I first heard the term "island eradication" back in 2011, when a colleague sent me an email that contained a project scoping notice from U.S. Fish & Wildlife (USFWS), San Francisco Bay National Wildlife Refuge Complex. This public notice announced a non-native mouse eradication project for the Farallon Islands, which are located 27 miles off the coast of San Francisco. The solemn tone of his words -- "Have you seen this?" -- quickly caught my attention.
As I read the document I couldn't believe what was being contemplated. USFWS wants to use helicopters to drop 1.3 metric tons of brodifacoum (in the form of loose rat poison pellets) over the Farallon Islands, an area that has been designated as a National Wildlife Refuge. Nonnative mice are the issue. The ashy storm-petrel, a seabird that is considered a species of special concern, is being indirectly impacted by the presence of mice.
It is Fish and Wildlife's assumption that the population of the ashy storm-petrel, a bird that is naturally a slow breeder, would recover if the mice could be eliminated. The rationale being used is that the mice are the food source that attracts an average of six burrowing owls--which also eat petrels--to the Farallon Islands every year. USFWS scientists believe the burrowing owls are staying longer than they normally would if the mice were not there. It is believed that the owls show up to feast on the mice when the mouse population spikes during the fall and early winter. The burrowing owl is also a species of special concern.
When the mouse population dips during the winter months, the few burrowing owls that remain on the island can, and do, turn to eating the chicks of the ashy storm-petrel. In reading the data provided by USFWS, I found it very interesting that out of 1,618 prey items analyzed in 679 owl pellets, only 82 storm-petrels were found. Based on the data from USFWS the majority of the owls' diet appears to be invertebrates and mice.
It is important to add that the owls are not the only animals consuming the ashy storm-petrel chicks. Western gulls, one of the most opportunistic birds I have ever worked with as a wildlife rehabilitator, also consume ashy storm-petrel chicks. I can't help but wonder when the Western gulls or any other species on the Farallones will be targeted next by USFWS in this unsettling fable of environmental ethics that pitches one species of animal against another.
If this 1.3 metric ton poison drop is allowed to move forward, thousands of wild animals will be inhumanely poisoned, and in turn, those killed become a poisoned food source for other animals. This is how the food web becomes contaminated. Since USFWS is chartered with the mission to protect ALL living resources within the public trust, the casual tone conveyed by this agency regarding collateral damage and "non-target species" is deplorable and unacceptable. I reached out to USFWS and asked for a comment with respect to that mission and how this project is contradictory. I have yet to receive a response.
There is also the potential for long term damage to the environment. Sub lethal impacts of anticoagulant rodenticides on wildlife are a threat that has the potential to impact future generations of birds, fish, sea lions, elephant seals, raptors, sharks, insects, crabs and other marine life. If the poison does not kill them outright, it can affect their behavior, reproduction, and survivability. Information on sub lethal poisoning was completely bypassed in the revised draft environmental impact statement (RDEIS) released this past October. Page 139 contains the statement that "Adverse effects as a result of possible sub-lethal exposure are unknown for brodifacoum or diphacinone." The EPA also makes mention of this omission on page 11 of their 18 page comment letter found here
Information on sub lethal impacts of anticoagulants is readily available to anyone with access to the internet and web browser. This report tells the story of a dog exposed to brodifacoum at one point in her life, though her owners don't know when, as this dog never displayed any acute symptoms of exposure. This dog was bred and the result was eight of her eleven puppies died soon after birth. Three were necropsied. Two of the puppies were found to be bleeding internally and brodifacoum was detected in the livers of two of the dead puppies. This is how brodifacoum and other anticoagulant rodenticides work. After animals ingest the poison, the animal bleeds to death because the active ingredient interferes with the blood's natural ability to clot. This is the type of scientific documentation that is required to be disclosed in an environmental impact statement. The exclusion of this critical information equates to "cherry picking" of science. What happened to this dog has the potential to be replicated by a number of species that live in, or close to the fragile ecosystem of the Farallon Islands, if brodifacoum or other anticoagulants were to be aerially broadcast across the terrain.
Here's the really scary thing. If this same event were to occur in nature as the result of brodifacoum permeating the food chain, the public and scientific community would not even be aware of it since the post project monitoring does not include monitoring for the presence of rodenticides or residues in the environment, except for intertidal invertebrates and then ONLY 'If greater than negligible bait drift into the marine environment is detected." (pg. 72 of the DEIS)
I started researching island eradication projects over two years ago and quickly learned of what happened on Rat Island in Alaska, a previous rodent eradication project that resulted in the poisoning of at least 46 bald eagles and over 420 seabirds. I found this highly critical report written by the Ornithological Council of USFWS and Island Conservation, and this story by Nature magazine.
I also received several emails urging me to investigate what was happening with the eradication project at Palmyra Atoll, which is located about 1000 miles from Hawaii. I have since learned that the eradication attempt at Palmyra Atoll resulted in bait getting into the water and fish becoming a contaminated food supply. The final report is available here.
I first wrote about this topic for the Huffington Post back in 2011, after members of the public were denied the opportunity to make public comments at the first public scoping meeting held in Fort Mason, San Francisco in May of 2011. We were given a presentation by the officials about the problem of non-native mice on the island, and the indirect impact these mice were having on the ashy storm-petrel, the farallon arboreal salamander, and the caramel cricket. We learned that an environmental impact statement was underway and that USFWS had engaged with two partners for this project; Island Conservation and PRBO (now Point Blue Conservation Science). After a presentation on how these projects are carried out and why one is needed at the Farallon Islands, we were divided into groups and sent to separate corners of the large room. Without a doubt, this was a technique for crowd control. There was a healthy turnout of concerned citizens and most were shocked and opposed at the prospect of using helicopters to carpet bomb the Farallones with a type of rat poison (brodifacoum) that has come under heavy scrutiny from the EPA and the California Dept of Pesticide Regulation.
In each of the room corners were representatives from USFWS, Island Conservation and Point Blue Bird Science. They had flip charts and wrote down questions, concerns and suggestions. In speaking with one representative from USFWS, I raised the question of other animals being poisoned in the process, something continually referred to as "non-target species." The response was casual and dismissive. "Nobody likes it, but it happens" one USFWS employee shrugged.
Conflict of Interest
Fast forward to the fall of 2013 and a 741 page Revised Draft Environmental Impact Statement (RDEIS) is released. Written by Island Conservation under two Cooperative Agreements found here, and here. The creation of the environmental impact statement netted the Santa Cruz based nonprofit a total of $481,883. Island Conservation is also the contractor that will get the eradication business if the decision is made to move forward with this project. And since Island Conservation is a registered 501c3, income earned from eradication projects is tax free. Details surrounding the financial relationship between Island Conservation and USFWS didn't surface until I asked Gerry McChesney, USFWS Refuge Manager for the Farallon Islands, how much Island Conservation has been paid to write the environmental impact statement. My request was handled under the Freedom of Information Act.
The blatant conflict of interest is disturbing, but what angers me is that it took my questioning before this information became public knowledge. Island Conservation has been paid $481,883 by USFWS to write the environmental impact statement for an eradication project they will be awarded worth approximately 1.3 million dollars. This explains the end result of a highly biased and misleading environmental impact statement.
According to NEPA's (National Environmental Policy Act) rules of engagement, financial interests of parties involved need to be disclosed in the environmental impact statement. This is something the EPA pointed out in their lengthy comment letter dated 12/09/13.
" In our scoping comments, we raised potential conflict of interest issues if Island Conservation were to prepare the impact assessment and also carry out the eradication project. Since the DEIS does not include the disclosure statement, required by 40 CFR 1506.5(c), specifying that Island Conservation has no financial or other interest in the outcome of the project, it is unclear whether this issue has been addressed." ~ EPA comment letter on the Farallones mouse eradication project, 12/09/13
Speaking of the EPA.....When they write an 18 Page Comment Letter with Concerns, We Need to Listen
This letter dated 12/09/13 from the EPA identified the numerous issues the EPA has with the draft environmental impact statement. What is unfortunate is that the EPA has no jurisdiction to stop this project. Only to give opinion and point out any potential NEPA violations, such as the conflict of interest issue.
The tone of the EPA's letter was serious and expressed great concern about this project moving forward. Points raised by the EPA include the fact that the amount of bait proposed for use violates federal law, that predictions with respect to the success of hazing of wildlife are overly optimistic and do not mention how hazing activities would affect the mice, and fails to include any information about the failures of several previous island eradication projects.
"Much information can be obtained from previous rodent eradication attempts and it is not clear that lessons learned from these projects have been integrated into the planning for the proposed project. We are aware that three recent rodent eradication attempts - Wake Atoll, Henderson Island, and Desecheo Island - have failed. These efforts all attempted to eradicate rat species. The Wake Atoll Rat Eradication Review concluded that planning and associated research did not seem to adequately address some of the key issues and the general complexities of the project, and that the number of information gaps noted during the planning process should have led to serious consideration of postponing the project until those issues were more fully addressed. This is our main concern for the Farallon project." ~ EPA comment letter, 12/09/13
Retired USFWS Biologist Weighs In
Biologist Sonce DeVries recently retired from USFWS after 22 years. During her tenure as Acting IPM Coordinator from 2010-2012, she reviewed proposals for a number of island eradication projects. While she fully agrees that invasive species are an issue that need to be addressed, she feels strongly that the approach that has been used in the past by USFWS and Island Conservation is not the way to do it. Her six page comment letter found here reflects many of the same concerns I have regarding the inaccurate and misleading science behind this proposed project.
"My review of the references cited in this DEIS shows that some significant misinterpretations of the original references have occurred. The authors of this environmental impact statement must accurately quote the scientific literature and not insert words or phrases that imply or state a different conclusion from that of the original reference being cited. While the DEIS states that no choice of alternatives has been made, the text clearly indicates that the reader is being strongly encouraged to select Alternative B, the use of Brodifacoum as the preferred alternative. Well written EISs go to great lengths to present a completely neutral discussion of the facts and allow the reviewer to reach their own conclusions. The DEIS does not meet that requirement." ~ Sonce DeVries, retired biologist and former Acting IPM Coordinator, USFWS.
The Ocean Foundation
Richard Charter is a Senior Fellow with The Ocean Foundation and Vice Chair of the Gulf of the Farallones National Marine Sanctuary Advisory Council. When it comes to protecting our oceans and marine life, Richard is a seasoned advocate on issues such as marine spatial planning and the prevention and mitigating of industrial impacts on ocean ecosystems. His environmental work has helped to create the Gulf of the Farallones, Cordell Bank, Channel Islands and the Monterey Bay National Marine Sanctuaries.
Richard has many concerns about the proposed project that he outlined in this four page comment letter here from the Ocean Foundation. Richard has a wealth of experience surrounding Natural Resource Damages Assessments (NRDA) and has requested that USFWS and/or Island Conservation post a surety bond in the event of accidental rat poison spills into the ocean (which occurred during a New Zealand project) and the inevitable deaths of non-target animals due to exposure to brodifacoum.
"The Revised DEIS is inadequate in reflecting a casual and dismissive attitude throughout the document regarding the inevitable mortality of public trust living resources, such as numerous non-target species, including birds and marine life, in a manner which hardly presents a fairly-considered cost-benefit analysis. Throughout the DEIS the document instead attempts to rationalize the unnecessary killing of a lot of innocuous wildlife in the process of eradication of one species - the mice - but the document provides no conclusive evidence that the Ashy Storm Petrel will benefit over the long term from all of this collateral damage throughout the overall ecosystem." ~ Richard Charter, Senior Fellow, The Ocean Foundation.
American Bird Conservancy
American Bird Conservancy is the only bird conservation organization that hasn't been drinking the USFWS/Island Conservation Kool-Aid about this proposed project. I think they are the only birding group that took the time to read and think critically about what USFWS wants to do. Below is a quote from the ten page comment letter submitted last month.
"American Bird Conservancy is concerned about the tenuous and indirect connection between the stated goals of the Project and the proposed means of achieving them. The conclusions in the RDEIS are founded on what we deem to be a faulty and incomplete analysis. We are concerned about poisoning the Farallon food web, including migrating raptors, sea birds, native terrestrial species, and marine mammals, and about what we consider an unacceptable level of projected incidental mortality of Western Gulls. We are also worried about the potential to cause long-term damage to the very practice of eradication of non-native mammals from islands. Related concerns include, but are not limited to, the inflated projection of effectiveness of gull hazing operations, the inadequate consideration of alternative methods of bait delivery, the biased selection of modeling assumptions, the exclusion of data from Rat Island, the under-estimation of brodifacoum toxicity, and the unorthodox and potentially biased risk assessment assumptions for diphacinone." ~ George H. Fenwick, PhD, American Bird Conservancy
Dolphins and Penguins Die Following Drops in New Zealand
To better understand what happens with island eradication projects, watch this news report which tells what happened on two islands in New Zealand after brodifacoum was aerially dropped over two islands. Notice how Richard Griffiths with the New Zealand Department of Conservation dances around the repeated question with respect to the testing of dead dolphins and penguins for exposure to brodifacoum. Richard is now employed by Island Conservation.
Despite the critical data and the many voices of opposition, USFWS may still decide to move forward. My plea to USFWS is to remember the work of one of their own most influential biologists, Rachel Carson. Her revolutionary book, Silent Spring, published in 1962, sounded the alarm about the environmental impacts of pesticides and the penetrating influence the chemical industry has on commercial agriculture. Fifty two years later, the dominion of the pesticide industry continues and has now expanded beyond the confines of agriculture to include invasive species as another market opportunity to exploit. With respect to the South Farallon Islands Mouse Eradication Project, this is the "con" in conservation.