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The Proposal to Poison a Wildlife Refuge

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About a week and half ago it came to my attention that US Fish & Wildlife Service is considering the aerial spraying of one of the most deadly poisons to wildlife, brodifacoum, as part of the South Farallon Islands Non-native Mouse Eradication project. The aerial disbursement of loose pellets of rat poison over an area designated as a wildlife refuge will result in unnecessary and extensive loss of wildlife, and the long-term affects of dumping a toxic pesticide on this fragile ecosystem are unknown.

On Thursday of this week, US Fish & Wildlife Service held a public scoping meeting in San Francisco to discuss this proposal and take comments from the public. I looked forward to this meeting and prepared the following letter to US Fish & Wildlife.

Oddly enough, at this public scoping meeting I was not allowed to read the comments I had prepared. Nor were any other members of the public that attended this meeting allowed to make statements. We were given a power-point presentation on this project, and then we broke off into small focus groups to discuss our concerns with employees of US Fish & Wildlife.

I would like to take this opportunity to share my comments on behalf of WildCare with you.

To learn more and sign our petition against this proposed crime against nature please visit

South Farallon Islands NEPA Scoping Comments
C/o Gerry McChesney
Farallon NWR Manager

Re: Scoping Notice for South Farallon Islands Non-native Mouse Eradication Project

Dear Mr. Chesney

For the last 50 years WildCare has been treating and rehabilitating injured wildlife in the San Francisco Bay area. We treat approx 4000 animals annually, with a range of over 200 species. 95% of the cases we treat are the result of animals coming into negative contact with people. These include animals being hit by cars, birds tangled up in fishing lines and hooks, wildlife attacked by domestic pets, glue traps, poisons and many beneficial predators killed by rodenticides.

In addition to my work as Director of Advocacy at WildCare, I have served as an appointed member of the IPM Commission for Marin County since 2009. Our focus as a Commission is to advise the Board of Supervisors on how to reduce pesticide use on county land. IPM (Integrated Pest Management) is a science based, decision making process for managing animal and plant pests using a combination of non-chemical and least toxic chemical controls. The spirit of IPM embraces that pesticides are used as an absolute last resort. It is this shift to IPM that has helped the County of Marin reduce pesticide use by over 90%, and implement site specific plans for county managed land and buildings. Rodenticides can not be used for rodent control unless an exemption has been granted, and a public health emergency declared by the county health officer.

What I have been shown in doing this work is that the use of rodenticides in our world is prolific and all too easy. WildCare experiences the tragic end result of what occurs when a vital food source for wildlife (rodents) becomes poisoned. When wildlife consumes poisoned rodents, they too, die a horrific death.

What happens far too often is that WildCare will receive a healthy, fit raptor or some other beneficial predator that has no visible signs of trauma, other than the fact that the animal is severely hemorrhaging from its mouth, ears, eyes and other body orifices. When our medical staff encounters this heartbreaking scenario, the protocol we follow consists of administering high doses of Vitamin K and other fluids in an attempt to prevent the animal from bleeding to death. Sometimes we are successful, sometimes not. The cases we admit for secondary poisoning are preventable, unnecessary and are the direct result of human interference with the natural world.

It is because of our front line experience in treating the many victims of secondary poisoning that we find ourselves called and compelled to educate the public, and to speak out against the indiscriminate use of these deadly pesticides that are already proving to be the next DDT.

Along with USFWS, PRBO and Island Conservation, WildCare is concerned about the impact, and the actual damage caused by this non-native mouse, and the plight of the Ashy Storm-Petrel and the Burrowing Owl. In addition, we are deeply concerned about all the wildlife on the Farallon Islands including the 11 other species of seabirds that have a breeding population of over 250,000, the 36 species of marine mammals, the reptiles and amphibians, plus the raptors and corvids that have been migrating and taking up residence. All of these animals, plus the entire ecosystem are being placed at risk if we were to allow an aerial spraying of rat poison.

Simply inserting the word "conservation" in the pesticide label and slightly watering down the percentage of the active ingredient, brodifacoum, does not make this rodenticide safe for wildlife, nor will it make it any less persistent. The lethal affects on non-target species of Brodifacoum 25 conservation is well documented in the Dec. 2010 analysis written by the Ornithological Council on what went so very wrong on Rat Island in 2008.

Yesterday, I was invited by Gerry McChesney to participate in a conference call to discuss my concerns about the option of aerial rodenticide spraying. On the call was Doug Cottrell with USFWS and Gregg Howald from Island Conservation. I do appreciate you reaching out to me and I did learn quite a bit on that call. One thing I discovered is that there are many unanswered questions regarding how this second-generation rodenticide affects the ecosystem long-term. What happens to the active ingredients in brodifacoum after the pellet breaks down into the soil? What about the inert ingredients? How will that affect plant life? What will happen when the poison penetrates the very permeable skin of the Farallon arboreal salamander? How will introduced anticoagulants impact aquatic life?

If we don't understand the reverberations or implications of one of the most lethal & persistent poisons being introduced to the environment, I will then defer to common sense. Don't use it.

In discussing the wildlife mortality at both Rat Island and Anacapa yesterday, I am grateful for the honesty shared on that call. This same aerial approach that was used in 2008 on the Rat Island Eradication Project is being considered as an option for the Farallon Islands. According to Terry Salmon's investigation of Rat Island, human error and lack of communication led to mistakes and caused the deaths of over 420 birds, including 46 bald eagles. Quoting directly from the executive summary, page 3 of the report prepared by The Ornithological Council below

"Further, we identified aspects of the planning and implementation process that contributed to the decision-making that in turn led to the application of too much bait, too fast which in turn contributed to the primary and secondary routes of exposure that resulted in the non target mortality. These included inadequate documentation of the basis of decisions, an apparent lack of routine processes to verify calculations, and communication gaps. Two of the partners appeared to lack sufficient expertise or did not avail themselves of the expertise of their staffers when evaluating key decisions and there was inadequate follow up on recommendations made by external reviewers."

And now, Island Conservation and USFWS want to do this all over again at the South Farallon Islands.

It was explained to me yesterday that what happened at Rat Island and on Anacapa Island were "learning experiences." How many more unnecessary deaths have to occur before the lessons are learned? Should our wildlife pay the ultimate price because they were simply in the wrong place at the wrong time? Can we risk one more learning experience when the price we pay is potentially the entire ecosystem of the South Farallon Islands?

In the midst of this, an unwelcome rodent-eating guest has also appeared. The Burrowing Owl has made its way to the Farallon Islands. The interesting thing is that both the Burrowing Owl and the Ashy Storm-Petrel share the same conservation status as being "a species of special concern." I did hear the statement that it is the mice that are the primary food source attracting the Burrowing Owls. It is believed that the Burrowing Owls are also predating on the Ashy Storm-Petrels. Burrowing Owls are also under tremendous pressure due to loss of habitat caused by development and encroachment. Survival instincts in nature are strong and wildlife will adapt to a changing global environment. Left on its own, animals will adapt to survive. This is what is happening here with the winter arrival of the Burrowing Owls. Now humans are contemplating interfering, by giving a more favored nation status to the Ashy Storm-Petrel over the Burrowing Owl. The question that troubles me the most is how do we decide which species gets preference over the other? How do we make that judgement call?

Is this worth the risk? Is it worth the collateral damage to wildlife and the fragile ecosystem, in a noble attempt to save one species of special concern, which may or may not need our help.

The more I learn about the South Farallon Islands Mouse Eradication project, and the challenges facing USFWS, the more convinced I become that this issue calls into play ethical questions in wildlife conservation. Is it acceptable to sacrifice or favor one species over another? How ethical is it to introduce lethal and persistent poisons into an ecosystem that is designated as wilderness?

It is my heartfelt wish that more options were available than what was listed in the Scoping Notice dated April 26, 2011. The choices consist of 1) do nothing, or 2) an aerial broadcast of one of the most deadly poisons known to wildlife.

Because of the impact to wildlife and the unknown impact on the entire ecosystem, WildCare strongly encourages USFWS and PRBO to not move forward with an aerial broadcast of rodenticide. We do understand that the impact caused by non-native mice is serious, and we support the continued investigation into possible alternatives.

In addition to our comments WildCare would like to deliver the results of our online petition. Over the past 24 hours we have collected over 1,650 signatures from concerned members of the public, all opposing the possibility of an aerial dispersal of rodenticides.

Thank you for including WildCare in these discussions.

Best Regards,
Maggie Sergio
Director of Wildlife Advocacy

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