Good afternoon. My name is Charles Dean, Senator District 3, State of Florida and a Citizen of Citrus County all my life. I’m here, first, as a citizen of Citrus County, and a recent member of the Water Quality of Crystal River that’s organized for the fixing of our water quality in Kings Bay. I would like to encourage this committee of folks from the Federal level to, please, join us in the water quality. I was involved in the Three Sisters purchase, getting some funding from the State of Florida. Little did I ever think that this joint public, Federal public, State of Florida, Citrus County Commission, City of Crystal River and private public funds would ever end up in what appears to be, now, an extension of over restriction of regulations in Kings Bay? The cooperative venture, instead of more regulations, takes over public waterways at taxpayers’ expense — and then they fund everything in this thing, and I remind you of that — what do they get in return? They get more regulations, more restrictions, less privilege for property ownership and usage. And then we have more rules and regulations to protect — and less and less, what do we do for property rights and property owners or watercraft owners and those guarantees to those people that come to Citrus County and help us support our community. I was looking at the take issue we have. Are we really at a point that a take issue is so bad, as we need to over restrict or either shut down public waterways, and, in particular, the public waterway of Kings Bay, that we’re all familiar with and used all of our life. And we’re not saying there’s not a reasonable solution to protect manatees. I’ve heard no one say that yet, and I don’t know of anyone in our community or our County that is not trying to protect the manatees. I think your reports show that. But at the same time, I’ll ask another question, of anything such as State rights that are being considered now, or is it all Federal rights? And if that be the case, I want to know what State agencies — and you don’t have to do it now, but later — provide the information and the input that they had or solicited for these rules and regulations. We have a way to getting to an issue here. We have a way to resolve it, but it takes common sense. And it takes a lot of giving instead of a lot of getting. And I would hope that in your pursuant of what you’re trying to do here, in the regulation and rule process, that you give consideration, again, to everybody that has a right to use the water. And we do respect the use of the water for the manatee. At the same time, the citizens have a right, too. Thank you very much.
Hello. I’m State Representative Jimmy T. Smith, District 43. I’ve lived in Citrus County for a very long time, and I hope to raise my daughter in Citrus County. One of the reasons for that is because our county, in this great state, does a wonderful job of balancing, properly, our environment and our economy. If you look at Citrus County, specifically, look at what we did with the Three Sisters. It was us that lead the way. It was not the Federal government. We understand the need to protect our manatees. We also understand the balance that’s required to make sure our community can benefit from ecotourism. This ecotourism gives us the dollars we need, once again, to handle protecting the manatee. If you take and implement more Federal intrusion into this, what you’re doing is taking our local government that has been, absolutely, leading the way on this issue, out of it. Why stop success? What is it about success that the Federal government thinks they’re going to improve upon? We don’t have the tax dollars, locally, how are we going to implement law enforcement to protect the manatees? How are we going to do the things needed? So we’re asking that you hold off on implementation of this. Do more studies; go back and review the facts. Come up with hard specific numbers. Work with, specifically, the leaders of the community, our agencies within the state and make sure that balance that we here, in Citrus County, have implemented, continues. This could possibly be your example for the entire state of Florida, on how to, properly, ensure the growth of manatees and the growth of our own economy. If you do that, what you’ll end up, long term, is a populace that is happy, and a manatee population that is protected.
First, I want to thank the Board for allowing us to speak this evening. It is with disappointment that I’m here to speak to Federal officials that have chosen to propose to establishing new rules, in one of the most popular water bodies in our county. And, apparently, it was done with minimal discussion relating to the rule crafting.
I wish to speak to the public safety portion of this. The elimination of the summer sports zone in Kings Bay, if adopted as proposed, those desiring to recreate in high-speed water sports, such as water skiing or personal water craft, will need to leave the area or shift to the Crystal River main channel. Those are unacceptable and unsafe conditions. The extensive boating and recreational activities that take place in the main river present significant risk to high-speed recreation use. The main channel of Crystal River sees extensive boat traffic, to and from the Gulf and the Bay. Major marine and boat ramps, directly access the channel. It attracts fishermen, travelers, ecotourism, and many residential properties, line its shore. If you spoke with our local marine enforcement staff, Coast Guard, and our local Sheriff’s office, water based staff, they will tell you that they discourage those activities in the main river. I would, also, like to point out that the manatees which feed on our coastal grass, must navigate the same waterway to reach Kings Bay, further complicating an already congested waterway. I would show or say that your own documentation on the graphs around the room, indicate that in 1979 there were only slightly more than 6,000 registered watercraft in Citrus County, and the population of the manatee was slightly less that a hundred — now, in this year, we have over 17,000 registered watercraft and between five and 600 manatees. Obviously, we have been doing something right. And so this is why I predict that a shift of high-speed activity from Kings Bay sports zone to the main channel will not result in reduction on manatee watercraft mortality and may result in human injury or death, which concerns us, greatly. Based on the unprecedented success of manatee survival in our county, we think we have been going a good job. This proposed change we think is unnecessary and needs to be abandoned. We appreciate your time and consideration, and thank you, again, for allowing us to speak.
Thank you, sir. Good evening. My name is Joe Meek, and I’m a Citrus County Commissioner and president of the economic development council in this community. First and foremost, I want to thank you all for allowing us to come this evening, and thank you for being here. I am a life-long resident of Citrus County, born and raised, literally, on the Crystal River. And as was mentioned, earlier, by the other Commissioners, we will be submitting a formal white paper, with regards to factual data and points that counter to the proposed new rule, by the deadline, but I’d like to speak this evening from a personal standpoint. As I mentioned I was born and raised here. I was raised on the Crystal River and, actually, lived on a place called Christmas Island, the only island on the Crystal River with a full house on it. Lived there for seven years of my life. I’m extremely familiar with the river, I’m familiar with the issues that are before the river and, unfortunately, the shape the river is in, right now. And it’s my opinion that it is vitally important that a recreational component be maintained in Crystal River, for a whole host of different reasons. Number one, from a youth and family standpoint, in a society where family, good wholesome family fun is declining. Water sports and water sports activities are an excellent way for families to join together. And a recreational component on the Kings Bay has enabled families to do that for years and years. And so for families and young children and for people that enjoy the bay, it’s important that they’re able to do that. Secondly, and more important than that, and Commissioner Webb hit on that, is the safety issue. What this proposed rule does is endanger the lives of the children and the families and the individuals that are using the Bay for recreational activities. And it does that by concentrating those activities in a narrowed channel with marked channels. You don’t need a feasibility study to tell you. All you need to do is go out there and look at it. We’re putting children on water — that are water skiing, that are tubing that are on watercraft, in a small, narrow channel, with large fishing and shrimp boats, and other activities at a high rate of speed. And it’s going to cause a problem, and it’s going to be dangerous. And so it’s important that a balance is struck between the two. Like I said, I’ve had my fondest memories involving the unique recreational component that has been available in Kings Bay. I’m now raising two small boys, a two- and a four-year-old, and I’ve begun to introduce them to the same wonders that I have had as a child. The quality of life is why I choose to raise my family here, and why a lot of people choose to live here. And a vision statement was adopted by Citrus County in 1995 by a group of citizens that came together. And it said that “Citrus County will become a place where nature and man live in harmony, where man and manatee play.” That’s our motto here, and we’ve done a good job sticking to that, as evidenced, again, by the fact that we’ve gone from less than 100 manatees years ago to close to 600 manatees. We’ve worked very closely with you all as a Federal and a State government to make sure that manatees are protected. There’s no bigger advocate than County government and City government. And so balance is vital. This rule does not provide balance, and balance is achieved through open communication between all stakeholders I commend you all for hosting this event, but I must note that we are here addressing a proposed rule that was drafted in Jacksonville, reviewed in Atlanta, authorized for publishing in Washington, D.C., and now we are here to seek — or you are here to seek our input. It would have been more efficient and effective if you had worked with us from the beginning, and that’s what we’re going to ask for you to do. Let me close with this final observation. I firmly believe that you will be able to achieve the goal of reducing manatee mortality providing the resources and personnel necessary to enforce the rules in place, right now. Expanding rules without the means to back them up is an exercise in futility. Thank you very much and have a good evening.
Good evening. My name is J.J. Kenney. I’m a proud Veteran of the United States Marine Corps, and I also had the pleasure to serve the people in Citrus County as Commissioner in District 2. Both of these positions are going to be my excuse for anything I may say tonight to offend you. I am aware that I’m supposed to focus on facts and not let emotions into this hearing. Sorry, but I’m going to disappoint you. Our country was built upon a foundation of democracy and the retention and protection of our personal freedoms. Grant it, in any modern civil society, there must be rules to advance the greater good of the community. Gentlemen, this is not one of them. Your rule proposes to change a negotiated plan that has successfully served its intentional purpose for over 20 years. There are more manatees in Citrus County waters now than there ever have been. Despite the increase in numbers, the mortality rate for manatees, from watercraft impact, has been kept in single digits since 1990. This community has adopted the manatee as a favorite child from the beginning and we have made significant concessions to advance its recovery. Your own agency points to us when you reach out to other Florida counties to do more to protect the manatee. But, apparently, you still want more, and the sad thing is we are probably perilous to do anything. That’s not what I wore the uniform for, and that’s not what I’m serving my community for now. I ask that you do the right thing. Table this rule. Invite us, City officials; let’s get over a cup of coffee. I’ll bring the doughnuts. Let’s work together to find an acceptable solution. We’re on the same side. This isn’t about manatees. This is about public service to our consituents. Let’s take the time, and let’s do it right.
Thank you very much. My name is Dennis Damato. As chairman of the Citrus County Board of County Commissioners, and the Commissioner representing District 1, which includes Kings Bay and Crystal River, I would like to thank you for hosting this public meeting, to allow our citizens to comment on this proposed rule. First, I would like to point out that Citrus County has been at the forefront for manatee protection, and that position has not changed. We have made many sacrifices in the interest of manatee protection and these are clearly documented within our manatee protection plan; the first adopted, in the state of Florida, and still use as a template for other plans. Our manatee protection plan was a thoroughly negotiated process, including local stakeholders, Federal and State agencies, representatives, and environmental interests. The final product went through an extended public hearing process, and, concurrently, the State utilized a similar process to adopt manatee speed zone regulations for all of our coastal waters. This included the establishment of the summer sports zone in Kings Bay. To, unilaterally, eliminate it by Federal mandate is counter to the cooperative efforts that led to our manatee protection plan and speed zones. On June 28th, the Board of County Commissioners, unanimously, adopted a resolution, regarding your proposed rule. It has a single focus, and I wish to read it into the record. “The Board formally requests the USFWS reconsider and postpone establishment of the Kings Bay as a manatee refuge, by Federal rule, and work in a cooperative partnership with local governments and the State, in seeking long-term solution to manatee protection, utilizing mobile data, sound science and increased enforcement of the existing regulations in place.” That concludes my comments tonight. Citrus County will file a more comprehensive written white paper position on this issue by your August 22nd deadline. It is my understanding that my fellow commissioners will also provide comments for tonight’s record, specific to focused issues regarding the proposed rule. Thank you, again, for allowing me the opportunity to speak.
I’m Citrus County’s operational project — my last name is spelled M-a-i-d-h-o-f. I’ll be running point on, preparing the County’s white paper, and there’s a lot of data that I will not go into tonight. But I do think it’s important to share some of the specific manatee numbers, to put this in perspective for some of the people that are attending. Aerial survey, which is a major component of determining the manatee population in Florida, it’s done in the winter typically when they come to warm-water refuge. Started in 1991, the aerial survey on that date for the entire state was 1,470 animals. The aerial data for the west coast was 650. Let’s jump to 2011, this year. 4,834 total in the state of Florida; 2,432 on the west coast; 646 of those animals were in Citrus County waters. 566 of them occurred in Kings Bay. That means the number of manatees occurring in Kings Bay is just slightly below the number of animals that were counted, total, on the west coast in 1991, a 10-year period. Now, let’s speak to watercraft mortality data, that goes back. Florida Fish and Wildlife maintains and break things out. In 1990 in the state, there were 206 manatees killed. 47 of them were by watercraft; one of them occurred in Citrus County. The highest County that year was Brevard, at seven. Now, jumping up ahead, admittedly, 2008 was a bad year for Citrus County, eight. That’s the most we’ve ever had. There were 90 total in the state, 337 total manatees died. Lee County led, once again, 14. I would point out over that 20-year period, the two counties that consistently come up with the most manatee deaths is Lee County and Brevard County. At no time has Citrus County ever had any watercraft-related deaths that exceed eight, and the typical number has been three or less. The question becomes, At what point does overregulation come into play? And we’re going to try to make that argument. There needs to be a balance here, and I think we’ve made many sacrifices that provide long-term assurance. Our manatee protection plan says we will not be building any more marinas, putting in any more boat ramps on any of our coastal rivers. That’s established in our Manatee Protection Plan. The number of vessels that we can get on our water bodies is limited by the number of homes, and what we can accommodate in our existing boat ramps. I think we’re doing a good job, and I do think that component of this rule needs to be revisited. I’ll re-emphasize what my commissioners said, what you heard from the City Council folks, and what my administrator has said. We would like to work with you, in revising this rule and taking the input you hear tonight, in crafting something that this community can support. Thank you.
I am the Director of Public Works for Citrus County. I’m not a Commissioner, for the record, but, currently, I’m also serving as the enacting County Administrator as Brad Thorpe, our administrator, is taking a long overdue vacation. He’s down south, enjoying himself. This is his first vacation in a while. As originally noted by my chairman, Citrus County will file formal comments complete with supporting backup regarding the proposed rule, prior to your August 22nd deadline. It will expand on many of the issues already raised here tonight by our Chairman, and one of our Commissioners and several other Commissioners that will speak. What I would like to do tonight is to formally extend an invite to the Service to meet with County staff and City staff, and whoever else we deem appropriate, to see if we can work through the concerns that are going to be raised here tonight, to see if we can achieve a majority support within our community. This is something, I think, would be a lot better off if we could do it in an informal setting, sitting around a table and get all the stakeholders together and work with it. If desired, we can facilitate attendance by the City staff, Chamber, representatives, local environmental groups, and whoever we deem it necessary, or any other stakeholders who wish to attend. Many of your staff are very familiar with my staff and County staff. We have a very good working relationship, and we would extend that for this process. We have a sound working relationship. Please, call on us and take advantage of the offer. Thank you very much, and here’s my Public Works Director card.
Thank you. I’m Josh Wooten, President and CEO of the Citrus County Chamber of Commerce, and I’d like to start out — as we, the Chamber, does to everybody — and welcome you here to our beautiful county. We’re the gem of the Nature Coast, and I hope since this meeting is running late, you’ll enjoy one of our fine hotels and restaurant establishments.I hope you have a big, fat Federal expense account. The signs that you’ve put up — I’m sitting here, as the leader of the largest business advocacy group in Citrus County, and I was thinking to myself, If I was a CEO or you were the board of directors for a company, and you said, Citrus County was your employers, and your job was to protect the manatees and you look at these statistics, I would think that you would say that we’ve done a tremendous job. In fact, you said they — at the Crystal River City Council meeting, that this is not a result of Citrus County doing anything wrong. It’s been touched on that we were the first county, in the state of Florida, that adopted the manatee protection plan. And Mr. Maidhof rightly pointed out that that came with some sacrifices; installation of new boat ramps, marinas, and boat slips. That had an economic impact, but we wrote the plan, we adopted it, and it’s a way of life here. We have a very good working relationship with your local office of U.S. Fish and Wildlife; not so much with you guys, yet, but we’ll see how that turns out. Some of the things that — you’ve asked for non-emotional fact base stuff, and the Chamber will get you some stuff, before October 22nd (sic), but there’s one group that is for this rule, that is sending out something that says “Needed protections from high-speed killing field hanging in the balance.” And they’re sending this, I guess, to all of their members all over the country. And that’s an insult to those of us in Citrus County, who take protection of manatees so seriously. In fact, using the term “killing fields,” that term is used about the extinction — extinct — I’m not getting that word out — extermination of 1.4 million Cambodians. So I don’t believe that that’s a rationale argument. I think that’s an emotional argument that you would equate losing a couple of manatees, over a several-year period, to the killing fields. And so that just tells me that they don’t give a damn about Citrus County’s economy, they don’t give a damn about the citizens that live here, and they don’t give a damn, if we have a right to ulitize that waterway So here are some facts: It’s easy to say that it’s not your business that it’s being impacted or your home, or your recreational pastimes, regardless, you wanted the facts and here are some. Under the Regulatory Flexibility Act, you as the USFWS must prepare and make available an analysis that describes the effect of the rule in small businesses, organizations, and government. Your response has been lacking, and I think you’ve heard that over and over, again, today. We’re hearing from many of our members that the impact is unknown, if you’re a jetski dealer or you’re a tour operator, or as Commissioner Meek said, you want to just do something, as good as teach your young sons how to water ski on the Bay, that you were raised on. So I would hope that you-all would not adopt this rule, that you would look at our stellar record for manatee protection, and trust us, as a community, to continue in a fashion that we are now. Thank you very much.
MAYOR JIM FARLEY
Good evening. My name is Jim Farley, F-a-r-l-e-y. I’m the Mayor of Crystal River. The new rules proposed by the U.S. Fish and Wildlife Service has the potential for significant economic damage to the City of Crystal River. It’s a glaring example of staff work that’s lacking in detail. As Mayor and former Police Chief, I can tell you I would never accept a proposal so lacking in important data. For example, in the pages dealing with the supposed economic impact, the terms “unknown” and “not enough data” are used repeatedly. A few examples, Page 36502 is speaking of fishing recreationists. It says, “A number of these recreationists and the number of trips they make is unknown. As a result, the economic cost of this rulemaking on these individuals is unknown.” Page 36503, speaking of commercial fishing and crabbing. “The number of fishing boats operating, in the amount of blue crab and mullet landings occurring in the areas, that would be newly designated speed zones under this proposed rule are unknown. Given this, the impact on the commercial fishing industry cannot by quantified.” It goes on and on. The State is referring to the (unintelligible) lack of information, yet, also on Page 36503, they hasten to assure us “Given available information, the economic impact of designating this manatee refuge is not expected to be significant; that is, it would not exceed $100 million a year.” In the bloated Federal budget, $100 million a year might not be significant, but in Crystal River, it could be $100 million. Even more disturbing, on Page 36500, it states, “We are proposing the taking of one or more manatees by managing human activities in this area. The refuge would incorporate an existing network of manatee sanctuaries. Affected waterborne activities would include swimming, diving, including skin and scuba diving, snorkeling, water skiing, surfing, including wind surfing, fishing, and the use of watercraft other vessels.” This language could be construed and used to shut down, at some point, all of human activities on our waterways. This document is so sweeping in scope in micromanagement of people, that it can’t truly be called a rule. It would be more properly described as legislation. In Article 1, Section 1, of the United States Constitution states that “all legislative powers are vested in Congress, which consists of a Senate and a House of representatives.” There is no mention of an agency.
This document — this document is flawed on so many levels, that I urge you to scrap it and start over. And this time, get the critical data and make all the unknowns known. Thank you.
Thank you. My name is Ron Kitchen. I’m vice-mayor and member of the City Council of the City of Crystal River. I appreciate the opportunity to be here tonight, and on June 27th, the City of Crystal River held a special council meeting. One of the main issues was to discuss the topic of the proposed plan. We, at that meeting, passed unanimously, a resolution, 11-R-22, that I will give to you tonight. I’m not going to read it. (Tenders to Dave Hankla.) Basically, it covers some of the points that have been discussed tonight. What I’d like to say into the record, though, is the City believes this plan is arbitrary and capricious, that there is no need for this that you — there has been no demonstrated need for this. I think the evidence that will be presented do, as well as the other agencies have said, the City of Crystal River will be presenting additional documentation to you in the future, to support our position. Much of it mirrors what you’ve heard, that is, that it seems in our community this has come down to an issue of, are you for the manatees, or are you against the Manatees? I find that totally false. Everyone in our community, that I know of, is for the manatees. It has become when is enough? What is the level of being a good steward? It’s interesting that the same people who were called — by the way, the elected officials of Crystal River are unanimous in their position on this, that we’re presenting, the basic concept is what you heard from the County. We felt we’ve worked together in the past, very successfully. We felt a great program has been created, and there’s evidence to support that. And we’d like to see that continue. We don’t like the arbitrary approach that’s been taken to say, This is what’s going to happen. We think some of that has been presented, unfortunately, perhaps, under misinformation. At our council meeting, we had a representative from Fish and wildlife say that one of the reasons you were looking at this, is Council asked you to do this, that the City of Crystal River asked you to do this. That is not correct, presented to council a recommendation that they would like to have passed on to Fish and Wildlife. At that time Council said that — agreed to send it to Fish and Wildlife for your review and recommendation. At no time did we ask this action to take place. Furthermore, in 2008 a motion was made by the City Council by the then council member to reduce the speed limit in Kings Bay, to slow speed year round, and not only did that not pass, but it did not even receive a second to have a vote taken on it. So any evidence that you have in the record to say that the City requested this is incorrect. Also, at the June 27th meeting, the statement was made that this has been cleared by the Coast Guard, that the Coast Guard had signed off on this and had no problem with it. When we asked, further, there was no evidence put into the record. So I would ask, because we all believe that there will be an accident occurring, if you force all this travel into a navigable boat channel, it should be on the record who approved that, because somebody said tonight, I have firsthand information where the Coast Guard stops people and tells them they shouldn’t be water skiing in the boat channel. So on one hand we have something that says it’s okay; and on the other hand, it’s not. So if we’re going to base this on facts and science, I think it should be on the In 2007 a subcommittee of waterfronts board1 record. Also, just again, just to leave with you that we look forward to what’s been said tonight, to work with you, to find something that’s mutually acceptable for everyone, and that we are good stewards of Crystal River. We live here. This is our home. We don’t want to destroy it. Thank you very much.
Good evening. My name is Maureen McNif and I’m a Crystal River City Council person. I’m going to apologize in advance if I’m repetitive of some of my predecessors, but I have to tell you that I feel obligated to come and represent my constituents in Crystal River, because I got a lot of input on this topic. And by and large, the large majority of input from Crystal River residents was against this proposed rulemaking. With that said, I want to suggest to you that perhaps it’s the wrong time for this. It’s the wrong time for a couple of reasons. Number one, two years ago there was a review of the manatee, in terms of its endangered species status. That review was being conducted, because it had recovered to a good point. Again, that didn’t happen, but my understanding at this point in time, is that next year, that review is coming up again. One can only assume it’s coming up, again, because the manatee population has recovered. I also want to suggest to you that it’s the wrong time, in terms of impact to the economy. You’ve heard several people, before me, talk about the impact to the economy, which to date has not been quantified by the study done by your agency. However, as several of my predecessors mentioned, both Crystal River and the County, will be providing you some data, prior to the August 22nd deadline. In addition, I think it’s the wrong time, because I didn’t see any evidence that there were alternatives researched. I believe that there are alternatives to a sweeping closure of Kings Bay for recreational activities. As Mr. Smith and Mr. Meek mentioned, I believe that there is a balance that can be achieved, and what I see in this proposed rule, does not suggest any balance whatsoever. Lastly, I just want to mention that some of the data that was provided, as a basis for the rulemaking, I don’t believe that there was any evidence that those manatees that were recovered dead, in and around the Bay and Crystal River, that there was any evidence that they were, actually, injured and their death caused within the confines of Kings Bay and Crystal River. So I have to urge you, as my predecessors and my colleagues in Crystal River and Citrus County did, to come to the table in a collaborative effort, and let’s work on something that’s workable and achieves balance. Thank you.
Good evening. My name is Mike Gudis, I’m a City Councilman for Crystal River. I’m also a past County Commissioner in Maryland, which had the largest county in Maryland. The reason I mention that is that I’ve been involved with government and citizens for 20 years, both Federal government, County and now City. And I have found, after many years of service and maybe the hard way, that the best way to get things done, when you’re talking about putting in something that affects citizens in a negative way, is to work together. Compromise to me is not a dirty word. It is something that we really, in this day and age, we should be living with. We should be working together, because we all want to protect the manatees and our citizens and provide recreational activities for our citizens. But to do it in this way presents a problem, and the problem is, is that we were not able to have any kind of 1 input, preliminarily, to you coming out with this proposed resolution. I have found in the past, that when you get citizens involved and there’s give and take and compromise is being made and people understanding better what is involved and what problems there are, there’s a much better chance of working out a sensible and realistic conclusion. I, therefore, propose that you consider having a citizen’s advisory — a citizen’s advisory committee to deal with this issue, now and for the future, so that we, as elected officials and citizens alike, have a chance to have input into your process. By doing this, I think you will find that everybody will come out ahead. Maybe not everybody agreeing on every issue, but at least having some input and feeling they’re part of the solution and not the problem. Thank you for having us here tonight.
CITY MANAGER HOUSTON
Good evening. My name is Andy Houston. I’m the City Manager in the City of Crystal River. I’d like to direct my comments to the points that are in your notes: Why this area should not be designated as a manatee refuge. The manatee population is thriving, under the current regulations. The take rate is not significantly different than in other areas within the state, and these type of regulations, there’s no evidence they’re being routinely applied throughout the state. There is some concern they’re being arbitrarily applied in this area, because we have a refuge office within Crystal River. The proposed regulation will unduly restrict recreational use of the only open water body that is readily accessible to the residents of Crystal River. You’re going to force people to either trailer to long distances, or you’re going to put them in a river that’s going to be unsafe. That’s unfair. It’s capricious. Is there any foreseeable economic impact? Yes, we think there will be. The Service quotes 1997 study that says “Values may affect increase.” That same study shows there is a negative correlation between location of property and distance to open water. This is not Fort Lauderdale, where there are other opportunities for open water. You would be taking that access away, by this proposed regulation. Contrary to there being increase in property values, I expect the documentation is going to be provided, by respected and long-established Realtors in this area, that are going to say there’s been a significant reduction in property values, given the reasons that people move to this area. And I would trust that the Service would put great weight on people who are experienced with this market at this time, versus, what the market was in Fort Lauderdale in 1997. The economic impact, with the ad valorem values on waterfront properties are, in fact, reduced, would be significant. Ad valorem values for the City of Crystal River are 40 percent comprised of ad valorem for our total general fund revenue. It would be a very significant impact to a small government, and I think you will need to take that into account. The $100 million figure item that is standard is set by Federal regulation. You need to understand that you’re in a community, where then general fund budget for the local government is barely $4 million. You cannot, in good faith, apply a $100 million figure in this community and use that as a basis to promulgate rules of this nature. Is there any action that could be considered, in lieu of the proposed regulations? Yes. Let’s enforce what we’ve got. Let’s give that a couple years. Let’s see if that doesn’t do what the intent is. The documentation that was submitted, supporting the proposed rule, speaks about the States’ statutory responsibility, to balance the needs of manatees with the needs of the boating community. Where is the Service’s desire to show that same balance? Is the Service overriding the State’s statutory responsibilities by imposing more stringent regulations on Kings Bay, because there’s a Federal refuge office located here? I was proud to be a part of the effort to acquire Three Sisters Spring. There are provisions in that management plan, that I think are violated by these rules, and we reserve the right to take exception to those on that basis. I do not think that the spirit or the intent of the Three Sisters agreement is, in any way, reflected in any of the rules that we’re seeing proposed here tonight. Thank you for the opportunity to speak.