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.

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.

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