6-APPLICATION SAJ-2025-00696 Gulfside8MileArtificialReef AttachmentPackage FINAL.pdf

SAJ-2025-00696

Gulfside Eight Mile Artificial Reef

Permit Application Attachments

Prepared by:

Dr. Hanna Koch, Artificial Reefs Director

Monroe County Board of County Commissioners

Monroe County, Florida

Submitted: 05/19/2025

Table of Contents

Attachment #1a Primary Information………………………………………………………….……

Attachment #1b Supplemental Information………………………………………………………..…

Table 1: Gulfside Eight Mile Artificial Reef Proposed Coordinates………………………….………3

Figure 1: Gulfside Network Map of Proposed/Permitted Artificial Reef Site……………………15

Figure 2: Gulfside Eight Mile Artificial Reef Access Map………..…...……………………..……….16

Figure 3: Gulfside Eight Mile Artificial Reef – NOAA Chart 1142

Figure 4: Typical Cross-Section for Gulfside Eight Mile Artificial Reef………………….……….18

Figure 5: Gulfside Network Preliminary Bottom Surveys ……

Figure 6: Gulfside Eight Mile Artificial Reef Benthic Surveys…..………………………….…

Figure 7: Shrimp Trawl Closure Map……………………………………..…………………….…………32

Figure 8: Map of Historical Shrimping Effort…………………………..………………………………..33

Figure 9: Examples of Material & Structure Types to be Deployed…………

Figure 10: Schematic of Spatial Planning Considerations for Artificial Reef Site.…………..35

Attachment #2 FWC Cargo Manifest/Pre-deployment Notification Form...….……………..36

Attachment #3 FWC Material Placement Report/Post-deployment Notification Form….37

Attachment #4 Florida Bureau of Historic Preservation Coordination…..…………………...38

Attachment #5 Consideration of Section 106: Impact………………………………………………39

Attachment #6 Consideration of Section 106: Scale………………………………………………..44

Attachment #7 Consideration of Section 106: Summary…………………………………………..54

Attachment #8 Consideration of Section 106: Subject Matter Expert Opinion Letter………57

[ATTACHMENT #1a]

SAJ-2025-00696 Primary Information

APPLICANT: Monroe County Board of County Commissioners C/o Dr. Hanna Koch 2798 Overseas Highway, Marathon, FL 33050

PROJECT NAME: Gulfside Eight Mile Artificial Reef

WATERWAY AND LOCATION:

The project would affect waters of the United States associated with the Gulf of America.

The project is located at a depth of 37’ MLLW in state waters, 25.61 nautical miles northeast of Key West at a bearing of 33 degrees, 22.91 nautical miles northeast of Stock Island at a bearing of 25 degrees, and 14.64 nautical miles northwest of Cudjoe Key at a bearing of 350 degrees. The proposed area is 21.96 nautical miles from Calda Channel Marker “3” northeast of Key West at a bearing of 41 degrees.

APPROXIMATE COORDINATES:

Table 1: Gulfside Eight Mile Artificial Reef Proposed Corner and Centroid Coordinates

PROJECT PURPOSE:

Basic: Artificial reef development.

Overall: This permit application is for the development of an artificial reef site with multiple deployments of approved materials to enhance the marine environment and create new habitat for marine organisms, including fish, within the offshore waters of the Gulf of America, Monroe County, Florida. The proposed Gulfside Eight Mile Artificial Reef Permit is part of an overall county-wide plan to create a network of separate 53-acre permitted artificial reef sites in this general area of the Gulf of America (~5-25 miles offshore in state or federal waters, outside the boundaries of the Florida Keys Marine Sanctuary, in waters ~35-60’ deep, ¼ nm by ¼ nm site, with sites ~2-5 nm apart) (Fig. 1). The purpose of the network is to provide ample, long-term, stable, quality, complex habitat to a variety of marine species and fish, provide waypoints for fish migrating between the near and offshore or between the Gulf and Atlantic, provide new fishing and diving opportunities while reducing human user conflicts and fishing pressure at any one location by having multiple

Lat (N) Lon (W) Lat (N) Lon (W) Lat (N) Lon (W) Center 24.904 -81.556 24° 54' 14.4'' 81° 33' 21.6'' 24° 54.24' 81° 33.36'

NW Corner 24.90607 -81.55831 24° 54' 21.852'' 81° 33' 29.916'' 24° 54.3642' 81° 33.4986' NE Corner 24.90607 -81.55373 24° 54' 21.852'' 81° 33' 13.428'' 24° 54.3642' 81° 33.2238' SE Corner 24.90191 -81.55373 24° 54' 6.8759'' 81° 33' 13.428'' 24° 54.1146' 81° 33.2238' SW Corner 24.90191 -81.55831 24° 54' 6.8759'' 81° 33' 29.916'' 24° 54.1146' 81° 33.4986'

8 Mile Decimal Degrees (DD) Degrees Minutes Seconds (DMS) Degrees Degrees Minutes (DDM) patch reefs within each proposed permit area, include a variety of structure types to promote biodiversity, and reduce pressure on natural reefs. This permit application is for one proposed artificial reef within the larger Gulfside Network. The Gulfside Ten Mile Artificial Reef permit (#SAJ-2024-00133, SP-GGM) has been approved. The Gulfside Five Mile Artificial Reef permit application has been submitted to USACE (#SAJ-2024-04159) and has already been approved as a General Permit by FDEP (#44-0453700-001-EG). The Gulfside Nine Mile Artificial Reef permit application has been submitted to USACE (#SAJ-2024-04827) and has already bee approved as a General Permit by FDEP (#44-0459830-001-EG).

EXISTING CONDITIONS:

The proposed permitted area is comprised of unconsolidated sand bottom, and the approximate depth of water within this site is ~37’ relative to mean low lower water (MLLW).

No natural hardbottom or submerged aquatic vegetation (SAV) is known within the vicinity of the proposed area.

PROPOSED WORK:

The applicant seeks a 10-year authorization to develop an artificial reef site known as the Gulfside Eight Mile Artificial Reef. The proposed artificial reef area would measure 0.25 nautical mile by 0.25 nautical mile encompassing 53 acres of sand bottom, of which less than 1 acre of artificial reef material footprint would be deployed during the lifetime of the permit. The proposed navigational clearance requested is -22’ MLLW, consistent with existing charted artificial reef permits in surrounding waters. All artificial reef materials will be consistent with the approved Gulf and Atlantic States Marine Fisheries Commission publication “Guidelines for Marine Artificial Reef Material, 3rd edition”, as well as NOAA’s ‘National Artificial Reef Plan’, and FWC’s ‘State of Florida Artificial Reef Strategic Plan’.

AVOIDANCE AND MINIMIZATION INFORMATION:

Selected sites are devoid of SAV and there are no natural rock outcrops or hard bottom formations. Materials will be deployed on sand bottom and a buffer of at least 200 feet will be maintained from any submerged aquatic resources if present, including seagrasses, macroalgae, corals, sponges, or hard bottom. To ensure that the deployed materials remain in place within the authorized boundaries, only materials that weigh at least 500 pounds will be deployed. There will be a 50’ buffer zone inside the site borders on all sides to ensure all reef materials will be deployed within the permitted zone.

COMPENSATORY MITIGATION:

Impacts to special aquatic sites are not proposed. Project purpose includes habitat enhancement involving placement of approved artificial reef materials on the seafloor.

There will be no excavation or turbidity impacts. Therefore, no compensatory mitigation is proposed.

CULTURAL RESOURCES:

The applicant is not aware of any known historic properties within the proposed area and coordinated with the Florida Bureau of Historic Preservation via email on May 19, 2025 to confirm the lack of cultural resources in the proposed area (Attachment 4). For a thorough analysis on the consideration of archaeological, cultural, and historic resources under Section 106, please refer to Attachments 5-8. In summary, there is little to no probability that any such resources exist within the proposed permit area.

ENDANGERED SPECIES:

The proposed activities are consistent with the Endangered Species Act – Section 7 Consultation Biological Opinion (2017) Project Design Criteria specific to Activity 7 for Aquatic Habitat Enhancement, Establishment, and Restoration Activities, Additional conditions for reef materials. The proposed site does not overlap with any currently established critical habitat areas. The proposed area does overlap with the pending green sea turtle critical habitat area designation proposed in July of 2023, but still no final ruling as of May 2025, and no impacts to green sea turtle habitats are expected. As part of our Best Management Practices, we will comply with all regulations as they become available, including necessary surveys and animal translocation procedures if required or applicable.

No queen conch were observed during any of the preliminary sediment surveys conducted in August 2024 or subsequent benthic surveys conducted in April 2025 (see Figs. 5a-5b below for survey details). For this reason, we do not anticipate impacts to queen conch in this area.

COASTAL ZONE MANAGEMENT CONSISTENCY:

Artificial reefs that are constructed in Florida's coastal zone require coordination with the state for Coastal Zone Management (CZM) Consistency as required under Section 307(c) of the Coastal Zone Management Act of 1972, as amended (16 U.S.C. 1456(c)). This coordination is required even when the state does not issue or require a state permit. CZMA review is expected as a component of FDEP permit review. A FDEP pre-application consultation was held on July 16, 2024 and after reviewing the permit application package herein, it was concluded that the scope of this proposed permit area complies with the requirements for issuance of a Noticed General Environmental Resource Permit (Chapter 62-341.600, Florida Administrative Code). A general FDEP permit application is being submitted simultaneously as this USACE permit application.

[ATTACHMENT #1b]

SAJ-2025-00696 Supplemental Information

1. Applicant: Monroe County Board of County Commissioners

Project Name: Gulfside Eight Mile Artificial Reef

Project Location: Monroe County is requesting a 10-year permit to authorize a new artificial reef site off Monroe County. The proposed Gulfside Eight Mile Artificial Reef site is a 0.25 nautical mile by 0.25 nautical mile square, encompassing 53 acres of sand bottom of which less than 1 acre of artificial reef material footprint will be deployed during the lifetime of the permit. The center coordinates of the proposed site are latitude 24° 54.24' N and 81° 33.36' W (Fig. 1). The site is located in the Gulf of America within state waters and lies outside of the boundaries for the Florida Keys National Marine Sanctuary. The project is located at a depth of ~37 ft MLLW in state waters of the Gulf of America, 25.61 nautical miles northeast of Key West at a bearing of 33 degrees, 22.91 nautical miles northeast of Stock Island at a bearing of 25 degrees, and 14.64 nautical miles northwest of Cudjoe Key at a bearing of 350 degrees (Fig. 2). The site is 21.96 nautical miles from Calda Channel Marker “3” northeast of Key West at a bearing of 41 degrees (Fig. 3). All deployed material will retain at least a 22’ navigational clearance. Table 1 lists the corners and centroid of the proposed site.

Table 1: Gulfside Eight Mile Artificial Reef Proposed Corner and Centroid Coordinates

Depth, Profile, and Clearance: The approximate depth of water within the site is -37 feet relative to Mean Lower Low Water (MLLW) (NOAA Chart 1142_1; Figure 3). The proposed minimum navigation clearance requested is 22 feet (MLLW), consistent with existing charted artificial reef permits in surrounding areas. Reef structures selected for deployment will maintain a minimum navigational clearance of at least 22 feet relative to MLLW (Fig. 4).

Previously existing permitted sites in the region show charted navigational clearances of 20 ft in 24 ft waters, 25 ft in 49 ft waters, and 28 ft in 38 ft waters. There will be a 50’ buffer zone

Lat (N) Lon (W) Lat (N) Lon (W) Lat (N) Lon (W) Center 24.904 -81.556 24° 54' 14.4'' 81° 33' 21.6'' 24° 54.24' 81° 33.36'

NW Corner 24.90607 -81.55831 24° 54' 21.852'' 81° 33' 29.916'' 24° 54.3642' 81° 33.4986' NE Corner 24.90607 -81.55373 24° 54' 21.852'' 81° 33' 13.428'' 24° 54.3642' 81° 33.2238' SE Corner 24.90191 -81.55373 24° 54' 6.8759'' 81° 33' 13.428'' 24° 54.1146' 81° 33.2238' SW Corner 24.90191 -81.55831 24° 54' 6.8759'' 81° 33' 29.916'' 24° 54.1146' 81° 33.4986'

8 Mile Decimal Degrees (DD) Degrees Minutes Seconds (DMS) Degrees Degrees Minutes (DDM) inside the site borders on all sides to ensure all reef materials will be deployed within the permitted zone.

2. Project Purpose:

Basic: Marine habitat enhancement and increase fishing/diving opportunities within state waters.

Overall: This permit application is for the development of an artificial reef with site multiple deployments of approved materials to enhance the marine environment and create new habitat for marine organisms, including fish, within offshore waters of the Gulf of America, Monroe County, Florida. The proposed Gulfside Eight Mile Artificial Reef Permit is part of an overall county-wide plan to create a network of separate 53-acre permitted artificial reef sites in this general area of the Gulf of America (~5-25 miles offshore in state or federal waters, outside the boundaries of the Florida Keys Marine Sanctuary, in waters ~35-60’ deep, ¼ nm by ¼ nm site, with sites ~2-5 nm apart). The purpose of the network is to provide ample, long-term, stable, quality, complex habitat to a variety of marine species and fish, provide waypoints for fish migrating between near and offshore or between the Gulf and Atlantic, provide new fishing and diving opportunities while reducing human user conflicts and fishing pressure at any one site by having multiple patch reefs within each proposed permit area, include a variety of structure types to promote biodiversity, include low relief structures to support early life stages for juvenile fish, and reduce pressure on natural reefs.

This permit application (SAJ-2025-00696) is for one proposed artificial reef within the larger Gulfside Network. A permit application for Gulfside Ten Mile Artificial Reef (SAJ-2024-00133, SP-GGM) has already been approved, and additional permit applications for this network will be submitted over time as benthic surveys are completed. Overall, we aim to create ~6- 10 permitted sites (i.e., artificial reefs) within the Gulfside Network.

Purpose of the artificial reef: The primary objective of this new permit authorization is to create additional long term, stable, quality marine habitat within state waters offshore of Monroe County for a variety of fish and other marine species.

Users: The Gulfside Eight Mile Artificial Reef will be accessible for recreational angling, charter boat use, and SCUBA diving.

3. Site Surveys:

An initial scoping meeting was held with Monroe County, Florida Fish and Wildlife Conservation Commission, and fishing guides from Key West on August 1, 2023 to discuss possible artificial reef locations and preferences for materials and design. Multiple fishermen stated the desire for reefs in the Gulf of America waters north of the Keys, stating the desire for juvenile fish habitat and additional structure in the sandy areas. On September 7, 2023, FWC conducted preliminary bottom surveys via SCUBA at seven locations north of Key West (within the vicinity of the proposed location herein) around

Gulfside 10 Mile and Gulfside 5 Mile sites (Fig. 5, red markers). In August 2024, Monroe County conducted another series of preliminary bottom surveys to identify additional artificial reef sites (Fig. 5). At 13 locations in state and federal waters of the Gulf of America, the depth and general sediment composition were recorded, and photographs of the seafloor were taken (Fig. 5, Table 2). At each site, the surveyor inserted her hand into the sand and did not find any hardbottom resources buried below the sand. Findings from all thirteen dives were compared with bottom sediment classification maps from NOAA’s Gulf of America Data Atlas and were consistent across each dive. The proposed area is classified as majority “sand” (80-100%) (Fig. 5). The results of these preliminary bottom surveys were then used to identify sites with appropriate substrate for artificial reef deployment (i.e., no hardbottom, no SAV, no mud, mix of coarse and fine sand) and which would be returned to for more extensive benthic surveys to record biological resources and confirm that no archaeological or historic resources existed within the proposed permit boundaries (Fig. 6).

Follow-up benthic surveys were conducted on April 13, 2025, where divers swam six transects within the proposed permit area (Fig. 6). Each of the dives (benthic surveys) lasted ~20 minutes with divers swimming between ~700 -1,500 feet per dive, depending on the strength and direction of the current. Divers took pictures and videos of the seafloor throughout the dive, and reported all areas are comprised of sand bottom. Few organisms were reported, which included primarily sparse sea stars, sea urchins, sea pens, sand dollars, and sea biscuits. Very few fish were observed. No stony corals or queen conch were observed. No archaeological, historic, or cultural resources were found. There were no reports of hardbottom or submerged aquatic vegetation on any of the dives. Based on the surveys completed, the proposed area is free of hardbottom resources and suitable for deployment of approved artificial reef materials.

The proposed area does not overlap with shrimping industry activities due to the Tortugas Shrimp Beds Area closure area (F.A.C. 68B-31.016) which prevents shrimp harvest in an area encompassing the proposed site (Fig. 7). Additional reports and desktop analyses further confirm the proposed area is outside of historic shrimping activities (Fig. 8).

The conclusion of the bottom survey reports and associated desktop analysis is that the site is appropriate for an artificial reef; the water depth and substrate composition suggest that minimal environmental impact would occur. Observed presence of infauna and benthic macrofauna was limited, but if exist in proposed permitted area, have ample opportunity to migrate within surrounding sand habitat. Of the 53 total acres of the proposed permitted area, less than one (1) acre will cover the seafloor. The addition of artificial reef materials to this site would increase settlement of invertebrate and finfish recruitment to an otherwise bare sand area. Overall, this is an ideal site for the proposed artificial reef system and will add to the biological diversity of the waters off the coast of Monroe County.

4. Reef Materials:

The artificial reef material types to be deployed in the proposed Gulfside Eight Mile Artificial Reef site will be consistent with the approved Gulf and Atlantic States Marine Fisheries Commission publication “Guidelines for Marine Artificial Reef Material, 3rd edition”, as well as NOAA’s ‘National Artificial Reef Plan’, and FWC’s ‘State of Florida Artificial Reef Strategic Plan’. Examples of proposed materials include secondary-use concrete (culverts, power poles, bridge material, junction boxes etc.), pre-fabricated or printed concrete artificial reef modules, and limestone boulders (Fig. 9). Modules will be constructed with the approved minimum turtle regress standard. Barges, vessels and metal structures are not proposed (e.g., we will not deploy chicken coops/cages).

Any concrete materials of opportunity with more than six inches of protruding metal rebar will be removed and cut flush prior to deployment to minimize safety concerns for divers and prevent fishing line entanglement to avoid excessive snags for fishermen.

All artificial reef materials shall be clean and free from excess dirt, asphalt, creosote, petroleum, or other hydrocarbons and toxic residues, loose free-floating material or other deleterious substances. Reef materials will have sufficient weight (greater than 500 lbs.) for the reef material to remain stable in storm currents anticipated to occur at the site. All reef materials will be stable and capable of at least a 20-year life expectancy to allow for the reef material to function as useful marine habitat. Material will be deployed into separate patch reefs within the proposed permitted area to maintain sand forage area between patch reefs and disperse fishing pressure between locations. An example patch reef design showing the relative placement and distance between patch reefs within the proposed permitted site can be found in Fig. 10. Materials may be deployed over the lifetime of the permit to create additional separate patch reefs as additional funding becomes available. Importantly, the structures will be configured in a way to prevent marine life entanglement or entrapment.

5. Project Design Criteria:

As consistent with the USACE Jacksonville District’s 2017 Programmatic Biological Opinion (JAXBO), all applicable artificial reef project design criteria (PDCs) will be followed:

A7.13. Artificial reef materials shall be clean and free from asphalt, creosote, petroleum, other hydrocarbons and toxic residues, loose free-floating material, or other deleterious substances.

● Response: Proposed materials include this standard.

A7.14. New reef sections are limited to 1 reef section measuring ¼- by ¼-nmi area (53 ac) in size with a distance of 500 ft between each section. Offshore reefs shall maintain a minimum vertical clearance of twice the height of the structure from the top of the deployed material relative to the MLW at all times.

● Response: Proposed area is ¼- by ¼-nmi area and there are no additional permitted areas within 500 ft. Requested vertical clearance is 22 ft, consistent with navigational clearance of existing permitted areas in the vicinity.

A7.15. Reauthorization of existing reefs is limited to the previously permitted size. Approved materials defined in PDC A7.19 can be added to the existing reef area.

● Response: Not applicable as this is a new area, not a reauthorization.

A7.16. No artificial reef materials shall be deployed until a benthic assessment of the bottom conditions has been accomplished by diver or submersible video camera. The inspection of the deployment area may occur at the time of deployment but no more than 1 year prior to deployment. The permittee shall maintain a deployment buffer of at least 200 ft from any submerged aquatic resources, including seagrasses, macroalgae, hard or soft coral (including coral reefs), sponges, oysters, or hard bottom when placed in areas of sand.

If materials are off-loaded from a barge or placed in areas that may generate turbidity (e.g., areas with fines or muck), a 500 ft buffer is required.

● Response: Bottom surveys have been completed by divers and no areas with submerged aquatic resources within 200 ft were found. There are no areas with silt or muck that would lead to turbidity issues.

A7.17. The project does not include the use of mid-water fish aggregation devices.

● Response: The project complies with this regulation.

A7.18. All reefs must be cleaned annually to remove marine debris and derelict fishing line in areas safely accessible to recreational SCUBA divers. Cleanup efforts shall follow the PDCs for Activity 9, marine debris removal, and all pertinent general PDCs.

● Response: We will comply with this regulation. The permitted area is within recreational diving limits and accessible by boat for divers to complete marine debris removals.

A7.19. Individual reef units or modules must weigh at least 500 pounds. Reef materials shall be clean and free from asphalt, petroleum, other hydrocarbons, and toxic residues, as well as loose, free-floating material, or other deleterious substances.

● Response: All artificial reef materials and/or structures will be selected, designed, constructed, and deployed to create stable and durable marine habitat.

Only the following reef materials may be used under this Opinion:

A7.19.1. Prefabricated artificial reef modules composed of ferrous and/or aluminum alloy metals, concrete, rock, or a combination of these materials.

A7.19.2. Natural rock boulders and pre-cast concrete material, such as culverts, stormwater junction boxes, power poles, railroad ties, jersey barriers, or other similar concrete material.

A7.19.3. Clean steel and concrete bridge or large building demolition materials such as slabs or piles with all steel reinforcement rods cut at the base of the concrete so no rebar or metal protrudes from the concrete.

● Response: The proposed reef materials all fall under A7.19.1, A7.19.2, and A7.19.3. Each single unit will weigh no less than 500 lbs. Examples of the types of approved materials and structures that may be deployed at the Gulfside Eight Mile Artificial Reef site can be found in Figure 9.

A7.20. Reef structures, materials, and installation methods shall be designed and deployed to prevent entanglement and entrapment of listed species. Open-bottom pre-fabricated reef modules may not be used unless the module also has a top opening sufficiently large to allow a turtle to escape. Approved open-bottom modules include:

A7.20.1. Three-sided modules where each side of the top opening is at least 36-in in length along its edge.

A7.20.2. Four or more sided modules where each side of the top opening is at least 40-in in length along its edge.

A7.20.3. Modules with a round opening with a diameter of at least 40-in (oval openings are not allowed unless a 40-in diameter circle space can fit within the oval).

A7.20.4. Modules that are approved by the FWS Artificial Reef Program as being turtle friendly. FWS is currently working on developing this list. No open-bottom modules are allowed that include additional modules, discs, or other materials stacked or placed on or immediately adjacent to the top opening, as they may prevent turtles from easily escaping.

● Response: Any prefabricated modules would either not have open-bottoms or be designed with appropriate openings for turtle egress and following all standards outlined in A7.20.1., A7.20.2., A7.20.3., and A7.20.4.

A7.21. This Opinion does not cover projects that use explosives to deploy reef material.

● Response: No materials will be deployed using explosives.

A7.22. If pile placement is required in the construction of a reef, such placement must comply with the PDCs for Activity 2, pile-supported structures, and all applicable general PDCs.

● Response: No pile placement is required.

Additional PCDs for Activity 7 applicable in critical habitat: A7.25-A7.31.

● Responses:

o The proposed area does not overlap with critical habitats for smalltooth sawfish (A7.25), gulf sturgeon (A7.26), North Atlantic right whale (A7.27), Acropora (A7.28), Johnson’s seagrass (A7.29), Loggerhead (A7.30), or U.S. Caribbean Sea Turtle (A7.31).

o We understand that the ruling on Queen Conch critical habitat will soon be published. As part of our Best Management Practices, we will comply with all regulations as they become available, including necessary surveys and animal translocation procedures if required or applicable. During all surveys conducted in 2024 and 2025, no Queen Conch were observed (Figs. 5-6).

6. Pre and Post Deployment Notification:

The County will submit a FWC Cargo Manifest/Pre-deployment Notification Form (Attachment 2) at least two weeks prior to each deployment to designated state and federal agencies to allow inspection of proposed deployment materials. Notification will include the address for the point of departure, name and telephone number for the individual managing the deployment, specific latitude and longitude coordinates of the proposed point of deployment, a description and quantity of the materials proposed for deployment and proposed water depth above the deployed material. The FWC Cargo Manifest will be attached to a copy of the permit and carried on board the deployment vessel in case of an on-water inspection by state or federal authorities. This form will be signed by the Monroe County designated representative.

Within 30 days of completion of reef deployments, an FWC Material Placement Report/Post-deployment Notification Form (Attachment 3) will be completed and signed by the Monroe County official observer and submitted to the listed agencies. Post-deployment surveys will be conducted as well, and a final report submitted to the listed agencies. The report must include an accurate depiction of the location and configuration of the completed activity, and the height of material after placement in relation to the mean low water of the navigable water. The latitude and longitude must be accurate within five meters horizontal distance on the post-deployment report. Depth shall be verified utilizing fathometer, depth sounder, or similar device accurate to within one meter. Also, include information on the condition of the material at the time of deployment. Representative photographs and/or video, if available, will also be submitted.

7. Cultural Resources:

Refer to Attachments 4-8: The applicant is not aware of any known historic properties within the proposed area and coordinated with the Florida Bureau of Historic Preservation (Florida Master Site File) via email on May 19, 2025 to confirm the lack of cultural resources in the proposed area. Under consideration of Section 106, preliminary background research was conducted to assess the probability of historic or archaeological resources existing within the proposed permit area. This research concluded there to be little to no probability of such existing resources. This conclusion is bolstered by the results of the ground-truthing surveys conducted in 2024 and 2025, which found nothing either. Furthermore, an exercise on visualizing the relatively small size of proposed materials and scale of project was conducted.

8. Endangered Species:

The proposed activities are consistent with the Endangered Species Act – Section 7 Consultation Biological Opinion (2017) Project Design Criteria specific to Activity 7 for Aquatic Habitat Enhancement, Establishment, and Restoration Activities, Additional conditions for reef materials. The proposed site does not overlap with any currently established critical habitats.

The proposed area overlaps with the pending green sea turtle critical habitat designation proposed in July of 2023. The specific features relevant to this proposed area include the reproductive essential feature (from mean high water line to 20m depth, sufficiently dark and unobstructed nearshore waters adjacent to nesting beaches), the migratory essential feature (from mean high water line to a particular depth or distance from shore), and the benthic foraging/resting essential feature (from mean high water line to 20m depth, underwater refugia and food resources).

The proposed artificial reef permit area is not anticipated to impact green turtles from the North Atlantic distinct population segment with regards to mating, transiting to nesting beaches, swim frenzy of post-hatchlings, or migration. FWC 2018-2022 sea turtle nesting data shows the nearest sea turtle nesting beaches are over 20 nautical miles away from the proposed permitted area. All materials would maintain the minimum navigational clearance and would pose no threat to turtle transit or swimming ability. Deployment activities, which occur during a limited time of typically less than a few hours duration, will require designated observers to watch for evidence of endangered species and halt all activities until the species have left the area of their own accord.

The proposed artificial reef permitted area is not anticipated to impact green turtles from the North Atlantic distinct population segment with regards to benthic foraging and resting.

The area is free from seagrasses and other foraging resources. Additionally, sea turtles are anecdotally reported to use artificial reefs as a resting area for protection from predators, indicating that the proposed project would benefit marine turtle shelter and growth by contributing to the benthic foraging/resting essential feature.

We understand that the ruling on Queen Conch critical habitat will soon be published. As part of our Best Management Practices, we will comply with all regulations as they become available, including necessary surveys and animal translocation procedures if required or applicable. During all benthic surveys conducted in 2024 and 2025, no Queen Conch were observed.

9. Liability:

Monroe County is a governmental entity and has sovereign immunity. This immunity meets liability in the Corps regulations at 322.5 (b) and NARP pages 34-36 and NFEA Section 205.

Figure 1: Gulfside Network Map of Proposed and Permitted Artificial Reef Sites in the Gulf of America

Figure 1: Map depicts location (center GPS coordinates, DDM) of permitted (Gulfside Ten Mile Reef #SAJ-2024-00133) and proposed (Gulfside Five Mile Reef #SAJ-2024-04159;

Gulfside Nine Mile Reef #SAJ-2024-04827; Gulfside Eight Mile Reef (this application, red marker, #SAJ-2025-00696)) artificial reef sites within the Gulfside Network. All sites are located outside of the Florida Keys National Marine Sanctuary (green line). Gulfside Ten Mile Reef is located in federal waters and Gulfside Five, Eight, and Nine Mile Reefs are located in state waters of the Gulf of America (dashed black line).

Figure 2: Gulfside Eight Mile Artificial Reef Access Map

Figure 2: Map depicts access points including distance (nautical miles) and bearing from Key West, Stock Island, and Cudjoe Key to the proposed Gulfside Eight Mile Artificial Reef site (red marker) as indicated by its central coordinates. The proposed permit area is outside of the Florida Keys National Marine Sanctuary and within Florida state waters.

Figure 3: Gulfside Eight Mile Artificial Reef – NOAA Chart 1142_1

Figure 3: NOAA nautical chart depicts distance (nautical miles) and bearing from Calda Channel Marker “3” to the proposed Gulfside Eight Mile Artificial Reef site. The red marker represents the proposed permit area.

Figure 4: Typical Cross-Section for Gulfside Eight Mile Artificial Reef

Figure 4: Schematic drawing depicts approximate 37’ depth of the proposed artificial reef site relative to MLLW, the 22’ navigational clearance, and 15’ maximum relief of the artificial reef once materials are deployed.

Figure 5: Map of Preliminary Bottom Surveys in State and Federal Waters of the Gulf of America

Figure 5: Map shows the locations (GPS coordinates in DD) of 13 locations (black markers) in state and federal waters of the Gulf of America where preliminary bottom surveys were conducted in August 2024 to determine depth and general sediment composition. The sites are located outside of the FKNMS (green boundary line). The red markers for Gulfside Ten Mile Reef (SAJ-2024-00133) and Gulfside Five Mile Reef (SAJ-2024-04159) are included for reference purposes only as surveys and permit applications for these sites have already been submitted. The map also depicts the US Seabed Bottom Sediments Map for the Gulf of America (NOAA Gulf of America Data Atlas:

https://gulfatlas.noaa.gov/) which shows the sand composition (%) for the proposed Gulfside Network Artificial Reefs geographical area (see legend to left). For each of the 13 surveyed sites (black markers) the depth and sediment composition results are below in Table 2.

Photographic evidence of each dive is below (Figs. 5A-5M).

Table 2: Depth and Sediment Composition Results for Preliminary Bottom Surveys https://gulfatlas.noaa.gov/

Date Site Depth (ft) Sediment Composition 8/20/2024 7 37 Coarse sand, fine sediment, no hardbottom 8/20/2024 13 37 Coarse sediment, no hardbottom 8/20/2024 14 39 Coarse sand, fine sediment, no hardbottom 8/20/2024 8 44 Fine sediment, some mud, no hardbottom 8/20/2024 12 45 Fine sediment, some mud, no hardbottom 8/21/2024 4 37 Coarse sand, fine sediment, no hardbottom 8/21/2024 3 38 Coarse sand, fine sediment, no hardbottom 8/21/2024 6 39 Coarse sand, fine sediment, no hardbottom 8/21/2024 9 45 Fine sediment, some mud, no hardbottom 8/21/2024 11 46 Coarse sand, fine sediment, some mud, no hardbottom 8/21/2024 2 45 Coarse sand, fine sediment, no hardbottom 8/22/2024 15 56 Mud, no hardbottom 8/22/2024 1 48 Coarse sand, fine sediment, some mud, no hardbottom

Figure 5A: Underwater photo of Site 7 bottom conditions. Swam north for 10 min (covered ~500’ of seafloor) and observed similar bottom conditions, 37’ depth, sand deeper than hand, no hardbottom, coarse sand, fine sediment, shell hash, random small patches of macroalgae, no fish species present.

Figure 5B: Underwater photo of Site 13 bottom conditions. Swam north for 8 min (covered ~400’ of seafloor) and observed similar bottom conditions, 37’ depth, sand deeper than hand, no hardbottom, coarse sand, fine sediment, some shell hash, some fish

Figure 5C: Underwater photo of Site 14 bottom conditions. Swam north for 8 min (covered ~400’ of seafloor) and observed similar bottom conditions, 39’ depth, sand deeper than hand, no hardbottom, coarse sand, fine sediment, shell hash, some fish

Figure 5D: Underwater photo of Site 8 bottom conditions. Drifted east for 5 min (covered ~500’ of seafloor) and observed similar bottom conditions, 44’ depth, sand deeper than hand, no hardbottom, more mud and fine sediment, some shell hash, no fish observed.

Figure 5E: Underwater photo of Site 12 bottom conditions. Swam 360º for a few min and observed similar bottom conditions, 45’ depth, sand deeper than hand, no hardbottom, more mud and fine sediment, some shell hash, no fish

Figure 5F: Underwater photo of Site 4 bottom conditions. Swam northeast for 7 min (covered ~500’ of seafloor) and observed similar bottom conditions, 37’ depth, sand deeper than hand, no hardbottom, coarse sand, fine sediment, some shell hash, no fish

Figure 5G: Underwater photo of Site 3 bottom conditions. Swam north for 7 min (covered ~500’ of seafloor) and observed similar bottom conditions, 38’ depth, sand deeper than hand, no hardbottom, coarse sand, fine sediment, some shell

Figure 5H: Underwater photo of Site 6 bottom conditions. Drifted east for 7 min (covered ~500’ of seafloor) and observed similar bottom conditions, 40’ depth, sand deeper than hand, no hardbottom, coarse sand, fine sediment, some shell

Figure 5I: Underwater photo of Site 9 bottom conditions. Drifted east for 7 min (covered ~500’ of seafloor) and observed similar bottom conditions, 45’ depth, sand deeper than hand, no hardbottom, fine sediment, some mud, no fish

Figure 5J: Underwater photo of Site 11 bottom conditions. Drifted east for 9 min (covered >500’ of seafloor) and observed similar bottom conditions, 46’ depth, sand deeper than hand, no hardbottom, coarse sand, fine sediment, some mud, no fish observed.

Figure 5K: Underwater photo of Site 2 bottom conditions. Drifted east for 9 min (covered >500’ of seafloor) and observed similar bottom conditions, 45’ depth, sand deeper than hand, no hardbottom, coarse sand, fine sediment, shell hash, some fish observed.

Figure 5L: Underwater photo of Site 15 min (covered >500’ of seafloor) and observed similar bottom conditions, 56’ depth, sediment deeper than hand, no hardbottom, mostly oolitic mud and fine sediment, no fish observed.

Figure 5M: Underwater photo of Site 1 min (covered >500’ of seafloor) and observed similar bottom conditions, 48’ depth, sediment deeper than hand, no hardbottom, coarse sand, fine sediment, some mud, no fish observed.

Figure 6 - Gulfside Eight Mile Artificial Reef Benthic Surveys conducted on 04/13/2025

Figure 6: Map depicting proposed permit area (black box), corner GPS (DD) coordinates (black markers), and six benthic surveys conducted within the proposed permit area at Gulfside Eight Mile Artificial Reef site on 4/13/2025. Each dive lists the start and end survey GPS (DDM) coordinates (pink markers) as well as distance and direction of travel (pink dashed arrows). Results of the benthic surveys are below.

Figure 6A: Photo of substrate at Dive #1.

Figure 6B: Bottom track at Dive #1.

Starting (DDM) Lat (N), Lon (W)

Ending (DDM) Lat (N), Lon (W)

Boat Depth (ft)

Sediment Description Biological Resources

24°54.125' 24°54.136' 81°33.487' 81°33.216'

Dive #1 SW Corner - 4/13/2024

Very few organisms observed, sparse sea urchins, sea pens, sea stars, sand dollars, sea biscuits, no fish 100% sand

(coarse & fine)

Figure 6C. Photo of substrate at Dive #2.

Figure 6D. Bottom track at Dive #2.

Ending (DDM) Lat (N), Lon (W)

Boat Depth (ft)

Sediment Description Biological Resources

24°54.127' 24°54. 279' 81°33.236' 81°33.144'

Dive #2 SE Corner - 4/13/2024

35.6 100% sand

(coarse & fine) Very few organisms observed, sparse sea urchins, sea pens, sea stars, no fish

Figure 6E. Photo of substrate at Dive #3.

Figure 6F. Bottom track at Dive #3.

Ending (DDM) Lat (N), Lon (W)

Boat Depth (ft)

Sediment Description Biological Resources

24°54.355' 24°54.360' 81°33.235' 81°33.375'

Dive #3 NE Corner - 4/13/2024

35.4 100% sand

(coarse & fine) Very few organisms observed, sparse sea urchins, sea stars, sea biscuits, 1 remora, small sponge

Figure 6G. Photo of substrate at Dive #4.

Figure 6H. Bottom track at Dive #4.

Ending (DDM) Lat (N), Lon (W)

Boat Depth (ft)

Sediment Description Biological Resources

24°54.125' 24°54.136' 81°33.487' 81°33.216'

Dive #4 SW Corner - 4/13/2024

35.7 100% sand

(coarse & fine) Very few organisms observed, sparse sea urchins, sea pens, sea stars, sand dollars, sea biscuits, no fish

Figure 6I. Photo of substrate at Dive #5.

Figure 6J. Photo of bottom track at Dive #5.

Ending (DDM) Lat (N), Lon (W)

Boat Depth (ft)

Sediment Description Biological Resources

24°54.199' 24° 54.286' 81°33.451' 81°33.372'

Dive #5 MID 1 - 4/13/2024

35.8 100% sand

(coarse & fine) Very few organisms observed, a few sea urchins, sea pens, sea stars, sand dollars, 2 filefish

Figure 6K. Photo of substrate at Dive #6.

Figure 6L. Photo of bottom track at Dive #6.

Ending (DDM) Lat (N), Lon (W)

Boat Depth (ft)

Sediment Description Biological Resources

24°54.284' 24° 54.181' 81°33.270' 81°33.421'

Dive #6 MID 2 - 4/13/2024

100% sand

(coarse & fine) Very few organisms observed, sparse urchins, sea pens, sea stars, sand dollars, 1 filefish

Figure 7: Shrimp Trawl Closure Map

Figure 7: Red stars correlate to permitted Gulfside Ten Mile Artificial Reef (SAJ-2024-00133), proposed Gulfside Five Mile Artificial Reef (SAJ-2024-04159), proposed Gulfside Nine Mile Artificial Reef (SAJ-2024-04827), and proposed Gulfside Eight Mile Artificial Reef (this application, SAJ-2025-00696), which are all located inside the Tortugas Shrimp Beds Closed area where no commercial shrimping takes place (pink shaded region).

Figure 8: Map of Historical Shrimping Effort

Figure 8: Red stars correlate to permitted Gulfside Ten Mile Artificial Reef (SAJ-2024-00133), proposed Gulfside Five Mile Artificial Reef (SAJ-2024-04159), proposed Gulfside Nine Mile Artificial Reef (SAJ-2024-04827), and proposed Gulfside Eight Mile Artificial Reef (this application, SAJ-2025-00696), which are all located outside of the area where current shrimp trawling takes place.

Figure 9: Examples of the Types of Materials & Structures that may be Deployed at Gulfside Eight Mile Artificial Reef

Figure 9: Examples of the types of structures and materials that may be deployed to the Gulfside Artificial Reefs include natural rock/limestone boulders (A-B), prefabricated concrete tetrahedron and layered disc modules that also contain limestone rocks (C-F), clean secondary use concrete (G-H), low relief prefabricated concrete layered stand and dome modules (I-J), and 3D-printed concrete spired blocks with cavities (K-L). Providing a variety of shapes, sizes, and designs that also have a variety of cavity sizes and spaces can promote biodiversity by providing a variety of complex habitat types to various marine species including fish and benthic organisms. All materials described here are durable, long-lasting, eco-friendly within marine environments, and have been deployed as part of artificial reef or living shoreline projects elsewhere in the US.

Figure 10: Spatial Planning Considerations for Gulfside Eight Mile Artificial Reef

Figure 10: Schematic drawing showing an example of the patch reef (n=9) design proposed for the Gulfside Eight Mile Artificial Reef site. The blue stars (n=9) represent a single patch reef, and the arrows show their proposed placement relative to the proposed permit boundaries and distance to other patch reefs within the site. Each site may be composed of a mix of different structure types to offer diverse, complex habitat while ensuring the spacing and configuration of the structures does not create entrapment or entanglement issues. Each site is expected to have multiple patch reefs to provide ample quality habitat for marine life, while at the same time providing new fishing and diving opportunities and minimizing human user conflict and fishing pressure at any one patch. The minimum distance materials would be deployed from the proposed permit boundary is no less than 50 feet, but we have included a 100-foot boundary in this example to serve as a conservative approach. Less than 1 acre of total seafloor will contain artificial reef materials at this site. Within this example, each patch reef has a 100-foot diameter footprint, which could be modified to adjust to the various types of materials that may be deployed here.

[Attachment 4 – FL Bureau of Historic Preservation Coordination]

[ATTACHMENT 5 – CONSIDERATION OF SECTION 106: IMPACT]

Question 1a: Does a federal project with the potential to affect historic properties exist?

The process begins when a federal or federally-assisted project has the potential to affect historic properties, if any are present.

Question 1b: For purpose of exercise, assume yes > What historic properties are present in the APE (area of potential effect)?

Action 1: Coordinated with SHPO & FL Master Site File > Result: No Recorded Historic Properties Present > Evidence: Attachment 4 above.

Action 2: Coordinated with local expert maritime archaeologist, Dr. Corey Malcolm, and asked him to do a search of known historic properties in the wider general area of Lower Keys Gulf of America > 4 WWII-era shipwrecks from 1942, all more than 14 miles away from APE > Result: No Effect to Known Properties > Evidence: Figure 11 below.

Figure 11 | ArcGIS map of known sites of historical significance relative to proposed Gulfside Eight Mile Artificial Reef area (red marker) within the Gulf of America. The USS Sturtevant

(orange marker), Bosilika (blue marker), Edward Luckenbach (yellow marker), and Gunvor (green marker) are WWII shipwrecks from 1942 (approximate coordinates). The WWII-era wrecks north of Key West all sank because they accidentally struck mines in a minefield designed to protect against German U-boats. The nearest shipwreck (Gunvor) is more than 14 miles away from the proposed artificial reef site. Neither the shipwrecks nor proposed artificial reef area occur within the Florida Keys National Marine Sanctuary. The shipwrecks (known historical properties) are not close enough to be impacted by the deployment of artificial reef material in the proposed Gulfside 9 Mile Reef area.

Question 3a: What about potential effects on unknown/undiscovered properties?

Question 3b: What could those properties/resources be?

Assumption 1: Shipwrecks.

Assumption 2: More recent shipwrecks would be on top of the seafloor and visible by eye.

Action 3: Conduct in-water ground-truthing surveys to characterize appropriate sediment for AR deployment, note biological resources present, and confirm no observation of cultural/historic resources > Result: No Archaeological, Cultural, or Historic Properties Present > Evidence: Figures 5 & 6 above.

Question 4: Does the APE have a history of significant maritime traffic?

Action 5: The subject matter expert team at BOEM examined where ships are reported to have sailed (i.e., vessel sailing logs and route maps), and therefore, where they were likely to have sunk. In so doing, 46 historic maps were collected that contained sailing route information from the 16th through 20th centuries. Four hundred eleven routes were mapped in ArcGIS, of which 358 crossed into the Gulf of America Region. This map provides a fair perspective of where ships were traveling at various points in time. The Historic Sailing Routes in the Gulf of Mexico Application allows the user to view the geo-rectified courses of ships taken over the past 400 years.

Result: No significant history of maritime traffic in APE in 17th century > Evidence:

Figure 12 below.

Result: No significant history of maritime traffic in APE in 18th century > Evidence:

Figure 13 below.

Result: Possible overlap of historic maritime traffic in 19th and 20th centuries > Evidence: Figures 14-15 below.

Figure 12 | BOEM-generated historic sailing routes and buffer zone for 17th century in the Gulf of America. Routes do not intersect proposed Gulfside 9 Mile Artificial reef area, therefore 17th century shipwrecks are unlikely in the target area. Historic Sailing Routes in the Gulf of Mexico Application | Bureau of Ocean Energy Management https://bobson.maps.arcgis.com/apps/webappviewer/index.html?id=bb6be5175fee44029c0a7a2abd9038d6 https://www.boem.gov/oil-gas-energy/mapping-and-data/map-gallery/historic-sailing-routes-gulf-mexico-application https://www.boem.gov/oil-gas-energy/mapping-and-data/map-gallery/historic-sailing-routes-gulf-mexico-application

Figure 13 | BOEM-generated historic sailing routes and buffer zone for 18th century in the Gulf of America. Routes do not intersect proposed Gulfside 9 Mile Artificial reef area, therefore 18th century shipwrecks are unlikely in the target area. Historic Sailing Routes in the Gulf of Mexico Application | Bureau of Ocean Energy Management

Figure 14 | BOEM-generated historic sailing routes for the 19th century in the Gulf of America. Routes could intersect Gulfside 9 Mile Artificial reef area, but reported cases of 19th century shipwrecks discovered during archaeology surveys (n=8) had wrecks on (not under) the seafloor. Historic Sailing Routes in the Gulf of Mexico Application | Bureau of Ocean Energy Management https://www.boem.gov/oil-gas-energy/mapping-and-data/map-gallery/historic-sailing-routes-gulf-mexico-application…