

 reasonable buffer to assure long-term productivity of the Looe Key reef system. 



The 5 sq nm sanctuary proposal has also been criticized as being too small 

 and vulnerable to outside harmful activities to warrant designation. It is true 

 that marine systems cannot be managed by reliance upon traditional land manage- 

 ment techniques. Essential differences between marine and terrestrial environ- 

 ments include the size of the ecosystems, the mobility of marine organisms and 

 the three dimensional nature of the hydrosphere, sink, and downstream 

 affects. Because of these characteristics, setting aside limited marine areas 

 such as Looe Key contributes to protection of the large system. Locating 

 these small candidates for protection involves consideration of their location, 

 number, size and linkages. Ideally, management would be able to identify the 

 linkages, protect them and thereby protect the region as a whole while we 

 continue to use and enjoy it. 



E-5 



