United States Environmental	Region 4
Protection Agency	61 Forsyth Street, SW
Atlanta, GA 30303
904-P-19-001
April 2019
US Army Corps
of Engineers®

of
DRAFT
Environmental Assessment
(EA)
National Pollutant Discharge Elimination System
(NPDES) Permit and Rivers and Harbor Act Section 10
Permit for Kampachi Farms - Velella Epsilon (VE)
Offshore Aquaculture Project

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Abbreviations Used in this Document
Abbreviation
Definition
ACL
Annual Catch Limit
APHIS
Animal and Plant Health Inspection Service
ATON
Aids to Navigation
BACT
Best Available Control Technology
BES
Baseline Environmental survey
BOEM
Bureau of Ocean Energy Management
BPJ
Best Professional Judgement
BSEE
Bureau of Safety and Environmental Enforcement
°C
Degree Celsius
CAA
Clean Air Act
CAAP
Concentrated Aquatic Animal Production
CASS
Coastal Aquaculture Siting and Sustainability
CEQ
Council on Environmental Quality
CFR
Code of Federal Regulations
Chl-a
Chlorophyll a
CWA
Clean Water Act
CZMA
Coastal Zone Management Act
DA
Department of Army
DO
Dissolved Oxygen
DOC
Department of Commerce
DOD
Department of Defense
DOI
Department of Interior
DPS
Distinct Population Segment
DWH
Deepwater Horizon Event
EA
Environmental Assessment
EEZ
Exclusive Economic Zone
EFH
Essential Fish Habitat
EFP
Exempted Fishing Permit
EIS
Environmental Impact Statement
ELG
Effluent Limitations Guidelines
EPA
U.S. Environmental Protection Agency
ESA
Endangered Species Act
FIFRA
Federal Insecticide, Fungicide, and Rodenticide Act
FMP
Fishery Management Plan
FR
Federal Register
ft
Feet
FWS
U.S. Fish and Wildlife Service
GAP
Gulf Aquaculture Permit

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GOMESA
Gulf of Mexico Energy Security Act
GPS
Global Positioning System
Gulf
Gulf of Mexico
HAB
Harmful Algal Blooms
HAPCs
Habitats of Particular Concern
kg/day
Kilograms per Day
km
Kilometer
lbs. gw
Pounds Gross Weight
LOP
Letter of Permission
m
Meters
MAS
Multi-Anchor System
MBTA
Migratory Bird Treaty Act
mg/1
Milligram per Liter
MMAP
Marine Mammal Authorization Program
MMPA
Marine Mammal Protection Act
MOU
Memorandum of Understanding
MP As
Marine Protected Areas
MSA
Marine Sanctuary Act
NAAQS
National Ambient Air Quality Standards
NEPA
National Environmental Policy Act
NHPA
National Historic Preservation Act
NMFS
National Marine Fisheries Service
nmi
Nautical Mile
NMSA
National Marine Sanctuaries Act
NMSP
National Marine Sanctuary Program
NO A A
National Oceanic and Atmospheric Administration
NPDES
National Pollutant Discharge Elimination System
NWR
National Wildlife Refuge
OCS
Outer Continental Shelf
ODCE
Ocean Discharge Criteria Evaluation
ODMDS
Ocean Dredged Material Disposal Site
PAHs
Polyaromatic Hydrocarbons
PATON
Private Aids to Navigation
PCBs
Polychlorinated Biphenyls
PDARP
Final Programmatic Damage Assessment and Restoration Plan
PEIS
Programmatic Environmental Impact Statement
PFEIS
Programmatic Final Environmental Impact Statement
PM
Particulate Matter
ppt
Parts per Thousand
PSD
Prevention of Significant Deterioration
PSMP
Protected Species Management Plan

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RAS
recirculating aquaculture system
RUE
Right of Use and Easement
SEFSC
Southeast Fisheries Science Center
SLA
Submerged Lands Act
SPCC
Spill Prevention, Containment, and Countermeasure
TKN
Total Kjeldahl Nitrogen
TOC
Total Organic Carbon
TP
Total Phosphorous
ug/L
Microgram per Liter
USACE
U.S. Army Corps of Engineers
USCG
U.S. Coast Guard
USD A
U.S. Department of Agriculture
WTCW
Well Treatment, Completion, and Workover (fluids)

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Table of Contents
1.0	Introduction	1
1.1	Regulatory Background	2
1.1.1	EPA—Clean Water Act	3
1.1.2	USACE-Section 10	4
1.2	Primary Federal Authorizations needed for Proposed Aquaculture Projects	4
1.3	Required Federal Consultations, Reviews, and Other Applicable Laws	5
1.4	Proposed Action	7
1.5	Purpose and Need for the Proposed Action	7
1.6	Site Selection	8
1.6.1	Description and Location	8
1.6.2	Surrounding Location Uses	9
1.6.3	Summary of Proposed Project Activities	9
1.7	Environmental Review Process	10
1.8	Cooperating Agencies	10
1.9	Documents incorporated by reference	11
2.0	Alternatives	12
2.1	Alternatives Considered	12
2.1.1	Alternative 1—No Action	12
2.1.2	Alternative 2 —Issuance ofNPDES Permit and Section 10 Authorization	12
2.2	Alternatives Considered but Eliminated from Detailed Study	12
2.3	Factors Used to Develop and Screen Alternatives	12
3.0	Affected Environment	14
3.1	Introduction	14
3.2	Physical Resources	14
3.2.1	Water Quality	15
3.2.2	Sediment Quality	16
3.2.3	Air Quality	17
3.2.4	Coastal Barrier Beaches	18
3.2.5	Noise Environment	18
3.2.6	Climate	18
3.3	Biological Resources	19
3.3.1	Fish	19
3.3.2	Invertebrate s	21

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3.3.3	Marine Mammals	21
3.3.4	Sea Turtles	22
3.3.5	Birds	25
3.3.6	Essential Fish Habitat	25
3.3.7	Deepwater Benthic Communities	26
3.3.8	Live Bottoms	26
3.3.9	Seagrasses	27
3.4 Social and Economic Environment	27
3.4.1	U.S. Seafood Consumption and Production	27
3.4.2	Commercial Marine Aquaculture Production	27
3.4.3	Commercial Landings of Almaco Jack	28
3.4.4	Commercial Fishing	29
3.4.5	Recreational Marine Fishing	29
3.4.6	Human Health/Public Health	30
3.4.7	Environmental Justice	30
4.0	Environmental Consequences	31
4.1	Introduction	31
4.2	Physical Resources	31
4.2.1	Water Quality	32
4.2.2	Sediment Quality	33
4.2.3	Air Quality	34
4.2.4	Coastal Barrier Beaches	35
4.2.5	Noise Environment	35
4.2.6	Climate	35
4.3	Biological Resources	35
4.3.1	Fish	36
4.3.2	Invertebrates	37
4.3.3	Marine Mammals	38
4.3.4	Sea Turtles	40
4.3.5	Birds	41
4.3.6	Essential Fish Habitat	42
4.3.7	Deepwater Benthic Communities	43
4.3.8	Live Bottoms	43

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4.3.9 Seagrasses	43
4.4 Social and Economic Environment	44
4.4.1	Commercial Marine Aquaculture Production	44
4.4.2	Commercial Fisheries	45
4.4.3	Recreational Fishing	45
4.4.4	Human Health/Public Health	46
4.4.5	Environmental Justice	46
5.0	Cumulative Impacts	48
5.1	DWH 48
5.2	Oil and Gas Operations	48
5.3	Future Aquaculture Operations	49
5.4	Physical Resources	49
5.4.1	Water Quality	49
5.4.2	Sediment Quality	50
5.4.3	Air Quality	51
5.4.4	Coastal Barrier Beaches	51
5.4.5	Noise Environment	51
5.4.6	Climate	51
5.5	Biological Resources	52
5.5.1	Fish	52
5.5.2	Invertebrates	53
5.5.3	Marine Mammals	53
5.5.4	Sea Turtles	54
5.5.5	Birds	54
5.5.6	Essential Fish Habitat	55
5.5.7	Deepwater Benthic Communities	56
5.5.8	Live Bottoms	56
5.5.9	Seagrasses	56
5.6	Social and Economic Environment	56
5.6.1	Aquaculture Production	57
5.6.2	Commercial and Recreational Fishing	57
5.6.3	Human Health/Public Health	58
5.6.4	Environmental Justice	58

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6.0	Summary of Alternatives	59
6.1	Alternatives Summary	59
6.1.1	Alternative 1: No Action	59
6.1.2	Alternative 2: Proposed Action—Issuance ofNPDES Permit and Section 10 Authorization for
Velella Epsilon	59
6.2	Comparison of Alternatives	60
6.3	Preferred Alternative	60
6.4	Unavoidable Adverse Impacts	60
6.5	Irreversible and Irretrievable Commitments of Resources	61
6.6	Relationship Between Short-term Uses of the Environment and the Maintenance and Enhancement of
Long-Term Productivity	62
6.7	Preliminary Finding of No Significant Impact (FONSI)	62
7.0	Other Protective Measures and Agency Coordination Efforts	63
7.1	State Coastal Zone Management Program Consistency	63
7.2	National Historic Preservation Act (NHPA)	63
7.3	The Wild and Scenic Rivers Act	64
7.4	Fish and Wildlife Coordination Act	64
7.5	Section 7 ESA Coordination	64
7.6	Essential Fish and Habitat Consultation	65
7.7	CWA Section 401	65
7.8	Marine Mammal Protection Act	66
8.0 References	67
9.0 Public Notice	78
10.0 Preparers
79

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List of Appendices
Appendix A - Baseline Environmental Survey
Appendix B - Cage/Pen Design
Appendix C - ODCE
Appendix D - ESA Consultation Document
Appendix E - EFH Consultation Documents
Appendix F - CASS Technical Report
Appendix G - Preliminary Finding of No Significant Impact
Appendix H - State Consultations (NHPA Section 106/CZMA)

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1.0 Introduction
Kampachi Farms, LLC (applicant) is proposing to install and operate a pilot-scale marine aquaculture
facility in federal waters of the Gulf of Mexico (Gulf) and has applied for permits from multiple federal
agencies (See Table 1). An interagency workgroup consisting of the U.S. Environmental Protection
Agency (EPA), U.S. Army Corps of Engineers (USACE) and National Marine Fisheries Service
(NMFS), has prepared this environmental assessment (EA) to evaluate the potential environmental
impacts of the construction and operation of the proposed project, named Velella Epsilon (VE).
This EA was prepared by the EPA as the lead federal agency with assistance from the NMFS and
USACE as cooperating agencies under the National Environmental Policy Act (NEPA). Cooperating
agencies have jurisdiction by law or special expertise with respect to the potential environmental
impacts resulting from the VE project. All three federal agencies have jointly prepared this EA in
compliance with the requirements of the NEPA Title 40 CFR Parts 1500-1508 regulations, and each
Agencies' implementing regulations.
A NEPA review is required when the EPA issues a NPDES permit for a "new source" under the Clean
Water Act (CWA). At this time, the proposed facility does not meet the definition of "new source,"
which includes facilities subject to and commencing construction after the promulgation of national
standards of performance under Section 306 of the CWA (40 CFR Section 122.2). The proposed facility
will commence construction after promulgation of national standards of performance for CAAP
facilities set forth at 40 CFR Part 451; however, those standards do not apply to facilities producing less
than 100,000 pounds of aquatic animals annually (the proposed facility will produce a maximum of
88,000 pounds of aquatic animals per year). Thus, the obligation to conduct NEPA review for issuance
of "new source" permits does not directly apply to the proposed permit.
While the NEPA regulations are not automatically applicable to the proposed facility, the EPA finds that
a NEPA analysis will be beneficial. It is appropriate to perform a NEPA review in accordance with
EPA's Policy for Voluntary Preparation of NEPA Documents (63 Federal Register 58045; October 29,
1998) based on the facility-specific circumstances surrounding the issuance of the NPDES permit. First,
preparing a NEPA evaluation will enhance and facilitate an analysis of environmental impacts that are
not well known because the proposed facility would be the first aquaculture facility to operate and
discharge in federal waters of the eastern Gulf. Second, the EPA's decision to prepare an EA is also
supported by 40 CFR Section 6.205(a), which provides for preparation of an EA when a proposed action
is expected to result in environmental impacts and the significance of the impacts are not known. Third,
improved coordination and efficiencies with other federal agencies will occur because these Agencies
are already required to prepare NEPA documentation for related permitting actions. Finally, the
proposed facility's maximum annual production of 88,000 lbs. is relatively close to the threshold for
meeting the new source definition for which EPA's NEPA requirements under 40 CFR Part 6 are
automatically applicable.
Following the approval of the Aquaculture Memorandum of Understanding MOU between Federal
agencies, and in consideration of the EPA's Policy for Voluntary Preparation of NEPA Documents and
the implementing regulations of NEPA (i.e. 40 CFR Part 1500-1508), the EPA elected to act as the lead
Federal agency for the creation of a single EA given that the action of permitting the proposed project
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involves more than one federal agency. The NMFS and USACE are cooperating agencies for the
development of the EA. The completion of a jointly created EA and potential finding of no significant
impact will satisfy EPA's obligations under NEPA.
As the lead federal agency, the EPA prepared this EA in accordance with the Title 40 Part 6 regulations.
In addition, the EPA requested that the Bureau of Ocean Energy Management (BOEM), the U.S. Fish
and Wildlife Service (FWS), Bureau of Safety and Environmental Enforcement (BSEE), and the U.S.
Coast Guard (USCG) participate in this process as participating agencies.
The roles of each federal agency in the VE project review process are described throughout this EA.
This document provides a basis for coordinated federal decision-making in a single document, avoiding
duplication among federal agencies (or other state agencies with federal delegation authority) using the
NEPA environmental review process. In addition to the lead and cooperating agencies, other federal,
state, and local agencies may use this EA in approving or issuing authorizations for this project. The
major federal, state, and local consultations associated with the proposed project are discussed in the
following sections: Regulatory Background (Section 1.1), Primary Federal Authorizations needed for
Proposed Aquaculture Projects (Section 1.2) and Required Federal Consultations, Review, and Other
Applicable Laws (Section 1.3).
Through the preparation of this 'voluntary' EA and supporting studies, the EPA will also help streamline
the NEPA process for any future aquaculture permitting actions, establish a monitoring and assessment
baseline of important water quality issues associated with similar discharges, and provide an increased
opportunity for public and stakeholder comments.
1.1 Regulatory Background
The operator of an offshore aquaculture facility must obtain required federal permits and authorizations
prior to beginning operations (e.g., USACE Section 10 permit needed before anchoring any structures
into federal waters of the Gulf and EPA's NPDES permit needed before stocking animals into those
structures). Table 1 summarizes the permits that are needed to conduct aquaculture in federal waters of
the Gulf.
Table 1: Federal Permits needed for o
Tshorc aquaculture projects.
» \«l'IIO
Miituti".
\iilliorifii-o
l*iir|MKi'
IVrmil
U.S. Army Corps of Engineers (USACE)
Section 10 of the Rivers and
Harbors Act
Required in navigable waters
of the U.S. to protect
navigation for commerce
Section 10 Permit
U.S.
Environmental Protection Agency (EPA)
Sections 402 and 403 of the Clean
Water Act
Required for the dischargs of
pollutants into waters of the
U.S.
NPDES Permit
Additional details regarding the statutory/regulatory framework that supports offshore aquaculture
permitting are provided in the following sections.
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1.1.1 EPA—Clean Water Act
In accordance with the CWA, all pollutant discharges must comply with specific legal requirements. The
CWA defines pollutant as dredged spoil, solid waste, incinerator residue, sewage, garbage, sewage
sludge, munitions, chemical wastes, biological materials, heat, wrecked or discarded equipment, rock,
sand, cellar dirt and industrial, municipal, and agricultural waste discharged into water. The CWA
established the NPDES program to protect and improve water quality by regulating point-source
discharges into waters of the United States. Pursuant to its CWA authority, the EPA developed the
NPDES Permit Program to permit pollutant discharges.
Discharges from aquaculture operations are primarily governed by the implementing regulations of
CWA Sections 402 and 403. The CWA Section 402 authorizes the EPA to issue NPDES permits for the
discharge of pollutants from point sources into waters of the United States. The CWA Section 402
requires that a NPDES permit for a discharge into federal waters of the ocean be issued in compliance
with EPA's ocean discharge criteria within CWA Section 403 for preventing unreasonable degradation
of the receiving waters (i.e., 40 CFR Section 125.121). Potential pollutant discharges from aquaculture
operations include solids, nutrients, ammonia, fish waste, feed waste, pharmaceuticals, chemicals, and
other industrial animal-processing byproducts. The proposed facility will require a NPDES permit
because it proposes to discharge pollutants from a point source to waters of the United States and,
therefore, is subject to the general CWA Section 301 prohibition against discharges unless authorized by
a NPDES permit.
Relevant to the proposed action is the CWA implementing NPDES regulation relating to concentrated
aquatic animal production (CAAP) facilities under 40 CFR Section 122.24, which requires technology-
based effluent limitations for certain discharges of pollutants from CAAP facilities. The discharges from
the proposed facility are not regulated as a CAAP because the facility does not meet the fish production
thresholds for the warm water category. Therefore, the discharge of pollutants from the facility will be
regulated as an aquatic animal production facility and the NPDES permit for the proposed facility will
include the CAAP effluent limitations based on best professional judgement as allowed by 40 CFR
Section 125.3(c).
Effective in 2004, the CAAP performance standards and effluent-limit guidelines (ELGs) are set forth in
40 CFR Part 451 and consist of a series of management practices designed to control pollutant
discharges. These standards and guidelines were developed for CAAP facilities producing over 100,000
pounds annually in net pens or submerged cage systems. Based on maximum production levels provided
by the applicant, the proposed action will not meet that production threshold. However, while the Part
451 effluent guideline limitations are not directly applicable, the NPDES permit for the facility will
adopt those same requirements in the permit based on the best professional judgment (BP J) of the permit
writer and based on the factors set forth in 40 CFR Part 125, Subpart A. An individual permit is required
because no general permit is available for off-shore aquatic animal production or CAAP operations
within federal waters of the Gulf. NPDES permits usually are issued for 5-year terms and reissued every
5 years.
The CWA's jurisdiction extends over navigable waters, territorial seas, the waters of the contiguous
zone, and the oceans. The CWA defines navigable waters to include the territorial seas, which are
defined as the belt of seas measured from the ordinary, low-water line in direct contact with the open sea
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and the line marking the seaward limit of inland waters and extending seaward 3 miles. The contiguous
zone is the entire zone established under Article 24 of the Convention of the Territorial Sea and the
Contiguous Zone, and any portion of the high seas beyond this zone is defined as the ocean. In most
places, federal waters extend from where state waters end out to about 200 nautical miles (nmi) also
known as the U.S. Exclusive Economic Zone (EEZ).1
The CWA Section 403 requires all offshore pollutant discharges to have permit limits consistent with
EPA's ocean discharge criteria, which are the EPA's regulations to prevent unreasonable degradation of
the marine environment in connection with discharges to the territorial seas, the contiguous zone, and
the oceans. Consequently, all CWA Section 402 permitted discharges into the territorial sea, the waters
of the contiguous zone, or the oceans must be consistent with CWA Section 403 criteria.
Additionally, depending upon the proposed design and operations, aquaculture facilities may also be
subject to federal requirements under the Animal and Plant Health Inspection Service (APHIS) which is
administered by the U.S. Department of Agriculture, the Spill Prevention, Containment, and
Countermeasure (SPCC) regulations, or the Federal Insecticide, Fungicide, and Rodenticide Act
(FIFRA), and NEPA (EPA, 2006).
1.1.2 US ACE—Section 10
The proposed action requires the issuance of a Department of the Army (DA) permit pursuant to Section
10 of the Rivers and Harbors Act of 1899 (33 U.S.C. Section 403). Section 10 requires prior
authorization for structures and work in, over, under, and affecting navigable waters. Under this
authority, operators must obtain a Section 10 permit prior to installing any offshore aquaculture
infrastructure, such as net pens and lines, provided that it is an "installation or other device" and is
attached to the seabed.
1.2 Primary Federal Authorizations needed for Proposed Aquaculture Projects
In addition to required federal permits, other federal authorizations may be needed to support
commencement of offshore aquaculture projects in federal waters. For example, if an aquaculture
facility is co-located within the outer continental shelf (OCS) oil and gas facilities (this is not the case
with the VE project), the BOEM and the BSEE must review and provide certain approvals which would
be incorporated into the federal permitting processes (i.e., no separate authorizations would be issued).
Once all federal permits have been obtained, applicants must apply to the USCG to receive an
authorization to deploy Private Aids to Navigation (PATON), (e.g., markers, buoys, at their approved
aquaculture operation site). Table 2 provides a summary of the federal authorizations that may be
needed for offshore marine aquaculture projects in federal waters.
1 EPA has delegated the NPDES program to the State of Florida for projects in state waters. The State of Florida's NPDES jurisdiction extends three miles
offshore. The CWA requires the EPA to issue NPDES permits for pollutant discharges beyond three miles seaward offshore Florida. For purposes of this
EA, nautical mile is used interchangeably with geographic miles (i.e., CWA) to be distinguished from statutory miles. For example, 9 nmi equals 8.99
geographic miles versus 10.36 statute miles.
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Table 2: Federal authorizations required for Offshore Aquaculture Projects.
Agency
Statutes/Authorities
Purpose
Application
Form(s)/Process4
Who initiates this
action and how?
Form of
authorization
AllllkiriAllkills
U.S. Coast
Guard
(USCG)
33 U.S.C. 1221 et
seq
33 CFR Section 66
Ensure safe
navigation
Authorize
Private Aids
To
Navigation
Private Aids to
Navigation
Application Form
(CG-2554)
Applicant seeking
to establish a
private aid
to navigation
Formal
authorization
from
appropriate
USCG
District
\ullkii'i/aluiiis liir \t|iiaculiui'c ()pcralk>iis (\»-l.ocalcd \x illi ()( S ()il and C ias I'acililics
Bureau of
Ocean Energy
Management
(BOEM)
Outer Continental
Shelf Lands Act;
Energy Policy Act of
2005; 30 CFR
Section 500-599
Required for
any offshore
aquaculture
operations
that utilize or
tether to
existing oil
and gas
facilities
Right of Use and
Easement (RUE)
for Energy and
Marine- Related
Activities Using
Existing OCS
Facilities
Operator of the
OCS aquaculture
facility proposing
to initiate offshore
aquaculture
activities submits
request for an
Alternate Use
RUE after
contacting and
receiving approval
from the OCS Oil
and Gas Facility
Owner
A formal
RUE is
established
using the
facility for
the purpose
of
aquaculture
Bureau of
Safety and
Environmental
Enforcement
(BSEE)
Outer Continental
Shelf Lands Act


Permitting
agencies request
BSEE consultation
on proposed
aquaculture
activities

1.3 Required Federal Consultations, Reviews, and Other Applicable Laws
The EPA and the USACE must also coordinate with other agencies when making permitting decisions
for offshore aquaculture operations. Table 3 provides a summary of these applicable laws and
coordination efforts. Additional information about the coordination and consultation efforts to comply
with other applicable federal laws is provided in Chapter 7 and in the Appendices of this EA.
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Table 3. Other Applicable Federal Laws

Description of the Requirement
Endangered Species
Act
Section 7 of the Endangered Species Act (ESA) requires any federal agency that issues a permit to consult
with NOAA's National Marine Fisheries Service (NMFS) and/or the U.S. Fish and Wildlife Service
(USFWS), if issuance of the permit may adversely affect ESA- listed species and/or the designated critical
habitat for ESA-listed species. The Section 7 consultation process requires an analysis of the effects of the
proposed action on ESA-listed species and designated critical habitat based on the best available science. The
analysis must determine if the proposed action is likely to adversely affect an ESA-listed species and/or
designated critical habitat. If the analysis determines the issuance of a proposed permit may adversely affect
an ESA-listed species, but will not jeopardize its continued existence, then reasonable and prudent measures
and implementing terms and conditions that minimize the adverse impacts must be developed.
Essential Fish Habitat
The Essential Fish Habitat (EFH) provisions of the Magnuson-Stevens Act requires federal agencies to
consult with NMFS when activities they undertake or permit have the potential to adversely affect EFH.
National Historic
Preservation Act
Section 106 of the National Historic Preservation Act (36 CFR Part 800) requires any federal agency issuing a
permit to account for potential effects of the proposed aquaculture activity on historic properties, e.g.,
shipwrecks, prehistoric sites, cultural resources. If a proposed aquaculture activity has the potential to affect
historic properties, these details must be provided by the applicant as part of the application packages.
Fish and Wildlife
Coordination Act
The Fish and Wildlife Coordination Act requires any federal agency issuing permits to consult with USFWS
and NMFS if the proposed aquaculture activities could potentially harm fish and/or wildlife resources. These
consultations may result in project modification and/or the incorporation of measures to reduce these effects.
National Marine
Sanctuary Resources
Act
Section 304(d) of the National Marine Sanctuaries Act (NMSA) requires that any federal agency issuing
permits to consult with NOAA's National Marine Sanctuary Program (NMSP) if the proposed aquaculture
activity is likely to destroy or injure sanctuary resources. As part of the consultation process, the NMSP can
recommend reasonable and prudent alternatives. While such recommendations may be voluntary, if they are
not followed and sanctuary resources are destroyed or injured in the course of the action, the NMSA requires
the federal action agency(ies) issuing the permit(s) to restore or replace the damaged resources.
Marine Mammal
Protection Act
The Marine Mammal Protection Act (MMPA) prohibits the harassment, hunting, capturing or killing of
marine mammals without a permit from either the Secretary of the Interior or the Secretary of Commerce.
Section 118 of the MMPA addresses the incidental capture of marine mammals during commercial fishing
operations. Section 118 also establishes the Marine Mammal Authorization Program (MMAP), which
provides a mechanism for commercial fishermen to receive an exemption to the prohibitions against capturing
marine mammals. To be eligible for the exemption, any commercial vessel or non-vessel gear (e.g.,
aquaculture facilities) engaging in a Category I or II fishery must obtain a MMAP certificate from NMFS or a
designated agent. Fishery categories are published in the annually reviewed and revised NMFS, which is
available on the NMFS website and in the Federal Register.
National Environmental
Policy Act
The National Environmental Policy Act (NEPA) requires federal agencies to prepare either an Environmental
Impact Statement (EIS) or Environmental Assessment (EA) for any federal action affecting the quality of the
human environment; unless it is determined the activity is categorically excluded from NEPA. NOAA has
completed a Programmatic EIS (PEIS), which broadly considers a range of similar aquaculture projects in the
Gulf. Federal agencies, in particular EPA and USACE, will ensure that any additional site specific
assessments deemed necessary are conducted. Permit applicants may be required to provide support for the
project-specific evaluation of alternatives and their environmental effects, such as providing estimates of
nutrient loadings, an assessment of the potential for benthic impacts, or effects on native species.
Coastal Zone
Management Act
The Coastal Zone Management Act of 1972 (CZMA) encourages coastal states to develop and implement
coastal zone management plans as a basis for protecting, restoring, and establishing a responsibility in
preserving and developing the nation's coastal communities and resources. Coastal states with an approved
coastal zone management program are authorized to review certain federal actions affecting the land or water
uses or natural resources of its coastal zone for consistency with its program. Under the CZMA, a state may
review: activities conducted by, or on behalf of, a federal government agency within or outside the coastal
zone that affects any land or water use or natural resource of the coastal zone; an application for a federal
license or permit; and any plan for the exploration or development or, or production from, any area that has
been leased under the Outer Continental Shelf Lands Act for offshore minerals exploration or development.
The CZMA requires federal agency activities to be consistent to the maximum extent practicable with the
enforceable policies of a state's approved coastal zone management program.
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1.4	Proposed Action
The applicant is proposing a pilot-scale project where up to 20,000 Almaco jack (,Seriola rivoliana, i.e.,
Kampachi) fingerlings will be reared in a single net pen aquaculture system in federal waters
approximately 45 miles west, southwest of Longboat Pass-Sarasota Bay, Florida. Project details are
provided in Section 1.6.3 Summary of Proposed Project Activities.
The proposed action is the issuance of a permit under the respective authorities of the EPA and the
USACE as required to operate the facility. The EPA's proposed action is the issuance of a NPDES
permit that authorizes the discharge of pollutants from an aquatic animal production facility that is
considered a point source into federal waters of the United States. The USACE's proposed action is the
issuance of a DA permit pursuant to Section 10 that authorizes anchorage to the sea floor, and structures
affecting navigable waters.
1.5	Purpose and Need for the Proposed Action
The applicant seeks permits and authorizations for the VE project which is a single net pen
demonstration project for open ocean aquaculture of marine finfish in federal waters of the Gulf. The
EPA and the USACE are the two federal agencies that are statutorily required to issue permits and
authorizations for this type of operation. The EPA and USACE agency specific purpose and need for the
proposed project are as follows:
EPA
On November 9, 2018, the EPA Region 4 received a complete application for a NPDES permit from the
applicant (Kampachi Farms) for the discharge from a marine aquaculture facility into federal waters of
the Gulf. The proposed action is the issuance of a new NPDES individual permit for discharges from a
new aquaculture facility into federal waters of the Gulf. The proposed facility would be the first
aquaculture facility to operate and discharge in federal waters of the eastern Gulf and, thus, the
significance of any impacts to the environment from such a facility is not known. Consistent with 40
CFR Section 6.205(a), the EA was prepared for the proposed action under EPA's Voluntary Policy for
the Preparation ofNEPA Documents. The applicant needs an NPDES permit in order to operate and
discharge from its proposed aquaculture facility in compliance with the CWA.
USACE
On December 13, 2017, a DA application was submitted to Fort Myers Permit Section for the VE
project. The application was determined complete, but the applicant indicated that the project location
and equipment was likely to change as a result of the NMFS exempted fishing permit (EFP) application
process (the EFP process was discontinued after the September 2018 court ruling regarding NMFS'
authority to regulate aquaculture as fishing under the Magnuson-Stevens Act in the Gulf). The
application was withdrawn on March 23, 2018, until the project details were finalized. On November 10,
2018, the USACE Jacksonville District received a complete application for a DA permit pursuant to
Section 10 for structures and work affecting navigable waters from Kampachi Farms. The USACE will
be evaluating the project for a DA authorization via a Letter of Permission (LOP) pursuant to Section
10. For the purposes of this EA, the Section 10 Permit and LOP will be used interchangeably. The LOP
will be valid for 5 years. In contrast, the application proposes a pilot-scale aquaculture system that will
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raise approximately 20,000 Almaco jack over a 12-14 month project period. An LOP was determined
appropriate for this action due to the small scale and temporary nature of the proposed pilot project.
The proposed action is the issuance of a USACE permit pursuant to Section 10 of the Rivers and
Harbors Act of 1899. Section 10 requires prior authorization for structures and work in, over, under, and
affecting navigable waters. Under this authority, operators must obtain a Section 10 permit prior to
installing any offshore aquaculture infrastructure, such as net pens and lines, provided that it is an
"installation or other device" and is attached to the seabed. The applicant needs a DA authorization in
order to operate its proposed aquaculture facility in compliance with Section 10.
1.6 Site Selection
Two potential site locations, approximately five nautical miles apart, were identified along the 40-meter
(m) isobath after an extensive preliminary siting analysis conducted with NOAA's National Ocean
Service National Centers for Coastal Ocean Science (NOS NCCOS) staff. Preliminary analysis used a
number of site criteria including: proximity to a commercial port, adequate water depths (at least 130 ft)
to allow net pen submersion and maximize mooring scope, avoidance of hardbottom habitats, artificial
reefs and submerged cultural resources (e.g., shipwrecks), areas consisting of unconsolidated sediments
for positioning the anchors, avoidance of marine protected areas (MP As), marine reserves, and Habitats
of Particular Concern (HAPCs). Selection criteria also considered the presence of navigational fairways,
vessel traffic routes, anchoring areas, lightering zones, deepwater ports, platform safety zones, military
zones, fisheries and tourism areas, dredging sites, mineral extraction areas, designated dredge material
dumping sites, rights of way for energy transmission lines and communications cables, and scientific
reference sites and fishery conflicts.
A baseline environmental survey (BES) (Appendix A) of both sites was commissioned by the applicant
to determine if the sites were clear of sensitive live bottom habitat, potential hazards, and potential
archeological and historic features not present in the data sets used in the preliminary site analysis. The
BES was also used for engineering analysis by determining whether selected sites contained sufficiently
deep layers of unconsolidated sediments suitable for cage anchors. Benthic surveys using sidescan
sonar, sub-bottom profiling, and towed magnetometer data determined that the seafloor at both locations
were free of any exposed pipelines, marine debris, underwater wrecks and cultural resources. This site
screening process informed federal agencies of viable action alternatives and non-viable alternatives as
part of the NEPA process.
1.6.1 Description and Location
The proposed facility will be located within the boundary of the coordinates shown in Table 4. The
boundary of the facility is -45 miles southwest of Sarasota, Florida and consist of water depths of
-130 feet which is conducive for placement of the single cage and multi-anchor system (MAS).
The applicant will select a specific location within that area based on diver-assisted assessments of the
sea floor when the cage and MAS are deployed. See Appendix A for additional information on the
project boundary.
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Table 4. Velella Epsilon Boundary Coordinates
Lot-ill ion
Liililiulc
Longitude
Upper Left Corner
27° 7.70607' N
83° 12.27012'W
Upper Right Corner
27° 7.61022'N
83° 11.65678'W
Lower Right Corner
27° 6.77773'N
83° 11.75379'W
Lower Left Corner
27° 6.87631' N
83° 12.42032'W
1.6.2	Surrounding Location Uses
The proposed area is located on a portion of the west Florida Shelf that is heavily trawled by the shrimp
fishing industry. Additionally, large portions of the west Florida Shelf are designated as military special
use airspace. To avoid user conflicts in this area, the applicant coordinated closely with the military and
the shrimping industry during the site selection process.
1.6.3	Summary of Proposed I "roject Activities
The proposed project would allow the applicant to operate a pilot-scale marine aquaculture facility with
up to 20,000 Almaco jack (Seriola rivoliana; i.e., Kampachi) being reared in federal waters for a period
of approximately 12 months (total deployment of the cage system is 18 months). Based on an estimated
85 % (percent) survival rate, the operation is expected to yield approximately 17,000 fish. Final fish size
is estimated to be approximately 4.4 lbs./fish, resulting in an estimated final maximum harvest weight of
88,000 lbs. (or 74,800 lbs. considering the survival rate). The fingerlings will be sourced from brood
stock that are located at Mote Aquaculture Research Park and were caught in the Gulf near Madeira
Beach, Florida. As such, only F1 progeny will be stocked into the proposed project. Following harvest,
cultured fish would be landed in Florida and sold to federally-licensed dealers in accordance with state
and federal laws.
A single CopperNet offshore strength (PolarCirkel-style) submersible fish pen will be deployed on an
engineered multi-anchor swivel (MAS) mooring system. The design provided by the applicant for the
engineered MAS will use three concrete deadweight anchors for the mooring system or embedment
anchors. The cage material for the proposed project is constructed with rigid and durable materials
(copper mesh net with a diameter of 4 millimeter (mm) wire and 40mm x 40 mm mesh square). The
mooring lines for the proposed project will be constructed of steel chain (50mm thick) and thick rope
(36mm) that are attached to a floating cage that will rotate in the prevailing current direction; the
floating cage position that is influenced by the ocean currents will maintain the mooring rope and chain
under tension during most times of operation. The bridle line that connects from the swivel to the cage
will be encased in a rigid pipe. Structural information showing the MAS and pen array, along with the
tethered tender vessel, is provided in Appendix B.
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The CopperNet cage design is flexible and self-adjusts to suit the constantly changing wave and current
conditions. As a result, the system can operate floating on the ocean surface or submerged within the
water column of the ocean. When a storm approaches the area, the operating team uses a valve to flood
the floatation system with water, causing the entire cage array to submerge. A buoy remains on the
surface, marking the net pen's position and supporting the air hose. When the pen approaches the
bottom, the system will maintain the cage several meters above the sea floor. Submerged and protected
from the storm above, the system is still able to rotate around the MAS and adjust to the currents. After
storm events, facility staff makes the cage system buoyant, causing the system to rise back to the surface
or near surface position to resume normal operational conditions. The proposed project cage will have at
least one properly functioning global positioning system device to assist in locating the system in the
event it is damaged or disconnected from the mooring system.
At the conclusion of the 12-14 month demonstration trial period, the net pen and all disconnected from
the mooring system. For a detailed schematic of the pen design sqq Appendix B.
1.7	Environmental Review Process
The EPA is the designated Lead Agency for NEPA compliance for the proposed VE project. According
to the 2017 Interagency MOU,2 agencies with permitting authority will apply the relevant and
applicable provisions of NEPA, Endangered Species Act (ESA) Section 7, National Historic
Preservation Act (NHPA) Section 106, the Coastal Zone Management Act (CZMA), the Marine
Sanctuary Act's (MSA's) Essential Fish Habitat (EFH) provisions, and other applicable laws to their
federal actions (NMFS, 2016). Because a particular agency may have more extensive authority and
expertise concerning the activities that are subject to these regulations, that agency (or agencies) will
generally take the lead on required evaluations or consultations in order to minimize delays and reduce
potential duplication and effort (NMFS, 2016). This EA has been developed consistent with the EPA's
NEPA implementing regulations and in cooperation with identified cooperating and participating federal
agencies.
This EA informs the decision process with regard to issuance of an NPDES permit and Section 10
authorization issued by the EPA and USACE, respectively. In accordance with the MOU, to streamline
the NEPA process, EPA requested that the USACE and NMFS participate as cooperating agencies on
development of the EA. The EPA and the USACE intend to use the EA to inform decisions related to
issuance of required permits and authorizations necessary for the VE project to proceed (note that the
applicant must secure permits from both agencies in order to complete the project). Specifically, this EA
analyzes a range of potential environmental impacts that could arise from a small-scale open ocean
aquaculture system to determine if there is potential for significant impacts to: 1) physical resources; 2)
biological resources; and 3) social and economic environment.
1.8	Cooperating Agencies
Consistent with EPA's NEPA regulations (40 CFR Part 6) and pursuant to the interagency MOU, EPA
sent a cooperating-agency request to federal agencies involved in the evaluation of the proposed VE
project on November 7, 2018. A cooperating agency request was submitted to the USACE and NMFS
and participation requests were sent to BOEM, BSEE, USCG and FWS.
2 On February 6, 2017, the Memorandum of Understanding (MOU) for Permitting Offshore Aquaculture Activities in federal waters of the Gulf of Mexico
became effective for seven federal agencies with permitting or authorization responsibilities.
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Even though EPA is the lead agency, this EA has been developed to support multiple federal
decisions/actions related the proposed project. By developing a single NEPA document, the EPA and
USACE are streamlining the NEPA process for this proposed project.
1.9 Documents incorporated by reference
The NEPA implementing regulations direct agencies to develop succinct NEPA documents and
incorporate material by reference when appropriate without impeding agency and public review of the
action (see 40 CFR Section 1502.21). Therefore, the EPA is incorporating the following documents and
references for this EA:
•	NOAA Fisheries' 2008 Programmatic Environmental Impact Statement (PEIS), NMFS
proposed regional regulations: Fishery Management Plan to Promote and Manage Marine
Aquaculture within the Gulf of Mexico Exclusive Economic Zone.
•	USEPA Region 4's 2016 Environmental Assessment (EA) for National Pollutant Discharge
Elimination System (NPDES) Permit for Eastern Gulf of Mexico Offshore Oil and Gas
Exploration, Development, and Production
•	NOAA Fisheries' 2016 final rule: the FMP for Regulating Offshore Aquaculture in the Gulf of
Mexico
•	40 CFR Part 6 - Procedures for Implementing the National Environmental Policy Act and
Assessing the Environmental Effects Abroad of EPA Actions.
•	2016 Interagency Memorandum of Understanding for Permitting Offshore Aquaculture
Activities in Federal Waters of the Gulf of Mexico.
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•natives
On November 9, 2018, the EPA Region 4 Office received a complete application from the applicant,
requesting NPDES permit coverage for discharges from an offshore aquaculture project in federal
waters of the Gulf. If approved, the NPDES authorization would allow for the discharge containing
pollutants from a point source the proposed offshore aquaculture project into the Gulf.
On November 10, 2018, a DA application was submitted to USACE Jacksonville District for the
proposed project pursuant to Section 10 which requires prior authorization for structures and work in,
over, under, and affecting navigable waters. This offshore aquaculture project represents one of the first
proposed projects of its type in the Gulf.
2.1	Alternatives Considered
The EPA and the USACE are considering two alternatives for the proposed VE project in this EA.
Alternatives considered include a No Action Alternative (Alternative 1) and issuance of a NPDES
permit and USACE Section 10 permit for the facility (Alternative 2).
2.1.1	Alternative 1 —No Action
Under the no-action alternative, the EPA would not issue a NPDES permit, and the USACE would not
issue a DA authorization for the proposed the VE project. The effects of the no action alternative are
described in Chapter 3, Affected Environment, in which no structures or pens would exist at the site
location.
2.1.2	Alternative 2 —Issuance	. Permit and Section 10 Authorization
Under Alternative 2, the EPA would issue a NPDES permit and the USACE would issue a Section 10
DA authorization for the proposed VE project. This Alternative complies with the statutory requirements
of the CWA and with the requirements of Section 10 of the Rivers and Harbors Act.
2.2	Alternatives Considered but Eliminated from Detailed Study
As discussed in Section 1.6 Site Selection, multiple sites were considered for the proposed project site.
An extensive screening process was undertaken by the applicant to evaluate these alternative sites. Sites
originally considered but identified in the BES (Appendix A) as non-viable were eliminated from further
consideration for not meeting the necessary criteria. For the purposes of NEPA, these alternative sites
have been eliminated for consideration by the EPA and USACE and are not carried forward for analysis
in this EA.
2.3	Factors Used to Develop and Screen Alternatives
As required by 40 CFR Section 1502.14, the EPA is required to rigorously explore and objectively
evaluate all reasonable alternatives, and for alternatives which were eliminated from detailed study,
briefly discuss the reasons for elimination. The EPA is also required to devote substantial treatment to
each alternative considered in detail including the proposed action so that reviewers may evaluate their
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comparative merits. In addition, the EPA must include reasonable alternatives not within the jurisdiction
of the lead agency and include the alternative of no action.
As required by 40 CFR Section 1502.14(a), USACE is required to consider only reasonable alternatives
in detail. Reasonable alternatives must be those that are feasible and such feasibility must focus on the
accomplishment of the underlying purpose and need (of the applicant) that would be satisfied by the
proposed federal action (permit issuance). The alternatives analysis should be thorough enough to use
for the public interest review.
As part of the NEPA process, the EPA and USACE must identify the agency's preferred alternative or
alternatives, if one or more exists, in the draft statement and identify such alternative in the final
statement unless another law prohibits the expression of such a preference. The EPA must also include
appropriate mitigation measures not already included in the proposed action or alternatives.
The EPA and USACE have included both action and no action alternatives in this EA. We provide
rationale for alternatives eliminated for additional study in this Chapter. We provide a detailed
discussion on the proposed action and the levels of impacts compared to the no action alternative in
Chapters 4. Chapter 5 describes cumulative impacts in the context of the proposed action. Chapter 6
provides the agency preference and rationale for the preferred alternative. Protective measures and
mitigation measures for the proposed action are described throughout this EA and all supporting
documents.
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3.0 Affe cte d Environment
3.1	Introduction
This chapter describes the existing environment potentially affected by the proposed action through
issuance of required federal permits and authorizations. The current status of each potentially affected
resource is discussed below, including: physical resources (Section 3.2), biological resources (Section
3.3), and social and economic environment (Section 3.4). This chapter describes the potentially affected
resources prior to the proposed action as a point of comparison for evaluating the consequences or
impacts resulting from the proposed action. Resources that are not expected to be impacted (e.g.
wetlands) by the proposed action are not discussed in this chapter and therefore are not carried forward
for analysis.
The discussion in this section is primarily focused on the proposed location for the VE project, which is
in the eastern Gulf (west Florida Shelf) approximately 45 miles southwest of Sarasota, Florida. The
applicant will utilize existing land-side facilities such as boat docks and hatcheries for all other aspects
that are not analyzed in this section.
The EPA used several sources of information to develop this chapter including but not limited to the
Final Environmental Assessment, National Pollutant Discharge Elimination System (NPDES) Permit for
Eastern Gulf of Mexico Offshore Oil and Gas Exploration, Development, and Production, 2016. The
Evaluation of the Ocean Discharge Criteria (ODCE) in Appendix C, Kampachi Farms - Velella Epsilon
Net Pen Fish Culture Facility and the NPDES Permit [FL0A00001] Outer Continental Shelf, Gulf of
Mexico, and Draft Biological Evaluation - Kampachi Farms, LLC - Velella Epsilon, Marine
Aquaculture Facility, Outer Continental Shelf Federal Waters of the Gulf of Mexico, March 15, 2019 in
Appendix D provide expanded discussions on the physical and biological environments in the eastern
Gulf and the general area of the proposed VE project.
3.2	Physical Resources
Ocean currents on the west coast of Florida were studied for 308 days at the Tampa Ocean Dredged
Material Disposal Site (ODMDS), located approximately 18 miles west of Tampa Bay, approximately
27-meters (m) deep, during the 2008-2009 time period (EPA, 2012). Measured currents in this study are
consistent with previous studies at the Tampa ODMDS in the 1980s revealing that currents flowed
predominately to the south and southeast with mean near bottom current velocities between 5 and 8
cm/sec. Ocean currents were also measured at a NOAA buoy (Station 42022) located along the 50-meter
isobath approximately 45 miles north-east of the project location from 2015 to 2018. Currents at this
location average 3-5 centimeters per second (cm/sec) higher than at the Tampa ODMDS. Currents at
both locations were shown to have a dominant southerly direction in the winter and northerly direction
in the summer consistent with circulatory current patterns of the eastern Gulf. Tides can dominate the
currents at the Tampa ODMDS, but most often they are dominated by other forces (e.g. surface winds
and the Gulf Loop Current). Tidal influence should be less pronounced further offshore.
Offshore habitats in the proposed project area include the water column and the sea floor. The west
Florida Shelf extends seaward of Sarasota Bay approximately 200 kilometer (km) to a depth of 200 m
and consists mainly of unconsolidated sediments punctuated by low-relief rock outcroppings and several
series of high relief ridges. The seafloor on the west Florida Shelf in the proposed project area consists
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mainly of course to fine grain sands with scattered limestone outcroppings making up about 18 percent
of the seafloor habitat. These limestone outcroppings provide substrata for the attachment of
macroalgae, stony corals, octocorals, sponges and associated hard-bottom invertebrate and reef fish
communities (EPA, 1994). Unconsolidated (soft) sediments provide habitat for benthic
macroinvertebrate communities, consisting of several hundred species and provide an important source
of forage for benthic and demersal fishes and shellfish.
3.2.1 Water Quality
Water quality studies have been conducted at the Tampa ODMDS, located approximately 18 miles west
of Tampa Bay. During a 2013 EPA Status and Trends study of the Tampa ODMDS the following water
quality parameters in the water column were evaluated: conductivity, dissolved oxygen (DO), salinity,
temperature, density; and turbidity and conducted laboratory analysis for nutrients, metals, polyaromatic
hydrocarbons (PAHs), polychlorinated biphenyls (PCBs), pesticides and butyltins. Temperatures
recorded ranged from 29.77 to 29.98 degrees Centigrade (°C), while salinity ranged from 35.47 to 35.88
parts per thousand (ppt), DO ranged from 5.99 to 6.19 mg/L, and density ranged from 22.14 to 22.99
sigma-T.
The results from chemical analyses of the water samples collected during that study revealed, with the
exception of six metals, all other analytes were either not detected at or above the reporting limit or the
reported values were flagged as estimates. The six detected metals and their range of values (in
micrograms per liter or ug/L) are arsenic (1.0 - 1.09), chromium (0.21 -0.49), copper (0.119 -0.139),
lead (0.025), nickel (0.21 - 1.74), and zinc (0.53 - 1.47). All of these values are below levels of concern.
3.2.1.1	Deepwater Horizon Spill
On April 20, 2010, the Deepwater Horizon (DWH) oil drilling rig operating 47 miles southeast of
Louisiana in the Mississippi Canyon Block 252 of the Gulf, exploded and sank killing 11 workers and
releasing the largest marine oil spill disaster in the U.S. history of marine oil drilling operations. Four
million barrels of oil flowed over an 87-day period from the damaged Macondo oil well, before the well
was finally capped on July 15, 2010 (EPA, 2017). The oil spill's surface extent exceeded 19,305 square
miles and ranged from central Louisiana to the Florida Panhandle (EPA, 2017). The Macondo well is
located more than 300 miles North/Northwest of the proposed location of the VE project. The Final
Programmatic Damage Assessment and Restoration Plan (PDARP) and Final Programmatic
Environmental Impact Statement (PEIS) describes the impacts of DWH and can be found at:
http://www.gulfspillrestoration.noaa.gov/restoration-planning/gulf-plan/.
3.2.1.2	Red Tide Outbreaks
During the month of October 2017, a bloom of the Florida red tide organism, Karenia brevis, broke out
in Southwest Florida and extended from Pinellas to northern Collier counties, along approximately 145
miles of coastline at its height. The bloom persisted for over a year and resulted in large scale fish kills,
as well as sea turtle and manatee mortality. A state of emergency was declared for seven Florida
counties, including Lee, Collier and Charlotte, due to the impact of red tide. Karenia brevis is still
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occurring in several locations along the coast. Updates on red tide occurrence off the west coast of
Florida can be found online.3
Nutrient addition to the Gulf is of concern because they contribute to harmful algal blooms (HABs).
HABs are on the rise in frequency, duration, and intensity in the Gulf, largely because of human-induced
activities (Corcoran, Dornback, Kirkpatrick, & Jochens, 2013). Of the more than 70 HAB species
occurring in the Gulf, the best-known is the red tide organism, Karenia brevis, which blooms frequently
along the west coast of Florida. Macronutrients, micronutrients and vitamins characteristic of fish farms
can be growth-promoting factors for phytoplankton. However, a NPDES permit is being issued with
conditions to monitor the discharge and protect water quality. The overall pollutant loading of the
project should be minimal given the small production levels. Additionally, it is not expected that
aquaculture-related pollutants will be measured in the water within 30 meters from the project.
The primary nutrients of interest in relation to open ocean aquaculture are nitrogen and phosphorus; both
may cause excess growth of phytoplankton and lead to aesthetic and water quality problems. Generally,
in marine waters, phytoplankton growth is either light or nitrogen limited, and phosphorus is not as
critical a nutrient as it is in fresh water (Ryther, 1971; Welch, 1980). However, it has been shown that
because nutrient fluctuations in the Gulf can be significant due to the large inputs from river systems,
both nitrogen limitation and phosphorus limitation can happen concurrently in different locations
(Turner & Rabalais, 2013).
3.2.1.3 Pharmaceuticals
Diseases may occur in net-pen systems because water moves freely between net-pens and the open
marine environment, allowing the transmission of pathogens between wild and farmed fish (Rust, et al.,
2014). Fish diseases occur naturally in the wild, but their effects often go unnoticed because moribund
or dead animals quickly become prey for other aquatic animals. Clinical disease occurs only when
sufficient numbers of pathogens encounter susceptible fish under environmental conditions that are
conducive to disease (Rose, Ellis, & Munro, 1989). Fisheries managers are concerned about the risk of
pathogen amplification on farms followed by transmission of pathogens from farmed to wild fish, as
well as the introduction of nonnative pathogens and parasites when live fish are moved from region to
region. Aquaculture facilities may use a number of measures, including vaccines, probiotics, limiting
culture density, high-quality diets, and use of antibiotics, which are effective at preventing and
controlling bacterial diseases. Antibiotics are considered a method of last resort and are being replaced
by other sound management approaches.
3.2.2 Sediment Quality
The EPA (EPA, 2014) analyzed sediments at the Tampa ODMDS for the following parameters: particle
size, total organic carbon, heavy metals, nutrients including total phosphorous (TP), NO2+NO3 (Nitrites
and nitrates), NH3 (Ammonia), and Total Kjeldahl Nitrogen (TKN), and extractable organic compounds
(e.g., Polyaromatic hydrocarbons or PAHs), pesticides, and Polychlorinated biphenyls or PCBs).
3 http://www.myfwc.com/RedTideStatus.
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All stations were shown to be predominantly sand, ranging from a low of 73.4 % sand to a high of 97.3
% sand. Silt/clay fractions ranged from 0.3 to 26.7 %. Total organic carbon (TOC) results ranged from
0.18 - 0.38 %. The amount of percent solids found for the Tampa ODMDS samples ranged from 68.3 -
82.4 %. The sediment chemistry showed all contaminants, except for metals, to be at or below detection
limits. For the thirteen metals analyzed, nine were found to be detectable at one or more sample
locations. However, the very low concentration results were not of a significant concern. This sediment
data represents the best available information for sediment quality in the region of the proposed action.
3.2.3 Air Quality
In the vicinity of the proposed action, Section 328 of the Clean Air Act Amendments of 1990 (CAA)
authorized EPA to establish air-emission control requirements for Outer Continental Shelf (OCS)
sources located off Florida's Gulf coast eastward of the 87°30' W longitude. The purpose of these air-
control requirements is the attainment and maintenance of federal and state ambient air quality standards
and the compliance with the CAA's provisions to prevent significant deterioration of air quality. The
EPA Region 4 currently administers the air quality program in the eastern Gulf and the Department of
Interior (DOI) is authorized to regulate air emissions in the western Gulf west of 87°30' W longitude
(EPA, 2016).
The CAA requires the EPA to set National Ambient Air Quality Standards (NAAQS) for six common
air pollutants (criteria air pollutants) to protect human health and welfare (EPA, 2018a). NAAQS have
been designated for these six criteria pollutants: carbon monoxide, ozone, sulfur dioxide, nitrogen
dixoide, Particulate Matter (PM) 10, PM2.5, and lead (EPA, 2018b). The EPA is required to designate
areas that meet (attainment) or do not meet (nonattainment) these 6 NAAQS to ensure compliance with
air quality standards. Additionally, the CAA requires states to develop a general plan (State
Implementation Plans) to attain and maintain the NAAQS. For those areas in nonattainment with
NAAQS, the states are required to develop a specific plan to achieve attainment for all standards
responsible for an area's nonattainment status (EPA, 2018c).
The Gulf has no fixed air quality monitoring stations. Beyond the states' seaward boundaries, the Gulf is
listed as unclassified with respect to NAAQS attaintment. Consequently, the only available air quality
data relevant to the Gulf is that data collected by the states of Mississippi, Alabama, and Florida's Gulf
coastal counties. The comparison of year 2014 to 2005 air quality data for the coastal counties for these
three states indicate that the overall air quality has improved. The only non-attainment area along the
Gulfs central and eastern coast is the greater Tampa/St Petersburg area within Hillsborough County,
Florida (EPA, 2016).
When any new source of air-pollutant emissions meeting a major status is located within an area
designated as unclassifiable with respect to the NAAQS, such as the Gulf, the CAA's Prevention of
Significant Deterioration (PSD) provisions are triggered. These provisions include: the installation of the
"Best Available Control Technology" (BACT); an air quality analysis; an additional impacts analysis;
and public involvement (EPA, 2018d).
The purpose of the PSD provisions is to assure that any decision to permit increased air pollution in
certain areas is made only after careful evaluation of all the consequences of such a decision and after
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adequate procedural opportunities for informed public participation in the decision making process. The
focus is to protect the public health and welfare; preserve, protect, and enhance the air quality in Class I
areas, such as areas of special national or regional natural, recreational, scenic, or historic value,
including national parks, national wilderness areas, national monuments, and national seashores; and
insure that economic growth will occur in a manner consistent with the preservation of existing clean air
resources. The closest Class I area to the vicininty of the proposed action is the Breton National Wildlife
Refuge (NWR) and Wilderness area offshore southeastern Louisiana near the seaward boundaries of
Mississippi and Alabama (EPA, 2016). The Refuge is comprised of a series of barrier islands including
Breton Island and the Chandeleur Islands in the Gulf.
3.2.4	Coastal Barrier Beaches
The Gulf is characterized by a broad spectrum of sediments, sediment transport processes, and
environments that vary along the spectrum from coastal shores to deep water. Waves, tides, currents,
and gravity are the primary transporters of sediments. The coastal sedimentary environments include:
beaches, tidal inlets, tidal flats, wetlands, and estuaries that are dominated by sediments originating from
land (terrigenous sediments) (Ward, 2017). The proposed action is to be located in approximately 40 m
water depth off southwest Florida, generally located approximately 45 miles west, southwest of
Longboat Pass-Sarasota Bay, Florida. There are several coastal barrier islands 1-2 miles off shore and in
the vicinity of Sarasota to include Siesta Key, Lido Key, Long Boat key, Manasota Key, etc. The islands
are highly developed with residential and businesses catering to tourism and recreation.
3.2.5	Noise Environment
The proposed project is located on the west Florida Shelf, approximately 45 miles southwest Sarasota,
Florida in federal waters. Ambient noise from wind, waves, and periodic noise from occasional boat and
vessel traffic are expected. The facility is not expected to make a significant contribution to ambient
noise and to current open operation noise.
3.2.6	Climate
The effect of ongoing human-caused climate change makes the Gulf environment vulnerable to rising
ocean temperatures, sea level rise, storm surge, ocean acidification, and significant habitat loss. Cores
from corals, ocean sediments, ice records, and other indirect temperature measurements indicate the
recent rapid increase of ocean temperature is the greatest that has occurred in at least the past
millennium and can only be reproduced by climate models with the inclusion of human-caused sources
of heat-trapping gas emissions. While the long-term global sea surface temperature pattern is clear, there
is considerable variability in the effects of climate change regionally and locally because oceanographic
conditions are not uniform and are strongly influenced by natural climate fluctuations (Doney, et al.,
2014).
Certain areas along the Atlantic and Gulf coasts are undergoing relatively rapid sea water inundation and
associated landscape changes because of the prevalence of low-lying coastal lands in combination with
altered hydrology and land subsidence. The combination of sea level rise and land subsidence is forecast
to result in various changes in the distribution and abundance of coastal wetlands and mangroves, which
could damage habitat functions for many important fish and shellfish populations (BOEM, 2016).
Shellfish populations also are at risk from ocean acidification. Increases in water temperatures will alter
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the seasonal growth and geographic range of harmful algae and certain bacteria, such as Vibrio
parahaemolyticus, which was responsible for human illnesses associated with oysters harvested from the
Gulf and northern Europe (Doney, et al., 2014).
3.3 Biological Resources
Biological resources refer to plant and animal communities and associated habitat that they comprise or,
that provides important support to critical life stages. This section focuses primarily on the biological
resources occurring in the eastern Gulf and in the area of the proposed VE project. The following sub-
sections provide a discussion on the biological setting of the eastern Gulf and resources such as birds,
reptiles, fish, marine mammals, marine invertebrates, plants, and fish species that may occur in the
project area.
The west Florida Shelf extends seaward of Sarasota Bay approximately 200 km to a depth of 200 m and
consists mainly of unconsolidated sediments punctuated by low-relief rock outcroppings and several
series of high relief ridges. The seafloor on the west Florida Shelf in the immediate vicinity of the
proposed project area consists mainly of course to fine grain sands with scattered limestone
outcroppings making up about 18% of the seafloor habitat. These limestone outcroppings provide
substrata for the attachment of macroalgae, stony corals, octocorals, sponges and associated hard-bottom
invertebrate and fish communities (EPA, 1994).
A 2010 survey of the Tampa ODMDS site 18 miles west of Tampa Bay, (70 miles northeast of the
proposed VE site) showed that the dominant substrata at the natural bottom sites in the area consisted of
sand, live coral, coralline algae, sponge, hydroid, octocorals, rubble, macro algae rock, and turf algae.
Macro invertebrate counts at the natural bottom sites were dominated by gastropods, crabs, sea urchins,
bivalves and several scelacterian corals including, Blushing star coral (Stephanocoenia intersepta), Tube
coral (Cladocora arbuscular), Smooth star coral (Solenastrea bournoni), Thin finger coral (Porites
divaricate), solitary disc corals such as Scolymias, and the Sinuous cactus coral (Isophyllia sinuosa).
3.3.1 Fish
The Gulf of Mexico has a diverse ichthyofaunal community consisting of more than 1400 finfish
species, over 51 shark species, and at least 49 species of rays and skates. About 900 marine fishes
occur off the west Florida coast, occupying all benthic and pelagic habitats, including many managed
fish stocks of great commercial and recreational importance. There are also a number of fish species
that are protected under the ESA.
Of the ESA-listed fish species, only the Smalltooth sawfish (Pristis pectinate), Giant manta ray (Manta
biros/ris), and Oceanic whitetip shark (Carcharhinus longimanus), may occur in the vicinity of the VE
project and the presence of even these species is likely rare. The aquaculture facility proposed sites are
more than 250 miles south of the Suwannee River, the southernmost river with a reproducing population
of Gulf sturgeon (Acipenser oxyrinchus desotoi). There are rare captures of Gulf sturgeon in the bays,
estuaries, and nearshore Gulf off Tampa Bay and Charlotte Harbor during the cool winter months, but
no reported captures in offshore waters. Nassau grouper (Epinephelus striatus), also listed under ESA,
are generally absent from the Gulf north and outside of the Florida Keys; this is well documented by the
lack of records in Florida Fish and Wildlife Conservation Commission's, Fisheries Independent
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Monitoring data as well as various surveys conducted by NOAA Fisheries Southeast Fisheries Science
Center (SEFSC). Based on this information, we believe both Gulf sturgeon and Nassau grouper will not
be present.
The smalltooth sawfish is a tropical marine and estuarine elasmobranch. Smalltooth sawfish primarily
occur in the Gulf off peninsular Florida and are most common off Southwest Florida and the Florida
Keys. There are distinct differences in habitat use based on life history stage as the species shifts use
through ontogeny. Juvenile smalltooth sawfish less than 220 cm, inhabit the shallow euryhaline waters
(i.e., variable salinity) of estuaries and can be found in sheltered bays, dredged canals, along banks and
sandbars, and in rivers (NMFS, 2000). As juveniles increase in size, they begin to expand their home
ranges (Simpfendorfer, Wiley, & Yeiser, 2010; Simpfendorfer, et al., 2011), eventually moving to more
offshore habitats where they likely feed on larger prey as they continue to mature. While adult
smalltooth sawfish may also use the estuarine habitats used by juveniles, they are commonly observed in
deeper waters along the coasts. Poulakis and Seitz (2004) noted that nearly half of the encounters with
adult-sized smalltooth sawfish in Florida Bay and the Florida Keys occurred in depths from 200-400 ft
(70-122 m) of water. Similarly, Simpfendorfer and Wiley (2005) reported encounters in deeper waters
off the Florida Keys, and observations from both commercial longline fishing vessels and fishery-
independent sampling in the Florida Straits report large smalltooth sawfish in depths up to 130 ft (-40
m) (International Sawfish Encounter Database, 2014). Even so, NMFS believes adult smalltooth sawfish
use shallow estuarine habitats during parturition (when adult females return to shallow estuaries to pup)
because very young juveniles still containing rostral sheaths are captured in these areas. Since very
young juveniles have high site fidelities, they are likely birthed nearby or in their nursery habitats.
Smalltooth sawfish feed primarily on teleost and elasmobranch fishes at all lifestages even though
sawfish move from estuarine to coastal habitats during their ontogeny (Poulakis, et al., 2017).
The Oceanic whitetip shark is a large open ocean highly migratory apex predatory shark found in
subtropical waters around the globe. It is usually found offshore in the open ocean, on the OCS or
around oceanic islands in deep water greater than 184 m, occurring from the surface to at least 152 m
depth. Occasionally, it is found close to land, in waters as shallow as 37 m (-120 ft.), mainly around
mid-ocean islands, or in areas where the continental shelf is narrow with access to nearby deep water.
Oceanic whitetip sharks feed mainly on teleosts and cephalopods (Backus, Springer, & Arnold, 1956;
Bonfil, Clarke, & Nakano, 2008), but studies have also reported that they consume sea birds, marine
mammals, other sharks and rays, mollusks, crustaceans, and even garbage (Compagno, 1984; Cortes,
1999). Backus, Springer, and Arnold (1956) recorded various fish species in the stomachs of oceanic
whitetip sharks, including blackfin tuna, barracuda, and white marlin. The available evidence also
suggests that oceanic whitetip sharks are opportunistic feeders.
On January 22, 2018, NOAA Fisheries published a final rule listing the giant manta ray (Manta
birostris) as threatened under the ESA effective February 21, 2018 (83 FR 2916). The giant manta ray is
the largest living ray, with a wingspan reaching a width of up to 9 m (29.5 ft), and an average size
between 4-5 m (15-16.5 ft). The giant manta ray is found worldwide in tropical subtropical, and
temperate seas. These slow-growing, migratory animals are circumglobal with fragmented populations.
Giant manta rays make seasonal long-distance migrations, aggregate in certain areas and remain
resident, or aggregate seasonally (Dewar, et al., 2008; Graham, et al., 2012; Girondot, et al., 2015;
Stewart, Hoyos-Padilla, Kumli, & Rubin, 2016). Giant manta rays are seasonal visitors along productive
coastlines with regular upwelling, in oceanic island groups, and near offshore pinnacles and seamounts.
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The timing of these visits varies by region and seems to correspond with the movement of zooplankton,
current circulation and tidal patterns, seasonal upwelling, seawater temperature, and possibly mating
behavior .They have also been observed in estuarine waters near oceanic inlets, with use of these waters
as potential nursery grounds (Adams & Amesbury, 1998; Milessi & Oddone, 2003; Medeiros, Luiz, &
Domit, 2015; Pate). Giant manta rays primarily feed on planktonic organisms such as euphausiids,
copepods, mysids, decapod larvae and shrimp, but some studies have noted their consumption of small
and moderately sized fishes (Miller & Klimovich, 2017). When feeding, giant manta rays hold their
cephalic lobes in an "O" shape and open their mouth wide, which creates a funnel that pushes water and
prey through their mouth and over their gill rakers. They use many different types of feeding strategies,
such as barrel rolling (doing somersaults repeatedly) and creating feeding chains with other mantas to
maximize prey intake.
3.3.2	Invertebrates
Of the more than 15,000 species of animals in the Gulf of Mexico, more than 13,000 are invertebrates.
Like fishes, marine invertebrates are distributed throughout the Gulf and they occupy all marine habitats.
Some species of crabs, shrimps and lobster, etc., make up important managed fishery stocks and several
invertebrate species are protected under ESA.
Marine invertebrates currently protected under ESA include a number of species of stony coral (i.e.,
Elkhorn (Acroporapalmata), Staghorn (Acropora cervicornis), Pillar (Dendrogyra cylindrus), Rough
cactus coral (Mycetophyllia ferox), Lobed star (Orbicella annularis), Mountainous star (Orbicella
faveolata), and Boulder star (Montastrea annularis). The listed coral species do not occur in or near the
VE project. Of the seven ESA-listed coral species in the Gulf, four (Elkhorn, Lobed star, Mountainous
star, and Boulder star) are known to occur in the Flower Banks National Marine Sanctuary, located 70 to
115 miles off the coast of Texas and Louisiana and all seven are known to occur near the Dry Tortugas,
a small group of islands located in the Gulf approximately 67 miles west of Key West, Florida.
3.3.3	Marine Mammals
There are 22 marine mammal species protected by the MMPA occurring in the Gulf, a manatee (under
Fish and Wildlife Service jurisdiction) and 21 cetacean species (dolphins and whales; all under NOAA
Fisheries' jurisdiction). Two of the marine mammals, Sperm whales (Physeter macrocephalus) and
manatees (genus Trichechus), have been protected under the ESA for many years and an unnamed
subspecies, the Gulf Bryde's whale (Balaenoptera edeni), was just listed as endangered under the ESA
(81 FR 88639).
The manatee species in the Gulf, Western Indian Manatee (Trichechus manatus) does not travel into
offshore waters of the VE project area. In contrast, most of the Gulf cetacean species reside in the
oceanic habitat (greater than or equal to 200 m). However, the Atlantic spotted dolphin (Stenella
frontalis) is found in waters over the continental shelf (10 m-200 m), and the Common bottlenose
dolphin (Tursiops truncatus truncatus) (hereafter referred to as Bottlenose dolphin) is found throughout
the Gulf, including within bays, sounds, and estuaries; coastal waters over the continental shelf; and in
deeper oceanic waters. Consequently, Bottlenose dolphins and Atlantic spotted dolphins are the most
likely marine mammal species that overlap with the facility's proposed sites. There are other marine
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mammal species that may overlap with the facility's proposed site, but these marine mammals are not
known to use this habitat regularly or are likely extralimital or occasional migrants.
Bottlenose dolphins in the Gulf can be separated into demographically independent populations called
stocks. Bottlenose dolphins are currently managed by NOAA Fisheries as 36 distinct stocks within the
Gulf. These include 31 bay, sound and estuary stocks, three coastal stocks, one continental shelf stock,
and one oceanic stock (Hayes, Josephson, Maze-Foley, & Rosel, 2017). Marine Mammal Stock
Assessment Reports and additional information on these species in the Gulf are available on the NOAA
Fisheries Office of Protected Species website: http://www.nmfs.noaa.gov/pr/sspecies/.
The Bottlenose dolphin stock that overlaps with this action is the Northern Gulf continental shelf stock.
The best abundance estimate for this stock is 51,192 with a resulting potential biological removal4 of
469 (Waring, Josephson, Maze-Foley, & Rosel, 2016). This stock of dolphins inhabits waters from 20 m
to 200 m deep from U.S.-Mexican border to the Florida Keys (Waring, Josephson, Maze-Foley, &
Rosel, 2016). Threats to this stock include fisheries entanglements (e.g., shark bottom hook and line and
bottom longline, snapper-grouper and other reef fish bottom longline and hook and line, and trawl
fisheries for Butterfish (Peprilus triacanthus) and shrimp) that can result in serious injury or death
(Waring, Josephson, Maze-Foley, & Rosel, 2016).
The Atlantic spotted dolphin occurs primarily from continental shelf waters 10 m to 200 m deep to slope
waters (Fulling et al., 2003; Mullin and Fulling, 2004; Maze-Foley and Mullin, 2006). The most recent
best abundance estimate for this stock is 37,611. However, the potential biological removal is currently
unknown given the lack of more current population surveys (Waring, Josephson, Maze-Foley, & Rosel,
2016). There tends to be a concentration of these animals over the Florida Shelf in the eastern Gulf and
stretched westward to the Florida panhandle (Waring, Josephson, Maze-Foley, & Rosel, 2016). It has
been suggested that this species may move inshore seasonally during the spring, but data supporting this
proposition are limited (Caldwell & Caldwell, 1966; Fritts, et al., 1983). Threats to this stock include
fisheries entanglements (e.g., pelagic longline and shrimp trawl gear) that can result in serious injury or
death (Waring, Josephson, Maze-Foley, & Rosel, 2016).
3.3.4 Sea Turtles
Green sea turtles (Chelonia mydas) North Atlantic and South Atlantic district population segments
(DPSs), Hawksbill (Eretmochelys imbricate), Kemp's ridley (Lepidochelys kempii), Leatherback
(Dermochelys coriacea), and Loggerhead (Caretta Caretta-Northwest Atlantic DPS) sea turtles are all
highly migratory and travel widely throughout the Gulf. Several volumes exist that cover the biology
and ecology of these species (Lutz & Musick, 1997; Lutz, Musick, & Wyneken, 2003; Wyneken,
Lohmann, & Musick, 2013). Sea turtles are primarily diurnal and feed and rest intermittently during a
typical day. Sea turtles can spend their nights sleeping at the surface while in deep water or on the
bottom wedged under rocks in nearshore waters. Many divers have seen green turtles sleeping under
4 The potential biological removal (PBR) level is defined by the MMPA as the maximum number of animals, not including natural mortalities, that may be
removed from a marine mammal stock while allowing that stock to reach or maintain its optimum sustainable population. The PBR level is the product of
the following factors—
•	The minimum population estimate of the stock;
•	One-half the maximum theoretical or estimated net productivity rate of the stock at a small population size; and
•	A recovery factor of between 0.1 and 1.0.
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ledges in reefs and rocks. Hatchlings typically sleep floating on the surface, and they usually have their
front flippers folded back over the top of their backs.
Green sea turtle hatchlings occupy pelagic areas of the open ocean and are often associated with
Sargassum rafts (Carr A., 1987; Walker, 1994). Pelagic stage Green sea turtles are thought to be
carnivorous. Stomach samples of these animals found ctenophores and pelagic snails (Frick, 1976;
Hughes, 1974). At approximately 20 cm to 25 cm carapace length, juveniles migrate from pelagic
habitats to benthic foraging areas (Bjorndal, 1997). As juveniles move into benthic foraging areas a diet
shift towards herbivory occurs. They consume primarily seagrasses and algae, but are also known to
consume jellyfish, Sea salps, and sponges (Bjorndal, 1980; Bjorndal, 1997; Paredes, 1969; Mortimer,
1981; Mortimer, 1982). During the day, green turtles occupy shallow flats and seagrass meadows. In the
evening, they return to their sleeping quarters of rock ledges, oyster bars and coral reefs. The diving
abilities of all sea turtle species vary by their life stages. The maximum diving range of Green sea turtles
is estimated at 110m (360 ft.) (Frick, 1976), but they are most frequently making dives of less than 20 m
(65 ft.) (Walker, 1994). The time of these dives also varies by life stage. The maximum dive length is
estimated at 66 minutes, with most dives lasting from nine to 23 minutes (Walker, 1994). NOAA
Fisheries and FWS removed the range-wide and breeding population ESA listings of the Green sea turtle
and listed eight DPSs as threatened and three DPSs as endangered, effective May 6, 2016. Two of the
Green sea turtle DPSs, the North Atlantic DPS and the South Atlantic DPS, occur in the Gulf and are
listed as threatened.
The Hawksbill sea turtle's pelagic stage lasts from the time they leave the nesting beach as hatchlings
until they are approximately 22-25 cm in straight carapace length (Meylan A. , 1988; Meylan &
Donnelly, 1999). The pelagic stage is followed by residency in developmental habitats (foraging areas
where juveniles reside and grow) in coastal waters. Little is known about the diet of pelagic stage
Hawksbills. Adult foraging typically occurs over coral reefs, although other hard-bottom communities
and mangrove-fringed areas are occupied occasionally. Hawksbills show fidelity to their foraging areas
over several years (van Dam & Diez, 1998). The Hawksbill's diet is highly specialized and consists
primarily of sponges (Meylan A. , 1988). Gravid (pregnant) females have been noted ingesting coralline
substrate (Meylan A., 1984) and calcareous algae (Anderes Alvarez & Uchida, 1994), which are
believed to be possible sources of calcium to aid in eggshell production. The maximum diving depths of
these animals are unknown, but the maximum length of dives is estimated at 73.5 minutes, more
routinely dives last about 56 minutes (Hughes, 1974).
Kemp's ridley sea turtle hatchlings are also pelagic during the early stages of life and feed in surface
waters (Carr A. , 1987; Ogren, 1989). After the juveniles reach approximately 20 cm carapace length
they move to relatively shallow (less than 50m) benthic foraging habitat over unconsolidated substrates
(Marquez, 1994). They have also been observed transiting long distances between foraging habitats
(Ogren, 1989). Adult and sub-adult Kemp's ridleys primarily occupy nearshore habitats that contain
muddy or sandy bottoms where prey can be found. Kemp's ridleys feeding in these nearshore areas
primarily prey on crabs, though they are also known to ingest mollusks, fish, marine vegetation, and
shrimp (Shaver, 1991). The fish and shrimp Kemp's ridleys ingest are not thought to be a primary prey
item but instead may be scavenged opportunistically from bycatch discards or discarded bait (Shaver,
1991). Given their predilection for shallower water, Kemp's ridleys most routinely make dives of 50 m
or less (Soma, 1985; Byles, 1988). Their maximum diving range is unknown. Depending on the life
stage, a Kemp's ridley may be able to stay submerged anywhere from 167 minutes to 300 minutes,
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though dives of 12.7 minutes to 16.7 minutes are much more common (Soma, 1985; Mendonca &
Pritchard, 1986; Byles, 1988). Kemp's ridleys may also spend as much as 96% of their time underwater
(Soma, 1985; Byles, 1988).
Leatherback sea turtles are the most pelagic of all ESA-listed sea turtles and spend most of their time in
the open ocean. They will enter coastal waters and are seen over the continental shelf on a seasonal basis
to feed in areas where jellyfish are concentrated. Leatherbacks feed primarily on cnidarians (medusae,
siphonophores) and tunicates. Unlike other sea turtles, Leatherbacks' diets do not shift during their life
cycles. Because Leatherbacks' ability to capture and eat jellyfish is not constrained by size or age, they
continue to feed on these species regardless of life stage (Bjorndal, 1997). Leatherbacks are the deepest
diving of all sea turtles. It is estimated that these species can dive in excess of 1,000 m (Eckert, Eckert,
Ponganis, & Kooyman, 1989) but more frequently dive to depths of 50 m to 84 m (Eckert, Nellis,
Eckert, & Kooyman, 1986). Dive times range from a maximum of 37 minutes to more routines dives of
4 to 14.5 minutes (Standora, Spotila, Keinath, & Shoop, 1984; Eckert, Nellis, Eckert, & Kooyman,
1986; Eckert, Eckert, Ponganis, & Kooyman, 1989; Keinath & Musick, 1993). Leatherbacks may spend
74% to 91% of their time submerged (Standora, Spotila, Keinath, & Shoop, 1984).
Loggerhead sea turtle hatchlings forage in the open ocean and are often associated with Sargassum rafts
(Hughes, 1974; Carr A., 1987; Walker, 1994; Bolten & Balazs, 1995). The pelagic stage of these sea
turtles is known to eat a wide range of things including Sea salps, jellyfish, amphipods, crabs,
syngnathid fish, squid, and pelagic snails (Brongersma, 1972). Stranding records indicate that when
pelagic immature Loggerheads reach 40 cm to 60 cm straight-line carapace length, they begin to live in
coastal inshore and nearshore waters of the continental shelf throughout the U.S. Atlantic (Witzell W.,
2002). Here they forage over hard- and soft-bottom habitats (Carr A. , 1986). Benthic foraging
loggerheads eat a variety of invertebrates with crabs and mollusks being an important prey source
(Burke, Morreale, & Rhodin, 1993). Estimates of the maximum diving depths of Loggerheads range
from 211 m to 233 m (692-764 ft.) (Limpus & Nichols, 1988; Thayer, Bjorndal, Ogden, Williams, &
Zieman, 1984). The lengths of Loggerhead dives are frequently between 17 and 30 minutes (Thayer,
Bjorndal, Ogden, Williams, & Zieman, 1984; Limpus & Nichols, 1988; Limpus & Nichols, 1994;
Lanyon, Limpus, & Marsh, 1989) and they may spend anywhere from 80% to 94% of their time
submerged (Limpus & Nichols, 1994; Lanyon, Limpus, & Marsh, 1989).
Of the five sea turtles species, loggerheads are the most abundant on the west Florida shelf. The west
Florida shelf hard-bottom and live-bottom habitats provide long-term residence and foraging habitats for
juvenile and adult loggerheads. The West Florida Shelf provides residence areas for post-nesting
loggerheads from four of the five loggerhead recovery units identified by the NOAA Fisheries and the
USFWS in their recovery plan for the northwest Atlantic loggerhead population (NOAA and FWS,
2008). Those four recovery units are peninsular Florida (Girard, Tucker, & Calmettes, 2009; Phillips,
2011; Ceriani, Roth, Evans, Weishampel, & Ehrhart, 2012; Foley, et al., 2013), the Dry Tortugas (Hart,
et al., 2012), the northern Gulf of Mexico (Hart, et al., 2012; Foley, et al., 2013), and the northern
Atlantic (Mansfield, 2006; Griffin, et al., 2013).
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3.3.5 Birds
The marine and coastal birds that occur in the Gulf region for at least some portion of their life cycle are
generally classified as seabirds, shorebirds, wetland birds, waterfowl, passerines, and raptors (EPA,
2016).
Seabirds include gulls, terns, loons, frigate birds, pelicans, tropicbirds, cormorants, gannets, boobies,
storm-petrels, and shearwaters. They spend a large portion of their lives on or over seawater and may be
found both in offshore and coastal waters of the Gulf. They feed on fish and invertebrates; their temporal
occurrence varies greatly. Some seabirds, e.g., boobies, petrels, and shearwaters, only occur in open
ocean habitats, including deeper waters of the continental slope and basin. Most seabird species of the
Gulf are found in the continental shelf and adjacent coastal and inshore habitats.
Shorebirds include plovers, oystercatchers, stilts, avocets, and sandpiper. Shorebirds typically are small
wading birds that feed on invertebrates in shallow waters and along beaches, mudflats, and sand bars.
Shorebirds are generally restricted to coastline margins except when migrating. Shorebirds are generally
solitary or occur in small- to moderate-sized flocks, although large aggregations of several species can
occur during migration.
There are 14 federally-listed avian species identified as threatened or endangered, previously delisted, or
as candidate species in the eastern Gulf of Mexico. Three species are listed as threatened; eight species
are listed as endangered; and three species are delisted. Of those species, only two listed species are
considered in this EA because their behavior and range could expose them to activities covered under
the proposed action: Piping plover (iCharadrius melodus) and Red knot (Calidris canutus). See the
Biological Evaluation - Appendix D for more information. There are several other listed species whose
range includes inshore and coastal margin waters that are very unlikely to be exposed to the activities
covered under the proposed VE permit.
The Piping plover is a shorebird that inhabits coastal sandy beaches and mudflats. Critical habitat rules
have been published for Piping plover, including designations for coastal wintering areas in Florida. The
Piping plover is considered a state species of conservation concern in all Gulf coast states (BOEM,
2012a).
The Red knot, listed as threatened in 2014, is a highly migratory species travels between nesting habitats
in mid- and high-Arctic latitudes and southern non-breeding habitats in South America and the U.S.
Atlantic and Gulf of Mexico coasts (BOEM, 2012b). Red knots forage along sandy beaches, tidal
mudflats, salt marshes, and peat banks for bivalves, gastropods, and crustaceans (FWS, 2013).
Wintering Red knots are found primarily in Florida and is considered a State Species of Conservation
Concern.
3.3.6 Essential Fish Habitat
There are seven Gulf Fishery Management Plans (FMPs), covering a number of representative finfish
and shellfish species, which result in most of the landings from the Gulf. The FMPs or amendments to
the plans, provide the basis for management of fishery resources in the Gulf of Mexico by regulating the
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amount of fish that are harvested and are enforced by the U.S. Coast Guard, enforcement agents from
the NMFS, and the Gulf states.
Representative fish species from all FMPs occur in the area around the proposed VE site. In general,
reef fish are widely distributed in the Gulf, occupying both pelagic and benthic habitats during their life
cycle. Habitat types and life history stages can be found in more detail in (Gulf of Mexico Fishery
Management Council, 2004). Generally, both eggs and larval stages are planktonic with larvae feeding
on zooplankton and phytoplankton. Exceptions to these generalizations include the Gray triggerfish
(.Balistes capriscus) that lay their eggs in depressions in the sandy bottom, and Gray snapper (Lutjanus
griseus) whose larvae are found around submerged aquatic vegetation. Juvenile and adult reef fish are
typically demersal, and are usually associated with benthic features which offer some relief (i.e., coral
reefs, artificial reefs, rocky hard-bottom substrates, ledges and caves, sloping soft-bottom areas, and
limestone outcroppings).
The 2010 EPA Tampa ODMDS survey identified 29 species of demersal fishes associated with the high
relief habitat created by the dredged material spoil mound, with 14 species on nearby natural low-relief
hard bottom habitat. Abundances of fishes on natural low-relief hard bottom in the area were also
significantly smaller than on the spoil mound (EPA, 2011). Coastal pelagic fishes that are common to
the area include some commercially important groups of fishes including sharks, anchovies, herring,
mackerel, tuna, mullet, bluefish and cobia. Oceanic pelagic species occur at or seaward of the shelf edge
include many larger species such as sharks, tuna, bill fishes, dolphin and wahoo.
More extensive descriptions of fish communities in the eastern Gulf, and their associated habitat, can be
found in the ODCE for Kampachi Farms, - Velella Epsilon Net Pen Fish Culture Facility, Appendix C,
the Final Environmental Assessment, National Pollutant Discharge Elimination System (NPDES)
Permit for Eastern Gulf of Mexico Offshore Oil and Gas Exploration, Development, and Production,
2016, and the NOAA Fisheries' 2008 Programmatic Environmental Impact Statement (PEIS), NMFS
proposed regional regulations: Fishery Management Plan to Promote and Manage Marine Aquaculture
within the Gulf of Mexico Exclusive Economic Zone.
3.3.7	Deepwater Benthic Communities
Depending on the criteria used, deepwater and related deepwater biological communities in the Gulf are
generally defined as occurring in a range of depths from 200 -500 m (i.e., 656-1500 ft.). The proposed
VE site is located along the 40-45 m (120-135 ft.) depth range. Because depths equal to 200 m occur
approximately 130 miles off Sarasota, FL, deepwater benthic communities are not found near the
proposed site.
3.3.8	Live Bottoms
The seafloor on the west Florida shelf in the immediate vicinity of the proposed project area consists
mainly of course to fine grain sands with scattered limestone outcroppings making up about 18% of the
seafloor habitat. These limestone outcroppings provide substrata for the attachment of macroalgae, stony
corals, octocorals, sponges and associated hard-bottom invertebrate and fish communities (EPA, 1994).
A 2010 survey of the Tampa ODMDS site 18 miles west of Tampa Bay, (70 miles northeast of the
proposed VE site) showed that the dominant substrata at the natural bottom sites in the area consisted of
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sand, live coral, coralline algae, sponge, hydroid, octocorals, rubble, macro algae rock, and turf algae.
Macro invertebrate counts at the natural bottom sites were dominated by gastropods, crabs, sea urchins,
bivalves and several scleractinian corals identified in Section 3.3 Biological Resources.
3.3.9 Seagrasses
The west Florida coast, in both Florida State waters and adjacent federal waters, include the two largest
contiguous seagrass beds in the continental United States: the Florida Keys and the Florida Big Bend
regions. Florida seagrasses include Turtle grass (Thalassia testudinum), Shoal grass (Halodule wrightii),
and Manatee grass (Syringodium filiforme), the most abundant species in estuarine and nearshore waters.
Star grass (Halophila engelmanii) is locally abundant in turbid estuarine environments, and Paddle grass
{Halophila decipiens), covers large areas of the west Florida shelf at depths from 9 m to more than 30 m
(30 to over 100 ft.). Wigeon grass (Ruppia maritima) is also widely distributed in Florida estuaries.
Sargent, Leary, Crewz, and Kruer (1995) estimated that Florida State waters contained approximately
2,660,000 acres of seagrass, of which 55% (1,451,900 acres) occur in the Florida Keys and Florida Bay.
An additional 826,800 acres (31% of statewide total seagrass area) occurred in the Big Bend region. The
remaining seagrass area, 381,200 acres, was distributed in estuaries and lagoons throughout the State. If
seagrasses in adjacent federal waters, including deepwater Halophila beds, are included, seagrass area in
State and federal waters totals more than 3 million acres.
Seagrasses are very sensitive to water column transparency, their depth, distribution, and survival are
primarily determined by water clarity. In areas with extremely clear water (the offshore areas of Big
Bend and the Florida Keys, seagrasses grow to depths greater than 20 m (65 ft.). The only seagrass
species that may be found of the shelf offshore Sarasota Bay is Paddle grass (Halophila decipiens),
which can occur at depths over 30m (90 ft.) in very clear water (Handley, Altsman, & DeMay, 2007).
3.4 Social and Economic Environment
The following sections provide discussion on the status of U.S. seafood production and consumption,
commercial aquaculture, commercial landings of Almacojack, and environmental justice.
3.4.1	U.S. Seafood Consumption and Production
The U.S. is a net importer of seafood. In 2017, the U.S. imported edible seafood products valued at
$21.5 billion and exported $5.7 billion (NMFS, 2018a). That is a seafood trade deficit of $15.8 billion.
U.S. commercial landings (wild-catch) cannot increase to eliminate that deficit without becoming
unsustainable. However, aquaculture production can increase and become a potentially sustainable
resource.
3.4.2	Commercial Marine Aquaculture Production
The U.S. ranks sixteenth in world aquaculture production (NMFS, 2018a). That production rank
includes both freshwater and marine aquaculture. Within the U.S, the Gulf is a major aquaculture
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producer (NMFS, 2015a), and marine aquaculture production has been increasing.5 However, current
freshwater aquaculture production far exceeds marine aquaculture.
Gulf marine aquaculture primarily produces oysters, hard clams, and live rock species. Florida ranks
toward the top in the U.S. for hard clam production and most of its production occurs in Cedar Key.
Florida is also the largest live rock producer that occurs in Monroe County. Economic and demographic
characteristics of these and other Gulf areas can be found in NOAA Fisheries community profiles. The
full-length community profiles, last updated in 2002 to 2005, have in-depth information regarding the
historic, demographic, cultural, and economic context for understanding a community's involvement in
fishing.6
3.4.3 Commercial Landings of Almaco Jack
Almaco jack is part of the Gulf Reef Fish Fishery and it along with Banded rudderfish (Seriola zonatci)
and Lesser amberjack (,Seriolafasciata) make up the 'Jacks Complex'. The Jacks Complex has a
combined commercial and recreational annual catch limit (ACL), and with the exception of 2013, annual
landings have been less than the ACL. Commercial landings of the complex are considerably lower than
recreational landings. More information about the Jacks Complex and the Reef Fish Fishery can be
found on the NMFS Southeast Regional Office's Gulf of Mexico Reef Fish webpage and is incorporated
by reference.
Dockside (ex-vessel) revenue from Almaco jack landings accounted for an average of 0.3% of the total
dockside revenue for commercial fishing vessels that harvested the species from 2012 to 2016. The very
low percentage is expected because Almaco jack is not a commercially targeted species. Instead, it is
incidentally harvested by commercial vessels that target pelagic species. Almaco jack has a relatively
low dockside price because it is commonly characterized as a 'trash fish'. For example, when compared
with other species (e.g., Banded rudderfish, Vermilion snapper (Rhomboplites aurorubens) and Hogfish
(Lachnolaimus maximus) and excluding King mackerel, (Scomberomorus cavalla) the reef fish fishery,
the dockside price of Almaco jack ranks towards the bottom. Nonetheless, commercial landings of wild-
caught Almaco jack generate economic benefits to the nation in the form of jobs and income, sales, and
value-added impacts. Average annual landings (59,633 lbs. gw with a value of $85,658 in 2016)
generates 11 full- and part-time jobs, $312 thousand in income impacts and other benefits (estimates
produced by NMFS SERO using model produced and applied in Fisheries Economics of the United
States, 2016).7 For more information about commercial landings within the Gulf, see reference at
NMFS, 2018a. There is presently no commercial aquaculture of Almaco jack in the Gulf. Nevertheless,
it is traditionally harvested.
5	More information about Gulf aquaculture at the regional and state levels can be found in the USDA Census of Aquaculture and is incorporated by reference
flittps://www,nass.usda.gov/Surveys/Guide to NASS Surveys/Census of Aauaculture/V
6	Community profiles for fishing communities in the Gulf can be found at http://sero.nmfs.noaa.gov/sustainable fisheries/social/communitv snapshot/ and is
incorporated by reference.
7	More information about the dealers and commercial fishing in Florida at the community level can be found within the community profiles and is
incorporated by reference (http://sero.nmfs.noaa.gov/sustainable fisheries/social/community snapshot/)
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3.4.4 Commercial Fishing
Commercially important species groups in the GOM include oceanic pelagic (epipelagic) fishes, reef
(hard bottom) fishes, coastal pelagic species, and estuarine-dependent species. Invertebrates such as
shrimp, blue crab, spiny lobster, and stone crab also contributed significantly to the value of
commercial landings. Other finfish species that contributed substantially to the overall commercial
value of the GOM fisheries included red grouper, red snapper, and yellowfin tuna.
The commercial fishing industry is an important component of the economy of the Gulf coast of
Florida. Table 5 show commercial landings and ex-vessel values for finfish and shellfish landing for
west Florida that are compiled annually by NMFS. In 2014 and 2015, commercial landings of all
fisheries in west Florida totaled in excess of 63 million and 71 million pounds, respectively and was
valued at $171 million and $190 million (NMFS Office of Science and Technology, 2016). The Gulf
shellfishery dominated, with only 22% of the total landings, but accounting for 78% of the value;
shrimp represented nearly 70% of the shellfish catch and value.
Important commercial finfish and shellfish include red grouper, Atlantic herring, king mackerel, striped
mullet, red snapper, yellowtail snapper, blue crab, stone crab (claws), spiny lobster, oysters, and brown
and pink shrimp.
Table 5. Annual Commercial Landings for West Florida, 2014 and 2015
Metrics
2014
2<)| 5
Thousand Pounds
63,657
71,633
Metric Tons
28,875
32,493
Thousand Dollars
171,565
190,586
Source: NMFS, 2016
3.4.5 Recreati Glial Marine Fi sliing
In 2017, the U.S. recreational marine fishers took an estimated 202 million fishing trips and harvested an
estimated 397 million fish weighing 447 million pounds. Approximately 36% of those trips were made
in the Gulf (NMFS, 2018a). Recreational fishing activity can affect a regional economy in a number of
ways. When anglers participate in fishing activities, they support sales and employment in recreational
fishing and other types of businesses. Anglers buy fishing equipment from bait and tackle shops, rent or
buy boats, or pay to have others take them on charter boats to fish. They may also pay for food and drink
at local restaurants, purchase gas for their boat, and stay in hotels for overnight fishing trips (NMFS,
2018b).
The majority of Gulf trips are in West Florida. In 2015, for example, approximately 64% of the Gulfs
recreational fishing trips were in West Florida (NMFS Office of Science and Technology, 2016) The
13,219 angler trips in West Florida generated 60,179 jobs, approximately $2.6 billion in income and
other beneficial impacts (NMFS, 2018b).
The most commonly caught non-bait species (numbers of fish) in the eastern Gulf in 2015 were Spotted
seatrout (Cynoscion nebulosus), Gray snapper, Red drum (Sciaenops ocellatus), Blue runner or
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Bluestripe jack (Caranx crysos), and Sand seatrout (Cynoscion arenarius). The largest harvests by
weight were for Spotted seatrout, Red drum, Red snapper (Lutjanus campechanus), King mackerel,
Sheepshead (Archosargusprobatocephalus), and Dolphinfish (Coryphaena hippurus) (NMFS Office of
Science and Technology, 2016). The species most commonly caught on Gulf trips that fished primarily
in federally-managed waters were Red snapper, Red grouper {Epinephelus mono). White grunt
(.Haemulon plumierii), Dolphinfish, and Yellowtail snapper (Ocyurus chrysurus). About 33 % of the
total Gulf catch came on trips that fished primarily in the state territorial seas.
3.4.6	Human Health/Public Health
Aquaculture's contribution to global seafood production continues to rise. With this rise in aquaculture
production, human health/public health issues associated with aquaculture should be considered. Human
health/public health concerns that can arise from aquaculture production include the increase in use of
formulated food, use of antibiotics, use of antifungals, and use of agrochemicals. These aquaculture
practices can potentially lead to elevated levels of antibiotic residuals, antibiotic-resistant bacteria,
persistent organic pollutants, metals, parasites, and viruses in aquaculture finfish. People working in and
around aquaculture facilities, populations living near these operations, and consumers may be at
potential risk of exposure to these containments (Sapkota, et al., 2008).
3.4.7	Environmental Justice
On February 11, 1994, the President issued Executive Order 12898 (E.O. 12898), "Federal Actions to
Address Environmental Justice in Minority Populations and Low-Income Populations." E.O. 12898
provides that"each federal agency shall make achieving environmental justice part of its mission by
identifying and addressing, as appropriate, disproportionately high and adverse human health or
environmental effects of its programs, policies, and activities on minority populations and low-income
populations." E.O. 12898 also provides for agencies to collect, maintain, and analyze information on
patterns of subsistence consumption of fish, vegetation, or wildlife.
Where an agency action may affect fish, vegetation, or wildlife, the agency should consider the potential
adverse effects on subsistence patterns of consumption and indicate the potential for disproportionately
high and adverse human health or environmental effects on low-income populations, and minority
populations. The proposed project is physically located on the west Florida shelf, approximately 45
miles west, southwest of Longboat Pass-Sarasota Bay, Florida in federal waters, which is not near any
minorities or low-income populations. However, harvested farmed fish would be brought to port where
wild fish are landed by potentially subsistence fishermen.
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4 0 Environmental Consequences
4.1	Introduction
This chapter describes the potential environmental impacts associated with the proposed actions as well
as the issuance of required federal authorizations necessary to operate the VE project. The anticipated
impacts on resources as a result of the VE project are discussed in the following sections.
Concerns related to the environment regarding aquaculture operations include water quality (waste and
pharmaceutical applications), genetic impacts to wild fish from cultured fish escapes (e.g., loss of fitness
to wild populations if wild and cultured fish interbreed), spread of disease from cultured to wild fish,
entanglement of protected species in aquaculture gear, use of bait fish as a feed source, risk of loss of
equipment and damage to the marine environment during severe storm events (e.g., tropical storms,
hurricanes), privatization of a public resource (federal waters) for profit, loss of ocean space where
aquaculture operations are sited, and socio-economic impacts on commercial or recreational fisheries.
Generally, open ocean aquaculture may have effects on water and sediment quality and the plant and
animal communities living in the water column and those in close association with, on, or in the
sediments. The two major factors which determine the geographic distribution and severity of impacts
of open ocean aquaculture on the water column, seafloor sediments and benthic communities are farm
operations management, and farm siting. Sound farm operating practices tend to reduce waste loading
by employing efficient feeding methods and by use of dry, slow sinking, more easily digested feed
types. Good management practices can also limit impacts due to escapes, spread of diseases, and
entanglements etc. Proper farm siting can minimize water column and benthic impacts by maximizing
over bottom depths and current flow through cages, and through avoidance of more sensitive biological
communities. Optimal siting can also reduce potential marine resource use conflicts.
A more extensive discussion of the potential impacts on physical and biological resources associated
with the proposed action are provided in Appendix C, Evaluation of the Ocean Discharge Criteria,
Kampachi Farms - Velella Epsilon Net Pen Fish Culture Facility and the NPDES Permit [FL0A00001J
Outer Continental Shelf, Gulf of Mexico and Appendix D, Draft Biological Evaluation - Kampachi
Farms, LLC - Velella Epsilon, Marine Aquaculture Facility, Outer Continental Shelf Federal Waters of
the Gulf of Mexico, March 15, 2019.
4.2	Physical Resources
Offshore aquaculture operations can affect physical resources in several ways. Particulates from fish
cages add to water column turbidity and reduced clarity. Solid wastes can alter the physical environment
and chemistry of benthic sediments. In cases of extreme loading, solid wastes can result in burial of
benthic habitats beneath cages. The placement of physical structures on the seafloor, i.e., anchors and
anchor lines, and in the water column, cages, may result in damage to seafloor habitat and entanglement
and collision impacts to motile marine animals.
Alternative 1 - No Action. The No Action alternative would result in no effect on physical resources
(water column and seafloor) because an aquaculture facility would not be able to discharge any
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operational wastes without an NPDES permit, and without a Section 10 permit, the facility would not be
constructed or operated at this location on the west Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES and Section 10 Permits. The Proposed Action
alternative, the issuance of an NPDES and Section 10 permits, will likely have minimal impacts to
physical resources in the vicinity of the proposed facility. The siting analysis conducted during the site
selection process chose an area consisting of unconsolidated sediments coupled with sufficient depth
and current flow parameters that should result in broad dispersion of solid wastes. Positioning away
from potential live bottom habitat will mitigate physical benthic impacts from anchors and mooring
lines. The cage is designed to swivel around the center of a suspended 3-point mooring, further reducing
anchor chain sweep. The relatively small fish biomass to be reared in the single cage (74,800 lbs. at
harvest) demonstration is expected to result in small daily loading rates per meter squared (m2)
downstream of the cage. Solid wastes settling on the seafloor will likely undergo resuspension and
transport and additional dispersion from the area resulting in minimal solids accumulation.
4.2.1 Water Quality
The water quality around offshore aquaculture operations is mainly affected by the release of dissolved
and particulate inorganic and organic nutrients. Water column effects around offshore aquaculture
operations include a decrease in dissolved oxygen and increases in biological oxygen demand, and
nutrients (Phosphorus, total Carbon and organic and inorganic Nitrogen), increased turbidity and
potential for ammonia toxicity. Degradation of water quality parameters is greatest within the fish
culture structures and improves rapidly with increasing distance from cages. Recent studies have
documented only limited water column impacts due to rapid dispersal (Holmer, 2010). The health of the
fish stocks is a self-limiting control on water column pollution. A more extensive discussion of water
quality impacts from offshore aquaculture operations can be found in the ODCE for Kampachi Farms, -
Velella Epsilon Net Pen Fish Culture Facility, Appendix C.
Alternative 1 - No Action. The No Action alternative would result in no change to the quality of the
water column because an aquaculture facility would not be able to discharge any operational wastes
without an NPDES permit and, without a Section 10 permit, the facility would not be constructed or
operated at this location on the west Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES and Section 10 Permits. The Proposed Action
alternative, issuance of an NPDES and Section 10 permits will likely have minimal impacts to water
quality in the vicinity of the proposed facility due to the small fish biomass, 74,800 lbs. produced during
a 280-day fish production cycle in the single cage facility and current flows measured in the vicinity of
the selected site. It is estimated (CASS Tech Report, Appendix F) that a total of 2,743 kg of ammonia
nitrogen would be produced during the production cycle. The CASS report suggested that daily
ammonia production at levels twice as high as estimated will be undetectable within 30 meters of the
cage at typical current flows regimes in the vicinity of the proposed site. The EPA's calculations
provided in the ODCE for this project, Appendix C, estimated that the flow-averaged ammonia
concentration at an ammonia production of 9.8 kilograms per day (kg/day) loading rate is approximately
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= 0.0072 milligrams per liter (mg/1), significantly below the USEPA's published ammonia aquatic life
criteria values for saltwater organisms.8
4.2.1.1 Pharmaceuticals
There is some concern that use of antibiotics in offshore aquaculture operations could lead to an increase
in antibiotic resistance among bacteria in the facility effluent. An extensive discussion of impacts
resulting from pharmaceutical application at offshore aquaculture operations can be found in the ODCE
for this project, Appendix C.
The applicant has indicated that FDA-approved antibiotics will not likely be used during the proposed
project due to the strong currents expected at the proposed action area and the low fish culture density.
In the unlikely event that therapeutants are used, administration of drugs will be performed under the
control of a licensed veterinarian. In addition, the NPDES permit will require that the use of any
medicinal products including therapeutics, antibiotics, and other treatments are to be reported to the
EPA. The report will include types and amounts of medicinal product used and the period of time it was
used.9
Alternative 1 - No Action. The No Action alternative would result in no use of pharmaceutical agents
because an aquaculture facility would not be able to discharge any operational wastes without an
NPDES permit and, without a Section 10 permit, the facility would not be constructed or operated at this
location on the west Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES and Section 10 Permits. The Proposed Action
alternative, issuance of NPDES and Section 10 permits will likely result in minimal use of
pharmaceutical agents only in the event of disease, and, therefore, have minimal impacts to sediment
quality in the vicinity of the proposed facility. Also, due to the small fish biomass, 74,800 lbs. produced
during a 280-day fish production cycle in the single cage facility, the amounts of pharmaceutical agents
needed will be small, and current flows measured in the vicinity of the selected site should result in
broad dispersal of any pharmaceutical agents onto the seafloor.
4.2.2 Sediment Quality
The two most significant sources of impacts to sediment quality from offshore aquaculture operations
are total solids deposition and organic enrichments to seafloor sediments from uneaten feed and fish
feces. Numerous studies have shown that organic enrichment of the seabed is the most widely
encountered environmental effect of culturing fish in cages (Karakassis, Tsapakis, Hatziyanni,
Papadopoulou, & Plaiti, 2000; Price & Morris Jr., 2013; Karakassis, Tsapakis, Smith, & Rumohr, 2002).
The spatial patterns of organic enrichment from offshore aquaculture operations varies with physical
conditions at the sites and farm specifics and has been detected at distances from meters to several
8	EPAS recommended saltwater aquatic life criteria is available at: www.epa.aov/wqc/natjonal-reconiniended-water-qualjtv-cnteria-aquatic-life-criteria-
table.
9	The applicant noted in the NPDES permit application that only FDA-approved therapeutants for aquaculture would be used. The applicant is not expected
to use any drugs; however, in the unlikely circumstance that therapeutant treatment is needed, three drugs were provided to the EPA as potential candidates
(hydrogen peroxide, oxytetracycline dihydrate, and florfenicol).
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hundred meters from the perimeter of the cage array (Mangion, Borg, & Schembri, 2014). Studies of
offshore aquaculture operations in the Mediterranean showed that the severe effects of organic inputs
from fish farming on benthic macrofauna are limited to up to 25 m from the edge of the cages
(Lampadariou, Karakassis, & Pearson, 2005) although the influence of carbon and nitrogen from farm
effluents in sea floor can be detected in a wide area about 1,000 m from the cages (Sara, Scilipoti,
Mazzola, & Modica, 2004). The impacts on the seabed beneath the cages were found to range from very
significant to relatively negligible depending on sediment type and the local water currents, with silty
sediments having a higher potential for degradation. The ODCE anticipates impacts from the VE facility
will likely be limited to 300 m—500 m from the perimeter of the cage (Appendix C). Moreover, model
results for this project predict that there are minimal to no risks to water quality or benthic ecology
funtions within the area of operation, CASS Technical Report Appendix F. A more in-depth discussion
of potential impacts to sediment quality can be found in the ODCE for Kampachi Farms - Velella
Epsilon Net Pen Fish Culture Facility, Appendix C.
Alternative 1 - No Action. The No Action alternative would result in no effect on sediment quality
around the site because an aquaculture facility would not be able to discharge any operational wastes
without an NPDES permit, and, without a Section 10 permit, the facility would not be constructed or
operated at this location on the west Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES and Section 10 Permits. The Proposed Action
alternative, issuance of NPDES and Section 10 permits will likely have minimal impacts to sediment
quality in the vicinity of the proposed facility. The siting analysis conducted during the site selection
process chose an area with sufficient depth and current flow parameters that should result in broad
dispersion of solid wastes. The relatively small fish biomass to be reared in the single cage (74,800 lbs.
at harvest) is expected to result in small daily loading rates per meter squared downstream of the cage.
Solid wastes settling on the seafloor will likely undergo resuspension and transport and additional
dispersion from the area resulting in minimal solids accumulation. The results of a depositional model
(CASS Tech Report, Appendix F) show that for the estimated production values, net organic carbon
accumulation would be at 3.0 grams per meter squared per year (g/m2/yr.) or less for 99.7 % of the test
grid. A portion of the organic wastes are expected to be assimilated by the macroinvertebrate community
inhabiting the soft sediments in the surrounding area. A more extensive discussion of the potential for
impacts to physical resources can be found in the ODCE for Kampachi Farms - Velella Epsilon Net Pen
Fish Culture Facility, Appendix C.
4.2.3 Air Quality
There are no large sources of anthropogenic (man-made) emissions expected to be released into the
atmosphere from the project area under the proposed alternative. A tender vessel, which will be moored
to the net pen array, may be a small source of emissions in offshore waters. Moreover, trade wind
conditions around Florida are likely to quickly disperse these emissions. It is not expected that proposed
facility routine marine aquaculture operations would have an adverse impact on air quality. Should EPA
receive credible scientific evidence during the comment period that suggests otherwise, the information
will be considered prior to issuance of the NPDES permit.
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4.2.4	Coastal Barrier Beaches
The proposed action is to be located in approximately 130 m water depth off southwest Florida,
approximately 45 miles southwest of Sarasota, Florida. The proposed action will be offshore from any
coastal barrier beaches. In accordance with the CZMA, the applicant obtained concurrence from the
Florida Department of Environmental Protection for the proposed project, Appendix H. It is possible that
miscellaneous debris from the aquaculture operation could impact coastal beaches, but it is anticipated
that impacts to coastal barrier beaches will be negligible.
4.2.5	Noise Environment
The proposed project's location, approximately 45 miles offshore off the western coast of Florida, is an
area with ambient noise from wind, waves, and periodic noise from occasional boat and vessel traffic.
The proposed facility is not expected to make a significant contribution to ambient noise and to current
open ocean noise.
4.2.6	Climate
As discussed in Section 3.2.6 Climate, the effect of ongoing human-caused climate change makes the
Gulf environment vulnerable to rising ocean temperatures, sea level rise, storm surge, ocean
acidification, and significant habitat loss. The climate in the project area would be as described in
Section 3.2.6 Climate.
Alternative 1 - No Action. The No Action alternative would result in no effect on the climate because
an aquaculture facility would not be built without an NPDES permit, and, without a Section 10 permit,
the facility would not be constructed or operated at this location on the west Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES and Section 10 Permits. The Proposed Action
alternative, issuance of NPDES and Section 10 permits, will likely result in negligible emissions of
Green House Gasses (GHGs) resulting from operation of support vessels. The cages could be vulnerable
to storm events in the Gulf, however, mitigation measures proposed in the NPDES permit will minimize
the potential for damage to the environment from such an event.
4.3 Biological Resources
The biological resources likely to occur in the immediate vicinity of the proposed VE project are
described in Section 3.3 Biological Resources. The factors with potential to impact biological resources
around coastal fish farms are disturbance, entanglement, vessel strikes, and the discharges of dissolved
and particulate inorganic and organic nutrients into the water column and discharges of total solids
deposition and organic enrichments to seafloor sediments from uneaten feed and fish feces. The latter
can potentially impact biological communities through the degradation of water quality, affecting
pelagic plants and animals, and organic enrichment of benthic sediments, thereby, affecting benthic
biota.
A more extensive discussion of the potential impacts on physical and biological resources associated
with the proposed action are provided in the Appendix C, Evaluation of the Ocean Discharge Criteria,
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Kampachi Farms - Velella Epsilon Net Pen Fish Culture Facility and the NPDES Permit[FL0A00001]
Outer Continental Shelf, Gulf of Mexico and Appendix D, Draft Biological Evaluation - Kampachi
Farms, LLC - Velella Epsilon, Marine Aquaculture Facility, Outer Continental Shelf Federal Waters of
the Gulf of Mexico, March 15, 2019.
4.3.1 Fish
Fish species that can occur in the vicinity of the proposed VE project area are discussed in Section 3.3.1
Fish. The factors that may impact fish near coastal offshore aquaculture operations are disturbance and
water and sediment quality degradation as a result of waste discharges. Potential water quality impacts
are associated with discharges of dissolved and particulate inorganic and organic nutrients into the water
column and discharges of total solids deposition and organic enrichments to seafloor sediments from
uneaten feed and fish feces. These discharges can potentially impact protected fish through the
degradation of water quality, affecting pelagic plants and animals, and organic enrichment of benthic
sediments, affecting benthic habitat.
Alternative 1 - No Action. The No Action alternative would result in no effect on water column biota or
benthic communities around the site, including fish, because an aquaculture facility would not be able to
discharge any operational wastes without an NPDES permit, and, without a Section 10 permit, the
facility would not be constructed or operated at this location on the west Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES and Section 10 Permits. The Proposed Action
alternative, issuance of NPDES and Section 10 permits, will likely have only very minimal impacts to
the fish species expected to occur near the proposed facility. The siting analysis conducted during the
site selection process chose an area with sufficient depth and current flow parameters that should result
in rapid dilution of dissolved wastes and broad dispersion of solid wastes discharged from the facility.
The relatively small fish biomass to be reared in the single cage (74,800 lbs. at harvest) demonstration is
also expected to result in small daily loading rates of discharged pollutants downstream of the cage. In
addition, it is expected that fish that may occur at the proposed VE project site would only encounter the
facility temporarily since they are motile animals. Exposure to any discharged pollutants will be
minimal.
The primary concern with marine cage culture and protected fish tends to be the threat of entanglement
with nets, lines or other floating equipment. The large diameter of the anchor line as well as the stiffness
of it and other lines make it extremely unlikely that a fish would be entangled. Additionally, the pen will
use a rigid copper alloy mesh, which presents no entanglement hazard.
Regarding potential impacts from water and sediment quality, protected fish species are not expected to
be impacted given their unique habitat preferences and known proximity to the proposed action area.
The Oceanic whitetip shark is not likely to occur near the proposed project given its preference for
deeper waters. The action agencies believe that the Nassau grouper will not be present given that it is
absent from the Gulf outside of the Florida Keys. Interactions with Smalltooth sawfish with the
proposed project is extremely unlikely because they primarily occur in the Gulf off peninsular Florida
and are most common off Southwest Florida. The Giant manta ray may encounter the facility given its
migratory patterns. However, long term impacts are not expected because the facility is relatively small
and is expected to have a short deployment period of approximately 18 months.
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The NPDES permit provisions will contain environmental monitoring (water quality, sediment, and
benthic infauna) and other conditions that minimize potential adverse impacts to fish from the discharge
of effluent from the proposed facility, and prohibit the discharge of certain pollutants (e.g., oil, foam,
floating solids, trash, debris, and toxic pollutants). Due to the pilot-scale size of the facility and low
density of cultured fish, water quality and benthic effects are not expected to occur outside of 30 m. The
discharges authorized by the proposed NPDES permit represent a small incremental contribution of
pollutants that are not expected to affect fish species in the project area.
4.3.2 Invertebrates
Marine invertebrates occurring in the Gulf are discussed in Section 3.3.2 Invertebrates. The factors that
may impact marine invertebrate communities near coastal offshore aquaculture operations are impacts to
water and sediment quality. Anchor placement and mooring line sweep may impact sessile benthic
invertebrates. Expected discharges from aquaculture operations include dissolved and particulate
inorganic and organic nutrients into the water column, total solids deposition, and organic enrichments
to seafloor sediments from uneaten feed and fish feces These discharges can potentially impact protected
corals through the degradation of water quality, and organic enrichment of benthic sediments, affecting
benthic habitat.
Alternative 1 - No Action. The No Action alternative would result in no change to water column biota
or benthic communities around the site, including stony corals, because an aquaculture facility would
not be able to discharge any operational wastes without an NPDES permit, and, without a Section 10
permit, the facility would not be constructed or operated at this location on the west Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES and Section 10 Permits. The Proposed Action
alternative, issuance of an NPDES and Section 10 permits, may result in impacts to invertebrate
communities in the benthos around the farm site due to benthic loading of discharged solid wastes,
however, any impacts to benthic invertebrates are expected to be minimal.
The siting analysis conducted during the site selection process chose an area with sufficient depth and
current flow parameters that should result in rapid dilution of dissolved wastes and broad dispersion of
solid wastes discharged from the facility. The relatively small fish biomass to be reared in the single
cage (74,800 lbs. at harvest) demonstration is also expected to result in small daily loading rates of
discharged pollutants downstream of the cage. Exposure of benthic invertebrates to any discharged
pollutants will be minimal.
The Proposed Action alternative, issuance of an NPDES and Section 10 permits, will likely have no
impact to protected corals as none of the listed species are expected to occur near the proposed facility.
Additionally, the anchoring system and cage will be placed in an area consisting of unconsolidated
sediments, away from potential hardbottom which may contain corals according to the facility's BES.
The discharge from the proposed facility will be covered by a NPDES permit with water quality
conditions required by the CWA. The aquaculture-specific water quality conditions contained in the
NPDES permit will generally include an environmental monitoring plan (i.e., water quality, sediment,
and benthic monitoring) and effluent limitations expressed as best management practices (BMPs).
Furthermore, the NPDES will require the proposed facility to be placed at least 500 meters from any
hardbottom habitat or coral reefs to protect those communities from physical impacts due to the
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deposition of solids and potential impacts due to organic enrichment. Water quality effects are not
expected to occur outside of 30 m due to the small size of the facility and low production levels. The
impacts from water quality are expected to be minimal or insignificant, and the likelihood that
deleterious water quality will contribute to any adverse effects to listed coral species is extremely
unlikely.
4.3.3 Marine Mammals
Marine mammals that can occur in the vicinity of the proposed VE project area are discussed in Section
3.3.3 Marine Mammals. The greatest risks to Bottlenose or Atlantic spotted dolphins at this site are
entanglement, vessel strike and behavioral disturbance. When dolphins become conditioned (a form of
behavioral disturbance) to an anthropogenic food source, the risk of vessel strikes, and entanglement
increases (Donaldson, Finn, & Calver, 2010).
The greatest risk to dolphins from this operation is entanglement in vertical lines that are associated with
the mooring lines and net pen connections. Flexible lines that easily loop are most risk-adverse for
dolphins (e.g., shrimp trawl lazy lines (Gearhart & Hataway, 2018) and crab pot buoy lines (Adimey, et
al., 2014). The line proposed for the mooring and net pen connection lines (Amsteel blue) is a strong,
but flexible line (pers comm. Gearhart, 2018). Entanglement risk to dolphins will depend greatly on the
tautness of the line; any slack in the line poses an entanglement risk (Maze-Foley & Mullin, 2006). The
copper alloy net mesh enclosing the pen is not anticipated to be an entanglement risk for dolphins given
its firm and inflexible state.
Vessel strikes are also a risk for dolphins. As the density of vessels increase in areas utilized by
dolphins, so does incident of boat strike injury or mortality to dolphins (Bechdel, et al., 2009). There is
likely to be an increase in boat traffic moving back and forth from port to the aquaculture operation. It is
recommended that the vessel captain slows to a no wake speed if dolphins are seen nearby and only
resumes normal speed when the animals leave the area. If dolphins wake or bow-ride while a vessel is
transiting, it is recommended that the vessel captain maintain the vessel's course and speed until the
dolphins depart or as long as it is safe to do so.
Dolphins are attracted to concentrated food sources specifically when feeding opportunities exist. There
is a possibility that if the animals are fed or are successful at extracting fish from divers or from the pen,
the dolphins will become conditioned and change their behavior to spend more time milling around the
net waiting for an opportunity to scavenge fish (Christiansen, et al., 2016). When dolphins learn to
associate anthropogenic sources with food, unnatural behaviors such as begging or depredating disrupt
their natural foraging repertoire and become an abnormal and detrimental feeding strategy (Powell &
Wells, 2010). Conditioned dolphins approach humans or anthropogenic food sources more readily
looking for handouts, thus increasing the animal's risk for boat strike or gear entanglement (Bechdel, et
al., 2009; Powell & Wells, 2010; Samuels & Bejder, 2004; Wells & Scott, 1997). To minimize
conditioning of dolphins to the pen, all operations staff must be educated that feeding or attempting to
feed wild dolphins is illegal. It is recommended that any divers collecting fish mortalities from the tank
remove and dispose of the fish in such a way that does not allow a dolphin an opportunity to scavenge or
depredate the discards.
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Another factor that may impact protected marine mammals around coastal offshore aquaculture
operations are the discharges of dissolved and particulate inorganic and organic nutrients into the water
column and discharges of total solids deposition and organic enrichments to seafloor sediments from
uneaten feed and fish feces. They can potentially impact marine mammal through the degradation of
water quality, affecting pelagic plants and animals, and organic enrichment of benthic sediments,
affecting benthic habitat.
Alternative 1 - No Action. The No Action alternative would result in no effect to marine mammals,
because the facility would not be constructed or operated at this location on the west Florida Shelf,
therefore there is no additional risks being added to this location.
Alternative 2 - Proposed Action, Issuance of NPDES and Section 10 Permits. The construction and
operation of an aquaculture facility at this site present marine mammal risks that will include
entanglement, vessel strike, and behavioral disturbance, however, the level of impact to individual
dolphins from these risks is unknown. An aquaculture facility of this type has not yet been operated in
the Gulf. As a means to better understand these risks and level of individual impacts, the applicant has
agreed to partner with NMFS SERO to collect information on dolphin interactions and behavior around
this facility. However, given the large size of these marine mammal stocks and, thus, larger potential
biological removal levels, it is anticipated the impacts to the overall population would be minimal.
Entanglement risks to marine mammals will be minimized by using rigid and durable cage materials and
by keeping all lines taut. The cage material for the proposed project is constructed with rigid and durable
materials. The mooring lines for the proposed project will be constructed of steel chain and thick rope
that are attached to a floating cage that will rotate in the prevailing current direction; the floating cage
position that is influenced by the ocean currents will maintain the mooring rope and chain under tension
during most times of operation. The bridle line that connects from the swivel to the cage will be encased
in a rigid pipe. Additionally, the limited number of vertical mooring lines (3) and the duration of cage
deployment (approximately 18 months) will reduce the risk of potential entanglement by marine
mammals. Furthermore, there have been no recorded incidents of entanglement from ESA-listed marine
mammal species interacting with a permitted commercial-scale marine aquaculture facility in Hawaii
(Blue Ocean Mariculture, 2014); interactions are anticipated to be highly unlikely. Because of the
proposed project operations and proximity to marine mammal habitat, the action agencies expect that the
effects of this entanglement interaction would be discountable; however, should entanglement occur, on-
site staff would follow the steps outlined in the Protected Species Management Plan (PSMP) and alert
the appropriate experts for an active entanglement.
In regard to vessel strikes, facility staff will be stationed on one vessel for the duration of the project
except during unsafe weather conditions. The probability that collisions with the vessel associated with
the proposed project would kill or injure marine mammals is discountable as the vessel will not be
operated at speeds known to injure or kill marine mammals. Given the limited trips to the facility with
only one vessel, and the high visibility of whales to small vessels, opportunities for strikes from the
vessel participating in the proposed project are expected to be insignificant. Strikes from other vessels
not operated by the facility are anticipated to be improbable due to the proximity to shore. Additionally,
all vessels are expected to follow the vessel strike and avoidance measures that have been developed by
the NMFS.
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Disturbance to marine mammals from ocean noise generated by the proposed facility is expected to be
extremely low given that the there is one production cage and one vessel that will be deployed for a
duration of approximately 18 months. The action agencies believe that the underwater noise produced
by operating a vessel and cage are minimal and will not interfere with the ability of marine mammals to
communicate, choose mates, find food, avoid predators, or navigate.
4.3.4 Sea Turtles
Sea turtles that can occur in the vicinity of the proposed VE project site are discussed in Section 3.3.4
Sea Turtles. The factors that may impact protected sea turtles near coastal offshore aquaculture
operations are impacts to water quality, entanglement, physical encounters with the pen system, and
behavioral disturbance.
Alternative 1 - No Action. The No Action alternative would result in no effect on water column biota or
benthic communities around the site, including sea turtles, because an aquaculture facility would not be
able to discharge any operational wastes without an NPDES permit, and without a Section 10 permit, the
facility would not be constructed or operated at this location on the west Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES and Section 10 Permits. Sea turtles frequent reefs
and other areas with submerged structures (Stoneburner, 1982; Booth & Peters, 1972; Witzell W. N.,
1982; Carr A. F., 1952) and may be attracted to the project area for food, shelter, and/or rest. The
primary concern with marine cage culture and listed sea turtles and fish tends to be the threat of
entanglement with nets, lines or other floating equipment. However, the large diameter of the anchor
line as well as the stiffness of it and the other lines make it extremely unlikely that a sea turtle would be
entangled. Mooring lines are designed to be kept taught, reducing the potential for entanglements.
Additionally, the pen will use a rigid copper alloy mesh, which presents no entanglement hazard.
Sea turtles may be indirectly affected by the proposed facility if it concentrates hook-and-line (i.e., rod
and reel) fishermen in the vicinity. Sea turtles are known to bite baited hooks and can be hooked
incidentally by these fishermen. Sea turtles do not transmit social information regarding new foraging
locations and opportunities like dolphins do thus, we do not believe such indirects to result in additional
reef fish fishing interactions with sea turtles.
Sea turtles may experience disturbance by stress due to a startled reaction should they encounter vessels
in transit to the proposed project site. Given the limited trips to the site, opportunities for disturbance
from vessels participating in the proposed project are minimal. ESA-listed sea turtles may be attracted to
aquaculture facilities as potential sources of food, shelter, and rest, but behavioral effects from
disturbance are expected to be insignificant. Additionally, all vessels are expected to follow the vessel
strike and avoidance measures that have been developed by the NMFS. Furthermore, there has been a
lack of documented observations and records of ESA-listed sea turtles interacting with a permitted
commercial-scale marine aquaculture facility in Hawaii (Blue Ocean Mariculture, 2014). The EPA
anticipates that such interactions would be unlikely. As a result, disturbance from human activities and
equipment operation resulting from the proposed action is expected to have insignificant effects on
ESA-listed reptiles.
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Sea turtles located in close proximity to an offshore aquaculture operation could also be impacted by the
discharges of dissolved and particulate inorganic and organic nutrients into the water column and
discharges of total solids deposition and organic enrichments to seafloor sediments from uneaten feed
and fish feces. These discharges can impact through the degradation of water quality, affecting pelagic
plants and animals, and organic enrichment of benthic sediments, affecting benthic biota and habitat.
However, the siting analysis conducted during the site selection process chose an area with sufficient
depth and current flow parameters that should result in rapid dilution of dissolved wastes and broad
dispersion of solid wastes discharged from the facility. The relatively small fish biomass to be reared in
the single cage (74,800 lbs. at harvest) demonstration is also expected to result in small daily loading
rates of discharged pollutants downstream of the cage. In addition, it is expected that sea turtles that may
occur at the proposed VE project site area would only encounter the facility temporarily since they are
pelagic animals. Exposure to any discharged pollutants will be minimal.
The risk of sea turtles being entangled in offshore aquaculture operation is greatly reduced by using rigid
and durable cage materials and by keeping all lines taut. The cage material for the proposed project is
constructed with rigid and durable materials. The mooring lines for the proposed project will be
constructed of steel chain and thick rope that are attached to a floating cage that will rotate in the
prevailing current direction; the floating cage position that is influenced by the ocean currents will
maintain the mooring rope and chain under tension during most times of operation. Additionally, the
bridle line that connects from the swivel to the cage will be encased in a rigid pipe. Moreover, the
limited number of vertical mooring lines (three) and the duration of cage deployment (less than 18
months) will reduce the risk of potential entanglement by sea turtles. Because of the proposed project
operations and duration, the action agencies expect that the effects of this entanglement interaction
would be discountable. However, should entanglement occur, on-site staff would follow the steps
outlined in the PSMP and alert the appropriate experts for an active entanglement.
4.3.5 Birds
Birds that may occur in the vicinity of the proposed VE project site are discussed in Section 3.3.5 Birds.
Potential impacts to seabirds from the VE project could be related to the physical structure, presence of
fish, and associated activities that would attract migratory seabirds as well as other migratory birds. A
number of species, such as Common loons (Gavia immer) and Double-crested cormorants
(Phalacrocorax auratus) may dive from the surface near the facility to try to access small fishes
underwater, whereas Brown pelicans (Pelecanus occidentalis), Northern gannets (Morus bassanus),
Masked boobies (Sula dactylatra), Brown boobies (Sulci leucogaster), and Red-footed boobies (Sula
sula) may attempt to plunge dive into the cage and may be injured by the taut mesh covering the tops of
the cages. Cage covering should limit the visibility of fish in cages, reducing diving activity.
Alternative 1 - No Action. The No Action alternative would result in no effect on seabirds and other
migratory birds occurring in the area, because, without an NPDES permit, and, without a Section 10
permit, the facility would not be constructed or operated at this location on the west Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES and Section 10 Permits. The Proposed Action
alternative, issuance of NPDES and Section 10 permits will likely have only very minimal impacts to
the seabirds and other migratory birds expected to occur in the vicinity of the proposed facility.
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The EPA and USACE considered disturbance as the only potential stressor to ESA-protected seabirds
from the proposed project. Seabirds are not expected to interact with the proposed project or become
trapped in the cage due to distance of the proposed project from shore (approximately 45 miles). The
Piping plover is a shorebird that primarily inhabits coastal sandy beaches and mudflats. The Red knot is
a highly migratory species. However, their known migratory routes do not overlap with the proposed
project and migration and wintering habitat for the Red knot are in intertidal marine habitats such as
coastal inlets, estuaries, and bays (FWS, 2014). Should there be any interaction that results in an injury
to a protected seabird, the on-site staff would follow the steps outlined in the PSMP and alert the
appropriate experts for an active entanglement.10 The project staff will suspend all surface activities,
including stocking, harvesting operations, and routine maintenance operations in the unlikely event that
an ESA-listed seabird comes within 100 m of the activity until the bird leaves the area. Any potential
effects from the proposed action on ESA-listed birds are discountable because the effects are extremely
unlikely to occur.
4.3.6 Essential Fish Habitat
The Gulf of Mexico Fishery Management Plans and essential fish habitat that apply to the proposed VE
project site are discussed in Section3.3.6 Essential Fish Habitat. The main factors most likely to impact
managed fishes, shellfish and essential fish habitat around offshore aquaculture operations are the
discharges of dissolved and particulate inorganic and organic nutrients into the water column and
discharges of total solids deposition and organic enrichments to seafloor sediments from uneaten feed
and fish feces. These discharges can cause impacts through the degradation of water quality, affecting
pelagic early life stages and adult stages of animals, and through organic enrichment of benthic
sediments, affecting demersal and benthic fish and shellfish species and critical benthic habitat. A more
extensive discussion of the potential for impacts of fish farming to managed fishes and essential fish
habitat can be found in the ODCE for Kampachi Farms - Velella Epsilon Net Pen Fish Culture Facility,
Appendix C and Appendix D, Threatened and Endangered Species Assessment.
Alternative 1 - No Action. The No Action alternative would result in no effect on either pelagic or
benthic fishes or essential fish habitat around the proposed VE site because an aquaculture facility
would not be able to discharge any operational wastes without an NPDES permit, and, without a Section
10 permit, the facility would not be constructed or operated at this location on the west Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES and Section 10 Permits. The Proposed Action
alternative, issuance of NPDES and Section 10 permits will likely have minimal impacts to managed
fishes and essential fish habitat expected to occur in the vicinity of the proposed facility. The siting
analysis conducted during the site selection process chose an area with sufficient depth and current flow
parameters that should result in rapid dilution of dissolved wastes and broad dispersion of solid wastes
discharged from the facility. The relatively small fish biomass to be reared in the single cage (74,800
lbs. at harvest) demonstration is also expected to result in small daily loading rates of discharged
pollutants downstream of the cage. Small loading rates and rapid dilution of dissolved constituents
downstream of the cage is expected to minimize exposure to early life stages of fish and shellfish in the
10 A PSMP has been developed by the applicant with assistance from the NMFS Protected Resources Division. The purpose of the PSMP is to provide
monitoring procedures and data collection efforts for species (marine mammals, sea turtles, seabirds, or other species) protected under the MMPA or ESA that
may be encountered at the proposed project.
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water column. The relatively low production of solid wastes and the wide dispersal of discharged solids
to the benthos should minimize impacts to benthic fishes. Additionally, the proposed VE site will be
located over unconsolidated sediments, limiting any potential impacts to reef fishes associated with live
bottom. The EPA provided an EFH assessment to the NMFS for consideration on our determination that
the proposed project would not result in substantial adverse effects on EFH and the permits will have
conditions to mitigate any minor impacts that may occur (Appendix E).
4.3.7	Deepwater Benthic Communities
Deepwater benthic communities do not occur within a distance of approximately 90 miles or more,
seaward of the proposed VE site. Therefore, no impact on this resource is expected.
4.3.8	Live Bottoms
Live bottom communities in the vicinity of the proposed VE project location are discussed in Section
3.3.8	Live Bottoms. The main impact causing factor to live bottom communities around offshore
aquaculture operations is the discharge of total solids consisting of uneaten feed and fish feces, resulting
in solids deposition and organic enrichments to seafloor sediments. These discharges can cause impacts
through the degradation of water and sediment quality, burial, and through organic enrichment of
benthic sediments, affecting demersal and benthic fish and macroinvertebrate species and critical
benthic habitat. A more extensive discussion of the potential for impacts of offshore aquaculture
operations to live bottom habitat and associated communities can be found in the ODCEfor Kampachi
Farms - Velella Epsilon Net Pen Fish Culture Facility, Appendix C.
Alternative 1 - No Action. The No Action alternative would result in no effect on live bottom habitat
and associated biological communities around the proposed VE site because an aquaculture facility
would not be able to discharge any operational wastes without an NPDES permit, and, without a Section
10 permit, the facility would not be constructed or operated at this location on the west Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES and Section 10 Permits. The Proposed Action
alternative, issuance of NPDES and Section 10 permits will likely have minimal impacts to live bottom
habitat and associated communities expected to occur in the vicinity of the proposed facility. The siting
analysis conducted during the site selection process chose an area with sufficient depth and current flow
parameters that should result in rapid and broad dispersion of solid wastes discharged from the facility.
The relatively small fish biomass to be reared in the single cage (74,800 lbs. at harvest) demonstration is
also expected to result in small daily loading rates of discharged pollutants downstream of the cage. The
relatively low production of solid wastes from the single cage facility and the wide dispersal of
discharged solids to the benthos should minimize impacts to live bottoms. Additionally, the proposed
VE site will be located over unconsolidated sediments, limiting any potential physical and biological
impacts to live bottoms. Positioning away from potential live bottom habitat will mitigate physical
benthic impacts from anchors and mooring lines. The cage is designed to swivel around the center of a
suspended 3-point mooring, further reducing anchor chain sweep.
4.3.9	Seagrasses
Seagrasses occurring on the west Florida shelf are discussed in Section 3.3.9 Seagrasses. Because
seagrass distribution is dependent on water clarity for light penetration, the main impact causing factor
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to sea grasses around offshore aquaculture operations is the discharge of suspended solids consisting of
uneaten feed and fish feces, resulting in reduced water clarity and light attenuation. Paddle grass was not
observed at the Tampa ODMDS at depths ranging from 14-27m (40-80 ft.), likely due to low water
clarity. Additionally, impacts may also result from solids deposition and organic enrichments to seafloor
sediments.
Alternative 1 - No Action. The No Action alternative would result in no effect on seagrasses and
associated biological communities around the proposed VE site because an aquaculture facility would
not be able to discharge any operational wastes without an NPDES permit, and, without a Section 10
permit, the facility would not be constructed or operated at this location on the west Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES and Section 10 Permits. The Proposed Action
alternative, issuance of NPDES and Section 10 permits will likely have only very minimal impacts to
sea grasses and associated communities as they are not expected to occur in the vicinity of the proposed
facility. In addition, the siting analysis conducted during the site selection process chose an area with
sufficient depth and current flow parameters that should result in rapid and broad dispersion of
suspended solids discharged from the facility. The relatively small fish biomass to be reared in the single
cage (74,800 lbs. at harvest) demonstration is also expected to result in small daily loading rates of
discharged pollutants downstream of the cage. The relatively low production of solid wastes from the
single cage facility and the wide dispersal of discharged solids to the benthos should minimize impacts
to seagrasses.
4.4 Social and Economic Environment
The following sections focus on the proposed action impacts on four primary areas: aquaculture
production, commercial fishing, recreational fishing, human health/public health, and environmental
justice.
4.4.1 Commercial Marine Aquaculture Production
This project is not expected to have an adverse socio-economic impact on current commercial
aquaculture production or producers in the Gulf because finfish production in the Gulf has been limited
to freshwater species, such as catfish or tilapias, and Almaco jack is not a substitute for those species.
Alternative 1: No Action. The No Action alternative would result in no effect commercial marine
aquaculture production, because an aquaculture facility would not be able to discharge any operational
wastes without an NPDES permit, and, without a Section 10 permit, the facility would not be
constructed or operated at this location on the west Florida Shelf.
Alternative 2: It is not expected the proposed project will negatively impact commercial marine
aquaculture production in the Gulf.
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4.4.2	Commerci fieries
A discussion of the status of commercial fisheries is provided in Section 3.4.3 Commercial Landings of
Almaco Jack and Section 3.4.4 Commercial Fisheries. The potential for impacts to commercially
important fin fishes and invertebrates were discussed above in Section 4.3.1 Fish and Section 4.3.2
Invertebrates.
As stated previously and should be emphasized, Almaco jack is not a targeted commercial fish. It is only
harvested incidentally. Consequently, production of farmed Almaco jack from the proposed VE project
is not expected to have an adverse economic impact on commercial fishing businesses that land Almaco
jack.
The siting analysis conducted during the site selection process chose an area with sufficient depth and
current flow parameters that should result in rapid dilution of dissolved wastes and broad dispersion of
solid wastes discharged from the facility. The relatively small fish biomass to be reared in the single
cage (74,800 lbs. at harvest) demonstration is also expected to result in small daily loading rates of
discharged pollutants downstream of the cage. Exposure to any discharged pollutants will be minimal.
Additionally, the proposed site was selected to minimize potential conflicts with shrimping and other
commercial fishing activities in the area. A more extensive discussion of the potential for impacts of fish
farming to commercial fisheries can be found in the ODCE for Kampachi Farms - Velella Epsilon Net
Pen Fish Culture Facility, Appendix C.
Alternative 1: No Action. The No Action alternative would result in no effect on commercial fisheries
around the site, because an aquaculture facility would not be able to discharge any operational wastes
without an NPDES permit, and, without a Section 10 permit, the facility would not be constructed or
operated at this location on the west Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES, and Section 10 Permits. The Proposed Action
alternative, issuance of NPDES and Section 10 permits will likely have minimal impacts to commercial
fishing industry.
4.4.3	Recreational Fishing
Recreational fishing that may occur in the vicinity of the proposed VE site is discussed in Section 3.4.5
Recreational Marine Fishing. The factors most likely to impact recreational fisheries around offshore
aquaculture operations are the discharges of dissolved and particulate inorganic and organic nutrients
into the water column and discharges of total solids deposition and organic enrichments to seafloor
sediments from uneaten feed and fish feces. These discharges can impact through the degradation of
water quality, affecting sensitive early life stages of marine fishes, and organic enrichment of benthic
sediments, affecting habitat that supports juvenile and adult fish communities and surrounding food
sources. In addition, siting of stationary fish farms may interfere with recreational fishing activities. A
more extensive discussion of the potential for impacts of fish farming to commercial fisheries can be
found in the ODCE for Kampachi Farms - Velella Epsilon Net Pen Fish Culture Facility, Appendix C.
Alternative 1 - No Action. The No Action alternative would result in no effect on early life stages of
fish water column or benthic fish communities around the site, because an aquaculture facility would not
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be able to discharge any operational wastes without an NPDES permit, and, without a Section 10 permit,
the facility would not be constructed or operated at this location on the west Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES and Section 10 Permits. The Proposed Action
alternative, issuance of NPDES and Section 10 permits will likely have minimal impacts to recreational
fisheries that may occur in the vicinity of the proposed facility. The siting analysis conducted during the
site selection process chose an area with sufficient depth and current flow parameters that should result
in rapid dilution of dissolved wastes and broad dispersion of solid wastes discharged from the facility.
The relatively small fish biomass to be reared in the single cage (74,800 lbs. at harvest) demonstration is
also expected to result in small daily loading rates of discharged pollutants downstream of the cage.
Exposure to any discharged pollutants will be minimal. Additionally, the proposed site was selected to
minimize potential conflicts with recreational fishing activities in the area.
4.4.4	Human Health/Public Health
Contamination from the use of the use of pharmaceuticals (Section 4.2.1.1) to prevent and control
disease in farmed fish and impacts to water and sediment quality (Sections 4.2.1 and 4.2.2) are potential
sources of bioaccumulated contaminants that can affect farmed fish quality. Consumption of farmed fish
exposed to pathogens and pollutants discharged from the aquaculture facility or in the open marine
environment could pose health risks to consumers. It is expected that potential adverse human health
outcomes are avoided or minimized based on the impact discussions presented in the following sections
of the EA: Water Quality (4.2.1), Pharmaceuticals (4.2.1.1), and Sediment Quality (4.2.2).
Alternative 1 - No Action. The No Action alternative would result in no effect on human health,
because an aquaculture facility would not be able to discharge any operational wastes without an
NPDES permit, and, without a Section 10 permit, the facility would not be constructed or operated at
this location on the west Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES and Section 10 Permits. The Proposed Action
alternative, issuance of NPDES and Section 10 permits will likely have minimal impacts to human
health due to water and sediment quality and fish health. The siting analysis conducted during the site
selection process chose an area with sufficient depth and current flow parameters that should result in
rapid dilution of dissolved wastes and broad dispersion of solid wastes discharged from the facility. The
relatively small fish biomass to be reared in the single cage (74,800 lbs. at harvest) demonstration is also
expected to result in small daily loading rates of discharged pollutants downstream of the cage. A small
harvest is also a fishery management measure of disease control and prevention in farmed fish (Section
3.2.1.3 Pharmaceuticals). Based on these factors, there are no significant human health/public health
impacts expected as a result of the proposed action.
4.4.5	Environmental Justice
Environmental justice (EJ) ensures that minority and low-income populations are not subject to
disproportionately high and adverse human health or environmental effects due to a proposed action. As
discussed in Section 4.4.4 Human Health/Public Health, contaminated fish resulting in adverse human
health outcomes is the same concern for EJ communities. The discharges authorized under this permit
are not expected to adversely impact farmed fish quality. Therefore, greater human health risks to
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minority and low-income populations from contaminated farmed fish is not expected. Refer to Section
4.4.4 Human Health/Public Health for the result of aquaculture and human health, and the alternative
effects.
The proposed action footprint would be relatively small and located well out to sea. There are no
minorities or low-income populations near the proposed action, but such populations may exist
in communities living onshore near staging areas used for the proposed VE project.
The proposed action would not cause changes to the physical or natural environment that would
affect coastal communities. The proposed action would not inhibit persons from any nearby
communities from fishing near the action area. Also, farmed fish landings from the proposed action are
not expected to effect commercial landings of Almaco jack because it is not directly targeted and is
incidentally caught by commercial fishermen. For these reasons, Alternative 2 is not likely to impact
adversely fish or other wildlife, habitats, or marine plants that are subsistence resources.
Finally, the proposed action is not expected to have disproportionately high and adverse environmental
or human health effects to minority and low-income populations that would require further consideration
under E.O. 12898.
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5.0	Cumulative Impacts
The Council on Environmental Quality's (CEQ) regulations define cumulative effects as "the impact on
the environment which results from the incremental impact of the action when added to other past,
present, and reasonably foreseeable future actions regardless of what agency (federal or non-federal) or
person undertakes such other actions" (40 CFR Section 1508.7). For this proposed action, it was
determined that the scope of the cumulative impacts analysis should encompass the project study area
and should extend the life of the permit action (5 years). As a part of this analysis, past, present and
reasonably foreseeable future actions that were considered included the 2010 Deep Water Horizon
(DWH) oil spill, oil and gas operations, future aquaculture operations and natural disasters. As noted in
1.9 Documents Incorporated by Reference of this EA, several previous NEPA documents are adopted by
reference. Information from these documents were used extensively in determining the cumulative
impacts of the proposed action. This analysis considers the cumulative impacts related to the preferred
alternative (Alternative 2). Below is a brief summary of issues and resource specific discussion related
to cumulative impacts in the context of the proposed action:
5.1	DWH
On April 20, 2010, the DWH mobile drilling unit exploded, caught fire, and eventually sank in the Gulf,
resulting in a massive release of oil and other substances from British Petroleum's Macondo well. The
Macondo well is located more than 300 miles North/Northwest of the proposed location of the VE
project. Regarding DWH, the NFMS conducted a thorough evaluation of direct, indirect and cumulative
impacts associated with the DWH in their 2015 Final Supplement to the Final Programmatic
Environmental Impact Statement for the Fishery Management Plan for Regulating Offshore Marine
Aquaculture in the Gulf of Mexico. EPA notes that on page 62 of this document NFMS concluded that
"several studies have produced preliminary information on the impacts of the DWH blowout to marine
organisms and ecosystems in the Gulf More information on the short- and long-term impacts of the
DWH blowout is needed to assess whether the additional stress caused by the DHW blowout has
resulted in a cumulative effect beyond current thresholds. " (NMFS, 2015b). The EPA and US ACE
concurs with these findings and recognize that the cumulative impacts associated with DWH are still
relatively unknown at this time and the minor incremental impact of the proposed action would have
little cumulative impact to the Gulf.
5.2	Oil and Gas Operations
Oil and gas operations are common in the Gulf. To evaluate the proposed action in the context of oil ang
gas activities EPA and US ACE considered information from both the EPA's 2016 National Pollutant
Discharge Elimination System (NPDES) Permit for Eastern Gulf of Mexico Offshore Oil and Gas
Exploration, Development, and Product Environmental Assessment (EPA, 2016) and the NMFS's 2015
Final Supplement to the Final Programmatic Environmental Impact Statement for the Fishery
Management Plan for Regulating Offshore Marine Aquaculture in the Gulf of Mexico (NMFS, 2015b).
As noted in the EPA EA (1.4.3 Moratoria) (EPA, 2016). Currently, there are no OCS areas restricted
under Congressional moratoria. However, in 2006 GOMES A [Gulf of Mexico Energy Security Act] was
enacted to restrict oil and gas leasing in portions of the Gulf through 2022. This action restricts leasing
within 125 miles of Florida in the eastern Gulf and within 100 miles of Florida in the central Gulf.
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The EPA notes that the proposed action is approximately 45 miles off the coast of Florida and within the
GOMES A restricted area. The EPA and US ACE conclude that the proposed action would have
negligible cumulative impacts regarding oil and gas operations because it is located in the drilling
moratoria area.
5.3	Future Aquaculture Operations
At present, there has only been one application received for which this EA is being developed and
another project (Manna Fish Farms) which is being proposed for an area located in the Northern Gulf.
This cumulative impact evaluation considered the incremental impacts associated with the aquaculture
impacts associated with this EA in combination with the future aquaculture operations proposed in the
Manna Fish Farms pre-application that is within the 5-year permit time frame. The Manna Fish Farms
proposes siting their facility off shore and south of Pensacola, FL. This project is planned to be a
commercial scale project. The location of the proposed Manna Fish Farm operations is approximately
300 miles from the operations proposed in this EA. Because of the significant distance between the two
aquaculture operations, the two operations would have negligible cumulative impacts on the Gulf.
However, EPA believes that it is reasonably foreseeable that the growth of the aquaculture industry in
the Gulf will occur at future point if these facilities are successful.
5.4	Physical Resources
As previously discussed in Section 4.2 Physical Resources, solid waste from the aquaculture operations
is the physical resource of concern and it was determined that the solid waste deposition would be
minimal. The incremental effect of the Proposed Action, issuance of the NPDES and Section 10 permits
would have minimal impact even combined with the other proposed project (Manna Fish Farms) for
aquaculture operations throughout the project area. Solid waste from the VE project and any future
aquaculture project would likely re-suspend and disperse. Other activities in the project area that were
considered such as any future oil and gas operations would cumulatively add little solid waste to the
project area.
5.4.1 Water Quality
As discussed in Section 4.2.1 Water Quality, the proposed action, issuance of the NPDES and Section 10
permits would produce ammonia levels significantly below the published ammonia aquatic life criteria
values for saltwater organisms (EPA, 1989). At present, there is only one NPDES permit application for
an aquaculture facility submitted to EPA in the Gulf (for which is the proposed action of this EA) and
one proposed project (Manna Fish Farms) discussed above. Also, the proposed action and Manna Fish
Farms proposed location are over 300 miles apart. Thus, it is anticipated that both actions combined
would cause negligible cumulative impacts to water quality.
In the USEPA Region 4's 2016 Environmental Assessment (EA) for National Pollutant Discharge
Elimination System (NPDES) Permit for Eastern Gulf of Mexico Offshore Oil and Gas Exploration,
Development, and Production, it was determined that water quality impacts associated with drilling
activities such as drilling fluids and cuttings during daily operations even combined with relatively
infrequent and low volume discharges such as WTCW fluids; deck drainage; sanitary and domestic
wastes; and miscellaneous wastes were minor water quality impacts. As previously discussed, there is a
moratorium on oil and gas operations within 125 miles of the Florida coast (EPA, 2016) and the
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proposed action is within that moratoria zone. Also, previously discussed, it was concluded that the
proposed action would have negligible cumulative impacts in relationship to large scale oil spills (such
as DWH).
There is a potential for water quality impacts associated with spills related to other shipping activities
(such as cargo ship spills, fuel spills due to ship wrecks or related to ship loss due to storms). However,
because of the minor water quality impacts associated with the Proposed Action it would have minor
cumulative impacts associated with spills from other shipping activities.
Additionally, the minor amount of ammonia produced by the Proposed Action would not incrementally
increase the cumulative impacts associated with other activities such as the proposed future oil and gas
activities, future aquaculture activities and any lingering environmental impacts associated with the
DWH.
5.4.1.1 Pharmaceuticals
As discussed in Section 4.2.1.1 Pharmaceuticals, the amounts of pharmaceuticals discharged will have
minimal direct impacts. The only other known facility within the Gulf that would have pharmaceutical
impacts would be the proposed Manna Fish Farm facility. As previously discussed, the Manna Fish
Farm would be over 300 miles in distance from the aquaculture operation being proposed so these
facilities would have negligible cumulative impacts to the Gulf.
In addition, the NPDES permit for the VE project will require that the use of any medicinal products
including therapeutics, antibiotics and other treatments are to be reported to the EPA. The report will
include types and amounts of medicinal product used and the period of time it was used.
5.4.2 Sediment Quality
As discussed in Section 4.2.2 Sediment Quality, numerous studies within the Mediterranean have shown
that organic inputs from fish farms on benthic macrofaunal are only limited up to 25 m from the edge of
the cages (Lampadariou, Karakassis, & Pearson, 2005) and carbon and nitrogen produced by fish farm
effluents on the sea floor is detected in an area about 1,000 m from the cages (Sara, Scilipoti, Mazzola,
& Modica, 2004). Also, the organic material will most likely re-suspend and be dispersed and will not
accumulate in any concentrations on the sea bed floor. Any remaining accumulation of organic material
would also be assimilated by macroinvertebrates living on the sea floor. Other potential sources of
organic and inorganic discharges near the proposed action could potentially be from point source
discharges such as land-based wastewater treatment and industrial discharges, discharges from septic
tanks and non-point discharges from stormwater. Additionally, waste from ships could contribute to
cumulative impacts associated with organic and inorganic pollution. It is unlikely that organic and
nitrogen from land-based discharges would reach the proposed facility 45 miles offshore. Conversely,
the effluent from the cages will have minimal impact and would not travel past 1,000 m to incrementally
combine with these other organic and nitrogen laden discharges to cause a cumulative impact. The
ODCE anticipates impacts from the VE facility will likely be limited to 300 m—500 m from the
perimeter of the cage (Appendix C). As previously stated, the other only known potential aquaculture
facility (Manna Fish Farm) is more than 300 miles away from the proposed facility and would not
incrementally contribute to the cumulative impacts in the study area.
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5.4.3 Air Quality
As discussed in Section 4.2.3 Air Quality, there are no large sources of anthropogenic emissions
expected to be released into the atmosphere from activities related to the proposed action. Aside from
the aquaculture facility, there may be some emissions from outboard motors used by sport fisherman and
commercial fishing operations. A tender vessel, used on site at the facility, may be a small source of
emissions in offshore waters; however, cumulative impacts from sources are expected to be minimal.
Should EPA receive credible scientific evidence during the comment period that suggests otherwise, the
information will be considered prior to issuance of the NPDES permit.
5.4.4	Coastal Barrier Beaches
As discussed in Section 4.2.4 Coastal Barrier Beaches, the VE project is to be located approximately 45
miles southwest of Sarasota and offshore from any coastal barrier beaches. Debris from the aquaculture
operation could accumulate and impact coastal beaches, but cumulative impacts to coastal barrier
beaches will be negligible.
5.4.5	Noise Environment
As discussed in Section 4.2.5 Noise Environment, the VE project location is an area with ambient noise
from wind, waves, and periodic noise from occasional boat and vessel traffic. Noise generated by the
site would remain at low levels and likely not be heard once coupled with water and wind effects that
would dampen any sounds originating at the facility. Cumulative impacts from noise are anticipated to
be negligible.
5.4.6	Climate
As discussed in Section 4.2.6 Climate, the VE project will result in negligible emissions of Green House
Gasses (GHGs) resulting from operation of support vessels. In general, aquaculture is considered to
make a minor, contribution to greenhouse gas emissions although the extent to which this occurs
depends on the species, size and location of facilities (Food and Agriculture Organization of the United
Nations, 2009). Additional contributors to GHG emissions in the Gulf include oil and gas operations,
commercial and recreational fishing operations, commercial shipping, and recreational boating.
While the proposed project may minimally contribute to global emissions, global climate change could
have significant effects on Gulf aquaculture operations. Climate change may affect the severity of
extreme weather (e.g., hurricanes), potentially generating more intense storms which could lead to
increases in storm-induced damage to equipment and facilities (IPCC, 2007; IPCC, 2013). The VE
project cages could be vulnerable to more frequent storm events in the Gulf, however, mitigation
measures in the NPDES permit will minimize the potential for damage to the environment from such an
event.
Other possible impacts of climate change include temperature changes which can influence organism
metabolism and alter ecological processes such as productivity and species interactions; changes in
precipitation patterns and a rise in sea level which could change the water balance of coastal ecosystems;
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altering patterns of wind and water circulation in the ocean environment; and influencing the
productivity of critical coastal ecosystems such as wetlands, estuaries, and coral reefs (IPCC, 2007).
None of these potential climate change impacts are expected to be significant with respect to the NPDES
permit duration of 5 years.
5.5 Biological Resources
As previously discussed in Section 4.3 Biological Resources, the factors with potential to impact
biological resources around coastal fish farms are disturbance, entanglement, vessel strikes, and the
discharges of dissolved and particulate inorganic and organic nutrients into the water column and
discharges of total solids deposition and organic enrichments to seafloor sediments from uneaten feed
and fish feces. The latter can potentially impact biological communities through the degradation of
water quality, affecting pelagic plants and animals, and organic enrichment of benthic sediments,
thereby, affecting benthic biota.
The EPA has determined that the small incremental effect of the Proposed Action, issuance of the
NPDES and Section 10 permits would have minimal impact even combined with the other proposed
projects (Manna Fish Farms) for aquaculture operations throughout the project area. Solid waste from
the VE project and any future aquaculture project would likely re-suspend and disperse. Other activities
in the project area that were considered when evaluating potential impacts on biological resources
included future oil and gas operations which would cumulatively add little solid waste to the project
area.
5.5.1 Fish
Fish that can occur in the vicinity of the proposed VE project area are discussed in Section 3.3.1 Fish. In
general, the factors that may impact fish near coastal offshore aquaculture operations are disturbance
and water and sediment quality degradation as a result of waste discharges. Potential water quality
impacts are associated with discharges of dissolved and particulate inorganic and organic nutrients into
the water column and discharges of total solids deposition and organic enrichments to seafloor
sediments from uneaten feed and fish feces. These discharges can potentially impact protected fish
through the degradation of water quality, affecting pelagic plants and animals, and organic enrichment
of benthic sediments, affecting benthic habitat. Cumulative impacts to water quality may include
discharges of dissolved and particulate inorganic and organic nutrients into the water column, and
discharges of total solids deposition and organic enrichments to seafloor sediments from uneaten feed
and fish feces. Other potential sources of organic and inorganic discharges are waste from ships and
point sources such as land-based wastewater treatment, industrial discharges, discharges from septic
tanks, and non-point discharges from stormwater. It is not expected that the discharges from the VE
project would incrementally combine with these other discharges because the proposed facility is 45
miles offshore in an area selected for enhanced currents.
There are also physical impacts throughout the Gulf that could cause fish mortality such as entanglement
in fishing gear and other floating material, and digestion of plastics. However, due to the small size of
the VE project and the expected temporary nature of the proposed project it is anticipated that this
proposed action would have minor to negligible impacts and would not cumulatively impact fish.
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As previously stated, the other only known potential aquaculture facility being proposed in the Gulf
(Manna Fish Farm) is more than 300 miles away from the proposed facility and would not incrementally
contribute to the cumulative impacts in the study area. Given the relatively small footprint of the VE
project in context of the previously discussed impacts, it is anticipated that this proposed action would
have minimal to negligible impacts and would not cumulatively impact fish. Furthermore, the EPA and
US ACE will include permit provisions that will contain environmental monitoring (water quality,
sediment, benthic infauna, etc.) and other conditions that minimize potential adverse impacts to fish.
5.5.2	Invertebrates
Marine invertebrates occurring in the Gulf are discussed in Section 3.3.2 Invertebrates. The factors that
may impact marine invertebrate communities near coastal offshore aquaculture operations are impacts to
water and sediment quality. Anchor placement and mooring line sweep may impact sessile benthic
invertebrates. Expected discharges from aquaculture operations include dissolved and particulate
inorganic and organic nutrients into the water column, total solids deposition, and organic enrichments
to seafloor sediments from uneaten feed and fish feces These discharges can potentially impact protected
corals through the degradation of water quality, and organic enrichment of benthic sediments, affecting
benthic habitat. Other potential sources of organic and inorganic discharges are waste from ships and
point sources such as land-based wastewater treatment, industrial discharges, discharges from septic
tanks, and non-point discharges from storm water. However, it is not expected that the discharges from
the VE project would incrementally combine with these other discharges because the proposed facility is
45 miles offshore in an area selected for enhanced currents.
Additionally, as previously stated, the other only known potential aquaculture facility being proposed in
the Gulf (Manna Fish Farm) is more than 300 miles away from the proposed facility and would not
incrementally contribute to the cumulative impacts in the study area. Given the relatively small
footprint of the VE project in context of the previously discussed impacts, it is anticipated that this
proposed action would have minimal to negligible impacts and would not cumulatively impact
invertebrates. Furthermore, the EPA and USACE will include permit provisions that will contain
environmental monitoring (water quality, sediment, benthic infauna, etc.) and other conditions that
minimize potential adverse impacts to invertebrates.
5.5.3	Marine Mammals
Marine mammals occurring in the Gulf are discussed in Section 3.3.3 Marine Mammals. The factors that
may impact marine mammals near coastal offshore aquaculture operations are potential entanglement,
vessel strikes, behavioral disturbance, and impacts to water and sediment quality. Entanglement risks to
marine mammals will be minimized by using rigid and durable cage materials and by keeping all lines
taut, however, should entanglement occur, on-site staff would follow the steps outlined in the PSMP and
alert the appropriate experts for an active entanglement. Facility staff will monitor for the potential of
vessel strikes, however, the probability that collisions with the vessel associated with the proposed
project would kill or injure marine mammals is discountable as the vessel will not be operated at speeds
known to injure or kill marine mammals. Additionally, all vessels are expected to follow the vessel
strike and avoidance measures that have been developed by the NMFS. Disturbance to marine
mammals from ocean noise generated by the proposed facility is expected to be extremely low given
that the there is one production cage and one vessel that will be deployed for a duration of
approximately 18 months.
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Expected discharges from aquaculture operations include dissolved and particulate inorganic and
organic nutrients into the water column, total solids deposition, and organic enrichments to seafloor
sediments from uneaten feed and fish feces These discharges can potentially impact protected corals
through the degradation of water quality, and organic enrichment of benthic sediments, affecting benthic
habitat. Other potential sources of organic and inorganic discharges are waste from ships and point
sources such as land-based wastewater treatment, industrial discharges, discharges from septic tanks,
and non-point discharges from stormwater. However, it is not expected that the discharges from the VE
project would incrementally combine with these other discharges because the proposed facility is 45
miles offshore in an area selected for enhanced currents.
Since the VE project has a very low potential of impacting marine mammals by entanglement, vessel
strikes, behavioral disturbance, and impacts to water and sediment quality, the overall cumulative impact
potential for VE project is negligible.
5.5.4	Sea Turtles
Sea turtles occurring in the Gulf are discussed in Section 3.3.4 Sea Turtles. The factors that may impact
protected sea turtles near coastal offshore aquaculture operations are impacts to water quality,
entanglement, physical encounters with the pen system, and behavioral disturbance.
Entanglement risks to sea turtles will be minimized by using rigid and durable cage materials and by
keeping all lines taut, additionally, the pen will use a rigid copper alloy mesh, which presents no
entanglement hazard. Sea turtles may experience disturbance by stress due to a startled reaction should
they encounter vessels in transit to the proposed project site. Given the limited trips to the site,
opportunities for disturbance from vessels participating in the proposed project are minimal.
Disturbance to sea turtles by the proposed facility is expected to be extremely low given that the there is
one production cage and one vessel that will be deployed for a duration of approximately 18 months.
Potential water quality impacts associated with discharges from aquaculture operations include
dissolved and particulate inorganic and organic nutrients into the water column, total solids deposition,
and organic enrichments to seafloor sediments from uneaten feed and fish feces These discharges can
potentially impact protected corals through the degradation of water quality, and organic enrichment of
benthic sediments, affecting benthic habitat. Other potential sources of organic and inorganic discharges
are waste from ships and point sources such as land-based wastewater treatment, industrial discharges,
discharges from septic tanks, and non-point discharges from stormwater. However, it is not expected
that the discharges from the VE project would incrementally combine with these other discharges
because the proposed facility is 45 miles offshore in an area selected for enhanced currents.
Since the VE project has a very low potential of impacting sea turtles by entanglement, physical
encounters with the pen system, behavioral disturbance, and water quality the overall cumulative impact
potential for VE project is negligible.
5.5.5	Birds
Birds occurring in the Gulf are discussed in Section 3.3.5 Birds. Potential impacts to seabirds from the
VE project may be due to the physical structure, presence of fish, and associated activities that would
attract migratory seabirds as well as other migratory birds. Seabirds are not expected to interact with the
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proposed project or become trapped in the cage due to distance of the proposed project from shore
(approximately 45 miles). Should there be any interaction that results in an injury to a protected seabird,
the on-site staff would follow the steps outlined in the PSMP and alert the appropriate experts for an
active entanglement. The project staff will suspend all surface activities, including stocking, harvesting
operations, and routine maintenance operations in the unlikely event that an ESA-listed seabird comes
within 100 m of the activity until the bird leaves the area. Any potential effects from the proposed action
on ESA-listed birds are discountable because the effects are extremely unlikely to occur.
Since the VE project has a very low potential of impacting birds due to the low potential for presence at
the site the overall cumulative impact potential for VE project on birds is negligible.
5.5.6 Essential Fish Habitat
The environmental factors most likely to impact essential fish habitat around offshore aquaculture
operations are the discharges of dissolved and particulate inorganic and organic nutrients into the water
column and discharges of total solids deposition and organic enrichments to seafloor sediments from
uneaten feed and fish feces. These discharges can impact through the degradation of water quality,
affecting habitat critical to sensitive early life stages of marine invertebrates and pelagic adult forms.
Organic enrichment of benthic sediments can impact habitat that supports juvenile and adult invertebrate
communities and surrounding food sources.
As previously discussed the Proposed Action alternative, issuance of an NPDES and Section 10 permits
will likely have only very minimal impacts to essential fish habitat expected to occur near the proposed
facility. The siting analysis conducted during the site selection process chose an area with sufficient
depth and current flow parameters that should result in rapid dilution of dissolved wastes and broad
dispersion of solid wastes discharged from the facility. The relatively small fish biomass to be reared in
the single cage (74,800 lbs. at harvest) demonstration is also expected to result in small daily loading
rates of discharged pollutants downstream of the cage. In addition, pelagic animals passing through the
area and would be at the facility temporarily. Exposure to any discharged pollutants would be minimal.
Other potential sources of organic and inorganic discharges near the VE project could potentially be
from point source discharges such as land-based wastewater treatment and industrial discharges,
discharges from septic tanks and non-point discharges from stormwater. Additionally, waste from ships
could contribute to cumulative impacts associated with organic and inorganic pollution. It is unlikely
that organic and nitrogen from land-based discharges would reach the proposed facility 45 miles off
shore Conversely, the effluent from the cages will have minimal impact and would not travel past 1,000
m to incrementally combine with these other organic and nitrogen laden discharges to cause a
cumulative impact. The ODCE anticipates impacts from the VE facility will likely be limited to 300
m—500 m from the perimeter of the cage (Appendix C). As previously stated, the other only known
potential aquaculture facility (Manna Fish Farm) would occur more than 300 miles away from the
proposed facility and, thus, would not incrementally contribute to the cumulative impacts in the study
area.
Additionally, impacts related to natural disasters combined with the previously discussed impacts could
cumulatively impact protected marine habitat. On page 363 in the NMFS PFEIS, it was documented that
the impacts related to natural disasters and economic change that "can also affect resources, ecosystems,
and communities. Such events include diseases outbreaks, red tides, changes in economic conditions,
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foreign imports, high fuel prices, hurricanes and storm events, and hypoxia" (Gulf of Mexico Fishery
Management Council and National Oceanic and Atmospheric Adminstration National Marine Fisheries
Service, 2009). However, it is anticipated that the cumulative impacts associated with the proposed
action and natural disasters (such as storms, hurricanes, red tides, etc.) would be minor. The EPA
provided an EFH assessment to the NMFS for consideration on our determination that the proposed
project would not result in substantial adverse effects on EFH and the permits will have conditions to
mitigate any minor impacts that may occur (Appendix E).
5.5.7	Deepwater Benthic Communities
Deepwater benthic communities do not occur within a distance of approximately 90 miles or more,
seaward of the proposed VE site. Therefore, no cumulative impact on this resource is expected.
5.5.8	Live Bottoms
The main impact causing factor to live bottom communities around coastal fish farms is the discharge of
total solids consisting of uneaten feed and fish feces, resulting in solids deposition and organic
enrichments to seafloor sediments. These discharges can affect water and sediment quality and may lead
to eutrophication of both, in turn affecting the benthic habitat and dynamic as a whole.
Cumulative impacts to live bottom habitats in the vicinity of the proposed facility are expected to be
minimal due to sufficient depth and flow parameters at the site that result in rapid dispersion of waste.
Small daily loading rates of discharged pollutants are anticipated due to the small fish biomass being
reared. This coupled with a wide dispersal of discharged solids limits impacts to live bottoms.
5.5.9	Seagrasses
Seagrass growth is dependent on water clarity for light penetration. As with live bottoms, the main
impact causing factor to seagrasses around offshore aquaculture operations is the discharge of total
solids consisting of uneaten feed and fish feces.
Cumulative impacts to seagrasses are expected to be minimal due to the lack of them in the vicinity of
the proposed facility. Additionally, sufficient depth and flow parameters at the site should result in rapid
dispersion of waste. Small daily loading rates of discharged pollutants are anticipated due to the small
fish biomass being reared. This coupled with a wide dispersal of discharged solids limits impacts to
seagrasses.
5.6 Social and Economic Environment
The following sections focus on the proposed action impacts on four primary areas: aquaculture
production, commercial and recreational fishing, human health/public health, and environmental justice.
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5.6.1	Aquaculture Producti on
The Gulf Region within state waters or inland is a major aquaculture producer. Freshwater aquaculture
far exceeds marine aquaculture and pond aquaculture, which is the most popular method. Nonetheless,
marine aquaculture production in Gulf state waters and inland has been increasing. Because Almaco
jack is not a commercially targeted species and is not a substitute for the Gulfs freshwater finfish
production (Sections 3.4.2 Commercial Marine Aquaculture Production, 3.4.3 Commercial Landings of
Almaco Jack, 4.4.1 Commercial Marine Aquaculture Production and 4.4.2 Commercial Fisheries)
cumulative impacts from the proposed facility are expected to be minimal.
5.6.2	Commercial and Recreational Fishing
The proposed action alternative is expected to have minimal impacts on commercial and recreational
fishing that may occur in the vicinity of the facility. Fishermen are expected to maintain a safe operating
distance from the site, as trolling too closely may result in the loss of expensive fishing lures and other
gear. With respect to safety and vessel operations, the risk of gear entanglements or collisions with the
feed barge, mooring line, or tethers are not expected.
One factor directly related to the proposed action that could impact commercial and recreational
fisheries around coastal fish farms are the discharges of dissolved and particulate inorganic and organic
nutrients into the water column and discharges of total solids deposition and organic enrichments to
seafloor sediments from uneaten feed and fish feces. The area chosen for the proposed activity has depth
and current flow parameters that should result in rapid and broad dispersion of solid wastes discharged
from the facility. Due to the small fish biomass (74,800 lbs. produced during a 280-day fish production
cycle) in the single cage facility and current flows measured in the vicinity of the selected site, impacts
on water quality as it relates to commercial/recreational fishing is expected to be minimal. To put the
proposed facility in perspective, the average annual catch of a single fishing ship in the U.S. is 40,000
metric tons (or the equivalent of 88,184,920 lbs.) (Stupachenko, 2018).
The rapid development of marine aquaculture around the world has raised concerns over the possible
genetic and ecological impact of escaped fish on natural populations. Potential effects include genetic
modification and reduced fitness, competition for food and space, introduction or spread of diseases and
parasites, and predation on native stocks. Intentional releases for stock replenishment or stock
enhancement may have positive or negative effects on natural populations by increasing stock size and
abundance. Additionally, the effects of accidental releases by species or number may or may not have
negative effects. The effect depends on the genetic state of the escaped cultured fish as well as the
numbers and mean individual size of the escaped population.
Some commercial fishermen are concerned that aquaculture will negatively affect prices for wild harvest
in the U.S. through increased supply (Rubino, 2008). Competition in seafood markets will exist with or
without domestic aquaculture. The U.S. cannot meet consumer seafood demand through wild caught
fishing activities alone, and seafood imports and other forms of protein (such as chicken and beef)
already provide significant competition. One reference source (Anderson & Shamshak, 2008) explains
that even if potential offshore aquaculture species are not raised domestically, the importation of these
and other aquaculture species will continue, and most likely increase, as the forecasted gap between
supply and demand for seafood widens.
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5.6.3	Human Health/Public Health
Bioaccumulation of contaminants in fish represent minimal cumulative impacts based on the relatively
small fish biomass proposed by the applicant. The potential adverse impacts to seafood quality would be
minimized by rapid dilution of dissolved wastes and dispersion of solid wastes discharged from the
facility, fishery management controls (Sections 3.2.1.3 and 4.2.1.1 Pharmaceuticals), and permit
conditions. Permit conditions that avoid or minimize potential adverse impacts to commercial and
recreational fisheries are the same requirements that would address human health concerns. Therefore, it
is not considered that potential impacts to human health from the activities proposed under this EA
would be significant.
5.6.4	Environmental Justice
Disproportionately high and adverse human health effects on EJ communities are not expected from the
permitted proposed action. Impacts on human health/public health related to farm fish quality and
landings have been discussed in the Human Health (Section 4.4.4) and Environmental Justice (Section
4.4.5) sections.
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6.0	Summary of Alternatives
6.1	Alternatives Summary
As discussed in Section 2.0 Alternatives, the EPA and the USACE are considering two alternatives for
the proposed VE project in this EA. Alternatives considered include a No-action alternative and an
action alternative, issuance of a NPDES permit and USACE Section 10 permit for the facility.
6.1.1	Alternative 1: No Action
Under the no-action alternative the EPA would not issue the NPDES permit and the USACE would not
issue a Section 10 permit for the proposed VE project. The effects of the no action alternative would be
as described in Chapter 3, Affected Environment, in which no structures or pens would exist at the site
location.
6.1.2	Alternative 2: Proposed Action—Issuance of NPDES Permit and Section 10
Authorization for Velella Epsilon
Under Alternative 2, the EPA would issue a NPDES permit and the USACE would issue a Section 10
permit for the proposed VE project. Below provides a summary of the permit conditions that will be
included in the NPDES permit and Section 10 permit:
EPA NPDES Permit
The proposed permit would include monitoring conditions and limitations that are based on the previous
NPDES permits and the BPJ of the permit writer. These permit conditions will be consistent with the
Clean Water Act (CWA) Section 308, Section 312, Section 402, and Section 403, and 40 CFR Section
125 and the concentrated aquatic animal production facilities regulations at 40 CFR Section 122.24 and
40 CFR Part 451. While 40 CFR Part 451 applies to facilities which meet the CAAP definition, and is
not directly applicable to the proposed facility which does not meet the production thresholds of the
CAAP definition, the NPDES permit for the proposed facility will apply the effluent guideline
limitations of 40 CFR Part 451 based on the BPJ of the permit writer and the factors in 40 CFR Part 125,
Subpart A.
The aquaculture-specific water quality conditions contained in the NPDES permit will generally include
an environmental monitoring plan and effluent limitations expressed as BMPs. The environmental
monitoring plan is included to examine the effects of the facility's discharges on surrounding ecosystem.
The environmental monitoring plan is based upon 40 CFR Section 125.123(d). The proposed NPDES
permit includes water quality monitoring (feed rate, pH, dissolved oxygen, chlorophyll a (chl-a),
temperature, nitrogen, phosphorus, turbidity, drugs, and total ammonia nitrogen), sediment monitoring,
and benthic macroinvertebrate sampling. The permit also includes the prohibitions on the discharge of
solid materials. The BMP Plan will require implementation of practices intended to meet the effluent
limit guidelines established for the Concentrated Aquatic Animal Production Point Source Category (40
CFR Section 451).
The permit also requires development and implementation of a facilities damage control plan to prevent
and contain facilities damages due to man-made and natural disasters. As part of the plan, the permittee
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will be required to identify equipment and implement procedures to be used to prevent and contain the
facility's damages due natural disasters and storm events. The requirement for the plan is included based
upon the BPJ of the permit writer. The permit also requires development and implementation of a spill
control plan to prevent and control spills of toxic or hazardous substances listed under CWA Section
307(a) and Section 311 that may reach surface waters. The permittee will be required to identify any
toxic chemicals used at the facility.
USACE Letter of Permission (LOP)
The proposed USACE LOP would include special conditions protecting general navigation of the area,
requirements for implementation of a tracking system for the net pen, adherence to the proposed Marine
Mammal, Sea Turtle, and Seabird Monitoring and Data Collection Plan (Protected Species Plan), and
other notification and compliance requirements, as deemed appropriate.
6.2	Comparison of Alternatives
The basic difference between the alternatives are action versus no action. Alternative 1 represents the
baseline conditions of the project location without an offshore aquaculture project being located at the
project site. The action alternative (Alternative 2) represents authorizing Kampachi Farms to install
aquaculture pens at the project location and allows discharges associated with the operation of these
pens. The anticipated impacts associated with Alternative 2 include relatively minimal impacts to
physical, biological, socioeconomic resources. The EPA and USACE believe the VE NPDES and
Section 10 permit, Alternative 2, will have adequate provisions to avoid or minimize potential
significant environmental impacts.
6.3	Preferred Alternative
EPA and the USACE have selected Alternative 2 as the preferred alternative. The major difference in
the alternatives is one represents the no action, Alternative 1, and one represents issuance of the
proposed NPDES and Section 10 permits, Alternative 2.
The proposed NPDES Individual Permit and Section 10 permit for the VE project, Alternative 2,
contains provisions that are sufficiently protective of the marine waters and resources of the Gulf. As
long as Kampachi Farms complies with the proposed Individual Permit and Section 10 permit
requirements, the EPA and the USACE do not expect the discharges from the facility or the construction
of the facility to materially degrade the environmental resources of the Gulf. In addition, the proposed
EPA Individual Permit, Alternative 2, has a re-opener provision that authorizes EPA to modify the
NPDES permit as necessary in response to new information demonstrating the provisions of the
proposed Individual Permit are inadequately protective of marine resources of the Gulf.
6.4	Unavoidable Adverse Impacts
The NPDES individual permit discharges from the proposed VE project are expected to have
unavoidable minor impacts, primarily in the vicinity of the proposed project. For the most part, these
impacts would be short-term in nature, limited in spatial extent, and expected to have a low likelihood to
result in cumulative impacts. The potential impacts of authorized effluent discharges are controlled
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through effluent discharge limits, the restricted use or prohibited use of substances contained in
authorized waste streams, and best management plans.
Notwithstanding the possibility of these unavoidable adverse impacts, EPA had determined that, based
on the findings of the ODCEs for the previous NPDES Individual Permits, the issuance of the proposed
NDPES Individual Permit for VE project will not result in unreasonable degradation of nor irreparable
harm to the marine environment of the Gulf of Mexico with all permit terms, conditions, and limitations
in place. The ODCE for this proposed Individual Permit has the same findings.
6.5 Irreversible and Irretrievable Commitments of Resources
The National Environmental Policy Act Section 101 (2)(c)(v) requires a detailed statement on any
irreversible and irretrievable commitments of resources that would be involved in the proposed action
should it be implemented. Irreversible and irretrievable resource commitments are related to the use of
non-renewable resources and the effects that the use of those resources have on future generations.
Irreversible commitments of resources are those that cannot be reversed except over an extremely long
period of time. These irreversible effects primarily result from destruction of a specific resource (e.g.,
energy and minerals) that cannot be replaced within a reasonable time frame. Irretrievable resource
commitments involve the loss in value of an affected resource that cannot be restored as a result of the
action (e.g., extinction of a threatened or endangered species or the disturbance of a cultural site).
The proposed action would constitute an irreversible or irretrievable commitment of non-renewable or
depletable resources, for the materials, time, money, and energy expended during activities
implementing the proposed action. Under the no-action alternative, there would be no irreversible and
irretrievable commitments of resources. Irreversible and/or irretrievable impacts for the proposed action
are noted below.
Consumption of fossil fuels and energy would occur during buildout of the aquaculture pens and
operation activities. Fossil fuels (gasoline and diesel oil) would be used to power support vessels and
generators. The energy consumed for project construction and operation represents a permanent and
non-renewable commitment of these resources.
Materials for construction of new facility would be irretrievably committed for the life of the project.
Use of these materials represents a further depletion of natural resources. Construction and maintenance
activities are considered a long-term non-renewable investment of these resources.
Impacts to the sea bottom are expected to be temporary and are not expected to be an irreversible and
irretrievable resource commitment, however access to the area around and the facility may be limited
during the life of the project. There would also be commitment of time and money for the planning,
permitting, and implementation of the proposed project.
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6.6	Relationship Between Short-term Uses of the Environment and the Maintenance and
Enhancement of Long-Term Productivity
The short-term uses of the environment that are considered in the EA include the water column and
discharges of total solids. Issuance of an NPDES individual permit and Section 10 permit for VE project
and the other cumulative activities in the Gulf, are compatible with the maintenance of long-term
productivity in the Gulf. Any unavoidable adverse impacts associated with the proposed activity are
anticipated to be primarily short-term and localized in nature.
6.7	Preliminary Finding of No Significant Impact (FONSI)
Consistent with 40 CFR §1508,13, the EPA has determined that the proposed action (issuance of an
NPDES permit, Alternative 2) will not cause a significant impact on the environment as outlined in this
draft EA. The issuance of the NPDES permit to the applicant will not cause a significant environmental
impact to water quality or result in any other significant impacts to human health or the natural
environment. The EPA is making this preliminary FONSI available to the public in accordance with 40
CFR Section 6.203 before finalizing our permit decision. Sqq Appendix G.
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7.0	Other Protective Measures ar eney Coordination Efforts
The proposed permit and authorization include several conditions, terms, and provisions that are
protective measures against potential environmental consequences of the proposed action. The EPA and
US ACE has consulted multiple federal and state agencies for the proposed project. These additional
consultation and coordination efforts include the following:
•	State CZMP consistency
•	National Historic Preservation Act
•	The Wild and Scenic Rivers Act
•	The Fish and Wildlife Coordination Act
•	ESA Consultation
•	EFH Consultation
•	Consideration of CWA Section 401
•	MMPA Coordination
7.1	State Coastal Zone Management Program Consistency
Coastal Zone Management Act (CZMA), 16 U.S.C. 1451 et seq. was enacted to protect the Nation's
coastal zone and is implemented through state-federal partnerships. Section 307(c) of CZMA prohibits
the issuance of NPDES permits for activities affecting land or water use in coastal zones unless the
permit applicant certifies that the proposed activity complies with the state coastal zone management
program.11
Issuing a NPDES permit and Section 10 authorization for the VE project is a federal action that requires
compliance with the CZMA, therefore the applicant is required to certify that their proposed project
complies with the State of Florida's Coastal Zone Management Program. On February 25, 2019, the
applicant received CZMA concurrence from the State of Florida for the proposed project. Agency
coordination letters and correspondences related to CZMA are provided in Appendix H.
7.2	National Historic Preservation Act i Ni UVO
Under 16 U.S.C. 470 et seq. Section 106 of the Act and implementing regulations (36 CFR Part 800)
require the Regional Administrator, before issuing a license (permit), to adopt measures when feasible to
mitigate potential adverse effects of the licensed activity and properties listed or eligible for listing in the
National Register of Historic Places. The Act's requirements are to be implemented in cooperation with
state historic preservation officers and upon notice to, and when appropriate, in consultation with the
Advisory Council on Historic Preservation.
During the permitting process for the proposed project the applicant coordinated with the State Historic
Preservation Office (SHPO) in Florida to ensure compliance with NHPA. In a letter dated February 8,
11 Cited from https://www.epa.gov/npdes/other-federal-laws-apply-npdes-permit-program
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2019, the SHPO provided concurrence that the project will have no effect on historic properties.
Agency coordination letters and correspondences related to NHPA are provided in Appendix H.
7.3	The Wild and Scenic Rivers Act
Under 16 U.S.C. 1273 et seq. Section 7 of the Act prohibits the Regional Administrator from assisting
by license or otherwise the construction of any water resources project that would have a direct, adverse
effect on the values for which a national wild and scenic river was established. The proposed project
selected site is located on the west Florida Shelf, approximately 45 miles west, southwest of Longboat
Pass-Sarasota Bay, Florida in federal waters. It is not expected that this project will impact any wild and
scenic rivers.
7.4	Fish and Wildlife Coordination Act
Under 16 U.S.C. 661 et seq. - the Regional Administrator, before issuing a permit proposing or
authorizing the impoundment (with certain exemptions), diversion, or other control or modification of
any body of water, consult with the United States Fish and Wildlife Service, Department of the Interior,
and the appropriate state agency exercising jurisdiction over wildlife resources to conserve those
resources.
The EPA has coordinated with the FWS to ensure compliance with the Fish and Wildlife Coordination
Act. The EPA invited thee FWS to participate as a cooperating agency for the development of this EA
for the proposed project on November 7, 2018. Agency coordination letters and correspondences related
to Fish and Wildlife Coordination Act are provided in Appendix H.
7.5	Section 7 ESA Coordination
16 U.S.C. 1531 et seq. Section 7 of the ESA requires that federal agencies consult with the ESA
administering services to ensure that any projects authorized, funded, or carried out by them are not
likely to jeopardize the continued existence of any endangered species or threatened species, or result in
the destruction or adverse modification of critical habitat of such species.
The EPA is communicating with FWS and NMFS to coordinate on endangered species. The
consultation letters are included in Appendix D of this EA. The EPA is submitting this EA and the
Biological Evaluation document, included as Appendix D, to the 'Services' for their review. In preparing
the EA, the EPA and US ACE have made the determination that its preferred alternative "may affect, but
not likely to adversely affect" listed species, critical habitat, or proposed species and proposed critical
habitat under the jurisdiction of NMFS. Additionally, the EPA and USACE have made the
determination that its preferred alternative will have "no effect" on listed species, critical habitat, or
proposed species and proposed critical habitat under the jurisdiction of FWS. The EPA will carefully
consider all comments from these agencies regarding ESA protected species in developing the final
permit and the finding of no significant impact (FONSI).
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7.6	Essential l'ish and Habitat Consultation
Essential Fish Habitat Provisions of the Magnuson-Stevens Act - EFH promotes the protection of
essential fish habitat in the review of projects conducted under federal permits, licenses, or other
authorities that affect or have the potential to affect such habitat. EFH requires that the EPA consult with
the NMFS for any EPA-issued permits which may adversely affect essential fish habitat identified under
the Magnuson-Stevens Act.
An EFH assessment was prepared by the EPA and the United States Army Corps of Engineers (US ACE).
On March 8, 2019, the EPA provided the EFH assessment to the NMFS and initiated abbreviated
consultation with the NMFS. On March 12, 2019, the NMFS concurred with the EFH determination made
by the EPA and the US ACE. After completion and concurrence of the assessment, minor changes were
made to the EFH document, though the updates did not change the findings of the assessment. On August
2, 2019 EPA provided the updated EFH assessment to NMFS for concurrence. Consultation with NMFS
on these changes will occur during the public comment period (See Appendix E).
7.7	CWA Section 401
Under Section 401 of the Clean Water Act, a federal agency cannot issue a permit or license for an
activity that may result in a discharge to waters of the U.S. until the state or tribe where the discharge
would originate has granted or waived Section 401 certification. Section 401 certification provides states
and authorized tribes with an effective tool to help protect state or tribal aquatic resources. The state or
tribe in which the discharge originates, in exercising Section 401 certification authority, decides whether
the licensed or permitted activity will be consistent with certain CWA provisions, including the state or
tribe's water quality standards. The state or tribe may grant, condition, deny or waive certification.
Under Section 401(d), the licensing or permitting agency must include in the license or permit any
conditions identified by the state or tribe as necessary to ensure compliance with the relevant CWA
provisions as well as appropriate requirements of state or tribal law.
The proposed facility is located approximately 45 miles west, southwest of Longboat Pass-Sarasota Bay,
Florida. For purposes of the CWA, state waters extend three miles from shore. Accordingly, CWA
Section 401 certification is not required because the proposed discharge does not originate in any state
or tribal waters.
In addition to the state or tribal certification requirement for the state or tribe in which the discharge
originates, Section 401 of the CWA also requires the EPA, if a proposed discharge may affect the
quality of the waters of any other state or tribe (e.g., if the discharge may affect waters of a state or tribe
that is nearby or downstream from the state or tribe in which the discharge originates), to notify such
other state or tribe. The state or tribe, so notified, then has an opportunity to submit its views or
objections to the proposed license or permit, and to request a public hearing. While the EPA is obligated
to condition any permit on compliance with the water quality standards of any affected state or tribe, in
the case of a nearby or neighboring state or tribe, it is not required to adopt any conditions requested by
the state or tribe. In this case, the EPA has determined, based on a review of the application and other
relevant information, including the location and nature of the proposed discharge, that the proposed
discharge will not affect the water quality of any neighboring state or tribal waters.
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7.8 Marine Mammal Protection Act
The Marine Mammal Protection Act established a moratorium, with certain exceptions, on the taking of
marine mammals in U.S. waters and by U.S. citizens on the high seas, and on the importing of marine
mammals and marine mammal products into the United States. Under the MMPA, the Secretary of
Commerce (authority delegated to NOAA Fisheries) is responsible for the conservation and
management of cetaceans and pinnipeds (other than walruses). The Secretary of the Interior is
responsible for walruses, sea and marine otters, polar bears, manatees, and dugongs.
Part of the responsibility NOAA Fisheries has under the MMPA involves monitoring populations of
marine mammals to ensure that they stay at optimum levels. If a population falls below its optimum
level, it is designated as "depleted," and a conservation plan is developed to guide research and
management actions to restore the population to healthy levels.
In 1994, Congress amended the MMPA to govern the taking of marine mammals incidental to
commercial fishing operations. This amendment required the preparation of stock assessments for all
marine mammal stocks in waters under U.S. jurisdiction, development and implementation of take-
reduction plans for stocks that may be reduced or are being maintained below their optimum sustainable
population levels due to interactions with commercial fisheries, and studies of pinniped-fishery
interactions.
Under Section 118 of the MMPA, NOAA Fisheries must publish, at least annually, a List of Fisheries
that places all U.S. commercial fisheries into one of three categories based on the level of incidental
serious injury and mortality of marine mammals that occurs in each fishery. The categorization of a
fishery in the List of Fisheries (LOF) determines whether participants in that fishery may be required to
comply with certain provisions of the MMPA, such as registration, observer coverage, and take
reduction plan requirements.
Currently, the applicant is assisting by partnering with NMFS SERO to develop a marine mammal
monitoring plan to collect data to better inform the risks associated with this type of aquaculture
operation to marine mammals and, thus, help determine how better to categorize this type of aquaculture
operation on future LOF. The applicant will carry onboard a current MMAP certificate (Southeast MMP
Authorization Certificate 2019 https://www.fisheries.noaa.gov/national/marine-mammal-protection/marine-
mammal-authorization-program) and report any marine mammal injuries to NMFS within 48 hours to
comply with Section 118 of the MMPA.
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9.0 Public Notice
The EPA will be providing the public an opportunity to review and comment on this EA during a 30-day
public comment period. The notice of availability for the EA will be published in both the Sarasota -
Herald Tribune and on EPA's website at https://www.epa.gov/aboiitepa/about-epa-region-4-southeast.
Copies of the EA along with a copy of the draft NPDES permit can be downloaded from the above
referenced website.
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10 0 Preparers
This EA was prepared by the EPA Region 4 Office with the assistance of personnel from cooperating
agencies.
Primary responsibility and direction for preparing this document included the following EPA Region 4
personnel:
•	Dan Holliman - NEPA Program Office
•	Roshanna White - NEPA Program Office
•	Jamie Higgins - NEPA Program Office
•	Alya Singh-White - NEPA Program Office
•	Christopher Militscher - NEPA Program Office
•	Roland Ferry - Water Protection Division
•	Paul Schwartz - Office of Regional Counsel
•	Kip Tyler - Water Protection Division
•	Megan Wahl strom-Raml er - Water Protecti on Di vi si on
Other Federal Agency personnel responsible for preparing providing assistance in development of this
EA included:
•	Dr. Jess Beck-Stimpert - NOAA Fisheries
•	Mark Sramek - NOAA Fisheries
•	Jennifer Lee - NOAA Fisheries
•	Jessica Powell - NOAA Fisheries
•	Noah Silverman - NOAA Fisheries
•	Denise Johnson - NOAA Fisheries
•	Rich Malinowski - NOAA Fisheries
•	Heather Blough - NOAA Fisheries
•	Mara Levy - NOAA Fisheries
•	Dr. Ken Riley - NOAA National Ocean Service
•	Katy R. Damico - Jacksonville District Army Corps of Engineers
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Appendix A -Baseline Environmental Survey
Appendix B - Cage/Pen Design
Appendix C - ODCE
Appendix D - ESA Consultation Documents
Appendix E - EFH Consultation Documents
Appendix F - CASS Technical Report
Appendix G - Preliminary Finding of No Significant Impact
Appendix H - State Consultations (Section 106/CZMA)
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Appendix A

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Updated - Final
Baseline Environmental Survey Report
For the
Velella Epsilon Project -
Pioneering Offshore Aquaculture in the Southeastern Gulf of Mexico
NOAA Sea Grant 2017 Aquaculture Initiative
Submitted to:
U.S. Environmental Protection Agency (EPA) Region 4
National Pollutant Discharge and Elimination System (NPDES)
Permitting and Enforcement Branch
Prepared by:
Kampachi Farms, LLC
Report Contributions from:
APTIM Environmental and Infrastructure, Inc.
Tidewater Atlantic Research, Inc.
NOS-NCCOS, NOAA
November 2018

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The Velella Epsilon Project - Baseline Environmental Survey Report
TABLE OF CONTENTS
1.0 Description of the Survey Area & Project Overview	1
2.0 BES Planning, Fieldwork, and Report Investigators	3
2.1	BES Planning and Report Investigator	3
2.2	BES Fieldwork	3
2.3	BES Report Investigator	3
2.4	BES Planning and Report Preparer	3
3.0 Description of the Field Survey Methodology	4
3.1	Navigation System	4
3.2	Survey Instrumentation	4
3.2.1	Single Beam Bathymetry	4
3.2.2	Sidescan Sonar	4
3.2.3	Sub-Bottom Profiler	5
3.2.4	Magnetometer	6
3.3	Survey Vessel	6
3.3.1	Vessel Description	6
3.3.2	Sensor Configuration and Set-backs	7
3.4	Vessel Speed and Course Changes	8
3.5	Sea State and Weather Conditions	8
3.6	Original Daily Survey Operation Logs and Sensor Tow Depths	8
3.7	Description of Survey Procedures	8
3.8	Explanation of Problems	12
4.0 Navigational Post Plot	12
4.1	Sub-Bottom Profiler Data Analysis	12
4.2	Sidescan Sonar and Magnetometer Data Analysis	15
4.3	Current Oil and Gas Operations	17
4.4	Former Oil and Gas Operations	17
5.0 Potential for Prehistoric Sites	20
5.1	Relict Geomorphic Features	20
5.2	Buried Prehistoric Sites	20
6.0 Existing Records Review of Reported Shipwrecks	20
6.1	Unidentified Magnetic Anomalies	20
6.2	Sidescan Sonar Contacts	20
6.3	Unknown Sources of Magnetic Anomalies and Sidescan Sonar Contacts	20
6.4	Correlation between Magnetic Anomalies and Sidescan Sonar Contacts	20
6.5	Positive Identification of Archaeological Resources	22
6.6	Potential for Shipwreck Preservation	22
6.7	Potential for Identification and Evaluation of Potential Shipwrecks	22
7.0 Representative Data Samples	24
7.1	Sub-Bottom Profiler Data	24
7.2	Recorded Unidentified Objects	24
8.0 Conclusions and Recommendations	24
8.1	Known or Potential Physical, Biological, and Archaeological Resources	24
8.2	Recommendations for Avoidance or Further Investigations	24
9.0 Additional Investigations Required by NOAA Fisheries and EPA	24
10.0 Hydrological Measurements	25
November 12, 2018

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The Velella Epsilon Project - Baseline Environmental Survey Report
LIST OF FIGURES
Figure 1. Proposed Alternative Site Locations for the VE Project	2
Figure 2. Survey Tracklines Conducted during the BES Fieldwork	10
Figure 3. Single Beam Bathymetry Conducted at Modified Site B during the BES Fieldwork	11
Figure 4. Example of Surface Sediment Types Identified from the BES Fieldwork	12
Figure 5. Seismic Line 324 from Modified Site B Trending North (left) to South (right) (APTIM 2018) .... 13
Figure 7. Seismic Line 323 from Modified Site B Trending South (left) to North (right) (APTIM 2018) .... 13
Figure 6. Surface Sediment Types Identified from Modified Site B Data Analysis (APTIM 2018)	14
Figure 8. Unconsolidated Sediment Thickness Isopach from Modified Site B (APTIM 2018)	16
Figure 9. Magnetometer Anomalies Detected during BES Fieldwork (APTIM 2018)	18
Figure 10. Magnetometer Anomalies Analyzed within Modified Site B (TAR 2018)	21
Figure 11. Near Surface (4m) Current Speed & Direction from NOAA Buoy Station 42022	25
Figure 12. Midwater (22m) Current Speed and Direction from NOAA Buoy Station 42022	26
Figure 13. Bottom (44m) Current Speed and Direction from NOAA Buoy Station 42022	27
LIST OF PHOTOGRAPHS
Photograph 1. Survey Vessel R/V Eugenie Clark used for the VE Project BES	7
Photograph 2. Sensors Deployed during the BES Fieldwork	7
LIST OF TABLES
Table 1. Summary System Set-backs (Offsets) Used during the BES Fieldwork	8
Table 2. Sensor Heights off the Seafloor for Start and End of each Survey Trackline	9
Table 3. Magnetometer Anomalies Detected from Modified Site B (APTIM 2018)	19
Table 4. SCR Potential from Magnetometer Anomalies Detected from Modified Site B (TAR 2018)	23
LIST OF APPENDICES
Appendix A "Results of Baseline Geophysical Survey for the Siting of Aquaculture Operations in the
Gulf of Mexico". APTIM Environmental and Infrastructure, Inc.
Appendix B "Submerged Cultural Resource Data Analysis Letter Report For: The Velella Epsilon
Project Pioneering Offshore Aquaculture in the Southeastern Gulf of Mexico". Tidewater
Atlantic Research, Inc.
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The Velella Epsilon Project - Baseline Environmental Survey Report
The Velella Epsilon Project - Baseline Environmental Survey
1.0 Description of the Survey Area & Project Overview
The project area is in the Gulf of Mexico (GOM) in approximately 40m water depth off southwest
Florida, generally located 45 miles southwest of Sarasota, Florida. Figure 1 provides the
location of two alternative site locations (Site A and Site B), originally under consideration.
APTIM Environmental and Infrastructure, Inc. (APTIM) was subsequently hired by Kampachi
Farms, LLC to conduct a geophysical baseline survey of the proposed site locations for siting
the VE Project demonstration aquaculture farm. Contents of the APTIM Geophysical Survey
Report to Kampachi Farms, LLC have been summarized, reorganized, and augmented to fulfil
the requirements of the Baseline Environmental Survey Guidance and Procedures for Marine
Aquaculture Activities in U.S. Federal Waters of the Gulf of Mexico, October 24th, 2016. The
original APTIM report; Results of Baseline Geophysical Survey for the Siting of Aquaculture
Operations in the Gulf of Mexico, is provided in Appendix A.
Tidewater Atlantic Research, Inc. (TAR) was subsequently hired by Kampachi Farms, LLC to
conduct the marine archaeological review and analysis of the geophysical baseline survey data.
The original TAR report; Submerged Cultural Resource Data Analysis Letter Report For: The
Velella Epsilon Project Pioneering Offshore Aquaculture in the Southeastern Gulf of Mexico", is
provided in Appendix B.
The purpose of the geophysical investigation was to characterize the sub-surface and surface
geology of the sites and identify areas with a sufficient thickness of unconsolidated sediment
near the surface while also clearing the area of any geohazards and structures that would
impede the implementation of an aquaculture operation. The geophysical survey for the VE
Project consisted of collecting single beam bathymetry, side scan sonar, sub-bottom profiler
(seismic reflection), and magnetometer data within the GOM at Sites A and B. Each site was
defined as approximately 1.3 x 1.3 nautical miles (nm; 1.7-square nm-site areas) which was
filled with 200m (meters) spaced survey lines, running north/south, as well as two tie lines
running east/west.
Site #A:
Location
Top Left
Top Right
Bottom Left
Bottom Right
Latitude
27.087752°
27.086662°
27.051718°
27.050629°
N
N
N
N
Longitude
-83.218684°
-83.178426°
-83.219894°
-83.179649°
W
W
W
W
Site #B:
Location
Top Left
Top Right
Bottom Left
Bottom Right
Latitude
27.145665°
27.144584°
27.109629°
27.108550°
N
N
N
N
Longitude
-83.258456°
-83.218175°
-83.259656°
-83.219389°
W
W
W
W
Water depths across each of these areas ranged from a minimum depth of 38.3m to a
maximum depth of 42.6m.
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Tallahassee
FLo»'ando
Tampajan^S;
Havana
Site A = Preferred Site
Site B = Alternate Site
Nautical Miles (NM)
Bathymetric Contours (m)
27°0'0"N
83°0'0"W
Figure 1. Proposed Alternative Site Locations for the VE Project
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The Velella Epsilon Project - Baseline Environmental Survey Report
2.0	BES Planning, Fieldwork, and Report Investigators
2.1	BES Planning and Report Investigator
Beau Suthard - (APTIM)
Project Manager
M.S./2005/ Geological Oceanography/University of South Florida, St. Petersburg, Florida
B.S. /1997/ Marine Science/Marine Geology/Eckerd College, St. Petersburg, Florida
Professional Geologist Licenses/FL (PG2615); VA (2801001948); DE (S4-0001296)
beau.suthard@aptim.com
2.2	BES Fieldwork
Patrick Bryce - (APTIM)
Data collection, sidescan sonar data processing and interpretation, APTIM report
B.Sc./2010/Marine Science/Marine Geology/Eckerd College, St. Petersburg, Florida
Professional Geologist License/Florida (PG2945)
patrick.bryce@aptim.com
Alexandra B Valente - (APTIM)
Data collection, seismic data processing and interpretation, APTIM report
B.Sc./2012/Marine Science/Marine Geology/Eckerd College, St. Petersburg, Florida
alexandra.valente@aptim.com
Franky Stankiewicz - (APTIM)
Magnetometer data review
B.Sc./2009/Marine Science/Coastal Carolina University, Conway, South Carolina
M.S (in progress)/2018/ Maritime Archaeology/ Flinders, Adelaide, Australia
frankv.stankiewicz@aptim.com
Michael Lowiec - (APTIM)
Single beam bathymetry data processing
M.Sc./Candidate/Coastal Zone Management/Nova Southeastern University, Florida
B.Sc./2002/Marine Science/ Coastal Carolina University, Conway, South Carolina
Professional Surveyor and Mapper License: Florida (LS# 6846)
michael.lowiec@aptim.com
Heather Vollmer - (APTIM)
ArcGIS modeling
M.Sc./2010/Environmental Studies/Florida International University, Miami, Florida
B.Sc./2003/Environmental Studies/Richard Stockton College, Pomona, New Jersey
GIS Professional (GISP), GIS Certification Institute, Des Plaines, Illinois (2011)
heather.vollmer@aptim.com
2.3	BES Report Investigator
Dr. Gordon Watts, JR., PH.D, RPA - (TAR)
Senior Marine Archaeologist and Principal Investigator
PhD/Maritime History and Nautical Archaeology, University of St. Andrews, Fife, Scotland
M.A./Maritime History from East Carolina University in Greenville, North Carolina
iimr@coastalnet.com
2.4	BES Planning and Report Preparer
Dennis Jay Peters - (Kampachi Farms, LLC)
VE Project Manager/Aquaculture Permitting Coordinator, report preparer
M.Sc./1984/Bio-Environmental Oceanography, Florida Institute of Technology, Melbourne, FL
B.Sc./1980/Biology/Lebanon Valley College, Annville, Pennsylvania
petersd1@cox.net
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3.0	Description of the Field Survey Methodology
3.1	Navigation System
Navigational, magnetometer, and depth sounder systems were interfaced with an onboard
computer, and the data were integrated in real time using Hypack Inc.'s Hypack 2017®
software. Hypack 2017® is a state-of-the-art navigation and hydrographic surveying system.
The location of the fish tow-point or transducer mount on the vessel in relation to the Trimble
DGPS was measured, recorded and entered into the Hypack 2017® survey program. The
length of cable deployed between the tow-point and each towfish was also measured and
entered into Hypack 2017®. Hypack 2017® then takes these values and monitors the actual
position of each system in real time. Online screen graphic displays include the replotted
survey lines, the updated boat track across the survey area, adjustable left/right indicator, as
well as other positioning information such as boat speed, and line bearing. The digital data are
merged with the positioning data (Trimble DGPS), video displayed and recorded to the
acquisition computer's hard disk for post processing and/or replay.
The navigation and positioning system deployed for the geophysical survey was a Trimble®
Differential Global Positioning System (DGPS) interfaced to Hypack, Inc.'s Hypack 2017®. A
Pro Beacon receiver provided DGPS correction from the nearest U.S. Coast Guard Navigational
Beacon. The DGPS initially receives the civilian signal from the global positioning system
(GPS) NAVSTAR satellites. The locator automatically acquires and simultaneously tracks the
NAVSTAR satellites, while receiving precisely measured code phase and Doppler phase shifts,
which enables the receiver to compute the position and velocity of the vessel. The receiver
then determines the time, latitude, longitude, height, and velocity once per second. The GPS
accuracy with differential correction provides for a position accuracy of one (1) to four (4) feet
during most of the operations. This is within the accuracy needed for geophysical
investigations.
3.2	Survey Instrumentation
3.2.1	Single Beam Bathymetry
The bathymetric survey was conducted using an ODOM Echotrac MKIII sounder with a 200 kHz
transducer pole mounted on the port side of the on the R/V Eugenie Clark. A TSS DMS-05
dynamic motion sensor was used to provide attitude corrections. For Quality Assurance/Quality
Control and data reduction purposes, APTIM water level recorder data, and NOAA water level
data were used to verify and/or correct onboard bathymetric readings.
Upon completion of the field work, data were edited and reduced using Hypack 2017® using
Single Beam Max application. Water level corrected data were exported and a comma delimited
XYZ file was created. All overlapping profile data were compared in cross section format to
ensure system accuracy. For surface and map creation the final XYZ data files were processed
through Golden Software's Surfer 12 for interpolation and grid creation. ERSI's Arc GIS 10.3
was used for final interpolation and presentation.
3.2.2	Sidescan Sonar
Sidescan sonar data were collected to verify the location and extent of the surficial
unconsolidated sediment and to map ocean bottom features such as benthic habitats, exposed
pipelines, cables, underwater wrecks, potential cultural resources, etc. APTIM utilized a dual
frequency EdgeTech 4200® sidescan sonar, which uses a full-spectrum chirp technology to
deliver wide-band, high-energy pulses coupled with high resolution and good signal to noise
ratio echo data. The sonar package includes a portable configuration with a laptop computer
running EdgeTech's Discover® acquisition software and dual frequency (300/600 kHz) towfish
running in high definition mode. The EdgeTech 4200® has a maximum range of 754ft (230 m)
to either side of the towfish at the 300kHz frequency and 394ft (120 m) to either side of the
towfish at the 600kHz frequency.
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Post processing of the sidescan sonar data was completed using Chesapeake Technology,
Inc.'s SonarWiz 7® software. This software allows the user to apply specific gains and settings
in order to produce enhanced sidescan sonar imagery that can be interpreted and digitized for
specific seafloor features, including potential areas indicative of consolidated and
unconsolidated sediment Post collection processing of the sidescan sonar data were completed
using Chesapeake Technology, Inc.'s SonarWiz 7® software. This software allows the user to
apply specific gains and settings in order to produce enhanced sidescan sonar imagery that can
be interpreted and digitized for specific benthic habitat features and debris throughout the study
area. The first step in processing was to import the data into the software and bottom track the
data. This is achieved using an automated bottom tracking routine and in some cases done
manually. This step provides the data with an accurate baseline representation of the seafloor
and eliminates the water column from the data.
Once the data were bottom tracked, they were processed to reduce noise effects (commonly
due to the vessel, sea state, or other anthropogenic phenomenon) and enhance the seafloor
definition. All of the sidescan sonar data utilized empirical gain normalization (EGN). An
empirical gain normalization table was built including all of the sidescan sonar data files. Once
the table was built it was applied to all of the sidescan sonar data. EGN is a relatively new gain
function that works extremely well in most situations and can be considered a replacement for
Beam Angle Correction (BAC). EGN is a function that sums and averages up all of the sonar
amplitudes in all pings in a set of sonar files by altitude and range. The amplitude values are
summed and averaged by transducer (port and starboard) so there are actually two tables. A
given sonar amplitude sample is placed in a grid location based on the geometry of the ping.
On the x-axis of the grid is range, and on the y-axis of the grid is altitude. The resulting table is
used to work out the beam pattern of sonar by empirically looking at millions of samples of data.
After processing each line, the data were inspected and interpreted for the location and extent
of unconsolidated sediment as well as ocean bottom features such as benthic habitats, exposed
pipelines, cables, underwater wrecks, potential cultural resources, etc. All geologic features and
sediment boundaries were digitized in SonarWiz 7® by encapsulating the feature into a
geographically referenced polygon/polyline shapefile for integration into ArcGIS®.
3.2.3 Sub-Bottom Profiler
An EdgeTech 3200® sub-bottom profiler with a 512i towfish was used to collect the high-
resolution seismic reflection profile data. This system is a versatile wideband frequency
modulated (FM) sub-bottom profiler that collects digital normal incidence reflection data over
many frequency ranges within the 0.5kHz - 12kHz range, also called a "chirp pulse". This
instrumentation generates cross-sectional images of the seabed capable of resolving bed
separation resolutions of 0.06m to 0.10m (depending on selected pulse/ping rate). The tapered
waveform spectrum results in images that have virtually constant resolution with depth. The
data were collected and recorded in the systems native, EdgeTech® .jsf format. The seismic
system was monitored and adjusted, if needed, in real-time to use the optimal settings for
environmental, oceanographic and geologic conditions in order to ensure the highest quality
data is being collected. Navigation and horizontal positioning for the sub-bottom system were
provided by the Trimble® DGPS system via Hypack® utilizing the Hypack® towfish layback
correction. The chirp sub-bottom profiler was operated using a pulse with a frequency sweep of
1.0 kilohertz (kHz) to 10.0kHz with a 5 millisecond (ms) pulse length. The system was set to
ping at a rate of 7 hertz (Hz) and was run with a 60% pulse power level.
Post-collection processing of the chirp sub-bottom profiler data was completed using
Chesapeake Technology, Inc.'s SonarWiz 7® software. This software allows the user to apply
specific gains and settings in order to produce enhanced sub-bottom imagery that can then be
interpreted and digitized for specific 4 stratigraphic fades relevant to the project goals. The data
were continuously bottom-tracked to allow for the application of real-time gain functions in order
to have an optimal in-the-field view of the data.
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Raw *.jsf files were imported into SonarWiz 7® and the data were then bottom tracked, gained
and swell filtered. The process of bottom tracking uses the high-amplitude signal associated
with the seafloor to map it as the starting point for gains and swells. Swell filtering is a ping
averaging function, which allows for the elimination of vertical changes caused from towfish
movement produced from changes in sea state. The swell filter was increased or decreased
depending on the period and frequency of the sea surface wave conditions and special care
was taken not to over-smooth and eliminate features on the seafloor. Time-varying gain (TVG)
was applied and manipulated to produce a better image (contrasts between low and high return
signals) below the seafloor to increase the contrast within the stratigraphy, and increase the
amplitude of the stratigraphy with depth, accounting for some of the signal attenuation normally
associated with sound penetration over time. A blank-water column function was also applied to
eliminate any features such as schools of fish under the chirp system which could produce
noise within the water column.
3.2.4 Magnetometer
A Geometries G-882 Digital Cesium Marine Magnetometer was used to perform a cursory
investigation of the magnetic anomalies within the study area. The magnetometer runs on
110/220 volts alternating current (VAC) power and capable of detecting and aiding the
identification of any ferrous, ferric or other objects that may have a distinct magnetic signature.
Factory set scale and sensitivity settings were used for data collection (0.004 nT/ ttHz rms [nT =
nanotesla or gamma]. Typically 0.02 nT P-P [P-P = peak to peak] at a 0.1 second sample rate
or 0.002 nT at 1 second sample rate). Sample frequency is factory-set at up to 10 samples per
second. The magnetometer was towed in tandem with the sidescan system at an altitude of no
greater than 6 meters (m) above the seafloor, per BOEM regulations, and far enough from the
vessel to minimize boat interference since the instrument has a sensitivity of 1 gamma. The
tandem systems were attached to a marine grade hydraulic winch to adjust for changes in the
seafloor and maintain an altitude of no greater than 20 feet (ft; 6m) above the seafloor.
Navigation and horizontal positioning for the magnetometer were provided by the Trimble®
DGPS system via Hypack® utilizing the Hypack towfish layback correction. Magnetometer data
were recorded in .raw Hypack® file format.
The magnetometer data were post processed by APTIM's personnel in Hypack® 2018's
MagEditor software to identify any potential magnetic anomalies. In order to normalize the
magnetic field and select anomalies with the finest data resolution possible, the background
magnetic field and background noise was adjusted to negate for diurnal variations. Within
MagEditor, the diurnal magnetic readings were duplicated and cropped. The cropped data were
then deducted from the original gamma readings to normalize the magnetometer data from any
diurnal variations. Anomalies were then selected with the Whole Magnetic Analysis tool,
accounting for the distance over ground, time elapsed, the minimum and maximum gamma
readings and the total peak to peak gamma readings.
3.3 Survey Vessel
3.3.1 Vessel Description
The R/V Eugenie Clark (Photograph 1) is a shallow-water hydrographic survey vessel owned
and operated by Mote Marine Laboratory. Based out of Sarasota, FL, the R/V Eugenie Clark
has operated on a number of offshore and nearshore surveys along the gulf coast of Florida. It
is a 46 ft fiberglass hulled vessel with a 16 ft beam and 3.3 ft draft. The vessel is equipped with
twin inboard C7 Caterpillar Diesel engines (470 HP each), a Northern Lights 12KW Marine
generator (120/208V), an A-Frame, and twin hydraulic 2 winches. With a cruising speed of 17
knots (kts) and a maximum speed of 20kts, the R/V Eugenie Clark was an efficient vessel,
which allowed for quick transit between survey areas, and fulfilled the necessary requirements
for survey operations.
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Photograph 1. Survey Vessel R/V Eugenie Clark used for the VE Project BES
3.3.2 Sensor Configuration and Set-backs
The geophysical survey consisted of collecting single beam bathymetry, side scan sonar, sub-
bottom profiler (seismic reflection), and magnetometer data (Photograph 2). The instrument
set-backs identify the distances from the zero mark (vessel GPS) to each of the towed/mounted
systems. As such, the system set-backs were measured from the GPS antenna (placed on
vessels Port side on the second deck) to each of the towpoints/mounted instruments and
inputted into the system set-up in Hypack©. Sidescan sonar and seismic sub-bottom had an
additional offset length of cable out from the towpoint to the instrument. The magnetometer
position was based on the sidescan sonar offset, and was set-back with an additional 20 ft of
cable (i.e., the magnetometer was set-back 20 ft behind the sidescan sonar). The raw data for
each survey system was recorded with the layback (set-back) already corrected during
navigation (Table 1).
Photograph 2. Sensors Deployed during the BES Fieldwork
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Table 1. Summary System Set-backs (Offsets) Used during the BES Fieldwork
System
X Offset (ft)
Y Offset (ft)
Z Offset (ft)
Vessel GPS (zero)
0
0
-15.5
Odom/Hydrotrack-mounted
-3.2
-5.5
0
Motion Reference Unit- mounted
2.5
15.3
-15.5
Chirp-towed
10.4
-13.6
-3.3
SSS-towed
2.7
-18
-7.4
3.4	Vessel Speed and Course Changes
The survey began with the APTIM crew mobilizing the R/V Eugenie Clark on August 12, 2018,
at the Mote Marine Laboratory's Facility in Sarasota, Florida. Once the vessel was mobilized, it
began its transit to the survey sites on August 14, 2018, and collected geophysical data
between August 14, 2018, and August 15, 2018. Average vessel speeds during the surveys
ranged from 4 kts to 7 kts.
3.5	Sea State and Weather Conditions
Weather conditions were characterized as relatively calm sunny days and mild breezes with
winds at approximately 5 to 10kts. Air temperatures ranged from 75 degrees Fahrenheit (°F) to
90°F, and sea temperatures between 85.5°F and 86.5°F. Seas were calm with swells at
approximately 2ft on both survey days.
3.6	Original Daily Survey Operation Logs and Sensor Tow Depths
Due to their file size (>18.3 GB), the original daily survey logs will be made available digitally
upon request. These files also include the sensor height for each towed system off the seafloor
for the beginning and end of each survey trackline (Table 2). On average, the magnetometer
and the sidescan sonar tows were maintained at relatively constant depths from the seafloor of
6m and 12m; respectively. The sub-bottom profiler was maintained within a range of depths
from the seafloor of approximately 14m to 21m, based on trackline bathymetry.
3.7	Description of Survey Procedures
During survey operations, APTIM personnel reviewed the data in real time, in order to establish
a basic site characterization and determine any structures or geology that would impede the
development of an aquaculture operation. APTIM began by collecting seismic sub-bottom,
sidescan sonar, magnetometer and bathymetric data along four (4) tracklines at a wide spacing
of 1968 ft (600 m) at Site A. Based on the data collected, it was evident that the area contained
more consolidated sediments (i.e. hardbottom) near the seafloor and very little unconsolidated
sediments (such as sands or siltier sands) at Site A.
APTIM communicated these preliminary findings to the Kampachi, LLC, Project Manager on the
evening of Tuesday, August 14, 2018 and a collective decision was made to move to Site B to
determine if Site B contained more unconsolidated than consolidated sediments. APTIM began
collecting seismic sub-bottom, sidescan sonar, magnetometer and bathymetric data along three
(3) tracklines at a wide spacing of 1968 ft (600 m) at Site B and reviewed the data in real time.
Based on the data collected, it was evident that the south eastern portion of the Site B survey
area contained more unconsolidated sediments (such as sands or siltier sands). As a result of
this information, APTIM revised the survey area and collected approximately 27 nautical miles
(nm) (46 line kilometers [km]) of data in a roughly 1.6nm x 1.4nm (3.0 km x 2.5 km) area,
targeting an area with a thicker (2 to 8ft) surficial layer of unconsolidated sediments near the
seafloor in the south eastern portion, and mostly outside of Site B (here forward referred to as
Modified Site B). A total of 16 tracklines were surveyed within this area (Figure 2). The depth
profiles are illustrated in Figure 3.
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Table 2. Sensor Heights off the Seafloor for Start and End of each Survey Trackline

Start
Start
Sides can
Mag
Sub-bottom
End
End
Sides can
Mag
Sub-bottom

Latitude
Longitude
Altitude (m)
Altitude (m)
Altitude (m)
Latitude
Longitude
Altitude (m)
Altitude (m)
Altitude (m)
Number
(DD MM.mmm')
(DD MM.mmm')
SOL
SOL
SOL
(DD MM.mmm')
(DD MM.mmm')
EOL
EOL
EOL
100
27° 5.270'
-83° 13.118'
17
9
23
27° 3.079'
-83° 13.188'
14
11
23
103
27° 5.277'
-83° 12.769'
18
13
23
27° 3.091'
-83° 12.821'
16
13
24
106
27° 5.247'
-83° 12.382'
11
9
20
27° 3.061'
-83° 12.464'
14
11
21
109
27° 5.256'
-83° 12.043'
17
13
22
27° 3.070'
-83° 12.090'
17
14
23
170
27° 8.689'
-83° 13.097'
14
7
22
27° 6.492'
-83° 13.161'
11
9
19
210
27° 8.157'
-83° 15.523'
16
13
22
27° 8.058'
-83° 12.500'
13
11
20
211
27° 7.169'
-83° 15.582'
14
13
23
27° 7.089'
-83° 13.136'
16
12
21
211_1
27° 7.093'
-83° 13.321'
21
15
25
27° 7.059'
-83° 12.177'
16
7
20
211_2
27° 7.032'
-83° 11.634'
14
5
22
27° 7.061'
-83° 12.359'
8
7
15
311
27° 7.916'
-83° 13.480'
17
11
20
27° 6.527'
-83° 13.534'
15
11
25
312
27° 7.897'
-83° 13.368'
9
5
16
27° 6.498'
-83° 13.403'
7
4
16
313
27° 7.905'
-83° 13.238'
14
8
22
27° 6.498'
-83° 13.282'
9
6
17
315
27° 7.902'
-83° 12.995'
16
10
19
27° 6.510'
-83° 13.038'
13
9
20
316
27° 7.904'
-83° 12.878'
15
10
20
27° 6.508'
-83° 12.925'
13
11
22
317
27° 7.883'
-83° 12.758'
9
6.5
17
27° 6.483'
-83° 12.806'
9
6
18
318
27° 7.883'
-83° 12.643'
8
5
16
27° 6.473'
-83° 12.685'
12
6
21
319
27° 7.901'
-83° 12.508'
12
8
18
27° 6.496'
-83° 12.558'
11
8
19
320
27° 7.896'
-83° 12.395'
12
9
20
27° 6.492'
-83° 12.450'
13
9
20
321
27° 8.398'
-83° 12.288'
16
8
18
27° 6.445'
-83° 12.318'
11
9
23
322
27° 7.889'
-83° 12.151'
14
10
20
27° 6.480'
-83° 12.191'
13
9
20
323
27° 7.886'
-83° 12.027'
15
10
19
27° 6.484'
-83° 12.068'
12
11
21
324
27° 7.862'
-83° 11.911'
9
4
15
27° 6.460'
-83° 11.958'
9
5
16
325
27° 7.866'
-83° 11.792'
15
6
21
27° 6.457'
-83° 11.835'
8
5
16
326
27° 7.878'
-83° 11.666'
15
11
21
27° 6.470'
-83° 11.710'
14
12
21
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The Velella Epsilon Project - Baseline Environmental Survey Report
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Legend:
	As-Run Tracklines
	Planned Lines
Notes:
1.	Coordinates are in feet
based on the Florida State
Plane Coordinate System,
West Zone, North American
Datum of 1983 (NAD 83).
2.	Data collected by APTIM
on August 14, 2018 and
August 15, 2018.
Map 1: As-Run Tracklines
Kampachi Farms
Velella Epsil
Geophysical Survey
>
725 US 301 South
APTIM Tampa, FL, 33619
%	www.APTIM.com
Figure 2. Survey Tracklines Conducted during the BES Fieldwork
November 12, 2018
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The Veiella Epsilon Project - Baseline Environmental Survey Report
20000-
Florida
Gulf
of
Mexico V H
2.500

1000000-
Legend:
	As-Rim Tracklines
Notes:
1.	Coordinates are in feet
based on the Florida State
Plane Coordinate System,
West Zone, North American
Datum of 1983 (NAD 83).
2.	Data collected by APTIM
on August 14, 2018 and
August 15, 2018.
Depth (NAVD88) (ft)
¦	-142 --140
¦-140 --138
¦1-138--136
~	-136- -134
~~-134 - -132
~	-132--130
¦	-130 --124
Map 4: Single Beam Bathymetry
(NAVD88)
Kampachi Farms
Veiella Epsil
Geophysical Survey
725 US 301 South
- APTIM Tampa, FL, 33619
%	www.APTIM.com
Figure 3. Single Beam Bathymetry Conducted at Modified Site B during the BES Fieldwork
November 12, 2018
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The Veiella Epsilon Project - Baseline Environmental Survey Report
Modified Site #B:
Location
Latitude
Longitude
Top Left
Top Right
Bottom Left
Bottom Right
27.131143° N
27.130512° N
27.107230° N
27.108377° N
-83.224303° W
-83.193872° W
-83.194890° W
-83.225442° W
During the processing of the sidescan sonar data, no contacts or targets were identified in the
entire survey area, indicating that the seafloor is free of any exposed pipelines, marine debris,
underwater wrecks, potential cultural resources, etc. Only two types of bottom textures were
identified throughout the study area (Figure 4). In order to characterize the two surficial
sediment types, sidescan sonar data were compared to the seismic isopach (i.e., sub-bottom
profiler data). Upon careful examination of the two data types, it was evident that areas with
high intensity backscatter and sand ripples (Texture 1) correlated to areas with exposed
consolidated sediments or a thin layer of unconsolidated sediments (upper portion of Figure 3).
Figure 4. Example of Surface Sediment Types Identified from the BES Fieldwork
The second texture (Texture 2), consisted of a medium intensity backscatter, and correlated
with a thick unconsolidated sediment layer (lower portion of Figure 3) in the seismic data (i.e.,
sub-bottom profiler data). Geologists typically utilize the backscatter intensity, distribution, and
texture to make educated interpretations as to the location of consolidated and unconsolidated
sediments; however, these interpretations are based solely on the acoustic interpretation. As
such, additional investigation (i.e., ground-truthing or surface samples) may be required in order
to characterize the sediment properties, as deemed necessary.
No survey difficulties or problems were encountered during the deployment; operations; or data
capture, analysis, and interpretation from any of the sensor systems that would affect the ability
APTIM, TAR, or Kampachi investigators to determine the potential for the presence of hazards,
debris, human activities (i.e., oil/gas structure, artificial reefs), and biological and archaeological
resources in the survey area.
3.8 Explanation of Problems
None were encountered.
4.0	Navigational Post Plot
4.1	Sub-Bottom Profiler Data Analysis
Bottom tracked chirp sub-bottom profile lines were opened to digitally display the recorded
subsurface stratigraphy. Given the large extent of the consolidated sediment layer, data
interpretation consisted of highlighting the top of consolidated sediment layer which was
November 12, 2018	Page 12 of 28

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The Veiella Epsilon Project - Baseline Environmental Survey Report
generally associated with the layer causing the blanking of the seismic signal impeding the
penetration of the chip pulse further below the seafloor. The green line in Figure 5 indicates the
digitized consolidated sediment boundary with unconsolidated sediments above.
3 ffi







..Ml ^rTT1


1 IB n J - i «•


Si

Figure 5. Seismic Line 324 from Modified Site B Trending North (left) to South (right) (APTIM 2018)
The stratigraphic reflector that best correlated with this layer was digitized by digitally clicking on
the reflector within SonarWiz to create a color-coded boundary. This boundary appears on the
subsequent chirp sub-bottom imagery (see Figure 5) to allow for an easy, visual reference for
the boundary between consolidated and unconsolidated material.
Figure 6 illustrates areas of high intensity backscatter (i.e., consolidated sediments, or thin
unconsolidated sediments encompassed in green) that are mostly located on the outer edges of
the revised study area, indicating that the thicker unconsolidated layer is located mostly in the
central portion of the investigation area. As previously mentioned, no contacts were identified
within the area therefore no additional features were plotted onto the map.
The SonarWiz® boundary was used to compute the thickness of the unconsolidated deposit by
calculating the distance between the digitized seafloor and the digitized top of consolidated
sediment boundary. Once the seismic data were reviewed in SonarWiz 7®, the thickness (xyz)
of the unconsolidated sediment unit was imported into Surfer 13 and gridded to create an
interpolated surface depicting the general trend of sand deposits within the area. This isopach
was then imported into ArcMap® 10.6 to compare to the digitized sidescan sonar
interpretations. Some of the thicker areas digitized throughout the area appear to be isolated
depressions (Figure 7) where the consolidated sediment has deepened allowing for more
unconsolidated sediment to be deposited. Seismic Line 323 (trending south to north) illustrates
an example of the deepening of the consolidated sediment layer.


5 ft

Oft

5ft

Oft ;

5ft * 		¦*	' * • ; : -
,0 A Mi s k*:

0 ft
-		;	j.	
5ft
o#
5ft
Figure 7. Seismic Line 323 from Modified Site B Trending South (left) to North (right) (APTIM 2018)
November 12, 2018
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The Velella Epsilon Project - Baseline Environmental Survey Report
Florida
Legend:
	As-Run Tracklines
1020000H £3 Digitized Consolidated
Sediment
1000000-
Notes:
1.	Coordinates are in feet
based on the Florida State
Plane Coordinate System,
West Zone, North American
Datum of 1983 (NAD 83).
2.	Data collected by APTIM
on August 14, 2018 and
August 15, 2018.
Map 2: Sidescan Sonar
Surface Geology
Kampachi Farms
Velella Epsil
Geophysical Survey
725 US 301 South
^ APTIM Tampa, FL, 33619
www.APTIM.com
Mexico
Figure 6. Surface Sediment Types Identified from Modified Site B Data Analysis (APTIM 2018)
November 12, 2018
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The Velella Epsilon Project - Baseline Environmental Survey Report
Figure 8 illustrates the unconsolidated sediment thickness of the surface sediments with a
general sediment trend across the area. The central and eastern areas demonstrate a thicker
unconsolidated sediment layer, which appears to migrate west. Statistics on the surface
indicate that the average thickness of the area is 2.6ft, with a standard deviation (+/-) of 1,4ft.
Maximum thickness reaches 13ft, with the minimum being zero (predominant on the western
side).
4.2 Sidescan Sonar and Magnetometer Data Analysis
As previously mentioned in Section 3.7, processing of the sidescan sonar data identified no
contacts or targets in the entire Modified Site B survey area, indicating that the seafloor is free
of any exposed pipelines, marine debris, underwater wrecks, potential cultural resources, etc.
Only two types of bottom textures (Texture 1, Consolidated Sediments; and Texture 2,
Unconsolidated Sediments) were identified throughout the study area (see Figure 3).
While no absolute criteria for identification of potentially significant magnetic and/or acoustic
target signatures exist, available literature confirms that reliable analysis must be made on the
basis of certain characteristics. Magnetic signatures must be assessed on the basis of three
basic factors. The first factor is intensity and the second is duration. The third consideration is
the nature of the signature; e.g., positive monopolar, negative monopolar, dipolar or multi-
component. Unfortunately, shipwreck sites have been demonstrated to produce each signature
type under certain circumstances. Some shipwreck signatures are more apparent than others.
Large vessels, whether constructed of iron or wood, produce magnetic signatures that can be
reliably identified. Smaller vessels, or disarticulated vessel remains, are more difficult to identify.
Their signatures are frequently difficult, if not impossible, to distinguish from single objects
and/or modern debris. In fact, some small vessels produce little or no magnetic signature.
Unless ordnance, ground tackle, or cargo associated with the hull produces a detectable
signature, some sites are impossible to identify magnetically. It is also difficult to magnetically
distinguish some small wrecks from modern debris. As a consequence, magnetic targets must
be subjectively assessed according to intensity, duration and signature characteristics. The
final decision concerning potential significance must be made on the basis of anomaly
attributes, historical patterns of navigation in the project area, and a responsible balance
between historical and economic priorities.
Acoustic signatures must also be assessed on the basis of several basic characteristics.
Perhaps the most important factor in acoustic analysis is the configuration of the signature. As
the acoustic record represents a reflection of specific target features, wreck signatures are often
a highly detailed and accurate image of architectural and construction features. On sites with
less structural integrity, acoustic signatures often reflect more of a geometric pattern that can be
identified as structural material. Where hull remains are disarticulated, the pattern can be little
more than a texture on the bottom surface representing structure, ballast, or shell hash
associated with submerged deposits. Unfortunately, shipwreck sites have been demonstrated
to produce a variety of signature characteristics under different circumstances. Like magnetic
signatures, some acoustic shipwreck signatures are more apparent than others.
November 12, 2018
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The Velella Epsilon Project - Baseline Environmental Survey Report
1020000-
b lorida
Gulf
Mexico
1000000
Legend:
	As-Run Tracklines
Notes:
1.	Coordinates are in feet
based on the Florida State
Plane Coordinate System,
West Zone, North American
Datum of 1983 (NAD 83).
2.	Data collected by APTIM
on August 14, 2018 and
August 15, 2018.
Thickness (ft)
¦	l
WM2
~	3
~	4
~	5
~6
~	8
~	10
¦	12
Hl-1
Map 3: Unconsolidated Sediment
Thickness Isopach
Rampachi Farms
Velella Epsil
Geophysical Survey
A	725 US 301 South
> APTIM Tampa, FL, 33619
r	www.APTIM.com
Figure 8. Unconsolidated Sediment Thickness Isopach from Modified Site B (APTIM 2018)
November 12, 2018
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The Velella Epsilon Project - Baseline Environmental Survey Report
In summary; ferrous items, detected via the magnetometer, are typically observed with an
increased gamma intensity reading and seen as monopoles, dipoles and multi-component
signals. These varying signals distinguish the anomalies from the natural environment.
Anomalies identified throughout the processing and identification phase were then classified
based on their magnetic signatures and intensity.
Different ferrous objects emit different signal types; for example, shipwrecks and pipelines are
normally associated with multicomponent signals and single monopole signals are normally
associated with small objects such as crab pots and other isolated ferrous objects. Each survey
line was viewed and interpreted in great detail for any magnetic anomalies. Throughout the
entire survey area, APTIM recorded a total of 45 magnetometer anomalies (Figure 9). Almost
all magnetometer hits observed throughout the survey site were minute, (less than 7 gammas
(g)) and do not appear to be of any significant impact in the development of the area. One
magnetometer anomaly (which was observed at over 1000g) is located outside of the Modified
Site B survey area. Due to the signature's disarrangement, the anomaly is likely noise due to a
change in the elevation of the magnetometer (Table 3).
This assumption is based on a combination of causes: (a) the as-run track for the
magnetometer position on that line extends itself further than the planned line so the system
was possibly recording while it was being retrieved at the end of the day; (b) when plotting the
towfish elevation data, towards the end of the line the fish's depth below water line changes
significantly and eventually reaches less than 10ft which would only occur when retrieving the
fish; and (c) the magnetometer anomaly extends itself 332ft, which makes it a significant impact
area and given the overall type and size of anomalies in the area, this is very unexpected.
When the fish is being retrieved, the gamma signal is constantly changing based on several
effects, such as the fish's proximity to the boat, other towed systems, and its overall movement
(pitching and rolling) while its coming up through the water column. All these factors increase
the overall magnetic field the sensor is capturing, therefore causing a large magnetic hit
(especially large objects like the boat). Additionally, when retrieving the geophysical equipment,
the vessel would have had to maintain its bearing for a significant period of time so the towed
systems would not get tangled; therefore, explaining the distance the "hit" was sensed.
TAR provided a seasoned marine archaeologist to additionally review each identified anomaly
and make a determination of the significant submerged cultural resources (SCR) potential, and
therefore, classify it based on its importance using both the geophysical data collected and
other sources that provide historical records of the area in question (see Sections 5.0 and 6.0
below).
4.3	Current Oil and Gas Operations
There are no current or planned oil and gas operations (e.g., well locations, platform sites,
and/or pipelines) in the vicinity of Site A, Site B, or Modified Site B at the time of this report
preparation.
4.4	Former Oil and Gas Operations
There are no former oil and gas operations (e.g., well locations, platform sites, and/or pipelines)
in the vicinity of Site A, Site B, or Modified Site B at the time of this report preparation.
November 12, 2018
Page 17 of 28

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The Velella Epsilon Project - Baseline Environmental Survey Report
NTS
Florida
Mexico


1020000-
-1000000
0.5
Nautical Miles
I
1000000-
t
Legend:
A Magnetometer Anomalies
	As-Run Tracklines
Notes:
1.	Coordinates are in feet
based on the Florida State
Plane Coordinate System,
West Zone, North American
Datum of 1983 (NAD 83).
2.	Data collected by APTIM
on August 14, 2018 and
August 15, 2018.
Map 4: Magnetometer Anomalies
Kampachi Farms
Velella Epsil
Geophysical Survey
725 US 301 South
- APTIM Tampa, FL, 33619
www.APTIM.com
Figure 9. Magnetometer Anomalies Detected during BES Fieldwork (APTIM 2018)
November 12, 2018
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The Velella Epsilon Project - Baseline Environmental Survey Report
Table 3. Magnetometer Anomalies Detected from Modified Site B (APTIM 2018)
Anomaly ID
X Coordinate
Y Coordinate
Line No
Signature Type
Gammas
DOG
Signature
106-1-DP-0.6g-768.69ft
263408
999787
106
1 Dipolar
0.6g
768.69ft
DP
106-2-MC-1.1g-1219.05ft
263200
993737
106
2 Multi-Component
1 -1 g
1219.05ft
MC
106-3-DP-1.9g-1694.3ft
263118
991183
106
3 Dipolar
l.9g
1694.3ft
DP
109-1-DP-1.6g-1128.71ft
265146
993344
109
1 Dipolar
1.6g
1128.71ft
DP
109-2-MP-0.9g-486.39ft
265277
996490
109
2 Monopolar
0.9g
486.39ft
MP
109-3-MP-1.1g-826.66ft
265316
997929
109
3 Monopolar
1 -1 g
826.66ft
MP
109-4-MP-0.9g-646.36ft
265413
1001015
109
4 Monopolar
0.9g
646.36ft
MP
211-1-MP-1.9g-962.03ft
247156
1014649
211
1 Monopolar
1.9g
962.03ft
MP
210-1-MP-1.4g-1880.73ft
252338
1020431
210
1 Monopolar
1.4g
1880.73ft
MP
210-2-MP-0.8g-510.25ft
258571
1020109
210
2 Monopolar
0.8g
510.25ft
MP
170-1-DP-1.8g-753.87ft
259787
1019498
170
1 Dipolar
1.8g
753.87ft
DP
170-2-MP-3g-752.38ft
259637
1015659
170
2 Monopolar
3g
752.38ft
MP
211 -1 -MP-1 g-673.81ft
264504
1013816
211
1 Monopolar
ig
673.81ft
MP
319-1-DP-0.8g-557.5ft
262897
1013895
319
1 Dipolar
0.8g
557.5ft
DP
317-1-MP-1,4g-514.64ft
261534
1013526
317
1 Monopolar
1.4g
514.64ft
MP
317-2-MP-0.6g-467.79ft
261508
1013004
317
2 Monopolar
0.6g
467.79ft
MP
317-3-DP-3.5g-650.89ft
261479
1011686
317
3 Dipolar
3.5g
650.89ft
DP
317-4-DP-3.2g-712ft
261450
1011002
317
4 Dipolar
3.2g
712ft
DP
315-1-DP-0.8g-704.95ft
260169
1011279
315
1 Dipolar
0.8g
704.95ft
DP
315-1-DP-0.6g-520.56ft
260202
1012165
315
1 Dipolar
0.6g
520.56ft
DP
315-2-DP-0.7g-440.43ft
260266
1013511
315
2 Dipolar
0.7g
440.43ft
DP
315-3-DP-0.4g-368.96ft
260416
1017470
315
3 Dipolar
0.4g
368.96ft
DP
312-1-DP-4.2g-351.39ft
258458
1018900
312
1 Dipolar
4.2g
351.39ft
DP
312-2-MP-3.5g-538.53ft
258419
1018495
312
2 Monopolar
3.5g
538.53ft
MP
312-3-MP-3.3g-467.99ft
258413
1018090
312
3 Monopolar
3.3g
467.99ft
MP
312-4-DP-2.4g-674.78ft
258384
1017783
312
4 Dipolar
2.4g
674.78ft
DP
312-5-DP-1.3g-464.63ft
258383
1016708
312
5 Dipolar
1.3g
464.63ft
DP
312-6-DP-3.6g-517.58ft
258351
1015675
312
6 Dipolar
3.6g
517.58ft
DP
312-7-DP-2.7g-454.22ft
258193
1011227
312
7 Dipolar
2.7g
454.22ft
DP
316-1-DP-3.2g-1258.05ft
260835
1011954
316
1 Dipolar
3.2g
1258.05ft
DP
316-2-MP-1.6g-449.32ft
260881
1012275
316
2 Monopolar
1.6g
449.32ft
MP
320-1-DP-1.2g-498.23ft
263710
1017768
320
1 Dipolar
1.2g
498.23ft
DP
211-1-MP-1.8g-286.83ft
264462
1013842
211
1 Monopolar
1.8g
286.83ft
MP
326-1-MP-2.1g-551,41ft
267371
1010591
326
1 Monopolar
2.1g
551.41ft
MP
326-2-DP-0.9g-560.88ft
267492
1013618
326
2 Dipolar
0.9g
560.88ft
DP
326-3-MP-4.3g-1070.04ft
267580
1015760
326
3 Monopolar
4.3g
1070.04ft
MP
326-4-MP-0.7g-426.31ft
267620
1017488
326
4 Monopolar
0.7g
426.31ft
MP
324-1-DP-1g-361,51ft
266293
1017957
324
1 Dipolar
ig
361.51ft
DP
324-2-DP-1.9g-394.94ft
266165
1014388
324
2 Dipolar
l.9g
394.94ft
DP
324-3-MC-4.1 g-281,09ft
266097
1012586
324
3 Multi-Component
4.1g
281.09ft
MC
324-4-MP-7g-416.61ft
266105
1012488
324
4 Monopolar
7g
416.61ft
MP
325-1-MP-1,7g-235.45ft
266884
1015812
325
1 Monopolar
1.7g
235.45ft
MP
325-2-DP-1.6g-422.34ft
266811
1014000
325
2 Dipolar
1.6g
422.34ft
DP
321 -1 -MC-1305.5g-332.08ft
264353
1021535
321
1 Multi-Component
1305.5g
332.08ft
MC
320-2-MC-1,2g-534.6ft
263709
1017773
320
2 Multi-Component
1.2g
534.6ft
MC
318-1 -MC-2g-260.45ft
262340
1018178
318
1 Multi-Component
2g
260.45ft
MC
Note: Coordinates are in feet based on the Florida State Plane Coordinate System, West Zone, North American Datum of
1983 (NAD 83). DOG = Distance Over Ground (length of anomaly signature). MP = Monopolar. DP = Dipolar.
November 12, 2018
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The Velella Epsilon Project - Baseline Environmental Survey Report
5.0	Potential for Prehistoric Sites
5.1	Relict Geomorphic Features
The survey area appears to be typical west-Florida continental shelf geomorphology, consisting
of a thin siliciclastic sediment veneer (0m to 2m) overlying a consolidated limestone surface
likely of upper Oligocene (28 million years ago - mya) to middle Miocene (15 mya) in origin. The
thin siliciclastic sediment veneer is relict material that was transported from the north (from the
southern Appalachian Mountains and Piedmont) to the south during the late Miocene (10 mya)
and Pliocene (5 to 3 mya), resulting in a relatively thin late Neogene to modern quartz-rich
veneer covering a thick (2km to 6km) Jurassic-to-Neogene carbonate succession (Hine et al.
2009).
There is no evidence in the sub-bottom data of any paleochannels, fluvial downcutting, infill, or
any paloefluvial activity anywhere within the survey area. The only evidence of erosion is the
top of the Miocene limestone layer, and is indicative of much lower eustatic sea levels from the
middle-Miocene, well before prehistoric times. Based on the geologic analysis of the data,
including the age of the geologic materials in question, the lack of relict geomorphic features
indicative of artifact preservation potential, and the relative deep elevation (>120 feet NAVD88)
and distant offshore location of the survey area, the likelihood for the presence and/or
preservation of prehistoric sites and geomorphic features with archaeological potential is very
low.
5.2	Buried Prehistoric Sites
Based on the capabilities of current technology in relation to the thickness and composition of
sediments overlying the area of Modified Site B, there is little to no potential for the identification
nor evaluation of buried prehistoric sites.
6.0	Existing Records Review of Reported Shipwrecks
6.1	Unidentified Magnetic Anomalies
Based on the results and conclusions presented earlier in Section 4.2, there were neither
unidentified magnetic anomalies viewed nor interpreted from surveys conducted at Modified Site
B, as previously confirmed in Table 2.
6.2	Sidescan Sonar Contacts
Based on the results and conclusions presented earlier in Section 4.2, there was no sidescan
sonar contacts identified from surveys conducted at Modified Site B.
6.3	Unknown Sources of Magnetic Anomalies and Sidescan Sonar Contacts
Based on the results and conclusions presented earlier in Section 4.2, there was neither
unknown sources of magnetic anomalies or sidescan sonar contacts identified from surveys
conducted at Modified Site B.
6.4	Correlation between Magnetic Anomalies and Sidescan Sonar Contacts
Magnetic and acoustic data were collected on 16 survey lines and one tie line associated with
Modified Site B. Magnetometer data was collected as Hypack® raw data. Each line file was
reviewed by the TAR marine archaeologist to identify and characterize anomalies that could be
generated by submerged cultural resources. Anomaly signatures were analyzed in accordance
with intensity, duration, areal extent and signature characteristics.
A total of 36 anomalies were identified in the data (Figure 10) associated with Modified Site B.
Analysis of each anomaly included consideration of magnetic and acoustic signature
characteristics previously demonstrated to be reliable indicators of historically significant
submerged cultural resources.
November 12, 2018
Page 20 of 28

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The Veiella Epsilon Project - Baseline Environmental Survey Report
315-^
317-3 nm-0 4g-40 9f
o
o
o
ID -
O
O
O
o
¦ o
CM
O
O
O
O
¦ LO
O
o
o
• o
260000
I
I
260000
265000
I
265000
7g-100.61
170-2-dp-1.8g-127.8f
Figure 10. Magnetometer Anomalies Analyzed within Modified Site B (TAR 2018)
November 12, 2018	Page 21 of 28

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The Velella Epsilon Project - Baseline Environmental Survey Report
Analysis of each anomaly included consideration of magnetic and acoustic signature
characteristics previously demonstrated to be reliable indicators of historically significant
submerged cultural resources. Assessment of each anomaly included recommendations for
additional investigation (if required) to determine the exact nature of the cultural material that
generated the signature and its potential National Register of Historic Places (NRHP)
significance. A magnetic contour map of the survey area was not produced to aid in analysis
and data representation as the survey line spacing was too broad. TAR prepared a table listing
all magnetic anomalies located during the survey (Table 4). This table includes the anomaly
name, identification number, signature characteristics, location coordinates and assessment of
the type of material generating the signature.
Acoustic sidescan sonar data was collected in the form of raw EdgeTech JSF data files.
Acoustic sub-bottom profiler data was also collected in the form of raw EdgeTech JSF data files.
Each line of acoustic data was reviewed by TAR using SONARWIZ software to identify and
characterize targets that could be generated by submerged cultural resources. Using
SONARWIZ software, APTIM produced a sonar coverage mosaic of the survey area to aid in
analysis and data representation (see Figure 6). Acoustic signatures suggestive of significant
submerged cultural material were to be isolated and analyzed in accordance with image
intensity, duration, a real extent and configuration characteristics. Analysis of target images
would normally include consideration of acoustic signature characteristics previously
demonstrated to be reliable indicators of historically significant submerged cultural resources.
However, no sonar targets were identified in the acoustic data. SONARWIZ software was also
used to review the sub-bottom profiler date and identify any relict landforms that could be
associated with prehistoric habitation. All lines of sub-bottom data confirmed a shallow sandy
deposit of varying thickness overlying hard bottom likely limestone (see Figures 5 and 7). As
stated previously, no relict landforms of potential significance were identified.
6.5	Positive Identification of Archaeological Resources
TAR's analysis of the APTIM magnetic data identified a total of 36 anomalies in the project
survey. All of the anomalies are very low intensity (see Table 4) and represent small ferrous
objects such as commercial crab or fish traps or debris lost or intentionally case overboard.
None of the anomalies appear to represent potentially significant submerged cultural resources.
Analysis of the sonar data confirmed that nothing associated with those magnetic anomalies or
nonferrous structures or cultural material is exposed on the bottom surface. Sub-bottom profiler
data confirmed that bottom sediment in the survey area consists of unconsolidated sediment,
such as sand of varying thickness, overlying hard bottom. Hard bottom in the area is likely
limestone and no karst or relict landforms were apparent.
6.6	Potential for Shipwreck Preservation
Based on the results and conclusions presented earlier in Section 4.2, there was no potential for
shipwreck preservation neither in terms of sediment type and thickness, nor from the effects of
past and present marine processes from surveys conducted at Modified Site B.
6.7	Potential for Identification and Evaluation of Potential Shipwrecks
Based on NOAA's Office of Coast Survey's Automated Wreck and Obstruction Information
System (AWOIS), the closest documented shipwreck (Record Number 2884; Kingfisher [sunk in
1980]) to Modified Site B is located at 26.833669° N and -83.166503° W, or approximately 18
nm SSW of Modified Site B. Therefore, there is little to no potential for the identification or
evaluation of potential shipwrecks at Modified Site B.
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The Velella Epsilon Project - Baseline Environmental Survey Report
Table 4. SCR Potential from Magnetometer Anomalies Detected from Modified Site B (TAR 2018)
Anomaly
X Cooidinate
Y Cooidinate
Line #
Anomaly U
Signature
Intensity
Duration
identification
SCR Potential
170-1 -pm -3g-102.1 f
259646.3
1015574.1
170
1
Positive Monopolar
3g
102. I f
Small Ferrous Object
Very Low
211-1 -pm -0.5g-252f
258192.6
1014115.9
211
1
Positive Monopolar
0.5g
252f
Small Ferrous Ob
ect
Very Low
211 -2-pm-1 g-147.2f
264584.7
1013799.7
211
2
Positive Monopolar
10
147.2f
Small Ferrous Ob
ect
Very Low
311-1 -dp-0.8g-240.7f
257602.7
1012897.4
311
1
Dipolar
0.8g
240.7f
Small Ferrous Ob
ect
Very Low
311-2-nm-0.4g-112.3f
257774.3
1017613
311
2
Negative Monopolar
0.4g
112.3f
Small Ferrous Ob
ect
Very Low
312-1-dp-2.7g-62.5f
258196.7
1011103.8
312
1
Dipolar
2.7g
62.5f
Small Ferrous Ob
ect
Very Low
312-2-dp-1.4g-48.9f
258255.6
1012855.9
312
2
Dipolar
1,4g
48.9f
Small Ferrous Ob
ect
Very Low
312-3-c#>-3.6g-58.3f
258349.6
1015546.3
312
3
Dipolar
3.6g
58.3f
Small Ferrous Ob
ect
Very Low
312-4-pm-1.3g-52.8f
258407.9
1016565.6
312
4
Positive Monopolar
1.3g
52.8f
Small Ferrous Ob
ect
Very Low
312-5-dp-2.4g-110.9f
258406.5
1017673.1
312
5
Dipolar
2.4g
110.9f
Small Ferrous Ob
ect
Very Low
312-6-dp-3.3g-62.8f
258412.2
1017965.6
312
6
Dipolar
3.3g
62.8f
Small Ferrous Ob
ect
Very Low
312-7-pm-3.5g-87.1f
258420.7
1018366.8
312
7
Positive Monopolar
3.5g
87.1f
Small Ferrous Ob
ect
Very Low
313-1-nm-0.7g-84.3f
259109.5
1018169
313
1
Negative Monopolar
0.7g
84.3f
Small Ferrous Ob
ect
Very Low
315-1-c|p-0.7g-97.1f
260165.4
1011362.4
315
1
Dipolar
0.7g
97.1f
Small Ferrous Ob
ect
Very Low
315-2-dp-0.5g-107.6f
260198.3
1012241.8
315
2
Dipolar
0,5g
107.6f
Small Ferrous Ob
ect
Very Low
315-3i3m-0.6g-80.9f
260266.6
1013589.3
315
3
Positive Monopolar
0.6g
80,9f
Small Ferrous Ob
ect
Very Low
315-4-pm-0.3g-53.2f
260411.9
1017541.9
315
4
Positive Monopolar
0.3g
53.2f
Small Ferrous Ob
ect
Very Low
316-1-dp-3.2g-306.3f
260842.4
1012042
316
1
Dipolar
3-2g
306.3f
Small Ferrous Ob
ect
Low
316-2-pm-1.5g-10l2f
260886.4
1012378.4
316
2
Positive Monopolar
1.5g
101.2f
Small Ferrous Ob
ect
Very Low
317-1 -dp-3.2g-123.3f
261465.4
1010900.1
317
1
Dipolar
3.2g
123.3f
Small Ferrous Ob
ect
Low
317-2-dp-3.5g-142.8f
261482.8
1011578.5
317
2
Dipolar
3.5g
142.8f
Small Ferrous Ob
ect
Low
317-3-nm-0.4g-40.9f
261518.4
1012897.5
317
3
Negative Monopolar
0.4g
40,9f
Small Ferrous Object
Very Low
317-4-pm-1.3g-99.7f
261541.1
1013409
317
4
Positive Monopolar
1.3fl
99.7f
Small Ferrous Ob
ect
Very Low
319-1-dp-0.8g-95.2f
262902.4
1013990.7
319
1
Dipolar
0.8g
95.2f
Small Ferrous Ob
ect
Very Low
320-1-dp-0.8g-105.9f
263488.9
1012419.3
320
1
Dipolar
0.8g
105.9f
Small Ferrous Ob
ect
Very Low
320-2-nm-1.2g-87f
263700.7
1017869.7
320
2
Negative Monopolar
1.2g
87f
Small Ferrous Ob
ect
Very Low
324-1-dp-7g-35.7f
266115.1
1012361,5
324
1
Dipolar
7g
35.7f
Small Ferrous Ob
ect
Very Low
324-2-dp-4.1g-45.4f
266114
1012454,8
324
2
Dipolar
4.1g
45,4f
Small Ferrous Ob
ect
Very Low
324-3-dp-1.9g-41.4f
266176.6
1014267,3
324
3
Dipolar
1.9a
41,4f
Small Ferrous Ob
ect
Very Low
324-4-dp-1 g-72.8f
266291.1
1017831.4
324
4
Dipolar
13
72.8f
Small Ferrous Ob
ect
Very Low
325-1-pm-0.8g42.6f
266738.9
1011720
325
1
Pos
tive Monopolar
0.8g
42.6f
Small Ferrous Ob
ect
Very Low
325-2-pm-1.5g-46.5f
266896.2
1015675
325
2
Pos
tive Monopolar
1.5g
46.5f
Small Ferrous Ob
ect
Very Low
326-1-pm-1.9g-96.7f
267376.3
1010714.4
326
1
Pos
tive Monopolar
1.9g
96.7f
Small Ferrous Ob
ect
Very Low
326-2-dp-0,9g-95.7f
267493.5
1013713,2
326
2
Dipolar
0.9g
95.7f
Small Ferrous Ob
ect
Very Low
326-3-dp-4.3g-237.9f
267579.1
1015878.3
326
3
DiDolar
4.3g
237.9f
Small Ferrous Object(s)
Low
326-4-pm-0.7g-100.6f
267616.4
1017590.3
326
4
Positive Monopolar
0.7g
100.6f
Small Ferrous Object
Very Low
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The Velella Epsilon Project - Baseline Environmental Survey Report
7.0	Representative Data Samples
7.1	Sub-Bottom Profiler Data
Representative data samples from the sub-bottom profiler data were provided in Section 4.1.
Due to the file size (>18.3 GB), the complete APTIM geophysical survey dataset, including the
16 survey tracklines from the original daily survey logs from Modified Site B were made
available digitally to NOAA Fisheries, EPA, USACE, and FL SHPO on September 19, 2018.
7.2	Recorded Unidentified Objects
Based on the results and conclusions presented earlier in Sections 4.2 and 6.3, there are no
contacts representing unidentified objects from surveys conducted at Modified Site B.
8.0	Conclusions and Recommendations
8.1	Known or Potential Physical, Biological, and Archaeological Resources
Based on the contents and data analyses provided by APTIM's Geophysical Survey Report to
Kampachi Farms, LLC, "there are no features (physical, biological, and archaeological
resources) that would preclude the siting of an aquaculture operation within Modified Site B.
8.2	Recommendations for Avoidance or Further Investigations
Based on the absence of any physical, biological, and archaeological resources, there are no
recommendations for avoidance. Further, while APTIM marine geologists utilized the
backscatter intensity, distribution, and texture to make educated interpretations as to the
location of consolidated and unconsolidated sediments, these interpretations are based solely
on the acoustic interpretation; therefore, additional investigation (i.e., ground-truthing or surface
samples) would be advisable in order to characterize the sediment properties of the desired
mooring locations at the time of deployment.
TAR's marine archaeologist summarized that based on the limited amount of bottom
disturbance associated with deployment of the ground tackle necessary for anchoring the
proposed floating structure, it is apparent that no submerged cultural resources will be impacted
if anchors and/or sinkers can be located on, or within 50 feet, of the surveyed lines. If that can
be accomplished, no additional archaeological investigation at the site is recommended. If the
anchoring design requires placing ground tackle outside the 100 foot corridors centered on the
data tracklines, additional investigation should be carried out to clear those sites.
TAR's marine archaeologist further recommended the institution of, and compliance with, an
"Unexpected Discovery Protocol". In the event that any project activities expose potential
prehistoric/historic cultural materials not identified during the remote-sensing survey, operations
should be immediately shifted from the site. The respective Point of Contact for regulatory
agencies with jurisdictional oversight should be immediately appraised of the situation.
Notification should address the exact location, where possible, the nature of material exposed
by project activities, and options for immediate archaeological inspection and assessment of the
site.
9.0 Additional Investigations Required by NOAA Fisheries and EPA
Due to the conclusions and recommendations of this BES Report, as well as the individual
conclusions and recommendations from the APTIM and TAR reports (Appendix A and B,
respectively), no additional investigations would be anticipated to be required by NOAA
Fisheries or EPA.
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The Veiella Epsilon Project - Baseline Environmental Survey Report
10.0 Hydrological Measurements
Hydrological data were captured from the NOAA Data Buoy Center; Station 42022 - C12 - WFS
Central Buoy located on the 50 m Isobath at approximately 27.505 N and 83.741 W; located
approximately 34 NM northwest of Modified Site B. These data represent approximately 66,711
records over nearly a 4 year summary from 2015 through 2018 of surface (4m; Figure 11),
midwater (22m; Figure 12), and bottom (44m; Figure 13) current speed and direction. As
such, these results provide a description of maximum, minimum and average currents, and are
provide as rose plots representative of near surface, mid-water, and near bottom currents.
These raw data file is being submitted electronically as part of this report and may be located at:
https://www.ndbc.noaa.gov/station history.php?station=42022.
NOAA BUOY 42022
2015-2018
NW
itMM
w
sw
NE Surface (4m)
Current Speed (cm/s)
¦	0 00 to 0 00
¦	0.00 to 0.00
¦	0 .00 to 0 00
¦	17.00 to 99.00
¦	15.00 to 17.00
	 E 13.00 to 15.00
11.00 to 13.00
¦	9.00 to 11.00
7.00 to 9.00
5.00 to 7.00
3.00 to 5 00
2.00 to 3.00
SE
Mean speed: 14.63
Peak frequency: 20.53
Peak direction: S
Percent calm 3.88%
Calm defined as: < 3.0 cm/s
Figure 11. Near Surface (4m) Current Speed & Direction from NOAA Buoy Station 42022
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The Veiella Epsilon Project - Baseline Environmental Survey Report
NOAA BUOY 42002
2015-2018
NW
NE
W

l
sw
Midwater (22 m)
Current Speed
(cm/s)
¦	0.00 to 0.00
¦	0 00 to 0 00
¦	0 00 to 0 00
¦	17.00 to 99 00
¦	15.00 to 17.00
13.00 to 15 00
11 00 to 13 00
¦	9.00 to 11 00
¦	7 00 to 9.00
5.00 to 7 00
3.00 to 5.00
2.00 to 3.00
SE
Mean speed: 12.16
Peak frequency: 21.67%
Peak direction: S
Percent calm: 5.75%
Calm defined as: < 3.0 cm/s
Figure 12. Midwater (22m) Current Speed and Direction from NOAA Buoy Station 42022
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The Veiella Epsilon Project - Baseline Environmental Survey Report
NOAA BUOY 42022
2015-2018
NW
18%
16k
14%
12%
10%
W
NE
Bottom (44 m)
Current Speed (cm/s)
¦	0 00 to 0.00
¦	0 00 to 0 00
¦	0 00 to 0 00
¦	17.00 to 99 00
¦	15.00 to 17.00
E 13.00 to 15.00
"11.00 to 13.00
¦	9 00 to 11 00
7 00 to 9 00
5 00 to 7.00
3.00 to 5 00
2 00 to 3 00
sw
SE
Mean speed
Peak frequency:
Peak direction:
Percent calm:
11.73
1906%
S
553%
Calm defined as: < 3 0 cm/s
Figure 13. Bottom (44m) Current Speed and Direction from NOAA Buoy Station 42022
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APPENDIX A
APTIM 2018 Report

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A
APTIM
725 US Highway 301 South
Tampa, FL 33619
Tel: +1 727 565 4660
Fax: +1 813 626 1663
Beau.Suthard@aptim.com
APTIM
August 22, 2018
Dennis J. Peters (via email)
Gulf South Research Corporation (GSRC)
815 Bayshore Drive, Suite B
Niceville, Florida 32578
Subject: Results of Baseline Geophysical Survey for the Siting of Aquaculture Operations in the
Gulf of Mexico.
APTIM Environmental and Infrastructure, Inc. (APTIM) was hired by Kampachi Farms, LLC to conduct a
geophysical baseline survey of a potential area offshore Sarasota Florida that will be used for aquaculture
activities. The area consisted of two (2) survey sites, proposed Site A and proposed Site B. The purpose
of the geophysical investigation was to characterize the sub-surface and surface geology of the sites and
identify areas with a sufficient thickness of unconsolidated sediment near the surface while also clearing
the area of any geohazards and structures that would impede the implementation of an aquaculture
operation.
Survey Operations
The Kampachi Farms, LLC Velella Epsilon Geophysical Survey consisted of collecting single beam
bathymetry, side scan sonar, sub-bottom profiler (seismic reflection) and magnetometer data within the
Gulf of Mexico at the proposed survey Sites A and B. Each site was 1.7x1.7 miles which was filled with
200 m (meters) spaced survey lines, running north/south, as well as two tie lines running east/west. A
detailed description of the vessel and equipment utilized for this survey can be found below.
The survey began with the APTIM crew mobilizing the RNEugenie Clark on August 12, 2018 at the Mote
Marine Laboratory's Facility in Sarasota, FL. Once the vessel was mobilized, it began its transit to the
survey sites on August 14, 2018 and collected geophysical data between August 14, 2018 and August
15, 2018. On both days, winds were approximately 5-10kts and swells were approximately 2 feet (ft).
During survey operations, APTIM personnel reviewed the data in real time in order to establish a basic
site characterization and determine any structures or geology that would impede the development of an
aquaculture operation. APTIM began by collecting seismic sub-bottom, sidescan sonar, magnetometer
and bathymetric data along four (4) tracklines at a wide spacing of 1968 ft (600m) and reviewed the data
in real time. Based on the data collected, it was evident that the area contained more consolidated
sediments (i.e. hardbottom) near the seafloor and very little unconsolidated sediments (such as sands or
siltier sands). APTIM personnel then moved over to Site B and determined that the south eastern portion
of the survey area contained more unconsolidated than consolidated sediments. Therefore APTIM
revised the survey area and collected approximately 27 nautical miles (nm) (46 line kilometers (km)) of
data in a roughly 1.6 x 1.4 nm (3.0 x 2.5 km) area, targeting an area with a thicker surficial layer of
unconsolidated sediments near the seafloor (Map 1 in Appendix A).
R/V Eugenie Clark
The RN Eugenie Clark is a shallow-water hydrographic survey vessel owned and operated by Mote
Marine Laboratory. Based out of Sarasota, FL, the RN Eugenie Clark has operated on a number of
offshore and nearshore surveys along the gulf coast of Florida. It is a 46 ft fiberglass hulled vessel with
a 16 ft beam and 3.3 ft draft. The vessel is equipped with twin inboard C7 Caterpillar Diesel engines (470
HP each), a Northern Lights 12KW Marine generator (120/208V), an A-Frame, and twin hydraulic

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>, APTIM
winches. With a cruising speed of 17 knots and a maximum speed of 20 knots, the RN Eugenie Clark
was an efficient vessel, which allowed for quick transit between survey areas, and fulfills the necessary
requirements for survey operations.
Hypack
Navigational, magnetometer, and depth sounder systems were interfaced with an onboard computer,
and the data were integrated in real time using Hypack Inc.'s Hypack 2017® software. Hypack 2017® is
a state-of-the-art navigation and hydrographic surveying system. The location of the fish tow-point or
transducer mount on the vessel in relation to the Trimble DGPS was measured, recorded and entered
into the Hypack 2017® survey program. The length of cable deployed between the tow-point and each
towfish was also measured and entered into Hypack 2017®. Hypack 2017® then takes these values and
monitors the actual position of each system in real time. Online screen graphic displays include the pre-
plotted survey lines, the updated boat track across the survey area, adjustable left/right indicator, as well
as other positioning information such as boat speed, and line bearing. The digital data are merged with
the positioning data (Trimble DGPS), video displayed and recorded to the acquisition computer's hard
disk for post processing and/or replay.
Navigation
The navigation and positioning system deployed for the geophysical survey was a Trimble Differential
Global Positioning System (DGPS) interfaced to Hypack. Inc.'s Hypack 2017®. A Pro Beacon receiver
provided DGPS correction from the nearest U.S. Coast Guard Navigational Beacon. The DGPS initially
receives the civilian signal from the global positioning system (GPS) NAVSTAR satellites. The locator
automatically acquires and simultaneously tracks the NAVSTAR satellites, while receiving precisely
measured code phase and Doppler phase shifts, which enables the receiver to compute the position and
velocity of the vessel. The receiver then determines the time, latitude, longitude, height, and velocity once
per second. Most of the time the GPS accuracy with differential correction provides for a position accuracy
of one (1) to four (4) ft. This is within the accuracy needed for geophysical investigations.
Single Beam Bathymetry
The bathymetric survey was conducted using an ODOM Echotrac MKIII sounder with a 200 kHz
transducer pole mounted on the port side of the on the RN Eugenie Clark. A TSS DMS-05 dynamic
motion sensor was used to provide attitude corrections. For Quality Assurance/Quality Control and data
reduction purposes. APTIM water level recorder data, and NOAA water level data were used to verify
and/or correct onboard bathymetric readings.
Upon completion of the field work, data were edited and reduced using Hypack 2017® using Single Beam
Max application. Water level corrected data were exported and a comma delimited XYZ file was created.
All overlapping profile data were compared in cross section format to ensure system accuracy. For
surface and map creation the final XYZ data files were processed through Golden Software's Surfer 12
for interpolation and grid creation. ERSI's Arc GIS 10.3 was used for final interpolation and presentation.
Sidescan Sonar
Sidescan sonar data were collected to verify the location and extent of the surficial unconsolidated
sediment and to map ocean bottom features such as benthic habitats, exposed pipelines, cables,
underwater wrecks, potential cultural resources, etc. APTIM utilized a dual frequency EdgeTech 4200
sidescan sonar, which uses a full-spectrum chirp technology to deliver wide-band, high-energy pulses
coupled with high resolution and good signal to noise ratio echo data. The sonar package includes a
portable configuration with a laptop computer running EdgeTech's Discover® acquisition software and
dual frequency (300/600 kHz) towfish running in high definition mode. The EdgeTech 4200 has a
maximum range of 754 ft (230 m) to either side of the towfish at the 300 kHz frequency and 394 ft (120
m) to either side of the towfish at the 600 kHz frequency.
2

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Aaptim
Post processing of the sidescan sonar data was completed using Chesapeake Technology, Inc.'s
SonarWiz 7 software. This software allows the user to apply specific gains and settings in order to
produce enhanced sidescan sonar imagery that can be interpreted and digitized for specific seafloor
features, including potential areas indicative of consolidated and unconsolidated sediment
Post collection processing of the sidescan sonar data were completed using Chesapeake Technology,
Inc.'s SonarWiz 7 software. This software allows the user to apply specific gains and settings in order to
produce enhanced sidescan sonar imagery that can be interpreted and digitized for specific benthic
habitat features and debris throughout the study area. The first step in processing was to import the data
into the software and bottom track the data. This is achieved using an automated bottom tracking routine
and in some cases done manually. This step provides the data with an accurate baseline representation
of the seafloor and eliminates the water column from the data.
Once the data were bottom tracked, they were processed to reduce noise effects (commonly due to the
vessel, sea state, or other anthropogenic phenomenon) and enhance the seafloor definition. All of the
sidescan sonar data utilized empirical gain normalization (EGN). An empirical gain normalization table
was built including all of the sidescan sonar data files. Once the table was built it was applied to all of
the sidescan sonar data. EGN is a relatively new gain function that works extremely well in most
situations and can be considered a replacement for Beam Angle Correction (BAC). EGN is a function
that sums and averages up all of the sonar amplitudes in all pings in a set of sonar files by altitude and
range. The amplitude values are summed and averaged by transducer (port and starboard) so there are
actually two tables. A given sonar amplitude sample is placed in a grid location based on the geometry
of the ping. On the x-axis of the grid is range, and on the y-axis of the grid is altitude. The resulting table
is used to work out the beam pattern of a sonar by empirically looking at millions of samples of data.
After processing each line, the data were inspected and interpreted for the location and extent of
unconsolidated sediment as well as ocean bottom features such as benthic habitats, exposed pipelines,
cables, underwater wrecks, potential cultural resources, etc. All geologic features and sediment
boundaries were digitized in SonarWiz 7 by encapsulating the feature into a geographically referenced
polygon/polyline shapefile for integration into ArcGIS.
Sub-Bottom Profiler
An EdgeTech 3200 sub-bottom profiler with a 512i towfish was used to collect the high-resolution seismic
reflection profile data. This system is a versatile wideband frequency modulated (FM) sub-bottom profiler
that collects digital normal incidence reflection data over many frequency ranges within the 0.5 kHz - 12
kHz range, also called a "chirp pulse". This instrumentation generates cross-sectional images of the
seabed capable of resolving bed separation resolutions of 0.06 m to 0.10 m (depending on selected
pulse/ping rate). The tapered waveform spectrum results in images that have virtually constant resolution
with depth. The data were collected and recorded in the systems native, EdgeTech .jsf format. The
seismic system was monitored and adjusted, if needed, in real-time to use the optimal settings for
environmental, oceanographic and geologic conditions in order to ensure the highest quality data is being
collected. Navigation and horizontal positioning for the sub-bottom system were provided by the Trimble
DGPS system via Hypack utilizing the Hypack towfish layback correction. The chirp sub-bottom profiler
was operated using a pulse with a frequency sweep of 1.0 kilohertz (kHz) to 10.0 kHz with a 5 millisecond
(ms) pulse length. The system was set to ping at a rate of 7 hertz (Hz) and was run with a 60% pulse
power level.
Post-collection processing of the chirp sub-bottom profiler data was completed using Chesapeake
Technology, Inc.'s SonarWiz 7 software. This software allows the user to apply specific gains and settings
in order to produce enhanced sub-bottom imagery that can then be interpreted and digitized for specific
3

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>.APT1M
stratigraphic fades relevant to the project goals. The data were continuously bottom-tracked to allow for
the application of real-time gain functions in order to have an optimal in-the-field view of the data.
Raw .jsf files were imported into SonarWiz 7 and the data were then bottom tracked, gained and swell
filtered. The process of bottom tracking uses the high-amplitude signal associated with the seafloor to
map it as the starting point for gains and swells. Swell filtering is a ping averaging function, which allows
for the elimination of vertical changes caused from towfish movement produced from changes in sea
state. The swell filter was increased or decreased depending on the period and frequency of the sea
surface wave conditions and special care was taken not to over-smooth and eliminate features on the
seafloor. Time-varying gain (TVG) was applied and manipulated to produce a better image (contrasts
between low and high return signals) below the seafloor to increase the contrast within the stratigraphy,
and increase the amplitude of the stratigraphy with depth, accounting for some of the signal attenuation
normally associated with sound penetration over time. A blank-water column function was also applied
to eliminate any features such as schools of fish under the chirp system which produce noise within the
water column.
Magnetometer
A Geometries G-882 Digital Cesium Marine Magnetometer was used to perform a cursory investigation
of the magnetic anomalies within the study area. The magnetometer runs on 110/220 volts alternating
current (VAC) power and capable of detecting and aiding the identification of any ferrous, ferric or other
objects that may have a distinct magnetic signature. Factory set scale and sensitivity settings were
used for data collection (0.004 nT/ ttHz rms [nT = nanotesla or gamma]. Typically 0.02 nT P-P [P-P =
peak to peak] at a 0.1 second sample rate or 0.002 nT at 1 second sample rate). Sample frequency is
factory-set at up to 10 samples per second. The magnetometer was towed in tandem with the sidescan
system at an altitude of no greater than 6 meters (m) above the seafloor, per BOEM regulations, and
far enough from the vessel to minimize boat interference since the instrument has a sensitivity of 1
gamma. The tandem systems were attached to a marine grade hydraulic winch to adjust for changes in
the seafloor and maintain an altitude of no greater than 20ft (6m) above the seafloor. Navigation and
horizontal positioning for the magnetometer were provided by the Trimble DGPS system via Hypack
utilizing the Hypack towfish layback correction. Magnetometer data were recorded in .raw Hypack file
format.
The magnetometer data were post processed by APTIM's personnel in Hypack 2018's MagEditor
software to identify any potential magnetic anomalies. In order to normalize the magnetic field and select
anomalies with the finest data resolution possible, the background magnetic field and background noise
was adjusted to negate for diurnal variations. Within MagEditor, the diurnal magnetic readings were
duplicated and cropped. The cropped data were then deducted from the original gamma readings to
normalize the magnetometer data from any diurnal variations. Anomalies were then selected with the
Whole Magnetic Analysis tool, accounting for the distance over ground, time elapsed, the minimum and
maximum gamma readings and the total peak to peak gamma readings.
Data Interpretation
Sidescan Sonar
During the processing of the sidescan sonar data, no contacts or targets were identified in the entire
survey area, indicating that the seafloor is free of any exposed pipelines, marine debris, underwater
wrecks, potential cultural resources, etc. Only two types of bottom textures were identified throughout the
study area (Figure 1). In order to understand the two surficial sediment types, sidecan sonar data were
compared to the seismic isopach (detailed in the seismic sub-bottom section). Upon careful examination
of the two data types, it was evident that areas with high intensity backscatter and sand ripples (Texture
1) correlated to areas with exposed consolidated sediments or a thin layer of unconsolidated sediments.
4

-------
^ APTIM
The second texture (medium intensity backscatter) correlated with a thick unconsolidated sediment layer
in the seismic data. While APTIM geologists utilized the backscatter intensity, distribution, and texture to
make educated interpretations as to the location of consolidated and unconsolidated sediments, these
interpretations are based solely on the acoustic interpretation therefore additional investigation (i.e
ground-truthing or surface samples) would be advisable in order to characterize the sediment properties
if deemed necessary.
Figure 1: Example of the two identified surface sediment types. Texture 1: high backscatter (upper portion of image). Texture 2: medium
intensity backscatter (lower part of image).
As can be seen in Map 2 in Appendix A, areas of high intensity backscatter (i.e, consolidated sediments,
or thin unconsolidated sediments encompassed in green) are mostly located on the outer edges of the
revised study area, indicating that the thicker unconsolidated layer is located mostly in the central portion
of the investigation area. As previously mentioned, no contacts were identified within the area therefore
no additional features were plotted onto the map.
Chirp Sub-Bottom Profiler
Bottom tracked chirp sub-bottom profile lines were opened to digitally display the recorded subsurface
stratigraphy. Given the large extent of the consolidated sediment layer, data interpretation consisted of
highlighting the top of consolidated sediment layer (Figure 2) which was generally associated with the
layer causing the blanking of the seismic signal impeding the penetration of the chip pulse further below
the seafloor.
5

-------
^ APTIM
; o>! a
CJ)i cc
ij
25 ft 3i
! I
! a
'I <£
:! n
i; c
i;
m	"'|
| §i
35 ft tj! tjI
; a; a;

s.in _	


55 ft


(soft


65 ft


Figure 2: Seismic Line 324 in Site B trending north to south. Green line indicates the digitized consolidated sediment boundary with
unconsolidated sediments above.
The stratigraphic reflector that best correlated with this layer was digitized by digitally clicking on the
reflector within SonarWiz to create a color-coded boundary. This boundary appears on the subsequent
chirp sub-bottom imagery to allow for an easy, visual reference for the boundary between consolidated
and unconsolidated material. This boundary was used within SonarWiz to compute the thickness of the
unconsolidated deposit by calculating the distance between the digitized seafloor and the digitized top of
consolidated sediment boundary. Once the seismic data were reviewed in SonarWiz 7, the thickness
(xyz) of the unconsolidated sediment unit was imported into Surfer 13 and gridded to create an
interpolated surface depicting the general trend of sand deposits within the area. This isopach was then
imported into ArcMap 10.6 to compare to the digitized sidescan sonar interpretations.
The unconsolidated sediment thickness surface (depicted in Map 3 in Appendix A) shows a general
sediment trend across the area. As can be seen on Map 3, the central and eastern area have a thicker
unconsolidated sediment layer, which appears to migrate west. Statistics on the surface indicate that the
average thickness of the area is 2.6 (ft), with a standard deviation (+/-) of 1.4ft. Maximum thickness
reaches 13 ft, with the minimum being zero (predominant on the western side). Some of the thicker areas
digitized throughout the area appear to be isolated depressions (Figure 3) where the consolidated
sediment has deepened allowing for more unconsolidated sediment to be deposited.
55 ft
m
jBOft"	*	4""j	"	^							r	
851""""	"""":								 				————-j-
Figure 3: Seismic Line 323 trending south to north showing the deepening of the consolidated sediment foyer.
Gridding of the xy-thickness data calculated for the four (4) lines in Site A indicate that the average
sediment thickness is 1.7ft (+/- 0.9ft) with a few isolated areas that are slightly thicker, as well as some
depressions like the example shown in Figure 3.
A seismic web project has been exported and is included in the digital version of this submittal. The
data can be viewed by either opening each PNG line image file in any image viewer, or by opening the
6

-------
^ APTIM
"2018_Kampachi_Seismic_Data_viewer.htm" file in any web browser to view the data interactively
(showing coordinates/depths and a location on a map).
Magnetometer
Ferrous items, detected via the magnetometer, are typically observed with an increased gamma
intensity reading and seen as monopoles, dipoles and multi-component signals (Figure 4). These
varying signals distinguish the anomalies from the natural environment. Anomalies identified throughout
the processing and identification phase were then classified based on their magnetic signatures and
intensity.
46,500



j \

46,400


J
\

46,300


/


46,200


/
/

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46,100


/
J


46,000

/


16711680 16711680 16711680 16711680 16711680 16711680
49,000 -
/]
/

48,500 -
I
1
\
48,000


47,500 -
I

47,000
j
\
46,500 -

V
\	
16711680 16711680 16711680 16711680 16711680 16711680
Figure 4: Magnetometer gommo signatures; Left: Dipole onomoly and Right: Mo no pole anomaly.
Each survey line was viewed and interpreted in great detail for any magnetic anomalies. Throughout the
entire survey area APTIM recorded a total of 45 magnetometer anomalies (Map 4 in Appendix A and
table in Appendix B). Almost all magnetometer hits observed throughout the survey site were minute,
(less than 7 gammas (g)) and do not appear to be of any significant impact in the development of the
area. One magnetometer anomaly, which is observed over 1000 g, is located outside of the survey area.
Due to the signature's disarrangement, the anomaly is likely noise due to a change in the elevation of the
magnetometer.
Results
APTIM has reviewed the data and has determined that there are no features that would preclude the
siting of an aquaculture operation within Site B and the area adjacent to it on the southeastern portion. It
is important to note that this data has not been reviewed by a professional and licensed archaeologist
and as such does not constitute a full evaluation of the geophysical data as required by National Oceanic
and Atmospheric Administration (NOAA) Fisheries in its Baseline Environmental Survey Guidance and
Procedures for Marine Aquaculture Activities in U.S. Federal Waters of the Gulf of Mexico.
Sincerely,
Beau Suthard
Client Program Manager
Aptim Environmental and Infrastructure, Inc.
7

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Aaptim
Appendix A
Maps

-------
NTS
Florida
N
Mexico
T
i\i
o>
o
o
o
o

77
Site B
1020000-
-1000000
Site A
0.5
§
CM
_l_


I
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"H-

-n-

'1!!!
!!
I j 1000000-
Tf-J-J-fJ
H|
> 1
I I I
' 1
1 1
I I I
tit"
I I I
' 1
1 1
>	1
>	1
>	1
I I I
Legend:
	As-Run Tracklines
	Planned Lines
Notes:
1.	Coordinates are in feet
based on the Florida State
Plane Coordinate System,
West Zone, North American
Datum of 1983 (NAD 83).
2.	Data collected by APTIM
on August 14, 2018 and
August 15, 2018.
Map 1: As-Run Tracklines
Kampachi Farms
Velella Epsil
Geophysical Survey
725 US 301 South
- AP7IM Tampa, FL, 33619
www.APTIM.com

-------
1020000-
1000000-
Legend:
	As-Run Tracklines
Digitized Consolidated
Sediment
Notes:
1.	Coordinates are in feet
based on the Florida State
Plane Coordinate System,
West Zone, North American
Datum of 1983 (NAD 83).
2.	Data collected by APTIM
on August 14, 2018 and
August 15, 2018.
Map 2: Sidescan Sonar
Surface Geology
Kampachi Farms
Velella Epsil
Geophysical Survey
725;US 301 South
- APTIM Tampa. FL, 33619
www.APTIM.com
Florida
Mexico
NTS

-------
Florida
Gulf
of
Mexico
1020000-
1000000-
Legend:
	As-Run Tracklines
Notes:
1.	Coordinates are in feet
based on the Florida State
Plane Coordinate System,
West Zone, North American
Datum of 1983 (NAD 83).
2.	Data collected by APTIM
on August 14, 2018 and
August 15, 2018.
Thickness (ft)
~	3
~	4
~	5
~	6
~	8
I 110
Map 3: Unconsolidated Sediment
Thickness Isopach
Kampachi Farms
Velella Epsil
Geophysical Survey
>	725;US 301 South
; APTIM Tampa, FL, 33619
www.APTIM.com

-------
Florida
Gulf
Mexico
NTS
-A
1000000
Nautical Miles
1020000-
Legend:
A Magnetometer Anomalies
	As-Run Tracklines
Notes:
1.	Coordinates are in feet
based on the Florida State
Plane Coordinate System,
West Zone, North American
Datum of 1983 (NAD 83).
2.	Data collected by APTIM
on August 14, 2018 and
August 15, 2018.
1000000-
Map 4: Magnetometer Anomalies
Kampachi Farms
Velella Epsil
Geophysical Survey
725 US 301 South
- APTIM Tampa, FL, 33619
www.APTIM.com

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Aaptim
Appendix B
Magnetometer Anomaly Table
9

-------
Anomaly ID
X Cooridnate
Y Coordinate
Anomaly
Line Number
Number
Signature Type
Gammas
DOG
Signature
106-l-DP-0.6g-768.69ft
263408
999787
106
1 Dipolar
0.6g
768.69ft
DP
106-2-MC-l.lg-1219.05ft
263200
993737
106
2 Multi-Component
1-lg
1219.05ft
MC
106-3-DP-l.9g-1694.3ft
263118
991183
106
3 Dipolar
1.9g
1694.3ft
DP
109-l-DP-l.6g-1128.71ft
265146
993344
109
1 Dipolar
1.6g
1128.71ft
DP
109-2-MP-0.9g-486.39ft
265277
996490
109
2 Monopolar
0.9g
486.39ft
MP
109-3-MP-l.lg-826.66ft
265316
997929
109
3 Monopolar
1-lg
826.66ft
MP
109-4-MP-0.9g-646.36ft
265413
1001015
109
4 Monopolar
0.9g
646.36ft
MP
211-l-MP-l.9g-962.03ft
247156
1014649
211
1 Monopolar
1.9g
962.03ft
MP
210-l-MP-l.4g-1880.73ft
252338
1020431
210
1 Monopolar
1.4g
1880.73ft
MP
210-2-MP-0.8g-510.25ft
258571
1020109
210
2 Monopolar
0.8g
510.25ft
MP
170-l-DP-l.8g-753.87ft
259787
1019498
170
1 Dipolar
1.8g
753.87ft
DP
170-2-MP-3g-752.38ft
259637
1015659
170
2 Monopolar
3g
752.38ft
MP
211-l-MP-lg-673.81ft
264504
1013816
211
1 Monopolar
lg
673.81ft
MP
319-l-DP-0.8g-557.5ft
262897
1013895
319
1 Dipolar
0.8g
557.5ft
DP
317-l-MP-l.4g-514.64ft
261534
1013526
317
1 Monopolar
1.4g
514.64ft
MP
317-2-MP-0.6g-467.79ft
261508
1013004
317
2 Monopolar
0.6g
467.79ft
MP
317-3-DP-3.5g-650.89ft
261479
1011686
317
3 Dipolar
3.5g
650.89ft
DP
317-4-DP-3.2g-712ft
261450
1011002
317
4 Dipolar
3.2g
712ft
DP
315-l-DP-0.8g-704.95ft
260169
1011279
315
1 Dipolar
0.8g
704.95ft
DP
315-l-DP-0.6g-520.56ft
260202
1012165
315
1 Dipolar
0.6g
520.56ft
DP
315-2-DP-0.7g-440.43ft
260266
1013511
315
2 Dipolar
0.7g
440.43ft
DP
315-3-DP-0.4g-368.96ft
260416
1017470
315
3 Dipolar
0.4g
368.96ft
DP
312-l-DP-4.2g-351.39ft
258458
1018900
312
1 Dipolar
4.2g
351.39ft
DP
312-2-MP-3.5g-538.53ft
258419
1018495
312
2 Monopolar
3.5g
538.53ft
MP
312-3-MP-3.3g-467.99ft
258413
1018090
312
3 Monopolar
3.3g
467.99ft
MP
312-4-DP-2.4g-674.78ft
258384
1017783
312
4 Dipolar
2.4g
674.78ft
DP
312-5-DP-l.3g-464.63ft
258383
1016708
312
5 Dipolar
1.3g
464.63ft
DP
312-6-DP-3.6g-517.58ft
258351
1015675
312
6 Dipolar
3.6g
517.58ft
DP
312-7-DP-2.7g-454.22ft
258193
1011227
312
7 Dipolar
2.7g
454.22ft
DP
316-l-DP-3.2g-1258.05ft
260835
1011954
316
1 Dipolar
3.2g
1258.05ft
DP
316-2-MP-l.6g-449.32ft
260881
1012275
316
2 Monopolar
1.6g
449.32ft
MP
320-l-DP-l.2g-498.23ft
263710
1017768
320
1 Dipolar
l-2g
498.23ft
DP
211-l-MP-l.8g-286.83ft
264462
1013842
211
1 Monopolar
1.8g
286.83ft
MP
326-l-MP-2.lg-551.41ft
267371
1010591
326
1 Monopolar
2-lg
551.41ft
MP
326-2-DP-0.9g-560.88ft
267492
1013618
326
2 Dipolar
0.9g
560.88ft
DP
326-3-MP-4.3g-1070.04ft
267580
1015760
326
3 Monopolar
4.3g
1070.04ft
MP
326-4-MP-0.7g-426.31ft
267620
1017488
326
4 Monopolar
0.7g
426.31ft
MP
324-l-DP-lg-361.51ft
266293
1017957
324
1 Dipolar
lg
361.51ft
DP
324-2-DP-l.9g-394.94ft
266165
1014388
324
2 Dipolar
1.9g
394.94ft
DP
324-3-MC-4.lg-281.09ft
266097
1012586
324
3 Multi-Component
4.1g
281.09ft
MC
324-4-MP-7g-416.61ft
266105
1012488
324
4 Monopolar
7g
416.61ft
MP
325-l-MP-l.7g-235.45ft
266884
1015812
325
1 Monopolar
l-7g
235.45ft
MP
325-2-DP-l.6g-422.34ft
266811
1014000
325
2 Dipolar
1.6g
422.34ft
DP
321-l-MC-1305.5g-332.08ft
264353
1021535
321
1 Multi-Component
1305.5g
332.08ft
MC
320-2-MC-l.2g-534.6ft
263709
1017773
320
2 Multi-Component
l-2g
534.6ft
MC
318-l-MC-2g-260.45ft
262340
1018178
318
1 Multi-Component
2g
260.45ft
MC
Note: Coordinates are in feet based on the Florida State Plane Coordinate System, West Zone, North American Datum of 1983 (NAD 83).

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Aaptim
Appendix C (Digital Only)
Seismic Web Project
10

-------
APPENDIX B
TAR 2018 Report

-------
Submerged Cultural Resource Data Analysis Letter Report For:
The Velella Epsilon Project
"Pioneering Offshore Aquaculture in the Southeastern Gulf of Mexico"
Submitted to:
Gulf South Research Corporation
815 Bayshore Drive, Suite B
Niceville, Florida 32578
Submitted by:
Tidewater Atlantic Research, Inc.
P. O. Box 2494
Washington, North Carolina 27889
With Significant Contributions from:
APTIM Environmental and Infrastructure, Inc.
101 16th Avenue South, Ste. 4
St. Petersburg, Florida 33701
Submittal Date:
24 October 2018

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Table of Contents
Page
List of Figures	ii
Survey Area Location and Project Overview	1
APTIM Field Survey Methodology and Equipment	1
Navigation System	1
Survey Instrumentation	4
Single Beam Bathymetry	4
Sidescan Sonar	4
Sub-Bottom Profiler	5
Magnetometer	5
Survey Vessel	6
Vessel Description	6
Remote-Sensing Sensor Configuration and Set-backs	6
Original Daily Survey Operation Logs and Sensor Tow Depths	7
Description of Survey Procedures	7
Sub-Bottom Profiler Data Analysis	8
Signature Analysis and Target Assessment	8
VE Project Data Analysis	9
Conclusions and Recommendations	11
Unexpected Discovery Protocol	11
Bibliography	14
Appendix A	15

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ii
List of Figures
Page
Figure 1. Velella Epsilon (VE) proposed project area	2
Figure 2. Proposed site locations for VE project	3
Figure 3. Project as-run track lines	9
Figure 4. Location of magnetic anomalies in survey area	10
Figure 5. Sonar coverage mosaic 	12
Figure 6. Example of subbottom profiler data collected from Survey Line No. 324	13

-------
Survey Area Location and Project Overview
The Velella Epsilon project area is in the Gulf of Mexico (GOM) in approximately 40m water depth off
southwest Florida, generally located 45 miles southwest of Sarasota, Florida (Figure 1). APTIM
Environmental and Infrastructure, Inc. (APTIM) was hired by Kampachi Farms, LLC (Kampachi) to
conduct a geophysical baseline survey of the proposed location for siting the Velella Epilon (VE) Project
demonstration aquaculture farm. The purpose of the geophysical investigation was to characterize the sub-
surface and surface geology of the sites and identify areas with a sufficient thickness of unconsolidated
sediment near the surface while also clearing the area of any geohazards and structures that would impede
the implementation of an aquaculture operation (Figure 2). The geophysical survey for the VE Project
consisted of collecting single beam bathymetry, sidescan sonar, sub-bottom profiler (seismic reflection),
and magnetometer data within the Gulf of Mexico project site.
Under contract with Kampachi, those data were reviewed by Tidewater Atlantic Research, Inc. (TAR) of
Washington, North Carolina to identify and assess the significance of any submerged cultural resources
that might be impacted by project related activities in the site location identified on the basis of APTIM's
data (Appendix A). The descriptions of survey equipment and methodology that follow are taken directly
from the report prepared by APTIM as presented by Kampachi (2018).
APTIM Field Survey Methodology and Equipment
Navigation System
Navigational, magnetometer, and depth sounder systems were interfaced with an onboard computer, and
the data were integrated in real time using Hypack 2017® software. Hypack 2017® is a state-of-the-art
navigation and hydrographic surveying system. The location of the fish tow-point or transducer mount on
the vessel in relation to the Trimble DGPS was measured, recorded and entered into the Hypack 2017®
survey program. The length of cable deployed between the tow-point and each towfish was also measured
and entered into Hypack 2017®. Hypack 2017® then takes these values and monitors the actual position
of each system in real time. Online screen graphic displays include the replotted survey lines, the updated
boat track across the survey area, adjustable left/right indicator, as well as other positioning information
such as boat speed, and line bearing. The digital data are merged with the positioning data (Trimble DGPS),
video displayed and recorded to the acquisition computer's hard disk for post processing and/or replay.
The navigation and positioning system deployed for the geophysical survey was a Trimble® Differential
Global Positioning System (DGPS) interfaced to Hypack 2017®. A Pro Beacon receiver provided DGPS
correction from the nearest U.S. Coast Guard Navigational Beacon. The DGPS initially receives the civilian
signal from the global positioning system (GPS) NAVSTAR satellites. The locator automatically acquires
and simultaneously tracks the NAVSTAR satellites, while receiving precisely measured code phase and
Doppler phase shifts, which enables the receiver to compute the position and velocity of the vessel. The
receiver then determines the time, latitude, longitude, height, and velocity once per second. The GPS
accuracy with differential correction provides for a position accuracy of one (1) to four (4) feet during most
of the operations. This is within the accuracy needed for geophysical investigations.

-------
2
250000
i
300000
'	
350000
	I	
400000
450000
500000
OLD TAMPA
BAY-
AERO
R Bn 3£
Long Key
15s 13M
/
V Manatee
Bradenton
SARASOTA
BAY
Longboat
SARASC
Little;
Bay
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12
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121
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14
14
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12

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12 \
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12 15
•8 m
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Dump Site t	J
(dredged material);*ft
(see note S) fiep 1988)
B at 15	11
-17-
;• Unexploded depth charge
(reported 1956)
Sand Key,
(use chart 11412)
19
15
16
11
18
14
17
14
19
19.
13
12
\ 21
Obstn1 ®
Fish Haven0 on uo 14
(auth min Th fms)
18 15
Project Area
Obstn-'4] 15
'"Fish Haven
(auth min 7V.?
M Sh 18
fms)
Siesta Key
(use chart 11424)
Obstns 13
14 Fish Haven ,,
(auth min 6V2 fms) \ RshH%en
16
15
Obstn Fish Haven
(auth min 5'/? tms)(' 'i
tPD 12
(auth min 5 tms)
;Obstn (5 Ims)
15 17 20 15
Miles
Obstn-"- 17
1^0&£
hH
uth
5 fms)
Obstn 101'
Fish Haven
(auth min \
o
o
o
o
in
o>
"	1	
450000
250000
300000
350000
400000
500000
Figure 1. Velella Epsilon (VE) proposed project area.

-------
Cfcjp
fctnrft
FLO"ando
Tampa 7„nl$4
P i
—I	M-ami
Havana
	
50
60
N o
f
30
40
• Site B
• Site A
Nautical MM* (NM)

TOV. .
SarasotavBradenton :
r h
#	Site A = Preferred Site
#	Site B = Alternate Site
Bathymetric Contours (m)
Figure 2. Proposed site locations for VE project as presented by Kampachi (2018:2).

-------
4
Survey Instrumentation
Single Beam Bathymetry
The bathymetric survey was conducted using an ODOM Echotrac MKIII sounder with a 200-kHz
transducer pole mounted on the port side of the on the R/V Eugenie Clark. A TSS DMS-05 dynamic motion
sensor was used to provide attitude corrections. For Quality Assurance/Quality Control and data reduction
purposes, APTIM water level recorder data, and NOAA water level data were used to verify and/or correct
onboard bathymetric readings. Upon completion of the field work, data were edited and reduced using
Hypack 2017® using Single Beam Max application. Water level corrected data were exported and a comma
delimited XYZ file was created. All overlapping profile data were compared in cross section format to
ensure system accuracy. For surface and map creation the final XYZ data files were processed through
Golden Software's Surfer 12 for interpolation and grid creation. ERSI's Arc GIS 10.3 was used for final
interpolation and presentation.
Sidescan Sonar
Sidescan sonar data were collected to verify the location and extent of the surficial unconsolidated sediment
and to map ocean bottom features such as benthic habitats, exposed pipelines, cables, underwater wrecks,
potential cultural resources, etc. APTIM utilized a dual frequency EdgeTech 4200® sidescan sonar, which
uses a full-spectrum chirp technology to deliver wide-band, high-energy pulses coupled with high
resolution and good signal to noise ratio echo data. The sonar package includes a portable configuration
with a laptop computer running EdgeTech's Discover® acquisition software and dual frequency (300/600
kHz) towfish running in high definition mode. The EdgeTech 4200® has a maximum range of 754ft (230
m) to either side of the towfish at the 300kHz frequency and 394ft (120 m) to either side of the towfish at
the 600kHz frequency.
Post processing of the sidescan sonar data was completed using Chesapeake Technology, Inc.'s SonarWiz
7® software. This software allows the user to apply specific gains and settings in order to produce enhanced
sidescan sonar imagery that can be interpreted and digitized for specific seafloor features, including
potential areas indicative of consolidated and unconsolidated sediment Post collection processing of the
sidescan sonar data were completed using Chesapeake Technology, Inc.'s SonarWiz 7® software. This
software allows the user to apply specific gains and settings in order to produce enhanced sidescan sonar
imagery that can be interpreted and digitized for specific benthic habitat features and debris throughout the
study area. The first step in processing was to import the data into the software and bottom track the data.
This is achieved using an automated bottom tracking routine and in some cases done manually. This step
provides the data with an accurate baseline representation of the seafloor and eliminates the water column
from the data.
Once the data were bottom tracked, they were processed to reduce noise effects (commonly due to the
vessel, sea state, or other anthropogenic phenomenon) and enhance the seafloor definition. All of the
sidescan sonar data utilized empirical gain normalization (EGN). An empirical gain normalization table
was built including all of the sidescan sonar data files. Once the table was built it was applied to all of the
sidescan sonar data. EGN is a relatively new gain function that works extremely well in most situations
and can be considered a replacement for Beam Angle Correction (BAC). EGN is a function that sums and
averages up all of the sonar amplitudes in all pings in a set of sonar files by altitude and range. The amplitude
values are summed and averaged by transducer (port and starboard) so there are actually two tables. A given
sonar amplitude sample is placed in a grid location based on the geometry of the ping. On the x-axis of the
grid is range, and on the y-axis of the grid is altitude. The resulting table is used to work out the beam
pattern of sonar by empirically looking at millions of samples of data.

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5
After processing each line, the data were inspected and interpreted for the location and extent of
unconsolidated sediment as well as ocean bottom features such as benthic habitats, exposed pipelines,
cables, underwater wrecks, potential cultural resources, etc. All geologic features and sediment boundaries
were digitized in SonarWiz 7® by encapsulating the feature into a geographically referenced
polygon/polyline shapefile for integration into ArcGIS®.
Sub-Bottom Profiler
An EdgeTech 3200® sub-bottom profiler with a 512i towfish was used to collect the high-resolution
seismic reflection profile data. This system is a versatile wideband frequency modulated (FM) sub-bottom
profiler that collects digital normal incidence reflection data over many frequency ranges within the 0.5kHz
- 12kHz range, also called a "chirp pulse". This instrumentation generates cross-sectional images of the
seabed capable of resolving bed separation resolutions of 0.06m to 0.10m (depending on selected pulse/ping
rate). The tapered waveform spectrum results in images that have virtually constant resolution with depth.
The data were collected and recorded in the systems native, EdgeTech® .jsf format. The seismic system
was monitored and adjusted, if needed, in real-time to use the optimal settings for environmental,
oceanographic and geologic conditions in order to ensure the highest quality data is being collected.
Navigation and horizontal positioning for the sub-bottom system were provided by the Trimble® DGPS
system via Hypack® utilizing the Hypack® towfish layback correction. The chirp sub-bottom profiler was
operated using a pulse with a frequency sweep of 1.0 kilohertz (kHz) to 10.0kHz with a 5 millisecond (ms)
pulse length. The system was set to ping at a rate of 7 hertz (Hz) and was run with a 60% pulse power level.
Post-collection processing of the chirp sub-bottom profiler data was completed using SonarWiz 7®
software. This software allows the user to apply specific gains and settings in order to produce enhanced
sub-bottom imagery that can then be interpreted and digitized for specific 4 stratigraphic facies relevant to
the project goals. The data were continuously bottom-tracked to allow for the application of real-time gain
functions in order to have an optimal in-the-field view of the data.
Raw .jsf files were imported into SonarWiz 7® and the data were then bottom tracked, gained and swell
filtered. The process of bottom tracking uses the high-amplitude signal associated with the seafloor to map
it as the starting point for gains and swells. Swell filtering is a ping averaging function, which allows for
the elimination of vertical changes caused from towfish movement produced from changes in sea state. The
swell filter was increased or decreased depending on the period and frequency of the sea surface wave
conditions and special care was taken not to over-smooth and eliminate features on the seafloor. Time-
varying gain (TVG) was applied and manipulated to produce a better image (contrasts between low and
high return signals) below the seafloor to increase the contrast within the stratigraphy, and increase the
amplitude of the stratigraphy with depth, accounting for some of the signal attenuation normally associated
with sound penetration over time. A blank-water column function was also applied to eliminate any features
such as schools of fish under the chirp system which could produce noise within the water column.
Magnetometer
A Geometries G-882 Digital Cesium Marine Magnetometer was used to perform a cursory investigation of
the magnetic anomalies within the study area. The magnetometer runs on 110/220 volts alternating current
(VAC) power and capable of detecting and aiding the identification of any ferrous, ferric or other objects
that may have a distinct magnetic signature. Factory set scale and sensitivity settings were used for data
collection (0.004 nT/ kHz rms [nT = nanotesla or gamma]. Typically, 0.02 nT P-P [P-P = peak to peak] at
a 0.1 second sample rate or 0.002 nT at 1 second sample rate). Sample frequency is factory-set at up to 10
samples per second. The magnetometer was towed in tandem with the sidescan system at an altitude of no
greater than 6 meters (m) above the seafloor, per BOEM regulations, and far enough from the vessel to

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6
minimize boat interference since the instrument has a sensitivity of 1 gamma. The tandem systems were
attached to a marine grade hydraulic winch to adjust for changes in the seafloor and maintain an altitude of
no greater than 20 feet (ft; 6m) above the seafloor. Navigation and horizontal positioning for the
magnetometer were provided by the Trimble® DGPS system via Hypack® utilizing the Hypack towfish
layback correction. Magnetometer data were recorded in .raw Hypack® file format.
The magnetometer data were post processed by APTIM's personnel in Hypack® 2018's MagEditor
software to identify any potential magnetic anomalies. In order to normalize the magnetic field and select
anomalies with the finest data resolution possible, the background magnetic field and background noise
was adjusted to negate for diurnal variations. Within MagEditor, the diurnal magnetic readings were
duplicated and cropped. The cropped data were then deducted from the original gamma readings to
normalize the magnetometer data from any diurnal variations. Anomalies were then selected with the Whole
Magnetic Analysis tool, accounting for the distance over ground, time elapsed, the minimum and maximum
gamma readings and the total peak to peak gamma readings.
Survey Vessel
Vessel Description
The R/V Eugenie Clark is a shallow-water hydrographic survey vessel owned and operated by Mote Marine
Laboratory. Based out of Sarasota, FL, the R/V Eugenie Clark has operated on a number of offshore and
nearshore surveys along the gulf coast of Florida. It is a 46-ft fiberglass hulled vessel with a 16-ft beam and
3.3-ft draft. The vessel is equipped with twin inboard C7 Caterpillar Diesel engines (470 HP each), a
Northern Lights 12KW Marine generator (120/208V), an A-Frame, and twin hydraulic 2 winches. With a
cruising speed of 17 knots (kts) and a maximum speed of 20 kts, the R/V Eugenie Clark was an efficient
vessel, which allowed for quick transit between survey areas, and fulfilled the necessary requirements for
survey operations.
Remote-Sensing Sensor Configuration and Set-backs
The geophysical survey consisted of collecting single beam bathymetry, sidescan sonar, sub- bottom
profiler (seismic reflection), and magnetometer data. The instrument set-backs identify the distances from
the zero mark (vessel GPS) to each of the towed/mounted systems. As such, the system set-backs were
measured from the GPS antenna (placed on vessels Port side on the second deck) to each of the
towpoints/mounted instruments and inputted into the system set-up in Hypack®. Sidescan sonar and
seismic sub-bottom had an additional offset length of cable out from the towpoint to the instrument. The
magnetometer position was based on the sidescan sonar offset, and was set-back with an additional 20 ft of
cable (i.e., the magnetometer was set-back 20 ft behind the sidescan sonar). The raw data for each survey
system was recorded with the layback (set-back) already corrected during navigation (Table 1).
System
X Offset (ft)
Y Offset tf§
Z Offset®
Vessel GPS (zero)
0
0
-15 5
Odom-HyctOStcaQls-mountecJ
-3 2
-5 5
0
Motion Reference Unit- mounted
2 5
153
-155
Chirp-towed
10,4
-136
-3 3
SSS-towed
27
-18
.7 4
Table 1. System set-backs used during fieldwork.

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7
Original Daily Survey Operation Logs and Sensor Tow Depths
These files include the sensor height for each towed system off the seafloor for the beginning and end of
each survey trackline. On average, the magnetometer and the sidescan sonar tows were maintained at
relatively constant depths from the seafloor of 6m and 12m; respectively. The sub-bottom profiler was
maintained within a range of depths from the seafloor of approximately 14m to 21m, based on trackline
bathymetry.
Description of Survey Procedures
During survey operations, APTIM personnel reviewed the data in real time, in order to establish a basic site
characterization and determine any structures or geology that would impede the development of an
aquaculture operation. APTIM began by collecting seismic sub-bottom, sidescan sonar, magnetometer and
bathymetric data along four (4) tracklines at a wide spacing of 1968 ft (600 m) at Site A. Based on the data
collected, it was evident that the area contained more consolidated sediments (i.e. hardbottom) near the
seafloor and very little unconsolidated sediments (such as sands or siltier sands) at Site A.
APTIM communicated these preliminary findings to the Kampachi, LLC, Project Manager on the evening
of Tuesday, August 14, 2018 and a collective decision was made to move to Site B to determine if Site B
contained more unconsolidated than consolidated sediments. APTIM began collecting seismic sub-bottom,
sidescan sonar, magnetometer and bathymetric data along three (3) tracklines at a wide spacing of 1968 ft
(600 m) at Site B and reviewed the data in real time. Based on the data collected, it was evident that the
southeastern portion of the Site B survey area contained more unconsolidated sediments (such as sands or
siltier sands). As a result of this information, APTIM revised the survey area and collected approximately
27 nautical miles (nm) (46 line kilometers [km]) of data in a roughly 1.6nm x 1.4nm (3.0 km x 2.5 km)
area, targeting an area with a thicker (2 to 8ft) surficial layer of unconsolidated sediments near the seafloor
in the southeastern portion, and mostly outside of Site B (here forward referred to as Modified Site B). A
total of 16 tracklines were surveyed within this area.
During the processing of the sidescan sonar data, no contacts or targets were identified in the entire survey
area, indicating that the seafloor is free of any exposed pipelines, marine debris, underwater wrecks,
potential cultural resources, etc. Only two types of bottom textures were identified throughout the study
area. In order to characterize the two surficial sediment types, sidescan sonar data were compared to the
seismic isopach (i.e., sub-bottom profiler data). Upon careful examination of the two data types, it was
evident that areas with high intensity backscatter and sand ripples (Texture 1) correlated to areas with
exposed consolidated sediments or a thin layer of unconsolidated sediments.
The second texture (Texture 2), consisted of a medium intensity backscatter, and correlated with a thick
unconsolidated sediment layer in the seismic data (i.e., sub-bottom profiler data). Geologists typically
utilize the backscatter intensity, distribution, and texture to make educated interpretations as to the location
of consolidated and unconsolidated sediments; however, these interpretations are based solely on the
acoustic interpretation. As such, additional investigation (i.e., ground-truthing or surface samples) may be
required in order to characterize the sediment properties, as deemed necessary.
No survey difficulties or problems were encountered during the deployment; operations; or data capture,
analysis, and interpretation from any of the sensor systems that would affect the ability APTIM or
Kampachi investigators to determine the potential for the presence of hazards, debris, human activities (i.e.,
oil/gas structure, artificial reefs), and biological and archaeological resources in the survey area (Kampachi
2018).

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8
Sub-Bottom Profiler Data Analysis
Bottom tracked chirp sub-bottom profile lines were opened to digitally display the recorded subsurface
stratigraphy. Given the large extent of the consolidated sediment layer, data interpretation consisted of
highlighting the top of consolidated sediment layer which was generally associated with the layer causing
the blanking of the seismic signal impeding the penetration of the chip pulse further below the seafloor.
The stratigraphic reflector that best correlated with this layer was digitized by digitally clicking on the
reflector within SonarWiz to create a color-coded boundary. This boundary appears on the subsequent
chirp sub-bottom imagery to allow for an easy, visual reference for the boundary between consolidated and
unconsolidated material.
The SonarWiz® boundary was used to compute the thickness of the unconsolidated deposit by calculating
the distance between the digitized seafloor and the digitized top of consolidated sediment boundary. Once
the seismic data were reviewed in SonarWiz 7®, the thickness (xyz) of the unconsolidated sediment unit
was imported into Surfer 13 and gridded to create an interpolated surface depicting the general trend of
sand deposits within the area. This isopach was then imported into ArcMap® 10.6 to compare to the
digitized sidescan sonar interpretations. Some of the thicker areas digitized throughout the area appear to
be isolated depressions where the consolidated sediment has deepened allowing for more unconsolidated
sediment to be deposited.
Signature Analysis and Target Assessment
While no absolute criteria for identification of potentially significant magnetic and/or acoustic target
signatures exist, available literature confirms that reliable analysis must be made on the basis of certain
characteristics. Magnetic signatures must be assessed on the basis of three basic factors. The first factor is
intensity and the second is duration. The third consideration is the nature of the signature; e.g., positive
monopolar, negative monopolar, dipolar or multi-component. Unfortunately, shipwreck sites have been
demonstrated to produce each signature type under certain circumstances. Some shipwreck signatures are
more apparent than others.
Large vessels, whether constructed of iron or wood, produce magnetic signatures that can be reliably
identified. Smaller vessels, or disarticulated vessel remains, are more difficult to identify. Their signatures
are frequently difficult, if not impossible, to distinguish from single objects and/or modern debris. In fact,
some small vessels produce little or no magnetic signature. Unless ordnance, ground tackle or cargo
associated with the hull produces a detectable signature, some sites are impossible to identify magnetically.
It is also difficult to magnetically distinguish some small wrecks from modern debris. As a consequence,
magnetic targets must be subjectively assessed according to intensity, duration and signature characteristics.
The final decision concerning potential significance must be made on the basis of anomaly attributes,
historical patterns of navigation in the project area and a responsible balance between historical and
economic priorities.
Acoustic signatures must also be assessed on the basis of several basic characteristics. Perhaps the most
important factor in acoustic analysis is the configuration of the signature. As the acoustic record represents
a reflection of specific target features, wreck signatures are often a highly detailed and accurate image of
architectural and construction features. On sites with less structural integrity acoustic signatures often
reflect more of a geometric pattern that can be identified as structural material. Where hull remains are
disarticulated the pattern can be little more than a texture on the bottom surface representing structure,
ballast or shell hash associated with submerged deposits. Unfortunately, shipwreck sites have been
demonstrated to produce a variety of signature characteristics under different circumstances. Like magnetic
signatures, some acoustic shipwreck signatures are more apparent than others. Large vessels, whether iron

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9
or wood, can produce acoustic signatures that can be reliably identified. Smaller vessels, or disarticulated
vessel remains are inevitably more difficult. Their acoustic signatures are frequently difficult, if not
impossible, to distinguish from concentrations of snags and/or modern debris. In fact, some small vessels
produce little or no acoustic signature. As a consequence, acoustic targets must be subjectively assessed
according to intensity of return over background, elevation above bottom and geometric image
characteristics. The final decision concerning potential significance of less readily identifiable targets must
be made on the basis of anomaly attributes, historical patterns of navigation in the project area and a
responsible balance between historical and economic priorities.
VE Project Data Analysis
Magnetic and acoustic data was collected on 16 survey lines and one tie line (Figure 3). Magnetometer
data was collected as Hypack® raw data. Each line file was reviewed by the TAR marine archaeologist to
identify and characterize anomalies that could be generated by submerged cultural resources. Anomaly
signatures were analyzed in accordance with intensity, duration, areal extent and signature characteristics.
A total of 38 anomalies were identified in the data (Figure 4; Appendix A).
s.
0 8751,750 3,500 5,250 7,000
Figure 3. Project as-run track lines.

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10
315-4 -pm-C ,3g-53.2f
-i jm-1.5g-46.5f
¦ 6-3-dp-4.3g-237.91
317-3 nm-0 4g-40 9f
260000
	1	
260000
265000
	I	
265000
170-2-dp-1.8g-127.8f
Figure 4. Location of magnetic anomalies in survey area.

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11
Analysis of each anomaly included consideration of magnetic and acoustic signature characteristics
previously demonstrated to be reliable indicators of historically significant submerged cultural resources.
Assessment of each anomaly included recommendations for additional investigation to determine the exact
nature of the cultural material that generated the signature and its potential National Register of Historic
Places significance. A magnetic contour map of the survey area was not produced to aid in analysis and
data representation as the survey line spacing was too broad. TAR prepared a table listing all magnetic
anomalies located during the survey (Appendix A). This table includes the anomaly name, identification
number, signature characteristics, location coordinates and assessment of the type of material generating
the signature.
Acoustic sidescan sonar data was collected in the form of raw Edgetech JSF data files. Acoustic subbottom
profiler data was also collected in the form of raw Edgetech JSF data files. Each line of acoustic data was
reviewed by TAR using sonarwiz software to identify and characterize targets that could be generated by
submerged cultural resources. Using sonarwiz software APTIM produced a sonar coverage mosaic of the
survey area to aid in analysis and data representation (Figure 5). Acoustic signatures suggestive of
significant submerged cultural material were to be isolated and analyzed in accordance with image intensity,
duration, areal extent and configuration characteristics. Analysis of target images would normally include
consideration of acoustic signature characteristics previously demonstrated to be reliable indicators of
historically significant submerged cultural resources. However, no sonar targets were identified in the
acoustic data, sonarwiz software was also used to review the subbottom profiler date and identify any
relict landforms that could be associated with prehistoric habitation. All lines of subbottom data confirmed
a shallow sandy deposit of varying thickness overlying hard bottom likely limestone (Figure 6). No relict
landforms of potential significance were identified.
Conclusions and Recommendations
Analysis of the APTIM magnetic data identified a total of 36 anomalies in the project survey. All of the
anomalies are very low intensity and represent small ferrous objects such as commercial crab or fish traps
or debris lost or intentionally case overboard. None of the anomalies appear to represent potentially
significant submerged cultural resources. Analysis of the sonar data confirmed that nothing associated with
those magnetic anomalies or nonferrous structures or cultural material is exposed on the bottom surface.
Subbottom profiler data confirmed that bottom sediment in the survey area consists of unconsolidated
sediment such as sand of varying thickness overlying hard bottom. Hard bottom in the area is likely
limestone and no karst or relict landforms were apparent.
Based on the limited amount of bottom disturbance associated with deployment of the ground tackle
necessary for anchoring the proposed floating structure, it is apparent that no submerged cultural resources
will be impacted if anchors and/or sinkers can be located on, or within 50 feet, of the surveyed lines. If that
can be accomplished, no additional archaeological investigation at the site is recommended. If the anchoring
design requires placing ground tackle outside the 100 foot corridors centered on the data tracklines,
additional investigation should be carried out to clear those sites.
Unexpected Discovery Protocol
In the event that any project activities expose potential prehistoric/historic cultural materials not identified
during the remote-sensing survey, operations should be immediately shifted from the site. The respective
Point of Contact for regulatory agencies with jurisdictional oversight should be immediately apprised of the
situation. Notification should address the exact location, where possible, the nature of material exposed by
project activities, and options for immediate archaeological inspection and assessment of the site.

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260000
265000
0 445 890 1,780 2,670 3,560
260000
265000
Figure 5. Sonar coverage mosaic presented by Kampachi (2018).

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Figure 6. Example of subbottom profiler data collected from Survey Line No. 324.

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14
Bibliography
Kampachi Farms
2018 Draft-Final Baseline Environmental Survey Report for the Velella Epsilon Project. Pioneering
Offshore Aquaculture in the Southeastern Gulf of Mexico. NOAA Sea Grant 2017 Aquaculture Initiative.
Report to U.S. Environmental Protection Agency, Region 4, Atlanta, from Kampachi Farms.

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Appendix A

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AppendixA
Anomaly
X Coordinate
Y Coordinate
Line #
Anomaly #
Signature
Intensity
Duration
Identification
SCR Potential
170-1 -pm-3g-102.1 f
259646.3
1015574.1
170
1
Positive Monopolar
3g
102.1f
Small Ferrous Object
Very Low
211-1-pm-0.5g-252f
258192.6
1014115.9
211
1
Positive Monopolar
0.5g
252f
Small Ferrous Object
Very Low
211-2-pm-1g-147.2f
264584.7
1013799.7
211
2
Positive Monopolar
ig
147.2f
Small Ferrous Object
Very Low
311-1-dp-0.8g-240.7f
257602.7
1012897.4
311
1
Dipolar
0.8g
240.7f
Small Ferrous Object
Very Low
311-2-nm-0.4g-112.3f
257774.3
1017613
311
2
Negative Monopolar
0.4g
112.3f
Small Ferrous Object
Very Low
312-1-dp-2.7g-62.5f
258196.7
1011103.8
312
1
Dipolar
2.7g
62.5f
Small Ferrous Object
Very Low
312-2-dp-1.4g-48.9f
258255.6
1012855.9
312
2
Dipolar
1.4g
48.9f
Small Ferrous Object
Very Low
312-3-dp-3.6g-58.3f
258349.6
1015546.3
312
3
Dipolar
3.6g
58.3f
Small Ferrous Object
Very Low
312-4-pm-1.3g-52.8f
258407.9
1016565.6
312
4
Positive Monopolar
1.3g
52.8f
Small Ferrous Object
Very Low
312-5-dp-2.4g-110.9f
258406.5
1017673.1
312
5
Dipolar
2.4g
110.9f
Small Ferrous Object
Very Low
312-6-dp-3.3g-62.8f
258412.2
1017965.6
312
6
Dipolar
3.3g
62.8f
Small Ferrous Object
Very Low
312-7-pm-3.5g-87.1f
258420.7
1018366.8
312
7
Positive Monopolar
3.5g
87.1f
Small Ferrous Object
Very Low
313-1-nm-0.7g-84.3f
259109.5
1018169
313
1
Negative Monopolar
0.7g
84.3f
Small Ferrous Object
Very Low
315-1-dp-0.7g-97.1f
260165.4
1011362.4
315
1
Dipolar
0.7g
97.1f
Small Ferrous Object
Very Low
315-2-dp-0.5g-107.6f
260198.3
1012241.8
315
2
Dipolar
0.5g
107.6f
Small Ferrous Object
Very Low
315-3-pm-0.6g-80.9f
260266.6
1013589.3
315
3
Positive Monopolar
0.6g
80.9f
Small Ferrous Object
Very Low
315-4-pm-0.3g-53.2f
260411.9
1017541.9
315
4
Positive Monopolar
0.3g
53.2f
Small Ferrous Object
Very Low
316-1-dp-3.2g-306.3f
260842.4
1012042
316
1
Dipolar
3.2g
306.3f
Small Ferrous Object
Low
316-2-pm-1.5g-101.2f
260886.4
1012378.4
316
2
Positive Monopolar
1.5g
101.2f
Small Ferrous Object
Very Low
317-1-dp-3.2g-123.3f
261465.4
1010900.1
317
1
Dipolar
3.2g
123.3f
Small Ferrous Object
Low
317-2-dp-3.5g-142.8f
261482.8
1011578.5
317
2
Dipolar
3.5g
142.8f
Small Ferrous Object
Low
317-3-nm-0.4g-40.9f
261518.4
1012897.5
317
3
Negative Monopolar
0.4g
40.9f
Small Ferrous Object
Very Low
317-4-pm-1.3g-99.7f
261541.1
1013409
317
4
Positive Monopolar
1.3g
99.7f
Small Ferrous Object
Very Low
319-1-dp-0.8g-95.2f
262902.4
1013990.7
319
1
Dipolar
0.8g
95.2f
Small Ferrous Object
Very Low
320-1-dp-0.8g-105.9f
263488.9
1012419.3
320
1
Dipolar
0.8g
105.9f
Small Ferrous Object
Very Low
320-2-nm-1.2g-87f
263700.7
1017869.7
320
2
Negative Monopolar
1.2g
87f
Small Ferrous Object
Very Low
324-1-dp-7g-35.7f
266115.1
1012361.5
324
1
Dipolar
7g
35.7f
Small Ferrous Object
Very Low
324-2-dp-4.1 g-45.4f
266114
1012454.8
324
2
Dipolar
4.1g
45.4f
Small Ferrous Object
Very Low
324-3-dp-1.9g-41.4f
266176.6
1014267.3
324
3
Dipolar
1.9g
41.4f
Small Ferrous Object
Very Low
324-4-dp-1g-72.8f
266291.1
1017831.4
324
4
Dipolar
ig
72.8f
Small Ferrous Object
Very Low
325-1-pm-0.8g-42.6f
266738.9
1011720
325
1
Positive Monopolar
0.8g
42.6f
Small Ferrous Object
Very Low
325-2-pm-1.5g-46.5f
266896.2
1015675
325
2
Positive Monopolar
1.5g
46.5f
Small Ferrous Object
Very Low
326-1-pm-1.9g-96.7f
267376.3
1010714.4
326
1
Positive Monopolar
1.9g
96.7f
Small Ferrous Object
Very Low
326-2-dp-0.9g-95.7f
267493.5
1013713.2
326
2
Dipolar
0.9g
95.7f
Small Ferrous Object
Very Low
326-3-dp-4.3g-237.9f
267579.1
1015878.3
326
3
Dipolar
4.3g
237.9f
Small Ferrous Object(s)
Low
326-4-pm-0.7g-100.6f
267616.4
1017590.3
326
4
Positive Monopolar
0.7g
100.6f
Small Ferrous Object
Very Low

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Appendix B

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PROFILE VIEW
BRIDLE LINE: HDPE PIPE WITH ROPE INSIDE
SPAR BUOY
SPAR
BUOY
ROPE

CURRENT D RECTIQN
ROPE
BALLAST TANK
CONCRETE BALLAST
CHAIN
DEADWEIGHT
ANCHOR
1)	Deadweight Anchors (concrete):
•	Three (3) anchors equally spaced
a 120rn from mooring centerline
m 120 degrees from each other
•	Each @ 4.5m x 4.5m x 4.5m (91 m3)
•	Concrete friction factor = 0.5 on wet sand
•	Each has an effective weight of 217 MT
2)	Mooring Chain (Grade 2 steel):
•	80m length on each anchor
•	50mm (2") thick links
•	No load = 70m length of each on seafloor
•	Design load = some entirely off seafloor/
others completely on seafloor
3)	Mooring Lines (rope):
•	40m length on each chain
•	AMSTEEL®-BLUE
•	36mm (1 1/2") thick lines
4)	Spar Buoy w/ Swivel (steel):
5)	Bridle Lines (rope inside HDPE pipe):
•	Three (3) ~30m bridle lines (rope) from swivel to
spreader bar
•	AMSTEEL®-BLUE
•	33.3mm (1 5/16") lines inside HDPE pipe
6)	Spreader Bar (HDPE):
•	Header Bar (load bearing) connected to Bridle Lines
o 30m in length
M 0.36m OD DR 11 HDPE pipe
•	Side and Rear Bars (smaller load bearing)
m 30m in length
g 0.36m OD DR 17 HDPE pipe
•	Four (4) corner spar buoys
7)	Net Pen Connection Lines (rope):
•	Four (4) ~13m connection lines (rope)
•	Connected from Spreader Bar to Net Pen Float Rings
•	AMSTEEL®-BI.UE
•	33.3mm (1 5/16") lines
8)	Net Pen Frame Structure (HDPE):
•	Top Frame Structure
B 18m in diameter
B One (1) HDPE side-by-side Float Rings
¦	On the sea surface
~ 0.36m OD DR 11 HDPE pipe
& One (1) HDPE net ring (railing)
¦	Connected ~ 1.0m above Float Rings
¦	Connected to Net Pen Mesh
~ 0.15m OD DR 17 HDPE pipe
•	Bottom Frame Structure
& 18m in diameter
H One (1) HDPE sinker ring
¦	7,0m below Float Rings
¦	Connected to Net Ring
~ 0.36m OD DR 11 HDPE pipe
et One (1) HDPE net ring
¦	7.0m below float rings
¦	Connected to copper alloy mesh
~ 0.15m OD DR 17 HDPE pipe
9)	Net Pen Mesh (copper alloy):
•	17m diameter x 7m depth
•	Top connected to top net ring (railing)
•	Bottom connected to bottom net ring
B 4mm wire diameter
B 40mm x 40mm mesh square
•	Effective volume of 1,600m3
10)	Shackle Point Connection (steel):
•	One (1) ~0.13m2 shackle plate
•	Four (4) connection lines
g 12 mm in diameter x 10m in length
Connected from shackle plate to HDPE sinker ring
•	~lm Grade 2 steel chain (32mm) connected to Floatation
Capsule
11)	Floatation Capsule (steel):
•	~ 1.5m in diameterx ~3.45m in length
•	Effective floatation volume = 6m3
•	~3m Grade 2 steel chain (32mm) connected to Counterweight
12)	Counter Weight (concrete):
•	~ 1.1m in diameterx~2.2m in length
•	Effective weight of 5 MT

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Appendix C

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DRAFT
OCEAN DISCHARGE CRITERIA EVALUATION
Kampachi Farms, LLC - Velella Epsilon
Net Pen Aquaculture Facility
Outer Continental Shelf
Federal Waters of the Gulf of Mexico
NPDES Permit Number
FL0A00001
August 5, 2019

Sr^

I
V *
SSEZ
LU
0
U.S. Environmental Protection Agency
Region 4
Water Division
61 Forsyth Street SW
Atlanta Georgia 30303

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TABLE OF CONTENTS
1.0 Introduction	6
1.1	Proposed Agency Action	6
1.2	Evaluation Purpose	6
1.3	ODCE Report Overview	7
2.0 Proposed Project Information	8
2.1	Proposed Project	8
2.2	Proposed Action Area	9
3.0 The Physical Environment	10
3.1	Physical Oceanography	10
3.1.1	Circulation	10
3.1.2	Climate	12
3.1.3	T emperature	12
3.1.4	Salinity	13
3.2	Chemical Composition	13
3.2.1	Micronutrients	13
3.2.2	Dissolved Gases	13
4.0 Discharged Materials	15
4.1	Fish Feed	15
4.2	Fish Wastes	16
5.0 Biological Overview	18
5.1	Primary Productivity	18
5.2	Phytoplankton	19
5.2.1	Distribution	19
5.2.2	Principal Taxa	19
5.3	Zooplankton	20
5.4	Habitats	21
5.4.1	Seagrasses	21
5.4.2	Offshore Habitats	21
5.5	Fish and Shellfish Resources	22
5.6	Marine Mammals	23
5.7	Endangered Species	23
6.0 Commercial and Recreational Fisheries	25
6.1	Overview	25
6.2	Commercial Fisheries	25
6.3	Recreational Fisheries	27
7.0 Coastal Zone Management Consistency and Special Aquatic Sites	29
7.1	Coastal Zone Management Consistency	29
7.2	Florida Coastal Management Program	29
7.3	Special Aquatic Sites	30
7.3.1	Madison-Swanson/Steamboat Lumps Marine Reserves/The Edges	30
7.3.2	Florida Middle Grounds HAPC (1984)	 30
7.3.3	Pulley Ridge	30
7.3.4	Sticky Ground Mounds	30
8.0 Federal Water Quality Criteria and Florida Water Quality Standards	32
8.1	Federal Water Quality Criteria	32
8.2	Florida Water Quality Standards	32
9.0 Potential Impacts	34
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9.1	Overview	34
9.2	Water Column Impacts	34
9.2.1	Turbidity	35
9.2.2	pH	35
9.2.3	T emperature	35
9.2.4	Fecal Coliforms	35
9.2.5	Nutrients	35
9.2.6	Ammonia Toxicity	36
9.2.7	Phosphorus	36
9.2.7 Dissolved Oxygen	36
9.3	Organic Enrichment Impacts to Seafloor Sediments	37
9.4	Organic Enrichment Impacts to Benthic Communities	38
9.5	Antibiotics	41
9.6	Waste Deposition Analysis	43
9.6.1	Solid Waste Discharge	44
9.6.2	Dissolved Wastes	44
10.0 Evaluation of the Ocean Discharge Criteria	46
10.1	Evaluation of the Ten Ocean Discharge Criteria Factors	46
10.1.1	Factor 1	46
10.1.2	Factor 2	46
10.1.3	Factor 3	46
10.1.4	Factor 4	47
10.1.5	Factor 5	47
10.1.6	Factor 6	47
10.1.7	Factor 7	47
10.1.8	Factor 8	47
10.1.9	Factor 9	48
10.1.10	Factor 10	48
10.2	Conclusion	48
References	49
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ABBREVIATIONS USED IN THIS DOCUMENT
BES
Baseline Environmental Survey
BMP
Best Management Practices
BOEM
Bureau of Ocean and Energy Management
CAAP
Concentrated Aquatic Animal Production
CFR
Code of Federal Regulations
CWA
Clean Water Act
CZMA
Coastal Zone Management Act
CZMP
Coastal Zone Management Program
DEP
Department of Economic Opportunity
DWH
Deep Water Horizon
EA
Environmental Assessment
EIS
Environmental Impact Statement
EPA
U.S. Environmental Protection Agency
FAO
Food and Agriculture Organization of the United Nations
FCR
Feed Conversion Ratio
FCMP
Florida Coastal Management Program
FDA
U.S. Food and Drug Administration
FDACS
Florida Department of Agriculture and Consumer Services
FDEP
Florida Department of Environmental Protection
FMP
Fishery Management Plan
FWC
Florida Fish and Wildlife Conservation Commission
GMFMC
Gulf of Mexico Fishery Management Council
HAB
Harmful Algal Blooms
HAPC
Habitat Area of Particular Concern
ITI
Infaunal Tropic Index
MAS
Multi-anchor Swivel
MMS
Minerals Management Service
MMPA
Marine Mammal Protection Act
NCCOS
National Ocean Service National Centers for Coastal Ocean Science
NMFS
National Marine Fisheries Service
NO A A
National Oceanic and Atmospheric Administration
NEPA
National Environmental Policy Act
NMFS
National Marine Fisheries Service
NPDES
National Pollutant Discharge Elimination System
OCS
Outer Continental Shelf
ODCE
Ocean Discharge Criteria Evaluation
ODMDS
Ocean Dredge Material Disposal Site
OTC
Oxytetracycline
PSMP
Protected Species Monitoring Plan
SAFMC
South Atlantic Fishery Management Council
SOD
Sediment Oxygen Demand
use
United States Code
USFWS
U.S. Fish and Wildlife Service
VE
Velella Epsilon
WQS
Water Quality Standards
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LIST OF TABLES
Table 2. 1 - Target Area With 3' to 10' of Unconsolidated Sediments	9
Table 3.1- Major dissolved constituents in seawater with a chlorinity of 19%o and a salinity of 34%o.. 13
Table 4. 1 - Nutritional composition of commonly used prepared fish diets	16
Table 5.1- Significant Dinoflagellate Species of the Eastern Gulf	20
Table 5.2 - Federally Listed Species, Listed Critical Habitat, Proposed Species, and Proposed Critical
Habitat Considered for the Proposed Action	24
Table 6.1 - Key Gulf Region Commercial Species or Species Groups	26
Table 6.2 - Total Weights and Values of Key Commercial Fishery Species in the Gulf Region in 2013
	26
Table 6.3 - Value of Gulf Coast Fish Landings by Distance from Shore and State for 2012 ($1,000) ... 26
Table 6.4 - 2013 Economic Impacts of the Eastern Gulf Region Seafood Industry (thousands of dollars)
	27
Table 6.5 - Total Landings and Landings of Key Species/Species Groups From 2010 to 2013 (thousands
of pounds)2003 2004 2005 2006 2007 2008 2009 2010 2011 2012	27
Table 6.6 - Key Gulf Region Recreational Species 	28
Table 6.7 - Estimated Number of People Participating in Eastern Gulf Marine Recreational Fishing in
2013 (thousands)	28
Table 6.8 - 2013 Economic Impacts of Recreational Fishing Expenditures in the Eastern Gulf (thousands
of dollars)	28
Table 5.1- Significant Dinoflagellate Species of the Eastern Gulf	20
Table 5.2 - Federally Listed Species, Listed Critical Habitat, Proposed Species, and Proposed Critical
Habitat Considered for the Proposed Action	24
LIST OF FIGURES
Figure 3.1- Major current regime in the Gulf	11
Figure 3.2- Depth average current rose diagram for the Tampa ODMDS showing current speeds and
direction. (EPA, 2012)	11
Figure 7. 1 - High Relief Live Bottom Areas in the Central and Eastern Gulf	31
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1.0 Introduction
1.1	Proposed Agency Action
Kampachi Farms, LLC (applicant) is proposing to operate a pilot-scale marine aquaculture facility (proposed
project) in federal waters of the Gulf. Clean Water Act (CWA) Section 402 authorizes the Environmental
Protection Agency (EPA) to issue National Pollutant Discharge Elimination System (NPDES) permits to
regulate the discharge of pollutants into waters of the United States. The proposed EPA action is the issuance
of a NPDES permit that authorizes the discharge of pollutants from an aquatic animal production facility that
is considered a point source into federal waters of the Gulf of Mexico (Gulf).
1.2	Evaluation Purpose
The purpose of this Ocean Discharge Criteria Evaluation (ODCE) is to identify pertinent information relative
to the Ocean Discharge Criteria and addresses the EPA's regulations for preventing unreasonable degradation
of the receiving waters for the discharges covered under this NPDES permit. Sections 402 and 403 of the CWA
require that a NPDES permit for a discharge into the territorial seas (baseline to 12 nautical miles, or farther
offshore in the contiguous zone or the ocean), be issued in compliance with EPA's regulations for preventing
unreasonable degradation of the receiving waters. Before issuing a NPDES permit, discharges must be
evaluated against EPA's published criteria for a determination of unreasonable degradation. The NPDES
implementing regulations at 40 CFR § 125.121(e) defines unreasonable degradation of the marine environment
as the following:
1.	Significant adverse changes in ecosystem diversity, productivity, and stability of the biological
community within the area of discharge and surrounding biological communities
2.	Threat to human health through direct exposure to pollutants or through consumption of exposed
aquatic organisms, or
3.	Loss of aesthetic, recreational, scientific or economic values, which is unreasonable in relation to the
benefit derived from the discharge.
This ODCE addresses the 10 factors for determining unreasonable degradation as required by 40 CFR §
125.122. It also assesses whether the information exists to make a "no unreasonable degradation"
determination, including any recommended permit conditions that may be necessary to reach that conclusion.
The following ten factors are specified at 40 CFR § 125.122 for determining unreasonable degradation:
1.	The quantities, composition, and potential for bioaccumulation or persistence of the pollutants to be
discharged;
2.	The potential transport of such pollutants by biological, physical or chemical processes;
3.	The composition and vulnerability of the biological communities which may be exposed to such
pollutants, including the presence of unique species or communities of species, the presence of species
identified as endangered or threatened pursuant to the Endangered Species Act, or the presence of those
species critical to the structure or function of the ecosystem, such as those important for the food chain;
4.	The importance of the receiving water area to the surrounding biological community, including the
presence of spawning sites, nursery/forage areas, migratory pathways, or areas necessary for other
functions or critical stages in the life cycle of an organism;
5.	The existence of special aquatic sites including, but not limited to, marine sanctuaries and refuges,
parks, national and historic monuments, national seashores, wilderness areas, and coral reefs;
6.	The potential impacts on human health through direct and indirect pathways;
7.	Existing or potential recreational and commercial fishing, including fin fishing and shell fishing;
8.	Any applicable requirements of an approved Coastal Zone Management plan;
9.	Such other factors relating to the effects of the discharge as may be appropriate; and
10. Marine water quality criteria developed pursuant to CWA Section 304(a)(1).
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If, on the basis of all available information, the EPA determines that the discharge will not cause unreasonable
degradation of the marine environment after application of any necessary conditions, an NPDES permit
containing such conditions can be issued. If it is determined, on the basis of the available information, that the
discharge will cause unreasonable degradation of the marine environment after application of all possible
permit conditions, the EPA may not issue an NPDES permit which authorizes the discharge of pollutants. If
the EPA has insufficient information to determine that there will be no unreasonable degradation of the marine
environment, there shall be no discharge of pollutants into the marine environment unless the director on the
EPA determines that:
1.	Such discharge will not cause irreparable harm to the marine environment during the period in which
monitoring is undertaken, and
2.	There are no reasonable alternatives to the on-site disposal of these materials, and
3.	The discharge will be in compliance with all permit conditions established pursuant to 40 CFR §
125.123(d).
1.3 ODCE Report Overview
The ODCE focuses on the sources, fate, and potential effects from discharges at a small-scale marine
aquaculture facility on various groups of marine aquatic life. It also assesses whether the information exists to
make a "no unreasonable degradation" determination, including any recommended permit conditions that may
be necessary to reach that conclusion. Each section of the ODCE addresses one of the 10 factors used in making
a determination about whether the discharge will cause unreasonable degradation.
Section 3 of this document describes the physical and chemical oceanography relevant to the coverage area
(ODCE Factor 2). Section 4 describes the characteristics, composition, and quantities of materials that
potentially will be discharged from the facility (Factor 1). Section 4 describes the transport and persistence of
pollutants in the marine environment (Factor 2). Section 5 provides a biological overview of the affected
environment (Factors 3 and 4). Section 6 provides information on commercial and recreational fisheries in the
receiving water environment (Factor 7). Section 7 describes the Florida Coastal Zone Management Plan
(CZMP) and Special Aquatic Sites (Factors 5 and 8). Section 8 provides a Federal Water Quality Criteria and
State Water Quality Standards Analysis (Factor 10). Section 9 describes potential impacts on human health
(Factor 6), and describes the toxicity and potential for bioaccumulation of contaminants in the waste streams
covered by the proposed permit (Factors 1 and 6). Section 10 summarizes the findings of this report. Note that
Factor 9, consideration of additional factors, was not deemed necessary in this evaluation as the EPA believes
that all critical environmental considerations have been addressed.
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2.0	Proposed Project InToi'miilion
2.1	Proposed Project
The proposed project would allow the applicant to operate a pilot-scale marine aquaculture facility with up
to 20,000 almaco jack (Seriola rivoliana) being reared in federal waters for a period of approximately 12
months (total deployment of the cage system is 18 months). Based on an estimated 85 percent survival rate,
the operation is expected to yield approximately 17,000 fish. Final fish size is estimated to be approximately
4.4 lbs/fish, resulting in an estimated final maximum harvest weight of 88,000 lbs (or 74,800 lbs considering
the anticipated survival rate). The fingerlings will be sourced from brood stock that are located at Mote
Aquaculture Research Park and were caught in the Gulf near Madeira Beach, Florida. As such, only F1 progeny
will be stocked into the proposed project.
One support vessel will be used throughout the life of the project. The boat will always be present at the facility
except during certain storm events or times when resupplying is necessary. The support vessel would not be
operated during any time that a small craft advisory is in effect for the proposed action area. The support vessel
is expected to be a 70 foot (ft) long Pilothouse Trawler (20 ft beam and 5 ft draft) with a single 715 HP engine.
The vessel will also carry a generator that is expected to operate approximately 12 hours per day. Following
harvest, cultured fish would be landed in Florida and sold to federally-licensed dealers in accordance with state
and federal laws. The exact type of harvest vessel is not known; however, it is expected to be a vessel already
engaged offshore fishing activities in the Gulf.
A single CopperNet offshore strength (PolarCirkel-style) fully enclosed submersible fish pen will be deployed
on an engineered multi-anchor swivel (MAS) mooring system. The engineered MAS will have up to three
anchors for the mooring, with a swivel and bridle system. The cage material for the proposed project is
constructed with rigid and durable materials (copper mesh net with a diameter of 4 millimeter (mm) wire and
40 mm x 40 mm mesh square). The mooring lines for the proposed project will be constructed of steel chain
(50 mm thick) and thick rope (36 mm) that are attached to a floating cage which will rotate in the prevailing
current direction; the floating cage position that is influenced by the ocean currents will maintain the mooring
rope and chain under tension during most times of operation. The bridle line that connects from the swivel to
the cage will be encased in a rigid pipe. Structural information showing the MAS and pen, along with the
tethered supporting vessel, is provided in Appendix A. The anchoring system for the proposed project is being
finalized by the applicant. While the drawings in Appendix A show concrete deadweight anchors, it is likely
that the final design will utilize appropriately sized embedment anchors instead.
The CopperNet cage design is flexible and self-adjusts to suit the constantly changing wave and current
conditions. As a result, the system can operate floating on the ocean surface or submerged within the water
column of the ocean; however, the normal operating condition of the cage is below the water surface. When a
storm approaches the area, the entire cage can be submerged by using a valve to flood the floatation system
with water. A buoy remains on the surface, marking the net pen's position and supporting the air hose. When
the pen approaches the bottom, the system can be maintained several meters above the sea floor. The cage
system is sable to rotate around the MAS and adjust to the currents while it is submerged and protected from
storms near the water surface. After storm events, the cage system is made buoyant, causing the system to
resume normal operational conditions. The proposed project cage will have at least one properly functioning
global positioning system device to assist in locating the system in the event it is damaged or disconnected
from the mooring system.
In cooperation with the NMFS, a protected species monitoring plan (PSMP) has been developed for the
proposed action to protect all marine mammal, reptiles, sea birds, and other protected species. Monitoring will
occur throughout the life of the project and represents an important minimization measure to reduce the
likelihood of any unforeseen potential injury to all protected species including ESA-listed marine animals. The
data collected will provide valuable insight to resource managers about potential interactions between
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aquaculture operations and protected species. The PSMP also contains important mitigative efforts such as
suspending vessel transit activities when a protected species comes within 100 meters (m) of the activity until
the animal(s) leave the area. The project staff will suspend all surface activities (including stocking fish,
harvesting operations, and routine maintenance operations) in the unlikely event that any protected species
comes within 100 m of the activity until the animal leaves the area. Furthermore, should there be activity that
results in an injury to protected species, the on-site staff would follow the steps outlined in the PSMP and alert
the appropriate experts for an active entanglement.1
2.2 Proposed Action Area
The proposed project would be placed in the Gulf at an approximate water depth of 130 ft (40 m),
generally located 45 miles southwest of Sarasota, Florida. The proposed facility will be placed within an area
that contains unconsolidated sediments that are 3 - 10 ft deep (see Table 2.1). The applicant will select the specific
location within that area based on diver-assisted assessments of the sea floor when the cage and MAS are
deployed. More information about the proposed project boundaries are shown in Appendix B. The proposed
action area is a 1,000-meter radius measured from the center of the MAS.
The facility potential locations were selected with assistance from NOAA's National Ocean Service National
Centers for Coastal Ocean Science (NCCOS). The applicant and the NCCOS conducted a site screening
process over several months to identify an appropriate project site. Some of the criteria considered during the
site screening process included avoidance of corals, coral reefs, submerged aquatic vegetation, and hard bottom
habitats, and avoidance of marine protected areas, marine reserves, and habitats of particular concern. This
siting assessment was conducted using the Gulf AquaMapper tool developed by NCCOS.2
Upon completion of the site screening process with the NCCOS, the applicant conducted a Baseline
Environmental Survey (BES) in August 2018 based on guidance developed by the NMFS and EPA.3 The BES
included a geophysical investigation to characterize the sub-surface and surface geology of the sites and
identify areas with a sufficient thickness of unconsolidated sediment near the surface while also clearing the
area of any geohazards and structures that would impede the implementation of the aquaculture operation. The
geophysical survey for the proposed project consisted of collecting single beam bathymetry, side scan sonar,
sub-bottom profiler, and magnetometer data within the proposed area. The BES report noted that there were
no physical, biological, or archaeological features that would preclude the siting of the proposed aquaculture
facility at one of the four potential locations shown in Table 2.1.
Table 2.1 - Target Area With 3' to 10' of Unconsolidated Sediments
Upper Left Corner
Upper Right Corner
Lower Right Corner
Lower Left Corner
27c
IT
IT
IT
7.70607' N
7.61022'N
6.77773'N
6.87631'N
83c
83c
83c
83c
12.27012' W
11.65678' W
11.75379' W
12.42032' W
1	A PSMP has been developed by the applicant with assistance from the NMFS Protected Resources Division. The purpose of the PSMP is
to provide monitoring procedures and data collection efforts for species (marine mammals, sea turtles, seabirds, or other species) protected
under the MMPA or ESA that may be encountered at the proposed project.
2	The Gulf AquaMapper tool is available at: https://coastalscience.noaa.gov/products-explorer/
3	The BES guidance document is available at: http://sero.nmfs.noaa.gov/sustainable_fisheries/Gulf_fisheries/aquaculture/
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3.0
The Physical l n\ iioiiiiuiil
3.1 Physical Oceanography
The Gulf is bounded by Cuba on the southeast; Mexico on the south and southwest; and the U.S. Gulf Coast
on the west, north, and east. The Gulf has a total area of 564,000 square kilometers (km2). Shallow and
intertidal areas (water depths of less than 20 m) compose 38 percent of the total area, with continental shelf
(22 percent), continental slope (20 percent), and abyssal (20 percent) composing the remainder of the basin.
The Gulf is separated from the Caribbean Sea and Atlantic Ocean by Cuba and other islands and has relatively
narrow connections to the Caribbean and Atlantic through the Florida and Yucatan Straits. The Gulf is
composed of three distinct water masses, including the North and South Atlantic Surface Water (less than 100
m deep), Atlantic and Caribbean Subtropical Water (up to 500 m deep), and Sub Antarctic Intermediate Water.
3.1.1 Circulation
Circulation patterns in the Gulf are characterized by two interrelated systems, the offshore or open Gulf, and
the shelf or inshore Gulf. Both systems involve the dynamic interaction of a variety of factors. Open Gulf
circulation is influenced by eddies, gyres, winds, waves, freshwater input, density of the water column, and
currents. Offshore water masses in the eastern Gulf may be partitioned into a Loop Current, a Florida Estuarine
Gyre in the northeastern Gulf, and a Florida Bay Gyre in the southeastern Gulf (Austin, 1970).
The strongest influence on circulation in the eastern Gulf is the Loop Current (Figure 3.1). The location of the
Loop Current is variable, with fluctuations that range over the outer shelf, the slopes, and the abyssal areas off
Mississippi, Alabama, and Florida. Within this zone, short-term strong currents exist, but no permanent
currents have been identified (MMS, 1990). The Loop Current forms as the Yucatan Current enters the Gulf
through the Yucatan Straits and travels through the eastern and central Gulf before exiting via the Straits of
Florida and merging with other water masses to become the Gulf Stream (Leipper, 1970; Maul, 1977). Currents
associated with the Loop Current and its eddies extend to at least depths of 700 m with surface speeds as high
as 150-200 centimeters (cm/s), decreasing with depth (BOEM, 2012).
In the shelf or inshore Gulf region, circulation within the Mississippi, Alabama, and west Florida shelf areas
is controlled by the Loop Current, winds, topography, and tides. Freshwater input also acts as a major influence
in the Mississippi/Alabama shelf and eddy-like perturbations play a significant role in the west Florida shelf
circulation. Current velocities along the shelf are variable. Brooks (1991) found that average current velocities
in the Mississippi/Alabama shelf area are about 1.5 cm/s, and east-west and northeast/southwest directions
dominate. MMS (1990) data showed that winter surface circulation is directed along shore and westward with
flow averaging 4 cm/s to 7 cm/s. During the spring and summer, the current shifts to the east with flow
averaging 2 cm/s to 7 cm/s. The mean circulation on the west Florida shelf is directed southward with mean
flow ranging from 0.2 cm/s to 7 cm/s (MMS, 1990).
An EPA study of ocean currents at the Tampa Ocean Dredged Material Disposal Site, which lies 18 miles due
west of Tampa Bay, FL was conducted by the EPA between 2008-2009 (EPA, 2012). The study showed that
current flow off the west FL coast is predominately in the south-southwest direction (Figure 3.2). Winter
months appear to be dominated by south-southwest currents, whereas north-northeast currents dominated the
spring months. The median surface current was 13 cm/s whereas the median bottom currents were 7 cm/s. The
depth average median current velocity was 9 cm/s.
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Figure 3. 1 - Major current regime in the Gulf
Source: NOAA 2007
Figure 3. 2 - Depth average current rose diagram for the Tampa ODMDS showing current speeds and
direction. (EPA, 2012)
North
0
180
Current Speed
(cm/sec)
I I <=5
I I >5 -10
I I >10-15
d >15 - 20
¦ >20 - 25
F~M >25
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Wind patterns in the Gulf are primarily anticyclonic (clockwise around high-pressure areas) and tend to follow
an annual cycle; winter winds from the north and southeast and summer winds from the northeast and south.
During the winter, mean wind speeds range from 8 knots to 18 knots. Several examples of mean annual wind
speeds in the eastern Gulf are 8.0 millibars (mb) in Gulf Port, Mississippi; 8.3 mb in Pensacola, Florida; and
11.2 mb in Key West, Florida (NOAA, 1986).
The tides in the Gulf are less developed and have smaller ranges than those in other coastal areas of the United
States. The range of tides is 0.3 meters to 1.2 meters, depending on the location and time of year. The Gulf has
three types of tides, which vary throughout the area: diurnal, semidiurnal, and mixed (both diurnal and
semidiurnal). Wind and barometric conditions will influence the daily fluctuations in sea level. Onshore winds
and low barometric readings, or offshore winds and high barometric readings, cause the daily water levels
either to be higher or lower than predicted. In shelf areas, meteorological conditions occasionally mask local
tide induced circulation. Tropical storms in summer and early fall may affect the area with high winds (18+
meters per second), high waves (7+ meters), and storm surge (3 to 7.5 meters). Winter storm systems also may
cause moderately high winds, waves, and storm conditions that mask local tides.
3.1.2	Climate
The Gulf is influenced by a maritime subtropical climate controlled mainly by the clockwise wind circulation
around a semi-permanent, high barometric pressure area alternating between the Azores and Bermuda Islands.
The circulation around the western edge of the high-pressure cell results in the predominance of moist
southeasterly wind flow in the region. However, winter weather is quite variable. During the winter months,
December through March, cold fronts associated with outbreaks of cold, dry continental air masses influence
mainly the northern coastal areas of the Gulf. Tropical cyclones may develop or migrate into the Gulf during
the warmer season, especially in the months of August through October. In coastal areas, the land-sea breeze
is frequently the primary circulation feature in the months of May through October. (BOEM, 2012)
3.1.3	Temperature
In the Gulf, sea surface temperatures range from nearly isothermal (29 - 30°C) in August to a sharp horizontal
gradient in January, ranging from 25°C in the Loop core to values of 14-15°C along the shallow northern
coastal estuaries. A 7°C sea surface temperature gradient occurs in winter from north to south across the Gulf.
During summer, sea surface temperatures span a much narrower range. The range of sea surface temperatures
in the eastern Gulf tends to be greater than the range in the western Gulf, illustrating the contribution of the
Loop Current.
Eastern Gulf surface temperature variation is affected by season, latitude, water depth, and distance offshore.
During the summer, surface temperatures are uniformly 26.6°C or higher. The mean March isotherm varies
from approximately 17.8°C in the northern regions to 22.2°C in the south (Smith, 1976). Surface temperatures
range as low as 10°C in the Louisiana-Mississippi shelf regions during times of significant snow melt in the
upper Mississippi valley (MMS, 1990).
At a depth of 1,000 m, the temperature remains close to 5°C year-round (MMS, 1990). In winter, nearshore
bottom temperatures in the northern Gulf are 10°C cooler than those temperatures offshore. A permanent
seasonal thermocline occurs in deeper off shelf water throughout the Gulf. In summer, warming surface waters
help raise bottom temperatures in all shelf areas, producing a decreasing distribution of bottom temperatures
from about 28°C at the coast to about 18-20°C at the shelf break.
The depth of the thermocline, defined as the depth at which the temperature gradient is a maximum, is
important because it demarcates the bottom of the mixed layer and acts as a barrier to the vertical transfer of
materials and momentum. The thermocline depth is approximately 30 m in the eastern Gulf during January
(MMS, 1990). In May, the thermocline depth is about 46 m throughout the entire Gulf (MMS, 1990).
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3.1.4 Salinity
Characteristic salinity in the open Gulf is generally between 36.4 and 36.5 parts per thousand (ppt). Coastal
salinity ranges are variable due to freshwater input, draught, etc. (MMS, 1990). During months of low
freshwater input, deep Gulf water penetrates the shelf and salinities near the coastline range from 29-32 ppt.
High freshwater input conditions (spring-summer months) are characterized by strong horizontal gradients and
inner shelf salinity values of less than 20 ppt (MMS, 1990).
3.2 Chemical Composition
Of the 92 naturally occurring elements, nearly 80 have been detected in seawater (Kenisha, 1989). The
dissolved material in seawater consists mainly of eleven elements. These are, in decreasing order, chlorine,
sodium, magnesium, calcium, potassium, silicon, zinc, copper, iron, manganese, and cobalt (Smith, 1981). The
major dissolved constituents in seawater are shown in Table 3.1. In addition to dissolved materials, trace
metals, nutrient elements, and dissolved atmospheric gases comprise the chemical makeup of seawater.
Table 3. 1 - Major dissolved constituents in seawater with a chlorinity of 19%o and a salinity of 34%o
l)issol\i'(l suhsliiiico
(Ion (ii* Compound)
( oiiitiiI
l^i'iiins per kilo
I'iilion
liiiiiii)
IVrccnl
(In
Chloride (CI )

18.98
55.04
Sodium (Na+)

10.56
30.61
Sulfate (SO.,2")

2.65
7.68
Magnesium (Mg2+)

1.27
3.69
Calcium (Ca2+)

0.40
1.16
Potassium (K+)

0.38
1.1
Bicarbonate (HCO3 )

0.14
0.41
Bromide (Br)

0.07
0.19
Boric Acid (H3BO3)

0.03
0.07
Strontium (Sr2+)

0.01
0.04
Fluoride (F )

0.00
0.00
Totals

34.48
99.99
3.2.1	Micronutrients
In Gulf waters, generalizations can be drawn for three principal micronutrients; phosphate, nitrate, and silicate.
Phytoplankton consume phosphorus and nitrogen in an approximate ratio of 1:16 for growth. The following
nutrient levels and distribution values were obtained from MMS (1990): phosphates range from 0 ppm to 0.25
ppm, averaging 0.021 ppm in the mixed layer, and with shelf values similar to open Gulf values; nitrates range
from 0.0031 ppm to 0.14 ppm, averaging 0.014 ppm; silicates range predominantly from 0.048 ppm to 1.9
ppm, with open Gulf values tending to be lower than shelf values.
In the eastern Gulf, inner shelf waters tend to remain nutrient deficient, except in the immediate vicinity of
estuaries. On occasions when the loop current occurs over the Florida slope, nutrient rich waters are upwelled
from deeper zones (MMS, 1990).
3.2.2	Dissolved Gases
Dissolved gases found in seawater include oxygen, nitrogen, and carbon dioxide. Oxygen is often used as an
indicator of water quality of the marine environment and serves as a tracer of the motion of deep-water masses
of the oceans. Dissolved oxygen values in the mixed layer of the Gulf average 4.6 milligrams per liter (mg/1),
with some seasonal variation, particularly during the summer months when a slight lowering can be observed.
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Oxygen values generally decrease with depth to about 3.5 mg/1 through the mixed layer (MMS, 1990). In some
offshore areas in the northern Gulf, hypoxic (<2.0 mg/1) and occasionally anoxic (<0.1 mg/1) bottom water
conditions are widespread and seasonally regular (Rabalais, 1986). These conditions have been documented
since 1972 and have been observed mostly from June to September on the inner continental shelf at a depth of
5 to 50 meters (Renauld, 1985; Rabalais et al., 1985).
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4.0 l)isi'h;ir<>c(l M;ileri;ils
The composition, characteristics, and quantities of materials that will or potentially will be discharged from
the facility under the NPDES permit are considerations under Factor 1 of the 10 factors used to determine
whether unreasonable degradation may occur. The materials to be discharged under NPDES permit to the Gulf
from the proposed project will consist of uneaten fish food pellets and fish wastes.
4.1 Fish Feed
Much of the discussion in this section was developed from information concerning large production scale fish
farms. It is important to note that the proposed project under consideration for this permit will be a small
demonstration proj ect. The prosed project will grow out a maximum of 20,000 fish that would be grown to 1.8
kg for less than one year. The total maximum biomass assuming no mortality is estimated to be approximately
39,000 kg. Fish will be fed a commercially available grow out diet with 43 percent protein content. Daily feed
rations range from 12 kg at stocking to a maximum total daily feed ration equivalent to 399 kg at harvest.
Maximum daily excretion of total ammonia nitrogen is estimated at 16 kg and solids production is 140 kg. A
total of 66,449 kg of feed will be used for production of each cohort of fish to achieve a feed conversion ratio
(FCR)of 1.8.
The quantities of food supplied per unit of fish depend on the type of food used, size of the fish, and the water
temperature. A typical salmon farm producing 340 metric tons (748,000 lbs) of fish annually will feed 340 to
680 metric tons (748,000-1,496,000 lbs) of food (Wash Dept. Fisheries, 1989). Fish cultured around the world
are fed a variety of foods, ranging from minced trash fish, to semi-moist pellets of minced fish and various
binders, to dry pellets. Semi-moist or dry pellets are used extensively in U.S. fish farms and consist of a
combination of fish meal and vegetable matter, mixed with vitamins, essential oils and other organic material.
Some studies have shown that when feeding methods are optimized, there is generally no significant difference
between pelletized artificial feeds and the use of trash fish regarding the discharge of nutrients and solid
materials from cages (Hasan, 2012). Table 4.1 shows the composition of several commonly used prepared fish
diets. Typical average levels of protein, fats and carbohydrates in fish feeds ranges from 18-50 percent, 10-25
percent and 15-20 percent respectively, depending on targeted species (Waldemar Nelson International, 1997;
Craig, 2009). The proposed permit prohibits the discharge of un-pelletized wet feeds.
The effectiveness of cultured fish feeding methods and diets are measured by calculating a FCR - the ratio of
food fed (dry weight) to fish produced (wet weight). Typically, average FCR's range from 1:1 for salmonid
fishes to 2:1 for some freshwater species (Hasan and Soto, 2017). That is, for every pound of fish produced, 1
to 2 lbs of feed were introduced into the water. In some laboratory experiments, FCR's of less than 1:1 have
been achieved, and most fish farmers now claim values between 1 and 1.5. The amount fed during any period
depends primarily upon the type of food used, the size of the fish, and the water temperature. Farmed fish are
typically fed 1-4 percent of their body weight per day. Though protein content may vary, generally, fish feed
includes about 7.7 percent nitrogen (Edwards, 1978) and 37.7 percent percent organic carbon (Waldemar
Nelson International, 1997).
Modern feeds are designed to reduce solid wastes by improving digestibility, ingredient selection and nutrient
balance (Cho and Bureau, 2001). Even with the highest FCRs, a portion of fish feed is not eaten and settles to
the bottom. Feed wastage has proven difficult to ascertain in field conditions. However, several studies in
Europe have suggested that a range of 1 to 30 percent of the feed may be lost (Gowen et al 1988; Pencsak et
al., 1982). Dry feed consistently showed the least amount of wastage (1 to 5 percent) while 5 to 10 percent of
moist fish foods were lost (Gowen and Bradbury, 1987). In Puget Sound farms, fish growers report that food
wastage is typically less than 5 percent (Weston, 1986). Specific studies of food wastage at a commercial
salmon farm in Sooke Inlet, B.C., showed that hand feeding, the most common practice in Puget Sound,
resulted in wastage of 3.6 percent. The use of automatic feeders increased wastage to 8.8 percent (Cross, 1988).
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Since food pellets do not decompose appreciably as they settle to the bottom, they are unlikely to experience
substantial reduction in nitrogen or carbon, either through solution or microbial activity, before depositing on
the bottom (Collins, 1983; Go wen and Bradbury, 1987). Thus, any food particles or pellets lost during feeding
will retain their nutrients essentially unaltered. Development of slower settling feeds, which are available to
the fish in the pens for longer periods, and feeds with more uniform size have reduced wastage. However, the
amount of wastage is still highly dependent upon the care used by the fish farmer during feeding.
Table 4. 1 - Nutritional composition of commonly used prepared fish diets 4
Source
1 isli
Species
l-'eed Brand
Iced
T\|>e
It •'
'it
Protein
it
it
I'als (:
it •*
'it
irholmlrales
BioProducts, Inc (EPA, 1991)
Salmon
Biodry 3000
Dry
44.5
15.0
14.7
Moore-Clark Co. (EPA, 1991)
Salmon
Select Ext.
Dry
45.0
22.0
14.0
BioProducts, Inc (EPA, 1991)
Salmon
Biomoist F.3
Moist
39.0
13.5
11.8
Moore-Clark Co. (EPA, 1991)
Salmon
Oregon Moist
Dry
35.0
11.0
13.0
ZieglerBros. (Ellis, 1996)
Grouper
Trout Grower
Dry
43.5
5.9
34.8
Rangen, Inc. (Ellis, 1996)
Grouper
Salmon Grower
Dry
52.7
15.2
13.8
Dainichi Corp. (Ellis, 1996)
Grouper
Cam. Fish Diet
Dry
55.6
7.8
20.7
Oceanic Institute (Ellis, 1996)
Grouper
Mahi ex. diet
Dry
61.8
14.2
12.9
Corey Feed Mills
Salmon
Fundy Choice
Dry
43.0
30.0
11.0
Aquaculture 1997 v. 151
Grouper
-
Dry
43.0
14.0
8.0
Oceanic Institute, 1993
Mahi-
Mahi
OI prepared diet
Dry
60.0
12.0
10.0
Williams, 1985
Pompano
Menhaden oil
diet
Dry
42.0
12.0
7.0
Burris Mill & Feed
Hybrid
Bass
Grower
Dry
42.0
7.0
19.0
Burris Mill & Feed
Red Drum
Grower
Dry
42.0
7.0
19.0
Burris Mill & Feed
Red Drum
Grower
Dry
40.0
10.0
30.0
Mean



45.9
13.1
16.0
4.2 Fish Wastes
Of the feed consumed, about 10 percent is lost as solid wastes and 30 percent lost as liquid wastes (Butz and
Vens-Capell, 1982; Craig, 2009). Unlike feed pellets, fish feces are more variable in size and density.
Consequently, the settling rate of these particles will vary greatly, but will be less than that of feed pellets. The
composition of the feces is dependent upon the chemical composition of the feed and its digestibility. Gowen
and Bradbury (1987) estimated from the literature that about 30 percent of the consumed carbon would be
excreted in the feces, along with about 10 percent of the consumed nitrogen.
Estimates of the total particulate matter emanating from net pens, for eventual deposit on the sea floor, have
been calculated. Weston (1986), assuming an FCR of 2:1 with 5 percent wastage and a third of the consumed
food being lost as feces, estimated that 733 kg (1,600 lbs) of sediment would be produced for every metric ton
4 Source: Modified from Waldemar Nelson International 1997.
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(2200 lbs) of fish grown. The Institute of Aquaculture (1988) estimated sediment production of 820 kg (1800
lbs), assuming 20 percent wastage and a 30 percent loss as feces.
Discharge limitations in the proposed permit state that fish food and metabolic wastes discharged from the
facility shall not cause unreasonable degradation of the environment beneath the facility and/or the surrounding
area as defined in 40 CFR § 125.122(a).
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5.0 ISiolo<>k-;il ()\on iew
This chapter describes the biological communities and processes in the eastern Gulf in general and in the
specific area of the proposed facility which may be exposed to pollutants, the potential presence of endangered
species, any unique species or communities of species, and the importance of the receiving water to the
surrounding biological communities.
5.1 Primary Productivity
Primary productivity is "the rate at which radiant energy is stored by photosynthetic and chemosynthetic
activity of producer organisms in the form of organic substances which can be used as food materials" (Odum,
1971). Primary productivity is affected by light, nutrients, and zooplankton grazing, as well as other interacting
forces such as currents, diffusion, and upwelling. The producer organisms in the marine environment consist
primarily of phytoplankton and benthic macrophytes. Since benthic macrophytes are depth/light limited,
primary productivity in the open ocean is attributable primarily to phytoplankton. The productivity of
nearshore waters can be attributed to benthic macrophytes—including seagrasses, mangroves, salt marsh
grasses, and seaweeds—and phytoplankton.
There are numerous methods for estimating primary productivity in marine waters. One method is to measure
chlorophyll content per volume of seawater and compare results over time to establish a productivity rate. The
chlorophyll measurement, typically of chlorophyll a, gives a direct reading of total plant biomass. Chlorophyll
a is generally used because it is considered the "active" pigment in carbon fixation (Steidinger and Williams,
1970). Another method, the C14 (radiocarbon) method, measures photosynthesis (a controversy exists as to
whether "net", "gross", or "intermediate" photosynthesis is measured by this method; Kennish, 1989). The C14
method introduces radiolabeled carbon into a sample and estimates the rate of carbon fixation by measuring
the sample's radioactivity. The units used to express primary productivity are grams of carbon produced in a
column of water intersecting one square meter of sea surface per day (g C/m2/d), or grams of carbon produced
in a given cubic meter per day (g C/m3/d).
C14 uptake throughout the Gulf is 0.25 g C/m3/hr or less, and chlorophyll measurements range from 0.05 to
0.30 mg/m3 (ppb). Eastern regions of the Gulf are generally less productive than western regions, and
throughout the eastern Gulf, primary productivity is generally low. However, outbreaks of "red-tide" caused
by pathogenic phytoplankton may occur in the mid- to inner-shelf. Also, depth-integrated productivity values
in the area of the Loop Current (primarily the outer shelf and slope) are actually higher than western and central
Gulf values. Enhanced productivity occurs in areas affected by upwelling. Near the bottom of the euphotic
zone, chlorophyll and productivity values are about an order of magnitude greater, probably due to the often
intruded, nutrient-rich Loop undercurrent waters (MMS, 1990).
Productivity measurements in the oceanic waters of the Gulf include: 0.1 g C/m2/d yielding 17 g C/m2/yr or
86 million tons of phytoplankton biomass (MMS, 1983); 103-250 g C/m2/yr (Flint and Kamykowski, 1984);
103 g C/m2/yr (Flint and Rabalais, 1981). For comparisons, the following data on primary productivity are
presented for coastal wetland systems as compiled by Thayer and Ustach (1981):
•	Salt Marshes, 200-2000 g C/m2/yr
•	Mangroves, 400 g C/m2/yr
•	Seagrasses, 100-900 g C/m2/yr
•	Spartina alterniflora, 1300gC/m2/yr
•	Thalassia, 580-900 g C/m2/yr
•	Phytoplankton, 350 g C/m2/yr
Biomass (chlorophyll a) measurements in the predominantly oceanic waters of the Gulf include: 0.05-0.30 mg
Chi a/m3 (MMS, 1983a); 0.05-0.1 mg Chi a/m3 (Yentsch, 1982); 0.22 mg Chi a/m3 (El-Sayed, 1972); and 0.17
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mg Chi a/m3 (Trees and El-Sayed, 1986). For the eastern Gulf, biomass (chlorophyll a) measurements include
the following (Yoder and Mahood, 1983):
•	Surface mixed layer values of 0.1 mg/m3;
•	Subsurface measurements at 40-60 m ranged from 0.2 to 1.2 mg/m3;
•	Average integrated values for the water column over the 100-200 m isobath was 10 mg/m2; and
•	Average integrated values for the water column greater than 200 m isobath was 9 mg/m2.
5.2 Phytoplankton
5.2.1	Distribution
Phytoplankton distribution and abundance in the Gulf is difficult to measure. Shipboard or station
measurements cannot provide information about large areas at one moment in time, and satellite imagery
cannot provide definitive information about local conditions that may be important. Due to fluctuations in light
and nutrient availability and the immobility of phytoplankton, distribution is temporally and spatially variable.
Seasonal fluctuations in location and abundance are often masked by patchy distributions which human
sampling designs must attempt to interpret. In addition, methods for measurement of chlorophyll or uptake of
carbon cannot always resolve all questions concerning variability among or within species under different
conditions, or those concerning the effects of grazing on abundance.
As mentioned in the previous section, phytoplankton occupy a niche at the base of food chain as primary
producers of our oceans. Herbivorous zooplankton populations require phytoplankton for maintenance and
growth -- generally 30-50 percent of their weight each day and surpassing 300 percent of their weight in
exceptional cases (Kennish, 1989). In the Gulf, phytoplankton are also often closely associated with bottom
organisms, and may also contribute to benthic food sources for demersal feeding fish.
Phytoplankton seasonality has been explained in terms of salinity, depth of light penetration, and nutrient
availability. Generally, diversity decreases with decreased salinity and biomass decreases with distance from
shore (MMS, 1990).
5.2.2	Principal Taxa
The principal taxa of planktonic producers in the ocean are diatoms, dinoflagellates, coccolithophores,
silicoflagellates and blue-green algae (Kennish, 1989).
Diatoms
Many specialists regard diatoms as the most important phytoplankton group, contributing substantially to
oceanic productivity. Diatoms consist of single cells or cell chains, and secrete an external rigid silicate
skeleton called a frustule. In 1969, Saunders and Glenn reported the following for diatom samples collected
5.6 to 77.8 kilometers (km) from shore in the Gulf between St. Petersburg and Ft. Myers, Florida. Diatoms
averaged 1.4 x 107(i2/l surface area offshore, 13.6 x 107|i2/l at intermediate locations and 13.0 x 108|i2/l inshore.
The ten most important species in terms of their cellular surface area were: Rhizosolenia alata, R. setigera, R.
stolterfothii, Skeletonema costatum, Leptocylindrus danicus, Rhizosolenia fragilissima, Hemidiscus
hardmanianus, Guinardia flaccida, Bellerochea malleus, and Cerataulina pelagica.
Dinoflagellates
Dinoflagellates are typically unicellular, biflagellated autotrophic forms that also supply a major portion of the
primary production in many regions. Some species generate toxins and when blooms reach high densities,
mass mortality of fish, shellfish, and other organisms can occur (Kennish, 1989). Notably, Gymnodinium breve
is responsible for most of Florida's red tides and several of the Gonyaulax species are known to cause massive
blooms (Steidinger and Williams, 1970). Table 5.1 lists species and varieties of dinoflagellates found to be
abundant during the Hourglass Cruises (a systematic sampling program in the eastern Gulf.)
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Table 5.1 - Significant Dinoflagellate Species of the Eastern Gulf 5
Species
Hioninss YhIiic (ii 4)
Amphibologia bidentata
Ceratium carriense
C. carriense var. volans
C. contortum var. karstenii
C. extensum
C. furca
C. fusus
C. hexacanthum
Ceratium hircus
C. inflation
C. massiliense
C. trichoceros
C. tripos var. atlanticum
Dinophysis caudata var. pedunculata
Gonyaulax splendens
Prorocentrum crassipes
P. gracile
P. mi cans
67,039 - 95,406
637,219 - 1,115,367
622,206 - 1,196,643
943,121 - 1,655,573
189,709 -323,546
23,157-43,369
34,463 - 154,722
687,593 - 1,384,016
211,709
145,897-221,276
543,762 - 1,002,222
104,110 -357,437
518,659 -964,436
92,153 -231,405
51,651
329,540
25,773
65,412
Coccolithophores
Coccolithophores are unicellular, biflagellated algae named for their characteristic calcareous plate, the
coccolith, which is embedded in a gelatinous sheath that surrounds the cell. Phytoplankton of offshore Gulf
are reported to be dominated by coccolithophores (Iverson and Hopkins, 1981).
Silicoflagellates
Silicoflagellates are unicellular flagellated (single or biflagellated) organisms that secrete an internal skeleton
composed of siliceous spicules (Kennish, 1989). Perhaps because of their small size (usually less than 30 |^m
in diameter) little specific information relative to Gulf distribution and abundance, is available for this group.
Blue Green Algae
Blue green algae are prokaryotic organisms that have chitinous walls and often contain a pigment called
phycocyanin that gives the algae their blue green appearance (Kennish, 1989). On the west Florida shelf,
inshore blooms of the blue green algae Oscillatoria erethraea sometimes occur in spring or fall.
5.3 Zooplankton
Like phytoplankton, zooplankton are seasonal and patchy in their distribution and abundance. Zooplankton
standing stocks have been associated with the depth of maximum primary productivity and the thermocline
(Ortner et al., 1984). Zooplankton feed on phytoplankton and other zooplankton, and are important
intermediaries in the food chain as prey for each other and larger fish.
As in many marine ecosystems, zooplankton fecal pellets contribute significantly to the detrital pool. The ease
of mixing in Gulf coastal waters may make them extremely important to nutrient circulation and primary
productivity, as well as benthic food stocks. Also contributing to the detrital pool is the concentration of
5 Source: Steidinger and Williams, 1970.
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zooplankton in bottom waters, coupled with phytoplankton in the nepheloid layer during times of greater water
stratification.
Copepods are the dominant zooplankton group found in all Gulf waters. They can account for as much as 70
percent by number of all forms of zooplankton found (NOAA, 1975). In shallow waters, peaks occur in the
summer and fall (NOAA, 1975), or in spring and summer, (MMS, 1983a). When salinities are low, estuarine
species such as Acartia tonsa become abundant.
The following information on zooplankton distribution and abundance in the eastern Gulf is summarized from
Iverson and Hopkins (1981):
•	During Bureau of Land Management-sponsored studies, small copepods predominated in net catches over
the shelf regions of the eastern and western Gulf.
•	During Department of Energy-sponsored studies at sights located over the continental slope of Mobile and
Tampa Bays, small calanoids such as Parcalanus, and Clausocalanus and cyclopoids such as Farralanula,
Oncaea, and Oithona predominated at the 0-200 m depths; and larger copepods such as Eucalanus,
Rhincalnus, and Pleuromamma dominated at 1,000 m depths. Euphausiids were also more conspicuous.
Night-time samples taken near Tampa showed larger crustaceans such as Lucifer and Euphasia. Biomass
data for the same site revealed a decrease in zooplankton with increasing depth. The mean cumulated
biomass value for the upper 1,000 m was 21.9 ml/m2
•	Studies funded by the National Science Foundation in the east-central Gulf found diurnal patterns of
distribution in the upper 1,000 m, with increases in the 50 m range at night and in the 300-600 m zone
during the day, most likely attributable to vertical migration. In the upper 200 m, in addition to copepods,
group such as chaetognaths, tunicates, hydromedusae, and euphausiids were significant contributors to the
biomass.
Icthyoplankton studies for the eastern Gulf conducted during 1971-1974 found fish eggs to be more abundant
in the northern half and fish larvae to be more abundant in the southern half of the eastern Gulf. Mean
abundances were 5,454 eggs/m2 and 3,805 larvae/m2 in the northern Gulf and 4,634 eggs/m2 and 4,869
larvae/m2 in the southern Gulf. Eggs were more abundant in waters less than 450 meters deep, whereas larvae
were more abundant in-depth zones greater than 50 meters (Houde and Chitty, 1976).
5.4 Habitats
5.4.1	Seagrasses
Seagrasses are vascular plants that serve a variety of ecologically important functions. As primary producers,
seagrasses are a direct food source and also contribute nutrients to the water column. Seagrass communities
serve as a nursery habitat for juvenile fish and invertebrates and seagrass blades provide substrate for epiphytes.
Species such as Thalassia testudinum have an extensive root system that stabilize substrate, and broad ribbon-
like blades that increase sedimentation. Seagrasses mainly occur in shallow, clear, highly saline waters.
Seagrass beds do not occur in the proposed activity area.
Approximately 1.25 million acres of seagrass beds are estimated to exist in exposed, shallow, coastal/nearshore
waters and embayments of the Gulf. About 3 percent of these beds are in Mississippi. Florida with Florida Bay
and coastal Florida accounting for more than 80 percent. True seagrasses that occur in the Gulf are shoal grass,
paddle grass, star grass, manatee grass, and turtle grass. Although not considered a true seagrass because it has
hydroanemophilous pollination (floating pollen grains) and can tolerate freshwater, widgeon grass is common
in the brackish waters of the Gulf. (BOEM, 2012).
5.4.2	Offshore Habitats
Offshore habitats include the water column and the sea floor. The west Florida Shelf extends seaward of Tampa
Bay approximately 200 km to a depth of 200 m and consists mainly of unconsolidated sediments punctuated
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by low-relief rock outcroppings and several series of high relief ridges. The seafloor on the west Florida shelf
in the proposed project area consists mainly of course to fine grain sands with scattered limestone outcroppings
making up about 18 percent of the seafloor habitat. These limestone outcroppings provide substrata for the
attachment of macroalgae, stony corals, octocorals, sponges and associated hard-bottom invertebrate and fish
communities (EPA, 1994).
5.5 Fish and Shellfish Resources
The distribution of fish resources in the eastern Gulf are highly dependent on a variety of factors including
habitat type, chemical and physical water quality variables, biological, and climatic factors. The Gulf contains
both a temperate fish fauna and a tropical fauna arrayed into inshore and offshore habitats depending on
latitude. To the south of the 20°C winter isotherm, approximately middle Florida, the more tropical fish fauna
occupies inshore habitats replacing the temperate fauna. To the north the tropical fauna is pushed further
offshore to avoid cold winter temperature and by increased competition by temperate species able to tolerate
cooler waters. In the northern Gulf where temperate species dominate inshore, a well-developed tropical fauna
occurs on offshore structures, particularly reefs (Hoese and Moore, 1977). During warm weather the early life
stages of the tropical fauna move further inshore around piers and jetties.
The temperate fish and invertebrate fauna of the north-central Gulf tend to be dominated by estuary dependent
species such as sciaenids (i.e., croaker, red and black drum, spotted seatrout), menhaden, shrimp, oysters and
crabs. These species require the transportation of early life stages into estuaries for grow out into mature adults
or juveniles and migration out to shelf environments. Shellfish resources in the Gulf tend to be more estuarine
dependent than finfishes. Gulf shellfish habitats range from brackish wetlands to nearshore shelf environments.
Of the 15 penaeid shrimp species found in the Gulf the brown, white and pink shrimp are the most important.
Adults of these species spawn in offshore marine waters and the free swimming postlarvae move into estuaries
to remain through their juvenile stages. Juvenile shrimp move back offshore to molt into adults.
Reef fish assemblages may consist of mainly temperate species in the more northern Gulf with increasing
dominance of more tropical fish species, typically associated with coral reefs, further offshore and in the more
southern portions of the Gulf. Natural reef habitat in the eastern Gulf ranges from low relief (>1 m) livebottom,
high relief ridge habitats along the Florida shelf break and pinnacle formations of the Florida Middle Grounds
on the west Florida shelf. Man-made or artificial reef habitats also exist from oil and gas platforms, sunken
vessels and a variety of other structures placed intentionally for fisheries enhancement. These structures
comprise critical habitats for many important commercial and recreational fishes such as groupers and
snappers.
Pelagic fish species are distributed by water column depth and relationship to the shore. Coastal pelagics are
those that move mainly around the continental shelf year-round, singly or in schools of various size. These
include some commercially important groups of fishes including sharks, anchovies, herring, mackerel, tuna,
mullet, bluefish and cobia. Oceanic pelagics occur at or seaward of the shelf edge throughout the Gulf. Oceanic
pelagics include many larger species such as sharks, tuna, bill fishes, dolphin and wahoo.
Extensive discussions of reef and migratory fish species in the Gulf can be found in the Final Programmatic
Environmental Impact Statement. Fishery Management Plan for Regulating Offshore Marine Aquaculture in
the Gulf (NOAA 2009).
A 2010 survey of the Tampa Ocean Dredge Material Disposal Site (ODMDS) that is approximately 18 miles
west of Tampa Bay, identified 29 species of demersal fishes associated with the high relief habitat created by
the dredged material spoil mound, with only 9 species on nearby natural low-relief hard bottom habitat.
Abundances of fishes on natural low-relief hard bottom in the area were also significantly smaller than on the
spoil mound (EPA, 2011).
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5.6 Marine Mammals
All marine mammals are protected under the Marine Mammal Protection Act of 1972 (MMPA). There are 22
marine mammal species that may occur in the Gulf (i.e., one sirenian species (a manatee), and 21 cetacean
species (dolphins and whales)) based on sightings and/or strandings (Schmidly, 1981; NOAA, 2009). Three
of the marine mammals (sperm whales, Gulf Bryde's whale, and manatees) are also currently protected
under the Endangered Species Act (ESA).
Cetaceans (whales, dolphins, and porpoises) are the most common. Six of the seven baleen whales in the Gulf
are currently listed as threatened or endangered and of the 20 toothed whales present only the sperm whale is
endangered. During 1978 to 1987, a total of 1,200 cetacean strandings/sightings was reported for Alabama,
Florida and Mississippi to the Southeastern U.S. Marine Strandings Network. Ninety percent of these
stranding/sighting occurred off Florida coasts (the Florida figure reflects strandings from both the Gulf and the
Atlantic waters (NOAA, 1991). The cetaceans found in the Gulf include species that occur in most major
oceans, and for the most part are eurythermic with a broad range of temperature tolerances (Schmidly, 1981).
An introduced species of pinniped, the California sea lion, occurred in small numbers only in the feral
condition, however no sightings of this species has been reported in the Gulf since 1990.
Most of the Gulf cetacean species reside in the oceanic habitat (greater than or equal to 200 m). However, the
Atlantic spotted dolphin (Stenella frontalis) is found in waters over the continental shelf (10-200 m), and the
common bottlenose dolphin (Tursiops truncatus truncatus) (hereafter referred to as bottlenose dolphins) is
found throughout the Gulf, including within bays, sounds, and estuaries; coastal waters over the continental
shelf; and in deeper oceanic waters. Bottlenose dolphins in the Gulf can be separated into demographically
independent populations called stocks. Bottlenose dolphins are currently managed by NOAA Fisheries as 36
distinct stocks within the Gulf. These include 31 bay, sound, and estuary stocks, three coastal stocks, one
continental shelf stock, and one oceanic stock (Hayes et al., 2017).6
More extensive discussions about marine mammals for the proposed project are within the Environmental
Assessment (EA) for the proposed project. Additionally, more information about marine mammals in the Gulf
can be found in the Final Programmatic Environmental Impact Statement (EIS) Fishery Management Plan for
Regulating Offshore Marine Aquaculture in the Gulf (NOAA, 2009), the EA for the EPA Oil and Gas general
NPDES permit (EPA, 2016), and in recent Bureau of Ocean and Energy Management (BOEM) EIS documents
(BOEM, 2012).
5.7 Endangered Species
The USFWS and NMFS evaluate the conditions of species and their populations within the United States.
Those species populations considered in danger of extinction are listed as endangered species pursuant to the
Endangered Species Act of 1973. In addition, Section 7(a)(2) of the ESA requires federal agencies to ensure
that their action do not jeopardize the continued existence of listed species or destroy or adversely modify
critical habitat. Table 5.2 provides the list of ESA-listed species that were considered by the EPA and could
potentially occur in or near the proposed action area.
More information about endangered species can be found in the Biological Evaluation for the proposed proj ect.
Overall, potential impacts to the ESA-listed species considered by the EPA are expected to be extremely
unlikely and insignificant due to the small size of the facility, the short deployment period, unique operational
characteristics, lack of geographic overlap with habitat or known migratory routes, or other factors that are
described in the below sections for each species.
6 Marine Mammal Stock Assessment Reports and additional information on these species in the Gulf are available on the NOAA Fisheries
Office of Protected Species website: www.nmfs.noaa.gov/pr/sspecies/.
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Threatened and endangered species that occur in the Gulf are discussed extensively in the 2016 EPA
Environmental Assessment for the EPA Oil and Gas general NPDES permit (EPA, 2016), BOEM EIS
documents (BOEM, 2013), and Final PEIS for Offshore Marine Aquaculture in the Gulf (NOAA, 2009).
Table 5.2 - Federally Listed Species, Listed Critical Habitat, Proposed Species, and Proposed Critical
Habitat Considered for the Proposed Action
Species Considered
I SA Sliilus
Criliciil
lliihiliil Sliilus
I'olenliiil Kxposnre In
Proposed Ad ion Area
Birds



1 Piping Clover
Threatened
Yes
No
2 Red Knot
Threatened
No
No
1 isli



1 Giant Manta Ray
Threatened
No
Yes
2 Nassau Grouper
Threatened
No
Yes
3 Oceanic Whitetip Shark
Threatened
No
Yes
4 Smnllloolli Saw fish
Endangered
\\.
Yes
Imerlehriiles



1 Boulder Star Coral
Threatened
No
No
2 Elkhorn Coral
Threatened
No
No
4 Mountainous Star Coral
Threatened
No
No
5 Pillar Coral
Threatened
No
No
7 Staghorn Coral
Threatened
No
No
6 Rough Cactus Coral
Threatened
No
Yes
3 Lobed Star Coral
Threatened
No
Yes
Murine M;imm;ils



1 Blue Whale
Endangered
No
Yes
2 Bryde's Whale
Endangered
No
Yes
3 Fin Whale
Endangered
No
Yes
4 Humpback Whale
Endangered
No
Yes
5 Sei Whale
Endangered
No
Yes
f> Sperm Whale
Endangered
\\.
Yes
Reptiles



1 Green Sea Turtle
Threatened
No
Yes
2 Hawksbill Sea Turtle
Endangered
Yes
Yes
3 Kemp's Ridley Sea Turtle
Endangered
No
Yes
4 Leatherback Sea Turtle
Endangered
Yes
Yes
5 Loggerhead Sea Turtle
Threatened
Yes
Yes
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6.0 ('oiiiiiioixiiil and KeiTCiilionnl Fisheries
6.1	Overview
Though the Gulf Region includes Alabama, Louisiana, Mississippi, Texas, and West Florida, much of the
following discussion will focus on Gulf states in the eastern portion of the Gulf. Federal fisheries in this region
are managed by the Gulf Fishery Management Council (GMFMC) and the NMFS under seven fishery
management plans (FMPs): Red Drum, Shrimp, Reef Fish, Coastal Migratory Pelagic Resources (with
SAFMC), Spiny Lobster (with SAFMC), Corals, and Aquaculture. The coastal migratory pelagic resources
and spiny lobster fisheries are managed in conjunction with the South Atlantic Fishery Management Council
(SAFMC).
Several of the stocks or stock complexes covered in these fishery management plans, are currently listed as
overfished: gray snapper, greater amberjack, and lane snapper.7 Other impacts to commercial fisheries in the
Gulf in recent years include a number of hurricanes, especially with major storms making landfall in Louisiana
and Texas in 2005 (Hurricanes Katrina and Rita) and 2008 (Hurricanes Gustav and Ike). Locally, these storms
severely disrupted or destroyed the infrastructure necessary to support fishing, such as vessels, fuel and ice
suppliers, and fish houses.8
The Deep water Horizon oil spill in 2010 severely affected fisheries in the Gulf. Large parts of the Gulf,
including state and federal waters, were closed to fishing during May through October, 2010. Both Alabama
and Mississippi reported less than half and Louisiana about three quarters of their annual shrimp landings
compared to the average of the previous three years. The impacts of the spill remain under study and the long-
term consequences of the oil spill on fish stocks and the fishing industry have yet to be fully assessed.
6.2	Commercial Fisheries
Information from the NMFS in 2013 shows that commercial fishermen in the Gulf Region landed 1.4 billion
pounds of finfish and shellfish, earning $937 million in landings revenue (NMFS, 2014; NMFS, 2015). In 2014
1.1 billion pounds were landed at a value of over $1.0 billion. From 2003 to 2013, most of the commercial
fisheries revenue and catch (91 percent and 96 percent respectively) was dominated by ten key species or
species groups (Table 6.1).
Commercially important species groups in the Gulf include oceanic pelagic (epipelagic) fishes, reef (hard
bottom) fishes, coastal pelagic species, and estuarine-dependent species. Landings revenue in 2012 was
dominated by shrimp ($392 million) and menhaden ($87 million). These species comprised 63 percent of total
landings revenue, and 90 percent of total landings in the Gulf Region. Other invertebrates such as blue crab,
spiny lobster, and stone crab also contributed significantly to the value of commercial landings. Other finfish
species that contributed substantially to the overall commercial value of the Gulf fisheries included red grouper,
red snapper, andyellowfin tuna. In terms of landing weight, Atlantic menhaden far surpassed other commercial
fish species in the Gulf, accounting for approximately 73 percent of the total weight of landed commercial
species in 2013 (Table 6.2). However, Atlantic menhaden accounted for only about 10 percent of the total
value of the Gulf commercial fishery. The portion of commercial fishery landings that occurred in nearshore
and offshore waters of the Gulf States is presented in Table 6.3
7	Updated information on fishery stock is available at: www.fisheries.noaa.gov/national/population-assessments/fishery-stock-status-updates
8	Current information on US fisheries can be found at: www.nmfs.noaa.gov/sfa/fisheries_eco/status_of_fisheries/
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Table 6.1 - Key Gulf Region Commercial Species or Species Groups
Shellfish
l-~i n I'isli
Crawfish
Groupers
Blue Crab
Menhaden
Oysters
Mullets
Shrimp
Red Snapper
Stone Crab
Tunas
Table 6.2 - Total Weights and Values of Key Commercial Fishery Species in the Gulf Region in 2013 9
Species
Weii-lil
(illOllSilll(Is of Ills)
Ysilue
(TIi
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landed in 2012. Finfish landings experienced a 9.6 percent decrease between 2012 and 2013 while shellfish
landings experienced a 1.6 percent decrease over the same period (Table 6.5).
From 2004 to 2013, species or species groups with large changes in landings include tunas (decreasing 46
percent), groupers (decreasing 39 percent), and oysters (decreasing 23 percent). Species or species groups with
large changes in landings between 2012 and 2013 include crawfish (increasing 66 percent), and red snapper
(increasing 24 percent) (NMFS, 2015).
The Deep Water Horizon event had immediate effects on the Gulf fishing industry between April and
November 2010, with up to 40 percent of Federal waters being closed to commercial fishing in June and July
(CRS 2010). Portions of Louisiana, Alabama, Mississippi, and Florida State waters have also been closed.
These areas are some of the richest fishing grounds in the Gulf for major commercial species such as shrimp,
blue crab, and oysters, and as prices for these items have increased, imports of these species have likely taken
the place of lost Gulf coast production. NOAA continued to reopen areas to fishing once chemical tests
revealed levels of hydrocarbons or dispersants in commercial species were not of concern to human health.
It cannot be determined from these data whether the decreases in fin and shell fish landings were the result of
reduced stock sizes, changes in stock geographic distribution or changes in fishing effort, however studies are
currently on going and it is not known at this time whether there are long term affects to fisheries due to the
spill.
Table 6.4 - 2013 Economic Impacts of the Eastern Gulf Region Seafood Industry (thousands of
dollars)11
Si:iie
Johs
L;indini>s Rcxcniic
Sides
Income
YiiIiic Added
Alabama
Mississippi
Florida
$ 12,090
$ 6,432
$ 78,378
55,434
$ 46,618
$ 148,058
$ 526,767
$ 268,367
$ 15,319,435
200,494
$ 107,340
$ 2,878,309
2o5,580
$ 138,779
$ 5,136,623
Table 6.5 - Total Landings and Landings of Key Species/Species Groups From 2010 to 2013
(thousands of pounds)12
L;iiidini>s
2010
2011
2012
2013
Finfish & other
810,649
1,472,798
987,374
1,092,148
Shellfish
261,419
319,752
305,821
300,216
Total landings
1,072,068
1,792,550
1,293,195
1,392,364
6.3 Recreational Fisheries
The NMFS (2015) estimates that in 2013, over 3.3 million recreational anglers took 25 million fishing trips in
the Gulf Region. The key fish species or species groups making up most of the recreational fishery in the Gulf
are listed in Table 6.6.
11	NMFS, 2015
12	NMFS, 2015
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Table 6.6 - Key Gulf Region Recreational Species 13
Atlanta Croaker	Gulf and Southern Kingfish
Sand and Silver Seatrout	Spotted Seatrout
Sheepshead porgy	Red Drum
Red Snapper	Southern Flounder
Spanish Mackerel	Striped Mullet
Of the three eastern Gulf States, western Florida had the highest number of anglers and fishing trips in 2013
(15.9 million), followed by Alabama (2.8 million), and Mississippi (1.8 million) (Table 6.7). Almost 67 percent
of the fishing trips in the Gulf coast left out of west Florida, followed by Alabama (7 percent), and Mississippi
(5 percent). 41.8 percent of the total recreational fish landings (by weight) in the Gulf occurred in Florida, 12.8
percent 33 in Alabama, and 5.3 percent in Mississippi.
In Mississippi, nearly all landings were made in inland waters (98.6 percent). While the inland catch was
important in Alabama (50.0 percent) and Florida (44.0 percent), the offshore catch was larger in these States,
with 34.1 percent of the total catch landed up to 5 km (3 mi) from shore, and 16 percent at more than 5 km (3
mi) in Alabama and 28.7 percent at less than 16 km (10 mi), and 27.3 percent at more than 16 km (10 mi) in
Florida.
Recreational fishing contributes to the Gulf state economies mainly through employment, expenditures (fishing
trips and durable good), and sales. Table 6.8 shows the economic impacts of recreational fisheries by Gulf
state. Recreational fishing activities generated over 87,000 full- and part-time jobs in Alabama, Mississippi
and West Florida, and over $10.0 billion in sales.
Table 6.7 - Estimated Number of People Participating in Eastern Gulf Marine Recreational Fishing in
2013 (thousands)14
Locution
( o;is(;il
Non-co;is(;il
Ou( of sink'
Tohil
West Florida
1,813
NA
2,538
4,351
Alabama
279
224
549
1,050
Mississippi
171
67
101
339
Gulf Total
2,263
291
3,098
5,740
Table 6.8 - 2013 Economic Impacts of Recreational Fishing Expenditures in the Eastern Gulf
(thousands of dollars)15
Locution
Trips
Johs
S:iles
Income
Ysilue Added
Alabama
$ 2,862
$ 10,163
$ 927,409
$ 358,769
$ 569,144
Mississippi
$ 1,761
$ 1,583
$ 146,333
$ 53,602
$ 87,684
West Florida
$ 15,949
$ 76,236
$ 9,086,311
$ 3,423,836
$ 5,341,420
Total
$ 20,572
$ 87,982
$ 10,160,053
$ 3,836,207
$ 5,998,248
13	NMFS, 2015
14	NMFS, 2015
15	NMFS, 2015
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7.0	Coastal /one Managemcnl Consistency and Special Aquatic Silos
This chapter addresses two of the 10 ODC: (5) The existence of special aquatic sites including, but not limited
to marine sanctuaries and refuges, parks, national and historic monuments, national seashores, wilderness areas
and coral reefs, and (8) Any applicable requirements of an approved Coastal Zone Management plan.
7.1	Coastal Zone Management Consistency
The Coastal Zone Management Act (CZMA) requires that any Federally-licensed or permitted activity
affecting the coastal zone of a state that has an approved coastal zone management program (CZMP) be
reviewed by that state for consistency with the state's program (16 USC § 1456(c)(A) Subpart D). Under the
Act, applicants for Federal licenses and permits must submit a certification that the proposed activity complies
with the state's approved CZMP and will be conducted in a manner consistent with the CZMP. The state then
has the responsibility to either concur with or object to the consistency determination under the procedures set
forth by the Act and their approved plan.
Consistency certifications are required to include the following information (15 CFR § 930.58): "A detailed
description of the proposed activity and its associated facilities, including maps, diagrams, and other technical
data; a brief assessment relating the probable coastal zone effects of the proposal and its associated facilities
to relevant elements of the CZMP; a brief set of findings indicating that the proposed activity, its associated
facilities, and their effects are consistent with relevant provisions of the CZMP; and any other information
required by the state."
The States of Mississippi, Alabama, and Florida have federally approved CZMP. Each Gulf state has specific
requirements in their CZMA plans that outline procedures for determining whether the permitted activity is
consistent with the provision of the program.
Discharges covered by the proposed permit will occur in Federal waters outside the boundaries of the coastal
zones of the State of Florida. However, because these discharges could create the potential for impacts on state
waters, consistency determinations for the individual NPDES permit will be prepared by the proposed project
and submitted to the State of Florida. The following summaries describe the requirements of the state's
management plan for consistency determination. The permit applicant must provide the necessary data and
information for the State to determine that the proposed activities comply with the enforceable policies of the
States' approved program, and that such activities will be conducted in a manner consistent with the program.
7.2	Florida Coastal Management Program
The Florida Coastal Management Program (FCMP) was approved by NOAA in 1981 and is codified at Chapter
380, Part II, F.S. The State of Florida's coastal zone includes the area encompassed by the state's 67 counties
and its territorial seas. The FCMP consists of a network of 24 state statutes administered by eight state agencies
and five water management districts.
The review of federal activities is coordinated with the appropriate state agency. Each agency is given an
opportunity to provide comments on the merits of the proposed action, address concerns, make
recommendations, and state whether the project is consistent with its statutory authorities in the FCMP.
Regional planning councils and local governments also may participate in the federal consistency review
process by advising the Department of Economic Opportunity (DEO) on the local and regional impact of
proposed federal actions. Comments provided by regional planning councils and local governments are
considered by the DEO in determining whether the proposed federal activity is consistent with specific sections
of Chapter 163, Part II, F.S., that are included in the FCMP. If a state agency determines that a proposed
activity is inconsistent, the agency must explain the reason for the objection, identify the statutes the activity
conflicts with and identify any alternatives that would make the project consistent.
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Federal consistency reviews are integrated into other review processes conducted by the state depending on
the type of federal action being proposed. The Florida State Clearinghouse administered by the Florida
Department of Environmental Protection (FDEP) Office of Intergovernmental Programs, is the primary contact
for receipt of consistency evaluations from federal agencies. The Clearinghouse coordinates the state's review
of applications for federal permits other than permits issued under Section 404 of the CWA and Section 10 of
the Rivers and Harbors Act. As the designated lead coastal agency for the state, the FDEP communicates the
agencies' comments and the state's final consistency decision to federal agencies and applicants for all actions
other than permits issued under CWA Section 404 and Section 10 of the Rivers and Harbors Act.
7.3 Special Aquatic Sites
Special aquatic sites are "geographic areas, large or small, possessing special ecological characteristics of
productivity, habitat, wildlife protection, or other important and easily disrupted ecological values. These areas
are generally recognized as significantly influencing or positively contributing to the general overall
environmental health or vitality of the entire ecosystem of a region" (40 CFR § 230.3). Areas of high relief
ridges and outcroppings occur on the west Florida Shelf (Figure 7-1). These include the Madison-Swanson
Marine Reserve, Florida Middle Grounds, Pulley Ridge, Steamboat Lumps Special Management Area, and
Sticky Ground Mounds (BOEM, 2013).
7.3.1	Madison-Swanson/Steamboat Lumps Marine Reserves/The Edges
Madison-Swanson and Steamboat Lumps Marine Reserves are at two ends of a line of ridges beginning north
of Tampa Bay along the 100 m isobath. Madison-Swanson and Steamboat Lumps were protected initially in
2002 and are now established Marine Protected Areas; no-take marine reserves sited on gag spawning
aggregation areas where all fishing is prohibited (219 square nautical miles). With the addition of The Edges,
during seasonal closures, Madison-Swanson and Steamboat Lumps cover 600 square miles.
7.3.2	Florida Middle Grounds HAPC (1984)
These reefs consist of a series of both high and low relief limestone ledges and pinnacles that exceed 15 meters
(49 feet) in some areas. The area consists of roughly 348 nm2 of this hardbottom region 150 kilometers (93
miles) south of the panhandle coast and 160 kilometers (99 miles) northwest of Tampa Bay. It is a Habitat
Area of Particular Concern protected by preventing use of any fishing gear interfacing with bottom.
7.3.3	Pulley Ridge
Pulley Ridge is the deepest known photosynthetic coral reef off the continental United States. The area contains
a near pristine, deep water reefs characteristic of the coral reefs of the Caribbean Sea which are located in the
southern quadrant of Pulley Ridge. These coral reefs occupy an area of about 111 square nautical miles. In 2005,
a section of Pulley Ridge was designated as Habitat Area of Particular Concern (HAPC), which prohibited
bottom anchoring by fishing vessels, bottom trawling, bottom longlines, buoy gear, and all trap/pot use in the
area.
7.3.4	Sticky Ground Mounds
Shelf-margin carbonate mounds in water depths of 116-135 m in the eastern Gulf along the central west
Florida shelf, off Tampa Bay. Various species of sessile attached reef fauna and flora grow on the exposed
hard grounds. Some taller species (e.g., sea whips and other gorgonians) appear to survive this intermittent
sand movement and accretion. Surveys on the southwest Florida Shelf revealed that the biotic cover on the live
bottom patches is generally low and that the patches tend to be dominated by either algae or encrusting
invertebrates (Woodward Clyde Consultants and CSA, 1984).
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Figure 7.1 - High Relief Live Bottom Areas in the Central and Eastern Gulf16
PENSACOLA
Madison-Swanson
Marine Reserve
Florida
Middle /
Grounds
Steamboat Lumps
Marine Reserve
Sticky Ground
Mounds"',
\ \
Eastern
Planning
Area
MS
- -V
. PANAMA CITY
• TALLAHASSEE
Central
Planning
Area
/ Live Bottom (Low Relief) Stipulation Blocks
Live Bottom (Pinnacle Trend) Stipulation Blocks
Proposed Sale Area
Representative Eastern Planning Area
High-Relief Live Bottoms
k
£ FLORIDA
• TAMPA
JT7
,NAPLES
200 Kilometers
200 Miles
16 BOEM, 2015
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8.0	Federal \\ aler Qualify Criteria and Florida \\ aler Qualify Standards
Factor 10 of the 10 factors used to determine no unreasonable degradation requires the assessment of Federal
marine water quality criteria and applicable state water quality standards (WQS).
8.1	Federal Water Quality Criteria
Pursuant to CWA § 303(c), the implementing regulations in 40 CFR § 131 establish the requirements for states
and tribes to review, revise and adopt WQS. The regulations also establish the procedures for EPA to review,
approve, disapprove and promulgate WQS pursuant to the CWA. State WQS apply within the jurisdictional
waters of the state. For marine waters, state WQS apply within three nautical miles of shore. There are no
WQS that apply for marine waters in the Gulf seaward of the three nautical mile boundary.
Section 304 of the CWA requires EPA to develop criteria for ambient water quality that accurately reflect the
latest scientific knowledge on the impacts of pollutants on human health and the environment.17 EPA designs
aquatic life criteria to protect both freshwater and saltwater organisms from short-term and long-term exposure.
Aquatic life criteria are based on how much of a chemical can be present in surface water before it is likely to
harm plant and animal life. EPA's Section 304(a) criteria are not laws or regulations; they are guidance that
states or Tribes may use as a starting point when developing their own WQS.
8.2	Florida Water Quality Standards
The proposed facility will be located approximately 45 miles seaward of Sarasota Bay, Florida, beyond the
jurisdictional waters of the state of Florida. The WQS promulgated by Florida are not applicable to the
proposed project because the project is within federal waters of the Gulf; however, some information about
Florida's WQS is presented below.
WQS for the surface waters of Florida are established by the Department of Environmental Regulation in the
Official Compilation of Rules and Regulations of the State of Florida, Chapter 62-302: Surface Water Quality
Standards (Effective March 27, 2018).18 Minimum criteria apply to all surface waters of the state and require
that all places shall at all times be free from discharges that, alone or in combination with other substances or
in combination with other components of discharges, cause any of the following conditions.
Settleable pollutants to form putrescent deposits or otherwise create a nuisance
Floating debris, scum, oil, or other matter in such amounts as to form nuisances
Color, odor, taste, turbidity, or other conditions in such degree as to create a nuisance
Acute toxicity (defined as greater than 1/3 of the 96-hour LC50)
Concentrations of pollutants that are carcinogenic, mutagenic, or teratogenic to human beings or to
significant, locally occurring wildlife or aquatic species
Serious danger to the public health, safety, or welfare.
These general criteria of surface water apply to all surface waters except within zones of mixing. A mixing
zone is defined as the surface water surrounding the area of discharge "within which an opportunity for the
mixture of wastes with receiving waters has been afforded." Effluent limitations can be set where the analytical
detection limit for pollutants is higher than the limitation based on computation of concentration in the
receiving water.
17	Current federal water quality criteria are found here: www.epa.gov/wqc/national-recommended-water-quality-criteria-aquatic-life-
criteria-table
18	https://floridadep.gov/dear/water-quality-standards
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The antidegradation policy of the standards requires that new and existing sources be subject to the highest
statutory and regulatory requirements under Sections 301(b) and 306 of the CWA. In addition, water quality
and existing uses of the receiving water shall be maintained and violations of WQS shall not be allowed.
As discussed in Section 3, all permitted waste discharges are subject to a NPDES permit. Potential impacts
from fish wastes will be determined by water quality and benthic monitoring to ensure that no unreasonable
degradation of the marine environment will occur in accordance with Section 403 of the CWA.
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9.0
Potential lni|)!K'ls
This section summarizes the potential impacts to receiving waters of the Gulf that might occur as a result of
the discharges from the proposed project. Also discussed in this section is the transport and persistence (Factor
2) and the toxicity and bioaccumulation potential (Factors 1 and 6) of pollutants discharged from the proposed
facility.
9.1	Overview
Net pen aquaculture and its resultant discharges may have effects on water and sediment quality and the plant
and animal communities living in the water column and those in close association with, on or in the sediments.
The major discharges, uneaten fish food and fish metabolic wastes, are likely to have their greatest impacts on
the water column, benthos and related communities.
The two major factors which determine the geographic distribution and severity of impacts of net pens on the
water column, seafloor sediments and benthic communities are farm operations management and siting.
Farm Operations Management
1.	Loading. The biomass of fish reared in the pens is proportional to the amount of organic matter
deposited from the pens. The greater the density of fish, the more concentrated the deposition of
organic waste.
2.	Pen size. Larger pens, with the same loading, deposit sediments over a relatively smaller area (Earll et
al 1984). Thus, the effects are more concentrated, however, the size of the area affected is less.
3.	Pen configuration. Pen configuration and orientation to the predominant currents can significantly
affect the dispersion of wastes.
4.	Feed type. Different feeds have different settling rates. Slower rates allow greater dispersion. In
addition, feed that has lower carbon and nitrogen levels and higher digestibility will produce less
organic matter on the bottom.
5.	Feeding method. Feeding methods can affect both wastage of feed and utilization of that feed by the
fish. In one study, hand feeding resulted in 3.6 percent wastage, and up to 27.0 grams per meter squared
per day (g/m2/day) organic matter deposition on the bottom. The use of automatic feeders resulted in
wastage of 8.8 percent and a maximum deposition of 88.1 g/m2/day (Cross, 1988).
Siting
1.	Water depth and current velocity. In deeper water and faster currents, the dispersion of wastes will be
greater.
2.	Bottom current velocity. High bottom current velocities can erode and disperse resuspended sediments
regardless of dispersion in the total water column.
3.	Bottom sediments and community. The benthic community will also affect the impact. Areas of high
biological productivity may be able to assimilate higher organic deposition. However, adverse impacts
may have greater significance due to the importance of such productive areas. Conversely, areas having
few organisms may have less assimilative capacity, but creation of an azoic zone may have less effect
on the biological community
9.2	Water Column Impacts
The water quality around coastal fish farms is affected by the release of dissolved and particulate inorganic
and organic nutrients. Water column effects around fish farms include a decrease in dissolved oxygen and
increases in biological oxygen demand, and nutrients (P, total C and organic and inorganic N) (Penczak et al.,
1982). Degradation of water quality parameters is greatest within the fish culture structures and improves
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rapidly with distance from holding pens. Recent studies have documented only limited water column impacts
due to rapid dispersal (Holmer, 2010). The health of the fish stocks is a self-limiting control on water column
pollution. Another review found that though the probability of any measurable impact from an offshore farm
appears to significantly decrease with distance from the farm, such information suffers from a general lack of
robustness and should be quantified with better systematic and standardized reporting with respect to physical
farm characteristics (Froehlich et. al., 2017).
9.2.1	Turbidity
Turbidity, an indication of water clarity, may be affected by fish farming operations. The loss of fish food and
feces is the largest source of increase in turbidity around net pens. Net cleaning can also significantly increase
turbidity down current of net pens. Turbidity will likely be most affected by cage siting with current velocities
and tidal influence the major factors. A study in the Puget Sound reported that floating net pens did not affect
turbidity (NMFS 1983). Turbidity ranged from 0.5 to 2.0 NTU throughout the study, but measurements were
not taken during net cleaning. In other studies, suspended solid concentrations and light attenuation (due to
turbidity) were found to be insignificant or localized.
9.2.2	pH
The effects of fish farming on water column pH was studied by Pease (1977) who reported that a net-pen
facility in a poorly flushed, log rafting area (Henderson Inlet, Washington) did not affect pH. Pease also
reported that tidal factors were the primary factor regulating pH at all sites.
9.2.3	Temperature
The operation of floating net pens would not affect water temperatures in the Gulf. Net pens have no features
that would measurably change heat loss or heat gain in surrounding waters.
9.2.4	Fecal Coliforms
Fecal coliform bacteria are produced in the digestive tracts of warm-blooded animals. Net pens do not directly
affect ambient (existing) fecal coliform concentrations in surrounding waters because fecal coliforms are not
produced in fish. However, fecal coliform levels could indirectly increase near net pens from increased marine
bird and mammal activity or human activity.
9.2.5	Nutrients
Nutrient addition to the Gulf is of concern because they contribute to harmful algal blooms (HABs). HABs are
on the rise in frequency, duration, and intensity in the Gulf, largely because of human activities (Corcoran,
et.al., 2013). Of the more than 70 HAB species occurring in the Gulf, the best-known is the red tide organism,
Karenia brevis, which blooms frequently along the west coast of Florida. Macronutrients, micronutrients and
vitamins characteristic of fish farms are growth-promoting factors for phytoplankton. The primary nutrients of
interest in relation to net pens are nitrogen and phosphorus; both may cause excess growth of phytoplankton
and lead to both aesthetic and water quality problems. Generally, in marine waters, phytoplankton growth is
either light or nitrogen limited, and phosphorus is not as critical a nutrient as it is in fresh water (Ryther and
Dunstan, 1971; Welch, 1980). However, it has been shown that because nutrient fluctuations in the Gulf can
be significant due to the large inputs from river systems, both nitrogen limitation and phosphorus limitation
can happen in different locations, but during the same time frame (Turner and Rabalais, 2013)
Nitrogen may be categorized as: (1) inorganic (nitrate, nitrite and ammonia and nitrogen gas); and (2) organic
(urea and cellular tissue). Most of the organic matter in waste food and feces from net pens is composed of
organic carbon and nitrogen (Liao and Mayo, 1974; Clark et al., 1985). About 22 percent of the consumed
nitrogen is retained within the fish tissue and the remainder (78 percent) is lost as excretory and fecal matter
(Gowen and Bradbury 1987). In a summary of nitrogen budgets in marine cage aquaculture, Islam (2005),
reported that 68-86 percent of the nitrogen input as feed is eventually released to the environment. In a recent
study, it was determined that about 63 percent of nitrogen fed at a rainbow trout Oncorhynchus mykiss farm
was lost as dissolved nitrogen (Nor5i et al., 2011).
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Approximately 87 percent of the metabolic waste nitrogen is in the dissolved form of ammonia and urea; the
remainder (13 percent) is lost with the feces (Hochachaka, 1969). Salmon will produce approximately 0.22 to
0.28 grams of all forms of dissolved nitrogen per day per kilogram of fish produced annually (Ackefors and
Sodergren, 1985; Penczak et al., 1982; Warren-Hansen, 1982). Ammonia and urea are essentially
interchangeable as phytoplankton nutrients. Immediately downstream of most net pens (6-30 m) the
concentration of ammonia diminishes greatly. This decrease is probably due to the natural microbial process
of nitrification (oxidation of ammonia to nitrites and nitrates). Rapid rates of nitrification are expected in any
well-oxygenated aquatic environment (Harris 1986). The effects of these factors on phytoplankton near fish
farms are variable and no good scientific evidence is available to suggest that macronutrients and
micronutrients from fish farming is related to the occurrence of red tides.
9.2.6	Ammonia Toxicity
Toxic chemicals would not be introduced into the net pens from fish stock or food. Ammonia in the un-ionized
form (NH3) is toxic to fish at high concentrations depending on water temperature and pH (EPA, 1986). High
ammonia levels in fish excrement have been shown to raise ambient (existing) ammonia concentrations.
Normal concentrations of ionized and un-ionized ammonia in Gulf waters are very low, with some variability.
A small percentage of the ammonia originating from net pens typically about 2 percent, will be of the toxic,
un-ionized form.
Near-field studies in Washington state (Milner-Rensel, 1986; Rensel, 1988 b,c) have shown increased
concentrations of ammonia immediately downstream or within the net pens. Total ammonia values typically
have increased from 3 to 55 percent above the low background levels. The highest observed concentrations
were only a small fraction of the maximum four-day, chronic exposure level recommended by EPA (1986). A
long-term study, under worst-case conditions in southern Puget Sound, found that the greatest concentration
of total ammonia observed at any time was 0.176 mg/1, equivalent to 0.006 mg/1 un-ionized ammonia, well
below chronic exposure threshold (Pease, 1977).
In summary, increases in dissolved nitrogen (including ammonia) are typically seen within salmon net pens.
Immediately downstream, nitrogen or ammonia levels may also be elevated compared to ambient, upstream
values. However, results are variable (Price and Morris, 2013). In some cases, concentrations were greater or
much less than expected compared to predicted values based on freshwater hatchery data. However, even
within the net pens, toxic concentrations of un-ionized ammonia were not approached. Net pen fish culture in
open Gulf waters will be characterized by relatively large volumes of water passing through cages per unit of
fish production. This results in much greater dilution of waste products such as ammonia in net pens when
compared to freshwater hatcheries or municipal sewage discharges (Weston, 1986).
9.2.7	Phosphorus
Although nitrogen is generally considered to be the limiting macro-nutrient in many ocean waters, increasing
phosphorus levels in coastal waters due to anthropogenic sources is also of concern because some marine
systems can be phosphorus limited. Increased phosphorus may, along with nitrogen, contribute to algal blooms
and coastal eutrophication. Like nitrogen, the principal sources of phosphorus from fish farms are uneaten
food, fecal matter and metabolic wastes. A review of phosphorus budgets of marine cage aquaculture reported
that an average of 71.4 percent of the phosphorus in feed was released into the environment, the amounts
depending on species cultured, feed type, and feeding efficiency (Islam, 2005). Though fewer studies looked
at phosphorus impacts, of those that did, a number showed measurable increases in dissolved phosphorus
around net pens, several showed statistically significant increases (Price and Morris, 2013).
9.2.7 Dissolved Oxygen
Dissolved oxygen consumption by fish, and by microbial decomposition of fish wastes and excess food, could
significantly reduce water column dissolved oxygen concentrations near the pens. Most of the microbial
decomposition is associated with solids that settle to the bottom (Institute of Aquaculture, 1988). Thus, the
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greatest potential for oxygen consumption would be from fish respiration near the surface and microbial
decomposition near the bottom.
The total effect of oxygen consumption from net-pen operations on dissolved oxygen concentrations near the
pens is highly variable. The loss of dissolved oxygen depends on the water exchange rate near pens, fish
density, and fish feeding rate. If the water exchange rate near the pens is high, there will be less reduction of
dissolved oxygen. If the fish density and fish feeding rate are high, there will be increased dissolved oxygen.
In general, the dissolved oxygen requirements of fish raised in net pens limit the impact net pens can have on
the environment. The lowest oxygen levels caused by net pens are likely to occur within the net pens and
immediately down current. Thus, the impact of low dissolved oxygen is likely to affect the net-pen operation
before having an effect on the surrounding environment.
9.3 Organic Enrichment Impacts to Seafloor Sediments
Numerous studies have shown that organic enrichment of the seabed is the most widely encountered
environmental effect of culturing fish in cages (Karakassis et al., 2000, Karakassis et al., 2002, Price and
Morris, 2013). The spatial patterns of organic enrichment from fish farms varies with physical conditions at
the sites and farm specifics and has been detected at distances from meters to several hundred meters from the
perimeter of the cage array (Mangion et al., 2014). Studies of fish farms in the Mediterranean showed that the
severe effects of organic inputs from fish farming on benthic macrofauna are limited to up to 25 m from the
edge of the cages (Lampadariou et al., 2005) although the influence of carbon and nitrogen from farm effluents
in sea floor can be detected in a wide area about 1,000 m from the cages (Sara et al., 2004). The impacts on
the seabed beneath the cages were found to range from very significant to relatively negligible depending on
sediment type and the local water currents, with silty sediments having a higher potential for degradation.
Sedimentation rates are often 1-3 orders of magnitude higher at fish farms compared to unaffected areas of the
coast (Brown et al., 1987; Hall et al., 1990). Weston and Gowen (1988) found the greatest sediment deposition
occurred in the direction of the dominant current. Sediment traps under the pens estimated deposition of 52.1
kilograms dry weight per meter squared per year (kg dry wt./m2/yr) and 29.7 kg dry wt./m2/yr at the pen
perimeter.
Sedimentation effects from net pens are the result of two major factors, additional particulate organic input
and inorganic sediment deposition. An additional factor contributing to sedimentation is organic matter that
grows on nets and is dislodged from the net during cleaning. This source contributes relatively little to the total
sedimentation generated by a net-pen operation (Weston, 1986). The organic input from these sources affects
both the chemical composition of the sediments and the responses of the organisms in the sediment (Pearson
and Rosenberg, 1978). A review of more recent studies pertaining to nutrient and organic carbon loading to
sediments from fish farms around the world can be found in Price and Morris (2013).
One of the main impacts of organic enrichment to seafloor sediments is the stimulation of sediment
metabolism, i.e., increased microbial activity, sediment oxygen demand and nutrient release (Holmer, 1991).
High organic loading to the sea floor may result in the development of anoxic and reducing conditions and the
production of toxic gases, i.e., ammonia, methane and hydrogen sulfide (H2S).
In undisturbed sediments, oxygen is only able to penetrate a short distance depending upon sediment porosity,
bioturbation (activity of burrowing organisms), and current velocity, which controls the rate at which oxygen
is renewed at the sediment surface. Oxygenated sediments are typically light tan to light grey in color. Below
this oxic layer, sediments are oxygen depleted (anoxic). Anoxic sediments are characterized by their dark black
color, and the production of hydrogen sulfide gas. With increasing organic loading, the demand for oxygen for
microbial processes and reoxidation of reduced mineralization products increases.
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Sediment oxygen demand (SOD) near fish farms can exceed the diffusive oxygen influx and the anoxic layer
moves closer to the surface (Brown et al., 1987). Studies have shown that sediment oxygen demand of
sediments enriched by fish-farming activities can be 2-5 times higher than in control areas (Hargrave, et al.,
1993). In these cases, the organic material often forms a layer over the original sediments. In stagnant areas of
poor circulation, oxygen demand by the anoxic sediments will reduce the dissolved oxygen in the overlying
water. Anaerobic metabolism of sediments becomes important in organic matter decomposition near farms
(Hall et al., 1990). Studies show that soleplate reduction is the terminal process for organic oxidation.
Anaerobic decomposition of the organic matter under these conditions may also lead to production of methane
in sufficient quantities to produce visible bubbles at the surface. At this point hydrogen sulfide will reach
concentrations that allow its distinctive "rotten egg" smell to be detected in the water. H2S is highly toxic,
making these sediments toxic, and at higher concentrations can lead to mortality of fish in pens.
The oxidation-reduction (redox) potential (positive = oxic; negative = anoxic) gives a relative indication of the
degree of enrichment. Negative oxidation-reduction (redox) values, indicating a strong possibility of anaerobic
conditions and the production ofthS, are common in sediments near and beneath net pens (Brown et al., 1987).
As organic matter continues to accumulate oxygen penetration into sediments are decreased and redox
potential values become more negative. Mats of white supplied oxidizing bacteria Beggiatoa spp. covering the
seafloor beneath salmonid cages have been observed (Hall et al. 1990).
It is estimated that only about 10 percent of the organic matter deposited from net pens each year is broken
down through microbial decomposition (Aure and Stigebrandt, 1990), and decomposition has been shown to
be inversely related to accumulation. Of the total carbon, nitrogen and phosphorous deposited to sediments,
around 79 percent, 88 percent and 95 percent respectively will accumulate and become unavailable to the
environment. Release of phosphorous to the environment is insignificant when deposits are greater than 7 cm.
Nitrogen mineralization is very slow in normally anaerobic sediments beneath net pens where bioturbation and
epifaunal reworking of sediments is minimized. In some studies, it was shown that nitrogen cycling,
nitrification (converting ammonium to nitrate) and denitrification (converting nitrate to N2 gas) ceased. Most
of the nitrogen is released to the water as ammonium and dissolved organic nitrogen.
A review of 41 papers (Kalantzi and Karakassis, 2006) covering a wide range of cultured species, habitats, site
characteristics and farm management practices concluded that their analysis suggests that the impact radius at
fish farms generally decreases with increased depth, at low latitudes and over fine sediment. The authors,
however, state that applying common standards over large geographic areas is challenging due to the complex
interplay of site characteristics among the studies they reviewed. A 2012 study of a farm in Norway in 190
meters of water showed that despite deep water and low water currents, sediments underneath the farm were
heavily enriched with organic matter, resulting in stimulated biogeochemical cycling concluding that water
depth alone may not be sufficient (Valdemarsen, et.al., 2012). In another review of 64 studies of benthic fish
farm impacts, Giles (2008) developed a quantitative assessment of the relationships between impact parameters
and site and farm characteristics. The analysis showed that benthic impact was a function of fish density, farm
volume, food conversion ratio, water depth, current strength and sediment mud content. The analysis also
suggested that fish farm impacts were confined to a radius of about 40 to 70 m around the farms, however, the
inability to satisfactorily model parameters as a function of distance from farms demonstrated the complexity
of the spatial distribution of the farms studied.
9.4 Organic Enrichment Impacts to Benthic Communities
The deposition of uneaten fish feed and feces may affect benthic communities in several ways. The
accumulation of organic and inorganic particulates may impact benthic flora and fauna. Significant changes in
the proportion of the fine sediment fractions can alter the micro structure of the habitat supporting
macroinfauna and meiofauna communities resulting in changes in both structure and function. High
sedimentation rates may interfere with feeding mechanisms of deposit and filter feeders. Benthic epifauna and
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flora may be buried at very high rates of sedimentation. Sedimentation rates are often 1-3 orders of magnitude
higher at fish farms compared to unaffected areas (Brown et al., 1987; Hall et al., 1990; Holmer, 1991).
Sedimentation from net pens decreases sediment oxygen levels by increasing the demand for oxygen, and by
decreasing both diffusion and water flow into the interstitial spaces of the sediment. As increasing amounts of
fine sediment accumulate, the depth to which oxygen penetrates is reduced and the underlying sediment layers
become devoid of oxygen (anoxic) and unable to support animal life. The only organisms found in such
sediments will be those that have access to the surface waters for respiration via burrows or siphons, and
anaerobic bacteria, which derive energy from sources other than oxygen.
Depending on the rates of organic loading, community structure near net pens may become dominated by
pollution tolerant species or fauna may disappear entirely. Impact studies show variable results with some
showing a clear correlation between the deposition of fish wastes and community changes (Brown et al., 1987).
Pearson and Rosenberg (1978) present a comprehensive review of the impacts of organic enrichment from a
variety of natural and man-made sources on bottom sediments and the associated benthic community. The
authors show that benthic communities tend to respond along a gradient of organic loading with effects most
pronounced near the source and decrease progressively with increasing distance.
In undisturbed sediments a stable, diverse benthic community exists comprised of relatively large epibenthic
(surface dwelling) organisms, smaller burrowing organisms (< 0.5 mm) comprising the macroinfauna and the
meiofauna, smaller (< 0.064 mm) that occupy the interstitial spaces between sediment particles. As organic
matter is introduced into an undisturbed environment, it provides an additional source of nutrition for the
benthic organisms. This additional organic matter benefits the existing filter- and deposit- feeders, and
encourages colonization by additional species. Thus, both species diversity and biomass (total weight) of the
benthic organisms increases, and the benthic community is enhanced. The authors refer to this as the
"transition zone."
Earll et al. (1984) observed benthic conditions below 25 net-pen facilities in Scotland. He noted that the redox
potentials were reduced to a distance of 20 to 30 m from the pens and that Beggiatoa first appeared 10 to 15 m
from the pen perimeter. Outside this zone, the sediment surface appeared normal and was light brown in color
with a thin covering of diatoms. Predator species such as crab, flatfish, nudibranchs, and anenomes were
abundant. Scallops, starfish, and sea cucumbers were also observed. Stewart (1984) noted that organic loading,
carbon:nitrogen ratios, and redox potentials were essentially normal beyond 40 m of a pen site. He concluded
that the transition zone extended 37 to 100 m from the pens.
High species abundance and diversity, representing both pre-existing species and newly colonized species,
were found in a zone 15 to 120 m from pens by Brown et al. (1987). Gowen et al. (1988) observed that total
organic carbon, redox potentials and dissolved oxygen levels were normal beyond 15 m of the pens, and that
opportunistic species dominated the zone between 15 and 120 m, with the inner boundary of the transition
zone being 20 to 25 m from the pen boundary.
In studies conducted by Weston and Gowen (1988) it was estimated that normal benthic communities extended
to within 150 to 450 m of the pens. Mobile predators are also abundant in this area, including flat fish (Pease
1984) and crab (Earll et. al., 1984; Cross, 1988). Weston and Gowen (1988) concluded that changes in the
biological community extended beyond the zone where chemical changes were detectable. Weston (1990)
studied benthic infauna response to organic enrichment at a large Puget sound fish farm. Species richness,
biomass and size of organisms decreased near the cages. Total abundance of individuals increased when
nematodes (pollution tolerant species) were included. Suspension and deposit feeders found at 450 m either
disappeared or were greatly reduced near cages.
Pearson and Rosenberg (1978) observed that as the level of organic input continues to increase, the sediments
become progressively dominated by various opportunistic deposit feeders which are able to flourish under
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these conditions. The most notable deposit feeder is the small, common polychaeta worm Capitella capitata,
indicative of organic enrichment. Under these conditions, the abundance of these opportunistic species can
reach very high densities, to the exclusion of other species. Elimination of the larger, deeper borrowing animals
further reduces the ability of oxygen to penetrate the sediments.
Gowen et al. (1988), and Brown et al. (1987) observed that the area between 3 and 15m was almost exclusively
dominated by opportunistic polychaete worms, especially Capitella capitata. The total number of species in
this zone was about 20 percent of that in undisturbed sediments. The number of individuals, however, was 2
to 3 times normal with total biomass slightly below normal. All of the organisms were polychaete worms, with
Capitella capitata representing 80 percent of the total organisms. Weston and Gowen (1988) observed
increased concentrations of carbon, nitrogen, and reduced redox potentials between 15 and 60 m down current
(east) from net pens in the Puget Sound. The abundance of organisms was approximately 4 times greater than
background at the pen perimeter and declined to background levels at about 45 m, with Capitella capitata the
dominant species. Biomass was reduced to about 45 m and increased moderately between 90 and 150 m.
Normal conditions were reached between 150 and 450 m from the pens. Pease (1984) reported that geoduck
(bivalve mollusk) abundance increased in this area away from the pens. No geoducks were found in the area
occupied by Bogota. However, in a more recently developed site in British Columbia, geoducks were observed
in within the more distant area occupied by Beggiotoa (Cross 1988).
At very high rates of organic sedimentation, few species can survive. At this point, the anoxic layer reaches
the sediment surface, depriving the animals of oxygen and exposing them to toxic H2S. In these sediments,
the surface is black and devoid of any animals (azoic). Gowen et al. (1988) estimated that input of organic
matter at rates greater than about 8 g carbon/m /day resulted in production of methane and azoic conditions.
At low concentrations, H2S can reduce fish health through gill damage and at higher concentrations be toxic
to fish in the pens above the sediments. Such affects have only been reported in stagnant areas with little water
circulation.
Azoic zones have been reported under most net pens, though their presence depends on the size (amounts of
wastes produced) of the fish farm (Weston and Gowen 1988) and water circulation beneath and around cages
(Weston 1986; Institute of Aquaculture 1988). The absence of Beggiotoa under the pens observed by Earll et
al. (1984) was attributed to its need for both oxygen from surface water and H2S from the anoxic sediments.
No live animals were observed in this zone; however, occasional dead starfish, nudibranchs and sea cucumbers
were observed on the surface. Gas bubbles (methane) were evident in the sediment and redox potentials were
severely depressed. Stewart (1984) observed these conditions to extend to about 3 m from the pen perimeter,
observed a zone of dark, black sediments under most net pens observed. Similar observations are reported by
Gowen et al., (1988) extending 3 m from the pens. In this zone, total organic carbon levels are about twice
background levels and redox potentials were consistently less than -100 mV, despite seasonal variations.
Dissolved oxygen in the overlying water was reduced and gas bubbles were observed. Hall and Holy (1986)
measured chemical changes below a small net pen complex. Both total organic carbon and nitrogen
concentrations were increased ten-fold above background levels, and benthic oxygen consumption was
increased 12 to 15 times. Deposition under these pens was 50 to 200 g/m2/day total solids, about 20 times
higher than background.
The effects of organic enrichment of the sediments begins quickly after installation and operation of the net
pens. Weston and Gowen (1988) observed only limited changes in the community at the Squaxin Island site
after 18 months of operation. Ritz et al. (1989) saw a decline in macroinfauna signifying moderately disturbed
conditions (biomass>abundance) beneath salmonid cages in Tasmania within seven weeks of fish stocking.
Infauna community conditions (biomass
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Recovery of affected benthic communities may take a period of months or years, however, the benthic sediment
chemistry appears to recover to normal levels relatively rapidly. In Puget Sound, Pamatmat et al. (1973)
observed normal benthic oxygen consumption 2 months after pen removal. Dixon (1986) noted that bottom
sediments appeared normal at two pen sites in the Shetland Island, 12 months after removal of the pens.
Biological recovery may take much longer depending on the successional colonization of the area by different
species and normal recruitment cycles (Pearson and Rosenberg, 1978). Species abundance will recover more
quickly than biomass due to the growth rates of the larger animals. Rosenberg (1976) observed that the
recovery of the area surrounding a pulp mill discharged required 3 to 8 years to recover.
An extensive review of more recent studies (since 2000) of fish farming impacts to benthic communities can
be found in Price and Morris (2013).
9.5 Antibiotics
Three antibiotics are currently registered by the U.S. Food and Drug Administration (FDA) for use in treating
fishes farmed for human consumption. Austin (1985) discussed the effects of antimicrobial compounds that
are used in fish farming and that may escape into the environment. He noted that data are not available on the
quantities of antimicrobial compounds entering the environment from fish farming. However, his research
provides estimates of probable concentrations of antibiotics leaving freshwater fish farms. The estimated
dilution of Oxytetracycline (OTC), based on maximum allowable levels of administration, was 1 part in
50,000,000. This dilution was regarded as a worst-case estimate, based on no retention of the administered
drug in the fish. Thus, Austin (1985) concludes that the concentrations of drugs reaching the environment are
very small.
Austin (1985) noted that use of antibiotics in fish farms could lead to an increase in antibiotic resistance among
bacteria in the farm effluent. Other authors have reported the phenomenon of antibiotic resistance of bacteria
near fish farms in which the medications are applied (Aoki, 1975, 1988; Aoki et al., 1971, 1972b, 1974, 1977,
1980, 1984, 1985, 1986a, 1987a; Aoki and Takahashi, 1986; Takashima, et al 1985; Bullock et al., 1974;
Toranzo et al., 1983). Bacteria can gain antibiotic resistance through the selection of bacteria which contain
resistance factors, or plasmids, some of which may be transferable from one fish pathogenic bacterium to
another under certain conditions (Akashi and Aoki, 1986b; Aoki and Kitao, 1985; Aoki and Takahashi, 1987;
Aoki et al., 1972a, 1986b, 1987b, 1981; Mitoma et al., 1984; Toranzo et al., 1984). It is also known that the
plasmids, or resistance factors, can confer resistance to more than one antibiotic when transferred from one
bacterium to another (Aoki et al., 1987a). The presence of plasmids has been documented in both fish
pathogenic bacteria (see above citations) and in native aquatic bacteria (Burton et al., 1982).
An FDA study to evaluate the use of OTC for aquatic applications analyzed the environmental impact of the
antibiotic on disease control in lobsters held in impoundments Katz (1984). Based on seawater dilution and
lack of long-term selective pressure favoring the persistence of OTC resistant organisms, Katz (1984)
concluded that "there should be no build-up of antibiotic resistant population of microorganisms from the use
of OTC in treating gaffkemia in lobsters." In the same report, Katz concluded that "the potential of R-factor
(resistance-factor) transfer between organisms should be minimal", due to dilution, low levels of nutrients, low
temperatures, and high salinity of seawater.
The technical literature cited above indicates the several factors. They are occurrence of antibiotic resistant
bacteria in association with aquaculture depends on the diversity, frequency, and dosage of antibiotic
administration, and environmental conditions of culture including temperature, dilution of the antibiotics, and
the containment of the fish and associated bacteria.
The reports of antibiotic resistance from Japan are from very intensive aquaculture sites characterized by warm
temperatures, high densities of fish grown in confined ponds, and the use of a variety of antibiotics not
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registered for use in the United States. As well, the dosage and duration of antibiotic treatment in Japan appears
to exceed both legal and general practices in the United States. Thus, while these studies document antibiotic
resistance in fish pathogenic bacteria due to the administration of antibiotics, they should not be interpreted to
indicate that similar antibiotic resistance will occur under very different environmental conditions and fish
husbandry practices. Importantly, studies (Austin, 1985; Aoki et al., 1984) have noted that the increased level
of antibiotic resistance associated with antibiotic use around fish farms was soon reduced after antibiotic use
stopped. This phenomenon has been observed in human medicine (Forfar et al., 1966) where dramatic declines
in resistance levels of bacteria occur after antibiotic treatments are stopped.
The possibility of transfer of drug-resistance factors from a fish disease-causing bacteria to a potential human
disease-causing bacteria, V. parahaemolyticus, was investigated in Japan (Hayashi et al., 1982). Using test
tube conditions and temperatures of about 86°F to 96°F, these authors were able to transfer drug resistance to
V. parahaemolyticus. These authors also noted that in Japan, where antibiotics have been extensively used in
aquaculture, drug-resistant strains of the V parahaemolyticus have never been found in the environment.
Toranzo et al (1984) reported the transfer of drug resistance from several bacteria isolated from rainbow trout
to the bacterium, Escherichia coli. The transfer to resistance was performed under laboratory conditions at 25°
C (77° F). The studies demonstrated the potential for transfer under controlled laboratory conditions and these
authors concluded that "Responsible use of drugs in aquaculture will aid in minimizing the development and
spread of R+ factor-carrying microorganisms that may confer drug resistance...".
The accumulation of antibiotic residues in shellfish near fish farms has received little study. In the Puget Sound
area (Tibbs et al., 1988) found that mussels, oysters, and clams suspended within a matrix of net pens in which
coho salmon were being given food supplemented with OTC had no detectable levels of the antibiotic in their
tissues. That study examined the phenomenon of antibiotic accumulation in shellfish under worst-case
conditions with regard to the distance between the fish pen and shellfish (the shellfish were placed within the
matrix of fish pens). Weston (1986) noted the large dilution factor that would occur when antibiotics are used
in a net pen. He made conservative calculations and computed a diluted level of 3 parts per billion of OTC in
a parcel of water passed through a fish pen receiving medicated feed. Given this dilution factor and the water-
soluble nature of antibiotics like OTC, Weston (1986) concluded that there was little potential for
bioaccumulation of antibiotics used in fish farming.
Jacobsen and Bergline (1988) reported the persistence of OTC in sediments from fish farms in Norway. These
authors also conducted laboratory tests and concluded that the half-life (time required for a given concentration
to decay to 50 percent of the starting concentration) for OTC in marine sediments was about ten weeks, but
would likely depend on sediment type and other factors. They examined sediments from underneath four farms,
but did not report the duration or quantities of OTC applied at each location. OTC was found in sediments
from three of the four farms at levels from 0.1 to 4.0 mg/kg (ppm) of dry matter. This level would potentially
be high enough to be inhibitory to marine bacteria (1-2 ppm is considered inhibitory) including vibrios.
However, since the concentration is reported relative to dry weight, it overestimates the actual concentration
in hydrated sediment. The study does demonstrate that measurable OTC can accumulate below fish farms.
Conservatively, the study can be interpreted to show the highest concentrations were just above inhibitory
levels on a dry-weight basis. The authors also noted that the oxidation state of the sediments would affect the
half-life of OTC. An Environmental Assessment of OTC by the FDA (USFDA, 1983) concluded that "the use
of OTC is beneficial to control diseases in aquatic environment and does not pose adverse effects on this
compartment. However, steps should be developed to avoid the emergence of drug-resistant organisms."
Accumulation of antibiotics in marine sediments is also a function of the dilution factor (which determines the
level of antibiotic reaching the sediment), biotransformation of the compound in the sediment, oxidation state
of the sediment, and water solubility of the antibiotic. Levels of OTC such as those calculated by Weston
(1986) to reach sediments are not likely to have inhibitory effects on non-pathogenic bacteria, which are little
affected at levels below 1 ppm (Carlucci and Pramer, 1960). In their study of the microbial quality of water in
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intensive fish rearing, Austin and Allen-Austin (1985) note that while it is difficult to make generalizations,
their study indicated that two freshwater fisheries they monitored did not produce "a major imbalance in the
aquatic bacterial communities."
Although some technical details require further study, the issues surrounding antibiotic use in fish farming
have received some detailed study. Studies demonstrate that antibiotics will be released into the environment
when used as a medication for farmed fish. Antibiotics have not been detected in shellfish held near salmon
net pens. One Norwegian study found concentrations of one antibiotic may have been close to inhibitory levels
in three of four farms. The concentrations of antibiotics outside of the immediate proximity of the fish pens
are regarded by most authors as being too low to have adverse effects.
The presence of plasmids, a mechanism by which bacteria transfer resistance, is documented in pathogenic
and native aquatic bacteria. Antibiotic resistance has been recorded in bacteria around fish farms. Most of the
technical literature describing antibiotic resistance in fish pathogenic bacteria is based on studies of aquaculture
practices and environmental conditions not comparable with salmon net-pen farming in the Puget Sound
region. These conditions include high temperatures, high densities of fish, close proximity of multiple farms,
and use of a variety of antibiotics not used in fish farming in the United States. Conditions in the studies
reporting antibiotic resistance favor the development of resistance. In comparison, salmon net-pen farming in
the Puget Sound region would not favor the development of antibiotic resistance. In addition, the federal
regulations that apply to the use of antibiotics in fish farming in the United States appear to be much more
stringent than those that apply in Japan and Europe, where most of the technical literature has originated.
Antibiotic resistance tends to disappear when antibiotic administration is stopped. Shellfish held within a net-
pen complex did not accumulate detectable levels of OTC. This observation and the calculated dilution of
antibiotics away from the fish pens further suggest that any quantities of antibiotics accumulated in shellfish,
or other benthic or planktonic marine invertebrates not near the pens would be substantially below levels of
concern.
The lack of antibiotic resistance in a potential human disease-causing bacteria such as V. parahaemolyticus in
Japan, despite the extensive use of antibiotics in aquaculture there, indicates the transfer of drug resistance
from fish to human pathogenic bacteria is unlikely. It appears such transfer is a laboratory phenomenon, which
requires highly controlled conditions and is not representative of phenomena that occur in the environment.
The Toranzo et al (1984) study further demonstrates the potential for drug resistance transfer under controlled
conditions (77°F).
The applicant has indicated that FDA-approved antibiotics or other therapeutants will not likely be used (within
any feed or dosing the rearing water) during the proposed project.19 The need for drugs is minimized by the
strong currents expected at the proposed action area, the low fish culture density, the cage material being used,
and the constant movement of the cage. In the event that drugs are used, the NPDES permit requires that the
use of any medicinal products including therapeutics, antibiotics, drugs, and other treatments are to be reported
to the EPA. The report must include types and amounts of medicinal product used and the period of time it
was used.
9.6 Waste Deposition Analysis
The proposed project generates and discharges various amounts of solid and dissolved wastes depending on
the fish biomass contained and amount of feed added daily. Solid waste consists primarily of unconsumed feed
and fecal material. Other minor sources of solid wastes include dead fish, fish parts (i.e. scales, mucous, etc.)
and material dislodged during net cleaning operations. Dissolved wastes include fish metabolic wastes, plus
19 The applicant is not expected to use any drugs; however, in the unlikely circumstance that therapeutant treatment is needed, three drugs
were provided to the EPA as potential candidates (hydrogen peroxide, oxytetracycline dihydrate, and florfenicol).
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therapeutic agents (e.g. antibiotics), if used, antifoulants, if applicable. The focus of this analysis is the
discharge of the primary solid wastes, feed and fecal material and dissolved metabolic wastes.
This facility as proposed consists of a single 17 m diameter surface floating cage estimated to hold
approximately 75,000 lbs of fish at harvest. It is estimated that feeding rates would approximately 745 lbs per
day at the maximum expected fish biomass. Factors influencing the transport and fate of materials discharged
from net-pen facilities include oceanographic characteristics of the receiving water, physical characteristics of
the net-pen, water depth below the net-pen, configuration and orientation of the net-pen system in relation to
predominant currents, type of food used, fish feeding rates and stock size. Oceanographic considerations
include tides, wind, stratification, and current velocities and direction.
The NCCOS conducted environmental modelling analysis of the proposed project to determine the fate and
effects of solid wastes discharged from the net-pen at maximum production rates (Riley et. al., 2018). The
report can be seen in Appendix A.
Numerical models were constructed based upon anticipated farming parameters including configuration (net
pen volume and mooring configuration), fish production (species, biomass, size) and feed input (feed rate,
formulation, protein content). It should be noted that several of the base production parameters have decreased
since the model was constructed. Additionally, the model did not take into account any reduction in maximum
fish biomass due to estimated mortality. Two model scenarios were constructed, the first based on the actual
estimated production of a single cohort to harvest. The second scenario examined the solids discharge based
on a doubling of the estimated actual production to provide a "worst case" for potential impacts.
9.6.1	Solid Waste Discharge
A solids deposition model DEPOMOD (see NCCOS technical report, Appendix A), was applied to data from
the production model and environmental and oceanographic data on the proposed offshore location.
DEPOMOD, a particle tracking model for predicting the flux of particulate waste material (with resuspension)
and associated benthic impact, was developed for use for net-pen fish farms. Net depositional flux of organic
carbon was predicted in g m2/yr on a two-dimensional grid overlaid on the farm footprint. The grid size, 2.04
km by 2.04 km, was selected such that it would encompass the whole depositional footprint.
The results of the depositional model show that for the estimated production values, net organic carbon
accumulation would be at 3.0 g/m2/yr or less for 99.7 percent of the test grid. At twice the estimated production,
net organic carbon accumulation would be 5.0 g/m2/yr or less for 99.0 percent of the grid. The net accumulation
of particulate wastes following a 1-year production cycle would likely not be detectable or distinguishable
from background levels through measurement of organic carbon.
The model also estimated a biotic index, Infaunal Tropic Index (ITI), that is used as an indicator of organic
enrichment based on expected changes in benthic macroinvertebrate community feeding responses to increases
in deposited organic matter. The two model simulations resulted in ITI predictions ranging from 58.67 to 58.81.
The predicted ITI close to 60 suggests that the Velella project, as proposed, will not likely have a discernable
impact on the benthic infaunal community around the site.
9.6.2	Dissolved Wastes
The NCCOS technical report (Appendix A) estimated that 2,743 kg of ammonia nitrogen would be produced
during a 280-day fish production cycle. The report suggested that daily ammonia production at levels twice as
high as estimated will be undetectable within 30 meters of the cage at typical current flows regimes in the
vicinity of the proposed site.
The NCCOS technical report did not provide dilution estimates for the dissolved waste discharge downstream
of the cage. Modelling input parameters within the NCCOS report were used to calculate the flow-averaged
ammonia concentration at the downstream edge of the cage for comparison with published water quality
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criteria for ammonia in saltwater (EPA, 1989). The ambient water quality criteria for ammonia in saltwater
state that "saltwater aquatic organisms should not be affected unacceptably if the four-day average
concentration of un-ionized ammonia does not exceed 0.035 mg/1 more than once every three years on the
average and if the one-hour average concentration does not exceed 0.233 mglL more than once every three
years on the average."
A total ammonia loading of 2,743 kg, based an initial estimated 280-day fish production cycle (Table 3 within
the NCCOS technical report) was averaged to 9.8 kg/ammonia/day and 113.0 milligrams per second (mg/s).
The flow-averaged ammonia concentration is estimated at 0.0072 mg/1 (based on an ammonia production of
9.8 kg/day loading rate).20
Since the NCCOS technical report, changes in estimated production parameters resulted in total ammonia
loading estimates for a 365-day production cycle of 3,978 kg/day. The average daily ammonia load was
calculated at 10.9 kg/d and 126.0 mg/s. The flow-averaged ammonia concentration was estimated at 0.008
mg/1 (based on an ammonia production of 10.9 kg/day loading rate). Estimates of the flow-averaged ammonia
concentrations at the cage edge at maximum fish production are significantly below the published ammonia
aquatic life criteria values for saltwater organisms.
20 The current velocity used for flow calculations is 13.26 cm/s, which is the total mean from Table 4 within the NCCOS technical report. A
lateral two-dimensional cage surface area is 1,190,000 cm3. The lateral flow through the cage was estimated 15,779,400 cm3/s.
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10.0 r.\iilu;ilion ol' (lie Ocean Discharge Criteria
This section summarizes the ten factors that the EPA must consider to ensure that the proposed NPDES permit
complies with Section 403 of the CWA. This section discusses how conditions and limitations included in the
final permit for the proposed project ensure compliance with these ocean discharge criteria, and the
determination, under CWA § 403, that the NPDES permit will not cause unreasonable degradation of the
marine environment with all NPDES permit limitations, conditions, and monitoring requirements in effect.
10.1 Evaluation of the Ten Ocean Discharge Criteria Factors
10.1.1	Factor 1
Quantities, Composition, and Potential for Bioaccumulation or Persistence of Pollutants
The quantities and composition of the discharged material was presented in Section 4 and the potential for
bioaccumulation or persistence was addressed in Section 9. Due to the relatively small fish biomass production
estimated for this demonstration and limited discharges other than fish food and fecal matter, the volume and
constituents of the discharged material are not considered sufficient to pose a significant environmental threat
through bioaccumulation or persistence. However, to confirm the EPA's decision and as a precaution against
any changes in operational practices that could change the EPA's assumptions, the NPDES Permit requires
environmental monitoring and implementation of an environmental monitoring plan to meet the requirements
of the CWA § 402 and CWA § 403.
10.1.2	Factor 2
Potential for Biological, Physical, or Chemical Transport
Section 3 and 4 of this document discusses the oceanographic process characteristic of the continental shelf
off the west coast of Florida responsible for the physical transport of fish wastes in the environment. Section
8 discusses the results of predicted impacts to the water column and waste deposition on the seafloor
surrounding the proposed facility.
Due to the small scale of the proposed project and because the discharged wastes are largely comprised of
organic and inorganic particulates and dissolved metabolic wastes, there is little potential for biological or
chemical transport. Ocean currents are expected to flush the cages sufficiently to carry wastes away from cages
and dilute and disperse dissolved and solid wastes over a large area. For any solid matter settling on the
seafloor, bioturbation should serve to mix sediments vertically at low to moderate benthic loading rates and
resuspension of sediments should further enhance the dispersion of uneaten food and fecal matter. High loading
rates that would be expected to impair benthic communities and reduce the effect of bioturbation are not
expected to occur. The physical transport of these waste streams is considered to be the most significant source
for dispersion of the wastes and monitoring and regulation is based on the results of those investigations.
10.1.3	Factor 3
Composition and Vulnerability of Biological Communities
The third factor used to determine no unreasonable degradation of the marine environment is an assessment of
the presence of unique species or communities of species, endangered species, or species critical to the
structure or function of the ecosystem. Section 4 describes the biological communities of the eastern Gulf
including the presence of endangered species and Section 8 discusses the factors that make these communities
or species vulnerable to the permitted activities.
High organic loading from fish farms have been shown to alter the physical structure of benthic sediment and
to cause anoxic conditions which reduce diversity and abundance of infauna, meiofauna and epibenthic
organisms. The area around the proposed facility is mainly comprised of soft sand sediments and their
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characteristic benthic communities. Results from deposition modeling (Section 8) show the potential for
benthic impacts over an area in excess of 1 km2. The potential for impacts due to toxic effects from a
demonstration size fish farm discharges is minimal.
10.1.4	Factor 4
Importance of the Receiving Water to the Surrounding Biological Community
The importance of the receiving waters to the species and communities of the eastern Gulf is discussed in
Section 4 and Section 5 in conjunction with the discussion of the species and biological communities. The
receiving water is considered when determining the discharge rate restrictions. The dissolved nutrient estimates
and deposition modeling considered concentrations of organic particulates that may have impacts on aquatic
life. Permit limitations on minor discharges ensure that levels of these effluents are below levels that could
have impacts on local biological communities. EPA believes that operating discharges from the proposed
facility will have little adverse impacts on species migrating to coastal or inland waters for spawning or
breeding.
10.1.5	Factor 5
Existence of Special Aquatic Sites
The existence of special aquatic sites and proximity to the proposed project are discussed in Section 7. It is
determined that the proposed area is located sufficiently far from special aquatic sites off the west Florida coast
and that any impacts resulting from the proposed facility will likely be limited to the surrounding area, within
300-500 meters from the perimeter of the cage array.
10.1.6	Factor 6
Potential Impacts on Human Health
Section 9 details the Federal and state human health criteria and standards for pollutants of concern. These
criteria and standards are for marine waters based on fish consumption. These analyses compare projected
pollutant concentrations at 100 m with these criteria and standards. The permit prohibits the discharge or use
of antifouling agents or chemical fish treatments other than antibiotics allowed by the FDA animals raised for
human consumption.
10.1.7	Factor 7
Recreational or Commercial Fisheries
The commercial and recreational fisheries occurring in the eastern Gulf, mainly Alabama, Florida, and
Mississippi, are assessed in Section 6. The conditions and limitations in the permit for the proposed project
were determined to protect water quality and preserve the health of these fisheries.
10.1.8	Factor 8
Coastal Zone Management Plans
Section 7 provides an evaluation of the coastal zone management plan for the State of Florida. On January 3,
2019, the permit applicant submitted a CZMA consistency determination to the Florida State Clearinghouse
with the Florida Department of Environmental Protection. On January 15, 2019, the Florida Department of
Agriculture and Consumer Services (FDACS) documented that the coastal consistency determination
submitted by the applicant was consistent with all FDACS statutory responsibilities for aquaculture. On
February 18, 2019, the Florida Fish and Wildlife Conservation Commission (FWC) found that the applicant's
coastal consistency determination was consistent with FCMP. Therefore, the EPA has determined that the
action covered by this permit is consistent with the CZMA and its implementing regulations.
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10.1.9	Factor 9
Other Factors Relating to Effects of the Discharge
Factor 9, the consideration of additional factors, was not deemed necessary in this ODCE as the EPA believes
that all critical environmental considerations have been addressed. Effluent Guidelines and Standards have
been developed for the Concentrated Aquatic Animal Production (CAAP) Point Source Category for facilities
producing 100,000 pounds or more of aquatic animals per year in floating net pens or submerged cage systems
(40 CFR Part 451 Subpart B). The New Source Performance Standards effluent limitation guidelines for the
CAAP industry were applied to the proposed project in the NPDES permit. The effluent limitations and
standards for these facilities are non-numeric effluent limitations expressed as practices designed to control
the discharge of pollutants from these types of operations.
The NPDES permit will contain conditions that will confirm EPA's determination and ensure no significant
environmental impacts will occur from the proposed proj ect. The aquaculture-specific water quality conditions
placed in the NPDES permit will include a comprehensive environmental monitoring plan. The applicant will
be required to monitor and sample certain water quality, sediment, and benthic parameters at a background
(up-current) location and near the cage. Additionally, the NPDES permit will include effluent limitations
expressed as best management practices (BMPs) for feed managment, waste collection and disposal, harvest
discharge, carcass removal, materials storage, maintenance, record keeping, and training. Impacts to water
quality will be reduced by a range of operational measures through the implementation of project-specific
BMPs.
10.1.10	Factor 10
Marine Water Quality Criteria
The Federal and state marine water quality criteria and standards are discussed in Section 8. The proposed
facility will be located in federal waters where no federal or state criteria apply; however, the discharges from
the proposed project are not expected to exceed the recommended federal water quality criteria for marine
waters that were considered in this ODCE.
10.2 Conclusion
The consideration of the ten factors discussed in this ODCE were based on the available information from
published literature regarding impacts that have occurred near net pen fish farms from around the world.
Sufficient information currently exists regarding open water marine fish farming activities and expected
impacts from such activities to allow the EPA to adequately predict likely environmental outcomes for the
Proposed project. As allowed by 40 CFR § 125.123(a), 21 the EPA also determined that the NPDES permit
must contain necessary conditions specified in 40 CFR § 125.123(d). Implementation of environmental
monitoring and an environmental monitoring plan within the NPDES permit meets the requirements 40 CFR
§ 125.123(d)(2) which allows the EPA to "specify a monitoring program, which is sufficient to assess the
impact of the discharge on water, sediment, and biological quality including, where appropriate, analysis of
the bioaccumulative and/or persistent impact on aquatic life of the discharge." The EPA believes that "no-
unreasonable degradation" will likely occur as a result of the discharges from this project due to the available
scientific information concerning open ocean fish farming, the results predicted by deposition and dilution
modeling, and the conditions within the NPDES permit.
21 40 CFR § 125.123(a) states that "If the director on the basis of available information including that supplied by the applicant pursuant to
§ 125.124 determines prior to permit issuance that the discharge will not cause unreasonable degradation of the marine environment after
application of any necessary conditions specified in §125.123(d), he may issue an NPDES permit containing such conditions."
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P-
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Appendix D

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
E-	REGION 4
-	ATLANTA FEDERAL CENTER
61 FORSV'TH STREET
ATLANTA. GEORGIA 30303-8960
AUG 1 3 2019

Ms. Roxanna Hinzman
I ield Super\ isor
I'.S. Fish and Wildlife Service
Souih Florida Ecolouical Services Field Office
1339 20l!l Street
Vero Beach. Florida 32960-3559
SUBJECT; Informal Endangered Species Act Section 7 Consultation Request
Kampachi [ amis, LLC - V elella Lpsilon Marine Aquaculturc f acility
Dear Ms. Hinzman;
1 he I'S. Environmental Protection Agency Region 4 and the \ LS. Army Corps of Engineers Jacksonville
District{(ISACE) are obligated under Section 7(a)(2) of the Endangered Species Act (ESA) to ensure that
any action it approves is not likely to jeopardize the continued existence of any threatened or endangered
species or result in the destruction or adverse modification of critical habitat. The purpose of this letter is
to request the initiation of informal consultation with the U.S. fish and Wildlife Service (USEW'S) under
ESA $7 in lederal waters of the Gulf. On November 10. 2018. the USACE receded a
Department ol Army application pursuant to Section 1(5 of the Rivers and Harbors Act for structures and
work ailecung navigable federal waters from the same marine aquaculturc facility On behalf of the two
I edeial .Agencies responsible for permitting aquaculture operations in federal waters of'the Gulf, the EPA
is requesting initiation of the ESA §7 informal consultation process for the two federal permits needed to
operate the proposed marine aquaculture faciliu. 1 he EPA is also initiating consultation pursuant to the
Fish and Wildhie Coordination Act. On August 12. 2019. the EPA sent an incorrect consultation request
to the USFWS via mail. Please disregard that request and consider this to be EPA's request for informal
consultation.
Given that the action of permitting the proposed project involves more than one federal agency the EPA
has elected to act as the lead agency to fulfill the consultation responsibilities pursuant to the implementing
1 In accordance w ith llic Itemonmdim, ,>f. I*mw,w Between the Environmental Prntmion Agency, Fi$h urn/ Wildlife Semcv and National
,1mi"i f-islKi ley Sen-tee Regarding Enhanced { oardmatmn Under the Cienn fi\ icr let and Endangered Species Act (20!) 11.
[ntt'he 1	iUHLi * \iftp vatwop,* go\
;tconsumcr)
rmr, "lull ill c • Fr'nh-»i .',,[h I't t Kn	j r.tp-nMini-., ,m > Fv-

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regulation;; o IT'S A cj7.~ This consultation request shall also serve as the written notice to the USFWS that
the P. PA is acting as the lead agency as required by 50 CFR §402.1)7. 1 he USACT, is a cooperating and
co-Ted era I agene\ for this informal consultation request. The completion ot this in formal consultation
shall satisfy the FPA's and USACK's obligations under FSA §7.
1 he attached supporting Biological L valuation (BP.) was prepared by the EPA and the USAC h to jointh
consider the potential effects that the proposed actions may have on listed and proposed species, and
designated and proposed critical habitat. Based on the information within the RE. the FPA and USACT,
ha\e determined that the proposed actions will have "no effect" on any listed or proposed species as well
a- designated and proposed critical habitat species under the jurisdiction of the USFWS. As outlined in
the FSA MOA. the EPA requests that the USFWS respond in writing within 30 days of receiving the "no
effect" determination documented within the FiF. I he response should state whether the F SFW S concuts
oi does not concur with the determination made by the FPA and \ 1SAC h. It the IISFWS does not concur,
it will provide a written explanation that includes the species and/or critical habitat of concern, the
perceived adverse effects, and supporting information.
The FPA and I SAUi are coordinating the interagency review process in accordance with the interagency
Memorandum of Understanding for Permitting Offshore Aqttacuhure Activities in Federal Waters oj the
(;////.! and conducting a comprehensive analysis ol all applicable environmental tequuements as allowed
b\ the National hnvironmental Policy Act (NFPA); however, a consolidated cooperation process under
NFPA is not being used to satisfy the requirements of FSA §7 as described in 50 CFR §402.06. I he
NMFS is a cooperating agenev for the NFPA anal}sis and has provided scientific expertise related to the
BP and NF.PA analvsis for the proposed facility including information about: site selection, FSA-listcd
species, marine mammal protection, and essential llsh habitat. W hile some inlormation related to the F.SA
analysis is within the coordinated NF.PA evaluation developed by multiple federal agencies, the attached
BE L being provided as a stand-alone document to comply with the consultation process under ESA §7.
: 5ft CFR § 402.07 allows a lead agency: "When a particular action involves more than one Federal agency, the consultation and conference
responsibilities may he fulfilled through a lead agency, Factors relevant in determining an appropriate lead agency include the time .sequence
in which the agencies would become involved, the magnitude ol their respective irtvoK enient. and their relative expertise with respect to the
environmental effects of the action. The Director shall he notified of the designation in writing b> the lead agency."
¦' On February 6. 2017, the Memorandum oj I 'nikrsumding for remitting Ojfshnrc Aquacuhwc Activities in t-ecknil Haters of the (hilt of
Mexico became effective For seven federal agencies with permitting or authorization responsibilities. The federal agencies included in the
MOU were: I-PA (Region 4 and 6), USAGE (Galveston, Jacksonville. Mobile, and New Orleans Districts). NMFS (Southeast Region!.
1 ,'SFWS (Southwest and Southeast Regions), BOF.M (Gulf ol" Mexico Region), BSEH (Gulf of Mexico Region), and the i fSCG. ^
4 50 CFR ij 402.06 states that "Consultation, conference, and biological assessment procedures under section 7 may be consolidated with
interagency cooperation procedures required by other statutes, such as the National Environmental Policy Act (NEPA) (42 USC 4321 el
set;., implemented at 40 CFR Farts 1500- 1508) or the Fish and Wildlife Coordination Act j FWCAl.'"

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Ik1',,Utnherinf0™ati011 dUring thiS consultatio" period or have any questions, please contact
at 404?5f "	m W ™ ema" 31 wrtlstro™ainler.meghan@epa.gov or by phone
al(404)562-9672.
Sincerely,
Chris 1 homas. Chief
Pencilling and Grants Branch
Waicr Divison
cc: Ms. Kat\ Damieu. I SAC'!" (via email)
Dr. Jess licL'k-Stiniperl. NMl-'S (via email)
Mr. Jeffrey Howe. \ iSKWS (\ia email)
3

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DRAFT
BIOLOGICAL EVALUATION
Kampachi Farms, LLC - Velella Epsilon
Marine Aquaculture Facility
Outer Continental Shelf
Federal Waters of the Gulf of Mexico
August 5, 2019
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U.S. Environmental Protection Agency
Region 4
Water Protection Division
61 Forsyth Street SW
Atlanta Georgia 30303
NPDES Permit Number
FL0A00001
US Army Corps
of Engineers®
U.S. Army Corps of Engineers
Jacksonville District
Fort Myers Permit Section
1520 Royal Palm Square Boulevard Suite 310
Fort Myers Florida 33919-1036
Department of the Army Permit Number
SAJ-2017-03488

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Table of Contents
1.0 Introduction and Federal Coordination	3
2.0 Proposed Action	4
3.0 Proposed Project	5
4.0 Proposed Action Area	7
5.0 Federally Listed and Proposed Threatened and Endangered Species and Critical Habitat	8
5.1	Federally Listed Threatened and Endangered Species	8
5.1.1	Birds	9
5.1.2	Fish	9
5.1.3	Invertebrates	10
5.1.4	Marine Mammals	11
5.1.5	Reptiles	12
5.2	Federally Listed Critical Habitat In or Near the Action Area	14
5.2.1	Birds	14
5.2.2	Reptiles	14
5.3	Federal Proposed Species and Proposed Critical Habitat	14
6.0 Potential Stressors to Listed and Proposed Species and Critical Habitat	15
6.1	Disturbance	15
6.2	Entangl em ents	15
6.3	Vessel Strike	15
6.4	Water Quality	16
7.0 Potential Effects of Action	19
7.1	Federally Listed Threatened and Endangered Species	19
7.1.1	Birds	19
7.1.2	Fish	19
7.1.3	Invertebrates	20
7.1.4	Marine Mammals	21
7.1.5	Reptiles	22
7.2	Federally Listed Critical Habitat	23
7.3	Federal Proposed Species and Proposed Critical Habitat	24
8.0 Conclusion	26
References	27
Appendix A - Cage and Mooring Detail	32
Appendix B - Location Area	33
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1.0 Inli-odiK'lion iiiul I'edoi'iil (oorriiniilion
In accordance with the Endangered Species Act (ESA) Section 7, interagency consultation and coordination
with the National Marine Fisheries Service (NMFS) and the U.S. Fish and Wildlife Service (USFWS) is required
to insure that any action authorized, funded, or carried out by an action agency is not likely to jeopardize the
continued existence of any listed species or result in the destruction or adverse modification of any designated
critical habitat (Section 7(a)(2)); and confer with the NMFS and USFWS on any agency actions that are likely
to jeopardize the continued existence of any species that is proposed for listing or result in the destruction or
adverse modification of any critical habitat proposed to be designated (Section 7(a)(4)).1
On November 9, 2018, the U.S. Environmental Protection Agency Region 4 (EPA) received a complete
application for a National Pollutant Discharge Elimination System (NPDES) permit from Kampachi Farms for
the point-source discharge of pollutants from a marine aquaculture facility in federal waters of the Gulf of
Mexico (Gulf). On November 10, 2018, the U.S. Army Corps of Engineers Jacksonville District (USACE)
received a completed Department of Army (DA) application pursuant to Section 10 of the Rivers and Harbors
Act for structures and work affecting navigable federal waters from the same marine aquaculture facility.
Given that the action of permitting the proposed project involves more than one federal agency, the EPA has
elected to act as the lead agency to fulfill the consultation responsibilities pursuant to the implementing
regulations of ESA Section 7.2 The USACE is a cooperating and co-federal agency for this informal consultation
request. The completion of the informal consultation shall satisfy the EPA's and USACE's obligations under
ESA Section 7(a)(2).
The EPA and the USACE (action agencies) have reviewed the proposed activity and determined that a biological
evaluation (BE) is appropriate. The BE was prepared by the EPA and the USACE to jointly consider the potential
direct, indirect, and cumulative effects that the proposed actions may have on listed and proposed species as
well as designated and proposed critical habitat, and to assist the action agencies in carrying out their activities
for the proposed action pursuant to ESA Section 7(a)(2) and ESA Section 7(a)(4). The EPA and the USACE are
providing this BE for consideration by the USFWS and the NMFS in compliance with the ESA Section 7.
The EPA and USACE are coordinating the interagency permitting process as required by the interagency
Memorandum of Understanding (MOU) for Permitting Offshore Aquaculture Activities in Federal Waters of
the Gulf,3 and conducting a comprehensive analysis of all applicable environmental requirements required by
the National Environmental Policy Act (NEPA); however, a consolidated cooperation process under NEPA is
not being used to satisfy the requirements of ESA Section 7 as described in 50 CFR § 402.06.4 The NMFS is a
cooperating agency for the NEPA analysis and has provided scientific expertise related to the BE and NEPA
analysis for the proposed action including information about: site selection, ESA-listed species, marine mammal
protection, and essential fish habitat. While some information related to the ESA evaluation is within the
coordinated NEPA document developed by multiple federal agencies, the attached BE is being provided as a
stand-alone document to comply with the consultation process under ESA Section 7.
1	The implementing regulations for the Clean Water Act related to the ESA require the EPA to ensure, in consultation with the NMFS and
USFWS, that "any action authorized the EPA is not likely to jeopardize the continued existence of any endangered or threatened species or
adversely affect its critical habitat" (40 CFR § 122.49(c)).
2	50 CFR § 402.07 allows a lead agency: "When a particular action involves more than one Federal agency, the consultation and conference
responsibilities may be fulfilled through a lead agency. Factors relevant in determining an appropriate lead agency include the time sequence
in which the agencies would become involved, the magnitude of their respective involvement, and their relative expertise with respect to the
environmental effects of the action. The Director shall be notified of the designation in writing by the lead agency."
3	On February 6, 2017, the Memorandum of Understanding for Permitting Offshore Aquaculture Activities in Federal Waters of the Gulf of
Mexico became effective for seven federal agencies with permitting or authorization responsibilities.
4	50 CFR § 402.06 states that "Consultation, conference, and biological assessment procedures under section 7 may be consolidated with
interagency cooperation procedures required by other statutes, such as the National Environmental Policy Act (NEPA) (implemented at 40 CFR
Parts 1500 - 1508) or the Fish and Wildlife Coordination Act (FWCA)."
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2.0 Proposed Action
Kampachi Farms, LLC (applicant) is proposing to operate a pilot-scale marine aquaculture facility (Velella
Epsilon) in federal waters of the Gulf. The proposed action is the issuance of a permit under the respective
authorities of the EPA and the USACE as required to operate the facility. The EPA's proposed action is the
issuance of a NPDES permit that authorizes the discharge of pollutants from an aquatic animal production
facility that is considered a point source into federal waters of the United States. The USACE's proposed action
is the issuance of a DA permit pursuant to Section 10 of the Rivers and Harbors Act that authorizes anchorage
to the sea floor and structures affecting navigable waters.
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3.0 Proposed Project
The proposed project would allow the applicant to operate a pilot-scale marine aquaculture facility with up to
20,000 almaco jack (Seriola rivoliana) being reared in federal waters for a period of approximately 12 months
(total deployment of the cage system is 18 months). Based on an estimated 85 percent survival rate, the operation
is expected to yield approximately 17,000 fish. Final fish size is estimated to be approximately 4.4 pounds (lbs)
per fish, resulting in an estimated final maximum harvest weight of 88,000 lbs (or 74,800 lbs considering the
anticipated survival rate). The fingerlings will be sourced from brood stock that are located at Mote Aquaculture
Research Park and were caught in the Gulf near Madeira Beach, Florida. As such, only F1 progeny will be
stocked into the proposed project.
One support vessel will be used throughout the life of the project. The boat will always be present at the facility
except during certain storm events or times when resupplying is necessary. The support vessel would not be
operated during any time that a small craft advisory in effect for the proposed action area. The support vessel is
expected to be a 70 ft long Pilothouse Trawler (20 ft beam and 5 ft draft) with a single 715 HP engine. The
vessel will also carry a generator that is expected to operate approximately 12 hours per day. Following harvest,
cultured fish would be landed in Florida and sold to federally-licensed dealers in accordance with state and
federal laws. The exact type of harvest vessel is not known; however, it is expected to be a vessel already
engaged offshore fishing activities in the Gulf.
A single CopperNet offshore strength (PolarCirkel-style) fully enclosed submersible fish pen will be deployed
on an engineered multi-anchor swivel (MAS) mooring system. The engineered MAS will have up to three
anchors for the mooring, with a swivel and bridle system. The design drawings provided for the engineered
MAS uses three concrete deadweight anchors for the mooring; however, the final anchor design will likely
utilize embedment anchors instead. The cage material for the proposed project is constructed with rigid and
durable materials (copper mesh net with a diameter of 4 millimeter (mm) wire and 40 mm x 40 mm mesh square).
The mooring lines for the proposed project will be constructed of steel chain (50 mm thick) and thick rope (36
mm) that are attached to a floating cage that will rotate in the prevailing current direction; the ocean currents
will maintain the mooring rope and chain under tension during most times of operation. The bridle line that
connects from the swivel to the cage will be encased in a rigid pipe. Structural information showing the MAS
and pen, along with the tethered supporting vessel, is provided in Appendix A. The anchoring system for the
proposed project is being finalized by the applicant. While the drawings in Appendix A show concrete
deadweight anchors, it is likely that the final design will utilize appropriately sized embedment anchors instead.
Both anchor types are included for ESA consultation purposes.
The CopperNet cage design is flexible and self-adjusts to suit the constantly changing wave and current
conditions. As a result, the system can operate floating on the ocean surface or submerged within the water
column of the ocean; however, the normal operating condition of the cage is below the water surface. When a
storm approaches the area, the entire cage can be submerged by using a valve to flood the floatation system with
water. A buoy remains on the surface, marking the net pen's position and supporting the air hose. When the pen
approaches the bottom, the system can be maintained several meters above the sea floor. The cage system is
sable to rotate around the MAS and adjust to the currents while it is submerged and protected from storms near
the water surface. After storm events, the cage system is made buoyant, causing the system to rise to resume
normal operational conditions. The proposed project cage will have at least one properly functioning global
positioning system device to assist in locating the system in the event it is damaged or disconnected from the
mooring system.
In cooperation with the NMFS, a protected species monitoring plan (PSMP) has been developed for the proposed
action to protect all marine mammal, reptiles, sea birds, and other protected species. Monitoring will occur
throughout the life of the project and represents an important minimization measure to reduce the likelihood of
any unforeseen potential injury to all protected species including ESA-listed marine animals. The data collected
will provide valuable insight to resource managers about potential interactions between aquaculture operations
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and protected species. The PSMP also contains important mitigative efforts such as suspending vessel transit
activities when a protected species comes within 100 meters (m) of the activity until the animal(s) leave the area.
The project staff will suspend all surface activities (including stocking fish, harvesting operations, and routine
maintenance operations) in the unlikely event that any protected species comes within 100 m of the activity until
the animal leaves the area. Furthermore, should there be activity that results in an injury to protected species,
the on-site staff would follow the steps outlined in the PSMP and alert the appropriate experts for an active
entanglement.5
The below information about chemicals, drugs, cleaning, and solid waste provides supporting details about the
proposed project:
Chemicals: The proposed facility has indicated they would not be using toxic chemicals, cleaners, or solvents
at the proposed project. The proposed project would use small amounts of petroleum to run the generator.
Spills are unlikely to occur; however, if a spill did occur they would be small in nature.
Drugs: The applicant has indicated that FDA-approved antibiotics or other therapeutants will not likely be
used (within any feed or dosing the rearing water) during the proposed project. 6 The need for drugs is
minimized by the strong currents expected at the proposed action area, the low fish culture density, the cage
material being used, and the constant movement of the cage.
Cleaning: The applicant does not anticipate the need to clean the cage for the short duration of the proposed
project. Should the cage system need cleaning, divers would manually scrub the cage surfaces with cleaning
brushes. No chemicals would be used while cleaning and any accumulated marine biological matter would
be returned to sea without alteration.
Solid Wastes: The applicant will dispose of all solid waste appropriately on shore.
5	A PSMP has been developed by the applicant with assistance from the NMFS Protected Resources Division. The purpose of the PSMP is to
provide monitoring procedures and data collection efforts for species (marine mammals, sea turtles, seabirds, or other species) protected under
the MMPA or ESA that may be encountered at the proposed project.
6	The applicant is not expected to use any drugs; however, in the unlikely circumstance that therapeutant treatment is needed, three drugs
were provided to the EPA as potential candidates (hydrogen peroxide, oxytetracycline dihydrate, and florfenicol).
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4.0 Proposed Action Aivsi
The proposed project would be placed in the Gulf at an approximate water depth of 40 m (130 feet), and
generally located 45 miles southwest of Sarasota, Florida. The proposed facility will be placed within an area
that contains unconsolidated sediments that are 3 - 10 ft deep (see Table 1). The applicant will select the specific
location within that area based on diver-assisted assessment of the sea floor when the cage and anchoring system
are deployed. The proposed action area is a 1,000 m radius measured from the center of the MAS.
The facility potential locations were selected with assistance from NOAA's National Ocean Service National
Centers for Coastal Ocean Science (NCCOS). The applicant and the NCCOS conducted a site screening process
over several months to identify an appropriate project site. Some of the criteria considered during the site
screening process included avoidance of corals, coral reefs, submerged aquatic vegetation, hard bottom habitats,
and avoidance of marine protected areas, marine reserves, and habitats of particular concern. This siting
assessment was conducted using the Gulf AquaMapper tool developed by NCCOS.7
Upon completion of the site screening process with the NCCOS, the applicant conducted a Baseline
Environmental Survey (BES) in August 2018 based on guidance developed by the NMFS and EPA.8 The BES
included a geophysical investigation to characterize the sub-surface and surface geology of the sites and identify
areas with a sufficient thickness of unconsolidated sediment near the surface while also clearing the area of any
geohazards and structures that would impede the implementation of the aquaculture operation. The geophysical
survey for the proposed project consisted of collecting single beam bathymetry, side scan sonar, sub-bottom
profiler, and magnetometer data within the proposed area. The BES report noted that were no physical,
biological, or archaeological features within the surveyed area that would preclude the siting of the proposed
aquaculture facility within the area shown in Table 1.
Table 1: Target Area with 3' to 10' of Unconsolidated Sediments
Upper Left Corner
Upper Right Corner
Lower Right Corner
Lower Left Corner
27° 7.70607' N
27° 7.61022'N
27° 6.77773'N
27° 6.87631'N
83° 12.27012'W
83° 11.65678'W
83° 11.75379'W
83° 12.42032'W
7	The Gulf AquaMapper tool is available at: https://coastalscience.noaa.gov/products-explorer/
8	The BES guidance document is available at: http://sero.nmfs.noaa.gov/sustainable_fisheries/Gulf_fisheries/aquaculture/
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5.0	Federally Listed ;iihI Proposed Threatened ;ind l.ndan»ered Species and Critical llahilat
5.1	Federally Listed Threatened and Endangered Species
The action agencies identified the ESA-listed species shown in Table 2 for consideration on whether the
proposed action may affect protected species in or near the proposed action area. In summary, the action agencies
considered the potential affects to threatened and endangered species from five groups of species: birds (2), fish
(4), invertebrates (7), marine mammals (6), and reptiles (5). The action agencies considered the species within
this Section of the BE because they may occur within the project footprint or near enough such that there are
potential routes of effects. Certain ESA-listed species are not discussed because their behavior, range, habitat
preferences, or known/estimated location do not overlap or expose them to the activities within the proposed
action area.
Table 2: Federally Listed Species, Listed Critical Habitat, Proposed Species, and
Proposed Critical Habitat Considered for the Proposed Action
Species Considered
KSA Slatus
Critical
Habitat Status
Potential Kxposure to
Proposed Action Area
Birds



1 Piping Clover
Threatened
Yes
No
2 Red Knot
Threatened
No
No
1 isli



1 Giant Manta Ray
Threatened
No
Yes
2 Nassau Grouper
Threatened
No
Yes
3 Oceanic Whitetip Shark
Threatened
No
Yes
4 Smalltooth Sawfish
Endangered
No
Yes
ln\er(ebra(es



1 Boulder Star Coral
Threatened
No
No
2 Elkhorn Coral
Threatened
No
No
4 Mountainous Star Coral
Threatened
No
No
5 Pillar Coral
Threatened
No
No
7 Staghorn Coral
Threatened
No
No
6 Rough Cactus Coral
Threatened
No
Yes
3 Lobed Star Coral
Threatened
No
Yes
Marine Mammals



1 Blue Whale
Endangered
No
Yes
2 Bryde's Whale
Endangered
No
Yes
3 Fin Whale
Endangered
No
Yes
4 Humpback Whale
Endangered
No
Yes
5 Sei Whale
Endangered
No
Yes
6 Sperm Whale
Endangered
No
Yes
Reptiles



1 Green Sea Turtle
Threatened
No
Yes
2 Hawksbill Sea Turtle
Endangered
Yes
Yes
3 Kemp's Ridley Sea Turtle
Endangered
No
Yes
4 Leatherback Sea Turtle
Endangered
Yes
Yes
5 Loggerhead Sea Turtle
Threatened
Yes
Yes
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5.1.1	Birds
There are 14 ESA-listed avian species identified as threatened or endangered, previously delisted, or as candidate
species in the eastern Gulf. Of those species, only two listed species, the piping plover and red knot, are
considered in this BE because their migratory range could expose them to activities covered under the proposed
action. There are several other listed species whose range includes only inshore and coastal margin waters and
are not exposed to the activities covered under the proposed action.
Piping Plover
The piping plover is a threatened shorebird that inhabits coastal sandy beaches and mudflats. Three populations
of piping plover are recognized under ESA: Great Lakes (endangered); Great Plains (threatened); and Atlantic
(threatened) (BOEM, 2012a). This species nests in sand depressions lined with pebbles, shells, or driftwood.
Piping plovers forage on small invertebrates along ocean beaches, on intertidal flats, and along tidal pool edges;
therefore, fish from the proposed action are not considered a potential source of food for the piping plover.
Possibly as high as 75% of all breeding piping plovers, regardless of population affiliation, may spend up to
eight months on wintering grounds in the Gulf. They arrive from July through September, leaving in late
February to migrate back to their breeding sites (BOEM, 2012b). They do not breed in the Gulf. Habitat used
by wintering birds include beaches, mud flats, sand flats, algal flats, and washover passes (where breaks in sand
dunes result in an inlet). The piping plover is considered a state species of conservation concern in all Gulf coast
states due to wintering habitat. The piping plover is it is a migratory shorebird with no open ocean habitat.
Red Knot
The red knot, listed as threatened in 2014, is a highly migratory shorebird species that travels between nesting
habitats in Arctic latitudes and southern non-breeding habitats in South America and the U.S. Atlantic and Gulf
coasts (BOEM, 2012a). Red knots forage along sandy beaches, tidal mudflats, salt marshes, and peat banks for
bivalves, gastropods, and crustaceans (USFWS, 2015). Horseshoe crab eggs are a critical food resource for this
species, and the overharvesting and population declines of horseshoe crabs may be a major reason for the decline
of red knot numbers.
Wintering red knots may be found in Florida and Texas (Wiirsig, 2017). They are considered a State Species of
Conservation Concern in Florida and Mississippi. The numbers of wintering and staging red knots using coastal
beaches in Gulf coast states other than Florida have declined dramatically (Wiirsig, 2017). Its population has
exhibited a large decline in recent decades and is now estimated in the low ten-thousands (NatureServe, 2019).
Critical habitat rules have not been published for the red knot. Within the Gulf region, wintering red knots are
found primarily in Florida, but this species has been reported in coastal counties of each of the Gulf states.
5.1.2	Fish
The four species of ESA-protected fish that may occur within the action area are: giant manta ray, nassau
grouper, smalltooth sawfish, and oceanic whitetip shark.
Giant Manta Ray
The giant manta ray was listed as threatened under the ESA on February 21, 2018. The giant manta ray is found
worldwide in tropical, subtropical, and temperate seas. These slow-growing, migratory animals are circumglobal
with fragmented populations. The giant manta ray is the largest living ray, with a wingspan reaching a width of
up to 9 m. Manta species are distinguished from other rays in that they tend to be larger with a terminal mouth,
and have long cephalic lobes (Evgeny, 2010), which are extensions of the pectoral fins that funnel water into
the mouth. Giant manta rays feed primarily on planktonic organisms such as euphausiids, copepods, mysids,
decapod larvae and shrimp, but some studies have noted their consumption of small and moderately sized fishes
(Miller and Klimovich, 2017).
Within the Southeast Region of the United States, the giant manta ray is frequently sighted along the east coast
and within the Gulf of Mexico. Giant manta rays are seasonal visitors along productive coastlines with regular
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upwelling, in oceanic island groups, and near offshore pinnacles and seamounts. Given the opportunistic
sightings of the species, researchers are still unsure what drives giant manta rays to certain areas and not others
(and where they go for the remainder of the time). The timing of these visits varies by region and seems to
correspond with the movement of zooplankton, current circulation and tidal patterns, seasonal upwelling,
seawater temperature, and possibly mating behavior. Although giant manta rays are considered oceanic and
solitary, they have been observed congregating at cleaning sites at offshore reefs and feeding in shallow waters
during the day at depths less than 10 m (O'Shea et al., 2010; Marshall et al., 2011; Rohner et al., 2013). The
giant manta ray ranges from near shore to pelagic habitats, occurring over the continental shelf near reef habitats
and offshore islands. The species can be found in estuarine waters near oceanic inlets, with use of these waters
as potential nursery grounds. This species appears to exhibit a high degree of plasticity in terms of their use of
depths within their habitat.
Nassau Grouper
The Nassau grouper is a reef fish typically associated with hard structure such as reefs (both natural and
artificial), rocks, and ledges. It is a member of the family Serranidae, which includes groupers valued as a major
fishery resource such as the gag grouper and the red grouper. These large fish are found in tropical and
subtropical waters of southern coastal Florida and the Florida Keys. Nassau grouper are generally absent from
the Gulf north and outside of the Florida Keys; this is well documented by the lack of records in Florida Fish
and Wildlife Conservation Commission's, Fisheries Independent Monitoring data, as well as various surveys
conducted by NOAA Fisheries Southeast Fisheries Science Center. There has been one verified report of the
Nassau Grouper in the northwest Gulf at Flower Gardens Bank national marine sanctuary; however, the Flowers
Gardens Bank is not near the proposed action area.
Oceanic Whitetip Shark
The oceanic whitetip shark is a large open ocean highly migratory apex predatory shark found in subtropical
waters throughout the Gulf. It is a pelagic species usually found offshore in the open ocean, on the outer
continental shelf, or around oceanic islands in deep water greater than 184 m. The oceanic whitetip shark can
be found from the surface to at least 152 m depth. Occasionally, it is found close to land in waters as shallow as
37 m, mainly around mid-ocean islands or in areas where the continental shelf is narrow with access to nearby
deep water. Oceanic whitetip sharks have a strong preference for the surface mixed layer in warm waters above
20°C and are therefore mainly a surface-dwelling shark.
Oceanic whitetip sharks are high trophic-level predators in open ocean ecosystems feeding mainly on teleosts
and cephalopods (Backus et al., 1956; Bonfil et al., 2008); however, some studies have found that they consume
sea birds, marine mammals, other sharks and rays, mollusks, crustaceans, and even garbage (Compagno, 1984;
Cortes, 1999).
Smalltooth Sawfish
The smalltooth sawfish was the first marine fish to receive protection as an endangered species under the ESA
in 2003. Their current range is poorly understood but believed to have significantly contracted from these
historical areas. Today, smalltooth sawfish primarily occur off peninsular Florida from the Calloosahtchee River
to the Florida Keys (Wiirsig, 2017). Historical accounts and recent encounters suggest immature individuals are
most common in shallow coastal waters less than 25 m (Bigelow and Schroeder, 1953; Adams and Wilson,
1995). Smalltooth sawfish primarily live in shallow coastal waters near river mouths, estuaries, bays, or depths
up to 125 m. Smalltooth sawfish feed primarily on fish. Mullet, jacks, and ladyfish are believed to be their
primary food resources (Simpfendorfer, 2001). Smalltooth sawfish also prey on crustaceans (mostly shrimp and
crabs) by disturbing bottom sediment with their saw (Norman and Fraser, 1938; Bigelow and Schroeder, 1953).
5.1.3 Invertebrates
The seven ESA-listed coral species in the Gulf are known to occur near the Dry Tortugas, a small group of
islands located approximately 67 miles west of Key West, Florida. Four of the ESA-listed coral species in the
Gulf (elkhorn, lobed star, mountainous star, and boulder star) are known to occur in the Flower Banks National
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Marine Sanctuary, located 70 to 115 miles off the coast of Texas and Louisiana. The most abundant depth ranges
for the ESA-listed invertebrates are provided in Table 3. Given the known geographic locations of the considered
coral species and their recognized habitat preferences related to water depth, only two invertebrate species (lobed
star coral and rough cactus coral) may occur in the proposed action area. Threats to coral communities
throughout the Gulf include predation, hurricane damage, and loss of habitat due to algal overgrowth and
sedimentation.
Table 3: ESA-listed Coral Depth Ranges
j-l Mm miaul IK-plli III)
Boulder Star Coral 3 - 82 9
Elkhorn Coral 3 - 16 10
Lobed Star Coral 6 - 130 11
Mountainous Star Coral 3 - 30 11
Pillar Coral 3-90
Rough Cactus Coral 15 -270 10
Staghorn Coral	15 - 60 10
5.1.4 Marine Mammals
All the ESA-listed marine mammals considered in this BE are endangered under the ESA. The six species of
whales that could occur within the action area are: blue whale, fin whale, Gulf Bryde's whale, humpback whale,
sperm whale, and sei whale; however, except for the Gulf Bryde's whale, each ESA-listed whale considered in
this BE are not common in the Gulf (Wiirsig, 2017). Threats to whales from aquaculture facilities include vessel
strikes, entanglement, and disturbance (ocean noise).
Blue Whales
Blue whales are found in all oceans except the Arctic Ocean. Currently, there are five recognized subspecies of
blue whales. Blue whales have been sighted infrequently in the Gulf. The only record of blue whales in the Gulf
are two strandings on the Louisiana and Texas coasts; however, the identifications for both strandings are
questionable. In the North Atlantic blue whales are most often seen off eastern Canada where they are present
year-round (NMFS, 2016). Blue whales also typically occur in deeper waters seaward of the continental shelf
and are not commonly observed in the waters of the Gulf or off the U.S. East Coast (CeTAP, 1982; Wenzel et
al., 1988; Waring et al., 2006). Blue whales are not expected to be within the proposed action area that is located
in a water depth of approximately 40 m.
Bryde's Whale
The Gulf Bryde's whale was listed as endangered on May 15, 2019. The Gulf Bryde's whales are members of
the baleen whale family and are a subspecies of the Bryde's whale. The Gulf Bryde's whales are one of the most
endangered whales in the world, with likely less than 100 whales remaining. They are the only resident baleen
whale in the Gulf. The Gulf Bryde's whale is one of the few types of baleen whales that do not migrate and
remain in the Gulf year-round. The historical range in Gulf waters is not well known; however, scientists believe
that the historical distribution of Gulf Bryde's whales once encompassed the north-central and southern Gulf.
For the past 25 years, Bryde's whales in U.S. waters of the Gulf have been consistently located in the
northeastern Gulf (largely south of Alabama and the western part of the Florida panhandle) along the continental
shelf break between the 100 and 400 m depth (Labrecque et al., 2015). This area has been identified as a
Biologically Important Area (BIA) for the Gulf Bryde's whale and encompasses over 5.8 million acres. BIAs
are reproductive areas, feeding areas, migratory corridors, or areas in which small and resident populations are
9	www.DCNANature.org, 2016
10	NMFS, 2016
11	www.IUCNRedList.org, 2016
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concentrated. The proposed action area is not located near the areas where the Gulf Bryde's whale is known to
be distributed and are not expected to occur at the water depth of the proposed project.
Fin Whales
Fin whales are found in deep, offshore waters of all the world's oceans, primarily in temperate to polar climates.
The NMFS has reported that the are about 2,700 fin whales in the North Atlantic and Gulf. There are few reliable
reports of fin whales in the northern Gulf. They are most commonly found in North Atlantic waters where they
feed on krill, small schooling fish, and squid (NMFS, 2016). Fin whales are generally found along the 100 m
isobath with sightings also spread over deeper water including canyons along the shelf break (Waring et al.,
2006). Therefore, fin whales are not expected to be found near the proposed action area where the water depth
is approximately 40 m.
Humpback Whales
Based on a few confirmed sightings and one stranding event, humpback whales are rare in the northern Gulf
(BOEM, 2012a). Baleen whale richness in the Gulf is believed to be less than previously understood (Wiirsig,
2017). U.S. populations of humpback whales mainly use the western North Atlantic for feeding grounds and use
the West Indies during winter and for calving (NMFS, 2016). Given that humpback whales are not a typical
inhabitant of the Gulf, they are not expected to be in found near the proposed action area. Additionally, the water
depth at the proposed action area (40 m) does not overlap to the habitat preference of humpback whales for
deeper waters.
Sei Whales
The sei whale is rare in the northern Gulf and its occurrence is considered accidental, based on four reliable and
one questionable strandings records in Louisiana and Florida (Jefferson and Schiro, 1997; Schmidley, 2004;
Wiirsig, 2017). Sei whales are more commonly found in subtropical to subpolar waters of the continental shelf
and slope of the Atlantic, with movement between the climates according to seasons (NMFS, 2016). Sei whales
typically occur in deeper waters seaward of the continental shelf and are not commonly observed in the waters
of the Gulf (CeTAP, 1982; Wenzel et al., 1988; Waring et al., 2006). Sei whales are not expected to be
geographically located near the proposed project.
Sperm Whales
In the northern Gulf, aerial and ship surveys indicate that sperm whales are widely distributed and present in all
seasons in continental slope and oceanic waters. Sperm whales are the most abundant large cetacean in the Gulf.
Greatest densities of sperm whales are in the central Northern Gulf near Desoto Canyon as well as near the Dry
Tortugas (Roberts et al., 2016). They are found in deep waters throughout the world's oceans, but generally in
waters greater than 200 to 800 m due to the habit of feeding on deep-diving squid and fish (Hansen et al., 1996;
Davis et al., 2002; Mullin and Fulling, 2003; Wiirsig, 2017). Research conducted since 2000 confirms that Gulf
sperm whales constitute a distinct stock based on several lines of evidence (Waring et al., 2006). Sperm whales
are not expected to be within the proposed action area due to their known preference for deeper water.
5.1.5 Reptiles
The five ESA-listed sea turtle species that may occur in or near the proposed action area are: green, hawksbill,
leatherback, kemp's ridley, and loggerhead. Sea turtles are highly migratory and travel widely throughout the
Gulf. Therefore, each sea turtle has the potential to occur throughout the entire Gulf. In general, the entire Gulf
coastal and nearshore area can serve as habitat for marine turtles. Florida is the most important nesting area in
the United States for loggerhead, green, and leatherback turtles. Several volumes exist that cover the biology
and ecology of these species (i.e., Lutz and Musick, 1997; Lutz et al., 2003, Wynekan et al., 2013).
Green sea turtle
Green sea turtle hatchlings are thought to occupy pelagic areas of the open ocean and are often associated with
Sargassum rafts (Carr, 1987; Walker, 1994). Pelagic stage green sea turtles are thought to be carnivorous.
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Stomach samples of these animals found ctenophores and pelagic snails (Frick, 1976; Hughes, 1974). At
approximately 20 to 25 centimeters (cm) carapace length, juveniles migrate from pelagic habitats to benthic
foraging areas (Bjorndal, 1997). As juveniles move into benthic foraging areas a diet shift towards herbivory
occurs. They consume primarily seagrasses and algae, but are also known to consume jellyfish, salps, and
sponges (Bjorndal, 1980, 1997; Paredes, 1969; Mortimer, 1981, 1982). The diving abilities of all sea turtle
species vary by their life stages. The maximum diving range of green sea turtles is estimated at 110 m (Frick,
1976), but they are most frequently making dives of less than 20 m (Walker, 1994). The time of these dives also
varies by life stage.
The NMFS and USFWS removed the range-wide and breeding population ESA listings of the green sea turtle
and listed eight distinct population segments (DPSs) as threatened and three DPSs as endangered, effective May
6, 2016. Two of the green sea turtle DPSs, the North Atlantic DPS and the South Atlantic DPS, occur in the
Gulf. The proposed action area is within the North Atlantic NPS where the green sea turtle is listed as threatened.
Hawksbill sea turtle
The hawksbill sea turtle's pelagic stage lasts from the time they leave the nesting beach as hatchlings until they
are approximately 22 to 25 cm in straight carapace length (Meylan, 1988; Meylan and Donnelly, 1999). The
pelagic stage is followed by residency in developmental habitats (foraging areas where juveniles reside and
grow) in coastal waters. Little is known about the diet of pelagic stage hawksbills. Adult foraging typically
occurs over coral reefs, although other hard-bottom communities and mangrove-fringed areas are occupied
occasionally. Hawksbills show fidelity to their foraging areas over several years (van Dam and Diez, 1998). The
hawksbill's diet is highly specialized and consists primarily of sponges (Meylan, 1988). Gravid females have
been noted ingesting coralline substrate (Meylan, 1984) and calcareous algae (Anderes, Alvarez, and Uchida,
1994), which are believed to be possible sources of calcium to aid in eggshell production. The maximum diving
depths of these animals are unknown, but the maximum length of dives is estimated at 73.5 minutes, more
routinely dives last about 56 minutes (Hughes, 1974). Hawksbill sea turtles are not known to regularly nest in
Florida but do occur occasionally.
Kemp's Ridley sea turtle
Kemp's ridley sea turtle hatchlings are also pelagic during the early stages of life and feed in surface waters
(Carr, 1987; Ogren, 1989). After the juveniles reach approximately 20 cm carapace length they move to
relatively shallow (less than 50 m) benthic foraging habitat over unconsolidated substrates (Marquez-M., 1994).
They have also been observed transiting long distances between foraging habitats (Ogren, 1989). Kemp's ridleys
feeding in these nearshore areas primarily prey on crabs, though they are also known to ingest mollusks, fish,
marine vegetation, and shrimp (Shaver, 1991). The fish and shrimp Kemp's ridleys ingest are not thought to be
a primary prey item but instead may be scavenged opportunistically from bycatch discards or discarded bait
(Shaver, 1991). Given their predilection for shallower water, Kemp's ridleys most routinely make dives of 50
m or less (Soma, 1985; Byles, 1988). Their maximum diving range is unknown. Depending on the life stage, a
Kemp's ridley may be able to stay submerged anywhere from 167 minutes to 300 minutes, though dives of 12.7
minutes to 16.7 minutes are much more common (Soma, 1985; Mendonca and Pritchard, 1986; Byles,
1988). Kemp's ridley turtles may also spend as much as 96 percent of their time underwater (Soma, 1985; Byles,
1988). In the United States, Kemp's ridley turtles inhabit the Gulf and northwest Atlantic Ocean; nesting occurs
primarily in Texas, and occasionally in Florida, Alabama, Georgia, South Carolina, and North Carolina.
Leatherback sea turtle
Leatherback sea turtles are the most pelagic of all ESA-listed sea turtles and spend most of their time in the open
ocean. They will enter coastal waters and are seen over the continental shelf on a seasonal basis to feed in areas
where jellyfish are concentrated. Leatherbacks feed primarily on cnidarians (medusae, siphonophores) and
tunicates. Unlike other sea turtles, leatherbacks' diets do not shift during their life cycles. Because leatherbacks'
ability to capture and eat jellyfish is not constrained by size or age, they continue to feed on these species
regardless of life stage (Bjorndal, 1997). Leatherbacks are the deepest diving of all sea turtles. It is estimated
that these species can dive more than 1,000 m (Eckert et al., 1989) but more frequently dive to depths of 50 m
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to 84 m (Eckert et al. 1986). Dive times range from a maximum of 37 minutes to more routines dives of 4 to
14.5 minutes (Standora et al., 1984; Eckert et al., 1986; Eckert et al., 1989; Keinath and Musick, 1993).
Loggerhead sea turtle
Loggerhead sea turtle hatchlings forage in the open ocean and are often associated with Sargassum rafts
(Hughes, 1974; Carr 1987; Walker, 1994; Bolten and Balazs, 1995). The pelagic stage of these sea turtles are
known to eat a wide range of things including salps, jellyfish, amphipods, crabs, syngnathid fish, squid, and
pelagic snails (Brongersma, 1972). Stranding records indicate that when pelagic immature loggerheads reach 40
to 60 cm straight-line carapace length, they begin to live in coastal inshore and nearshore waters of the
continental shelf throughout the U.S. Atlantic (Witzell, 2002). Loggerhead sea turtles forage over hard-bottom
and soft-bottom habitats (Carr, 1986).
Benthic foraging loggerheads eat a variety of invertebrates with crabs and mollusks being an important prey
source (Burke et al., 1993). Estimates of the maximum diving depths of loggerheads range from 211 m to 233
m (Thayer et al., 1984; Limpus and Nichols, 1988). The lengths of loggerhead dives are frequently between 17
and 30 minutes (Thayer et al., 1984; Limpus and Nichols, 1988; Limpus and Nichols, 1994; Lanyon et al., 1989)
and they may spend anywhere from 80 to 94 percent of their time submerged (Limpus and Nichols, 1994;
Lanyon et al., 1989). Loggerhead sea turtles are a long-lived, slow-growing species, vulnerable to various threats
including alterations to beaches, vessel strikes, and bycatch in fishing nets.
5.2	Federally Listed Critical Habitat In or Near the Action Area
5.2.1	Birds
Onshore critical habitat has been designated for the piping plover including designations for coastal wintering
habitat areas in Alabama, Mississippi, and Florida.12 The proposed project is not expected to impact any onshore
habitats.
5.2.2	Reptiles
The only critical habitat designated near the proposed action area is the Northwest Atlantic DPS of loggerhead
sea turtles. Specific areas of designated habitat include: nearshore reproductive habitat, winter area, breeding
areas, migratory corridors, and Sargassum habitat. The northwest Atlantic loggerhead DPS designated critical
habitat portion that occurs in federal waters (i.e., a Sargasso habitat unit) consists of the western Gulf to the
eastern edge of the loop current, through the Straits of Florida and along the Atlantic coast from the western
edge of the Gulf Stream eastward. Sargassum habitat is home to most juvenile sea turtles in the western Gulf.
5.3	Federal Proposed Species and Proposed Critical Habitat
The action agencies did not identify any Federally-listed proposed species or proposed critical habitat in the
proposed action area.
12 Critical habitat locations for the piping plover are available at: https://ecos.fws.gov/ecp0/profile/speciesProfile?spcode=B079
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6.0	Potential Stressors to Listed ;iihI Proposed Species and Critical I Inhibit
The action agencies evaluated the potential impacts of the proposed project on ESA-listed species that were
identified in Section 5.0 and that may occur in or near the proposed action area. Potential effects considered in
this analysis may occur because of a potential overlap between the proposed aquaculture facility location with
the species habitat (socialization, feeding, resting, breeding, etc.) or migratory route. Section 6.0 broadly
describes the most likely stressors, directly and indirectly, that were considered to potentially impact the species
near the proposed facility. The action agencies identified four categories of risks from the proposed project:
disturbance; entanglement; vessel collisions; and impacts from water quality. The specific analysis of potential
impacts to each species from the proposed project is provided in Section 7.0.
6.1	Disturbance
Disturbance in the context of this BE includes ocean noise (low-frequency underwater noises) and breakage
(invertebrates). Underwater noises can interrupt the normal behavior of whales, which rely on sound to
communicate. As ocean noise increases from human sources, communication space decreases and whales cannot
hear each other, or discern other signals in their environment as they used to in an undisturbed ocean. Different
levels of sound can disturb important activities, such as feeding, migrating, and socializing. Mounting evidence
from scientific research has documented that ocean noise also causes marine mammals to change the frequency
or amplitude of calls, decrease foraging behavior, become displaced from preferred habitat, or increase the level
of stress hormones in their bodies. Loud noise can cause permanent or temporary hearing loss. Underwater noise
threatens whale populations, interrupting their normal behavior and driving them away from areas important to
their survival. Increasing evidence suggests that exposure to intense underwater sound in some settings may
cause some whales to strand and ultimately die.
ESA-listed sea turtles, whales, and fish may experience stress due to a startled reaction should they encounter
vessels, or vessel noise, at the proposed location or in transit to the proposed project site. The reaction could
range from the animal approaching and investigating the activity, to the opposite reaction of flight, where the
animal could injure itself while attempting to flee. The most likely source of disturbance from the proposed
aquaculture activity would be noise from the vessel engines and barge generator.
6.2	Entanglements
Entanglement, for the purposes of this BE, refers to the wrapping of lines, netting, or other man-made materials
around the body of a listed species. Entanglement can result in restrainment and/or capture to the point where
harassment, injury, or death occurs. The cage, mooring lines, and bridles from the proposed project may pose
an entanglement risk to listed species in the project area; however, entanglement risks to ESA-listed species at
any aquaculture operation are mitigated by using rigid and durable cage materials, and by keeping all facility
lines taut as slack lines are the primary source of entanglements (Nash et al., 2005).
Past protected species reviews by the NMFS for a similar scale aquaculture project determined that cetacean and
sea turtle entanglement is not expected when facility mooring and tether lines are kept under near-constant
tension and free of loops (NMFS, 2016). Additionally, the NMFS determined that a similar aquaculture project
had the potential to result in interactions with marine mammals; however, the NMFS found that the most likely
effect of the project on marine mammals was behavioral interactions (e.g., individuals engaging in investigative
behavior around the array or that prey on wild fish accumulated near the facility) as opposed to causing injury
or mortality from entanglement.
6.3	Vessel Strike
A vessel strike is a collision between any type of boat and a marine animal in the ocean. All sizes and types of
vessels have the potential to collide with nearly any marine species. Strikes can result in death or injury to the
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marine animal and may go unnoticed by the vessel operator. Some marine species spend short durations "rafting"
at the ocean's water surface between dives which makes them more vulnerable to vessel strikes.
The NMFS estimates collisions between some cetaceans and vessels are relatively rare events based on data
from Marine Mammal Stock Assessments for the Atlantic and Gulf (NMFS, 2017). Collisions between marine
mammals and vessels can be further minimized when vessels travel at less than 10 knots based on general
guidance from the NMFS for vessels transiting areas where there are known populations of whales (HIHWNMS,
2011). Detection of sea turtles by vessel operators may be more difficult because most vessel operators usually
sight protected species and avoid them. In past biological opinions in support of similar aquaculture activities,
the NMFS has determined that the rate of collisions between sea turtles and vessels was negligible and did not
expect sea turtle vessel strikes to occur (NMFS, 2016).
The support vessel used for the proposed project is expected to be vigilant against the possibility of protected
species collisions. Piloting of all vessels associated with the proposed project will be done in a manner that will
prevent vessel collisions or serious injuries to protected species. Operators and crew will operate vessels at low
speeds when performing work within and around the proposed project area and operate only when there are no
small craft advisories in effect. All vessels are expected to follow the vessel strike and avoidance measures that
have been developed by the NMFS.13 These operating conditions are expected to allow vessel operators the
ability to detect and avoid striking ESA-listed species.
6.4 Water Quality
Although offshore marine cage systems do not generate a waste stream like other aquaculture systems, effluent
from the proposed action area can adversely affect water quality, sea floor sediment composition, and benthic
fauna though the additions of uneaten feed, ammonia excretions, and fish feces from the increased fish biomass.
Water quality in aquaculture is primarily assessed through measures of nitrogen (N), phosphorus (P), solids
(total suspended solids, settleable solids, and turbidity), dissolved oxygen (DO), and pH. The increased amount
of organic material has the potential to increase N, P, and solids levels in the surrounding waters. The
concentration of N (such as total nitrogen, ammonia, nitrate, nitrite) and P (as total phosphorus or
orthophosphate) are indicators of nutrient enrichment and are commonly used to assess the impact of aquaculture
on water quality. The release of nutrients, reductions in concentrations of DO, and the accumulation of sediments
under certain aquaculture operations can affect the local environment by boosting overall productivity in
phytoplankton and macroalgal production in marine ecosystems through eutrophication and degradation of
benthic communities (Stickney, 2002).
According to Marine Cage Culture and The Environment (Price and Morris, 2013), "there are usually no
measurable effects 30 meters beyond the cages when the farms are sited in well-flushed water. Nutrient spikes
and declines in dissolved oxygen sometimes are seen following feeding events, but there are few reports of long-
term risk to water quality from marine aquaculture." Price and Morris (2013) also considered the benthic effects
of Marine Cage Culture and found that "well-managed farms may exhibit little perturbation and, where chemical
changes are measured, impacts are typically confined to within 100 meters of the cages. Benthic chemical
recovery is often rapid following harvest". Conversely, poorly managed farms or heavily farmed areas, can see
anaerobic conditions persisting and extending hundreds of meters beyond the aquaculture facility. Changes in
water quality associated with commercial scale marine aquaculture facilities can be measurable downstream for
approximately 205 m (Nash et al., 2005).
The NCCOS reviewed global siting data to identify aquaculture site characteristics that are best suited for water
quality protection, concluding that, "Protection of water quality will be best achieved by siting farms in well-
13 The NMFS has determined that collisions with any vessel can injure or kill protected species (e.g., endangered and threatened species, and
marine mammals). The vessel strike avoidance guidelines developed by the NMFS are the standard measures that should be implemented to
reduce the risk associated with vessel strikes or disturbance of these protected species to discountable levels. NMFS Southeast Region Vessel
Strike Avoidance Measures and Reporting for Mariners; revised February 2008.
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flushed waters." (Price, 2013). The hydrology near the proposed action area has powerful and mixing ocean
currents that would constantly flush and dilute particulate and dissolved wastes. In addition, the proposed action
has other attributes cited in this study that contributes to decrease water quality impacts, including deep waters
and a sand bottom type. Neither particulates nor dissolved metabolites are expected to accumulate due to a low
fish production levels and the near constant flushing of the cage by strong offshore currents that dissipate wastes.
The EPA evaluated the proposed action's potential impacts to water quality, impacts of organic enrichment to
the seafloor, and impacts to benthic communities from organic enrichment as required by the Sections 402 and
403 of the CWA. The EPA determined that discharges from the proposed facility are not expected to exceed
federally recommended water quality criteria; that the discharged material is not sufficient to pose a
environmental threat through seafloor bioaccumulation; and the potential for benthic impacts from the proposed
project are minimal.14 Additionally, the EPA considered recent environmental modeling performed by the
NMFS for a similar small scale aquaculture facility (Velella Delta).15 NCCOS concluded that there are minimal
risks to water column or benthic ecology functions in the subject area from the operation of the fish cage as
described in the applicant's proposal. Furthermore, EPA reviewed the previous and current environmental
monitoring data collected from a commercial-scale marine aquaculture facility, Blue Ocean Mariculture (BOM),
in Hawaii raising the same fish species.16 While the size of the proposed project is significantly smaller than the
BOM commercial-scale facility and BOM is in slightly deeper waters, the results show that soluble and
particulate nutrients from the BOM facility do not substantially affect the marine environment. Based on EPA's
analysis, as well as a review and comparison of representative water quality information, the proposed action
would not likely raise particulate and dissolved nutrient concentrations in the proposed action area.
The proposed facility will be covered by a NPDES permit as an aquatic animal production facility with protective
conditions required by the Clean Water Act. The NPDES permit will contain conditions that will confirm EPA's
determination and ensure no significant environmental impacts will occur from the proposed project. The
aquaculture-specific water quality conditions placed in the NPDES permit will generally include a
comprehensive environmental monitoring plan. The applicant will be required to monitor and sample certain
water quality, sediment, and benthic parameters at a background (up-current) location and near the cage.
Additionally, the NPDES permit will include effluent limitations expressed as best management practices
(BMPs) for feed managment, waste collection and disposal, harvest discharge, carcass removal, materials
storage, maintenance, record keeping, and training. Impacts to water quality will be reduced by a range of
operational measures through the implementation of project-specific BMPs. For example, feeding will always
be monitored to ensure fish are fed at levels just below satiation to limit overfeeding and decrease the amount
of organic material that is introduced into the marine environment. Moreover, the Essential Fish Habitat
assessment requires certain mitigation measures within the NPDES and Section 10 permits.17
14	Further information about EPA's analysis and determination for impacts to water quality, seafloor, and benthic habitat can be found in the
final NPDES permit and the Ocean Discharge Criteria (ODC) Evaluation, as well as other supporting documents for the NPDES permit such
as the Essential Fish Elabitat Assessment and the NEPA evaluation.
15	The NCCOS previously produced models to assess the potential environmental effects on water quality and benthic communities for the
applicant's Velella Delta project that is similar Velella Epsilon in terms of fish production (approximately 120,000 lbs), operation duration,
and cultured species; however, the water depth was dissimilar between the two projects (6,000 ft vs. 130 ft). At maximum capacity, NCCOS
determined there were no risks to water quality from the Velella Delta project, and only insignificant effects would occur in the water column
down to 100 feet. Because of the great depth, strong currents, and physical oceanographic nature of the Velella Delta site, dissolved wastes
would be widely dispersed and assimilated by the planktonic community. Furthermore, the model results showed that benthic impacts and
accumulation of particulate wastes would not be detectable through measurement of organic carbon or infaunal community biodiversity.
16	Water quality information from a Blue Ocean Mariculture (BOM) facility in Elawaii was reviewed as representative data and compared to
the proposed project. The BOM farm previously produced approximately 950,000 lbs/yr prior to 2014 and has produced up to 2,400,000 lbs/yr
after 2014. The BOM facility is in a similar depth of water as the proposed project with an average depth of 60 m. Over eight years of
comprehensive water quality and benthic monitoring, the BOM facility has not adversely impacted water quality outside of the mixing zone at
the facility (BOM, 2014).
17	The EPA and the USACE will require mitigation measures to be incorporated into the NPDES permit to avoid or limit organic enrichment
and physical impacts to habitat that may support associated hardbottom biological communities. The NPDES permit will require facility to be
positioned at least 500 meters from any hardbottom habitat; the DA permit will not authorize the anchor system to be placed on vegetated
and/or hardbottom habitat.
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The EPA also considered the potential water quality impacts from chemical spills, drugs, cleaning, and solid
wastes.
Chemical Spills: Spills are unlikely to occur; however, if a spill did occur they would be small in nature and
dissipate rapidly due to strong currents in the project area. The terms and conditions of the NPDES permit
would require the applicant to follow operational procedures (i.e. BMPs) that minimize the risk of wastes
and discharges that may affect any ESA-listed species or habitat. The risk of accidental fuel or oil spills into
the marine environment is minimized by the support vessel not being operated during any time that a small
craft advisory is in effect at the proposed facility.
Drugs: The applicant indicated that FDA-approved antibiotics or other therapeutants will not likely be used
during the proposed project due to the strong currents expected at the proposed action area, the low fish
culture density, and the cage material being used. In the unlikely event that drugs/therapeutants are used,
administration of drugs will be performed under the control of a licensed veterinarian and only FDA-
approved therapeutants for aquaculture would be used as required by federal law. In addition, the NPDES
permit will require that the use of any medicinal products be reported to the EPA, including therapeutics,
antibiotics, and other treatments. The report will include types and amounts of medicinal product used and
the duration they were used. The EPA does not expect the project to a cause a measurable degradation in
water quality from drugs that may affect any ESA-listed species.
Cleaning: Another potential source of water quality impacts would be from the cleaning of the cage system.
The applicant does not anticipate the need to clean the cage for the short duration of the proposed project.
Experience from previous trials by the applicant demonstrated that copper alloy mesh material used for the
cage is resistant to fouling. Should the cage system need cleaning, divers would manually scrub the cage
surfaces with cleaning brushes. No chemicals would be used while cleaning and any accumulated marine
biological matter would be returned to sea without alteration.
Solid Wastes: Multiple federal laws and regulations strictly regulate the discharge of oil, garbage, waste,
plastics, and hazardous substances into ocean waters. The NPDES permit prohibits the discharge of any
solid material not in compliance with the permit.
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7.0 Potential Meets of Action
Under the ESA, "effects of the action" means the direct and indirect effects of an action on the listed species or
critical habitat, together with the effects of other activities that are interrelated or interdependent with that action
(50 CFR § 402.02). The NMFS and USFWS standard for making a "no effect" finding is appropriate when an
action agency determines its proposed action will not affect that ESA-listed species or critical habitat, directly
or indirectly (USFWS and NMFS, 1998). Generally, a "no effect" determination means that ESA-listed species
or critical habitats will not be exposed to any potentially harmful/beneficial elements of the action (NMFS,
2014).
The applicable standard to find that a proposed action "may affect, but not likely to adversely affect" (NLAA)
listed species or critical habitat is that all the effects of the action are expected to be discountable, insignificant,
or completely beneficial. Insignificant effects relate to the size of the impact and should never reach the scale
where take occurs. Discountable effects are those extremely unlikely to occur. Beneficial effects are
contemporaneous positive effects without any adverse effects to the species or critical habitat.
A summary of the potential effects considered and the determination of impact for each listed species and critical
habitat is provided in Table 4. Overall, potential impacts to the ESA-listed species considered in this BE are
expected to be extremely unlikely and insignificant due to the small size of the facility, the short deployment
period, unique operational characteristics, lack of geographic overlap with habitat or known migratory routes,
or other factors that are described in the below sections for each species. The federal action agencies used
multiple sources to support the determinations described within this section including the analysis of potential
impacts that the NMFS used as the basis for its ESA determination for up to 20 commercial scale offshore
marine aquaculture facilities in the Gulf (EPA, 2016; NMFS, 2009; NMFS, 2013; NMFS, 2015; NMFS, 2016).
7.1 Federally Listed Threatened and Endangered Species
7.1.1	Birds
The action agencies did not consider any potential threats to ESA-protected birds from the proposed project.
The two species of birds considered are not expected to interact with the proposed project due to the distance
between the proposed project from shore (approximately 45 miles) to their onshore habitat preferences. The
piping plover and red knot are migratory shorebirds. Known migratory routes do not overlap with the proposed
project. Both birds primarily inhabit coastal sandy beaches and mudflats of the Gulf; migration and wintering
habitat are in intertidal marine habitats such as coastal inlets, estuaries, and bays (USFWS, 2015). Additionally,
the normal operating condition of the cage is expected to be below the water surface which will further decrease
the likelihood of any bird interaction with the proposed project.
The ESA-listed bird species will not be exposed to any potentially harmful impacts of the proposed action. The
action agencies have determined that the activities under the proposed project will have no effect on the
threatened species of birds.
7.1.2	Fish
The action agencies considered disturbance, entanglement (for smalltooth sawfish only), and water quality as
potential impacts to endangered or threatened fish from the proposed project in the rare event that interaction
occurs.
Impacts from disturbance, entanglement, and water quality are highly unlikely for each ESA-listed fish species
that was considered given their unique habitat preferences and known proximity to the proposed action area.
The oceanic whitetip shark is not likely to occur near the proposed project given its preference for deeper waters.
The action agencies believe that the Nassau grouper will not be present given that it is absent from the Gulf
outside of the Florida Keys. Interactions with smalltooth sawfish with the proposed project is extremely unlikely
because they primarily occur in the Gulf off peninsular Florida and are most common off Southwest Florida. The
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giant manta ray may encounter the facility given its migratory patterns; however, disturbance is not expected
because the facility is small and will have a short deployment period of approximately 18 months.
Entanglement impacts were considered for smalltooth sawfish because it is the only listed fish species large
enough to become entangled within the proposed facility's mooring lines. Entanglement risks to the smalltooth
sawfish from the proposed project are minimized by using rigid and durable cage materials and by keeping all
lines taut (as described in Section 3.0). The ocean currents will maintain the floating cage, mooring lines, and
chain under tension during most times of operation. Additionally, the limited number of vertical mooring lines
reduce the risk of potential entanglement by this listed fish species. Furthermore, interactions are anticipated to
be highly unlikely given their current range in southwest Florida between Ft Myers and the Florida Keys.
Because of the proposed proj ect operations and lack of proximity to the known habitat for the smalltooth sawfish,
the action agencies expect that the effects of this entanglement interaction would be discountable.
For water quality impacts, the EPA is proposing NPDES permit conditions required by the Clean Water Act.
These permit provisions will contain environmental monitoring (water quality, sediment, and benthic infauna)
and conditions that minimize potential adverse impacts to fish from the discharge of effluent from the proposed
facility, and prohibit the discharge of certain pollutants (e.g., oil, foam, floating solids, trash, debris, and toxic
pollutants). Due to the pilot-scale size of the facility, water quality and benthic effects are not expected to occur
outside of 10 meters. The discharges authorized by the proposed NPDES permit represent a small incremental
contribution of pollutants that are not expected to affect any ESA-listed fish species in or near the proposed
action area.
Any potential effects from the proposed action on ESA-listed fish are discountable and insignificant. The action
agencies have determined that the activities under the proposed project is NLAA the threatened and endangered
species of fish.
7.1.3 Invertebrates
Potential routes of effects to coral from the proposed project include disturbance (breakage of coral structures)
and water quality impacts (e.g., increased sedimentation, increased nutrient loading, and the introduction of
pollutants).
Regarding disturbance, anthropogenic breakage is extremely unlikely and discountable because the proposed
facility will not be in areas where listed corals may occur. Most of the ESA-listed invertebrate species are
associated with coral reefs that occur in shallower areas of the Gulf and along the west Florida shelf. Only five
species of the invertebrates considered (boulder star, elkhorn, mountainous star, pillar, and staghorn) are not
known to occur near the proposed project location or at depths where the proposed facility is located. Only two
invertebrate species (lobed star coral and rough cactus coral) may occur in the proposed action area. Moreover,
the anchoring system and cage will be placed in an area consisting of unconsolidated sediments, away from
potential hardbottom which may contain corals according to the facility's seafloor survey. Given the known
geographic locations of the considered coral species and their recognized habitat preferences related to water
depth, the disturbance effects of the proposed action is anticipated to be minimal and extremely unlikely.
Regarding impacts from water quality, the discharge from the proposed facility will be covered by a NPDES
permit with water quality conditions required by the Clean Water Act. The aquaculture-specific water quality
conditions contained in the NPDES permit will generally include an environmental monitoring plan (water
quality, sediment, and benthic monitoring) and effluent limitations expressed as BMPs. Water quality effects
are not expected to occur outside of 30 m due to the small size of the facility and low production levels.
Sedimentation from the facility is not expected to occur outside of 1,000 m (assuming a maximum production
for the entire duration of the project) with impacts resulting from the proposed facility likely limited to within
300-500 meters from the cage. The NPDES permit will prohibit discharges within 500 m of areas of biological
concern, including live bottoms or coral reefs. The impacts from water quality and sedimentation are expected
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to be minimal or insignificant, and the likelihood that deleterious water quality will contribute to any adverse
effects to listed coral species is extremely unlikely.
Any adverse effects from the proposed project on ESA-listed corals are discountable and insignificant. The
action agencies have concluded that the proposed project will NLAA on the ESA-listed invertebrate species.
7.1.4 Marine Mammals
Generally, endangered whales are not likely to be adversely affected by any of the threats considered by the
action agencies at or near the proposed facility because they are unlikely to overlap geographically with the
small footprint of the proposed action area. All whales considered in this BE prefer habitat in waters deeper than
the proposed action (40 m) as described in Section 5.1.4. The expected absence of the ESA-listed marine
mammals in or near the proposed action area is an important factor in the analysis of whether impacts from the
proposed project will have any effect on ESA-listed whales; however, the action agencies have still considered
potential threats (disturbance, entanglement, vessel strikes, and water quality) to the six species of marine
mammals considered in this BE.
Disturbance to marine mammals from ocean noise generated by the proposed facility is expected to be extremely
low given the duration of the project, minimal vessel trips, and scale of the operation. The production cage will
be deployed for a duration of approximately 18 months. Opportunities for disturbance from the vessel
participating in the proposed project are minimal due to the limited trips to the site. The most likely source of
disturbance from the proposed aquaculture activity would be noise from the vessel engines and barge generator.
The noise emitted from the engines and generator would not significantly add to the frequency or intensity of
ambient sound levels in the proposed action area, and are not expected to be different from other vessels
operating in federal waters. The action agencies believe that the underwater noise produced by operating a vessel
and cage will not interfere with the ability of marine mammals to communicate, choose mates, find food, avoid
predators, or navigate. The limited amount of noise from the proposed project would have negligible effect on
ESA-listed whales.
Entanglement risks to marine mammals at any aquaculture operation is minimized by using rigid and durable
cage materials and by keeping all lines taut. As described in Section 3.0, the cage material for the proposed
project is constructed with rigid and durable materials that will significantly decrease the likelihood that ESA-
listed species will become entangled. The limited number of vertical mooring lines (3) and the duration of cage
deployment (approximately 18 months) will reduce the risk of potential entanglement by marine mammals.
When the currents change, the lines would likely remain taut even as the currents shift because of the weight of
chain and rope create a negative buoyancy on the facility anchorage lines. While it is highly unlikely that ESA-
listed whales would become entangled in the mooring lines; if incidental line contact occurs, serious harm to the
listed whales or sea turtles is not likely due to the tension in the mooring lines. The cage will be constructed of
semi-rigid copper alloy mesh with small openings that will further prevent entanglements.
Additionally, there have been no recorded incidents of entanglement from ESA-listed marine mammal species
interacting with a permitted commercial-scale marine aquaculture facility in Hawaii (BOM, 2014). The depth
of water and line length used at the proposed project would provide adequate spaces for most marine mammals
to pass through. The proposed action would not likely entangle marine mammals as they are likely to detect the
presence of the facility and would be able to avoid the gear; however, should entanglement occur, on-site staff
would follow the steps outlined in the PSMP and alert the appropriate experts for an active entanglement.
Furthermore, because of the proposed project operations and location of marine mammal habitat, the action
agencies expect that the effects of this entanglement interaction would be interactions are anticipated to be highly
unlikely.
Regarding vessel strikes, facility staff will be stationed on one vessel for the duration of the project except during
unsafe weather conditions. The probability that collisions with the vessel associated with the proposed project
would kill or injure marine mammals is discountable as the vessel will not be operated at speeds known to injure
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or kill marine mammals. Given the limited trips to the facility with only one vessel, and the high visibility of
whales to small vessels, opportunities for strikes from the vessel participating in the proposed project are
expected to be insignificant. Strikes from other vessels not operated by the facility are anticipated to be
improbable due to the proximity to shore (-45 miles). Additionally, all vessels are expected to follow the vessel
strike and avoidance measures that have been developed by the NMFS. Moreover, should there be any vessel
strike that results in an injury to an ESA-protected marine mammal, the on-site staff would follow the steps
outlined in the PSMP and alert the appropriate experts for an active entanglement.
Regarding potential impacts from water quality, each ESA-listed whale species considered in this BE is not
expected to be affected given their unique habitat preferences and known proximity to the proposed action area.
The discharge from the proposed facility will be covered by a NPDES permit with project-specific conditions
that includes water quality monitoring and implementation of practices to protect the environment near the
proposed action area. The discharge of wastewater from the proposed project are expected to have a minor
impact on water quality due to factors concerning the low fish biomass produced; the relatively small amounts
of pollutants discharged; depth of the sea floor; and current velocities at the proposed action area. It is anticipated
that the proposed activity would add relatively small amounts of nutrient wastes (nitrogen, phosphorus,
particulate organic carbon, and solids) to the ocean in the immediate vicinity of the proposed action area. The
facility's effluent is expected to undergo rapid dilution from the prevailing current; constituents will be difficult
to detect within short distances from the cage. The impacts from water quality are expected to be insignificant,
and the likelihood of water quality impacts contributing to any adverse effects to ESA-listed marine mammals
is extremely unlikely (see Section 6.4 for more information).
The action agencies believe that any adverse effects from the potential threats considered to ESA-listed marine
mammals are extremely unlikely to occur and are discountable. The action agencies have determined that the
activities authorized under the proposed permits will NLAA any marine mammals considered in this BE.
7.1.5 Reptiles
The action agencies considered disturbance, entanglement, vessel strike, and water quality as the only potential
threats to reptiles within the proposed action area.
Sea turtles may experience disturbance by stress due to a startled reaction should they encounter vessels in transit
to the proposed project site. Given the limited trips to the site, opportunities for disturbance from vessels
participating in the proposed project are minimal. ESA-listed sea turtles may be attracted to aquaculture facilities
as potential sources of food, shelter, and rest, but behavioral effects from disturbance are expected to be
insignificant. Additionally, all vessels are expected to follow the vessel strike and avoidance measures that have
been developed by the NMFS.7 Furthermore, there has been a lack of documented observations and records of
ESA-listed sea turtles interacting with a permitted commercial-scale marine aquaculture facility in Hawaii
(BOM, 2014); we anticipate that such interactions would be unlikely. As a result, disturbance from human
activities and equipment operation resulting from the proposed action is expected to have insignificant effects
on ESA-listed reptiles.
The risk of sea turtles being entangled in offshore aquaculture operation is greatly reduced by using rigid cage
materials and by keeping all lines taut. Section 3 describes how the cage and mooring material for the proposed
project is constructed with rigid and durable materials, and how the mooring lines will be constructed of steel
chain and thick rope that will be maintained under tension by the ocean currents during most times of operation.
Additionally, the bridle line that connects from the swivel to the cage will be encased in a rigid pipe. Moreover,
the limited number of vertical mooring lines (three) and the duration of cage deployment (less than 18 months)
will reduce the risk of potential entanglement by sea turtles. Because of the proposed project operations and
duration, the action agencies expect that the effects of this entanglement interaction would be discountable;
however, should entanglement occur, on-site staff would follow the steps outlined in the PSMP and alert the
appropriate experts for an active entanglement.
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In regard to vessel strikes, facility staff will use only one vessel for the duration of the project. The vessel will
be operated at low speeds that are not known to injure or kill sea turtles; therefore, the probability that collisions
with the vessel associated with the proposed project would kill or injure sea turtles is discountable. Opportunities
for strikes to reptiles from the vessel participating in the proposed project are expected to be insignificant given
the limited number of trips to the facility with one vessel. Strikes from other vessels not operated by the facility
are anticipated to be improbable due to the proximity to shore. Additionally, all vessels are expected to follow
the vessel strike and avoidance measures that have been developed by the NMFS.
The proposed activity would not add significantly to the volume of maritime traffic in the proposed action area.
The number of trips associated with deploying and retrieving the facility components, routine maintenance,
stocking, and harvest operations would minimally increase vessel traffic in the proposed action area. The project
activities are not expected to result in collisions between protected species and any vessels. Collisions with ESA-
listed species during the proposed activity would be extremely unlikely to occur.
Commercial and recreational fishermen are expected to visit the proposed project because it could act as a fish
attraction device. While fishermen would be attracted to the project area from other locations, overall fishing
effort by these fishermen in federal fisheries would not increase as these fishermen would have fished elsewhere
if the project was not in place. The action agencies do not expect that any increased fishing activity in the project
area since there were no reports or observations of interactions between fishermen and ESA-listed species in
previous Velella trials (Velella Beta and Velella Gamma) in Hawaii (NMFS, 2016).
The impacts from water quality are expected to be insignificant, and the likelihood of water quality impacts
contributing to any adverse effects to ESA-listed reptiles in or near the proposed action area is extremely unlikely
(see Section 6.4 for more information related to water quality impacts). The discharge from the proposed facility
will be covered by a NPDES permit with project-specific conditions that includes water quality monitoring and
implementation of practices to protect the environment. Water quality effects are not expected to occur outside
of 10 m due to the low fish production levels and fast ocean currents.
Any adverse effects from the proposed project on ESA-listed reptiles are extremely unlikely to occur and are
discountable. The action agencies have determined that the activities under the proposed permit will NLAA the
sea turtles considered in this BE.
7.2 Federally Listed Critical Habitat
7.2.1 Reptiles
The action agencies identified vessel strike and water quality as the only potential routes of impacts to the
loggerhead turtle DPS critical habitat of the Northwest Atlantic. In the Gulf, designated critical habitat consists
of either nearshore reproductive habitat or Sargassum habitat. The proposed project is roughly 45 miles from
shore and will not affect nearshore reproductive habitat. Therefore, the essential features of loggerhead turtle
critical habitat that the proposed action may affect are foraging habitat for hatchlings and association of
hatchlings around Sargassum mats.
Sargassum mats may be impacted by vessel traffic; however, the PSMP that was developed for the proposed
project area includes a provision that trained observers will look for Sargassum mats and will inform vessel
operators as to their location to avoid the mats to the maximum extent practicable. The proposed project will be
sited in the open ocean environment, and Sargassum mats may infrequently drift into the project area; however,
it is highly unlikely the proposed facility would impact Sargassum habitat further offshore where the facility
will be located. Additionally, the facility will only bring the submerged aquaculture cage to the surface for brief
periods to conduct maintenance, feeding, or harvest activities due to the high energy open-ocean environment
where the proposed facility will be located.
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Sargassum mats are not anticipated to be negatively impacted by water quality due to the conditions in the
NPDES permit. Potential impacts on loggerhead critical habitat is expected to be discountable because of active
monitoring for Sargassum mats and the extremely low likelihood of impacts from water quality.
The action agencies believe that the adverse effects from the proposed action will have insignificant effect on
the Northwest Atlantic loggerhead DPS critical habitat due to location of the facility and operational methods
used while the cage is deployed. The action agencies have determined that the activities under the proposed
permit will NLAA the listed sea turtle critical habitat.
7.2.2 Birds
Critical habitat has been designated in for the piping plover for coastal wintering habitat areas in Florida;
however, the proposed action does not interfere with any nearshore areas. Therefore, critical habitat for the
piping plover will not be exposed to any potentially harmful elements of the proposed action. The action
agencies have determined that the activities under the proposed project will have no effect to the piping plover's
critical habitat.
7.3 Federal Proposed Species and Proposed Critical Habitat
The action agencies did not perform an analysis of impacts because no federally-listed proposed species or
proposed critical habitat in or near the proposed action area were identified.
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Table 4: Summary of potential impacts considered and ESA determination
(iroup and Species
I'mential Impacts
Considered
Potential KITect Determination
Birds
1	Piping Plover
2	Red Knot
I isli
1	Giant Manta Ray
2	Nassau Grouper
3	Oceanic Whitetip Shark
4	Smalltooth Sawfish
Inxertehrates
1	Boulder Star Coral
2	Elkhorn Coral
3	Mountainous Star Coral
4	Pillar Coral
5	Staghorn Coral
6	Rough Cactus Coral
7	Lobed Star Coral
Marine Mammals
1	Blue Whale
2	Fin Whale
3	Humpback Whale
4	Sei Whale
5	Sperm Whale
(¦> Brydc's Whale
Reptiles
1	Green Sea Turtle
2	Hawksbill Sea Turtle
3	Kemp's Ridley Sea Turtle
4	Leatherback Sea Turtle
5	Loggerhead Sea Turtle
Critical Habitat
1	Hawksbill Sea Turtle
2	Leatherback Sea Turtle
3	Loggerhead Sea Turtle
4	Piping Plover	
None
Disturbance,
entanglement, and
water quality
None
No effect
Discountable and May affect, but not
insignificant	likely to adversely affect
Disturbance and water Discountable and May affect, but not
quality	insignificant	likely to adversely affect
,	, Discountable and May affect, but not
entanglement, vessel	^	... * , . . .... ,
lnsignmcant	likely to adversely aiiect
strike, and water quality
Disturbance,
entanglement, vessel
strike, and water quality
Discountable and May affect, but not
insignificant
likely to adversely affect
Vessel strike and water Discountable and May affect, but not
quality	insignificant	likely to adversely affect
None
None
No effect
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8.0 Conclusion
The EPA and USACE conclude that the proposed project's potential threats (disturbance, entanglement, vessel
strike, water quality) to ESA-listed species and critical habitat are highly unlikely to occur or extremely minor
in severity; therefore, the potential effects to ESA protected species and critical habitats are discountable or
insignificant.
The EPA and USACE have determined that the proposed project will have "no effect" on the listed species
and critical habitat under the jurisdiction of the USFWS that may occur in the proposed action area and that
may be affected. This determination includes the piping plover and the red knot and critical habitat for the
piping plover. No other listed species, proposed species, critical habitats, or proposed critical habitats were
considered under the authority of the USFWS because there is no evidence to support that a potential effect from
the proposed project may occur. The EPA and USACE request concurrence from the USFWS for this
determination under ESA S ection 7.
The EPA and USACE have determined that the proposed project "may affect, but is not likely to adversely
affect" the listed species and critical habitat or designated critical habitat under the jurisdiction of the NMFS.
This determination includes: four species of fish, seven species of invertebrates, six species of whales, reptiles
from five species, and critical habitat for reptiles. No other listed species, proposed species, critical habitats, or
proposed critical habitats were considered under the authority of the NMFS because there is no evidence to
support that a potential effect from the proposed project may occur. The EPA and USACE request concurrence
from the NMFS for this determination under ESA S ection 7.
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University Sea Grant College.
O'Shea, O. R., Kingsford, M. J., and Seymour, J. 2010. Tide-related periodicity of manta rays and sharks to
cleaning stations on a coral reef. Marine and Freshwater Research. 61, 65-73. doi: 10.1071/MF08301
Paredes, R. (1969). Introduccion al Estudio Biologico de Chelonia mydas agassizi en el Perfil de Pisco. Master's
thesis, Universidad Nacional Federico Villareal, Lima.
Price, C.S. and J.A. Morris, Jr. 2013. Marine Cage Culture and the Environment: Twenty-first Century Science
Informing a Sustainable Industry. NOAA Technical Memorandum NOS NCCOS 164. 158 pp.
Roberts, J.J., B.D. Best, L. Mannocci, E. Fujioka, P.N. Halpin, D.L. Palka, L.P. Garrison, K.D. Mullin, T.V.N.
Cole, C.B. Khan, W.A. McLellan, D.A. Pabst, and G.G. Lockhart. 2016. Habitat-based cetacean density models
for the U.S. Atlantic and Gulf of Mexico. Scientific Reports 6:22615.
Rohner, C. A., Pierce, S. J., Marshall, A. D., Weeks, S. J., Bennett, M. B., and Richardson, A. J. 2013. Trends
in sightings and environmental influences on a coastal aggregation of manta rays and whale sharks. Mar. Ecol.
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Schmidly, D. 2004. The mammals of Texas, revised edition. University of Texas Press, Austin.
Shaver, D. 1991. Feeding Ecology of Wild and Head-Started Kemp's Ridley Sea Turtles in South Texas
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Sims, N. 2014. Culture and Harvest of a Managed Coral Reef Fish Species (Seriola rivoliana) Using a Fixed
Mooring and Rigid Mesh Submergible Net Pen in Federal Waters West of the Island of Hawaii, State of Hawaii.
29 pp.
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Simpfendorfer, C., Yeiser, B., Wiley, T., Poulakis, G., Stevens, P., and Heupel, M. 2011. Environmental
Influences on the Spatial Ecology of Juvenile Smalltooth Sawfish (Pristis pectinata): Results from Acoustic
Monitoring. PLOS One, 6(2). doi:https://doi.org/10.1371/journal.pone.0016918
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subadult leatherback turtle, Dermochelys coriacea. Herpetologica, 40, 169-176.
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Mammal Science, 4(2): 172-175.DLNR (Department of Land and Natural Resources). 2012. Final Programmatic
Assessment: Fish Aggregating Device System. State of Hawaii. 36 pp.
Witzell, W. 2002. Immature Atlantic loggerhead turtles (Caretta caretta): suggested changes to the life history
model. Herpetological Review, 33(4), 266-269.
Wiirsig B. 2017. Marine Mammals of the Gulf of Mexico. In: Ward C. (eds) Habitats and Biota of the Gulf of
Mexico: Before the Deepwater Horizon Oil Spill. Springer, New York, NY
Wyneken, J., Lohmann, K., and Musick, J. 2013. The Biology of Sea Turtles. Volume III. 457. Boca Raton,
London, New York: CRC Press.
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Appendix A - Cage and Mooring Detail
PROFILE VIEW
BRIDLE LINE: HOPE PIPE WITH ROPE INSIDE
SPAR BUOY
SPAR	v
BUOY
5.0
CURRENT DIRECTION
ROPE	s
BALLAST TANK	s
CONCRETE BALLAST
CHAIN
4.0
DEADWEIGHT
ANCHOR
1)
Deadweight Anchors (concrete):

•
Three (3) anchors equally spaced


o 120m from mooring centerline


o 120 degrees from each other

•
Each @ 4.5m x 4.5m x 4.5m (91 m3)

•
Concrete friction factor = 0.5 on wet sand

•
Each has an effective weight of 217 MT
2)
Mooring Chain (Grade 2 steel):

•
80m length on each anchor

•
50mm (2") thick links

•
No load = 70m length of each on seafloor

•
Design load = some entirely off seafloor/


others completely on seafloor
3)
Mooring lines (rope):

•
40m length on each chain

•
AMSTEELS-BLUE

•
36mm (1 1/2") thick lines
4)
Spar Buoy w/ Swivel (steel):
5)
Bridle Lines (rope inside HDPE pipe):

•
Three (3) ~30m bridle lines (rope) from swivel to


spreader bar

•
AMSTEEL®-BLUE

•
33.3mm (1 5/16") lines inside HDPE pipe
6)
Spreader Bar (HDPE):

•
Header Bar {load bearing) connected to Bridle Lines


o 30m in length


o 0.36m OD DR 11 HDPE pipe

•
Side and Rear Bars (smaller load bearing)


o 30m in length


o 0.36m OD DR 17 HDPE pipe


Four (4) comer spar buoys
7)	Net Pen Connection Lines (rope}:
•	Four (4) ~13m connection lines (rope)
•	Connected from Spreader Bar to Net Pen Float Rings
•	AMSTEELS-BLUE
33.3mm (1 5/16") lines
8)	Net Pen Frame Structure (HDPE):
•	Top Frame Structure
o 18m in diameter
o One (1) HDPE side-by-side Float Rings
" On the sea surface
¦	~ 0.36m OD OR 11 HDPE pipe
o One (1) HOPE net ring (railing)
¦	Connected ~ 1.0m above Float Rings
¦	Connected to Net Pen Mesh
¦	~ 0.15m OD DR 17 HDPE pipe
•	Bottom Frame Structure
o 18m in diameter
o One (1) HDPE sinker ring
¦	7.0m below Float Rings
¦	Connected to Net Ring
~ 0.36m OD DR 11 HDPE pipe
o One (1) HDPE net ring
¦	7.0m below float rings
¦	Connected to copper alloy mesh
¦	~ 0.15m OD DR 17 HDPE pipe
9)	Net Pen Mesh (copper alloy):
•	17m diameter x 7m depth
•	Top connected to top net ring (railing)
•	Bottom connected to bottom net ring
o 4mm wire diameter
o 40mm x 40mm mesh square
•	Effective volume of 1,600m3
10)	Shackle Point Connection (steel):
•	One (1) ~0.13m2 shackle plate
•	Four (4) connection lines
o 12 mm in diameter x 10m in length
o Connected from shackle plate to HDPE sinker ring
•	~lm Grade 2 steel chain (32mm) connected to Floatation
Capsule
11)	Floatation Capsule (steel):
•	~ 13m in diameter x ~3.45m in length
•	Effective floatation volume = 6m3
•	~3m Grade 2 steel chain (32mm) connected to Counter Weight
12)	Counter Weight (concrete):
•	~ 1-lm in diameter x~2.2m in length
•	Effective weight of 5 MT
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Appendix B - Location Area
1Q00DDD-
# .^-sa resiMagacLic .-LaociaLisi
Map * 1 "nccraolidawt Sediment
Ttnckne&k 1 trench
k^iuputbi lanus
Vvlelhi 1. (iShjl on
Gwiphyskal Survey
>	735tiS 301 SrtUh
APTIM i'l.jhi*
WUm APT1M turn
VE Project - Modified Site B & Pen Placement
H«id*
SliKkn*'^ 1 fl j
1L12DQ0D "
Sttsdiif
Nfrf
	.Vs-'Ruil J rackJines-
y ™ w
Incoascliciitc
SedrroeTiM
QjarrSiniites are in fed
hiSOii art the Flcirnil SlrtW
Plane Cmrtiiniite System.
We*! Zcvie, Nflrth Artienodn
Danwrt of ISflJtNAD U\
2 Dntii collected by APTIM
4D A^iwt 14. 2018 md
A up,i:s.1 15, 3c."rtli
Vnriounl V?« P«?tj PlaHacnri
l25i'iii •DLamt^rFwjtpriuit)
Position
s Decimal • Latitude
E Decimal: Longftutfs
Decimals Latitude
Decimal0 Longitude
Perimeter (fern)
Area |Km3)


Modlfls
d Site B from BES Report



Upper ^efl
27" 7.86653' N
¦53" 13.45627' W
27.131143" N
53.224303" W
11.1571
7.7237
Upper Rigtn
27' 7.35Z75' H
33* 11.53237' W
27.130512" N
63.15307.2" IV
Lowe- ^ofi"
27" 5.43331' U
¦33' 11.59245' W
27.107230" N
63.1S4B9D" W
Lower ^efl
27' 6.5D261r H
¦33" 13.52655' W
27.1D8377" N
63.225442" W
Center
27" 7.11266/ H
33" 12.58604 W
27.118543" N
63.2C9757* W
Targeted Subset Area of Modified Site B from 8ES Report |3' to 10' Unconsolidated Ss-amentsii
Ucper _efl
27" 7.706CI7' N
¦33" 1227C-12' W
27.12S445" N
63.2C4502" W
52273
1.5435
UKier Rfofv-
27" 7.51D22' N
33" 11.55676' W
27.126637" N
63.154278" W
Lowe-' Rotvi
27" 6.77773' N
¦33" 11.75375' W
27.1 *2552" N
63.135697" W
Lowe" Lett
27" 6.37E-3r H
•33" 12.42D32" W
27.114605" N
63.2C7C05" W
Center
27" 7.34135 N
33" 12.02291' W
27.122355" N
63.2E0332" W


Notional Net Pen Placem
Hits within Modine-d site B
from BES Repon


t
27" 7.54724r N
33" 11.35393'W
27.125737" N
63.157555" W
0.7353
Q.Q491
2
27" 7.17431' N
¦33" 11.32576' W
27.119530" N
63.1S7D95" W
3
27" 6.9353C' H
33" 11.9478CW
27.115655" N
B3.1S913D" W
4
27" 6.52575- N
33" 12.09175' W
27.1 C$753" N
E3.2G1530" W
Biological Evaluation
Kampaclii Farms - Velella Epsilon
Page 33 of 33

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^•crt-0 s&ir,
/1|\
i;r-?
AUG ! 2 2019
Ci-.R i il II i) MAI!. 7018 22W OOOO 9993 5415
R1 11 R\ RECEIPT REQEESJ I¦:[)
Mr.. David Bemhart
Assistant Regional Administrator
National Oceanic and Atmospheric Administration
National Marine Fisheries Son ice
Southeast Regional Office
Protected Resources Division
263 13th Avenue South
St. Petersburg. Florida 33701-5505
SUBJECT: Informal Endangered Species Act Section 7 Consultation Request
Kampachi Farms, LLC - Vclclla Epsilon Marine Aquaculture Facility
Dear Mr. Bemhart:
The U.S. Environmental Protection Agency Region 4 (EPA) and the U.S. Annv Corps oi Engineers
Jack son \ ille District (I SACK) are obligated under Section 7(a)(2) oi the Endangered Species Act f HSA)
to ensure that any action it approves is not likely to jeopardize the continued existence of am threatened
or endangered species or result in the destruction or adverse modification oi critical habitat. 1 he purpose
of this letter is to request the initiation of informal consultation with the National Marine Fisheries Service
(NMFS) under HSA § 7(a)(2), the ESA implementing regulations at 50 CFR § 402.13, and the
Memorandum of Agreement (MOA) Between the EPA. NMFS. and U,S Fish and Wildlife Service
tUSF W'S) regarding enhanced coordination (PSA MOA).'
On Nov ember 9, 2018, the EPA received a complete application for a National Pollutant Discharge
Elimination System (NPDES) permit from Kampachi Farms for the discharge of pollutants from Velella
Epsilon Marine Aquaculture Facility in federal waters of the Gulf. On November 10,. 2018. the \ .SAC E
received a Department of' Anm application pursuant to Section 10 ol the Rivers and Harbors Act for
structures and work affecting navigable iederal waters from the same marine aquaculture lacilitv. On
behalf of the two federal agencies responsible for permitting aquaculture operations in federal waters ot
the Gulf, the EPA is requesting initiation of the ESA ^ 7 informal consultation process for the two federal
permits needed to operate the proposed marine aquaculture facility. 1 he F.PA is also initiating consultation
pursuant to the Fish and W ildlife Coordination Act.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

1 In jecordl.inec wtlh the Memorandum ot. Igrcenwnt Between the Environmental Protection	tish and H ildltje Service and National
Marine Fisheries Service Regarding Enhanced I 'oordination i nder the (lean II ater tct and Endangered Specks Acl (2001).
Internet Address (URL) • http://www.8pa.gov
Recycied-'Recyclabte • Printed with Vegetable OH Based Inks! on Recycled Paper {Minimum 30% Postconsnmeri

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Omen that the action of permitting the proposed project involves more than one federal agency. the HIM
has elected to act as the lead agency to fulfill the consultation responsibilities pursuant to the implementing
regulations of ESA ij 1 ~ This consultation request shall also serve as the written notice to the NMFS that
the EPA is acting as the lead agency as required by 50 O'K § 402.07. "Ihe I'SACH is a cooperating and
co-federal agency for this informal consultation request. Ihe completion of this informal consultation
shall satisfy the EPA's and USACE's obligations under ESA § 7.
fhe attached supporting Biological Evaluation {HE) was prepared by the EPA and the ENACE to jointly
consider the potential effects that the proposed actions may have on listed and proposed species and on
designated and proposed critical habitat. Based on (he information within the Bf. the EPA and I'SACE
have determined that the proposed actions are not likely to adv ersely affect any listed or proposed species
as well as designated and proposed critical habitat species under the jurisdiction of the NMFS. As outlined
in the ESA MO A. the EPA requests that the NMFS respond in writing within 31) days of reeciv ing the not
likely to adversely afiect determination documented within the BE. l'he response should slate whether the
NMES concurs or docs not concur with the determination made by the EPA and ESACE. If the NMES
does not concur, it will prov ide a written explanation that includes the species and 'or critical habitat of
concern, the perceived adverse effects, and supporting information,
i he EPA and I'SACE. are coordinating the interagency rev iew process in accordance with the interagency
Memorandum of Understanding for Permitting Offshore A quae it I fun1 Activities in Federal Waters of the
(iafj. * and conducting a comprehensive analysis of all applicable en\ irunmental requirements as allowed
by the National Environmental Policy Act (NEPA): however, a consolidated cooperation process under
NEPA is not being used to satisfy the requirements of ESA vf 7 as described in 50 CER ^ -402.06."' I'he
NMES is a cooperating agency lor the NEPA analysis and has provided scienlillc expertise related to the
BE. and NEPA analysis for the Velella Epsilon facility including information about: site selection. E.SA-
listcd species, marine mammal protection, and essential lish habitat. While some information related h>
the EISA analysis is within the coordinated NEPA evaluation developed by multiple federal agencies, the
attached BE is being provided as a stand-alone document to comply with the consultation process under
ESA § 7.
511 ( I K § -102.07 allows a lead agent}: "When a particular action involves more than one Federal agency. the consultation and conference
responsibilities may be fulfilled through a lead agent}. 1-actors relevant in determining art appropriate lead agency include the time sequence
in which the agencies would become involved, the magnitude of their respective involvement, and their relative expertise with respect to the
environmental effects of the action 1 he Director shall be noli lied of the designation in writing bv the lead ayenev."
' On February 6. 2017, the Memorandum of Understanding for Permitting (Iflshore Av|uaeulture Activities in Federal Waters of the Gulf of
Mexico became effective for seven federal agencies with permitting or authorization responsibilities.
' 50 CFR if 402.(16 Mates that "Consultation, conference, and biological assessment procedures under section 7 may be consolidated with
interagency cooperation procedures required by other statutes, such as the National Environmental Policy Act (NI.I'A) (42 l.SC 4321 er
scq., implemented at 4(1 CFR Farts 1500- 1508 i or the Fish and Wildlife Coordination Act (l-AVCA)."

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If you require any further information during this consultation period or have any questions, please contact
Ms. Meghan Wahlstrom-Ramicr via email at wahlstrom-ramler.meghan!
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DRAFT
BIOLOGICAL EVALUATION
Kampachi Farms, LLC - Velctla Fpsilon
Marine Aqurtculturc Facility
Outer Continental Shelf
Federal Waters of the Gulf of Mexico
August 5,2019
v?
s*

£
A
z
SJJ
3 R C
U.S. Kn\ ironmental Protection Agency
Region 4
Water Protection Division
(it Forsub Street SW
Atlanta Georgia 30303
NPDES Permit Number
FL0A000Q1
US Army Corps
of Engineers®
U.S. Army Corps of Engineers
Jacksonville District
fort Myers Permit Section
1520 Royal Palm Square Boulevard Suite 310
Fort Myers Florida 33919-1036
Department of the Army Permit Number
SAJ-2017-034 SX

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Table of Contents
1.0	Introduction and Federal Coordination		„								3
2<0	Proposcd .Action	4
3.0	1 e opoxed. I. roj cct	5
4.0	I i o posed tion A re^	7
5.0	Federally Listed and Proposed Threatened and Endangered Species and Critical Habitat.......... 8
5.1	Federally Listed Threatened and Endangered Species									8
5.1.1	Birds													-9
5.1.2	Fish..........									-9
5.1.3	Invertebrates,,.													10
5.1.4	Marine Mammals															11
5.1.5	Reptiles				—	12
5.2	Federally Listed Critical Habitat In or Near the Action Area									.14
5.2.1	Birds																		.14
5.2.2	Reptiles.										14
5.3	Federal Proposed Species and Proposed Critical 1 iabitat							14
6.0 Potential Stressors to Listed and Proposed Species and Critical Habitat				15
6.1	Disturbance												15
6.2	Entanglements..................						15
6.3	Vessel Strike...														.......15
6.4	Water Quality.,...,..									16
7.0 Potential Effects of Action........	19
7.1	Federally Listed Threatened and Endangered Species								....19
7.1.1	Birds										.................................19
7.1.2	Fish.....................												,,19
7.1.3	Invertebrates																	...20
7.1.4	Marine Mammals														2 1
7.1.5	Reptiles																	22
7.2	Federally Listed Critical Habitat...................					....23
7.3	Federal Proposed Species and Proposed Critical Habitat		24
8.0 Cone! us ion
Rdtrtnos ..........a........................«.»»«»...»««.*..¦ ....a*......*..... 27
Appendix A - Cage and Mooring Detail									32
ppt,nd.ix. ii 1 Location	33
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1.0 Introduction and Federal Coordination
in accordance witli llic Endangered Species Act (h.SA) Section 7. interagency consultation and coordination
with the National Marine Fisheries Serv ice (NMFS) and the U.S. Fish and Wildlife Service (USFWS) is required
to insure that any action authorized, funded, or carried out by an action agency is not likely to jeopardize the
continued existence of any listed speeies or result in the destruction or adverse modification of any designated
critical habitat (Section 7(a)(2)); and confer with the N VIFS and USFWS on any agency actions that are likely
to jeopardize the continued existence of any species that is proposed for listing or result in the destruction or
adverse modification of any critical habitat proposed to be designated (Section 7(a)(4)).1
On November 9. 2018, the U.S. Environmental Protection Agency Region 4 (EPA) received a complete
application for a National Pollutant Discharge Elimination System (NPDES) permit from Kampachi Farms for
the point-source discharge of pollutants from a marine aquae u It tire facility in federal waters of the Gulf of
Mexico (Gulf). On November 10, 2018, the U.S. Army Corps of Engineers Jacksonville District (USAGE)
received a completed Department of Army (DA) application pursuant to Section 10 of the Rivers and Harbors
Act for .structures and work affecting navigable federal waters from the same marine aquaculture facility.
Given that the action of permitting the proposed project involves more than one federal agency, the EPA has
elected to act as the lead agency to fulfill the consultation responsibilities pursuant to the implementing
regulations of ESA Section 7.2 The USAGE is a cooperating and co-federal agency for this informal consultation
request. The completion of the informal consultation shall satisfy the liPA's and USAGE'S obligations under
ESA Section 7(a)(2).
The EPA and the USAGE (action agencies) have reviewed the proposed activity and determined that a biological
evaluation (BE) is appropriate. The BE was prepared by the EPA and the USAGE to jointly consider the potential
direct, indirect, and cumulative effects that the proposed actions may have on listed and proposed species as
well as designated and proposed critical habitat, and to assist the action agencies in carrying out their activities
for the proposed action pursuant to ESA Section 7(a)(2) and ESA Section 7(a)(4). The EPA and the USAGE are
providing this BE tor consideration by the USFWS and the NMFS in compliance with the ESA Section 7.
The EPA and USAGE are coordinating the interagency permitting process as required by the interagency
Memorandum of Understanding (MOlI) for Permitting Offshore Aquaculture Activities in Federal Waters of
the Gull,3 and conducting a comprehensive analysis of all applicable environmental requirements required by
the National Environmental Policy Act (NEPA); however, a consolidated cooperation process under NEPA is
not being used to satisfy the requirements of ESA Section 7 as described in 50 CFR § 402.06.4 The NMFS is a
cooperating agency for the NEPA analysis and has provided scientific expertise related to the BE and NEPA
analysis for the proposed action including information about: site selection, ESA-listcd species, marine mammal
protection, and essential fish habitat. While some information related to the ESA evaluation is within the
coordinated NEPA document developed by multiple federal agencies, the attached BE is being provided as a
stand-alone document to comply with the consultation process under ESA Section 7.
' The implementing regulations for the Clean Water Act related to (he ESA require the EPA to ensure, m consultation with the NMFS and
USf-WS, that "any action authorized the EPA is not KLeh to jeopardize the continued existence of any endangered or threatened species or
adversuj affect its critical habitat" (40 CFR 5 122.49(c)).
* 50 CFR $ 40?..07 allows a lead agenev; "When a particular action involves more than one Federal agency, the consultation and conference
responsibilities may be fulfilled through a lead agency. Factors relevant in determining an appropriate lead agency include the time sequence
m which the agencies would become involved, the magnitude of their respective involvement, and their relative expertise with respect to the
em ironmcntai elfects of the action. The Director shall he notified of the designation in writing by the lead agency."
' On February 6, 2017, the Memorandum of Understanding for Permitting Offshore Aquaculture Activities in Federal Waters of (he Gulf of
M e\ico became effective for seven federal agencies with permitting or authorization responsibilities.
4 50 ( FR !: 402.00 states that "Consultation, conference, and biological assessment procedures under section 7 may be consolidated with
interagenev cooperation procedures required by other statutes, such as the National Environmental Policy Act I NEPA) (implemented at 40 CFR
Parts i 500 - 15081 or the I'tsh and Wildlife Coordination Act (FWC \ )¦"
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2.0 Proposed Action
Kampachi Farms, LLC (applicant) is proposing to operate a pilot-scale marine aquacullurc facility (Velella
Epsilon) in federal waters of the Gulf, The proposed action is the issuance of a permit under the respective
authorities of the EPA and the USACH as required to operate the facility. The EPA's proposed action is the
issuance of a NPDES permit that authorizes the discharge of pollutants from an aquatic animal production
facility that is considered a point source into federal waters of the United States. The USACH's proposed action
is the issuance of a DA permit pursuant to Section 10 of the Rivers and Harbors Act that authorizes anchorage
to the sea floor and structures affecting navigable waters.
Biological Evaluation
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3.0 Proposed Project
The proposed project would allow the applicant to operate a pilot-scale marine aquaeulture facility with up to
20,000 almaeo jack {Serinla rivoliami) being reared in federal waters for a period of approximately 12 months
(total deployment of the cage system is 18 months). Based on an estimated 85 percent survival rate, the operation
is expected to yield approximately 17,000 fish. Final fish size is estimated to be approximately 4.4 pounds (lbs)
per fish, resulting in an estimated final maximum harvest weight of 88,000 lbs (or 74,800 lbs considering the
anticipated survival rate). The fingerlings will be sourced from brood stock that are located at Mote Aquaeulture
Research Park and were caught in the Gulf near Madeira Beach, Florida. As such, only F1 progeny will be
stocked into the proposed project.
One support vessel will be used throughout the life of the project. The boat will always be present at the facility
except during certain siorm events or limes when rcsupplying is necessarv The support \essel would not be
operated during any time that a small craft advisory in effect for the proposed action area. The support vessel is
expected to be a 70 ft long Pilothouse Trawler (20 ft beam and 5 ft draft) with a single 715 HP engine. The
\esse! will also cany a generator thai is expected to operate approximately 12 hours per day. Following harvest,
cultured fish would be landed in Florida and sold to federally-licensed dealers in accordance with state and
federal laws. The exact type of harvest vessel is not known; however, it is expected to be a vessel already
engaged offshore fishing activities in the Gulf.
A single CopperNet offshore strength (PolarCirkel-style) fully enclosed submersible fish pen will be deployed
on an engineered multi-anchor swivel (MAS) mooring system. The engineered MAS will have up to three
anchors for the mooring, with a swivel and bridle system. The design drawings provided for the engineered
MAS uses three concrete deadweight anchors for the mooring; however, the final anchor design will likely
utilize embedment anchors instead. The cage material for the proposed project is constructed with rigid and
durable materials (copper mesh net with a diameter of4 millimeter (mm) wire and 40 mm x 40 mm mesh square).
The mooring lines for the proposed project will be constructed of steel chain (50 mm thick) and thick rope (36
mm) that are attached to a floating cage that will rotate in the prevailing current direction; the ocean currents
will maintain the mooring rope and chain under tension during most times of operation, the bridle line that
connects from the swivel to the cage will be encased in a rigid pipe. Structural information showing the MAS
and pen, along with the tethered supporting vessel, is provided in Appendix A. The anchoring system for the
proposed project is being finalized by the applicant. While the drawings in Appendix A show concrete
deadweight anchors, it is likely that the final design will utilize appropriately sized embedment anchors instead.
Both anchor types are included for ESA consultation purposes.
The CopperNet cage design is flexible and self-adjusts to suit the constantly changing wave and current
conditions. As a result, the system can operate floating on the ocean surface or submerged within the water
column of the ocean; however, the normal operating condition of the cage is below the water surface. When a
storm approaches the area, the entire cage can be submerged by using a valve to flood the floatation system with
water. A buoy remains on the surface, marking the net pen's position and supporting the air hose. When the pen
approaches the bottom, the system can be maintained several meters above the sea floor. The cage system is
sable to rotate around the MAS and adjust to the currents while it is submerged and protected from storms near
the water surface. After storm events, the cage system is made buoyant, causing the system to rise to resume
normal operational conditions. The proposed project cage will have at least one properly functioning global
positioning system device to assist in locating the system in the event it is damaged or disconnected from the
mooring system.
In cooperation with the NtVIFS. a protected species monitoring plan (PSMP) has been developed for the proposed
action to protect all marine mammal, reptiles, sea birds, and other protected species. Monitoring will occur
throughout the life of the project and represents an important minimization measure to reduce the likelihood of
arty unforeseen potential injury to all protected species including ESA-listed marine animals. The data collected
will provide valuable insight to resource managers about potential interactions between aquaeulture operations
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and protected species. The PS VIP also contains important mitigative efforts such as suspending vessel transit
activities when a protected species comes within 100 meters (in) of the activity until thcaninial(s) leave the area.
The project staff will suspend all surface activities (including stocking fish, harvesting operations, and routine
maintenance operations) in the unlikely event that any protected species comes within 100 ni of the activity until
the animal leaves the area. Furthermore, should there be activity that results in an injury to protected species,
the on-site staff would follow the steps outlined in the PSMP and alert the appropriate experts for an active
entanglement.5
The below information about chemicals, drugs, cleaning, and solid waste provides supporting details about the
proposed project:
Chemicals: The proposed facility has indicated they would not be using toxic chemicals, cleaners, or solvents
at the proposed project. The proposed project would use small amounts of petroleum to run the generator.
Spills are unlikely to occur; however, if a spill did occur they would be small in nature.
Drugs: The applicant has indicated that FDA-approved antibiotics or other therapeutants will not likely be
used (within any feed or dosing the rearing water) during the proposed project.The need for drugs is
minimized by the strong currents expected at the proposed action area, the low fish culture density, the cage
material being used, and the constant movement of the cage.
Cleaning: The applicant does not anticipate the need to clean the cage for the short duration of the proposed
project. Should the cage system need cleaning, divers would manually scrub the cage surfaces with cleaning
brushes. No chemicals would be used while cleaning and any accumulated marine biological matter would
be relumed to sea without alteration.
Solid Wastes: The applicant will dispose of all solid waste appropriately on shore.
A PSMP has been developed by the applicant with assistance from the NMI-'S Protected Resources Dmstori. The purpose of"the PSMP is to
provide monitoring procedures and data collection efforts for species (marine mammals, sea tunic*, seabirds, or other species) protected under
the \1MP\ or ESA thai may be encountered at the proposed project.
'' The applicant is not expected to use arty drugs; however, in the unlikely circunvstanee that therapeutartt treatment is needed, three drucs
were provided to the liPA as potential candidates (hydrogen peroxide, oxyletraeycline dihydrate, and ilorfenieoS).
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4 J Proposed Action Area
The proposed project would be placed in the Gulf at an approximate water depth of 40 m (130 feet), and
generally located 45 miles southwest of Sarasota, Florida. The proposed facility will be placed within an area
that contains unconsolidated sediments that are 3 — 10 ft deep (sec Table 1). The applicant will select the specific
location within that area based on diver-assisted assessment ofthe sea lloor when the cage and anchoring system
are deployed. The proposed action area is a 1,000 m radius measured from the center ol the MAS.
The facilit\ potential locations were selected with assistance from NOAA's National Ocean Service National
Centers for Coastal Ocean Science (NCCOS). The applicant and the XCCOS conducted a site screening process
o\cr several months to identify an appropriate project site. Sonic of the criteria considered during the site
screening process included avoidance of corals, coral reefs, submerged aquatic vegetation, hard bottom habitats,
and avoidance of marine protected areas, marine reserves, and habitats of particular concern. This siting
assessment was conducted using the (.iulf AquaVlapper tool developed by NCCOS.
I'pon completion of the site screening process with the NCCOS, the applicant conducted a Baseline
l:n\ ironmcntai Survey (BHS) in August 201 S based on guidance developed by the NMl-'S and H1'A.S The BfS
included a geophysical investigation to characterize the sub-surface and surface geology ol the sites and identify
areas with a sufficient thickness of unconsolidated sediment near the surtace while also clearing the area ol am
geoha/ards and structures that would impede the implementation ot the aqiiaeulture operation. 1 he geophysical
survey for the proposed project consisted of collecting single beam bathymetry, side scan sonar, sub-bottom
profiler, and magnetometer data within the proposed area. The BFS report noted that were no physical,
biological, or archaeological features within the surveyed area that would preclude the siting of the proposed,
aqiiaeulture facility within the area shown in Table 1,
Table I: Target Area with 3' to 1®' of Unconsolidated Sediments
I (ic:ilii)ii
l.alitiuie
Longitude
Upper Right Comer
Lower Right Comer
Louver Left Corner
27° 7.61022' N
27° 6.77773" N
27"' 6.87631" N
. ¦ ;• -i:: w
83° 1 1.65678" W
83° 11.75379' W
83° 12.42032' W
7 The Gulf AquaMapper loot is available al: https^'coaslalscicnce.miaa.jinv'proclucls-expiorwi
* The BFS guidance document is. ;t\ailable at: h»tp:i •stro.nmft.miaa.gcw'susJairiahlc fisheries,1'Gulffishcries/aquaculturc/
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5 J Federally Listed and Proposed Threatened and Endangered Species a rid Critical Habitat
5.1 Federally Listed Threatened and Endangered Species
The action agencies identified the ESA-Iisted species shown in Table 2 for consideration on whether the
proposed action may affect protected species in or near the proposed action area. In summary, the action agencies
considered the potential affects to threatened and endangered species from five groups of species: birds (2), fish
(4), invertebrates (7), marine mammals (6), and reptiles (5). The action agencies considered the species within
this Section of the BE because they may occur within the project footprint or near enough such that there are
potential routes of effects. Certain ESA-listed species are not discussed because their behavior, range, habitat
preferences, or known/estimated location do not overlap or expose them to the activities within the proposed
action area
Table!: Federally Listed Species, Listed f "riticni Habitat. Proposed Species, and
Proposed Critical Habitat Considered for the Proposed Action
Species i onsidercd
I .S \ Statu*
{'riiic:il
Habitat Status
Potential l-Apo'iinv to
Proposed Action \rca
Birds



1 Piping Clover
Threatened
Yes

2 Red Knot
Threatened
No *
\i '
Fish



1 Giant .Manta Ray
Threatened
No
Yes
2 Nassau Grouper
Threatened
No
Yes
3 Oceanic Whitetip Shark
Threatened
No
Yes
4 Smalltooth Sawfish
Endangered
No
Yes
Invertebrates



1 Boulder Star Coral
Threatened
No
No
2 Llkhom Coral
Threatened
No
No
4 Mountainous Star Coral
Threatened
No
No
5 Pillar Coral
Threatened
No
No
7 Staghom Coral
Threatened
No
No
6 Rough Cactus Coral
Threatened
No
Yes
3 Lobed Star Coral
Threatened
No
Yes
Marine Mammals



1 Blue Whale
Hndangered
No
Yes
2 Bryde's Whale
Endangered
No
Yes
3 Fin Whale
Endangered
No
Yes
4 Humpback Whale
Endangered
No
Yes
5 Sei Whale
Endangered
No
Yes
6 Sperm Whale
Endangered
No
Yes
Reptiles



1 Green Sea Turtle
1 hrcatcncd
No
Yes
2 I lawksbill Sea Turtle
Hndangered
Yes
Yes
3 Kemp's Ridley Sea Turtle
Endangered
No
Yes
4 Leatherhack Sea Turtle
Endangered
Yes
Yes
5 Logperhead Sea Turtle
Threatened
Yes
Yes
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5.1.1	Birds
There arc 14 ESA-listcd avian species identified as threatened or endangered, previously delisted, or as candidate
species in the eastern Gulf. Of those species, only two listed species, the piping plover and red knot, are
considered in this BE because their migratory range could expose ihem to activities covered under the proposed
action. There are several other listed species whose range includes only inshore and coastal margin waters and
are not exposed to the activities covered under the proposed action.
Piping Plover
The piping plover is a threatened shorebird that inhabits coastal sandy beaches and mudflats. Three populations
of piping plover are recognized under FSA: Great Lakes (endangered); Great Plains (threatened); and Atlantic
(threatened) (BOHVI. 2012a). This species nests in sand depressions lined with pebbles, shells, or driflwood.
Piping plovers forage on small invertebrates along ocean beaches, on intertidal Hats, and along tidal pool edges;
therefore, fish from the proposed action are not considered a potential source of food for the piping plover.
Possibly as high as 75" o of all breeding piping plovers, regardless of population affiliation, may spend up to
eight months on wintering grounds in the Gulf. They arrive from July through September, leaving in late
February to migrate back to their breeding site.s (BOKM. 2012b). They do not breed in the Gulf. Habitat used
by wintering birds include beaches, mud flats, sand Hats, algal flats, and wash over passes (where breaks in sand
dunes result iti an inlet). The piping plover is considered a state species of conservation concern in all Gulf coast
states due to wintering habitat. The piping plover is it is a migratory shorebird with no open ocean habitat.
Red Knot
The red knot, listed as threatened in 2014, is a highly migratory shorebird species that travels between nesting
habitats in Arctic latitudes and southern non-breeding habitats in South America and the U.S. Atlantic and Gulf
coasts (BOEM, 2012a). Red knots forage along sandy beaches, tidal mudflats, salt marshes, and peat banks for
bivalves, gastropods, and crustaceans (I SI \\ S. 201 ?). Horseshoe crab egg> are a critical food resource for this
species, and the overharvesting and population declines of horseshoe crabs may be a major reason for the decline
of red knot numbers.
Wintering red knots may be found in Florida and Texas (Wursig, 2017). They are considered a State Species of
Conservation Concern in Florida and Mississippi. The numbers of wintering and staging red knots using coastal
beaches in Gulf coast states other than Florida have declined dramatically (Wursig, 2017). Its population has
exhibited a large decline in recent decades and is now estimated in the low ten-thousands (NatureServe. 2010)
Critical habitat rules have not been published for the red knot. Within the Gulf region, wintering red knots are
found primarily in Florida, but this species has been reported in coastal counties of each of the Gulf states.
5.1.2	Fish
The four species of ESA-protected fish that may occur within the action area are: giant manta ray, nassau
grouper, smalltooth sawfish, and oceanic whitetip shark.
Giant Manta Ray
The giant manta ray was listed as threatened under the F.SA on February 21. 201X. The giant mania ray is found
worldwide in tropical, subtropical, and temperate seas. These slow-growing, migratory animals are circumglobal
with fragmented populations. The giant manta ray is the largest living ray, with a wingspan reaching a width of
up to 9 m. Mania species are distinguished from other rays in that they tend to be larger with a terminal mouth,
and have long cephalic lobes (Evgeny, 2010). which are extensions of the pectoral ftns that funnel water into
the mouth. Giant mania rays Iced primarily on planklonic organisms such as cuphauMids. eopepods, mysids,
decapod larvae and shrimp, but some studies have noted their consumption of small and moderately sized fishes
(Miller and Klimovich, 2017).
Within the Southeast Region of the United States, the giant manta ray is frequently sighted along the east coast
and within the Gulf of Mexico. Giant manta rays are seasonal visitors along productive coastlines with regular
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upwelling, in oceanic island groups, and near offshore pinnacles and seamounts. Given the opportunistic
sightings of the species, researchers arc still unsure what drives giant manta rays to certain areas and not others
(and where they go for the remainder of the time). The timing of these visits varies by region and seems to
correspond with the movement of zooplankton, current circulation and tidal patterns, seasonal upwelling,
scawater temperature, and possibly mating behavior. Although giant manta rays are considered oceanic and
solitary, they have been observ ed congregating at cleaning sites at offshore reefs and feeding in shallow waters
during the day at depths less than 10 m (O'Shea et a!., 2010; Marshall et al.. 2011: Rohncr et al,, 2013). The
giant manta ray ranges from near shore to pelagic habitats, occurring over the continental shelf near reef habitats
and offshore islands. The species can be found in estuarinc waters near oceanic inlets, with use of these waters
as potential nursery grounds. This species appears to exhibit a high degree of plasticity in terms of their use of
depths within their habitat.
Nassau Grouper
The Nassau grouper is a reef fish typically associated with hard structure such as reefs (both natural and
artificial), rocks, and ledges. It is a member of the family Scrranidae. which includes groupers valued as a major
fishery resource such as the gag grouper and the red grouper. These large fish are found in tropical and
subtropical waters of southern coastal Florida and the Florida Keys, Nassau grouper arc generally absent from
the Gulf north and outside of the Florida Keys; this is well documented by the lack of records in Florida Fish
and Wildlife Conservation Commission's, Fisheries Independent Monitoring data, as well as various surveys
conducted by NO A A Fisheries Southeast Fisheries Science Center, There has been one verified report of the
Nassau Grouper in the northwest Gulf at Flower Gardens Bank national marine sanctuary; however, the Flowers
Gardens Bank is not near the proposed action area.
Oceanic White!ip Shark
The oceanic whitetip shark is a large open ocean highly migratory apex predatory shark found in subtropical
waters throughout the Gulf. It is a pelagic species usually found offshore in the open ocean, on the outer
continental shelf, or around oceanic islands in deep water greater than 184 m. The oceanic whitetip shark can
be found from the surface to at least 152 m depth. Occasionally, it is found close to land in waters as shallow as
37 in. mainly around mid-ocean islands or in areas where the continental shelf is narrow with access to nearby
deep water. Oceanic whitetip sharks have a strong preference for the surface mixed layer in warm waters above
20°C and arc therefore mainly a surface-dwelling shark.
Oceanic whitetip sharks are high trophic-level predators in open ocean ecosystems feeding mainly on teleosts
and cephalopods (Backus et al., 1956; Bon III et al.. 2008); however, some studies have found that they consume
sea birds, marine mammals, other sharks and rays, mollusks, crustaceans, and even garbage (Compagno, 1984;
Cortes, 1994),
Smalltooth Sawfish
The smalliooth sawfish was the first marine fish to receive protection as an endangered species under the ESA
in 2003. Their current range is poorly understood but believed to have significantly contracted front these
historical areas. Today, smalltooth sawfish primarily occur tillpeninsular Florida from the Calloosahtchec River
to the Florida Keys (Wiirsig. 2017). Historical accounts and recent encounters suggest immature individuals are
most common in shallow coastal waters less than 25 m (Bigelow and Schroeder. 1953; Adams and Wilson.
1995). Smalltooth sawfish primarily live in shallow coastal waters near river mouths, estuaries, bays, or depths
up to 125 m. Smalltooth sawfish feed primarily on fish. Mullet, jacks, and ladyfish arc believed to be their
primary food resources (Simpfendorfer, 2001). Smalltooth sawfish also prey on crustaceans (mostly shrimp and
crabs) by disturbing bottom sediment with their saw (Norman and Frascr. 1938; Bigelow and Schroeder. 1953).
5.1.3 Inv ertchrates
The seven F.SA-ltsted coral species in the Gulf are known to occur near the Dry Tortugas. a small group of
islands located approximately 67 miles west of Key West, Florida. Four of the ESA-listed coral species in the
Gulf (elkhom. lobed star, mountainous star, and boulder star) arc known to occur in the Flower Banks National
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Marine Sanctuary, located 70 to 115 miles off the coast of Texas and Louisiana. The most abundant depth ranges
for the ESA-listcd invertebrates arc provided in Table 3. Given the known geographic locations of the considered
coral species and their recognized habitat preferences related to water depth, only two invertebrate species (lobed
star coral and rough cactus coral) may occur in the proposed action area. Threats to coral communities
throughout the Gulf include predation. hurricane damage, and loss of habitat due to algal overgrowth and
sedimentation.
Table 3: ESA-Iisted Coral Depth Ranges
Coral Spfi-K's	Mom AIhuuJuih Ikpth (ft)
Boulder Star Coral	3 - 82
Hlkhoni Coral	3-16 10
Lobed Star Coral	6 - 130 ;;
Mountainous Star Coral	3 - 30 '1
Pillar Coral	3 - 90
Rough Cactus Coral	15 - 270 10
Slaghom Coral 	15 - 60 10		
5.1.4 Marine Mammals
All the ESA-lisied marine mammals considered in this BE arc endangered tinder the ESA. The six species of
whales that could occur within the action area arc; blue whale, fin whale. Gulf Bryde's whale, humpback whale,
sperm whale, and sei whale; however, except for the Gulf Bryde's whale, each ESA-listcd whale considered in
this BE are not common in the Gulf (Wiirsig. 2017). Threats to whales from aquaculture facilities include vessel
strikes, entanglement, and disturbance (ocean noise}.
Blue Whales
Blue whales are found in all oceans except the Arctic Ocean. Currently, there are five recognized subspecies of
blue whales. Blue whales have been sighted infrequently in the Gulf. The only record of blue whales in the Gulf
arc two brandings on the Louisiana and Te\a» coasts; however, the identifications for both strandings arc
questionable. In the North Atlantic blue whales are most often seen off eastern Canada where they are present
year-round (NMES, 2016). Blue whales also typically occur in deeper waters seaward of the continental shelf
and are not commonly observed in the waters of the Gulf or off the U.S. East Coast (C'eTAP, 1982; Wenzcl et
al,, 19K8; Waring et al.. 2006). Blue whales arc not expected to be within the proposed action area that is located
in a water depth of approximately 40 m.
Bryde's Whale
The Gulf Bryde's whale was listed as endangered on May 15, 2019. The Gulf Bryde's whales are members of
the baleen whale family and are a subspecies of the Bryde's whale. The Gulf Bryde's whales are one of the most
endangered whales in the world, with likely less than 100 whales remaining. They are the only resident baleen
whale in the Gulf. The Gulf Bryde's whale is one of the few types of baleen whales that do not migrate and
remain in the Gulf year-round. The historical range in Gulf waters is not well known; however, scientists believe
that the historical distribution of Gulf Bryde's whales once encompassed the north-central and southern Gulf.
For the past 25 years, Bryde's whales in U.S. waters of the Gulf have been consistently located in the
northeastern Gulf (largely south of Alabama and the western part of the Florida panhandle) along the continental
shelf break between the 100 and 400 m depth (Labrecque et al., 2015). This area has been identified as a
Biologically Important Area (BIA) for the Gulf Bryde's whale and encompasses over 5.8 million acres. BIAs
are reproductive areas, feeding areas, migratory corridors, or areas in which small and resident populations are
" www.DCNANaluic.org, 2016
MMFS, 2016
n www.UK"NReilLiM.org, 2016
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concentrated The proposed action area is not located near the areas where the Gulf Brvde's whale is known to
be distributed and are not expected to occur at the water depth of the proposed project.
Fin Whales
Fin whales are found in deep, offshore waters of all the world's oceans, primarily in temperate to polar climates.
The NMFS has reported that the are about 2.700 fin whales in the North Atlantic and Gulf. There are few reliable
reports of fin whales in the northern Guif. They are most commonly found in North Atlantic wfaters where they
feed on krill. small schooling fish, and squid (NMFS, 2016). Fin whales are generally found along the 100 m
isobath with sightings also spread over deeper water including canyons along the shelf break {Waring et af,
2006). Therefore, fin whales are not expected to be found near the proposed action area where the water depth
is approximately 40 m.
Humpback W hales
Based on a few con finned sightings and one stranding event, humpback whales arc rare in the northern Gulf
(BOHM. 2012a). Baleen whale richness in the Gulf is believed to be less than previously understood {Wiirsig.
2017). U.S. populations of humpback whales mainly use the western North Atlantic for feeding grounds and use
the West Indies during winter and for calving (NMFS. 2016). Given that humpback whales are not a typical
inhabitant of the Gulf, they are not expected to be in found near the proposed action area Additionally, the water
depth at the proposed action area (40 m) does not overlap to the habitat preference of humpback whales for
deeper waters.
Sei Whales
The sei whale is rare in the northern Gulf and its occurrence is considered accidental, based on four reliable and
one questionable standings records in Louisiana and Florida (Jefferson and Schiro, 1997, Schmidley, 2004;
Wiirsig, 2017). Sci whales are more commonly found in subtropical to subpolar waters of the continental shelf
and slope of the Atlantic, with movement between the climates according to seasons (NMFS. 2016). Sei whales
typically occur in deeper waters seaward of the continental shelf and are not commonly observed in the waters
of the Gulf (CeTAP. 1982; Wen/el et al. 1988; Waring et al., 2006). Sei whales arc not expected to he
geographically located near the proposed project.
Sperm Whales
In the northern Gulf, aerial and ship surveys indicate that sperm whales arc widely distributed and present in all
seasons in continental slope and oceanic waters. Sperm whales arc the most abundant large cetacean in the Gulf.
Greatest densities of sperm whales are in the central Northern Gulf near Desoto Canyon as well as near the Dry
Torlugas (Roberts et al, 2016). They are found in deep waters throughout the world's oceans, but generally in
waters greater than 200 to 800 m due to the habit of feeding on deep-diving squid and fish (Hansen et al,, 1996;
Davis et al., 2002; Mullin and Fulling, 2003; Wiirsig, 2017). Research conducted since 2000 confirms that Gulf
sperm whales constitute a distinct stock based on several lines of evidence (Waring et al., 2006). Sperm whales
arc not expected to be within the proposed action area due to their known preference for deeper water.
5.1.5 Reptiles
The five ESA-listed sea turtle species that may occur in or near the proposed action area are; green, hawksbill.
leatherback, kemp's rid ley, and loggerhead. Sea turtles are highly migratory and travel widely throughout the
Gulf. Therefore, each sea turtle has the potential to occur throughout the entire Gulf. In general, the entire Gulf
coastal and nearshore area can serve as habitat for marine turtles. Florida is the most important nesting area in
the United States for loggerhead, green, and leatherback turtles. Several volumes exist that cover the biology
and ecology of these species (i.e . Lutz and Musiek, 1997; Lutz et al., 2003, Wynekan et al., 2013).
Green sea turtle
Green sea turtle hatehlings are thought to occupy pelagic areas of the open ocean and are often associated with
Stirxtmum rafts (Carr, 1987; Walker, 1994). Pelagic stage green sea turtles arc thought to be carnivorous.
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Stomach samples of these animals found ctcnophores and pelagic snails (Frick, 1976; Hughes, 1974). At
approximately 20 to 25 centimeters (cm) carapace length, juveniles migrate from pelagic habitats to benthic
loraging areas (Bjorndal. 1997). As juveniles nunc into benlhic foraying areas a diet shift towards hcrbivnrv
occurs. Thcv consume primarily seagrasses and algae, but arc also known to consume jellyfish, salps. and
sponges (Bjorndal, 1980. 1997; Paretics. 1969; Mortimer, 1981, 19X2). The diving abilities of all sea turtle
species vary by their life stages. The maximum diving range of green sea turtles is estimated at 110 in (Frick,
1976). but they are most frequently making dives of less than 20 m (Walker, 1994). The time of these dives also
varies by life stage.
The NMFS and USFWS removed the range-wide and breeding population FSA listings of the green sen turtle
and listed eight distinct population segments (I)PSs) as threatened and three DPSs as endangered, effective May
(\ Two of the green sea turtle DPSs. the North Atlantic [DPS and the South Atlantic DPS. occur in the
Gulf. The proposed action area is within die North Atlantic NFS where the green sea turtle is listed as threatened.
Man ksbill sea turtle
The hawksbill sea turtle's pelagic stage lasts from the time they leave the nesting beach as hatchlings until they
are approximately 22 to 25 cm in straight carapace length (Mcylan, 1988; Mcylan and Donnelly. 1999). The
pelagic stage is followed by residency in developmental habitats (foraging areas where juveniles reside and
growl in coastal waters. Little is known about the diet of pelagic stage hawksbilis. Adult foraging typically
occurs over coral reefs, although other hard-bottom communities and mangrove-fringed areas are occupied
occasionally. Hawksbilis show fidelity to their foraging areas over several years (van Dam and Die/, 1998). The
hawksbill's diet is highly specialized and consists primarily of sponges (Mcylan, 1988). Gravid females have
been noted ingesting coralline substrate (Mcylan, 1984) and calcareous algae (Andercs, Alvarez, and Uehida,
1994J, which are believed to be possible sources of calcium to aid in eggshell production. The maximum diving
dcpihs of these animals are unknown, but the maximum length of dives is estimated at 73.5 minutes, more
routinely dives last about 56 minutes (Hughes, 1974). Hawksbill sea turtles are not known to regularly nest in
Florida but do occur occasionally.
Kemp's Ridley sea turtle
Kemp's rid Icy sea turtle hatchlings are also pelagic during the early stages of life and feed in surface waters
(Can*, 1987; Ogrcn, 1989). After the juveniles reach approximately 20 cm carapace length they move to
relatively shallow (less than 50 m) benthic foraging habitat over unconsolidated substrates (Marqucz-M., 1994).
Thc\ have also been ohser\ed transiting long distances hclueen foraging habitats (Ogrcn. 19X9). Kemp's ridteys
feeding in these ncarshore areas primarily prey on crabs, though they arc also known to ingest mollusks. fish,
marine vegetation, and shrimp (Shaver, 1991). The fish and shrimp Kemp's rid leys ingest are not thought to be
a primary prey item but instead may be scavenged opportunistically from bycatch discards or discarded bait
(Shaver, 1991). Given their predilection for shallower water, Kemp's ridlcys most routinely make dives of 50
m or less (Soma, 1985; Byles, 1988). Their maximum diving range is unknown. Depending on the life stage, a
Kemp's ridley may be able to stay submerged anywhere from 167 minutes to 300 minutes, though dives of 12.7
minutes to 16.7 minutes are much more common (Soma, 1985; Mcndonca and Pritchard, 1986; Byles,
1988), Kemp's ridley turtles may also spend as much as 96 percent of their time underwater (Soma, 1985; Byles,
1988). In the United States, Kemp's ridley turtles inhabit the Gulf and northwest Atlantic Ocean; nesting occurs
primarily in Texas, and occasionally in Florida. Alabama, Georgia, South Carolina, and North Carolina.
Leafherback sea turtle
l.catherback sea turtles arc the most pelagic of all ESA-listcd sea turtles and spend most of their time in the open
ocean. They will enter coastal waters and are seen over the continental shelf on a seasonal basis to feed in areas
where jellyfish are concentrated. 1	eatherbaeks feed primarily on cnidarians (medusae, siphonophores) and
lunieates. Unlike other sea turtles. Icatherbacks' diets do not shift during their life cycles. Because loathcrbacks"
ability to capture and cat jellyfish is not constrained by size or age, they continue to feed on these species
regardless of life stage (Bjorndal, 1997). Lcatherbacks are the deepest diving of all sea turtles. It is estimated
that these species can dive more than 1,000 m (Eckert et at., 1989) but more frequently dive to depths of 50 in
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to 84 in (Eekcrt ct al. 1986). Dive times range from a maximum of 37 minutes to more routines dives of 4 to
14.5 minutes (Standora ct al., 1984; Kekert et al.. 1986; Kckert ct al, 19X9; Keinath and Musick. 1993).
Loggerhead sea turtle
Loggerhead sea turtle hatchlings forage in the open ocean and are often associated with Sargassum rafts
(Hughes. 1974: Carr 19S7; Walker. 1944; Boltcn and Bala/v 1995). The pelagic Mage ofthe^e sea lurlles are
known to eat a wide range of things including salps, jellyfish, amphipods. crabs, svngnathid fish, squid, and
pelagic snails (Brongersma, 1972). Stranding records indicate that when pelagic immature loggerheads reach 40
to 60 cm straight-line carapace length, they begin to live in coastal inshore and nearshore waters of the
continental shelf throughout the U.S. Atlantic (Wilzcll, 2002). Loggerhead sea turtles forage over hard-bottom
and soft-bottom habitats (Carr, 1986).
Benthic foraging loggerheads eat a variety of invertebrates with crabs and mollusks being an important prey
source (Burke et a!., 1993). Estimates of the maximum diving depths of loggerheads range from 211 m to 233
m (Thayer et al., 1984; Limpus and Nichols, 1988). The lengths of loggerhead dives arc frequently between 17
and 30 minutes (Thayer et at.. 1984; Limpus and Nichols. 19KX; Limpus and Nichols, 1994; I .an von et al., 1989)
and they may spend anywhere from 80 to 94 percent of their time submerged {Limpus and Nichols, 1994;
L an yon el al., 1989). Loggerhead sea turtles are a long-lived, slow-growing species, vulnerable to various threats
including alterations to beaches, vessel strikes, and byeateh in fishing nets.
5.2	Federally Listed Critical Habitat In or Near the Action Area
5.2.1	Birds
Onshore critical habitat has been designated for the piping plover including designations for coastal wintering
habitat areas in Alabama. Mississippi, and Florida.'2 The proposed project is not expected to impact any onshore
habitats.
5.2.2	Reptiles
The only critical habitat designated near the proposed action area is the Northwest Atlantic DPS of loggerhead
sea turtles. Specific areas of designated habitat include: nearshore reproductive habitat, winter area, breeding
areas, migrator}' corridors, and Sargassum habitat. The northwest Atlantic loggerhead DPS designated critical
habitat portion that occurs in federal waters {i.e., a Sargasso habitat unit) consists of the western Gulf to the
eastern edge of the loop current, through the Straits of Florida and along the Atlantic coast from the western
edge of the Gulf Stream eastward. Sargassum habitat is home to most juvenile sea turtles in the western Gulf.
5.3	Federal Proposed Species and Proposed Critical Habitat
The action agencies did not identify any Fedcr dl> listed proposed species or proposed critical habitat in the
proposed action area.
11 Critical habitat locations for the piping plover are available at: https://ccos.fws.gov/ecp0/protile/spccicsProf1Ie7spcode-B079
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6,0 Potential Stressors to Listed and Proposed Species aid Critical Habitat
I he action agencies ev aluated the potential impacts of the proposed project on ESA-listed species that were
identified in Section 5.0 and that may occur in or near the proposed action area. Potential effects considered in
this analysis may occur because of a potential overlap between the proposed aquaculture facility location with
the species habitat (socialization, feeding, resting, breeding, etc.) or migratory route. Section 6.0 broadly
de>cribcs ihe most likeh stressors, directly and indirectly, that were considered to potentially impact the species
near the proposed facility. The action agencies identified four categories of risks from the proposed project;
disturbance; entanglement; vessel collisions; and impacts from water qualify. The specific analysis of potential
impacts to each species from the proposed project is provided in Section 7.0.
6.1	Disturbance
Disturbance in the context of this BE includes ocean noise (low-frequency underwater noises) and breakage
(invertebrates). Underwater noises can interrupt the normal behavior of whales, which rely on sound to
communicate. As ocean noise increases from human sources, communication space decreases and whales cannot
hear each other, or discern other signals in their environment as they used to in an undisturbed ocean. Different
levels of sound can disturb important activities, such as feeding, migrating, and socializing. Mounting evidence
ironi scientific research has documented thai ocean noise also causes marine mammals lo change the frequency
or amplitude of calls, decrease foraging behavior, become displaced from preferred habitat, or increase the level
of stress hormones in their bodies. Loud noise can cause permanent or temporary hearing loss. Underwater noise
threatens whale populations, interrupting their normal behavior and driving them away from areas important to
their survival. Increasing evidence suggests that exposure to intense underwater sound in some settings may
cause some whales to strand and ultimately die.
ESA-listed sea turtles, whales, and tish may experience stress due to a startled reaction should they encounter
vessels, or vessel noise, at the proposed location or in transit to the proposed project site. The reaction could
range from the animal approaching and investigating the activity, to the opposite reaction of flight, where the
animal could injure itself while attempting to flee. The most likely source of disturbance from the proposed
aquaculture activity would be noise from the vessel engines and barge generator.
6.2	Entanglements
Entanglement, for the purposes of this BE, refers to the wrapping of lines, netting, or other man-made materials
around the body ot a listed species. Entanglement can result in restrainment and/or capture to the point where
harassment, injury, or death occurs. The cage, mooring lines, and bridles from the proposed project may pose
an entanglement risk to listed species in the project area; however, entanglement risks to ESA-listed species at
any aquaculture operation are mitigated by using rigid and durable cage materials, and by keeping all facility
lines taut as slack lines are the primary source of entanglements (Nash et al., 2005).
Past protected species reviews by the NMFS for a similar scale aquaculture project determined thai cetacean and
sea turtle entanglement is not expected when facility mooring and tether lines arc kept under near-constant
tension and free ot loops {NMf-S, 2016). Additionally, the NMFS determined that a similar aquaculture project
had the potential to result in interactions with marine mammals; however, the NMFS found that the most likely
effect oJ the project on marine mammals was behavioral interactions (e.g.. individuals engaging in investigative
behavior around the array or that prey on wild fish accumulated near the facility) as opposed to causing injury
or mortality from entanglement.
6.3	Vessel Strike
A vessel strike is a collision between any type ot boat and a marine animal in the ocean. All sizes and types of
vessels have the potential to collide with nearly any marine species. Strikes can result in death or injury to the
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marine animal and may go unnoticed by the vessel operator. Some marine species spend short durations "rafting"
at the ocean's water surface between dives which makes them more vulnerable to vessel strikes.
The NMFS estimates collisions between some cetaceans and vessels are relatively rare events based on data
from Marine Mammal Stock Assessments for the Atlantic and Gulf (NMFS, 2017). Collisions between marine
mammals and vessels can be further minimized when \essels travel at less than 10 knots based on genera!
guidance from the NMFS for \essels tiansitingareas where there are known populations ofu hales (HIHW NMS,
2011». Detection of sea turtles by vessel operators may be more difficult because most vessel operators usually
sight protected species and avoid them. In past biological opinions in support of similar aquaculture activities,
the NMFS has determined that the rate of collisions between sea turtles and vessels was negligible and did not
expect sea turtle vessel strikes to occur (NMFS. 2016).
The support vessel used for the proposed project is expected to be vigilant against the possibility of protected
species collisions. Piloting of all vessels associated with the proposed project will be done in a manner that will
prevent vessel collisions or serious injuries to protected species. Operators and crew will operate vessels at low-
speeds when performing work within and around the proposed project area and operate only when there are no
small craft advisories in effect. All vessels are expected to follow the vessel strike and avoidance measures that
have been developed by the NMFS.15 These operating conditions are expected to allow vessel operators the
ability to detect and avoid striking FSA-listed species.
6.4 Water Qualify
Although offshore marine cage systems do not generate a waste stream like other aquaculture systems, effluent
from the proposed action area can adversely affect water quality, sea floor sediment composition, and benthic
fauna though the additions of uneaten feed, ammonia excretions, and fish feces from the increased fish biomass.
Water quality in aquaculture is primarily assessed through measures of nitrogen (N), phosphorus (P). solids
(total suspended solids, scttleable solids, and turbidity), dissolved oxygen (DO), and pl l. The increased amount
of organic material has the potential to increase N, F, and solids levels in the surrounding waters. The
concentration of N (such as total nitrogen, ammonia, nitrate, nitrite) and P (as total phosphorus or
orthophosphate) are indicators of nutrient enrichment and arc commonly used to assess the impact of aquaculture
on water quality. The release of nutrients, reductions in concentrations of DO, and the accumulation of sediments
under certain aquaculture operations can affect the local environment by boosting overall productivity in
phytoplankton and macroalgal production in marine ecosystems through eutrophication and degradation of
benthic communities (Stickney. 2002).
According to Marine Cage Culture and The Environment (Price and Morris. 2013), "there are usually no
measurable effects 30 meters beyond the cages when the farms are sited in well-Hushed water. Nutrient spikes
and declines in dissolved oxygen sometimes are seen following feeding events, but there are few reports of long-
term risk to water quality from marine aquaculture." Price and Morris (2013) also considered the benthic effects
of Marine Cage Culture and found that "well-managed farms may exhibit little perturbation and, where chemical
changes are measured, impacts arc typically confined to within 100 meters of the cages. Benthic chemical
recovery is often rapid following harvest". Conversely, poorly managed farms or heavily farmed areas, can see
anaerobic conditions persisting and extending hundreds of meters beyond the aquaculture facility. Changes in
water quality associated with commercial scale marine aquaculture facilities can be measurable downstream for
approximately 205 m (Nash et al., 2005).
The NCCOS reviewed global siting data to identify aquaculture site characteristics that are best suited for water
quality protection, concluding that, "Protection of water quality will he best achieved by siting farms in well-
n "Flic NMFS has determined that collisions with any \e>sd can injure or kill protected species (e.g., endangered and threatened species, and
marine mammals). The vessel strike avoidance guidelines developed by the NMFS are the standard measures that should be implemented in
reduce the risk associated with \essel striken or disturbance of these protected species to discountable levels. NMFS Southeasl Region Vessel
Strike Avoidance Measures and Reporting lor Manners; revised February lOfJK.
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flushed waters." (Price, 2013). The hydrology near the proposed action area has powerful and mixing ocean
currents that would constantly flush and dilute particulate and dissolved wastes. In addition, the proposed action
has other attributes cited in this study that contributes to decrease water quality impacts, including deep waters
and a sand bottom type. Neither particulates nor dissolved metabolites are expected to accumulate due to a low
fish production le\ els and the near constant flushing ofihe cage by strong offshore currents that dissipate wastes.
The EPA evaluated the proposed action's potential impacts to water quality, impacts of organic enrichment to
the sea floor, and impacts to benthie communities from organic enrichment as required by the Sections 402 and
403 of the CWA. The EPA determined that discharges from the proposed facility are not expected to exceed
federally recommended water quality criteria; that the discharged material is not sufficient to pose a
environmental threat through sea floor bioaccumulation; and the potential for benthie impacts from the proposed
project are minimal.14 Additionally, the EPA considered recent environmental modeling performed by the
NMFS for a similar small scale aquaculture facility (Velella Delta).1- NCCOS concluded that there arc minimal
risks to water column or benthie ecology functions in the subject area from the operation of the fish cage as
described in the applicant's proposal. Furthermore, EPA reviewed the previous and current environmental
monitoring data collected from a commercial-scale marine aquaculture facility, Blue Ocean Maricullurc (BOM),
in Hawaii raising the same fish species.16 While the size of the proposed project is significantly smaller than the
BOM commercial-scale facility and BOM is in slightly deeper waters, the results show that soluble and
paniculate nutrients from the BOM facility do not substantially affect the marine environment. Based on HPA's
analysis, as well as a review and comparison of representative water quality information, the proposed action
would not likely raise particulate and dissolved nutrient concentrations in the proposed action area.
The proposed facility will be covered by a NPDES permit as an aquatic animal production facility with protective
conditions required b\ the (lean Water Act. The NPDES permit will contain conditions that will confirm IiPA's
determination and ensure no significant environmental impacts will occur from the proposed project. The
aquaculfure-speeific water quality conditions placed in the NPDES permit will generally include a
comprehensive environmental monitoring plan. The applicant will be required to monitor and sample certain
water quality, sediment, and benthie parameters at a background (up-current) location and near the cage.
Additionally, the NPDES permit will include effluent limitations expressed a;> best management practices
(BMPs) for feed managment, waste collection and disposal, harvest discharge, carcass removal, materials
storage, maintenance, record keeping, and training. Impacts to water quality will be reduced by a range of
operational measures through the implementation of project-specific BMPs. For example, feeding will always
be monitored to ensure fish are fed at levels just below satiation to limit overfeeding and decrease the amount
of organic material that is introduced into the marine environment. Moreover, the Essential Fish Habitat
assessment requires certain mitigation measures within the NPDES and Section 10 permits.17
Further information about FPA's analysis and determination for impacts to water qualilv, seafUw. and benthie habitat can be found in Hie
final NPDES penmi and the Ocean Discharge Criteria lODfl Evaluation, as well as other supporting documents for the NPDLS permit such
.is the hssential Fish Habitat Assessment and the NbPA evaluation.
' The NCO >S previously produced models to assess the potential environmental effects on water quality and benthie communities for the
applicant's Velella Delta protect that is similar Velella iipsikm m terms of fish production (approximately 120,000 lbs|, operation duration,
and cultured species; however, the water depth was dissimilar between the two projects lb.000 11 \v 130 ft). At maximum capacity, NCCOS
determined there were no risks to water quality from the Velella Delta project, and only insignificant effects would occur in the water column
down to 1I» feet. Because of the great depth, strong eurrenis, and physical oecano graphic nature of the Velella Delta site, dissolved wastes
would be widely dispersed and assimilated by the plaoktomc community. Furthermore, the model results showed that benthie impacts and
accumulation of particulate wastes would not be detectable through measurement of organic carbon or mfannal community biodiversity
Water quality information from a Blue Ocean MariculUnc (BOM) facility m Hawaii was reviewed as representative data and compared to
the proposed project. The BOM farm pre<. tousiy produced approximately 950,00(1 lbs 'yr prior to 2014 and has produced up to 2,400.001) lbs yr
alter 2014, The BOM facility is m a similar depth of waler as the proposed project with an average depth of Ml m. Over eight years of
cornpahensu e water quality and benthie monitoring, the BOM facility has not adversely impacted water quality outside of the mixing /one at
the facility (BOM. 20141
The EPA and the USACT: will require mitigation measures to he incorporated into the NPDES permit to avoid or limit organic enrichment
ami physical impacts to habitat that may support associated hardbottom biological eommuniiies, 'the NPDKS permit will require facility to be
positioned at least 500 meters from any hardbottom habitat; the DA permit will not authorize the anchor system to be placed on vegetated
and or hardbottom habilat
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The 1'PA also considered the potential waiu qu-dity impacts from chemical spills, drags, cleaning, and solid
v. astes.
Chemical Spills; Spills are unlikely to occur; however, if a spill did occur they would be small in nature and
dissipate rapidly due to strong currents in the project area. The terms and conditions of the NPDES permit
would require the applicant to follow operational procedures (i.e. BMPs) that minimize the risk of wastes
and discharges that may affect any ESA-listcd species or habitat. The risk of accidental fuel or oil spills into
the marine environment is minimized by the support vessel not being operated during any time thai a small
craft advisory is in effect at the proposed facility.
Drugs: The applicant indicated that FDA-approved antibiotics or other therapeutants will not likely be used
during the proposed project due to the strong currents expected at the proposed action area, the low fish
culture density, and the cage material being used. In the unlikely event that drags/therapeutants are used,
administration of drugs will be performed under the control of a licensed veterinarian and only FDA-
approved therapeutants for aquaculturc would be used as required by federal law. In addition, the NPDES
permit will require that the use of any medicinal products be reported to the EPA, including therapeutics,
antibiotics, and other treatments. The report will include types and amounts of medicinal product used and
the duration they were used. The EPA does not expect the project to a cause a measurable degradation in
water quality from drags that may affect any HSA-hsted species.
Cleaning: Another potential source of water quality impacts would be from the cleaning of the cage system.
The applicant does not anticipate the need to clean the cage for the short duration of the proposed project.
Experience from previous trials by the applicant demonstrated that copper alloy mesh material used for the
cage is resistant to fouling. Should the cage system need cleaning, divers would manually scrub the cage
surfaces with cleaning brushes. No chemicals would be used while cleaning and any accumulated marine
biological matter would be relumed to sea without alteration.
Solid Wastes: Multiple federal laws and regulations strictly regulate the discharge of oil, garbage, waste,
plastics, and hazardous substances into ocean waters. The N'PDHS permit prohibits the discharge of any
solid material not in compliance with the permit.
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7.0' Potential Effects of Action
I inder the FSA. "effects of the action" means the direct and indirect effects of an action on the listed species or
critical habitat, together with the effects of other acli\ilies that arc interrelated or interdependent with that action
(50 Cl-K S 402.02). The NMFS and L'SFYVS standard for making a "no effect" finding is appropriate when an
action agency determines its proposed action will riot affect that ESA-listed species or critical habitat, directly
or indirectly (USFWS and NMFS. 1 W8>. (ieneraily. a "no elTect" determination mcaih that FSA-lisied species
or critical habitats will not be exposed to any potentially harmful,beneficial elements of the action (NMFS,
2014).
The applicable standard to find that a proposed action "may affect, but not likely to adversely affect" (Nl.AA)
listed species or critical habitat is that all the effects of the action are expected to be discountable, insignificant,
or completely beneficial. Insignificant effects relate to the size of the impact and should never reach the scale
where take occurs. Discountable effects are those extremely unlikely to occur. Beneficial effects arc
contemporaneous positive effects without any adverse effects to the species or critical habitat.
A smnniarv ol the potential effects considered and the determination of impact for each listed species and critical
habitat is provided in Table 4. Overall, potential impacts to the ESA-listed species considered in this BE are
expected lo be extremely unlikely and insignificant due to the small size of the facility, the short deployment
period, unique operational characteristics, lack of geographic overlap with habitat or known migratory routes,
or other factors that are described in the below sections for eaeh species. The federal action agencies used
multiple sources to support the determinations described within this section including the analysis of potential
impacts that the NMFS used as the basis for its HSA determination for up to 20 commercial scale offshore
marine aquaculUire facilities in the Gulf (HPA. 2016; NMFS. 2009; NMfS. 2013; NMFS. 2015; NMFS. 2(11 ft).
7,1 Federally Listed Threatened ami I nd inured Species
7.1.1	Birds
The action agencies did nol consider an\ potential threats to FSA-protecled birds from the proposed project.
The two species of birds considered are not expected to interact with the proposed project due to the distance
between the proposed project from shore (approximately 45 miles) to their onshore habitat preferences. The
piping plover and red knot are migrator)' sltorebirds. Known migratory routes do not overlap with the proposed
project. Both birds primarily inhabit coastal sandy beaches and mudflats of the Gulf; migration and wintering
habitat are in iinertidal marine habitats such as eoaMal inlets, estuaries, and hays (l/SFWS. 2015). Additionally
the normal operating condition of the cage is expected to be below the water surface which will further decrease
the likelihood of any bird interaction with the proposed project,
"1 he I.SA-listed bird species will not be exposed to any potentially harmful impacts of the proposed action. The
action agencies have determined that the activities under the proposed project will have no effect on the
threatened species of birds.
7.1.2	Fish
The action agencies considered disturbance, entanglement {for smalltooth sawfish only), and water quality as
potential impacts to endangered or threatened fish from the proposed project in the rare event that interaction
occurs.
Impacts from disturbance, entanglement, and water quality are highly unlikely for each HSA-iisted fish species
that was considered given their unique habitat preferences and known proximity to the proposed action area.
The oceanic whitelip shark is not likely to occur near the proposed project given its preference for deeper waters.
The action agencies believe that the Nassau grouper will not be present given that it is absent from the Gulf
outside of the Florida Keys. Interactions with smalltooth sawfish with the proposed project is extremely unlikely
because they primarily occur in the Gulf off peninsular Florida and are most common off Southwest Florida. The
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giant mama ray may encounter the facility given its migrator)' patterns; however, disturbance is not expected
because the facility is small and will have a short deployment period of approximately 18 months.
Entanglement impacts were considered for smalltooth sawfish because it is the only listed fish species large
enough to become entangled within the proposed facility's mooring lines. Entanglement risks to the smalltooth
sawfish from the proposed project are minimized by using rigid and durable cage materials and by keeping all
lines taut (as described in Section 3.0). The ocean currents will maintain the floating cage, mooring lines, and
chain under tension during most times of operation. Additionally, the limited number of vertical mooring lines
reduce the risk of potential entanglement by this listed fish species. Furthermore, interactions are anticipated to
be highly unlikely given their current range in southwest Florida between Ft Myers and the Florida Keys.
Because of the proposed project operations and lack of proximity to the known habitat for the smalltooth sawfish,
the action agencies expect that the effects of this entanglement interaction would be discountable.
For water quality impacts, the EPA is proposing NPDES permit conditions required by the Clean Water Act.
These permit provisions will contain environmental monitoring (water quality, sediment, and bcnthic in fauna)
and conditions that minimize potential adverse impacts to fish from the discharge of effluent from the proposed
facility, and prohibit the discharge of certain pollutants (e.g., oil, foam, floating solids, trash, debris, and toxic
pollutants). Due to the pilot-scale size of the facility, water quality and henthie effects are not expected to occur
outside of 10 meters. The discharges authorized by the proposed NPDES permit represent a small incremental
contribution of pollutants that arc not expected to affect any ESA-listed fish species in or near the proposed
action, area.
Any potential effects from the proposed action on ESA-listed fish are discountable and insignificant. The action
agencies have determined that the activities under the proposed project is NLAA the threatened and endangered
species of fish.
7.1,3 Invertebrates
Potential routes of effects to coral from the proposed project include disturbance {breakage of coral structures)
and water quality impacts (e.g.. increased sedimentation, increased nutrient loading, and the introduction of
pollutants).
Regarding disturbance, anthropogenic breakage is extremely unlikely and discountable because the proposed
facility will not be in areas where listed corals may occur. Most of the ESA-listed invertebrate species are
associated with coral reefs that occur in shallower areas of the Gulf and along the west Florida shelf Only five
species of the invertebrates considered (boulder star, elkhorn. mountainous star, pillar, and staghom) are not
known to occur near the proposed project location or at depths where the proposed facility is located. Only two
invertebrate species (lobed star coral and rough cactus coral) may occur in the proposed action area. Moreover,
the anchoring system and cage will be placed in an area consisting of unconsolidated sediments, away from
potential hardbottom which may contain corals according to the facility's sea floor survey. Given the known
geographic locations of the considered coral species and their recognized habitat preferences related to water
depth, the disturbance effects of the proposed action is anticipated to be minimal and extremely unlikely.
Regarding impacts from water quality, the discharge from the proposed facility will be covered by a NPDES
permit with water quality conditions required by the Clean Water Act. The aquaculture-speeific water quality
conditions contained in the NPDES permit will generally include an environmental monitoring plan (water
quality, sediment, and bcnthic monitoring) and effluent limitations expressed as BMPs. Water quality effects
are not expected to occur outside of 30 m due to the small size of the facility and low production levels.
Sedimentation from the facility is not expected to occur outside of 1,000 in (assuming a maximum production
for the entire duration of the project) with impacts resulting from the proposed facility likely limited to within
300-500 meters from the cage. The NPDES permit will prohibit discharges within 500 m of areas of biological
concern, including live bottoms or coral reefs. The impacts from water quality and sedimentation are expected
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to be minimal or insignificant, and the likelihood that deleterious water quality will contribute to any adverse
effects to listed coral species is extremely unlikely.
Any adverse effects from the proposed project on k.SA-iisled corals are discountable and insignificant. 1 he
action agencies have concluded that the proposed project will NLA A on the ESA-listed invertebrate species.
7.1.4 Marine Mammals
Generally, endangered whales are not likely to be adversely affected by any oi the threats considered by the
action agencies at or near the proposed facility because they are unlikely to overlap geographically with the
small footprint of the proposed action area. All whales considered in this BE prefer habitat in waters deeper than
Use proposed action (4(1 m) as described in Section 5,1.4. 1 he expected absence oi the hSA-iisted marine
mammals in or near the proposed action area is an important factor in the analysts of whether impacts from the
proposed project will have any effect on ESA-listed whales; however, the action agencies have still considered
potential threats (disturbance, entanglement, vessel strikes, and water quality) to the six species of marine
mammals considered in this BE.
Disturbance to marine mammals from ocean noise generated by the proposed facility is expected to be extremely
low given the duration of the project, minimal vessel trips, and scale of the operation. The production cage will
be deployed for a duration of approximately 18 months. Opportunities for disturbance from the vessel
participating in the proposed project are minimal due to the limited trips to the site. The most likely source of
disturbance from the proposed aquaculture activity would be noise from the vessel engines and barge generator.
The noise emitted from the engines and generator would not significantly add to the frequency or intensity oJ
ambient sound levels in the proposed action area, and arc not expected to be different from other vessels
operating in federal waters. The action agencies believe that the underwater noise produced by operating a vessel
and cage will not interfere with the ability of marine mammals to communicate, choose mates, find food, avoid
predators, or navigate. The limited amount of noise from the proposed project would have negligible effect on
ESA-listed whales.
Entanglement risks to marine mammals at any aquaculture operation is minimized by using rigid and durable
cage materials and by keeping all lines taut. As described in Section 3.0, the cage material tor the proposed
project is constructed with rigid and durable materials that will significantly decrease the likelihood that ESA-
listed species will become entangled. The limited number of vertical mooring lines (3) and the duration of cage
deployment (approximately 18 months) will reduce the risk of potential entanglement by marine mammals.
When the currents change, the lines would likely remain taut even as the currents shift because of the weight of
chain and rope create a negative buoyancy on the facility anchorage lines. While it is highly unlikely that ESA-
listed whales would become entangled in the mooring lines; if incidental line contact occurs, serious harm to the
listed whales or sea turtles is not likely due to the tension in the mooring lines. The cage will be constructed oi
semi-rigid copper alloy mesh with small openings that will further prevent entanglements,
Additionally, there have been no recorded incidents of entanglement from ESA-listed marine mammal species
interacting with a permitted commercial-scale marine aquaculture facility in Hawaii (BOM, 2014). The depth
of water and line length used at the proposed project would provide adequate spaces for most marine mammals
to pass through. The proposed action would not likely entangle marine mammals as they are likely to detect the
presence of the facility and would be able to avoid the gear; however, should entanglement occur, on-site staff
would follow the steps outlined in the PSMP and alert the appropriate experts for an active entanglement.
Furthermore, because of the proposed project operations and location of marine mammal habitat, the action
agencies expect that the effects of this entanglement interaction would be interactions arc anticipated to be highly
unlikely.
Regarding vessel strikes, facility staff will be stationed on one vessel for the duration of the project except during
unsafe weather conditions. The probability that collisions with the vessel associated with the proposed project
would kill or injure marine mammals is discountable as the vessel will not be operated at speeds known to injure
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or kill marine mammals. Given the limited trips to the facility with only one vessel, and the high visibility of
whales to small vessels, opportunities for strikes from the vessel participating in the proposed project are
expected to be insignificant. Strikes from other vessels not operated by the facility are anticipated to be
improbable due to the proximity to shore (-45 miles). Additionally, all vessels are expected to follow the vessel
strike and avoidance measures that have been developed by the NMF5, Moreover, should there be any vessel
strike that results in an injury to an ESA-protccted marine mammal, the on-site staft would follow the steps
outlined in the PS MP and alert the appropriate experts tor an active entanglement.
Regarding potential impacts from water quality, each ESA-listed whale species considered in this BE is not
expected to be affected given their unique habitat preferences and known proximity to the proposed action area.
The discharge from the proposed facility will be covered by a NPDES permit with project-specific conditions
that includes water quality monitoring and implementation of practices to protect the environment near the
proposed action area. The discharge of wastewater from the proposed project arc expected to have a minor
impact on water quality due to factors concerning the low fish biomass produced; the relatively small amounts
of pollutants discharged; depth of the sea floor; and current velocities at the proposed action area. It is anticipated
that the proposed activity would add relatively small amounts of nutrient wastes (nitrogen, phosphorus,
particulate organic carbon, and solids) to the ocean in the immediate vicinity of the proposed action area. The
facility's effluent is expected to undergo rapid dilution from the prevailing current; constituents will be difficult
to delect within short distances from the cage. The impacts from water quality are expected to be insignificant,
and the likelihood of water quality impacts contributing to any adverse effects to ESA-listed marine mammals
is extremely unlikely (see Section 6.4 for more in formal ion).
The action agencies believe that any adverse effects from the potential threats considered to ESA-listed marine
mammals are extremely unlikely to occur and are discountable. The action agencies have determined that the
activities authorized under the proposed permits will XL A A any marine mammals considered in this BE.
7.1.5 Reptiles
The action agencies considered disturbance, entanglement, vessel strike, and wafer quality as the only potential
threats to reptiles within the proposed action area.
Sea tunics may experience disturbance by stress due to a startled reaction should they encounter vessels in transit
to the proposed project site. Given the limited trips to the site, opportunities for disturbance from vessels
participating in the proposed project are minimal. ESA-listed sea turtles may be attracted to aquaculture facilities
as potential sources ot food, shelter, and rest, but behavioral effects from disturbance arc expected to be
insignificant. Additionally, all vessels are expected to follow the vessel strike and avoidance measures that have
been developed by the NV1FS. Furthermore, there has been a lack of documented observations and records of
ESA-listed sea turtles interacting with a permitted commercial-scale marine aquaculture facility in Hawaii
(BOM, 2014); we anticipate that such interactions would be unlikely. As a result, disturbance from human
activities and equipment operation resulting from the proposed action is expected to have insignificant effects
on. ESA-listed reptiles.
The risk of sea turtles being entangled in offshore aquaculture operation is greatly reduced by using rigid case
materials and by keeping all lines taut. Section 3 describes how the cage and mooring material lor the proposed
project is constructed widi rigid and durable materials, and how the mooring lines will be constructed of steel
chain and thick rope that will be maintained under tension by the ocean currents during most times of operation.
Additionally, the bridle line that connects from the swivel to the cage will be encased in a rigid pipe. Moreover,
the limited number of vertical mooring lines (three) and the duration of cage deployment (less than 1K months)
will reduce the risk of potential entanglement by sea turtles. Because of the proposed project operations and
duration, the action agencies expect that the effects of this entanglement interaction would be discountable;
however, should entanglement occur, on-site staff would follow the steps outlined in the PSMP and alert the
appropriate experts for an active entanglement.
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In regard to vessel strikes, facility staff will use only one vessel for the duration of the project The vessel will
be operated at low speeds that are not known to injure or kill sea turtles; therefore, the probability that collisions
with the vessel associated with the proposed project would kill or injure sea turtles is discountable. Opportunities
for strikes to reptiles from the \esse! participating in the proposed project arc expected to be insignificant gi\en
the limited number of trips to the facility with one vessel. Strikes from other vessels not operated by the facility
are anticipated to be improbable due to the proximity to shore. Additionally, all vessels are expected to follow
the vessel strike and avoidance measures that have been developed by the NMFS.
The proposed activity would not add significantly to the volume of maritime traffic in the proposed action area.
The number of trips associated with deploying and retrieving the facility components, routine maintenance,
stocking, and harvest operations would minimally increase vessel traffic in the proposed action area. The project,
activities are not expected to result in collisions between protected species and any vessels. Collisions with ESA-
listed species during the proposed activity would be extremely unlikely to occur.
Commercial and recreational fishermen are expected to visit the proposed project because it could act as a fish
attraction device. While fishermen would be attracted to the project area from other locations, overall fishing
ellurl b\ ihose fishermen in federal fisheries would not increase as these fishermen would have fished elsewhere
if the project was not in place. The action agencies do not expect that any increased fishing activity in the project
area since there were no reports or observations of interactions between fishermen and ESA-listed species in
previous Velella trials (Velella Beta and Velella Gamma) in Hawaii (NMFS, 2016).
The impacts from water quality are expected to he insignificant, and the likelihood of water qualitv impacts
contributing to any adverse effects to ESA-listed reptiles in or near the proposed action area is extremely unlikely
(sec Section 6.4 for more information related to water quality impacts). The discharge from the proposed facility
will be covered by a NPDES permit with project-specific conditions that includes water quality monitoring and
implementation, of practices to protect the environment. Water quality effects are not expected to occur outside
of 10 m due to the low fish production levels and fast ocean currents.
Any adverse effects from the proposed project on ESA-listed reptiles arc extremely unlikely to occur and arc
discountable. The action agencies have determined that the activities under the proposed permit will NLA A the
sea turtles considered in this BE.
7,2 Federally Listed Critical Habitat
7.2.1 Reptiles
The action agencies identified vessel strike and water quality as the only potential routes of impacts to the
loggerhead turtle DPS critical habitat of the Northwest Atlantic. In the Gulf, designated critical habitat consists
of either nearshore reproductive habitat or Sargassum habitat. The proposed project is roughly 45 miles from
shore and will not affect nearshore reproductive habitat. Therefore, the essential features of loggerhead turtle
critical habitat that the proposed action may affect are foraging habitat for hatchlings and association of
hatch!ings around Sargassum mats.
Sargassum mats may be impacted by vessel traffic; however, the PS MP that was developed for the proposed
project area includes a provision that trained observers will look for Sargassum mats and will in form vessel
operators as to their location to avoid the mats to the maximum extent practicable. The proposed project will be
sited in the open ocean environment, and Sargassum mats may infrequently drift into the project area; however,
it is highly unlikely the proposed facility would impact Sargassum habitat further offshore where the facility
will be located. Additionally, the facility will only bring the submerged aquaculturc cage to the surface for brief
periods to conduct maintenance, feeding, or harvest activities due to the high energy open-ocean environment
where the proposed facility will be located.
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Sargassum mats arc not anticipated to be negatively impacted by water quality due to the conditions in the
NPDES permit. Potential impacts on loggerhead critical habitat is expected to be discountable because of active
monitoring for Sargassum mats and the extremely low likelihood of impacts from water quality.
The action agencies believe that the adverse effects from the proposed action will have insignificant effect on
the Northwest Atlantic loggerhead DPS critical habitat due to location of the facility and operational methods
used while the cage is deployed. The action agencies have determined that the activities under the proposed
permit will NLAA the listed sea turtle critical habitat.
7.2.2 Birds
Critical habitat has been designated in for the piping plover for coastal wintering habitat areas in Florida;
however, the proposed action does not interfere with any ncarshore areas. Therefore, critical habitat for the
piping plover will not be exposed to any potentially harmful elements of the proposed action. The action
agencies have determined that the activities under the proposed project will have no effect to the piping plover's
critical habitat.
7.3 Federal Proposed Species and Proposed Critical Habitat
The action agencies did not perform an analysis of impacts because no federally-listed proposed species or
proposed critical habitat in or near the proposed action area were identified.
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Table 4: Summary of potential impacts considered and ESA determination
Group :nid SjK'i ii-s
Birds
1	Piping Plover
2	Red Knot
Fish
] Giant Manta Ray
2	Nassau Grouper
3	Oceanic Whilctip Shark
4	Smailtooth Sawfish
Invertebrates
]
2
3
4
5
6
7
Potential Impaeis
Considered
None
Disturbance,
entanglement, and
water quality
Potential MfuiM Di'iiTHiiiiiiinui
None
No effect
Discountable and May affect, but not
insignificant	likely to adversely affect
Boulder Star Coral
Elkhom Coral
Mountainous Star Coral
Pillar Coral
Staghom Coral
Rough Cactus Coral
Lobed Star Coral
Marine Mammals
1	Blue Whale
2	Fin Whale
3	Humpback Whale
4	Sei Whale
5	Sperm Whale
6	Bryde's Whale
Reptiles
Green Sea Turtle
1 lawksbill Sea Turtle
Kemp's Ridley Sea Turtle
Leaiherbaek Sea Turtle
Loggerhead Sea Turtle
Critical Habitat
1	Hawksbill Sea Turtle
2	Leaiherbaek Sea Turtle
3	Loggerhead Sea Tutile
4	Piping Plover
Disturbance and water Discountable and May affect, but not
quality	insignificant	likely to adversely affect
Disturbance,
entanglement, vessel
strike, and water quality
Disturbance,
entanglement, vessel
strike, and water quality
Vessel strike and water
quality
None
Discountable and May affect, hut not
insignificant	likely to adversely affect
Discountable and
insignificant
May affect, but not
likely to adversely affect
Discountable and May affect, but not
insignificant	likely to adversely affect
None
No effect
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8.0 Conclusion
The EPA and USAGE conclude that the proposed project's potential threats (disturbance, entanglement, vessel
strike, water quality) to ESA-listed species and critical habitat are highly unlikely to occur or extremely minor
in severity; therefore, the potential effects to ESA protected species and critical habitats are discountable or
insignificant.
The EPA and USAGE have determined that the proposed project will have "no effect" on the listed species
and critical habitat under the jurisdiction of the USFWS that may occur in the proposed action area and that
may be affected. This determination includes the piping plover and the red knot and critical habitat for the
piping piover. No other listed species, proposed species, critical habitats, or proposed critical habitats were
considered under the authority of the USFWS because there is no evidence to support that a potential effect from
the proposed project may occur. The EPA and USAGE request concurrence from the USFWS for this
determination under ESA Section 7,
The EPA and USAGE have determined that the proposed project "may affect, but is not likely to adversely
affect" the listed species and critical habitat or designated critical habitat under the jurisdiction of the NMFS.
This determination includes: four species offish, seven species of invertebrates, six species of whaics. reptiles
from five species, and critical habitat for reptiles. No other listed species, proposed species, critical habitats, or
proposed critical habitats were considered under the authority of the NMFS because there is no evidence to
support that a potential effect from the proposed project may occur. The EPA and USAGE request concurrence
from the NMFS for this determination under FSA Section ?.
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Mexico: Before the Deepwater flori/,on Oil Spill. Springer. New York. N\
Wyneken. J., l.ohmann, K.. and Musick, J. 2013. The Biology of Sea Turtles, Volume III. 457. Boca Raton,
London. New York: CR(' f'res.s.
Biological [-valuation
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Appendix B - Location Area
VE Project - Modified Site B & Peri Placement
I ytffiitl:
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~ y 10 io"
L a-iouiciicilrc
SfdhiiPTin
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r jjiwr rwrifalMlf SwtCBI
lane. North Amtncui
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Augiat ' ^ ^ilIR
M*p 3 I *ncnr>i1 uivevl Scyhrncin
TItk k ti «* I %opacli
kauipucbi l arw*
YrlHI.i hpvilnii
Gwphyffcal .Sur\t»j
£ APTIM
"-'HSi'l Si'fll.
tUT(l. I I IH1M
** v « uTiMiim
Vorioi il Vflt P?» PI® r f me nri
flSOia Diameter J oetpciat)
rhivknt^s (ft)
~ >>3r?iOlagariic Anomalies
Guff
of
.Vmiv
POfidOOfl
* Decimal Latitude
8 Decimal Longitude
Decimal1 Latitude
Decimal3 Longitude
Perimeter (Km) Area (Km1)

Modified site E From BE5 Report
uccer ^en
27* 7 36562- N
33* 13.45627-W
27.131143* N
53.224303" W
11.1571
7.7237
uwr B.qr:
27* 7 93C7S' N
33* 11 63237 VV
27.13051 r N
13 193172" W
Lower Rah:
27* §43381- ^
33* 11 59345" W
27.1C7230* N
63.154890" W
lo*€-' >en
27* € 5026V N
33" 13 52655' W
27.1D8377* N
£3.225442* VV
Obiter
27* T11266 s
93* 12 56604 W
27.116543* N
63.2D9757" W

Targeted Subset Area of Modined site B from SES Report (3* to I
cr unconsolidated Sediment


ucoe^
27* 7.70£0T *4
33* 1227C12" W
27 128445" ISt
63-2D4502* W
5.2273
1.6435
UDoe- Riorc
27* 7 51C22* M
33* 11 65678" W
27.126637" N
53 154276" W
Lc*e- *. or:
27 * 6.77773' S
S3* 1175375' W
27.112562" N
53.155597" W
Lower -en
27* t 37631' M
33* 12-42032' VV
27.114605* N
E3 227COS' W
Center
27*7 341SS' N
33* 12.02291 W
27.1223-65* N
63.200332* VV

Notional Net Fen Piacem
rfitt wttftin Moaned site B
from BES Report


1
27* 7 54-724" N
33* 11 35393" W
27.125737* N
53 1 57555* VV
0.7354
0.0491
2
27* 7 17461" N
33* 11.82576* W
27.119530* H
C3.197C95" W
3
27* 6 9393C ^
33* 11 34780' VV
27.115665* N
63.199130*W
4
27" 6 52575" M
33* 12.09175 VV
27.106763' N
63.201530* W
Biological Evaluation
Kampachi Farms - Veletla Epsilon
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Appendix E

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ESSENTIAL FISH HABITAT ASSESSMENT
Kampachi Farms, LLC - Velella Epsilon
Marine Aquaculture Facility
Outer Continental Shelf
Federal Waters of the Gulf of Mexico
August 2, 2019
vS
e° sr.,*

\ PR0^°

ro
z
ill
o
U.S. Environmental Protection Agency
Region 4
Water Protection Division
61 Forsyth Street SW
Atlanta Georgia 30303
NPDES Permit Number
FL0A00001
US Army Corps
off Engineers®
U.S. Army Corps of Engineers
Jacksonville District
Fort Myers Permit Section
1520 Royal Palm Square Boulevard Suite 310
Fort Myers Florida 33919-1036
RHA Section 10 Permit
SAJ-2017-03488

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Table of Contents
1.0 Introduction and Federal Coordination	3
2.0 Proposed Action	4
3.0 Proposed Proj ect	4
4.0 Proposed Action Area	5
5.0 Assessment and Ecological Notes on the EFH Fisheries and Species	6
5.1	EFH Overview	6
5.2	Shrimp Fishery	6
5.3	Red Drum Fishery	8
5.4	Reef Fish	8
5.5	Coastal Migratory Pelagic Fishery	11
5.6	Spiny Lobster Fishery	12
5.7	Coral and Coral Reefs	12
5.8	Highly Migratory Species	12
6.0 Assessment of EFH and HAPC in the Gulf	12
6.1	Water Column EFH	13
6.2	Benthic EFH	14
6.2.1	Vegetated Bottoms	14
6.2.2	Unconsolidated Sediments	14
6.2.3	Live Bottoms	14
6.2.4	West Florida Shelf	15
7.0 Federal Action Agency Determination and Mitigation	16
References	18
Appendix A - Cage and Mooring Detail	19
Appendix B - Location Area	20
EFH Assessment
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1.0 Inli'odiKiion ;in(I lodcnil (oordinnlion
The Magnuson-Stevens Fishery Conservation and Management Act (MSA) sets forth a mandate for NOAA's
National Marine Fisheries Service (NMFS), regional fishery management councils (FMC), and other federal
agencies to identify and protect important marine fish habitat. The essential fish habitat (EFH) provisions of
the MSA support one of the nation's overall marine resource management goals of maintaining sustainable
fisheries. Essential to achieving this goal is the maintenance of suitable marine fishery habitat quality and
quantity. The FMCs, with assistance from NMFS, have delineated EFH for federally managed species. Federal
action agencies which fund, permit, or carry out activities that may adversely affect EFH are required to consult
with NMFS regarding the potential impacts of their actions on EFH and respond in writing to NMFS or FMC
with any recommendations.
The MSA, administered by the NMFS and regional FMCs, requires collaboration to stop or reverse the
continued loss of fish habitats. Congress mandated the identification of habitats essential to managed species
and measures to conserve and enhance this habitat. Under the MSA, Congress directs NMFS and the eight
regional FMCs, under the authority of the Secretary of Commerce, to describe and identify EFH in Fishery
Management Plans (FMPs); minimize, to the extent practicable, the adverse impacts on EFH; and identify
other actions to encourage the conservation and enhancement of EFH.
On November 9, 2018, the U.S. Environmental Protection Agency Region 4 (EPA) received a complete
application for a Clean Water Act (CWA) National Pollutant Discharge Elimination System (NPDES) permit
from Kampachi Farms for the point-source discharge of pollutants from a marine aquaculture facility in federal
waters of the Gulf of Mexico (Gulf). On November 10, 2018, the U.S. Army Corps of Engineers Jacksonville
District (USACE) received a complete application for Department of Army (DA) permit pursuant to Section
10 of the River and Harbors Act (RHA), 1899 (Section 10), for structures and work affecting navigable waters
from Kampachi Farms.
Given that the action of permitting the proposed project involves more than one federal agency, the EPA has
elected to act as the lead agency to fulfill the consultation responsibilities as allowed by 50 CFR § 600.920(b).1
In the consultation request, the EPA has also notified the NMFS that the EPA is acting as the lead agency as
required by 50 CFR § 600.920(b). The USACE is a cooperating and co-federal agency for the EFH consultation
request. The completion of this abbreviated consultation shall satisfy the EPA's and USACE's obligations
under MSA Section 305(b)(2).
This EFH assessment was prepared by the EPA and the USACE to jointly consider the potential effects that
the proposed actions may have on EFH under the jurisdiction of the NMFS as required by 50 CFR §
600.920(e)(1). The EPA and the USACE (action agencies) have reviewed the proposed activity and determined
that the level of detail provided in this EFH assessment is commensurate with the complexity and magnitude
of the potential adverse effects of the proposed action as allowed by 50 CFR 600.920(e)(2), and meets the
information requirements that all EFH assessments must include according to 50 CFR § 600.920(e)(3). The
EPA and the USACE are providing this EFH assessment for consideration by the NMFS in compliance with
the MSA Section 305(b)(2).
The EPA and USACE are coordinating the interagency review process as required by the interagency
Memorandum of Understanding for Permitting Offshore Aquaculture Activities in Federal Waters of the Gulf
of Mexico (Aquaculture MOU),2 and conducting a comprehensive analysis of all applicable environmental
1	50 CFR § 600.920(b) allows a lead agency: "If more than one Federal agency is responsible for a Federal action, the consultation
requirements of sections 305(b)(2) through (4) of the Magnuson-Stevens Act may be fulfilled through a lead agency. The lead agency should
notify NMFS in writing that it is representing one or more additional agencies."
2	On February 6,2017, the Memorandum of Understanding for Permitting Offshore Aquaculture Activities in Federal Waters of the Gulf of
Mexico became effective for seven federal agencies with permitting or authorization responsibilities.
EFH Assessment
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requirements under the National Environmental Policy Act (NEPA); however, a consolidated cooperation
process under NEPA is not being used to satisfy the EFH assessment requirements as described in 50 CFR §
600.920(e)(1).3 The NMFS is a cooperating agency for the NEPA analysis and has provided scientific
expertise related to the NEPA analysis for the proposed action including information about: site selection,
Endangered Species Act (ESA) listed species, and marine mammal protection. While some information related
to the EFH Assessment is within the coordinated NEPA evaluation developed by multiple federal agencies,
this EFH Assessment is being provided as a stand-alone document to comply with the consultation process
under the MSA.
2.0 Proposed Action
Kampachi Farms, LLC (applicant) is proposing to operate a pilot-scale marine aquaculture facility (Velella
Epsilon) in federal waters of the Gulf. The proposed action is the issuance of the CWA and RHA permits under
the respective authorities of the EPA and the USACE as required to operate the facility. The EPA's proposed
action is the issuance of a NPDES permit that authorizes the discharge of pollutants from an aquatic animal
production facility that is considered a point source into waters of the United States. The USACE's proposed
action is the issuance of a DA permit pursuant to Section 10 of the RHA that authorizes anchorage to the sea
floor, structures and work in, over, under, and affecting navigable waters.
3.0 Proposed Project
The proposed project would allow the applicant to operate a pilot-scale marine aquaculture facility with up
to 20,000 almaco jack (Seriola rivoliana) being reared in federal waters for a period of approximately 12
months. Based on an estimated 85 percent survival rate, the operation is expected to yield approximately
17,000 fish. Final fish size is estimated to be approximately 4.4 lbs/fish, resulting in an estimated final
maximum harvest weight of 88,000 lbs (or 74,800 lbs considering the survival rate).
The fingerlings will be sourced from brood stock that are located at Mote Aquaculture Research Park and were
caught in the Gulf near Madeira Beach, Florida. As such, only filial 1 (Fl) progeny will be stocked into the
offshore net pen. Following harvest, cultured fish would be landed in Florida and sold to federally-licensed
dealers in accordance with state and federal laws.
A single CopperNet offshore strength (PolarCirkel-style) manufactured submersible fish pen will be deployed
on an engineered multi-anchor swivel (MAS) mooring system. The design provided for the engineered MAS
uses three concrete deadweight anchors for the mooring; however, the final anchor design is likely to utilize
embedment anchors instead. The cage material for the proposed project is constructed with rigid and durable
materials (copper mesh net with a diameter of 4 mm wire and 40 x 40 mm mesh square). The mooring lines
for the proposed project will be constructed of steel chain (50 mm diameter) and rope (36 mm diameter) that
are attached to a floating cage that will rotate in the prevailing current direction; the floating cage position that
is influenced by the ocean currents will maintain the mooring rope and chain under tension during most times
of operation. The bridle line that connects from the swivel to the cage will be encased in a rigid pipe. Structural
information showing the current MAS with deadweight anchors and net-pen array is provided in the Appendix
A.4
The CopperNet cage design is flexible and self-adjusts to suit the constantly changing wave and current
3	50 CFR § 600.920(e)(1) states that "Federal agencies may incorporate an EFH Assessment into documents prepared for other purposes
such as Endangered Species Act (ESA) Biological Assessments pursuant to 50 CFR part 402 or National Environmental Policy Act (NEPA)
documents and public notices pursuant to 40 CFR Part 1500."
4	The anchoring system for the proposed project is being finalized by the applicant. The proposed project will utilize appropriately sized
deadweight or, more likely, embedment anchors. Both anchor types are considered within the EFFI assessment and are included for EFFI
consultation purposes. The selected final anchor design will be available in the administrative record for the NPDES or USACE permit.
EFH Assessment
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conditions. As a result, the system can operate floating on the ocean surface or submerged within the water
column of the ocean. When a storm approaches the area, the operating team simply opens a valve to flood the
floatation system with water, causing the entire net pen array to submerge. A buoy remains on the surface,
marking the net pen's position and supporting the air hose. When the net pen approaches the bottom, the system
will maintain the cage several m above the sea floor. Submerged and protected from the storm above, the
system is still able to rotate around the MAS and adjust to the currents. After storm events, the operating team
pumps air back into the floatation system via a hose, making the net pen array buoyant, causing the system to
rise back to or near the surface position to resume operational conditions. The proposed project cage will have
at least one properly functioning global positioning system device to assist in locating the system in the event
it is damaged or disconnected from the mooring system.
4.0 Proposed Action Aivsi
The proposed project would be placed in the Gulf at an approximate water depth of 130 feet (40 m),
generally located 45 miles southwest of Sarasota, Florida. The proposed facility will be placed within an
area that contains unconsolidated sediments that are 3 - 10 ft deep (see Table 1). The applicant will select the
specific location within that area based on diver-assisted assessment of the sea floor when the cage and
anchoring system are deployed. More information about the proposed project area boundaries are shown in
Appendix B.
Table 1: Target Area with 3' to 10' of Unconsolidated Sediments
Upper Left Corner
Upper Right Corner
Lower Right Corner
Lower Left Corner
IT
IT
IT
IT
7.70607' N
7.61022'N
6.77773'N
6.87631'N
83c
83c
83c
83c
12.27012'W
11.65678'W
11.75379'W
12.42032'W
The proposed facility location was selected with assistance from NOAA's National Ocean Service, National
Ocean Service National Centers for Coastal Ocean Science (NCCOS). The applicant and the NCCOS
conducted an exhaustive site screening process to identify an appropriate project site. Some of the criteria
considered during the site screening process included avoidance of corals, coral reefs, submerged aquatic
vegetation, and hard bottom habitats; and avoidance of marine protected areas, marine reserves, and habitats
areas of particular concern (HAPC). This siting assessment was conducted using the Gulf AquaMapper tool
developed by NCCOS.5
Upon completion of the site screening process with the NCCOS, the applicant conducted a Baseline
Environmental Survey (BES) based on guidance developed by the NMFS and EPA.6 The BES included a
geophysical investigation to characterize the sub-surface and surface geology of the sites and identify areas
with a sufficient thickness of unconsolidated sediment near the surface while also clearing the area of any
geohazards and structures that would impede the implementation of the aquaculture operation. 7 The
geophysical survey for the proposed project consisted of collecting single beam bathymetry, side scan sonar,
sub-bottom profiler, and magnetometer data within the proposed area. The BES report noted that were no
physical, biological, or archaeological features that would preclude the siting of the proposed aquaculture
facility at one of the four potential locations shown in Table 1.
5	The Gulf AquaMapper tool is available at: https://coastalscience.noaa.gov/products-explorer/
6	The BES guidance document is available at: http://sero.nmfs.noaa.gov/sustainable_fisheries/Gulf_fisheries/aquaculture/
7	The BES constitutes additional results to support the evaluation of habitat and site-specific effects that the proposed project may have on
EFH within the proposed action area in accordance with 50 CFR § 600.920(e)(4)(i). The BES was provided to the NMFS by the applicant.
EFH Assessment
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5.0	Assessment iiihI l.colo»k;il Notes on (lie F.M I lis lie lies nil (I Species
5.1	EFH Overview
According to the NEPA documentation and the Ocean Discharge Criteria Evaluation prepared in support of
the NPDES permit for the proposed project, which discuss the habitat in the eastern portion of the Gulf, and
the portion of the west Florida shelf, the area specific to the proposed project is known to support commercially
important invertebrates and fishes. The proposed area consists of a wide variety of marine habitats including
unconsolidated sediments (sand and gravel) and low-relief hard bottom habitat, providing critical support for
commercially and recreationally important fishes and invertebrates in the eastern Gulf.
The seasonal and year-round locations of designated EFH for the managed fisheries are depicted on figures
available from the NMFS.8 The NMFS selected 27 species from seven existing Fisheries Management Units
(FMUs). Table 2 lists the 27 species (plus various coral reef fish assemblages) which are known to reside in
Gulf waters and which are managed under the MSA. The listed species are considered ecologically significant
to their respective FMU, and their collective habitat types occur throughout marine and estuarine waters in the
Gulf.
The MSA defines EFH as "those waters and substrate necessary to fish for spawning, breeding, feeding or
growth to maturity" (MSA § 3(10)). EFH must be designated for the fishery (16 USC § 1853(a)(7)). The final
rule clarifies that every FMP must describe and identify EFH for each life stage of each managed species. The
EFH assessment is based on species distribution maps and habitat association tables. In offshore areas, EFH
consists of those areas depicted as "adult areas", "spawning areas", and "nursery areas".
5.2	Shrimp Fishery
The brown, white and pink shrimp yields in the Gulf are highly dependent upon the abundance and health of
estuarine marshes and seagrass beds. The prey species (food source) for these shrimp depend on similar
vegetated coastal marshes and seagrass beds.
Brown Shrimp
Brown shrimp are generally more abundant in the central and western Gulf and found in the estuaries and
offshore waters to depths of 120 m. Postlarve and juveniles typically occur within estuaries while adults occur
outside of bay areas. In estuaries, brown shrimp postlarve and juveniles are associated with shallow vegetated
habitats, but also are found over silty sand and non-vegetated mud bottoms. In Florida, adult areas are primarily
seaward of Tampa Bay, and associated with silt, muddy sand, and sandy substrates.
Spawning area: Florida waters to edge of continental shelf; year round
Nursery area: Tampa Bay
White Shrimp
White shrimp are offshore and estuarine dwellers and are pelagic or demersal depending on their life stage.
The eggs are demersal and larval stages are planktonic, and both occur in nearshore marine waters. Adult white
shrimp are demersal and generally inhabit nearshore Gulf waters in depths less than 33 m on soft mud or silty
bottoms. In Florida, white shrimp are not common east or south of Apalachee Bay and are not expected to be
impacted by the discharges.
Spawning area: off Mississippi and Alabama; March to October
Nursery area: Mississippi Sound
8 Designated EFH for managed fisheries are available at: http://sero.nmfs.noaa.gov/maps_gis_data/habitat_conservation/efh_Gulf/
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Pink Shrimp
Juvenile pink shrimp inhabit most estuaries in the Gulf but are most abundant in Florida. Juveniles are
commonly found in estuarine areas with seagrass. Postlarve, juvenile, and subadults may prefer coarse
sand/shell/mud mixtures. Adults inhabit offshore marine waters, with the highest concentration in depths of
10 to 48 m. According to the NMFS species distribution map, pink shrimp use Tampa Bay from the larval
stage until the species matures to the late juvenile stage.
Spawning area: Mississippi, Alabama, and Florida offshore; year round
Nursery area: major nursery areas in Tampa Bay and Florida west coast state waters; summer and
fall in the northern Gulf
Table 2: EFH Species within the Central and Eastern Gulf
Species
1 1 II
Shrimp (Brown,
White, Pink, Royal
Red)
All estuaries; the US/Mexico border to Fort Walton Beach, Florida, from
estuarine waters out to depths of 100 fathoms; Grand Isle, Louisiana, to
Pensacola Bay, Florida, between depths of 100 and 325 fathoms; Pensacola
Bay, Florida, to the boundary between the areas covered by the Gulf of
Mexico (GMFMC) and the South Atlantic FMC (SAFMC) out to depths of
35 fathoms, Crystal River, Florida, to Naples, Florida, to 25 fathoms and in
Florida Bay to 10 fathoms. Marsh, seagrass, mangrove and open water
habitats.
Coastal Migratory
Pelagics
All estuaries; the US/Mexico border to Florida from estuarine waters out to
depths of 100 fathoms.
Red Drum
All estuaries; Vermilion Bay, Louisiana, to the eastern edge of Mobile Bay,
Alabama, out to depths of 25 fathoms; Crystal River, Florida, to Naples,
Florida, between depths of 5 and 10 fathoms; and Cape Sable, Florida, to the
boundary between the areas covered by the GMFMC and the SAFMC
between depths of 5 and 10 fathoms.
Reef Fish
All estuaries; the US/Mexico border to the boundary between the areas
covered by the GMFMC and the SAFMC from estuarine waters out to
depths of 100 fathoms. Reef, seagrass, and mangrove habitat.
Spiny Lobster
From Tarpon Springs, Florida, to Naples, Florida, out to 10 fathoms; and
Cape Sable, Florida, to the boundary between the areas covered by the
GMFMC and the SAFMC out to depths of 15 fathoms. Hardbottom habitats
with macroalgae, seagrass and mangrove habitats.
Coral
Distributed throughout the Gulf including: the North and South Tortugas
Ecological Reserves, East and West Flower Garden Banks, McGrail Bank,
and the southern portion of Pulley Ridge; the pinnacles and banks from
Texas to Mississippi, at the shelf edge and at the Florida Middle Grounds,
the southwest tip of the Florida reef tract, and predominant patchy hard
bottom offshore of Florida from approximately Crystal River south to the
Florida Keys.
Deepwater Coral
The Viosca Knoll Lease Area south of Mississippi and the Green Canyon
Lease Area south of central Louisiana. The Twin Ridges area south of Cape
San Bias, Florida. Alderdice, McGrail, and Sonnier Banks off Louisiana.
Royal Red Shrimp
Royal red shrimp are most abundant in the northeastern Gulf in water depths between 270 and 550 m. Little is
known about the larvae. Distribution maps were not available by the NMFS for the royal red shrimp due to the
EFH Assessment
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limited knowledge and information available for the species. The permitted discharges will take place at or
near the surface, thus there should be no impact on the primary EFH.
Spawning area: unknown
Nursery area: unknown
5.3	Red Drum Fishery
Red Drum
In the Gulf, red drum occur in a variety of habitats, ranging from depths of about 43 m offshore to very shallow
estuarine waters. They commonly occur in all the Gulf s estuaries where they are associated with a variety of
substrate types including sand, mud, and oyster reefs. Estuaries are important to red drum for both habitat
requirements and for dependence on prey species which include shrimp, blue crab, striped mullet and pinfish.
The GMFMC considers all estuaries to be EFH for the red drum. Schools of large red drum are common in the
deep Gulf waters with spawning occurring in deeper water near the mouths of bays and inlets, and on the Gulf
side of the barrier islands. The Tampa Bay EFH estuarine map shows red drum juveniles to be abundant or
highly abundant in the fall and winter and common in the spring and summer.
Spawning area: Gulfwide from nearshore to just outside state waters, fall and winter
Nursery area: major bays and estuaries including Mobile Bay and Tampa Bay, year round
5.4	Reef Fish
Many species of snapper and grouper (mutton, dog, lane, gray and yellowtail snapper- and red, gag and
yellowfin groupers) occupy inshore areas during juvenile stages where they feed on estuarine-dependent prey.
As these species mature they generally move to offshore waters and change their feeding habits. However, reef
fish species still depend on estuarine species for prey.
Red Grouper
The red grouper is demersal and occurs throughout the Gulf at depths from 3 to about 200 m, preferring 30 to
130-m depths. Juveniles are associated with inshore hard bottom habitat, and grass beds, rock formations,
while shallow reefs are preferred for nursery areas. Species distribution maps show that spawning for the red
grouper occurs throughout much of the Gulf waters off Florida, including the Florida Middle Grounds. Nursery
areas occur within and around the selected site.
Spawning area: Florida continental shelf, well offshore, extending from south of Apalachicola Bay all
the way to west of the Florida Keys; April to May
Nursery area: extensively throughout the continental shelf off Florida and along the northern Gulf, year
round
Black Grouper
The black grouper occurs in the eastern half of the Gulf. The species is demersal and is found from shore to
depths of 170 m. Adults occur over wrecks and rocky coral reefs. Juveniles travel into estuaries occasionally.
Species distribution maps for the black grouper indicate that the range of the species occurs within the Gulf,
outside of state waters.
Spawning area: throughout eastern Gulf to 170-m depth, spring and summer
Nursery area: probably the same as the red grouper
Gag Grouper
The gag grouper is demersal and is most common in the eastern Gulf, especially the west Florida shelf. Post
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larvae and pelagic juveniles move through inlets, coastal lagoons and high salinity estuaries in April-May
where they settle into grass flats and oyster beds. Late juveniles move offshore in the fall. Adults prefer hard
bottom areas, offshore reefs and wrecks, coral and live bottom. The species EFH distribution maps indicate
presence throughout the Gulf including estuarine areas.
Spawning area: spawning areas are not specified on EFH maps
Nursery area: pelagic waters until post larvae or juvenile
Scamp
Scamp are demersal and widely distributed in the shelf areas of the Gulf, especially off Florida. Juveniles
prefer inshore hard bottoms and reefs in depths of 13 to 36 m. Adults prefer high relief hard bottom areas. The
species EFH distribution maps indicate presence throughout the Gulf including estuarine areas. Presence in
these areas is based only on records for adults.
Spawning area: spawning area not specified in the EFH maps
Nursery area: nurseries not specified in the EFH maps
Red Snapper
Red snapper is demersal and found over sandy and rocky bottoms, around reefs, and underwater objects in
depths to 218 m. Juveniles are associated with structures, objects or small burrows, or barren sand and mud
bottoms in shelf waters ranging from 20 to 200 m. Adults favor deeper water in the northern gulf preferring
submarine gullies and depressions, and over coral reefs, rock outcroppings, and gravel bottoms. Spawning
occurs in offshore waters over fine sand bottoms away from reefs. Gulf distribution map show red snapper
nursery areas within the estuarine waters of the Mississippi Sound, and Tampa Bay offshore of state waters
Spawning area: spawning occurs throughout the Gulf, June to October
Nursery area: extensive throughout the Gulf, year-round, including Mississippi Sound and Tampa Bay
Vermillion Snapper
Vermillion snapper are found over reefs and rocky bottom from depths of 2 to 220 m in the shelf areas of the
Gulf spawning occurs in offshore areas, with juveniles occupying the same areas as the adults.
Spawning area: EFH maps not available, not specified in literature reviewed
Nursery area: EFH maps not available, not specified in literature reviewed
Gray Snapper
The gray snapper generally occurs in the shelf waters of the Gulf and is particularly abundant in south and
southwest Florida. Gray snapper occurs in almost all the Gulfs estuaries but are most common in Florida.
Adults are demersal and mid-water dwellers, occurring in marine, estuarine, and riverine habitats. They are
found among mangroves, sandy grass beds, and coral reefs, and over sandy muddy bottoms. Spawning occurs
offshore, with post larvae moving into estuarine habitat over dense beads of Halodule and Syringodium
grasses. Juveniles are marine, estuarine, and riverine found in most types of habitats. They appear to most
prefer Thalassia grass flats, marl bottoms, seagrass meadows and mangrove roots. Species distribution maps
indicate that nursery areas exist within estuarine areas including the Mississippi Sound and Tampa Bay. Major
adult areas are encountered from the Mississippi Sound across Gulf waters to west of Tampa Bay, where year-
round adult areas occur within Florida state waters and into the southern half of Tampa Bay.
Spawning area: spawning areas probably exist in the Gulf off many of the nursery areas, but have not
been positively identified
Nursery area: found in coastal waters throughout the Gulf, including Mississippi Sound and Tampa
Bay
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Yellowtail Snapper
Juvenile yellowtail snapper are found in nearshore nursery areas over vegetated sandy substrate and in muddy
shallow bays. Thalassia beds and mangrove roots are preferred habitat of the gray snapper. Late Juvenile and
adults prefer shallow reef areas. According to the Gulf distribution map, this species has nursery areas within
the 3 League Line and Tampa Bay. Spawning and adult areas occur in Gulf waters outside of the 3 League
Line through the Florida Middle Ground and southern Apalachicola areas. EFH is not designated in the state
waters of Mississippi or Alabama.
Spawning area: west and north of Tampa Bay; spring and summer
Nursery area: throughout the western and southern coast of Florida, including Tampa Bay
Lane Snappers
The snappers seem to prefer mangrove roots and grassy estuarine areas as well as sandy and muddy bottoms.
Juveniles favor grass flats, reefs and soft bottom areas, to offshore depths of 33 m. Adults occur offshore at
sand bottoms, natural channels, banks, and manmade reef and structures. Gulf distribution maps indicate that
the lane snapper use shallow coastal waters including the Mississippi Sound and Tampa Bay and areas outside
of state waters as nursery areas.
Spawning area: throughout the adult areas, summer
nursery areas: shallow coastal areas throughout the Gulf including Mississippi Sound and Tampa Bay.
Greater Amber jack
Greater amberjack seems to prefer habitats that are marine but not estuarine. Based on the Gulf distribution
maps, greater amberjack occur outside the barrier islands across Gulf waters, and usually over reefs, wrecks
and around buoys. Spawning and nursery areas are similar.
Spawning area: throughout the adult areas in most of the Gulf; year round
Nursery area: throughout the adult areas; year round
Lesser Amberjack
Juvenile lesser amberjack are found offshore in the late summer and fall in the northern Gulf, along with
smaller juveniles, in areas associated with sargassum. Adults and spawning areas are found offshore year-
round in the northern gulf where they are associated with oil and gas rigs and irregular bottom. The Gulf
distribution map shows the range of the species throughout much of the Gulf and into the Atlantic coastline.
Spawning area: in adult areas, offshore, in the northern Gulf; year-round
Nursery area: probably similar to adult areas year-round; EFH map not available
Tilefish
Tilefish occur throughout the continental shelf in the Gulf, usually at depths from 50-200 m.
Spawning area: throughout the adult area from March to September
Nursery area: throughout the adult area; year round
Triggerfish
Larval and juvenile gray triggerfish are associated with grass beds, Sargassum and mangrove estuaries. Adults
seem to prefer offshore waters associated with reefs. A general species distribution map was not available,
however a map showing catches per hour by trolling methods within the Gulf was available from the National
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Oceanic and Atmospheric Administration (NOAA).9 This map indicated that there is a record of occupancy
for gray triggerfish in state waters of Mississippi/Alabama and Florida.
Spawning area: EFH map not available; assumed to be adult preferred areas offshore
Nursery area: EFH map not available; assumed to be estuarine areas throughout the Gulf
5.5 Coastal Migratory Pelagic Fishery
Collectively, these species are commonly distributed from the estuaries throughout the marine waters of the
entire Gulf. However, estuaries are very important, since they contain the major prey base for these species.
King Mackerel
King mackerel are found throughout the Gulf and seldom venture into brackish waters. Juveniles occasionally
use estuaries but are not estuarine dependent, and nursery areas occur in marine environments. According to
the species distribution map, adult areas are also used for nurseries and spawning (May to November). These
areas occur outside of the Mississippi Sound, across state waters, throughout the Gulf and into Tampa Bay.
Spawning area: throughout the Gulf, estuaries and coastal waters in adult areas; May to November
Nursery area: adult areas; year-round, marine waters, estuaries used occasionally
Spanish Mackerel
Adult Spanish mackerel tolerate brackish to oceanic waters and often inhabit estuaries. Estuarine and coastal
waters also offer year-round nursery habitat. Juveniles appear to prefer marine salinities and sandy bottoms.
Adults and spawning areas typically occur in offshore areas. According to the species distribution map, EFH
for adult and nursery areas occurs throughout the selected site. Spawning areas occur in Gulf waters off the
coast of Florida.
Spawning area: waters off the coast on the western (Summer and Fall) and eastern Gulf (Spring and
Summer)
Nursery area: coastal waters throughout the Gulf
Cobia
Cobia only occasionally inhabit estuaries. Spawning occurs in nearshore areas and larvae are found in estuarine
and offshore waters. Nursery areas are the same as the adult areas which include coastal areas, bays and river
mouths. The range of cobia extends throughout the Gulf nearshore areas, with the summer adult areas and
year-round nursery areas from the Mississippi Sound into Gulf waters and to the adult area (spring, summer,
and fall) and year-round nursery area that extends from just inside Gulf water, halfway into Tampa Bay.
Spawning area: occurs throughout the adult areas except in bays and estuaries in the northern Gulf,
Spring and Summer
Nursery area: coastal areas, bays and river mouths
Dolphin (Mahi-Mahi)
Dolphin are primarily an oceanic species, but occasionally enter coastal waters with high enough salinity. They
are common in coastal waters of the northern Gulf mainly during the summer months. It is an epipelagic species
known for aggregating underneath or near floating objects, especially Sargassum. Spawning occurs throughout
the adult areas of the open Gulf year-round, with peaks in early spring and fall. Larvae are usually found over
depths of greater than 50 m and are most abundant at depths over 180 m. Adults occur over depths up to 1,800
m, but are most common in waters at 40 to 200 m in depth. Nursery areas are year-round in oceanic and coastal
9 The map is available at: http://cMstensenmac.nos.noaa.gov/Gulf-efli/gtrigger.gif
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waters where salinity is high.
Spawning: throughout the adult areas in open waters of the Gulf; year-round
Nursery area: throughout the adult areas in open waters of the Gulf; year-round
Bluefish
Bluefish can be found in Gulf estuaries but are more common in estuaries and waters of the Atlantic Ocean.
Spawning grounds are located on the outer half of the continental shelf Nursery areas occur inshore along
beaches and in estuaries, inlets and rivers. Gulf distribution maps were not available for this species and
therefore EFH could not be identified, but may be assumed to include nursery areas within the Mississippi
Sound and Tampa Bay.
Spawning area: not specified in literature reviewed, EFH map not available
Nursery area: not specified in literature reviewed; EFH map not available, but probably exists within
the Mississippi Sound and Tampa Bay
5.6	Spiny Lobster Fishery
The principal habitat for the spiny lobster is offshore reefs and seagrass. Spiny lobsters spawn in offshore
waters along the deeper reef fringes. Adults are known to inhabit bays, lagoons, estuaries, and shallow banks.
According to the species distribution map, spiny lobsters use the lower half of Tampa Bay for nursery areas.
According to the GMFMC, Tampa Bay seems to be the upper limit for spiny lobster abundance due to the
higher salinities found south of the Bay. The Tampa Bay-specific distribution map indicates that spiny lobster
in the Bay are rare. However, the Gulf distribution maps indicate that Tampa Bay is used as an adult area year-
round, and as a nursery area.
Spawning area: throughout the adult area, particularly north and south of Tampa Bay; March to July
Nursery area: lower half of Tampa Bay used as nursery; year-round
5.7	Coral and Coral Reefs
The three primary areas in the Gulf where hermatypic corals are concentrated are the East and West Flower
Garden Banks, the Florida Middle Grounds, and the extreme southwestern tip of the Florida Reef Tract, the
Tortugas Ecological Reserve HAPC and the Pulley Ridge HAPC. A number of other identified areas along the
west Florida Shelf, i.e., Long Mound, Many Mounds, North Reed Site, and the West Florida Wall are all on
the west Florida shelf in depths of 200-1000 m and contain deep water (low light) coral communities. Results
from recent research expeditions indicate that the west Florida shelf may have more deep-water coral coverage
than other areas in the Gulf.
5.8	Highly Migratory Species
In addition to the managed fish species described in the previous section, another group of fish with highly
migratory habits have also been examined. This group includes billfish (blue marlin, white marlin and sailfish),
swordfish, tunas (yellow fin, bluefin and skipjack), and of sharks (black tip, bull, dusky, silky, mako, Atlantic
sharpnose, tiger and longfin mako). Most are found beyond the 50, 100 and 200 m contours.
().0 Assessment of KM I and 11A PC" in (lie (¦ nil'
The categories of EFH and HAPC for managed species which were identified in FMP Amendments of the
Gulf FMC and which may occur in marine waters of the Gulf are shown in Table 3. These habitats require
special consideration to promote their viability and sustainability. Some of the habitat categories presented in
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Table 3 are not present in the area affected by the proposed project. Impacts on habitats present or potentially
present are discussed in the following paragraphs. Descriptions of the habitats were mostly excerpted from the
Generic Amendments for Addressing EFH Requirements, HAPC, and Adverse Effects of Fishing in the
Following Fishery Management Plans for the Gulf of Mexico (GMFMC, 1998; GMFMC, 2005).
Table 3: EFH and HAPC Identified in Fishery Plan Amendments of the Gulf and
Presence in Area Affected by the Proposed Action
I I II
I'lVM'lllV
Water Column
Vegetated Bottoms
Non-vegetated Bottoms
Live Bottoms
Coral Reefs
Geologic Features
Continental shelf fisheries
West Florida Shelf
f Particular Concern	
Florida Middle Grounds
Florida Keys National Marine Sanctuary
Florida Bay
Dry Tortugas
Pulley Ridge
Madison-Swanson and Steamboat Lumps
Marine Reserves
Yes
Yes
Yes
Yes
No: solitary specimens may exist in action area
Yes
Yes
Yes
No: located
No: located
No: located
No: located
No: located
No: located
outside
outside
outside
outside
outside
outside
of action area
of action area
of action area
of action area
of action area
of action area
6.1 Water Column EFH
The flow-averaged total ammonia concentration was calculated using the loading and current velocity
information from the NCCOS modelling report for the proposed project. It was estimated that the total
ammonia discharged from the cage at the maximum fish biomass will be 9.8 kg/day and the biochemical
oxygen demand (BOD) at 59.3 kg/day. The flow-averaged ammonia concentration was estimated at about 4.7
x 10"3 mg/1 at the cage. EPA's published ammonia criteria for saltwater is 4-day average is equal to 3.5 x 10"2
mg/L, and the 1-hr average is equal to 2.33 x 10"1 mg/1. BOD is estimated at 6.8 x 10"4 mg/1. At the maximum
biomass of 36,367 kg, the max feeding rate is estimated at 399 kg/day. The maximum solid waste production
is estimated at 83 kg/day. Due to factors concerning the small size of the project and relatively small amounts
of pollutants discharged, location, over bottom depth, and average current velocity, the discharges of wastes
from the proposed project are expected to have a minor impact to water column EFH. It is expected that the
effluent will undergo rapid dilution and constituents will be difficult to detect within short distances from the
cage. 10
The proposed facility will be covered by a NPDES permit as an aquatic animal production facility with
protective conditions required by the Clean Water Act. The NPDES permit will contain conditions that will
confirm EPA's determination and ensure no significant environmental impacts will occur from the proposed
10 Further information about EPA's analysis and determination for impacts to water quality, seafloor, and benthic habitat can be found in
the final NPDES permit and the Ocean Discharge Criteria (ODC) Evaluation, as well as other supporting documents developed for the
NPDES and Section 10 permits such as the Biological Evaluation that was created to comply with the ESA and the Environmental Assessment
that was developed to comply with NEPA.
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project. The aquaculture-specific water quality conditions placed in the NPDES permit will generally include
a comprehensive environmental monitoring plan. The applicant will be required to monitor and sample certain
water quality, sediment, and benthic parameters at a background (upstream) location and near the cage
occuring at a frequency that is correlated to fish production levels. Additionally, the NPDES permit will include
effluent limitations expressed as best management practices (BMPs) for feed managment, waste collection and
disposal, harvest discharge, carcass removal, materials storage, maintenance, record keeping, and training.
Moreover, the NPDES permit will also require a quality assurance plan to ensure appropriate standards are
met when sampling and emergency management plan to establish operational procedures during disaster events
such as hurricanes.
6.2 Benthic EFH
Discharges from net-pen aquaculture can impact benthic habitat due to the deposition of solid wastes,
comprised of fish feces and uneaten food, onto the seafloor. Due to factors concerning the small size of the
project and relatively small amounts of pollutants discharged, location, over bottom depth, and average current
velocity, the discharges of solid wastes from the cage are expected to have only minor impacts on benthic
habitat and the supported communities.
Modeling of the project estimates the total solids discharge occurring at maximum fish biomass to be about 83
kg/day and organic carbon at 28 kg/day. The slow settling velocities of fecal and food pellets, 0.032 m/s and
0.095 m/s respectively, and variability in current directionality, should cause solids deposition to be distributed
over a large area of the seafloor. Assuming a direct relationship between waste loading and fish biomass, based
on several estimates from large scale fish farms, it's roughly estimated that the maximum solids load to the
seafloor will range from 1.0-4.0 g/m2/day with about 35% of that as organic carbon.
6.2.1	Vegetated Bottoms
Seagrasses and macroalgae have long been recognized as important primary producers in marine habitats. Due
to the depths of the area affected by the proposed draft permit, seagrasses are unlikely to be present. The
distribution of benthic algae is ubiquitous throughout the Gulf from bays and estuaries out to depths of 200 m.
It is a significant source of food for fish and invertebrates. The wide gently sloping continental shelf,
particularly in the eastern Gulf, provides a vast area where benthic species of algae can become established
and drift along the bottom and continue to grow even when detached from the substrate. Benthic algae also
form large mats that drift along the bottom. The cage employed will be anchored within an expanse of
unconsolidated sediments unlikely to have attached algal communities. Nutrient loading from the small
amounts of deposited solid wastes are not likely to effect marine plants.
6.2.2	Unconsolidated Sediments
Unconsolidated sediments provide habitat for a diverse invertebrate community consisting of several hundred
of burrowing species and well as benthic fish and macro-invertebrate communities living directly on the sea
floor. These habitats also provide foraging for fishes associated with nearby demersal habitat. Unconsolidated
seafloor habitat may affect shrimp and fish distributions directly in terms of feeding and burrowing activities
or indirectly through food availability, water column turbidity, and related factors. The small amounts of solid
waste deposition predicted from the proposed project should minimize any potential physical impacts to
unconsolidated seafloor habitat. Organic carbon loading is likely to have little measurable effect on associated
benthic communities.
6.2.3	Live Bottoms
Live bottoms are defined as those areas that contain biological assemblages consisting of such sessile
invertebrates as sea fans, sea whips, hydroids, anemones, ascidians, sponges, bryozoans, seagrasses, or corals
living upon and attached to naturally occurring hard or rocky formations with rough, broken, or smooth
topography favoring the accumulation of turtles and fishes. These communities are scattered across the shallow
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waters of the west Florida Shelf and within restricted regions of the rest of the Gulf. Hard substrate on the west
Florida shelf ranges from scattered low relief limestone outcroppings to major structures or groups of structures
which are high relief, biologically developed areas with extensive inhabitation by hermatypic corals, octocorals
and related communities. Additionally, the NPDES will require the proposed facility to be placed at least 500
meters from any hardbottom habitat to protect those communities from physical impacts due to the deposition
of solids and potential impacts due to organic enrichment; the DA permit will not authorize the anchor system
to be placed on vegetated and/or hardbottom habitat (see mitigation measures shown in Section 7).
6.2.4 West Florida Shelf
The west Florida shelf is composed mainly of carbonate sediments. These sediments are in the form of quartz-
shell sand (> 50 percent quartz), shell-quartz sand (< 50 percent quartz), shell sand, and algal sand. The bottom
consists of a flat limestone table with localized relief due to relict reef or erosional structures. The benthic
habitat types include low relief hardbottom, thick sand bottom, coralline algal nodules, coralline algal
pavement, and shell rubble. The west Florida shelf provides a large area of scattered hard substrates, some
emergent, but most covered by a thin veneer of sand, that allow the establishment of a tropical reef biota in a
marginally suitable environment. The only high relief features are a series of shelf edge prominences that are
themselves the remnants of extensive calcareous algal reef development prior to sea level rise and are now, in
most cases, too deep to support active coral communities.
Along the west Florida shelf are areas with substantial relief. In an area south of the Florida Middle Grounds,
in water depths of 46 to 63 m, is a ridge formed from limestone rock termed the Elbow, and it is about 5.4 km
at its widest and has a vertical relief of 6.5 to 14 m. South of Panama City are two notable areas with high
relief. The Madison Swanson Marine Reserve are in 66 to 112 m of water and have rock ledges with 6 to 8 m
of relief and are covered with coral and other invertebrate growth. The Mud Banks are formed by a ledge that
has a steep drop of 5 to 7 m. The ledge extends for approximately 11 to 13 km in 57 to 63 m of water. The "3
to 5s", a series of ledges located southwest of Panama City, occur in water depths of 31 to 42 m of water. The
ledges are parallel to the 36.5-m isobath and have relief of 5.5 to 9 m. The features listed above are part of a
larger area of shelf-edge reefs that extend along the 75-m isobath offshore of Panama City to just north of the
Tortugas which also includes the Twin Ridges, The Edges, Steamboat Lumps Marine Reserve (Koenig et. al:
2000). According to Koenig et. Al (2000), the northeastern portion of this area represents the dominant
commercial fishing grounds for gag and contains gag and scamp spawning aggregation sites. Two of the areas,
Madison Swanson and Steamboat Lumps, were designated as marine reserves on June 19, 2002 for a four-year
period to protect a portion of the gag spawning aggregations and to protect a portion of the offshore population
of male gag.
Another west Florida shelf region with notable coral communities is bounded by the waters of Tampa Bay on
the north and Sanibel Island on the south. The area consists of a variety of bottom types. Rocky bottom occurs
at the 18 m contour where sponges, alcyonarians, and the scleractinians Solenastrea hyades and Cladocora
arbuscula are especially prominent.
The Pulley Ridge HAPC is a 100+ km-long series of north-south trending, drowned, barrier islands
approximately 250 km west of Cape Sable, Florida. The ridge is a subtle feature about 5 km across with less
than 10 m of relief. The shallowest parts of the ridge are about 60 m deep. The southern portion of the ridge
hosts an unusual variety of zooxanthellate scleractinian corals, green, red and brown macro algae, and typically
shallow-water tropical fishes. The corals Agaricia sp. and Leptoceris cucullata are most abundant, and form
plates up to 50 cm in diameter and account for up to 60% live coral cover at some localities. Less common
species include: Montastrea cavernosa, Madracis formosa, M. decactis, Porities divaricata, and Oculina
tellena. Sponges, calcareous and fleshy algae, octocorals, and sediment occupy surfaces between the corals.
Coralline algae appear to be producing as much or more sediment than corals, and coralline algal nodule and
cobble zones surround much of the ridge in deeper water (greater than 80 m). The fishes of Pulley ridge
comprise a mixture of shallow water and deep species with more than 60 species present.
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7.0 I'odei'iil Action A«eiu\v l)eloniiin;ilion iind \lhi»;ilion
The implementing regulations of MS A define adverse effect as "any impact that reduces quality and/or quantity
ofEFH. Adverse effects may include direct or indirect physical, chemical, or biological alterations of the
waters or substrate and loss of, or injury to, benthic organisms, prey species and their habitat, and other
ecosystem components, if such modifications reduce the quality and/or quantity ofEFH. Adverse
effects to EFH may result from actions occurring within EFH or outside ofEFH and may include site-specific
or habitat-wide impacts, including individual, cumulative, or synergistic consequences of actions" (50 CFR
600.910(a)).
The EPA and USACE have determined that the minimal short-term impacts associated with the discharge will
not result in substantial adverse effects on EFH, HAPC, or managed species in any life history stage, either
immediate or cumulative, in the proposed project area. A summary of findings is presented in Table 4. Any
potentially harmful physical characteristics and chemical constituents present at the time of discharge should
disperse rapidly as the waste streams undergo physical dilution processes. Major adverse impacts to any
benthic or demersal EFH are unlikely to occur as a result of the discharge. The high degree temporal and spatial
patchiness regarding the distribution of plankton assemblages in the water column should greatly limit
plankton exposure to potentially harmful water quality conditions. Major adverse impacts to any benthic EFH
are unlikely to occur because of the installation of the proposed MAS mooring system.
The EPA will require mitigation measures to be incorporated into the NPDES permit to avoid or limit organic
enrichment and physical impacts to habitat that may support associated hardbottom biological communities.
The NPDES permit will require a condition that the proposed project must be positioned at least 500 m from
any hardbottom habitat. The DA permit condition will state that the proposed MAS anchor system shall be
installed on substrate devoid of vegetated and/or hardbottom habitat.
The federal action agencies used multiple sources to support the determinations described within this EFH
assessment including the analysis of potential impacts that the NMFS used as the basis for its EFH
determination for up to twenty commercial scale offshore marine aquaculture facilities in the Gulf (NMFS,
2009). Additionally, the EFH determination for the proposed project is also supported by the NMFS'
concurrence with EPA's EFH determination for the eastern Gulf Oil and Gas General NPDES Permit (NMFS,
2016). These assessments and determinations have been provided to the NMFS and are incorporated by
reference pursuant to 50 CFR § 600.920(e)(5).11 The EPA and USACE request concurrence from the NMFS
for this EFH determination under the MSA Section 305(b)(2).
11 50 CFR § 600.920(e)(5) states that "The assessment may incorporate by reference a completed EFH Assessment prepared for a similar
action, supplemented with any relevant new project specific information, provided the proposed action involves similar impacts to EFH in
the same geographic area or a similar ecological setting. It may also incorporate by reference other relevant environmental assessment
documents. These documents must be provided to NMFS with the EFH Assessment."
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Table 4: Summary of Potential Impacts to EFH and Geographically Defined HAPC
Continental Shelf Fisheries
Coral Reefs
Geologic Features
Live Bottoms
Non-vegetated Bottoms
Vegetated Bottoms
Water Column
West Florida Shelf
.11 \ivmiI I'.iriii'iil.ir < inKiTii
I).
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Dry Tortugas	No
Florida Bay	No
Florida Keys National Marine Sanctuary	No
Florida Middle Grounds	No
Madison-Swanson and Steamboat Lumps	No
Marine Reserves
No Significant Impact
No Significant Impact
No Significant Impact
No Significant Impact
No Significant Impact
No Significant Impact
No Significant Impact
No Significant Impact
No exposure
Not present
No exposure
Limited solid waste deposition
Limited solid waste deposition
Limited solid waste deposition
Low levels of ammonia and BOD will
be quickly diluted and dissipated
Limited solid waste deposition
Presence i
Assessment
Reas
No Significant Impact	Avoided
No Significant Impact	Avoided
No Significant Impact	Avoided
No Significant Impact	Avoided
No Significant Impact	Avoided
Pulley Ridge
No
No Significant Impact Avoided
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References
Gulf Fishery Management Council. 1998. General Amendment for Addressing EFH Requirements in the
Fishery Management Plans of the Gulf.
Gulf Fishery Management Council. 2003. Reef Fish Amendment 21, Continuation of Madison-Swanson and
Steamboat Lumps Marine Reserves, to be Reviewed via Conference Call. News Release. April 8, 2003.
Gulf Fishery Management Council. 2005. General Amendment Number 3 for Addressing EFH Requirements
in the Fishery Management Plans of the Gulf.
Gulf Fishery Management Council. 2010. 5-Year Review of the Final Generic Amendment Number 3.
Addressing EFH Requirements, Habitat Areas of Particular Concern, and Adverse Effects of Fishing in the
Fishery Management Plans of the Gulf.
Koenig, CC, Coleman, CC, Grimes, CB, Fitzhugh, GR, Scanlon, KM, Gledhill, CT, Grace, M. 2000. Protection
of Fish Spawning Habitat for the Conservation of Warm-Temperate Reef-Fish Fisheries of Shelf-Edge Reefs
of Florida. Bulletin of Marine Science, 66(3): 593-616, 2000.
NMFS (National Marine Fisheries Service). 2000. EFH: A Marine Fish Habitat Conservation Mandate for
Federal Agencies. St. Petersburg, FL.
NMFS (National Marine Fisheries Service). 2009. Essential Fish Habitat (EFH) Review of the Fishery
Management Plan for Regulating Offshore Marine Aquaculture in the Gulf of Mexico.
NMFS (National Marine Fisheries Service). 2015. EFH-Gulf. NOAA Southeast regional Office. Ver: 082015.
http://sero.nmfs.noaa.gov/habitat_conservation/efh/guidance_docs/efh_gmfmc_ver082015.pdf
NMFS (National Marine Fisheries Service). 2016. EFH concurrence for the eastern Gulf of Mexico Oil and
Gas General NPDES Permit.
U.S. Department of Commerce and U.S. Department of Interior. Federal Inventory Sites of the Eastern Gulf
Region. http://www.mpa.gov/mpaservices/atlas/Gulf/gome.thml.
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Appendix A - Cage and Mooring Detail
PROFILE. VIEW
/—BRIDLE LINE: HDPE PIPE WITH ROPE INSIDE
5DAR BUO'i
O0--T
BUOY
CURRENT DIRECTION
ROPE
BALLAST TANK
CONCRLIl BA_Li.S!
HAi'-i
DEAD WEIGH
ANCHOR
1)	Deadweight Anchors (concrete):
•	Three (3) anchors equally spaced
o 120m from mooring centerline
o 120 degrees from each other
•	Each @ 4.5m x 4.5m x 4.5m (91 m3)
•	Concrete friction factor = 0.5 on wet sand
•	Each has an effective weight of 217 MT
2)	Mooring Chain (Grade 2 steel):
•	80m length on each anchor
•	50mm (2") thick links
•	No load = 70m length of each on seafloor
•	Design load = some entirely off seafloor/
others completely on seafloor
3)	Mooring lines (rope):
•	40m length on each chain
•	AMSTEEL®-BLUE
•	36mm (1 1/2") thick lines
4)	Spar Buoy w/ Swivel (steel):
5)	Bridle Lines (rope inside HDPE pipe):
•	Three (3) ~30m bridle lines (rope) from swivel to
spreader bar
AMSTEELS-BLUE
•	33.3mm (1 5/16") lines inside HDPE pipe
6)	Spreader Bar (HDPE):
•	Header Bar (load bearing) connected to Bridle Lines
o 30m in length
o 0.36m OD DR 11 HDPE pipe
•	Side and Rear Bars (smaller load bearing)
o 30m in length
o 0.36m OD DR 17 HDPE pipe
•	Four (4) corner spar buoys
7)	Net Pen Connection Lines (rope):
•	Four (4) ~13m connection lines (rope)
•	Connected from Spreader Bar to Net Pen Float Rings
AMSTEELe-BLUE
•	33.3mm (1 5/16") lines
8)	Net Pen Frame Structure (HDPE):
•	Top Frame Structure
o 18m in diameter
o One (1) HDPE side-by-side Float Rings
¦	On the sea surface
¦	~ 0.36m OD DR 11 HDPE pipe
o One (1) HDPE net ring (railing)
¦	Connected ~ 1.0m above Float Rings
¦	Connected to Net Pen Mesh
¦	-0.15m OD DR 17 HDPE pipe
•	Bottom Frame Structure
o 18m in diameter
o One (1) HDPE sinker ring
¦	7.0m below Float Rings
¦	Connected to Net Ring
¦	~ 0.36m OD DR 11 HDPE pipe
o One (1) HDPE net ring
¦	7.0m below float rings
¦	Connected to copper alloy mesh
~ 0.15m OD DR 17 HDPE pipe
9)	Net Pen Mesh (copper alloy):
•	17m diameter x 7m depth
•	Top connected to top net ring (railing)
•	Bottom connected to bottom net ring
o 4mm wire diameter
o 40mm x 40mm mesh square
•	Effective volume of 1,600m3
10)	Shackle Point Connection (steel):
•	One (1) ~0.13m2 shackle plate
•	Four (4) connection lines
o 12 mm in diameter x 10m in length
o Connected from shackle plate to HDPE sinker ring
•	~lm Grade 2 steel chain (32mm) connected to Floatation
Capsule
11)	Floatation Capsule (steel):
•	~ 15m in diameter x~3.45m in length
•	Effective floatation volume = 6m3
•	~3m Grade 2 steel chain (32mm) connected to Counter Weight
12)	Counter Weight (concrete):
•	~ 1.1m in diameter x ~2.2m in length
•	Effective weight of 5 MT
EFH Assessment
Kampachi Farms - Velella Epsilon
Page 19 of 20

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Appendix B - Location Area
VE Project - Modified Site B & Pen Placement
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PR0tiC>
# - *	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8980
m v • • c	MAR I 8 2019
Ms. Virginia Fay
Assistant Regional Administrator
National Oceanic and Atmospheric Administration
National Marine Fisheries Service
Southeast Regional Office
Habitat Conservation Division
263 13th Avenue South
St. Petersburg, Florida 33701-5505
SUBJECT: Essential Fish Habitat Consultation Request
Kampachi Farms, LLC - Velella Epsilon Marine Aquaculture Facility
Dear Ms. Fay:
The U.S. Environmental Protection Agency Region 4 (EPA) and the U.S. Army Corps of Engineers
Jacksonville District (USAGE) are obligated under Section 305(b)(2) of the Magnuson-Stevens Act (MSA)
to consult with the National Marine Fisheries Service (NMFS) to ensure that any action it authorizes will not
adversely affect essential fish habitat (EFH). The purpose of this letter is to request the initiation of an
abbreviated consultation with the NMFS under MSA Section 305(b)(2).
On November 9,2018, the EPA received a complete application for a National Pollutant Discharge
Elimination System (NPDES) permit from Kampachi Farms for the discharge of pollutants from a marine
aquaculture facility in federal waters of the Gulf of Mexico (Gulf). On November 10, 2018, the USAGE
received a Department of Army (DA) application pursuant to the Rivers and Harbors Act, 1899 (Section 10)
for structures and work affecting navigable federal waters from the same marine aquaculture facility. On
behalf of the two federal agencies responsible for permitting aquaculture operations in federal waters of the
Gulf, the EPA is requesting initiation of the abbreviated EFH consultation process for the two federal permits
needed to operate the proposed marine aquaculture facility pursuant to the MSA implementing regulations at
50 CFR § 600.920(h).
Given that the action of permitting the proposed project invokes more than one federal agency, the EPA has
elected to act as the lead agency to fulfill the consultation responsibilities as allowed by 50 CFR §
600.920(b).1 This consultation request shall also serve as the written notice to the NMFS that the EPA is
acting as the lead agency as required by 50 CFR § 600.920(b), The USAGE is a cooperating and co-federal
agency for this abbreviated consultation request. The completion of this consultation shall satisfy the EPA's
and USACE's obligations under MSA Section 305(b)(2).
The attached EFH Assessment was prepared by the EPA and the USAGE to jointly consider the potential
effects that the proposed actions may have on EFH under the jurisdiction of the NMFS as required by 50
CFR § 600.920(e)(1). In the attached EFH assessment, the EPA and the USAGE have determined that the
1 50 CFR § 600.920(b) allows a lead agency: "If more than one Federal agency is responsible for a federal action, the consultation
requirements of sections 305(b)(2) through (4) of the Magnuson-Stevens Act may be fulfilled through a lead agency. The lead agency should
notify NMFS in writing that it is representing one or more additional agencies."
Interns! Address {URL) • http://www.9pa.gov
Recycled/Recyclable • Primed with Vegetable Oil Based Inks on Recycled Paper (M-nimum 30% Postconsumer)

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proposed actions will not result in substantial adverse effects on EFH and have further determined that the
permits being Issued by the EPA and the USAGE will include conditions to mitigate the minor impacts that
may occur as a result of the proposed actions. We would like to request that the NMFS respond In writing
within 30 days of receiving the EFH Assessment, The response should stale whether the NMFS concurs or
does not concur with the determination made by the EPA and USAGE. If the NMFS does not concur with the
assessment determination made by the EPA and USACE, please provide any conservation recommendations
and/or indicate whether expanded consultation is needed to review the proposed project's impacts on EFH.
The EPA and USACE are coordinating the interagency permitting process in accordance with the
interagency Memorandum of Understanding (Aquaculture MOU) for Permitting Offshore Aquaculture
Activities in Federal Waters of the Gulf,2 and conducting a comprehensive analysis of all applicable
environmental requirements required by the National Environmental Policy Act (NEPA); however, a
consolidated process under NEPA is riot being used to satisfy the requirements of MSA as described in 50
CPR § 600.920(e)(1),3 The NMFS is a cooperating agency for the NEPA analysis and has provided scientific
expertise related to the EFH Assessment and NEPA analysis for the proposed facility, including information
about: site selection, marine mammal protection, and the Endangered Species Act While some information
related to the EFH Assessment is within the coordinated NEPA evaluation developed by multiple federal
agencies, the attached EFH Assessment is being provided as a stand-alone document to comply with the
consultation process under the MSA, The EPA arid USACE will use the EFH consultation concurrence from
the NMFS to support the NEPA analysis for each federal agency action and, If appropriate, a finding of no
significant impacts.
If you have any questions about the EFH assessment or consultation, please contact Ms. Molly Davis
(Davis.MolIy@epa.gov or 404-562-9236).
Sincerely,
Mary Jo Brdgari, Chief
NPDES Permitting ana Enforcement Branch
Water Protection Divison
cc: Ms. Katy Damico, USACE (via email)
Dr. Jess Beck-Stimpert, NMFS (via email)
2	On February 6, 2017, the Memorandum of Understanding for Permitting Offshore Aquaculture Activities in Federal Waters of the Gulf of
Mexico became effective for seven fetters' -~'-s with permitting or authorization responsibilities.
3	50 CFR § 600.920{e)( 1) states that "Feds	ies may incorporate an EFH Assessment into documents prepared for other purposes such
as Endangered Species Act (ESA) Biota; essments pursuant to 50 CPR part 402 or National Environmental Policy Act (NEPA)
documents and public notices pursuant to 		.'art 1500,"

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/*:\
*
UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
NATIONAL MARINE FISHERIES SERVICE
Southeast Regional Office
283 13th Avenue South
St. Petersburg, Flonca 33701-5505
hl!p:/teero.nmfs noaa.gov
March 12, 2019 F/SER46:MS/RS
Ms. Mary Jo Bragan, Chief
NPDES Permitting and Enforcement Branch
Water Protection Division
United States Environmental Protection Agency
Region 4, Atlanta Federal Center
61 Forsyth Street
Atlanta, Georgia 30303-8960
Dear Ms. Bragan,
NOAA's National Marine Fisheries Service (NMFS), Southeast Region, Habitat Conservation
Division has reviewed your letter dated March 8, 2019, and essential fish habitat (EFH)
Assessment regarding issuance of the U.S. Environmental Protection Agency's (EPA) National
Pollutant Discharge Elimination System (NPDES) Permit Number FL0A00001. The EPA
received an application for a NPDES permit from Kampachi Farms for the discharge of
pollutants from a marine aquaculture facility proposed in federal waters of the Gulf of Mexico in
130 feet of water approximately 45 miles southwest of Sarasota, Florida. The applicant proposes
to operate a pilot scale marine aquaculture facility rearing up to 20,000 almaco jack (,Seriola
rivoliana) for a period of approximately 12 months. The U.S. Army Corps of Engineers
(USACE) also received an application for a Rivers and Harbors Act Section 10 Permit for
structures and work affecting navigable federal waters at the same facility. Permitting the
proposed facility requires authorizations from both the USACE and EPA; however, the EPA is
serving as the lead federal agency for this action including completing the EFH consultation.
Detailed information on federally managed fisheries and their EFH is provided in the 2005
Generic Amendment of the Fishery Management Plans for the Gulf of Mexico prepared by the
Gulf of Mexico Fishery Management Council and in the 2009 Amendment 1 to the Consolidated
Atlantic Highly Migratory Species (HMS) Fishery Management Plan prepared by the NMFS as
required by the Magnuson-Stevens Act Fishery Conservation and Management Act (Magnuson-
Stevens Act). As specified in the Magnuson-Stevens Act, EFH consultation is required for
federal actions which may adversely affect EFH.
In providing its EFH Assessment the EPA and USACE have determined issuance of the NPDES
and Section 10 Permits for the Kampachi Farms project will not result in substantial adverse
effects on EFH. The Permits will include conditions to mitigate the minor impacts that may
occur as a result of the proposed actions.
We have reviewed the EFH Assessment and concur with your determination, and have no EFH
Conservation Recommendations to provide. Assuming the NPDES and Section 10 Permits are
not revised, this satisfies the consultation procedures outlined in 50 C.F.R. Section 600.920 of
the regulation to implement the EFH provisions of the Magnuson-Stevens Act.
A

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Thank you for your consideration of these comments. Please contact Mr. Mark Sramek at the
letterhead address, through email at Mark. Sramek@noaa.gov or by calling (727) 824-5311 if you
have questions regarding these comments.
Sincerely,
/}
m -
Virginia M. Fay
Assistant Regional Administrator
Habitat Conservation Division
cc: File
DIR Blough
F/SER Silverman, Beck-Stimpert
F/SER2 Malinowski
F/SER3 Bernhart, Lee, Powell
F/SER4 Fay, Dale, O'Day
F/SER46 Sramek
NOS NCCOS Riley
USACE Tampa Damico
2

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From:	Wahlstrom-Ramler. Meghan
To:	mark.sramek(anoaa.aov
Subject:	Updated EFH Assessment Document - Kampachi Farms, LLC - Velella Epsilon
Date:	Friday, August 2, 2019 3:04:00 PM
Attachments:	Updated EFH Assessment - Kampachi Farms.pdf
Mr. Sramek,
On March 8, 2019 EPA provided the EFH assessment for the Velella Epsilon project to the NMFS and
initiated consultation with the NMFS. On March 12, 2019, the NMFS concurred with the EFH
determination made by the EPA and the USACE. After completion and concurrence of the
assessment, minor changes were made to the EFH document.
As per our conversation on Monday, July 29th I am providing the updated document attached to this
email. The changes do not change the determination that the proposed actions will not result in
substantial adverse effects on EFH and the EPA and USACE permits will still include conditions to
mitigate the minor impacts that may occur as a result of the proposed actions. I've highlighted the
changes and they can be found on pages 4, 5, 15, 16.
We request that the NMFS respond in writing (by letter or email) within 30 days of receiving the EFH
Assessment. The response should state whether the NFMS concurs or does not concur with the
determination made by the EPA and USACE, taking into consideration the changes made to the
document. If the NMFS no longer concurs with the assessment determination made by the EPA and
USACE, please provide any conservation recommendations and/or indicate whether expanded
consultation is needed to review the proposed project's impacts on EFH.
Thank you,
Meghan Wahlstrom
Meghan Wahlstrom | Environmental Engineer | Permitting & Grants Branch | Water Division
Special Emphasis Program Manager for the Federal Women's Employment Program (FWP)
Region 4 | Atlanta Federal Center | 61 Forsyth Street SW | Atlanta, GA 30303-8960
(404) 562-9672 | Wahlstrom-ramler.meghan@epa.gov

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Appendix F

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Coastal Aquaculture Siting and Sustainability
NCCOS/National Ocean Service
'Went of

CASS Technical Report
Environmental Modelling to Support NPDES Permitting for
Velella Epsilon Offshore Demonstration Project in the
Southeastern Gulf of Mexico
Lead Scientists: Kenneth Riley, Ph.D. and James Morris, Ph.D.
Environmental Engineer: Barry King, PE
Submitted to Jess Beck (NMFS) and Kip Tyler (EPA), July 19, 2018
This analysis uses an environmental model to simulate effluent to inform the NMFS Exempted
Fishing Permit (EFP) and EPA National Pollutant Discharge Elimination System (NPDES) Permit
for the Velella Epsilon Offshore Demonstration Project. Kampachi Farms, LLC (applicant)
proposes to develop a temporary, small-scale demonstration net pen operation to produce two
cohorts of Almaco Jack (Seriola rivoliana) at a fixed mooring located on the West Florida Shelf,
approximately 45 miles offshore of Sarasota, Florida (Figure 1; Table 1). Scientists from the
NOAA Coastal Aquaculture Siting and Sustainability (CASS) program worked with the EPA
project manager and the applicant to develop estimates of effluents and sediment related
impacts for the offshore demonstration fish farm.
A numerical production model for two cohorts of Almaco Jack was constructed based upon
anticipated farming parameters including configuration (net pen volume and mooring
configuration), fish production (species, biomass, size) and feed input (feed rate, formulation,
protein content). Using industry standard equations, daily estimates of biomass, feed rates, total
ammonia nitrogen production, and solids production (see Microsoft Excel Spreadsheet - Velella
Epsilon Production Model) were developed under a production scenario to estimate the
maximum biomass of 20,000 fish that would be grown to 1.8 kg in approximately 280 days. The
total biomass produced with one cohort and no mortality was determined to be 36,280 kg. The
density in the cage at harvest would be 28 kg/m3. Fish will be fed a commercially available
growout diet with 43% protein content. Daily feed rations range from 12 kg at stocking to a
maximum total daily feed ration equivalent to 399 kg at harvest. Maximum daily excretion of
total ammonia nitrogen is estimated at 16 kg and solids production is 140 kg. A total of 66,449
The Coastal Aquaculture Siting and Sustainability (CASS) program supports works to provide science-based decision
support tools to local, state, and federal coastal managers supporting sustainable aquaculture development The CASS
program is located with the Marine Spatial Ecology Division of the National Centers for Coastal Ocean Science, National
Ocean Service, NOAA. To learn more about CASS and how we are growing sustainable marine aquaculture practices at:
https: //coastalscience.noaa.gov/research/marine-spatial-ecologv/aquaculture/ or contact Dr. Ken Riley at
Ken.Rilev(5)noaa.gov.

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kg of feed will be used for production of each cohort of fish to achieve a feed conversion ratio
(FCR) of 1.8. Summary statistics were developed for each cohort and the entire project (Table
2).
Table 1. Boundary locations for the Velella Epsilon Offshore Aquaculture Project.
Location	Latitude	Longitude
Northwest corner	27.072360 N	-83.234709 W
Northeast corner	27.072360 N	-83.216743 W
Southwest corner	27.056275 N	-83.216743 W
Southeast corner	27.056275 N	-83.234709 W
83=15^	83'10'W
Florida, USA
0 50 100 km
Bathymetry (m)
Scale: 1:100,000
0.8
o _
47
3 km
frvtce Layer Credits: Sources. Esri. GEBCO, NOAA, National Geographic,
imtin, HERE. Geonames org, and other contributors
Figure 1. Bathymetric map of proposed Velella Epsilon Offshore Aquaculture Project.
Page 2

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Table 2. Summary statistics for the Velella Epsilon Offshore Aquaculture Project.
Farming parameter
Growout duration
Total number
Individual size at harvest
Maximum biomass
Cage density at harvest
Maximum daily feed rate
Total feed used
Feed conversion ratio
Value
280 days per cohort
20,000 fish per cohort
1.8 kg
36,280 kg
28 kg/m3
399 kg
66,449 kg
1.8
In order to estimate sediment related impacts, a depositional model (DEPOMOD; Cromey et al
2002) was parameterized with data from the production model and environmental and
oceanographic data on the proposed offshore location. DEPOMOD is the most established and
widely used depositional model for estimating sediment related impact from net pen operations.
DEPOMOD is a particle tracking model for predicting the flux of particulate waste material (with
resuspension) and associated benthic impact of fish farms. The model has been proven in a wide
range of environments and is considered through extensive peer-review to be robust and
credible (Keeley et al 2013). Although this modelling platform was initially developed for
salmon farming in cool-temperate waters (Scotland and Canada), it has since been applied and
validated with warm-temperate and tropical net pen production systems (Magill et al. 2006;
Chamberlain and Stucchi 2007; Cromey etal. 2009; Cromey et al. 2012). Coastal managers
responsible for permitting aquaculture worldwide have been using this modelling platform
because it produces consistent results that are field validated and comparable (Chamberlain and
Stucchi 2007; Keeley et al 2013). It is routinely used in Scotland and Canada to set biomass (and
thereby feed use) limits and discharge thresholds of in-feed chemotherapeutants (SEPA 2005).
Further, the model output has been used to develop comprehensive and meaningful monitoring
programs that ensure environmentally sustainable limits are not exceeded (ASC 2012).
Traditionally a baseline environmental survey is used to inform water quality and depositional
models with site specific analysis of currents, tidal flows, sediment profiles, and benthic infaunal
profiles (species richness and abundance). In the absence of a survey, data were collected from
oceanographic and environmental observing systems in the vicinity of the project area. Current
data were obtained from NOAA Buoy Station 42022 along the 50-m isobath and located 45 miles
northwest of the project location (27.505 N, 83.741 W). Currents were recorded continuously
from July 2015 through April 2018. Currents were measured at 1-meter intervals from 4.0
meters to 42.0 meters below the surface (Table 3). Bathymetric data were obtained from the
Page 3

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NOAA Coastal Relief Model. Bathymetry was resampled to 10 x 10 meter grid cells using a
bilinear interpolation to all for use within the deposition model.
Table 3. Water column related impacts for the Velella Epsilon Offshore Aquaculture Project.
Values represent summation of daily values over a 280-day production cycle.
Parameter	Value (kg)
Total solids production	23,257
Total ammonia nitrogen	2,743
Total oxygen consumption	16,612
Total carbon dioxide production	19,187
The depositional model was executed for two different production simulations that assume
maximum standing biomass and maximum feed rate, which is characteristic when the fish are at
pre-harvest size. The first simulation represented the maximum standing biomass for the Velella
Epsilon Offshore Aquaculture Project. The model was run for 365 days assuming a net pen with
a constant daily standing biomass at 36,275 kg (28 kg/m3) and a daily feed rate of 1.1 percent of
biomass or equivalent to 399 kg of feed. The second simulation doubled production to assess
sediment related impacts at higher levels of biomass and feed rates. The second simulation at a
higher level of production was intended to aid EPA in development of an environmental
monitoring program. Under the second simulation, the model was run for 365 days assuming
two net pens each with a combined constant daily standing biomass at 72,550 kg (28 kg/m3 per
net pen) and a daily feed rate of 1.1 percent of biomass or equivalent to 798 kg of feed.
Waste feed and fish fecal settling rates are important determinants of distance that these
particles will travel in the current flow. The model does not allow the settling velocity of
particles to change through the growing cycle. The values used for feed and feces represented
those that would be encountered during the period of highest standing biomass, largest feed
pellet size, and highest waste output. Each simulation assumed maximum standing biomass each
day of the simulation with a fecal settling velocity at 3.2 cm/s. Many marine fish have fecal
settling velocities ranging from 0.5 to 2.0 cm/s, while salmonids tend to have higher settling
velocities ranging from 2.5 to 4.5 cm/s. Fecal settling velocities applicable to salmon production
were used because they are well studied, validated, and allow for maximum benthic impact
assessment. Standard feed waste was estimated at 3% and the food settling velocity was 9.5
cm/s. Pelleted fish feed is the single largest cost of fish farming, and because of this expense,
farms use best feeding practices to ensure minimal loss. Feed digestibility and water content
were set at 85% and 9%, respectively, which are standards based on technical data provided by
feed manufacturers. All other model parameters were consistent with existing net pen farm
waste modelling methodologies (Cromey et al. 2002a,b) and regulatory farm modelling
standards (SEPA 2005).
Page 4

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(A) 4-m depth
Curr»«l v»locHy
{cnv1®)
¦	>60 I
¦	50 1-60.0
¦	40 1 — SO 0
I	30.1-40.0
¦	20 1 - 30.0
¦	10 1-20.0
¦	0.0-10.0
(B) 24-m depth
H
NMW	NN(
Current velocity
(emi's)
¦	>60 1
¦	50,1 -B0.0
¦	40 1 - SO.O
¦	30.1-40.0
¦	20.1-30.0
¦	10 1-200
¦	Q.0-10.0
(C)36-m depth
M
KKW	"**	NNE
Curre/M velocity
[cmi's)
¦f >60 1
¦	50 1-60.0
¦	40.1-50.0
| 30 1-40.0
¦	20.1-30.0
¦	10.1-20.0
¦	00-100
Figure 2. Distribution of current velocities (cm/s) and direction for NOAA Buoy Station 42022
located along the 50-m isobath approximately 45 miles northwest of project location. Currents
are reported for water column depths of 4 m, 24 m, and 36 m.
Page 5

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Table 4. Current velocities (cm/s) for NOAA Buoy Station 42022 located along the 50-m isobath
approximately 45 miles northwest of project location. Average current velocities are reported
with standard deviation.
Depth	Average current	Maximum current
(m)	(cm/s)	(cm/s)
4	14.6 ± 8.1	83^9
10	12.8 ±8.0	80.3
20	12.2 ± 7.3	67.6
30	13.8 ±8.2	70.8
40	12.9 ± 7.6	68.7
Table 5. Model settings applied for depositional simulations of an offshore fish farm in the Gulf
of Mexico.
Input variable	Setting
Feed wastage	3%
Water content of feed pellet	9%
Digestibility	85%
Settling velocity of feed pellet	0.095 m/s
Settling velocity of fecal pellet	0.032 m/s
Offshore fish farms can be managed in terms of maximum allowable impacts to water quality
and sediment that are based on quantifiable indicators. This project will be difficult to monitor
and detect environmental change because of the relatively low level of production associated
with a demonstration farm and the nature of the net pen configuration deployed and moving
about on a single point mooring.
Overall, this analysis found that the proposed demonstration fish farm is not likely to cause
significant adverse impacts on water quality, sediment, or the benthic infaunal community.
Water quality modelling demonstrated that at the maximum farm production capacity of 36,280
kg only insignificant effects would occur in the water column. We believe that the excreted
ammonia levels of 16 kg per day will be rapidly diluted to immeasurable values near (within 30
meters) of the net pen under typical flow regimes of 12.8 ± 8.0 cm s_1. Dilution models could be
used to estimate nearfield and farfield dilution as used in conventional ocean outfall systems.
Page 6

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However, based on our experience with offshore aquaculture installations and development of
modeling and monitoring programs, we believe that ammonia levels will be difficult to detect
beyond the zone of initial dilution.
The model does not allow the net pen or mooring configuration to move in space or time,
therefore, the model was executed at a fixed location (27.064318, -83.225726) in the center of
the project location (i.e., farm footprint). Net depositional flux was predicted in g nr2 yr1 on a
two-dimensional grid overlaid on the farm footprint. The grid size was selected such that it
would encompass the whole depositional footprint. The distribution of deposited materials
beneath the cage is a function of local bathymetry and hydrographic regime. In low current
speed environments, only limited distribution of the solids footprint occurs. As current speeds
increase, greater dispersion of solids occurs during settling resulting in a more distributed
footprint. Greater water depth at a site results in increased settling times and result in a more
distributed footprint. Solids distribution is even greater where bottom current speeds are high
causing sediment erosion and particle resuspension and redistribution.
The predicted carbon deposition and magnitude of biodeposition for the single and dual cage
scenarios were estimated over a 2.04 km by 2.04 km evaluation grid. The grid is partitioned into
cells numbering 82 east-west by 82 north-south and identified as 1-82 in both directions. The
units of the axes in both Figures 3 and 4 are these cell counts. The dimension of a single cell
therefore is 2,040m/82=24.87 m. The depositional model predicted and integrated at each one-
hour step, the total carbon that ended up in each cell in the model grid, of which there are 82 x
82 = 6,724 cells. At the end of an execution run the accumulated mass of carbon within each cell
is reported. Predicted annual benthic carbon deposition are presented in Figures 3 and 4.
Frequency histograms of the carbon deposition per cell were created to help with interpretation
of results. The depositional data derived from the frequency histograms are presented in Table
6 and 7.
Table 6 shows the distribution of carbon that results from a single net pen operated for one year
at maximum standing biomass. Of the 6,724 computational cells, 1,386 had no carbon from the
farm. Over 88% of the cells received less than or equal to 1 gram of carbon. Only 2 cells on the
farm measured more than 4 grams of carbon over the year-long simulation.
Table 7 shows the distribution of carbon that results from a two net pens operated for one year
at maximum standing biomass. Similar to the depositional model with one cage, over 75% of the
cells received less than or equal to 1 gram of carbon. One cell was calculated to receive more
than 11 grams, but it is a minuscule mass of carbon to be assimilated by a square meter of ocean
bottom.
Page 7

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Table 6. Frequency of carbon deposition within 6,724 cells, each measuring 619 m2, over a
4.16-km2 grid system. Values represent an annual sum of carbon deposition resulting from an
offshore fish farm with a constant standing stock biomass of 36,275 kg.
Carbon deposition
(g/m2/yr)
Occurrence
(N)
Frequency
(%)
0
1,386
20.6
0.1-1.0
4,561
67.8
1.1-2.0
620
9.2
2.1-3.0
141
2.1
3.1-4.0
14
0.2
4.1-5.0
2
0.03
Table 7. Frequency of carbon deposition within 6,724 cells, each measuring 619 m2, over a
4.16-km2 grid system. Values represent an annual sum of carbon deposition resulting from an
offshore fish farm with a constant standing stock biomass of 72,550 kg.
Carbon deposition	Occurrence	Frequency
(g/m2/yr)	(N)	(%)
0
999
14.9
0.1-1.0
4,086
60.8
1.1-2.0
903
13.4
2.1-3.0
390
5.8
3.1-4.0
200
3.0
4.1-5.0
75
1.1
5.1-6.0
40
0.6
6.1-7.0
20
0.3
7.1-7.0
7
0.1
8.1-9.0
3
0.04
9.1-10.0
0
0.0
10.1-11.0
0
0.0
11.1-12.0
1
0.01
Page 8

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Because of physical oceanographic nature of the site including depth and currents (>10 cm/sec),
dissolved wastes will be widely dispersed and assimilated by the planktonic community (Rensel
et al. 2017). The results of the depositional model show that benthic impacts and accumulation
of particulate wastes would not be detectable or distinguishable from background levels through
measurement of organic carbon, even when the standing stock biomass is doubled. The final
component or step in the modeling process is to predict some measure of change in the benthic
community as a result of increased accumulation of waste material. Deposition of nutrients may
result a minor increase in infaunal invertebrate population or no measureable effect whatsoever.
As part of the model assessment, benthic community impact was predicted by an empirical
relationship between depositional flux (deposition and resuspension) and the Infaunal Trophic
Index (ITI). The ITI is a biotic index that has been used to quantitatively model changes in the
feeding mode of benthic communities and community response to organic pollution gradients
(Word 1978,1980; Maurer etal. 1999). ITI scores are calculated based on predicted solids
accumulation on the seabed (g nr2 yr1). ITI scores range from 0 to 100 g nr2 yr1 and are banded
in terms of impact as:
•	60 < ITI < 100 - benthic community normal
•	30 < ITI <60 - benthic community changed
•	ITI <30	- benthic community degraded.
Correlations between predicted solids accumulation and observed ITI and total infaunal
abundance have been established using data from numerous farm sites around the world.
Among the findings of these studies, a completely unperturbed benthic community at
equilibrium is considered to have an ITI of 60 and an ITI rating of 30 is the boundary where the
redox potential of the upper sediment goes from positive to negative and sulfide production
begins. A standard approach in Europe and Canada is to use an ITI of 30 as a lower limit for
acceptable impacts. In the present study with the Velella Project, the two model simulations
resulted in ITI predictions ranging from 58.67 to 58.81. The predicted ITI close to 60 suggests
that the Velella Project, as proposed, will not likely have a discernable impact on the sediment or
benthic infaunal community around the site.
In summary, the resulting model predictions covered a range of outputs representing both
submitted farming parameters and a worst-case scenario (doubled standing stock biomass) for
the Velella Epsilon Project. We conclude that there are minimal to no risks to water column or
benthic ecology functions in the subject area from the operation of the net pen as described in
Kampachi Farms, LLC applications for EFP and NPDES permits.
Page 9

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Organic
6 Carbon
[g/m2]
250m 500m
10 20 30 40 50 60 70 80
Easting
Figure 3. Predicted annual benthic carbon deposition field beneath one net pen with a standing
stock biomass of 36,280 kg of Almaco Jack [Seriola rivoliana). Gray circle indicates center
position of the net pen. Axes indicate simulation cell numbers and deposition mass is in grams.
Page 10

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Organic
Carbon
(g/m2)
10 20 30 40 50 60 70 80
Easting
Figure 4. Predicted annual benthic carbon deposition field beneath two net pens with a standing
stock biomass of 72,560 kg of Almaco Jack [Seriola rivoliana). Gray circle indicates center
position of the net pen. Axes indicate simulation cell numbers and deposition mass is in grams.
The center of the pens is located at (27.056275 N, -83.216743 W). Predicted carbon loading was
derived from the 12-month time series relationship based on depositional flux with
resuspension.
References
ASC (Aquaculture Stewardship Council) 2017. ASC salmon standard. Version 1.1 April 2017.
Available at https://www.asc-aqua.org/wp-content/uploads/2017/07/ASC-Salmon-
Standard_vl-l.pdf
Chamberlain J., Stucchi D. 2007. Simulating the effects of parameter uncertainty on waste model
predictions of marine finfish aquaculture. Aquaculture 272: 296-311
Cromey C.J., Black K.D. 2005. Modelling the impacts of finfish aquaculture. In: Hargrave BT (ed)
Environmental effects of marine finfish aquaculture. Handb Environ Chem 5M: 129-155
Page 11

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Cromey, C.J., Nickell, T.D., Black, K.D. 2002a. DEPOMOD modelling the deposition and biological
effects of waste solids from marine cage farms. Aquaculture 214, 211-239
Cromey C.J., Nickell T.D., Black K.D., Provost P.G., Griffiths C.R. 2002b. Validation of a fish farm
water resuspension model by use of a particulate tracer discharged from a point source in a
coastal environment. Estuaries 25: 916-929
Cromey C.J., Nickell T.D., Treasurer J., Black K.D., Inall M. 2009. Modelling the impact of cod
[Gadus morhua L) farming in the marine environment—CODMOD. Aquaculture 289: 42-53
Cromey C.J., Thetmeyer H., Lampadariou N., Black K.D., Kogeler J., Karakassis I. 2012. MERAMOD:
predicting the deposition and benthic impact of aquaculture in the eastern Mediterranean Sea.
Aquacult Environ Interact 2: 157-176
Keeley, N.B., Cromey, C.J., Goodwin, E.O., Gibbs, M.T., Macleod, C.M. 2013. Predictive depositional
modelling (DEPOMOD) of the interactive effect of current flow and resuspension on ecological
impacts beneath salmon farms. Aquaculture Environment Interactions, 3(3), 275-291.
Magill S.H., Thetmeyer H., Cromey C.J. 2006. Settling velocity of faecal pellets of gilthead sea
bream (Sparus aurata L.) and sea bass (Dicentrarchus labrax L.) and sensitivity analysis using
measured data in a deposition model. Aquaculture 251:295-305
Maurer, D., Nguyen, H., Robertson, G., Gerlinger, T. 1999. The Infaunal Trophic Index (ITI): its
suitability for marine environmental monitoring. Ecological Applications, 9(2), 699-713.
National Geophysical Data Center, 2001. U.S. Coastal Relief Model - Florida and East Gulf of
Mexico. National Geophysical Data Center, NOAA. doi:10.7289/V5W66HPP [6/1/2018].
Rensel, J.E., King B., Morris J.A., Jr. 2017. Sustainable Marine Aquaculture in the Southern
California Bight: A Case Study on Environmental and Regulatory Confidence. Final Report for
California Sea Grant, Project Number: NAI40AR4170075.
SEPA (Scottish Environmental Protection Agency) 2005. Regulation and monitoring of marine
cage fish farming in Scotland, Annex H: method for modelling in-feed antiparasitics and benthic
effects. SEPA, Stirling.
Word, J.Q. 1978. The infaunal trophic index. Coastal Water Research Project Annual Report,
Southern California Coastal Water Research Project, El Segundo, CA, pp. 19-39.
Word, J.Q. 1980. Classification of benthic invertebrates into infaunal trophic index feeding
groups. Coastal Water Research Project Biennial Report 1979-1980, Southern California Coastal
Water Research Project, El Segundo, CA, pp. 103-121.
Page 12

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Appendix G

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Preliminary Finding of No Significant Impact
Kampachi Farms/Velella Epsilon National Pollutant Discharge System Elimination (NPDES)
Permit
In accordance with 40 CFR §6.206 for issuance of a Findings of No Significant Impact (FONSI),
I ensure that the applicant has committed to any required mitigation and possesses the authority
and ability to fulfill its commitments. Consistent with 40 CFR §1508,13,1 have determined that
the proposed action (issuance of an NPDES permit) will not cause a significant impact on the
environment as outlined in the draft Environmental Assessment (EA). The issuance of the
NPDES permit to the applicant will not cause an significant environmental impact to water
quality or result in any other significant impacts to human health or the natural environment.
I am making this preliminary FONSI available to the public in accordance with 40 CFR §6.203
before taking action.
This FONSI becomes effective 30 days from the date of authorization.
Date:
Responsible Official:	
Mary S. Walker, Regional Administrator

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Appendix H

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Florida Department of State
RON DESANTIS
Governor
LAUREL M. LEE
Secretary of State
Chris Stahl
February 08, 2019
Florida State Clearinghouse
Florida Department of Environmental Protection
3800 Commonwealth Blvd., M.S. 47
Tallahassee, Flonda 32399-2400
RE: DHR Project File No.: 2018-6301-B, Received by DHR: January 02, 2019
Application No.: FL201901048510C
Project Name: Department of Commerce, National Oceanic and Atmospheric Administration, Vdel la
Epsion Project by Kampachi Farms, Offshore Aquaculture, Gulf of Mexico
County: Sarasota
To Whom It May Concern:
The Florida State Flistoric Preservation Officer reviewed the referenced project for possible effects on historic
properties listed, or eligible for listing, on the National Register of Historic Places. The review was conducted in
accordance with Section 106 of the National Historic Preservation Act of1966, as amended, and its implementing
regulations in 36 CFR Part 800: Protection of Historic Properties.
In 2018, a baseline environmental survey (BES) employing single-beam bathymetry, sidescan sonar,
magnetometry, and sub-bottom profiling was completed for the proposed project, Baseline Environmental Survey
Report For the Velella Epsilon Project - Pioneering Offshore Aquaculture in the Southeastern Gulf of Mexico,
NOAA Sea Grant 2017 Aquaculture Initiative.
Dr. Gordon Watts, Jr., Senior Marine Archaeologist and Principal Investigator at Tidewater Atlantic Research,
Inc. (TAR), analyzed and interpreted the resulting data sets, determining that no submerged cultural resources will
be impacted by the proposed project if anchors and/or sinkers can be located on, or within, 50 feet of the surveyed
lines. Conditional upon the placement of anchors and/or sinkers on, or within, 50 feet of the surveyed lines, TAR
recommended no additional archaeological investigation of the project area. TAR recommended additional
investigation of the project area should the anchoring design require placing ground tackle outside of the 100 foot
corridors centered on the data tracklines.
Based on the information provided, our office concurs with TAR's recommendations. Should the anchoring
design for the proposed project require placing ground tackle outside of the 100 foot corridors centered on the
data tracklines or project plans change, we request additional consultation with our office, as supplemental remote
sensing surveying may be required.
It is the opinion of this office that the proposed project will have no effect on historic properties. However,
unexpected finds may occur during ground-disturbing activities, and we recommend that the permit, if issued,
Division of Historical Resources
RA. Gray Building • 500 South Bronough Street* Tallahassee, Florida 32399
850.245.6300 • 850.245.6436 (Fax) FLHeritage.com

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Florida State Clearinghouse
02/08/2019
Pg.2
should include the following "Unexpected Discovery Protocol," as outlined by Kampachi Farms, LLC in the
referenced BES report:
• In the event that any project activities expose potential prehistoric/historic cultural materials not identified
during the remote-sensing survey, operations should be immediately shifted from the site. The respective
Point of Contact for regulatory agencies with jurisdictional oversight should be immediately apprised of
the situation. Notification should address the exact location, where possible, the nature of material
exposed by project activities, and options for immediate archaeological inspection and assessment of the
site.
If you have any questions, please contact Kristen Hall, Historic Sites Specialist, by email at
Kristen. Hall @dos.myflorida.com, or by telephone at 850.245.6342 or 800.847.7278.
Sincerely,
Timothy A Parsons, Ph.D.
Director, Division of Historical Resources
& State Historic Preservation Officer

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Florida Fish
and Wildlife
Conservation
Commission
Commissioners
Robert A. Spottswood
Chairman
Key West
Michael W. Sole
Vice Chairman
Tequesta
Joshua Kellam
Palm Beach Gardens
Gary Lester
Oxford
Gary Nicklaus
Jupiter
Sonya Rood
St. Augustine
Executive Staff
Eric Sutton
Executive Director
Thomas H. Eason, Ph.D.
Assistant Executive Director
Jennifer Fitzwater
Chief of Staff
Division of Marine
Fisheries Management
Jessica McCawley
Director
(850) 487-0554
(850) 487-4847 FAX
Managing fish and wildlife
resources for their long-term
well-being and the benefit
of people.
620 South Meridian Street
Tallahassee, Florida
32399-1600
Voice: 850-488-4676
Hearing/speech-impaired:
800-955-8771 (T)
800 955-8770 (V)
February 18, 2019
Submitted via Electronic Mail
Mr. Chris Stahl
Florida Department of Environmental Protection
Florida State Clearinghouse
state.clearinghouse@deD.state.fl.us
RE: FL201901048510C; Department of Commerce, National Oceanic and
Atmospheric Administration, Velella Epsilon Project by Kampachi Farms,
Offshore Aquaculture, Gulf of Mexico; Coastal Zone Management Act
Consistency Determination
Dear Mr. Stahl:
The Florida Fish and Wildlife Conservation Commission (FWC), Division of Marine
Fisheries Management has reviewed the Coastal Consistency Determination (CCD)
for the Kampachi Farms offshore aquaculture Velella Epsilon Project (VEP), and
provide the following comments pursuant to the Coastal Zone Management
Act/Florida Coastal Management Program.
Section 3.17 of the CCD briefly analyzes the potential impacts from VEP to fish and
wildlife resources of the State of Florida. While the analysis for this Section does
identify what steps VEP is taking to avoid genetic impacts to Florida's coastal
fishery resources (e.g., using native broodstock that are not genetically engineered,
only using first generation offspring), the analysis does not address the mating
ratios and cohort sizes which could also affect the genetics of Florida's coastal
fishery resources. While this information is critical to the review of a CCD for
offshore aquaculture activities, the FWC did coordinate with VEP in advance of the
CCD being submitted (email correspondence dated 3/12/2018) and confirmed the
proposed mating ratios and cohort sizes were genetically appropriate. The FWC
would emphasize that this information should be included in any future CCD
provided for review of proposed offshore aquaculture activities.
Another potentially significant impact from VEP-proposed activities which was not
addressed in the CCD is the potential to affect the health of Florida's coastal fishery
resources. The analysis in the CCD did not identify any steps VEP may be taking to
ensure that unhealthy fish are not introduced into the wild or maintained in net
pens. While this information is also critical to the review of a CCD for offshore
aquaculture activities, the FWC does not want to delay permitting for VEP and is
confidant that this issue will be appropriately addressed through application for an
FWC Special Activity License and facility certification with the Department of
Agriculture and Consumer Services (DACS).
The FWC finds the CCD provided for VEP consistent with FWC statutes and rules
included in Florida's Coastal Management Program, and looks forward to working
with Kampachi Farms during the FWC licensing and DACS certification processes.
MyFWC.com

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Mr. Chris Stahl
Page 2
February 18, 2019
The FWC appreciates the opportunity to review this Coastal Consistency
Determination. For questions or additional information, please contact Lisa Gregg in
the Division of Marine Fisheries Management at: Lis a. Ore gg@MvFW C .com or (850)
617-9621.
Sincerely,
QjMi- '
I
Jessica McCawley
Director
jm/lg

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Division of Aquaculturb
(850) 617-7600
(850) 617-7601 Fax
The Holland Building, Suite 217
600 South Calhoun Street
Tallahassee, Florida 32399-1300
Florida Department of Agriculture and Consumer Services
Commissioner Nicole "Nikki" Fried
Mr. Chris Stahl
Florida State Clearinghouse
Florida Department of Environmental Protection
2600 Blairstone Road, MS 47
Tallahassee, Florida 32399-2400
RE: FL201901048510C - Coastal Consistency Determination in Compliance with the Federal
Consistency Requirements of the Coastal Zone Management Act in Support of the Velella Epsilon Project
Dear Mr. Stahl:
In response to a request submitted on January 3, 2019, the Florida Department of Agriculture and
Consumer Services, Division of Aquaculture has conducted a review of the Florida Coastal Zone
Management Coastal Consistency Determination in Support of the Velella Epsilon Project - Pioneering
Offshore Aquaculture in the Southeastern Gulf of Mexico (CCD:VE Project). Pursuant to Chapter 597
F.S., the Florida Department of Agriculture and Consumer Services (the department) is designated as the
primary agency responsible for regulating aquaculture in the state. Additionally, in section 253.68, F.S.,
the Florida Legislature recognizes aquaculture as a practicable resource management alternative to
produce aquaculture products, to protect and conserve natural resources, to reduce competition for
national stocks and to augment and restore natural populations. The department is directed to foster the
development of aquaculture activities that are consistent with state resource management goals,
environmental protection, proprietary interests, and the state aquaculture plan.
Based upon our review of the CCD:VE Project, the department concurs with the conclusion of the report
and finds that the proposed activities are consistent with all department statutory responsibilities. Further,
this project is in the public interest as it may yield critical information regarding the regulatory permitting
process and the commercial viability of offshore, finfrsh aquaculture in the Gulf of Mexico.
If you need further information, please feel free to contact me at (850) 617-7600.
January 15, 2019
Sincerely,
Portia Sapp, Director
Division of Aquaculture
1 -800-HELPFLA
nft.
www.FreshFromFlorida.com

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Tvler. Kip
Holliman. Daniel: Schwartz. Paul: Ferrv. Rol: Wahlstrom-Ramler. Menhan
FW: State_Clearance_Letter_For_FL201901048510C_Velella Epsilon Project by Kampachi Farms, Offshore
Aquaculture, Gulf of Mexico, Florida
Tuesday, February 26, 2019 12:02:46 AM
FWC Comments - Velella Fpsilon Proiect.pdf
Stahl-FL Clearinqhouse-FL201901048510C.pdf
DHR Comments for 2018-6301 -R Velella Fnsion Project hv Kamnachi Farms Offshore Anuaculture Gulf of Mexico
App. No. FL20190104851 PC 106 EPA.msq'
CZMA concurrence for the Kampachi project is complete.
Note that: CZMA concurrence is from FDACS, NHPA concurrence is from FDEP, and Florida coastal
management program concurrence comes from FDEP/FWC.
Kip Tyler
w 404.562.9294 | m 404.323.6094
From: Dennis Peters 
Sent: Monday, February 25, 2019 6:29 PM
To: Chris.Stahl@dep.state.fl.us
Cc: Tyler, Kip ; Jess Beck - NOAA Federal ; Damico, Katy R
CIV USARMY CESAJ (US) (Katy.R.Damico@usace.army.mil) ; Neil
Sims (neil@kampachiworld.com) ; lisa@kampachifarm.com; Ken Riley
(ken.riley@noaa.gov) ; Sapp, Portia 
Subject: FW: State_Clearance_Letter_For_FL201901048510C_Velella Epsilon Project by Kampachi
Farms, Offshore Aquaculture, Gulf of Mexico, Florida
Thank you Chris -
The Kampachi Team and our stakeholders appreciate the State's thorough review of the VE Project
plan.
V/R - Dennis
Dennis J. Peters
Gulf South Research Corporation (GSRC)
(850) 240-3414 (Cell)
From: Stahl, Chris rmailtoiChris.Stah l@dep .state ,f I.usl
Sent: Monday, February 25, 2019 2:11 PM
To: petered 1 @cox.nef.
Cc: State_Clearinghouse; 'FWC Conservation Planning Services'; Sapp, Portia
Subject: State_Clearance_Letter_For_FL20190104851 OC_Velella Epsilon Project by Kampachi Farms,
Offshore Aquaculture, Gulf of Mexico, Florida
From:
To:
Subject:
Date:
Attachments:
February 25, 2019

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Dennis Peters
Gulf South Research Corporation
815 Bayshore Drive
Niceville, Florida 32579
RE: Department of Commerce, National Oceanic and Atmospheric Administration, Velella Epsilon
Project by Kampachi Farms, Offshore Aquaculture, Gulf of Mexico, Florida
SAI # FL201901048510C
Dear Dennis:
Florida State Clearinghouse staff has reviewed the proposal under the following authorities:
Presidential Executive Order 12372; § 403.061(42), Florida Statutes; the Coastal Zone Management
Act, 16 U.S.C. §§ 1451-1464, as amended; and the National Environmental Policy Act, 42 U.S.C. §§
4321-4347, as amended.
The Florida Departments of Agriculture and Consumer Services and Department of State, as well as
the Florida Fish and Wildlife Conservation Commission have reviewed the proposed project and
provided comment letters which are attached and incorporated hereto.
Staff of the Florida Departments of Transportation noted on Page 8 of 20 (see pdf page 9 of 123), of
the "Supplemental Data: In support of the - Velella Epsilon Project" document dated 01/03/2019,
states "NOAA navigational charts of the area were referenced and did not indicate any conflict with
major shipping channels or DoD Restricted Access areas." Florida Department of Transportation's
Seaport Office compared the spatial location of the proposed "Most Desired Alternative Sites" with
historical AIS (Automatic Identification System) vessel tracking data, and was able to identify
potential cargo and cruise vessel conflicts with the proposed locations. This same finding appears to
be confirmed by a NOAA National Centers for Coastal Ocean Science slide "Vessel Traffic (AIS Data -
2013)" also included in the document data 01/03/2019 (see pdf page 53 of 123).
Based on the information submitted and minimal project impacts, the state has no objections to the
subject project and, therefore, the funding award is consistent with the Florida Coastal Management
Program (FCMP). The state's final concurrence of the project's consistency with the FCMP will be
determined during any environmental permitting processes, in accordance with Section 373.428,
Florida Statutes, if applicable.
Thank you for the opportunity to review the proposed plan. If you have any questions or need
further assistance, please don't hesitate to contact me.
Sincerely,
(tytnib StaM

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Chris Stahl, Coordinator
Florida State Clearinghouse
Florida Department of Environmental Protection
3800 Commonwealth Blvd., M.S. 47
Tallahassee, FL 32399-2400
ph. (850) 717-9076
State.Clearinghouse@floridadeD.gov

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