Via Email to: March 12, 2024

Sirena Davila, Sirena.Davila@FloridaDEP.gov

Norva Blandin, Norva.Blandin@FloridaDEP.gov

Florida Department of Environmental Protection

3900 Commonwealth Blvd.

Tallahassee, FL 32399

Dear Ms. Davila and Ms. Blandin,

Last Stand is a Keys-wide community advocate focused on the impacts of development on our environment and affordable housing with more than a thousand members and supporters. We supported FOLKs' successful litigation to stop Marathon's use of shallow wells for disposal of sewage effluent and to require Marathon to develop a deep well instead. We are writing you because we understand you are reviewing a petition filed by Marathon to expand the use of the Area 3 wastewater treatment plant and shallow wells.

Last Stand strongly opposes any expansion which will increase the flow of partially-treated sewage to Marathon's shallow wells. Data from the recent EPA-funded study by Pennsylvania State University show that the Area 3 shallow wells, at their current rate of flow, are allowing migration of contaminants, including nutrients, to the nearby surface waters in excess of EPA Strategic Target levels.

Any expansion of discharge from a Wastewater Treatment Plant which is already in violation of its permit and negatively impacting nearby surface waters should be rejected.

Further, Marathon has admitted that the expansion of Area 3 which it seeks is for future development.

“The two proposed new concrete SBRs are going to each have a capacity of 131,356 gallons and be equivalent in tank capacity to the three existing SBR’s. Therefore, the City of Marathon will have a 2/3 increase in the capacity at the plant to allow for future development and expansion in the Area 3 Service Area.” Capacity Analysis Report, City of Marathon Area 3 Wastewater Treatment Facility (2020) (emphasis supplied)

Therefore, expansion of Area 3 should await such time as additional effluent from any future development can be disposed of in the new deep well, not in the shallow wells which have already proved to be inadequate.

Thank you for consideration of our concerns,

The Last Stand Board of Directors