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Item O03 BOARD OF COUNTY COMMISSIONERS AGENDA ITEM SUMMARY Meeting Date: December 17. 2003 Division: BOCC Bulk Item: Yes No --X- Department: DISTRICT 5 AGENDA ITEM WORDING: Discussion of Monroe County requesting a letter from the National Marine Fisheries Service to designate Monroe County as the primary respondent for marine mammals in distress in the Florida Keys and further to consider Monroe County to transfer and designate this responsibility to Marine Mammal Conservancy (MMC). ITEM BACKGROUND: Since 1988 members ofMMC have and will continue to provide at no cost to Monroe County: Leadership n rescue, rehabilitation and release of marine mammals in distress. Nearly $300.000 worth of donated equipment, property and infrastructure necessary for long- term care Education, public relations and research afforded by the best rescue/release record in the country (31 of 59 dolphins/whales rescued and release). PREVIOUS RELEVANT BOCC ACTION: CONTRACT/AGREEMENT CHANGES: STAFF RECOMMENDATIONS: TOTAL COST: BUDGETED: Yes No COST TO COUNTY: SOURCE OF FUNDS: REVENUE PRODUCING: Yes No AMOUNTPERMONTH_ Year APPROVED BY: County Atty _ OMBlPurchasing _ Risk Management_ DIVISION DIRECTOR APPROVAL: ~ C ~ MAY . URRAYE.NELSON DOCUMENTATION: Included x To Follow_ Not Required_ DISPOSITION: AGENDA ITEM #05 Revised 1/03 l~/~l/~~~j 14:~~ j~tl~~tlb/~tl C~lKI::.YSI::.A~CH f-JAt:it. ~Il ~lItIfl:jlltJe'l'WII'\'l~...._- ._..._~em."""..".. M__"~"::~~ _.. INTEROFFICE MEMORANDUM ","",I~...:r.n.."":"'_-.:_"::':'::..",:,:,:,:",_-_":,,_-...,,=--_":..~_~__-::.,,=,,_-=-=:-____..::"____..:\,::,,_,,,::-,.., .II"...:.""I':or:r.,':''''_"'____.___. ~.__..._.:.~~\"...~':.&f~,";';T=:':':~__:_=._':.-_"';"_"':;.:_":'.-==:':..'":.:C ,..~:~.., ":.,',~. ~.-:"':...'!;.'::!"~\~ '. TO: MA YOR MURRAY NELSON IN ell RR 0[0' DONNi\ FROM: RICK TRou'r, MARINE M M'JMAJ, CONS.l:illVANCY SUBJECt: AGEN])A WORDING FOR 12/17/03 DATE: 12/2/2003 Request designation of Msrine Mammal ConsetVancy a.s Monroe County'!; pdmary respondex for dolphins and whales in disUess. Request lette.t to National Marine Fisheries Service to improve Montoe County rescue progt:am by fottnally designating Marine Manunal Conservancy as ptUnau:y lE:$ponder in Monroc County. BllCkgtound: Since 1988 tnembers of MMC have and will continue to provide at no COgt (Q Monroe (:ounfJr. Lea.dersbip in rescue, rehabilitation and release of marine manttnals in disttc 55. Nearly $300,000 worth of donated equipttJ.ent, property, and intt:\sttucbi1:'C tlCCessary for long-tenn ca.re. Education, public relations an.d tesea1;Ch 'fforded by the best rescue/release record in the country (31 of 59 dolphina/whales rescued an.d relea.scd). These su.ccess stones could be even mot'c historic with i1nproved support fr J:tIJ National Marine Fisheries Service. We request and call for the BOCC to acknowledge, endorse, and designate Marine Mamttlal C~nset:Vancy as the best pO$sibL~ solution t j achieve itnpt"ovcd marine mammaltescuc:: response in MOOJ:oe: County. Thank: you in a.dva.ncc for yout serious consideration.. Rick Trout, V olunteer/YP'/Director of HusbandJ:y Marine Ma.mrnsJ Conse.tv1l1cy 305-853-0675, 305-522~0534 .' ./~ . .' . . ~ C.__..J'-.~.., -.'" " tr 3058530675 M..*C IMMEDIATE RELEASE OR EDITORIAL PAGE Nov. 12,2003 Dolp,",ins: Dead or Alive ltem: Sept. 2000 Myrtle Beach SC - Mother and calf PYgmy sperm stranded Ofl beach. City wor\{er5 load both. stilt alive, into front end loader and onto a f1et bed truck deStined for city dumP. Item: Sept 2001 Kev west FL - do1phln strands and is trucked to city dump bec8uselocal responder does not respond. Item: 1999 Los Angeles and Orange County California - Local bead'! communities move to avoid such publiC relation ntghtrneres by wri'Litlg a single letter to National Marine Fisheries Service deSigneling the votunteers of the Whale Rescue Team as responderS to marine mammals in distresS ins&de county lines since no federal agency or capttve dolphin facirdy can or wiH respond. South Cardina is in the ..me region as the Keys and is overseen by feden:1I stranding CXJOrCIinators in offices in Miami. St. Pete FL. and SilVer Spring, 11.40 of the National Marine Fisheries Service. NMFS is a taxPayer supported divisiOn of the Department of Commerce. NMFS' coordinators have beftn monkey wrenching one the countrYs most successful marine mammal rescue teamS while doing litUe to coordinate improved rescue response in other parts of tl,e region or country. If you need any more realOn to memorialize the young pilot whalEI whose ch8l"109 for survival was taken ffWSY by NMFS' intet18rence In the recenl: Big Pine Key pilot whale rescue, remember NMFS appro'lled the Navy's sonar weapon bOmbardment of marine mammals until scientists and lawyers sued to stop 'them after over 50 wheIe deaths. NMFS is presently entert8inin9 giving Sea WQf1d 8 5 year worldwide permit to colleCl sex organs from any dotphin. wham, seal or sea lion to enhance Sea Wond's artificial insemination project and to create a better marine mammal freak show' NMFS is an agency that caters to the greed and nonsense of businesS and mi"t~ry, not the proteetion of manne mammals. For thOse who care, please contact Monroe County Commissioners and ask: them to, Uke Los Angeles. deSignate the Marine Mammal conservancy wi1.h one of the co~ry's best recordS (31 of 59 rescued/reteased dolphinlwhales) at. this county's primary responder (at no cost to county taxpayers sim::e MMC has. can and wil. raise f\n:IS privately). If that is too much for Monroe County Commissioners to do then ask them to write our elected congressional and Senate offidals to demand that NMFS stop wasting tax dollars and start protecting marine mammals especially those who MMC can helP in MonrOl:t county and stop neglecting and destroying them elSeWhere. Memorandum Department of Marine Resources 2798 Overseas Highway, Suite 420 Marathon, Florida 33050 Voice: (305) 2892507 FAX: (305) 289 2536 Email: garrett-george:ll.nlonrOeColll1lv-ll.gm Board of Co un tv Commissioners Mayor Murray Nelson, Dist. 5 Mayor Pro Tern David Rice, Dist. 4 Commissionerr Dixie Spehar, Dist. I Commissioner George Neugent, Dist. 2 Commissioner Charles "Sonny" McCoy, Dist. 3 DATE: 17 December, 2003 TO: Monroe County Board of Commissioners FROM: George Garrett, DireGtor of Marine Resources SUBJECT: Discussion of December BOCC Agenda item 03, Request to designate Monroe County as the primary respondent for marine mammals stranded in the Florida Keys A Board member of the Marine Mammal Conservancy has requested that the Board of County Commissioners write a letter to NOAA, National Marine Fisheries Service (NMFS) seeking sole responsibility for the disposition of stranded marine mammals in the Florida Keys. Similarly, it has been suggested that this responsibility be transferred to the Marine Mammal Conservancy. Staff indicates that this request represents a substantial liability for the County and recommends no action be taken on this request. Background Under the Marine Mammal Protection Act (MMP A), according to NMFS General Council, there are essentially two ways that marine mammals may be "taken" under the law; (1) through a stranding response agreement (commonly know as an LOA or Letter of Agreement) between an individual or group capable of marine mammal protection or conservation andNMFS, or (2) as part of the lawful duties undertaken by a Federal, State or local government whose logical responsibilities would include, (a) protection of the mammal for its own welfare; (b) protection of the public health and welfare; or BC0312 Staff Response OJ.doc 12/17/038:08 AM Q] The first approach can be visualized as a permit to "take" manne mammals authorized by NMFS to a subordinate entity. The second approach can be visualized as another governmental agency (Federal, State, or local) retaining a parallel and co-equal authority to manage marine mammals for the purposes stated above. The essential difference between the approaches to "taking" marine mammals under the MMP A is the level of authority relative to NMFS. Analysis Should the Board of County Commissioners elect to exercise authority for the protection of marine mammals, several issues must be considered. Whether as a subordinate to NMFS or as a co-equal with NMFS in the protection and conservation of marine mammals, NMFS retains ultimate authority and responsibility for these animals. Thus, if the County chose to acquire a "take" permit from NMFS (an LOA), NMFS would clearly define the terms for that LOA. On the other hand, if the County chose to exercise authority that it arguably has to protect and conserve marine mammals under its own authority and jurisdiction, NMFS would still play a role in how that new County responsibility would be carried out. As NMFS would retain authority and responsibility in the area, they as the principal agency responsible for the protection and conservation of marine mammals, would be obligated to coordinate their activities with those of the County. In their estimation, this would involve the development of a Memorandum of Agreement (MOA) spelling out the individual agency responsibilities. Thus in the same way that permit conditions would be spelled out in an LOA, they would be similarly spelled out in aMOA. The only conclusion that one can have is that NMFS would retain control of marine mammal protection and conservation in the Florida Keys, contrary to the concept contemplated in the MMC request to the Commission. In either case noted above, the County would become responsible for most if not all aspects of the requirements and process involved in the protection and conservation of marine mammals in the Florida Keys. Although this responsibility could be delegated, it would not be diminished in the County. As a permit holder, the County would have to be responsive toNMFS. As a co-equal authority to that of NMFS, the County would be obligated to meet the intent and direction of the Marine Mammal Protection Act, asNMFS is now. 2 The Marine Mammal Conservancy indicates that there would be no cost to the County once the authority was delegated toMMC. In large part this might be true, but it should be underscored that the County would become the responsible authority as opposed to the forum for discussion about marine mammal issues. In simple terms, the County would be responsible. At a minimum this would involve some staff time to oversee the County's interests in this authority. In more consequential terms, after the release of the pilot whales from Big Pine Key earlier this summer, it was NMFS that bore the cost of tracking the animals. This required a substantial expense. Then there is the simple politics of being involved in the marine mammal protection and conservation business in Monroe County. The Commission has heard this issue on numerous occasions and the Florida Keys National Marine Sanctuary Advisory Council (FKNMS SAC) has heard it and taken a position on a similar number of occasions. The FKNMS SAC has recommended that three LOAs exist in Monroe County (for the lower, middle, and upper Keys). The NMFS has currently issued two LOAs. They do not plan to reduce the number of LOAs at this time. The immediate consequences of fulfilling the MMC request would be to eliminate one LOA, currently held by Becky Arnold. The second immediate consequence of taking his action would be to become the legally responsible arbiter of any issue related to the protection and conservation of marine mammals in Monroe County. This is a much more consequential position than the one currently held by the Commission, that of a friendly ear and forum for discussion. The third consequence of an action to accept an LOA or to become the authority in Monroe County, would be to accept absolute liability for any actions under that authority and responsibility and to potentially accept substantial costs as well. Though the volunteer groups currently involved in marine mammal protection do a laudable job in their trade, we again currently view that effort holding absolutely no responsibility for any outcome. However, as other recent activities within our responsibilities have shown, it does not pay to relinquish responsibility in the face of delegated authority. In the recent past, we have seen requests for marine mammal facilities. Would the responsibility for such a facility increase if the County assumed authority? Would we need multiple facilities in each area of the Keys? Then there would be other attendant responsibilities if for any reason, MMC could not fulfill its obligations 3 under a delegated responsibility; funding for equipment and vessels, finding and retaining volunteers, maintaining available qualified staff able to handle a stranding event, and funding such efforts as tracking animals once released. If the responsibility for a stranding similar to the on that occurred with the pilot whales last spring and early summer fell solely to the County, would we currently be prepared to handle it or do we want to have to be prepared to handle it? Based on the information provided staff it appears that the potential liability of assuming the responsibility for marine mammal protection and conservation in the Keys is beyond the County's capability at this time. Recommendations Staff indicates that the request made by the Marine Mammal Conservancy to assume authority for the protection and conservation of marine mammals in the Florida Keys represents a substantial liability and beyond the County's capability at this time. Staff further recommends that no action be taken on this request. 4