In Hawaii, the Department of Land and Natural Resources (DLNR), and U.S Fish & Wildlife, (USFWS) are planning several rat poison drops via helicopter onto Lehua Island, located approximately 30 miles west of Kaua’i. These drops are being fast-tracked for this summer, part of an eradication project for the 284 acre bird sanctuary. The planned drop is ¾ of a mile from an important Native Hawaiian community, the Ni’ihauans. There is risk that the poison pellets (lethal anticoagulant rodenticides) could impact the biologically diverse and important Lehua Crater.
Sources indicate that DLNR and USFWS are pressuring the State Department of Agriculture to grant permission for the poison bait to be dropped right up to the shoreline, which will result in bait entering the marine environment, allowing the toxins to infiltrate and settle in waters frequented by commercial and Native Hawaiian subsistence fishermen.
The agencies will not disclose or estimate the duration or extent of any fishing bans for tour and recreational boats in surrounding waters. The extent of a ban might be of concern to the local fishing and tour boat communities, given that a 942-day fishing ban was recommended after another Island Conservation poison drop on Wake Island in the in 2012.
If given the green light, the poison drops will happen on Lehua this summer, delivering an estimated 8-10 tons of anticoagulant rodenticide. Birds, fish, monk seals, and other wildlife that consume the cereal-based poison bait either directly or indirectly (secondarily) will be affected, and there is risk of contaminating the food web.
Note: the estimated application rate has been calculated from the amount disclosed on a kg/per hectare basis. Pesticide labels were not included in the draft environmental assessments (EA), so it is unclear if the proposed amount to be dropped is within legal limits.
Lehua Controversy – The Failed 2009 Poison Drop – Fish Die-Off and a Dead Whale
This will be the second poisoning of Lehua in the name of “conservation,” after a failed attempt in 2009. The previous drop was highly controversial—dead fish washed up on the neighboring island of Ni’ihau, and a juvenile whale beached itself. The state of Hawaii claimed the fish die-off and dead whale were “coincidental” and not related in any way to the nearly four tons of rat poison that had been dropped on the island just days earlier.
After researching the failed event in 2009, which included findings in this presentation given at a national pesticides conference, questions remain about what really happened. Why was there a two month delay in requesting the fish be tested for exposure to the poison? Since the rodenticide used in 2009, diphacinone, metabolizes quickly, did the delay in testing capture meaningful results? Are the chain of custody documents available for review? Could ultra-nutrification and de-oxygenating of the waters, due to the cereal component of the poison bait that entered the surrounding ocean, be a contributing reason for the algae bloom, which, officials claimed, was the cause of the fish kill? Or, could the poison pellets that entered the marine environment have impacted the fish, not enough to kill them, but enough to cause immunosuppression, thereby making the fish more susceptible to the impacts of an algae bloom? These questions have never been addressed by the agencies.
Are Rats a Problem on Lehua? – Not According to the Data
The data provided in both draft EAs (both the state and feds created a draft environmental assessment) does not support that the rodents on Lehua are having a negative impact on the bird life on the island. All evidence provided is anecdotal, and astonishingly, USFWS has no idea of the size of the rodent population. One could reasonably ask—since this critical piece of data is unknown—why is this project being fast tracked?
The agencies need to respond to these questions: Why is the collateral damage and potential risk to the food web, in addition to putting sustenance and commercial fishermen in jeopardy, worth the risk? How much consideration was truly given to the Native Hawaiian Ni’ihauans in this accelerated operation, aside from conversations set up and/or attended by the owner of Ni’ihau, the Robinson family?
The only evidence of rodent impact to birds included in the state issued EA shows that four eggs from the nest of a wedge tail shearwater showed indication of predation by rats. As the wedge tailed shearwater is considered to be a species of least concern by the IUCN (with a worldwide population of over 5 million birds), this hardly constitutes a scientifically-based rationale for dropping 8-10 tons of pesticide, threatening the fragile ecosystem, rare reef system, and food chain. DLNR and USFWS have yet to respond to public demands for site-based scientific (vs. anecdotal) evidence on the Lehua rat population, bird decline and mortality causation on Lehua, if any, that justifies this large scale poison drop.
Downplaying Risks to People and the Environment – The Selling of Island Eradication Projects
Both EAs issued mispresent environmental risks, and make misleading statements about the lethal and sub-lethal impacts to wildlife poisoned, which are referred to as “non-target species.”
Though the proposed poisons have never been tested on coral reefs, and the impact is completely unknown, the EA makes the puzzling, badly worded statement on page 73 of the federal EA that “there are no data to indicate corals have been impacted by anticoagulant rodenticides from previous eradication projects.” Since there are no studies which reflect that rodenticide testing on coral reefs has ever been carried out, and long term, ecosystem monitoring is lacking in eradication projects, the above statement made in the EA could be viewed as disingenuous. I asked Dr. Mourad Gabriel, who has done extensive research on wildlife diseases, including the impacts of rodenticides on wildlife for his thoughts on the statement specific to coral reefs - his response can be found below.
"The lack of data collected on a topic should not imply that a deleterious impact does not occur." - Mourad W. Gabriel MS, PhD - Executive Director of Integral Ecology Research Center.
Page 51 of the federal EA cites studies from 1977, 1998, and 1999 with respect to birds eating the poison bait and make the following, false claims:
9. To minimize consumption of bait pellets by shorebirds and terrestrial birds, the bait pellets are dyed a green or blue color, which birds appear to prefer less than yellow or red. 10. Bait pellets are formulated large enough that it would be difficult for a small, seed-eating bird to consume the whole pellet.
The video below, from the New Zealand documentary, “Poisoning Paradise – Eco-cide NZ,” is evidence that color and size of the pellets will not deter birds or other animals from eating them. Deaths of birds poisoned during these projects can occur either directly from eating the bait, or secondarily, by consuming poisoned rodents, insects and fish. Video courtesy of Clyde Graf.
Island Eradications – Previous Problems
Information received from a FOIA request filed in 2014 reveals serious ethical issues from previous eradication projects and shows the consequences of what can go wrong.
Rat Island – in October 2008, USFWS and Island Conservation aerially dropped 51 tons of brodifacoum over Rat Island, located in the Aleutian Islands, and then left for eight months. When they returned, over 400 dead birds were collected, including 46 bald eagles. Note: the total number of poisoned wildlife counted was by no means the total number of animals poisoned, nor was any long term monitoring done to test for sub-lethal impacts.
In the investigation that followed, U.S. Fish & Wildlife Law Enforcement division reported ten illegal actions including exceeding legal application rates mandated by the pesticide label, failure to properly calibrate dispersion equipment and failure to keep accurate records of their pesticide applications.
You can read a copy of the full USFWS law enforcement report here, released as the result of a FOIA request.
After the investigation by USFWS law enforcement, the Ornithological Council issued this scathing report. You can find a copy of it here.
Wake Island – located in the South Pacific, Wake Island is host to a military base and is under the jurisdiction of the U.S. Air Force. Wake Island was the recipient of an island eradication attempt in 2012, carried out by Island Conservation and USFWS. While the almost 20 ton rat poison drop failed to kill all the rats, the more serious issues are the internal emails released in response to the 2014 FOIA request. The discussions between USFWS, the USAF and Island Conservation show that after the fish were tested for brodifacoum, a fishing ban was recommended for 942 days.
FYI – note the Wake Atoll brodifacoum results analysis. We have a couple of options. I guess it comes down to how long we want to restrict consumption of fish at Wake. The current recommendation is approximately 942 days. Also with no money [and] furloughs occurring July 8 – end of September, it is unlikely that a sampling project will occur this FY. I’ll keep you in the loop, but thought you’d might like this info for future projects.” - USAF
You can find the entire email exchange containing the details of the fishing ban recommendation here.
While USFWS and the state of Hawaii assert that no final decision has been made, sources indicate that this project is planned for this summer, and that lead state agencies are awaiting approval from the Hawaii Dept. of Agriculture (Pesticides Division). It is notable that some of the supporting state agencies for this poison drop are currently facing a federal investigation charging racial discrimination against Hawaii’s native communities in their lack of care in state pesticide regulation.
The Farallon Islands – Rejected Project on the Mainland
This is not the first time that helicopter drops of rodenticides have been called into question. In 2013, a planned rodenticide drop of 1.5 tons of brodifacoum over the Farallon Islands National Marine Sanctuary was halted due to public opposition and heavy questioning into Island Conservation’s conflict of interest in authoring the draft environmental impact statement. The city of San Francisco closed their strongly worded letter urging USFWS to seek a partner for the risk assessment that did not have a financial interest in the project.
It remains to be seen whether Hawaii’s impacted communities and scientists will demand fuller disclosure and further study from its agencies and sole-source contractor Island Conservation. For it is Kaua’i’s fishing and tourism industries, and local Hawaiian residents that have the most to lose if anything should go wrong.
In 1962, with the publication of “Silent Spring,” Rachel Carson warned us of the influence the pesticide industry has on agriculture. Fifty-five years later, the dominion of the pesticide industry continues, and non-native species has become another market opportunity to exploit.