United States Environmental
Protection Agency
Region 4
61 Forsyth Street, SW
Atlanta, GA 30303
904-P-19-001
September 2020
US Army Corps
of Engineers®
'1Went of
Final
Environmental Assessment
National Pollutant Discharge Elimination System Permit
for Ocean Era, Inc - Velella Epsilon Offshore Aquaculture
Project - Gulf of Mexico
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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
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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
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
LOA
Letter of Authorization
LOP
Letter of Permission
m
Meters
MAS
Multi-Anchor System
MBTA
Migratory Bird Treaty Act
mg/1
Milligram per Liter
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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
ODC
Ocean Discharge Criteria
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
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PSMP
Protected Species Management Plan
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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ntents
1.0 Introduction 1
1.1 Environmental Review Process and Coordination 2
1.2 Regulatory Background 2
1.2.1 EPA—Clean Water Act 2
1.2.2 USACE-Section 10 4
1.3 Primary Federal Authorizations needed for Proposed Aquaculture Projects 4
1.4 Required Federal Consultations, Reviews, and Other Applicable Laws 5
1.5 Proposed Action 7
1.6 Purpose and Need for the Proposed Action 7
1.7 Site Selection 8
1.7.1 Description and Location 8
1.7.2 Surrounding Location Uses 9
1.7.3 Summary of Proposed Project Activities 9
1.8 Documents incorporated by reference 10
2.0 Alternatives 11
2.1 Alternative 1—No Action 11
2.2 Alternative 2 —Issuance of NPDES Permit and Section 10 Authorization 11
2.3 Alternatives Considered but Eliminated from Detailed Study 11
2.4 Factors Used to Develop and Screen Alternatives 11
3.0 Affected Environment 13
3.1 Introduction 13
3.2 Physical Resources 13
3.2.1 Water Quality 14
3.2.1.1 Deepwater Horizon Spill 14
3.2.1.2 Red Tide Outbreaks 15
3.2.1.3 Pharmaceuticals 15
3.2.2 Sediment Quality 16
3.2.3 Air Quality 16
3.2.4 Coastal Barrier Beaches 17
3.2.5 Noise Environment 17
3.2.6 Climate 18
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3.3 Biological Resources 18
3.3.1 Fish 19
3.3.2 Invertebrates 20
3.3.3 Marine Mammals 21
3.3.4 Sea Turtles 22
3.3.5 Birds 24
3.3.6 Essential Fish Habitat 25
3.3.7 Deepwater Benthic Communities 26
3.3.8 Live Bottoms 26
3.3.9 Seagrasses 26
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 28
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
4.2.1.1 Pharmaceuticals 33
4.2.2 Sediment Quality 33
4.2.3 Air Quality 35
4.2.4 Coastal Barrier Beaches 35
4.2.5 Noise Environment 35
4.2.6 Climate 35
4.3 Biological Resources 36
4.3.1 Fish 36
4.3.2 Invertebrates 38
4.3.3 Marine Mammals 39
4.3.4 Sea Turtles 41
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4.3.5 Birds 43
4.3.6 Essential Fish Habitat 44
4.3.7 Deepwater Benthic Communities 44
4.3.8 Live Bottoms 44
4.3.9 Seagrasses 45
4.4 Social and Economic Environment 46
4.4.1 Commercial Marine Aquaculture Production 46
4.4.2 Commercial Fisheries 46
4.4.3 Recreational Fishing 47
4.4.4 Human Health/Public Health 48
4.4.5 Environmental Justice 48
5.0 Cumulative Impacts 50
5.1 Deepwater Horizon Event 50
5.2 Oil and Gas Operations 51
5.3 Future Aquaculture Operations 51
5.4 Physical Resources 52
5.4.1 Water Quality 52
5.4.1.1 Pharmaceuticals 53
5.4.2 Sediment Quality 53
5.4.3 Air Quality 53
5.4.4 Coastal Barrier Beaches 54
5.4.5 Noise Environment 54
5.4.6 Climate 54
5.5 Biological Resources 55
5.5.1 Fish 55
5.5.2 Invertebrates 56
5.5.3 Marine Mammals 56
5.5.4 Sea Turtles 57
5.5.5 Birds 58
5.5.6 Essential Fish Habitat 58
5.5.7 Deepwater Benthic Communities 59
5.5.8 Live Bottoms 59
5.5.9 Seagrasses 60
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5.6 Social and Economic Environment 60
5.6.1 Aquaculture Production 6 0
5.6.2 Commercial and Recreational Fishing 60
5.6.3 Human Health/Public Health 61
5.6.4 Environmental Justice 62
6.0 Summary of Alternatives 63
6.1 Alternatives Summary 63
6.1.1 Alternative 1: No Action 63
6.1.2 Alternative 2: Proposed Action—Issuance of NPDES Permit a for Velella Epsilon 63
6.2 Comparison of Alternatives 64
6.3 Preferred Alternative 64
6.4 Unavoidable Adverse Impacts 64
6.5 Irreversible and Irretrievable Commitments of Resources 65
6.6 Relationship Between Short-term Uses of the Environment and the Maintenance and Enhancement
of Long-Term Productivity 65
6.7 Finding of No Significant Impact 66
7.0 Other Protective Measures and Agency Coordination Efforts 67
7.1 State Coastal Zone Management Program Consistency 67
7.2 National Historic Preservation Act 67
7.3 The Wild and Scenic Rivers Act 68
7.4 Fish and Wildlife Coordination Act 68
7.5 Section 7 Endangered Species Act Coordination 68
7.6 Essential Fish and Habitat Consultation 69
7.7 Clean Water Act Section 401 69
7.8 Marine Mammal Protection Act 70
8.0 References 71
9.0 Public Notice 82
10.0 Preparers 84
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List of Tables
Table 1 - Errata table
Table 2 - Federal permits needed for offshore aquaculture projects
Table 3 - Federal authorizations required for offshore aquaculture projects
Table 4 - Other applicable Federal laws
Table 5 - Velella Epsilon boundary coordinates
Table 6 - Annual commercial landings for West Florida 2014 and 2015
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Table 1 - Errata Table - Substantive Changes from draft to final EA
Page Number Scclion
Change lYum dm 11 In final L\
(rlobal
Added Ocean Era, Inc. as applicant
Global
Clarification that permit will be limited to "one production cycle"
Introduction
Text revised
Table 3
Revised ESA and MMPA text
Section 3.2.3 - Air Quality
Text revised and updated
Section 4.2.1 - Water
Quality
Text Revised
Section 4.2.1.1 -
Pharmaceuticals
Text revised
Section 4.2.2 - Sediment
Quality
Text revised
Section 4.2.3 Air Quality
Text revised
Section 4.3.1 - Fish
Text revised
Section 4.3.3 - Marine
Mammals
Text revised
Section 4.3.4 - Sea Turtles
Text revised
Section 4.3.6 - Essential
Fish Habitat
Concurrence correspondence text added
Section 4.4.3 -
Recreational Fishing
Text revised
Section 4.4.4 -
Commercial Fishing
Text revised
Section 4.4.5 -
Environmental Justice
Text revised
Section 5.0- Cumulative
Impacts
Text revised
Section 5.3 Future
Aquaculture Operations
Text revised
Section 5.4 - Physical
Resources
Text revised
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Section 5.4.1 - Water
Quality
Text revised
Section 5.4.1.1 -
Pharmaceuticals
Text revised
Section 5.4.2 - Sediment
Quality
Text revised
Section 5.4.3 - Air Quality
Section has been revised to reflect updated information
Section 5.5- Biological
Resources
Text revised
Section 5.5.4 - Sea Turtles
Text revised
Section 5.5.6 - Essential
Fish Habitat
Text revised and concurrence correspondence text added
Section 6.0- Alternatives
Text revised
Section 6.7 - Preliminary
FONSI
Text revised
Section 7.5 - Section 7
ESA Coordination
Text revised
Section 7.6 - Essential
Fish Habitat Consultation
Text revised
Section 9.0 - Public
Notice
Section has been revised to reflect public comment period, public
hearing, and agency responses^
List of Appendices
Appendix A - Baseline Environmental Survey
Appendix B - Cage/Pen Design
Appendix C - ODC Evaluation
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
Ocean Era, Inc. (formerly 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 2). This EA was prepared by the
U.S. Environmental Protection Agency (EPA) as the lead federal agency with assistance from
the National Marine Fisheries Service (NMFS) and U.S. Army Corps of Engineers (USACE) as
cooperating agencies under the National Environmental Policy Act (NEPA). This EA evaluates
the potential environmental impacts from the construction and operation of the proposed project,
named Velella Epsilon (VE). Cooperating agencies have jurisdiction by law or special expertise
with respect to the potential environmental impacts resulting from the VE project.
A NEPA review is required when the EPA issues a National Pollutant Discharge Elimination
System (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 Concentrated Aquatic
Animal Production (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 80,000 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 FR 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 Environmental Assessment (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. Finally, the
proposed facility's maximum annual production of 80,000 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. While the EPA voluntarily used NEPA review procedures in
conducting the analysis for the NPDES permit issuance, the EPA also has explained that "[t]he
voluntary preparation of these documents in no way legally subjects the Agency to NEPA's
requirements" (63 FR 58046).
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1.1 Environmental Review Process and Coordination
This will be the first offshore aquaculture project in the Gulf to be issued under the new
interagency process for coordinating aquaculture permitting.1 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). In addition to the cooperating agencies, 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) contribute in this
process as participating agencies.
1.2 Regulatory Background
The operator of an offshore aquaculture facility must obtain required federal permits and
authorizations prior to beginning operations (e.g., US ACE Section 10 permit needed before
anchoring any structures into federal waters of the Gulf and EPA's NPDES permit needed before
discharging pollutants from those structures). Table 1 summarizes the permits that are needed to
conduct aquaculture in federal waters of the Gulf.
Table 2: Federal Permits needed for offshore aquaculture projects.
Agency
Statutes/Authorities
Purpose
Permit
U.S. Army Corps of
Engineers
Section 10 of the
Rivers and Harbors
Act
Required in navigable waters of the
U.S. to protect navigation for
commerce
Section 10 Permit
or Letter of
Permission
U.S. Environmental
Protection Agency
Sections 402 and 403
of the Clean Water
Act
Required for the discharge 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.
1.2,1 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.
1 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.
2
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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 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 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 (EEL)2
2 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.
3
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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).
1.2.2 USAGE—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 (RHA) approved March 3, 1899, (33 U.S.C. 403)
(hereinafter referred to as Section 10) only. Pursuant to 33 CFR 320.2(b), Section 10 prohibits the
unauthorized obstruction or alteration of any navigable water of the United States (U.S.). The
construction of any structure in or over any navigable water of the United States, the excavating
from or depositing of material in such waters, or the accomplishment of any other work affecting
the course, location, condition, or capacity of such waters is unlawful unless the work has been
recommended by the Chief of Engineers and authorized by the Secretary of the Army. The
instrument of authorization is designated a permit. The authority of the Secretary of the Army to
prevent obstructions to navigation in navigable waters of the United States was extended to
construction of artificial islands, installations, and other devices located on the seabed, to the
seaward limit of the outer continental shelf, by section 4(f) of the Outer Continental Shelf Lands
Act of 1953 as amended (43 U.S.C. 1333(e)). (See 33 CFR part 322.3(b)).
1.3 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 3 provides a summary
of the federal authorizations that may be needed for offshore marine aquaculture projects in
federal waters.
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.
4
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Table 3: Federal authorizations required for Offshore Aquaculture Projects.
Agency
Statutes/Authorities
Purpose
Application
Form(s)/Process4
Who initiates this
action and how?
Form of
authorization
\m|Ik-l.ocalcd u illi ()( S ()il and (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
Environmenta
1 Enforcement
(BSEE)
Outer Continental
Shelf Lands Act
Permitting
agencies request
BSEE consultation
on proposed
aquaculture
activities
1.4 Required Federal Consultations, Reviews, and Other Applicable Laws
The EPA and the US ACE must coordinate with other agencies when making permitting
decisions for offshore aquaculture operations. Table 4 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 4. Other Applicable Federal Laws
Federal Law
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 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 require federal agencies to consult
with NMFS when activities they undertake or permit may 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.
There are some exemptions to marine mammal take which are specified in sections 101 and 118 of the Marine
Mammal Protection Act.
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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1.5 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 1.7.3 Summary of Proposed Project Activities.
The proposed action is the issuance of a permit under the respective authorities of the EPA 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. In addition, the USACE
proposed action is the issuance of a Letter of Permission (LOP) pursuant to Section 10 that
authorizes anchorage to the sea floor, and structures affecting navigable waters.
1.6 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 (Ocean Era) 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 are not
fully 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
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.
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 Ocean
Era. The USACE evaluated this project pursuant to a LOP pursuant to 33 CFR 325.2(b)(2) and
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(e)(1). Pursuant to 325, Appendix B (6) Categorical Exclusions, all applications which qualify as
letters of permission (as described at 33 CFR 325.2(b)(2) are categorically excluded from NEPA
as they are not considered to be major Federal actions significantly affecting the quality of the
human environment.
For the purposes of this EA, the Section 10 Permit and LOP will be used interchangeably. The
LOP will be valid for five years. However, the applicant proposes a pilot-scale aquaculture
system that will raise approximately 20,000 almaco jack over an 18-month project period. An
LOP was determined appropriate for this action due to the small scale and temporary nature of
the proposed pilot project.
1.7 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.
1.7.1 Description and Location
The proposed facility will be located within the boundary of the coordinates shown in Table 5.
The boundary of the facility is -45 miles southwest of Sarasota, Florida and consists of water
depths of-130 feet which is conducive for placement of the single cage and multi-anchor system
(MAS).
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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.
Table 5. Velella Epsilon Boundary Coordinates
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
1.7.2 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.
1.7.3 Surmnatv of Purposed Pioject Activities
The proposed project activities include operation of 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), which
will represent one production cycle. 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 80,000
lbs. (considering a 90% 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 offshore strength (PolarCirkel-style) submersible fish pen will be deployed on an
engineered MAS mooring system. The design provided by the applicant for the engineered MAS
will use embedment anchors for the mooring 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 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
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in a rigid pipe. Structural information showing the MAS and pen array, along with the tethered
tender vessel, is provided in Appendix B.
The 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 18-month demonstration trial period, the net pen and all mooring
equipment would be removed from the site and hauled to shore for proper cleaning and storage.
For a detailed schematic of the pen design sqq Appendix B.
1.8 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:
• NMFS' 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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2.0 Alternatives
The EPA considered 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 for
the facility (Alternative 2).
2.1 Alternative 1 —No Action
Under the no-action alternative, the EPA would not issue a NPDES permit for the proposed 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.
2.2 Alternative 2 -Issuance of NPDES Permit and Section 10 Authorization
Under Alternative 2, the EPA would issue a NPDES permit for the proposed VE project. This
Alternative complies with the statutory requirements of the CWA.
2.3 Alternatives Considered but Eliminated from Detailed Study
As discussed in Section 1.7 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.
2.4 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 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 part of the NEPA process, the EPA 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 has included both action and no action alternatives in this EA. Rationale for
alternatives eliminated for additional study is provided in Chapter 1. We provide a detailed
discussion on the proposed action and the levels of impacts compared to the no action alternative
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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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vO A ffccted 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 ODC Evaluation in Appendix C, Ocean Era - Velella Epsilon Net
Pen Fish Culture Facility and the NPDES Permit [FL0A00001] Outer Continental Shelf, Gulf of
Mexico, and Draft Biological Evaluation - Ocean Era, 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.
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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 mainly of coarse 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 Spi 11
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.3 a
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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 occurring in several locations along the coast. Updates on red
tide occurrence off the west coast of Florida can be found online.4
Nutrient addition to the Gulf is of concern because they can contribute to harmful algal blooms
(HABs); however, quantitative direct links to marine aquaculture are lacking in the scientific
literature. 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 FLAB 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 5-10meters 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
4 http://www.myfwc.com/RedTideStatus.
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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.
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, particulate matter with an aerodynamic diameter
less than or equal to 10 microns (PM10), and particulate matter with an aerodynamic diameter
less than or equal to 2.5 microns (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 attainment. Consequently, the only
available air quality data relevant to the Gulf is that data collected by the states of Mississippi,
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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. There are no non-attainment areas along the Gulfs central and eastern coast as of
2020. The greater Tampa/St Petersburg area within Hillsborough County, Florida is a
maintenance area that has been redesignated from nonattainment (EPA, 2016).
When any new source of air-pollutant emissions meeting a major status is proposed, 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 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 vicinity 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 of
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.
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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 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 coarse 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
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(,Solenastrea bournoni), thin finger coral (Porites divaricate), solitary disc corals such as
Scolymias, and the sinuous cactus coral (Isophyllia sinuosa).
3S*. ,-j ••»—( • 1
.3.1 Fish
The Gulf 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 birostris), 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 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).
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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. 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, 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 (iOrbicella annularis),
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mountainous star (iOrbicella 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 Mammal s
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 (Ba/aenoplera 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 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 from the NOAA Fisheries Office of Protected Species.5
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
removal6 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
5 http://www.iiiiifs.iioaa.goY/pr/sspecies/.
6 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— 1) The minimum population estimate of the stock; 2) One-half the maximum theoretical or
estimated net productivity rate of the stock at a small population size; and3) A recovery factor of between 0.1 and 1.0.
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(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 (CheIonia 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 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
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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, 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,
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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).
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.
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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 (Charadrius 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 designated a State
Species of Conservation Concern.
3.3.6 Essential Fisli 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 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
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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 ODC Evaluation, 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, Florida, 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 coarse 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 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
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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 on 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 almaco jack, 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
producer (NMFS, 2015a), and marine aquaculture production has been increasing.7 However,
current freshwater aquaculture production far exceeds marine aquaculture.
7 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 (https://www.nass.usda.gov/Surveys/Guide_to MASS Surveys/Census_of_ Aquaculture/').
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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 rock8 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.9
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
zonata) 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).10 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.
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
8 Live rock is fragmented pieces of old coral reefs. These pieces are colonized by marine life such as invertebrates, corals,
sponges, and millions of beneficial nitrifying bacteria.
g
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 bv reference.
10
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 Chttp://sero.nmfs.noaa.gov/sustainable fisheries/social/communitv snapshot/)
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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 6 shows 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 6. Annual Commercial Landings for West Florida, 2014 and 2015
Metrics
2<)|4
2<) 1 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 Recreational Marine Fishing
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 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
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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 morio), white grunt (Haemulonplumierii), 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 Eiwironmentai I onsequences
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, ODC Evaluation and the
NPDES Permit [FL0A00001] Outer Continental Shelf, Gulf of Mexico and Appendix D, Draft
Biological Evaluation - Ocean Era, 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.
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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 operational wastes without an NPDES permit the facility would not be constructed
or operated at this location on the west Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES permit. The proposed action alternative,
the issuance of an NPDES permit, 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
(80,000 lbs. at harvest - one production cycle) 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 biochemical
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 ODC Evaluation, 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 the facility would not be constructed or operated at this
location on the west Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES permit. The proposed action alternative,
issuance of an NPDES permit will likely have minimal impacts to water quality in the vicinity of
the proposed facility due to the small fish biomass, 80,000 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 Reports, Appendix F) that a total of 2,743 kg of
ammonia nitrogen would be produced during the production cycle. The EPA's calculations
provided in the ODC Evaluation 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
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is approximately = 0.0072 milligrams per liter (mg/1), significantly below the USEPA's
published ammonia aquatic life criteria values for saltwater organisms.11
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 ODC Evaluation for this project, Appendix C.
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, the facility would not be constructed or operated at this location on
the west Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES permit. The proposed action alternative,
issuance of NPDES permit 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, 80,000 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.
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.12 In accordance with the NPDES permit, all
drugs, pesticides and other chemicals must be applied in accordance with label directions.
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,
11EPAS recommended saltwater aquatic life criteria is available at: www.epa.gov/wqc/national-iecommended-water-quality-
criteila-aquatic-life-criteria-table.
12 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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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 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. Model results for this project predict that
there are minimal to no risks to water quality or benthic ecology functions within the area of
operation, CASS Technical Reports Appendix F. A more in-depth discussion of potential impacts
to sediment quality can be found in the ODC Evaluation, 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, the facility would not be constructed or operated
at this location on the west Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES permit. The proposed action alternative,
issuance of NPDES permit 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 (80,000 lbs. at
harvest - one production cycle) 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 Reports, Appendix F) show that
for the estimated production values, net organic carbon accumulation would be at 5.0 grams per
meter squared per year (g/m2/yr.) or less for 99.0 % 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 ODC Evaluation, Appendix C. The results of deposition
modeling, even when doubling fish production amounts, conclude that net accumulation of
wastes following a 1-year production cycle would likely not be distinguishable from background
levels of organic carbon. Even when the period of discharge is increased to the full 5-year permit
term, the modeling report indicated that the proposed project "will not likely have a discernable
impact on benthic communities around the project location" and that the project "will present
challenges for monitoring and detecting environmental impacts on sediment chemistry or benthic
communities because of the circulation around the project location and the small mass flows of
materials from the net pen installation."
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4.23 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. The
tender vessel is an 80-foot ocean going Staysail Schooner, the SV Machias, a U.S. Coast Guard
inspected and documented (Document No. 289053) sailing vessel with a commercial fishing
endorsement, outfitted and approved for open ocean, blue water cruising that includes space for
24 passengers. The vessel is equipped with modern communications and navigation technology,
e.g., two-way radio, GPS, radar, high frequency transceivers, etc. It can use both sail power and
diesel power and in the event of problems, can communicate with the Coast Guard for assistance.
At least two scientific field technicians from Ocean Era, LLC, will be stationed on the tender
vessel at all times for the duration of the project. Staff will be rotated, so that each individual is
at sea for four weeks, then off for two weeks. The vessel will maintain position at the site via
mooring to the array. All marine engines on the vessel meet IMO/EPA air quality standards.
Hoteling emissions are expected while the vessel is moored at the project site. The vessel is
equipped with two generators on-board (25KW and 15KW) units. Moreover, trade wind
conditions around Florida are likely to quickly disperse these emissions. The EPA has reviewed
detailed information regarding the support vessel and confirmed that the emission associated
with the tender vessel will not be a significant source of air emissions.
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, the facility would
not be constructed or operated at this location on the west Florida Shelf.
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Alternative 2 - Proposed Action, Issuance of NPDES permit. The Proposed Action alternative,
issuance of NPDES permit, 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, ODC Evaluation and
Appendix D, Draft Biological Evaluation - Ocean Era, 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 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, the facility
would not be constructed or operated at this location on the west Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES permit. The proposed action alternative,
issuance of NPDES permit, 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
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the facility. The relatively small fish biomass to be reared in the single cage (80,000 lbs. at
harvest - one production cycle) 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.
One concern with marine cage culture and 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.
Another concern is related to the potential for fish escapes and genetic impact they may have on
native fish. The farmed species, almaco jack, is native and common to the Gulf. The fingerlings
will be sourced from brood stock that are located at Mote Marine Aquaculture Research Park and
were caught in the Gulf near Madeira Beach, Florida. As such, only F1 (first filial generation)
progeny from those wild caught brood stock will be stocked into the net-pen for the proposed
project. Neither the brood stock, as they are native and wild caught, or the first-generation
fingerlings from that brood stock, have undergone any genetic modification or selective
breeding, and would not likely pose a competitive risk to wild stock. It's also not likely that there
would be any genetic contamination or weakening if any fugitive fish spawned with wild
individuals. Therefore, there is limited to no risk for non-indigenous stock establishment.
Furthermore, the risks that escaped farm fish pose to wild populations are a function of the
probability of escape, and the magnitude of the event that could cause an escape event. The
copper mesh cage to be used is impact resistant and designed to survive storm events while being
completely submerged. The EPA believes that the cage design will result in a low probability of
escape.
An additional concern is related to the potential for pathogens and parasites to be released from
the pen impacting wild fish. Pathogen and parasite transfer is considered in the NPDES permit
through the following conditions:
1) The permittee will be required to create and implement health management strategies
for marine aquaculture organisms in the BMP plan. Effective disease prevention
programs may include routine health exams and inspections, accurate record-keeping
by the permittee, biosecurity measures, preventative actions like vaccines.
2) The permittee will be required to certify that the fish were examined prior to going
offshore to ensure they are healthy, so any pathogens that affect them would come
from the surrounding environment.
3) The NPDES permit includes fish health and disease control conditions that are
comparable to the Gulf Aquaculture FMP requirements referenced below.
"Marine aquaculture activities should: (1) Minimize impacts of disease outbreaks
if they occur; (2) Create and implement health evaluation programs and policies
that prevent the importation or release of disease pathogens or parasites of
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regulatory concern. These policies should support development and utilization of
technologies to identify and control disease organisms; (3) Develop effective
disease control, quarantine, and inventory destruction procedures to prevent the
spread of disease to public waterways, native species, and other marine
aquaculture facilities; (4) Create and implement health management strategies for
marine aquaculture organisms in cooperation with states, federal agencies,
industry, veterinarians, and scientists; and (5) Use only FDA approved therapeutic
and chemical treatments as part of best management practices."
Regarding potential impacts from water and sediment quality, 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.
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, the
facility would not be constructed or operated at this location on the west Florida Shelf.
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Alternative 2 - Proposed Action, Issuance of NPDES permit. The proposed action alternative,
issuance of an NPDES permit, 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 (80,000 lbs. at harvest - one production cycle) 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 permit, 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 permit 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 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
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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.
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 mammals
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 permit. 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,
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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. The risk of an entanglement
interaction is likely minimal if lines are kept taut or covered in rigid pipes; 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. There is a low probability that collisions with
the vessel associated with the proposed project would kill or injure marine mammals given the
limited trips to the facility with only one vessel and that the vessel will 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 minimal given that there is one production cage and one vessel that will be deployed for a
duration of approximately 18 months.
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, the
facility would not be constructed or operated at this location on the west Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES permit. 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
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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 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.
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
(80,000 lbs. at harvest - one production cycle) 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.
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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 (Sulci dactylatra), brown boobies (Sula
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, the facility
would not be constructed or operated at this location on the west Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES permit. The proposed action alternative,
issuance of NPDES permit will likely have only very minimal impacts to the seabirds and other
migratory birds expected to occur in the vicinity of the proposed facility.
The EPA and US ACE 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.13 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.
13
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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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 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 on essential fish
habitat can be found in the ODC Evaluation, Appendix C and Appendix D, Threatened and
Endangered Species Assessment.
Alternative 1 - No Action. The No Action alternative would result in no effect on 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, the facility would not be
constructed or operated at this location on the west Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES permit. The proposed action alternative,
issuance of NPDES permit will likely have minimal impacts to 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 (80,000 lbs. at
harvest - one production cycle) demonstration is also expected to result in small daily loading
rates of discharged pollutants downstream of the cage. The proposed VE site will be located over
unconsolidated sediments, limiting any potential impacts to reef fish habitat such as live bottom
areas 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). The NMFS
provided written concurrence with our determination in a letter dated March 12, 2019 (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
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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 ODC Evaluation, 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, the facility would not be constructed or operated at this location on the west Florida
Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES permit. The proposed action alternative,
issuance of NPDES permit 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
(80,000 lbs. at harvest - one production cycle) 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 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, the facility
would not be constructed or operated at this location on the west Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES permit. The proposed action alternative,
issuance of NPDES permit 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
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suspended solids discharged from the facility. The relatively small fish biomass to be reared in
the single cage (80,000 lbs. at harvest - one production cycle) 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, 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.
4.4.2 Commercial Fisheries
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.
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, the facility would not be constructed or operated
at this location on the west Florida Shelf. The baseline conditions described in Section 3.4.3
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Commercial Landings of Almaco Jack and Section 3.4.4 Commercial Fisheries would not be
impacted.
Alternative 2 - Proposed Action, Issuance of NPDES permit. The proposed action alternative,
issuance of NPDES permit will likely have minimal impacts to the commercial fishing industry,
almaco jack is not a commercially targeted species. Instead, it is incidentally harvested by
commercial vessels that target pelagic species. Consequently, almaco jack has a low dockside
price. There is a low potential for almaco jack being a substitute for commercial landings of one
or more species, increasing market supply, and causing a decrease in market price of those
substitute species. However, based on supplemental information provided by the applicant, fish
harvested from the VE project will be sold to multiple state and Federally licensed dealers in an
effort to test the marketability of almaco jack. This should spread any impact across multiple
markets. In addition, almaco jack are expected to be harvested over a three-month period, thus
avoiding the entire project harvest hitting the market at one landing.
With regards to conflicts with commercial fishing activities, the proposed site was selected to
minimize potential conflicts with shrimping and other commercial fishing activities in the area.
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 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 (80,000 lbs. at harvest - one production cycle)
demonstration is also expected to result in small daily loading rates of discharged pollutants
downstream of the cage. Species that would be commercially targeted would have minimal
exposure to any discharged pollutants.
4.4.3 Recreational Fisliing
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 fishing 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 ofbenthic 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.
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 be able to discharge any operational wastes without an NPDES permit, the
facility would not be constructed or operated at this location on the west Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES permit. The proposed site was selected to
minimize potential conflicts with recreational fishing activities in the area, therefore, the
proposed action alternative, issuance of NPDES permit will likely have minimal impacts on
recreational fishing that may occur in the vicinity of the proposed facility. In addition, the siting
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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 (80,000 lbs. at harvest - one production cycle) 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 for recreationally targeted fish.
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, the facility would not be constructed or operated at this location on the west
Florida Shelf.
Alternative 2 - Proposed Action, Issuance of NPDES permit. The proposed action alternative,
issuance of NPDES permit 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 (80,000 lbs. at harvest - one
production cycle) 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 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.
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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. Based on
discussion with the applicant, shared dock space at Port Manatee will be utilized for staging and
any conflicts in use will be minimized.
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). Other
actions considered in this cumulative impact analysis include the 2010 Deep Water Horizon
(DWH) oil spill event, oil and gas operations, future aquaculture operations and natural disasters.
As noted in 1.8 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:
Based on public comments received on the draft EA, the EPA understands there are several areas
of concern relating to cumulative impacts of the proposed action. Two primary concerns
highlighted were the period of time that should be considered when evaluating other actions and
the potential for a commercial scale VE project being permitted at or near the current location of
the pilot-scale project. The EPA initially considered cumulative impacts over the full permit term
(5 years), however, the NPDES permit has been modified to limit discharges from the VE project
to one production cycle. The EPA expects this cycle to take no-longer than 18-months, therefore
significantly shortening the time in which other offshore aquaculture projects or other actions
may have an incremental impact. In addition, if a commercial scale VE project were to be
authorized, the new project would be subject to a new permit process and new NEPA analysis.
5.1 Deepwater Horizon Event
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 Ocean Era 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 concur
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.
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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 and gas activities EPA 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 (7.4.3Moratoria) (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.
The EPA notes that the proposed action is approximately 45 miles off the coast of Florida and
within the GOMESA restricted area. The EPA 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
The EPA understands that it is reasonably foreseeable that the marine aquaculture industry may
expand in the Gulf, and therefore we considered expansion of the industry as a possibility in our
cumulative impacts analysis. When evaluating cumulative impacts, EPA must consider past,
present, and reasonably foreseeable future actions that can result in incremental impact of the
proposed action (See 40 CFR § 1508.7). The EPA determined that one reasonably foreseeable
action that could have an incremental impact on the environment was other offshore aquaculture
operations in the Gulf (in the vicinity of the project). The EPA determined that it was not
reasonable to consider future projects that are speculative. Based on information EPA had when
drafting the EA, the owner/operators of the VE pilot-scale project had not committed to a
location of a commercial operation and had not submitted a NPDES permit application for such
an operation. Without a draft NPDES permit application and no formal pre-application process
started for a commercial scale VE project, it would be unreasonable for EPA to consider impacts
from such a facility.
At present, there is one other offshore aquaculture project (Manna Fish Farms) which is being
proposed for an area located in the Northern Gulf. This project is in the pre-application stages,
but the applicant has yet to submit a NPDES application to the EPA. Therefore, it is unclear if
the Manna Fish Farms project will be permitted and operational prior to the end of the
production cycle for the VE project. Manna Fish Farms has proposed siting their facility offshore
and south of Pensacola, FL. The Manna Fish Farms 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 and the NPDES permit limit of one production cycle for the VE project,
the EPA determined that the proposed action will not result in incremental impacts that could
become significant. We base this determination on our impact analysis supporting the NPDES
permitting process. Because of small scale of this project, it is not precedent setting or predictive
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of decision-making for commercial scale aquaculture projects. In addition, the effects of the
proposed action will be monitored through submission of periodic reports to EPA.
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 permit 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 permit,
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. Because of the
significant distance between the two aquaculture operations and the NPDES permit limit of one
production cycle for the VE project 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 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 shipwrecks 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.
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5,4,1.1 Pharmaceutical s
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. Because of the
significant distance between the two aquaculture operations and the NPDES permit limit of one
production cycle for the VE project, 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. In accordance with the NPDES permit, all drugs, pesticides and other chemicals must
be applied in accordance with label directions. The permittee must maintain records of all drug,
pesticide, and other chemical applications including date and time of application and the quantity
of the drug or chemical 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 seafloor 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 seabed floor. Any
remaining accumulation of organic material would also be assimilated by macroinvertebrates
living on the seafloor. 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 source discharges
from stormwater. It is unlikely that organics and nitrogen from land-based discharges would
reach the proposed facility 45 miles offshore. The effluent from the cage will have minimal
impact on sediment quality. The results of deposition modeling, even when doubling fish
production amounts, conclude that net accumulation of wastes following a 1-year production
cycle would likely not be distinguishable from background levels of organic carbon. Even when
the period of discharge is increased to the full 5-year permit term, the modeling report indicated
that the proposed project "will not likely have a discernable impact on benthic communities
around the project location." Additionally, because of the significant distance between the two
aquaculture operations and the NPDES permit limit of one production cycle for the VE project
the two projects would not incrementally contribute to the cumulative impacts to sediment
quality in the study area.
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
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a small source of emissions in offshore waters; however, cumulative impacts from sources are
expected to be minimal.
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.
Conditions in the NPDES permit provide requirements and prohibitions relating to the discharge
of solid material (if specifically not covered in the permit), discharges of domestic waste, debris
during catastrophic events, and discharges associated with support vessels. Based on these
permit conditions, the cumulative impact from the VE project 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; 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.
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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 due to the small incremental effect of the proposed action, issuance
of the NPDES permit 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 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.
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 VE project and would not
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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 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 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 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.
Additionally, as previously stated, because of the significant distance between the two
aquaculture operations and the NPDES permit limit of one production cycle for the VE project
the proposed action 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 Mammal s
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
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given that the there is one production cage and one vessel that will be deployed for a duration of
approximately 18 months.
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 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. 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.
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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 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 Fisli 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 permit, will
likely have only very minimal impacts to essential fish habitat 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 (80,000 lbs. at harvest - one production cycle) 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 would be at the facility temporarily.
Exposure to any discharged pollutants would be minimal.
Other potential sources of organic and inorganic discharges are 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 will not incrementally
combine with these other organic and nitrogen laden discharges to cause a cumulative impact.
The ODC Evaluation anticipates deposition from the VE facility will not likely have a
discernable impact on benthic communities around the project location.
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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 significant cumulative impacts of essential fish habitat 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 "can also affect
resources, ecosystems, and communities. Such events include diseases outbreaks, red tides,
changes in economic conditions, foreign imports, high fuel prices, hurricanes and storm events,
and hypoxia" (Gulf of Mexico Fishery Management Council and National Oceanic and
Atmospheric Administration 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). The NMFS
provided written concurrence with our determination in a letter dated March 12, 2019 (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.
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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 arid 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.
5.6.1 Aquaculture Production
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 tackle 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 (80,000 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
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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. Almaco jack, is
native and common to the Gulf. The fingerlings for the VE project will be sourced from brood
stock that are located at Mote Marine Aquaculture Research Park and were caught in the Gulf
near Madeira Beach, Florida. As such, only F1 (first filial generation) progeny from those wild
caught brood stock will be stocked into the net-pen for the proposed project. Neither the brood
stock, as they are native and wild caught, or the first-generation fingerlings from that brood
stock, have undergone any genetic modification or selective breeding, and would not likely pose
a competitive risk to wild stock. It's also not likely that there would be any genetic
contamination or weakening if any fugitive fish spawned with wild individuals. Therefore, there
is limited to no risk for non-indigenous stock establishment.
Furthermore, the risks that escaped farm fish pose to wild populations are a function of the
probability of escape, and the magnitude of the event that could cause an escape event. The
copper mesh cage to be used is impact resistant and designed to survive storm events while being
completely submerged. EPA believes that the cage design will result in a low probability of
escape.
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.
The permit applicant worked with the NMFS and local commercial fisheries groups to site the
project in an area that would not conflict with commercial fishing activity occurring offshore
Florida. An evaluation of impacts on commercial fishing is provided in section 4.4.2. In general,
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. Additionally,
the proposed site was selected to minimize potential conflicts with shrimping and other
commercial fishing activities in the area.
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
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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 Surnmarv of Alternatives
6.1 Alternatives Summary
As discussed in Section 2.0 Alternatives, the EPA considered 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 for the facility.
6.1.1 Alternative 1: No Action
Under the no-action alternative the EPA would not issue the NPDES permit for the proposed 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.
6.1.2 Alternative 2: Proposed Action-Issuance of NPDES Permit a for Velella
Epsilon
Under Alternative 2, the EPA would issue a NPDES permit for the proposed VE project. A
summary of the permit conditions are described below:
The proposed permit would include monitoring conditions and limitations that are based on
previous marine aquaculture 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
the 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 will be required to identify equipment and implement procedures to be used
to prevent and contain the facility's damages due to natural disasters and storm events. The
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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.
Additionally, the proposed US ACE LOP would include special conditions protecting general
navigation of the area, requirements for implementation of a tracking system for the net pen,
removal of the net pen system, adherence to the proposed Marine Mammal, Sea Turtle, and
Seabird Monitoring and Data Collection Plan (Protected Species Plan) and other ESA listed
species standard protection measures, 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
Ocean Era 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 believes
the VE NPDES, Alternative 2, will include permit conditions to avoid or minimize potential
significant environmental impacts.
6.3 Preferred Alternative
The EPA has 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 permit, Alternative 2.
The proposed NPDES Individual 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 Ocean
Era complies with the permit requirements, the EPA does not expect the discharges from the
facility to materially degrade the environmental resources of the Gulf. In addition, the proposed
EPA 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
permit are inadequately protective of marine resources of the Gulf.
6.4 Unavoidable Adverse Impacts
The discharges authorized by the NPDES permit from the proposed VE project are expected to
have unavoidable minor impacts, primarily in the immediate 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 through effluent discharge limits, the restricted use or
prohibited use of substances contained in authorized waste streams, and best management
practices.
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In ODC Evaluations for other marine aquaculture NPDES permits, the EPA made the finding
that those projects would not result in unreasonable degradation of, nor irreparable harm to the
marine environments. The ODC Evaluation for the VE project has the same finding
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 the 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.
6.6 Relationship Between Short-term Uses of the Environment and the
Maintenance and Enhancement of Long-Teen 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 permit for VE project and the other
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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 Finding of No Significant Impact
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 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 Finding of No Significant Impact (FONSI) is
provided in Appendix G.
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7.0 Other Protective Measures and Agency 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 consulted multiple federal and state agencies for the proposed project. These
additional consultation and coordination efforts include the following:
• State Coastal Zone Management Program consistency
• National Historic Preservation Act
• The Wild and Scenic Rivers Act
• The Fish and Wildlife Coordination Act
• Endangered Species Act Consultation
• Essential Fish Habitat Consultation
• Consideration of Clean Water Act Section 401
• Marine Mammal Protection Act 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.14
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 I listoric Preservation Act
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.
14 Cited from https://www.epa.gov/npdes/other-federal-laws-apply-npdes-permit-program
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During the permitting process for the proposed project the applicant coordinated with the State
Historic Preservation Office (SHPO) in Florida to ensure compliance with National Historic
Preservation Act (NHPA). In a letter dated February 8, 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.
73 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 Endangered Species Act 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 ESA
requires federal agencies to consult with the appropriate administrative agency (NMFS, USFWS,
or both) when proposing an action that may affect threatened or endangered species or critical
habitat. Consultations are necessary to determine the potential impacts of the proposed action.
They are concluded informally when proposed actions may affect but are "not likely to adversely
affect" threatened or endangered species or designated critical habitat. Formal consultations,
resulting in a biological opinion, are required when proposed actions may affect and are "likely
to adversely affect" threatened or endangered species or adversely modify designated critical
habitat.
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The EPA consulted with FWS and NMFS on potential impacts to endangered and threatened
species. The EPA concluded the required consultations with the USFWS on August 27, 2019 and
NMFS on September 30, 2019. Consultation letters are included in Appendix D of this EA.
7.6 Essential Fish 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 jointly prepared by the EPA and the 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 Clean Water Act 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
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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.
7.8 Marine Mammal Protection Act
The Marine Mammal Protection Act (MMPA) established a moratorium, with certain
exemptions(see sec. 101 and 118), 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.
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 letter of authorization (LOA). 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 provided the public an opportunity to review and comment on this EA during a 30-day
public comment period. On August 30, 2019, the EPA released for public notice and comment a
draft NPDES permit, a draft EA to comply with the NEPA, and other associated documents for
the proposed project.15 The first public comment period lasted for 30-days and ended on
September 30, 2019.
On December 12, 2019, EPA released a notice of public hearing and extended the public
comment period regarding the proposed issuance of a NPDES permit and supporting documents.
On January 18, 2020, EPA published a public notice as a reminder of the public hearing. A
public hearing was held on January 28, 2020. The second public comment period ended on
February 4, 2020 and lasted for 54 days. The public was able to submit comments orally or in
writing at the public hearing or by submitting written comments to EPA.
In accordance with 40 CFR § 124.17, EPA must issue a response to comment (RTC) document
at the time of the final permit decision. The RTC is required to have certain information: 1)
specify any provisions of the draft permit that have been changed in the final permit and the
reason for the change; and 2) briefly describe and respond to all significant comments on the
draft permit and supporting documents raised during the public comment period including the
public hearing. Additionally, the implementing regulations for NEPA require the EPA to respond
to all substantive comments received on the preliminary FONSI (40 CFR § 6.206(f)).
EPA received approximately 44,500 comments from various interested individuals and parties
during the public comment period. In addition to written comments, EPA received about 50
verbal comments during the public hearing. Written and verbal comments were provided by
national, regional, and local non-governmental organizations;16 university and research
organizations;17 aquaculture associated organizations;18 fishing groups;19 and federal, state, and
local governments.20
15 In accordance with 40 CFR § 124.10, the public notices were published on EPA's website and in the Sarasota Herald-Tribune,
and sent to the applicant, federal and state agencies, and various interested parties.
16 Non-government organizations included: C.A. Goudey & Associates, Center for Biological Diversity, Center for Food Safety,
Citizens of Sarasota County, Clean Water Tribe, Community Alliance for Global Justice, Cuna Del Mar, Environmental
Confederation of Southwest Florida, Farmworker Association of Florida, Friends of Animals, Friends of the Earth, Food and
Water Watch, Green Justice Legal, Gulf Fisheries Management Council, Elands Along the Water, Elealthy Gulf, Mansoatta-88,
National Family Farm Coalition, Northwest Atlantic Marine Alliance, Ocean Conservation Research, Paradise Cove Association,
Potesta & Associates, Sierra Club, Siesta Key Association, Sarasota County Council of Neighborhood Associations, Solutions to
Avoid Redtide, Stocking Savvy Environmental Consulting, Suncoast Waterkeeper, and Wildlife Law Center.
17 Universities and research organizations included: Coonamessett Farm Foundation, Mote Marine Laboratory, University of
Miami, and University of South Florida.
18 Aquaculture associated groups: Aquaculture Consulting Services, Aquarium of the Pacific, Florida Aquaculture Association,
Manna Fish Farms, National Aquaculture Association, Recirculating Farms Coalition, and Sanibel-Captiva Conservation
Foundation Marine Laboratory.
19 Fishing associated groups: Bonefish and Tarpon Trust, Fish for America USA, Kirk Fishing Company, and Live Advantage
Bait.
20 Government entities included: City of Naples, City of Sarasota, City of Sanibel, Florida Department of State, Lee County
Natural Resources, Mississippi-Alabama Sea Grant Consortium, and Siesta Key Chamber of Commerce.
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The EPA's responses to significant public comments received on the proposed draft NPDES
permit, draft EA and FONSI, and all supporting documents can be found in the RTC. The EPA
has addressed all significant issues raised during the public comment period. Where multiple
comments were received on similar topics, the comments are grouped together and summarized.
Excerpts from some comments have been included to provide context. All comments are part of
the administrative record.
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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 Section
• Roshanna White - NEPA Section
• Jamie Higgins - NEPA Section
• Alya Singh-White - NEPA Section
• Christopher Militscher - NEPA Section
• Ntale Kajumba - NEPA Section
• Rol and F erry - Water Di vi si on
• Paul Schwartz - Office of Regional Counsel
• Kip Tyler - Water Division
• Megan Wahlstrom-Ramier - Water Division
Other Federal Agency personnel responsible for preparing or 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 - U.S. Army Corps of Engineers, Jacksonville District
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Appendix A -Baseline Environmental Survey
Appendix B - Cage/Pen Design
Appendix C - ODC Evaluation
Appendix D - ESA Consultation Documents
Appendix E - EFH Consultation Documents
Appendix F - CASS Technical Reports
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
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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.
November 12, 2018
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Tallahassee
FLo»'ando
Tampajan&i
Havana
# Site A = Preferred Site
# Site B = Alternate Site
Bathymetric Contours (m)
Nautical Miles (NM)
27°0'0"N
83°0'0"W
Figure 1. Proposed Alternative Site Locations for the VE Project
November 12, 2018
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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
November 12, 2018
Page 9 of 28
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The Velella Epsilon Project - Baseline Environmental Survey Report
Florida
Mexico
S j j
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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 Tracklmes
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
Page 10 of 28
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The Veiella Epsilon Project - Baseline Environmental Survey Report
Legend:
As-Run Tracklines
Florida
0000-
Gulf
of v ,
Mexico \ %Jt
2.500
Notes:
1. Coordinates are m 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
¦ -138 --136
~ -136- -134
~ -134--132
~ -132 --130
-130 --124
-124 - 0
1000000-
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
Page 11 of 28
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The Veiella Epsilon Project - Baseline Environmental Survey Report
Modified Site #B:
Location
Top Left
Top Right
Bottom Left
Bottom Right
Latitude
27.131143° N
27.130512° N
27.107230° N
27.108377° N
Longitude
-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
-------
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.
" £
™ ~jT
£ k
... , - ^—
—
Hi
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
OK
5 ft
Oft
ft" - """
ft# IV
Oft •'
. Zmbfrft
5ft
Oft
5 ft
Figure 7. Seismic Line 323 from Modified Site B Trending South (left) to North (right) (APTIM 2018)
November 12, 2018
Page 13 of 28
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The Velella Epsilon Project - Baseline Environmental Survey Report
Florida
Legend:
As-Run Tracklines
1020000H 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 Fpsil
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
Page 15 of 28
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The Velella Epsilon Project - Baseline Environmental Survey Report
1020000-
1000000-
Legend:
As-Run Trackliiies
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
¦ 14
Map 3: Unconsolidated Sediment
Thickness Isopach
Kampachi Farms
V elella Epsil
Geophysical Survey
725 US 301 South
~ APTIM Tampa, FL, 33619
www.APTIM.com
Florida
Gulf
Mexico
Figure 8. Unconsolidated Sediment Thickness Isopach from Modified Site B (APTIM 2018)
November 12, 2018
Page 16 of 28
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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
1
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
Page 18 of 28
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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
Page 19 of 28
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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-^
-5 j 3m-1.5g-46.5f
¦ J 6-3-dp-4.3g-237.
317-3-nm-O 4g-40 9f
O
o
o
id -
o
o
o
o
¦ o
CN
o
o
o
o
¦LO
o
o
o
¦ o
260000
I
I
260000
265000
265000
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.
November 12, 2018
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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 Coordinate
Y Coordinate
Line #
Auomalv #
Signature
Intensity
Duration
idsntificatioii
SCR Potential
I7u-1-pm-3g-102. If
259646.3
1015574.1
170
1
Positive Monopolar
ay
102.1 f
Smail 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
Ifl
147,2f
Small Ferrous Ob
ect
Very Low
311-1-dp-0.8g-240.7f
257602.7
1012897.4
311
1
Dipolar
Q.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-c#)-2.7g-62.5f
258196.7
1011103.8
312
1
Dipolar
2.7g
62.5f
Small Ferrous Ob
ect
Very Low
312-2-0-1.4g-48.9f
258255.6
1012855.9
312
2
Dipolar
1 4g
48.9f
Small Ferrous Ob
ect
Very Low
312-3-dp-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
1-30
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-ctj-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-fim-0.7g-84.3f
259109.5
1018169
313
1
Negative Monopolar
0-7fl
84.3f
Small Ferrous Ob
ect
Very Low
315-1-dp-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
315-3-pm-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-101.2f
260886.4
1012378.4
316
2
Positive Monopolar
1-5fl
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 Ob
ect
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 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
1.9g
41.4f
Small Ferrous Ob
ect
Very Low
324-4-dp-1 g-72.8f
266291.1
1017831.4
324
4
Dipolar
ig
72,8f
Small Ferrous Ob
ect
Very Low
325-1-pm-0.8g-42.Gf
266738.9
1011720
325
1
Positive Monopolar
0.8g
42.6f
Small Ferrous Ob
ect
Very Low
325-2-pm-1.5g-46.5f
266896.2
1015675
325
2
Positive Monopolar
1-5g
46.5f
Small Ferrous Ob
ect
Very Low
326-1-pm-1.9g-96.7f
267376.3
1010714.4
326
1
Positive 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
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
November 12, 2018
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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.
November 12, 2018
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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
N
nw | ne Surface (4m)
Current Speed (cm/s)
\. IS* /
¦ 0.00 to 0.00
¦ 0.00 to 0.00
«0 00 to 0.00
s* ¦ 17.00 to
ft \W ¦ 15.00 to 17.00
W <1 I e 13 00 to 15.00
W y 11 00 to 13.00
VA
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
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
November 12, 2018 Page 25 of 28
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The Veiella Epsilon Project - Baseline Environmental Survey Report
NOAA BUOY 42002
2015-2018
NW
NE
w
I
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
November 12, 2018
Page 26 of 28
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The Veiella Epsilon Project - Baseline Environmental Survey Report
NOAA BUOY 42022
2015-2018
NW
NE
W
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 11.73
Peak frequency: 19.06%
Peak direction: S
Percent calm: 5.53%
Calm defined as: < 3.0 cm/s
Figure 13. Bottom (44m) Current Speed and Direction from NOAA Buoy Station 42022
November 12, 2018
Page 27 of 28
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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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> APTIM
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
-------
> APTIM
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
55" ft"1 I-—
""" " " ; """ * " "
65 ft --p.-..-——.-...-.....— ---———
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.
45 ft
Son
55 ft
)6 0 ft
55 ft
^
?0 ft '
75 ft
' '
BO ft
85 ft
Figure 3: Seismic Line 323 trending south to north showing the deepening of the consolidated sediment layer.
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.
49,000- I |
48,500 - / \
48,000 - / \
47,500 - J \
47,000 - /
\
46,500 \ — ~~ \
16711680 16711880 16711680 16711680 16711680 16711680
Left: Dipole anomaly 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.
46,500
f\
/ \
j \
46,400
\
\
46,300
1
X.
46,200
/
46,100
46,000
\ /
16711680 16711680 16711680 16711680 16711680 16711680
Figure 4: Magnetometer gamma signatures;
1
-------
> APTIM
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
¦H
"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
~
NTS
Florida
Gulf
of
Mexico
-------
1020000-
2.500
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)
m
U 2
¦ 3
~4
~ 5
~ 6
~ 8
HO
112
¦ 14
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
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
-------
> APTIM
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).
-------
> APTIM
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
-------
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
-------
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
300000
'
350000 400000
1
450000
500000
OLD TAMPA
BAY
R Bn 3£
Long Key
15s 13M
tr Manatee
Bradenton
SARASOTA
BAY
SARASC
Little;
Bay
(dredged material)
(see note S) (Rep mg) p2
B h, 15 11
12
WOr
C Priv
12*
PA
14
14
11
12 I
10
12
•|4 Obstns•: 1 o';
17
Co S/7 G lv 9
12 15
¦:VJk
'11
Dump Site i J
-17-
;• Unexploded depth charge
(reported 1956)
19
15
16
11
18
14
17
14
19
19,
Sand Key,
(use chart 11412)
Longboat
13
12
Project Area
Obstn1 ®
Fish Haven6 00 14
(auth min 71h fms)
18 15
17
11
12
Siesta Key
(use chart ?f424J
OfesJns 13
Obstni"] I5 14 Fish Haven 11
Fish Haven
(auth min Tk
M Sh 18
fms)
(auth min Vhfms) N
16
15
Go
Sh Co (auth min 51ms)
Obstn Fish Haven _ 11\
(auth min 5'/> fms):'' '< ")Oi>stn (5 fms)
/PD12 \
0£>sfn 1
fisfl Haven
uthmi
5 fms)
(auth min ^
o
o
.0
o
m
" 1
450000
250000
300000
350000
400000
500000
Figure 1. Velella Epsilon (VE) proposed project area.
-------
Tallahas-
Efep
FL>'ando
Tampa
P ~
—J Miami
Havana
50
60
N o
30
40
• Site B
• Site A
Nautical Miles
-------
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®}
Y Offset (ft)
Z Offset (ft)
Vessel GPS (zero)
0
0
-155
OdomtildiiEiCfcniounlecf
-3.2
-5 5
}
Motion Reference Unit- mounted
25
153
-15 5
Chirp-towed
104
-13 8
-3,3
SSS-towed
21
-18
-74
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).
250000 255000 260000
« i \ ^
\ 1
o T^_
O ¦¦
o
o -
\ 1
s ¦[
i- Ml
© " ifc !
265000
) ,
§
.8
O
8
-S
o
-' Inil
1- ^
o
§
8.
©
o
oo
® 0 8751,750 3,500 5,250 7,000
, " ' f
250000 255000 260000
[Mil
hk_ 2
T*.
o
o
O
O
o
0
-o
1
265000
Figure 3. Project as-run track lines.
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10
315-4-pm-G,3g-5:
325-ipm-1.5g-46.5f
¦ 26-3-dp-4.3g-237.91
3' 9-1-di -0.8g-J5.2f,
317-3 nm-0 4g-40.9f
—i r
260000 265000
260000 265000
I I
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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13
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
-------
Appendix B
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Appendix C
-------
Final
OCEAN DISCHARGE CRITERIA EVALUATION
Ocean Era, Inc. - Velella Epsilon
Net Pen Aquaculture Facility
Outer Continental Shelf
Federal Waters of the Gulf of Mexico
NPDES Permit Number
FL0A00001
September 30, 2020
/W\
\PR0^°
U.S. Environmental Protection Agency
Region 4
Water Division
61 Forsyth Street SW
Atlanta Georgia 30303
-------
Table of Contents
List of Acronyms 3
1.0 Introduction 4
1.1 Proposed Agency Action 4
1.2 Evaluation Purpose 4
1.3 ODC Evaluation Report Overview 5
2.0 Proposed Project Information 6
2.1 Proposed Project 6
2.2 Proposed Action Area 7
3.0 Physical Environment 8
3.1 Physical Oceanography 8
3.2 Chemical Composition 11
4.0 Discharged Materials 13
4.1 Fish Feed 13
4.2 Fish Wastes 14
5.0 Biological Overview 16
5.1 Primary Productivity 16
5.2 Phytoplankton 17
5.3 Zooplankton 19
5.4 Habitats 19
5.5 Fish and Shellfish Resources 20
5.6 Marine Mammals 21
5.7 Endangered Species 22
6.0 Commercial and Recreational Fisheries 24
6.1 Overview 24
6.2 Commercial Fisheries 24
6.3 Recreational Fisheries 26
7.0 Coastal Zone Management Consistency and Special Aquatic Sites 28
7.1 Coastal Zone Management Consistency 28
7.2 Florida Coastal Management Program 28
7.3 Special Aquatic Sites 29
8.0 Federal Water Quality Criteria and Florida Water Quality Standards 31
8.1 Federal Water Quality Criteria 31
8.2 Florida Water Quality Standards 31
9.0 Potential Impacts 33
9.1 Overview 33
9.2 Water Column Impacts 33
9.3 Organic Enrichment Impacts to Seafloor Sediments 36
9.4 Organic Enrichment Impacts to Benthic Communities 38
9.5 Antibiotics 40
9.6 Waste Deposition Analysis 43
10.0 Evaluation of the Ocean Discharge Criteria 45
10.1 Evaluation of the Ten ODC Factors 45
10.2 Conclusion 48
References 49
Appendix A 59
Appendix B 72
-------
List of Acronyms
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
MM PA
Marine Mammal Protection Act
NCCOS
National Ocean Service National Centers for Coastal Ocean Science
NMFS
National Marine Fisheries Service
NOAA
National Oceanic and Atmospheric Administration
NEPA
National Environmental Policy Act
NPDES
National Pollutant Discharge Elimination System
OCS
Outer Continental Shelf
ODC
Ocean Discharge Criteria
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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1.0 Introduction
1.1 Proposed Agency Action
Ocean Era, Inc. (applicant) is proposing to operate a pilot-scale marine aquaculture facility (proposed project)
in federal waters of the Gulf of Mexico (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 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.
1.2 Evaluation Purpose
The purpose of this Ocean Discharge Criteria (ODC) Evaluation is to identify pertinent information relative to
the ODC and address the EPA's regulations for preventing unreasonable degradation of the receiving waters
for the discharges covered under this NPDES permit. CWA Sections 402 and 403 require that a NPDES permit
for a discharge into the territorial seas (coast 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 ODC evaluation 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 (ESA), 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;
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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).
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 of 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 ODC Evaluation Report Overview
The ODC Evaluation 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 ODC Evaluation addresses one
of the 10 factors used in making a determination about whether the discharge will cause unreasonable
degradation as shown in Table 1.1.
Table 1.1 - Summary of the ODC Topics
Section
ODC Factor
Description
3
2
Physical and chemical oceanography relevant to the action area
4
land 10
Characteristics, composition, and quantities of materials that potentially will be discharged
from the facility; transport and persistence of pollutants in the marine environment
5
3 and 4
Biological overview of the affected environment
6
7
Information on commercial and recreational fisheries in the receiving water environment
7
5 and 8
Florida Coastal Zone Management Plan (CZMP) and Special Aquatic Sites
8
10
Federal Water Quality Criteria and State Water Quality Standards Analysis
9
1, 2, and 6
Potential impacts on human health, and describes the toxicity and potential for
bioaccumulation of contaminants
10
Summary
Evaluation of the ODC
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2.0 Proposed Project Information
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 80,000 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 (Sarasota, FL) 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 in offshore fishing activities in the Gulf.
A single cage, that is offshore strength 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 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 able 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 National Marine Fishery Service (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 is an important minimization
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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 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 entanglement or 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 the National Oceanic and Atmospheric
Administration's (NOAA) 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
Location
Latitude
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 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 Physical Environment
3.1 Physical Oceanography
The Gulf is bounded by Cuba on the southeast; Mexico on the south and southwest; and the United States
(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 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
100'W 98" 96® 94° 92° 90° 88* 86" 84* 82" 80" 78° W
100° W 98" 96° 94° 92° 90° 88° 86° 84* 82° 80* W
Source: NOAA 2007
Figure 3. 2 - Depth average current rose diagram for the Tampa ODMDS showing current speeds and
direction. (EPA, 2012)
North
0
Current Speed
(cm/sec)
I U=5
I 1-5-10
I MO-15
I~1-»15-20
¦ >20 - 25
180
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Wind patterns in the Gulf are primarily anticyclonic (clockwise around high-pressure areas) and tend to follow
an annual cycle; winterwindsfrom the north and southeastand summerwindsfrom the northeastand 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.
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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).
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
Dissolved substance
(Ion or Compound)
Concentration
(grams per kilogram)
Percent
(by weight)
Chloride (CI )
18.98
55.04
Sodium (Na+)
10.56
30.61
Sulfate (S042")
2.65
7.68
Magnesium (Mg2+)
1.27
3.69
Calcium (Ca2+)
0.40
1.16
Potassium (K+)
0.38
1.1
Bicarbonate (HC03 )
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.
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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/l), with some seasonal variation, particularly during the summer months when a slight lowering can be
observed. Oxygen values generally decrease with depth to about 3.5 mg/l through the mixed layer (MMS,
1990). In some offshore areas in the northern Gulf, hypoxic (<2.0 mg/l) and occasionally anoxic (<0.1 mg/l)
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 Discharged Materials
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 project. The proposed project will grow out a maximum of 20,000 fish that would be grown
to 1.8-2.0 kg for one year. The total maximum biomass assuming no mortality is estimated to be
approximately 36,288 kg. Fish will be fed a commercially available grow out diet with 43 percent protein
content. The total maximum daily feed ration at harvest is equivalent to 399 kg at harvest. Maximum daily
excretion of total ammonia nitrogen is estimated at 18-19 kg and maximum total solids production is 161 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 offish 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 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 offish 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
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Sound, resulted in wastage of 3.6 percent. The use of automatic feeders increased wastage to 8.8 percent
(Cross, 1988).
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; Gowen 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
Fish Species
Feed Brand
Feed
Type
%
Protein
%
Fats
%
Carbohydrates
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
Ziegler Bros. (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
01 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.
4 Source: Modified from Waldemar Nelson International, 1997.
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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 (2200 lbs) offish 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.
A discharge limitation will be placed in the NPDES permit to 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 Biological Overview
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, 1300 g C/m2/yr
• Thalassia, 580-900 g C/m2/yr
• Phytoplankton, 350 g C/m2/yr
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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 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
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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.)
Table 5.1 - Significant Dinoflagellate Species of the Eastern Gulf5
Species
Biomass Value (ji3)
Amphibologia bidentata
67,039 - 95,406
Ceratium carriense
637,219- 1,115,367
C. carriense var. volans
622,206-1,196,643
C. contortum var. karstenii
943,121 - 1,655,573
C. extensum
189,709 - 323,546
C. furca
23,157-43,369
C. fusus
34,463 -154,722
C. hexacanthum
687,593 - 1,384,016
Ceratium hircus
211,709
C. inflatum
145,897-221,276
C. massiliense
543,762 - 1,002,222
C. trichoceros
104,110-357,437
C. tripos var. atlanticum
518,659 - 964,436
Dinophysis caudata var. pedunculata
92,153-231,405
Gonyaulax splendens
51,651
Prorocentrum crassipes
329,540
P. gracile
25,773
P. micans
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 |im
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 Source: Steidinger and Williams, 1970.
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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
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 forthe 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
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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 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 post larvae 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) live
bottom, 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.
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Pelagic fish species are distributed by water column depth and relationship to the shore. Coastal pelagic fish
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 pelagic fish occur at or seaward of the shelf edge throughout the Gulf.
Oceanic pelagic fish 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).
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 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 a I., 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
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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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
project. 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.
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 the Final PEIS for Offshore Marine Aquaculture in the Gulf (NOAA, 2009).
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Table 5.2 - Federally Listed Species, Listed Critical Habitat, Proposed Species, and Proposed Critical
Habitat Considered for the Proposed Action
Species Considered
ESA Status
Critical Habitat
Status
Potential Exposure to
Proposed Action Area
Birds
1 Piping Plover
Threatened
Yes
No
2 Red Knot
Threatened
No
No
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 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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6.0 Commercial and Recreational 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 Deepwater 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, and yellowfin 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
In 2013, the eastern Gulf Region's seafood industry generated $527 million in sales in Alabama, $268 million
in sales in Mississippi, and $15 billion in sales in Florida Table 6.4). Florida generated the largest employment,
income, and value-added impacts, generating 78,000 jobs, $2.9 billion, and $5.1 billion, respectively. The
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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smallest income impacts were generated in Mississippi ($200 million) and the smallest employment impacts
were also generated in Mississippi (6,432 jobs) (NMFS, 2015).
Table 6.1 - Key Gulf Region Commercial Species or Species Groups
Shellfish
Finfish
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
Weight
(thousands of lbs)
Value
(Thousands of dollars)
% Weight
% Value
Menhaden
1,020,244
95,277
73.3
10.2
Shrimp
204,527
503,842
14.7
53.8
Blue crab
46,543
61,264
3.3
6.5
Oyster
19,230
76,729
1.4
8.2
Crayfish
19,823
16,593
1.4
1.8
Mullets
13,482
13,222
0.01
0.01
Stone crab
3,778
24,762
0.003
2.6
Groupers
7,280
23,396
0.005
2.5
Red snapper
5,286
20,493
0.004
2.2
Tuna
2,107
7,352
0.002
0.008
Total
1,392,364
936,660
-
-
Table 6.3 - Value of Gulf Coast Fish Landings by Distance from Shore and State for 2012 ($1,000) 10
State
Distance from Shore
0-3 miles 3-200 miles
Florida (Gulf)
$
64,727
$ 75,232
Alabama
$
15,870
$ 27,195
Mississippi
$
29,767
$ 19,509
In 2013 1.4 billion pounds of finfish and shellfish were landed in the Gulf Region. This was a 6.7 percent
decrease from the 1.5 billion pounds landed in 2004 and a 7.0 percent increase from the 1.3 billion pounds
9 NMFS, 2015.
10 https://www.st.nmfs.noaa.gov/commercial-fisheries/commercial-landings/other-specialized-programs/preliminary-annual-landings-
by-distance-from-shore/index
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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
State
Jobs
Landings Revenue
Sales
Income
Value Added
Alabama
$
12,090
$ 55,434
$ 526,767
$
200,494
$ 265,580
Mississippi
$
6,432
$ 46,618
$ 268,367
$
107,340
$ 138,779
Florida
$
78,378
$ 148,058
$ 15,319,435
$
2,878,309
$ 5,136,623
Table 6.5 - Total Landings and Landings of Key Species/Species Groups From 2010 to 2013 (thousands of
pounds)12
Landings
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.
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
11 NMFS, 2015
12 NMFS, 2015
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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 6.6 - 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
Table 6.7 - Estimated Number of People Participating in Eastern Gulf Marine Recreational Fishing in 2013
(thousands)14
Location
Coastal
Non-coastal
Out of state
Total
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
Location
Trips
Jobs
Sales
Income
Value 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 Zone Management Consistency and Special Aquatic Sites
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
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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.
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 reef 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
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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).
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
' / 1 Live Bottom (Low Relief) Stipulation Blocks
111111 Live Bottom (Pinnacle Trend) Stipulation Blocks
Proposed Sale Area
Representative Eastern Planning Area
High-Relief Live Bottoms
200 Kilometers
200 Miles
• TALLAHASSEE
PANAMA CITY
£ FLORIDA
• TAMPA
Central
Planning
Area
• NAPLES
16 BOEM, 2015
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8.0
Federal Water Quality Criteria and Florida Water Quality 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 that applies in Florida waters 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 point source wastewater 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 Impacts
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 offish, 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
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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
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. a I., 2017).
9.2.1 Turbidity
Turbidity, an indication of water clarity, may be affected by fish farming operations. The loss offish 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 offish 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 certain 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 offish 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 a I., 1985). About 22 percent of the consumed
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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 (NorSi et al., 2011).
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 (5-30 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 not enough scientific evidence is available to suggest that macronutrients and
micronutrients from fish farming, or the proposed project, can be directly 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 orwithin 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/l, equivalent to 0.006 mg/l 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
offish 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
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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 offish 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
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 offish 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 a I., 2000, Karakassis et a I., 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 a I., 2014). Studies offish 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 a I., 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 a I., 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 a I., 1987; Hall et a I., 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).
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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.
Sediment oxygen demand (SOD) near fish farms can exceed the diffusive oxygen influx and the anoxic layer
moves closer to the surface (Brown et a I., 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 a I.,
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 a I., 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 offish 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 of H2S, are common in sediments near and beneath net pens (Brown
et a I., 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
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offish 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 microstructure 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 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 a I., 1987; Hall et a I., 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 a I.,
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
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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 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 15 m 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 8g 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
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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 underthese 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 offish stocking.
Infauna community conditions (biomass
-------
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 offish grown in confined ponds, and the use of a variety of antibiotics
not 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 offish 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.
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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
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 offish, 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
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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 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 floating cage estimated to hold approximately
80,000 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 help determine the fate
and effects of solid wastes discharged from the net-pen at maximum production rates. 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 the models used the maximum fish production amounts for the
entirety of the simulation period. Several 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. The third
model scenario assumed a maximum biomass for the entire 5-year term of the NPDES permit.
9.6.1 Solid Waste Discharge
A solids deposition model was performed using data from the production model, as well as environmental
and oceanographic data on the proposed offshore location (see NCCOS technical reports in Appendix A and
B). DEPOMOD and NewDEPOMOD, a particle tracking model for predicting the flux of particulate waste
material (with resuspension) and associated benthic impact, was developed 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 of 4 km2 was selected such that it would encompass the whole depositional footprint.
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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The results of the first 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. The second depositional model
performed 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 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 three model simulations resulted in ITI predictions ranging from
58.67 to 58.96. The predicted ITI close to 60 suggests that the proposed Velella project will not likely have a
discernable impact on the benthic infaunal community around the site. The third modeling scenario (full
production for the 5-year term) showed that "Velella project will present challenges for monitoring and
detecting environmental impacts on sediment chemistry or benthic communities because of the circulation
around the project location and the small mass flows of materials from the net pen installation."
9.6.2 Dissolved Wastes
The NCCOS technical reports estimated that 2,743 kg of ammonia nitrogen would be produced using the
maximum biomass for the entire 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
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/l more than once every three years on the
average and if the one-hour average concentration does not exceed 0.233 mg/L 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/l (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/l (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 cm2. The lateral flow through the cage was estimated 15,779,400 cm3/s.
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10.0 Evaluation of the Ocean Discharge Criteria
This section summarizes EPA's review of the ten factors that the EPA must consider in determining, pursuant
to 40 CFR § 125.122(a), whether a discharge will cause unreasonable degradation of the marine environment,
to ensure that the proposed NPDES permit complies with CWA § 403. This section discusses how conditions
and limitations included in the final permit for the proposed project ensure compliance with these ODC, 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 ODC Factors
10.1.1 Factor 1 - Quantities, Composition, and Potential for Bioaccumulation or Persistence of Pollutants
The quantities and composition of the discharged material were 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 project 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 offish 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
characteristic benthic communities. Results from deposition modeling (Section 8) show the potential for
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benthic impacts over an area in excess of 1 km2. The potential for impacts due to toxic effects from a
demonstration size fish farm discharge, however, 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 finds 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. EPA
has determined that the proposed area is located sufficiently far from special aquatic sites off the west Florida
coast 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, and will therefore not impact any special aquatic
sites.
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 with these criteria and standards, and indicate that there will be an insignificant
depositional and water quality impact. In addition, 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. Based on consideration of this factor, EPA finds that the proposed facility is not likely to have
impacts on human health.
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. Based on the following, EPA finds that the discharges from the project
will not adversely affect water quality or the health of these fisheries:
1. The modeling performed for the proposed project found that there would be minimal to insignificant
impact on water quality and seafloor benthic communities.
2. EPA determined that the conditions and limitations in the permit for the proposed project are
adequate to ensure that the recreational and commercial fisheries will not be adversely impacted. In
addition to environmental monitoring, the NPDES permit will include a requirement that all fish
stocked must obtain an Official Certificate of Veterinary Inspection prior to being stocked, and
implement BMPs related to fish health management.
3. EPA evaluated that potential social, economic, and environmental impacts to commercial and
recreational fisheries caused by the proposed project within the Environmental Assessment to
comply with the National Environmental Policy Act (NEPA).
4. The EPA determined, in consultation with NMFS, that there the minimal short-term impacts
associated with the discharge will not result in substantial adverse effects on Essential Fish Habitat
(EFH), habitats of particular concern, or managed species in any life history stage, either immediate
or cumulative, in the proposed project area (see EFH consultation record for more information).
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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.
10.1.9 Factor 9 - Other Factors Relating to Effects of the Discharge
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 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. Therefore, impacts to water quality will be reduced by a range of
non-numeric effluent limitations through the implementation of project-specific BMPs and operational
measures.
Factor 9 of the marine unreasonable degredation criteria are "such other factors relation to the effects of
the discharge as may appropriate. Factor 9 was considered, along with the other 9 factors, in developing
permit conditions to ensure that unreasonable degradation to the marine environment will not occur as a
result of the discharges from the proposed facility. As provided in 40 CFR § 125.123(a),21 the EPA has included
permit conditions that have been determined to be necessary to ensure that unreasonable degradation of
the marine environment will not occur by including necessary conditions specified in 40 CFR § 125.123(d),
including the following conditions:
1. Implementation of environmental monitoring and an environmental monitoring plan will be required
in the NPDES permit to meet the requirements 40 CFR § 125.123(d)(2).22 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.
2. In accordance with 40 CFR § 125.123(d)(3),23 the NPDES permit must include two conditions related
to fish health management and the indirect discharge of pathogens:
a. a requirement that all stocking of live aquatic organisms, regardless of life stage, must be
accompanied by an Official Certificate of Veterinary Inspection signed by a licensed and
accredited veterinarian attesting to the health of the organisms to be stocked; and
b. the BMP plan shall include conditions to control or minimize the transfer of pathogens to wild
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."
22 40 CFR § 125.123(d)(2) states that EPA is allowed 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."
23 40 CFR § 125.123(d)(3): "Contain any other conditions, such as performance of liquid or suspended particulate phase bioaccumulation
tests, seasonal restrictions on discharge, process modifications, dispersion of pollutants, or schedule of compliance for existing discharges,
which are determined to be necessary because of local environmental conditions, and"
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fish.
3. In accordance with CWA § 403 of the, 40 CFR § 125.123(a), and 125.123(d)(3), the NPDES permit will
contain a condition that "The discharge from the facility shall not cause unreasonable degradation of
the marine environment underneath the facility and in the surrounding area" under 40 CFR §
125.123(d)(3).
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 ODC Evaluation.
10.2 Conclusion
The consideration of the ten factors discussed in this ODC Evaluation were based on the available information
from published literature regarding impacts that have occurred near net pen fish farms from around the
world, and information in the Administrative Record for the NPDES permit action regarding the proposed
facility and the potential impacts of discharges from the proposed facility. Sufficient information currently
exists regarding open water marine fish farming activities and expected impacts from such activities, coupled
with information regarding the proposed discharge, to allow the EPA to adequately predict likely
environmental outcomes for the Proposed project.
The EPA also determined that the NPDES permit must contain necessary conditions allowed by 40 CFR §
125.123(d). First, the NPDES permit will contain a comprehensive environmental monitoring plan that will
confirm EPA's determination and ensure no significant environmental impacts will occur from the proposed
project. Second, the NPDES permit must include a requirement that all stocking of live aquatic organisms,
must obtain an Official Certificate of Veterinary Inspection prior to being stocked, and implement BMPs
related to fish health management. Finally, the NPDES permit will contain a condition that the discharge from
the facility shall not cause unreasonable degradation of the marine environment. EPA finds that these
conditions, along with other the other conditions in the NPDES permit (i.e. BMP plan, Facility Damage
Prevention and Control Plan, etc.), will ensure thatthe discharges from the facility do not cause unreasonable
degradation of the marine environment.
The EPA finds that "no-unreasonable degradation" will likely occur as a result of the discharges from this
project based on the available scientific information concerning open ocean fish farming, the results
predicted by deposition and dilution modeling, the effluent limit guidelines for the CAAP industry that are
being applied to this facility, and the conditions included within the NPDES permit as allowed by the ODC
implementing regulations.
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Appendix A
CASS Technical Report
Environmental Modelling to Support NPDES Permitting for Velella Epsilon Offshore Demonstration
Project in the Southeastern Gulf of Mexico
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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
S3'15W
83"10'W
Florida, USA
0 50 100 km
Z
in _
Scale: 1:100,000
1.6 nm
Layer Credits. Sources: Esn. GEBCO, NOAA, National Geographic.
HERE, Geonames org, and other contributors
Bathymetry (m)
Figure 1. Bathymetric map of proposed Velella Epsilon Offshore Aquaculture Project.
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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
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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).
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(A) 4-m depth
(B) 24-m depth
(C)36-m depth
Curr««l v*lecrty
[tm/j)
¦ '60 1
¦ JO 1-60.0
¦ 40 1-500
30.1-40.0
¦ 20 1 - 30.0
¦ 10 1 - 20.0
¦ 0.0-10.0
Currant velocity
(tmi's)
¦ >60 1
¦ 50.1 -80.0
¦ 40 1-50.0
¦ 30.1-40.0
¦ 20.1-30.0
¦ 10 1-20.0
¦ 0.0-10.0
Current velocity
{cmi's)
¦f 3-601
¦ 50 1-60.0
¦ 40.1-50.0
30 1-40.0
¦ 20.1-30.0
¦ 10.1-20.0
¦ 0 0-10 0
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.
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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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80
70
60
50
bJO
a
i 40
30
20
10
a « B i
250m 500m
12
11
10
9
8
7
Organic
6
Carbon
[g/m2]
5
4
3
2
1
10
20
30
60
70
80
40 50
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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um 250m 500 m
12
11
10
9
8
7
Organic
6
Carbon
(g/m2]
5
4
3
2
1
40
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 B
CASS Technical Report
Addendum: Environmental Modelling to Support NPDES Permitting for Velella Epsilon Offshore
Demonstration Project in the Southeastern Gulf of Mexico
ODC Evaluation
Ocean Era, Inc. - Velella Epsilon
Page 72 of 85
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^OATMOS^
CASS Technical Report
^rtoENT OF ^
Addendum: 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 Kip Tyler (EPA), September 23, 2020
This report is submitted as an addendum to the report "Environmental Modelling to Support NPDES
Permitting for Velella Epsilon Offshore Demonstration Project in the Southeastern Gulf of Mexico" of
August 2018. The Environmental Protection Agency (EPA) is preparing to issue an NPDES permit for
the Velella Epsilon Offshore Demonstration Project. The applicant, Kampachi Farms, LLC (now
Ocean Era, Inc.), proposes to develop a temporary, small-scale demonstration net pen operation to
produce a single cohort of Almaco Jack (Seriola rivoliana) at a fixed mooring located on the West
Florida Shelf, approximately 45 miles offshore of Sarasota, Florida. With this addendum, scientists
from the NOAA Coastal Aquaculture Siting and Sustainability (CASS) program continued to work
with the EPA NPDES permitting program to develop estimates of farm discharge deposition on the
seabed and surrounding benthic community. Specifically, the farm simulation was executed for five
years at the maximum stocking density, with the predicted feed and fish waste daily contributions. The
most recent version of DEPOMOD modelling software (i.e., NewDEPOMOD) was used to calculate
the distribution and deposition of solid materials at the project location.
Current data were obtained from NOAA Buoy Station 42022 along the West Florida Shelf at the 50-m
isobath and located 45 miles northwest of the project location (27.505 N, 83.741 W). The buoy is
owned and data are collected by the University of South Florida Coastal Ocean Monitoring and
Prediction System with support from the U.S. Integrated Ocean Observing System. Lacking five
continuous years of water column flow data at the site, a single year of current data from the original
simulation was used to produce the assumed current profile at the project location. Given that single
year current data was used for this model, year-to-year variability in oceanographic patterns that are
associated with changing climate and weather patterns, water temperature, and storm tracks (e.g.,
hurricanes) are not evaluated.
As previously reported, bathymetric data were obtained from the NOAA Coastal Relief Model.
Bathymetry was resampled to 25 x 25 meter grid cells using a bilinear interpolation to all, for use
within the deposition model. The characterization of the site and composition of benthic surfaces were
informed by U.S. Geological Survey offshore surficial sediment data (usSEABED) that describes
seabed characteristics, including textural, geochemical, and compositional information for the Gulf of
Mexico. The benthic surfaces for the project location were also informed by acoustic survey and sub-
bottom profile data included with the applicant's Baseline Environmental Survey (BES). Sediment
samples, including core or grab samples, were not collected or analyzed as part of the BES. Without
-------
knowing explicitly the hydraulic roughness of the benthic surface at the project location, the model
was run (as previous) with the assumption of a smooth benthic surface characteristic of unconsolidated
sediments (coarse to fine grain sand bottom) such as those common on the West Florida Shelf.
Modelling with a smooth benthic surface and reduced roughness tends to lower the bed shear stress
and increase resuspension.
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). The model domain also remained as reported. The model domain was
set to encompass the whole initial depositional footprint under average current velocities estimated at
20 cm/s and with particles settling at rates faster than 0.75 cm/s. The dimensions for the model domain
are standards required by the Scottish Environmental Protection Agency for marine aquaculture
operations. The domain also captures reasonable efficiency in processing large data sets or long time-
series data (i.e., model requires 24-36 hours to process). The predicted carbon deposition and
magnitude of biodeposition were estimated over a 2.04 km by 2.04 km evaluation grid. The grid is
partitioned into square cells with sides measuring 24.87 m and cells numbering 82 east-west by 82
north-south with cells identified as 1-82 in both directions. The modelling software reports the average
solids and carbon within each cell as grams per square meter at the moment it is queried, typically at
the end of the simulation period.
This model execution did 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 from the net pen
operation. Each simulation assumed maximum standing biomass each day of the simulation with fecal
settling and food settling velocities applicable to salmon production at 3.5 and 9.5 cm/s, respectively.
The values for fecal settling velocity may have implications for dispersion. For this study, a
conservative settling velocity (3.5 cm/s) was used to assess the maximum extent of fecal deposition on
benthic surfaces. Knowledge of the physical properties of fish feces under net pen conditions is
rudimentary. Most reported literature addresses the fecal stability, density, and settling velocity (3.5
cm/s) of farmed salmon (Reed et al. 2009). Data on fecal settling velocity for Ambeijack (Seriola spp.)
are scarce. Amberjack feces are shapeless and unstable in the water column (e.g., lacking
cohesiveness). The species has a reported fecal settling velocity of about 1.6 cm/s owing to its smaller
size and density (Fernandes and Tanner 2008).
The model was run for 1,825 days assuming a net pen with a constant daily standing biomass at
36,288 kg (22.85 kg/m3) and a daily feed rate of 1.1 percent of biomass or equivalent to 399 kg of
feed. Standard feed waste was estimated at 3%. The model simulates release of fecal and feed particles
from a net pen at hourly increments. Multiple particles are released representing different mass
percentages and different settling velocities defined in the set-up files. The particles are all tracked
throughout the domain at each time step over the duration of the simulation. Particles that are
transported out of the domain boundary at 1,020 m away at the closest, are lost and removed from the
calculations. Only masses of material that remain in the domain at the moment a surface is queried and
2
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recorded are reported. At high current velocity sites, such as this project location where the average
flow is 13 cm/s and peaking at 67 cm/s at 4 meters above the seabed (Figure 1), the bulk of settleable
solids from the aquaculture operation are dispersed outside of the simulation domain. It is expected
that these solids would continue to be oxygenated and transported along benthic surfaces downstream
where currents allow for deposition and resuspension. This particulate organic carbon would be
readily available and consumed by bacteria and benthic infauna.
SOFTWARE UPDATES
NewDEPOMOD (version 1.3, released July 2020) and previous versions of DEPOMOD are computer
models that have been developed by the Scottish Association of Marine Science to inform siting,
permitting, and regulation of marine fish farms. The model predicts the impact of farm deposition on
the seabed in order to optimize the operation of aquaculture sites to match the environmental capacity.
The Scottish Environmental Protection Agency has used the software for over a decade in direct
support of their aquaculture permitting standards.
NewDEPOMOD incorporates a range of features in its newest release including:
• improved predictive abilities for offshore aquaculture projects including the capacity to use
three-dimensional hydrodynamic flow field data;
• an updated and characterized resuspension process using data from an extensive set of field
measurements of erosion, resuspension and transport at farm sites;
• a new model framework for sediment deposition which allows the model to include varying
bathymetry; and
• a model that produces conservative estimates of the holding capacity of a proposed site that can
be tuned using data collected once a farm enters production to improve predictions, also useful
for planning expansion of an existing farm.
ESTIMATING DEPOSITION AND MASS FLOW TO THE BENTHOS
Mass flows of solids onto the seabed were estimated from the mass of cultured fish on the farm and
the specific rate, which they are fed (Table 1). We developed a model for a 1,296-m3 net pen1 with a
stocking density of 28 kg/m3, which will yield a biomass of 36,288 kg. An estimated 399.17 kg of feed
will be applied per day at a feeding rate of 1.1 percent of body weight. During permitting, the
applicants changed the net pen design to a larger volume, however the biomass within remained the
same at 36,288 kg which is the keystone value for the waste dispersion simulation.
1 After completion of modelling, it was noted by the EPA that minor changes occurred with submission of the Ocean
Era permit application. The net pen configuration changed as did the size of fish at harvest. The discrepancy in net
pen volume (1,296 m3 vs 1,588 m3] and fish size (1.8 kg vs. 2.0 kg), and the implications on model results are
negligible.
3
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With a feed moisture content of 9% and an estimated 3% food waste rate, the feed dry mass lost from
the net pen is: [ 399.17 kg feed * (100%-9% kg dry feed / kg feed) * 3% kg dry feed lost/kg dry feed]
= 10.89 kg dry feed lost to the environment each day, or 0.454 kg per hour.
Since the feed is measured as 49% carbon, the flux is: 10.89 kg dry feed wastage * 0.49 kg carbon/ kg
dry feed = 5.34 kg carbon per day from feed.
Similarly, for the fecal mass produced with the assumed 9% feed moisture and 85% utilization:
[(399.17 kg feed - 3% lost (11.97 kg)) * 15% fecal mass/mass of solid feed ingested * 91% kg solid
feed / kg feed] = 52.85 kg of fecal solids per day, or 2.2022 kg per hour.
Fecal matter is measured as 30% carbon and yields: 52.85 kg of fecal solids * 0.30 kg carbon / kg of
fecal solids = 15.85 kg carbon per day
Combining the flux masses for solids and carbon an estimated 63.74 kg of solids and 21.19 kg of
carbon are released into the environment each day from the demonstration project.
Table 1. Summary statistics for the Velella Epsilon Offshore Aquaculture Demonstration Project.
Farming parameter Value
Initial Total number 20,000 fish
Individual size at harvest 1.8 kg
Maximum biomass during growout 36,288 kg
Net pen density at harvest 22.85 kg/m3
Maximum daily feed rate 399 kg
Total feed used 66,449 kg
Feed conversion ratio 1.8
Table 2 reports the mass flows of solids and carbon from the Velella Epsilon Offshore Aquaculture
Demonstration Project within the simulation domain. The bulk of released solids and their carbon are
lost from the domain, carried into the far-field by currents. Comparing values of solids in Table 2, the
simulation predicts that 3.63% of the solids remain within the simulation domain after five years.
There are periods in the water flow cycles when solids accumulation is variable in the domain, as
illustrated in Figure 2. The masses on the final day approximate the average concentrations.
4
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Table 2. Mass flows of solids and carbon from the Velella Epsilon Offshore Aquaculture
Demonstration Project within the simulation domain at the end of 5 years.
Model Parameters and Simulation Results Value
Mass of feed applied (5 years) 728,481.60 kg
Mass of feed wastage (5 years ) 19,887.57 kg
Mass of feed wastage carbon (5 years) 9,744.89 kg
Mass of fecal materials (5 years) 96,454.61 kg
Mass of fecal carbon (5 years) 28,936.38 kg
Total mass dry solids released / day 63.75 kg
Total mass dry solids released / year 23,268.43 kg
Total mass dry solids released / 5 years 116,342.17 kg
Total mass carbon released / day 21.20 kg
Total mass carbon released / year 7,736.25 kg
Total mass carbon released / 5 years 38,681.27 kg
Solids balance (Total solids within domain after 5 years) 4,224.87 kg
% solids retained inside domain 3.63 %
% solids exported outside domain 96.37 %
Carbon balance (Total carbon within domain after 5 years) 1,406.13 kg
% carbon retained inside domain 3.64 %
% carbon exported outside domain 96.36 %
At the project location, water velocities are typical for currents along the West Florida Shelf. Figure 1
illustrates the water velocity at the Velella site at a depth of 36.7 meters or approximately 4.0 meters
above the seafloor. Currents at this project location will likely re-suspend feed wastes and fecal
materials transporting these solids across the seafloor. The simulation software calculates the
movement of the released solids using the particle characteristics, the nature of the seafloor, and the
velocity of the water body in the proximity of the seafloor.
5
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80
70
60
S 50
'V
J 40
o>
9-
a
20
10
0
0 20 40 60 80 100 120 140 160 ISO 200 220 240 260 2 SO 300 320 340 360
Time (d)
Figure 1. Water currents and flow velocity measured at 4 m above the seafloor.
Figure 2 illustrates the fate of the remaining solids within the domain over the five-year simulation,
calculated from the total mass of released solids, minus the total mass of solids that are exported out of
the simulation domain. The figure shows that over the five-year simulation solids on the seafloor
within the domain reach an equilibrium, at an average total mass of 4,013 kg. The leading edge of the
plot illustrates the point material accumulates on the seabed where it will eventually resuspend leading
to more material being transported away from the depositional site as currents reach the shear force
threshold. During the first days of operation little material was available for resuspension, all the
while, new material was being added at a constant 63.75 kg per day.
NewDEPOMOD reports distribution of solids as surface plots of either solids or carbon, it does not
distinguish between the sources of the carbon, either feed or fecal, and are combined. In Figure 3, the
distribution of carbon is plotted for the final hour of the five-year simulation. Within the software,
each surface plot generates its own scale to coincide with the colors on the map. The reader should use
caution when comparing plots.
6
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0 200 400 600 800 1000 1200 1400 1600 1800 2000
Time (d)
Figure 2. Predicted solids deposition beneath one net pen with a standing stock biomass of 36,288 kg
of Almaco Jack (Seriola rivoliana) after five-year farm simulation.
Figure 3 shows the carbon distribution over the 2,040 x 2,040 meter Velella simulation domain on day
number 1,830. The highest concentration of aquaculture sourced carbon on the site is 4.35 g/m2 Most
noticeable in this deposition prediction map is the wide distribution of carbon over 4 km2 with small
accumulations and no areas of excessive concentrations. 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 3.
This wide dispersion and low concentration of carbon created the average Infaunal Trophic Index (ITI)
score for this final overall benthic surface of 58.96 out of 60. As previously reported, a predicted ITI
of close to 60 suggests that the Velella project will not likely have a discernable impact on benthic
communities around the project location. Similar to other studies reporting ITI as a measure of benthic
impacts from net pen operations, we do not expect significant impact on sediment redox potential or
sulfide production. For example, Hargrave (2010) and Keeley et al. (2013) extensively documented
correlations among the carbon deposition rate, redox potential, hydrogen sulfide concentration,
interstitial dissolved oxygen, and ITI. We believe that the Velella project will present challenges for
monitoring and detecting environmental impacts on sediment chemistry or benthic communities
because of the circulation around the project location and the small mass flows of materials from the
net pen installation. As the simulation illustrates, the high energy environment at the site and the mass
7
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flow of materials equilibrates at a resident total mass of waste products at approximately 4,000 kg with
local masses never exceeding more than 43.4 g solids per square meter for a single sample point over
the 5 year simulation.
CONCLUSION
There are minimal to no risks to sediment chemistry or benthic ecology functions in the project area
from the operation of the net pen as described in the Ocean Era, LLC application for an NPDES
permit.
60
a
13
ti
o
£
80
70
60
50
40
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20
10
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in uiaijiusiiiaiaiiHU
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Organic
3 Carbon
(g m- yr1)
Easting
Figure 3. Predicted benthic carbon deposition field beneath one net pen with a standing stock biomass
of 36,288 kg of Almaco Jack (Seriola rivofiana) after five years. Grey circle indicates center position
of the net pen. Axes indicate simulation cell numbers and carbon deposition mass is in grams.
8
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Table 3. 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 36,288 kg.
Carbon deposition
(g/m2/yr)
Occurrence
(N)
Frequency
(%)
0
1,508
22.43
0.1-1.0
4,526
67.32
1.1-2.0
559
0.08
2.1-3.0
111
1.65
3.1-4.0
16
<0.01
4.1-5.0
4
<0.01
REFERENCES
Fernandes, M. and J. Tanner. 2008. Modelling of nitrogen loads from the farming of yellowtail
kingfish Seriola lalandi (Valenciennes, 1833). Aquae. Res. 39: 1328-1338.
Hargrave, B.T. 2010. Empirical relationships describing benthic impacts of salmon aquaculture.
Aquae. Env. Inter. 1(1): 33-46.
Keeley, N. B., C. J. Cromey, E. O. Goodwin, M. T. Gibbs, and C. M. Macleod. 2013. Predictive
depositional modelling (DEPOMOD) of the interactive effect of current flow and resuspension on
ecological impacts beneath salmon farms. Aquae. Env. Inter. 3(3): 275-291.
Reid, G. K., M. Liutkus, S. M. C. Robinson, T. R. Chopin, and others. 2009. A review of the
biophysical properties of salmonid faeces:implications for aquaculture waste dispersal models and
integrated multi-trophic aquaculture. Aquae. Res. 40: 257-273
9
-------
Appendix: Time-series simulation of predicted benthic carbon deposition beneath one net pen
with a standing stock biomass of 36,288 kg of Almaco Jack (Seriola rivoliana). The reader should
use caution comparing plots. The software generates a new legend for each plot in the time
series. The scale and color ramp varies with each surface plot.
g cart)on/m2
g cart»n/m2
Day 450
10
-------
Appendix: Time-series simulation of predicted benthic carbon deposition beneath one net pen
with a standing stock biomass of 36,288 kg of Almaco Jack (Seriola rivoliana). The reader should
use caution comparing plots. The software generates a new legend for each plot in the time
series. The scale and color ramp varies with each surface plot.
Day 540
|
\
m
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X \ \ V
r
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Day 810
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-4J -Si -21 -10 0
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ii
-------
Appendix: Time-series simulation of predicted benthic carbon deposition beneath one net pen
with a standing stock biomass of 36,288 kg of Almaco Jack (Seriola rivoliana). The reader should
use caution comparing plots. The software generates a new legend for each plot in the time
series. The scale and color ramp varies with each surface plot.
g cartx>n/m2
g carborVm2
Day 1260
%
yj
!¦
g carbon/m2
g carbon/m2
12
-------
Appendix: Time-series simulation of predicted benthic carbon deposition beneath one net pen
with a standing stock biomass of 36,288 kg of Almaco Jack (Seriola rivoliana). The reader should
use caution comparing plots. The software generates a new legend for each plot in the time
series. The scale and color ramp varies with each surface plot.
Day~1440
SffaftB I
3 ¦ 4
¥ *
g cartx>n/m2
-t} -SI -21
Depth (m)
Day 1530
^ m
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m
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g carbon/m2
4i -ji -n -i«
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g caroon/m2
42 -31 -21 -10 0
Depth (m)
Day 1710
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r-. • > •
1 k ¦ Jr m J|
1 * * 1 L * .
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I A J 8
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llll
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>1 -21 -10 0
Depth (m)
13
-------
Appendix D
-------
%
4PV .. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
E REGION 4
Wi/y / ATLANTA FEDERAL CENTER
J R1 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
A'Jo 1 3 2019
Ms. Roxanna Hinzman
licit! Superv isor
I'.S. Fish and Wildlife Service
South Florida ideological Ser\ ices Field Office
1JW2U1" Street
Vero Beach. I lorida 32960-3559
SUBJECT: Informal Endangered Species Act Section 7 Consultation Request
Kampachi Farms, LLC - Velella Epsifon Marine Aquaculture Facility
Dear Ms. Hinzman:
1 he I'.S. Environmental Protection Agencv Region 4 and ihe I LS. Arim Corps of Engineers Jacksonville
District {FSACE} are obligated under Section 7(a)(2) of the Endangered Species Act (FSA) to ensure that
any action it approv es is not likeh to jeopardize the continued existence of any threatened or endangered
species oi result in the destruction or adverse modification of critical habitat. The purpose of this Setter is
to request the initiation of informal consultation with the U.S. fish mid Wildlife Service (USIAYS) under
fSA ). the ESA implementing regulations at 50 CFR $402.1 and the Memorandum of Agreement
Between the EPA. National Marine Fisheries Service (NMFS). and the FSI WS reeardin» enhanced
coordination (FSA MO,A).1
On November 9, 2018. the EPA received a complete application for a National Pollutant Discharge
Elimination System (N'PDES) permit I mm kampachi Farms for the discharge of pollutants from a marine
aquaciiltuie facility in federal waters oi the Gulf. On November 10. 201 K. the USACE received a
Depai iment ol Army application pursuant to Section 10 of the Rivers ami Harbors Act for structures and
work altcctmg navigable federal waters from the same marine aquaculture lacilitv. On behalf of the two
I cdeial Agencies responsible for permitting aquaculture operations in federal waters of the Gulf, the EPA
is lequesting initiation of the FSA §7 informal consultation process for the two federal permits needed to
operate the proposed marine aquaculture facility. I he EPA is also initiating consultation pursuant to the
fish and Wildlife Coordination Act. On August 12. 20R 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 agencv. the EPA
has elected to act as the lead agency to fulfill the consultation responsibilities pursuant to the implementing
1 In accordance with the Memorandum of Agreement Between the Environmental Protection Agency, / »/, unit If, Mine Sendee and National
Mm Hit I isket i«4 Sa vice Regarding hnhaticed Coordination Under the (lean I1 uter. let and Endangen d Spa m ,4ci (2(H) 11.
, internet Address (URL) • http://www.epa.gov
** "" 'i,Uhf,"rn'1 •• «' ' u*^ ,1 , fii'i I P.-inm, im 30% Postconsumer)
-------
regulations of ESA §7.2 This consultation request shall also serve as the written notice to the I. SI-W S thai
the EPA is aetinu as the lead agency as required by 50 CFR §402.07. The f'SACE is a cooperating and
co-federal agency for this informal consultation request. The completion of this informal consultation
shall satisfy the HPA's and USACE's obligations under ESA §7.
1 he attached supporting Biological I: valuation (BE) was prepared by the EPA and the USACH to jointly
consider the potential effects that the proposed actions may have on listed and proposed species, and
desimutted and proposed critical habitat. Based on the inlormation within the BP. the EPA and ESAC E
have determined that the proposed actions will ha\e "no ellect on any listed or proposed species as well
as designated and proposed critical habitat species under the jurisdiction ol the USI-WS. As outlined in
the PSA MOA. the IZPA requests that the 1 ^SPWS respond in writing within 30 days of receiving the "no
effect" determination documented within the BE. 1 he response should state whether the L Sf \\ S concurs
oi does not concur with the determination made by the EPA and I iSACE. 11 the i iSl-WS does not concur,
it will provide a written explanation that includes the species and/or critical habitat o( concern, the
perceived adverse effects, and supporting information.
'1 he IP A and 1 'SACK are coordinating the interagency review process in accordance with the interagency
Memorandum of Under standing for Permitting Offshore Aifuaeuiture Activities in Federal 11 utei s of the
(iulfand conducting a comprehensive analvsis ol all applicable en\ iionmental requirements as allowed
h\ the National Environmental Policy Act (NPPA); however, a consolidated cooperation process under
NPPA is not being used to satisfy the requirements of l-SA §7 as described in 50 C1R §402.06.' I he
NMES is a cooperating auencv lor the NPPA anaEsis and has prov ided scientiiic expertise related to the
BP and NEPA analvsis for the proposed facility including information about: site selection. PSA-listed
species, marine mammal protection, and essential fish habitat. While some information related to the ESA
anaEsis is within the coordinated NF.PA ev aluation 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.
- 50 CFR § 402.07 allows a lead agents: "When a particular action involves more thun one Federal agency, the consultation and conlerence
responsibilities may be fulfilled through a lead agency. Factors reie\ ant in determining an appropriate lead agency include the time sequence
in which the agencies would become involved, the magnitude oflhdr 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 bv the lead agency."
On February 6. 2017, the Memorandum of I 'miershimiiiig for Permitting Offshore Aiiuacultmv Activities in Fetkral Waters of the dtiij ol
,1 tc.xica became effecthe for seven federal agencies with permitting or authorization responsibilities. I he federal agencies included in the
MrtU were: FPA (Region 4 and 6), I ISACE (Gakeston. lacksonville. Mobile, and New Orleans Districts). KMFS (Southeast Region I.
IJSFWS (Southwest and Southeast Regions). BOtiM (Gulf of Mexico Region). BSEF (Gulf of Mexico Region), aid the OSCG.
•i 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 fNFPA) (42 USC 4321 et
\cq,, implemented at 40 CFR Parts 1500- 1508) or the Fish and Wildlife Coordination Act (FWC'\),"
-------
5 01' LfiTherinfT,ati°" d"r'"8 th'S consultation Peri°d or any questions, please contact
at (404) 56 " %72 em 3t wahls,rom-ramle™eghan®epa.gov or by phone
Ms. Met
Sincere!
\ .
Chris I homas. Chief
Perm it liny and Grunts Branch
Water .Divison
Ms. Katy Oamieu. I'SACH (via email)
Dr, Jess Heck-Stimpert. NMFS (via email)
Mr. Jeffre> 1 lovvc, US1' VV S (vi& cnictil)
3
-------
DRAFT
BIOLOGICAL EVALUATION
Kampachi Farms, LLC - Velella Epsilon
Marine Aquaculture Facility
Outer Continental Shelf
Federal Waters of the Gulf of Mexico
August 5, 2019
nS
S 7^
$
s
J3
\
SB
^ PRCf^°
I)
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LU
(D
T
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
Biological Evaluation
Kampachi Farms - Velella Epsilon
Page 2 of 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)."
Biological Evaluation
Kampachi Farms - Velella Epsilon
Page 3 of 33
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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.
Biological Evaluation
Kampachi Farms - Velella Epsilon
Page 4 of 33
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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
Biological Evaluation
Kampachi Farms - Velella Epsilon
Page 5 of 33
-------
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).
Biological Evaluation Page 6 of 33
Kampachi Farms - Velella Epsilon
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4.0
Proposed Action Ami
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/
Biological Evaluation
Kampachi Farms - Velella Epsilon
Page 7 of 33
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5.0 Federally Listed ;iihI Proposed Threatened ;ind Fndangered 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
SI 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 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 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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Kofi* roil cos
Adams, W., and Wilson, C. 1995. The status of smalltooth sawfish. Pristis pectinata Latham 1794 (Pristiformes:
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Appendix A - Cii«e ;iihI Mooring Detail
1) Deadweight Anchors Lconcreteii
* Three 3; arch? s e*^.u2S y SD3;ec i5
: 110 h froT mconnj certer ire
:> IK degrees frorr e.ct other
* Each '£¦< 4 5*n » 4 5t x 4 5-tr SI mSl
* Goncete f icticr 'a:tcr = 0 5 cr wet
* Each has an effective ws-ght cf Z."" ^ J
2) IVJooi'r 2 Chain fGrade2 steel?:
* SCt lergrh cr each arcncr
* EOtsti (Z",itnic^ I
* No load = 70^ lergthcfeachcr :eaf oo<
» D-55'gn load = lome ert^-s *> o*f i^a^ecv
otner: temp ete v or seaf a x
3} Mooting Lmesffope^
* 4Ct Lrtgth or each cba-n
* AM5TEElj-ELUE
» 5.6mm ft 1/1 ; tmes
4) Spar Buoy w/ Swivel (steel):
5) Bridle L nes irope irside HD^E
* ThTe° (2; -30m bMSe fmts iropei *rom swivel to
rpraaJei Lar
mMSTE£l:-BL.UE
* ?3 3r*iT fl 5--5"! ire: iintJ: HDFE pipe
5} Spieatfen Bar fHDPEj:
» Heac-er 5a 'load seanrgi ccmerted to Bridle Lines
; ?0'T> rr f-ergth
: 0 55m 00 D3 __ WDFE pipe
* Side and F>zd,r Ears UTaiitr obo bearing!
: ?0in ir length
: 0 CD 17 HDFE pipe
* Fgu' '4f coner rpar b^vvs
7) Net Pen Connection! Lines trope):
Four |4i ~13m connection lines trope)
» Conceited 'rom Spreader Bar "o Net Per Flc-at Rings
AVSTEE.--5LUE
¦ •> Jnn il 5/15' i I'reL
8} fJetFen Frame Structure IHDPEj
• Tog Fr;ne Stiurtjre
: IZr h* c arrets!
: One ill HDPE Jide-t>v-nce -irat^irgs
¦ On theses £jr*ace
* -|J ;6t CDZF ntiDPEcias
~ One (!) H JPE rc: ring (rairrgl
* Cornecfeft ~ 1.0,r. above F.o-at Firg8;
* Ccrnecteo to vic- °e ? Mesh
~ 0.15m OD CP 1" HDFE.ire
• Sottoir crarr,e Stnittw-f:
: ISt tr-carnetei
: One (1| HQPEsmlrre d^ari~ter
: 'Otpi \ JJnir Tiejb square
• E't-.ct ve vokirre of _,5?'0m'*
10} Shackle Point Connection (steetj;
• One (1) ~0.13m* shackle plate
• Four |4) connect «?n lines
o i2 mm m diameter ^ 1'It. ir lerfh
~ Icnnea^d tern; tack e pate to HDFE sinker ring
« "lm Grade i. -*ee' ctein /32Timt connecter *o Ficatatlon
Capsaie
11} Ftoatatbn CapuIt: {-.teeJjt:
» "1 5n> in JiaT-stef < -3 45-n rr lergrh
• Effective fioatrtni ^o'ume = 6tt3
• "3m j?c je 2 nee thsir (32Tm) connected ?a Countef Weight
121 Cowntei Weifhtjconriete):
« - I lm in diaTetc > ~2.2m in length
• Efteove weight of? ^ J
Biological Evaluation
Kampachi Farms - Velella Epsilon
Page 32 of 33
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Appendix B - Location Area
VE Project - Modified Site B & Pen Placement
Flerida
0 2.500
vaxtvi/
r
I ^gfiul:
As*ttuii TidcLbie:
3* W W
l: at o a solicited
Sediments
Nr»t».-s:
1 Coorrinnnfce* line in fed
fcasoii ail thti Floririi State
Plane Ononftinflte System,
West Zccie. N<"irlh Amenaln
rMn*ri L.f 1983 {NAD 83)
2 Eftit.ii cc'lleclc-ri by APTIM
Oft 14.201S ftnd
Annual 15, 2098.
i >"orionnl \"«tPf u Plswwif nn
125-iim Dij sne 1 e r Fug ic riii 1)
Thkkm^m
Hi
# NcareslMagae-iicADOcaaLks
Map 3 UncratfoBforect Sodiment
Tbickneas Uopncli
Kjiiupucftii 1'unus
\ vlflh tpvilnii
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
AUG 1 2 2019
CERTIFIED MAIL 7018 2290 0000 9993 5415
RETURN RECEIPT REQUESTED
Mr. David Bernhart
Assistant Regional Administrator
National Oceanic and Atmospheric Administration
National Marine Fisheries Service
Southeast Regional Office
Protected Resources Division
263 13 th Avenue South
St. Petersburg. Florida 33701-5505
SUBJECT: Informal Endangered Species Act Section 7 Consultation Request
Kampachi Farms. LLC - Velella Epsilon Marine Aquaculture Facility-
Dear Mr. Bernhart:
The U.S. Environmental Protection Agency Region 4 (EPA) and the U.S. Army Corps of Engineers
Jacksonville District (USACE) 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 National Marine Fisheries Service
(NMFS) under ESA § 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
(USFWS) regarding enhanced coordination (ESA MOA).1
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 Velella
Epsilon Marine Aquaculture Facility in federal waters of the Gulf. On November 10, 2018. the USACE
received a Department of Army application pursuant to Section 10 of the Rivers and Harbors Act tor
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 ot
the Gulf, the EPA is requesting initiation of the ESA § 7 informal consultation process for the two lederal
permits needed to operate the proposed marine aquaculture facility. The EPA is also initiating consultation
pursuant to the Fish and Wildlife Coordination Act.
1 In accordance with the Memorandum of Agreement Between the Environmental Protection Agency, Fish and Wildlife Service and National
Marine Fisheries Service Regarding Enhanced Coordination Under the Clean Water Act and Endangered Species Act (2(H)!).
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)
-------
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 § 7,2 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 (T'R 402.07. The ESACE is a cooperating and
co-federal agency for this informal consultation request. The completion of this informal consultation
shall satisfy the EPA's and USACE's obligations under I'SA § 7.
The attached supporting Biological Evaluation (BE) was prepared by the EPA and the 1JSACE 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 the information within the BE. the EPA and ESACE
have determined that the proposed actions are not likely to ad\ersely affect am listed or proposed species
as well as designated and proposed critical habitat species under the jurisdiction of the NMES. As outlined
in the ESA MOA. the EPA requests that the NMFS respond in writing within 30 days of receiving the not
likeh to ad\ersely affect determination documented within the B1 . 1 he response should state whether the
NMFS concurs or docs not concur with the determination made b> the EPA and ESACE. If the NMES
doe;- 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 EPA and ESACE are coordinating the interagency re\ie\\ process in accordance with the interagency
Memorandum of Understanding for Permitting Offshore Aquaculture Activities in ledcral Hater* of the
(iuljS and conducting a comprehensive analysis of all applicable environmental 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 J: 7 as described in 50 CER ^ 402.06.J fhe
NMES is a cooperating agency for the NEPA analysis and has pro\ ided scientilic expertise related to the
BE and NEPA analysis for the Velella Epsiion facility including information about: site selection. I-.SA-
lisied species, marine mammal protection, and essential fish habitat. While some information related to
the ESA 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.
1 50 CFR § 402.(17 allows a lead agency: "When a particular action involve* mure than one federal agency, the consultation and conference
responsibilities may be fulfilled through a lead agency. Factors relevant in determining art appropriate lead agency include the time sequence
in which the agencies would become involved, the magnitude of their respeethe involvement, and their relative e\perii*.e with respect to the
environmental effects of (he action. The Director shall he noli lied of the designation in writing by the lead agency."
' On February 6. 2(117, the Memorandum of Understanding tbr Permitting Offshore Aquaeulture 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 ma\ be consolidated with
interagency cooperation procedures required by other statutes, such as the National [environmental Policy Act (NITAi (42 t'SC 4.121 el
sci/.. implemented at 40 CFR Farts 1500- 1508) or the Fish and Wildlife Coordination Act fFWCAj,"
-------
If you require any further information during this consultation period or have any questions, please contact
Ms, Meghan Wahlslrom-Ramler via email at wahlstrom-ramler,m.eghan!'5lepa gov or by phone at
(404) 562-%72.
Christopher B. Thomas. Chief
Permitting and (iranls Branch
cc: Ms. Kat\ Damico. I 'SACf. i\ia email)
Dr. .less Beck-Slimpert. NMFS {\ia email)
Ms. Jennifer i.ee. NM1 S (\ia email)
Mr. Jeffrey Howe, USFWS (\ia email)
-------
-------
DRAFT
BIOLOGICAL EVALUATION
Kampachi Farms, LLC - Velella Epsilon
Marine Aquaculture Facility
Outer Continental Shelf
Federal Waters of the Gulf of Mexico
August 5, 2019
US Army Corps
of Engineers®
U.S. Environmental Protection Agency
Region 4
Water Protection Division
61 Forsytli Street SW
Atlanta Georgia 30303
NPDES Permit Number
FL0A00001
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 snd F*ed.eral (Joordmstion 3
2*0 PropQscd Action 4
3.0 Proposcdl Proj cc t 5
4*0 1^roposcd Action rc^ 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 Speeies and Proposed Critical Habitat.................. 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 1.5
6.4 Water Quality.......................... 1.6
7*0 Potential Effects of Action2 9
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 I isted Critical Habitat............... .....23
7.3 Federal Proposed Species and Proposed Critical Habitat..... .24
8.0 Co nc! us ion 26
References 27
Appendix A Cage and IVloonn^i Detail 32
Appendix B - Location Area 33
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1J Introduction and Federal Coordination
In accordance with the Endangered Species Act (ESA) Section 1. interagency consultation and coordination,
with the National Marine Fisheries Serv ice (NMFS) and the I '.S. Fish and Wildlife Serv ice (1,'SFWS) 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 arc likely
to jeopardize the continued existence of any species that is proposed for listing or result in ihe 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 (NFDES) permit from Kampachi Farms for
the point-source discharge of pollutants from a marine aquaculture facility in federal waters of the Gulf of
Mexico (Gull)- On November 10. 2018. die 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-fcderal agency for this informal consultation
request. The completion of the informal consultation shall satisfy the FPA's and USACE'.s obligations under
ESA Section 7(a)(2).
1 he 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 for consideration by the USFWS and the NM1-S 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 (MOU) for Permitting Offshore Aquaculture Activities in Federal Waters of
the Gulf, 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 ihe Clean Water Act related to the FSA require Ihe EPA to ensure, in consultation with the NMFS and
t'SFWS, that "any action authorized ihe EPA is not likely to jeopardise the continued existence of any endangered or threatened species or
advust.K a fleet its critical habitat" (40 CFR $ 122.49(e)).
• 5lt I i R § 402.07 allows a lead agency: "When a particular action invokes mure 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 vviih respect to the
em ironnienta! effects of the action. *] he Director shall he notified of the designation in writing bv the lead agency."
•' On Febniary <1, 2017, the Memorandum of Understanding for Permitting Offshore Aquaculture Activities in Federal Waters of the Gulf of
Mexico became effective foi seven federal agencies with permitting or authorization responsibilities.
511 CFR JS 402.0(i 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 CNF PAH implemented at 40 CFR
Parts 15011 - I SOS) or the Fish and Wildlife Coordination Act (l-WCA)."
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2 J' 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 USAGE as required to operate the facility. The HPA'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 L'SACH'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 ihc applicant to operate a pilot-scale marine aquaeulture facility with up to
21),000 almaeo jack (Serioia rivoliuna) 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 fingcrlings will be soureed from brood stock that arc located at Mote Aquaeulture
Research Park and were caught in the Gulf near Madeira Beach, Florida. As such, only Fl 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 limes when resupplying is necessary. 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
vessel will also cany a generator thai is expected to operate approximately 12 hours per day. Following har\cst.
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, fhe 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 N'MFS. 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 aquaeulture operations
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and protected species. The PS VIP also contains important mitigativc efforts such as suspending vessel transit
activities when a protected species comes within 100 meters protected under
the MM PA or ESA thai may be encountered at the proposed project,
'' The applicant it. not expected to use any drugs; however, in the unlikely circumstance that thcrapcutam treatment is needed, three drags
were provided to the LPA as potential candidates (hydrogen peroxide, oxytetraeychnc dth.vdrate, and ilortemcoi»,
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4.0 Proposed Action Area
The proposed project would be placed in the Gulf at an approximate water depth ot 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 It deep (see Table 1), The applicant will select the specific
location within that area based on diver-assisted assessment ofthe sea floor when the cage and anchoring sy.-tcm
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
o\er several months to identify an appropriate project site. Some ofthe criteria considered during the site
screening process included avoidance of corals, coral reels, submerged aquatic vegetation, hard bottom habitats,
and avoidance of marine protected areas, marine reserves, and habitats of particular concern. I his siting
assessment was conducted using the Gulf AquaMapper tool developed by NCCOS.'
Upon completion of the site screening process with the NCCOS. the applicant conducted a Baseline
Ln\ ironmentai Survey iBHS) in August 201X based on guidance developed by the NMKS and hPA.s 1 he RhS
included a geophysical investigation to characterize the sub-surface and surface geology ofthe sites and identity
areas with a sufficient thickness of unconsolidated sediment near the surface while also clearing the area oi any
geoha/ards and structures that would impede the implementation ofthe 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 Bl'S 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 19* of Unconsolidated Sediments
I iicaiioi!
Upper Left Comer
Upper Right Comer
Lower Right Comer
Lower Left Corner
Latitude
IT 7.61022' N
27: 6.77773" N
27D 6.87631* N
Luiigiuide
; i 1 1 •'! s V\
83° 11,65678' W
83° 11.75379' W
83° 12.42032* W
1 The Gult AqmMapper lool is available at: hitps:• 'coastalscicnccjuua.jiov products-explorer
* The BES guidance document is available af htlp:'/stro.nmfs.iwaa.iiovsiHtjiiiabie_fIsheneslGuif ilshcrics/aquaculture/
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5 J Federally Listed and Proposed Threatened and Endangered Species and Critical Habitat
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 summitry, the action agencies
considered the potential affects to threatened and endangered species from five groups of species: birds (2), fish
{4k 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 tSiat 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 H:ihitat Considered for the Proposed Action
Species ( onsiiliTed
l!S.\ Stains
< "rilical
I lubitat
Birds
I'otL'iiti.il ['AiMictiri- (o
I'ropnsi'd \etion Ai'cii
1 Piping Clover
Threatened
Yes
No
2 Red Knot
Threatened
No
No
Fish
1 Giant Manta Ray
Threatened
No
Yes
2 Nassau Grouper
Threatened
No
Yes
3 Oceanic Whitetip Shark
Threatened
No
Yes
4 Small tooth Sawfish
Endangered
No
Yes
Invertebrates
1 Boulder Star Coral
Threatened
No
No
2 Elkhoro 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 Lobcd Star Coral
Threatened
No
Yes
Marine Mammals
1 Blue Whale
Endangered
No
Yes
2 Bryde's Whale
Endangered
No
\CN
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 Tutile
Threatened
No
Yes
2 Mawksbill Sea Turtle
Endangered
Yes
Ws
3 Kemp's Ridley Sea Turtle
Endangered
No
Yes
4 Lcatherback Sea Turtle
Endangered
Yes
\ c;»
5 Loggerhead Sea Turtle
Threatened
Yes
Yes
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5.1.1 Birds
There are 14 HS A-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
arc not exposed to the activities covered under the proposed action.
Piping Plover
The piping plover is a threatened shorcbird that inhabits coastal sandy beaches and mudflats. Three populations
of piping plover are recognized under liSA: 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, leasing in late
February to migrate back to their breeding sites (iiOFM. 2012b). They do not breed in the Gulf. Habitat used
by wintering birds include beaches, mud flats, sand flats, algal Hats, 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 shorcbird with no open ocean habitat.
Red Knot
The red knot, listed as threatened in 2014, is a highly migratory shorcbird 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 batiks for
bivalves, gastropods, and crustaceans (USFWS, 2015). Horseshoe crab eggs ere 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.
Winiering red knots may be found m Florida anil lexas (Wiirsig. 201 7). The\ 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 wa> listed as threatened under (he F.SA on Febraars 21. 20IK. The giant mania ray i> 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 wmgspan 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 (Fvgeny. 2010). which are extensions of the pectoral fins that funnel water into
the mouth. Giant manta rays feed primarily on planktonic organisms such as cuphausiids. 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 arc seasonal visitors along productive coastlines with regular
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upwclling, 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 upwclling,
scawater temperature, and possibly mating behavior. Although giant manta rays are considered oceanic and
solitary, they have been observed congregating at cleaning sites at onshore reefs and feeding in shallow waters
during the day at depths less than 10 in (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 lish 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 survevs
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 Whitelip Shark
The oceanic whitelip 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 whitelip 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
3? 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; Bon 111 et al., 2008); however, some studies have found that they consume
sea birds, marine mammals, other sharks and rays, mollusks, crustaceans, and even garbage (Coinpagno, 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 (Bigclow 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 lady fish arc believed to be their
primary food resources (Simpfcndorfer, 2001). Smalltooth sawfish also prey on crustaceans (mostly shrimp and
crabs) by disturbing bottom sediment with their saw (Norman and Frascr, 193K; 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) 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-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 lo algal overgrowth and
sedimentation.
Table 3: ESA-listcd Coral Depth Ranges
Cural Spt'i'if.s Mint AimiuJan! Ikpth (fi)
Boulder Star Coral .1 - 82''
hlkhorn Coral 3 - 16 ifl
Lobed SiarCoral 6 - 130
Mountainous Star Coral 3-30 11
Pillar Coral 3-90
Rough Cactus Coral 15 - 270 10
torn Coral IS 60 10
5.1.4 Marine Mammals
All the HSA-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 arc found in all oceans except the Arctic Ocean. Currently, there arc 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 twu strandings on the Louisiana and Texas coasts; however, the identifications for both stranding?, are
questionable. In the North Atlantic blue whales arc 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 arc not commonly observed in the waters of the C in! for off the U.S. hast Coast (CVTAP. 19S2; 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 arc 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.
Lor the past 2? 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.DCKANalure.org, 2016
1(1 NMFS, 2016
11 www.lUC'NRedLssuirg, 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 arc 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 arc 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 lo be found near the proposed action area where the water depth
is approximately 40 m.
Humpback W hales
Based on a lew con finned sightings and one stranding event, humpback whales are rare in the northern Gulf
(BOKM, 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 giounds 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 in) 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 sirandings records in Louisiana and Florida (Jefferson and Schiro. 1997, Sehmidiey. 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 hea>ons (NMFS, 2016). Set 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 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 arc the most abundant large cetacean in the Gulf.
Greatest densities of sperm whales arc 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 in due to the habit of feeding on deep-diving squid and fish (Hansen et al., 1996;
Davis ct 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 KSA-listcd sea turtle species that may occur in or near the proposed action area arc; green, hawksbilt.
leatherback, kemp's rid ley, and loggerhead. Sea turtles are highly migratory and travel widely throughout the
Gulf. Th erefore, cacti sea turtle has the potential to occur throughout the entire Gulf. In general, the entire Gulf
eoastal and nearshorc 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 c , 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, 19K7; 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 (em) carapace length, juveniles migrate from pelagic habitats to benthic
foraging areas (Bjomdal 1997). As juveniles move into benthie foraging areas a diet shift towards hcrbivory
occurs. They consume primarily seagrasscs and algae, but are also known to consume jellyfish, salps, and
sponges (Bjomdal, 1980, 1997; Paredes, 1969; Mortimer, 1981, 1982). The diving abilities of all sea turtle
species vary by their life stages. The maximum dhing range of green sea turtles is estimated at 110 in (Frick,
1976). but they arc 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 sea turtle
and listed eight distinct population segments (DPSs) as threatened and three DPSs as endangered, effective Ma\
0, 2016. Two of the green sea turtle DPS.s. 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 last> from the time they leave the nesting beach as hatehlings 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
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 (Mcylan, 1988). Gravid females have
been noted ingesting coralline substrate (Mcylan, 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 o!' dives is estimated at 73,5 minutes, more
routinely dives last about 56 minutes (Hughes, 1974). Hawksbill sea turtles arc not known to regularly nest in
Florida but do occur occasionally.
Kemp's Ridley sea turtle
Kemp's rid Icy sea turtle hatehlings arc 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 at>o been observed transiting long distances betw een foraging habitats (Ogren, 19X0}. Kemp's ridlc\s
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; Bylcs, 1988). Their maximum diving range is unknown, Depending on the life stage, a
Kemp's ridle\ may he able to stay submerged anywhere from 167 minutes to 30!) minutes, though dives of 12.7
minutes to 16.7 minutes are much more common (Soma. 1985; Mcndonca and Pritchard, 1986; Bylcs,
1988). Kemp's rid Icy turtles may also spend as much as 96 percent of their time underwater (Soma, 1985; Byles,
1988). In the United States, Kemp's rid ley 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
1.catherback sea turtles are the most pelagic of all HSA-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. Leathcrbacks feed primarily on cnidarians (medusae, siphonophores) and
tunicates. Unlike other sea turtles, leathcrbacks' diets do not shift during their life cycles. Because leathcrbacks'
ability to capture and eat jellyfish is not constrained by size or age, they continue to feed on these species
regardless of life stage (Bjomdal. 1997). Leathcrbacks are the deepest diving of all sea turtles. It is estimated
that these species can dive more than 1,000 m (Eekert et al.. 1989) but more frequently dive to depths of 50 m
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to 84 m (Eekert 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; Eekert etai, 1986; Eckert. et al,, 1989; Keinath and Musick. 1993),
Loggerhead sea turtle
Loggerhead sea turtle hatehlings forage in the open ocean and are often associated with Sargassum rafts
(Hughes. 1974; Carr 1987; Walker. 1994; Bolten and Bala/s. 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, thev begin to live in coastal inshore and nearshore waters of the
continental shelf throughout the U.S. Atlantic (Wit/ell, 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 211m to 233
m (Thayer ct al., 1984; Limpus and Nichols. 198K). 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 cl 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, 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 acliun agencies did not identify any Federally-listed proposed species or proposed critical habitat in the
proposed action area.
11 Critical habitat locations for the pipii g plover are available at: htlps://ccos.fws.gov/ecp0/profile/specicsProfile?spcode=B079
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6,0 Potential Stressors to Listed and Proposed Species and Critical Habitat
The action agencies evaluated the potential impacts of the proposed project on HSA-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 ol 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 likeh stressors, directly and indirect!), that were con>idered 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 Irom 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
irom scientilic research has documented that ocean noise also causes marine mammals to change the frequency
or amplitude of calls, decrease ioraging 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
jange 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 rcstrainment and/or capture to the point where
harassment, injury, or death occurs. I he cage, mooring lines, and bridles from the proposed project may pose
an entanglement risk to listed species in the project area: howeser. entanglement risk's to FSA-iisted species at
any aquaculture operation arc mitigated by using rigid and durable cage materials, and by keeping all facility
lines taut as slack lines arc the primary source of entanglements (Nash et al, 2005).
Past protected species reviews by the NMPS 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 ot 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 ol the project on marine mammals was behavioral interactions I e.g., individuals engaging in investigative
behavior around the array or tiiat 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. AH 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 vessel can be further minimi/ed when vessels inn el at less than 10 knots based on general
guidance from the NMFS for \csseK transiting areas wliese there are known populations oi whales iHHIWWIS.
if il iDetection 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 aquaeulturc 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, 2010).
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 arc 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 aquaeulturc 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 aquaeulturc 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 aquaeulturc 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 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 fanned 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-
1' 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 he implemented to
reduce the risk associated with \ esse! strikes or disturbance of thest 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 lex els and the near constant Hushing of the cage hy strung offshore currents that dissipate wastes.
The FPA evaluated the proposed action's potential, impacts to water quality, impacts of organic enrichment to
the sea floor, and impacts to benthic communities from organic enrichment as required by the Sections 402 and
4()> of the C'W'A. The hi'A 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.N Additionally, the EPA considered recent environmental modeling performed by the
NMFS for a similar small scale aquaculturc facility (Vclella Delta).15 MCCGS 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, FPA reviewed the previous and current environmental
monitoring data collected from a commercial-scale marine aquaculture facility. Blue Ocean Mariculturc (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 I:PA'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 NPDFS permit as art aquatic animal production facility with protective
conditions required by the Clean Water Act. "The NPDFS permit will contain conditions that will confirm FPA's
determination and ensure no significant environmental impacts will occur from the proposed project. The
aquaeulture-speeific water quality conditions placed in the NPDFS 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 NPDFS permit uill include effluent limitations expressed as best management practices
(B.VlPs) for feed managmcnt, 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
"4 f-urther information about FPA\ analysis and determination for impacts to water quaht\, sea Hour, and benthic habitat can be found in the
final NPDES permit and the Ocean Discharge Criteria t'ODC) Evaluation, as well as other supporting documents for the NPDES permit such
as the Essential Fish Habitat Assessment and the NEPA evaluation.
" The NC'C'OS previously produced models lo assess the potential environmental effects on water quality and benthic communities for the
applicant's Velella Delta project that is similar Velella Epsiloo in terms of fish production (approximately 120.000 Ibsh operation duration,
and cultured species, however, the water depth was dissimilar between the two projects (6.000 11 \s, 130 ft). At maximum capacity, NCCO!j
determined there were no risks to water quality from the Velella Delta project, and only uiMgntlieant effects would occur in the water column
down to 100 feet. Because of the great depth, strong currents, and physical oecano graphic nature of the Veiella Delta site, dissolved wastes
v. ou Id be widely dispersed and assimilated by the plankumic community. Furthermore, the model results showed that benthic impacts and
accumulation of particulate wastes would not be detectable through measurement of organic carbon or mfaunal community biodiversity.
Water quahtv information from a Blue Ocean Mariculture (BUM) facility m Hawaii was reviewed as representative data and compared to
the proposed project. The BOM farm previously produced approximately 950,01)0 Ibs'yr prior to 2014 and has produced up lo 2,400,000 Ibs'yr
alter 2014. The BOM facility is in a similar depth of water as the proposed project with an average depth of 6(1 ni. Over eight years of
comprehensive water quality and benthic monilormg, the BOM faeilitv has not adverse!) impacted water qualm outside of the mixing zone at
the facility {BOM. 2014).
The EPA and the I 'SAC F. will require mitigation measures to be incorporated into the NPDES permit to avoid or limit organic enrichment
and physical impacts to habitat thai may support associated hard bottom biological communities. The NPDES permit will require facility to he
positioned at least 500 meters from any hard bottom habitat, the DA pen nit will not authorize the anchor system to be placed on vegetated
and'or bardbottom habitat.
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The EPA also considered the potential water quality impacts from chemical spills, dnigs, cleaning, and solid
v. astcs.
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 XPDES 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 tlierapeutants 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 tlierapeutants for aquaculture would be used as required by federal law. In addition, the NPDIiS
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 docs not expect the project lo a cause a measurable degradation in
water quality from drags 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 10 fouling. Should the cage system need cleaning, divers would manually scrub the cage
surfaces with cleaning brashes. 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 Effects 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 arc interrelated or interdependent with that action
(50 CFK $ -102.02). 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-iisted 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" (SLAA)
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 migrator}' routes,
or other iaetors 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 aquaeulture facilities in the Gulf (hi\Y 20 Hi; NMFS. 2009; NMFS. 2013; NMFS. 2015; NMFS. 20UV).
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 migrator)' 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 intcrtidal 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 ha\e 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,
fhe 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 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 smalftooth 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 si/c 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 arc not expected to affect any ESA-listed fish species in or near the proposed
action area.
Anv 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 reels 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) arc 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 hardbotlom 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-spccific water quality
conditions contained in the NPDES pennit 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 lhat the proposed project will NLA A on the ESA-listed invertebrate species.
7,1.4 Marine Mammals
Generally, endangered whales arc not likely to be adversely affected by any ot 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) described in Section 5.1.4. The expected absence ol the hSA-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-listcd 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 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 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 IK 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 stall
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 arc 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 HSA-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 Jo 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 hav e 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 tloor; 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 (sec Section 6.4 for more information).
The action agencies believe that any adverse efleets 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 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 arc 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 inteiacting 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 greatlv reduced by using rigid case
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 hi 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 NMF8.
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
cUorl b> 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 (Velclla 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 u NPDHS 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 lev els 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 ncarshore reproductive habitat or Sargassum habitat. The proposed project is roughly 45 miles from
shore and will not affect ncarshore reproductive habitat. Therefore, the essential features of loggerhead turtle
critical habitat that the proposed action may affect arc foraging habitat for hatchlings and association of
hatchlings 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 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 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 oi'actnc
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 efleet 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 NLA A 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 I s \ determination
Group and Speril's
Birds _
1 Piping Plover
2 Red Knot
Fish
1 Giant Manta Ray
2 Nassau Grouper
3 Oceanic Whitctip Shark
4 Smalltooth Sawfish
Invertebrates
.1
2
3
4
5
6
7
Boulder Star Coral
{•Ikhorn Coral
Mountainous Star Coral
Pillar Coral
Staghom Coral
Rough Cactus Coral
Lobed Star Coral
I'uU-nlial Impacts
Considered
None
I'oteiitial M'ecl l>eUriiimati<»n
None
No effect
Disturbance, Discountable and May affect, but not
entanglement, and insignificant likely to adversely affect
water quality
Disturbance and water Discountable and May affect, but not
quality insignificant likely to adversely affect
Marine Mammals
1 Blue Whale
2 Fin Whale
3 Humpback Whale
4 Sei Whale
5 Spent) Whale
6 Bryde's Whale
Reptiles
1 Green Sea Turtle
2 1 lawksbill Sea Turtle
3 Kemp's Ridley Sea Turtle
4 Leatherback Sea Turtle
5 Loggerhead Sea Turtle
Critical Hahitat
1 Hawksbill Sea Turtle
2 Lealherback Sea Turtle
3 Loggerhead Sea Turtle
¦1 Piping Plo\ er
Disturbance, Discountable and May affect, but not
entani, emcnt, vesse insignificant likely to adversely affect
strike, and water quality
Disturbance, Discountable and May affect, but not
entanglement, vessel jnsi ificant ,lkdy l0 adversely affect
strike, and water quality
Vessel strike and water Discountable and May affect, but not
quality insignificant likely to adversely affect
No effect
None
None
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8.0 Conclusion
The EPA and US ACT, 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 L'SFWS that may occur in the proposed action area and that
may be affected. This determination includes the piping plover and the red knot arid 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 USEWS for this
determination under ESA Section 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 FPA and USACE request concurrence
from the NMFS for this determination under ESA Section 7.
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NMFS. 2015. Endangered Species Act (ESA) Section 7 Consultation to Address Recent Endangered Species
Act Section 4 Listing Actions for the Fishery Management Plan for Regulating Offshore Marine Aquaeulturc in
the Gulf of Mexico (Gulf).
NMFS. 2016. Finding of No Significant Impact - Issuance of a Permit to Authorize the Use of a Net Pen and
Feed Barge Moored in Federal Waters West of the Island of Hawaii to Fish for a Coral Reef Ecosystem
Management Unit Species, Seriola rivoliana. (RIN 064K-XP961) July 2016
NMFS. 2017. US Atlantic and Gulf of Mexico Marine Mammal Stock Assessments - 2017 (Second Edition).
NO A A Technical Memorandum NMFS-NE-245.
Ogren, L. 19X9. Distribution of juvenile and subadult Kemp's ridlcy sea turtles: preliminary results from 1984-
19S7 surveys, in C. Caillouet Jr., and J, Landry (Ed.), Proceedings of the First International Symposium on
Kemp's Ridley Sea Turtle Biology, Conservation, and Management (pp. 116-123). Galveston: Texas A&M
University Sea Grant College.
O'Shea, O. R., Kingsford. M, J., and Seymour, J. 2010. Tide-related periodicity of mania rays and sharks to
cleaning stations on a coral reef. Marine and Freshwater Research. 61, 65-73. doi: 10.1071/MF08301
Paredes, R. (1969). Introduction al Estudio Biologico de Chelonia inydas agassizi en el Perfil de Pisco. Master's
thesis, Universidad National Federico Villarcal, Lima.
Price, C.S. and J.A. Morris, Jr. 2013. Marine Cage Culture and the Environment: Twenty-first Ccntwy Science
Informing a Sustainable Industry. NOAA Technical Memorandum NOS NCCOS 164. 158 pp.
Roberts, J.J., B.D. Best, L. Mannocci, E. Fuji oka. P.N. Halpin, D.L. Palka, L.P. Garrison. K.D. Vlullin. T.V.N.
Cole, C.B. Khan. W.A. McLcllan. 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.
Prog. Ser. 482, 153-168. doi; 10.3354/mcps 10290
Schmidly, D. 2004. The mammals of Texas, revised edition. University of Texas Press, Au tin
Shaver, D. 1991. Feeding Ecology of Wild and Head-Started Kemp's Ridley Sea Turtles in South Texas
Waters. Journal of 1 lcrpcU>log\. 25|3). 327-334.
Sims. N. 2014. Culture and Harvest of a Managed Coral Reef Fish Species (Seriola rivoliana) Using a Fixed
Mooring and Rigid Mesh Submergiblc Net Pen in Federal Waters West of the Island of Hawaii, State of Hawaii.
29 pp.
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Kampachi Farms - Velella Epsiion
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Simpfcndorfcr, C., Yciser, B.. Wiley, T.» Poulakis, (J., Stevens, P., and Heupel, M. 2011. Environmental
Influences on the Spatial Ecology of Juvenile Smalltooth Sawfish (Pristis pectinata): Results from Acoustic
Monitoring. FLOS One, 6(2), doi:https://doi.org/10.1371 /joumal.ponc.0016918
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communities, Estuaries, 7. 351.
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Consultation and Conference Activities Under Section 7 of the Endangered Species Act, Available from:
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at two Carribean islands. Journal of Experimental Marine Biology and Ecology, 220(1), 15-24.
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Conservation Workshop 1994:79-94.
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Science Center. \\ oods Hole. Massachusetts 02543-!02fv March.
Wen/el, F.. D. K., Mattila and P. J., Clapham, 1988. Baiaenoptera museulus in the Gulf of Maine. Marine
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.
Wursig 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 Spiti. Springer, New York. N\
Wyneken, J., Lohmann, K.. and Musick, J. 2013. The Biology of Sea Turtles. Volume 111. 457. Boca Raton,
London, New York: CRC Press,
Biological Fvaluation
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Appendix B - Location Area
—.Yi-Rim lutkl-ics-
lo 10*
latoaiclioicc
1 are in tec:
bus*.'it on t}v Hnrt'fa Sin to
Plaits fYordbnatf Swtcm
HV«I /rr>c. \orth Aroencsui
Oanvn .if ll3K^i>J\n JH.
2 1 -ofa £f>ltc-t!rd by \m 1M
id AiyuW 14. iti>l
"ViigiBiT I* 201R
Voriflnil V^iPj a Plirfmfun
l25Sm Duaiftprf ootprmO
"Piklmrv* (ft)
¦11
CD\
C=J4
D«
IB Hi
Bh2
m\A
~ Magaruc Axtocaalie s
\Up \ I "rtc.TT^'l wired ScdirrcciH
Th
-?51 S "'"I Scw«A
APTIM lMTtl.lt UMK
MU« WHMiut*
VE Project - Modified Site B & Pen Placement
Gulf
of
Mexico
Potioon
* Decimal Latitude
8 Dectm3J Longitude
Dectmai: Latitude
Decimals Longitude 1 Perimeter (Km)
Area (Km1)
ModJfis
d Site B from BE5 Report
upoer ^efv
27* 7 3656-2' N
32* 13.45527" W
27.131143* N
63.224303" W
11.1571
7 7237
uc-0r' sqr:
27* ? 83G7S* H
S3* 11 5323"" W
27.130512* N
£3 193872* w
LowerRjqfl*
27* € 433-3* S
33* 11 59345" W
27.107230* N
63.194690* W
Lower _ert
27* € 5026V N
53" 13 5255B' W
27.1 05377* H
£3.225-442* V.
Obiter
27* 7.11256" N
33* 12 56604 w
27.116643" N
63.2C9757" W
Targeted
uBset Area of Modified sits B from 9=3 Report (3' to 1
r unconsolidated Segment
3)
u do** -eft
27* 7.70607- M
33* 1227C12
27 12S445* M
63-204502* W
52273
1 6435
uooer ojohi
27* 7.51022* N
33* 11 55676"
27 126537* N
53 154276* W
LOWS'"
27* 6.77773' S
33* 11 75375'
27.112562* N
£3.195697* W
Lower -en
27* £ 37631" W
33* 1242032
27,1 14605* N
63.207005* W
Center
27* 7.34195" N
33* 1202291 W
27.122355* N
63.2QG332" W
Notional Net Pen Plfecm
>ntt wrtfttn Modified site B
from bes Report
1
27* 7 54724' N
93* 11 35393' W
27.125737" N
63.197555* W
0.7354
0.0491
2
27* 7 1743?- H
33* 11 32576' W
27.119530* N
63 197095* W
3
27* 6.93S3C- N
33* 1194780' W
27.115655* N
53.1995 30* V.
A
27" £ 52*75' N
33* 12-09175 W
27.106763* N
63.201530" W
Biological Evaluation
Kampachi Farms - Velella Epsilon
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Final
BIOLOGICAL EVALUATION
Ocean Era, Inc. - Velella Epsilon
Marine Aquaculture Facility
Outer Continental Shelf
Federal Waters of the Gulf of Mexico
September 30, 2020
$ n
^ PRO^°
CJ
T
Z
LU
US Army Corps
of Engineers®
U.S. Environmental Protection Agency
Region 4
Water Protection Division
61 Forsyth Street SW
Atlanta Georgia 30303
U.S. Army Corps of Engineers
Jacksonville District
Fort Myers Permit Section
1520 Royal Palm Square Boulevard Suite 310
Fort Myers Florida 33919-1036
NPDES Permit Number
FL0A00001
Department of the Army Permit Number
SAJ-2017-03488
-------
Table of Contents
1.0 Introduction and Federal Coordination 3
2.0 Proposed Action 5
3.0 Proposed Project 6
4.0 Proposed Action Area 8
5.0 Federally Listed and Proposed Threatened and Endangered Species and Critical Habitat 9
5.1 Federally Listed Threatened and Endangered Species 9
5.1.1 Birds 10
5.1.2 Fish 10
5.1.3 Invertebrates 12
5.1.4 Marine Mammals 12
5.1.5 Reptiles 14
5.2 Federally Listed Critical Habitat In or Near the Action Area 16
5.2.1 Birds 16
5.2.2 Reptiles 16
5.3 Federal Proposed Species and Proposed Critical Habitat 16
6.0 Potential Stressors to Listed and Proposed Species and Critical Habitat 17
6.1 Disturbance 17
6.2 Entanglements 17
6.3 Vessel Strike 17
6.4 Water Quality 18
7.0 Potential Effects of Action 21
7.1 Federally Listed Threatened and Endangered Species 21
7.1.1 Birds 21
7.1.2 Fish 21
7.1.3 Invertebrates 22
7.1.4 Marine Mammals 23
7.1.5 Reptiles 24
7.2 Federally Listed Critical Habitat 25
7.3 Federal Proposed Species and Proposed Critical Habitat 26
8.0 Conclusion 28
8.1 Consultation with USFWS 28
8.2 Consultation with NMFS 28
References 29
Appendix A - Cage and Mooring Detail 35
Appendix B - Location Area 36
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1.0
Introduction and Federal Coordination
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 Ocean Era (formerly
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 have
provided this BE for consideration by the USFWS and the NMFS in compliance with the ESA Section 7.
The EPA and USACE coordinated 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 conducted a comprehensive analysis of all applicable environmental requirements required by
the National Environmental Policy Act (NEPA); however, a consolidated cooperation process under NEPA was
not used to satisfy the requirements of ESA Section 7 as described in 50 CFR § 402.06.4 The NMFS was 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
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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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 provided as a
stand-alone document to comply with the consultation process under ESA Section 7.
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2.0 Proposed Action
Ocean Era, Inc. (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 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 facilityinto 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 harvest weight of 80,000 lbs considering a 10% mortality
rate. The fingerlings will be sourced from brood stock that are located at Mote Aquaculture Research Park, in
Sarasota, Florida, 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 vessel 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 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 in offshore fishing activities in the Gulf.
A fully enclosed and submersible single copper pen that is offshore strength (PolarCirkel-style) 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 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 flotation 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 able to rotate around the MAS and adjust to currents while it is submerged and protected from
storms. After storm events, the cage system is made buoyant again by pumping air back into the flotation
system, 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.
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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 and protected species. The PSMP also contains important mitigative efforts such as
suspending vessel transit activities when a protected species is observed to come 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 is observed to come 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 aboutthe
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 spills 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 Area
The proposed project will 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 there
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 and Proposed Threatened and Endangered Species and Critical Habitat
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
ESA Status
Critical Habitat
Status
Potential Exposure to
Proposed Action Area
Birds
1 Piping Plover
2 Red Knot
Fish
1 Giant Manta Ray
2 Nassau Grouper
3 Oceanic Whitetip Shark
4 Smalltooth Sawfish
Invertebrates
1 Boulder Star Coral
2 Elkhorn Coral
4 Mountainous Star Coral
5 Pillar Coral
7 Staghorn Coral
6 Rough Cactus Coral
3 Lobed Star Coral
Marine Mammals
1 Blue Whale
2 Bryde's Whale
3 Fin Whale
4 Humpback Whale
5 Sei Whale
6 Sperm Whale
Reptiles
1 Green Sea Turtle
2 Hawksbill Sea Turtle
3 Kemp's Ridley Sea Turtle
4 Leatherback Sea Turtle
5 Loggerhead Sea Turtle
Threatened No
Endangered Yes
Endangered No
Endangered Yes
Threatened Yes
Threatened No
Threatened No
Threatened No
Threatened No
Threatened No
Threatened No
Threatened No
Threatened No
Threatened No
Threatened No
Endangered No
Threatened Yes
Threatened No
Endangered No
Endangered No
Endangered No
Endangered No
Endangered No
Endangered No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
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5.1.1 Birds
There are 14 ESA-listed avian species identified as threatened or endangered, previously delisted, or 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 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
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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 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 a I., 2010; Marshall et a I., 2011; Rohner et
a I., 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 Flower
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 a I., 1956; Bonfil et a I., 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 Caloosahatchee
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
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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
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
Cor.il Species Most Abundant Depth (ft)
Boulder Star Coral
3-829
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
a I., 1988; Waring et a I., 2006). Blue whales are not expected to be within the proposed action area that is
located in a water depth of approximately 40 m.
9 www.DCNANature.org, 2016
10 NMFS, 2016
11 www.IUCNRedList.org, 2016
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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 a I., 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 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 there 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 a I., 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 found near the proposed action area. Additionally, the
water depth at the proposed action area (40 m) does not overlap 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 a I., 1988; Waring et a I., 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 a I., 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 a I., 1996; Davis et a I., 2002; Mullin and Fulling, 2003; Wiirsig, 2017). Research conducted since 2000
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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 a I., 2003, Wynekan et a I., 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.
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.,
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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 a I., 1989) but more frequently dive to
depths of 50 m 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.
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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 and Proposed Species and Critical Habitat
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 a I., 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 NMFSfor 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 a I., 2005).
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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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-
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 decreased water quality impacts, including
deep waters and a sand bottom type. Neither particulates nor dissolved metabolites are expected to
accumulate due to 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 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 an
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 management, 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
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 Habitat 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 Hawaii was reviewed as representative data and compared to
the proposed project. The BOM farm previously produced approximately 950,000 Ibs/yr prior to 2014 and has produced up to 2,400,000
Ibs/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).
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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
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 spills do occur they are expected to 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.
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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7.0
Potential Effects 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.
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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,
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 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 5-10 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 offish.
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.
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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 5-10 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
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 are 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 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.
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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 location of the proposed project relative to marine mammal
habitat, the action agencies anticipate the effects of entanglement are 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 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
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aquaculture facility in Hawaii (BOM, 2014); we anticipate that such interactions would be unlikely. As a result,
disturbance effects from human activities and equipment operation associated with the proposed action are
expected to be insignificant on ESA-listed species.
The risk of sea turtles being entangled in an 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.
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 efforts 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 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 5-10 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
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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.
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 on the Northwest Atlantic
loggerhead DPS critical habitat will be insignificant 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 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
Group and Species
Potential Impacts
Considered
Potential Effect Determination
Birds
1 Piping Plover
2 Red Knot
Fish
1 Giant Manta Ray
2 Nassau Grouper
3 Oceanic Whitetip Shark
4 Smalltooth Sawfish
Invertebrates
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
6 Bryde'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 likely
insignificant to adversely affect
Disturbance and water Discountable and May affect, but not likely
quality insignificant to adversely affect
Disturbance,
entanglement, vessel
strike, and water
quality
Disturbance,
entanglement, vessel
strike, and water
quality
Discountable and May affect, but not likely
insignificant to adversely affect
Discountable and May affect, but not likely
insignificant to adversely affect
Vessel strike and water Discountable and May affect, but not likely
quality insignificant 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.
8.1 Consultation with USFWS
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 § 7.
On August 13, 2019, EPA and USACE provided the jointly developed BE to USFWS and initiated consultation
with USFWS. EPA and USACE determined that the discharges and structures authorized by the NPDES or RHA
Section 10 permit will have "no effect" on any federally listed species, proposed species, or critical habitat for
sea birds that are under the jurisdiction of the USFWS and within the proposed action area. On August 27,
2019, a USFWS provided notification that the USFWS does not object to the permit issuance for the proposed
project and had no additional comments. Completion of the informal consultation with the USFWS satisfies
EPA's obligations under ESA § 7(a)(2).
8.2 Consultation with NMFS
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 § 7.
On August 13, 2019, EPA and USACE provided the jointly developed BE to NMFS and initiated consultation with
the NMFS. Regarding federally listed species, proposed species, or critical habitat under the jurisdiction of the
NMFS, EPA and USACE determined that the proposed project "may affect, but not likely to adversely affect"
certain fish, invertebrates, marine mammals, and reptiles within the proposed action area. On September 30,
2019, NMFS concluded "that the proposed action is not likely to adversely affect listed species under NMFS's
purview." Completion of the informal consultation with the NMFS satisfies EPA's obligations under ESA §
7(a)(2).
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Appendix A - Cage and Mooring Detail
DRiUUI LINE.: HDPL PiPF WITH ROPE ihSiDi
SAL. LAS = i ANK
CONCRETE BAlLAS
1) Deadweight Anchors (concrete):
• Three (3) anchors equally spaced
o 120m from mooring centeriine
o 120 degrees from each other
• Each @ 3 ton Stevpris Mk-5 drag embedment anchor
2) Mooring Chain (Grade 2 steel):
• 80m length on each anchor
• 50mm (2") thick links
• No load = 70m length of each on seafioor
• Design load = some entirely off seafioor/
others completely on seafioor
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 Ones (rope inside HDPE pipe):
• Three (3) ~30m bridle lines (rope) from swivel to
spreader bar
• A!V1STEEL®-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 0.36rn 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
• AMSTEEL®-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 Capsuie (steel);
• ~1.5m in diameter x~3.45rn in length
• Effective floatation volume = 6m'5
• ~3m Grade 2 steel chain (32mm) connected to Counter Weight
12) Counterweight (concrete):
• ~ 1.1m in diameter x~2.2m in length
• Effective weight of 5 MT
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Appendix B - Location Area
VE Project - Modified Site B & Pen Placement
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-------
/ V \
UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
NATIONAL MARINE FISHERIES SERVICE
Southeast Regional Office
263 13th Avenue South
St. Petersburg, Florida 33701-5505
https://www.fisheries.noaa.gov/region/southeast
09/30/2019
F/SER31:JLL
SER-2019-02205
Christopher B. Thomas
Chief, Permitting and Grants Branch
U.S. Environmental Protection Agency
Region 4
Atlanta Federal Center
61 Forsyth Street
Atlanta, Georgia, 30303-8960
Dear Mr. Thomas:
This letter responds to your request for consultation with us, the National Marine Fisheries
Service (NMFS), pursuant to Section 7 of the Endangered Species Act (ESA) and the Fish
and Wildlife Coordination Act (FWCA) for the following action.
Project Name
Applicant(s)
SER Number
Project Type
Velella Epsilon
Kampachi
SER0-2019-
Offshore Cage Aquaculture,
Marine Aquaculture
Farms, LLC
02205
NPDES permit, Section 10
Facility
permits
Your request is on behalf of the U.S. Environmental Protection Agency (EPA) and U.S. Army
Corps of Engineers Jacksonville District (USACE), the two federal agencies responsible for
permitting aquaculture operations in federal waters of the Gulf of Mexico. The EPA is
proposing to issue a National Pollutant Discharge Elimination System (NPDES) permit to
Kampachi Farms, LLC for the point-source discharge of pollutants from their proposed Velella
Epsilon marine aquaculture facility. The USACE is proposing to issue a Department of Army
permit pursuant to Section 10 of the Rivers and Harbors Act for structures and work affecting
navigable federal waters from the same aquaculture facility. The EPA has elected to act as the
lead action agency and the USACE is a cooperating and co-federal agency. The EPA and
USACE have determined that their proposed actions are not likely to adversely affect any listed
or proposed species or designated or proposed critical habitat.
Consultation History
We received your letter requesting consultation and Biological Evaluation on August 13, 2019
and initiated consultation that day.
Project Location
The proposed aquaculture facility will be located in the Gulf of Mexico in an approximate
water depth of 130 feet (ft) (40 meters [m]), 45 miles (mi) southwest of Sarasota, Florida.
The applicant has submitted four potential locations to place the cage and multi-anchor swivel
-------
(MAS) mooring system. The applicant will select one of these four potential locations based on
diver-assisted assessments of the sea floor when the cage and the MAS are deployed.
Proposed Potential Project Locations
Address
Location
Option
Latitude/Longitude
(North American Datum
1983)
Water body
Approximately 45 mi off
Sarasota, Florida
1
27.125787°N, 83.197565°W
Gulf of Mexico
2
27.119580°N, 83.197096°W
3
27.115655°N, 83.19913°W
4
27.108763°N, 83.201529°W
Pursuant to 50 C.F.R. § 402.02, the term action area is defined as "all areas to be affected
directly or indirectly by the federal action and not merely the immediate area involved in the
action. The EPA defined the proposed action area as a 1,000 m radius measured from the
center of the MAS, based on the result of their water quality analysis.
Existing Site Conditions
The proposed facility will be placed within an area that contains unconsolidated sediments that
are 3-10 ft deep. The facility's 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,
marine protected areas, marine reserves, and habitats of particular concern. This siting
assessment was conducted using the Gulf AquaMapper tool developed by NCCOS.1
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.2 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
Project Description
The project applicant, Kampachi Farms, LLC, is proposing to operate a pilot-scale marine
aquaculture facility, rearing up to 20,000 almaco jack (,Seriola rivoliana) for approximately 12
months (with total deployment of the cage system 18 months) in federal waters of the Gulf of
Mexico in 130 ft of water.
A single CopperNet offshore strength (PolarCirkel-style) fully-closed submersible fish pen will
be deployed on an MAS mooring system. The engineered MAS will have up to three anchors
(concrete deadweight or embedment anchors) for the mooring, with a swivel and bridle system.
The cage material for the proposed project is constructed with rigid and durable materials
1 The Gulf AquaMapper tool is available at: https://coastalscience.iioaa.gov/products-explorer/
2 The BES guidance document is available at: https://www.fisheries.noaa.gov/content/fishery-management-plan-
regijlating-offshore-marine-aqiiaciiltiire-giilf-mexico
2
-------
(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 (50 mm thick) and
thick rope (36 mm) that are attached to a floating cage that will rotate in the prevailing current
direction; this 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.
The CopperNet cage design is flexible and self-adjusts to suit the constantly changing wave and
current conditions. Consequently, the system can operate floating on the ocean surface or
submerged within the water column of the ocean. Normal operating condition of the cage is
below the water surface. The cage will be submerged and only brought to the surface for brief
periods to conduct maintenance, feeding, or harvest activities due to the high-energy open ocean
environment.
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.
One support vessel, expected to be a 70-ft-long Pilothouse Trawler (20 ft beam and 5 ft draft)
with a single 715 horsepower engine, will be tethered to the facility. Another vessel would be
used for harvest and transport of the fish. The exact harvest vessel is not known; however, it is
expected to be a vessel already engaged in offshore fishing activities in the Gulf.
Construction Conditions
The applicant has agreed to follow a protected species monitoring plan (PSMP), which they
developed with assistance from the NMFS Protected Resources Division. The purpose of the
PSMP is to provide monitoring procedures and data collection efforts for species protected under
the MMPA or ESA that may be encountered at the proposed project. The PSMP also contains
precautionary measures including suspending vessel transit and all surface activities (including
stocking fish, harvesting operations, and routine maintenance operations) when a protected
species comes within 100 m of the activity until the animal(s) leave the area. The applicant also
commits to following vessel strike avoidance guidelines developed by the NMFS. (i.e., NMFS
Southeast Region Vessel Strike Avoidance Measures and Reporting for Mariners; revised
February 2008).
3
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Effects Determination(s) for Species the Action Agency or NMFS Believes May Be Affected
by the Proposed Action
ESA
Action
NMFS Effect
Determination
Species
Listing
Status3
Agency Effect
Determination
Sesi Turtles
Green (North Atlantic [NA] distinct
T
NLAA
NLAA
population segment [DPS])
Green (South Atlantic [SA] DPS)
T
NLAA
NLAA
Kemp's ridley
E
NLAA
NLAA
Leatherback
E
NLAA
NLAA
Loggerhead (Northwest Atlantic [NWA]
DPS)
T
NLAA
NLAA
Hawksbill
E
NLAA
NE
Tisli
Smalltooth sawfish (U.S. DPS)
E
NLAA
NLAA
Nassau grouper
T
NLAA
NE
Giant manta ray
T
NLAA
NLAA
Oceanic whitetip shark
T
NLAA
NLAA
Invertebrates and Marine Plants
Elkhorn coral (Acroporapalmata)
T
NLAA
NE
Staghorn coral (Acropora cervicornis)
T
NLAA
NE
Boulder star coral (Orbicellafranksi)
T
NLAA
NE
Mountainous star coral (Orbicella
T
NLAA
NE
faveolata)
Lobed star coral (iOrbicella annularis)
T
NLAA
NE
Rough cactus coral (Mycetophylliaferox)
T
NLAA
NE
Pillar coral (Dendrogyra cylindrus)
T
NLAA
NE
Marine Mammals
Bryde's whales
E
NLAA
jNE
Blue whale
E
NLAA
NE
Fin whale
E
NLAA
NE
Sei whale
E
NLAA
NE
Sperm whale
E
NLAA
NE
There are listed species for which you made NLAA determinations for the proposed project but
for which we believe there are no effects. Our rationale for that determination for each of these
species is as follows:
1. Hawksbill sea turtles have very specific life history strategies, which are not supported at
the project site. Hawksbill sea turtles typically inhabit inshore reef and hard bottom areas
where they forage primarily on encrusting sponges. The proposed facility is located in an
offshore area that contains 3 to 10-ft deep unconsolidated sediments and not near any
3 E = endangered; T = threatened; NLAA = may affect, not likely to adversely affect; NE = no effect; NP = not
present
4
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hardbottom habitat. Consequently, we believe that Hawksbill sea turtles will not be
present, and that there are no potential rotes of effects on this this species.
2. The absence of Nassau grouper in the Gulf of Mexico (excluding around the Florida Keys
and Dry Tortugas) is well-documented by the lack of records in Florida Fish and Wildlife
Conservation Commission, Fisheries Independent Monitoring data as well as in various
surveys conducted by NMFS, Southeast Fisheries Science Center. Nassau grouper are
not found in or close enough to the action area for there to be any potential routes of
effects to this species.
3. The proposed project will be placed in an area consisting of unconsolidated sediments
and not near any hardbottom. In your analysis, you concluded that water quality effects
are not expected to occur outside of 30 m (0.02 mi) due to the small size of the facility.
You also concluded that sedimentation from the Velella Epsilon facility is not expected
outside of 1,000 m (0.62 mi), and impacts resulting from the proposed facility are likely
limited to within 300 to 500 m (0.12 to 0.31 mi) from the cage. Listed corals generally
occur in the Gulf only near the Florida Keys and Dry Tortugas and in the Flower Banks
National Marine Sanctuary, located off the coast of Texas and Louisiana. Listed corals
do not occur in or close enough to the action area for there to be any potential routes of
effects on these species.
4. Two strandings on the Louisiana and Texas coast comprise the only possible record of
blue whales in the Gulf of Mexico and identifications for both strandings are
questionable, thus we do not believe blue whales live in the Gulf of Mexico.
5. Water depth at the project site is only 40 m deep, and the site is approximately 80+ mi
from Bryde's whale biological important areas, the 100-m depth contour, and the shelf
break. Sperm whales are the most abundant large cetacean in the Gulf of Mexico, found
year-round in waters greater than 200 m. Sei whales also typically occur in these deeper
waters. Sei whales are generally found in oceans along the 100-meter depth contour with
with sightings also spread over deeper water including canyons along the shelf break.
Fin and sei whale do occasionally strand in the Gulf indicating they may occur, but
neither is commonly observed in the waters of the Gulf of Mexico. We do not believe
any of these species will occur in the action area for this project or close enough for there
to be any potential routes of effects to these species.
Critical Habitat
We do not concur with your determination that the proposed action may affect hawksbill,
leatherback, and loggerhead sea turtle critical habitat. The project is not located in or near
designated critical habitat of these or any other species. The nearest critical habitat to the project
is loggerhead nearshore nesting habitat (Units 29 and 30), more than 40 mi away from the action
area.
Analysis of Potential Routes of Effects to Species
Potential routes of effects to the listed species that may occur in the action area (i.e., sea turtles
[green NA and SA DPSs, loggerhead, leatherbacks, and Kemp's ridleys] and ESA-listed fish
[i.e., smalltooth sawfish, giant manta rays, and oceanic whitetip sharks]4) include disturbance,
vessel strike, entanglement, and water quality changes.
4 Hereafter, sea turtles and ESA-listed fish refer to these specific species.
5
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Vessel strike
A vessel strike is a collision between any type of boat and a marine animal in the ocean.
Collision with the hull, outboard motor, or propeller of a vessel can kill or injure marine animals
including air-breathing whales and sea turtles as well as any other marine species when feeding,
basking or even just swimming close to the surface (e.g., giant manta rays and oceanic whitetip
sharks). Collisions may occur anywhere a vessel cross paths of a species. However, we have
determined that the potential for a vessel strike on any listed species to result from this proposed
action is discountable. The proposed project involves only two vessels. A support vessel will be
present at the facility throughout the life of the project except during certain storm events or
times when resupplying is necessary; a harvest vessel (expected to be a vessel already engaged in
offshore fishing in the Gulf) will be used to transport the fish, once grown, to land. Vessels are
expected to follow the vessel strike and avoidance measures that have been developed by
NMFS5. A collision between any specific vessel and marine animal is extremely unlikely to
occur. For example, when using the conservative mean estimate of a sea turtle strike every 193
years (range of 135-250 years) per vessel, it would require a moderately-sized marina project
(e.g., -200 new vessels introduced to an area) to potentially result in a sea turtle take in any
single year (Barnette 20186). Given the limited vessel activity and duration of the project, a
vessel strike is extremely unlikely.
Disturbance
ESA-listed fish and sea turtles may experience disturbance by stress via a startled reaction should
they encounter the proposed facility, including the cage associated and the support vessel and/or
harvest vessel or associated noise (e.g., vessel engine or barge generator), when moving through
the area. A behavioral reaction could range from the animal approaching and investigating the
facility to avoidance and moving away from the area. A potential source of disturbance from the
proposed aquaculture facility would be vessel engine and barge generator noise. ESA-listed fish
and sea turtles may also be attracted to aquaculture facilities as potential sources of food, shelter,
and/or rest. However, any stress and behavioral effects on ESA-listed fish and sea turtles from
disturbance are expected to be insignificant. The facility is not in an area known to be a hot spot
or high-use area for any important activities (e.g., feeding, reproducing) of the sea turtle or ESA-
listed fish species. Also, because this is a pilot study with only one cage in the open ocean, the
proposed project site is small (each potential site <8 square kilometers) and will in no way limit
movement or ability of a species to avoid the area or navigate through the area. As a result,
disturbance from human activities and equipment and vessel operation resulting from the
proposed action is expected to have only insignificant effects on ESA-listed fish and sea turtles.
Entanglement/Entrapment
The cage, mooring lines, and bridle line from the proposed project may pose an entanglement
and an entrapment risk to ESA listed fish and sea turtles. Entanglements occur when lines,
netting, or other man-made materials become wrapped around the body (e.g., flipper, fin) of the
5 NMFS. Vessel Strike Avoidance Measures and Reporting for Mariners NOAA Fisheries Service, Southeast
Region, February 2008. National Oceanic and Atmospheric Administration, National Marine Fisheries Service,
Southeast Regional Office, Protected Resources Division, Saint Petersburg, Florida.
https://www.fisheries.noaa.gov/southeast/consultations/regulations-policies-and-guidance
6 Barnette, M. C. 2018. Threats and Effects Analysis for Protected Resources on Vessel Traffic Associated with
Dock and Marina Construction. National Oceanic and Atmospheric Administration, National Marine Fisheries
Service, Saint Petersburg, Florida.
6
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animal. Entrapment can occur when an animal becomes restrained or stuck in man-made
structure and cannot escape. However, we believe the effects to sea turtles or ESA listed fish
from entanglement will be discountable because of how the cage will be constructed and
deployed. The risk of sea turtles and ESA listed fish being entangled or entrapped is greatly
reduced by using rigid cage materials and by keeping all lines taut. The cage and moorings for
the proposed project are constructed with rigid and durable materials, and 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. For example, the lines would likely remain taut even as
the currents shift because of the weight of the chain and rope creating a negative buoyancy on
the facility anchorage lines. The cage, even in storm conditions, will be at least several meters
from the sea floor, allowing safe passage under the cage. Additionally, the bridle line that
connects from the swivel to the cage will be encased in a rigid pipe. The limited number of
vertical mooring lines (3) and the duration of cage deployment (less than 18 months) will also
reduce the risk of potential entanglement. Because of the proposed project operations and
duration, we expect that the effects of possible entanglement to be discountable.
Water quality
Sea turtles and ESA-listed fish species may be affected by water quality/habitat degradation if it
leads to reduced habitat quality. However, we believe any potential water quality effects on
ESA-listed fish and sea turtles from the proposed action will be insignificant. Effluent from the
proposed action can adversely affect water quality, sea floor sediment composition, and benthic
fauna through the additions of uneaten feed, ammonia excretions, and fish feces from the
increased fish biomass. The release of nutrients, reductions of dissolved oxygen, and the
accumulation of sediments under certain aquaculture operations lead to eutrophication and
degradation of benthic communities. The EPA evaluated the proposed action's potential impacts
to water quality and impacts of organic enrichment to the seafloor and benthic communities. The
EPA also considered the potential water quality impacts from chemical spills, drugs, cleaning,
and solid wastes. 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. The EPA anticipates 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. Per EPA's analysis, (1) water quality effects are not
expected to occur more than 30 m (0.02 mi) away from the cage site due to the small size of the
facility, and (2) sedimentation from the Velella Epsilon facility is not expected to go more than
1,000 m (0.62 mi) from the cage, and impacts resulting from the proposed facility are likely
limited to within 300 to 500 m (0.12 to 0.31 mi) from the cage. The discharges authorized by the
proposed NPDES permit represent a small incremental contribution of pollutants and will have
an insignificant affect any on the ESA-listed fish or sea turtles in the action area.
Conclusion
Because all potential project effects to listed species were found to be discountable, insignificant,
or beneficial, we conclude that the proposed action is not likely to adversely affect listed species
under NMFS's purview. This concludes your consultation responsibilities under the ESA for
species under NMFS's purview. Consultation must be reinitiated if a take occurs or new
7
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information reveals effects of the action not previously considered, or if the identified action is
subsequently modified in a manner that causes an effect to the listed species or critical habitat in
a manner or to an extent not previously considered, or if a new species is listed or critical habitat
designated that may be affected by the identified action. NMFS's findings on the project's
potential effects are based on the project description in this response. Any changes to the
proposed action may negate the findings of this consultation and may require reinitiation of
consultation with NMFS.
In your letter to us, you also initiated consultation pursuant to the Fish and Wildlife
Coordination Act (FWCA). NMFS's Southeast Regional Office, Habitat Conservation Division
reviewed the information in the Draft Biological Evaluation pursuant to the FWCA, and based
on that review, we anticipate any adverse effects that might occur on marine and anadromous
fishery resources would be minimal. Therefore, we do not object to issuance of the permit per
the FWCA.
We look forward to further cooperation with you on other projects to ensure the conservation of
our threatened and endangered marine species and designated critical habitat. If you have any
questions on this consultation, please contact Jennifer Lee, Fishery Biologist, at (727) 551-5778
or by email at Jennifer.lee@noaa.gov.
Sincerely,
David Bernhart
Assistant Regional Administrator
for Protected Resources
cc: F/SER - J. Beck
F/SER31 - J. Lee
File: 1514-22.k
8
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Appendix E
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
Ms. Virginia Fay
MAR . 8 2019
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 (USACE) 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 USACE
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 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 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 USACE 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 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). In the attached EFH assessment, the EPA and the USACE 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."
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Printed 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 USACE wiit 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 state whether the NMFS concurs or
does not concur with the determination made by the EPA and USACE. 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 OfTshore 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 not 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 and 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.Molly@epa.gov or 404-562-9236).
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 Qfiyiore Aquaculture Activities in Federal Waters of the Gulf of
Mexico became effective for seven fedcra' acenrits with permitting or authorization responsibilities.
3 50 CFR § 600.920(c)( 1) stales that "Fetters! agencies may incorporate an EFH Assessment into documents prepared for other purposes such
as Endangered Species Act (ESA) Biological A>yessments pursuant to 50 CFR part 402 or National Environmental Policy Act (NEPA)
documents and public notices pursuant to 40 CFR Part 1500 "
Mary Jo Etegar, Ch«eC
Ni'DES Permitting and Enforcement Branch
Water Protection Divison
Sincerely,
-------
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
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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
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
Kampachi Farms - Velella Epsilon
Page 2 of 20
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1.0 Inli'odiKiion ;in(I I'odoi'iil (oorriiniilion
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
Kampachi Farms - Velella Epsilon
Page 3 of 20
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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
Kampachi Farms - Velella Epsilon
Page 4 of 20
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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.
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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
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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
EFH Assessment
Kampachi Farms - Velella Epsilon
Page 14 of 20
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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.
EFH Assessment
Kampachi Farms - Velella Epsilon
Page 15 of 20
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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."
EFH Assessment Page 16 of 20
Kampachi Farms - Velella Epsilon
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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
PlVSCIll
Yes
No
Significant Impact
No
No
Significant Impact
Yes
No
Significant Impact
Yes
No
Significant Impact
Yes
No
Significant Impact
Yes
No
Significant Impact
Yes
No
Significant Impact
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 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
EFH Assessment
Kampachi Farms - Velella Epsilon
Page 17 of 20
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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.
EFH Assessment
Kampachi Farms - Velella Epsilon
Page 18 of 20
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Appendix A - Cage siihI Mooring Detail
13PIDLL JJ-.t: HD::iF KIPL
: xlOn TroT: moomg ce^ier me
: liO degrees fron e?ch other
Each g 4 5*n x 4 5er * 4 5t (31 rr,i\
* Lon:retetri:tior 'actor = C 5 :rwet35 td
* Each ha; ar e+fertrfee v.e.fht cf l-.7 h'T
2) Mooring v.ham jGiade 2 steel):
* oOti. lergth :r ¦each ari^scr
» S^Tin C ! imVr
* No load = 70n ler^th cf each cr s-eaf oor
* De^.gn 1:2d = someert tey -^3cc:< /
ctne?: tcnp ets y o< :e3f cor
3) Mooring Lines iiope);
* 40m lingth cr each ch3n
jv-5TEe:;-slue
* 3omm U 1/2" > thsck lines
41 Spar Buoy w/ Swivel {steei):
5} Bridie lmes [r^f e inside HOPE jupc}:
* Tivee ;?i~30t brr ip C'srneter
One ill HDFE voce Float Pirgi
¦ Or -h* *Jt"eaue
* -0 jc-n CO LP l.H^Eciue
One til H3FE i e. nr g i/ai M.gl
* L-r.iects:. - 1 C't sLove F ».at
¦ C«. rned"S"~ to Ne* Merh
* 0 15ti CO IP l"7 HC&Epi?e
• Sottcr =ian>e >.ti j£U*re
ISt » r ar>etei
One di H:iFr rnkef ling
¦ ~ Or be ov* Pi:: at Ftrgi
¦ r necteo :o *4e* ^ing
" .i ¦ : :c, -
One ill HOPE rei nn:
¦ fie o»v float insr
* t -ii'iecte-' *o -jppet d 0\ res
0 15t> Cj SR 1? HD3E Dice
9) Met Pen Mesh (copper alloy):
• 17m diameter x7m depth
• Top connected to top net ring (railtngj
• S-ortom connected to Ssottom net ring
c 4mm wire diameter
o 40mm x 40mm mesh square
• Effective volume of 1.600m5
One US HiW shackle plate
Four i^] ccrnection "nes
c iJ nn- ir d.amete'- * 10m ir lergth
o Coin^ctetf fon s'nark e p a:e tc riD^E sir«,er in
~lm Grade I ^tee c1"3ir 'SlT-ms canned:-:1 to Floatation
11)
tapsule jsteein
1 5m i i Jrarete > ~5 45«r ir lergth
Effective floa:::iOM vcune = 6ts
' 3m je Z stce ^3i! > riymj co
ter Weight{oucictej:
11m n Jot etc x -1 2m in length
Effectue ^eightofS f/T
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
- Hcwtda
Sfaxicv
UJJ
ul:
— A«-Ruii J rock line*
llKOBSobdltcd
SpdlTOfTlM
1 foorriwuilei arc in feet
bated cm the P Intuit Stnte
Plane Coordinate System,
Weat Aaw, North American
Oanvn of tOftJ (NAD 8*»
2 Data collected by APTIM
August 14. 201 & and
August 15. 2CH8
I XMtMal >"*iP*a an
12 50 in Diaaeterl ootfrinl)
IMJaiiiaim
# Nearest Magnetic Anomalies
Map 3 I'nconsolidarcd Sediment
Thneknes* hrpoch
kiampuchi l irat
N firth hpviloii
(>iMipk\»kal SurM'i
l 7SSCS 301 soak
\ APTIM i--.ii
V wu« AMlMumi
Portion
¦ Decimal Latitude
• Decimal1 Longitude
Decimal1 Latitude
Decimal9 Longitude
Perimeter (km)
Area (KmJ)
Modlflfl
d Site B from BES Report
upoef .eft
27' 7.86663' N
S3* 13 -15827* W
27.131143* N
83.224303* W
Upper RiglH
27* 7.83079" N
S3* 11.63237* W
27.130512* N
63.153672* W
Lowe? °.
-------
/V\
tresis*
jUNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
NATIONAL MARINE FISHERIES SERVICE
Southeast Regional Office
263 13ln Avenue South
St. Petersburg, Florida 33701-5505
https://www. fisheries .noaa.aov/reaionfeoutheast
August 23, 2019
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
Attention: Ms. Meghan Wahlstrom-Ramler
Dear Ms. Bragan,
NOAA's National Marine Fisheries Service (NMFS), Southeast Region, Habitat Conservation
Division has reviewed your staffs email and revised essential fish habitat (EFH) assessment
dated August 2, 2019, regarding issuance of the U.S. Environmental Protection Agency's (EPA)
National Pollutant Discharge Elimination System (NPDES) Permit Number FL0A00001. The
U.S. Army Corps of Engineers 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. The
project applicant, Kampachi Farms, LLC is proposing to operate a pilot-scale marine aquaculture
facility, Velella Epsilon, in federal waters of the Gulf of Mexico in 130 feet of water
approximately 45 miles southwest of Sarasota, Florida.
The NMFS previously completed our EFH consultation for this project on March 12, 2019. The
EPA's revised EFH assessment includes the following proposed project design changes:
(1) The anchoring system for the project would utilize either deadweight or embedment style
anchors. Final anchor style(s) would be placed within three to 10 feet deep unvegetated
sandy sediments and sited through diver-assisted placement on the sea floor when
deployed.
(2) The NPDES permit will include mitigation measures requiring 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 August 2, 2019, EFH assessment includes a determination that issuance of the NPDES and
Section 10 permits for the Kampachi Farms project will not result in substantial adverse effects
on EFH. We concur with the EPA's determination in the EFH assessment. Therefore, NMFS
has no EFH conservation recommendations to provide. Assuming the NPDES and Section 10
Permits are not further 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.
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.
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
Sincerely,
Virginia M. Fay
Assistant Regional Administrator
Habitat Conservation Division
cc: File
2
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Appendix F
-------
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.
-------
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
S3'15W
83"10'W
Florida, USA
0 50 100 km
Z
in _
Scale: 1:100,000
1.6 nm
Layer Credits. Sources: Esn. GEBCO, NOAA, National Geographic.
HERE, Geonames org, and other contributors
Bathymetry (m)
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
(B) 24-m depth
(C)36-m depth
Curr««l v*lecrty
[tm/j)
¦ '60 1
¦ JO 1-60.0
¦ 40 1-500
30.1-40.0
¦ 20 1 - 30.0
¦ 10 1 - 20.0
¦ 0.0-10.0
Currant velocity
(tmi's)
¦ >60 1
¦ 50.1 -80.0
¦ 40 1-50.0
¦ 30.1-40.0
¦ 20.1-30.0
¦ 10 1-20.0
¦ 0.0-10.0
Current velocity
{cmi's)
¦f 3-601
¦ 50 1-60.0
¦ 40.1-50.0
30 1-40.0
¦ 20.1-30.0
¦ 10.1-20.0
¦ 0 0-10 0
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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80
70
60
50
bJO
a
i 40
30
20
10
a « B i
250m 500m
12
11
10
9
8
7
Organic
6
Carbon
[g/m2]
5
4
3
2
1
10
20
30
60
70
80
40 50
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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um 250m 500 m
12
11
10
9
8
7
Organic
6
Carbon
(g/m2]
5
4
3
2
1
40
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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^OATMOS^
CASS Technical Report
^rtoENT OF ^
Addendum: 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 Kip Tyler (EPA), September 23, 2020
This report is submitted as an addendum to the report "Environmental Modelling to Support NPDES
Permitting for Velella Epsilon Offshore Demonstration Project in the Southeastern Gulf of Mexico" of
August 2018. The Environmental Protection Agency (EPA) is preparing to issue an NPDES permit for
the Velella Epsilon Offshore Demonstration Project. The applicant, Kampachi Farms, LLC (now
Ocean Era, Inc.), proposes to develop a temporary, small-scale demonstration net pen operation to
produce a single cohort of Almaco Jack (Seriola rivoliana) at a fixed mooring located on the West
Florida Shelf, approximately 45 miles offshore of Sarasota, Florida. With this addendum, scientists
from the NOAA Coastal Aquaculture Siting and Sustainability (CASS) program continued to work
with the EPA NPDES permitting program to develop estimates of farm discharge deposition on the
seabed and surrounding benthic community. Specifically, the farm simulation was executed for five
years at the maximum stocking density, with the predicted feed and fish waste daily contributions. The
most recent version of DEPOMOD modelling software (i.e., NewDEPOMOD) was used to calculate
the distribution and deposition of solid materials at the project location.
Current data were obtained from NOAA Buoy Station 42022 along the West Florida Shelf at the 50-m
isobath and located 45 miles northwest of the project location (27.505 N, 83.741 W). The buoy is
owned and data are collected by the University of South Florida Coastal Ocean Monitoring and
Prediction System with support from the U.S. Integrated Ocean Observing System. Lacking five
continuous years of water column flow data at the site, a single year of current data from the original
simulation was used to produce the assumed current profile at the project location. Given that single
year current data was used for this model, year-to-year variability in oceanographic patterns that are
associated with changing climate and weather patterns, water temperature, and storm tracks (e.g.,
hurricanes) are not evaluated.
As previously reported, bathymetric data were obtained from the NOAA Coastal Relief Model.
Bathymetry was resampled to 25 x 25 meter grid cells using a bilinear interpolation to all, for use
within the deposition model. The characterization of the site and composition of benthic surfaces were
informed by U.S. Geological Survey offshore surficial sediment data (usSEABED) that describes
seabed characteristics, including textural, geochemical, and compositional information for the Gulf of
Mexico. The benthic surfaces for the project location were also informed by acoustic survey and sub-
bottom profile data included with the applicant's Baseline Environmental Survey (BES). Sediment
samples, including core or grab samples, were not collected or analyzed as part of the BES. Without
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knowing explicitly the hydraulic roughness of the benthic surface at the project location, the model
was run (as previous) with the assumption of a smooth benthic surface characteristic of unconsolidated
sediments (coarse to fine grain sand bottom) such as those common on the West Florida Shelf.
Modelling with a smooth benthic surface and reduced roughness tends to lower the bed shear stress
and increase resuspension.
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). The model domain also remained as reported. The model domain was
set to encompass the whole initial depositional footprint under average current velocities estimated at
20 cm/s and with particles settling at rates faster than 0.75 cm/s. The dimensions for the model domain
are standards required by the Scottish Environmental Protection Agency for marine aquaculture
operations. The domain also captures reasonable efficiency in processing large data sets or long time-
series data (i.e., model requires 24-36 hours to process). The predicted carbon deposition and
magnitude of biodeposition were estimated over a 2.04 km by 2.04 km evaluation grid. The grid is
partitioned into square cells with sides measuring 24.87 m and cells numbering 82 east-west by 82
north-south with cells identified as 1-82 in both directions. The modelling software reports the average
solids and carbon within each cell as grams per square meter at the moment it is queried, typically at
the end of the simulation period.
This model execution did 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 from the net pen
operation. Each simulation assumed maximum standing biomass each day of the simulation with fecal
settling and food settling velocities applicable to salmon production at 3.5 and 9.5 cm/s, respectively.
The values for fecal settling velocity may have implications for dispersion. For this study, a
conservative settling velocity (3.5 cm/s) was used to assess the maximum extent of fecal deposition on
benthic surfaces. Knowledge of the physical properties of fish feces under net pen conditions is
rudimentary. Most reported literature addresses the fecal stability, density, and settling velocity (3.5
cm/s) of farmed salmon (Reed et al. 2009). Data on fecal settling velocity for Ambeijack (Seriola spp.)
are scarce. Amberjack feces are shapeless and unstable in the water column (e.g., lacking
cohesiveness). The species has a reported fecal settling velocity of about 1.6 cm/s owing to its smaller
size and density (Fernandes and Tanner 2008).
The model was run for 1,825 days assuming a net pen with a constant daily standing biomass at
36,288 kg (22.85 kg/m3) and a daily feed rate of 1.1 percent of biomass or equivalent to 399 kg of
feed. Standard feed waste was estimated at 3%. The model simulates release of fecal and feed particles
from a net pen at hourly increments. Multiple particles are released representing different mass
percentages and different settling velocities defined in the set-up files. The particles are all tracked
throughout the domain at each time step over the duration of the simulation. Particles that are
transported out of the domain boundary at 1,020 m away at the closest, are lost and removed from the
calculations. Only masses of material that remain in the domain at the moment a surface is queried and
2
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recorded are reported. At high current velocity sites, such as this project location where the average
flow is 13 cm/s and peaking at 67 cm/s at 4 meters above the seabed (Figure 1), the bulk of settleable
solids from the aquaculture operation are dispersed outside of the simulation domain. It is expected
that these solids would continue to be oxygenated and transported along benthic surfaces downstream
where currents allow for deposition and resuspension. This particulate organic carbon would be
readily available and consumed by bacteria and benthic infauna.
SOFTWARE UPDATES
NewDEPOMOD (version 1.3, released July 2020) and previous versions of DEPOMOD are computer
models that have been developed by the Scottish Association of Marine Science to inform siting,
permitting, and regulation of marine fish farms. The model predicts the impact of farm deposition on
the seabed in order to optimize the operation of aquaculture sites to match the environmental capacity.
The Scottish Environmental Protection Agency has used the software for over a decade in direct
support of their aquaculture permitting standards.
NewDEPOMOD incorporates a range of features in its newest release including:
• improved predictive abilities for offshore aquaculture projects including the capacity to use
three-dimensional hydrodynamic flow field data;
• an updated and characterized resuspension process using data from an extensive set of field
measurements of erosion, resuspension and transport at farm sites;
• a new model framework for sediment deposition which allows the model to include varying
bathymetry; and
• a model that produces conservative estimates of the holding capacity of a proposed site that can
be tuned using data collected once a farm enters production to improve predictions, also useful
for planning expansion of an existing farm.
ESTIMATING DEPOSITION AND MASS FLOW TO THE BENTHOS
Mass flows of solids onto the seabed were estimated from the mass of cultured fish on the farm and
the specific rate, which they are fed (Table 1). We developed a model for a 1,296-m3 net pen1 with a
stocking density of 28 kg/m3, which will yield a biomass of 36,288 kg. An estimated 399.17 kg of feed
will be applied per day at a feeding rate of 1.1 percent of body weight. During permitting, the
applicants changed the net pen design to a larger volume, however the biomass within remained the
same at 36,288 kg which is the keystone value for the waste dispersion simulation.
1 After completion of modelling, it was noted by the EPA that minor changes occurred with submission of the Ocean
Era permit application. The net pen configuration changed as did the size of fish at harvest. The discrepancy in net
pen volume (1,296 m3 vs 1,588 m3] and fish size (1.8 kg vs. 2.0 kg), and the implications on model results are
negligible.
3
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With a feed moisture content of 9% and an estimated 3% food waste rate, the feed dry mass lost from
the net pen is: [ 399.17 kg feed * (100%-9% kg dry feed / kg feed) * 3% kg dry feed lost/kg dry feed]
= 10.89 kg dry feed lost to the environment each day, or 0.454 kg per hour.
Since the feed is measured as 49% carbon, the flux is: 10.89 kg dry feed wastage * 0.49 kg carbon/ kg
dry feed = 5.34 kg carbon per day from feed.
Similarly, for the fecal mass produced with the assumed 9% feed moisture and 85% utilization:
[(399.17 kg feed - 3% lost (11.97 kg)) * 15% fecal mass/mass of solid feed ingested * 91% kg solid
feed / kg feed] = 52.85 kg of fecal solids per day, or 2.2022 kg per hour.
Fecal matter is measured as 30% carbon and yields: 52.85 kg of fecal solids * 0.30 kg carbon / kg of
fecal solids = 15.85 kg carbon per day
Combining the flux masses for solids and carbon an estimated 63.74 kg of solids and 21.19 kg of
carbon are released into the environment each day from the demonstration project.
Table 1. Summary statistics for the Velella Epsilon Offshore Aquaculture Demonstration Project.
Farming parameter Value
Initial Total number 20,000 fish
Individual size at harvest 1.8 kg
Maximum biomass during growout 36,288 kg
Net pen density at harvest 22.85 kg/m3
Maximum daily feed rate 399 kg
Total feed used 66,449 kg
Feed conversion ratio 1.8
Table 2 reports the mass flows of solids and carbon from the Velella Epsilon Offshore Aquaculture
Demonstration Project within the simulation domain. The bulk of released solids and their carbon are
lost from the domain, carried into the far-field by currents. Comparing values of solids in Table 2, the
simulation predicts that 3.63% of the solids remain within the simulation domain after five years.
There are periods in the water flow cycles when solids accumulation is variable in the domain, as
illustrated in Figure 2. The masses on the final day approximate the average concentrations.
4
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Table 2. Mass flows of solids and carbon from the Velella Epsilon Offshore Aquaculture
Demonstration Project within the simulation domain at the end of 5 years.
Model Parameters and Simulation Results Value
Mass of feed applied (5 years) 728,481.60 kg
Mass of feed wastage (5 years ) 19,887.57 kg
Mass of feed wastage carbon (5 years) 9,744.89 kg
Mass of fecal materials (5 years) 96,454.61 kg
Mass of fecal carbon (5 years) 28,936.38 kg
Total mass dry solids released / day 63.75 kg
Total mass dry solids released / year 23,268.43 kg
Total mass dry solids released / 5 years 116,342.17 kg
Total mass carbon released / day 21.20 kg
Total mass carbon released / year 7,736.25 kg
Total mass carbon released / 5 years 38,681.27 kg
Solids balance (Total solids within domain after 5 years) 4,224.87 kg
% solids retained inside domain 3.63 %
% solids exported outside domain 96.37 %
Carbon balance (Total carbon within domain after 5 years) 1,406.13 kg
% carbon retained inside domain 3.64 %
% carbon exported outside domain 96.36 %
At the project location, water velocities are typical for currents along the West Florida Shelf. Figure 1
illustrates the water velocity at the Velella site at a depth of 36.7 meters or approximately 4.0 meters
above the seafloor. Currents at this project location will likely re-suspend feed wastes and fecal
materials transporting these solids across the seafloor. The simulation software calculates the
movement of the released solids using the particle characteristics, the nature of the seafloor, and the
velocity of the water body in the proximity of the seafloor.
5
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80
70
60
S 50
'V
J 40
o>
9-
a
20
10
0
0 20 40 60 80 100 120 140 160 ISO 200 220 240 260 2 SO 300 320 340 360
Time (d)
Figure 1. Water currents and flow velocity measured at 4 m above the seafloor.
Figure 2 illustrates the fate of the remaining solids within the domain over the five-year simulation,
calculated from the total mass of released solids, minus the total mass of solids that are exported out of
the simulation domain. The figure shows that over the five-year simulation solids on the seafloor
within the domain reach an equilibrium, at an average total mass of 4,013 kg. The leading edge of the
plot illustrates the point material accumulates on the seabed where it will eventually resuspend leading
to more material being transported away from the depositional site as currents reach the shear force
threshold. During the first days of operation little material was available for resuspension, all the
while, new material was being added at a constant 63.75 kg per day.
NewDEPOMOD reports distribution of solids as surface plots of either solids or carbon, it does not
distinguish between the sources of the carbon, either feed or fecal, and are combined. In Figure 3, the
distribution of carbon is plotted for the final hour of the five-year simulation. Within the software,
each surface plot generates its own scale to coincide with the colors on the map. The reader should use
caution when comparing plots.
6
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0 200 400 600 800 1000 1200 1400 1600 1800 2000
Time (d)
Figure 2. Predicted solids deposition beneath one net pen with a standing stock biomass of 36,288 kg
of Almaco Jack (Seriola rivoliana) after five-year farm simulation.
Figure 3 shows the carbon distribution over the 2,040 x 2,040 meter Velella simulation domain on day
number 1,830. The highest concentration of aquaculture sourced carbon on the site is 4.35 g/m2 Most
noticeable in this deposition prediction map is the wide distribution of carbon over 4 km2 with small
accumulations and no areas of excessive concentrations. 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 3.
This wide dispersion and low concentration of carbon created the average Infaunal Trophic Index (ITI)
score for this final overall benthic surface of 58.96 out of 60. As previously reported, a predicted ITI
of close to 60 suggests that the Velella project will not likely have a discernable impact on benthic
communities around the project location. Similar to other studies reporting ITI as a measure of benthic
impacts from net pen operations, we do not expect significant impact on sediment redox potential or
sulfide production. For example, Hargrave (2010) and Keeley et al. (2013) extensively documented
correlations among the carbon deposition rate, redox potential, hydrogen sulfide concentration,
interstitial dissolved oxygen, and ITI. We believe that the Velella project will present challenges for
monitoring and detecting environmental impacts on sediment chemistry or benthic communities
because of the circulation around the project location and the small mass flows of materials from the
net pen installation. As the simulation illustrates, the high energy environment at the site and the mass
7
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flow of materials equilibrates at a resident total mass of waste products at approximately 4,000 kg with
local masses never exceeding more than 43.4 g solids per square meter for a single sample point over
the 5 year simulation.
CONCLUSION
There are minimal to no risks to sediment chemistry or benthic ecology functions in the project area
from the operation of the net pen as described in the Ocean Era, LLC application for an NPDES
permit.
60
a
13
ti
o
£
80
70
60
50
40
30
20
10
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in uiaijiusiiiaiaiiHU
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Organic
3 Carbon
(g m- yr1)
Easting
Figure 3. Predicted benthic carbon deposition field beneath one net pen with a standing stock biomass
of 36,288 kg of Almaco Jack (Seriola rivofiana) after five years. Grey circle indicates center position
of the net pen. Axes indicate simulation cell numbers and carbon deposition mass is in grams.
8
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Table 3. 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 36,288 kg.
Carbon deposition
(g/m2/yr)
Occurrence
(N)
Frequency
(%)
0
1,508
22.43
0.1-1.0
4,526
67.32
1.1-2.0
559
0.08
2.1-3.0
111
1.65
3.1-4.0
16
<0.01
4.1-5.0
4
<0.01
REFERENCES
Fernandes, M. and J. Tanner. 2008. Modelling of nitrogen loads from the farming of yellowtail
kingfish Seriola lalandi (Valenciennes, 1833). Aquae. Res. 39: 1328-1338.
Hargrave, B.T. 2010. Empirical relationships describing benthic impacts of salmon aquaculture.
Aquae. Env. Inter. 1(1): 33-46.
Keeley, N. B., C. J. Cromey, E. O. Goodwin, M. T. Gibbs, and C. M. Macleod. 2013. Predictive
depositional modelling (DEPOMOD) of the interactive effect of current flow and resuspension on
ecological impacts beneath salmon farms. Aquae. Env. Inter. 3(3): 275-291.
Reid, G. K., M. Liutkus, S. M. C. Robinson, T. R. Chopin, and others. 2009. A review of the
biophysical properties of salmonid faeces:implications for aquaculture waste dispersal models and
integrated multi-trophic aquaculture. Aquae. Res. 40: 257-273
9
-------
Appendix: Time-series simulation of predicted benthic carbon deposition beneath one net pen
with a standing stock biomass of 36,288 kg of Almaco Jack (Seriola rivoliana). The reader should
use caution comparing plots. The software generates a new legend for each plot in the time
series. The scale and color ramp varies with each surface plot.
g cart)on/m2
g cart»n/m2
Day 450
10
-------
Appendix: Time-series simulation of predicted benthic carbon deposition beneath one net pen
with a standing stock biomass of 36,288 kg of Almaco Jack (Seriola rivoliana). The reader should
use caution comparing plots. The software generates a new legend for each plot in the time
series. The scale and color ramp varies with each surface plot.
Day 540
|
\
m
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X \ \ V
r
RJr+Lri.
IVf rJ
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ie • |
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g cart>on/m2
-4J -Si -21 -10 0
Depth (m)
ii
-------
Appendix: Time-series simulation of predicted benthic carbon deposition beneath one net pen
with a standing stock biomass of 36,288 kg of Almaco Jack (Seriola rivoliana). The reader should
use caution comparing plots. The software generates a new legend for each plot in the time
series. The scale and color ramp varies with each surface plot.
g cartx>n/m2
g carborVm2
Day 1260
%
yj
!¦
g carbon/m2
g carbon/m2
12
-------
Appendix: Time-series simulation of predicted benthic carbon deposition beneath one net pen
with a standing stock biomass of 36,288 kg of Almaco Jack (Seriola rivoliana). The reader should
use caution comparing plots. The software generates a new legend for each plot in the time
series. The scale and color ramp varies with each surface plot.
Day~1440
SffaftB I
3 ¦ 4
¥ *
g cartx>n/m2
-t} -SI -21
Depth (m)
Day 1530
^ m
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m
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g carbon/m2
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g caroon/m2
42 -31 -21 -10 0
Depth (m)
Day 1710
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r-. • > •
1 k ¦ Jr m J|
1 * * 1 L * .
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I A J 8
» si -te. tek
'
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g carbon/m2
llll
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13
-------
Appendix G
-------
Finding of No Significant Impact
Ocean Era, Inc. Velella Epsilon
National Pollutant Discharge System Elimination (NPDES) Permit
Ocean Era, Inc (formerly Kampachi Farms. LLC) (applicant) is proposing to operate and discharge from a pilot-
scale marine aquaculture facility in federal waters of the Gulf of Mexico (Gulf) and has applied for a National
Pollutant Discharge Elimination (NPDES) permit from the U.S. Environmental Protection Agency. Region 4
The applicant requested a permit and authorizations for the Velella Epsilon project, which is a single net pen
demonstration project for open ocean aquaculture of marine fin fish in federal waters of the Gulf. The applicant
needs an NPDES permit in order to operate and discharge from its proposed aquaculture facility in compliance
with the Clean Water Act (CWA).
The EPA is required to comply with the procedural requirements of the National Environmental Policy Act
(NEPA) when issuing NPDES permits under section 402 of the CWA for "new sources." as defined in section
306 of the CWA. The proposed facility does not meet the definition of a "new source" under section 306 of the
CWA and therefore, is exempt from NEPA compliance under section 511(c) of the CWA and is not subject to
NEPA analysis requirements. Nevertheless, as a matter of policy. EPA voluntarily used NEPA procedures for this
proposed action since the Agency determined that such an analysis would be beneficial. See 63 FR 58045 (Notice
of Policy and Procedures for Voluntary Preparation of National Environmental Policy Act Document. October 29,
1998). While the EPA voluntarily used NEPA review procedures in conducting the analysis for the NPDES
permit issuance, the EPA also has explained that "[t]he voluntary preparation of these documents in no way
legally subjects the Agency to NEPA's requirements" (63 FR 58046).
The environmental review process, which is documented by the enclosed final Environmental Assessment (EA),
indicates that no significant environmental impacts are anticipated from the proposed action. The NPDES permit
conditions include protective measures, and these measures are described in the EA and the final NPDES permit.
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. Accordingly, the
EPA is issuing this Finding of No Significant Impact (FONSI) to document this determination. Substantive public
comments received on the Velella Epsilon NPDES permit and EA and the responses to those comments are
included in the response to comment (RTC) document which is included in the final NPDES permit package and
administrative record.
(EPA).
MARY
WALKER
Digitally signed by
Responsible Official:
MARY WALKER
Date: 2020.09.30
13:50:34 -04'00'
Date:
Mary S. Walker. Regional Administrator
-------
Appendix H
-------
Florida Department of State
i *
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
-------
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
-------
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
-------
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,
Jessica McCawley
Director
jm/lg
-------
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
-------
Tvler. Kip
Holliman. Daniel: Schwartz. Paul: Ferrv. Rol: Wahlstrom-Ramler. Meghan
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 Epsilon Proiect.pdf
Stahl-FL Clearinqhouse-FL201901048510C.pdf
DHR Comments for 2018-6301-B Velella Epsion Project bv Kampachi Farms Offshore Aquaculture Gulf of Mexico
App. No. FL2019010485IPC 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 [mailto:Chris.Stahl@dep.state.fl.usl
Sent: Monday, February 25, 2019 2:11 PM
To: petersdl@cox.net
Cc: State_Clearinghouse; 'FWC Conservation Planning Services'; Sapp, Portia
Subject: State_Clearance_Letter_For_FL201901048510C_Velella Epsilon Project by Kampachi Farms,
Offshore Aquaculture, Gulf of Mexico, Florida
From:
To:
Subject:
Date:
Attachments:
February 25, 2019
-------
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
-------
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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