A Special Sanctuary

The Farallon Islands, often visible 28 miles from San Francisco’s Golden Gate, host the largest seabird colony in the lower-48 states. Known as “California’s Galapagos”, these islands are home to an estimated 250,000 seabirds, representing 13 species in prolific breeding colonies. The islands also provide safe shoreline haulouts for countless marine mammals.

The lush ocean waters surrounding the Farallones boast some of the region’s most productive fishing grounds and are teeming with Great White Sharks and multiple species of whales. All of these species are protected within the Greater Farallones National Marine Sanctuary and two of California’s iconic State Marine Protected Areas.

No Place for Deadly Poisons

Here, the U.S. Fish and Wildlife Service is proposing to use helicopters to release one and a half tons of toxic rodenticide bait laced with a deadly wildlife poison to try to eliminate a few protected Burrowing Owls in the hope of benefitting a small seabird known as the Ashy Storm Petrel. The Wildlife Service is pursuing the unproven theory that if it could kill every mouse on the Southeast Farallon Island, these Burrowing Owls might no longer be attracted to this spot. This particular poison is so harmful to all animals and so damaging to the food chain, that a moratorium on its use has been implemented throughout California until the state can reevaluate it. Carpet-bombing the Farallones’ ecosystem with a broad-spectrum wildlife poison will threaten one of the most sensitive food chains on our planet.

Burrowing Owl

The Problem:
An Average of Eight Burrowing Owls

The U.S. Fish and Wildlife Service’s misguided project proposes to try to completely eradicate invasive house mice from the Southeast Farallon Island. It is thought that the mice were introduced by European explorers as early as the late 1500s, or else they were accidentally brought by Russian fur traders sometime in the 1800s.

During the fall months of most years, a seasonal overpopulation of these mice on the island attracts, on average, eight Burrowing Owls that fly over from the nearby Marin County coastline to prey on the mice. But as the temporary seasonal spike in the mouse population naturally subsides, a few Burrowing Owls linger on the Southeast Farallon Island. These remaining owls can then prey on a small seabird called the Ashy Storm Petrel.

While the Farallones are a breeding and habitat area for the Ashy Storm Petrels, the very same U.S. Fish and Wildlife Service has ironically twice rejected this population as a candidate for stronger protection under the Endangered Species Act. Both times, this petrel’s natural population variation has been cited by this agency as a rationale for their repeated denial of any additional protection. It is entirely possible that the Burrowing Owls may have always come out to this nearshore island, even prior to the probable human introduction of the mice so long ago. Therefore, no one can predict whether or not the owls might still continue to arrive, even without the mice.

Yet it’s a matter of record that Brodifacoum, the poison selected for this experiment, has a tendency to move insidiously throughout seabird colonies; harming raptors, owls, and other avian predators.

Ashy Storm Petrel

Ashy Storm Petrels are also found on Southern California’s San Miguel and Santa Barbara Islands, where recreational kayakers have been known to unintentionally cause nest abandonment when entering sea caves. Throughout their habitat, the threats proven most dangerous to Ashy Storm Petrels are posed by floating oil spills, eggshell thinning with various causes, ingesting marine contaminants and plastics, and the sometimes-fatal propensity of this species to become disoriented while feeding at night by the bright lights on boats, offshore oil drilling rigs, and also likely by similar lights on future commercial offshore wind electrical generation arrays. Precluding offshore drilling rigs while preventing marine oil spills in the vicinity of the Farallones were two of the primary reasons for the 1970’s citizens movement to secure the initial designation of the Greater Farallones National Marine Sanctuary, thus benefitting the petrels there. Burrowing Owls, which are protected under the Migratory Bird Treaty Act, are also the focus of conservation efforts by many parties, primarily due to population challenges posed by loss of much of their favored habitat on the mainland to development and agriculture.

Sacred Ground:
The Original Tribal Ancestors

The Farallon Islands have been integral to the cosmology and traditions of the Ohlone People for over 6,000 years. Traditionally, the Farallones are known as the Islands of the Dead.

The ancient stories of the Ohlone reflect the mythic characters of Coyote, Eagle (or Condor), Hummingbird, and Coyote’s Flea (or Shrimp) Wife, and these stories are still embedded in the landscape of this place. The Farallon Islands are part of the immense geomorphic theophany and mortuary complex of the West Berkeley Shellmound, together with the lands and waters of the greater San Francisco Bay Area. Marin County is viewed as the giant head of Coyote, whose body spreads northward along the coast and over the North Bay. The San Francisco Peninsula is Coyote’s Flea Wife or Shrimp Wife. The San Francisco Bay is Eagle or Condor, with wings outstretched. The West Berkeley Shellmound is a cremation mound and portal for the dead, at the midpoint of the Eagle’s tail. The beak of the Eagle points west through the Ohlone’s Western Gate, now the Golden Gate. A straight sightline runs from the West Berkeley Shellmound, up the middle Eagle’s body, and outward through the Golden Gate to the Farallones. It has been believed that after death, the spirits of the Ohlone would first travel to what was known as Pelican Island (now Alcatraz), where they remained for four days. Following cremation or burial, they flew west to the Farallones on that straight line, carried by Eagle. Today, the Farallon Islands are still considered to be the home of the Ohlone ancestral spirits.

The West Berkeley Shellmound was named as a City Landmark by the City of Berkeley, is on the State of California’s Register of Historic Resources, and is on the 2020 roster of America’s Most Endangered Historic Places identified by the National Trust for Historic Preservation. This entire complex is more ancient than Stonehenge, and it is an American treasure.

The Ohlone’s neighboring Tribe to the north, the Coast Miwok, also knew that they lived on the body of the Coyote landform, and the spirits of their dead migrated southward from Point Reyes on a trail of seafoam, likely to the Farallones.

To date, the sacred aspects of the Farallon Islands as traditional cultural landscapes have not been adequately evaluated during the institutional consideration of the U.S. Fish and Wildlife poisoning proposal. Both the Ohlone and Coast Miwok have thus far been disenfranchised in the planning process for the poisoning, leaving important Traditional Ecological Knowledge, in the context of eco-cultural considerations, missing from the decision-making process. In this framework, the proposed Farallones poisoning by a federal agency represents a continuation of longstanding colonial imposition on the affected Tribes, given that the pending agency decisions, questionable private funding sources, biased federal documents, and the flawed project planning have been formulated largely absent Indigenous consultation and consent.

Just Coming Back:
Recovery to Date from Historic Take of Wildlife

Seeking food for their ship’s crew, the first European sailors to row a longboat ashore at the Farallones appear to have arrived no earlier than the late 1500s, to hunt seals and gather seabird eggs. This earliest recorded landfall may have possibly resulted in the initial introduction of house mice, although a genetic analysis of the Farallones mice seems to indicate a strain with origins in Russia, which tends to point to their more recent introduction via Russian fur traders during the 1800s. The Russians also took eggs, as well as dried seabird carcasses for food. Since many of the living resources at the Farallones have been subject to a challenging history of extractive abuse, the wildlife there has taken many decades to slowly recover to current levels.

“The Eggers”

Starting during the Gold Rush era, seabird egg harvesters called “Eggers” removed as many as 14 million Common Murre eggs from the Farallones, at first to sell to miners in the Sierras and then to restaurants in San Francisco for as much as a dollar per egg. The egg hunters first went onto the islands to smash the eggs in every nest they could find as an assurance that the ones they would later return to gather up for sale would be as fresh as possible. Western Gull eggs were also marketed during this period, but these were considered less desirable than those from the Murres. Seabird eggs are said to have been sold by the children of certain historic Farallones lighthouse keepers to satisfy a fad that generated an artificial demand created by collectors seeking to possess one egg from every species in their personal collections. Sometimes other seabird eggs were even disguised as Ashy Storm Petrel eggs because those were particularly valuable to collectors. Virtually every species of marine mammal was also hunted ruthlessly during several different eras, to meet the demand for food and fur. Salted Sea Lion meat and Northern Fur Seal pelts were major commodities derived from Farallones wildlife. Meanwhile, the region’s population of California Sea Otters was driven to near extinction in the quest for their unique pelts. Local Sea Otter populations around the Farallones have still not recovered.

The Eradication Game:
Unnecessary Mortality of Harmless Wildlife

Throughout the world’s oceans, most of the more remote island habitats have long been colonized by seabirds attracted by an abundance of food in surrounding waters and the accompanying lack of native predators. The subsequent arrival of humans to these seabird islands has often brought the inadvertent introduction of mammalian predators of many kinds, elsewhere comprised most commonly of shipboard rats, for which strychnine poison originally served humans as the early rodenticide of choice. The chemical methods for the control of rodents have since escalated. The pest control industry has continually amplified the killing power of its products, while seeking a single feed strategy that can enable one single feeding of poison to eventually kill anything consuming the bait, even though that death may come slowly.

Unfortunately, the second-generation anticoagulant rodenticide (SGAR) compound chosen for the proposed Farallones mouse eradication, Brodifacoum, is extremely toxic to most other living organisms that consume the bait. Brodifacoum will inevitably induce the slow secondary poisoning of any gull, raptor, or other species that consumes dead or dying poisoned mice, or else preys on any of the other non-target animals that have been subjected to the bait.

The biochemical mechanism by which a second-generation anticoagulant rodenticide like Brodifacoum acts is as ingenious as it is slow and tortuous, in terms of the physiological symptoms experienced by its victim. By inhibiting an animal’s blood clotting mechanism, this type of poison exposure results in the animal slowly bleeding to death internally over a protracted period of time. The prolonged process of death by the gradual internal bleeding can take up to two weeks, depending on the dosage acquired and the species of animal exposed. Severe dehydration inevitably accompanies this internal bleeding.

While island poisoning proponents often rationalize that any misplaced invasive rodent simply represents a pest to be killed by any means available, a similar philosophical justification cannot legitimately be applied to non-target bykill of species that are unfortunate enough to share the same habitat and food chain as the targeted pest. Poisoned rodents themselves quickly become attractive prey for avian predators as they slowly die, with Brodifacoum concentrations in the liver serving as one of the main bioconcentration pathways by which these poisons are inevitably conveyed to harmless non-target species. For the Farallones, the seasonal timing of the proposed poison application unfortunately coincides with the annual autumn Golden Gate Raptor Migration, during which many majestic birds of prey may well be attracted to the island by the ready availability of an impaired prey species like dying mice. Fur seal pupping season at the Farallones also extends into September, putting another sensitive life stage in this fragile ecosystem at risk.

Due to its adverse impact on entire ecosystems, Brodifacoum poison has been banned from retail sale in California since 2014 and, effective as of January 1, 2021, the State Legislature and Governor Gavin Newsom, by way of new legislation in the form of AB 1788, have placed a statewide moratorium on the use of this compound, and others like it, until a full evaluation of its impacts can be completed. Certain exemptions in California’s AB 1788 mean that it does not similarly halt the use of Brodifacoum on offshore islands, although this law became necessary because of its association with the observed ongoing destruction of wildlife throughout North America.

This collateral damage includes the documented prevalence of Brodifacoum and other SGAR rodenticide poisons now discovered in a large percentage of mountain lions, bobcats, raccoons, skunks, and a small mammal called the Pacific Fisher, as well as the frequent poisoning of eagles, hawks, owls, and even household pets - and occasionally children - all inadvertently exposed to this dangerous compound. The obvious functional obsolescence of Brodifacoum amidst evidence of mounting ecosystem contamination and human safety concerns is now prompting society to employ more focused, humane ways to address pest control. This shift is driving the rapid development of much-needed scientific advancements in fertility control measures as a more effective abatement tool for rodents, including mice.

Raptor Killed by Rodenticides

When the First Try Fails, They Do It Again

Worldwide, thirty-eight-percent (38%) of the initial aerial applications of this same Brodifacoum rodenticide bait during eradication efforts to control mice on islands have failed to fully eliminate the mice. Since it is not uncommon for an initial Brodifacoum drop to fail to fully eradicate mice, a follow-up repetition of recurring poison applications is often tried during the following years. Mice, in particular, tend to quickly develop a genetic resistance to rodenticides, further complicating the escalating biological risks for non-target species in the path of what then becomes an inevitable series of repeated multi-year poison drops.

The official EPA label on a package for Brodifacoum rodent bait clearly specifies prescribed legal application limitations that are aimed at strictly constraining the amount of poison that can be spread per unit area. The Environmental Protection Agency, however, has previously granted label modification requests to other prior poison projects by simply issuing what is called a “Supplemental Pesticide Label” for the Brodifacoum 25-D Conservation bait that the Service is planning to utilize during the Farallones drop. If granted, such a label exemption would mean that more poison than normally allowable within a given acreage would then be distributed over the Farallones. Page 82 of the Wildlife Service’s Final Environmental Impact Statement for the project states: “The specific bait product used for this alternative is registered with the EPA (EPA Reg. No. 56228-37) and would be applied in compliance with EPA and the Federal Insecticide, Fungicide and Rodenticide Act bait label. As described in Section 2.10 and elsewhere in this FEIS, a supplemental label will be acquired, in consultation with USDA/APHIS and EPA, to allow the Service to adopt bait label specifications to suit specific needs of this project.”

For this kind of poison, a label modification, when granted by EPA, is usually requested in order to boost the level of toxic exposure in an attempt to increase the probability that the first poison application might be more likely to kill a higher percentage of the target species. There is, however, no way to predict whether or not increasing the poison coverage will increase the odds of achieving total eradication of mice on the first try. Over-application of this bait, when facilitated by such label changes, unfortunately also can increase the level of threat posed by the poison to non-target species and has therefore been associated with some of the worst biological mishaps caused by similar rodenticide drops elsewhere.

The ecological dynamics of the Farallones differ from other islands, in part because species there interact so closely with nearby mainland coastal ecosystems. The simple fact that what may appear to be a problem for one of its seabird species due to predation by only a few migrating burrowing owls from the mainland - themselves attracted by mice - means that the projected remedy strategy is not a direct one, thus it should not be undertaken in haste using primitive methodologies like the proposed blanket aerial poison application.

Disasters Elsewhere:
Even When Everything Goes Right, Things Go Wrong

Unanticipated non-target harm to ecosystems on other islands around the globe resulting from spreading Brodifacoum poison is well-documented. Not surprisingly, follow-up analytical studies found that Brodifacoum was still present in fish within the drop zone three years after the carefully-planned 2012 helicopter application of this same poison on Wake Island. The U.S. Air Force, following the Brodifacoum application there, recommended a restriction on human consumption of fish for 942 days. Since the initial poison bait application on Wake Island also failed to permanently eradicate all of the targeted rats at all locations there, a proposal for a repeat application justifiably remains very controversial.

A Modified Supplemental Label from EPA

Elsewhere, previous unfortunate examples of disastrous “incidental” ecological damage caused by helicopter poisoning with Brodifacoum and similar rodenticides have unintentionally killed Peregrine Falcons, Glaucous-Winged Gulls, and many species of raptors. In Alaska, belated monitoring conducted after the U.S. Fish and Wildlife Service’s infamous 2008 Hawadax Island poison drop (colloquially known as Rat Island) ultimately documented 46 dead Bald Eagles and a total of 467 bird carcasses. Unanticipated delays after the drop in Alaska meant that the required post-project monitoring was inexplicably postponed until a full eight months after the poison was applied, so a full count of the unintentional bykill will never be known. Globally, many similar island poisoning projects have not been subjected to truly independent monitoring, thus the self-serving tendency of some subcontractors to fail to duly report unexpected project anomalies would appear to result in misleading claims of successful eradications, even when unacceptable side-effects have clearly occurred.

The Consensus:
Scattering Poison in a National Marine Sanctuary Would Be Irrational

The Southeast Farallon Island lies in the midst of the Greater Farallones National Marine Sanctuary, which was created primarily in response to past Department of Interior federal oil and gas leasing overtures for offshore drilling in these waters. The concerted bipartisan effort that eventually led to the original 1981 NOAA designation for this Marine Sanctuary involved a broad coalition of local governments, commercial and sport fishing interests, and the public, along with a multi-term sequence of California governors, congressional Representatives, and U.S. Senators. These stakeholders banded together for many years to seek a protective federal mechanism that would reliably preclude pollution from any source, while also permanently banning offshore oil and gas leasing within these Sanctuary waters.

The resulting Greater Farallones National Marine Sanctuary today provides some of the most carefully-crafted marine resource protections anywhere in the world. The science-based Marine Sanctuary stewardship of these waters by NOAA includes duly adopted “enter and injure” regulations that even prohibit the introduction of any substance that originates outside of Sanctuary boundaries, but which may subsequently be conveyed into the Sanctuary boundaries on breezes or ocean currents, if the introduced substance in any way alters Sanctuary values and resources. This elevated level of resource protection is a model that should become standard throughout other Marine Sanctuaries nationwide, rather than being disregarded as something to be undermined by the dangerous precedent inherent in the proposed poison drop.

Most of the stakeholders directly involved in the original creation of the Greater Farallones National Marine Sanctuary have collectively expressed their opposition in response to any plan to drop Brodifacoum from helicopters in the midst of this Sanctuary. In addition, California’s critical Marine Life Protection Act stakeholder process resulted in the 2010 designation of two important State Marine Protected Areas that lie immediately to the north and south of the Southeast Farallon Island, adding an additional level of adjacent state protections that are encompassed within the overarching National Marine Sanctuary framework. Ocean stewardship by the State of California overlaps the Greater Farallones National Marine Sanctuary throughout these contiguous State Marine Protected Areas, with State jurisdiction extending up to three miles seaward from adjacent land. Meaningful consultation by the Wildlife Service with the full range of state authorities by fully disclosing all potential project impacts on these critical sites has also been largely lacking to date. In addition to these federal and state protections, the Farallon Islands and the entire surrounding coastal region have, since 1988, been further protected in the global context as part of the UNESCO Golden Gate International Biosphere Reserve.

The Stewardship Mandate:
A Place Protected by NOAA and the State of California

On the Southeast Farallon Island, the U.S. Fish and Wildlife Service has operated under the pretext that the surrounding Greater Farallones National Marine Sanctuary ought to have minimal direct jurisdictional authority over the Wildlife Service’s proposed helicopter bait drop. The Wildlife Service assumes that in spite of the planned aerial dispersal of so much deadly poison, not one single toxic pellet would manage to fall into Sanctuary waters. This implausible theory disregards the steep vertical gradient of the precipitous slopes of this island, while ignoring the natural effects of wind, waves, rain, and gravity and their inconvenient tendency to inevitably convey poison pellets into the surrounding intertidal zone and ocean waters. During similar helicopter poison drops on the island of Lehua, Hawaii, conducted in August and September of 2017, even a supposedly carefully-targeted application of what is called a first-generation rodent poison, Diphacinone, managed to result in swaths of the rodenticide pellets being extensively distributed throughout the intertidal zone and into the ocean itself. The presence of this poison was documented in video and photographs, with the toxic pellets clearly visible in the water among floating dead fish and seabird carcasses.

Lehua, Hawaii Aftermath

The Need for Compassionate Conservation

The protected Farallones today provide critical seabird and marine mammal rookery and nursery habitat. No other location in North America shelters a similarly robust concentration of sensitive species outside of Alaska. Fish and Wildlife proposes to utilize a poison that can impact virtually all living things that remain present during and immediately after the poison drop, except insects, although insects can covey the poison to anything that consumes them. A host of other non-target species would also be subjected to secondary exposure to the poison as a result of the proposed project’s scorched earth method of execution and the accidental dispersion of poison into the ocean. Studies have found that certain sea turtles appear to be even more susceptible to the anticoagulant rodenticides than rats.

In addition, the proposed plan includes capturing limited numbers of certain species in nets or traps. These animals would then be isolated and held in captivity at off-island locations during the poison drop, to later theoretically be reintroduced to re-populate their former native habitat once the toxic bait concentrations on the island are believed to have sufficiently subsided.

Lehua, Hawaii Aftermath

Species from the wild, when held in captivity, are put under stress and become particularly susceptible to disease, as evidenced by the unanticipated viral outbreak among valued endemic mice that were sequestered in a building for their protection during a 2009 poison project aimed at killing rats on Southern California’s Anacapa Island. The birds and fish that inhabit the Southeast Farallon Island and the surrounding waters are federally-designated Marine Sanctuary resources, so any weakening of the survivability of key species would be an interruption of the very ecosystem function that the Sanctuary site was designated to protect.

What Happens on the
Farallones Doesn’t Stay
On the Farallones

The Fish and Wildlife Service has previously made the assertion that their sole-source private subcontractors would somehow be able to successfully haze - or frighten away - virtually every single animal of each mobile non-target species during their project. Thereafter, this kind of hazing would need to continue to reliably keep these species frightened away from their customary natural habitat throughout the anticipated multi-week duration of the initial poisoning, as well as again for the duration of any of the follow-up applications of poison. This attempted hazing effort hypothetically involves the use of propane cannons, fireworks, lasers, “cracker” shells in shotguns, and other unproven wildlife deterrent techniques that have demonstrated only a partial degree of success elsewhere. Often tried around hydroelectric dams and during oil spills, hazing has shown only limited effectiveness at dissuading gulls, in particular, from remaining on their home habitat. Gulls, as any picnicking beachcomber knows, can be very persistent in circumstances in which anything resembling food is made available to them. Dead and dying mice would definitely be considered a food source to hungry gulls.

In the context of habitat disturbance, the proposed hazing activities are, by themselves, clearly inconsistent with the stewardship values and related regulations of the surrounding National Marine Sanctuary. Timely comments by the Greater Farallones National Marine Sanctuary and its own Sanctuary Advisory Council raising these and related questions have not yet generated a formal response from the U.S. Fish and Wildlife Service.

Internal U.S. Fish and Wildlife Service emails have revealed that the agency’s experienced staff with expertise in similar helicopter rodenticide drops concede that they anticipate the slow death of as many as 3,000 of the Farallones’ Western gulls if this project is allowed to proceed. U.S. Fish and Wildlife now says that if damage from their Farallones plan reaches 1,050 Western Gulls, population damage would occur. Given the toxicity of the compound being used and its direct and indirect pathways to Western Gulls, it is reasonable to anticipate reaching that number. Studies tracking Western Gulls from the Farallones have revealed that these birds have been found as far south as San Diego, California and as far north as Coos Bay, Oregon. Poison proponents boast that their Farallones project will require only one-and-a-half ounces of Brodifacoum, underscoring the fact that the incredibly potent toxicity of this poison requires dilution into a ton-and-a-half of cereal bait for wide dispersal and even then each kernel of bait still packs a large number of fatal doses.

Western Gulls from the Farallones Commute to the Mainland

In their independent federal agency review of the proposed Farallones project, the office of Region IX EPA has also cautioned, in their official comment letter of April 15, 2019, that the carcasses of poisoned gulls resulting from incidental bykill at the Farallones are expected to wash up on mainland California beaches and will need to be handled with HAZMAT toxic hazardous waste precautions, due to their likely body burden of residual Brodifacoum.

There has been no plan released for how the carcasses of this beached bykill could then be safely handled, and there is no identification of where the carcasses would be taken for disposal. Fish and Wildlife theoretically justifies their predicted acceptable level of incidental non-target bykill with the optimistic rationalization that overall population numbers for most of the damaged non-target species will hopefully ultimately achieve sufficient natural recovery within ten years after the drop. There have not been any studies provided that can reliably substantiate this one-decade recovery timeline claim for damaged non-target populations, or even whether such recovery is actually achievable. Unforeseen effects of human endeavors often appear in ways that cannot be predicted, as the unintended consequences cascade through entire ecosystems.

Poisonous Politics:
Fumbling by the Feds

The ambiguous regulatory status of the Farallones poisoning proposal results from a prior abortive 2019 permit application by the U.S. Fish and Wildlife Service to the California Coastal Commission as the Wildlife Service at that time previously attempted to secure a necessary key approval in the form of a “federal consistency determination”. Local Fish and Wildlife staff, while presenting at a July, 2019 Coastal Commission hearing in San Luis Obispo, California, were regrettably unable to answer relevant questions being asked of them by Coastal Commissioners. Questions from the Commission included requests for the project sponsors to identify at what point during the poison drop, in the event that Fish and Wildlife were to observe “excessive” bykill of non-target species, would the project’s personnel decide to halt the poison application once it had begun. No answer to this question was forthcoming from the Wildlife Service staff present at this hearing. Another legitimate inquiry by the Coastal Commissioners then present, about the Service’s emergency first-responder plan should a helicopter-originated spill of poison bait pellets accidentally take place - either on the island itself, on the mainland, or over the waters of San Francisco Bay or the Pacific Ocean – also left the Fish and Wildlife Service staff unable to respond. Large accidental poison pellet bait spills have occurred in New Zealand, absent any effective response protocols, so this is an important question. An apparent lack of timely answers by Wildlife Service representatives to legitimate questions about the Farallones proposal at the 2019 California Coastal Commission hearing resulted in a temporary withdrawal of the project application by the Service at that time.

Now, a revised re-application to conduct the Farallones poison drop by the U.S. Fish and Wildlife Service is expected to be resubmitted during the spring of 2021, with the California Coastal Commission subsequently tasked with deciding whether or not to reconsider a determination of federal consistency for the Farallones poisoning. This will likely be taken up at one of the Commission’s monthly meetings, as early as May of 2021, or soon thereafter.

Any decision by the California Coastal Commission about the fate of the Farallones would set an important precedent for a host of proposed poison projects that could similarly threaten dozens of other U.S. islands. The Coastal Commission’s decision about the Farallones could thereby also determine the precautionary level-of-care standards going forward for this particular National Marine Sanctuary as a model for addressing adverse poison impacts in other sensitive locations considering similar proposals.

Who’s Opposing Safer Alternatives and Why?
The Hard Conversation that Some Poison Advocates Don’t Want to Have

This controversial poisoning plan at the Farallones would likely have expired of its own irrational irrelevance by now, but the commercial pesticide industry and its profit-seeking cohorts have a strong fiscal motivation to ensure that the current supply chain of anticoagulant rodenticides is viewed by the public in a favorable light. The pesticide companies, including those involved at the Farallones, often rely on what they call the “ick factor” to try to frighten the public about all types of pests. Some global interest groups with virtually unlimited financial resources continually disseminate fear-based propaganda aimed at attempting to discredit more humane alternatives so that the use of Brodifacoum and similar poisons can be falsely portrayed as the only available option for places like the Farallones. Substantial financial benefits would accrue to some of these organizations if the poison drop on the Farallones is allowed to go forward, and those same entities therefore make every effort to try to portray solutions other than Brodifacoum as nonviable.

One could reasonably ask why otherwise credible groups might seem to favor this destructive project amidst such a sensitive ecosystem setting. In spite of a tragic history of notable biological messes and notorious ecological disasters that extends from Rat Island to Palmyra and beyond, this type of Death by Conservation endeavor remains very financially profitable for those seeking non-competitive government funding. The underlying belief among poison proponents seems to be that the ends justify the means. But in the case of Brodifacoum, the ends are clearly known to create foreseeable new problems, while the means have frequently failed to accomplish the stated goals, particularly with respect to the history of failed attempts at the total elimination of mice. The total elimination of an adapted invasive species would best be achieved in a balanced manner by targeting the root of the problem, which is reproduction. This means slow removal, progressing to theoretical elimination, then restriction of renewed invasion.

Some entities involved in publicly expressing support for the Farallones proposal even appear capable of suspending any semblance of compassion, ignoring the most fundamental humane principles with respect to nontarget bykill casualties. Various groups seem to find it helpful to try to divorce the slow death leading to so much extensive unnecessary overkill by falling back on the false rationalization that even if the Brodifacoum poison does cause population level damage, that the Farallones ecosystem will just have to take a one-time hit in order to try to eliminate the misplaced mice. This theory simply attempts to justify trading the possible enhancement of one species in the ecosystem for known deliberate damage to many other species, an arbitrary value judgment that ignores overall ecosystem stability and provides an argument based not on real science, but one that instead relies on human hubris.

Farallones Arboreal Salamander

Unproven Theories:
Trading One Species for Another

Worldwide, certain seabirds may indeed be at some degree of risk due to the ravages of longstanding anthropogenic impacts, but substituting one human impact for another is not a step toward true ecosystem recovery. The hypothetical case statement implying that the Ashy Storm Petrel population at the Farallones may be at risk from Burrowing Owls has clearly not been made in a manner that has thus far proven convincing to the U.S. Fish and Wildlife Service itself, or this agency would not have twice in the past categorically denied enhanced regulatory protections for the same species.

Islands everywhere are living laboratories for understanding the interplay between food web interactions and ecosystem function relationships. To arbitrarily disrupt the entire food web at the Farallones in the haphazard quest to possibly benefit one single species, absent any conclusive evidence that this species is really in trouble, is merely a personal value judgment that has little scientific basis. Seabirds themselves are ecosystem engineers, as are Burrowing Owls. Clearly, a better overview of the entire Farallones food web and how it interacts with the mainland, including the role of multiple species of seabirds, the island’s plants, the endemic Camel Cricket, the Farallones Arboreal Salamander, and even the Burrowing Owls, is needed before any official approval is given to the proposed poison drop.

In the words of Dr. Michael Fry of the U.S. Fish and Wildlife Service, in predicting gull mortality: “Probably half will die in San Francisco. Minimum number will be 3000 dead gulls in SF. More if the hazing is less successful.”

Safer Ways:
More Focused and Less-Destructive Pest Control Alternatives Are Now Available

Predictably, scientific research is now advancing in response to the moral and ethical questions posed by habitual misuse of the current versions of anticoagulant chemical compounds. Accommodating an obvious emerging market demand for a new generation of rodent control mechanisms amidst compelling evidence of the obsolescence of second-generation anticoagulant rodenticides like Brodifacoum will likely prove to be a strong motivator for adaptation by this industry. U.S. and international research laboratories, responding to emerging societal pressures to find new methods of rodent control that are less damaging to sensitive ecosystems, have already made significant advances in the applied biochemistry of fertility control measures. This welcome technological progress has also resulted in substantial advancements in the timely agency permitting and commercial application of contraceptive baits for safer rodent control.

The emerging new generation of contraceptive baits depend on species-specific fertility control and thus don’t damage non-target living systems, don’t bio-concentrate in the food chain, and are presently approved for use by EPA and the California Department of Pesticide Regulation. These contraceptive baits are now being utilized throughout the food production industry, by animal rescue entities, and by the poultry industry for control of rats. Development of similar contraceptive baits that are of solid formulation for broadcast for mice is now progressing rapidly, and will enable Fish and Wildlife to refocus the use of effective fertility control technologies that pose no threat to nontarget species. The Wildlife Service could easily proceed in a more constructive direction without delaying efforts toward their proposed project on the Farallones.

The most logical procedural path forward at this time would be for the U.S. Fish and Wildlife Service to issue a Supplemental Environmental Impact Statement (SEIS) document that resurrects the previously-studied, but prematurely-discarded, option of using contraceptive bait for the proposed project at the Farallones. The agency should update their present outdated version of a NEPA document to instead adopt a more noncontentious and less dangerous approach, fully reflective of recent advances in the use of contraceptive baits to target invasive mice.

This more current and contemporary science would move the present policy debate away from whether or not to rid the Southeast Farallon Island of mice, and instead promote a more constructive evaluation of how best to eradicate the mice from the Southeast Farallon Island without unnecessary collateral damage to the vast populations of innocuous non-target species that share the same habitat within the Greater Farallones National Marine Sanctuary. Achieving balanced decline of the adapted invasive species, without the bykill, should be the goal of any project at the Farallones.

There appears to be no viable way that any eradication project variant involving helicopter dispersal of Brodifacoum poison could avoid unacceptable multi-year incidental damage to commercially and ecologically important terrestrial and marine species, nor could such a project provide sufficient assurances that associated activities would not adversely impact valuable fishing grounds and critical fisheries habitat in the waters immediately surrounding the Farallones. It must be kept in mind that an essential regional economy is based upon the integrity and marketability of seafood from these waters, as well as on the fragile public perception of the safety of the produced seafood commodities by the consumer.

Viable Solutions Are Already Available

The Secretary of Interior should instruct the U.S. Fish and Wildlife Service to consult with the relevant Tribes having traditional cultural landscapes in this region to obtain their consent for any proposed action and for the anticipated adverse impacts.

Further, the Secretary of Interior needs to instruct the U.S. Fish and Wildlife Service Director to withhold the issuance of the decisive Record of Decision document and to also freeze all permit actions involving this project as currently proposed. An objective process can then ensure the efficacy and permit availability for harmless fertility control baits capable of achieving the project purpose without excessive devastating bykill. The option of fertility control can then be fully evaluated by the agency in a transparent NEPA proceeding involving the requisite public and Tribal input.

By considering Traditional Ecological Knowledge in the context of animal welfare alongside animal conservation, it may become possible to establish wildlife management protocols that are explicitly oriented towards the lives of individual animals and their social groups, not just the species or population as a whole.

Your Voice Counts:
Public Resources at Risk on Your Public Lands

The California Coastal Commission is the most important public agency that will need to consider whether or not to allow the Farallones Poison Drop to proceed, because the proposal is within the Coastal Zone of the State of California. Even though the island itself is comprised of federal land in a National Wildlife Refuge surrounded by the federal protections granted by the Greater Farallones National Marine Sanctuary, its proximity to the mainland actually makes the geographic location a part of the City of San Francisco. The California Coastal Commission is being asked by the U.S. Fish and Wildlife Service to grant their consent through what is called a “consistency determination”. Such an action would certify that the poisoning proposal is consistent with the state’s federally-approved Coastal Zone Management Plan. As noted, when the Wildlife Service last approached the California Coastal Commission for such an approval at the July 2019 public hearing in San Luis Obispo, it was apparent that many of the questions posed to the Wildlife Service staff by Coastal Commissioners could not be answered. Fortunately, the application was temporarily withdrawn by the Wildlife Service at that time. Prior public meetings on this proposal held by the U.S. Fish and Wildlife Service in San Francisco in May of 2011 provided clear evidence of the strong regional opposition to this poison plan.

The central primary principle which each individual member of the California Coastal Commission is sworn to uphold on behalf of the State of California is the protection of Environmentally Sensitive Habitat Areas within the Coastal Zone, also known as ESHA. With a globally-significant concentration of critical habitat and the recognized diversity of fragile wildlife, the Farallones themselves represent the heart of what is referred to as Hyper-ESHA.

The California Coastal Commission itself is structured in such a manner that the prevailing views of the public are generally - but not always - reflected in the decisions reached by the Commission. Since the monthly meetings of the Coastal Commission will likely remain in an online webinar mode, virtual public hearing testimony will be taken by the Commission to hear from those who have previously submitted an online registration to testify. One must use the Commission’s user-friendly website for the appropriate month’s agenda to sign up to testify at the upcoming virtual public hearing on this proposal. Meanwhile, letters and emails to the Coastal Commissioners should be submitted as early as possible prior to their anticipated decision at a special meeting on this topic that may occur as early as June of 2021.

The most important single thing that you can do at this time is to send a short email expressing your views on this proposal to farallonislands@coastal.ca.gov

Other state and federal agencies will also be opening important opportunities for further public input, and the appropriate links for you to comment on these will be updated as they become available at http://PoisonFreeSanctuary.org

Because of the sensitivity of our special coastal environment and the profound precedents involved for all wildlife, this is going to be one of the most important decisions in the history of the California coast.

Thank you for joining us.

Please send an email now to: farallonislands@coastal.ca.gov

About the Author and the Book Team:

Richard Charter has been working for over four decades to ensure protection for fragile marine ecosystems and sensitive coastlines throughout the world. A Senior Fellow with the Coastal Coordination Program of The Ocean Foundation, he helped to coordinate the local government and congressional support that led to the initial creation of the original Gulf of the Farallones, Cordell Bank, Channel Islands, and Monterey Bay National Marine Sanctuaries along the California coast. Mr. Charter has also worked for the past twelve years to protect the wildlife of the Greater Farallones National Marine Sanctuary from dangerous wildlife poisons. Publications include the book “Bring Back the Gulf”, “Negotiating for the Nonnegotiable on the California Coast” in the MIT Environmental Assessment Review, “An Intergovernmental Response to Offshore Oil and Gas Leasing”, and numerous magazine and newspaper articles.

Co-Editors/Researchers:

Maggie Sergio is a conservationist, environmental educator and writer. She has researched and written about a wide range of environmental issues including the impact of rodenticides on wildlife, the open-air testing of experimental pesticides and GMOs in Hawaii, and the little-known industry behind the practice of island eradications.

Lou-Anne Fauteck Makes-Marks, PhD, Coast Miwok, Pomo, is the Director of Sacred America. Visit online at sacredamerica.org

Alison Hermance is the Director of Communications at WildCare, a wildlife hospital, nature education and wildlife advocacy organization located in Northern California. Visit WildCare online at discoverwildcare.org

Production and Design by The Book Designers, at bookdesigners.com

Published by the Coastal Coordination Program of The Ocean Foundation, Washington, DC, oceanfdn.org

ISBN: 978-0-578-87405-0

Additional copies of this publication are available free of charge as an eBook download at PoisonFreeSanctuary.org

Photo and Graphics Credits:

Front Cover: Photo of helicopter courtesy of Clyde Graf, The Graf Boys; Farallones Seabirds, Alamy Stock

Inside Front Cover: Map/California Department of Fish and Wildlife

Illustrations: Burrowing Owl by Dori Merr, Wikipedia Images; Ashy Storm Petrel, Shutterstock

Illustrations: Graphic of “Dancing on the Edge of the Pacific”, Lou-Anne Fauteck Makes-Marks, PhD

Illustrations: Photo of “The Eggers, 1875”, California State Library

Illustrations: Typical Raptor Rodenticide Victim, WildCare

Illustrations: Modified Rodenticide Label, EPA

Illustrations: Photo from Lehua, Hawaii video

Illustrations: Photo from Lehua, Hawaii video

Illustrations: Gull map

Illustrations: Map of Marine Protections, NOAA

Illustrations: Endemic Farallones Arboreal Salamander

Illustrations: Whale, Alamy Stock

Illustrations: Cartoon courtesy of George Russell and the Marin Independent Journal; Color Foodchain Graphic by Raptors are the Solution; Map/NOAA

Back Cover: Marine Mammals, Alamy Stock

Please consider contributing to our future efforts, by making a donation to this project at http://AdoptanOcean.org

This publication is gratefully dedicated to the ethical practitioners who understand and apply the principles of compassionate conservation based upon sound science and the humane treatment of all animals everywhere.