The enclosed information is being submitted in partial completion of Special Condition 3 (US Army Corps of Engineers permit 960100004) which was issued to IOTA Partners on 16 May 1996. This permit authorized the archeological excavation of the Santa Margarita, a Spanish galleon which sank off the Rota coast during the early 1600's.

On behalf of Mr. Jack Harbeston, CEO, the following environmental data is respectfully being presented for review by the appropriate Federal and CNMI regulatory agencies. For ease in following the specific requirements outlined in Special Condition 3, it is rewritten below:

SPECIAL CONDITION 3: You shall implement a monitoring program during this project to assess the impacts of the salvage work on adjacent coral colonies. Monitoring shall include visual observations of the project area as well as measurements of water turbidity near the water surface and above the sea floor at locations determined by DEQ. Turbidity levels must be measured prior to the start of in-water work for comparison purposes. You must obtain photographs of coral colonies up current and down current of the project site at similar depths. To tile extent possible, these coral colonies should include the same species. Copies of the data obtained will be sent to the Corps, U.S. Fish and Wildlife Service, National Marine Fisheries Service, the U.S. Environmental Protection Agency and CNMI Department of Environmental Quality as soon as possible, and in all cases, within seven days of the sampling date. The initial data report will include a map of the sampling locations. You must submit a final data report summary no less than one week after completion of the in-water work.

The water quality (ie., turbidity) requirement will be met by complying with Condition 5 in the Section 401 Water Quality Certification which was issued by the CNMI Division of Environmental Quality on 5 February 1999. The turbidity monitoring issue was previously addressed in three facsimiles from Micronesian Environmental Services (MES) to Ms. Juliana Sandvold (CNMI/IOTA liaison) dated May 3, 7, and 17, 1999 and it is my understanding that this requirement has been satisfied.

Pre-excavation turbidity levels were measured at various depths (surface, mid-depth and bottom) prior to excavation work which officially commenced on June 7, 1999, These turbidity values are shown in Table 1, while Figure 6 presents the same data graphically(both are shown below). A portion of this data was previously reported in facsimiles from MES to Ms. Juliana Sandvold dated May 3, 7, and 17, 1999.

After several reconnaissance dives, coral reference sites were initially selected based on their location relative to the proposed excavation areas. Specific sites were chosen due to the diversity of coral species immediately surrounding the rebar marker as well as the site containing similar species to those transplanted from the excavation area.

In order to monitor the project area, four coral reference sites were identified and marked with rebar: two sites were positioned up-current from the "project site area" (ie., sand pit) while two sites were situated down-current. These sites were further delineated into shallow and deep and are identified on the aerial photograph labeled Figure 1 below.

Photographs of the corals found at each reference site were taken on 14 May 1999 and are shown in Figures 2, 3, 4 and 5, Follow-up photographs are proposed for July, Water depth at each reference site was measured on 14 May 1999 at ebb tide and follows: (up-current shallow) (4 feet); (up-current deep) (25 feet); (down current shallow) (12 feet); and (down-current deep) (32 feet).

The positions of these four reference sites should provide some information related to sediment associated impacts from excavation, though it should be cautioned that a direct cause and effect relationship cannot be established solely on measured effects of these sites.

If you should require further information or have any questions, please contact me at your earliest convenience.

Sincerely,
John Gourley