“San Francisco’s Natural History”: A mixed bag of fact and fiction

Million Trees breaks its self-imposed silence to bring you this book review of San Francisco’s Natural History:  Sand Dunes to Streetcars, by Harry G Fuller.  It was frustrating to read this book because I had high expectations that I would like it and learn from it.  And to some extent, I did.  However, the book also repeats old myths about eucalyptus that have long ago been debunked and fabricates a new myth.  It also supports deadly and dangerous “restoration” projects in the Bay Area without acknowledging the loss of wildlife they cause. On the other hand, historical records of San Francisco’s natural history seem to be accurately reported by Fuller and he paints the picture of pre-settlement San Francisco as drifting sand dunes and treeless grass and chaparral. 

Persistent myths about eucalyptus

Fuller says, “There is evidence…that eucalyptus trees may be deadly to both wintering birds and monarch butterflies…At the same time the trees provide necessary shelter, their chemical make-up and their sticky leaves may prove deadly.”

Hummingbird in eucalyptus flower. Courtesy Melanie Hoffman

Fuller does not provide the “evidence” for this statement, so we must speculate about what he means.  It seems likely that he is repeating the 23-year old claim that eucalyptus kills birds by suffocating them with their sticky nectar when eucalyptus blooms in winter months. (Neither the nectar, nor the leaves of eucalyptus is sticky.)  A local birder reported seeing two dead birds in eucalyptus forest over the course of his long career as a serious birder and parlayed those isolated observations into the generalization that birds are killed by eucalyptus trees.  Decades of research was required to put that accusation to rest. (1, 2) Officially, the myth died when the California Invasive Plant Council updated the classification of eucalyptus in 2015.  The claim that eucalyptus kills birds was deleted from Cal-IPC’s revised classification. It was aggravating to see this claim repeated by Mr. Fuller in his book, which was published in 2017.

Fuller’s claim that eucalyptus is also deadly to monarch butterflies is unprecedented.  I have heard innumerable stories about the bad habits of eucalyptus, but I have never heard that eucalyptus kills monarch butterflies.  You won’t find that accusation anywhere on the internet and you won’t find it anywhere in the scientific literature.  I confirmed with Art Shapiro, Distinguished Professor of Ecology and Evolution at UC Davis and author of Field Guide to Butterflies of the San Francisco Bay and Sacramento Valley Regions, that he had never heard that claim either. 

In fact, available empirical evidence contradicts that claim. Eucalypts are the preferred trees for over-wintering monarchs in California:  “Three types of trees were used most frequently by roosting monarchs:  eucalyptus (75% of the habitats primarily Eucalyptus globulus), pine (20% of the habitats primarily Pinus radiata), and cypress (16% of the habitats Cupressus macrocarpa).  Twelve other tree species were identified…with a combined prevalence of only 10%.” (3)  Monarchs migrate down the coast of California during the winter months, when eucalyptus is flowering at a time when there is little else blooming in California.  They are an essential source of nectar during the monarch migration. 

Fuller says, “The eucalyptus’s natural herbicides prevent many other plants from growing beneath their canopy.”   

This is another accusation that has been repeatedly disproven by empirical research.  The eucalyptus forest is as biodiverse as native oak woodland (4).  The 2015 revision of the California Invasive Plant Council assessment of eucalyptus deleted previous mention of the allelopathic (the scientific term for “natural herbicide”) properties of eucalyptus.  A rigorous study at Cal Poly concluded, “In these experiments, we found that germination and seedling growth of the species tested were not inhibited by chemical extracts of blue gum foliage, either at naturally-occurring or artificially concentrated levels.” (5)  This study was presented by its author at the most recent conference of the California Native Plant Society, which should establish its credibility with native plant advocates.

Presentation at conference of California Native Plant Society

Fuller says in support of his “natural herbicide” theory, “You never see moss or lichen on a healthy eucalyptus trees.”

We don’t see moss or lichen on eucalyptus tree trunks because the thin, papery bark on the trunk sloughs off annually, leaving the trunk bare.  Moss and lichen grow slowly on tree trunks in the bark that remains on the tree throughout the tree’s life.

Spartina (aka cordgrass) eradication

Ironically, Mr. Fuller prefaces his strong support for cordgrass eradication with this admonition:  “Do not forgive ignorance, please.”  Then, he displays profound ignorance of the consequences of cordgrass eradication in the San Francisco Bay Area.  Fuller is a professional birder, yet he is seemingly unaware of the fact that the eradication of cordgrass has nearly wiped out the population of endangered Ridgway Rail (formerly Clapper Rail) in the Bay Area.  He is also unaware of the huge quantities of herbicide that have been used to eradicate cordgrass.  Elsewhere in his book, he expresses concern about pesticides and other forms of pollution, yet in the case of cordgrass eradication he turns a blind eye.  (6)

Pesticide Application Notice, Heron’s Head, 2012

Eradication of mice on Farallon Islands

Mr. Fuller also supports plans to eradicate mice on the Farallon Islands:  “The latest effort to return the Farallones to a more natural preserve is an attempt to remove all the house mice.”  He is either unaware of plans to aerial bomb rodenticides on the Farallons to kill the mice or he chooses to use the euphemism “remove” to avoid the issue.  Elsewhere in the book, he mentions that rodenticides used in Golden Gate Park to kill rats also killed Great Horned Owls that ate the dead or dying rats.  He seems to understand that non-target birds are killed by rodenticides, yet he apparently supports the use of rodenticides on the Farallons, a national marine sanctuary.  (7)

Farallon Islands, NOAA

A Cautionary Tale

Mr. Fuller displays a sincere concern for the wildlife of San Francisco throughout his book.  He also acknowledges the very real threats of climate change and pollution for the future of the environment in the Bay Area.  I do not doubt his sincerity and I believe he has written a valuable book that is unfortunately damaged by his uncritical acceptance of inaccurate versions of several important environmental issues in the Bay Area.  I believe Mr. Fuller has been a victim of “incestuous amplification” in his acceptance of these myths.  Let that be a lesson to all of us to look deeply at every issue and to verify any tale you are told by an amateur or someone with a vested interest in those issues, such as employment. 

I cannot recommend this book to anyone who is not prepared to read it critically.  If you don’t already have a basic knowledge of the natural history of San Francisco you could easily be led astray by baseless rumors. 

  1. https://milliontrees.me/2013/11/05/eucalyptus-trees-do-not-kill-birds/
  2. https://milliontrees.me/2014/07/26/birds-and-butterflies-in-the-eucalyptus-forest/
  3. Dennis Frey and Andrew Schaffner, “Spatial and Temporal Pattern of Monarch Overwintering Abundance in Western North America,” in The Monarch Butterfly Biology and Conservation, Cornell University Press, 2004.
  4. https://milliontrees.me/2011/02/04/biodiversity-another-myth-busted-2/
  5. https://milliontrees.me/2018/02/06/highs-and-lows-of-the-2018-conference-of-the-california-native-plant-society/
  6. https://milliontrees.me/2014/06/02/spartina-eradication-herbicides-are-their-dirty-little-secret/
  7. https://milliontrees.me/2014/01/10/the-mouse-eradication-project-on-the-farallon-islands-the-con-in-conservation/

Island eradications in the Bay Area rear their ugly head again

The Farallon Islands are a National Wildlife Sanctuary just 27 miles off the coast of San Francisco, where millions of birds and marine animals are legally protected.  Plans of the US Fish and Wildlife Service (USFWS) to aerial bomb 1.3 metric tons of rodenticide to kill mice on the Farallon Islands originated over 5 years ago.

Farallon Islands, NOAA
Farallon Islands, NOAA

The stated purpose of this project was to protect the ashy storm petrel, a legally protected species of concern.  The mice are not a direct threat to the petrel.  Rather, USFWS claims that another legally protected species of concern, the burrowing owl, eats the chicks of the petrel when the population of mice dwindles.  Because the average population of burrowing owls on the Farallons is said to be only 6 burrowing owls, the scale of their predation of petrel chicks seems minimal given that their preferred prey is mice.  USFWS theorizes that if the mice are killed, the burrowing owls will leave the Farallons.  This rather fanciful scenario is less credible than the more likely outcome that the burrowing owls will either be killed by the poison or eat yet more petrel chicks if their mice diet is eliminated.

Aside from the convoluted and questionable rationale for this project, the main concern is the anticipated collateral damage caused by aerial bombing huge quantities of rodenticide (brodifacoum).  The planned rodenticide is an anti-coagulant that is highly persistent and causes all vertebrate animals (mammals, reptiles, birds, fish, etc.) to bleed to death.  Death is not quick; the poisoned animals stumble around before dying and are easy prey for other animals that are then killed by the poison.  Dead, poisoned mice are equally attractive food for some birds.  The poison pellets are also as appealing to other animals as to mice.  Even the supporters of this project readily admit that many animals other than mice are likely to be killed directly by the rodenticide or as secondary victims.  “Stuff happens,” they say with a shrug.

The author of the Environmental Impact Statement is the same organization—Island Conservation—that will implement the project, if and when it is approved.  This conflict of interest seems one of many unwise decisions made by US Fish and Wildlife Service.

The opposition to this project has been loud and clear.  Maggie Sergio, who reported this project on Huffington Post, published a petition in opposition to the project that was signed by over 32,000 people.  And many prestigious organizations including the EPA, American Bird Conservancy, City of San Francisco, The Ocean Foundation, and several retired USFWS scientists, have also criticized the project.  Yet, five years later approval of the Revised Draft Environmental Impact Statement is still pending. Theoretically this project is still alive.

Farallons project comes to life again

The Farallons project has always seemed to us so ill-advised and misconceived that we could not believe it would materialize.  We have therefore not covered it since 2014 when we republished Maggie Sergio’s Huffington Post article and asked people to sign her petition.

Unfortunately, we were under-estimating the power and influence of the supporters of this project.  Bay Nature, a local nature magazine, recently published an article about the Farallons project and island eradications in general.  That article seems to assume there is consensus that mice must be eradicated on the Farallons and that the only question is the method that will be used (more about Bay Nature’s proposed method later).  And the California Invasive Plant Council (Cal-IPC) has published an endorsement of island eradications—including the Farallons—in its most recent newsletter (available here: Cal-IPCNews_Summer2016).  Cal-IPC’s preferred strategy for eradications is aerial application of rodenticide.  Therefore, our concern about the proposed Farallons project has once again been elevated to crisis levels.  When two local organizations, which claim to advocate for conservation endorse the Farallons project, we must take it seriously.

History of island eradications

Since learning about plans to eradicate mice using rodenticides, we have learned that the practice originated in New Zealand, where poison applications began over 60 years ago to kill a wide range of non-native animals.  Bill Benfield tells the entire story of eradications in New Zealand in his book, At War With Nature.  (1) We have relied on that valuable resource for this article.  That history is relevant to us because there are some striking similarities between the North American and New Zealand versions of invasion biology, the ideology that drives eradication attempts in North America and New Zealand.

The moa was a huge flightless bird that was hunted to extinction by Polynesians when they occupied New Zealand.
The moa was a huge flightless bird that was hunted to extinction by Polynesians when they occupied New Zealand.

Humans occupied New Zealand more recently than their arrival in North America.  Prior to their arrival, New Zealand was inhabited by many flightless birds that were successful because they had no predators.  The moa was the largest of those birds.  Although it has been extinct for hundreds of years, palaeontologists tell us the moa was about 12 feet tall and weighed about 500 pounds.  It was easy prey for the first humans who arrived in New Zealand about 800 hundred years ago from Polynesian islands.  As most sea-faring humans do, they unintentionally brought with them a species of rat, the kiore.

The climate of New Zealand is much colder than the Polynesian home of the first humans and their agriculture was not well suited to the climate of their new home.  The moa quickly became the main source of food for the humans. The moa were rapidly driven to extinction by hunting, which forced the humans to retreat to the northern end of New Zealand where the climate is milder and their agriculture was more successful.

Although there is some debate about the size and range of the moa population, Dr. Graeme Caughley reported that the moa population was very large and widely spread, based on a calculation of the available sustainable bio-mass.  He believes moa populations existed in all vegetation types, including forests where they would have browsed the forests.  Intense browsing of the forests would have encouraged the growth of the slower growing and unpalatable browse-resistant trees that became the forest giants. The faster growing species of trees were the palatable browse- tolerant species that were held back by browse, allowing the growth of slower growing trees that would in time become the forest giants.  The moa also would have spread the seeds of the trees they ate and inhibited the growth of an understory.  In other words, the forest that humans found when they arrived in New Zealand around 1200 AD was adapted to the big population of moa.

In the absence of moa the composition of the forest quickly responded to the absence of browsing.  Fast growing trees that were formerly held back by browse were no longer at a disadvantage compared to slow growing and unpalatable browse-resistant trees; the forest under-story became denser.  The composition of the forest that was found by Europeans when they arrived in New Zealand several hundred years later was in transition. 

Forest in New Zealand
Forest in New Zealand

The first humans on New Zealand did not have a written language.  The landscape they found when they arrived is not recorded in history and is only known to the extent that archaeological and paleontological evidence is accurately used to reconstruct it.  As all human science does, these disciplines are continually evolving and therefore did not inform the earliest versions of ecology that spawned the eradication movement on New Zealand.  In other words, the forest found by Europeans when they arrived in New Zealand is still considered the pristine ideal that ecologists wish to replicate.  In fact, that landscape was just as modified by human habitation as any modern, “novel” ecosystem.

This fantasy of a pristine, pre-human landscape is similar to the fantasy in North America that the landscape found by Europeans when they arrived on the East Coast in the 16th century and the West Coast in the 18th Century was the “natural” landscape, unaltered by humans.  They are just as mistaken in that assumption as they are in New Zealand. Native Americans actively managed the landscape to serve their horticultural and cultural needs.  The consequences of that fantasy have been just as deadly and destructive in New Zealand as they have been here in California.

The deadly crusade in New Zealand

Europeans brought many animals with them to New Zealand, just as they did to North America.  They brought both domesticated animals such as sheep and wild animals such as deer that they could hunt.  The deer browse the forest, just as they do here, and the impact they have on the forest is similar to the impact moa had on the forest. The deer and other browsers are the functional substitute for the extinct moa. Fast growing palatable species of trees are disadvantaged by browsing and these are the trees that early ecologists considered the “natural” forests of New Zealand because they were the trees that were found when Europeans arrived. 

1080 Poison Warning in New Zealand
1080 Poison Warning in New Zealand

Deer poisoned by 1080. Graff Brothers, New Zealand
Graf Brothers, New Zealand

Hence, aerial poisoning of the land began over 60 years ago to kill all browsing animals in New Zealand except domesticated animals kept behind fences.  Smaller non-native animals such as possum are also targets for eradication because they are assumed to be predators of the few flightless birds that remain in New Zealand.  This accusation is refuted by Bill Benfield who tells us that possum are primarily vegetarians and that a study of the contents of possum stomachs found no evidence of bird predation.  Possum are also accused of being carriers of bovine TB, a disease that infects domesticated animals.  However, recent laboratory tests find no evidence that possum are infected with bovine TB, beyond minute levels.  In any case, the possum population is small because it is a species that rears only one pup per year, so its population would grow only slowly if they weren’t being exterminated in New Zealand.

The killing fields

A different poison is used in New Zealand–called Compound 1080–that operates in a different way than anti-coagulant rodenticide.  It kills indiscriminately any life form that requires oxygen.  It was developed as an insecticide in Europe, and was initially used in the US where it was briefly used to kill coyotes and other wildlife considered inconvenient predators until its use was severely restricted because of its extreme toxicity.  It is entirely banned in California, which is why our local version of island eradications use anti-coagulant rodenticide instead of 1080.

Graff Brothers DVD available on Amazon
Graf Brothers DVD available on Amazon

1080 is a slow, grisly killer of EVERYTHING: insects, fish, mammals, birds, amphibians, etc.  It is just as likely to kill native animals as non-native animals and it does.  This indiscriminate killing of every living thing in New Zealand was described in chilling detail by Elizabeth Kolbert in the New Yorker.  It is also visible in the videos of the Graf brothers for those with a strong stomach.  HERE is one of many of their videos.

Exporting death

We could turn a blind eye to what is happening in New Zealand if this strategy were not being exported all over the “civilized” world.  Amazingly, such island eradications have happened in many places and are being proposed in many places where local resistance is trying to prevent them from being implemented.  What have we learned from the projects that have been done?  The record is sketchy because very little after-the-fact monitoring of completed projects has been done.  What we DO know, suggests that it is not in the interests of the promoters of these projects to monitor the outcome of their projects because the results are consistently deadly and unsuccessful.

Killing one species of plant or animal does not restore an ecosystem

Readers of Million Trees will not be surprised to learn that killing one species does not magically “restore” an ecosystem to some historic ideal because ecosystems are very complex and their occupants live in communities with many, complex interactions that are not perfectly understood by humans, even humans calling themselves invasion biologists.

One study of islands off the coast of New Zealand compared the vegetation structure and ecosystems of three island systems: islands that never had rats, islands with rats, and islands on which rats had been “controlled.” They concluded that, “The extent to which structure and function of islands where rats have been eradicated will converge on uninvaded islands remains unclear…Since most impacts of rats were mediated through seabird density, the removal of rats without seabird recolonization is unlikely to result in a reversal of these processes. Even if seabirds return, a novel plant community may emerge.” (2)

There are many other factors that prevent the re-creation of historical landscapes, such as climate change.  There are undoubtedly many factors that are not known to us, which prevents us from “fixing” something we do not understand.  In any case, many of us don’t consider it necessary to “fix” something that we don’t consider broken.

Collateral damage and incompetent execution

In those few cases when after-the-fact monitoring was done, there is considerable evidence that many non-target animals were killed and the water was polluted.

In the case of Rat Island, off the coast of Alaska, no monitoring was planned after the aerial bombing of 46 metric tons of anti-coagulant rodenticide to kill rats.  However, neighbors of Rat Island demanded an investigation when they saw dead birds and animals floating in the vicinity of the island after the project was done.  That investigation (available HERE) was done by USFWS Law Enforcement.  The investigation found that the manufacturer’s recommendations regarding dosage were exceeded, that instructions to collect dead rats so they would not be eaten by birds were not followed, and that hundreds of birds died, including many legally protected bald eagles.  The investigation was not done until 7 months after the project was completed.  We should assume that the number of dead animals found would have been greater if the investigation had been done promptly after the project was completed.

Palmyra Atoll. USFWS
Palmyra Atoll. USFWS

In the case of Palmyra Island, off the coast of Hawaii, the scientific study conducted after the aerial bombing of rodenticides reported, “We documented brodifacoum [rodenticide] residues in soil, water, and biota, and documented mortality of non-target organisms. Some bait (14–19% of the target application rate) entered the marine environment to distances 7 m from the shore. After the application commenced, carcasses of 84 animals representing 15 species of birds, fish, reptiles and invertebrates were collected opportunistically as potential non-target mortalities. In addition, fish, reptiles, and invertebrates were systematically collected for residue analysis. Brodifacoum residues were detected in most (84.3%) of the animal samples analyzed. Although detection of residues in samples was anticipated, the extent and concentrations in many parts of the food web were greater than expected.” (3)

The rats return

The most damning evidence of all is that after killing untold numbers of animals, including those not meant to be killed, and poisoning the environment with a deadly toxin that bioaccumulates and persists in our bodies, the rat population often returns to pre-project levels within a few years. 

Henderson atoll in the Pacific is an example of such a failure.  Eighty tons of rodenticide pellets were aerial bombed on Henderson in 2011.  Apparently, at least two rats survived, one presumably male and one presumably female.  Within a few years the rat population had returned to pre-projects levels of 50,000 to 100,000 rats.

The rats were said to have been introduced to Henderson over 800 years ago.  Surely they had reached some balance between population size and available food sources.  Rats are an ancient species that would not be here if they completely wiped out their food sources.  Rat population growth is modulated by available food sources.  Hence, when almost completely eradicated, the rats rapidly reproduced back to equilibrium with food sources.

Claims that the Henderson project was urgently needed to prevent the extinction of a bird species with which rats had co-existed for over 800 years were bogus.  If rats had not exterminated the birds within 800 years, they weren’t likely to do so before this pointless project killed tens of thousands of animals, probably including many birds.

Like most “restoration” projects, claims are made about a conservation crisis that is often just an emotional appeal without any scientific basis.  Money is raised and spent in response to these fabricated crises and many “non-profit,” untaxed organizations subsist on these campaigns.  In the case of New Zealand, the poison they are using is manufactured by the government, creating an unholy financial incentive for these eradication projects. 

The failure of the extermination attempt on Henderson is not an isolated incident.  Lehua is one of the Hawaiian islands on which extermination was attempted and failed.  An evaluation of that attempt was published in 2011 to determine the cause of the failure so that a subsequent attempt would be more successful.  That evaluation included this report on the success of similar attempts all over the world:  “An analysis of 206 previous eradication attempts against five species of rodents on islands using brodifacoum or diphacinone is presented in an appendix to this report. For all methods, 19.6% of 184 attempts using brodifacoum failed, while 31.8% of 22 attempts using diphacinone failed.”  Brodifacoum and diphacinone are both anti-coagulant rodenticides.  Diphacinone is considered less toxic and less persistent than brodifacoum.

The silver bullet?

The “restoration” industry is meeting with a great deal of public opposition.  Because some of the opposition is based on concerns about polluting the environment with pesticides–such as herbicides used to kill plants and rodenticides used to kill animals–the “restoration” industry is looking for a less controversial method of accomplishing their deadly goals.

This brings us back to the recently published article in Bay Nature about island eradications.  The article informs us that a genetic modification of mice is now being developed, which would drive that species to extinction by ensuring that all off-spring would be males, thereby ending reproduction of the species. This method has a seductive appeal because it would not poison the environment.  However, it is an insidious proposal and we will let some of the commenters on the Bay Nature article tell us why, because some of them sound like knowledgeable scientists with ethical concerns:

  • Has the conservation movement lost its mind? Gene drive is unsafe, unproven and unethical. It is the most insane idea I have heard of in my 20 years reporting on genetic engineering. And it is presented here with no critical analysis, scientific, ethical, or environmental. I have spent my life in conservation and want to do all I can for to stop extinction but using extinction to stop extinction? Gene Drive is a technology that says one species (us) gets to decide which other species live or die. This is not populations that will be eradicated, it is aimed at an entire species. Who likes pests like rats or mosquitoes? But think. What’s next? Could this be a cynical ploy to use conservation to test this dangerous technology? Because once accepted it can then be used for many far less “acceptable purposes – such as a bioweapon.” – Claire Cummings
  • “The Alison Hawkes article reminds me (as a Kiwi i.e. New Zealander) of the mad and dangerously flawed science that is rampant in New Zealand. And just because it’s labelled science, don’t unquestioningly believe in it. Scientists here have to operate under a commissioned, paid science regime. The science becomes warped and inaccurate. Too often pseudo science (e.g. New Zealand’s destructive 1080 programme) intrudes and disrupts the natural ecosystem with disastrous consequences.  In NZ, objectives are often founded on unrealistic goals, i.e. turning NZ ‘s ecological clock back to 500AD. That’s impossible while humans and mad science remain.” – Tony Orman
  • It is extremely disappointing to see Bay Nature carry an article on such a controversial and risky plan with such lack of balance or even basic journalistic diligence. Contrary to the impression presented here CRISPR CAS9 gene drives are highly immature – it being barely 15 months since the first proof of principle of the ‘mutagenic chain reaction’s shown and they already have generated enormous controversy including a 200 page National Academy of Sciences Study that warned against open release and growing discussions at the Convention on Biological Diversity where there have been strong calls for a moratorium on this risky new technology.” – Jim Thomas

It seems that destructive “restoration” techniques are developing faster than human common sense can keep up with.  What can we do to slow it down?  What can we do to prevent the pointless poisoning of our environment and the needless killing of defenseless animals and harmless plants?  I don’t know the answer, but I will keep asking the questions and I hope my readers will as well. 

Update:  The Final Environmental Impact Statement for the mouse eradication project on the Farallon Islands was published on March 15, 2019.  The Final Environmental Impact Statement recommends the original plan as the “preferred alternative.”  In other words, despite intense opposition to this plan, its implementation is now eminent. 

No public comments are allowed on a Final Environmental Impact Statement, so there’s nothing further we can say about what seems to be an unnatural disaster in the making.  At this stage of a project, lawsuits are the only way to stop it.  I don’t know if anyone is willing and able to sue. 


  1. William F Benfield, At War With Nature: Corporate Conservation and the Industry of Extinction, 2015, available on Amazon.com in digital format
  2. Christa Mulder et.al., “Direct and indirect effects of rats: does rat eradication restore ecosystem functioning of New Zealand seabird islands?” Biological Invasions, August 2009, 1671-1688
  3. William Pitt, et. al., “Non-target species mortality and the measurement of brodifacoum rodenticide residues after a rat (Rattus rattus) eradication on Palmyra Atoll, tropical Pacific,” Biological Conservation, May 2015, 36-46

“The mouse eradication project on the Farallon Islands: The ‘con’ in conservation”

We are republishing the following article published by Huffington Post on January 7, 2013, with permission of the author, Maggie Sergio.  Maggie has done some impressive research about the appalling project to aerial bomb the Farallon Islands with rodenticides to kill mice.  We shudder to think about how many other animals will be killed by this project.  Please sign the petition to US Fish and Wildlife to abandon this horrible plan.  The petition is available HERE.

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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 aspecies of special concern, is being indirectly impacted by the presence of mice.

Photo of ashy storm-petrel courtesy of Wikipedia images. Photo taken by Duncan Wright
2014-01-04-ASPDWrightresize.jpeg

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.

Photo of burrowing owl courtesy of Wikipedia images. Photo taken by Dori Merr
2014-01-04-BurrOwlresiz.jpg
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 thisstory 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.

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 andPRBO (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 herereflects 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 BankChannel 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.


Update:  The Final Environmental Impact Statement for the mouse eradication project on the Farallon Islands was published on March 15, 2019.  The Final Environmental Impact Statement recommends the original plan as the “preferred alternative.”  In other words, despite intense opposition to this plan, its implementation is now eminent. 

No public comments are allowed on a Final Environmental Impact Statement, so there’s nothing further we can say about what seems to be an unnatural disaster in the making.  At this stage of a project, lawsuits are the only way to stop it.  I don’t know if anyone is willing and able to sue. 

“It’s not nice to fool Mother Nature”

Southern sea otter
Southern sea otter. Creative Commons

U.S. Fish & Wildlife Service recently announced that after a 25-year effort, they are finally giving up on the fantasy that they can relocate otters from the coast of California to one of the Channel Islands off the coast.  From 1987 to 1991, they captured and relocated 140 otters in a futile attempt to create a “no-otter zone.”  (1)

Only 40 otters remain near the Channel Islands.  Fish & Wildlife claims that most of the otters returned to the coast.  We’ll never know how many otters died in the process of relocation and subsequent repatriation.  Clearly, even if they survived the pointless ordeal, they didn’t benefit from it.   

Otters were nearly hunted to extinction because of their soft fur.  Their population plummeted from 16,000 in the late 1700s to only 50 in the 1930s.  They were listed by the Endangered Species Act as a threatened species in 1977 and their population has stabilized at about 2,800.

Because of their status as a legally protected species, U.S. Fish & Wildlife decided to move them based on their belief that they would be safer.  They claimed to be concerned that the otters might be harmed by off-shore oil drilling.  One wonders if their concern might have had more to do with the fishermen who say that otters are depriving them of their catch of abalone and sea urchins. 

Fish & Wildlife published a study of their project in 2005, which acknowledged the failure of the effort, yet it took 7 years for them to get around to officially ending it.

Killing one animal to save another

Such attempts to control nature and the animals that live in it are the stock and trade of U.S. Fish & Wildlife as well as their colleagues in state agencies with a similar mission.  Here are a couple of local examples.

Northern spotted owl
Northern spotted owl

The spotted owl was given endangered species status over 25 years ago.  Logging was substantially reduced in the Pacific Northwest in an effort to save the habitat of the spotted owl, with devastating consequences for the timber-based economy.  Despite that effort, the population of spotted owls declined over 40% in the past 25 years.

So, now US Fish & Wildlife has selected a new scapegoat for the decline of the spotted owl population.  They have decided that another owl, the barred owl, is the culprit.  The barred owl is larger and its range is apparently expanding.  So, in its infinite wisdom, Fish & Wildlife recently announced that it will begin shooting barred owls where they don’t “belong” based on their assumption that the spotted owl will benefit from the removal of its competitor. (2)

Carpet bombing with rodenticides

As crazy as the plan to shoot barred owls is, here’s a plan that strikes us even worse.  In April 2011, U.S. Fish & Wildlife announced its intention to evaluate a plan to aerial bomb the Farallon Islands off the coast of San Francisco with rodenticides to kill resident mice.  (3)

Ashy storm petrel. Creative Commons
Ashy storm petrel. Creative Commons

Here’s their logic for this strategy:  the mice are eaten by burrowing owls which don’t “belong” on the Farallones, in their opinion.  They claim that they don’t want to kill the burrowing owls because they acknowledge that they are just as rare in their historic range as the birds they claim will be saved by this bizarre plan.  They claim that when the burrowing owls eat all the mice, they start eating the eggs of the ashy storm petrel which is an equally rare bird, but it “belongs” on the Farallones, so its perceived needs trump those of the equally rare burrowing owl.  They believe that if the mice are killed, the burrowing owls will return to where Fish & Wildlife believes they belong. 

There is so much wrong with this plan that it’s difficult to know where to start.  The Farallones are an important bird sanctuary, home to many species of birds many of which are rare.  Can Fish & Wildlife guarantee that the burrowing owl is the only species of bird that will eat the poisoned mice?  How many burrowing owls will die from eating the poisoned mice?  If they don’t die, won’t they eat even more eggs of the storm petrel?  Will the death of the mice deprive other species of birds of their food?   As the rodenticide washes off the islands into the ocean, will it kill the marine life around the island?  Will it enter the food web of the entire island, killing unintended targets such as the birds that eat fish?

As crazy as this plan sounds, it is not a new strategy for Fish & Wildlife.   In 2008, 46 tons of rodenticides were dumped on an island in the Aleutian chain off the coast of Alaska.  That carpet bombing is known to have killed a total of 420 birds, including 40 bald eagles. (4)

The outcry about the birds being killed by rodenticides has been getting louder recently.  The San Francisco Chronicle reports that a coalition of wildlife and public health advocates has asked California’s regulator of pesticides to take rosenticides off the market.  We hope these pleas for sanity will be heeded before the Farallones are bombed with rodenticides. 

Nature is on the move

Just as humans have moved around the Earth in search of more hospitable conditions—more food, better climate, less competition—animals have done the same.  Now humans have decided that the animals must stay put.  Wherever they existed in the historic past is where they “belong.”  When animals move, man has decided they are “invasive” and they must be stopped. 

Man’s war on invasive species is accelerating because as the climate changes there is greater pressure on animals to move to find the food and habitat they need and on plants to find suitable growing conditions.  Humans are apparently unwilling or unable to do anything to stop climate change, yet they are willing and able to try to prevent plants and animals from adjusting to climate change. 

As senseless as it seems to deprive plants and animals of their survival mechanisms, this harmful approach has been immortalized in U.S. law by the Endangered Species Act.  The ESA is about 40 years old and was enacted at a time when the consequences of climate change were largely unknown.  It defines endangered species as any plant or animal that becomes rare within its historic range.  So, for example, if an animal or plant moves in response to climate change, it is often designated as an endangered species even though it may be plentiful in its new home to which it is better adapted.  And Fish & Wildlife comes to its “rescue” by trying to force it to return to its historic range to which it is no longer adapted.

As we pondered this conundrum, we were reminded of a television commercial in 1970.  Mother Nature is telling stories to her animal friends in the forest, when someone hands her a tub of margarine to taste.  She smiles sweetly and congratulates herself on how delicious butter is.  She is informed that it isn’t butter, but rather an artificial substitute.  She rises from her throne, raises her voice to scold, shoots lightning from her fingers and warns us, “It’s not nice to fool Mother Nature.”  (see this charming video here).    

Will nature punish humans for their refusal to allow it to change as needed to survive? No, not literally, of course, but perhaps we will suffer the unintended consequences of our arrogant attempts to control natural processes we do not understand.

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(1)    Peter Fimrite, “Feds scrap ‘dumb idea’ of relocating otters,” San Francisco Chronicle, December 18, 2012

(2)    Associated Press, “U.S. plans to kill Barred owls to save spotted owls,” San Francisco Chronicle, February 29, 2012

(3)    Kelly Zito, “Pesticide bombing of Farallones mice stirs debate,” San Francisco Chronicle, May 12, 2011

(4)    Peter Fimrite, “Concern over fallout of bombing mice,” San Francisco Chronicle, October 17, 2011