“When the Killing’s Done” Maybe never.

I have few opportunities to read fiction because most of my time is spent trying to keep up with rapidly evolving ecological science.  I was grateful for the chance to read the fictional account of island eradications on the Channel Islands because it closely relates to my interest in the planned eradication of mice on the Farallon Islands, which is still pending and as controversial as similar projects on the Channel Islands.  TC Boyle’s book foretells the Farallones project as he sends a member of the fictional project team to the Farallon Islands after completion of the project on the Channel Islands.

When the Killing’s Done by TC Boyle is not entirely fictional. (1)  It is impressively accurate in its description of the eradication projects themselves, but Boyle weaves a tight fictional plot around the key players who implemented the project and those who fought like hell to prevent it from happening.  Like other books by Boyle that I have read, When the Killing’s Done creates intense suspense that moves the reader along at top speed.  His characters are vivid and complex. 

Boyle lives in Montecito, near Santa Barbara, close to the Channel Islands.  No doubt he followed the projects closely as they were debated and resisted by opponents, who were primarily animal rights activists according to Boyle’s account.  In interviews after the publication of the book in 2011, Boyle claimed not to have a personal opinion of the projects:  “I’m not an activist in any way. With certain exceptions, I don’t think politics and art mix very well.”  He sees value in both sides of the debate and the characters in his story have much in common.  The antagonists are vegetarians who value nature and care deeply about the environment and the animals who live in it.  I believe this common ground is also true of the adversaries in the debate about the Farallones project and others like it.

However, the ending of the book suggests that Boyle doubts the ability of humans to control nature.  Although the projects on the Channel Islands were completed to the satisfaction of the land managers–National Park Service and The Nature Conservancy—the final image in Boyle’s story is of animals considered non-native on the Islands making their way to the shore of the Island.  The implication is that maybe the killing is never done and that is the crux of the problem with island eradications in general and the planned mice eradication on the Farallon Islands in particular.

Rat eradication on Anacapa Island

The aerial application of rodenticide to kill rats on Anacapa Island in 2001-2002 was the first of its kind in North America.  The project was also unique because it was complicated by the need to spare a population of endemic native mice on Anacapa.  Over 1,000 native mice were captured before the aerial application of rodenticide and released back on the island after the poison was no longer effective. 

Anacapa Island is the usual success story cited by supporters of the Farallones project where non-native mice are the target for eradication.  Native mice on Anacapa were not considered a threat to birds, but non-native mice on the Farallones are, although there is no evidence that mice actually harm birds on the Farallones either.  The operative word here is “native.”  The mice on the Farallones are targets only because they aren’t native.  The mice on Anacapa undoubtedly eat vegetation too, but that’s not considered a problem so long as they are native.   The mice on Anacapa are probably an important source of food for birds, just as they on the Farallones. 

If mice are not harmful to birds, there is no legitimate reason to poison them, along with untold numbers of non-target animals.  The mice on the Farallones are targets only because they aren’t native. 

Killing of non-target animals

Rodenticides are indiscriminate killers of warm blooded animals, including birds.  An animal who eats rodenticide slowly bleeds to death.  The grisly process of dying takes about 10-20 days.  If poisoned mice are eaten by other animals that animal is also poisoned.  It is therefore inevitable that non-target birds who are predators of mice will be killed by widespread dispersal of rodenticide pellets on the ground that can also be directly eaten by birds and other animals.  This deadly sequence of events has been demonstrated many times by island eradications using rodenticides all over the world and the project on Anacapa Island is no exception. 

Billboard sponsored by Raptors Are The Solution (RATS)

Raptors are the main predators of mice.  Therefore, 63% of raptors on Anacapa Island (37 of 59 individual birds) were captured and either relocated or kept in captivity until the project was done, according to the first study of the project published in 2005. According to that study, “The fate of the remaining birds of prey on the island is unclear. There is evidence that some birds survived the bait application… However, three barn owls, six burrowing owls and an American kestrel either died while in captivity or were found dead on the island. The American kestrel and a burrowing owl that were captured in 2001, after the bait application, likely died from brodifacoum poisoning.” The analysis of the project considers these deaths “negligible.”

A total of 94 seed-eating birds were also found dead after the poison drop.  Most were song birds, but an additional 6 birds were too decomposed to identify the species.  The study notes that these collateral kills were consistent with other similar projects.

Western Gull on Channel Islands. NPS photo

The study makes no mention of gulls that were undoubtedly killed by the project.  Gulls are omnivorous scavengers for whom dead and dying mice are ideal food, preferable to dive bombing for French fries on your picnic table.  According to the National Park Service, “Western gulls are the most abundant breeding seabird in the Channel Islands National Park, with a population estimated at more than 15,000.” Shortly after the poison drop, dead seabirds washed up on the shore near the Santa Barbara harbor.  UC Santa Barbara’s daily newspaper said, “…a strong correlation exists between the National Park Service’s most recent airdrop of pesticide on Anacapa Island and the dead birds.”

In other words, those who implemented the eradication project on Anacapa are probably not telling the full story about the death of non-target birds.  The death of hundreds of gulls is anticipated by the promoters of the project on the Farallones.  If the organization that implements the project is the same organization that monitors and reports on the project (as was the case for the projects on the Channel Islands), we may never know the actual impact on the birds living on the Farallones.

Those who promote these poisonous projects justify the death of non-target birds by saying they are “incidental” and have no lasting impact on the species population.  They will apply for and receive “incidental take permits” in advance of the Farallones project that will satisfy legal requirements of the Migratory Bird Treaty Act and the Endangered Species Act.  The lawsuit that was filed to prevent the Anacapa project was overturned on those grounds.

The killing is never done

Rat eradication on Anacapa and pig eradication on Santa Cruz (where over 5,000 pigs were shot by sharpshooters and 54 Golden Eagles were removed because they were predators of endemic foxes) are the focus of TC Boyle’s masterful book.  Both were implemented and considered successful by the organizations that implemented the projects.  Although land managers are no longer killing animals (to our knowledge) in the Channel Islands they are waging a continuous war on non-native plants by spraying them with herbicide.  When we visited Santa Cruz Island in 2010, we witnessed the application of Garlon on non-native fennel.

Roundup (glyphosate) has been used on the Farallon Islands every year since 1988.  Between 2001-2005, an average of 226 gallons of herbicide were used annually (5.4 gallons per acre per year), according to the annual report of the Farallon National Wildlife Refuge.  Given that these islands are not far from the California coast and are visited by thousands of migratory birds every year, we must expect that the arrival of new plants to the islands will be continuous: seeds are eaten and carried by birds; seeds are carried by birds in their feathers and feet; wind and storms carry seeds to the islands, etc.

The Environmental Protection Agency recently published a Biological Evaluation of glyphosate products.   EPA reports that glyphosate is “likely to adversely affect” 93% of legally protected endangered and threatened plants and animals. That finding applies equally to all plants and animals, whether they are legally protected or not because the physiological processes of species in the same order are similar.

The Environmental Impact Statement for the Farallones project accuses mice of eating vegetation, although far more vegetation is probably killed by herbicides.  Non-native vegetation arrives on the Farallones partly because birds eat it and carry it to the Farallones.  Animals do not care if edible vegetation is native.  Nativism is a human prejudice not shared by animals who seek food and shelter wherever they can find it.

The constant poisoning of plants is perhaps a trivial consideration in comparison to the futility of trying to eradicate mice.  Although rats have been successfully (leaving aside the death of non-target animals) eradicated by some projects, attempts to eradicate mice have been significantly less successful. 

A study of 139 attempted eradications on 107 Mediterranean islands in eight countries, with Greece, Italy, and Spain accounting for the highest number found that eradication projects targeted 13 mammal species. The black rat was the target of over 75% of the known attempted eradications in the Mediterranean Basin; other species targeted were feral goat, house mouse, European rabbit, and domestic cat. The most widely used technique was poisoning (77% of all eradications), followed by trapping (15%) and hunting (4%).  Techniques were largely target-specific.

The average failure rate of the projects was about 11%, but success was defined only as the death of animals living on the islands at the time of the project. However, this percentage varied according to species. The failure rate of house mouse eradication was 75%. Reinvasion occurred after 15% of eradications considered initially successful. 

Farallon Islands, NOAA

The proposed project on the Farallon Islands is a dead end in many ways.  It will kill many non-target animals. It will probably not be successful in the short run or the long run.  Every time it is repeated it will kill more animals. Furthermore, it is pointless because mice do not harm birds on the Farallon islands. 

  • T.C. Boyle, When the Killing’s Done, Viking, 2011.

FUZZ: Fatal encounters of animals with humans

In Fuzz, Mary Roach treats a serious subject with a light touch, intended to entertain.  Whether you are amused or horrified, Fuzz will inform you of the fatal consequences of animals threatening or inconveniencing humans.  In every case, choices made by humans are the cause of these interactions.  In most cases, animals pay for these encounters with their lives.  When animals are spared, adjustments in human behavior are needed.

Hungry Bears

Bears became a problem for us when we occupied their territory and intercepted their travel corridors with our own corridors.  Our relationship with bears became lethal when they learned that we are an easy source of food.  We created that association partly by feeding them in our National Parks for 60 years by making huge, open garbage dumps available to them.  That policy was abruptly abandoned in the 1960s when NPS made a commitment to “restoring natural processes.”  NPS mistakenly assumed bears would disappear into the forest quietly and without incident. Predictably, the bears took to raiding campsites and vehicles.  There were many grisly deaths of hikers and campers before NPS realized they had created a situation requiring active management.  Bear proof containers and trash bins were developed and requirements to use them were rigorously enforced.

Bears being fed by visitors at Yellowstone National Park

Dangerous encounters with bears in wild places are still common.  Relocating problem bears to distant, uninhabited locations is rarely successful.  Many quickly find their way back.  Those that stay are likely to engage in the same behavior and the pressure on them to do so is greater because they are in unfamiliar territory.  Bears are reluctantly killed only after they hurt people. 

Mary Roach visited Aspen, Colorado, where there are many bears and wealthy animal lovers as well as unlimited resources to prevent fatal conflicts between them.  Home owners who experience bear break-ins are coached about how to harden their homes against entry.  They are also encouraged to reconsider their landscaping preferences to avoid favorite foods of bears, such as plants that produce berries, fruit, and acorns.  The poor sods tasked with keeping the citizens of Aspen safe from wild animals were horrified when the city planted crabapple trees downtown.  Patrolling restaurants late at night to enforce requirements that they secure their garbage is another of their thankless tasks.

When birds get in the way

Farmers have been at war with birds for as long as humans have engaged in agriculture, some 10,000 years.  Crows, grackles, blackbirds, and starlings are often targets of efforts to eliminate them in agricultural areas.  Between 1939 and 1945 about 3.8 million crows in Oklahoma were killed by dynamiting their roosts.  A study of that effort found no evidence that either the population of crows or crop production was affected by that campaign because nature adjusts:  “Destroy a chunk of a population, now there’s more food for the ones who remain.  Through a variety of physiological responses—shorter gestation periods, larger broods, delayed implantation—a well-fed individual produces more offspring than one that’s struggling or just getting by.”  This balancing act is known to be true of many other species, such as coyotes and rodents.

Dynamiting rookeries has been abandoned, but the National Wildlife Research Center continues to search for effective methods to deter birds.  Many methods of scaring birds have been tried and found to be only temporarily frightening.  “It is easy to scare birds away, but much tougher to keep them away.”  Scarecrows are the traditional method used by farmers.  Research suggests that scarecrows may actually attract birds, because birds associate them with food, like the golden arches on the highway is a signal to pull off for a burger.   

When the twin towers collapsed on 9/11, there was a real world test of our ability to haze birds.  About 2,000 human corpses were scattered among the debris of the towers.  Within 3 days, the gulls arrived to scavenge in the debris.  Harmless explosions were used to scare the gulls.  When the gulls became accustomed to the explosions, those guarding the human remains resorted to shooting and killing the gulls. Twenty-three gulls were shot and their remains were hung in effigy over the debris pile as a warning to their brethren.


Gullls scavenging a garbage dump. Attribution

These experiences with hazing birds should be a lesson to those who plan to dump 1.5 tons of rodenticide on the Farallon Islands to kill mice. There are about 250,000 gulls living on the Farallon Islands and they are expected to eat poisoned mice, but the perpetrators of this deadly project want us to believe they can scare the gulls away from the islands before two poison drops about 21 days apart.  Given that mice are expected to survive for 21 days after being poisoned, and the poison is expected to be effective for over 100 days, how can we believe that hazing will be effective long enough to save the gulls?  Must we shoot gulls to save other gulls?  Is this the Hobson’s choice “restorationists” ask us to make?

Human attitudes toward animals

Humans are ambivalent about wild animals.  We have an abstract sympathy for animals that can quickly dissolve when animals get in our way or we feel threatened by them.  Our sympathy is universal, but is often influenced by cultural attitudes.  India is a place where we can observe this conflict between our sympathies and our physical need for food and safety.

Hindu deity Krishna and his cow companion. Attribution

Hinduism is the predominate religion in India and respect for animals is a central theme in Hindu life.  Many of the gods in the Hindu pantheon are animals.  Ganesh, the elephant god, symbolizes wisdom, understanding, and an astute intellect.  Hanuman, the monkey god, is a central character in the Hindu epic Ramayana.  Cows are sacred in India and roam freely through suburban neighborhoods where poor people share the food they have with revered cows.  The line between humans and animals is obscured by the Hindu belief in reincarnation.  The cow wandering in the neighborhood could be your departed uncle returned to Earth in the exalted status of a sacred cow.  He must have had good karma!

As we should expect, many Indians make every effort to spare the lives of animals, even when they are destructive.  Elephants must travel long distances to find the great quantities of vegetation they eat and their corridors are often obstructed by human activities.  Elephants often resort to eating and trampling crop fields of poor farmers, who quite rightly are outraged by their loss.  Indian officials who are responsible for the lives of the elephants are deeply committed to protecting people and elephants. They try to create refuges for the elephants to minimize their raids on agricultural crops.  With a growing population and diminishing wild land, this is a challenging task. 

Monkeys are difficult to control partly because they are very intelligent.  In a national park with many naïve visitors, monkeys have learned to pilfer valuable objects from tourists, such as glasses and phones, and then barter with the tourists for food that is equally valuable to the monkey. 

Attempts to prevent deadly tiger attacks are particularly sad because they are often fatal for both humans and tigers.  Tigers are stealthy hunters at night and even in daylight.  School children walking to school are attractive prey for tigers as well as women who must walk into the forest alone at night to relieve themselves where there are no available latrines.  Animal rangers try to mitigate for these encounters by building latrines and urging children to walk to school in groups. 

When a tiger kills, human sympathy is stretched beyond its capacity to tolerate loss.  Angry mobs sometimes kill the first tiger they encounter after such incidents.  Rangers counsel patience while they hunt for the culprit and confirm its guilt with a DNA test.  Rangers are willing to kill a tiger that has been confirmed as a killer.

The need for tolerance

Mary Roach manages to give us a happy ending by visiting a feed lot where beef and dairy operations send their cattle to be raised.  The grain elevator where animal feed is stored is swarming with mice, but the fellow who runs the feed lot just shrugs them off:  “In the grand scheme of things, the wind probably blows away more than the mice eat.  You know, so I’m not sure that’s a huge problem.”  He has barn cats to keep mice out of his vehicles where they can chew up wiring. Other than that, he doesn’t see much point in pursuing the mice. 

Mary Roach sees hope in this encounter:  “To me, he represents a possible future where people may be frustrated by wild animals that get up in your business but they’re living with them.  In that possible future, people’s reaction to the damage brought about by wildlife is something akin to acceptance.” 

A timely reminder

I publish this article today as a reminder that on Thursday, December 16, 2021, the California Coastal Commission will consider the approval of the project on the Farallon Islands that will aerial dump 1.5 tons of rodenticide on the marine sanctuary to eradicate mice.  If you are ready to accept the existence of mice where they have lived in peace with hundreds of thousands of birds and marine mammals for nearly 200 years, please consider writing a public comment or making an oral comment at the hearing.  Here’s how to do it.

Send written comments to the Commission here:  EORFC@coastal.ca.gov. The deadline to send a written comment is 5 pm, Friday, December 10, 2021.  You can also submit a request to speak on agenda item 11b at the meeting HERE.   The deadline to request to speak is 5 pm, Wednesday, December 15, 2021. 

All quotes are from Fuzz by Mary Roach (W.W. Norton & Company, 2021)

It’s time to comment on the deadly project on the Farallon Islands

US Fish and Wildlife proposes to aerial bomb 1.5 tons of rodenticide on the Farallon Islands to kill mice that do not harm birds, as explained in articles published earlier by Conservation Sense and Nonsense.  The California Coastal Commission declined to approve the project in 2019.  At the request of US Fish and Wildlife, the California Coastal Commission will reconsider the Farallon Islands project at their meeting on December 16, 2021.  It’s time to make your opinion of this project known to the Coastal Commission.  The Environmental Impact Statement for the project explains the project and its anticipated impacts. 

Click on this pictures of the Farallon Islands to see a video prepared by the Ocean Foundation about the islands and the proposed project.

Below is my message to the Coastal Commission. Beyond Pesticides has also provided a sample comment letter that is available HERE.   Please consider sending your own comment to the Commission here: EORFC@coastal.ca.gov. The deadline to send a written comment is 5 pm, Friday, December 10, 2021.  You can also submit a request to speak on agenda item 11b at the meeting HERE.   The deadline to request to speak is 5 pm, Wednesday, December 15, 2021. 

Update:  The project on the Farallon Islands that will aerial drop 1.5 tons of rodenticide to kill mice that have lived there for over 200 years was approved by the California Coastal Commission on December 16, 2021.  Speakers in opposition to the project did an outstanding job.  Jane Goodall recorded a message against the project.  The vote was 5-3.  Doubtful Commissioners asked some excellent questions and did not receive clear answers from US Fish & Wildlife.  As the meeting wore on over 7 hours, the project made less and less sense.  https://www.sfchronicle.com/climate/article/California-Coastal-Commission-approves-mouse-16709056.php

Dear California Coastal Commission, 

Please take my comments into consideration when evaluating the proposed project on the Farallon Islands.  I hope the Coastal Commission will confirm their lack of support of the project at your December 2021 meeting.

Thank you for your consideration.

Public Comment on Farallon Islands project

I am opposed to the plans to aerial bomb rodenticides on the Farallon Islands to eradicate mice for several reasons:

  • The project admits that hundreds of non-target birds will be killed by the rodenticide, either directly or by eating poisoned mice.  In September 2020, California banned the use of the rodenticide that will be used by this project because of the deadly impact on non-target wildlife, yet an exemption was created that will enable its use by this project.  The promoters of this project cannot deny that hundreds, if not thousands of non-target animals will be killed by this project.  That outcome is now confirmed by California State Law and by similar projects elsewhere in the world.   
  • The EIS clearly states that mice are not harming birds or chicks, the claimed beneficiaries of this project.  The EIS clearly states that a small population of burrowing owls is blamed for eating birds and chicks of other bird species. Removing the owls from the Farallon Islands is the non-toxic solution to the perceived problem. Yet, “…translocation of burrowing owls in lieu of eradicating mice was not considered as an alternative.” (pg 47)  The EIS then contradicts itself by offering translocation as mitigation for anticipated collateral bird mortality: “Migrant species including burrowing owls would be transported off the island released into suitable habitat on the mainland.” (pg 73)  Translocation is possible, but eradicating non-native mice is clearly the objective, not protecting bird species.  The mice are prey to many bird species.  Their loss will harm birds, not help them.
  • The food web on the Farallon Islands has not been adequately studied.  The project plan reports that the mice are a source of food for burrowing owls.  However, the project plan has not identified all of the predators of the mice.  Therefore, the project has not evaluated the extent to which the entire food web would be disrupted by the elimination of a major source of prey for birds of prey.  All predators of the mice are at risk of eating the poisoned mice and being killed by the poison.  Details on that issue are provided below.

These are the inadequacies of the EIS for this project:

Resident Burrowing Owls should be removed from Farallon Islands

The owls are the predators of the ashy storm petrel, not the mice.  Therefore, the owls are the obvious target for removal.  Given their small number relative to the large population of mice, their removal would be easier and less deadly to every animal living on the islands. 

This strategy was successfully used by the National Park Service to save the endangered Channel Island Fox on the Channel Islands.  Golden Eagles were not considered “native” to the Channel Islands.  They arrived in the 1990s because of feral pigs and goats that had been introduced to the islands.  When NPS took over management of the islands, they removed the feral pigs and goats, but not the Golden Eagles.  Deprived of the food the eagles came for, the eagles turned to preying on the Channel Island Fox, nearly driving it to extinction.  From 1999 to 2006, the eagles were trapped and moved off the island: “In order to mitigate golden eagle predation on island foxes, The Santa Cruz Predatory Bird Research Group, with the support of the Park Service and The Nature Conservancy, relocated golden eagles to distant sites on the California mainland. A total of 44 golden eagles, including 10 eaglets born on the islands, were trapped and relocated, and monitoring indicates that none have returned.” NPS considers the removal of eagles the primary factor in saving the Channel Island Fox from extinction.  The 44 birds that were removed were more than 4 times more numerous than the 8-10 burrowing owls on the Farallon Islands.  They are enormous carnivorous birds, compared to the pint-sized, ground-dwelling burrowing owls. 

Please note that the threat to the fox posed by Golden Eagles was created by the removal of the prey of the Golden Eagles without adequate analysis and understanding of the food web.  NPS should have predicted that the loss of the preferred prey of Golden Eagles would disrupt the food web in ways that could have been predicted.  Now other “experts” are poised to make a similar mistake at the expense of thousands of rare birds and marine mammals on the Farallons.

The Madrone Chapter of Audubon Society in Santa Rosa opposes this project and agrees that relocation of burrowing owls is “feasible and could be planned and carried out.”

Disrupting the Food Web

The EIS has not adequately analyzed the food web on the Farallon Islands and has therefore not identified the environmental impact of eradicating an important source of food for the animals that live on the island. 

This depiction of a fresh-water aquatic food web is an example of the complexity of food webs.  The food web on the Farallon Islands is probably very different, but remains largely unknown because the EIS does not analyze it or describe it.  Source:  Creative Commons-Share Alike

According to the EIS, there are many birds of prey on the Farallon Islands, most migrating, but some resident:  falcons, hawks, kites, eagles, owls, and kestrels. Most of the migrating raptors are on the island in the fall, when the mouse population is at its peak.  The EIS acknowledges that the raptors probably eat mice on the island, but dismisses that as a significant issue. However, it would be a significant factor in evaluating environmental impact if migrating raptors compensate for the loss of mice as their prey by preying on birds or salamanders.  The EIS does not address the important question of what birds of prey will eat if mice are eradicated. 

Given that mice are expected to survive for 21 days after being poisoned, and the poison is expected to be effective for over 100 days, it is more likely that many birds of prey will be killed by eating poisoned dead or dying mice. The number of days the rodenticide is expected to be effective exceeds the known limits of hazing effectiveness. For that reason, the EIS says the project will “attempt” to capture raptors present on the island prior to and during bait application.  An unsuccessful “attempt” will result in the death of raptors.

There are also many animals living on the Farallons that could eat the poison or the poisoned mice, but not killed by the poison, such as invertebrates and Dungeness crabs.  Although they are not killed, they would be contaminated by the poison they eat and become killers of the animals that eat them, such as birds and marine mammals. 

The EIS states that many of the insects that live on the Farallons are detritivores that feed on decomposing carcasses, such as the poisoned mice.  Then they become killers of the warm-blooded animals that eat them.  The Farallon Islands are located within the Dungeness crab fishery.  If they are contaminated by poison pellets or fish, they could become killers throughout the fishery.  According to the EIS, “Adult crabs are opportunistic feeders, but prefer clams, fish, isopods and amphipods. Cannibalism is common. Several species of predators feed on Dungeness crabs, especially the pelagic larvae and small juveniles, including octopuses, larger crabs and predatory fish such as salmon, flatfishes, lingcod, cabezon and various rockfishes. They are numerous in offshore areas of the Gulf of the Farallones, and support one of the most productive fisheries in California.”

A similar mistake was made by a rat eradication project on the Palmyra atoll.  The first attempt to eradicate the rats in 2002 failed partly because Palmyra’s abundant land crabs outcompeted the rodents for the poisonous bait. The crabs’ physiology allowed them to eat the poison—the anticoagulant brodifacoum—without ill effect.  The reason why this attempt failed was that the “experts” who designed this poison drop did not realize that the rats lived in the coconut palms and didn’t spend much time on the ground.  In other words, the poison wasn’t dropped where the rats lived.  The second drop was delivered to the crowns of the palms:  “The crowns became a convenient platform for stashing cotton gauze sacks of poison bait, delivered by workers firing slingshots or dangling from helicopters.”  This project is now focused on eradicating 30,000 adult palms and over 2 million juvenile palms from Palmyra using herbicide.  These island eradications have repeatedly demonstrated that they are not successful and they ultimately put land managers on a perpetual pesticide treadmill.   The result is a poisoned environment that is dangerous to every living plant and animal on the island.

Ironically, the explosion of the mouse population on the Farallons was the unintended consequence of inadequate understanding of the food web:  “House mice and other animals such as cats and rabbits were introduced to the island when ships landed there in the 19th century. While the cats and rabbits have been removed, the mice population has exploded to an estimated 60,000, or about 500 mice per acre.”  One of the primary predators of the mice was removed, which resulted in increased population of their prey, the mice.  Now USFWS proposes to eradicate the prey, which will have unintended consequences, such as the death of the predators who will eat the poisoned mice, or the predators of the mice eating bird eggs and chicks instead, or predators not having adequate food, or all of the above.   

Rodenticides are known killers of birds of prey

This article published by Beyond Pesticides explains how birds of prey are killed by rodenticides:  “While a rodent is likely to die from this poison, ingesting it also turns it into a sort of poison Trojan horse for any predator that may take advantage of its slow decline. An eagle that eats a poisoned rodent at the edge of death will be the next to succumb to the anticoagulant effects ‘Humans need to understand that when those compounds get into the environment, they cause horrible damage to many species, including our national symbol, the bald eagle,’” said the scientist who conducted a study of eagle deaths that found: “‘The vast majority of bald and golden eagles in the United States are contaminated with toxic anticoagulant rodenticides, according to research published earlier this month.’” We know that 46 bald eagles and over 420 seabirds were killed by the rat eradication attempt on Rat Island in Alaska, but we don’t know how many more were contaminated with rodenticide and are handicapped by sub-lethal effects. 

Source: Beyond Pesticides

Temporary Results

One of many reasons the mouse eradication project on the Farallon Islands is controversial is that similar projects all over the world are not successful.  Some are not successful in the short run and are immediately done again. 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. The Farallons project plans to use brodifacoum. 

Some are not successful in the long run.  Rodenticides were aerial bombed on the Lord Howe Islands in Australia in 2019 at a cost of $16 million. Two years later, two rats (one male and one pregnant female) have been found.  Genetic tests will determine if they arrived from elsewhere or are descendants of the original population. An article in The Guardian explains the elaborate effort on Lord Howe to find new rats and exterminate them.  This strategy might work on an inhabited island, such as Lord Howe, but it is not an effective strategy on the Farallons because it is not inhabited, has only occasional visitors, and its steep, rocky terrain is not easily monitored.  New mice or rats could be undetected on the Farallons long before anyone would know it. 

This is an example of one of the fundamental truths of the “restoration” industry:  The work is NEVER done.  It must be done repeatedly.  The cost is daunting, the collateral damage to non-target animals often unacceptable, the results only temporary.  The cost-benefit ratio is unfavorable.

Ethical considerations

For the record, I would like to clearly state my objection to the Farallons project.  I consider it unethical to kill one species of animal based on a presumed benefit to another animal species.  In this case, the chosen scapegoat is considered a non-native animal that has lived on the Farallon Islands for nearly 200 years and is therefore fully integrated into the food web.  There are hundreds of thousands of sea birds and mammals living on the Farallons.  They are the best testament to the fact that mice have not been harmful to birds and other animals on the Farallons.

Hundreds of non-target animals will be killed by this project because of the toxicity of the rodenticide and the random manner in which it will be applied on the island.  The project will clearly do a great deal of harm to all life on the Farallons and its benefits are obscure at best. Please do not endorse this pointless, deadly project.   

Update on California’s 30X30 initiative: The good, the bad, and the ugly

In May 2021, Conservation Sense and Nonsense introduced California’s $11 billion investment in addressing climate change and protecting biodiversity by protecting 30% of land and coastal waters by 2030 (30X30). Since then, the California Natural Resources Agency (CNRA) held a series of workshops to explain the initiative and give the public an opportunity to provide feedback to CNRA.  Sixteen hundred Californians participated in those workshops, including me. Today I am reporting what I learned about the initiative and tell you my opinion of what I learned.

Update: The final California budget commits $15 billion for climate change and protecting biodiversity.

Good news always comes first

The Land Conservation Panel identified the opportunity to remediate degraded spaces that will address many of the objectives of the 30X30 initiative.  Many degraded spaces are found in poor communities that are exposed to toxic waste and pollution.  Eliminating public health hazards in these communities will not only improve their health, it will make those spaces available for recreational and other purposes.  Here are just a few of many such opportunities in California:

Superfund sites in California as of 2013. Source: Environmental Protection Agency
  • There are 94 toxic waste Superfund sites in California.  Where these sites are threatening the health and safety of the public they should be high priorities for remediation.  For example, nearly 30,000 corroding barrels of DDT were recently found on the ocean floor near Catalina Island.  The extent of that particular toxic dump was not known at the time the LA Times reported it, but investigating scientists speculated that as many as half a million barrels may have been dumped by the manufacturer of DDT.
  • There are 47,000 abandoned mine sites in California, according to the Bureau of Land management.  84% of those sites present physical safety hazards and 11% of the sites present environmental safety hazards.  Abandoned mine sites that are potential recreational areas in underserved communities should be considered high priorities for remediation.
  • The California Clean Water Act identifies “impaired waters.”  The list of impaired waters is long and it is alarming.  It identifies pollution with toxic substances such as mercury, diazinon, sewage from leaking septic tanks, sedimentation from erosion, run off of agricultural chemicals, etc.  Addressing these issues will reduce public health hazards and improve fish and wildlife habitat.  Most rivers in California are ultimately watersheds into the ocean, therefore cleaning up these “impaired waters” will also improve ocean health.  At this time of extreme drought and the expectation of continuing drought, water quality should be a high priority for the 30X30 initiative.
  • There are over 5,000 orphan oil wells in California with no known responsible operator.  Capping and retiring these oil wells would reduce health hazards and make the land available for recreational and other uses.  These abandoned oil wells are frequently found in economically disadvantaged areas such as Bakersfield and poor areas in the Los Angeles basin, which is all the more reason to remediate this blight on the landscape. 

The remediation of hazardous pollution would benefit Californians, reducing health hazards for humans and wildlife and potentially making land available for other useful purposes.  Remediating polluted, dangerous land must be a higher priority than funding the horticultural preferences of hobbyists with romantic notions about recreating a landscape that is long gone and cannot be replicated.  If we are to achieve durable objectives, we must have realistic expectations and goals that are consistent with current and anticipated climate conditions.  Thriving landscapes that do not require irrigation should not be replaced with fragile landscapes that require irrigation and access restrictions.  No land that requires pesticides to accomplish “conservation” goals can legitimately be called “conserved.”

Not so good indicators of destructive projects

Although the Summary Document of the Panel for Coastal Waters made vague references to the importance of “Linking protection of land and coastal ecosystems through adjacent terrestrial and marine protected areas,” the words “watershed” and “wetlands” do not appear in the Summary Document.  No specific suggestions were made to address the close relationship between coastal land and coastal waters.

The preservation and expansion of wetlands will reduce the flow of pollution from land to ocean by acting as a filter of runoff from the land.  Wetlands are also one of our chief defenses against rising sea levels if they are expanded to perform that function.  Wetlands are the nurseries of our fisheries and they provide essential habitat for wildlife.  Wetlands are also significant carbon sinks.  Yet the Summary Document makes no mention of these essential functions that contribute to healthy oceans.

Cleaning up the watersheds that are now draining toxic pollutants into the ocean is a more worthwhile endeavor than anything suggested by the Coastal Waters Summary Document. Most rivers in California are ultimately watersheds into the ocean, therefore cleaning up these “impaired waters” will also improve ocean health.  Many important fish species that migrate from ocean to rivers are killed or harmed by these hazardous contaminants.  The ocean is only as healthy as its watersheds.

Instead of addressing the opportunities to expand wetlands and cleaning up watersheds, the Coastal Waters Panel is proposing an outdated “restoration” approach that begins with killing plants and animals. The attempt to “restore” kelp forests is one of the few specific examples of possible projects that is mentioned in the Panel’s Summary Document.  Like most of these futile projects, that project begins by killing thousands (millions?) of the chosen scapegoat, purple urchins, predators of kelp.  Where urchins are killed kelp is being replanted.  Like most of these projects, the chosen method does not address the underlying causes for declining kelp forests that were killed by ocean heat waves.  Ocean heat waves are a consequence of inexorable climate change.  It is delusional to assume that the heat waves that killed the kelp will not occur again.  Furthermore, the massive die-off of sea stars from a mysterious “wasting syndrome” is an important factor in the explosion of urchin populations that are prey of sea stars.  As you might know, sea stars are making a comeback.  Sea Otters are also predators of urchins.  If their populations weren’t repeatedly suppressed by commercial fishing interests, urchins would have more predators.  In other words, present methods of “restoring” kelp forests are based on inadequate understanding of the food web and the underlying causes of the loss of kelp forests.  Is anyone trying to breed a more heat-tolerant variety of kelp?  Is anyone looking for a functional equivalent in warmer waters?  In other words, the loss of kelp forests is a serious problem, but the methods being used to address it are amateurish and futile.

The Ugly:  Composition of 30X30 panels is deeply flawed

There are representatives of organizations on two 30X30 panels that promote and participate in island eradication projects such as the Farallon Islands project that proposes to kill mice by aerial bombing 1.5 tons of rodenticide on the islands.  One representative on the Biodiversity Panel identifies himself as a “conservation entrepreneur” and the founder of Island Conservation, the organization that has conducted more than 350 island eradications in 65 countries around the world and is participating in the Farallons project.  One member of the Coastal Waters Panel represents Point Blue, an organization that has participated in many deadly projects.  Point Blue actively promotes the Farallons project and has participated in its development. 

The Farallon Islands project is another example of a project that has selected an animal scapegoat for eradication without addressing the underlying cause of the perceived problem, which is a dwindling population of ashy storm petrels.  Mice are the chosen scapegoat despite the fact that they do not harm any birds or their chicks.  The mice are blamed because they are the preferred prey of a small number (8-10) of burrowing owls that prey on the petrel chicks when mice are not available.  The burrowing owls could easily be non-lethally removed from the island (Try walking up to a burrowing owl.  Chances are it won’t flinch.)  The National Park Service removed 44 Golden Eagles from the Channel Islands because they were preying on Channel Island Foxes (after NPS eradicated sheep and goats from the islands that were the Eagles’ preferred prey).  USFWS proposes to kill the mice by aerial bombing 1.5 tons of rodenticides on the Farallons and they acknowledge that hundreds (thousands?) of non-target birds are likely to be collateral damage, as they have been in hundreds of similar projects all over the world.  USFWS claims that the burrowing owls will “go away” if their preferred prey is eliminated.  It seems more likely that the burrowing owls will either be killed by the rodenticide or will eat more birds if that’s all there is to eat.  Second-generation rodenticides were recently banned in California because they are killing non-target birds and mammals.  Unfortunately an exemption for projects considered ecological “restorations” was carved out of that ban. Why the proposed Farallons project is considered a “restoration” is a mystery to me. 

We saw burrowing owls in Argentina in 2010. We walked up to them to test the claim that they are easily disturbed by people. We got even closer than this before the owl reacted.

Similar island eradications have been completed all over the world.  Rats are the usual target of those projects and unlike the mice on the Farallons, there is evidence that rats are capable of harming birds.  However, a significant portion of those projects were unsuccessful because rats are resourceful creatures capable of reproducing quickly after their population is reduced.  More importantly, those projects have killed thousands of non-target birds who ate the poison (or poisoned rats) and contaminated the water around the islands, harming fish and marine mammals that live around the islands.

Island eradications done by Island Conservation

As I told California Natural Resources Agency in my written public comments, Point Blue and Island Conservation should not be represented on 30X30 panels because they are likely applicants for projects that will be funded by the state.  This is a serious conflict of interest.  Point Blue is involved in hundreds of destructive projects all over California, including surveying barred owls in preparation for shooting them. Island Conservation has published a study that identified other islands off the coast of California for potential island eradications.  If these organizations are in a position to influence the types of projects that are funded by the 30X30 initiative, they will be in a position to profit from creating projects they can perform. 

Several of the public commenters at the Coastal Waters workshop on August 17th mentioned that there is no representation on the Coastal Waters Panel of recreational and commercial fishermen.  Other panels include representation of recreational interests because increasing recreational opportunities is one of the primary goals of the 30X30 initiative.  Point Blue should be replaced on the Coastal Waters Panel by representation of recreational and commercial fishermen. 

Where do we go from here?

You can view the 30X30 workshops on CNRA’s You Tube Channel. You can read the recommendations of the 30X30 panels on CNRA’s website.  And you can respond to CNRA’s invitation to send them pictures of successful restoration projects:

“If you or your organization has images of before and after climate smart land management projects, successful nature-based solutions; or iconic California landscapes we would love to feature them!…If your organization is interested in sharing pictures, please email them to Heather Williams at the California Natural Resources Agency (CNRA) by September 17. Please include a description/caption of the image, the organization’s name, and the image date(s). Send only high-resolution images (1200×800 or larger). By emailing these pictures, you give CNRA the right to use these images in our nature-based solutions and climate-smart land efforts.”

Organizations that will compete for $11 billion of grant funds will undoubtedly provide many beautiful pictures of their projects.  If you have pictures of projects that were not successful, you may send them as well. 

There will be another round of workshops to review draft plans in Fall 2021.  You can ask to be notified of those workshops and register to attend them by sending an email to californianature@ca.gov.  Plans will be finalized for implementation in January 2022. 

The 30X30 initiative has the potential to be constructive by addressing important issues with viable projects.  It also has the potential to be destructive by destroying harmless plants and animals, poisoning our land, and installing replacement landscapes that are not adapted to current and anticipated environmental conditions.  Our participation in the development of the plans is our only means of influencing the outcome.  California taxpayers will pay for these projects, whether we like them or not.  It is in our hands.

“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.


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

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
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.


(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