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till lit , 7 :_{ 'e 1 f ] d MY1 "� Q I' ll I it ti it ja 4` ix w kIlr The Sebastian Inlet Marina is located in the City limits of Sebastian and therefore falls under the City ' s regulatory purview. Notwithstanding , the proposed marina expansion is required by the State to be consistent with the County ' s Manatee Protection and Boating Safety Comprehensive Management Plan (MPP) . The Sebastian Inlet Marina expansion is the first marina expansion (or new facility) in the county since the MPP was adopted by the County Commission in August 2000 (and accepted by the State in November 2000) . As such , the proposed marina expansion is a "test case " for implementation of the MPP . Consequently, the proposal has brought to light some issues and internal inconsistencies in the MPP . The specific issues are : • The MPP prohibition of new marinas or expansions in areas with a combined history of high manatee watercraft mortality and high manatee abundance vs . MPP identification of the Sebastian riverfront ("Zone 3 ") as an appropriate area for new marinas or expansions . • The MPP requirement of a four- foot minimum water depth at the location of wet slips (and other marina areas) , regardless of the presence (or lack thereof) of seagrasses or other aquatic resources , and regardless of the size and draft of vessels to use the wet slips (as limited by design) . In order to address these issues , staff is recommending that the Board consider revising the MPP by modifying the current MPP formula for calculating high manatee watercraft-related mortality, as more specifically described herein . Staff is also proposing a change to the four- foot minimum depth requirement to account for site-specific conditions . MANWAC Recommendation On November S . 2001 , at a special meeting of the Marine Advisory / Narrows Watershed Action Committee (MANWAC), staff presented alternatives and recommendations to the MANWAC on revisions to the manatee mortality calculation and four- foot depth requirement. At that meeting, the MANWAC voted 5 to 3 to recommend that the Board revise the high manatee mortality calculation as presented in Attachment 1 to this memorandum ("Method 3 ") . The MANWAC also voted (unanimously) to modify the four-foot depth requirement language (see Attachment 2 ) . ANALYSIS High Manatee Watercraft Mortality Calculation The MPP states that "Zone 3 " of the Indian River Lagoon, the area of the proposed marina expansion , is a good place for new marinas or expansions if specific criteria are met. However, based on the current MPP fonnula for calculating "high manatee watercraft-related mortality, " marina expansions or rearrangements in much of Zone 3 would not be allowed. As currently formulated in the MPP, it would take approximately 35 years of no new watercraft deaths in this area for marina expansions to be allowed under the current MPP . That severe of a restriction in Zone 3 was not the intent of the County in adopting the MPP . Following is a summary of three alternative methods discussed at the November 8 " MANWAC meeting for calculating high manatee watercraft—related mortality, including the current MPP method . Also listed is a fourth alternative ("Method 4 ") that staff is now recommending as the preferred alternative, as hereafter described. • Method l (Existing formula) The existing formula compares , proportionately, manatee watercraft-related deaths (since 1974) within a three -mile radius of a project to the County ' s goal of one watercraft-related manatee death per year countywide. An issue with this formula is that it projects the County ' s goal of one watercraft-related manatee mortality per year into the past, such that the goal-side of the equation is based on one death per year dating back to 1974, the year that manatee mortality data became available . This approach creates an inequity that results in a prohibition on new or expanded marinas in the Sebastian area for at least 35 years . When this was explained to the MANWAC, it was the consensus of those at the MhNWAC meeting that the current formula warrants revision . November 20 , 2001 38 P 17, It Ylit, l Ic , It1 .-