It has come to our attention that environmental site conditions in the vicinity of Midnight Pass are being impacted due to the significant increase in boating since Hurricane Milton. Prop dredging is degrading important sea grass habitat, boating activities such as: prop scars, hydrocarbon pollution, and wildlife disturbance are on the increase.

It appears that the priority in management of the Midnight Pass area by Sarasota County is to establish boat access to the Gulf of Mexico from Little Sarasota Bay, not environmental resource protection.

ManaSota-88, Inc. strongly recommends the FDEP and the Florida Fish and Wildlife Conservation Commission monitor and enforce Chapters 327 and 328 Florida Statutes regarding boating activities in the Midnight Pass area.

Since the closure of Midnight Pass in 1983, the population of Sarasota County has more than doubled from approximately 200,000 residents in 1980 to nearly 465,000 residents today. Mangrove forests, wetlands and pine flatwoods have been modified or eliminated and replaced with an urban land scape. An integral part of understanding the health of Little Sarasota Bay (LSB) must also incorporate the functions and values of the existing beach and estuarine habitats.

Establishing a stable LSB Gulf to Bay tidal connection (an unlikely outcome) will not solve the pollution problems of Little Sarasota Bay, it nearly moves the pollution to the Gulf of Mexico where unintended consequences are likely to occur. The solution to pollution is NOT dilution, the solution to pollution is elimination and reduction. Stormwater runoff is the primary cause of the pollution in LSB.

Verify that Stormwater Discharges are Being Monitored for Compliance

Sarasota County does not sample stormwater outfall discharges. Compliance monitoring, illicit discharge survey information, presumptive criteria and associated hydrologic and water quality model calibration and verification is needed.

There are hundreds of public and private stormwater outfalls discharging into Little Sarasota Bay. These outfalls discharge directly to Little Sarasota Bay with no compliance monitoring of the discharge (either storm event or periodic). A total count of public outfalls and a tally of private outfalls should be identified and monitored.

Currently the County estimates the annual pollutant loading for these outfalls by using pollutant loading models, this is insufficient in understanding the source, location and amount of pollutants going into Little Sarasota Bay.

Estimates of pollutant loading should not be based upon uncalibrated and unverified models that could be off by orders of magnitude. Specific outfall sampling is needed for calibration or verification of the historic models used to estimate pollutant loads discharging to Little Sarasota Bay.

Increased runoff for impervious surfaces and continuing urbanization of the Little Sarasota Bay watershed contribute to decrease in the Bays water quality.
Storm water runoff changes salinity patterns and increases toxic chemical transportation and sedimentation into the bay. Freshwater and intertidal wetlands have been severely altered or eliminated in the watershed of Little Sarasota Bay. Wetlands provide valuable habitat, filter pollutants, and regulate freshwater flow into the Bay.

Measurable goals and outcomes for water quality improvements for Little Sarasota Bay and the Little Sarasota Bay watersheds include but are not limited to:

- Verification that stormwater discharges are being monitored for compliance

- Specific outfall sampling

- A temporal or spatial correlation regarding stormwater discharge and seagrass die-off or water quality degradation

- Identification of Illicit discharges into Sarasota Countys stormwater conveyance systems in the Little Sarasota Bay watershed

- Sampling and analyzed of the sediments of Little Sarasota Bay and its tributaries in the proximity of stormwater outfalls

- Enhancement and restoration of wetlands that have been previously altered or eliminated in the creeks and waterways of Little Sarasota Bay.

Increased enforcement of boating regulations and a decrease in boat-related pollutants

Sea grass beds have been severely impacted by personal watercraft, powerboats and motorboats in the shallow waters of Little Sarasota Bay and the Midnight Pass area. A significant number of recreational boats are brought into Little Sarasota Bay by seasonal visitors each year.

Measurable goals and outcomes for water quality improvements for Little Sarasota Bay and the Little Sarasota Bay watershed include but are not limited to:

- Restriction of motorized watercraft in sea grass areas and repair areas of disturbed bay bottom

- Elimination or reduction of the adverse cumulative impacts, as well as secondary impacts from boating activities such as: prop scars, hydrocarbon pollution, boat paints, and wildlife disturbance

- Increased Marine patrol and law enforcement in problem areas

- Elimination or reduction of boat-related contaminants adding noxious amounts of undissolved oils and greases to the waters

- Elimination or reduction of the negative environmental impacts associated with the seasonal increase in boats.

Reduce or Eliminate Pollution from Septic Tanks

Septic tanks can discharge residual nitrogen, phosphorus, and other pollutants into adjacent waterways. Most soils located in the Little Sarasota Bay watershed is rated severe by the Natural Resource Conservation Service and are not appropriate for septic tanks.

Measurable goals and outcomes for water quality improvements for Little Sarasota Bay and the Little Sarasota Bay watershed include but are not limited to:

- Eliminate septic tanks in the Little Sarasota Bay watershed.

Restore the Jim Neville Preserve

Measurable goals and outcomes for water quality improvements for Little Sarasota Bay and the Little Sarasota Bay watershed include but are not limited to:

- Upland restoration, marsh and mangrove creation, and tidal lagoon restoration of the 35-acre preserve owned by Sarasota County

- Native habitat enhancement of the Jim Neville Preserve.

- Control Invasive Plants

- The proliferation of Australian Pine trees and other invasive, non-native plants within the Little Sarasota Bay watershed threatens the overall environmental integrity and health of the Bay. Changes in the diversity and abundance of native species can affect water quality in a negative manner.

- Eradication of Australian Pines and other invasive, non-native plants.

Ecological Management of the Former Midnight Pass Area

A productive community including mature mangroves, nesting least terns, and loggerhead sea turtle nests, currently exists or has existed within the proximity of the Midnight Pass area. The habitat value of the Midnight Pass location provides for a variety of important fish species. Midnight Pass is a rich haven for young fish. Due to past development within the Little Sarasota Bay watershed, such fisheries are in short supply.

The beach at the Midnight Pass area is a nesting habitat for threatened loggerhead sea turtles, and numerous species of wading birds that frequent the grassy flats of Little Sarasota Bay.

Measurable goals and outcomes for water quality improvements for Little Sarasota Bay and the Little Sarasota Bay watershed include but are not limited to:

- Protection and enhancement of the habitat values for threatened, rare and endangered species found at the former Midnight Pass area

- Protection and enhancement of the nursery habitat now enjoyed by the fish community currently within Little Sarasota Bay

- Protection and enhancement of the productive Little Sarasota Bay estuarine system.

Maintain Existing Mangrove Trees and Increase Mangrove Tree Acreage in the Little Sarasota Bay Watershed

Mangroves are critical to the formation of estuarine marine food chains, shoreline protection and stabilization, wildlife nurseries, and the natural filtering process of water. Mangrove cutting and trimming result in deleterious ecological effects, these effects include the reduction in standing leaf crop, net primary production export, flower and propagule production and reduced fauna habitat utilization.

Mangrove root systems filter nitrates, phosphates and other pollutants from the water, improving the water quality.

Measurable goals and outcomes for water quality improvements for Little Sarasota Bay and the Little Sarasota Bay watershed include but are not limited to:

- Enforcement of existing regulation on the trimming and cutting of mangroves

- Maintaining existing mangrove trees and increase mangrove tree acreage in the Little Sarasota Bay Watershed.

Protect Existing Sea Turtle Nesting Habitat and Increase Sea Turtle Hatchling Numbers

Mote Marines Sea Turtle Conservation and Research Program has documented sea turtle activities and the status of shoreline habitat since 1982.

Measurable goals and outcomes for water quality improvements for Little Sarasota Bay and the Little Sarasota Bay watershed include but are not limited to:

- Maintaining the existing sea turtle nesting habitat

- Increase the number of sea turtle nests in the vicinity of the Midnight Pass area

- Elimination or reduction of the adverse impacts on the nesting habitat of sea turtles.

Protect Wading & Shore Bird Species Habitat and Increase the Number of Wading Birds

Measurable goals and outcomes for water quality improvements for Little Sarasota Bay and the Little Sarasota Bay watershed include but are not limited to:

- Maintain and increase wading and shore bird feeding habitat acreage

- Maintain and increase grassy flats, shallow tidal flats and mud flats acreage that are frequented by the numerous species of wading birds

- Maintain and increase the number of wading birds and different species of wading birds.

Protect and Enhance Juvenile Fish Nurseries

Measurable goals and outcomes for water quality improvements for Little Sarasota Bay and the Little Sarasota Bay watershed include but are not limited to:

- Protect and enhance the nursery habitat now enjoyed by the fish community currently within the Little Sarasota Bay

- Protect and enhance spawning areas for estuarine dependent fish species.

Meet the Public Interest Criteria for Any Project in the LSB Outstanding Florida Water

Any project located within the Outstanding Florida Water of LSB must clearly be in the public interest. Section 403.918(2), Florida Statutes, sets forth the criteria which must be balanced to determine if a project is clearly in the public interest.

Little Sarasota Bay and the Gulf of Mexico are Class III Waters. Little Sarasota Bay was designated an Outstanding Florida Water (OFW) on April 29, 1986.

Any project proposed must not cause or contribute to violations of water quality standards or lower the ambient water quality within the OFW. Secondary impacts of the project, and cumulative impacts must not result in violations of water quality standards.

Measurable goals and outcomes for water quality improvements for Little Sarasota Bay and the Little Sarasota Bay watershed include but are not limited to:

- Meet the Public Interest Criteria of Section 403.918(2), Florida Statutes for any project in Little Sarasota Bay.

Increase Protection for Manatees

The Midnight Pass area is critical habitat for the endangered West Indian Manatee.

Measurable goals and outcomes for water quality improvements for Little Sarasota Bay and the Little Sarasota Bay watershed include but are not limited to:

- Reduce Manatee / Boat collisions Ensure sufficient abundance and distribution of seagrasses and freshwater vegetation to support manatee population

- Coordination Manatee Protection Activities with Law Enforcement

- Reduce seagrass scarring.