Florida Keys National Marine Sanctuary
33 East Quay Road
Key West, FL 33040
Re: Docket Number NOAA-NOS-2019-0094
Dear Ms. Fangman:
I am writing to express the strong support of the Association of Zoos and Aquariums (AZA) for the most protective measures possible to protect the Florida Keys National Marine Sanctuary (FKNMS) based on the proposed Florida Keys Restoration Blueprint. The Blueprint addresses the threats to the sanctuary, restores habitats and protects marine wildlife. The Sanctuary is a national treasure that protects more than 6,000 species of marine life; 800 underwater historic sites; 1,800 miles of mangrove-fringed islands; 1.4 million acres of extensive seagrass beds; and the only coral barrier reef in the continental United States.
AZA is a non-profit organization dedicated to the advancement of accredited zoos and aquariums in the areas of animal care and husbandry, conservation, education, science and recreation.
AZA's 238 accredited aquariums, nature centers, science centers and zoos annually host more than 200 million visitors, collectively generate more than $22 billion in annual economic activity, and support more than 208,000 jobs across the country. In 2018, AZA-accredited facilities contributed more than $230 million to field conservation in over 130 countries benefiting over 880 species and subspecies, including over 240 species listed as endangered or threatened under the Endangered Species Act. The expertise of AZA-accredited aquariums and zoos in scientific research, conservation breeding, and wildlife rescue and rehabilitation is supported by their premier role in conservation education.
In its Restoration Blueprint, NOAA proposes to: (1) expand the boundary of the FKNMS, (2) update sanctuary-wide regulations, (3) modify existing and create new marine zones, (4) update associated marine zone-specific regulations, and (5) revise the FKNMS management plan.
The following are specific actions that we encourage NOAA to implement in its final Restoration Blueprint:
The Restoration Blueprint should expand the number and size of no-take areas that protect habitats and biodiversity. In the Florida Keys, large, no-take areas, like the Dry Tortugas Ecological Reserves, have shown increased biomass and wildlife diversity. These benefits spill over to adjacent waters aiding in habitat recovery, fisheries productivity, and sustaining hot spots of biodiversity and wildlife richness. To realize the greater benefits of fully protected areas, no- take protected areas should be expanded and levels of protection should be strengthened, such as in the proposed Conservation Areas, to scale up these benefits.
The Restoration Blueprint should strengthen protection of high biodiversity areas and wildlife corridors. Certain areas — spawning aggregation sites for multiple species, nursery and key foraging grounds, critical habitat for endangered and threatened species, and areas that species use during sensitive life stages — need stronger protections. Pulley Ridge, the deepest known photosynthetic coral reef off the continental United States, and Western Dry Rocks, an important multi-species spawning ground, are hotspots of biodiversity that should be fully protected. NOAA needs to protect areas like the Marquesas Keys Turtle Area, an internationally important foraging ground for a unique aggregation of endangered green sea turtles and the only known population in southeast US. Similarly, mangroves and backcountry islands, like Pigeon Key, should be fully protected as important, highly sensitive bird nesting and rookery site.
From fish to sea birds to sea turtles to marine mammals, many species call the Florida Keys home at all different stages in life. It is important to recognize that in addition to these hot spots of biodiversity, we need to understand the importance of wildlife connectivity and the critical role that wildlife corridors play in protecting species that utilize different parts of the marine environment across the Florida Keys ecosystem. For example, the Tortugas Corridor can protect resident corals as well as fish transiting from the nearshore waters and shallow banks of Dry Tortugas National Park, which are essential juvenile fish nurseries, to the deeper adult fish spawning habitat in the Tortugas South Ecological Reserve.
The Restoration Blueprint needs to protect a diversity of habitats. Certain habitat types — like backcountry hard bottom areas and seagrass beds, mangrove forests, sand bars, offshore patch reefs and deep reefs — have been studied more recently and their importance and interconnectedness in the larger Keys ecosystem is better understood now. Mangroves and seagrasses capture sediment and nutrients from land before it washes offshore, smothering the coral reefs. Mangroves and seagrasses also serve as important nursery habitats, sheltering sensitive life stages of commercially and recreationally important reef fish species. Patch reefs and deep reefs offshore are often more resilient, showing less impact from higher sea surface temperatures, ocean acidification, and water quality degradation, making them critical for restoration of the Florida Keys reef tract. All of these habitats protect our coastal communities during storms by attenuating waves and storm surges. And all of these habitats are intertwined and connected. It is important to look more holistically at protecting a diversity of habitats for more effective ecosystem conservation.
The Restoration Blueprint needs to protect larger areas from shoreline to reef zones. Creating large, contiguous areas containing diverse habitat types offers the highest protections for multiple species and sustaining ecosystem functions in the face of the changing climate and water quality challenges. They also contribute to juvenile and adult fish that spill over into areas of the sanctuary to replenish fish stocks. Protecting specific habitats and zones will only protect wildlife during certain life phases. Western Sambo Sanctuary Preservation Area is an interconnected network of nearshore and mid-shelf patch reefs and bank reef with a prominent spur-and-groove habitat along with associated seagrass and hard bottom communities. This zone provides a corridor for the migration of juvenile and adult fish and invertebrate populations, including lobster, that spawn in deeper reefs and then shelter and feed at offshore and mid-shelf reefs throughout the larger area.
Similarly, connecting large areas, like Long Key and Tennessee Reef and Carysfort Reef Sanctuary Preservation Area, into a more comprehensive protected area from seagrass, shallow hard bottom, patch reef, and deep reefs with slower growing corals provides a corridor for migration of different life stages of fish from Florida Bay into the offshore reefs and spawning locations for fish and lobster.
The FKNMS needs stronger, more robust protections to build resilient ecosystems and foster successful restoration. Stronger protections that safeguard and bolster greater biodiversity and cover a network of interconnected habitats enhance the ability of ecosystems to respond to global, regional, and local stresses by both buffering the impacts and supporting recovery afterwards. Supporting adaptive, flexible emergency response to threats can aid in more effective management, safety, and resource recovery. Likewise, a strong management plan that focuses on key priorities, promotes sustainable use, and enhances collaboration with key partners is needed to protect and conserve the marine environment. Ultimately, increasing the protections throughout the Florida Keys is needed to facilitate success of innovative restoration efforts on a far greater scale. Partners and managers are looking to scale up active restoration of coral reefs and other habitats to help the Florida Keys thrive. Now is a critical time to look at higher levels of protection and balancing activities that impact marine resources in order to create conditions that can lead to successful restoration of the Florida Keys’ marine environment.
AZA and its members know first-hand the threats that the Florida Keys’ marine environment are facing. In 2014, an unidentified coral tissue loss disease was first observed in Miami-Dade County, Florida, and quickly spread throughout the northern areas of the Florida Reef Tract (FRT). The disease outbreak has continued to slowly and persistently progress south of Miami through the Upper, Middle and Lower Keys and now beyond.
In response, the Florida Fish & Wildlife Conservation Commission, NOAA, and the Florida Department of Environmental Protection have assembled the Florida Coral Rescue Team to plan and execute the Florida Coral Rescue Plan to save what is left of Florida’s healthy coral stocks. This Rescue Plan has two primary goals: 1) to prevent ecological extinction along the Florida Reef Tract for the most susceptible species, and 2) to maintain as much genetic diversity as possible for ~25 priority species in preparation for restoration and future disturbances.
The Rescue Team reached out to AZA and its member institutions and has requested resources to house and maintain corals (and more recently, live rock for substrate) for gene banking, and propagation for potential future recovery and restoration activities. AZA-accredited aquariums in Florida (led by the Florida Aquarium, Mote Marine Laboratory and Aquarium, SeaWorld, and Disney Animals, Science and the Environment) have answered the call, as have other zoos and aquariums within the AZA community. However, the bottom line is if there is no acceptable
Florida Keys ecosystem to reintroduce these precious corals back to, our collective efforts have made no ecological impact and those corals will thrive only in AZA facilities in the future.
AZA-accredited zoos and aquariums and the National Marine Sanctuary Program are in a unique position to work collaboratively to raise the public's levels of awareness on many important environmental and resource issues affecting our Nation's ocean and coastal environments. People across the nation need to see and understand this part of our public commons, our natural heritage, heretofore largely hidden from view by the surface of the sea. AZA and its member institutions stand ready to assist, given available resources, by implementing formal and informal educational programing about the Florida Keys and other marine sanctuaries and monuments, linking spectacular regions of our oceans to those areas and animals that we already highlight for our guests.