Section 7 Environmental Consequences
[7-1](#section-7-7-environmental-consequences)

7.1 Introduction to Evaluation of Environmental Consequences
[7-1](#introduction-to-evaluation-of-environmental-consequences)

7.2 Direct and Indirect Impacts of the Alternatives
[7-3](#direct-and-indirect-impacts-of-the-alternatives)

7.2.1 Alternative 1 (No Action) [7-3](#alternative-1-no-action)

7.2.2 Alternatives 2 and 3 [7-4](#alternatives-2-and-3)

7.3 Cumulative Impacts [7-24](#cumulative-impacts)

7.3.1 Alternative 1 (No Action) [7-29](#alternative-1-no-action-1)

7.3.2 Alternatives 2 and 3 [7-29](#alternatives-2-and-3-1)

7.4 Other NEPA- and CEQA-Mandated Discussions
[7-37](#other-nepa--and-ceqa-mandated-discussions)

7.4.1 Irreversible and Irretrievable Commitment of Resources and
Environmental Changes
[7-37](#irreversible-and-irretrievable-commitment-of-resources-and-environmental-changes)

7.4.2 Relationship between Short-Term Uses of the Environment and the
Maintenance and Enhancement of Long-Term Productivity
[7-38](#relationship-between-short-term-uses-of-the-environment-and-the-maintenance-and-enhancement-of-long-term-productivity)

7.4.3 Growth-Inducing Impacts [7-38](#growth-inducing-impacts)

7.4.4 Significant and Unavoidable Adverse Impacts
[7-38](#significant-and-unavoidable-adverse-impacts)

# Section 7 7 Environmental Consequences

## Introduction TO evaluation of Environmental Consequences

This section describes and compares the potential environmental
consequences of the proposed action (restoration of the natural
resources injured by the DDTs and PCBs discharged to coastal waters of
Southern California) by analyzing the individual projects and the three
alternatives described in this Restoration Plan. This plan has been
prepared as a programmatic Environmental Impact Statement
(EIS)/Environmental Impact Report (EIR) for the purposes of the National
Environmental Policy Act (NEPA) and the California Environmental Quality
Act (CEQA). The potential environmental consequences are considered
within the following context:

-   The fundamental purpose of the proposed action is to restore injured
    natural resources and the services they provide (i.e., to improve
    the natural and human environment).

-   The DDTs and PCBs of the Montrose case are expected to persist in
    the marine environment of the Southern California Bight for many
    years.

-   The alternatives presented in this Restoration Plan include actions
    for which this programmatic EIS/EIR fulfills NEPA/CEQA requirements
    as well as actions that will require further NEPA and/or CEQA
    analysis at a subsequent stage, after the details of the action are
    developed.

-   The Natural Resource Trustees for the Montrose case (Trustees)
    anticipate updating the Restoration Plan as implementation
    progresses and new information becomes available. The actions
    evaluated constitute the actions the Trustees reasonably foresee
    implementing over the initial phase (Phase 1) of the program, which
    will run approximately through 2010.

Subsequent planning and environmental impact analysis will be tiered off
of this programmatic EIS/EIR. In the terminology of NEPA, "tiering"
refers to the coverage of general matters in a broad EIS with subsequent
narrower environmental analysis that incorporates by reference the
general discussions and concentrates solely on the issues specific to
the analysis subsequently prepared. Tiering is appropriate when impact
analysis progresses from a program, plan, or policy EIS to an analysis
of lesser scope or to a site-specific analysis. Tiering is appropriate
when it helps focus analysis on the issues that are ripe for decision
and excludes from consideration issues already decided or unresolved
(U.S. Council for Environmental Quality regulations for implementing
NEPA, Title 40 Code of Federal Regulations \[CFR\] Section 1508.28).

In addition to addressing the overall Montrose Settlements Restoration
Program (MSRP) effort at a programmatic level, this Restoration Plan and
Programmatic EIS/EIR fulfills the impact analysis requirements for ten
individual actions (see Table 6-1).[^1] Analyses of the direct and
indirect environmental effects and proposed mitigation are provided in
Section 7.2 for these ten actions and, to the extent possible at this
stage, for the remaining seven actions that will require further
analysis at a later point when more details are available. Expanded
discussions of the actions are provided in Appendices A--D.

NEPA and CEQA also require the analysis of cumulative impacts (Section
7.3) and other mandated discussions (Section 7.4), including:
irreversible and irretrievable environmental changes and commitments of
resources, the relationship between short-term uses of the environment
and the maintenance and enhancement of long-term environmental
productivity, growth-inducing effects, and identification of any
significant and unavoidable adverse impacts.

The environmental impact analysis in this Restoration Plan and
Programmatic EIS/EIR focuses on the following categories considered to
have potential relevance to the anticipated actions:

-   Biological resources (fish, birds and other wildlife)

-   Physical resources (earth resources, including sediments, water
    resources, and oceanographic and coastal processes)

-   Human use (recreation, socioeconomics, and aesthetics)

    Effects in the following categories are considered insignificant or
    not relevant to the anticipated actions:

-   Air quality: Air quality impacts from any individual project will
    either be non-existent or minor (i.e., involve limited production of
    fugitive dust and emissions from construction vehicles). The impacts
    will be insignificant contributions, both individually and combined,
    when compared to impacts from other construction projects and from
    motor vehicle emissions on highways and streets in the areas where
    restoration actions take place, and will not represent a significant
    contribution to regional air quality.

-   Agriculture: None of the project sites or anticipated sites are
    suitable for agricultural use.

-   Noise: Restoration activities will not take place at sites near
    existing human habitation. Construction will involve equipment that
    produces noise similar to or below the levels already allowed by
    local ordinances governing normal construction activities. Social
    attraction as a method for restoring seabirds to islands involves
    production of recorded sounds in these remote areas, but these
    activities have been successfully employed in the past and it is
    unlikely to result in adverse consequences to other biological
    organisms.

-   Population and housing: The sites where actions will take place are
    not populated and are not considered viable areas for housing
    development.

-   Soils, geology, and geologic hazards: Restoration activities do not
    involve any modification of the geology at any sites, and no
    geologic hazards will be increased by MSRP activities.

-   Land use planning: The implementation of the MSRP Restoration Plan
    will not involve significant changes in land use or be inconsistent
    with existing local and regional plans and policies on land use.

The potential effects in the following categories are not anticipated to
be significant at this point, but detail is not yet sufficient for final
analysis in this EIS/EIR because the actions that could affect these
categories are still conceptual:

-   Hydrology: The restoration of full tidal exchange wetlands may have
    hydrological impacts, depending on the nature of the actions and
    their scale. The potential for such impacts, if any, will be
    addressed once potential site(s) are identified and project details
    are more fully developed. None of the other actions evaluated in
    this Restoration Plan involve physical changes that have the
    potential for hydrological impacts.

-   Navigation and navigation safety: The construction and final
    placement of material for artificial reefs as envisioned in this
    Restoration Plan will either have no impacts or insignificant
    impacts to navigation and navigation safety. During the site
    selection and design of artificial reefs, the Trustees and other
    project proponents will consider potential effects on navigation and
    address these issues in site-specific environmental analyses.
    Numerous artificial reefs have been constructed in Southern
    California coastal waters in recent decades (Appendix A1, Figure
    A1-1), and potential impacts to navigation are avoided through
    consideration of the locations and depths of material placement. For
    example, in a Mitigated Negative Declaration that the Port of Los
    Angeles prepared for the proposed San Pedro artificial reef project
    (Los Angeles Harbor Department 2003), the Port proposed a minimum
    reef crest depth and proposed avoiding placement of reef material
    within shipping lanes or within a 200-yard radius around a
    navigational marker buoy to accommodate U.S. Coast Guard maintenance
    of the buoy.

-   Transportation, traffic, and roadway safety: Existing
    transportation, traffic, and roadway systems will remain unaltered
    by any projects undertaken under the MSRP. A small amount of
    temporary traffic may result from moving equipment in and out of
    certain sites. The potential traffic impacts of transporting rock or
    concrete to potential reef or roost sites may need to be addressed
    in a subsequent environmental analysis once greater details about
    site-specific activities are known; however, it is likely that the
    minimal number of truck trips to move material from source sites to
    barge-loading areas will simply replace truck trips of alternative
    uses of the materials (e.g., to crushers and landfills).

-   Cultural resources: No significant impacts to cultural resources
    have been identified for any of the restoration actions. For
    projects that will involve construction and for which specific sites
    have not yet been identified (e.g., construction of reefs or
    modification to fishing facilities), a review of potential cultural
    resource impacts will need to be conducted once specific sites are
    identified.

## Direct and Indirect impacts of the alternatives

This section evaluates the direct and indirect environmental effects of
the proposed action through analysis of each of the three alternatives:
Alternative 1 (No Action), Alternative 2 (Preferred) and Alternative 3.
This section also presents mitigation measures to reduce or avoid
potential adverse impacts. Expanded descriptions and detailed analysis
of the individual projects against the evaluation criteria, including
their beneficial and adverse impacts, are provided in Appendices A--D.

### Alternative 1 (No Action)

Under the No Action Alternative, the MSRP would not implement any
restoration activities except monitoring. Consequently, there would be
no environmental impacts when compared to the baseline, or current
conditions. Beneficial effects of natural resource restoration actions
would not be realized. The purpose and need for the MSRP (i.e.,
utilizing the funds from the Montrose settlements to restore injured
resources and lost services) would not be met. Without active
restoration projects, there would be no biological, physical, or human
use benefits or adverse impacts. However, natural resource injuries and
lost services resulting from the DDTs and PCBs of the Montrose case
would persist in the Southern California Bight for the foreseeable
future. Also, no compensation for interim lost natural resource services
from the date of the enactment of the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) (1980) until injuries
cease would be realized.

### Alternatives 2 and 3

Each of these two alternatives consists of a different combination of
the 17 restoration actions described in Section 6 and evaluated in
detail in Appendices A--D. Several of these individual actions are
common to both alternatives, some are only in one alternative, and some
are not included in either. The direct and indirect environmental
effects of each of the 17 actions are presented here individually (in
the same order as the actions are listed in Appendices A--D); the
headings indicate which of the alternatives each action is a part of.

These two comprehensive alternatives have been compiled to evaluate
different mixes of restoration actions that the Trustees believe they
can accomplish within the \$25 million funding level set for Phase 1 of
implementation. Although some of the actions are not specifically
included under either Alternative 2 or 3, all actions are evaluated at
this point. As a result, the Trustees would be able to proceed with any
of the other actions should additional funding become available, or
should any of the proposed actions prove infeasible.

A1. Construct Artificial Reefs and Fishing Access Improvements
Alternative 2 \[  \] Alternative 3 \[  \] Neither \[ \]

This action will require subsequent environmental analysis when the
project details are more fully developed.

##### **[Biological Effects]{.underline}**

**Direct Effects.** This action will convert soft-bottom aquatic habitat
to reef habitat. The reduction of soft-bottom habitat on the limited
scale feasible under this restoration action, when compared to the
predominant extent of such habitat throughout the region, will not
significantly affect the total available soft-bottom habitat to those
species that rely on it. Unless care is exercised in siting artificial
reefs, their construction can potentially impact the availability of
other limited inshore habitat or resources, such as eelgrass beds,
spawning areas for market squid (*Loligo opalescens*), or important
nursery areas for certain fish species such as California halibut.

The displacement of the sandy- or muddy-bottom habitat with hard-bottom
substrate will increase the diversity and may increase the number of the
animal and plant biota in the area. The fish productivity of rocky reef
habitat has been estimated to be between 9 and 23 times that of
sandy-bottom habitat (MEC Analytical Systems 1991).

At a conceptual level, reef construction projects are not likely to
adversely affect threatened or endangered species or essential fish
habitat. Nonetheless, detailed analysis will be performed at a
site-specific level once specific sites for reefs are identified.

**Indirect Effects.** To the extent that reefs constructed under the
MSRP program function as production sites for rockfishes or other
species that are currently depleted, the reefs may benefit the
management and recovery of these depleted species of fish.

Reef-associated fish typically contain lower concentrations of DDTs and
PCBs than soft-bottom species, so constructed reefs benefit the
biological organisms that prey on fish in the vicinity of the
constructed reefs, as these organisms are likely to be exposed to
reduced levels of these contaminants.

It is possible that fishing pressure and thus fish mortality may
increase in the vicinity of newly constructed reefs. Such an effect
might also occur should improvements to fishing access and amenities be
constructed under this restoration action and lead to increases in
fishing trips to a particular site.

**Mitigation Measures.** The specific location of each constructed reef
will be studied and selected such that the MSRP reefs avoid impacts to
eelgrass beds or other nearshore soft-bottom areas that are currently
important and contain limited habitat types. State and federal fisheries
agencies will be consulted to ensure appropriate reef design, size, and
placement, and to ensure that long-term management will accommodate
anticipated increases in fishing and other uses of the reef site.

##### **[Physical Effects]{.underline}**

**Direct Effects.** The placement of concrete or rock materials into
marine waters will cause short-term suspension of sediments at the reef
construction site that will result in short-term water quality impacts.
The principal effect will be increased turbidity; however, depending on
local conditions, the sediments at the reef site might contain elevated
contaminant levels.

**Indirect Effects.** To the extent that the material used to construct
a reef is from the demolition of concrete structures, the beneficial
reuse of this material will divert it from land disposal and conserve a
corresponding increment of landfill space. There may be other trade-offs
related to transportation and disposal of materials (such as reduced air
quality impacts relative to land disposal), but whether these trade-offs
will have net positive or net negative consequences cannot be determined
until the site-specific implementation factors are determined.

Placement of reefs in nearshore areas has the potential to disrupt the
normal transport of sediment and affect the topography of adjacent
subtidal and beach areas. Also, depending on the nature of the soft
substrate in a given area, the depth to bedrock, and the slope, the hard
substrate dropped to the marine bottom could potentially not perform as
intended.

**Mitigation Measures.** Adjustments to the methods and timing for reef
material placement may be developed in consultation with regulatory
agencies (i.e., the California Regional Water Quality Control Board, the
U.S. Army Corps of Engineers, and the U.S. Environmental Protection
Agency \[EPA\]) to address local conditions and reduce the potential
short-term water quality impacts of the construction.

Once planning progresses to the stage in which site-specific studies are
undertaken, the potential short-term physical impacts from placing rock
or rubble in a given area will undergo engineering and water quality
analysis, and additional evaluation will be performed to identify
measures to minimize adverse effects.

##### 

##### **[Human Use Effects]{.underline}**

**Direct Effects.** Artificial reef construction in areas where fish
species contaminated by DDTs and PCBs will be displaced by
less-contaminated species associated with hard-bottom and water-column
habitats will have a direct benefit to anglers whose fishing has been
impacted by fish consumption advisories.

Improvements to fishing access (e.g., the addition of various fishing
site amenities, including pier extensions, fish-cleaning stations,
benches, parking improvements, or other such actions) are not possible
to evaluate at this stage as they are highly dependent on the specific
details and local site characteristics. However, construction activities
at fishing sites (e.g., construction improvements to piers, amenities
such as fish-cleaning stations, parking, etc.) may cause short- term
disruption to users of a site during the construction period.

**Indirect Effects.** Artificial reefs provide human use benefits beyond
fishing, as they are also popular areas for scuba and free diving for
purposes of recreation, hunting, and underwater photography. As with the
biological benefits, the human use benefits will be sustained for a
period of decades or perhaps longer with minimal operational or
maintenance costs.

Depending on their location, design, and depth, artificial reefs could
have adverse impacts on various other types of human uses. Uses that
could potentially be impacted by shallow reefs include body surfing or
wind surfing and, possibly, navigation. Also, constructed reefs will
displace soft-bottom species, and the anglers who favor catching these
species at the site of a constructed reef will find it harder to catch
these fish. Potential impacts to recreational and navigational uses will
be a significant consideration in the selection of candidate sites.
Findings on these issues will be included in subsequent site-specific
environmental documentation and provided to the public for review.

**Mitigation Measures.** The Trustees undertook a survey of recreational
and subsistence anglers in 2002 and 2003, in part for the purpose of
determining fishing preferences at fishing sites along the Los Angeles
County and Orange County coastline. The data generated by this field
intercept survey and follow-up public involvement activities will be
used to select sites that minimize negative impacts to anglers who may
be targeting soft-bottom fishes exclusively. The Trustees are also
gathering chemistry data on fish contamination. Up-to-date fish
contamination data provide a means for optimizing the placement of
constructed reefs with respect to prevailing contamination. Thus, if the
fish caught after reef construction are lower in contamination, then
fishing and fish consumption benefits will be realized from these
projects.

Steps will be taken to minimize the impacts resulting from the
construction of fishing access improvements. These impacts will be
addressed at the stage when site-specific plans are being considered.

When initiating a design for site-specific reef development, the MSRP
will consider the potential adverse human use impacts identified above
by avoiding placement of reef material where it would cause such adverse
impacts. Also, fishing reefs will not typically be constructed in areas
shallow enough to affect surfing because swells and waves would deter
development of the types of fish communities that are the intent of the
reefs.

A2. Provide Public Information to Restore Lost Fishing Services
Alternative 2 \[  \] Alternative 3 \[  \] Neither \[ \]

##### **[Biological Effects]{.underline}**

**Direct Effects.** This action will not have any direct biological
effects.

**Indirect Effects.** Should the public information program lead to
changes in fishing practices in the region, it is possible that fishing
exploitation of certain contaminated species of fish will decrease and
fishing for cleaner species of fish will increase. It is also possible
that the public information program could lead to increased fishing
exploitation of fish populations in the locations that the program
identifies as having fish lower in contamination.

**Mitigation Measures.** The Trustees will consider both contamination
levels and vulnerability to over-fishing as factors when providing
fishing advice to anglers. Thus, the program will not advise anglers to
target any species that is currently over-fished or at risk of future
over-fishing due to population status or specific life-history
characteristics that might make that species more vulnerable to
over-fishing. The Trustees will work closely with state and federal
fisheries managers and provide them opportunities to review materials
prior to initiating public information and outreach on fishing to ensure
that any MSRP recommendations on specific fishing sites and species do
not conflict with pertinent fishing regulations (e.g., catch
restrictions).

##### **[Physical Effects]{.underline}**

This program will not have any direct or indirect effects on the
physical environment.

##### **[Human Use Effects]{.underline}**

**Direct Effects.** Because this project focuses on providing
information that enables fishing rather than restricting fishing, no
significant direct effects on human uses are anticipated.

**Indirect Effects.** Development of better data on fish contamination
and improved dissemination of information on fish contamination
(including the locations and species of fish that are safer for catching
and consuming) should provide recreational benefits for anglers and
could potentially lead to increased human uses of ocean fish resources.
Minor impacts to aesthetics could occur if informational signs or kiosks
are erected, depending on the design, size, and placement of the signs.

**Mitigation Measures.** The designs for the informational signs will be
adopted from the previous designs developed and employed by the State of
California and the county health departments in the study area. The
signs will be placed in consultation with appropriate local authorities
in such a way as to minimize any impacts to the aesthetics of the
surrounding area.

A3. Restore Full Tidal Exchange Wetlands Alternative 2 \[  \]
Alternative 3 \[ \] Neither \[ \]

This action will require subsequent environmental analysis when the
project details are more fully developed.

##### **[Biological Effects]{.underline}**

**Direct and Indirect Effects.** The biological consequences of
restoration projects for Southern California coastal wetlands are
largely beneficial given the historical losses of such habitats, their
relative scarcity today, and their valuable ecological functions.
Wetlands restoration requires careful planning, analysis, and
consideration of the trade-offs between different and sometimes
competing biological resources and uses. MSRP funding will be
specifically earmarked for actions that benefit wetlands-dependent
marine fish species, which might conceivably alter the relative balance
of habitat types targeted for restoration within an overall plan.
However, this possibility cannot be fully analyzed until site-specific
details are developed.

**Mitigation Measures.** Appropriate mitigation measures will be
identified once potential site(s) are identified and project details are
more fully developed.

##### **[Physical Effects]{.underline}**

**Direct Effects.** Depending on their location and design, wetlands may
provide benefits to water quality (USEPA 2001). Restoration of full
tidal exchange may also increase contributions of sediment from
terrestrial watersheds into coastal areas.

**Indirect Effects.** Wetlands restoration could have several indirect
physical effects, including hydrological consequences, the need to
identify disposal requirements for dredged material, and impacts on
roads and utilities.

**Mitigation Measures.** Appropriate mitigation measures will be
identified once potential site(s) are identified and project details are
more fully developed.

##### **[Human Use Effects]{.underline}**

**Direct and Indirect Effects.** Wetlands provide numerous active and
passive recreational use values, including birding, boating, fishing,
and other uses. Wetlands restoration may also impact current
recreational and other human uses of sites slated for restoration.
Environmental effects on human uses will need to be analyzed at a later
stage, when more site-specific information is available.

**Mitigation Measures.** None are identified at this time.

A4. Augment Funds for Implementing Marine Protected Areas in California
Alternative 2 \[  \] Alternative 3 \[ \] Neither \[ \]

This action will not establish new Marine Protected Areas (MPAs) or
modify the boundaries or human use restrictions of the MPAs already
established for the Channel Islands. Rather, this action will enhance
implementation of these MPAs so that they will be managed and monitored
in ways closer to those originally envisioned. Thus, this analysis
evaluates impacts relative to the No Action Alternative (i.e., the
current MPA management activities), not the MPA management plan as
originally developed.

##### **[Biological Effects]{.underline}**

**Direct Effects.** MPAs are established for the purpose of restoring
and/or preserving marine biological communities, so increased funding to
improve management and monitoring efforts for the Channel Island MPAs
will increase the beneficial biological effects for which the MPAs were
established.

**Indirect Effects.** It is possible that the increased public awareness
and enforcement of restrictions on the taking of biological organisms
from within the boundaries of the Channel Island MPAs that might result
from this action could redirect fishing efforts to other marine areas to
a greater extent than do the current MPAs. However, the original
selection of MPA locations and boundaries was in large part driven by a
conscious effort by resource managers to shift such fishing to areas
capable of supporting it and away from areas where such practices have
led to depletions of critical marine resources. Also, an important
component of MPA monitoring is an examination of the degree to which
MPAs may result in spillover benefits to fish stocks outside of their
boundaries, thus increasing the capacity of surrounding areas to support
greater fishing pressure.

**Mitigation Measures.** Before providing funding to augment
implementation of the Channel Islands MPAs, the Trustees will ensure
that overall MPA monitoring efforts include adequate provisions for
reviewing the effects of the MPAs on surrounding areas.

##### **[Physical Effects]{.underline}**

This action will have no known direct or indirect effects on the
physical environment.

##### **[Human Use Effects]{.underline}**

**Direct and Indirect Effects.** Several potential benefits to human
uses could result from improved effectiveness of the implementation of
the Channel Island MPAs. Restoration of depleted resources within the
boundaries of the reserves could provide recreational opportunities
outside of the reserve. Although the MPAs generally prohibit the taking
of biota within the MPA boundaries, effectively managed MPAs have the
potential to lead to spillover of fish to adjacent areas and thus
improve fishing use outside their boundaries.

It is possible that augmenting MPA implementation and enforcement (i.e.,
to levels closer to those originally envisioned) may have increased
consequences on some human uses (e.g., fishing within their boundaries)
above what might exist in the absence of MSRP support. By their nature,
MPAs restrict several types of human uses within their boundaries. This
impact was addressed in the environmental documentation that supported
the original establishment of the Channel Island MPAs (CDFG 2002). The
most seriously debated impact of the Channel Island MPAs related to the
question of their contribution to commercial and recreational catches.
The opponents of these MPAs suggested that even though MPAs may increase
the abundance of fish within their boundaries, they exclude fishermen
from productive fishing areas, concentrating them in the less productive
areas and resulting in an overall reduction of catch. This concern was
addressed during the development of the Channel Island MPAs through
extensive collaboration with the fishing community to avoid restrictions
to fishing in already established, favored fishing locations. In
addition, the Channel Island MPA evaluation plan included extensive
socio-economic impact studies designed to address the potential negative
impacts of MPAs on human uses (CDFG 2004a).

**Mitigation Measures.** Before providing funding to augment
implementation of the Channel Island MPAs, the Trustees will ensure that
the Channel Island MPA Monitoring Plan provisions for socioeconomic
impact studies are being implemented as planned.

B. Complete the NCI Bald Eagle Feasibility Study Before Deciding on
Further Restoration Actions Alternative 2 \[  \] Alternative 3 \[ \]
Neither \[ \]

This is an interim action that will require subsequent environmental
analysis.

##### **[Biological Effects]{.underline}**

**Direct Effects.** Individual bald eagles will be impacted by the
restoration efforts. Eight of the 34 bald eagles released on Santa Cruz
Island as part of the Northern Channel Island (NCI) Bald Eagle
Feasibility Study have died from various causes. Overall, the survival
rate of eagles released on the Northern Channel Islands appears to be
within the normal range of both eagle survival in the wild and a
reintroduction program. The loss of several individuals is not
considered significant in light of the overall recovery of the bald
eagle in the United States and the efforts to restore this species to
the Channel Islands.

This course of action proposes to suspend funding of the Santa Catalina
Island Bald Eagle Program after 2005 during the interim period until
subsequent restoration decisions are made, in or around 2008. One
potential outcome of stopping human intervention and allowing bald eagle
nests to fail is that eagle pair bonds may break down and the birds may
abandon the island. However, it is highly likely that bald eagles will
remain on the island for several years despite their inability to hatch
offspring naturally. Bald eagles in the wild typically live for 25 to 30
years, and Santa Catalina Island currently supports 15 to 20 birds of a
wide range of ages. Currently, five bald eagle nesting territories are
active on the island, and the Institute for Wildlife Studies reports
that two birds are currently establishing a new territory near Avalon.
Even assuming that the Santa Catalina Island bald eagles fail to hatch
new chicks in the coming years, bald eagle experts do not expect that
they will immediately break their pair bonds and abandon their Santa
Catalina Island territories. Rather, it is likely that bald eagles will
remain on the island, with their numbers diminishing gradually over a
period of 10 years or longer as some of the birds die and are not
replaced by others and as certain bald eagle pairs break their pair
bonds and leave the island after several years of failing to produce
chicks.

**Indirect Effects.** Bald eagles historically played an important role
in the ecology of the Channel Islands by serving as both a top carnivore
and a scavenger. Bald eagles prey primarily on fish taken live from the
ocean; however, they also feed on seabirds and the carcasses of animals
that wash up on shore. Restoration of bald eagles to the Channel Islands
provides broad benefits to the island ecosystems.

The presence of bald eagles in the Northern Channel Islands may provide
benefits to the endangered island foxes on San Miguel, Santa Rosa, and
Santa Cruz Islands. Predation by golden eagles on island foxes has
resulted in precipitous declines in island fox populations on these
islands (Coonan et al. 1998, USFWS 2004). The presence of territorial
bald eagles on the Northern Channel Islands will complement other
efforts in the recovery of the island fox if they deter golden eagles
from inhabiting the islands.

As explained above, suspension of funding for the Santa Catalina Island
Bald Eagle Program until the completion of the NCI Bald Eagle
Feasibility Study is highly unlikely to result in the disappearance of
bald eagles from Santa Catalina Island. Nevertheless, the Trustees have
analyzed the potential indirect effects of a disappearance of bald
eagles from Santa Catalina Island and have concluded that such a
disappearance is not likely to adversely affect the endangered island
fox.

Unlike the Northern Channel Islands, island fox numbers diminished on
Santa Catalina Island as a result of canine distemper rather than
predation by golden eagles. An absence of bald eagles on Santa Catalina
Island is unlikely to result in the future establishment of golden
eagles on the island, as the island likely does not have a sufficient
terrestrial vertebrate prey base to attract and sustain golden eagles.
Also, unlike on the Northern Channel Islands, there is no nearby
mainland source for golden eagles. Given the ongoing efforts to remove
golden eagles and eradicate their non-native prey base from the Northern
Channel Islands, it is unlikely that these islands would serve as a
source of golden eagles to Santa Catalina Island.

The Trustees have informally consulted with the endangered species
office of the U.S. Fish and Wildlife Service (USFWS) on this issue, and
this office has concurred with this analysis. The Letter of Concurrence
is available as part of the MSRP Administrative Record.

The restoration of bald eagles on the Northern Channel Islands is not
expected to result in significant impacts to seabird populations.
Seabirds are not a principal component of bald eagle diets on Santa
Catalina Island, and the same situation is expected to apply on the
Northern Channel Islands. This potential impact was discussed in detail
in the Feasibility Study for Reestablishment of Bald Eagles on the
Northern Channel Islands (MSRP 2002).

**Mitigation Measures.** The methods for hacking and monitoring bald
eagles are well established and designed such that potential impacts to
birds are minimized. Measures such as supplementing prey for the
juvenile eagles once they are released are part of the NCI Bald Eagle
Feasibility Study and will be incorporated into future restoration
efforts.

##### **[Physical Effects]{.underline}**

This action would have no known direct or indirect effects on the
physical environment.

##### **[Human Use Effects]{.underline}**

**Direct and Indirect Effects.** The presence of the bald eagle on the
Channel Islands provides benefits to humans on many levels. The presence
of bald eagles provides both aesthetic and recreational benefits to
visitors. Also, the bald eagles inhabiting the Channel Islands, which
are readily identified by their tags, range freely over great distances
and have been sighted on the U.S. mainland, notably along the Southern
California coast.

The bald eagle also plays an important role in the cultural history of
the Channel Islands. The presence of bald eagles on the island therefore
fills an important cultural as well as an ecological niche.

The suspension of funding for the Santa Catalina Island Bald Eagle
Program may lead to a diminishing number of bald eagles on Santa
Catalina Island during the applicable time period. Fewer bald eagles
could result in a reduction in the human use benefits they provide, as
there may be fewer occasions for viewing the eagles.

**Mitigation Measures.** The Trustees' placement of approximately 12
young birds per year on Santa Cruz Island since 2002 may offset the
potential reduction in opportunities for viewing bald eagles should
their numbers diminish on Santa Catalina Island during the intervening
years before a decision is reached on further bald eagle restoration.

B. Complete the NCI Bald Eagle Feasibility Study; Regardless of its
Outcome, Continue Funding Santa Catalina Island Bald Eagle Program
Alternative 2 \[ \] Alternative 3 \[  \] Neither \[ \]

##### **[Biological Effects]{.underline}**

**Direct Effects.** This course of action will seek to continue
maintaining bald eagles on Santa Catalina Island through human
intervention (e.g., egg manipulation, incubation, and chick fostering)
for as long as funds remain available. Historically, the Channel Islands
were a stronghold for this species. Should it ultimately be found that
bald eagles are unable to reproduce on their own on other Channel
Islands, maintaining a bald eagle presence on Santa Catalina Island will
at least represent a partial or temporary restoration of this important
resource.

Individual bald eagles will continue to experience reproductive injuries
if intervention efforts continue to maintain them on Santa Catalina
Island. These birds are exposed to sufficiently high levels of DDTs and
PCBs that they experience reproductive failure. Also, at least one bald
eagle death on Santa Catalina Island has been attributed to DDT
poisoning. However, the loss of several individuals is not considered
significant in light of the overall recovery of the bald eagle in the
United States and the efforts to restore this species to the Channel
Islands.

**Indirect Effects.** Bald eagles historically played an integral role
in the ecology of the Channel Islands by serving as both a carnivore and
a scavenger. Bald eagles prey primarily on fish taken live from the
ocean; however, they also feed on seabirds and the carcasses of animals
that wash up on shore. Thus, the restoration of bald eagles to the
Channel Islands will provide benefits to the island ecosystem.

The continued presence of bald eagles on Santa Catalina Island is not
expected to result in significant impacts to seabird populations.
Seabirds are not a principal component of the diets of the bald eagles
on Santa Catalina Island.

**Mitigation Measures.** Humans have actively maintained bald eagles on
Santa Catalina Island for over 15 years. Therefore, the methods for
manipulating nests and monitoring bald eagles on Santa Catalina Island
are well established and have been designed such that potential impacts
to birds are minimized. Monitoring would continue to be performed to
examine trends in contamination levels and to guide the ongoing
restoration efforts.

##### **[Physical Effects]{.underline}**

This action would have no known direct or indirect effects on the
physical environment.

##### **[Human Use Effects]{.underline}**

**Direct and Indirect Effects.** The presence of the bald eagle on Santa
Catalina Island provides important benefits to humans on many levels.
Santa Catalina Island is a popular tourist destination, and the presence
of bald eagles provides both aesthetic and recreational benefits to
visitors on the island. Also, the bald eagles inhabiting the Channel
Islands, which are readily identified by their tags, range freely over
great distances and have been sighted on the U.S. mainland, notably
along the Southern California coast.

The bald eagle also plays an important role in the cultural history of
the Channel Islands. The presence of bald eagles on the island therefore
fills an important cultural as well as an ecological niche.

C1. Restore Peregrine Falcons to the Channel Islands Alternative 2 \[ \]
Alternative 3 \[ \] Neither \[  \]

This potential action will require subsequent environmental analysis
when the project details are more fully developed.

##### **[Biological Effects]{.underline}**

**Direct Effects.** The active restoration of peregrine falcons would
speed the recovery of this species into its historically occupied
habitat on both the Channel Islands and the U.S. mainland. Based on the
results of earlier release programs, this effort would likely result in
the establishment of additional peregrine falcon territories on the
Channel Islands (Walton 1997). This program would result in an influx of
birds around the Southern Channel Islands, thus encouraging
recolonization on these islands. Although peregrine falcons are
recolonizing the Southern Channel Islands, as demonstrated by the recent
breeding on Santa Barbara and Santa Catalina Islands, recolonization has
not yet occurred on San Clemente and San Nicolas Islands. In addition,
peregrine falcons that fledge from the Channel Islands frequently
disperse to the mainland (Walton 1999). Therefore, unoccupied
territories on the mainland are also likely to benefit from a release
program.

**Indirect Effects.** Raptors, such as the peregrine falcon, are an
essential part of healthy, functioning ecosystems. The peregrine falcon
is an apex predator that fills a particular ecological niche in the
Channel Islands ecosystem. Although peregrine falcons are once again a
top predator on the majority of the Channel Islands, complete recovery
has not yet been achieved. Additional active restoration would further
encourage recovery on the Channel Islands and help to fully restore a
missing component of the island ecosystem.

The peregrine falcon is a highly specialized feeder, concentrating
almost entirely on birds. The recovery of the peregrine falcon on the
Channel Islands may have a negative impact on bird populations,
particularly for those species that are in decline or have limited
populations. The Channel Islands are critical breeding areas for
seabirds and support important colonies of special status or declining
species, such as the state-threatened Xantus's murrelet, rare ashy
storm-petrel, and federally threatened western snowy plover. Peregrine
falcons are known predators of the Xantus's murrelet and western snowy
plover (Hunt 1994, USFWS 2001). Peregrine falcons have also been
documented preying on petrels (Walton 1997, White et al. 2002);
therefore, ashy storm-petrels could be impacted as well. Because many
seabirds are under constant threat (e.g., from oil spills, human
disturbance, and El Niño events), they may not be able to withstand
peregrine falcon predation (Paine et al. 1990). In particular, depressed
populations of seabirds may not be able to effectively absorb the
additional predation pressure from increased numbers of peregrine
falcons on these islands.

Recolonization of peregrine falcons to the Southern Channel Islands may
also impact the federally endangered San Clemente loggerhead shrike
(*Lanius ludovicianus mearnsi*). This bird subspecies is endemic to the
U.S. Navy--owned San Clemente Island, and the U.S. Fish and Wildlife
Service listed it as endangered in 1977 due to its localized range,
critically low population numbers, consistently low productivity, and
intense predation pressure. Significant effort has been made to decrease
the threat of extinction to the wild population. Although this
population has been increasing recently, the subspecies remains highly
endangered and vulnerable to predation pressure.

Peregrine falcons do not prey on California brown pelicans (Walton
1997); therefore, release of additional birds is not expected to
adversely impact this species.

**Mitigation Measures.** The methods for hacking and monitoring
peregrine falcons are well established and designed such that potential
impacts to the birds are minimized. Seabird populations would continue
to be monitored to determine whether they are being significantly
impacted by increased predation pressure from the restoration of
peregrine falcons to the Channel Islands.

##### **[Physical Effects]{.underline}**

This action would have no known direct or indirect effects to the
physical environment.

##### **[Human Use Effects]{.underline}**

**Direct and Indirect Effects.** The recovery of the peregrine falcon to
the Channel Islands provides both aesthetic and recreational benefits to
visitors to the islands. Peregrine falcons are known for their
spectacular flights, with an average speed of 40--55 kilometers/hour
(25--34 miles/hour) and speeds reaching 112 kilometers/hour (70
miles/hour) (Cade 1982).

C2. Monitor the Recovery of Peregrine Falcons on the Channel Islands
Alternative 2 \[  \] Alternative 3 \[  \] Neither \[ \]

##### **[Biological Effects]{.underline}**

**Direct Effects,** Due to the lack of focused surveys for peregrine
falcons on the Channel Islands, important information regarding this
species is unknown. A monitoring program would provide information on
territory occupancy, nest success, and productivity. These measures are
all indicators of population health and are important in understanding
the long-term recovery of this species on the Channel Islands. The
monitoring data would inform natural resource managers of potential
threats to peregrine falcon recovery, thereby enabling improved
management of this species on the Channel Islands.

A monitoring program would not result in significant impacts to the
biological environment. Peregrine falcon pairs may be temporarily
disturbed during certain monitoring activities (e.g., entering the nest
to collect eggshell fragments or band young); however, the majority of
the observations would be from a distance and would not disturb
peregrine falcons. The monitoring plan would also consider the presence
of seabird nesting colonies and avoid and minimize any impacts to
nesting areas during the monitoring efforts.

**Indirect Effects.** As top predators of their food chain, peregrine
falcons are an excellent indicator species of the overall health of the
ecosystem in which they live. The monitoring of this species would
provide valuable information on the overall levels of contamination in
the environment.

**Mitigation Measures.** Impacts from monitoring activities would be
minimized through established survey techniques for peregrine falcons
and avoidance of biologically sensitive areas, such as seabird colonies.

##### **[Physical Effects]{.underline}**

This action would have no known direct or indirect effects on the
physical environment.

##### **[Human Use Effects]{.underline}**

This action would have no known direct or indirect effects on human
uses.

C3. Restore Peregrine Falcons to the Baja California Pacific Islands
Alternative 2 \[ \] Alternative 3 \[ \] Neither \[  \]

##### **[Biological Effects]{.underline}**

**Direct Effects.** Actions taken to reduce human disturbance would
likely result in recolonization of unoccupied habitat and increased
reproductive success. The recolonization of peregrine falcons into
historically occupied habitat on these islands would provide direct
long-term benefits to this species, as peregrine falcon territories
generally remain occupied indefinitely, with new adults recruiting from
the floating population over time.

The presence of the peregrine falcon may have a negative impact on bird
populations, particularly on those species that are in decline or have
limited populations. The Baja California Pacific islands are critical
breeding areas for seabirds and support important colonies of special
status or declining species, such as the state-threatened Xantus's
murrelet and the rare ashy storm-petrel. Because many seabirds are under
constant threat (e.g., from oil spills, human disturbance, and El Niño
events), they may not be able to withstand peregrine falcon predation
(Paine et al. 1990). In particular, depressed populations of seabirds
may not be able to effectively absorb the additional predation pressure
from increased numbers of peregrine falcons on these islands.

Peregrine falcons do not prey on California brown pelicans; therefore,
an increase in the number of peregrine falcon pairs is not expected to
adversely impact California brown pelicans.

**Indirect Effects.** Raptors, such as the peregrine falcon, are an
essential part of healthy, functioning ecosystems. The peregrine falcon
is an apex predator that fills a particular ecological niche on island
ecosystems. Significant efforts are under way to restore the ecosystems
of the Baja California Pacific islands, such as the removal of
non-native species and habitat restoration. Recovery of this species on
the Baja California Pacific islands would complement ongoing efforts to
restore the island ecosystems of the region.

In addition, peregrine falcons typically disperse 16 to 241 kilometers
(10 to 150 miles) to adjacent unoccupied territories. An increase in the
number of peregrine falcons on the Baja California Pacific islands may
lead to further recovery of peregrine falcons on the Channel Islands due
to their proximity.

**Mitigation Measures.** Impacts from monitoring activities would be
minimized through established survey techniques for peregrine falcons
and avoidance of biologically sensitive areas, such as seabird colonies.

##### **[Physical Effects]{.underline}**

This action would have no known direct or indirect effects on the
physical environment.

##### **[Human Use Effects]{.underline}**

**Direct and Indirect Effects.** The recovery of the peregrine falcon to
the Baja California Pacific islands would provide both aesthetic and
recreational benefits to visitors and residents of the islands.

This project proposes to limit human disturbance in the vicinity of
peregrine falcon nesting areas. This action may impact residents on the
islands during the breeding season for this species. However, this
impact is not anticipated to be significant due to the minimal number of
people that inhabit the islands.

**Mitigation Measures.** No mitigation is currently proposed.

D1. Restore Seabirds to San Miguel Island Alternative 2 \[  \]
Alternative 3 \[ \] Neither \[ \]

This action will require subsequent environmental analysis when the
project details are more fully developed.

##### **[Biological Effects]{.underline}**

**Direct and Indirect Effects.** The eradication of rats on San Miguel
Island has a wide range of potential direct and indirect beneficial and
adverse biological impacts; these impacts are more extensively described
in Appendix D1. The potential benefits of rat eradication on San Miguel
Island include (1) increases in small crevice-nesting seabird
populations (such as alcids and storm-petrels), (2) decreased predation
on ground-nesting seabirds, such as western gulls, (3) protection of the
important seabird colonies on Prince Island and Castle Rock from rat
invasion, (4) a decrease in predation of some terrestrial and marine
intertidal invertebrates, and (5) broad ecological benefits to the San
Miguel Island ecosystem.

However, to eliminate rats from San Miguel Island, a highly efficacious
rodenticide must be used to ensure complete eradication. Because there
are no rat-specific toxicants, the use of a rodenticide to eradicate
rats will pose a primary and secondary risk of poisoning to non-target
species on San Miguel Island. Of particular concern are the potential
impacts to non-target species, such as the endemic deer mouse and the
endangered island fox. Studies will be initiated to evaluate the
potential risk of poisoning to non-target species and to develop
appropriate mitigation measures.

**Mitigation Measures.** The removal of the rats will be timed according
to a set of biological conditions that maximize the probability of
eradicating rats and minimize the potential impact to the San Miguel
Island environment. This project will be designed and implemented in a
manner that avoids, minimizes, and mitigates impacts to the natural
environment on San Miguel Island. Comprehensive measures to avoid and
mitigate any impacts from the project will be developed during the
planning phase and addressed in subsequent environmental analysis.
Particular emphasis will be given to the development of a comprehensive
mitigation strategy for the island fox and deer mouse. The successful
mitigation program used during rat removal on Anacapa Island will be
considered during the development of a mitigation program for San Miguel
Island. Potential mitigation measures are outlined in Appendix D1.

This project will proceed only if the risks to non-target species, in
particular the endangered island fox and endemic deer mouse, can be
minimized to an acceptable level.

##### **[Physical Effects]{.underline}** 

**Direct and Indirect Effects.** Generally, this action will have no
known direct or indirect effects on the physical environment. Unintended
temporary water quality impacts could result should some of the bait
enter the marine environment.

**Mitigation Measures.** Specific measures will be developed and
implemented to prevent bait from entering the marine environment or to
minimize and carefully monitor the amount entering the marine
environment.

##### **[Human Use Effects]{.underline}**

**Direct and Indirect Effects.** Because rats pose health and safety
hazards (e.g., Pratt et al. 1977) and can cause destruction to supplies
and equipment, the eradication of rats will benefit visitors and
National Park Service (NPS) personnel on San Miguel Island. Although no
known rodent-vector diseases have been transmitted to island staff or
residents in the recent past, any rodent population has the potential to
transmit disease to humans. This action will improve health and safety
standards at NPS facilities on the island and will eliminate a potential
source of disease. The removal of black rats from San Miguel Island is
expected to have long-term health, safety, aesthetic, and recreational
benefits and will remove a destructive nuisance to human habitation and
use of the island. However, the removal of rats from the island may
reduce the human use and non-use benefits to any members of the public
who value the presence of this species on the island.

With the possible exception that project workers might experience skin
irritation as a result of contact with bait, no negative impacts are
expected on humans. Although rodenticides are toxic to humans,
significant health effects are not expected unless standard safety
precautions are ignored and very large doses are consumed.

**Mitigation Measures.** To minimize the potential exposure of visitors,
San Miguel Island will be closed for several days when the rodenticides
are applied. Recreational activities such as camping and hiking will not
be permitted during this time. However, due to the distance of San
Miguel Island from the U.S. mainland and the annual visitation rate of
less than 200 campers each year, the closure of the island will not have
a significant impact on recreational and visitor activities.

Project workers will be educated to follow proper safety procedures and
avoid contact with the bait. Monitoring will be used to ensure that the
project workers follow the safety procedures.

D2. Restore Alcids to Santa Barbara Island Alternative 2 \[  \]
Alternative 3 \[  \] Neither \[ \]

##### **[Biological Effects]{.underline}**

**Direct Effects.** Restoring native vegetation and placing nest boxes
in appropriate locations on Santa Barbara Island will provide a
favorable environment for both Cassin's auklets and Xantus's murrelets.
In Northern California, nest boxes have enhanced the population growth
rate of several cavity-nesting alcid species at various sites by
increasing recruitment of breeding-age birds, improving productivity,
and decreasing mortality (Sydeman et al. 2000). The use of playback
systems will further facilitate the recolonization of the Cassin's
auklet on the island. These techniques should increase the number of
breeding pairs of Cassin's auklets and Xantus's murrelets on the island,
thereby increasing the number of offspring produced successfully.

This project is expected to have minimal short-term adverse biological
impacts. Additional human activity will occur on Santa Barbara Island as
a result of this project that could result in temporary displacement of
native wildlife or the trampling of native plants.

**Indirect Effects.** The removal of exotic vegetation may include the
use of herbicides, which could have short-term adverse impacts on
non-target plants. Subsequent monitoring may temporarily disturb target
species.

**Mitigation Measures.** The removal of exotic vegetation and the
planting of native plants will be done during the non-breeding season to
avoid impacts to nesting birds. Any herbicides will be applied in a way
that avoids or minimizes adverse impacts and is in compliance with NPS
policies and other applicable laws and regulations. Potential short-term
adverse environmental impacts that might occur during the removal of
exotic vegetation will be addressed as part of the environmental
compliance for this project.

The use of nest boxes will minimize adverse impacts to nesting alcids
due to any disturbance during monitoring.

##### **[Physical Effects]{.underline}**

There may be minimal short-term adverse impacts due to trampling and
increased soil erosion.

##### **[Human Use Effects]{.underline}**

This action will have no known impacts to human uses. Cultural resources
will be avoided on the island during project implementation. It is
expected that the nest boxes will be largely screened by vegetation and
will not be visible to the public.

D3. Restore Seabirds to San Nicolas Island Alternative 2 \[  \]
Alternative 3 \[ \] Neither \[ \]

This potential action will require subsequent environmental analysis
when the project details are more fully developed.

##### **[Biological Effects]{.underline}**

**Direct Effects.** This action will result in the eradication of feral
cats from San Nicolas Island. Eradication of these introduced cats will
provide long-term conservation benefits for Brandt's cormorants and
western gulls by removing a non-native predator from the island
ecosystem. The Trustees anticipate that this project will result in
increased reproductive success for these species and therefore an
expansion of these colonies. Both of these species are endemic to the
west coast of North America and have limited ranges. The colonies on San
Nicolas Island are located within the center of their range and have
historically supported large numbers of birds. This project will
contribute to the protection of these colonies, though they will still
be subject to predation by the native island fox. However, it is
anticipated that larger, more robust colonies will more effectively
resist ongoing predation pressure from the island fox.

This action could potentially affect the island fox due to its
similarity in size to a feral cat and their similar diets. Although some
short-term impacts might occur to individual foxes, the fox population
will likely benefit overall from the eradication of feral cats, as they
are competitors for food resources and habitat. The eradication
methodologies and potential impacts will be addressed fully in
subsequent environmental documentation for the project.

**Indirect Effects.** In addition to benefiting seabirds, this project
will also have collateral benefits to the island ecosystem. Sensitive
species such as the island fox, the endemic deer mouse, the threatened
island night lizard, and the threatened snowy plover will likely benefit
from reduced predation and competition. The removal of feral cats will
also likely benefit both resident and migratory landbirds on San Nicolas
Island. The U.S. Navy has identified the control/eradication of cats as
a recommended management action to protect the island's biological
resources.

**Mitigation Measures.** Before initiating this action, techniques that
will vary according to the eradication methodologies selected will be
investigated and employed in a manner that avoids and minimizes the
potential for impacts to the non-target island fox.

##### **[Physical Effects]{.underline}**

This action will have no known direct or indirect effects to the
physical environment.

##### **[Human Use Effects]{.underline}**

**Direct Effects.** The removal of non-native species is a critical step
in the restoration of island ecosystems. The eradication of feral cats
will help restore populations of native species on San Nicolas Island.
Such restoration will provide aesthetic and recreational benefits to
U.S. Navy personnel. Because the island has restricted access, this
project will not likely provide aesthetic or recreational benefits to
the general public.

During the eradication program, certain areas may be closed or their use
restricted for safety reasons. Such restrictions may limit recreational
opportunities for U.S. Navy personnel. However, feral cat control was
initiated in the 1980s, and U.S. Navy personnel have accommodated to
this activity. Although the action is designed to be an intensive effort
over approximately 3 years, it will be compatible with the military use
of the island.

**Indirect Effects.** This action will have no known indirect effects.

**Mitigation Measures.** Feral cat eradication efforts will be closely
coordinated with the U.S. Navy, and the project will be developed in a
manner that minimizes impacts on military and recreational activities on
the island.

D4. Restore Seabirds to Scorpion and Orizaba Rocks Alternative 2 \[  \]
Alternative 3 \[  \] Neither \[ \]

##### **[Biological Effects]{.underline}**

**Direct Effects.** Elimination of invasive plants and restoration of
native plants will benefit burrow-nesting species by providing increased
nesting habitat and stabilization of the rapidly eroding soil horizon on
Scorpion Rock. By providing additional high-quality breeding habitat,
this action seeks to increase the number of breeding seabirds on the
rock, in particular Cassin's auklets, Xantus's murrelets, and ashy
storm-petrels. The use of nest boxes will enhance suitable habitat for
seabirds on both Scorpion and Orizaba Rocks, thereby increasing the
number of offspring produced and decreasing mortality.

Seabirds such as the California brown pelican are particularly sensitive
to human disturbance. Reducing human disturbance will have a positive
influence on the survival of brown pelicans by reducing the energy
expenditure associated with flushing and relocating due to human
disturbance. In addition, reducing disturbance will protect nesting
auklets and murrelets from harassment by trespassers.

This project is expected to have minimal short-term adverse effects.
Some temporary disturbance to roosting seabirds may occur during the
revegetation effort. Exotic vegetation will be removed using mechanical
methods, thereby eliminating the need for herbicides. Mechanical removal
may result in minimal short-term adverse impacts to surrounding native
vegetation and soil.

**Indirect Effects.** Subsequent monitoring may result in temporary
disturbance to seabirds.

**Mitigation Measures.** The removal of exotic vegetation and the
planting of native plants will be done during the non-breeding season to
avoid impacts to nesting birds. The National Park Service will consult
with the U.S. Fish and Wildlife Service regarding project implementation
to ensure that California brown pelicans will not be adversely affected.
The use of matting will help minimize potential erosion and stabilize
the soil. The use of nest boxes will greatly minimize impacts to nesting
alcids.

##### **[Physical Effects]{.underline}**

Mechanical removal of invasive plants may result in minimal short-term
adverse impacts to surrounding soil.

##### **[Human Use Effects]{.underline}**

This action will have no known effects on cultural resources,
recreation, aesthetics, or transportation. Cultural resources will be
avoided on the island during project implementation.

D5. Restore Seabirds to Baja California Pacific Islands Alternative 2 \[
 \] Alternative 3 \[  \] Neither \[ \]

Multiple seabird restoration projects are under consideration for the
Baja California Pacific islands. Recent efforts to remove introduced
species on many of these islands have resulted in opportunities to
restore seabird populations. In general, restoration actions will
include using social attraction techniques (including decoys and
vocalizations), improving nesting opportunities with artificial nests,
restoring habitat, reducing human disturbance, shielding lights, and
eradicating non-native species. The effects of individual projects are
described in Appendix D5 and are summarized collectively below.

##### **[Biological Effects]{.underline}**

**Direct Effects.** The restoration activities proposed for the Baja
California Pacific islands will result in direct benefits to a suite of
seabirds, including the Cassin's auklet, Brandt's cormorant,
double-crested cormorant, California brown pelican, ashy storm-petrel,
and Xantus's murrelet.

Social attraction efforts will facilitate the recolonization of seabirds
on these islands after the removal of introduced species. These types of
efforts will encourage seabirds to use suitable and historically
occupied habitats. Once attracted to the island, seabirds will be
further encouraged to nest in suitable habitat by the presence of nest
boxes. The use of nest boxes will also allow biologists to monitor the
success of the restoration efforts and minimize disturbance to nesting
seabirds. Although social attraction may only be used for a limited
time, the recolonization and recovery of historically occupied colonies
will provide long-term benefits to seabird populations in the Southern
California Bight, as the re-established presence of a colony of birds
will likely serve as an ongoing natural attractant in perpetuity.

A reduction in human disturbance around the colonies will significantly
benefit roosting and breeding seabirds. Nesting seabirds that are
sensitive to disturbance, such as California brown pelicans and
cormorants, will in particular benefit from a reduction in human
disturbance. At least six species of marine birds had experienced severe
population declines due to human disturbance, and subsequent protection
has resulted in almost complete recovery of all of these populations
(Anderson and Keith 1980).

The proposed activities have the potential to result in limited
short-term impacts, including soil disturbance in the areas where nest
boxes are used or short-term disturbance to seabirds during monitoring
efforts. However, the proposed activities will not result in significant
impacts to biological resources.

**Indirect Effects.** The increase in seabird populations that could
result from this action will also likely benefit resident peregrine
falcon pairs that prey on seabirds such as petrels and auklets. Because
peregrine falcon pairs prey on a number of seabirds (Kiff 1980),
increases in seabird populations may help buffer the impacts of
increased predation by peregrine falcons.

**Mitigation Measures.** The removal of exotic vegetation and the
planting of native plants will be done during the non-breeding season to
avoid impacts to nesting birds. The use of matting will help minimize
potential erosion and stabilize the soil. The use of nest boxes will
minimize the impacts of monitoring activities on breeding seabirds.

##### **[Physical Effects]{.underline}**

This action will have no direct or indirect effects on the physical
environment.

##### **[Human Use Effects]{.underline}**

**Direct and Indirect Effects.** The waters around the Baja California
Pacific islands offer many recreational and economic opportunities.
Healthy and complete ecosystems support fishing communities around these
islands (Anderson and Keith 1980). Seabird colonies are a valuable part
of island ecosystems and provide economic benefits in the form of
tourism.

This action proposes to limit human disturbance in the vicinity of
seabird colonies. This action will likely impact people that either
inhabit or illegally camp on the islands. However, this impact is not
anticipated to be significant due to the small number of people that
inhabit the islands.

**Mitigation Measures.** When this action involves limiting human
activity around seabird colonies, alternate routes will be provided to
accommodate human activities on the islands.

D6. Create/Enhance/Protect California Brown Pelican Roost Habitat
Alternative 2 \[ \] Alternative 3 \[ \] Neither \[  \]

This action will require subsequent environmental analysis when the
project details are more fully developed.

##### **[Biological Effects]{.underline}**

**Direct Effects.** Improvements in the existing network of communal
roosts along the coast would have a positive influence on the energy
budgets of pelicans by reducing the energy costs associated with (1)
commuting between prey locations and roosts, (2) flushing and relocating
due to human disturbance, and (3) using suboptimal microclimates within
roosts. The costs of migration would also be reduced by the increased
availability, quality, and capacity of stopover sites. Cumulative energy
reductions should result in improved body condition for individual
birds. The expected population-level effects from improving the
condition of individual birds are increased juvenile and adult survival
and increased reproductive success for pelicans in California.

The environmental consequences of increased use of lagoons and other
roosting areas by pelicans may include impacts on water quality if guano
accumulation exceeds the circulation ability of the lagoon. However, in
some locations brown pelican guano in the vicinity of roosts could
provide a desirable source of nutrient enrichment and might enhance
local food webs.

The negative aspects of pelican use of harbors for roosting include the
increased risk of contact with environmental contaminants (such as oil),
the increased likelihood of injury due to scavenging (e.g., entanglement
in fishing line or puncture from fishing hooks), and the development of
nuisance issues. However, the project is not expected to result in major
increases in pelican use of harbors. Rather, the goal would be to
improve the quality of resting time within harbors.

**Indirect Effects.** Other bird species that occur in association with
roosting pelicans are likely to benefit from the proposed roost
projects. Bird groups that would benefit from increased availability of
island habitat and reduced human disturbance in coastal environments
would include gulls, terns, cormorants, shorebirds, herons, egrets, and
ducks. The suite of species receiving benefits would vary with the type
of roost treatment and project site. The restoration projects would
inform and enrich the public through associated interpretation displays
and would help foster an awareness and stewardship ethic that should
result in reduced disturbance to roosting California brown pelicans and
other coastal waterbirds at other locations.

**Mitigation Measures.** Specific mitigation measures would be developed
and incorporated into project design as specific sites are selected and
potential impacts are identified.

##### **[Physical Effects]{.underline}**

Given the relatively small scale of physical construction envisioned
under this conceptual action, and given that pelican roost site
enhancements would be constructed on existing physical features or
structures, no direct or indirect physical effects are anticipated.
Further environmental analysis would be required should this action be
selected for implementation.

##### **[Human Use Effects]{.underline}**

**Direct Effects.** Public enjoyment of pelicans would be increased by
projects that allow the public to view communal roosting groups without
causing disturbance.

Pelican roost site creation projects, if not carefully designed, could
lead to interference with human activities or potential liability
situations. Some projects would likely require ongoing inspection and/or
management oversight. This issue would be addressed in subsequent
planning and environmental documentation.

**Indirect Effects.** Vegetation on any earthen islands that are created
may need to be periodically controlled or removed.

**Mitigation Measures.** Pelican restoration projects would be designed
to minimize impacts to recreational activities such as fishing, boating,
and kayaking. Because pelicans are very susceptible to human
disturbance, projects would be sited in areas that are compatible with
human uses. Potential impacts to navigation would be evaluated for each
site-specific project. Careful site selection, project design, selection
of raw materials, and adequately funded maintenance programs would
offset potential liability concerns.

D7. Implement an Entanglement Reduction and Outreach Program to Protect
Seabird Populations Alternative 2 \[ \] Alternative 3 \[ \] Neither \[ 
\]

##### **[Biological Effects]{.underline}**

**Direct Effects.** The use of signs and brochures would help promote
public awareness of entanglement issues and thus reduce bird injuries
and deaths. Seabirds that would benefit from this project include
California brown pelicans, cormorants, and gulls. A successful outreach
program would aid in the ongoing recovery of the endangered California
brown pelican by reducing a source of injury and death to the species.

**Indirect Effects.** This program would provide information on the
proper disposal of fishing line. A reduction in fishing line debris
would provide benefits to other marine organisms currently impacted by
waste fishing line.

**Mitigation Measures.** This action is not anticipated to have any
adverse effects.

##### **[Physical Effects]{.underline}**

A reduction in fishing line debris would improve the general quality of
the marine environment.

##### **[Human Use Effects]{.underline}**

**Direct Effects.** The proper handling and disposal of fishing line
would result in improved health and safety, as discarded hooks can
injure humans as well as wildlife. Humans are also at risk of injury
when attempting to disentangle a hook or line from a seabird. A
reduction in seabird/angler interactions would result in improved
recreation because hooking a seabird is a frustrating and unwelcome
experience. The proper disposal of fishing line would also enhance the
aesthetics of the fishing structure and its vicinity.

This action focuses on education rather than restrictions on fishing, so
no negative impacts on human uses would result.

**Indirect Effects.** The design, size, and placement of program signs
could have minor impacts to aesthetics.

**Mitigation Measures.** The design of program signs would likely be
adopted from the design developed and employed by a recent restoration
effort performed by the American Trader Trustee Council. The signs would
be placed in consultation with appropriate local authorities in such a
way as to minimize any impacts to the aesthetics of the surrounding
area.

D8. Restore Ashy Storm-Petrels to Anacapa Island Alternative 2 \[  \]
Alternative 3 \[  \] Neither \[ \]

##### **[Biological Effects]{.underline}**

**Direct Effects.** The Channel Islands are critical nesting habitat for
the ashy storm-petrel. With the recent removal of rats from Anacapa
Island, high-quality breeding habitat is again available to
crevice-nesting seabirds such as the ashy storm-petrel. The combination
of social attraction and nest boxes will provide a favorable environment
for the establishment of an ashy storm-petrel colony. Although social
attraction may only be used for a short amount of time, the colonization
of Anacapa Island will provide long-term benefits to the ashy
storm-petrel in the Southern California Bight, as the established
presence of a colony of birds will likely serve as an ongoing natural
attractant over the long term.

This project seeks to aid in the recovery of this rare and declining
species. Given the limited range and overall small population size of
the ashy storm-petrel, the establishment of additional secure breeding
sites will be a significant benefit. Additional breeding sites buffer
the potential catastrophic effects of oil spills and the negative
impacts of non-native species on this species.

This action will have minimal short-term adverse biological impacts. The
playback of tape-recorded vocalizations causes little disturbance or
trauma to birds if the duration of the playback is kept within
reasonable bounds.

**Indirect Effects.** Human activity in the vicinity of the target
locations may disturb other species of seabirds that may be nesting
nearby.

**Mitigation Measures.** Researcher activity in the vicinity of nesting
areas will be minimized to avoid destruction of the local habitat and
disturbance (Johnson et al. 1981, Baptista and Gaunt 1997).
Storm-petrels are sensitive to disturbance, including that generated by
researchers, especially during the incubation period (Ainley et al.
1974). The project will be implemented in a manner that avoids impacts
to nesting seabirds on Anacapa Island.

##### **[Physical Effects]{.underline}**

This action will have no known direct or indirect effects on the
physical environment.

##### **[Human Use Effects]{.underline}**

A slight increase in human uses on Anacapa Island will occur during the
implementation of the action, and this use may impact visitors'
experience on the island. However, this use is expected to have minimal
short-term adverse impacts.

## Cumulative Impacts

Cumulative impacts are impacts that result from an action and other
past, present, and reasonably foreseeable near-term future actions taken
together. Significant cumulative impacts can result from a combination
of actions that do not have significant impacts individually. Taken
collectively, the effects of several actions may be additive,
countervailing, or synergistic. Impacts are considered regardless of the
agencies or parties involved. Thus, in considering cumulative impacts,
this analysis is not limited to the actions of the MSRP but also
considers current operations, resource management programs, land use
plans, and development projects in the region of interest.

Overall, the Montrose Settlements Restoration Program actions will
result in a long-term net improvement in fish and wildlife habitat, the
restoration of ecological balance in areas where contamination and other
human-caused disturbances have led to adverse impacts on sensitive
native species, and improvement in the human use and non-use services
provided by fish and wildlife in the region. Cumulative impact analysis
is nonetheless required to evaluate whether specific components of the
MSRP actions, when considered in combination with other past, present,
and future actions in the affected area, will have potentially
significant adverse effects.

The cumulative effects analysis in this Restoration Plan and
programmatic EIS/EIR focuses on the same environmental issues as those
in the direct/indirect effects analyses in Section 7.2:

-   Biological resources (fish, birds, and other wildlife)

-   Physical resources (earth resources, including sediments, water
    resources, and oceanographic and coastal processes)

-   Human uses (recreational, socioeconomic, and aesthetics)

    The MSRP study area (see Figure 3.0-1) is located within the
    Southern California Bight (SCB), extending from Point Dume to Dana
    Point along the Southern California mainland coast. The study area
    includes the California Channel Islands and those Baja California
    Pacific Islands that lie within the SCB. Other actions considered as
    part of the cumulative impacts analysis for this programmatic
    EIS/EIR were identified by researching the activities within this
    study area that are affecting or will affect the same or similar
    resources. These other actions were identified through consultations
    within each of the six agencies that constitute the Trustees,
    consultations with the planning departments of local governments and
    authorities and other state and federal agencies, and searches of
    the database of the State of California Office of Planning and
    Research.

    Several of the actions in this programmatic EIS/EIR are still only
    conceptual and will require subsequent environmental analysis. Some
    actions do not have specific project locations identified yet. The
    assessment of cumulative impacts herein focuses on those MSRP
    actions, locations, and resources for which sufficient detail is
    currently available. To the extent it is included, the cumulative
    effects analysis for the actions that are still conceptual is not as
    detailed. More specific analysis of these actions will be performed
    in subsequent environmental analyses. When there is uncertainty
    about cumulative impacts, the Council on Environmental Quality
    recommends that the uncertainty be addressed through subsequent
    project monitoring and adaptive management (Council on Environmental
    Quality 1997).

    The study area encompasses a large geographic region in which many
    types of other actions affect the environment. In keeping with
    Council on Environmental Quality recommendations, the Trustees have
    narrowed the focus of the cumulative effects analysis to those
    actions that have relevance to the effects of the MSRP actions and
    to important issues of national, regional, or local interest
    (Council on Environmental Quality 1997).

    The following discussion identifies the plans or categories of
    actions that may affect the same or similar resources as the MSRP
    actions. The MSRP actions and the affected resources that are
    relevant to each of these other actions are also listed. These other
    actions are considered in the cumulative impacts analysis that
    follows.

-   **Channel Islands National Park 2001--2005 Strategic Plan:** This
    plan addresses the management of natural resources and research and
    the recreational uses of these resources for the Channel Islands
    National Park. The plan also develops long-term policy
    recommendations to enhance the management of the areas in the
    Channel Islands under the park's jurisdiction. Cumulative additive
    beneficial effects are expected from the combination of NPS
    management activities and MSRP actions.

    MSRP actions affecting the same or similar resources: the bald
    eagle, peregrine falcon, and seabird restoration actions on the
    Channel Islands will occur within the park's boundaries.

-   **Channel Islands National Marine Sanctuary 1983 Management Plan:**
    This plan addresses the management of marine resources under the
    sanctuary's jurisdiction. The management plan has been under review
    since 1999, and a revision is currently being prepared; it is
    anticipated that the draft revised management plan will be released
    for public review and comment during 2005. Expansion of the
    boundaries of the Channel Islands National Marine Sanctuary is under
    consideration as part of the draft revised plan. Cumulative additive
    beneficial effects are expected from the combination of Channel
    Islands National Marine Sanctuary management activities and MSRP
    actions.

    MSRP actions affecting the same or similar resources: "augment funds
    for implementing Marine Protected Areas in California," and bald
    eagle, peregrine falcon, and seabird restoration projects on the
    Channel Islands within the boundaries of the Channel Islands
    National Marine Sanctuary.

-   **Southern California Wetlands Recovery Project 2001 Regional
    Strategy and Implementation Plan:** This plan articulates long-term
    goals and specific implementation strategies to guide the efforts of
    the multi-party project and its partners to accelerate the
    restoration of coastal wetlands. Cumulative additive beneficial
    effects are expected from the combination of Southern California
    Wetlands Recovery Project activities and MSRP efforts to restore
    coastal wetlands.

    MSRP action affecting the same or similar resources: "restore full
    tidal exchange wetlands."

-   **Other Seabird Restoration Projects:** In addition to the seabird
    restoration actions proposed by the MSRP, several other recently
    completed, ongoing, and proposed projects target the same seabird
    species and their habitats. These projects stem from natural
    resource damage (NRD) settlements from other cases and from the
    independent efforts of various environmental organizations that
    focus on seabird restoration. Other recently settled NRD cases that
    have resulted in seabird restoration actions in the region include
    the American Trader, Command, and Cape Mohican cases. Other NRD case
    settlements are likely to occur in the future, leading to additional
    seabird restoration projects. The seabird restoration projects
    conducted or planned for target species and/or within the study area
    include the Anacapa Island Restoration Project, the Brown Pelican
    Roost Enhancement Project in the San Diego Bay Salt Ponds, the Brown
    Pelican Entanglement Outreach and Education Program for Southern
    California, the Common Murre Restoration Project, the Western and
    Clark\'s Grebe Restoration Project, and the Seabird Colony
    Protection Program. These and other projects are further described
    in the restoration plans associated with these NRD cases. Cumulative
    additive beneficial effects are expected from the combination of
    these projects and the MSRP seabird restoration actions. The other
    seabird restoration projects, when considered together with the MSRP
    bald eagle and peregrine falcon restoration actions, will have minor
    additive beneficial effects on bald eagles (which prey to a limited
    extent on seabirds) and will have somewhat greater additive
    beneficial effects on peregrine falcons (which prey on seabirds to a
    greater extent than bald eagles).

    MSRP actions affecting the same or similar resources: bald eagle,
    peregrine falcon, and seabird restoration actions.

-   **Ports of Los Angeles and Long Beach:** The Ports of Los Angeles
    and Long Beach are the largest ports on the west coast of the United
    States. Numerous construction and environmental mitigation projects
    are at various stages of planning, design, and implementation. Some
    of these projects include marine harbor and pier terminal
    redevelopments projects, construction of the Rainbow Harbor master
    plan, reconfiguration of wharves and expansion of backlands, channel
    deepening projects, construction of a crude oil receiving facility
    at Port of Los Angeles Pier 400, expansion of Cabrillo Marine
    Aquarium, and construction of a fishing reef off of Point Fermin,
    near the San Pedro breakwater. The potential for cumulative impacts
    from MSRP actions and port projects cannot be adequately assessed
    until further details are developed on the MSRP fishing and fish
    habitat actions. The Trustees will consider the potential for
    cumulative impacts as the planning and design of these actions
    progress.

    MSRP actions affecting the same or similar resources: "construct
    artificial reefs and fishing access improvements."

-   **Cooling Water Intake Entrainment and Impingement -- New
    Requirements:** Coastal electric power generation stations and other
    large industrial facilities draw in millions of gallons per day from
    nearshore waters for cooling purposes. Marine life can be either
    entrained or impinged on the intake structures. Entrained organisms
    are those that are not strong enough to swim against the current of
    the intake system. Impinged organisms are those that are collected
    on traveling screens designed to remove large debris from the intake
    water. Cooling water intakes kill billions of fish larvae and
    hundreds of thousands of juveniles and adults each year (USEPA
    2004a). In addition to fish losses, larval forms of invertebrates
    and adult zooplankton are lost to the ecosystem. Fourteen coastal
    power plants in Southern California use large quantities of cooling
    water. In July 2004, the EPA issued new regulations under Section
    316(b) of the federal Clean Water Act that set requirements for
    large power plants (those utilizing over 50 million gallons of water
    per day) to reduce the impacts of cooling water intake on marine
    organisms. MSRP restoration actions will have beneficial
    counteracting effects to the ongoing adverse effects from the
    operation of major cooling water intake structures in the Southern
    California Bight. MSRP restoration actions will have beneficial
    additive effects to the beneficial effects from the reductions in
    entrainment and impingement that are expected as a result of the
    implementation of the new EPA regulatory requirements for cooling
    water intakes.

    MSRP actions that affect the same or similar resources: fishing and
    fish habitat actions.

-   **Desalination Facilities:** Currently, several seawater
    desalination facilities exist in the study area and about a dozen
    facilities are being considered. The existing coastal desalination
    facilities are relatively small, but the total output of all of the
    proposed coastal facilities, including some that would be among the
    largest in the country, could be far greater. Coastal desalination
    facilities may have adverse impacts on marine organisms due to the
    effects of the seawater intake and discharge on nearby marine life.
    The largest proposed desalination facilities would be located at
    coastal power plants that use ocean water for cooling, and these
    facilities would propose to use hundreds of millions of gallons of
    seawater per day. The existing desalination facilities in Southern
    California are located on Santa Catalina Island, San Nicolas Island,
    and various offshore oil and gas platforms. These facilities have a
    combined maximum capacity of about 200 acre-feet per year. New
    facilities in various stages of planning, design, and approval for
    construction include facilities in Long Beach, Los Angeles,
    Huntington Beach, San Onofre, Carlsbad, and San Diego. The potential
    combined maximum capacity of these new facilities is over 200,000
    acre-feet per year.

    MSRP actions that affect the same or similar resources: fishing and
    fish habitat restoration actions.

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-   **California Marine Life Protection Act (MLPA) Initiative:** The
    1999 MLPA directed the state to design and manage a network of
    marine protected areas to, among other things, protect marine life
    and habitats, marine ecosystems, and marine natural heritage, as
    well as improve the recreational, educational, and study
    opportunities provided by marine ecosystems. The California
    Resources Agency and the California Department of Fish and Game are
    partnering with the Resources Legacy Fund Foundation, NOAA, and the
    MPA Science Institute of the National Marine Protected Areas Center
    in a new initiative to achieve the MLPA goals. This public-private
    partnership is being guided by the advice of scientists, resource
    managers, experts, stakeholders, and members of the public. The MLPA
    Initiative, which is governed by a blue-ribbon task force, will
    oversee the preparation of a statewide guide for developing a Marine
    Protected Area master plan, create a pilot project in an area along
    the central coast to identify potential networks of Marine Protected
    Areas, develop a strategy for long-term funding, and make
    recommendations for improved coordination of Marine Protected Areas
    with key federal agencies.

    MSRP actions that affect the same or similar resources: "augment
    funding for MPAs in California."

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-   **Liquefied Natural Gas Deepwater Port Import Terminals and
    Associated Facilities and Operations:** Several proposals have been
    made to construct and operate liquefied natural gas (LNG) import,
    storage, and transport facilities within the study area of this
    plan. Specific projects include three along the Southern California
    coast (a Port of Long Beach LNG terminal and the Cabrillo Port and
    Crystal Clearwater Port projects, which are proposed for 11 to 12
    miles offshore of Ventura County) and three along the Pacific coast
    of Baja California (Energia Costa Azul, which is 14 miles north of
    Ensenada, GNL Mar Adentro \[Chevron\], which is near South Coronado
    Island, and the Moss Maritime facility, which is 5 miles offshore of
    Rosarito). Sempra Energy has commenced construction of the Energia
    Costa Azul facility, which is expected to be operational by 2008;
    the other facilities are in various stages of planning, design, and
    environmental review and legal dispute. These projects have several
    common components, including LNG carrier berths, storage facilities,
    regasification units, and pipelines. The Cabrillo Port and Crystal
    Clearwater Port projects are approximately 20 miles away from the
    nearest Channel Island, Anacapa, and for this analysis it is assumed
    that they are far enough away that normal operations would not be
    expected to seriously disrupt seabird colonies in the Channel
    Islands. In contrast, the potential GNL Mar Adentro facility, which
    is proposed for a location near South Coronado Island, would be
    located approximately 1 mile from that island, and thus disruption
    to seabirds would be expected to occur if this facility were built.

    MSRP actions that affect the same or similar resources: seabird
    restoration projects near South Coronado Island.

-   **SOCAL Range Complex and Point Mugu Sea Range Operations:** The
    U.S. Navy owns two of the Channel Islands, San Nicolas and San
    Clemente, and conducts military training and testing operations on
    them. The SOCAL Range Complex includes the following military
    training ranges: San Clemente Island, the Southern California
    Anti-Submarine Warfare Range, a live-fire exercise range, an
    aircraft emergency jettison area, the shallow water training range,
    and the shore bombardment range. Missile and aircraft overflights
    associated with ongoing operations on San Nicolas Island occur about
    eight times per year along the shore of the island. The Navy is also
    working with other partners to restore the endemic and federally
    endangered San Clemente loggerhead shrike. Restoration of peregrine
    falcons to the Southern Channel Islands could have counteractive
    effects on efforts to increase the numbers of San Clemente
    loggerhead shrikes, as the peregrine falcons might prey on the
    shrikes.

    MSRP actions that affect the same or similar resources: "restore
    seabirds to San Nicolas Island" and peregrine falcon restoration.

### Alternative 1 (No Action)

### Alternatives 2 and 3

As described in Section 7.2.1, under the No Action Alternative no
cumulative impacts would occur. The beneficial effects of natural
resource restoration actions would not be realized. The purpose and need
for the Montrose Settlements Restoration Program (i.e., utilizing the
funds from the Montrose settlements to restore injured resources and
lost services) would not be met. Without active restoration projects,
there would be no biological, physical, or human use beneficial or
adverse impacts. However, natural resource injuries and lost services
resulting from the DDTs and PCBs of the Montrose case would persist in
the Southern California Bight for the foreseeable future. Also, no
compensation for interim lost natural resource services from the date of
the enactment of CERCLA until the time that the injuries cease would be
realized.

This section presents an assessment of cumulative effects for the two
action alternatives, Alternatives 2 and 3. Each of these two
alternatives consists of a different combination of the 17 restoration
actions described in Section 6 and evaluated in detail in Appendices
A--D. Several of these individual actions are common to both
alternatives, some are only in one alternative, and some are not
included in either. The cumulative impacts of each of the 17 actions are
presented here one by one (in the same order as the actions are listed
in Appendices A--D); the headings indicate which of the alternatives
each action is a part of.

A1. Construct Artificial Reefs and Fishing Access Improvements
Alternative 2 \[  \] Alternative 3 \[  \] Neither \[ \]

This action will require subsequent environmental analysis when the
project details are more fully developed.

##### **[Cumulative Biological Effects]{.underline}**

The soft-bottom marine habitats covered by artificial reefs under this
action are the spatially predominant benthic habitat type in the coastal
regions of the Southern California Bight. For example, in a U.S.
Geological Survey (USGS) study of the seafloor of Short Bank in central
Santa Monica Bay (Dartnell and Gardner 2004), less than 11 percent of
the seafloor was classified as rock. Thus, on a regional scale the
percentage of soft-bottom marine benthic habitat that may be covered by
reefs constructed by the MSRP, even when considered along with other
jurisdictions that have constructed or may construct artificial reefs
(e.g., Port of Los Angeles or the San Onofre Nuclear Generating Station)
would be insignificant.

The construction of new artificial reefs may increase fish production,
though the amount of increase would depend on their design and location
(see Appendix A1). When considered in association with the adverse
effects on marine life from current and proposed desalination and
cooling water intake structures in the study area, the construction of
artificial reefs may have countervailing (i.e., beneficial or
mitigating) biological effects. Cumulative beneficial biological effects
may also be realized by the combination of MSRP artificial reef
construction with other similar fisheries enhancement actions in the
study area (construction of the Point Fermin and other artificial reefs,
reduction of entrainment and impingement brought about by the
implementation of new EPA regulations on cooling water intakes, and
increased productivity from the establishment of Marine Protected
Areas).

##### **[Cumulative Physical Effects]{.underline}**

At the regional level, when considering the cumulative size of the
proposed MSRP and other artificial reef projects reasonably foreseeable
for the Southern California Bight, the potential cumulative impacts of
artificial reef construction on sediments, water resources, and
oceanographic and coastal processes are not considered to be
significant. Potential concerns over short-term water quality impacts
from reef material placement and concerns about potential effects on
sediment transport or other processes will be addressed in subsequent
site-specific analysis as potential reef sites are identified.
Individual reef construction projects will be spatially and temporally
spread apart; thus, the physical impacts from MSRP reef construction are
not expected to have additive cumulative impacts. The potential for
additive impacts due to non-MSRP construction activities will be
addressed in subsequent site-specific environmental analysis.

##### **[Cumulative Human Use Effects]{.underline}**

Considered cumulatively, the effects of MSRP- and other-constructed
reefs on recreation would be largely beneficial. The restoration of lost
fishing services, one of the objectives of the MSRP, would entail
actions to improve the ability of recreational and subsistence anglers
to fish for fish that are not the subject of state consumption
advisories. Unless care is taken during planning to consider the
potential cumulative impacts associated with the locations and
construction of multiple new reefs, these reefs have the potential to
adversely affect other aquatic human uses such as surfing and boating.
The locations and designs of reefs will be determined so as to avoid or
minimize potential conflicts with other human uses and to consider the
cumulative impacts associated with the combination of MSRP-sponsored
work and other actions.

A2. Provide Public Information to Restore Lost Fishing Services
Alternative 2 \[  \] Alternative 3 \[  \] Neither \[ \]

##### **[Cumulative Biological and Physical Effects]{.underline}**

This action would have no known direct or indirect effects on the
biological or physical environment.

##### **[Cumulative Effects on Human Uses]{.underline}**

The public information on fishing and fish contamination that is made
available by the MSRP and others may potentially redistribute or
increase or decrease the number of fishing trips that occur at different
fishing sites along the Southern California coast. These effects will
improve recreational enjoyment by making better information available on
where and how to fish for cleaner fish. Several other regional and
national public campaigns are aimed at educating the public and changing
public fishing and fish consumption practices. for example, the EPA has
created the local Fish Contamination Education Collaborative, and the
EPA and the Food and Drug Administration have implemented national
campaigns on reducing exposures to mercury in certain fish species. In
combination, these public information actions have beneficial additive
cumulative effects on human uses.

A3. Restore Full Tidal Exchange Wetlands Alternative 2 \[  \]
Alternative 3 \[ \] Neither \[ \]

This action will require subsequent environmental analysis when the
project details are more fully developed.

##### **[Cumulative Biological, Physical, and Human Use Effects]{.underline}**

Coastal wetland habitat is scarce along the Southern California coast,
and the large-scale projects that create or improve existing habitat of
this type that the MSRP may contribute funding to are the subject of a
major regional planning effort (Southern California Wetlands Recovery
Project 2004). Although restorers of coastal wetlands in Southern
California seek outcomes having highly beneficial cumulative effects on
the environment, such projects involve numerous biological, physical,
and human use trade-offs. The cumulative effects of coastal wetlands
restoration in Southern California has been analyzed recently in several
relevant environmental impact reports and statements (e.g., the 2001
Final EIS/EIR for the Bolsa Chica lowlands restoration project \[USFWS
2001a\]). Until more specific decisions are made, this MSRP action,
which contributes toward wetlands restoration, is not yet specific
enough for cumulative impacts analysis; these effects will be addressed
in subsequent NEPA/CEQA analysis for the specific wetlands restoration
project(s) to which the MSRP contributes a portion of funding.
Alternatively, should the Trustees contribute toward a wetlands project
for which NEPA/CEQA documentation has already been completed, the
Trustees will evaluate and adopt that existing documentation.

A4. Augment Funds for Implementing Marine Protected Areas in California
Alternative 2 \[  \] Alternative 3 \[ \] Neither \[ \]

##### **[Cumulative Effects on the Biological Environment]{.underline}** 

To the extent that MSRP funding improves the implementation of the
Channel Islands MPAs, it may increase the biological productivity within
the MPA boundaries. This increase may have beneficial (countervailing)
cumulative effects on marine life in the study area when considered in
combination with the potentially adverse impacts to marine life if new
desalination plants are constructed in the region. This action may also
have beneficial additive cumulative effects when considered in
combination with the reductions in entrainment and impingement from
coastal cooling water intakes as new EPA regulations are implemented.

##### **[Cumulative Effects on the Physical Environment]{.underline}**

This action would have no known direct or indirect effects on the
physical environment.

##### **[Cumulative Effects on Human Uses]{.underline}**

Given the long-term goals of the California Marine Life Protection Act
(see Appendix A4), it is possible that the MSRP enhancement to
implementation and monitoring of the Channel Island MPAs may contribute
information to the efforts at implementing the California Marine Life
Protection Act, and this information will factor into subsequent
decisions on whether to create additional MPAs elsewhere along the
California coast. The information from this action may potentially lead
to both beneficial and adverse effects on fishing and other types of
human uses of the ocean environment in and around the MPAs; however,
insufficient information is available at this point to consider how such
future actions will play out.

B. Complete the NCI Bald Eagle Feasibility Study Before Deciding on
Further Restoration Actions Alternative 2 \[  \] Alternative 3 \[ \]
Neither \[ \]

This is an interim action that will require subsequent environmental
analysis.

##### **[Cumulative Biological Effects]{.underline}**

This is an interim action in that it defers longer range decisions on
bald eagle restoration until the NCI Bald Eagle Feasibility Study is
concluded. Other actions affecting the same or similar resources are the
Channel Islands National Park and Channel Islands National Marine
Sanctuary management plans and the Catalina Island Conservancy annual
operational plan. Because some, if not most, of the bald eagles
currently on Santa Catalina Island are expected to remain during the
interim period even if the suspension of MSRP funding leads to a
discontinuation of that program, no cumulative adverse biological
effects are expected from this bald eagle action. There is a potential
that the separate past, present, and future bald eagle restoration
actions on Santa Catalina Island, Santa Cruz Island, and on the
California mainland will have additive or synergistic beneficial effects
on bald eagles throughout the region. Further analysis of the potential
cumulative effects will be a part of subsequent decision-making on bald
eagle restoration in or around 2008.

Bald eagle restoration actions alone are not expected to result in
significant impacts to seabirds, as seabirds are not a principal
component of bald eagle diets in the Channel Islands. This potential
impact was discussed in detail in the Feasibility Study for
Reestablishment of Bald Eagles on the Northern Channel Islands (MSRP
2002). When bald eagle actions are considered cumulatively with the
restoration of peregrine falcons, which prey almost exclusively on other
birds, there is a greater potential for impacts on sensitive seabird and
terrestrial bird species in the Channel Islands. Further discussion of
this point is presented in the following section on peregrine falcon
restoration.

##### **[Cumulative Physical Effects]{.underline}**

This action would have no known direct or indirect effects on the
physical environment.

##### **[Cumulative Effects on Human Uses]{.underline}**

Cumulative effects on human uses are not expected from this action given
the interim nature of this action and the likelihood that bald eagles
will remain on Santa Catalina Island and continue to be sighted by
residents and visitors.

B. Complete the NCI Bald Eagle Feasibility Study; Regardless of its
Outcome, Continue Funding Santa Catalina Island Bald Eagle Program
Alternative 2 \[ \] Alternative 3 \[  \] Neither \[ \]

##### **[Cumulative Effects on the Biological Environment]{.underline}**

This action, along with implementation of other Channel Island
management plans identified above, is expected to have additive
beneficial effects on bald eagles and further the collective aims of
these plans to restore the natural ecological attributes of these island
environments. Bald eagle restoration actions alone are not expected to
result in significant impacts to seabirds, as seabirds are not a
principal component of bald eagle diets in the Channel Islands. This
potential impact was discussed in detail in the Feasibility Study for
the Reestablishment of Bald Eagles on the Northern Channel Islands (MSRP
2002). When bald eagle actions are considered cumulatively with the
restoration of peregrine falcons, which prey almost exclusively on other
birds, there is a greater potential for impacts on sensitive seabird and
terrestrial bird species in the Channel Islands. Further discussion of
this point is presented in the following section on peregrine falcon
restoration.

##### **[Cumulative Effects on the Physical Environment]{.underline}**

This action would have no known cumulative effects on the physical
environment.

##### **[Cumulative Effects on Human Uses]{.underline}**

This action would have no known cumulative effects on human uses.

C1. Restore Peregrine Falcons to the Channel Islands Alternative 2 \[ \]
Alternative 3 \[ \] Neither \[  \]

C2. Monitor the Recovery of Peregrine Falcons on the Channel Islands
Alternative 2 \[  \] Alternative 3 \[  \] Neither \[ \]

C3. Restore Peregrine Falcons to the Baja California Pacific Islands
Alternative 2 \[ \] Alternative 3 \[ \] Neither \[  \]

These three peregrine falcon restoration actions are analyzed
collectively.

##### **[Cumulative Biological Effects]{.underline}**

The Trustees have evaluated whether peregrine falcon restoration to the
Channel Islands, together with other actions that could adversely affect
sensitive seabird and terrestrial bird species in the Channel Islands,
may have additive cumulative impacts. Increasing the overall numbers of
predatory birds (bald eagles and peregrine falcons) inhabiting the
Channel Islands may have countervailing impacts when considering other
actions aimed at restoring rare, threatened, or endangered seabirds and
terrestrial birds. Birds constitute only a small fraction of the diet of
bald eagles; however, peregrine falcons prey almost exclusively on other
birds. Given that other actions (by the MSRP and other entities) to
restore other bird populations are proceeding at the same time and given
that bald eagles and peregrine falcons have had a long historical
presence on the Channel Islands prior to their extirpation and
presumably coexisted with other bird populations there, the restoration
of bald eagles and peregrine falcons at a carefully monitored, measured
pace is not expected to have a significant adverse cumulative impact on
recovery efforts for other bird populations (MSRP 2002).

In addition to the potential countervailing effects of the restoration
of bald eagles and peregrine falcons on the restoration and recovery of
seabirds and terrestrial birds, the potentially adverse impacts of the
LNG facility to be constructed and operated near South Coronado Island
should be considered. The incremental degree of increase in losses of
sensitive seabird species such as petrels and auklets to predation due
to a rise in the numbers of peregrine falcons foraging in the Coronado
Islands and the LNG development is uncertain. This uncertainty will be
addressed through subsequent project monitoring and adaptive management.

The potential for interactive effects from MSRP bird restoration
projects is one of the factors contributing to the Trustees' preference
for Alternative 2, which provides a more balanced mix of funding for
predatory bird and seabird restoration. In the absence of seabird
restoration, predatory bird restoration has a greater potential to
adversely affect sensitive seabird populations. Similarly, increases in
seabird numbers likely benefit peregrine falcons and other predatory
birds. Thus, the potential for cumulative adverse effects on other birds
from peregrine falcon and bald eagle restoration are offset when seabird
restoration proceeds at the same time.

##### **[Cumulative Physical Effects]{.underline}**

This action would have no known cumulative effects to the physical
environment.

##### **[Cumulative Human Use Effects]{.underline}**

This action would have no known cumulative effects on human uses.

D1. Restore Seabirds to San Miguel Island Alternative 2 \[  \]
Alternative 3 \[ \] Neither \[ \]

This action will require subsequent environmental analysis when the
project details are more fully developed.

##### **[Cumulative Biological Effects]{.underline}**

As described in Section 7.2.2, efforts to restore seabirds through the
eradication of rats from San Miguel Island has the potential to
adversely affect non-target species, particularly the native deer mouse,
and to indirectly affect the ongoing recovery efforts for the endangered
island fox. This action will proceed only if the risks to non-target
species can be minimized to an acceptable level, which will be the
subject of subsequent planning efforts.

Potential cumulative adverse effects to rats targeted for removal or
eradication from San Miguel Island under this action are considered
insignificant given the wide distribution and numbers in which such rats
occur elsewhere, particularly on the U.S. mainland. Numerous efforts to
remove non-native species (rabbits, cats, feral sheep, cattle, burros,
and feral pigs) from the island environments along the California coast
have occurred in the recent past, including the projects undertaken by
the natural resource trustee councils for the Cape Mohican, M/T Command,
and American Trader oil spill cases (NOAA 2005a) as well as the resource
management projects undertaken by the Channel Islands National Park (NPS
2005). Together, these projects have resulted in substantial recoveries
of endemic plants and animals on the islands (MSRP 2002) without
adversely affecting the species targeted for eradication where they
occur elsewhere.

##### **[Cumulative Physical Effects]{.underline}** 

This action would have no known cumulative effects to the physical
environment.

##### **[Cumulative Human Use Effects]{.underline}**

This action would have no known cumulative effects on human uses.

D2. Restore Alcids to Santa Barbara Island Alternative 2 \[  \]
Alternative 3 \[  \] Neither \[ \]

This action will require subsequent environmental analysis when the
project details are more fully developed.

##### **[Cumulative Biological Effects]{.underline}**

This action would have no known cumulative effects on biological
resources.

##### **[Cumulative Physical Effects]{.underline}**

This action would have no known cumulative effects on the physical
environment.

##### **[Cumulative Human Use Effects]{.underline}**

This action would have no known cumulative impacts to human uses.
Cultural resources would be avoided on the island during project
implementation.

D3. Restore Seabirds to San Nicolas Island Alternative 2 \[  \]
Alternative 3 \[ \] Neither \[ \]

This action will require subsequent environmental analysis when the
project details are more fully developed.

##### **[Cumulative Biological Effects]{.underline}**

This action would complement the conservation actions that the U.S. Navy
is taking on San Nicolas Island. The MSRP-funded feral cat eradication
effort would expand ongoing control efforts with the goal of eradicating
cats from the island over a 3-year time frame. Eradication of feral cats
would benefit not only seabird populations but also island foxes and
other endemic species on San Nicolas Island.

Potential cumulative adverse effects to non-native feral cats targeted
for removal or eradication from San Nicolas Island under this action are
considered insignificant given the wide distribution and numbers in
which such cats occur elsewhere, particularly on the U.S. mainland.
Numerous efforts to remove non-native species (rabbits, cats, feral
sheep, cattle, burros, feral pigs, and invasive plants) from the island
environments along the California coast have occurred in the recent
past, including projects undertaken by natural resource trustee councils
for the Cape Mohican, M/T Command, and American Trader oil spill cases
(NOAA 2005a) as well as the resource management projects undertaken by
the Channel Islands National Park (NPS 2005). These projects have
resulted in substantial recoveries of endemic plants and animals on the
islands (MSRP 2002) without adversely affecting the species targeted for
eradication where they occur elsewhere.

##### **[Cumulative Physical Effects]{.underline}**

This action would have no known cumulative effects on the physical
environment.

##### **[Cumulative Human Use Effects]{.underline}**

This action would have no known cumulative effects on human uses.

D4. Restore Seabirds to Scorpion and Orizaba Rocks Alternative 2 \[  \]
Alternative 3 \[  \] Neither \[ \]

This action will require subsequent environmental analysis when the
project details are more fully developed.

##### **[Cumulative Biological, Physical, and Human Use Effects]{.underline}**

This action would have no known cumulative effects on the biological or
physical environment or on human uses.

D5. Restore Seabirds to Baja California Pacific Islands Alternative 2 \[
 \] Alternative 3 \[  \] Neither \[ \]

##### **[Cumulative Biological Effects]{.underline}**

As described above in the analysis of cumulative effects for the
peregrine falcon restoration actions, seabird restoration on the
Coronados Islands and future LNG-related construction and operation near
these islands may have countervailing effects. Specifically, the
benefits of the MSRP actions aimed at restoring seabird populations
around the Coronado Islands may be counteracted should the proposed GNL
Mar Adentro (Chevron) LNG facility be constructed. The nature and degree
of countervailing effects is unknown at this time. This uncertainty will
be addressed through subsequent project monitoring and adaptive
management.

##### **[Cumulative Physical Effects]{.underline}**

These actions would have no known direct or indirect effects on the
physical environment.

##### **[Cumulative Human Use Effects]{.underline}**

These actions would have no known direct or indirect effects on human
uses.

D6. Create/Enhance/Protect California Brown Pelican Roost Habitat
Alternative 2 \[ \] Alternative 3 \[ \] Neither \[  \]

This action will require subsequent environmental analysis when the
project details are more fully developed.

##### **[Cumulative Biological, Physical, and Human Use Effects]{.underline}**

##### Because no specific sites have been selected for this action, the nature and degree of cumulative effects are unknown at this time. This uncertainty will be addressed through subsequent environmental analysis.

D7. Implement an Entanglement Reduction and Outreach Program to Protect
Seabird Populations Alternative 2 \[ \] Alternative 3 \[ \] Neither \[ 
\]

##### **[Cumulative Biological Effects]{.underline}**

This action would have no known cumulative effects on the biological
environment.

##### **[Cumulative Physical Effects]{.underline}**

This action would have no known cumulative effects on the physical
environment.

##### **[Cumulative Human Use Effects]{.underline}**

Although numerous other small- and larger-scale public outreach and
education efforts aim at reducing adverse impacts to non-targeted
resources from fishing and other coastal recreational activities, the
cumulative effects on human uses of this and other such actions are not
considered significant.

D8. Restore Ashy Storm-Petrels to Anacapa Island Alternative 2 \[  \]
Alternative 3 \[  \] Neither \[ \]

This action will require subsequent environmental analysis when the
project details are more fully developed.

##### **[Cumulative Biological Effects]{.underline}**

This action will capitalize on the recently completed rat eradication
efforts on Anacapa Island. The recent removal of the rat population
provides an excellent opportunity for colonization on the island by ashy
storm-petrels, as the amount of suitable nesting habitat for seabirds
has increased substantially.

##### **[Cumulative Physical Effects]{.underline}**

This action would have no known cumulative effects on the physical
environment.

##### **[Cumulative Human Use Effects]{.underline}**

This action would have no known cumulative effects on human uses.

## Other NEPA- and CEQA-Mandated Discussions

### Irreversible and Irretrievable Commitment of Resources and Environmental Changes

The MSRP will require a relatively small but irretrievable commitment of
energy and material resources to construct and monitor the preferred
alternative. CEQA regulations require that an EIR consider significant
irreversible environmental changes. Construction of artificial reefs
will involve physical placement of material on the seafloor that will be
for all practical purposes an irreversible action. Most of the MSRP
actions, however, such as those aimed at restoring birds through removal
of non-native fauna and flora from islands, the use of social attraction
techniques, and the hacking of bald eagles and peregrine falcons, could
theoretically be reversed at some point in the future. Depending on
other future developments, the suspension of the Trustees' funding
support for the bald eagle program on Santa Catalina Island could
eventually lead to the disappearance of bald eagles from that island.
This result could happen if no other funding sources are found to
continue the intervention needed because the bald eagles cannot
reproduce on their own and if the Trustees decide not to pursue further
bald eagle restoration work on Santa Catalina Island after the NCI Bald
Eagle Feasibility Study is complete. Such consequences could be reversed
at some point in the future by hacking new bald eagles onto the island.

### Relationship between Short-Term Uses of the Environment and the Maintenance and Enhancement of Long-Term Productivity

The short-term uses of the environment that will occur in conjunction
with the proposed actions are expected to lead to substantially greater
long-term productivity.

### Growth-Inducing Impacts

CEQA regulations require that an EIR address the potential
growth-inducing impacts of a proposed project. Implementation of the
MSRP actions will not foster economic or population growth or the
construction of additional housing, and therefore will not have a
growth-inducing impact.

### Significant and Unavoidable Adverse Impacts

To the extent known at this stage in the planning, no adverse impacts
identified in this programmatic EIS/EIR are expected to be significant.
Several individual projects require subsequent site-specific detail
development and environmental analysis. Should any significant and
unavoidable adverse environmental impacts be identified at a later stage
in planning, they will be addressed in subsequent environmental
documentation. The Trustees do not intend to pursue natural resource
restoration projects that, on subsequent analysis, have significant and
unavoidable adverse environmental impacts.

[^1]: As a matter of practice, the lead federal agency for this
    programmatic EIS/EIR, the National Oceanic and Atmospheric
    Administration (NOAA), undertakes a NEPA analysis for all of its
    major actions with potential for significant effects on the
    environment, including those occurring outside the United States and
    its territories. The analysis of potential restoration actions on
    Baja California Pacific Islands is being provided to ensure that the
    public is fully informed about important environmental issues. The
    production of this NEPA document is in no way intended to affect or
    influence other United States government policies regarding the
    applicability of NEPA to actions taken outside the United States.
    Subsequent site-specific detail development for potential
    restoration actions in Baja California Pacific Islands may be
    subject to the environmental review requirements of the Mexican
    government.