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. EFTA00802702

I. INTRODUCTION Great St. Jim, LLC is seeking to construct two docks, one of which is a combination dock/ barge landing, and a temporary barge landing to provide access to Great St. James Island. There is currently a small pile-supported dock located within Shallow Bay on the north side of the island. The bay is very shallow and vessels accessing the dock have damaged the shallow seagrass beds within the bay. At one time, there had been a concrete bulkhead at the shoreline with a small floating dock. The previous owner submitted an application for the existing dock which was approved by DPNR's Division of Coastal Zone Management, but was not approved by the U.S. Army Corps of Engineers due to objections by National Marine Fisheries because of the shallowness of the bay. The dock was constructed by the previous owner despite not receiving the federal permit and notices were issued by the USACE requesting the removal of the unpermitted structure. The dock however was never removed. The applicant, understands the issues with the existing dock and is proposing to remove the dock as soon as another dock is constructed and usable. A detailed study was done around the entire island to determine suitable locations for dock location. All ESA listed corals were located and docks and barge landings were designed to avoid these corals. A temporary barge landing is being proposed on the northwestern facing beach. This site is to the west of the salt pond and the associated wetlands. This a shoreline ramp which is 25 feet (ft) wide and 40ft in length extends to the Mean Water Line. The landing is free of both coral and seagrass colonization. The landing is excellent for short term transfer of material or equipment. The site is well protected from normal wave action but is periodically impacted by wave action from ferries which travel through current cut between Great St. James and St. Thomas. The wakes from these vessels make it an unattractive site for mooring a barge for any length of time at the site. This landing can be quickly constructed and utilized while the combination dock and barge landing on the southeastern side of the island is constructed. The western dock is proposed on the northern end of Christmas Cove. Historically there was a dock in this location and there are still old concrete piles lying in the shallows of this site. The proposed dock will be 10ft in width and 195ft in length extending 187ft from mean low water (MLW) and I93ft from mean high water (MHW). The dock extends beyond the nearshore hardbottom to a depth of 15ft out in the uncolonized sand to allow for safe dockage for deeper vessels. EFTA00802703

The southern dock is located off the point closest to Little St. James. The dock is "L" shaped and is 20ft wide (to allow for barge landing) and 150ft in length extending 141ft from MLW and 148ft from MHW, the "L" then turns east and extends 100ft by 20ft. A wave attenuating/reef creating system is proposed beneath the dock which will allow for more protected docking inside the dock when seas from the south are rough. The dock has 9ft of water depth of the southern end and 7ft to 8ft on the inside of the "L". The dock has been designed so that barges can approach and land on the end of the dock while vessels can dock along the "L". REASON FOR MITIGATION The marine habitats around Great St. James have abundant coral and seagrass resources. There are numerous ESA listed corals species near the proposed dock locations. Acropora palmata, Acropora. cervicornis, Orbicella annularis, Orbicella franksi and Orbicella faveolata as well as Dendrogyra cylindrus are found off all the beach from which the proposed docks and barge landings are planned. At the northern temporary barge landing site, these corals are located primarily to the west in an area of coral boulders and coral rubble. However, there are several small A. palmata and several 0. amiularis located on the shoreline cobble which extends out to a depth of 6.5ft. The presence of these species as well as several non-ESA listed Porites astreoides has dictated the location of the ramp. The proposed temporary barge landing position avoids all coral and seagrass resources. Location of the western dock has a cobble beach between two areas of emergent bedrock and boulders. A. palmata occur on the emergent bedrock to the north. Offshore the seafloor quickly gives way to exposed pavement. There is a long linear depression right offshore and an old piling lies within this area. The fractured pavement then extends to approximately 11.5ft of depth over the next 100ft heading offshore. The area has some widely-scattered boulders and patchy coral colonization. There are scattered ESA corals including Orbicella and Dendrogyra. During the first survey, there was a very large A. palrnata colony immediately seaward of where the old piling lay near shore. However, upon the next visit by the island it was noted that an old boat was tied nearshore apparently attached to the old piling. During a dive, several weeks later it was noted that the boat was gone and the large A. cervicornis had been badly broken. The location of all the ESA species has dictated the location of the dock. Approximately 75 corals will require relocation to minimize impact but no listed corals will need relocation. The southern dock also extends from a cobble beach which gives way to rock pavement and has emergent bedrock and boulders on either side of the beach. There are Acropora colonies to the east and farther to the south on the bedrock and boulders. There are Orbicella and Dendrogyra within the embayment and their locations have dictated the location of the dock. The dock avoids all ESA listed corals but will require the relocation of approximately 75 corals. EFTA00802704

II. MITIGATION OBJECTIVES It is the objective of this mitigation project to limit the amount of coral and coral habitat that is lost as a result of the dock and barge access construction. All of the coral, sponge, and sessile life forms within the footprint of the facility or which might be potentially impacted during construction or operation will be transplanted. Approximately one hundred and fifty (150) corals 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 corals from the Christmas Cove site will be located to the north onto the adjacent hardbottom areas which are at equivalent depths. The corals from the southeastern dock site will be transplanted to the hardbottom to the south which are at equivalent depths. Figure 1. Recipient site Christmas Cove EFTA00802705

k iffrcult tocreate usabie cess ,frvecipient A Figure 2. Recipient site southeastern dock IV. SITE PROTECTION INSTRUMENT The applicant will prepare an easement setting these areas aside as protected areas. V. BASELINE INFORMATION Benthic Habitat Description General Sandy beaches, cobble beaches and steep rocky shorelines surround great St. James Island. All three of the proposed dock and barge landing sites will extend from cobble beaches. The northern shore where the temporary barge landing is proposed has cobble which extends down to a depth of approximately 7ft and has sparse seagrass colonization within the barge approach. There are scattered corals in the bay to the east and dense seagrasses offshore beyond the landing site. The cobble within the landing site is only colonized by fire coral. The emergent bed rock to both the east and west sides of the bay are colonized by corals species including ESA corals. The northern portion of Christmas Cove where the Access Dock is located has emergent bedrock to either side of the small embayment which are colonized by coral and sponge species. Rock pavement and scattered boulders extends offshore to a depth of 11.5ft where it gives way to a sandy bottom. Corals and sponges colonize the rock pavement and scattered boulders. There is seagrass off shore but it begins beyond the terminus of the proposed dock. The southern facing dock is off a cobble beach between to rocky shorelines. There is rock pavement extending off shore and then broken rock pavement further out. Corals and sponges colonized the rock pavement. EFTA00802706

ESA listed coral species are found at all three locations and the Nassau Grouper (Epinephelus striatus) was seen off both the Christmas Cove and southern dock site. Methods The NOS St. John and St. Thomas Habitat map Tile 16 (Figure 6.06.1) of the Great St. James area shows the colonized rock pavement and bedrock as well as the offshore seagrass beds. The seagrass beds are not as continuous near the shoreline as shown, and the offshore area at both Christmas Cove and the southern dock site are colonized pavement rather than bedrock right off the cobble beaches and on the northern facing beach the pavement doesn't extend completely across the bay as shown. Surveys were done on Scuba and Acropora palmata and Acropora cerviconds, Dendrogyra cylindrus, Orbicella annularis, Orbicella faveolata, Orbicella franksi, and Mycetophyllia ferox were mapped so that they could be avoided. Habitat boundaries were marked with GPS and/or by the surveyor for accuracy. Percent abundance was determined along transect lines and utilizing a meter square. -2•••• 0:1•••••••••••••••••+ MIns••••a••••• gr. 1=12 Figure 1. NOAA Benthic Habitat Map • PE • MO la, Benthic Resources NM. Great St. James is located off Water Point on the eastern end of St. Thomas. This oddly shaped island has a variety of shoreline types and six salt pond/wetland habitats. There is a well-protected shallow northern bay where an existing dock is located. Shallow Bay is colonized by seagrass which includes Thalassia testudinum, Syringodium Monne and Halodule wrightii. Recently the sea vine Halophila stipulacea has colonized areas which have been disturbed. The densest seagrass beds once lay near shore and to the east of the dock. Over the last several years these beds have been highly disturbed. The peninsula to the east of this point is surrounded by rocky headlands and is a very exposed EFTA00802707

environment. The rocky cliffs extend below the sea surface and due to the intense wave action, the shallowest areas are not colonized. By a depth of 8ft-10ft the rocky substrate becomes colonized by a wide variety of corals and sponges. The slope is steep offshore and the water reaches a depth of 40ft to 50ft relatively close to shore. The rocky slope gives way to a cobble then sand bottom and there are sparse to moderately dense seagrass beds that extend seaward. The rocky shoreline continues around to the south, with coral colonized nearshore hardbottom and seagrass colonized sand and cobble further offshore. There are two cobble beaches further to the south divided by a small rocky headland, there is some colonized beach rock nearshore and shallow seagrass beds off shore. The shoreline facing St. James Cut and the southern end of the island is rocky. This area has limited coral colonization in the inner tidal zone giving way to an abundant diverse coral community on the submerged rocky slopes. The rock is relatively steep with numerous grottos, and caves, and gives way to a cobble/sand bottom at around 20ft to 25ft. There are moderate to dense seagrass beds off shore. The Stragglers lay off the southern most point of the cay, and like the southern shoreline of the island there is minimal colonization in the inner tidal areas of the emergent rocks with coral colonization and diversity increasing with depth. The western shoreline is well protected and is a combination of rock and sandy beach. The water deepens much more gradually on this side of the island. In the areas with rock along the shoreline are colonized by corals and sponges. The less colonized inner tidal area is much less defined here due to the more protected nature of the site. Within Christmas Cove there is a rock groin like structure that extends into the bay near the center of the embayment. Offshore to the north of the groin there is a small beach rock shelf and then a strip of uncolonized sand before sparse to moderately dense seagrass beds begin. The site is currently used by boats anchoring adjacent to the beach. To the south of the groin there is a beach rock shelf with moderate coral colonization which falls off to depth of over 6ft only 40ft from shore and there is a board area of uncolonized sand out to a depth of 10ft before reaching the moderately dense seagrass beds and open sandy plains. The shoreline becomes rocky again to the north along Current Cut and the area is more subject to wave and current action. There is coral colonization along the rocky shoreline and on the rock pavement that extends off shore. The north-facing bay to the east of Current Cut is a mixture of cobble and rocky shoreline with a small sandy beach in front of the salt pond. Where rock is present there is coral colonization and in the open sandy areas there is moderate to dense seagrass colonization. The temporary barge landing is located at the western end of the north-west bay. The landing. The beach is cobble and the cobbles extend out to a depth of 7ft at the landing site. The landing site contains some scattered Millepora complanata, but no hard-coral species. There are scattered corals to the east in the cobble including a few Orbicella amudaris and Acropora palmata. Porites astreoides is the most abundant coral in the cobble to the east. The location for the barge ramp was chosen due to the presence of corals and coral colonized boulders throughout the bay to the east. To the east in the bay there are numerous Orbicella annularis, O. faveolata and Dendrogyra cylindrus as well as other coral species. Offshore there are dense seagrass beds consisting of 77wlassia testudinum and Syringodiumfiliforme, however these are greater than the 75ft off shore EFTA00802708

which the barge will extend while moored. There very sparse Syringodium colonization within the barge approach, representing less than 5% bottom coverage. Northern site Figure 2. Benthic habitats at the bare landing. obble in footprint of barge mooring site eagrass offshore well beyond the cobble EFTA00802709

approach Sparse seagrass in the immediate barge The access dock in Christmas Cove is near the location of an old historic dock. The beach is a mixture of sand and cobble. There is rock pavement extending offshore and there is an area of cobbles in the center of this area which is uncolonized out to a depth of 5ft. The rock pavement has various depressions and breaks and within one of these depression is a pile from the old concrete dock. Beyond the depression, the water deepens quickly out to a depth of 12ft. The rock pavement is colonized by Diplona strigosa, D. labyrinthifonnis, Orbicella annularis, 0. franksi, Porites astreoides, P. porites, Dendrogyra cylindrus, Gorgonia sp. and Millepora sp. and the sponges Aplysinafidva, Amphimedon compressa and Ircinia sp. Coral colonization increases on either end of the small embayment and with depth. Beyond the nearshore hard bottom, approximately 120ft off shore the bottom becomes sandy. There is a minimally colonized area before the bottom begins to become colonized by Syringodiztmfilifonne which slowly grades into a mixed bed of Thalassia testitudium and Syringodium. The exotic seavine Halophila stipulacea is also present. This seavine was not present in 2006. There was a very large intact Acropora cerviconzis in the center of the bay just off the old dock piling in the depression early in 2016. However, a boat moored on the old piling and on a subsequent dive the Acropora was found completely broken. Pieces of this Acropora remain. There are Acropora palmata in the shallows to the north of the proposed dock location both on the cobble and bedrock. EFTA00802710

The bottom formation is dead visible this •hoto• a h. Fi tire 3. Benthic Habitats Christmas Cove obble with minimal colonization 43 EFTA00802711

Sand beyond colonized pavement Old piling Shallow Acropora Broken A. cerviconzis The Access Dock/Barge dock is located in the bay closest to Little St. James. Like the other two bays there is cobble on the shoreline which extends into the sea to 2ft to 4ft of water depth. Offshore there is pavement with boulders and odd rock formation. The area is colonized by scattered corals which are most abundant on the boulders. Orbicella amiulans, O. franksi, O. faveolata, Dendrogyra cylindrus, Porites astreoides, P. porites, Diploria strigosa, D. clivosa. D labyrinthifonnis Gorgonia sp. and Millepora sp. and sponges Aplysinafidva, Amphiniedon compressa and Ircinia sp. are present. Acropora pabnata is present on the headlands to the east and south. There are scattered boulders and broken pieces of bedrock offshore, most of which are colonized by corals and sponge species. EFTA00802712

Figure 4. All of the ESA corals in the bay were mapped by the surveyor in order to avoid hem with the dock design. Figure 5. Benthic Habitats in the southeastern embayment EFTA00802713

VII. MITIGATION WORK PLAN CORALS Prior to the start of the relocation project the footprint of the docks 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. Individual corals that are attached to the near shore hardbottom will be removed with chisels. These corals will be collected in bins and carried to recipient site. 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 starts to set. Divers will then collect those corals and sessile invertebrates that colonize cobbles and rocks within the dock footprint that are of a small enough size to allow hand carrying. These are cobbles and boulders that are in a range of I ft2 to 2.5ft2. These corals are usually growing on pieces of coral rubble. 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 I ft2 to 1.5112 corals will be placed in underwater bins and carried by divers to the recipient sites. The larger corals will be placed directly on a transport tray. Once the tray is full it will be lifted by lift bags and walked to the relocation site. 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 EFTA00802714

lifted and walked 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. COMPENSATORY MITIGATION To mitigate for impacts that cannot be avoided a special reef building system will be placed beneath the southeastern dock. This system serves not only as a wave attenuator by provides additional substrate to allow for colonization beneath the dock. Grated decking will be used on the dock to facilitate light transmission. .... .2 0 0. .. ID • • % (i),(;) • • 1•`); II < • )0 • • • ...a ....,• • , Ilt•MB 4 • v za .,•• • • •I • >0 A% I • se•Ni. I ,-..\, _ 4a< • * • Of • it • A • ? • ..• \ t o:F\ • • i i*•>• P r•) 4 •e.4 • • „•, .... • :e.-. • „•,... P • 1•(•> 4 W • IN • Y• • ,.. .../ O C •• * • • • / ... SO ;te\ Ol t • • IP • Ci • N . . • ( • , it •< • 2 • 2. •• )2 • Re, •• >so • fa •• >It • *< •• >ft • •C i>• • /„ e , , ••./., • i %NJ, • .0 N.V.. , 0,// • , ‘• , • * < •,,2 \•,)24 10/•\* .,•*<‘ •/•<,•,, , ,<,slys< • )1•<,,,Ocney• ,* . II (1171‘1{<1• N ih••••4 • ft /No.:.)11 • if <,•>* • Nilie•Nli • iiii)iii", ...• . • . • ... . • NI N.' a l • • SAS'. a • anal . • a ..11.1 a a • t......„.... . we X 3/4' X1 1/2' FRP 50% OPEN DECK GRATING 12' FRP C-CHANNEL JOISTS & BEAMS WAVE ATTENUATION EEF MAKING SYSTEM SETTING CLAMP FRP 12• PENNON PILES -16'-- BABE BLOCK STONE SCOUR PROTECTION 50' WAVE ATTENUATION SETUP EFTA00802715

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. 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. Great St. Jim, LLC 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. 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 transplanted corals at each site will be marked with numbered tags for monitoring. The tags will be maintained throughout the 5 year monitoring period. The corals 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. The percent live tissue, color, stress, surround algal growth, algal growth on dead areas of tissue and any signs of disease for each monitored coral will be noted in the reports. 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, EFTA00802716

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. In order to monitor the success of the reef creating system under the southeastern dock, it will be monitored concurrently with the corals and a detailed photographic recorded will be kept depicting colonization, survival and growth of coral and sponge species. 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 Great St. Jim, LLC is committed to the survival of the transplanted coral species and the success of the reef building system and will make every effort to ensure that both are a success. XII. ADAPTIVE MANAGEMENT PLAN In the event that there are difficulties with the mitigation or if the mitigation is deemed unsuccessful as planned, Great St. Jim, LLC 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. Great St. Jim, LLC will meet with the permitting agencies to determine the additional compensatory mitigation needed to meet the mitigation goal. XIII. FINANCIAL ASSURANCES Great St. Jim, LLC 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. The bond will follow the guidelines set out by the U.S. Army Corps of Engineers Regulatory Guidance Letter EFTA00802717

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. EFTA00802718

APPENCIX C ENVIRONMENTAL AND WATER QUALITY MONITORING PLAN FOR THE CONSTRUCTION OF A TEMPORARY BARGE LANDING AND TWO DOCKS ON GREAT ST. JAMES, U.S. VIRGIN ISLANDS INTRODUCTION The following is the proposed monitoring program for the construction of a temporary barge ramp and two docks on the island of Little St. James. The purpose of this monitoring plan is to evaluate and minimize the impact of the proposed construction on marine water quality and the benthic community. Great St. Jim, LLC is seeking to construct two docks, one of which is a combination dock/ barge landing, and a temporary barge landing to provide access to Great St. James Island. The marine construction will consist of the vibra-hamming or socketingof piles and the placement of docks. The impact pile driving or vibra-hammer driving will have a minimal potential for creating turbidity. However, where 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 a number of piles may require socketing. 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 and a double set will be deployed. ESTABLISHMENT OF BASELINE CONDITIONS AND SAMPLING POINTS Prior to the start of any construction activities a baseline of existing conditions will be assessed. 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. The baseline samples sites are shown in Figures 1 and 2. No monitoring should be necessary for the temporary barge landing. Baseline samples will be tested for secchi depth and turbidity expressed as NTU. 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 sediment runoff. EFTA00802719

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 Figures 1 and 2 will also be sampled. Water quality will be secchi depth and turbidity expressed as NTUs. ACTION TRIGGERS During construction if the water samples show NTUs, or secchi disk 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 GSJ. 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. 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 will be delivered to all agencies and GSJ throughout the monitoring period. EFTA00802720

Figure 1. Christmas Cove Monitoring Stations and Controls Figure 2. Southeastern monitoring stations and controls EFTA00802721

APPENDIX D VIRGIN ISLANDS TREE BOA MITIGATION PLAN — GREAT ST. JAMES ISLAND ACCESS DOCK CONSTRUCTION Introduction Little St. James island habitat for the Virgin Islands Tree Boa, Epicrates monensis granti and two tree boas were seen in 2006 on the island. The tree boa was listed as Federally Endangered in 1979 and the Virgin Islands Endangered and Indigenous Species Act also protects this species. The tree boa is nocturnal and arboreal, the snake forages at night and seeks shelter during the day. The snakes seek refuge in termite nests, debris piles and under rocks during the day. While the snakes' habitat is listed as dry forests, coastal scrub, moist woodlands, mangroves and rocky cliffs, the snakes can occur in any habitat that allows for off ground movement. The structure of the habitat is more important than the species composition; the dock access had some structure which might be adequate for these species. There is an abundant prey base of lizards on the cay, and there is refugia present; logs and rock piles. Fish and Wildlife states that the snakes are extremely difficult to locate even for an experienced snake biologist, and therefore it must be assumed that the endangered species is present, especially when suitable habitat and refugia are present. Tree boas are known to be present the applicant will make every effort not to take (harass, harm, pursue, shoot, wound, kill, trap, capture, or to attempt to engage in such conduct) any of these endangered species. The dock access way will be cleared by hand and rock piles will be dismantle by hand. All personnel involved in site clearing and site construction will be informed of the potential presence of the snake, and the importance of protecting the snakes. Photographs of the tree boas will be shown to all workers as well as a description of their behavior and habitat. All workers must acknowledge that they understand the importance of protecting this rare and endangered species. The site will be cleared directionally from the existing access way towards the shoreline. If tree boas are encountered, work will be stopped in the area of the snake, and the Division of Fish and Wildlife will be contacted immediately. Ever means necessary will be implemented to prevent harm to the tree boa. The DFW will be notified of any snakes observed or capture. Phone numbers for Fish and Wildlife will be posted at the site to aid in immediate notification. EFTA00802722