CORAL TRANSPLANT AND BENTHIC MITIGATION PROGRAM

FOR THE CONSTRUCTION OF THE DOLPHIN FACILITY AT

CORAL WORLD
U.S. VIRGIN ISLANDS

PREPARED FOR

CORAL WORLD (VI)

PREPARED BY

BIOIMPACT, INC.
P.O. BOX 132 KINGSHILL
ST. CROIX, U.S. VIRGIN ISLANDS 00851

JULY 2016
 TABLE OF CONTENTS
I. INTRODUCTION
II. OBJECTIVES
III. SITE SELECTION
IV. SITE PROTECTION INSTRUMENT
V. BASELINE INFORMATION
VI. COMPENSATION FOR UNAVOIDABLE IMPACTS
VII. MITIGATION WORK PLAN
VIII. MAINTENACE PLAN
IX. ECOLOGICAL PEFORMANCE STANDARDS
X. MONITORING REQUIREMENTS
XI. LONG-TERM MANAGEMENT PLAN
XII. ADAPTIVE MANAGEMENT PLAN
XIII. FINANCIAL ASSURANCES

This plan follows the compensatory mitigation guidelines as set forth in 40 CFR Part
230, Compensatory Mitigation for Loses of Aquatic Resources: Final Rule. The
fundamental objective of compensatory mitigation is to offset environmental losses
resulting from unavoidable impacts to the waters of the United States authorized by DA
permits.
 CORAL TRANSPLANT AND BENTHIC MITIGATION PROGRAM
FOR THE CONSTRUCTION OF THE DOLPHIN FACILITY AT
CORAL WORLD
U.S. VIRGIN ISLANDS
REVISED JULY 2016

I. INTRODUCTION

The project area is located in Water Bay on the north side of the island of St. Thomas.
Water Bay was highly impacted by dredging activity which occurred in 1961, 1965 and
again in 1968. A study of the area suggested wide spread coral mortality in the bay as a
result of this activity (Sigma, 1975). Despite these past activities there are still dense
grass beds in the center of the bay in areas that were not dredge, there is a scattered
cobble/rock shoreline community which fringes the southern side of the point and there is
a healthy coral community which has colonized the hard rock bottom surrounding the
terminus of Coki Point. There is an Acropora palmata within the proposed buffer zone
and Acropora palmata colonies to the east of the existing pier just outside the project site,
and a single small Acropora palmata which has recruited within the enclosure these
corals were listed on the endangered species list in 2008. Both Orbicella annularis and
Dendrogyra cylindrus, which were listed on the federal endangered species list in
September of 2014, occur within the proposed enclosure and Orbicella annularis occurs
within the footprint of the enclosure and will require relocation. Approximately seventy-
five (75) Orbicella annularis will require relocation. One (1) Dendrogyra cylindrus lies
within the enclosure but it should not be impacted by the construction or operational
activities.

The enclosure will impact corals and sea grass which lie within the footprint of the
pilings and docks associated with the enclosure. The enclosure was designed to avoid the
areas of densest sea grass and the project has been significantly redesigned to reduce the
originally proposed 267 pilings to a newer design requiring only 114 pilings (going from
12” pilings to 16” pilings): 74 pilings within the area with scattered coral outcroppings, 6
pilings within areas with scattered corals within sparse to moderate sea grass beds, 26
pilings within areas with sparse sea grass to minimally colonized sand, 6 pilings within
the hard bottom, and 2 pilings within the sea grass Porites rubble area. The dock section
spans from the eastern shoreline have been increased from 20’ to 30’ sections. Since the
hard bottom is approximately 35 ft. in width at the area where the structure will cross,
only 6 pilings will be driven in the hard bottom area minimizing the overall impact on
critical habitat. Because of the presence of the hard bottom it is probable that the pilings
will have to be socketed. The reduction of the number of pilings minimizes the potential
water quality impacts.

The pilings which will impact sea grass in their footprints, will also create a halo due to
wave turbulence. Each piling will directly affect 1.25 sq. ft. of sea grass and each piling
will probably affect a maximum of 2.5 additional ft. due to water turbulence based on
halos seen around rubble and debris within the area. During storm events, additional
scouring could occur. The fencing will reach the seafloor and will also have an impact on
benthic resources, and the dock will directly shade 0.4 acres (17,424 sq. ft.) of benthic
habitat. It is probable that the enclosure will result in a loss of 0.05 acres (2178 sq. ft) of
sea grass. The structure will impact approximately 0.32 acres (13,929 sq. ft.) of scattered
coral habitat, 0.01 acre (436 sq. ft. of sea grass in Porites rubble, 0.01 acre (436 sq. ft.) of
hard bottom, and 0.02 acres (872 sq. ft.) of scattered sea grass and coral.

The vast majority of corals within the area of impact are not attached to bedrock, and it
will be possible to relocate these corals attached to their substrates. Even the coral
boulders of significant size can be moved utilizing lift bags. Only those corals attached
to the nearshore hard bottom will require removal from their substrate with a hammer and
chisel and where possible a portion of the rock will be broken free as well so that the
colonizing corals do not have to be removed from their substrates. In order to minimize
impacts from the construction corals and boulders will be relocated from an area of 10ft
width along the length of the main docks and the enclosure areas. Corals will also be
removed from spudding areas if corals cannot be avoided by the barge. It is anticipated
that all spudding areas can avoid corals. Based on the lay out of the docks and the
enclosure approximately 250 corals will require relocation, these corals include Orbicella
annularis, Siderastrea siderea, Diploria strigosa, Porites astreoides, Porites porites and
Pseudopterogorgia americana.

This plan proposes to transplant approximately two hundred and fifty (250) corals
including those within the footprint of the facility and those corals likely to be impacted
by the facility’s construction and use and 0.05 acres (2178 sq. ft.) of sea grass. To
provide compensatory mitigation for those impacts which are not avoided, Coral World
will install 3 informational buoys to protect shallow coral species, including listed species
from vessel strikes and anchoring, and will install 2 public moorings within Water Bay to
minimize anchoring impacts on seagrass.

REASON FOR MITIGATION

There are a total of 114 pilings: 74 pilings within the area with scattered coral
outcroppings, 6 pilings within areas with scattered corals within sparse to moderate sea
grass beds, 26 pilings within areas with sparse sea grass to minimally colonized sand, 6
pilings within the hard bottom, and 2 pilings within the sea grass Porites rubble area.

Pilings within the sea grass will create a halo due to wave turbulence. Each piling will
directly affect 1.25 sq. ft. of sea grass and each piling will probably affect 2 additional ft.
due to water turbulence base on halos seen around rubble and debris within the area.
Most of the scouring will occur during storm events. The enclosure fencing wills the
seafloor and will also have a direct and indirect scouring impact.

The dock will directly shade 0.4 acres (17,424 sq. ft.) of benthic habitat. It is probable
that the enclosure will result in a loss of 0.05 acres (2178 sq. ft.) of sea grass. The
structure will impact approximately 0.32 acres (13,929 sq. ft.) of scattered coral habitat,
0.01 acre (436 sq. ft.) of sea grass in Porites rubble, 0.01 acre (436 sq. ft.) of hard bottom
and 0.02 acres (872 sq. ft.) of scattered sea grass and coral.

Figure 1. The proposed facility.

Figure 2. Area of impact.

II. MITIGATION OBJECTIVES

It is the objective of this mitigation project to limit the amount of coral and coral habitat,
sea grass and sea grass habitat that is lost as a result of the facility construction. All of
the coral, sponge, sea grass and sessile life forms within the footprint of the facility or
which might be potentially impacted during construction or operation will be
transplanted. Approximately two hundred and fifty (250) corals including 75 ESA listed
species and sponges will be transplanted and approximately 0.05 acres (2178 sq. ft.) of
sea grass will be relocated.

III. SITE SELECTION

The recipient sites were selected due to their being similar environments and being close
to the mitigation site.

The coral relocation is to the north of the Coki peninsula and is the same habitat type as
the one from which the corals are being removed. The area contains the same coral and
sponge species as found within the impact area. The area is of the same depth and also
offers shoreline hardbottom of the same depths to reattach loose corals.

The seagrass transplant site is in close proximity to impact site and is an area which was
impacted by boat anchoring in the past.

IV. SITE PROTECTION INSTRUMENT

The coral recipient site is within the area currently leased by Coral World and protected
by buoys around the Coral World Observation Tower. This area is protected from boat
anchoring or groundings. Coral World will prepare documents which state that this area
will not be altered by Coral World during the operation of their facility and identifying
the area as a coral mitigation area. The seagrass transplant area is within the areas
which will be protected by buoys around the dolphin pens to prevent boats from
approaching the enclosure. Again this area is under lease by Coral World and Coral
World will designate in written documentation that this is a seagrass mitigation area and
no future impacts on the mitigation area will be proposed while Coral World holds the
lease.

V. BASELINE INFORMATION

GENERAL DESCRIPTION OF AREA TO BE IMPACTED

There is an existing dock extending from Coki Point and this dock serves as a dividing
line between the coral colonized bedrock to the east and the scattered coral outcroppings
to the west and colonized pavement. The coral colonized bedrock to the east extends off
shore between 20’ and 50’ moving towards the point. There are a few Acropora palmata
scattered within the shallows to the east of the dock and one Acropora colony in the
shallows within the proposed enclosure. To the west of the pier within the shallows there
are scattered boulders extending from the rocky shoreline and these enjoy sparse coral
colonization. Within this area there are scattered coral outcroppings primarily consisting
of Orbicella annularis, which is being listed on the endangered species list in May of
2012. These outcroppings are scattered in uncolonized sand, and uncolonized coral
rubble and vary in abundance and live tissue coverage. Moving westerly in the shallows
there is patch dense colonization by the algae Sargassum. Farther to the west the
sandy/cobbly bottom gives way to sea grass colonization, and the scattered coral colonies
are found within sparse to moderately dense Thalassia beds. There is a large area of
coral rubble (consist of primarily Porites porites rubble) toward the western end of the
proposed enclosure and it has scattered Thalassia growing between the small fragments.
An occasional live Porites fragment can be found within the rubble. Sea grasses become
denser to the west and to the south as the water deepens. In the deeper water, sea grasses
become denser to the west, but to the east there are areas where the grass becomes very
sparse and in areas completely die off. There is scattered Amphimedon compressa within
the sea grass beds. To immediate east of the dock coral colonization is minimal. Moving
more westerly off the dock the abundance of both hard and soft corals increase. Corals
noted within the project area include Orbicella annularis, O. franksi, O. faveolata,
Siderastrea siderea, Porites porites, Porites astreiodes,Diploria strigosa, Siderastrea
radians, Dendrogyra cylindrus, Agaricia agaricites,Diploria labyrinthiformis,Favia
fragum, Pseudopterogorgia americana, Gorgonia ventalina, Plexaura flexuosa and
Montastrea cavernosa.. Sponges within the area include Amphimedon compressa,
Ircinia felix, Aplysina cauliformis, Neofibularia nolitangere, Verongula rigida and
Aplysina insularis. There are numerous large Siderastrea siderea heads within the
shallows immediately along the shoreline. Algae is abundant especially in the shallow
coral areas, noted were Caulerpa, Sargassum, Udotea, Halimeda, Penicillus, Dictyota
and Laurencia. The ESA listed Orbicella species which must be relocated range in size
from 1ft2 with 2 to 3 lobes, to 3ft2 with 10 or more lobes.

VII. MITIGATION WORK PLAN

CORALS

Prior to the start of the relocation project the footprint of the facility and the predicted
impact zone will be marked on the seafloor using small pin flags. Any coral or boulder
which partially extends into this zone will be relocated.

Divers will measure each individual Orbicella, as to width and height and number of
lobes within the colony. The percent of live tissue on each colony will be recorded and
each coral will be numbered for future monitoring with a cattle tag attached to an area of
dead tissue so it cannot impact live tissue. These tags will be maintained throughout the
five-year monitoring period.
Individual corals that are attached to the near shore hardbottom will be removed with
chisels. This includes several small head and plate corals. The corals in this area range
in size from under 6” to a maximum of 1.5ft2. These corals will be collected in bins and
carried to the transport tray and relocated to the north side of the point. These corals will
be transplanted onto the nearshore hardbottom to the east of the tower. These corals will
be fixed in placed in their new locations with two-part underwater epoxy, which sets in a
matter of minutes (Splashzone). The base of the coral will be carefully cleaned with a
wire brush and the new substrate will be cleaned to remove algae and any other material
which might interfere with the adhesion of the epoxy or cement. The coral will be
carefully placed and held until the epoxy or cement starts to set.

Divers will then collect those corals and sessile invertebrates that colonize cobbles and
rocks within the facility footprint that are of a small enough size to allow hand carrying.
These are cobbles and boulders that are in a range of 1ft2 to 2.5ft2. These corals are
usually growing on pieces of coral rubble which have been partially buried in the sand
and have become stable. Divers will wear disposable gloves while working with corals
minimize touching live tissue and keep any coral that appear unhealthy or diseased away
from other corals. Corals which appear to be diseased will be marked, and not
transplanted to the recipient area to minimize the potential of the spread of disease to the
recipient site. The diseased corals will be photographed and will be addressed in the
baseline report for the transplant identifying the size and location of each individual
colony. If a coral is handled that appears unhealthy or diseased gloves will be changed
prior to working with other corals. The 1ft2 to 1.5ft2 corals will be placed in underwater
bins and carried by divers to the transport tray. The larger corals will be placed directly
on the tray. Once the tray is full it will be lifted beneath the boat and at idle speed carried
to the relocation site. The relocation site is on the north side of Coki Point within the
area currently protected by the enclosure around Coral World’s underwater observation
tower. Once on site the tray will be lowered near the seafloor and divers will remove the
corals from the tray. The coral will be placed in the recipient site in such a fashion that
the rock is stable and will not be subject to movement. This will be done by digging a
depression in the sand to rebury the base to the same depth as it was prior to transplant.
Care will be taken to make sure no live tissue is buried or too close to the sand that it may
become buried. If possible if hard substrate or other larger rocks or rubble is found the
coral base will be attached to it with “Splashzone” two-part underwater epoxy. Care will
be taken so that these transplanted materials will not impact existing organisms at the
transplant site.

Splashzone epoxy is used because it is approved for drinking water systems by EPA.
This epoxy does not leach any harmful chemicals into the water. This epoxy also does
not create the temperature change which occurs with hydraulic cement.

For corals and larger coral colonized rocks, those greater than 2.5ft2, lift bags, and ropes
will be utilized. divers will lift and transport larger corals, and coral colonized rocks then
slowly carry the organisms to the transport tray. Again when the tray is full it will be
lifted beneath the boat and at idle speed proceed to the recipient site. When attaching the
corals to the lift bags ropes will be placed so that they avoid live coral tissue. If
necessary, a plate may be placed underneath corals so that it lifted without the tissue
being impacted by the ropes. The coral boulders and larger rocks will be placed in the
recipient site in such a fashion that the rock is stable which may require some excavation
into the sand to create a depression for the previously buried part of the rock. Care will be
taken so that these transplanted materials will not impact existing organisms at the
recipient site. Care will be taken to place corals in the same orientation and depth as they
were in their original locations.

SEA GRASS

The potential area of sea grass impact will be delineated on the seafloor and all the sea
grass within this area will be transplanted to an uncolonized area to the southwest within
the bay.

Two methods of sea grass transplant will probably be utilized since the consistency of the
substrate within the bay varies. If the substrate is very coarse and sandy, the sea grasses
rhizomes will be carefully removed from the sand in as long of runners as possible. Care
will be taken to not break hair roots and rhizomes. These runners will be collected in
large baskets and carried to the recipient site. Once at the recipient site trenches will then
be excavated for the rhizomes and the grasses will be carefully replanted with care taken
to make sure the rhizomes are sufficiently buried. Sea grass staples (lignin-based so that
they will biodegrade over time) will also be used to help stabilize the new runners in
place.

Where the sediment is found to be of a sufficient consistency to be relocated with the

grass, large sodding squares will be cut from the beds and the sodding units will be
placed on large metal trays (8’x4’) and carried utilizing lift bags to the recipient site
where they will be placed in depressions excavated to receive them. The sea grasses will
be covered during transport to avoid grass and sediment loss. The planting units will be
planted abutting one another to aid in the stability of the newly planted bed. Sea grass
staples (lignin-based) will be utilized to stabilize the planting units.

Both of these methods have been found to be very successful in previous transplanting
efforts.

COMPENSATORY MITIGATION

To mitigate for impacts that cannot be avoided Coral World will be installing 3
information buoys that will serve to protect shallow water corals, including listed species,
from impacts by vessel strikes and anchoring. Figure 3 below documents the location of
the proposed buoys. Two of the buoys will be placed along Coki Point one near the
terminus and one near the shoreline where there is a cluster of Acropora. These buoys
will state “Warning – Shallow Coral”, approximately 1500m2 (0.37 acre of hardbottom
habitat will be protected. The third informational buoy will be placed on Turtle Rock;
this rock is periodically hit by boaters (including jet skiers). The marking of this are with
a buoy stating “Warning Shallow Coral” will protect more than 100 m2 (0.025 acre) of
shallow coral colonized hardbottom habitat.

Coral World will place and will be responsible for the long-term maintenance of these
buoys for the live of the dolphin exhibit. If at any time they become damaged or are lost
they will be replaced. Coral World will check the tackle for the buoys on an annual
basis.

Coral World will also place two public mooring in Water Bay, these day moorings can be
picked up by boaters. These will be first-come first serve, and will specifically state no
overnight mooring. This will protect the seagrass beds from anchor damage. Boat
anchoring and mooring can impact from between 3 and 300m2 depending on water depth,
how the anchor/mooring is deployed, and the effect of wind and wave action on the vessel
(Walker et al ,1989, Hasting et al 1995). Based on the existing halo’s visible on Google Earth
from mooring and anchors in the bay, the two moorings will protect between 70 and 100m2
(0.017-0.025 acre) of seagrass and benthic habitat apiece for a combined protection of 140 to
200m2 (0.034-0.05 acre).

Coral World will place and will be responsible for the long-term maintenance of these
mooring buoys for the live of the dolphin exhibit. If at any time they become damaged or
are lost they will be replaced. The mooring buoys will be inspected on an annual basis.
Figure 3. Location of Recipient Sites

VIII. MAINTENACE PLAN

Divers will survey the recipient site on a bi-weekly basis for the first 2 months after the
transplant to ensure that the corals have not become unattached or shifted. If for any
reason the corals become loose or move they will be re-situated and or reattached. After
the first two months the corals will be monitored on a monthly basis for the first year and
then on a bi-monthly basis for the following 2 years then every 6 months for year 4 and 5
after the transplant. During each monitoring event divers will make sure that the rocks
have remained stable and not shifted, and that corals and sponges have not come loose.
If necessary corals will be repositioned and re-attached.

Divers will survey the sea grass recipient site on a bi-weekly basis for the first 2 months
after the transplant to make sure the seagrasses have not become uprooted. After the first
2 months the seagrass wll be monitored on a monthly basis for the remainder of the first
year, and then on a bi-monthly basis for the following year and then every 6 months for
the following 3 years. During each monitoring activity divers will make sure that the sea
grass has not become uprooted and will re-bury sea grass that has become loose from the
substrate.

IX. ECOLOGICAL PEFORMANCE STANDARDS

The object of this mitigation is to minimize impact to benthic resources which provide
high quality habitat to marine species. In order to objectively evaluate the mitigation
project, ecological performance standards must be established. The performance
standards will include viability of the transplanted corals and sponges and relocated
seagrass.

It is the intent of this transplanting program to obtain a minimum of 80% survival of the
transplanted corals and sponges and seagrasses. Coral World (VI) is committed to put
forth the greatest effort to see that the relocation is successful and that they obtain the
greatest potential survival of transplanted organisms.

Coral World (VI) has received an Incidental Take Statement for the ESA listed species, if
more take of ESA-listed corals occurs than is estimated in the ITS, consultation will have
to be reinitiated. If the success criteria of 80% survival of transplanted corals and
seagrasses is not met, Coral World (VI) will work with NMFS and COE to develop
contingency measures and additional mitigation for the corals and seagrass
transplantation goal which was not met.

Coral World (VI) has been issued the following Incidental Take Statement under Section
7(b)(4) of the ESA which specifies the amount and impact of any incidental take on listed
species, which results from action otherwise found to comply with Section 7(a)(2) of the
ESA. Take is defined as to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture or
collect, or attempt to engage in any such conduct. Incidental take is defined as take that is
incidental to, and the purpose of, the carrying out of an otherwise lawful activity.
Incidental take statements serve a number of functions, including providing reinitiation
triggers for all anticipated take, providing exemptions from Section 9 liability for
prohibited take, and identifying reasonable and prudent measures that will minimize
the impact of anticipated incidental take.

Amount or Extent of Take

NMFS anticipates:

• 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.

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.
X. MONITORING REQUIREMENTS

Monitoring the compensatory mitigation project site is necessary to determine if the

project is meeting its performance standards, and to determine if adaptive measures are
necessary to ensure that the project does meet its objectives.

As per the guidelines set forth in §230.96 Monitoring the mitigation project will be
monitored for a minimum period of 5 years.

In total twenty-five percent (forty-four (44)) of the non ESA transplanted corals will be
marked with numbered tags for monitoring and all of the Orbicella annularis will be
tagged and monitored. Prior to relocation each of the Orbicella will have been measured,
number of lobes assessed and percent live tissue. A numbered tag will be placed around
an area of dead tissue so that it cannot impact live tissue. The tags will be maintained
throughout the 5 year monitoring period. Twenty-five (25) corals already in the
transplant site will also be monitored. The insitu corals selected for monitoring will be
of the same species relocated, including ESA listed Orbicella. These corals will be
marked and surveyed prior to the start of the transplant. The marked corals and tagged
Orbicellas will be surveyed for percent live tissue, color, algal growth and indicators of
disease and photographed on a monthly basis for the first twelve (12) months. Corals
will then be monitored on a bi-monthly basis for the follow 2 years and then every 6
months for years 4 and 5 after the transplant. All photographs will include location and
scale as well as the description of the health; percent live tissue, color, stress, surround
algal growth, algal growth on dead areas of tissue and any signs of disease for each
monitored coral.

If at any time during the monitoring degradation of the corals is noted, degradation being
defined as tissue loss, indication of disease, color change, excessive algal growth or
notable mucus, affected corals will be compared to those within the other monitoring
quadrats and corals in areas outside the impact area of the project. This information will
be used to determine whether the degradation of the corals is due to the transplant,
activities related to construction or resort or due to natural phenomena (such as wide
spread bleaching). If the corals appear to be stress due to the transplant, the reason for
the demise will be assessed, poor positioning, sand scour, light attenuation, etc. If
necessary, the coral or sponge will be repositioned. Every effort will be made to save the
coral or sponge. If the degradation is seen both in the project area non-transplanted
corals and the transplanted corals, the reason will be assessed for the demise. If the
source of the impact cannot be readily assessed by the monitoring being undertaken, the
monitor will work with NMFS and VI Fish and Wildlife and the other resource agencies
to expand the monitoring so that the source of the impact can be identified.

Twenty quadrats will be established within the sea grass recipient site, these will be
marked with PVC stakes and with numbered tags. Five sea grass quadrats will also be
established in the surrounding natural beds containing the same species of seagrass and
similar densities as to the transplanted quadrat. The marked quadrats will be sampled and
photographed on a monthly basis for the first 12 months and then will then be monitored
every two months for the next year and then every six months for the following 3 years.
Monitoring will assess seagrass densities, blade sloughing, new growth and amount of
epiphytes.

If at any time during the monitoring degradation of the sea grass is noted, the transplanted
sea grass will be compared to those within the other monitoring quadrats and sea grasses
in areas outside the impact area of the project. This information will be used to
determine whether the degradation of the sea grass is due to the transplant activities). If
the sea grass appears to be stressed due to the transplant, the reason for the demise will be
assessed, poor positioning, sand loss, light attenuation, etc. If necessary, the sea grass
will be replanted. Every effort will be made to save the sea grass. If the degradation is
seen both in the project area non-transplanted sea grass and the transplanted sea grass, the
reason will be assessed for the demise.

The monitoring results will be delivered to the agencies within two weeks of the
monitoring period. If negative impacts are noted the agency will be notified by phone
and by email within 24 hours. The agencies will be apprised of what steps are being
taken to identify the impact and rectify the problem. The agencies will be provided a
detailed report on the steps that are taken and the results of those actions.

XI. LONG TERM MANAGEMENT PLAN

Coral World (VI) is committed to the survival of the transplanted coral and seagrass
species and to the maintenance and monitoring of the informational buoys and moorings.

Corals are being transplanted into the viewing area around the Coral World (VI)
Observation Tower. The area is protected from potential impact of boat anchoring or
groundings since the area is completely enclosed by a buoy barrier. The transplanted
corals will also be visible from the subsurface observation area making it possible for
Coral World staff members and others to track the long-term health and survival of the
corals. It is important for Coral World to have viable corals around their tower for the
enjoyment of visitors and Coral World will maintain the area around the tower in the best
manner possible to provide a suitable area for the corals.

Coral World will place and will be responsible for the long-term maintenance of the
informational buoys for the life of the dolphin exhibit. If at any time they become
damaged or are lost they will be replaced. Coral World will check the tackle for the
buoys on an annual basis.

XII. ADAPTIVE MANAGEMENT PLAN

In the event that there are difficulties with the mitigation or if the mitigation is deemed
unsuccessful as planned, Coral World (VI) is prepared to take additional steps to see that
compensatory mitigation goal is achieved. If necessary, extended monitoring and
maintenance or additional marking of the sites will be undertaken in order to meet the
mitigation goal.

If the mitigation goal of 80% survival at the end of five years is not met, the applicant
will prepare a detailed report of why the mitigation was not successful. Coral World (VI)
will meet with the permitting agencies to determine the additional compensatory
mitigation needed to meet the mitigation goal.

Coral World (VI) has received an Incidental Take Statement for the ESA listed species, if
more take of ESA-listed corals occurs than is estimated in the ITS, consultation will have
to be reinitiated.

XIII. FINANCIAL ASSURANCES

Coral World (VI) will secure a performance bond in the amount of the cost mitigation
program and subsequent monitoring throughout the implementation and monitoring
period or provide another form of acceptable financial assurance. If a bond is utilized,
the bond will follow the guidelines set out by the U.S. Army Corps of Engineers
Regulatory Guidance Letter No. 50-1, 14 February 2005, SUBJECT: Guidance on the
Use of Financial Assurances, and Suggested Language for Special Conditions for
Department of the Army Permits Requiring Performance Bonds.

The cost of the mitigation for the 5 year monitoring period under the USACOE is as
follows:

MITIGATION - CORAL AND

SEAGRASS RELOCATION
Action Cost
Lay out transplant zone (construction $4,000.00
impact)
Lay out recipient site $4,000.00
Orbicella Assessment $4,000.00 ESA coral related
Coral Relocation $25,000.00 includes special measurement and
tagging of ESA corals
Layout seagrass transplant $4,000.00
zone/recipient site
Seagrass Relocation $20,000.00
Establish Control Corals $4,000.00 ESA coral related
Monitoring year 1 $98,000.00 includes special ESA monitoring
Monitoring year 2-5 $84,000.00 includes special ESA monitoring
$235,000.00

Contingency $47,000.00

Total Mitigation with Contingency $ 282,000.00