DRAFT
BIOLOGICAL EVALUATION
Kampachi Farms, LLC - Velella Epsilon
Marine Aquaculture Facility
Outer Continental Shelf
Federal Waters of the Gulf of Mexico
August 5, 2019
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U.S. Environmental Protection Agency
Region 4
Water Protection Division
61 Forsyth Street SW
Atlanta Georgia 30303
NPDES Permit Number
FL0A00001
US Army Corps
of Engineers®
U.S. Army Corps of Engineers
Jacksonville District
Fort Myers Permit Section
1520 Royal Palm Square Boulevard Suite 310
Fort Myers Florida 33919-1036
Department of the Army Permit Number
SAJ-2017-03488
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Table of Contents
1.0 Introduction and Federal Coordination 3
2.0 Proposed Action 4
3.0 Proposed Project 5
4.0 Proposed Action Area 7
5.0 Federally Listed and Proposed Threatened and Endangered Species and Critical Habitat 8
5.1 Federally Listed Threatened and Endangered Species 8
5.1.1 Birds 9
5.1.2 Fish 9
5.1.3 Invertebrates 10
5.1.4 Marine Mammals 11
5.1.5 Reptiles 12
5.2 Federally Listed Critical Habitat In or Near the Action Area 14
5.2.1 Birds 14
5.2.2 Reptiles 14
5.3 Federal Proposed Species and Proposed Critical Habitat 14
6.0 Potential Stressors to Listed and Proposed Species and Critical Habitat 15
6.1 Disturbance 15
6.2 Entangl em ents 15
6.3 Vessel Strike 15
6.4 Water Quality 16
7.0 Potential Effects of Action 19
7.1 Federally Listed Threatened and Endangered Species 19
7.1.1 Birds 19
7.1.2 Fish 19
7.1.3 Invertebrates 20
7.1.4 Marine Mammals 21
7.1.5 Reptiles 22
7.2 Federally Listed Critical Habitat 23
7.3 Federal Proposed Species and Proposed Critical Habitat 24
8.0 Conclusion 26
References 27
Appendix A - Cage and Mooring Detail 32
Appendix B - Location Area 33
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1.0 Inli-odiK'lion iiiul I'edoi'iil (oorriiniilion
In accordance with the Endangered Species Act (ESA) Section 7, interagency consultation and coordination
with the National Marine Fisheries Service (NMFS) and the U.S. Fish and Wildlife Service (USFWS) is required
to insure that any action authorized, funded, or carried out by an action agency is not likely to jeopardize the
continued existence of any listed species or result in the destruction or adverse modification of any designated
critical habitat (Section 7(a)(2)); and confer with the NMFS and USFWS on any agency actions that are likely
to jeopardize the continued existence of any species that is proposed for listing or result in the destruction or
adverse modification of any critical habitat proposed to be designated (Section 7(a)(4)).1
On November 9, 2018, the U.S. Environmental Protection Agency Region 4 (EPA) received a complete
application for a National Pollutant Discharge Elimination System (NPDES) permit from Kampachi Farms for
the point-source discharge of pollutants from a marine aquaculture facility in federal waters of the Gulf of
Mexico (Gulf). On November 10, 2018, the U.S. Army Corps of Engineers Jacksonville District (USACE)
received a completed Department of Army (DA) application pursuant to Section 10 of the Rivers and Harbors
Act for structures and work affecting navigable federal waters from the same marine aquaculture facility.
Given that the action of permitting the proposed project involves more than one federal agency, the EPA has
elected to act as the lead agency to fulfill the consultation responsibilities pursuant to the implementing
regulations of ESA Section 7.2 The USACE is a cooperating and co-federal agency for this informal consultation
request. The completion of the informal consultation shall satisfy the EPA's and USACE's obligations under
ESA Section 7(a)(2).
The EPA and the USACE (action agencies) have reviewed the proposed activity and determined that a biological
evaluation (BE) is appropriate. The BE was prepared by the EPA and the USACE to jointly consider the potential
direct, indirect, and cumulative effects that the proposed actions may have on listed and proposed species as
well as designated and proposed critical habitat, and to assist the action agencies in carrying out their activities
for the proposed action pursuant to ESA Section 7(a)(2) and ESA Section 7(a)(4). The EPA and the USACE are
providing this BE for consideration by the USFWS and the NMFS in compliance with the ESA Section 7.
The EPA and USACE are coordinating the interagency permitting process as required by the interagency
Memorandum of Understanding (MOU) for Permitting Offshore Aquaculture Activities in Federal Waters of
the Gulf,3 and conducting a comprehensive analysis of all applicable environmental requirements required by
the National Environmental Policy Act (NEPA); however, a consolidated cooperation process under NEPA is
not being used to satisfy the requirements of ESA Section 7 as described in 50 CFR § 402.06.4 The NMFS is a
cooperating agency for the NEPA analysis and has provided scientific expertise related to the BE and NEPA
analysis for the proposed action including information about: site selection, ESA-listed species, marine mammal
protection, and essential fish habitat. While some information related to the ESA evaluation is within the
coordinated NEPA document developed by multiple federal agencies, the attached BE is being provided as a
stand-alone document to comply with the consultation process under ESA Section 7.
1 The implementing regulations for the Clean Water Act related to the ESA require the EPA to ensure, in consultation with the NMFS and
USFWS, that "any action authorized the EPA is not likely to jeopardize the continued existence of any endangered or threatened species or
adversely affect its critical habitat" (40 CFR § 122.49(c)).
2 50 CFR § 402.07 allows a lead agency: "When a particular action involves more than one Federal agency, the consultation and conference
responsibilities may be fulfilled through a lead agency. Factors relevant in determining an appropriate lead agency include the time sequence
in which the agencies would become involved, the magnitude of their respective involvement, and their relative expertise with respect to the
environmental effects of the action. The Director shall be notified of the designation in writing by the lead agency."
3 On February 6, 2017, the Memorandum of Understanding for Permitting Offshore Aquaculture Activities in Federal Waters of the Gulf of
Mexico became effective for seven federal agencies with permitting or authorization responsibilities.
4 50 CFR § 402.06 states that "Consultation, conference, and biological assessment procedures under section 7 may be consolidated with
interagency cooperation procedures required by other statutes, such as the National Environmental Policy Act (NEPA) (implemented at 40 CFR
Parts 1500 - 1508) or the Fish and Wildlife Coordination Act (FWCA)."
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2.0 Proposed Action
Kampachi Farms, LLC (applicant) is proposing to operate a pilot-scale marine aquaculture facility (Velella
Epsilon) in federal waters of the Gulf. The proposed action is the issuance of a permit under the respective
authorities of the EPA and the USACE as required to operate the facility. The EPA's proposed action is the
issuance of a NPDES permit that authorizes the discharge of pollutants from an aquatic animal production
facility that is considered a point source into federal waters of the United States. The USACE's proposed action
is the issuance of a DA permit pursuant to Section 10 of the Rivers and Harbors Act that authorizes anchorage
to the sea floor and structures affecting navigable waters.
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3.0 Proposed Project
The proposed project would allow the applicant to operate a pilot-scale marine aquaculture facility with up to
20,000 almaco jack (Seriola rivoliana) being reared in federal waters for a period of approximately 12 months
(total deployment of the cage system is 18 months). Based on an estimated 85 percent survival rate, the operation
is expected to yield approximately 17,000 fish. Final fish size is estimated to be approximately 4.4 pounds (lbs)
per fish, resulting in an estimated final maximum harvest weight of 88,000 lbs (or 74,800 lbs considering the
anticipated survival rate). The fingerlings will be sourced from brood stock that are located at Mote Aquaculture
Research Park and were caught in the Gulf near Madeira Beach, Florida. As such, only F1 progeny will be
stocked into the proposed project.
One support vessel will be used throughout the life of the project. The boat will always be present at the facility
except during certain storm events or times when resupplying is necessary. The support vessel would not be
operated during any time that a small craft advisory in effect for the proposed action area. The support vessel is
expected to be a 70 ft long Pilothouse Trawler (20 ft beam and 5 ft draft) with a single 715 HP engine. The
vessel will also carry a generator that is expected to operate approximately 12 hours per day. Following harvest,
cultured fish would be landed in Florida and sold to federally-licensed dealers in accordance with state and
federal laws. The exact type of harvest vessel is not known; however, it is expected to be a vessel already
engaged offshore fishing activities in the Gulf.
A single CopperNet offshore strength (PolarCirkel-style) fully enclosed submersible fish pen will be deployed
on an engineered multi-anchor swivel (MAS) mooring system. The engineered MAS will have up to three
anchors for the mooring, with a swivel and bridle system. The design drawings provided for the engineered
MAS uses three concrete deadweight anchors for the mooring; however, the final anchor design will likely
utilize embedment anchors instead. The cage material for the proposed project is constructed with rigid and
durable materials (copper mesh net with a diameter of 4 millimeter (mm) wire and 40 mm x 40 mm mesh square).
The mooring lines for the proposed project will be constructed of steel chain (50 mm thick) and thick rope (36
mm) that are attached to a floating cage that will rotate in the prevailing current direction; the ocean currents
will maintain the mooring rope and chain under tension during most times of operation. The bridle line that
connects from the swivel to the cage will be encased in a rigid pipe. Structural information showing the MAS
and pen, along with the tethered supporting vessel, is provided in Appendix A. The anchoring system for the
proposed project is being finalized by the applicant. While the drawings in Appendix A show concrete
deadweight anchors, it is likely that the final design will utilize appropriately sized embedment anchors instead.
Both anchor types are included for ESA consultation purposes.
The CopperNet cage design is flexible and self-adjusts to suit the constantly changing wave and current
conditions. As a result, the system can operate floating on the ocean surface or submerged within the water
column of the ocean; however, the normal operating condition of the cage is below the water surface. When a
storm approaches the area, the entire cage can be submerged by using a valve to flood the floatation system with
water. A buoy remains on the surface, marking the net pen's position and supporting the air hose. When the pen
approaches the bottom, the system can be maintained several meters above the sea floor. The cage system is
sable to rotate around the MAS and adjust to the currents while it is submerged and protected from storms near
the water surface. After storm events, the cage system is made buoyant, causing the system to rise to resume
normal operational conditions. The proposed project cage will have at least one properly functioning global
positioning system device to assist in locating the system in the event it is damaged or disconnected from the
mooring system.
In cooperation with the NMFS, a protected species monitoring plan (PSMP) has been developed for the proposed
action to protect all marine mammal, reptiles, sea birds, and other protected species. Monitoring will occur
throughout the life of the project and represents an important minimization measure to reduce the likelihood of
any unforeseen potential injury to all protected species including ESA-listed marine animals. The data collected
will provide valuable insight to resource managers about potential interactions between aquaculture operations
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and protected species. The PSMP also contains important mitigative efforts such as suspending vessel transit
activities when a protected species comes within 100 meters (m) of the activity until the animal(s) leave the area.
The project staff will suspend all surface activities (including stocking fish, harvesting operations, and routine
maintenance operations) in the unlikely event that any protected species comes within 100 m of the activity until
the animal leaves the area. Furthermore, should there be activity that results in an injury to protected species,
the on-site staff would follow the steps outlined in the PSMP and alert the appropriate experts for an active
entanglement.5
The below information about chemicals, drugs, cleaning, and solid waste provides supporting details about the
proposed project:
Chemicals: The proposed facility has indicated they would not be using toxic chemicals, cleaners, or solvents
at the proposed project. The proposed project would use small amounts of petroleum to run the generator.
Spills are unlikely to occur; however, if a spill did occur they would be small in nature.
Drugs: The applicant has indicated that FDA-approved antibiotics or other therapeutants will not likely be
used (within any feed or dosing the rearing water) during the proposed project. 6 The need for drugs is
minimized by the strong currents expected at the proposed action area, the low fish culture density, the cage
material being used, and the constant movement of the cage.
Cleaning: The applicant does not anticipate the need to clean the cage for the short duration of the proposed
project. Should the cage system need cleaning, divers would manually scrub the cage surfaces with cleaning
brushes. No chemicals would be used while cleaning and any accumulated marine biological matter would
be returned to sea without alteration.
Solid Wastes: The applicant will dispose of all solid waste appropriately on shore.
5 A PSMP has been developed by the applicant with assistance from the NMFS Protected Resources Division. The purpose of the PSMP is to
provide monitoring procedures and data collection efforts for species (marine mammals, sea turtles, seabirds, or other species) protected under
the MMPA or ESA that may be encountered at the proposed project.
6 The applicant is not expected to use any drugs; however, in the unlikely circumstance that therapeutant treatment is needed, three drugs
were provided to the EPA as potential candidates (hydrogen peroxide, oxytetracycline dihydrate, and florfenicol).
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4.0
Proposed Action 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/
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5.0 Federally Listed ;iihI Proposed Threatened ;ind l.ndan»ered 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
KSA Slatus
Critical
Habitat Status
I'lili'iilial I'ApiiMiiv In
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
( nral S|htk-n Mn»l \Iminlanl 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
Potential Impacts
Considered
Potential Kliccl 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:
Pristidae) in the United States, 6(4), 1-5. Chondros.
Anderes Alvarez, B., andUchida, I. 1994. Study of hawksbill turtle (Eretmochelys imbricata) stomach content
in Cuban waters. Study of Hawksbill Turtle in Cuba (I), 27-40. Cuba: Ministry of Fishing Industry.
Backus, R. H., Springer, S., and Arnold, E. L. 1956. A contribution to the natural history of the white-tip shark,
Pterolamiops longimanus (Poey). Deep Research (1953), 179-184. doi:https://doi.org/10.1016/0146-
6313(56)90002-8
Bigelow, H., and Schroeder, W. 1953. Fishes of the Western North Atlantic: Sawfishes, Guitarfishes, Skates,
and Rays, Chimaeroids: Part 2. (J. Tee-Van, C. Breder, A. Parr, W. Schroeder, and L. Schultz, Eds.)
Bjorndal, K. 1980. Nutrition and grazing behavior of the green turtle, Chelonia mydas. Marine Biology (56),
147-154.
Bjorndal, K. 1997. Foraging ecology and nutrition of sea turtles. (P. Lutz, and J. Musick, Eds.) The Biology of
Sea Turtles.
Blue Ocean Mariculture, LLC. 2014. Final Environmental Assessment for a Production Capacity Increase at the
Existing Open Ocean Mariculture Site off Unualoha Point, Hawaii.
Bolten, A. B., and G. H. Balazs. 1995. Biology of the early pelagic stage - the 'lost year'. Pages 579-581 in K.
A. Bjorndal, editor. Biology and Conservation of Sea Turtles. Smithsonian Institution Press, Washington, DC.
BOEM (Bureau of Ocean and Energy Management). 2012a. Final Environmental Impact Statement: Gulf of
Mexico OCS Oil and Gas Lease Sales: 2012-2017 Western Planning Area Sales 229, 233, 238, 246, and 248,
Central Planning Area Lease Sales 227, 231, 235, 241, and 247. BOEM 2012-2019, Volume 1. BOEM Gulf of
Mexico OCS Region.
BOEM. 2012b. Final Programmatic Environmental Impact Statement: U.S. Department of Interior Bureau of
Ocean Energy Management Outer Continental Shelf Oil and Gas Leasing Program 2012-2017. BOEM 2012-
030.
Bonfil, R., Clarke, S., and Nakano, H. 2008. The biology and ecology of the oceanic whitetip shark,
Carcharhinus longimanus. In M. D. Camhi, E. K. Pikitch, & E. A. Babcock (Eds.), Sharks of the Open Ocean:
Biology, Fisheries, and Conservation (pp. 128-139). Blackwell Publishing Ltd.
Brongersma, L. 1972. European Atlantic Turtles. Zoologische Verhandelingen (121), 1-318.
Burke, V., Morreale, S., and Rhodin, A. 1993. Lepidochelys kempii (Kemp's ridley sea turtle) and Caretta
(loggerhead sea turtle): diet. Herpetological Review, 24(1), 31-32.
Byles, R. 1988. Satellite Telemetry of Kemp's Ridley Sea Turtle, Lepidochelys kempi, in the Gulf of
Mexico. Report to the National Fish and Wildlife Foundation.
Carr, A. 1987. New perspectives on the pelagic stage of sea turtle development. Conservation Biology 1(2): 103-
121.
Biological Evaluation
Kampachi Farms - Velella Epsilon
Page 27 of 33
-------
CeTAP. 1982. A characterization of marine mammals and turtles in the mid- and north Atlantic areas of the U.S.
outer continental shelf. Cetacean and Turtle Assessment Program, University of Rhode Island. Final Report
#AA55 1 -CT8-48 to the Bureau of Land Management, Washington, DC, 538 pp. 6
Compagno, L. 1984. Carcharhiniformes. Sharks of the World Species-An Annotated and Illustrated Catalogue
of Sharks Species Known to Date, 4(2). Food and Agriculture Organization of the United Nations .
Cortes, E. 1999. Standardized diet compositions and trophic levels of sharks. ICES Journal of Marine Science:
Journal du Conseil, 56(5), 707-717.
Davis, R.W., J.G. Ortega-Ortiz, C.A. Ribie, W.E. Evans, D C. Biggs, P. 11. Ressler, RB. Cady, R.L. Leben, K.D.
Mullin, andB. Wttrsig. 2002. Cetacean habitat in the northern Gulf of Mexico. Deep-SeaResearch49:12 1-142.
Eckert, S., Eckert, K., Ponganis, P., and Kooyman, G. 1989. Diving and foraging behavior of leatherback sea
turtles (Dermochelys coriacea). Canadian Journal of Zoolology, 67(11), 2834-2840.
Eckert, S., Nellis, D., Eckert, K., and Kooyman, G. 1986. Diving patterns of two leatherback sea turtles
(Dermochelys coriacea) during internesting intervals at Sandy Point, St. Croix , U.S. Virgin
Islands. Herpetologica, 42(3), 381-388.
Evgeny R. 2010. Mobulidae of the Indian Ocean: an identification hints for field sampling. IOTC Working
Party on Ecosystems and Bycatch (WPEB). Victoria, Seychelles, 27-30 October 2010.
EPA. 2016. Environmental Assessment for the National Pollutant Discharge Elimination System (NPDES)
General Permit for Eastern Gulf of Mexico Offshore Oil and Gas Exploration, Development, and Production.
904-P-16-001, July 2016.
Frick, J. (1976). Orientation and behavior of hatchling green turtles Chelonia my das in the sea. Animal Behavior,
24(4), 849-857.
Hansen, L., K. Mullin, T. Jefferson, and G. Scott. 1996. Visual surveys aboard ships and aircraft. Page 55-132
in R.W. Davis and G.S. Farigion, eds. Distribution and abundance of cetaceans in the north central and western
Gulf of Mexico: Final Report. Vol. II: Technical Report. OCS Study MMS 96-0027. Prepared by the Texas
Institute of Oceanography and the National Marine Fisheries Service. U.S. Dept. of the Interior, Minerals Mgmt.
Service, Gulf of Mexico OCS Region, New Orleans, La.
Hughes, G. 1974. Is a sea turtle no more than an armored stomach? Bulletin of the South African Association
for Marine Biological Research 11:12-14.
Jefferson, T.A. and Schiro, A.J. (1997) Distribution of cetaceans in the offshore Gulf of Mexico. Mammal
Review 27(l):27-50.
Kapetsky, J.M. and J. Aguilar-Manjarrez. 2007. Geographic information systems, remote sensing and mapping
for the development and management of marine aquaculture. FAO Fisheries Technical Paper No. 458. 125 pp.
Keinath, J., and Musick, J. 1993. Movements and diving behavior of leatherback turtle. Copeia, 4, 1010-1017.
LaBrecque E., Curtice C., Harrison J., Van Parijs S., Halpin P. 2015. Biologically important areas for cetaceans
within U.S. waters - Gulf of Mexico region. Aquatic Mammals 4:30-38
Lanyon, J., Limpus, C., and Marsh, H. 1989. Dugongs and turtles: grazers in the seagrass system. (A. Larkum,
A. McComb, and S. Shepard, Eds.) Biology of Seagrasses, 610.
Biological Evaluation
Kampachi Farms - Velella Epsilon
Page 28 of 33
-------
Limpus, C., and Nichols, N. 1988. The southern oscillation regulates the annual numbers of green turtles
(Chelonia mydas) breding around northern Australia. Australian Journal of Wildlife Research, 15, 157.
Limpus, C., and Nichols, N. 1994. Progress report on the study of the interaction of El Nino Southern Oscillation
on annual Chelonia mydas numbers at the southern Great Barrier Reef rookeries. Proceedings of the Australian
Marine Turtle Conservation Workshop. Queensland.
Lutz, P., and Musick, J. (Eds.). 1997. The Biology of Sea Turtles. Boca Raton, Florida: CRC Press.
Lutz, P., Musick, J., and Wyneken, J. (Eds.). 2003. The Biology of Sea Turtles. Volume II. Washington, D.C.:
CRC Press.
Marquez, M. 1994. Synopsis of biological data on the Kemp's ridley turtle, Lepidochelys kempii (Garman
1880). Miami: U.S. Department of Commerce, National Oceanic and Atmospheric Administration, National
Marine Fisheries Service, Southeast Fisheries Science Center.
Marshall, A., Dudgeon, L, and Bennett, M. 2011. Size and structure of a photographically identified population
of manta rays (Manta alfredi) in southern Mozambique. Marine Biology 158(5): 1111-1124. May 2011.
Mendonca, M., and Pritchard, P. 1986. Offshore movements of post-nesting Kemp's ridley sea turtles
(Lepidochelys kempii). Herpetoogica, 42, 373-380.
Meylan, A. 1984. Feeding ecology of the hawksbill turtle Ertmochetys imbricata: Spongivoy as feeding niche
in the coral reef community. Unpublished Ph.D. Dissertation. Gainesville, Florida: University of Florida.
Meylan, A. 1988. Spongivory in hawksbill turtles: a diet of glass. Science, 239, 393-395.
Meylan, A., and Donnelly, M. 1999. Status justification for listing the hawksbill turtle (Eretmochelys imbricata)
as critically endangered on the 1996 IUCN Red List of Threatened Animals. Chelonian Conservation and
Biology, 3(2), 200-204.
Miller, M., and Klimovich, C. 2017. Endangered Species Act Status Review Report: Giant Manta Ray (Manta
birostris) and Reef Manta Ray (Manta alfredi). Office of Protected Species. Silver Springs: NOAA.
Mortimer, J. 1981. The feeding ecology of the west Caribbean green turtle (Chelonia mydas) in
Nicaragua. Biotropica, 13(1), 49-58.
Mortimer, J. 1982. Feeding ecology of sea turtles. Biology and Conservation of Sea Turtles, 103-109. (K.
Bjorndal, Ed.) Washington, D.C.: Smithsonian Institution Press.
Mullin, K.D., and G.L. Fulling. 2003. Unpublished report. Abundance of cetaceans in the oceanic northern Gulf
of Mexico, 1996—2001, 35 p. Southeast Fisheries Science Center, 3209 Frederic Street, Pascagoula, MS 39567.
Nash, C.E., P.R. Burbridge, and J.K. Volkman (editors). 2005. Guidelines for ecological risk assessment of
marine fish aquaculture. U.S. Department of Commerce, NOAA Tech. Memo. NMFS-NWFSC-71, 90p.
NatureServe. 2019. NatureServe Web Service. Arlington, VA. U.S.A.
Available http://services.natureserve.org. (Accessed: 2019)
Norman, J.R., Fraser, F.C., 1938. Giant Fishes, Whales and Dolphins. W.W. Norton and Company, Inc., New
York, NY., 361 pp.
Biological Evaluation
Kampachi Farms - Velella Epsilon
Page 29 of 33
-------
NMFS. 2008. Biological Evaluation: Effects of continued operation of the non-longline pelagic fisheries of the
western Pacific on ESA-listed sea turtles and marine mammals. NMFS PIR, Honolulu, Hawaii. 32 pp. July,
2008.
NMFS. 2009. Endangered Species Act Section 7 Consultation on the Fishery Management Plan (FMP) for
Regulating Offshore Marine Aquaculture (OMA) in the Gulf of Mexico.
NMFS. 2013. Determination of the Need to Reinitiate ESA Section 7 Consultation for the Fishery management
Plan for Regulating Offshore Marine Aquaculture in the Gulf of Mexico (FMP).
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 Aquaculture 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 0648-XD961) July 2016
NMFS. 2017. US Atlantic and Gulf of Mexico Marine Mammal Stock Assessments - 2017 (Second Edition).
NOAA Technical Memorandum NMFS-NE-245.
Ogren, L. 1989. Distribution of juvenile and subadult Kemp's ridley sea turtles: preliminary results from 1984-
1987 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 manta rays and sharks to
cleaning stations on a coral reef. Marine and Freshwater Research. 61, 65-73. doi: 10.1071/MF08301
Paredes, R. (1969). Introduccion al Estudio Biologico de Chelonia mydas agassizi en el Perfil de Pisco. Master's
thesis, Universidad Nacional Federico Villareal, Lima.
Price, C.S. and J.A. Morris, Jr. 2013. Marine Cage Culture and the Environment: Twenty-first Century Science
Informing a Sustainable Industry. NOAA Technical Memorandum NOS NCCOS 164. 158 pp.
Roberts, J.J., B.D. Best, L. Mannocci, E. Fujioka, P.N. Halpin, D.L. Palka, L.P. Garrison, K.D. Mullin, T.V.N.
Cole, C.B. Khan, W.A. McLellan, D.A. Pabst, and G.G. Lockhart. 2016. Habitat-based cetacean density models
for the U.S. Atlantic and Gulf of Mexico. Scientific Reports 6:22615.
Rohner, C. A., Pierce, S. J., Marshall, A. D., Weeks, S. J., Bennett, M. B., and Richardson, A. J. 2013. Trends
in sightings and environmental influences on a coastal aggregation of manta rays and whale sharks. Mar. Ecol.
Prog. Ser. 482, 153-168. doi: 10.3354/mepsl0290
Schmidly, D. 2004. The mammals of Texas, revised edition. University of Texas Press, Austin.
Shaver, D. 1991. Feeding Ecology of Wild and Head-Started Kemp's Ridley Sea Turtles in South Texas
Waters. Journal of Herpetology, 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 Submergible Net Pen in Federal Waters West of the Island of Hawaii, State of Hawaii.
29 pp.
Biological Evaluation
Kampachi Farms - Velella Epsilon
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Simpfendorfer, C., Yeiser, B., Wiley, T., Poulakis, G., Stevens, P., and Heupel, M. 2011. Environmental
Influences on the Spatial Ecology of Juvenile Smalltooth Sawfish (Pristis pectinata): Results from Acoustic
Monitoring. PLOS One, 6(2). doi:https://doi.org/10.1371/journal.pone.0016918
Soma, M. 1985. Radio biotelemetry system applied to migratory study of turtle. Journal of the Faculty of Marine
Science adn Technology, 21, 47.
Standora, E., Spotila, J., Keinath, J., and Shoop, C. 1984. Body temperatures, diving cycles, and movement of
subadult leatherback turtle, Dermochelys coriacea. Herpetologica, 40, 169-176.
Stickney, R. 2002. Impacts of cage and net-pen culture on water quality and benthic communities. In:Tomasso
JR (ed) Aquaculture and the environment in the United States. US Aquaculture Society, World Aquaculture
Society, Baton Rouge, LA, p 105-118.
Thayer, G., Bjorndal, K., Ogden, J., Williams, S., and Zieman, J. 1984. Role of large herbivores in seagrass
communities. Estuaries, 7, 351.
USFWS. 2015. Status of the Species - Red Knot. Available from:
https://www.fws.gov/verobeach/StatusoftheSpecies/20151104_SOS_RedKnot.pdf
USFWS and NMFS. 1998. Endangered Species Consultation Handbook. Procedures for Conducting
Consultation and Conference Activities Under Section 7 of the Endangered Species Act. Available from:
http://www.nmfs.noaa.gov/pr/pdfs/laws/esa_section7_handbook.pdf
van Dam, R., andDiez, C. 1998. Home range of immature hawksbill turtles (Eretmochelys imbricata [Linnaeus])
at two Carribean islands. Journal of Experimental Marine Biology and Ecology, 220(1), 15-24.
Walker, T. 1994. Post-hatchling dispersal of sea turtles. Proceedings of the Australian Marine Turtle
Conservation Workshop 1994:79-94.
Waring, G.T, E. Josephson, C.P., Fairfield, and K. Maze-Foley (eds). 2006. U.S. Atlantic and Gulf of Mexico
Marine Mammal Stock Assessments. NOAA Technical Memorandum NMFS-NE- 194. Northeast Fisheries
Science Center, Woods Hole, Massachusetts 02543-1026. March.
Wenzel, F., D. K., Mattila and P. J., Clapham. 1988. Balaenoptera musculus 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.
Wiirsig B. 2017. Marine Mammals of the Gulf of Mexico. In: Ward C. (eds) Habitats and Biota of the Gulf of
Mexico: Before the Deepwater Horizon Oil Spill. Springer, New York, NY
Wyneken, J., Lohmann, K., and Musick, J. 2013. The Biology of Sea Turtles. Volume III. 457. Boca Raton,
London, New York: CRC Press.
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Appendix A - Cage and Mooring Detail
1)
Deadweight Anchors (concrete):
•
Three (3) anchors equally spaced
o 120m from mooring centerline
o 120 degrees from each other
•
Each @ 4.5m x 4.5m x 4.5m (91 m3)
•
Concrete friction factor = 0.5 on wet sand
•
Each has an effective weight of 217 MT
2)
Mooring Chain (Grade 2 steel):
•
80m length on each anchor
•
50mm (2") thick links
•
No load = 70m length of each on seafloor
•
Design load = some entirely off seafloor/
others completely on seafloor
3)
Mooring Lines (rope):
•
40m length on each chain
•
AMSTEEL®-BLUE
•
36mm (1 1/2") thick lines
4)
Spar Buoy w/ Swivel (steel):
5)
Bridle Lines (rope inside HDPE pipe):
•
Three (3) ~30m bridle lines (rope) from swivel to
spreader bar
•
AMSTEEL®-BLUE
•
33.3mm (1 5/16") lines inside HDPE pipe
6)
Spreader Bar (HDPE):
•
Header Bar {load bearing) connected to Bridle Lines
o 30m in length
o 0.36m OD DR 11 H D PE pipe
•
Side and Rear Bars (smaller load bearing)
o 30m in length
o 0.36m OD DR 17 HDPE pipe
Four (4) comer spar buoys
7) Net Pen Connection Lines (rope):
•
Four (4]
~13m connection lines (rope)
•
Connected from Spreader Bar to Net Pen Float Rings
•
AMSTEELS-BLUE
•
33.3mm (1 5/16") lines
8) Net Pen Frame Structure {HDPE):
•
Top Frame Structure
0
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
0
One (1) HDPE sinker ring
¦ 7.0m below Float Rings
¦ Connected to Net Ring
¦ ~ 0.36m OD DR 11 HDPE pipe
0
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
Q
4mm wire diameter
o
40mm x 40mm mesh square
Effective volume of 1,600m3
10) Shackle Point Connection (steel):
• One (1) ~0.13m2 shackle ptate
• Four (4) connection lines
o 12 mm in diameter x 10m in length
o Connected from shackle plate to HDPE sinker ring
• ~lm Grade 2 steel chain (32mm) connected to Floatation
Capsule
11) Floatation Capsule {steel):
• ~ 1.5m in diameter x~3.45m in length
• Effective floatation volume = 6m3
• ~3m Grade 2 steel chain (32mm) connected to Counter Weight
12) Counter Weight {concrete):
• ~ 1.1m in diameter x ~2.2m in length
• Effective weight of 5 MT
Biological Evaluation
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Appendix B - Location Area
VE Project - Modified Site B & Pen Placement
Ni>tex:
I iih uiI:
As-ELuii J ijckljie:
3*»10*
UIKD11 SO lid 1 Led
Sedinwnti
1 CcorriinnlM tire in fed
based dit ihe Floriiii Sink'
Plane Qnpnfinnte System,
W<«rt Jx*\c. North AmefMto
Dutwn af 1903 (NAD 83)
2 Dnfii collecSe-d by AFTIM
m August 14. 20.18 and
A 15, 2098
>"orion3l >"«< ?eajes1 Mague-iic .¦LaaciaLitii
Map 3c UnGwisal-ktaftHl Sediment
Thnknns Istipncdi
k^kiupucfai I' armni
VvMEvi t. |i vjI on
G wiphyskal Survev
i APTIM
HUM A
"251 S 3fll S«llh
i, i l. nw
Wum AJfTlM ium
Position
* Decimal • Latitude
E Decimal1 Longltuife
Decimal = Latitude
DecimalLongitude
Pertmeter |Km)
Area | Km3)
Modlfis
d Site B from BES Report
Upper
27' 7.36B53" H
¦33" 1345627 W
27.131143" N
53.224303" W
11.1571
7.7237
Upper Right
27* 7.83C7S* N
33" 11.63237' VV
27.130512" N
63.153672" W
Lower Riah"
27" 64333V n
33* 11.5924=' W
27.1C7230" N
63.154690" W
Lowe-' Lett
27" 6.50261" N
¦33" 13.52655' VV
27.1CS377" N
63.225442" W
Center
27' 7.11266 N
33" 12.58604 W
27.1185-^3" N
63.2C<9757" W
Targeted Subaet Area of Modified Sit® B from 8ES Report |3' to 10" Unconsolidated Sa-cf mental
Uc-oer _efl
27' 7.70607' N
33" 12271/12' VV
27.126445" N
63.204 50 2" W
52273
1.6435
Ucoef fjoft"
27' T.51D22' N
33" 11.65678' W
27.126E37" N
63.154278" W
Lowe-' Rtota
27" 6.77773' N
•33" 11.75375' W
27.112=62" N
63.155697" W
Lowe- .eft
27" 6.37631* H
33" 1242C32' W
27.114605" N
E3.2D7C05" W
Center
27" 7.34135' N
33" 12.02291' W
27.122365" N
S3.2C0332" W
Nodonal Net Peri P-lacem
-nt-3 within Mortified Site B
from BES Report
t
27" 7.54724' N
33* 11.35393' VV
27.125737" N
63.1 §7565" W
0.7353
Q.Q491
2
27' 7.1743f N
¦33" 11.32576' VV
27.1195-30" N
63.157095" W
3
27' 6.93530' N
33" 11.9478C W
27.115655' N
63.159130* W
4
27" 6.52579- H
33" 12X19175' W
27.1D8763" N
E3.2D153D" W
Biological Evaluation
Kampaclii Farms - Velella Epsilon
Page 33 of 33
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