ENVIRONMENTAL AND WATER QUALITY MONITORING PLAN

FOR THE
CONSTRUCTION AND OPERATION OF AN OFFSHORE DOLPHIN
ENCLOSURE IN WATER BAY AT CORAL WORLD
ST. THOMAS, U.S. VIRGIN ISLANDS

REVISED JULY 2016

INTRODUCTION

The following is the proposed monitoring program for the construction of an offshore
dolphin enclosure at Coral World in Water Bay St. Thomas. This monitoring plan also
includes long-term monitoring of water quality and the marine environment. of the
dolphin facility. The purpose of this monitoring plan is to evaluate and minimize the
impact of the proposed construction and operation on marine water quality and the
benthic community. Coral World (VI) has been issued an Incidental Take Statement for
the ESA species within the potential impact area of the facility. Special monitoring is
proposed for those species which will occur during construction and throughout the
operation of the facility. The Biological Opinion (BO) has been issued to the USACOE
and they are responsible for the enforcement of the conditions within the BO during the 5
year monitoring period stipulated in the mitigation plan. Prior to the expiration of the
Corps permit, Coral World will modify their TPDES permit and incorporate the long-
term monitoring and reporting required by the BO and the ITS into the TPDES permit.

Coral World is proposing to construct an offshore dolphin enclosure in Water Bay. The
facility will consist of fixed docks and floating platforms, a double row of fencing and a
wave barrier.
The project has the potential to impact water quality both during construction and
operation of the facility. During upland construction soils will be disturbed and a
potential for sedimentation and erosion will be created. Sediment and erosion control
measures will be implemented and maintained during all upland construction activities.
The marine construction will consist of the driving of piles and the placement of docks
and fencing. The impact pile driving or vibra-hammer driving will have a minimal
potential for creating turbidity. However, when rock encountered it is possible that piles
may need to be socketed. Pile socketing greatly increases the potential for turbidity, and
creates large volumes of rock flour. Based on observations in the field and the
construction of the existing dock, only a very limited number of piles may require
socketing. These piles most likely would be in the hard bottom area west of the dock.
Turbidity barriers (silt curtains) will be installed surrounding all pile driving/socketing
activities. The curtains will serve not only to maintain turbidity created by pile driving
but will also contain floating debris within the project area. The turbidity barriers will be
properly installed and will extend to within 1 ft. of the seafloor where piles are driven. If
piles require socketing, curtains will extend to the seafloor.
There is an Acropora palmata within 30 ft. of the enclosure to the west and eight
Acropora palmata located to the east of the proposed structure. There are numerous
Orbicella complex corals within the footprint and surrounding the proposed facility as
well as a Dendrogyra cylindrus. It is imperative that water quality be maintained due to
the corals within the area including the large number of ESA listed coral species within
the potential area of impact. Initially, Coral World is proposing to develop and
interactive program that will commence with six breeding age Atlantic Bottlenose
dolphins. Overtime the number will expand to ten-twelve dolphins through acquisition
and breeding. To increase the number of dolphins from the initial 6, Coral World,
pursuant to a Special Condition in its CZM Permit, “must provide CZM with water
quality monitoring results for a twelve-month consecutive period. Parameters monitored
shall be consistent with Virgin Islands Class B Water Quality Standards as set forth by
the Division of Environmental Protection.” Currently water quality standards allow for
3NTU turbidity, standards are proposed to decrease the allowable turbidity to 1 NTU.
Coral World will adhere to the Class B guidelines when they change. The dolphins will
feed and will defecate within the pen and therefore will have an impact on water quality.
This plan includes increased monitoring as the number of dolphins increases to ensure
that impacts to water quality or the environment do not occur.
This monitoring plan includes monitoring to ensure that fecal coliform levels and nutrient
levels do not become elevated above the allowable limits within the facility or
immediately surrounding areas. As modeled, 6 to 18 dolphins are not reasonably
anticipated to result in elevated levels of fecal coliform or nutrients in the pen areas or to
the outlying bay (See Coral World EAR pp. 92-95). If levels increase above allowable
limits, Coral World will take steps to identify whether Coral World dolphins may be
acting as a possible source(s) and whether their potential contribution is the primary
cause for the elevated parameters.

ESTABLISHMENT OF BASELINE CONDITIONS AND SAMPLING POINTS

Prior to the start of any construction activities a baseline of existing conditions will be
assessed. Consistent with DPNR-DEP Water Quality Certificate No: WQT-13-0001
(dated November 19, 2012), and as outlined in this plan baseline samples will be
conducted over a two-month period. The sampling locations have been established to
encompass the area most likely to be potentially impacted during construction, and
operation of the proposed facility. The baseline samples sites are shown in Figure 1.
Baseline samples will be tested for temperature, salinity, dissolved oxygen secchi depth
and turbidity expressed as NTUs as well as fecal coliform and enterococci bacteria, Total
Kendal Nitrogen (TKN) and total phosphates. As part of the baseline sampling, sampling
during normal and storm conditions will be completed prior to project construction to
determine the natural range in turbidity and duration of elevated turbidity levels to which
corals in the area are naturally exposed. Samples will also be taken after large rainfall
events which result in an influx of runoff to determine the existing fecal coliform and
enterococci levels within the project area.

Because bacteria also concentrate in sediments, 3 baseline sediment samples will also be
collected and analyzed for fecal coliform, enterococci bacteria, TKN and total
phosphorus. These samples will be taken within the footprint of the proposed enclose
and to the east and west of the enclosure.
 DURING CONSTRUCTION

MARINE WATER QUALITY MONITORING

During the construction of the docks water quality at the stations in the vicinity of the
work will be sampled on a daily basis. Three water samples will be taken 10 meters
outside the turbidity barriers surrounding the area of work. Two control samples shown
in Figure 1 will also be sampled. Water quality will be sampled for temperature, salinity,
dissolved oxygen secchi depth and turbidity expressed as NTUs. Construction should not
have an impact on nutrients or bacteria so no sampling for those parameters will be
undertaken during construction.

Figure 1. Baseline and Control sampling locations.

ACTION TRIGGERS

During construction if the water samples show NTUs, secchi disk, temperature, or
dissolved oxygen readings outside the allowable regulatory limits, the reviewing agencies
and the applicant will be notified, in writing within 24 hours of the parameter
exceedance. The baseline samples will be utilized to determine if other parameters are
elevated above normal background levels. Controls will also be used to determine if the
readings are a result of natural phenomena or if the monitoring sample is elevated above
the ambient background as a result of the construction project.
If it is determined that the elevated turbidity is the result of the construction project, the
source of the elevated turbidity will be identified and methods worked out to abate the
degradation. Someone will be on hand at the construction site at all times who has the
authority to implement sediment control devices or other remedial actions, so that
problems can be resolved as quickly as possible. Once the source of the impact is
identified, steps will be taken immediately to abate that impact. The action that was taken
to resolve the issue, as well as confirmatory sampling data that the degradation has been
resolved will be included within the written report to the agencies and Coral World. A
monitor will be on site throughout the day during construction activities to ensure that
turbidity barriers are adequate maintain and that escaping sediments do not go unabated.

ENVIRONMENTAL MONITORING

Shading and barge impacts during construction is one of the greatest potential impacts of
the construction. In order to minimize these potential impacts, the barge will be
positioned as frequently as possible during construction in a footprint which will keep it
over the area with the least colonization. On weekends and during times when work is
not occurring the barge will be repositioned into this position. Once weekly the monitor
will survey the area surrounding the barge and look for bleaching of corals, sediment
impacts or any other impact. If any bleaching is noted the agencies and Coral World will
be immediately notified in writing within 24 hours of the discovery and the barge will be
moved more frequently to eliminate this impact.

Barge spudding is always of great concern. Clear footprints for spud placement will be
marked in the field by buoys and the barge will only be able to spud within these areas.
If the barge inadvertently spuds outside a designated area monitoring divers will
immediately document any impact the spudding event may have had and a report will be
prepared for the agencies which will accompany the weekly report. If ESA listed species
are impacted the incident will be documented and NMFS will be immediately notified as
to the take. The report will include the action which has been take to remediate the
impact. Monitoring of the area of impact will be undertaken to ensure the recovery of the
area.

As the barge leaves an area permanently the area will be surveyed to determine to
whether backfilling of holes or other stabilization of substrate is needed to allow natural
recovery of benthic habitat. Deep spud holes’ act as traps for marine mollusk such as
conch and hermit crabs, and create unstable area into which adjacent coral colonized
rocks and fall and result in burial of corals.

Photoquadrats

Marine fauna and flora will be monitored on a regular basis during construction. Greatest
emphasis will be placed on monitoring of coral health and benthic community species,
and potential impacts potentially resulting from construction activity. Corals and the
benthic community are of focus given 1) the present threatened status of the three
identified coral species present; 2) the relative sensitivity of corals and certain benthic
community species to changes in environmental conditions; and 3) recognition that coral
health and benthic community health provides an integrated, direct measure of potential
impacts to resident biota.

Twenty-five permanently marked modified meter square photoquadrats will be

established both around and inside the enclosure (Figure 2).

The quadrats will be selectively placed within the areas of potential impact to encompass
the greatest diversity of sessile organisms and flora, including coral and sponge species.
Quadrats will be positioned so they encompass the Acropora palmata, Dendrogyra
cylindrus, and Orbicella annularis) that are present both inside and outside the enclosure.
Quadrats will also be established within the seagrass beds.

Metal pins and or PVC marker will be inserted into the substrate to serve as markers for
the camera stand to insure the exact relocation of the photograph in repetitive samplings.
Organisms will be identified and quantified as to percent cover and health prior to the
commencement of development. The percentage of viable living coral tissue cover, coral
size coral color, presence or absence of an excessive mucus coat, algal over growth, and
sediment sloughing, will be used to determine health. Any diseased corals will be noted
and marked and watched for changes in health.

The quadrats will be established and monitored monthly for a period of two months prior
to the commencement of construction to establish a baseline.

The photoquadrats will be monitored on a monthly basis during in-water work. All
visible changes will be documented and reasons for these changes assessed. Coral health
will be evaluated as to changes in coral color, percentage of live tissue, amount of mucus,
amount of sediment on the corals, and amount of algal growth and grazing marks will be
noted. Reports will be provided that include photographs and detailed survey
information containing the above listed parameters will be given to the Department of
Planning and Natural Resources (DPNR), the Division of Environmental Protection
(DEP), NMFS, COE and Coral World on a monthly basis.

Additional weekly surveys will be made by divers and immediately after any significant
turbidity plume is noted. Divers will dust corals if sediment coats are noted to minimize
impact.

If at any time any of the monitoring sites shows significant deterioration that does not
appear to be natural phenomena, DPNR, DEP and Coral World will be immediately
notified in writing in order that remedial measures can be implemented to prevent future
negative impacts. Within each quadrat the number and health of all benthic invertebrates
such as sea cucumbers, anemones, urchins and mollusk will be assessed as part of the
monitoring. If significant changes in numbers are noted the agencies will be immediately
notified. If a deterioration of health of any of the organisms are noted the agencies will
be notified immediately.
Special ESA Species Monitoring

Coral World (VI) has been issued an Incidental Take Statement under Section 7(b)(4) of
the ESA. Amount or extent of take NMFS anticipates is as follows:
• the lethal take of 8 lobed star coral colonies and the nonlethal take of 67 lobed star coral
colonies that will be transplanted from the in-water construction footprint to the Coral
World underwater observatory in Coki Bay.
• the lethal take of 60 lobed star, 79 mountainous star, and 11 boulder star corals from
declines in water quality associated with project operation.
• the take of 50 future elkhorn coral recruits from impacts to the essential feature of
elkhorn and staghorn coral critical habitat associated with declines in water quality
associated with project operation.
• the lethal take of 1 pillar star coral colony that will be transplanted from the in-water
construction footprint to the Coral World underwater observatory in Coki Bay.

Because the amount of take is specified that ESA corals within and immediately around
the pen will be individually monitored throughout the life of the project. Each ESA listed
coral will be tagged both within enclosure and within 50ft. of the outside of the
enclosure. These will be assessed for size and percent live tissue prior to any work at the
site and then will be monitored throughout the construction and life of the project.
During the sampling of the photoquadrats the individually marked ESA corals will be
each checked for viability, percent live tissue, coral and any indicator of disease.

Figure 2. Approximate location of monitoring quadrats both inside and outside the
enclosure.
REPORTING OF DATA

In the event of any emergency or noted degradation in any of the water quality
parameters above the allowable or acceptable limits, or any impact to the benthic
community the owner and the reviewing agencies will be immediately notified in writing
by e-mail. NMFS will be notified immediately of any impact to ESA listed species.
Weekly water quality reports and descriptions of the survey of the benthic community for
bleaching or impact will be delivered to all agencies and Coral World throughout the
monitoring period.

The Biological Opinion (BO) has been issued to the USACOE and they are responsible
for the enforcement of the conditions within the BO during the 5 year monitoring period
stipulated in the mitigation plan. Reports will be delivered to the COE through this
permit. Prior to the expiration of the Corps permit, Coral World will modify their
TPDES permit and incorporate the long-term monitoring and reporting required by the
BO and the ITS into the TPDES permit. Upon transfer of the enforcement to the TPDES
permit reports will be provided to DPNR, Division of Environmental Protection as part of
the TPDES reporting.

OPERATION MONITORING

Once the construction is completed and the dolphins are placed in the facility, monitoring
of the facility and the surrounding environment will continue throughout the operation of
the facility. Monitoring of water quality within the facility (e.g., main habitat area) will
be performed on a weekly basis for the first year when dolphins are present and then at a
lower frequency throughout the period of operation, consistent with Coral World’s
obligations for the care, treatment and housing of dolphins under the Animal Welfare Act
and USDA requirements and in order to assure the continued health of the benthic
community. Accordingly, monitoring within the facility throughout the period of
operation to insure dolphin welfare is separate from the scope of monitoring activities
described below. As presented, monitoring in areas immediately outside as well as
within the facility will be performed to insure protection of the surrounding marine
environment of Water Bay

MARINE WATER QUALITY MONITORING

Once the facility is operational, water quality in areas immediately bordering the facility
(i.e., sample locations 1, 2 and 3, and two identified control locations, shown in Figure 3)
will be sampled on the same day and timeframe for temperature, salinity, dissolved
oxygen, secchi depth and turbidity expressed as NTUs as well as fecal coliform and
enterococci bacteria, TKN and total phosphates. Sample location 4 in Figure 3 depicts
the within-facility sample. Samples will be obtained from locations 1 through 4 and the
control locations on a weekly basis for the first year of operation of the facility, during
the initial period of time six dolphins will be present, consistent with the 12-month period
of monitoring stipulated in the Special Condition of the CZM Permit and then throughout
the operation of the facility. Anytime additional dolphins are added water sampling will
be taken weekly for the first 3 months to ensure that no water quality degradation occurs.
If no degradation occurs water quality sampling will decrease to bi-weekly for the
following 6 months and then every 4 weeks (monthly) if no degradation of water quality
is noted. If degradation is noted methods must be undertaken to abate that impact
whether if be turbidity, nutrients or bacterial. Coral World will work with the monitor,
CZM, DEP, NMFS and COE to come up with method to abate them impact if the impact
cannot be abated the number of dolphins may have to be decreased to that at which water
quality standards can be maintained.
Should exceedances to allowable limits at the three locations bordering the facility (i.e.,
locations 1, 2 and 3) or within the facility be attributed to the operations, steps will be
taken to evaluate the source.
Measurements from monitoring locations 1 through 4 and the two control locations will
be obtained by using an EPA-approved instrument. Water samples from these locations
obtained for laboratory analysis of fecal coliform, enterococci and nutrients will be
collected, handled, processed and analyzed using EPA approved methods by technicians
who have passed annual proficiency testing in the EPA method. Every 10th sample a
duplicate must be collected and analyzed as a QAQC sample by an EPA certified
laboratory.

RESPONSE TO WATER QUALITY DEGRADATION

Because the health of the dolphins and surrounding environment is foremost in Coral
World operations, if water quality becomes degraded, and may negatively impact the
dolphins and/or the surround benthic community steps will be taken and this may include
isolating dolphins in separate areas using a pool liner in one or both of the smaller pools.
These liners as designed by the US Navy to protect their dolphins are a simple system
that isolates the dolphin’s water from the polluted water. The dolphins’ water will be
filtered by cartridge filter and treated with ozone. The skid mounted filtration system is
similar to the off the shelf system developed by Coral World vendor Emperor Aquatics
but will be custom designed to use ozone for the disinfectant produced by Del ozone
generators and will have cartridge filters to eliminate backwash discharge into the
ecosystem There will not be a backwash discharge into the environment. Chlorine will
not be used as a disinfectant. These small pools developed for the US Navy marine
mammal program are capable of supporting Dolphins for several weeks in emergency
situations. Once the dolphins are removed it can be determined whether or not the
dolphins are responsible for the elevated bacterial readings.
If it is determined that the dolphins are responsible for negatively impacting the water
quality, overfeeding or other contributing issues will be evaluated and appropriately
addressed. DPNR, DEP, COE and NMFS will be informed and involved in the solution.
Figure 3. Location of sampling stations.

During the operation of the facility periodically the dolphins maybe administered
antibiotics. Antibiotics can have a negative impact on the marine environment. If
antibiotics are given to the dolphins long-term (more than 2 weeks), samples must be
taken and analyzed for the present of the antibiotic within the water column. It may be
necessary to isolate the dolphin during treatment with antibiotics if antibiotics are found
in the water column.

ENVIRONMENTAL MONITORING

Once construction is complete monitoring of the photoquadrats will continue on a

monthly basis for the first year of the operation and then on a 6-month basis for the
duration of the operation of the facility. Any time an increase in dolphins occurs
photoquadrats will be monitored on a monthly basis for the first 3 months after the
introduction to look for changes in coral health, if no changes are noted over the 3
months of monitoring, monitoring will drop back to the semi-annual frequency. The
reason for the changes will be assessed and methods determined to abate the impact.
Worse case a limit may be required on the number of dolphins within the enclosure.

If impacts are noted the area of impact will be monitored on a monthly basis until such
time the area recovers or coral health becomes stable. If possible additional measures
will be undertaken to ensure the corals recovery, such as dusting of sediment or re-
stabilizing the coral. Any potential measure will be discussed with NMFS before it is
undertaken.
 ESA SPECIES MONITORING

As that Coral World has an Incidental Take Statement they are required to monitor the
potential take of the ESA listed species. The ESA listed species which were tagged prior
to construction will continue to be monitored when the photoquadrats are monitored
throughout the operation of the project. At any time that any impact or degradation to
any of the individual corals are noted NMFS will be notified immediately.

If at any time that the number of species taken exceeds the allowable take and it is due to
operations at Coral World, consultation with NMFS may have to be re-opened.

SEDIMENT TESTING

Bacteria and nutrients are known to concentrate in sediments therefore on a monthly

basis for the first year of operation sediment samples will be collected and analyzed for
fecal coliform, enterococci, TKN and total phosphate. A sample will be taken inside the
enclosure and to the east and the west. These samples will be compare to the baseline
result collect prior to construction of the facility. If any of the parameters increase
methods will be implemented to abate the accumulation. This may include reducing
feeding volumes and or reducing the number of dolphins present in the pen if it is
determined that the increase is due to the facility. Other parameters will be utilized to
help determine if it is a result of the facility.

NUTRIENT AND BACTERIAL TESTING

Currently the area is effected by human and domestic (dogs) and agricultural (cattle,
horse, and goat) animal waste from the encompassing watershed.

If corals become diseased or distressed corals are found which are not indicative of is not
an easily identifiable coral disease such as black band or white band, or bleaching due to
a natural phenomenon (i.e. being found throughout the island), samples of mucus will be
collected for bacteria analysis. Bacteria have been found to accumulate in coral mucus at
higher levels than the surrounding water column and have longer survivability. (E.K.
Lipp et. al, 2002). Fecal bacteria have been collected in the mucus of Montastrea
annularis complex (now Orbicella) in often higher abundances than other coral species
(E.K. Lipp et al, 2002). Mucus samples will be collected and evaluated for fecal coliform
bacteria (Escherichia coli), which are present in the feces of warm blooded animals
(human and dolphin feces). While the fecal coliform bacteria may not be the direct cause
of the coral stress or disease it is an indicator that other pathogens may be present. If
fecal coliform is found within the mucus of the coral, bacterial source tracking will be
undertaken to determine if the fecal coliform is dolphin or human in origin.
 ACTION TRIGGERS

After the facility is operational, if the water samples show NTUs, secchi disk, salinity,
temperature, dissolved oxygen readings, fecal coliform, enterococci or nutrient levels
outside the allowable limits in Class B waters, or. if bacterial or nutrient levels as seen to
increase in sediments over baseline readings, the reviewing agencies and the applicant
will be notified, in writing, within 24 hours of the incident. For example, under Class B
waters, if fecal coliform measurements for sample locations within and immediately
outside the facility (i.e., sample locations 1 through 4) is found to be greater than 70
colonies/100ml, a tiered evaluation will be performed to determine the cause of the
exceedance and to determine steps for mitigation.
The tiered evaluation will consider a number of factors to evaluate the source and relative
contribution of the operation relative to non-operational, regional sources. This work is
needed to insure that mitigative steps implemented at the facility result in improvement in
conditions. The tiered evaluation will be as follows 1) laboratory data validation and
Chain-of-Custody inspection; 2) comparison of confirmed data to contemporaneously
collected control samples; 3) examination of any additional local water quality
monitoring station data if available (e.g., DPNR station VI-STT-19 which is taken
quarterly)); and 4) compilation and evaluation of potential non-point source loading
information, such as upland agricultural, WWTP and septic sources. If it is determined
that the elevation in fecal coliform levels is due to the operation of the facility the
agencies will be consulted and steps worked out with agency input to reduce bacterial
levels. If corals are effected and indicators of disease are noted. Bacterial will be
collected form the mucus of the coral and bacterial source tracking will be undertaken to
determine the source of the bacteria. And if the source is found to be related to the
dolphins the agencies will be immediately notified and steps take to reduce bacterial
levels.

REPORTING OF DATA

Reports will be delivered to DPNR (CZM/DEP), COE and NMFS on a monthly basis
providing the results of the data collected over the month. QAQC data from the EPA
approved laboratory will accompany the reports, consistent with the project specific
Quality Assurance Project Plan (QAPP).

References

Lipp, Erin K., Jennifer L. Jarrell, Dale W. Griffin, Jerzy Lukasik, Jennifer Jacukiewitz,
Joan B. Rose, 2002. Preliminary evidence for human fecal contamination in corals of the
Florida Keys, USA, Marine Pollution Bulletin 44 (2002) 666-670.