Pink algae found on the coral 

throughout the Refuge gives 

Rose Atoll its name. 

USFWS

U.S. Department of the Interior

U.S. Fish & Wildlife Service

Rose Atoll National Wildlife Refuge

c/o National Park Service

Pago Pago, AS 96799

Phone: 684/633-7082 ext. 15

Fax: 684/699-3986

October 2012

Font Cover Photos

Main: An array of seabirds find refuge

at Rose Atoll

USFWS

Inset: Pisonia tree

JE Maragos/USFWS

Red-tailed tropic bird chick

Greg Sanders/USFWS

Tridacna maxima

JE Maragos/USFWS
Reef life at Rose Atoll

JE Maragos/USFWS

Comprehensive Conservation Plans 

provide long-term guidance for 

management decisions and set forth goals, 

objectives, and strategies needed to 

accomplish refuge purposes and identify the 

Service’s best estimate of future needs. These plans 

detail program planning levels that are sometimes 

substantially above current budget allocations and, as 

such, are primarily for Service strategic planning and 

program prioritization purposes. The plans do not constitute a 

commitment for staffing increases, operational and 

maintenance increases, or funding for future land acquisition.

Rose Atoll , as seen from low Earth orbit

Refuge Vision

Perched on an ancient volcano, reef corals, algae, and clams grow upwards thousands of feet on the foundation built by their 

ancestors over millions of years. Here, Rose Atoll National Wildlife Refuge glows pink in the azure sea. This diminutive 

atoll shelters a profusion of tropical life. Encircled by a rose-colored coralline algal reef, the lagoon teems with brilliant 

fish and fluted giant clams with hues of electric blue, gold, and dark teal. Sea turtles gracefully ply the waters and find safe 

haven lumbering ashore to lay eggs that perpetuate their ancient species. On land, stately Pisonia trees form a dim green 

cathedral where sooty tern calls echo as they fly beneath the canopy. Their calls join the cackling of the red-footed boobies, 

whinnying of the frigate birds, and moaning of the wedge-tailed shearwaters. Inspired by their living history at the atoll, 

tamaiti perpetuate Fa’a Samoa through an understanding and shared stewardship of their natural world. In the vast deep 

South Pacific, Rose Atoll survives as a monument from the past and beacon for the future of biological, geological, and 

cultural diversity for all Samoa.

Pale o Galuega o le Faasao mo Meaola

O lona taoto mai, o se pala ma ̄tu ̄ na eaea ma ̄lie a’e lona faavae i luga o se maugamu ̄, si’omia e ‘amu lona a’au, o ituaiga limu 

eseese e ola i lona gataifale, ma faisua e ola lauusiusi aga’i i luga e pe a ma le afe ni futu lona maualuga o lo o taoto mai ai 

lenei nofoaga na foa mai e ona tua’a ̄ i le miliona o tausaga ua mavae. I lea la nofoaga, o le Faasao a le Ma ̄lo ̄ Tele mo Meaola 

e pei ona mautu nei i le motu ‘amu o Rose e sulugia mai ai le lanu piniki i le sami tioata. O lenei tama’i motu ‘amu ua fai ma 

nofoaga e tua i ai le tele o meaola o le si’osi’omaga. E si’osi’omia lona a’au e se limu e soa ma le lanu o le rosa, e mau lona 

aloalo i i’a matagofie ma ‘amu tetele faatasi ai ma meaola ninii e felanulanua’i solo ma o lo o atagia mai ai le lanu moana,

lanu auro, ma le lanu uliuli e sosolo faapei o se faititili lona tino mai. E fega ̄soloa’i laumei o le gataifale i le foga ̄sami ae 

ma ̄lo ̄lo ̄ mai i lo latou mapusaga i le mata ̄faga e tu’ufua ai ma atili olaola ai lo latou tupu’aga na amata asa ̄ le vavau se i o’o

mai nei ona po. I luga o lea fanua, e fa’alafua ̄ le tuputupu a’e o laau e ta’ua o laumatui ua fai ma nofoaga tumau o gogo ma 

lagona leotele ai le fetalia’i o o latou leo i lalo o le malu o pupu laau. E fea ̄lumi nei leo o manu tagi ma le pa ̄fuga o le ‘a ̄, o le 

tagi lea o le fua’o ̄, faatasi ai ma le tagi mai o le ‘atafa, ma le uio ̄ o le toloa. Ona o le taualoa tele o talatuu tau measina o lea 

motu ‘amu, ua teu fatu ai le naunauta’iga a tupulaga talavou e u’una’i pea le Faasamoa i se faagaoioiga malamalama toe 

manino ma avea ai i latou o ni tausimea i le taavili soifua o lea si’osi’omaga tu ̄pito. I le vasa loaloa o i le Pasefika i Saute,

o lo o pa ̄pa ̄’aveloa le soifua o le motu ‘amu o Rose ua avea ai o se motu iloga toe faailogaina na amata mai lava i lona anamua 

ma o lea ua avea o se taula’iga e faasinoala i su’esu’ega tau paiolo (biological), su’esu’ega o le eleele (geological), ma le talia 

lelei o eseesega tau aganuu mo Samoa atoa.

USFWS/DMWR
Rose Atoll 

National Wildlife Refuge 

Draft Comprehensive Conservation Plan 

and 

Environmental Assessment 

Prepared by: 

Rose Atoll National Wildlife Refuge/Marine National Monument 

c/o National Park Service 

Pago Pago, American Samoa 96799 

U.S. Fish and Wildlife Service 

Hawaiian and Pacific Islands Planning Team 

300 Ala Moana Boulevard, Room 5-231 

Honolulu, Hawai‘i 96850 

 October 2012 

Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Table of Contents i 

Table of Contents 

Chapter 1. Introduction and Background ...................................................................................... 1-1

1.1 Introduction ............................................................................................................................... 1-1

1.2 Significance of the Refuge ........................................................................................................ 1-2

1.3 Proposed Action ........................................................................................................................ 1-5

1.4 Purpose and Need for Action .................................................................................................... 1-5

1.5 Legal and Policy Guidance ....................................................................................................... 1-6

1.5.1 The U.S. Fish and Wildlife Service .................................................................................. 1-6

1.5.2 National Wildlife Refuge System ..................................................................................... 1-6

1.5.3 Presidential Proclamation 8337 ........................................................................................ 1-8

1.5.4 Other Laws and Mandates ................................................................................................ 1-9

1.6 Refuge Establishment and Purposes ......................................................................................... 1-9

1.6.1 Legal Significance of the Refuge Purpose(s) .................................................................... 1-9

1.6.2 Purpose and History of Refuge Establishment ............................................................... 1-10

1.6.3 Land Status and Ownership ............................................................................................ 1-10

1.7 Relationship to Other Planning Efforts ................................................................................... 1-13

1.7.1 Relationship to Refuge Plans .......................................................................................... 1-13

1.7.2 Other Plans and Assessments .......................................................................................... 1-13

1.8 Special Designation Lands ...................................................................................................... 1-14

1.9 Planning Process and Issue Identification ............................................................................... 1-14

1.9.1 Planning Process ............................................................................................................. 1-14

1.9.2 Key Issues Addressed in the CCP ................................................................................... 1-15

1.9.3 Issues outside the Scope of the CCP ............................................................................... 1-15

1.10 Refuge Vision and Goals ...................................................................................................... 1-16

1.10.1 Refuge Vision (Pale o Galuega o le Faasao mo Meaola).............................................. 1-16

1.10.2 Refuge Goals (Manulautī o le Faasao mo Meaola) ....................................................... 1-16

Chapter 2. Management Alternatives ............................................................................................. 2-1

2.1 Alternatives Development ........................................................................................................ 2-1

2.2 Actions Considered but not Developed .................................................................................... 2-1

2.3 Alternative Descriptions ........................................................................................................... 2-1

2.3.1 Features Common to All Alternatives .............................................................................. 2-1

2.3.2 Summary of Alternatives .................................................................................................. 2-5

2.4 Goals, Objectives, and Strategies ............................................................................................ 2-13

2.4.1 Goal 1: Protect and maintain the lagoon habitats to meet the life-history needs of 

native species in this community. ............................................................................................ 2-14

2.4.2 Goal 2: Restore, protect, and maintain the perimeter crustose coralline algal reef to 

meet the life-history needs of native species in this community. ............................................ 2-15

2.4.3 Goal 3: Protect and maintain the natural state of the channel (ava) to protect all other 

Refuge habitats and the hydrology of the lagoon. ................................................................... 2-17

2.4.4 Goal 4: Restore, protect, and maintain the beach strand habitat to meet the lifehistory needs of native species in this community. .................................................................. 2-18

2.4.5 Goal 5: Restore, protect, and maintain littoral forest to meet the life-history needs of 

native species in this community including plants, seabirds, shorebirds, landbirds, 

waterbirds, reptiles, and land crabs. ......................................................................................... 2-20

2.4.6 Goal 6: Gather scientific information (inventories, monitoring, assessments, and 

research) to support adaptive management decisions under objectives for Goals 1-5. ........... 2-23
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

ii Table of Contents 

2.4.7 Goal 7: Strengthen resource conservation and the public’s shared stewardship of the 

ecological, geologic, and cultural richness of the Refuge by providing outreach, 

interpretation, and environmental education opportunities. ..................................................... 2-28

2.4.8 Goal 8: Identify, protect, preserve, and interpret the Refuge’s Samoan cultural 

resources and facilitate, where appropriate, cultural practices. ............................................... 2-31

Chapter 3. Physical Environment ...................................................................................................... 1

3.1 Climate ......................................................................................................................................... 1

3.1.1 General Climate .................................................................................................................... 1

3.1.2 Climate Change ..................................................................................................................... 1

3.2 Hydrology .................................................................................................................................... 6

3.3 Topography and Bathymetry ....................................................................................................... 6

3.4 Geology and Geomorphology ...................................................................................................... 7

3.5 Soils .............................................................................................................................................. 9

3.6 Environmental Contaminants ....................................................................................................... 9

3.6.1 Military Use in WWII ......................................................................................................... 10

3.6.2 Wreck of the Jin Shiang Fa 1993 ....................................................................................... 10

3.7 Air Quality ................................................................................................................................. 11

3.8 Water Quality ............................................................................................................................. 11

3.9 Surrounding Land Use ............................................................................................................... 12

Chapter 4. Biological Environment ................................................................................................. 4-1

4.1 Biological Integrity Analysis .................................................................................................... 4-1

4.2 Selection of Priority Resources of Concern .............................................................................. 4-3

4.2.1 Analysis of Priority Resources of Concern ....................................................................... 4-3

4.3 Habitat Types ............................................................................................................................ 4-8

4.3.1 Ava .................................................................................................................................. 4-11

4.3.2 Reef (Crest and Back) ..................................................................................................... 4-12

4.3.3 Lagoon ............................................................................................................................ 4-12

4.3.4 Intertidal .......................................................................................................................... 4-13

4.3.5 Beach Strand ................................................................................................................... 4-14

4.3.6 Littoral Forest .................................................................................................................. 4-15

4.4 Threatened, Endangered, and Sensitive Species ..................................................................... 4-17

4.4.1 Tuli (Numenius tahitiensis) or Bristle-thighed Curlew ................................................... 4-18

4.4.2 Tuli (Pluvialis fulva) or Pacific Golden Plover .............................................................. 4-18

4.4.3 I’a sa (Chelonia mydas) or Green Turtle ........................................................................ 4-19

4.4.4 Hawksbill Turtle (Eretmochelys imbricata) ................................................................... 4-20

4.4.5 Faisua (Tridacna maxima) or Giant Clam ...................................................................... 4-21

4.5 Seabirds ................................................................................................................................... 4-22

4.5.1 Tava’e’ula (Phaethon rubricauda) or Red-tailed Tropicbird ......................................... 4-23

4.5.2 Atafa (Fregata minor) or Great Frigatebird .................................................................... 4-23

4.5.3 Atafa (Fregata ariel) or Lesser Frigatebird .................................................................... 4-24

4.5.4 Fua’o (Sula dactylatra) or Masked Booby ..................................................................... 4-25

4.5.5 Fua’o (Sula leucogaster) or Brown Booby ..................................................................... 4-26

4.5.6 Fua’o (Sula sula) or Red-footed Booby .......................................................................... 4-27

4.5.7 Gogo Uli (Anous minutus) or Black Noddy .................................................................... 4-28

4.5.8 Gogo (Anous stolidus) or Brown Noddy ......................................................................... 4-29

4.5.9 Manu Sina (Gygis alba) or White Tern .......................................................................... 4-30

4.5.10 Gogosina, Gogo Uli (Onychoprion fuscatus) or Sooty Tern ........................................ 4-31
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Table of Contents iii 

4.5.11 Gogosina (Onychoprion lunatus) or Gray-backed Tern ............................................... 4-31

4.5.12 Gogosina (Sterna sumatrana) or Black-naped Tern ..................................................... 4-32

4.6 Shorebirds and Wading Birds ................................................................................................. 4-33

4.6.1 Tuli (Arenaria interpres) or Ruddy Turnstone ............................................................... 4-34

4.6.2 Tuli (Calidris alba) or Sanderling .................................................................................. 4-34

4.6.3 Tuli (Tringa incana) or Wandering Tattler ..................................................................... 4-35

4.6.4 Matu’u (Egretta sacra) or Pacific Reef Heron ............................................................... 4-35

4.7 Land Birds ............................................................................................................................... 4-35

4.7.1 Aleva (Eudynamis taitensis) or Long-tailed Cuckoo ...................................................... 4-35

4.8 Invertebrates ............................................................................................................................ 4-35

4.8.1 Tuitui (Sea Urchin) ......................................................................................................... 4-35

4.8.2 Terrestrial Invertebrates .................................................................................................. 4-36

4.9 Reef Building Species ............................................................................................................. 4-37

4.9.1 Coral ................................................................................................................................ 4-39

4.9.2 Coralline Algae ............................................................................................................... 4-43

4.10 Fish ........................................................................................................................................ 4-45

4.11 Invasive and Nuisance Species ............................................................................................. 4-48

4.11.1 Mammals ....................................................................................................................... 4-48

4.11.2 Reptiles ......................................................................................................................... 4-50

4.11.3 Invertebrates .................................................................................................................. 4-50

4.11.4 Vegetation ..................................................................................................................... 4-50

4.12 Wildlife and Habitat Research Inventory and Monitoring .................................................... 4-51

Chapter 5. Social and Economic Environment .............................................................................. 5-1

5.1 Cultural Resources .................................................................................................................... 5-1

5.1.1 Historical Background ...................................................................................................... 5-1

5.1.2 Rose Atoll and Manu’a Islands ......................................................................................... 5-2

5.2 Refuge Facilities ....................................................................................................................... 5-6

5.3 Public Use Overview ................................................................................................................ 5-6

5.4 Wildlife-Dependent Public Uses ............................................................................................... 5-6

5.4.1 Hunting ............................................................................................................................. 5-6

5.4.2 Fishing ............................................................................................................................... 5-6

5.4.3 Wildlife Viewing and Photography .................................................................................. 5-6

5.4.4 Environmental Education .................................................................................................. 5-7

5.4.5 Interpretation/Outreach ..................................................................................................... 5-7

5.4.6 Cultural Resources Interpretation ..................................................................................... 5-7

5.5 Illegal Uses ................................................................................................................................ 5-7

5.6 Social/Economic Environment ................................................................................................. 5-8

5.6.1 Communities near Rose Atoll National Wildlife Refuge ................................................. 5-8

5.6.2 Population, Housing, and Income ..................................................................................... 5-8

5.6.3 Employment and Business ................................................................................................ 5-9

5.6.4 Refuge Impact on Local Economies ............................................................................... 5-10

5.6.5 Additional Economic Contributions ............................................................................... 5-11

Chapter 6. Summary of Effects ....................................................................................................... 6-1

6.1 Effects Common to All Alternatives ......................................................................................... 6-4

6.2 Effects to the Physical Environment ......................................................................................... 6-4

6.2.1 Effects to Soils .................................................................................................................. 6-5

6.2.2 Effects to Water Quality ................................................................................................... 6-6
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

iv Table of Contents 

6.2.3 Effects to Air Quality ........................................................................................................ 6-7

6.3 Effects to Wildlife and Habitats ................................................................................................ 6-8

6.3.1 Effects to Habitats ............................................................................................................. 6-8

6.3.2. Effects to Wildlife .......................................................................................................... 6-11

6.4 Effects to Cultural and Historic Resources ............................................................................. 6-15

6.5 Effects to Social Resources ..................................................................................................... 6-16

6.5.1 Opportunities for Quality Environmental Education and Interpretation and Outreach .. 6-16

6.5.2 Extent of Illegal Use ....................................................................................................... 6-16

6.5.3 Environmental Justice ..................................................................................................... 6-16

6.6 Effects to Economic Resources............................................................................................... 6-17

6.6.1 Management Strategies ................................................................................................... 6-17

6.6.2 Additional Economic Impacts ......................................................................................... 6-18

6.7 Other Effects ........................................................................................................................... 6-19

6.7.1 Potential Impacts on Adjacent Lands and their Associated Natural Resources .............. 6-19

6.7.2 Potential Impacts to Nearby Residents ........................................................................... 6-19

6.8 Cumulative Effects .................................................................................................................. 6-19

6.8.1 Protected Areas ............................................................................................................... 6-20

6.8.2 Climate Change ............................................................................................................... 6-20

Appendices 

Appendix A. Rose Atoll NWR Species Lists .................................................................................... A-1

Appendix B. Appropriate Use Findings ............................................................................................. B-1

Appendix C. Compatibility Determinations ...................................................................................... C-1

Appendix D. Implementation ............................................................................................................. D-1

Appendix E. Wilderness Review for Rose Atoll National Wildlife Refuge ...................................... E-1

Appendix F. Biological Resources of Concern .................................................................................. F-1

Appendix G. Integrated Pest Management (IPM) Program ............................................................... G-1

Appendix H. Statement of Compliance ............................................................................................. H-1

Appendix I. Common Acronyms and Abbreviations .......................................................................... I-1

Appendix J. CCP Team Members and Public Involvement ............................................................... J-1

Appendix K. Cooperative Agreement and Presidential Proclamation ............................................... K-1

Appendix L. References ..................................................................................................................... L-1

Figures 

Figure 1-1. Regional and local area. ................................................................................................... 1-3

Figure 1-2. Refuge overview and land status. ................................................................................... 1-11

Figure 2-1. Alternative A. ................................................................................................................... 2-9

Figure 2-2. Alternative B. ................................................................................................................. 2-11

Figure 4-1. Habitats. ........................................................................................................................... 4-9

Figure 4-2. Atoll formation. .............................................................................................................. 4-38

Tables 

Table 2-1. Summary of Alternatives by Issue ..................................................................................... 2-7

Table 4-1. Biological Integrity, Diversity, and Environmental Health ............................................... 4-2

Table 4-2. Priority Resources of Concern ........................................................................................... 4-5

Table 4-3. Shorebirds and Wading Birds of Primary Conservation Importance in the U.S. Pacific 

Region ............................................................................................................................................... 4-34

Table 5-1. Employment and Labor Income 2002 ............................................................................... 5-9
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Table of Contents v 

Table 5-2. Economic Projections 2000-2015 .................................................................................... 5-10

Table 6-1. Summary of Effects under CCP Alternatives .................................................................... 6-2

Table 6-2. Annual Salaries (including locality pay and COLA and benefits) for Refuge Employees by 

Alternative ......................................................................................................................................... 6-18

 
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Rose Atoll National Wildlife Refuge 

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Chapter 1. Introduction and Background 1-1 

Chapter 1. Introduction and Background 

1.1 Introduction 

Aerial photo of Rose Atoll. USFWS. 

Rose Atoll National Wildlife Refuge (NWR or Refuge) is located approximately 180 miles east of 

Tutuila in American Samoa. The next closest island to Rose is Ta’ū Island in Manu’a 78 miles away. 

This 1,613-acre Refuge was established on August 24, 1973 with the American Samoa Government 

(ASG) by a cooperative agreement (see Appendix K). It is the southernmost unit of the National 

Wildlife Refuge System (Refuge System) and shares 

the distinction with Jarvis Island of being one of two 

NWRs located south of the equator. 

Originally established to conserve and protect fish 

and wildlife resources, the Refuge provides habitat 

for migratory seabirds and shorebirds, turtles, and 

unique marine fish, coral reefs, and other 

invertebrates. The focus of Refuge management is to 

maintain and preserve these habitats for these species 

with a greater understanding of ecosystem health 

through expanded and enhanced monitoring. Gogosina (tern) chick. Jiny Kim, USFWS. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

1-2 Chapter 1. Introduction and Background 

1.2 Significance of the Refuge 

Rose Atoll is one of the smallest atolls in the world. It 

consists of a perimeter reef encircling a central 

lagoon. Rose Atoll is a nearly square geographical 

feature, with sides that are approximately 1.5 miles in 

length. Within the atoll there are two low, sandy 

islands—Rose and Sand—located on a coralline algal 

reef which surrounds the lagoon. A single channel 

(ava) links the lagoon to the sea surrounding the atoll. 

The lagoon is roughly 1.2 miles wide and 98 feet 

deep. 

Coral communities at Rose Atoll are distinctive from 

reefs around the other islands in Samoa. This fringing 

reef gives off a striking pink hue due to the crustose coralline algae (CCA) that is the primary reefbuilding species at the atoll. The CCA reef plays a significant role in the atoll, stabilizing the 

perimeter and protecting the lagoon and islands from ocean swells. 

Another rare habitat at the Refuge is its tropical Pisonia forest. This type of forest can provide habitat 

for many nesting seabird species. This forest type is declining in the Pacific due to the effects of 

human habitation, coconut plantings, and pests such as rats and insects. 

Unlike the rest of the Samoan Archipelago where they are harvested by humans, the spectacularly 

colored giant clams (faisua) are found in high densities at the Refuge. Similarly, fish density is very 

high and species diversity moderately high when compared to other reefs in the Samoan Archipelago. 

The fish assemblages also differ by having a high density of planktivorous and carnivorous fishes 

(especially unicornfishes and snappers) and lower density of herbivorous fishes (especially 

parrotfishes and damselfishes). 

Rose Atoll’s beach strand provides important nesting sites for the threatened green turtle, which 

migrate between American Samoa and other Pacific Island nations. As the only terrestrial rat-free 

areas in American Samoa, Rose Atoll’s islands are vital nesting and roosting habitat supporting 12 

species of federally protected seabirds and sea turtles. 

Further information (e.g., biology, cultural/historic resources, etc.) can be found in Chapters 3-5. 

CCA. Jean Kenyon, USFWS. Faisua. Jean Kenyon, USFWS. Beach strand. USFWS. 

Rose Island. USFWS. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 1. Introduction and Background 1-3 

Figure 1-1. Regional and local area. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

1-4 Chapter 1. Introduction and Background 

The back sides of maps are blank to improve readability. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 1. Introduction and Background 1-5 

1.3 Proposed Action 

We, the U.S. Fish and Wildlife Service (Service), manage national wildlife refuges as part of the 

Refuge System. We propose to adopt and implement a Comprehensive Conservation Plan (CCP) for 

Rose Atoll NWR. This document is the Draft Comprehensive Conservation Plan and Environmental 

Assessment (Draft CCP/EA). A CCP sets forth management guidance for a refuge for a period of 15 

years, as required by the National Wildlife Refuge System Administration Act of 1966 (16 U.S.C. 

688dd-688ee, et seq.) (Administration Act) as amended by the National Wildlife Refuge System 

Improvement Act of 1997 (Pub. Law 105-57) (Improvement Act). The Improvement Act requires 

CCPs to identify and describe: 

 The purposes of the refuge; 

 The fish, wildlife, and plant populations, their habitats, and the archaeological and cultural 

values of the refuge; 

 Significant problems that may adversely affect wildlife populations and habitats and ways to 

correct or mitigate those problems; 

 Areas suitable for administrative sites or visitor facilities; and 

 Opportunities for wildlife-dependent recreation. 

The proposed action in the CCP is to implement Alternative B, which has been identified as the 

Service’s preferred alternative. The Service has developed and examined a total of two alternatives 

for future management and discloses anticipated effects for each alternative, pursuant to the National 

Environmental Policy Act of 1969 (NEPA), as amended (42 U.S.C. 4321-4347). The goals, 

objectives, and strategies under Alternative B best achieve the purpose and need for the CCP and 

integrate the varied management needs and programs. It represents the most balanced approach for: 

achieving the Refuge purposes, vision, and goals; contributing to the Refuge System mission; 

addressing relevant issues and mandates; and managing the Refuge consistently with the sound 

principles of fish and wildlife management. 

The preferred alternative may be modified between the draft and final document depending upon 

comments received from the public or other agencies and organizations. The Service’s Regional 

Director for Region 1 will decide which alternative will be implemented. For details on the specific 

components and actions comprising the range of alternatives see Chapter 2. 

1.4 Purpose and Need for Action 

The purpose of developing the CCP is to provide the refuge manager with a 15-year management 

plan for the conservation of fish, wildlife, and plant resources and their related habitats, while 

providing opportunities for compatible, wildlife-dependent recreational uses. The CCP, when fully 

implemented, should achieve refuge purposes; help fulfill the Refuge System mission; maintain and, 

where appropriate, restore the biological integrity, diversity, and environmental health (BIDEH) of 

each refuge and the Refuge System; help achieve the goals of the National Wilderness Preservation 

System; and meet other mandates. The CCP must be specific to the planning unit and identify the 

overarching wildlife, public use, or management needs for the refuge (602 FW 3.4C1d). 

The need for action at Rose Atoll NWR includes: 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

1-6 Chapter 1. Introduction and Background 

 Identify and anticipate negative effects of climate change most likely to influence biological 

integrity, diversity, and environmental health at Rose Atoll and formulate response and 

mitigation plans; 

 Contribute to the protection and conservation of fish, wildlife, and plants at the Refuge; 

 Evaluate the role of Rose Atoll NWR in the context of other marine protected areas (MPA) 

and seabird colonies in the Southern part of the Central tropical Pacific Islands to identify 

species and ecological processes for which to manage; 

 Identify ecological restoration actions needed at Rose Atoll that can be achieved by direct 

management intervention; 

 Improve capacity to protect resources, make them more accessible to the public, and study 

the ecosystem at Rose Atoll using remote technologies; and 

 Identify and evaluate the Refuge’s Samoan cultural resources and facilitate, where 

appropriate, compatible cultural practices. 

1.5 Legal and Policy Guidance 

1.5.1 The U.S. Fish and Wildlife Service 

All refuges are managed by the Service, an agency within the Department of the Interior. The Service 

is the principal Federal agency responsible for conserving, protecting, and enhancing the Nation’s 

fish and wildlife populations, and their habitats. 

The mission of the Service is “working with others, to conserve, protect and enhance fish, wildlife, 

plants and their habitats for the continuing benefit of the American people.” Although we share this 

responsibility with other Federal, State/Territorial, tribal, local, and private entities, the Service has 

specific trust responsibilities for migratory birds, certain endangered and threatened species, and 

certain anadromous fish and marine mammals. The Service has similar trust responsibilities for the 

lands and waters we administer to support the conservation and enhancement of fish, wildlife, plants, 

and their habitats. The Service also enforces Federal wildlife laws and international treaties for 

importing and exporting wildlife, assists with State/Territorial fish and wildlife programs, and helps 

other countries develop wildlife conservation programs. 

1.5.2 National Wildlife Refuge System 

A refuge is managed as part of the Refuge System within a framework provided by legal and policy 

guidelines. The Refuge System is the world’s largest network of public lands and waters set aside 

specifically for conserving wildlife and protecting ecosystems. 

The needs of wildlife and their habitats come first on refuges, in contrast to other public lands that 

are managed for multiple uses. Refuges are guided by various Federal laws and Executive orders, 

Service policies, and international treaties. Fundamental are the mission and goals of the Refuge 

System and the designated purpose(s) of the refuge unit as described in establishing legislation, 

Executive orders, or other documents establishing, authorizing, or expanding a refuge. 

Key concepts and guidance of the Refuge System derive from the Administration Act, the Refuge 

Recreation Act of 1962 (16 U.S.C. 460k-460k-4), as amended, Title 50 of the Code of Federal 

Regulations (CFR), and the Fish and Wildlife Service Manual. The Administration Act is 
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implemented through regulations covering the Refuge System, published in Title 50, subchapter C of 

the CFR. These regulations govern general administration of units of the Refuge System. 

1.5.2.1 National Wildlife Refuge System Mission and Goals 

The mission of the Refuge System is: “to administer a national network of lands and waters for the 

conservation, management, and where appropriate, restoration of the fish, wildlife, and plant 

resources and their habitats within the United States for the benefit of present and future generations 

of Americans” (Administration Act). 

The goals of the Refuge System, as articulated in the National Wildlife Refuge System Mission and 

Goals and Refuge Purposes Policy (601 FW 1) are: 

 Conserve a diversity of fish, wildlife, and plants and their habitats, including species that are 

endangered or threatened with becoming endangered; 

 Develop and maintain a network of habitats for migratory birds, anadromous and interjurisdictional fish, and marine mammal populations that is strategically distributed and 

carefully managed to meet important life-history needs of these species across their ranges; 

 Conserve those ecosystems, plant communities, wetlands of national or international 

significance, and landscapes and seascapes that are unique, rare, declining, or 

underrepresented in existing protection efforts; 

 Provide and enhance opportunities to participate in compatible wildlife-dependent recreation 

(hunting, fishing, wildlife observation and photography, and environmental education and 

interpretation); and 

 Foster understanding and instill appreciation of the diversity and interconnectedness of fish, 

wildlife, and plants and their habitats. 

1.5.2.2 National Wildlife Refuge System Administration Act 

Of all the laws governing activities on NWRs, the Administration Act exerts the greatest influence. 

The Improvement Act amended the Administration Act in 1997 by including a unifying mission for 

all national wildlife refuges as a system, a new process for determining compatible uses on refuges, 

and a requirement that each refuge will be managed under a CCP developed in an open public 

process. 

The Administration Act states that the Secretary shall provide for the conservation of fish, wildlife 

and plants, and their habitats within the Refuge System as well as ensure that the biological integrity, 

diversity, and environmental health of the Refuge System are maintained. House Report 105–106 

accompanying the Improvement Act states “... the fundamental mission of our System is wildlife 

conservation: wildlife and wildlife conservation must come first.” Biological integrity, diversity, and 

environmental health are critical components of wildlife conservation. As later made clear in the 

BIDEH policy (601 FW 3) “the highest measure of biological integrity, diversity, and environmental 

health is viewed as those intact and self-sustaining habitats and wildlife populations that existed 

during historic conditions.” 

Under the Administration Act, each refuge must be managed to fulfill the Refuge System mission as 

well as the specific purpose(s) for which it was established. The Administration Act requires the 

Service to monitor the status and trends of fish, wildlife, and plants in each refuge. 
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1-8 Chapter 1. Introduction and Background 

Additionally, the Administration Act identifies six wildlife-dependent recreational uses for the 

Refuge System. These uses are hunting, fishing, wildlife observation and photography, and 

environmental education and interpretation. Under the Administration Act, the Service is to grant 

these six wildlife-dependent public uses, when compatible, special consideration in the planning for, 

management of, and establishment and expansion of units of the Refuge System. The overarching 

goal of the wildlife-dependent public use programs is to enhance opportunities and access to quality 

wildlife-dependent visitor experiences on refuges while managing refuges to conserve fish, wildlife, 

plants, and their habitats. When determined compatible on a refuge-specific basis, these six uses 

assume priority status among all uses of the refuge in question. The Service is to make extra efforts 

to facilitate priority wildlife-dependent public use opportunities. 

When preparing a CCP, refuge managers must re-evaluate all general public, recreational, and 

economic uses (even those occurring to further refuge habitat management goals) proposed or 

occurring on a refuge for appropriateness and compatibility. No refuge use may be allowed or 

continued unless it is determined to be appropriate and compatible. Generally, an appropriate use is 

one that contributes to fulfilling the refuge purposes, the Refuge System mission, or goals or 

objectives described in an approved refuge management plan. A compatible use is a use that, in the 

sound professional judgment of the refuge manager, will not materially interfere with or detract from 

the purpose(s) of the refuge or the fulfillment of the Refuge System. Updated appropriate use 

findings and compatibility determinations for existing and proposed uses for Rose Atoll NWR are in 

Appendices B and C of this Draft CCP/EA, respectively. 

The Administration Act also requires that, in addition to formally established guidance, the CCP 

must be developed with the participation of the public. Issues and concerns articulated by the public 

play a role in guiding alternatives considered during the development of the CCP, and together with 

the formal guidance, can play a role in selection of the preferred alternative. It is Service policy that 

CCPs are developed in an open public process and that the Service is committed to securing public 

input throughout the process. Appendix J of the Draft CCP/EA details public involvement that has 

been undertaken during this CCP process. 

1.5.3 Presidential Proclamation 8337 

On January 6, 2009, President George W. Bush signed Presidential Proclamation 8337, designating 

the Rose Atoll Marine National Monument (Monument) which included the Rose Atoll NWR. The 

President directed that the Secretary of the Interior shall have management responsibility for the 

Monument, including the Refuge, in consultation with the Secretary of Commerce, except that the 

Secretary of Commerce, through the National Oceanic and Atmospheric Administration (NOAA), 

shall have the primary management responsibility regarding the management of the marine areas of 

the Monument seaward of mean low water, with respect to fishery-related activities regulated 

pursuant to the Magnuson-Stevens Fishery Conservation and Management Act (16 U.S.C. 1801 et 

seq.), and any other applicable authorities. Then on January 16, 2009, Secretary of the Interior 

Kempthorne issued Secretarial Order 3284, delegating all his responsibilities for the Monument to 

the Service Director, and directed that the Refuge continue to be managed consistent with the 

Proclamation and within boundaries set forth in the Notice of Establishment, 71 FR 13183 (April 5, 

1974). 

Additionally, in Proclamation 8337 the President directed the Secretary of Commerce to initiate the 

process to add the marine areas of the Monument to the Fagatele Bay National Marine Sanctuary in 

accordance with the National Marine Sanctuaries Act (16 U.S.C. 1431 et seq.). This process is now 
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underway by the Sanctuary with the release of the final management plan and final environmental 

impact statement on June 2, 2012. Within the Department of Commerce, NOAA is leading that 

process. This Rose Atoll NWR CCP is a separate plan for the conservation of the Refuge area only. 

1.5.4 Other Laws and Mandates 

Many other Federal laws, Executive orders, Service policies, and international treaties govern the 

Service and Refuge System. Examples include the Migratory Bird Treaty Act of 1918 (MBTA), 

Refuge Recreation Act of 1962, National Historic Preservation Act of 1966, and the Endangered 

Species Act of 1973 (ESA). For additional information on laws and other mandates, a list and brief 

description of Federal laws of interest to the Service can be found in the Laws Digest at 

http://www.fws.gov/laws/Lawsdigest.html. 

In addition, over the last few years, the Service has developed or revised numerous policies and 

Director’s Orders to implement the mandates and intent of the Improvement Act. Some of these key 

policies include the BIDEH; Refuge Compatibility (603 FW 2); Comprehensive Conservation 

Planning (602 FW 3); Mission and Goals and Refuge Purposes (601 FW 1), Appropriate Refuge 

Uses (603 FW 1); Wildlife-Dependent Public Uses (605 FW 1-8); Wilderness Stewardship policies 

(610 FW 1-5), and the Director’s Order for Coordination and Cooperative Work with 

State/Territorial Fish and Wildlife Agency representatives on management of the Refuge System. 

These policies and others in draft or under development can be found at: 

http://refuges.fws.gov/policymakers/nwrpolicies.html. 

In developing a CCP, we must consider these broader laws and policies as well as Refuge System 

and ecosystem goals and vision. The CCP must be consistent with these and also with the refuge 

purpose(s). For Rose Atoll NWR, specific examples of these broader laws include: 

 ESA; 

 MBTA; 

 Clean Water Act; 

 Federal Insecticide, Fungicide, and Rodenticide Act; and the 

 Magnuson-Stevens Act (Essential Fish Habitat – which Rose Atoll is identified). 

1.6 Refuge Establishment and Purposes 

1.6.1 Legal Significance of the Refuge Purpose(s) 

The purpose(s) for which a refuge was established or acquired is of key importance in refuge 

planning. Purposes must form the foundation for management decisions. Refuge purposes are the 

driving force in the development of the refuge vision statement, goals, objectives, and strategies in a 

CCP and are critical to determining the appropriateness and compatibility of existing and proposed 

refuge uses. 

The purpose(s) of a refuge are specified in or derived from the law, proclamation, Executive order, 

agreement, public land order, donation document, or administrative memorandum establishing, 

authorizing, or expanding a refuge, refuge unit, or refuge subunit. 
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Unless the establishing law, order, or other document indicates otherwise, purposes dealing with the 

conservation, management, and restoration of fish, wildlife, and plants, and the habitats on which 

they depend take precedence over other purposes in the management and administration of any unit. 

Where a refuge has multiple purposes related to fish, wildlife, and plant conservation, the more 

specific purpose will take precedence in instances of conflict. When an additional unit is acquired 

under an authority different from the authority used to establish the original unit, the addition takes 

on the purpose(s) of the original unit, but the original unit does not take on the purpose(s) of the 

newer addition. When a conflict exists between the Refuge System mission and the purpose(s) of an 

individual refuge, the refuge purpose(s) supersedes the mission. 

1.6.2 Purpose and History of Refuge Establishment 

The establishment authority for the Refuge is the Fish and Wildlife Act of 1956, as amended. 

The purposes for Rose Atoll NWR are: 

 “... for the development, advancement, management, conservation, and protection of fish and 

wildlife resources ...” 16 U.S.C. § 742f(a)(4); 

 “... for the benefit of the United States Fish and Wildlife Service, in performing its activities 

and services. Such acceptance may be subject to the terms of any restrictive or affirmative 

covenant, or condition of servitude ...” 16 U.S.C. § 742f(b)(1) (Fish and Wildlife Act of 

1956, 16 U.S.C. §742(a)-754, as amended). 

1.6.3 Land Status and Ownership 

Rose Atoll is managed by the Service in cooperation with the American Samoa government as a 

National Wildlife Refuge under a cooperative agreement with the Government of American Samoa 

(see Appendix K). Per Presidential Proclamation 4347, the U.S. government maintains jurisdiction 

over the submerged lands and waters of the atoll and surrounding territorial seas. 

The exterior boundary of the Refuge is the extreme low waterline outside the perimeter reef, except 

at the entrance channel where the boundary is a line extended between the extreme low waterlines on 

each side of the entrance channel. 
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Figure 1-2. Refuge overview and land status. 
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1-12 Chapter 1. Introduction and Background 

The back sides of maps are blank to improve readability. 
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1.7 Relationship to Other Planning Efforts 

When developing a CCP, the Service considers the goals and objectives of existing national, 

regional, State/Territorial, and ecosystem plans and/or assessments. The CCP is expected to be 

consistent, as much as possible, with existing plans and assist in meeting their conservation goals and 

objectives (602 FW 3). This section summarizes some of the key plans reviewed by members of the 

core team while developing this CCP. 

1.7.1 Relationship to Refuge Plans 

1.7.1.1 Rose Atoll NWR 

 Final Restoration Plan for Rose Atoll National Wildlife Refuge (USFWS and DMWR 2001). 

Step-down management plans (SDMPs) have been identified for development and are as follows 

(implementation schedule can be found in Appendix D): 

 Inventory and Monitoring Plan; and 

 Biological Review/Habitat Management Plan. 

1.7.2 Other Plans and Assessments 

Recovery Plan for U.S. Pacific Populations of the Green Turtle (Chelonia mydas) (NMFS and 

USFWS 1998a). The green turtle is listed as threatened throughout its Pacific Range, except for the 

endangered population nesting on the Pacific coast of Mexico, which is covered under the Recovery 

Plan for the East Pacific green turtle. By far, the most serious threat to these green turtles is from 

direct take of turtles and eggs, both within U.S. jurisdiction and on shared stocks that are killed when 

they migrate out of U.S. jurisdiction. Human development is also having an increasingly serious 

impact on nesting beaches. 

Recovery Plan for U.S. Pacific Populations of the Hawksbill Turtle (Eretmochelys imbricata) 

(NMFS and USFWS 1998b). The Hawksbill turtle is listed as endangered throughout its range. 

Threats to these turtles include harvest of species for meat, eggs, and the tortoiseshell and stuffed 

curio trade and increasing human populations and subsequent destruction of habitat. Actions 

identified to recover the species include addressing harvesting and development threats, reducing 

incidental mortalities by commercial and artisanal fisheries, better surveying and monitoring, 

supporting management in areas that have existing populations, identifying stock home ranges and 

primary nesting and foraging areas, and controlling non-native predators. 

U.S. Pacific Islands Regional Shorebird Conservation Plan (Engilis and Naughton 2004). 

Conservation and restoration of shorebird habitats is essential for the protection of endangered and 

declining shorebird populations. Wetlands, beach strand, coastal forests, and mangrove habitats are 

particularly vulnerable on Pacific Islands due to increasing development pressures and already 

limited acreage. Monitoring and research needs include assessment of population sizes and trends; 

assessment of the timing and abundance of birds at key wintering and migration stop-over sites; 

assessment of habitat use and requirements at wintering and migration areas; exploration of the 

geographic linkages between wintering, stop-over, and breeding areas; and evaluation of habitat 

restoration and management techniques to meet the needs of resident and migratory species. 
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Education and public outreach are critical components of this plan. Resource management agencies 

of Federal, Territorial, Commonwealth, and State governments will need to work together with 

military agencies, non-governmental organizations, and the scientific community. On a larger scale, 

coordination at the international level will be essential to the conservation of vulnerable species, both 

migratory and resident. 

U.S. Fish and Wildlife Service Regional Seabird Conservation Plan (USFWS 2005). The most 

serious threats to seabirds identified in this regional plan involve invasive (non-native) species, 

interactions with fisheries, oil and other pollution, habitat loss and degradation, disturbance, and 

global climate change. Priorities for seabird management include habitat management (maintenance, 

protection, enhancement, and restoration), threat management, inventory and monitoring, research 

for informed decision-making, outreach and education, and planning and coordination. 

1.8 Special Designation Lands 

The Refuge is also included in the National List of MPAs under the “Pacific Islands” heading. The 

National MPA List was developed in accordance with Executive Order 13158 on MPAs that was 

signed by President Clinton on May 26, 2000. 

1.9 Planning Process and Issue Identification 

The core planning team evaluated the issues and concerns raised both by staff and the public during 

public scoping as well as throughout the multi-year planning process. Issues are defined as matters of 

controversy, dispute, or general concern over resource management activities, the environment, land 

uses, or public use activities. Issues are important to the planning process because they identify topics 

to be addressed in the CCP, pinpoint the types of information to gather, and help define alternatives 

for the CCP. It is the Service’s responsibility to focus planning and analysis on the major issues. 

Major issues typically suggest different actions or alternative solutions, are within the Refuge’s 

jurisdiction, and have a positive or negative effect on the resource. Major issues will influence the 

decisions proposed in the Draft CCP/EA. Key issues to be considered are presented below. 

1.9.1 Planning Process 

The core planning team for Rose Atoll NWR consists of the project leader for the Pacific Reefs 

NWRC, Refuge/Monument Manager, biologists, and natural resource planner. The full list of core 

and extended team members and their roles is provided in Appendix J. The extended team assisted in 

the development of this Draft CCP/EA, particularly in providing comments at key milestones. 

The initial CCP planning process for the Refuge began in 2005. However, due to staff turnover and 

change in management, efforts did not truly get underway again until 2009. Public scoping began in 

the fall of 2009 with a notice in the Federal Register (November 9, 2009) and a total of three public 

meetings held in November 2009 on the Manu’a Islands and on the Island of Tutuila. In all, over 60 

people participated. Public input was also solicited through distribution of planning updates to our 

mailing list. Additionally, meetings with local, Territorial, and Federal agencies and elected officials, 

community groups, non-governmental organizations, and others were also held. The comments and 

suggestions made through this process helped further develop and refine the management alternatives 

for the CCP, including the preferred alternative. It also helped to identify the top priority species, 
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groups, and communities for the Refuge. These priorities are also called conservation targets and 

most of the biological emphasis of the CCP is focused on protecting and restoring these species. 

This Draft CCP/EA will result in additional comments, which will be evaluated by the planning 

team. More information on public involvement can be found in Appendix J. 

1.9.2 Key Issues Addressed in the CCP 

Wildlife and habitats. How can habitat and species management be improved? How can we 

maximize the ability of habitats and species to adapt and resist effects of climate change and ocean 

acidification? What are our priority research and survey needs to support management? 

Cultural/historic resources. How is Rose Atoll connected to Samoan cultural and what is its 

significance? How can we facilitate and support cultural connections to Rose Atoll? How can they be 

woven together with public interpretation? How can historic resources management be enhanced? 

Visitor services and wildlife-dependent recreation. What are appropriate and compatible uses in 

relations to on-site levels of environmental education and interpretation? 

Law enforcement. How can trespass, illegal activity, and human-caused disturbance to wildlife be 

managed more effectively given limited personnel and remoteness of the Refuge? 

1.9.3 Issues outside the Scope of the CCP 

While CCPs are very comprehensive plans, no single plan can cover all issues. The planning team 

has identified management of the Monument to be outside the scope of this CCP. 

Management of the Monument is complex, with three Federal and two Territorial agencies working 

together. The Secretary of the Interior through the Service has overall management responsibility for 

the Monument, including Rose Atoll NWR. However, the Secretary of Commerce, through the 

NOAA National Marine Fisheries Service (NMFS) has primary management responsibility regarding 

the management of the marine areas of the Monument seaward of mean low water, with respect to 

fishery-related activities. The Monument Proclamation prohibits commercial fishing in the 

Monument. The NMFS is developing proposed Monument non-commercial fishing regulations that 

include establishing a 0- to 12-nautical mile (nmi) no-take area around the Refuge and propose to 

establish regulations that permit sustenance and traditional indigenous fishing and recreational 

fishing in the 12-50 nmi zone of the Monument. Additionally, the Office of National Marine 

Sanctuaries (ONMS) has initiated the process to add the marine areas of the Monument, outside of 

the Refuge, to the Fagatele Bay National Marine Sanctuary, and the American Samoa Government 

through the Department of Marine and Wildlife Resources (DMWR) and Department of Commerce 

(ASDOC) is a cooperating agency. 

Consequently, each Federal agency is currently in the process of developing management plans 

and/or regulations related to their authorities in the Monument, in coordination with interagency 

partners. These management plans and regulations will be the basis for management of the 

Monument. However, if after these plans are completed and proclamation requirements remain 

outstanding, a process and regulatory regime will be identified by the Service, in consultation with 

partners, using existing appropriate authorities to address these gaps. 
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1.10 Refuge Vision and Goals 

The following vision and goals for Rose Atoll NWR were developed during the planning and public 

scoping process. 

1.10.1 Refuge Vision (Pale o Galuega o le Faasao mo Meaola) 

O lona taoto mai, o se pala mātū na eaea mālie a’e lona faavae i luga o se maugamū, si’omia e ‘amu 

lona a’au, o ituaiga limu eseese e ola i lona gataifale, ma faisua e ola lauusiusi aga’i i luga e pe a ma 

le afe ni futu lona maualuga o lo o taoto mai ai lenei nofoaga na foa mai e ona tua’ā i le miliona o 

tausaga ua mavae. I lea la nofoaga, o le Faasao a le Mālō Tele mo Meaola e pei ona mautu nei i le 

motu ‘amu o Rose e sulugia mai ai le lanu piniki i le sami tioata. O lenei tama’i motu ‘amu ua fai ma 

nofoaga e tua i ai le tele o meaola o le si’osi’omaga. E si’osi’omia lona a’au e se limu e soa ma le 

lanu o le rosa, e mau lona aloalo i i’a matagofie ma ‘amu tetele faatasi ai ma meaola ninii e 

felanulanua’i solo ma o lo o atagia mai ai le lanu moana, lanu auro, ma le lanu uliuli e sosolo faapei o 

se faititili lona tino mai. E fegāsoloa’i laumei o le gataifale i le fogāsami ae mālōlō mai i lo latou 

mapusaga i le matāfaga e tu’ufua ai ma atili olaola ai lo latou tupu’aga na amata asā le vavau se i o’o 

mai nei ona po. I luga o lea fanua, e fa’alafuā le tuputupu a’e o laau e ta’ua o laumatui ua fai ma 

nofoaga tumau o gogo ma lagona leotele ai le fetalia’i o o latou leo i lalo o le malu o pupu laau. E 

feālumi nei leo o manu tagi ma le pāfuga o le ‘ā, o le tagi lea o le fua’ō, faatasi ai ma le tagi mai o le 

‘atafa, ma le uiō o le toloa. Ona o le taualoa tele o talatuu tau measina o lea motu ‘amu, ua teu fatu ai 

le naunauta’iga a tupulaga talavou e u’una’i pea le Faasamoa i se faagaoioiga malamalama toe 

manino ma avea ai i latou o ni tausimea i le taavili soifua o lea si’osi’omaga tūpito. I le vasa loaloa o 

i le Pasefika i Saute, o lo o pāpā’aveloa le soifua o le motu ‘amu o Rose ua avea ai o se motu iloga 

toe faailogaina na amata mai lava i lona anamua ma o lea ua avea o se taula’iga e faasinoala i 

su’esu’ega tau paiolo (biological), su’esu’ega o le eleele (geological), ma le talia lelei o eseesega tau 

aganuu mo Samoa atoa. 

Perched on an ancient volcano, reef corals, algae, and clams grow upwards thousands of feet on the 

foundation built by their ancestors over millions of years. Here, Rose Atoll National Wildlife Refuge 

glows pink in the azure sea. This diminutive atoll shelters a profusion of tropical life. Encircled by a 

rose-colored coralline algal reef, the lagoon teems with brilliant fish and fluted giant clams with hues 

of electric blue, gold, and dark teal. Sea turtles gracefully ply the waters and find safe haven 

lumbering ashore to lay eggs that perpetuate their ancient species. On land, stately Pisonia trees form 

a dim green cathedral where sooty tern calls echo as they fly beneath the canopy. Their calls join the 

cackling of the red-footed boobies, whinnying of the frigate birds, and moaning of the wedge-tailed 

shearwaters. Inspired by their living history at the atoll, tamaiti perpetuate Fa’a Samoa through an 

understanding and shared stewardship of their natural world. In the vast, deep South Pacific, Rose 

Atoll survives as a monument from the past and beacon for the future of biological, geological, and 

cultural diversity for all Samoa. 

1.10.2 Refuge Goals (Manulautī o le Faasao mo Meaola) 

Refuge management goals are descriptive, open-ended, and often broad statements of desired future 

conditions that convey a purpose, but do not define measurable units. Goals must support the refuge 

vision and describe the desired end result. The following are goals for Rose Atoll NWR. 
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Manulautī 1: Puipuia ma toe faaleleia nofoaga ‘ainā i le aloalo ina ia o gatasi ma tulaga moomia na 

iai ituaiga olaga faamauina o meaola eseese i lea lotoifale. 

Goal 1: Protect and maintain the lagoon habitats to meet the life-history needs of native species in 

this community. 

Manulautī 2: Fa’afo’isia, puipui, ma toe faaleleia le si’omaga e ola ai le ituaiga limu e ta’ua o le 

“crustose coralline algae” i le a’au ina ia ‘ausia tulaga moomia tau le faaolaolaga o meaola i ituaiga 

eseese o lo o i lea itulagi. 

Goal 2: Restore, protect, and maintain the perimeter crustose coralline algal reef to meet the lifehistory needs of native species in this community. 

Manulautī 3: Puipui ma toe faaleleia foliga ma tulaga masani o le ava e puipuia uma isi nofoaga ua 

‘ainā e meaola o le Faasao ma le aafia o le pala mātū ona o le fogāsami o lo o si’omia ai le aloalo. 

Goal 3: Protect and maintain the natural state of the channel (ava) to protect all other Refuge habitats 

and the hydrology of the lagoon. 

Manulautī 4: Fa’afo’isia, puipui, ma toe faaleleia le gataifale o lo o fai ma nofoaga o meaola o lea 

si’omaga ina ia o gatasi ma tulaga moomia na iai se ituaiga olaga faamauina o meaola eseese i lea 

lotoifale. 

Goal 4: Restore, protect, and maintain the beach strand habitat to meet the life-history needs of native 

species in this community. 

Manulautī 5: Fa’afo’isia, puipui, ma toe faaleleia nofoaga o lo o folasia i le oneone o le gataifale ina 

ia o gatasi ma tulaga moomia na iai se ituaiga olaga faamauina o meaola eseese i lea lotoifale e aofia 

ai laau, manufelelei o le sami, manufelelei e masani ona aumau i le nofoaga oneonea o le matafaga, 

manufelelei o le laueleele, manufelelei e aumau i se vai o i le laueleele, o ituaiga manu fetolofi e i le 

faatulagaga e faaperetania o “reptiles”, ma pa’a e maua i le pala mātū. 

Goal 5: Restore, protect, and maintain littoral forest to meet the life-history needs of native species in 

this community including plants, seabirds, shorebirds, landbirds, waterbirds, reptiles, and land crabs. 

Manulautī 6: Faamaopoopo faamatalaga faasaienitisi (faamaumauga tau tamaoaiga, vaavaaiga o le 

itu i fafo ma totonu, laulilīuga, ma su’esu’ega) e lagolagoa fa’ai’uga fai a le taupulega e pei ona 

folasia mai e manulauti 1-5. 

Goal 6: Gather scientific information (inventories, monitoring, assessments, and research) to support 

adaptive management decisions under objectives for Goals 1-5. 

Manulautī 7: Fa’atāua le faatoetoe o alagaoa ma opogi faatasi le faiva faatausimea e va’ava’alua ai 

ma tagata lautele e tusa ai o le si’osi’omaga o meaola uma, su’esu’ega tau le eleele, ma le tele o le 

tamaoaiga fa’aleaganu’u o le Faasao e ala i le faafoega o polokalama e feso’ota’i atu ai ma tagata 

lautele, o galuega tau faaliliu upu, ma a’oa’oga tau le si’osi’omaga. 

Goal 7: Strengthen resource conservation and the public’s shared stewardship of the ecological, 

geologic, and cultural richness of the Refuge by providing outreach, interpretation, and 

environmental education opportunities. 
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Manulautī 8: Faailoa ma’oti, puipui, faatoetoe, ma faaliliu tulaga tau alagaoa fa’aleaganu’u o le 

Faasao ma faafaigofie, pe a talafeagai ai, faagaoioiga fa’aleaganu’u. 

Goal 8: Identify, protect, preserve, and interpret the Refuge’s Samoan cultural resources and 

facilitate, where appropriate, cultural practices. 
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Chapter 2. Management Alternatives 2-1 

Chapter 2. Management Alternatives 

2.1 Alternatives Development 

During development of the alternatives for the Draft CCP/EA, the Service reviewed and considered a 

variety of resource, social, economic, and organizational aspects important for managing the Refuge. 

These biological, physical, and socio-economic conditions are described more fully in the following 

chapters. As is appropriate for a national wildlife refuge, resource considerations were fundamental 

in designing alternatives. House Report 105-106 accompanying the Improvement Act states “... the 

fundamental mission of our System is wildlife conservation: wildlife and wildlife conservation must 

come first.” 

Alternatives development by the planning team began by reviewing relevant plans, studies, and past 

and current research. We also held meetings with American Samoa and Federal agencies and elected 

officials, local villages, non-profit organizations, and others. Additionally, public scoping occurred 

during 2009 and over 60 people participated. This helped us to further identify issues and priorities to 

consider during alternatives development. We also provided planning updates throughout the 

development of this Draft CCP/EA, which allowed for public comment opportunities to assist with 

alternatives development. Further details of public involvement and participation can be found in 

Appendix J. 

2.2 Actions Considered but not Developed 

During development of the alternatives, the planning team considered the actions detailed below. 

Both of these actions were ultimately eliminated for the reasons provided. 

Tours. Commercial scuba diving and commercial or amateur photographic tours to the Refuge were 

considered and dismissed due to the safety hazard of navigating the entrance channel (ava). Such 

activities would also cause unacceptable levels of wildlife disturbance, threats of introduced species, 

and would require a level of on-site Service oversight currently unavailable in order to adequately 

manage the use. 

Fishing. Fishing in the Refuge, with contemporary, historic, or traditional gear for recreational or 

traditional use was considered and dismissed due to the small size of the lagoon and its limited fish 

and giant clam (faisua) populations. The ecological limits of these populations make them vulnerable 

to exploitation from fishing. Dismissing fishing as an alternative will maintain the value of the 

Refuge as an intact ecosystem for these populations, meet the Refuge’s purposes, fulfill the Governor 

of American Samoa’s support for no-take areas to protect the coral reef ecosystem, and supports the 

spirit of the Monument Proclamation which prohibits commercial fishing in the Monument. 

2.3 Alternative Descriptions 

2.3.1 Features Common to All Alternatives 

All alternatives contain some common features. These are presented below to reduce the length and 

redundancy of the individual alternative descriptions. 
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Access. The Refuge is closed to general public use and access in accordance with the Administration 

Act. The specific proposed uses of the Refuge are described in Appendices B and C. Specific 

requests to access the Refuge associated with proposed uses will be evaluated on a case-by-case basis 

and authorized through issuance of a Refuge Special Use Permit (SUP) by the Refuge/Monument 

Manager.

Adaptive management. Based on 522 Departmental Manual (DM) 1 (Adaptive Management 

Implementation policy), Refuge staff shall utilize adaptive management for conserving, protecting, 

and, where appropriate, restoring lands and resources. Within Title 43 of the CFR 46.30, adaptive 

management is defined as a system of management practices based upon clearly identified outcomes, 

where monitoring evaluates whether management actions are achieving desired results (objectives). 

Adaptive management accounts for the fact that complete knowledge about fish, wildlife, plants, 

habitats, and the ecological processes supporting them may be lacking. Adaptive management 

emphasizes learning while doing based upon available scientific information and best professional 

judgment considering site-specific biotic and abiotic factors on refuge lands and waters. Part of 

measuring the success of adaptive management in the Refuge also includes 5-year reviews and 15-

year revision of the CCP, which will be initiated by the Service and involve many of the same steps 

and engagement with partners and the public as the original CCP. 

Biosecurity measures. Refuge visitation protocols will continue to include strict biosecurity 

measures to prevent non-native introductions (e.g., rats, ants, scale insects, etc.) and impacts from 

reactive materials (e.g., iron). Anyone entering the Refuge (including staff) will be required to follow 

the written aquatic and terrestrial quarantine procedures used for all uninhabited refuges in the 

Pacific Reefs NWRC. Restrictions are designed to remove or kill pest species that may be in clothes 

or gear before they are taken to the Refuge. 

Cultural and historic resource protection. Cultural and historic resources on refuges receive 

protection and consideration in accordance with Federal cultural resources laws, Executive orders, 

and regulations, as well as policies and procedures established by the Department of the Interior 

(DOI) and the Service. Actions with the potential to affect cultural and historic resources will 

undergo a thorough review before being implemented, as is consistent with the requirements of 

cultural resource laws. All ground-disturbing projects will undergo a review (including but not 

limited to archaeological and cultural surveys) under Section 106 of the National Historic 

Preservation Act (NHPA). The Service will provide our Regional Historic Preservation Officer 

(RHPO) a description and location of all projects and activities that affect ground and structures, 

including project requests from third parties. Information will also include any alternatives being 

considered. We will also coordinate and consult with the American Samoa Historic Preservation 

Office (ASHPO) and the Office of Samoan Affairs (OSA) and seek assistance from Manu’a people 

on issues related to cultural resource education and interpretation, special programs, and the NHPA. 

Groundings. To deter ship groundings, we will develop targeted outreach materials and work within 

the international maritime community (e.g., International Maritime Organization), through 

appropriate U.S. agencies, to designate the Refuge as “area to be avoided.” Also, the Service will 

reinstall Refuge signage at Rose Atoll as well as improving information available to educate the 

sailing community about the Refuge’s closed status to yachtsmen, and other mariners at regional 

embarkation points (e.g., harbors in Samoa, French Polynesia). These points are where boaters may 

depart from, en route to other destinations, and may pass by the Refuge. 
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Implementation subject to funding availability. After the CCP is completed, actions will be 

implemented over a period of 15 years as funding becomes available. Draft project priorities and 

projected staffing/funding needs are included in Appendix D. 

Integrated pest management (IPM). In accordance with 517 DM 1 and 569 FW 1, an IPM 

approach would be used, where practicable, to eradicate, control, or contain pest and invasive species 

(herein collectively referred to as pests) on refuges. The IPM would involve using methods based 

upon effectiveness, cost, and minimal ecological disruption, which considers minimum potential 

effects to non-target species and the refuge environment. Pesticides may be used where physical, 

cultural, and biological methods or combinations thereof, are impractical or incapable of providing 

adequate control, eradication, or containment. If a pesticide would be needed on refuge lands or 

waters, the most specific (selective) chemical available for the target species would be used unless 

considerations of persistence or other environmental and/or biotic hazards would preclude it. In 

accordance with 517 DM 1, pesticide usage would be further restricted because only pesticides 

registered with the U.S. Environmental Protection Agency (EPA) in full compliance with the FIFRA 

and as provided in regulations, orders, or permits issued by EPA may be applied on lands and waters 

under refuge jurisdiction.

Environmental harm by pest species would refer to a biologically substantial decrease in 

environmental quality as indicated by a variety of potential factors including declines in native 

species populations or communities, degraded habitat quality or long-term habitat loss, and altered 

ecological processes. Environmental harm may be a result of direct effects of pests on native species 

including preying and feeding on them; causing or vectoring diseases; killing their young or 

preventing them from reproducing; out-competing them for food, nutrients, light, nest sites or other 

vital resources; or hybridizing with them so frequently that within a few generations few if any truly 

native individuals remain. Environmental harm also can be the result of an indirect effect of pest 

species. For example, decreased seabird reproduction may result from a pest killing native plants that 

provide nesting habitat. 

Environmental harm may involve detrimental changes in ecological processes. For example, 

cyanobacterial infestations can inhibit the growth of CCA which is a very important reef builder. 

This can lead to a situation where reef growth does not keep up with reef erosion, lowering the reef 

elevation and threatening the islands with ocean inundation. Environmental harm may also cause or 

be associated with economic losses and damage to human, plant, and animal health. 

Predator management is aimed at minimizing entry of non-native predators using quarantine 

protocols, exclusion, habitat modification, control, and eradication. For example, live trapping and 

use of bait stations could be used to eradicate illegally-introduced rats and mice. Predator and pest 

management will be conducted by Service personnel or contractors. 

See Appendix G for the Refuge’s IPM program documentation to manage pests for this CCP. Along 

with a more detailed discussion of IPM techniques, this documentation describes the selective use of 

pesticides for pest management on refuges, where necessary. Throughout the life of the CCP, most 

proposed pesticide uses on the Refuge would be evaluated for potential effects to biological 

resources and environmental quality. These potential effects would be documented in “Chemical 

Profiles” (see Appendix G). Pesticide uses with appropriate and practical best management practices 

for habitat management would be approved for use where there likely would be only minor, 

temporary, and localized effects to species and environmental quality based upon non-exceedance of 
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threshold values in Chemical Profiles. However, pesticides may be used where substantial effects to 

species and the environment are possible (exceed threshold values) in order to protect human health 

and safety. 

Partnerships. Partnerships are critical components in refuge management, including implementing 

such management as maintaining and restoring resources, conducting inventories and surveys, 

providing for cultural uses, and coordinating education and outreach opportunities. These important 

partnerships typically involve joining forces with the American Samoa Government (ASG) as well as 

other Monument partners, other Federal partners, villages, businesses, and non-governmental 

organizations in meeting common mission objectives. Some current examples of valued partnerships 

the Service would maintain include: 

Under all alternatives, the Service will maintain regular discussions with the ASG to coordinate on 

management of the Refuge. The Service will work with the DMWR to continue research, monitoring, 

education, outreach, interpretation, law enforcement, and management activities at the Refuge. We 

will continue to work with the OSA to facilitate and maintain appropriate relationships with people in 

the villages in Manu’a and Tutuila. The Service will also keep the ASDOC and the DMWR informed 

of activities through regular discussions and common forums such as the Coral Reef Advisory Group 

and the Rose Atoll Marine National Monument Intergovernmental Committee. 

The Service will maintain its partnership with the NOAA through its National Ocean Service, 

ONMS, NMFS’s Marine National Monument Program (MNMP), and Pacific Islands Fisheries 

Science Center (PIFSC) and its Coral Reef Ecosystem Division (CRED). The CRED provides 

intensive oceanography, water quality, habitat, biological population, and acoustic data as well as 

benthic habitat mapping as part of their Reef Assessment Monitoring Program (RAMP). The RAMP 

missions to the Refuge currently take place every 2 years (from 2002-2012), however, due to 

decreased funding, NOAA has proposed to scale back missions to every 3 years after 2012. The 

Service has also worked closely with DMWR since the creation of the Refuge for conducting 

biological monitoring and habitat restoration projects. The Service will also maintain its partnership 

with the U.S. Coast Guard (USCG). The USCG has provided a law enforcement presence by having 

vessels patrol the area, and through overflights of the Refuge. 

Additionally we have partnerships with the National Park Service (NPS), ONMS, U.S. Geological 

Survey, and the ASDOC. The NPS provides the Service office space and will assist with biological 

monitoring and habitat restoration projects in the future. We will also work closely with NPS on 

interpretation, environmental education (EE), and outreach (e.g., Refuge display in their visitor 

center). The Service is building a partnership with ONMS and ASDOC for their proposal to manage 

uses in the Monument surrounding the Refuge. The Service has overall management responsibility 

for the Monument in consultation with NOAA/NMFS. The proposed Muliava Unit of Fagatele Bay 

National Marine Sanctuary may overlay areas of the Monument, outside of the Refuge. 

Response capacity. Within 5 years, create response capacity to minimize trespass and poaching 

using outreach, education, remote sensing, law enforcement, and other methods (e.g., evaluate the 

possibility of enforcement officers from Manu’a, formalize partnership with USCG for surveillance). 

Vessel. The Service will acquire a vessel, part ownership in a vessel, or long-term vessel charter 

contract to assist with management actions, law enforcement, and monitoring. 
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Wilderness review. The Service’s CCP policy requires that a wilderness review be completed in all 

CCPs. A wilderness review determines if an area is eligible to be added to the National Wilderness 

Preservation System. This review consists of three phases: wilderness inventory, wilderness study, 

and wilderness recommendation. If it is determined that the area meets the minimum requirements 

for wilderness, the process moves on to the wilderness study phase. As part of the process for this 

Draft CCP/EA, the team completed a wilderness inventory which can be found in Appendix E. This 

review concluded that the Refuge is suitable to move on to the wilderness study phase. At the time of 

writing this Draft CCP/EA, a Draft Legislative Environmental Impact Statement was in the process 

of being drafted for all eligible National Wildlife Refuges in the Hawaiian and Pacific Islands 

National Wildlife Refuge Complex in preparation for public and partner review after a public 

scoping comment period was concluded. 

2.3.2 Summary of Alternatives 

Both alternative describes a combination of management actions designed to achieve the Refuge 

purposes, vision, and goals. These alternatives provide different ways to address and respond to 

management concerns, major public and partner issues, and opportunities identified during the 

planning process. They also reflect the direction in the Administration Act, Service policies, and 

legal mandates outlined in Chapter 1. A summary of the key differences between the alternatives is 

presented in Table 2-.1. A brief description as well as accompanying map of each alternative follows. 

2.3.2.1 Alternative A: No Action (Current Management) 

This alternative assumes little to no change (based on existing initiatives the Service is already 

moving forward with) in current management programs and is the base from which to compare the 

other alternative. 

Wildlife and habitat. The Service protects, maintains, and restores habitat for priority species, 

including seabirds, shorebirds, turtles, native plants, reef fish, invertebrates (including coral), and 

coralline algae. The Refuge is closed to the general public and entry is limited to those who have 

been issued a SUP. 

The Refuge is extremely remote, being 180 miles from Tutuila. Therefore, it requires a very 

seaworthy vessel for the full day trip and is very expensive and logistically challenging. Because of 

this, trips to the Refuge by managers and biologists have been limited to once a year or once every 2 

years, and last from 3 days to 3 weeks. These trips have been undertaken by Refuge Complex staff 

based out of Honolulu and include rapid ecological assessments (REA) for wildlife and ecosystem 

monitoring, pest species management, and restoration projects including the removal of debris from a 

1993 shipwreck. It was not until 2011 that the Refuge had a full-time staff member. The new Refuge 

Manager (who is also the Monument Manager) is responsible for on-site management as well as 

coordination with all partners. 

Refuge management is aided by our partnership with the CRED, which collects bathymetry data and 

monitors water quality, coral reef habitat, and fish populations; as well as our partnership with the 

DMWR, which monitors fish and wildlife populations and conducts habitat restoration projects with 

Refuge staff. 
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Outreach, interpretation, and environmental education. The Refuge maintains a Website where 

general information materials can be found. An interpretive display about Rose Atoll that was housed 

with the American Samoa National Park was lost in the 2009 tsunami. 

Cultural resources. In 2011, village chiefs, students, and teachers and staff from the Samoan 

Studies Institute visited the Refuge in conjunction with a MNMP grant to DMWR for the Monument. 

The information gathered by SSI would be used to develop video and printed materials for 

interpretation and educational use, including cultural resources. 

2.3.2.2 Alternative B: Preferred –Enhanced Habitat Restoration, Monitoring, and 

Outreach 

This alternative is the preferred because it improves habitat management for native species, improves 

our understanding of the status and trends of wildlife and habitat on the Refuge, and provides 

increased opportunities for public engagement to help protect and manage the Refuge. A vessel 

contract that provides for at least 2 visits per year of at least 5 days in duration would allow more 

regular and predictable access for understanding the health of Refuge resources and completing 

project work. 

Wildlife and habitat. In addition to continuing activities in Alternative A, implementing this 

alternative would enhance protection and management of resources with improved monitoring, law 

enforcement, and an enhanced understanding of the atoll. By visiting at least twice annually, the 

quality and quantity of monitoring efforts would be increased. This would allow the creation of a 

database and time series to aid management decisions. In addition to increasing the frequency of 

management trips to the Refuge it would fortify close partnerships with our ASG partners. A remote 

sensing system (e.g., automated camera) would be set up to monitor nesting seabirds, turtles, and 

other wildlife. More frequent visits would improve information for law enforcement, provide a 

presence to deter illegal activity, and remote sensing would also provide better management and 

documentation of unauthorized entry into the Refuge. 

We would explore restoration of the littoral forest on Rose Island by extirpating the introduced scale 

insect (Pulvinaria urbicola) and propagating native forest trees. Other pest species would be detected 

and controlled or eradicated with regular monitoring and a rapid response program. We would 

continue the restoration effort from the 1993 ship grounding through consistent surveying of the 

wreck site and removing any debris and continued monitoring. 

Several of our strategies also recognize the potential impact climate change may have on Rose Atoll. 

We propose increased monitoring and data collection to better understand these impacts throughout 

the life of this 15-year plan. Our proposed management actions aim to maintain and restore habitats 

and species to strengthen their resiliency, sustainability, and adaptability to meet such challenges. 

Attributes for each objective indicate the desired status of that habitat at the time of Refuge 

management visitation. 

Outreach, interpretation, and environmental education. Refuge staff would provide outreach and 

interpretation opportunities and develop an EE program for American Samoa schools. We would 

develop programs to inform elected officials, students, and the general public of American Samoa 
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about the ecology of Rose Atoll and the mission of the Service. We would work closely with our 

partners to develop complementary interpretive displays for visitor’s centers. 

Cultural resources. We would expand Refuge management related to cultural resource management 

by working with the ASHPO, OSA, and other partners to conduct archaeological surveys at Rose 

Atoll, integrate cultural resources into interpretation and EE, and improve dialogue with Manu’a 

villages. We would also work with local officials to facilitate appropriate cultural practices. 

Table 2-1. Summary of Alternatives by Issue 

Key Themes Objectives Alternative A (Current 

Management) 

Alternative B 

(Enhanced Habitat 

Restoration, 

Monitoring, and 

Outreach) 

Lagoon Habitat 1.1 Protect and maintain 

the lagoon habitats 

Work with partners to 

continue collecting data 

on bathymetry, water 

quality, and species 

diversity 

In addition to 

Alternative A, develop 

and implement 

monitoring protocols for 

fish, corals, other 

invertebrates, and 

marine pests to manage 

populations as needed; 

install remote sensing to 

monitor resources and 

document illegal boat 

traffic 

Perimeter Reef 2.1 Restore, protect, and 

maintain the perimeter 

reef 

Monitor cyanobacterial 

cover which greatly 

increased in response to 

the 1993 shipwreck, 

continue to remove 

debris 

In addition to 

Alternative A, develop 

reef monitoring program 

Ava 3.1 Protect and maintain 

the ava 

Work with partners to 

continue collecting data 

on water flow and 

bathymetry 

In addition to 

Alternative A, survey 

for predator and prey 

fish species 

Beach Strand 4.1 Restore, protect, and 

maintain the beach 

strand 

Restore tamole 

(Portulaca lutea) 

In addition to 

Alternative A, prepare 

and implement a 

monitoring plan and 

rapid response program 

for terrestrial non-native 

species 

Littoral Forest 5.1 Restore, protect, and 

maintain littoral forest 

Monitor seabirds and 

control niu (Cocos 

nucifera) 

In addition to 

Alternative A, restore 

native littoral forest, and 
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Key Themes Objectives Alternative A (Current 

Management) 

Alternative B 

(Enhanced Habitat 

Restoration, 

Monitoring, and 

Outreach) 

improve monitoring of 

seabirds, vegetation, and 

pest species 

Inventory, Monitoring, 

and Research 

6.1 Conduct high 

priority inventory and 

monitoring (survey) 

activities and scientific 

assessments 

Work with partners to 

continue monitoring 

water quality, 

bathymetry, species 

distribution, and habitat 

associations 

In addition to 

Alternative A, improve 

the quality and quantity 

of monitoring efforts by 

monitoring more often, 

creating standardized 

protocols and 

management databases 

6.2 Conduct high 

priority research 

Limited research Increase research as part 

of restoration efforts for 

habitats and wildlife 

populations 

Outreach, 

Interpretation, and 

Environmental 

Education (EE) 

7.1 Enhance and expand 

interpretation and 

outreach 

Maintain Website; 

participate in 

community events 

In addition to 

Alternative A, develop 

more interpretive 

opportunities with our 

partners 

7.2 Develop EE No EE program Develop an EE program 

Cultural Resources 8.1 Protect and 

perpetuate cultural 

resources related to 

Rose Atoll 

Work with partners to 

create information 

materials 

In addition to 

Alternative A, 

inventory, restore, and 

maintain cultural 

resources and work with 

local representatives to 

facilitate appropriate 

cultural traditions 

related to Rose Atoll 
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Figure 2-1. Alternative A. 
Rose Atoll National Wildlife Refuge 

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The back sides of maps are blank to improve readability. 
Rose Atoll National Wildlife Refuge 

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Figure 2-2. Alternative B. 
Rose Atoll National Wildlife Refuge 

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The back sides of maps are blank to improve readability. 
Rose Atoll National Wildlife Refuge 

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2.4 Goals, Objectives, and Strategies 

A CCP describes management actions that help bring a refuge closer to its vision. A vision broadly 

reflects the refuge purpose(s), the Refuge System mission and goals, other statutory requirements, 

and larger-scale plans as appropriate. Goals then define general targets in support of the vision, 

followed by objectives that direct effort into incremental and measurable steps toward achieving 

those goals. Strategies identify specific tools and actions to accomplish objectives (USFWS and 

USGS 2004). 

Goals and objectives are the unifying elements of successful refuge management. They identify and 

focus management priorities, resolve issues, and link to refuge purposes, Service policy, and the 

Refuge System mission. 

The draft goals for the Refuge for the 15 years following completion of the CCP are presented on the 

following pages. Each goal is followed by the objectives that pertain to it. All objectives are for the 

lifetime of the CCP unless otherwise specified. Some objectives pertain to multiple goals and have 

simply been placed in the most appropriate spot. Similarly, some strategies pertain to multiple 

objectives. The goal order does not imply any priority in this CCP. Priority actions are identified in 

the staffing and funding analysis (see Appendix D). 

Readers, please note the following: 

The objective statements as written apply to the Service’s Preferred Alternative. Below each 

objective statement are the strategies that could be employed in order to accomplish the objectives. 

Note the following: 

 Check marks (✓ ) alongside each strategy show which alternatives include that strategy; and 

 If a column for a particular alternative does not include a check mark for a listed strategy, it 

means that strategy would not be used in that alternative. 

Other symbols used in the following tables include: 

~ Approximately; 

% Percent sign; 

> Greater than; 

< Less than; 

> Greater than or equal to; and 

< Less than or equal to. 
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2.4.1 Goal 1: Protect and maintain the lagoon habitats to meet the life-history 

needs of native species in this community. 

Objective 1.1 Protect and maintain the lagoon habitats. 

Protect a maintain lagoon reef habitats to provide the following attributes: 

 547 acres of shallow (<100 feet) water lagoon habitat to meet life-history requirements of all 

existing native members of the lagoon community. See Appendix A for species listings; 

 Natural flow of marine water with quality measures of pH, salinity, temperature, nutrients, 

chlorophyll-a, that are appropriate to maintain native organisms in the lagoon community; 

 Benthic bottom cover of sand interspersed with patch reefs, limestone blocks, and pinnacles 

providing a variety of substrates and rugose structure to provide habitat for lagoon species;

 Species diversity including algae, fish, turtles, and invertebrates including reef-building corals 

and reef-building crustose coralline algae; 

 Lagoon free of debris; and

 Minimal human disturbance. 

Strategies Applied to Achieve Objective: Alt A 

(Current) 

Alt B 

(Preferred) 

Work with partners to collect bathymetry data every 10 years in order to 

document changes in the lagoon, reef, or ava that could affect 

hydrography or habitat characteristics (see Objective 6.1) 

 

Work with National Oceanic Atmospheric Administration’s (NOAA) 

Coral Reef Ecosystem Division (CRED) and other partners to collect 

oceanographic and water quality data in order to track changes that could 

affect the reef or wildlife (see Objective 6.1) 

 

Work with partners to conduct Rapid Ecological Assessment (REA) to 

document habitat associations and species distribution, density, and 

diversity in marine habitats (see Objective 6.1) 

 

Identify, prioritize, and implement restoration needs such as debris 

removal in lagoon habitats affected by anthropogenic impacts such as iron 

contamination from shipwrecks 

 

Within 5 years, develop and implement monitoring protocols to track 

populations of focal lagoon species including: fish, corals, giant clams 

(faisua), other invertebrates, and marine pests to determine abundance, 

density, and biomass of each at selected sites (see Objective 6.1) 



Within 10 years characterize nutrient budgets and dynamics at Rose Atoll 

and evaluate them relative to data from other similar reef sites to identify 

possible stressors and the positive effects of healthy seabird colonies 

adjacent to living reefs (see Objective 6.2) 



Within 4 years, install remote sensing systems to document boat traffic in 

the lagoon 


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Rationale: In the middle of an ocean that is mostly over 

10,000 feet deep, the lagoon provides 547 acres of 

shallow water habitat (< 100 feet deep). The reef protects 

this lagoon from the large swells of the open ocean, and 

light is able to penetrate to the bottom so corals and other 

sea life can thrive. While the deepest part of the lagoon 

has a simple sand bottom, sections on the edge have coral 

pinnacles which grow up close to the surface providing 

excellent habitat for faisua (Tridacna maxima). This 

shallow lagoon hosts a unique assemblage of fish and the 

largest population of faisua in American Samoa. These 

giant clams are listed under CITES and have suffered 

serious depletion throughout their range due to over-harvesting. While it can provide larval fish 

recruitment for the other Samoan Islands, the small size of the lagoon and its limited fish and 

invertebrate community make it particularly susceptible to fishing pressure. 

Monitoring fish and invertebrate abundance and biomass as well as abiotic factors is critical so we can 

assess if the Service is maintaining the biological integrity, diversity, and environmental health of the 

lagoon (see Goal 6). Monitoring is key to refining the metrics in the attributes (which currently reflect 

how little is known at present about this habitat). Ongoing restoration efforts emphasize removal of 

debris and monitoring the cyanobacterial bloom. We would also pursue installing a remote sensing 

system to document unauthorized boat traffic in the lagoon since such traffic could involve unregulated 

fishing or damage other Refuge resources. 

2.4.2 Goal 2: Restore, protect, and maintain the perimeter crustose coralline 

algal reef to meet the life-history needs of native species in this community. 

Objective 2.1 Restore, protect, and maintain the perimeter crustose coralline algal reef. 

Restore, protect, and maintain the perimeter crustose coralline algal reef (CCA) to support habitats and 

species with the following attributes: 

 Healthy living reef dominated by CCA (Porolithon spp.) in a mosaic with small corals forming a 

network of pools and raised areas that provide habitat for reeftop organisms; 

 Geomorphic structure intact with elements of rugosity and a mosaic of microhabitats;

 Boring sea urchins (Echinometra, Echinostrephus spp.) are present in at least 50% of available 

holes along the entire seaward margin of the perimeter reef; 

 Holes that can be occupied by boring sea urchins are present at a density of at least 1/m2 in the 

“urchin zone” along the entire seaward margin of the perimeter reef; 

 CCA are present in 80% of sampling sites and occupy >25% of total solid substratum; 

 Cyanobacteria (Lyngbya, Oscillotoria, Symploca, Calothrix spp.) are rare (<5% total cover) 

 The erect coralline alga Jania adherens, and the mat forming green alga Codium spp., are rare 

(i.e., present in < 5% of sample sites); 

 CCA characterized as eroded is not a prominent cover type and the proportion of this type does 

not fluctuate significantly between surveys; 

 Variation in cover of crustose corallines is primarily due to reef position (i.e., fore, mid, or inner 

Goatfish in lagoon. Jim Maragos, USFWS. 
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reef), reflecting the wave energy and structural gradients across the reef flat; and 

 100% removal of manmade debris including fishing gear and metallic debris from shipwrecks. 

Strategies Applied to Achieve Objective: Alt A 

(Current) 

Alt B 

(Preferred) 

Continue monitoring abundance and distribution of the cyanobacterial 

community which became dominant on a section of the southwest arm of 

the atoll due to elevated iron levels following a 1993 shipwreck (see 

Objective 6.1) 

 

Within 5 years, work with partners to develop and implement reef 

monitoring program, including rate of growth, elevation change, chemical 

composition and other variables related to reef growth and the atoll’s 

ability to maintain itself in an anticipated environment of climate change 

and ocean acidification (see Objective 6.1) 



Within 5 years, develop and implement monitoring protocols to track 

abundance and distribution of focal perimeter reef species including eels 

and urchins to determine abundance, density, and biomass of each at 

selected sites (see Objective 6.1) 



Monitor benthic succession of the reef which was damaged due to the 

1993 shipwreck (see Objective 6.1) 



Within 2 years, establish systematic marine debris removal program 

Rationale: The reef crest of Rose Atoll has a pink 

hue because it is primarily composed of CCA. It 

varies between 1,000–3,000 feet wide and has a 

single channel connecting the inner lagoon with the 

open ocean. Waves can break hard over the reef 

crest, but during low tides it can be completely 

exposed. Several of the dominant species of algae 

on this reef (Porolithon onkodes, P. craspedium, 

and P. gardineri) are reef-building organisms that 

form a strong and resilient reef platform upon which 

all the other shallow water organisms depend. Two 

other cover types on the reef platform are a coralline 

red algae Jania spp. that forms turfs rather than a 

crust, and areas of eroded and dead coralline algae that are bare reef matrixes without macroscopic algae 

present. 

In 1993 a fishing vessel ran aground on the southwest arm of the reef and broke apart. The vessel 

released roughly 100,000 gallons of fuel, 500 gallons of oil, and 2,500 pounds of ammonia into the 

environment. This killed a large area of CCA, and facilitated a population explosion of cyanobacteria 

and non-reef building algae. Major salvage operations began 6 weeks after the wreck and continued until 

2007 due to the large tonnage of metal and the difficulty of working on a remote atoll. The ship rocking 

back and forth in the waves physically damaged the reef by grinding it away. Because iron is a limiting 

nutrient at remote oceanic atoll locations, the increased iron levels have to a drastic increase in several 

species of cyanobacteria (Symploca spp., Oscillatoria spp., Lyngbia spp., and Calothrix spp.) and turf 

forming forms of coralline algae near the shipwreck site. These species are not reef building organisms, 

Reef crest spillway. Jim Maragos, USFWS. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 2. Management Alternatives 2-17 

and in places where they grow in thick mats, reef 

building corals and CCA cannot compete, so the reef 

can begin to erode. These species initially formed a 

carpet, covering large sections of the reef near the 

wreck. It is vital to control them in order to maintain 

the reef. 

Though the vast majority of the ship has been 

removed and the area recovering, there are likely 

scattered pieces on the fore reef continuing to release 

iron into the water and promoting the growth of 

cyanobacteria. This, combined with the acute effects 

of the initial spill and the physical destruction of the 

reef by the ship, has seriously damaged the CCA near the shipwreck site and recovery efforts would be 

ongoing. 

It is vital to maintain the living coralline algae on these perimeter reefs because they form a growing 

platform that is resistant to physical and bio-erosion upon which all the shallow water and terrestrial 

organisms at the Refuge depend. The focal species of urchins serve as indicators of the state of the reef 

on areas least affected by the shipwreck and areas where subsequent urchin mortality resulted from 

spilled fuel and cyanobacterial overgrowth. Densities of peppered morays foraging on the reef flat also 

are an indication of the productivity and health of that habitat. As identified in Figure 1-2 in Chapter 1, 

the perimeter reef where this work would occur is the exterior boundary of the Refuge which is the 

extreme low waterline outside the perimeter reef. 

2.4.3 Goal 3: Protect and maintain the natural state of the channel (ava) to 

protect all other Refuge habitats and the hydrology of the lagoon. 

Objective 3.1 Protect and maintain the ava. 

Protect and maintain the natural state of the ava to support habitats and species with the following 

attributes: 

 Unobstructed water flow between the lagoon and the ocean;

 Geomorphology that supports hydrology of the atoll; and 

 Species diversity and biomass of reef builders and reef dwellers, including large predator and 

prey fishes, remains high. 

Strategies Applied to Achieve Objective: Alt A 

(Current) 

Alt B 

(Preferred) 

Within 5 years, work with partners to monitor water flow rate and 

direction in the ava using archival pressure and flow rate instruments 

that can be downloaded at every visit in order to document any changes 

in flow through the ava (see Objective 6.1)

 

Work with partners to collect bathymetry data every 10 years in order to 

document changes in the lagoon, reef, or ava which could affect 

hydrography or habitat characteristics (see Objective 6.1) 

 

Grounded vessel. USFWS. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

2-18 Chapter 2. Management Alternatives 

Within 5 years, develop and implement monitoring protocol to track 

abundance and biomass of fish, including predatory and prey fish 

species, around the opening of the ava to detect any changes in structure 

or function of this important geological feature for large predators in the 

Refuge (see Objective 6.1) 



Work toward the inclusion of better warnings about the hazard to 

mariners of waters in and near the ava to prevent vessel groundings, and 

improve public communications about the Refuge being closed 



Rationale: The shape, size, and location of the ava are vital to maintaining the lagoon, reef, and island 

habitats. The ava is a small, direct connection between the lagoon and the open ocean. As ocean water 

spills into the lagoon over the sides of the reef, it is released out through the ava. Though water usually 

flows out the ava, tides and waves occasionally create a situation where water flows into the lagoon 

through the ava. The elevation of the ava controls the water movement out of the lagoon, and plays a 

major role in the layering of lagoon water by temperature and salinity. Additionally, the shape and 

location of the ava is an important factor in the location and longevity of the islands on the atoll. Water 

movement inside the atoll creates currents that remove sand from some areas and deposit it in other 

areas. This sediment transport regime has created and maintained Rose and Sand Islands as islands 

dynamic in size and shape but located in roughly the same location since Rantzau mapped Rose Atoll in 

1873 (Rodgers et al. 1993). The ava is also the major passageway for fish and other organisms in and out 

of the lagoon, where species that require more shelter from rough water to breed or live may 

concentrate. Sharks and other predators congregate at the mouth of the ava waiting for prey. For these 

reasons, it is vital to protect and maintain the ava because it is fundamental to the functioning of many 

systems in Rose Atoll. Though there are currently no known threats to the ava and it is stable, given 

potential climate change impacts, constant alertness to changing conditions is important. As identified in 

Figure 1-2 in Chapter 1, the ava where this work would occur is the exterior boundary of the Refuge 

where the boundary line is extended between the extreme low waterlines on each side of the entrance 

channel.

2.4.4 Goal 4: Restore, protect, and maintain the beach strand habitat to meet 

the life-history needs of native species in this community. 

Objective 4.1 Restore, protect, and maintain beach strand habitat for shorebirds, ground nesting 

seabirds, and nesting turtles. 

Restore, protect, and maintain >3 acres of the beach strand on Sand and Rose Islands to support habitats 

and species with the following attributes: 

 Open ground maintained, with native plants (e.g., tamole) occupying the edge between beach 

strand and littoral forest; 

 Free of terrestrial non-native predators and other non-native animals; and 

 Free of pest and non-native plants. 

Strategies Applied to Achieve Objective: Alt A 

(Current) 

Alt B 

(Preferred) 

Within 2 years, use GPS to map the perimeter of the islands at high and 

low tide on each visit to the Refuge and obtain any available satellite 

imagery for incorporation into GIS in order to document changes in island 

size and location (see Objective 6.1) 


Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 2. Management Alternatives 2-19 

Within 15 years, restore and protect native coastal plants using best 

available information about original indigenous ecosystem. Restore native 

tamole (Portulaca lutea; a native yellow purslane) population that was 

extirpated on Rose Atoll by introduced rats (Rattus exulans) but survived 

on an offshore coral block. Monitor survivorship, growth, and maturation 

of planted tamole (see Objective 6.1) 





Within 10 years, investigate the ecological relationships between marine 

gastropods such as turban shells (Turbo spp.), and land hermit crabs 

(Coenobita perlatus and C. brevimanus). Evaluate factors affecting crab 

populations, including observed reduction in availability of shells to crabs 

at the Refuge and what management may improve mollusk shell 

availability to the Coenobita spp. which are important scavengers and 

herbivores on both islands (see Objective 6.2) 



Within 5 years, work with universities and other partners to evaluate the 

geomorphology, hydrology, and sediment budget of Rose Atoll to 

understand the processes that have maintained the islands as dynamic units 

(see Objective 6.2) 



Within 6 months, revise existing biosecurity measures to comprehensively 

address prevention of introducing non-native pest species to the atoll 



Within 2 years, prepare and implement a monitoring plan and rapid 

response program for terrestrial non-native species and respond

immediately if detected (see Objective 6.1)



Within 2 years, working with NOAA/NMFS and other partners, develop 

and implement monitoring protocol to track turtle abundance and 

movements using field counts, tagging, remote sensing, and satellite 

telemetry (see Objective 6.1) 



Within 5 years, working with NOAA/NMFS and other partners, develop a 

cooperative management plan with Fiji to protect shared stocks of 

threatened green turtles that migrate between Rose Atoll (to nest) and Fiji 

(to feed). Meet with appropriate Fiji managers as needed 



Rationale: Beach strand is a very dynamic habitat that is constantly being reshaped by the wind, waves, 

currents, and tides. Likely this will be exacerbated by climate change with more storms, changes in sea 

level, and coral. All of Sand Island can be classified as beach strand, as can the sandy section of Rose 

Island between the water and the vegetation. During a storm, beach strand habitat can change 

dramatically, but when conditions are right, it reforms quickly and is stable in the long run. This is the 

case with the beach strand habitats of the Refuge. After any given storm the islands may change size and 

shape, but since the area was mapped by Rantzau in 1873 (Rodgers et al. 1993) the location and total 

area of the islands has remained surprisingly stable. 

Because the Refuge provides beach strand habitat free of predators since the 1993 eradication of 

Polynesian rats (Rattus exulans) and is far from human populations, it is ideal foraging habitat for 

wintering shorebirds and nesting habitat for seabirds and green turtles, and possibly hawksbill turtles. 

The beach strand is used extensively by nesting sooty terns, brown noddies, brown boobies, and green 

turtles. The Refuge provides the only known rat-free area in American Samoa for several of these 

ground-nesting species. Part of enhancing this habitat for these birds and fulfilling BIDEH, is restoring 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

2-20 Chapter 2. Management Alternatives 

previously extirpated plants such as the tamole. It is a 

rare plant that used to exist on the beach strand habitat. 

Ghost crabs (Ocypoda spp.) forage and dig their 

burrows in the beach strand as well. The land hermit 

crabs Coenobtia perlatus and C. brevimanus are 

numerically and ecologically important in the terrestrial 

ecosystem of Rose Atoll, serving as the dominant 

herbivores and scavengers of the system. Densities of 

these two species have decreased markedly since 1991 

and biologists visiting the Refuge have noticed a change 

in the condition and type of the marine gastropod shells 

that the crabs are using for their homes. There seem to 

be fewer of the preferred shells in the genus Turbo and those that are being used have more damage and 

wear. Substitutes such as the partridge tun (Tonna perdix) shells are more fragile and presumably offer 

less protection. 

Tagging data demonstrates that Rose Atoll and Fiji share 

a common stock of green turtles. After nesting at Rose 

Atoll, the turtles migrate directly to Fiji to feed on 

extensive seagrass beds there (there is little seagrass in 

American Samoa). A comprehensive recovery plan 

requires protection at both its nesting and feeding 

destinations of this species. While turtle harvesting is 

prohibited in Fiji, enforcement there is difficult due to 

the hundreds of small islands and remote villages, thus 

poaching is considered a serious threat. Green turtles are 

a threatened species with a very small population size at Rose Atoll (est. 24-36 nesting females). 

In order to maintain the beach strand as a naturally occurring dynamic habitat which benefits many 

species, we would control any plant or animal pest species, and monitor the size and shape of the islands 

to ensure they are maintaining themselves under changing climatic conditions. 

2.4.5 Goal 5: Restore, protect, and maintain littoral forest to meet the lifehistory needs of native species in this community including plants, seabirds, 

shorebirds, landbirds, waterbirds, reptiles, and land crabs. 

Objective 5.1 Restore, protect, and maintain littoral forest. 

Restore, protect, and maintain 15 acres of the littoral forest with the following attributes: 

 Forest species composition includes a mixture of pu’a vai (Pisonia grandis), taukanave (Cordia 

subcordata), tausuni (Tournefortia argentea), fotulona (Hernandia nymphaeifolia), talie 

(Terminalia samoensis), fao (Neisosperma oppositifolium), fau (Hibiscus tiliaceus), and all 

other indigenous species that recruit through natural means and resembling comparable islands 

in the region that have not been previously affected by rats; 

 <5% introduced niu (Cocos nucifera) cover of total vegetated area;

Tava’e’ula (red-tailed tropic bird). Kelsie 

Ernsberger, USFWS. 

Turbo shell used by crab. USFWS. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 2. Management Alternatives 2-21 

 Free of introduced terrestrial non-native predators and other non-native animals; and 

 Free of pest and non-native plants. 

Strategies Applied to Achieve Objective: Alt A 

(Current) 

Alt B 

(Preferred) 

Within 2 years, prepare a monitoring and rapid response program for 

terrestrial non-native species and respond immediately if detected 

(see Objective 6.1) 



Maintain cover of introduced niu (coconut palms [Cocos nucifera]) 

at or below 5% using mechanical or direct application of herbicides 

as appropriate (see Appendix G)

 

Within 2 years, review existing vegetation community distribution 

data and develop GIS database of terrestrial and marine habitats and 

update them every 5 years (see Objective 6.1) 



Within 3 years and working with experts, prepare a restoration 

design that identifies which desired species would require active 

propagation and outplanting and which would recruit naturally now 

that rat herbivory has been eliminated. Part of this strategy would be 

to work with universities and other partners to investigate 

composition and structure of terrestrial communities on Rose Island 

prior to the introduction of rats to inform ecological restoration 

activities (see Objective 6.2)



Within 4 years, develop and implement a monitoring protocol to 

track changes in numbers, cover, and basal area of different plant 

species (see Objective 6.1)



Within 5 years, implement restoration design and begin outplanting 

vegetation 



Continue monitoring presence or absence of breeding bird 

populations (annually or less often depending on visit schedule to 

the Refuge) as one indicator of the success of habitat restoration 

measures 



Within 3 years, develop and implement a monitoring protocol to 

track seabird abundance, nesting rates, and feeding territories. 

Include remote sensing observations to improve future monitoring 

efforts (see Objective 6.1) 



Within 10 years, eradicate the scale insect (Pulvinaria urbicola) and 

any other non-native insects, specifically focusing on eradicating 

introduced ant species that facilitate scale growth and spread 


Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

2-22 Chapter 2. Management Alternatives 

Rationale: The tropical wet littoral forest ecotype has 

become very rare in the Pacific Islands due to the value of 

mesic coastal sites for human habitation. There are no 

records of the species composition of the forest on Rose 

Island prior to the introduction of Polynesian rats. When 

first described, Rose Island had a native plant community 

made up of only pu’a vai, tamole, and ufi’atuli (Mayor 

1921, Setchell 1924, Satchet 1954) and the introduced niu. 

Presently, the forest is dominated by tausuni but this is a 

recent change in forest community. Tausuni was not 

recorded on Rose Island until 1970 (Swerdloff and 

Needham 1970) but is a good saltwater disperser and often 

recruits on sandy islets throughout the tropical Pacific. 

Tausuni is indigenous to the Pacific and provides habitat 

for tree-nesting seabirds. Since rats were eradicated at the 

Refuge in 1993, the plant community has been released 

from this source of seed and seedling herbivory so 

propagules from indigenous Samoan plants that wash 

ashore are now able to survive, increasing the total number 

of species present to at least eight. Factors leading to the 

decline of the pu’a vai forest and subsequent dominance of 

tausuni include hurricane damage from six significant storms since 1987, and the introduction of the 

scale insect. In March 2011, there were only three very unhealthy large pu’a vai trees remaining on Rose 

Island but a number of seedlings and saplings survive.

The littoral forest on Rose Island provides nesting habitat for the majority of seabird species in the 

Refuge as well the Pacific reef heron. Various seabirds nest in different parts of the forest with some 

nesting in the trees and others nesting on the ground. Niu have been planted on Rose Island on several 

occasions (Satchet 1954). While early attempts to establish niu failed (perhaps due to the presence of the 

rat), there is presently a thriving population that is spreading rapidly. If no efforts are made to control 

the niu, it is very possible they would become the dominant vegetation on Rose Island. This would be 

highly detrimental to seabird populations since the straight trunks of nui do not provide places to build 

nests, and falling coconuts can crush birds. While eradication of nui is a possibility, it is desirable to 

maintain a small nui grove due to their importance in Samoan culture. 

Invasive ants, including Pheidole megacephala and Tetramorium bicarinatum, are known to occur on 

Rose Atoll. These ants are severely disrupting the ecology of the atoll, including facilitating an outbreak 

of Pulvinaria urbicola, an invasive scale insect responsible for killing Pisonia grandis trees. These 

aggressive, predatory ants are also likely reducing numbers of arthropods native to the atoll. Once ants 

are removed, natural enemies of the scale, such as predaceous beetles and parasitic wasps that may now 

be prevented from attacking the scale by the ants, would be expected to increase in number and to 

reduce scale abundances to a level better tolerated by Pisonia. Pisonia trees are declining throughout 

their range, and the eradication of ants would facilitate the removal of Pulvinaria scale and help in the 

recovery of an isolated Pisonia forest. 

The goal of restoring and maintaining the littoral pu’a vai forest community would be a long-term 

project involving the eradication of non-native or invasive species, the propagation and planting of 

native forest tree seedlings, and an in-depth monitoring program so we can track the effectiveness of 

restoration efforts. 

Fua’o nesting in Pisonia. USFWS. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 2. Management Alternatives 2-23 

2.4.6 Goal 6: Gather scientific information (inventories, monitoring, 

assessments, and research) to support adaptive management decisions under 

objectives for Goals 1-5. 

Objective 6.1 Conduct high priority inventory and monitoring (survey) activities and scientific 

assessments. 

Conduct inventory and monitoring (survey) activities that evaluate resource management activities to 

facilitate adaptive management. These surveys contribute to the enhancement, protection, preservation, 

and management of wildlife populations and their habitats on and off Refuge lands. Specifically, they 

can be used to determine if we are meeting resource management objectives identified under Goals 1-5. 

These surveys have the following attributes: 

 Long-term monitoring that centers on focal species population status and trends in order to 

determine if the Refuge is sustaining biological integrity, diversity, and environmental health at 

current levels; 

 Projects would adhere to scientifically defensible protocols for data collection; 

 Data collection techniques would require minimal animal mortality or disturbance and minimal 

habitat destruction; 

 Collect the minimum number of samples (e.g., water, soils, vegetative litter, plants, 

macroinvertebrates, vertebrates) for robust statistical analysis requirements in order to minimize 

long-term or cumulative impacts; and 

 Follow quarantine and cleaning protocols to minimize the potential spread or introduction of 

non-native and pest species. 

Conduct scientific assessments providing baseline information and expanding knowledge on the status 

of biological integrity, diversity, and environmental health to better inform resource management 

decisions. These scientific assessments would contribute to the development of Refuge resource 

objectives and they would also be used to facilitate habitat restoration through selection of appropriate 

habitat management strategies based upon site-specific conditions. These assessments have the 

following attributes: 

 Use accepted standards, where available, for completion of assessment; and 

 Scale and accuracy of assessments would be appropriate for development and implementation of 

Refuge habitat and wildlife management actions. 

The following is a list of priority monitoring and other activities to 

support resource management decisions on the Refuge: 

Alt A 

(Current) 

Alt B 

(Preferred) 

Finalize Memorandum of Understanding (MOU) with DMWR to 

coordinate data collection and management activities at the Refuge 

 

Work with partners to deploy an Ecological Acoustic Recorder (EAR) in 

the ava to collect biological data that may improve monitoring of behavior 

and abundance of marine organisms 

 

Within 5 years, begin to monitor climate change variables and responses 

including: sea level, temperature, water quality (pH, conductivity, 

dissolved oxygen, nitrogen, photosynthetically available light (PAR), 

phosphorus, iron) and the frequency and duration of extreme storm events 

 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

2-24 Chapter 2. Management Alternatives 

Work with partners to monitor status and trends of focal communities 

(hard corals, algae), including the incidence and severity of coral and algal 

disease and bleaching 

 

Within 5 years, monitor the growth and survival rate of coral colonies at 

different depths 



Work with partners to conduct REA to document habitat associations and 

species distribution, density, and diversity in marine habitats (see 

Objective 1.1) 

 

Work with NOAA’s CRED and other partners to collect oceanographic 

and water quality data in order to track changes that could affect the reef or 

wildlife (see Objective 1.1) 

 

Within 5 years, develop and implement monitoring protocols to track 

populations of focal lagoon species including: fish, corals, giant clams 

(faisua), other invertebrates, and marine pests to determine abundance, 

density, and biomass of each at selected sites (see Objective 1.1) 



Work with partners to collect bathymetry data every 10 years in order to 

document changes in the lagoon, reef, or ava which could affect 

hydrography or habitat characteristics (see Objectives 1.1, 3.1) 

 

Within 5 years, develop and implement monitoring protocols to track 

abundance and distribution of focal perimeter reef species including eels 

and urchins to determine abundance, density, and biomass of each at 

selected sites (see Objective 2.1) 



Continue monitoring abundance and distribution of the cyanobacterial 

community which became dominant on a section of the southwest arm of 

the atoll due to elevated iron levels following a 1993 shipwreck (see 

Objective 2.1) 

 

Monitor benthic succession of the reef which was damaged due to the 

1993 shipwreck (see Objective 2.1) 



Within 5 years, work with partners to develop and implement reef 

monitoring program, including rate of growth, elevation change, chemical 

composition, and other variables related to reef growth and the atoll’s 

ability to maintain itself in an anticipated environment of climate change 

and ocean acidification (see Objective 2.1) 



Within 5 years, work with partners to monitor water flow rate and 

direction in the ava using archival pressure and flow rate instruments that 

can be downloaded at every visit in order to document any changes in flow 

through the ava (see Objective 3.1) 

 

Within 5 years, develop and implement monitoring protocol to track 

abundance and biomass of fish, including predatory and prey fish species, 

around the opening of the ava to detect any changes in structure or 

function of this important geological feature for large predators in the 

Refuge (see Objective 3.1) 


Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 2. Management Alternatives 2-25 

Within 2 years, working with NOAA/NMFS and other partners, develop 

and implement monitoring protocol to track turtle abundance and 

movements using field counts, tagging, remote sensing and satellite 

telemetry (see Objective 4.1) 



Within 2 years, use GPS to map the perimeter of the islands at high and 

low tide on each visit to the Refuge and obtain any available satellite 

imagery for incorporation into GIS in order to document changes in island 

size and location (see Objective 4.1) 



Monitor survivorship, growth, and maturation of outplanted tamole (see 

Objective 4.1) 



Within 2 years, prepare and implement a monitoring plan and rapid 

response program for terrestrial non-native species and respond

immediately if detected (see Objectives 4.1 and 5.1) 



Within 2 years, review existing vegetation community distribution data 

and develop GIS database of terrestrial and marine habitats and update 

them every 5 years (see Objective 5.1) 



Within 4 years, review available vegetation data and develop and 

implement a monitoring protocol to track changes in numbers, cover, and 

basal area of different species (see Objective 5.1) 



Within 3 years, develop and implement a monitoring protocol to track 

seabird abundance, nesting rates, and feeding territories. Include remote 

sensing observations to improve future monitoring efforts (see Objective 

5.1) 



Within 2 years, develop and implement a monitoring protocol to track 

changes in numbers, cover and basal area of different plant species (see 

Objective 5.1) 



Rationale: The Administration Act requires us to “monitor 

the status and trends of fish, wildlife, and plants in each 

refuge.” Surveys would be used to track populations and 

abiotic variables in order to assess progress toward 

achieving refuge management objectives (under Goals 1-5 

in this CCP) derived from the Refuge System mission, 

refuge purposes, and maintenance of BIDEH (601 FW 3). 

Determining resource status and evaluating progress toward 

achieving objectives is essential to implementing adaptive 

management on DOI lands and waters as required by policy 

(522 DM 1). Specifically, results of surveys would be used 

to refine management strategies over time in order to 

achieve resource objectives. Surveys would provide the best 

available scientific information to promote a transparent 

decision making process for resource management on refuge lands and waters. 

Monitoring data would help us track the effects of climate change and ocean acidification on the Refuge. 

As a living reef, built and maintained by CCA, corals, and other calcifying organisms, Rose Atoll will be 

particularly susceptible to sea level rise and ocean acidification. As the sea rises, the reef will need to 

Tamole to transplant for restoration. 

Jiny Kim, USFWS. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

2-26 Chapter 2. Management Alternatives 

grow faster to maintain the same elevation in relation to sea level, but at the same time, the concentration 

of carbonate ions (the calcifying organisms needed to build the reef) will be declining due to ocean 

acidification and coral bleaching will become more 

common as the ocean warms. Monitoring the growth 

of the reef and abiotic factors would help us 

understand what is happening to the reef and predict 

and plan for future conditions. Where applicable, 

monitoring would also tie into a larger remote sensing 

system. 

In accordance with DOI policy for implementing 

adaptive management on refuge lands (522 DM 1), 

appropriate and applicable environmental assessments 

are necessary to determine resource status, promote 

learning, and evaluate progress toward achieving objectives whenever using adaptive management. 

These assessments would provide fundamental information about biotic (e.g., vegetation data layer) as 

well as abiotic processes and conditions (e.g., soils, topography) that are necessary to ensure that 

implementation of on-the-ground resource management achieve resource management objectives 

identified under Goals 1-5. 

Objective 6.2 Facilitate high-priority research at the Refuge to directly support management 

objectives and guide management decisions. 

Facilitate research projects that provide the best science for habitat and wildlife management on and off 

the Refuge. Scientific findings gained through these projects would expand knowledge regarding lifehistory needs of species and species groups as well as identify or refine habitat and wildlife management 

actions. Research also would reduce uncertainty regarding wildlife and habitat responses to Refuge 

management actions in order to achieve desired outcomes reflected in resource management objectives 

and to facilitate adaptive management. These research projects have the following attributes: 

 Focus wildlife population research on assessments of species-habitat relationships. Develop 

models that predict wildlife response to management; 

 Design and conduct issue-driven (problem-driven) research unlikely to be reliably addressed 

using long-term monitoring. Develop models that predict wildlife response to management; 

 Promote Refuge research and science priorities within the broader scientific community. Ensure 

that cooperative research focuses on meeting information needs identified in biological goals 

and objectives; 

 Assigns a high priority to the collection of information that would better predict, understand, and 

address the effects of climate change and ocean acidification on fish, wildlife, and their habitats 

at all spatial scales in the Refuge, as well as the ability of managers to meet CCP objectives in 

response to climate changes; 

 Adhere to scientifically defensible protocols for data collection in order to develop the best 

science for resource management; 

 Data collection techniques would have minimal animal mortality or disturbance and minimal 

habitat destruction; 

 Collect the minimum number of samples (e.g., water, soils, vegetative litter, plants, 

macroinvertebrates, vertebrates) to meet robust statistical analysis requirements in order to 

minimize long-term or cumulative impacts; 

Monitoring Porites lutea. Jim Maragos, USFWS. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 2. Management Alternatives 2-27 

 Follow quarantine and cleaning protocols to minimize the potential spread or introduction of 

non-native and pest species; and 

 Often result in peer-reviewed articles in scientific journals and publications and/or symposiums. 

The following is a prioritized list of research to support resource 

management decisions on the Refuge: 

Alt A 

(Current) 

Alt B 

(Preferred) 

Within 10 years, characterize nutrient budgets and dynamics at Rose Atoll 

and evaluate them relative to data from other similar reef sites to identify 

possible stressors and the positive effects of healthy seabird colonies 

adjacent to living reefs (see Objective 1.1) 



Within 5 years, work with universities and other partners to evaluate the 

geomorphology, hydrology, and sediment budget of Rose Atoll to 

understand the processes that have maintained the islands as dynamic units 

(see Objective 4.1) 



Within 10 years, investigate the ecological relationships between marine 

gastropods such as turban shells (Turbo spp.), and land hermit crabs 

(Coenobita perlatus and C. brevimanus). Evaluate factors affecting crab 

populations, including observed reduction in availability of shells to crabs 

at the Refuge and what management may improve mollusk shell 

availability to the Coenobita spp., which are important scavengers and 

herbivores on both islands (see Objective 4.1) 



Within 3 years, work with universities and other partners to investigate 

composition and structure of terrestrial communities on Rose Island prior 

to the introduction of rats to inform ecological restoration activities (see 

Objective 5.1) 



Rationale: Rose Atoll is unique in the Samoan archipelago 

in being a coralline algal atoll. Research projects on Refuge 

lands and waters would address a wide range of natural 

resource questions. Examples of research projects include 

habitat use and life-history requirements for particular 

species, practical methods for habitat management and 

restoration, extent and severity of environmental 

contaminants, techniques to control or eradicate pest 

species, effects of climate change, and ocean acidification 

on environmental conditions and associated habitat and 

wildlife response, identification and analyses of 

paleontological specimens, wilderness character, and 

modeling of wildlife populations. Projects may be speciesspecific, Refuge-specific, or evaluate the relative 

contribution of the Refuge to larger landscape (e.g., 

archipelago, regional, Pacific, global) issues and trends. 

Like monitoring, results of research projects would expand 

the best available scientific information and potentially 

reduce uncertainties to promote transparent decision-making 

processes for resource management over time on the Refuge 

and other protected areas. In combination with results of 

surveys, research would promote adaptive management on the Refuge. Scientific publications resulting 

Pisonia research. Jim Maragos, USFWS. 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

2-28 Chapter 2. Management Alternatives 

from research on the Refuge would help increase the understanding of the Refuge System for resource 

conservation and management in the larger science realm.

2.4.7 Goal 7: Strengthen resource conservation and the public’s shared 

stewardship of the ecological, geologic, and cultural richness of the Refuge by 

providing outreach, interpretation, and environmental education 

opportunities. 

Objective 7.1 Enhance and expand interpretation and outreach. 

Provide high-quality interpretation and outreach that supports a knowledgeable public who are aware of 

the conservation provided by the Refuge. The public is informed about the Refuge’s complex ecosystem, 

cultural connections, geologic history, and management challenges by focusing on “bringing the Refuge 

to the people, instead of the people to the Refuge.” Interpretation and outreach associated with the 

Refuge would have the following attributes: 

 People are exposed to at least one of the four key interpretive themes regarding: 

o Ecology; 

o Geology; 

o Culture; and 

o the NWRS; 

 Products and messages engage a diverse audience from American Samoa and across the United 

States and Oceania; 

 Outreach and interpretation use standard media as well as social media and evolving 

technologies; and 

 Supports the Service’s “Connecting People with Nature” emphasis. 

Strategies Applied to Achieve Objective: Alt A 

(Current) 

Alt B 

(Preferred) 

Install minimal signage on Rose Island to inform people of Refuge 

boundary and regulations 

 

Maintain Refuge Website and update at least annually with current 

information such as species lists, interactive tools, management updates, 

news releases, science reports, etc. 

 

Develop brochures, Website and utilize social media and other outreach 

tools specifically designed to communicate Refuge protection and safety 

issues and make these available to mariners 



Develop outreach messages using social media such as blogs or 

interpretive videos on line to “bring the Refuge to the people” 



Explore opportunities and community interest for supporting the 

development of a Refuge “Friends” group to help with interpretation, 

outreach, and other Refuge needs 



Develop a Refuge volunteer program to provide local and national 

stewardship opportunities and assist in Refuge management activities 


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Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 2. Management Alternatives 2-29 

Work with partners (especially within the Manu’a Islands) to develop 

interpretive displays and printed materials to provide outreach messages 

at visitor centers as well as mobile displays for traveling exhibits 



Participate in community meetings and local events to educate people 

about the Refuge, especially within the Manu’a Islands 

 

Enhance law enforcement through the production of interpretive 

brochures for distribution in American Samoa and to the yachting 

community and collaboration with the USCG and NOAA for 

enforcement 



Work with partners to deploy an EAR in the ava to collect data on boat 

entry into the lagoon 



Rationale: The mission of the Service is “working with others to conserve, protect, and enhance fish, 

wildlife, and plants and their habitats for the continuing benefit of the American people.” As reflected in 

the first three words, the Service acknowledges that we cannot effectively carry out our enormous 

natural resource management mission single-handedly. Thus, outreach is needed to enlist the support of 

a wide range of people and agencies by improving communications with them. The fundamental purpose 

of Service outreach is to build understanding, trust and support from a variety of groups by helping them 

understand what the Service does and why we do it. 

Because the Refuge is closed to the general public due to the hazards of getting there and the sensitivity 

of the resources to disturbance, visits to the Refuge are rare and require a SUP. Therefore, our 

interpretation and outreach program would be based on “bringing the Refuge to the people,” instead of 

bringing the people to the Refuge. In order to reach people, we would work with our partners to establish 

Refuge displays for visitor centers in American Samoa, and develop outreach materials and social media 

capacity to provide other interpretive opportunities for people in American Samoa and around the world. 

The Service did not have staff stationed in American Samoa before February 2011, so the public often 

confuse the Service with the DMWR or the NPS. Few people are aware of the Service in American 

Samoa and what we do. Messages describing the Service and the Refuge System need to be developed, 

along with good communications with a variety of people and organizations. Good communication with 

elected officials is essential for the Service to be effective and responsive to the American Samoa public. 

Conservation groups have a great interest in resource management, and their support can influence 

others. Businesses can be a source of funding or support through partnerships. Other Federal agencies, as 

well as American Samoa and village governments, can help give momentum to the Service’s outreach 

initiatives, and their support can enhance a project’s likelihood of success. Finally, the news media can 

directly inform mass audiences. Each of these can have a significant bearing on how effectively the 

Service’s mission is accomplished and the Refuge achieves its goals. 

Objective 7.2 Develop environmental education products and programs to perpetuate and enhance 

knowledge and appreciation of wildlife, habitat, and their importance to American Samoa culture 

and the world. 

Provide a high-quality EE program associated with Rose Atoll National Wildlife Refuge with the 

following attributes: 

 Focuses on students in American Samoa from pre-K through college; 

 Involves local teachers to ensure program is relevant to local students and curricula; 

 Incorporates measurable learning objectives and uses audience-appropriate curricula; and 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

2-30 Chapter 2. Management Alternatives 

 Supports and complements the Service’s mission, and the Refuge’s purpose(s) and goals. 

Strategies Applied to Achieve Objective: Alt A 

(Current) 

Alt B 

(Preferred) 

Create EE materials such as DVDs and posters for use with school groups 

Work with partners to develop EE curriculum and classroom materials 

that introduce students to American Samoa wildlife, protected areas, and 

conservation of natural resources, especially in relation to effects from 

man-made climate change 



Partner with schools and universities to conduct surveys and/or relevant 

research 



Explore appropriate on-site EE opportunities (<once every 3 years) to 

allow a small group of teachers and students (<10 people) to visit the 

Refuge for specific EE purposes developed with the Refuge’s EE 

program 



Develop a brief, picture-oriented PowerPoint presentation describing the 

ecology of the Refuge and present this to three American Samoa schools 

each year 



Develop a student intern program with the Refuge office to introduce 

students to protected areas and wildlife management 



Rationale: American Samoa is a rapidly changing society which is in the process of enhancing EE in 

the schools’ curriculum. This creates an excellent opportunity for the Service to play a role in helping to 

develop EE programs. As a small Refuge with a small staff, working with our partners would be vital to 

the success of any EE program. Because we manage a coral crustose coralline algal atoll in American 

Samoa, the Service is in a position to educate people about the effects of climate change and ocean 

acidification.

In the past, the Service has had a very limited EE program. There have been rare trips to the Refuge for 

teachers and students, but these trips are very expensive, can only be done with strict biological 

restrictions in place to avoid disturbance, and only reach a handful of students. We would be able to 

reach many more students through outdoor programs, classroom presentations and activities, and 

internship programs. We can include people outside of American Samoa with an improved presence on 

the Internet and the development of classroom materials “bringing the Refuge to the people, instead of 

the people to the Refuge.” 

2.4.8 Goal 8: Identify, protect, preserve, and interpret the Refuge’s Samoan 

cultural resources and facilitate, where appropriate, cultural practices. 

Objective 8.1 Encourage and facilitate identification, protection, perpetuation, and interpretation 

of Samoan cultural resources, practices, and traditions related to Rose Atoll. 

Strategies Applied to Achieve Objective: Alt A 

(Current) 

Alt B 

(Preferred) 

Research the history of Samoan names for Rose Atoll and consider 

changing Refuge name accordingly 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 2. Management Alternatives 2-31 

Work with the American Samoa Historical Preservation Office to 

conduct an archaeological survey at Rose Atoll 

Consult with the OSA and local villagers to understand and 

perpetuate Refuge-appropriate traditional cultural practices related to 

Rose Atoll 



Work with partners to collect and compile oral histories from village 

leaders 



Work with the partners to create information materials such as 

videos, reports, and pamphlets regarding cultural uses and the oral 

history of Rose Atoll 

 

Restore the cement monument erected on Rose Island during the 

Governor’s 1920 visit 

Rationale: During public meetings held in 2009 at the 

beginning of the CCP process, people expressed the 

desire that the oral history and cultural resources and 

traditions of Rose Atoll be preserved. There was also the 

desire that the Samoan people be allowed some access to 

the Refuge for cultural practices. The Service recognizes 

that observing and perpetuating cultural practices and 

resources is an essential part of Samoan heritage and we 

would work closely with the OSA and villages to protect 

these resources and manage the Refuge consistent with 

fa’a Samoa (the Samoan way). 

Representatives from Manu’a on a 2011 

cultural visit to Rose Atoll. Raymond Morse.
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Chapter 3. Physical Environment 3-1 

Chapter 3. Physical Environment 

3.1 Climate 

3.1.1 General Climate 

The climate of Rose Atoll can be generalized as tropical, with moderate breezes and moderate 

rainfall. Because Rose Atoll is a small atoll with two tiny islands only a few feet above sea level, the 

climate there is similar to the open ocean. The ocean temperature in American Samoa averages near 

82 ̊F and may vary by 2-3 degrees seasonally. The constant ocean temperature has a strong 

moderating effect on the climate. 

Because there is not a climate monitoring station at Rose Atoll, data must be generalized from 

Tutuila Island 180 miles away. Since both islands are at 14 degrees south latitude, temperature data 

are comparable between the islands. 

While the climate of American Samoa is warm and wet year-round, there is some seasonal 

variability. The wetter, warmer season lasts from October-May and the cooler, drier season is from 

June-September. In the warm season air temperature averages 83 ̊F, and rainfall averages about 13 

inches a month at the airport in Tutuila. In the cool season, air temperature averages around 81 ̊F, 

and rainfall averages about 6 inches a month. Due to a lack of any real topography, Rose Atoll 

receives substantially less rain than Tutuila, but the precipitation is enough to support the littoral 

forest (Wegmann and Holzwarth 2006). 

Aside from being the drier and cooler season, June-September is also the trade wind season with 

winds blowing out of the southeast. Hurricanes are more common between November-April when 

the ocean is slightly warmer (Craig 2009). There have been six hurricanes in Samoa between 1980-

2011, some of which have caused forest and reef damage at Rose Atoll.

3.1.2 Climate Change 

Climate change can be defined as a change in the state of the climate characterized by changes in the 

mean and/or the variability of its properties, persisting for an extended period, typically decades or 

longer (IPCC 2007). Climate variables that may change include temperature, water vapor, sea level, 

precipitation, etc. Such changes are part of the natural system, but can also be affected by human 

activities, particularly in the form of emissions of greenhouse gases such as carbon dioxide (CO2). 

The Intergovernmental Panel on Climate Change (IPCC) is a scientific intergovernmental body 

organized by the World Meteorological Organization and the United Nations Environment 

Programme to assess the causes, impacts, and response strategies to changes in climatic conditions. 

According to the Fourth Assessment Report by the IPCC, global temperatures on the Earth’s surface 

have increased by 1.33°F over the last 100 years. This warming trend has accelerated within the last 

50 years, increasing by 0.23°F each decade. Global ocean temperatures to a depth of almost 2,300 

feet have also increased, rising by 0.18°F between 1961 and 2003 (IPCC 2007). 

Global climate models offer a variety of projections based on different emission scenarios. The U.S. 

Global Change Research Program suggests that a continuing increase in greenhouse gas emissions 

(CO2, methane, and nitrous oxides of primary concern) could double atmospheric concentrations of 

CO2 by 2060 and subsequently increase temperatures by as much as 2-6.5°F over the next century. 
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Sea level rise (SLR) is expected to accelerate by 2-5 times the current rate due to both ocean thermal 

expansion and the melting of glaciers and polar ice caps. Recent modeling projects sea level rising by 

0.59-1.93 feet by the end of the 21st century. These changes may lead to more severe weather, shifts 

in ocean circulation (currents, upwelling), as well as adverse impacts to economies and human 

health. The extent and ultimate impact these changes will have on Earth’s environment remains 

under considerable debate (OPIC 2000, Buddemeier et al. 2004, IPCC 2007). 

3.1.2.1 Climate Change at Rose Atoll 

Small island groups are particularly vulnerable to climate change. The following characteristics 

contribute to this vulnerability: small emergent land area compared to the large expanses of 

surrounding ocean; limited natural resources; high susceptibility to natural disasters; and inadequate 

funds to mitigate impacts (IPCC 2001). Thus, Rose Atoll is considered to have a limited capacity to 

adapt to future climate changes. Other stressors brought on by increased CO2 will be increasing at the 

same time, and some of them may work synergistically (Anlauf et al. 2010, Hoeke et al. 2011). Sealevel rise, higher ocean temperatures, ocean acidification and a likely increase in hurricane strength 

will all affect the reef and organisms of Rose Atoll and some factors will intensify others. 

3.1.2.2 Sea Level Rise 

According to the IPCC, the oceans are now absorbing more than 80 percent of the heat added to the 

Earth’s climate system. Since 1961, this absorption has caused average global ocean temperatures to 

increase and seawater to expand. Thermal expansion of the sea is the primary cause of global sea 

level changes. Melting ice-sheets, ice caps, and alpine glaciers also influence ocean levels. 

Worldwide, sea level changes have occurred historically on a small scale; however, scientific 

evidence suggests that the current, accelerated rate of global change began between the mid-1800s 

and 1900s. Similarly, sea levels in the Pacific have regularly changed over the centuries due to 

variations in solar radiation. Since 1800, sea levels in the Pacific region have been rising. During the 

last century, these levels have risen about 6 inches and this is likely to rapidly increase in the next 

century (Noye and Grzechnik 2001, GAO 2007). 

Due to localized geographic and oceanographic variations, it is not possible to discuss impacts of 

SLR on a global scale. Near Pacific Island ecosystems, SLR is influenced by the rate and extent of 

global SLR, as well as changes in episodic events, such as the El Niño Southern Oscillation (ENSO, 

which results in light trade winds in the western Pacific and drier conditions) and the varying 

strength of trade winds over multi-year timespans. Furthermore, it is important to note that shoreline 

sea levels are historically and currently influenced by isostatic tectonic changes as the islands move 

with the Pacific Plate, which are not due to global changes in sea level. Thus, sea level change in the 

Pacific is highly variable due to geologic uplift (Michener et al. 1997, Carter et al. 2001). 

Despite this variability, SLR will have an impact on Rose Atoll, specifically to the reef height that 

currently protects the islands and lagoon habitats. The rate of growth of corals and CCA (i.e., 

calcification) must meet or exceed the rate of erosion and any SLR to maintain current conditions. 

Biological accretion of the reef will also be affected by increased temperatures, changes in seawater 

chemistry, and increases in destructive weather events. For Samoa, monthly averages of the historical 

tide gauge, satellite (since 1993) and gridded sea-level (since 1950) data agree well after 1993 and 

indicate interannual variability in sea levels of about 7.9 inches (estimated 5–95 percent range) after 

removal of the seasonal cycle. The sea-level rise near Samoa measured by satellite altimeters since 

1993 is about 0.16 inches per year, slightly larger than the global average of 0.13 ± 0.016 inches per 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 3. Physical Environment 3-3 

year. This rise is partly linked to a pattern related to climate variability from year to year and decade 

to decade (PCCSP 2011). Increased water depths on reef flats may allow for faster upward growth of 

the reef flat (Brown et al. 2011) but other factors such as ocean acidification may be slowing reef 

growth at the same time. It is not yet clear whether reefs will continue to produce enough sand to add 

to both islands to maintain them above sea level. 

3.1.2.3 Ocean Temperatures 

Many corals are living near the limit of their thermal tolerance, and increasing sea-surface 

temperatures are leading to more frequent cases of coral bleaching. Coral bleaching is a condition 

where corals expel the tiny zooxanthellae (microscopic plants) that live inside the coral tissues and 

provide food for the coral through photosynthesis. The zooxantellae give coral their colors. When 

corals expel their zooxanthellae in high temperature conditions, the coral appears bleached white 

because we see through the translucent live coral tissue to the skeleton. If temperatures rise just 

slightly above the bleaching threshold, corals can recover, but higher temperatures typically cause 

coral mortality. The longer the corals are exposed to higher temperatures, the less likely they are to 

recover. With warming oceans, corals will suffer more frequent, more severe, and longer duration 

bleaching events. More frequent and severe coral die offs are expected to cause coral populations to 

decline because they will have less time to recover between these stress events and while under this 

stress, their reproductive capacity is diminished (Hoeke et al. 2011, Buddemeier et al. 2004, HoeghGuldberg et al. 2007). 

Different corals have different tolerances to sea-surface temperature (Fabricius et al. 2011), so 

bleaching will likely lead to changes in the coral communities. American Samoa is already 

experiencing this with mass bleaching events in 1994, 2002, and 2003 (Craig 2009) and annual 

summer bleaching in back reef pools of Tutuila (Fenner and Heron 2009). By mid-century, coral 

reefs are predicted to be shifting rapidly from coral-dominated to algae-dominated (Hoeke et al. 

2011, Buddemeier et al. 2004, Hoegh-Guldberg et al. 2007). 

3.1.2.4 Storm Frequency/Intensity 

Most climate projections suggest that more intense wind speeds and precipitation amounts will 

accompany tropical hurricanes and increased tropical sea surface temperatures in the next 50 years. 

The intensity of tropical hurricanes is likely to increase by 10-20 percent in the Pacific region when 

atmospheric levels of CO2 reach double preindustrial levels (McCarthy et al. 2001). One model 

projects a doubling of the frequency of 4 inches per day rainfall events and a 15-18 percent increase 

in rainfall intensity over large areas of the Pacific. While powerful storms can move through deep 

ocean without leaving much evidence, these hurricanes have the ability to cause great damage to 

terrestrial species on islands – as seen in 2005 when Hurricane Olaf, a Category 5 storm, hit Rose 

Atoll and washed over much of Rose and all of Sand Islands causing loss of forest cover and 

mortality of seabird eggs and chicks. Storms toss chunks of the fore-reef up onto the reef platform, 

leaving Rose’s characteristic boulder-strewn reef flat. 

Shallow reef organisms are also affected by being buried by redistributed sediment. Coral reefs are 

also impacted by hurricanes when wave height and energy break apart coral reefs. During the past 30 

years hurricanes have impacted American Samoa at intervals of 1-13 years: 1981 (Esau), 1987 

(Tusi), 1990 (Ofa), 1991 (Val), 2004 (Heta) and 2005 (Olaf). 
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3.1.2.5 Ocean Acidification 

In addition to SLR and warmer ocean temperatures, as CO2 levels rise, corals and coralline algae will 

live in an ocean that is more acidic and contains less carbonate. Corals and crustose coralline algae 

need a minimum concentration of carbonate (CO3) in sea water to build their calcium carbonate 

skeletons. As CO2 increases in the ocean it triggers a series of reactions that remove CO3 from the 

water. Thus, the same process that makes the ocean more acidic, reduces the concentration of CO3. 

Reef building requires a minimum carbonate concentration of 200 micromoles per kilogram, and 

concentrations are presently at 210 micromoles per kilogram and dropping (Hoegh-Guldberg et al. 

2007). Once atmospheric CO2 reaches 550 parts per million, scientists predict calcification of corals 

will stop in the Samoa area (Jokiel et al. 2008, Guinotte et al. 2003). Early research shows that CCA 

are even more susceptible to reductions in carbonate than corals (Kuffner et al. 2008). Coralline algae 

form the rose-colored reef crest that protects the reef flat and islands from erosion. Once acidification 

slows or stops that growth, the reef flats and islands will be at risk. While research still needs to be 

done, the long-term outlook for Rose Atoll and other coral reefs is one of slowed growth due to 

decreased calcification and increased erosion. 

3.1.2.6 Additional Ecological Responses to Climate Change 

Evidence suggests that recent climatic changes have affected a broad range of individual species and 

populations in both the marine and terrestrial environment. Organisms have responded by changes in 

phenology (timing of seasonal activities) and physiology; range and distribution; community 

Rose Island before Olaf and Rose Island after Olaf, where ocean inundation is clearly visible. USFWS. 

18-foot storm surge effects on Rose Island. Holly Freifeld, USFWS. 
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composition and interaction; and ecosystem structure and dynamics. For example, paleoecological 

studies have shown that the distribution of vegetation is highly influenced by climate. The 

reproductive physiology and population dynamics of amphibians and reptiles are highly influenced 

by environmental conditions such as temperature and humidity (i.e., sea turtle sex is determined by 

the temperature of the nest environment; thus, higher temperatures could result in a higher female to 

male ratio). In addition, increases in atmospheric temperatures during seabird nesting seasons will 

also have an effect on seabirds (Duffy 1993, Walther et al. 2002, Baker et al. 2006) by increasing 

thermoregulatory stress in young chicks. 

Warming has also caused species to shift toward the poles or higher altitudes and changes in climatic 

conditions can alter community composition. Increases in CO2 levels can impact plant photosynthetic 

rates, reduce water stress, decrease nutrient content, and lower herbivore weights. Climate change 

can also increase the loss of species as has been shown by the extirpation of two populations of the 

Bay checkerspot butterfly (Euphydryas editha bayensis) in California (Bedoya et al. 2008). Some of 

the characteristics that make species vulnerable include small population sizes, restricted or patchy 

ranges (such as those organisms that live on isolated islands), occurrences at either high or low-lying 

areas, with limited climatic ranges, and narrow or specific habitat requirements. Although there is 

uncertainty regarding these trajectories, it is probable that there will be ecological consequences 

(Vitousek 1994, Walther et al. 2002, Ehleringer et al. 2002). 

Effects of climate change to nesting green turtles on Rose Island could include loss/degradation of 

nesting habitat from sand erosion, and changes in incubation times, hatchling success, and sex ratios. 

As incubation temperature increases, incubation time goes down, the sex ratio is predicted to be 

highly biased toward females, and hatchling survival will be reduced (Fuentes et al. 2011). 

Effects of climate change to seabirds could include loss/degradation of nesting habitat from sand 

erosion and changes in food source abundance or behavior. Increased salt water intrusion onto Rose 

Island may lead to the loss of vegetation that is less tolerant of salt water, while increased erosion 

would lead to the loss of terrestrial habitats. 

Climate change represents a growing concern for the management of national wildlife refuges. The 

Service’s climate change strategy, titled “Rising to the Urgent Challenge,” establishes a basic 

framework for the agency to work within a larger conservation community to help ensure wildlife, 

plant, and habitat sustainability (USFWS 2010). In addition, the Service is supporting regional 

Landscape Conservation Cooperatives (LCC). These cooperatives are public-private partnerships that 

recognize conservation challenges transcend political and jurisdictional boundaries and require a 

more networked approach to conservation—holistic, collaborative, adaptive, and grounded in science 

to ensure the sustainability of America’s land, water, wildlife and cultural resources. The local LCC 

is the Pacific Islands Climate Change Cooperative (PICCC), headquartered in Honolulu, Hawai‘i, but 

working across the Pacific. The PICCC was established in 2010 to assist those who manage native 

species, island ecosystems, and key cultural resources in adapting their management to climate 

change for the continuing benefit of the people of the Pacific Islands. The PICCC steering committee 

consists of more than 25 Federal, State, private, indigenous, and nongovernmental conservation 

organizations and academic institutions, forming a cooperative partnership that determines the 

overall organizational vision, mission, and goals. 
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3.2 Hydrology 

No known hydrological studies have been conducted at Rose Atoll. There are no streams, lakes, 

wetlands or any other surface water on Rose Atoll (Brainard et al. 2008). Rain water on Rose Island 

is likely taken up by plant roots and lost through transpiration. It is unlikely that any freshwater is 

stored in an aquifer due to the small size of the islands, the sandy soils, and the fact that there would 

likely be salt water intrusion if there was an aquifer. 

3.3 Topography and Bathymetry 

Both islands have elevations of less than 15 feet and are subject to wash overs by waves in larger 

storms. Because both islands have components of mobile sand and coral rubble, they can vary in size 

and shape (Mayor 1921, Satchet 1954, Setchell 1924, Shallenberger et al. 1980, Williamson 1998), 

but maintain their position on the reef due to central cores of rock (exposed on Rose, inferred for 

Sand Island). Freycient pointed out in 1826 that Rose Island was highest in the southwest and 

gradually sloped down toward the northeast where it merged with the sand of the shore (Rodgers et 

al. 1993). Rose Island has the same basic shape today. Sand Island is likely more variable in shape, 

but has maintained the same basic location over the years. 

Below the elevation of the islands is the reef crest which maintains roughly the same elevation all the 

way around the atoll. The one exception is the ava, the channel that connects the lagoon with the 

outside ocean, which is between 6-50 feet deep. Inside the reef crest is the lagoon slope, which is 

mostly less than 10 feet deep. In the middle of the atoll is the lagoon with a maximum depth near 98 

feet. On the outside of the reef crest the atoll plummets steeply to the bottom of the Pacific Ocean 

over 2 miles below the surface. 

In 2006 the NOAA CRED mapped the bathymetry in and around Rose Atoll using multibeam 

equipment and towed-diver surveys. This was the first high resolution mapping of the area and the 

data are available at http://www.soest.hawaii.edu/pibhmc/pibhmc_amsamoa_rose_bathy.htm. 

Image showing the steep sides of Rose Atoll 

sloping rapidly down to more than 2 miles deep. 

Roger Meyers, American Samoa Department of 

Marine and Wildlife Resources. 

Depths at Rose Atoll. USFWS. 
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3.4 Geology and Geomorphology 

The Samoan Island chain is a series of volcanic islands that are sinking back into the Pacific Ocean 

over millions of years. These islands are on the Pacific tectonic plate and surrounded by ocean which 

is mostly 2-3 miles deep. The Pacific plate is moving northwest averaging about 2-3 inches a year. 

About 100 miles south of the Samoan chain, part of the Pacific Plate sinks into the 6-mile-deep 

Tongan Trench and ultimately under the Australian Plate. As the plate moves, it bends and cracks 

creating volcanic hot spots where lava oozes out forming volcanoes and ultimately islands (Birkeland 

et al. 2008). 

Most of the Samoan Island chain was created by a volcanic hot spot, presently located between Rose 

Atoll and Ta’ū under Vailulu’u seamount. The peak of this seamount is about 1,800 feet deep. 

Savai’i, is the westernmost island and the oldest with an estimated age around 5 million years. Ta’ū

is the easternmost island and the youngest with an estimated age around 1 million years. There are 

seamounts west of Savai’i, some of which were likely islands that have sunk below the sea surface. 

Rose Atoll is an anomaly in the Samoan Island chain. It is older than any of the other islands, but lies 

at the younger end of the chain. This is because Rose Atoll was not created by the same hot spot that 

created the rest of the Samoan Islands. It was created by volcanic activity that took place before the 

present hot spot became active (Birkeland et al. 2008). 

Rose started as an ancient volcano that built up from eruptions beginning on the deep sea floor many 

millions of years ago. The ancient volcano eventually emerged as a volcanic island that eventually 

went extinct, leading to its subsidence due to the growing weight of the volcano pushing down on the 

ocean floor beneath it and natural erosion. The first corals and other reef-building organisms settled 

on the fringes of the volcano and continued to survive, grow, and die, leaving their skeletons behind 

These photos illustrate how variable island size can be given the dynamic nature of the environment. 

USFWS. 
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3-8 Chapter 3. Physical Environment 

and allowing younger reef builders to settle upon them and grow. This maintained proximity to the 

sea surface during the long period of subsidence. Over millions of years the upward growth rate of 

the reef kept pace with the downward rate of subsidence of the volcano, leading to the creation of a 

coral cap encircling and eventually covering the summit of the extinct volcano. Eventually the 

volcano disappeared altogether beneath the sea surface and was replaced by a lagoon, completing the 

transition from volcanic island with reefs fringing its coasts to an atoll. 

Darwin’s idea that atolls were perched atop sinking volcanos was verified when scientists drilled 

through more than 4,000 feet of calcium carbonate reef to hit basalt from an creation of ancient 

volcano. However, today we know that the creation of atolls is a more complex process, which has 

happened over the last several thousands of years, not over the millions of years that it takes a 

volcano to sink. The creation of atolls as we know them today, a ringed–reef surrounding a lagoon 

often with sand islets, is the result of changes in sea levels that have occurred during glacial and 

interglacial times. During the last glacial period about 20,000 years ago, sea level was over 100 

meters (328.1 feet) lower than it is today. Reefs that had grown during times of higher sea level 

protruded out of the sea and were subject to thousands of years of erosion and subsidence. As the sea 

rose again these eroded reefs began to grow again, but now their centers had been eroded. Five 

thousand years ago, sea levels were about 2 meters (6.6 feet) higher than today, so these reefs grew 

higher than present day sea level. As sea levels have gone down, a few meters of reef have been 

exposed, and islands have formed on some of these newly exposed reefs (Dickinson 2009, 

Woodroffe 2007). 

For most of the last 100,000 years Rose Atoll emerged out of the sea. The islands we see at Rose 

likely only existed since about 1,000 AD. The distinctive square shape of the reef structure today is 

thought to reflect the shape of the ancient volcano that had dikes of more resistant rock intersecting at 

a right angle. Although there is insufficient evidence to determine the thickness of the coral reef cap 

at Rose Atoll, coral drilling on Enewetak Atoll in the Marshall Islands has revealed coral reef cap 

attaining a thickness of over 4,000 feet in depth that began its growth more than 50 million years ago 

(Maragos 2011a). 

Rose has a higher percentage of CCA than most atolls, and this gives Rose a pink hue (Brainard et al. 

2008, Green et al. 1997, Mayor 1921). Aside from the main ring of the atoll, there is a series of 

Samoan Island Chain. National Park of American Samoa. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 3. Physical Environment 3-9 

blocks and pinnacles created by coral and CCA that provide habitat diversity in the lagoon and on the 

back reef. 

Rose Atoll is one of about 500 surviving atolls in the Pacific today, but countless others have 

drowned well below the lighted (photic) zone of the ocean because their upward reef growth could 

not keep pace with the corresponding downward subsidence and sea level fluctuations during the 

Pleistocene. 

3.5 Soils 

The soils on Sand Island and the non-vegetated parts of Rose Island are composed of limestone sands 

and rubble of algal and coral origin surrounding and partially covering a core of paleoreef rock. This 

soil is considered to be a Fusi soil type (Amerson et al. 1982). These soils are non-consolidated sands 

that are often washed over during storm events. The sands shift around the rock island core with the 

wave and wind action making the shape and size of the islands dynamic. This is evident in the 

constant necessity to replace grid markers used for biological surveys during visits by Service 

personnel between 1980 and the present. Due to the large numbers of seabirds nesting on the islands, 

there is a substantial input of guano. All the seabirds at Rose forage over deep ocean thus there is a 

constant input of nutrients from outside the atoll system. 

The description of the soil that follows is based on a 1924 survey under the Pisonia forest (Lipman 

and Shelley 1924). Changes may have taken place as the Pisonia trees have died back and been 

replaced by Tournefortia argentea. The soils in the Pisonia forest can be divided into a top organic 

layer of rich chocolate-colored humus, an intermediate layer of very porous, partially decomposed 

limestone, and a bedrock layer of compact, fine-textured, pure calcium carbonate without texture and 

no vital structure (also described as coquina). Lipman and Shelley (1924) also found high 

concentrations of salt and postulated that the toxic effects of the salts might be mitigated to some 

degree by the high content of organic matter. The soils analysis (from bedrock to soil) also indicated 

increasingly high percentages of aluminum, phosphorus, sulfur, sodium, and potassium, compared to 

decreasing percentages of calcium and magnesium, and little change in silicon. The increased 

sodium, potassium, and sulfur resulted from the large absorptive capacity of the soil, differential 

leaching, and contribution from ocean spray. Nitrate and nitrate producing bacteria were also present 

in the soils. Based on comparison of soils from Pisonia forests in the Marshall Islands, it was 

suggested that bird guano was acidified by humus as it washed down through the soil, leading to a 

lack of hardpan below the humus layer. Lipman and Shelley linked the fertility of Rose Island to the 

phosphatization, followed by bacterial nitrogen-fixation. 

3.6 Environmental Contaminants 

The Agency for Toxic Substance and Disease Registry, a Federal bureau of the U.S. Department of 

Health and Human Services, defines a contaminant as “a substance that is either present in an 

environment where it does not belong or is present at levels that might cause harmful (adverse) 

health effects” (ATSDR 2009). Contaminants commonly include pesticides and their residues, 

industrial chemicals, fertilizers, metals, and other toxic substances. By altering biological or physical 

processes, contaminants may produce adverse and even detrimental effects to an ecosystem. 
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3-10 Chapter 3. Physical Environment 

3.6.1 Military Use in WWII 

On February 14, 1941, the territorial waters surrounding the islands of Rose Atoll were established 

and reserved as the Rose Island Naval Defensive Sea Area. These airspaces over the territorial waters 

and islands were set apart and reserved as the Rose Island Naval Airspace Reservation (Executive 

Order 8683). In 1943 the 4th Marine Base Defense Wing was given permission to use Rose Atoll as a 

dive bomb practice area. In 1996 the Army Corps of Engineers completed a Defense Environmental 

Restoration Project for Formerly Used Defense Sites (FUDS) for Rose Atoll (USACE 1996). In the 

Army FUDS investigation, the only reported ordnance was a single MK-23 practice bomb and two 

0.30-caliber cartridge casings found by biologists. They found no paperwork indicating that Rose 

was ever used for bomb practice. It is also believed that it was not used for storage of fuel or other 

hazardous materials. The FUDS report states, “No land-based evidence of OEW (Ordnance or 

Exploded Wastes) or other military remnants were observed during visual reconnaissance of Rose 

Atoll .... The site was otherwise unremarkable with no signs of Ordnance and Explosive Waste 

(OEW) or environmental stress attributable to former military use” (USACE 1996). 

3.6.2 Wreck of the Jin Shiang Fa 1993 

On October 14, 1993, the Taiwanese long-line fishing vessel 

Jin Shiang Fa ran aground on the southwest arm of Rose 

Atoll spilling 100,000 gallons of diesel fuel, 500 gallons of 

lube oil, and 2,500 pounds of ammonia. The vessel broke up 

before a salvage tug could reach the atoll, depositing 200 

tons of iron on the reef as well as miles of fishing line and 

other materials from the ship (Green et al. 1997). 

The contaminants spilled over a 6-week period were washed 

over the reef and into the lagoon by waves and currents. 

Traces of fuel and oil were detected in sediments 22 months later (USFWS and DMWR 2001). The 

spill killed the coral and CCA, which created openings on the reef for opportunistic cyanobacteria 

and turf algae to colonize. Ultimately this led to a phase shift from a CCA-dominated reef 

community to a cyanobacteria/turf algae-dominated reef community (USFWS and DMWR 2001). 

Early observations at Rose Atoll also suggested that fish populations may have been affected and 

large numbers of faisua and tuitui died (Green et al. 1997). The iron scattered about the reef from the 

wreck has promoted the continued prevalence of cyanobacteria and turf algae in the reef flat 

community. 

Jin Shiang Fa. USFWS. 

Debris clean up. Jim Maragos, USFWS. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 3. Physical Environment 3-11 

Though iron removal from the ship wreck continued until 2007, monitoring of the site continues. The 

natural resource damage assessment, restoration, and monitoring being done by the Service was 

funded by the Oil Spill Liability Trust Fund, established by the Oil Pollution Act of 1990 and 

managed by the U.S. Coast Guard National Pollution Funds Center. 

3.7 Air Quality 

Being over 2,700 miles to Sydney, Australia; 4,700 to Los Angeles, California; and 6,000 miles to 

Peru, Rose Atoll is a long way from any major source of air pollution. No known air quality 

sampling has taken place, however, due to the lack of human presence and on-site vehicles (other 

than boats used for Refuge management 1-2 times a year), distance to air polluted areas, and trade 

winds, air quality is thought not to be impaired. 

3.8 Water Quality 

Though little water quality monitoring has been done at the Refuge, given its remote location, it is 

anticipated that ocean water quality is not impaired. Water quality testing was conducted after the Jin 

Shiang Fa ran aground on the atoll in 1993 spilling 100,000 gallons of diesel fuel and other 

contaminants into the waters in and around Rose Atoll. Shortly after the grounding, the majority of 

the vessel hull was removed from the reef. Despite the removal of much of the metallic debris from 

the fore-reef slope, there was a sufficient source of 

dissolved iron seaward of the reef edge to sustain elevated 

iron levels in the water flowing over the reef platform. In 

2002, concentrations of iron were still elevated 5-10 fold 

above background levels (approximately 0.6 nanomoles) 

within a plume of water approximately 557 yards wide 

flowing onto the reef platform. However, peak 

concentrations within the plume in 2002 were only half of 

the peak values found in 1998. 

Iron is a limiting element in atoll marine environments that 

Cyanobacteria overgrows pink crustose are far from continental margins, and this increased iron 

coralline algae. Jean Kenyon, USFWS. 

Disarticulated engine block and scrap metal on coral. USFWS. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

3-12 Chapter 3. Physical Environment 

resulted in higher cyanobacterial growth near the wreck site (Green et al. 1997). There have been 

several cleanup operations funded to remove the remaining pieces of the ship, and by 2007 all major 

pieces had been removed. Measurements of iron concentration in the water upstream and 

downstream of the wreck site continue as part of the monitoring program evaluating recovery from 

the Jin Shiang Fa grounding. Monitoring is ongoing and new strategies for active restoration of the 

area are being evaluated. 

Storm wash over and sand erosion on the two islands may periodically lead to temporary turbidity in 

near shore waters. Storm wash and rainfall could also lead to nutrient enrichment from bird guano in 

the marine environment. The nutrient budgets of coral reef systems adjacent to healthy seabird 

colonies and areas where seabird populations have been extirpated is currently an area of active 

investigation in tropical regions around the world. 

3.9 Surrounding Land Use 

In 2009, Presidential Proclamation 8337 

created the Monument which overlays the 

Refuge and extends out 50 nautical miles 

covering a total of 13,451 square miles. 

There is no commercial fishing allowed in 

the Monument, and large vessels (greater 

than 50 feet) are excluded from fishing in an 

area roughly 50 nautical miles from all the 

islands and atolls of American Samoa per 

NMFS regulations (Federal Register 2012). 

The Refuge and the Monument are in the 

American Samoa Exclusive Economic Zone. 

While commercial fishing is prohibited in 

the Monument, at the time of this writing, 

the Western Pacific Regional Fisheries 

Council and NMFS are developing proposed 

Monument non-commercial fishing 

regulations that include establishing a 0 

to12-nautical mile (nmi) no-take area around 

the Refuge and propose to establish 

regulations that permit sustenance and 

traditional indigenous fishing and recreational fishing in the 12-50 nmi zone of the Monument. 

Additionally, ONMS has initiated the process of bringing the areas of the Monument (excluding the 

Refuge) into the National Marine Sanctuary System. 

Given the remoteness of Rose Atoll NWR, there is very little use of this area. However, Service staff have 

seen recreational sailboats accessing the area. In June 2009, the Paul Eric entered the Refuge as an 

emergency stop to repair its engine. Unfortunately, as the vessel weighed anchor in preparation to depart, 

strong winds and currents pushed the vessel aground on the shallow eastern reef near Sand Island. During 

the removal of the Paul Eric from the reef, a second large yacht, the Southwest was seen approaching 

Rose from the south. 

Surrounding land use: the Monument, Exclusive Economic 

Zone, and Large Fishing Vessel Exclusion Zone. USFWS. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Biological Environment 4-1 

Chapter 4. Biological Environment 

This chapter addresses the biological resources and habitats found on Rose Atoll NWR. However, it 

is not an exhaustive review of all species occurring within the Refuge. The chapter begins with a 

discussion of biological integrity (historic conditions and ecosystem function), as required under the 

Administration Act. The bulk of the chapter is then focused on the presentation of pertinent 

background information for habitats used by each of the Priority Resources of Concern (ROC) and 

other benefiting species designated under the CCP. The background information includes 

descriptions, conditions, and trends of habitats and threats (stresses and sources of stress) to the 

habitats and/or associated ROC. This information was used to develop goals and objectives for the 

CCP. 

4.1 Biological Integrity Analysis 

The Administration Act, as amended, directs the Service to ensure that biological integrity, diversity, 

and environmental health (BIDEH) of the Refuge System is maintained for the benefit of present and 

future generations of Americans. The elements of BIDEH are represented by native fish, wildlife, 

plants, and their habitats, as well as those ecological processes that support them. The Refuge System 

policy on BIDEH (601 FW 3) also provides guidance on consideration and protection of the broad 

spectrum of fish, wildlife, and habitat resources found on a refuge and in associated ecosystems that 

represents BIDEH. 

Biological integrity lies along a continuum from a completely natural system to a biological system 

extensively altered by considerable human impacts to the landscape (which includes seascapes). No 

modern landscape retains complete BIDEH. We strive to prevent the further loss of natural biological 

features and processes. Maintaining or restoring biological integrity is not the same as maximizing 

biological diversity. Maintaining biological integrity may entail managing for a single species or 

community at some refuges and combinations of species or communities at other refuges. 

Maintaining critical habitat for a specific endangered species, even though it may reduce biological 

diversity at the refuge scale, helps maintain biological integrity and diversity at the ecosystem or 

national landscape scale. 

On refuges, we typically focus our evaluations of biological diversity at the refuge scale; however, 

these refuge evaluations can contribute to assessments at larger landscape scales. We strive to 

maintain populations of breeding individuals that are genetically viable and functional. Evaluations 

of biological diversity begin with population surveys and studies of flora and fauna. The Refuge 

System’s focus is on native species and natural communities such as those found under historical 

conditions (BIDEH policy). However, given the likely impacts of climate change (e.g., sea level rise, 

ocean acidification, ocean temperature) on reefs and atoll islands, maintaining historic conditions 

may not be possible in the future. The Service will continue to promote resilience by minimizing 

other anthropogenic effects to the Refuge so the species and habitats have improved chances of 

adapting to a changing climate. Additionally, we will incorporate new climate science into our 

management as it becomes available. 

We evaluate environmental health by examining the extent to which environmental composition, 

structure, and function have been altered from historic conditions. Environmental composition refers 

to abiotic components such as air, water, and soils, all of which are generally interwoven with biotic 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-2 Chapter 4. Biological Environment 

components (e.g., decomposers live in soils). Environmental structure refers to the organization of 

abiotic components, such as atmospheric layering, aquifer structure, and topography. Environmental 

function refers to the processes undergone by abiotic components, such as wind, tidal regimes, 

evaporation, and erosion. A diversity of abiotic composition, structure, and function tends to support 

a diversity of biological composition, structure, and function. 

Due to its remoteness and limited acreage, Rose Atoll is a far more natural system than most 

landscapes. The atoll has had very limited human contact and no development on it (other than a sign 

and monument installed). Its distinctive CCA, rare Pisonia forest, terrestrial fauna, and unique 

assemblage of marine fishes and invertebrates in the lagoon are all critical components of BIDEH. 

The overarching BIDEH principles that were integrated into the CCP analysis included the Refuge 

purposes, Refuge System mission, and where appropriate maintenance of BIDEH for wildlife and 

habitat, and BIDEH in a landscape context. The BIDEH for the Refuge is summarized in Table 4-1. 

Table 4-1. Biological Integrity, Diversity, and Environmental Health 

Habitats Population/Habitat 

Attributes 

Natural processes 

responsible for these 

conditions 

Limiting Factors 

Lagoon Lagoon floor (to ~98 feet 

depth) and back reef 

composed of carbonate 

sand and rubble, with low 

coral and CCA cover (< 

1%). Hard-substrate 

pinnacles and patch reefs 

with moderate coral and 

CCA cover (>10%), 

supporting diverse fish 

assemblage and faisua 

Potential conservation 

species: faisua, sea turtles, 

candidate ESA coral 

species 

Intact perimeter reef 

(present-day height, 

width, biotic construction) 

and ava (present-day 

depth, width, location 

unblocked flow) that 

regulate seawater 

exchange with 

surrounding ocean and 

seawater flow inside 

lagoon; natural 

breakdown of calcifying 

organisms providing 

carbonate sediment 

Proliferation of cyanobacteria; 

illegal fishing and faisua 

poaching; reduced calcification 

linked to ocean acidification 

Perimeter 

Crustose 

Coralline 

Algal Reef 

Living reef dominated by 

CCA, with intact 

geomorphic structure 

providing mosaic of 

microhabitats for 

invertebrates including 

corals and sea urchins 

Potential conservation 

species: candidate ESA 

coral species 

Growth of CCA and other 

calcifying organisms, and 

accretion of carbonate 

through geochemical 

processes, maintains 

constructional platform 

between open ocean and 

inner lagoon 

Rate of SLR relative to natural 

capacities for growth and 

accretion; reduced calcification 

linked to ocean acidification; 

overgrowth by nonconstructional cyanobacteria 

Ava Unobstructed channel 

between lagoon and fore 

reef with present-day 

Natural hydrological 

regimes of oceanic and 

lagoonal seawater flow 

Impedance of natural flow 

patterns by boat grounding or 

other obstacles 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Biological Environment 4-3 

Habitats Population/Habitat 

Attributes 

Natural processes 

responsible for these 

conditions 

Limiting Factors 

depth, width, and location 

Potential conservation 

species: faisua, sea turtles, 

candidate ESA coral 

species 

Beach 

Strand 

Beach strand habitat clear 

of invasive introduced 

plants and marine debris 

that provides nesting sites 

for ground-nesting seabirds 

and turtles and foraging 

sites for migratory 

shorebirds 

Sand and rubble formed 

by the action of storms 

and bio-erosion of living 

CCA reef community is 

deposited and re-arranged 

by ocean waves. Plant 

community on the beach 

strand areas are kept at 

seral stage by repeated 

overwashing and storms. 

Current sea level. 

Non-native invasive species of 

plants and animals; human 

disturbance and trampling; 

interruption in the supply of 

gastropod shells from the reef 

that are used by land hermit 

crabs; sea level rise; reduced 

calcification linked to ocean 

acidification; increased storm 

frequency and intensity 

changing sediment distribution 

patterns 

Littoral 

Forest 

South Central tropical 

Pacific littoral forest with a 

native species composition 

typical of other intact 

habitats of similar rainfall 

and soil type. This forest 

provides nesting sites for 

arboreal and groundnesting seabirds as well as 

native land crabs, insects, 

and migratory shorebirds 

Nutrient input from 

seabird guano and 

precipitation favor pu’a 

vai and other species of 

plants dispersed by birds 

or ocean currents 

Non-native invasive species of 

plants, animals, and pathogens, 

human disturbance; SLR; 

reduced calcification linked to 

ocean acidification; increased 

storm frequency and intensity; 

changing sediment distribution 

patterns 

 

4.2 Selection of Priority Resources of Concern 

4.2.1 Analysis of Priority Resources of Concern 

Wildlife and habitat goals and objectives were designed directly around the habitat requirements of 

species designated as Priority ROC (ROC are called conservation targets in conservation planning 

methodologies used by other agencies and NGOs). As defined in the Service’s Policy on Habitat 

Management Plans (620 FW 1), resources of concern are: 

“all plant and/or animal species, species groups, or communities specifically identified in 

refuge purpose(s), System mission, or international, national, regional, state, or ecosystem 

conservation plans or acts. For example, waterfowl and shorebirds are a resource of concern 

on a refuge whose purpose is to protect ‘migrating waterfowl and shorebirds.’ Federal or 
Rose Atoll National Wildlife Refuge 

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4-4 Chapter 4. Biological Environment 

State threatened and endangered species on that same refuge are also a resource of concern 

under terms of the respective endangered species acts (620 FW 1.4G)... 

“Habitats or plant communities are resources of concern when they are specifically identified 

in refuge purposes, when they support species or species groups identified in refuge 

purposes, when they support NWRS resources of concern, and/or when they are important in 

the maintenance or restoration of biological integrity, diversity, and environmental health.” 

Therefore, ROC for a refuge may be a species or species group, or the habitat/plant community that 

supports a priority species/species group. 

In developing its listing of Priority ROC, the planning team selected not only species mentioned in 

establishing documents for the Refuge, but also species that captured the ecological attributes of 

habitats required by larger suites of species. The ecological attributes of habitats should be analyzed 

to meet the life-history requirements of ROC, and are therefore critical to sustain the long-term 

viability of the ROC and other benefiting species. Ecological attributes of terrestrial habitats include 

vegetation structure, species composition, age class, patch size and/or contiguity with other habitats; 

hydrologic regime; and disturbance events (e.g., flooding, fire). Likewise, in the marine environment, 

ecological attributes include benthic structure; species composition and distribution; oceanographic 

regime (waves, tides, currents, upwelling); water quality parameters such as pH, temperature, 

salinity, light attenuation, nutrient levels; and disturbance events (e.g., tropical storms). These 

provide measurable indicators that strongly correlate with the ability of a habitat to support a given 

species. Tables listing the desired conditions for habitat types found on the Refuge incorporate 

“desired” conditions that were based on scientific literature review and team members’ professional 

judgment. These desired conditions for specific ecological attributes were then used to help design 

habitat objectives, as presented in Chapter 2. However, not all ecological attributes or indicators were 

deemed ultimately feasible or necessary around which to design an objective. Other factors, such as 

feasibility and the Refuge’s ability to reasonably influence or measure certain indicators, played a 

role in determining the ultimate parameters chosen for each habitat objective. Thus, ecological 

attributes should be viewed as a step in the planning process. The ultimate design of objectives was 

subject to further discussion and consideration. 

Limiting factors were also considered in developing objectives. A limiting factor is a threat to, or an 

impairment or degradation of, the natural processes responsible for creating and maintaining plant 

and animal communities. In developing objectives and strategies, the team gave priority to mitigating 

or abating limiting factors that presented high risk to ROC. In many cases, limiting factors occur on a 

regional or landscape scale and are beyond the control of individual refuges. Through the 

consideration of BIDEH, the Refuge will provide for or maintain all appropriate native habitats and 

species. Refuge management priorities may change over time, and because the CCP is designed to be 

a living, flexible document, changes will be made at appropriate times. 

Early in the planning process, the planning team cooperatively identified priority species for the 

Refuge, as recommended under the Service’s 620 FW 1. These ROC frame the development of goals 

and objectives for wildlife and habitat. The ROC may be species, species groups, or features that the 

Refuge will actively manage to conserve and restore over the life of the CCP, or species that are 

indicators of habitat quality for a larger suite of species. Negative features of the landscape, such as 

invasive plants, may demand Refuge management effort, but are not designated as ROC. 
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Chapter 4. Biological Environment 4-5 

The main criteria for selecting priority ROC included the following requirements: 

 The resource must be reflective of the refuge’s establishing purpose(s) and the Refuge 

System mission; 

 The resource must include the main natural habitat types found at the refuge; 

 The resource must be recommended as a conservation priority in the Wildlife and Habitat 

Management Review; or 

 The resource must be federally or State/Territory listed as a candidate for listing, or a species 

of concern. 

Other criteria that were considered in the selection of the resources of concern included the 

following: 

 Species groups or refuge features of special management concern; 

 Species contributing to the BIDEH of the ecosystem; or 

 Species for which it is feasible to estimate population size (needed for future monitoring and 

adaptive management). 

Table 4-2. Priority Resources of Concern 

Focal Species Habitat Type Habitat Structure Life History 

Requirements 

Other Benefiting 

Species 

Pu’a vai 

(Pisonia) 

Littoral Forest Sandy and phosphate 

soils with elevation 

sufficient to avoid 

overwashing in all but 

the largest storms (> 

6.6 feet) 

All Tree-nesting seabirds 

fua’o (red-footed 

booby), atafa (lesser 

frigatebird), atafa 

(great frigatebird), 

gogo (black noddy), 

white tern (manu 

sina) 

Littoral forest 

tree species – 

Cordia 

subcordata, 

Tournefortia 

argentea, 

Hernandia 

nymphaeifolia, 

Terminalia 

samoensis, 

Neisosperma 

oppositifolium, 

and Hibiscus 

tiliaceus

Littoral forest 

(mesic) 

Sandy and phosphate 

soils with elevation 

sufficient to avoid 

overwashing in all but 

the largest storms (> 

6.6 feet) 

All Matu’u (Pacific reef 

heron) for nesting 

habitat and aleva 

(long-tailed cuckoo) 

for wintering, 

molting, and foraging 

Tava’e’ula 

(red-tailed 

tropicbird) 

Littoral forest Ground under 

vegetation in 

understory and base of 

Nesting Gogo (brown noddy), 

fua’o (brown booby)
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4-6 Chapter 4. Biological Environment 

Focal Species Habitat Type Habitat Structure Life History 

Requirements 

Other Benefiting 

Species 

trees; sites that 

provide adequate 

shade for nestling for 

the duration of the 

growth period

Fua’o (redfooted booby)Littoral forest Tournefortia and 

Pisonia trees that 

provide appropriate 

structure for nest 

construction above the 

ground

Nesting Atafa (lesser 

frigatebird), atafa 

(great frigatebird), 

gogo (black noddy)

Land hermit 

crabs 

Coenobita 

perlatus and 

Coenobita 

brevimanus

Littoral forest Sandy and phosphate 

soils, vegetation and 

shade protection from 

tropical sun 

Reproduction – 

aquatic larvae, 

terrestrial adults, 

foraging, proximity 

to sea water source 

for osmoregulation 

and gill 

maintenance

Bristle-thighed 

curlews prey upon 

land hermit crabs. 

Entire forest 

community benefits 

from Coenobita

acting as scavengers 

and nutrient recyclers 

Gogo uli 

(sooty tern)

Beach strand 

and littoral 

forest 

Open beach habitat or 

forest sites with 

minimal understory 

that provide open 

access for landing and 

takeoff and visibility 

for these highly social 

nesters 

Nesting Gogosina (graybacked tern), 

gogosina (blacknaped tern), bristlethighed curlews, 

ruddy turnstones that 

prey on sooty tern 

eggs

Tuli (bristlethighed 

curlew) 

Beach strand 

and littoral 

forest 

Open beach habitat or 

open forest 

Wintering, molting, 

feeding 

Tuli (ruddy 

turnstone), tuli 

(sanderling), tuli 

(wandering tattler), 

tuli (whimbrel), tuli 

(Pacific golden 

plover) 

I’a sa (green 

turtle) and 

laumei uga 

(hawksbill 

turtle) 

Beach 

strand/littoral 

forest/lagoon 

Sand with access to 

the water but above 

the high tide line 

Nesting (green 

turtle only), resting, 

feeding 
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Chapter 4. Biological Environment 4-7 

Focal Species Habitat Type Habitat Structure Life History 

Requirements 

Other Benefiting 

Species 

Tamole 

(yellow 

purslane, 

Portulaca 

lutea) 

Beach strand Open sand, no over 

story 

All 

Malie (gray 

reef shark) 

Lagoon, ava Pinnacles, patch reefs, 

back reefs 

All Malie alamata 

(blacktip reef shark), 

whitetip reef shark 

(Triaenodon obesus), 

Bumphead parrotfish, 

Maori wrasse, gatalauli (Peacock 

grouper), Leopard 

grouper, Coral hind, 

Strawberry grouper, 

mata’ele (Flagtail 

grouper), 

Honeycomb grouper, 

gatala-aloalo (Dwarf 

spotted grouper), 

Masked grouper 

Amu (stony 

corals) 

Acropora, 

Astreopora, 

Cyphastrea, 

Favia, 

Leptastrea, 

Montastrea, 

Montipora, 

Pavona, 

Platygyra, 

Porites, 

Psammocora, 

Stylocoeniella 

spp. 

Reef crest, 

back reef, 

lagoon 

pinnacles and 

patch reefs 

Hard substrate, depth 

and water clarity 

sufficient for light 

penetration, moderate 

temperatures, seawater 

immersion time 

sufficient to prevent 

desiccation, low 

nutrients, low algae 

and cyanobacteria, 

herbivorous fish and 

invertebrates 

All (growth, feeding 

(endosymbiosis, and 

plankton capture), 

reproduction) 

Reef-associated fish; 

other benthic 

invertebrates (soft 

corals, mollusks, 

crustaceans, worms, 

echinoderms, 

tunicates) 

Faisua (giant 

clam) 

(Tridacna 

maxima) 

Lagoon 

pinnacles and 

patch reefs 

Hard substrate, water 

depth and clarity 

sufficient for light 

penetration 

All (growth, feeding 

(endosymbiosis, and 

filter-feeding), 

reproduction 
Rose Atoll National Wildlife Refuge 

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4-8 Chapter 4. Biological Environment 

Focal Species Habitat Type Habitat Structure Life History 

Requirements 

Other Benefiting 

Species 

Sea urchins 

(tuitui) 

Reef crest, 

back reef, 

lagoon 

pinnacles and 

patch reefs 

Hard substrate, 

available holes for 

occupancy, algal films 

and turf for grazing

All (growth, 

grazing, 

reproduction) 

Corals, CCA 

Turban shells 

(Turbo 

crassus, Turbo 

setosus, Turbo 

argyrostomus)

Reef and 

lagoon habitats

CCA reef flats with 

epilithic algae for 

grazing

Foraging 

(herbivores and 

detritus feeders)

Land hermit crabs 

(Coenobita perlatus

and C. brevimanus) 

that use shells of 

these gastropods

Crustose 

coralline algae 

(Porolithon

spp., 

Hydrolithon

spp.) 

Reef Hard substrate, 

moderate 

temperatures, low 

cyanobacteria, 

herbivorous fish and 

invertebrates 

All (growth, 

photosynthesis, 

reproduction) 

Stony corals 

4.3 Habitat Types

An atoll is a reef formation atop a subsiding extinct volcano that includes a lagoon surrounded by a 

shallow perimeter reef, at least one emergent island, and regular surface water exchange between the 

lagoon and the open ocean (Woodroffe and Biribo 2011, Maragos and Williams 2011). Rose Atoll 

has all these major habitats and associated biological groups found on Pacific atolls. It supports 

island and marine species groups that are adapted to each of these habitats. 

All biological communities and habitats at Rose Atoll are profoundly influenced by the ocean and 

associated climate. The early life cycle stages of most reef species at Rose are tiny and moved by 

tides, waves, and ocean currents. Water quality, motion, temperature, light, salinity, and substrate 

characteristics influence the behavior of these small organisms causing them to settle on or near 

favorable habitats to begin the transition to adult phases. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Biological Environment 4-9 

Figure 4-1. Habitats. 
Rose Atoll National Wildlife Refuge 

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4-10 Chapter 4. Biological Environment 

The back sides of maps are blank to improve readability. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Biological Environment 4-11 

4.3.1 Ava 

The ava is a shallow (less than 50 feet) and narrow (130 feet) passage that connects the open ocean to 

the lagoon. The shape, size, and location of the ava are vital to maintaining the lagoon, reef, and 

island habitats. As ocean water spills into the lagoon over the sides of the reef, it is released out 

through the ava. Though water usually flows out the ava, tides and waves occasionally create a 

situation where water flows into the lagoon through the ava. A data-logging current meter deployed 

in the ava by NMFS PIFSC in 2002 showed that water flowed predominantly out of the ava from the 

lagoon, attaining flow rates of 3.3 knots, with only short periods of flow reversal (NMFS PIFSC 

n.d.). 

The elevation of the ava controls the water movement out of the lagoon, and plays a major role in the 

layering of lagoon water by temperature and salinity. Additionally, the shape and location of the ava 

is an important factor in the location and longevity of the islands on the atoll. Water movement inside 

the atoll creates currents that remove sand from some areas and deposit it in other areas. This 

sediment transport regime has created and maintained Rose and Sand Islands as dynamic islands in 

roughly the same location since Rantzau mapped Rose Atoll in 1873 (Rodgers et al. 1993). The ava 

is also the major passageway for fish and other organisms in and out of the lagoon, where species 

that require more shelter from rough water to breed or live may concentrate. Sharks and other 

predators congregate at the mouth of the ava waiting for prey. As such, the ava connects reef life on 

both sides of the perimeter reef at Rose Atoll. 

In addition, the size and depth of the ava affect the amount of water exchange between the lagoon 

and the ocean, and indirectly the height and width of the perimeter reef crest and reef slopes 

surrounding the lagoon. In the case of Rose, the two islands are relatively small in relation to the total 

circumference of the open reef crests, allowing more water to enter the lagoon over the crests during 

high tides and heavy wave action. Because the ava is shallow and narrow, water exiting the ava is 

less than the amount of water entering over the perimeter reefs during tidal cycles. As a consequence, 

water levels in the lagoon remain higher than those on the ocean side except at the highest tides. This 

allows the perimeter reef crests to remain wet as water spills over them, and that allows the reef 

builders on the crests to grow slightly higher, to levels above mean low water. Over time, the crest of 

the perimeter reefs can grow upwards as much as 3 feet above the surrounding ocean at low tides. As 

a result, water levels in the lagoon are higher than that of the surrounding ocean, and the quantity and 

velocity of water flowing “downstream” out the ava greatly exceeds that which enters the ava during 

rising tides. 

Thus, any modification of the ava, such as widening or deepening it to facilitate better or larger boat 

passage, or having a large vessel disabled and blocking the flow of water through the ava, can have 

drastic effects on the biology of the lagoon and kill the reef builders on the crests of the perimeter 

reefs. Widening or creating boat channels through atoll reefs have degraded the lagoons of Kanton 

Atoll in the Phoenix Islands, atolls in Tuvalu, and several other atolls (Carpenter and Maragos 1989, 

Kaly and Jones 1991, Maragos 1993, 2011a, 2011b) and even the lagoons in some NWRs such as 

Johnston Atoll, Midway Atoll, and Palmyra Atoll. 

The ava is used by Refuge staff to enter the atoll when conducting management. No active 

management of the ava is conducted other than regulating boat traffic through the pass. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-12 Chapter 4. Biological Environment 

4.3.2 Reef (Crest and Back) 

The reef crest at Rose Atoll, constructed by countless 

generations of calcifying marine organisms whose 

remains have been cemented together over time by 

biochemical processes, varies from 1,000-3,000 feet 

wide. The predominance of CCA was noted by early 

scientific visitors (Mayor 1921, Setchell 1924) and 

has been reiterated many times thereafter. The reef 

crest is the living veneer of the ancient physical 

barrier separating the deep surrounding ocean from 

the shallow interior lagoon. By breaking the force of 

waves and currents, the shallow reef crest provides a 

sheltered environment inside which lagoon habitats 

have developed, and itself harbors a biotic 

assemblage adapted to shallow intertidal conditions. 

This living platform, which continues to accrete with successive generations of calcifying organisms, 

is resistant to physical- and bio-erosion, enabling formation and maintenance of the marine and 

terrestrial lagoon habitats in which other organisms exist. The reef crest is a vital habitat for Pacific 

reef herons and snowflake eels. 

In the aftermath of the 1993 grounding, extensive damage resulted to CCA, corals, sea urchins, and 

other biota on the reef crest and neighboring lagoon back reef from mechanical abrasion and 

chemical release. Iron released by the deterioration of metallic debris stimulated cyanobacterial 

populations on the reef crest and neighboring back and patch reefs and caused them to spread to other 

parts of the atoll that were not directly affected by the grounding. Transects conducted on the reef 

crest from 1995-2010 showed continuing recovery of CCA cover. 

The perimeter reef crest includes the back reef which is the unconsolidated terrain, composed largely 

of rubble that slopes from the reef crest to the more interior, sandier benthos. 

4.3.3 Lagoon 

Rose has an almost completely enclosed 

lagoon, measuring less than 1.2 miles at its 

widest point, with only one ava at the 

northwest corner. Because the ava is shallow 

and narrow, the volume of water exiting the 

ava is less than the volume of water entering 

over the reef crest during tidal cycles. As a 

consequence, water levels in the lagoon remain 

higher than those on the ocean side except at 

the highest tides, and the volume and velocity 

of water flowing out the ava greatly exceeds 

that which enters at that site. 

Reef flat. Frank Pendleton, USFWS. 

Lagoon with pinnacle. Kelsie Ernsberger, USFWS. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Biological Environment 4-13 

The lagoon includes the more finely divided “shallow lagoon,” “lagoon floor,” and “lagoon 

pinnacles.” Detailed bathymetry produced by NMFS PIFSC shows the lagoon floor maximum depth 

at 98 feet. Circulation and water mixing in tropical reef lagoons and back-reef areas is restricted 

compared to neighboring fore-reef slopes and surrounding oceanic surface waters. This restricted 

circulation frequently results in temperature differences of several degrees between the lagoon 

reservoir and the surrounding ocean. This effect is especially apparent in enclosed atoll morphologies 

during periods of high solar radiation and low winds. At Rose Atoll, interpolation of in situ surface 

water temperatures measured from conductivity/temperature/depth instruments and towed 

thermistors in February 2002 showed warmer surface waters by up to 5.5°F higher inside the lagoon 

and back-reef areas compared to the cooler, relatively well mixed waters in the fore-reef area and 

surrounding ocean. Turbidity as indicated by short-term measurements of beam transmission was 

notably higher inside the lagoon compared with other areas outside the perimeter reef crest (NMFS 

PIFSC 2008). The lagoon also displayed higher values of Chlorophyll-a, NO2, and SiO2 when 

compared with the fore reef. Finally, the lagoon consistently registered the densest and most saline 

waters at Rose, especially below the sill depth (approximately 16 feet) of the ava. These elevated 

nutrient concentrations, coupled with increased or variable turbidity, suggest prolonged periods of 

mixing, flushing, and nutrient cycling within the surface-water layers of the protected shallow-water 

lagoon. Wave-induced lagoon circulation is tidally modulated as more wave set-up occurs during 

high tides and less during low tides. The net effect is that surface waters in the lagoon likely have a 

short residence time. The high-salinity and high-density subsurface waters in the lagoon, on the other 

hand, have no obvious means to circulate and flush out of the lagoon. Hence, lagoon bottom waters 

likely have much longer residence times. 

While much of the lagoon floor consists of 

unconsolidated sand and rubble (Kenyon et 

al. 2010), a number of hard-bottom pinnacles 

are found rising toward the surface, 

providing substrate that supports corals, 

faisua, other macroinvertebrates, and diverse 

fish populations. Coral cover on the lagoon 

pinnacles is dominated by the genera Favia, 

Montipora, Porites, and Astreopora. Faisua 

density is highest at the base of the lagoon 

pinnacles. Small- to medium-sized fish are 

very abundant around several of the larger 

pinnacle patch reefs inside the lagoon, where 

parrotfish, snapper, emperor, goatfish, and 

jacks are common (NMFS PIFSC 2008). 

4.3.4 Intertidal 

The North end of Rose Island is characterized by an expanse of sand and rubble that is exposed at 

low tide. Large groups of terns (primarily brown noddies and sooty terns) form “clubs” here when 

the area is exposed, possibly because it is not being used for nest territories and offers good visibility 

for quick escape. Seabird clubs are ephemeral single-species groups of apparently unoccupied birds 

that congregate and socialize or rest together. Shorebirds such as wandering tattlers and ruddy 

Coral cover on the lagoon pinnacles is dominated by the 

genera Favia, Montipora, Porites, and Astreopora. Jean 

Kenyon, USFWS. 
Rose Atoll National Wildlife Refuge 

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4-14 Chapter 4. Biological Environment 

turnstones also forage on the exposed sediment. When the tide comes in reef fish move in as well to 

forage in the shallow water. 

4.3.5 Beach Strand 

Whistler (1992) defines littoral/herbaceous 

strand (part of beach strand) as a narrow zone of 

vegetation occupying the upper portion of sandy 

or rocky beaches, limited inland by littoral 

forest or littoral shrubland, and seaward by the 

high-tide mark of the ocean. Littoral strand 

occupies the transition zone between the sea and 

the forest (Amerson et al. 1982). This 

community is dominated by herbaceous 

creeping vines, and shrubby species up to 6.5 

feet or more in height (sometimes prostrate or 

dwarfed by the strong, salty sea winds). It also 

includes strand species found on coasts with 

exposed rocks within, or beyond, the reef 

(Amerson et al. 1982). The beach strand habitat 

is a harsh environment, subjected to dry conditions, high temperatures, salt spray, or occasional 

inundations by salt water. In addition, plants in this community must grow in direct tropical sunlight 

and grow on poor sandy or rocky soil. 

Beach strand habitat is a result of dynamic, natural processes of waves washing away and rebuilding 

sediment on both Rose and Sand Islands. On Sand Island the habitat is often devoid of vegetation or 

sparsely vegetated while on Rose Island the habitat supports Tournefortia argentea (tree heliotrope) 

shrubs. The beach strand vegetation on Rose Island is dominated by Boerhavia repens and 

historically also consisted of Portulaca lutea or tamole (Amerson et al. 1982, IUCN 1991, Setchell 

1924). It is presently confined to a single boulder in the reef crest. These large coral blocks thrown 

up by extreme storm events serve as roosts for Pacific reef herons and brown boobies. It is likely that 

seeds of additional species regularly wash up on the beach and then die back as storm surges wash 

them away. In 1921 when Mayor described the atoll, Sand Island had absolutely no vegetation; 

however, some species would be established periodically until the next storm waves washed them 

away. 

Beach strand at Rose Island. Kelsie Ernsberger, 

USFWS. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Biological Environment 4-15 

Some native ground nesting seabirds (i.e., sooty terns) thrive in this open habitat. Sooty terns, brown 

noddies, gray-backed terns, and black-naped terns use (mainly for nesting) the beach strand habitat 

on Rose and Sand Islands. Rose Atoll beach strand habitat is an important foraging, resting, and 

molting ground for six migratory shorebirds: the ruddy turnstone, sanderling, wandering tattler, 

whimbrel, bristle-thighed curlew, and the Pacific golden plover. Ghost crabs (Ocypoda spp.) forage 

and dig their burrows in the beach strand and Coenobita (hermit) crabs traverse the sand at night to 

get to the water’s edge for hydration. Due to overharvest, loss of beach habitat, incidental kills in 

fishing gear, and other reasons, green turtle numbers have declined worldwide and the beach strand 

at Rose Atoll provides a vital nesting area for this species. Present management of the beach strand 

includes removing marine debris and looking for and controlling invasive plants. 

4.3.6 Littoral Forest 

Littoral forest is a common vegetation type occurring on tropical shores. It often consists of a dense 

forest dominated by a single tree species. The major factor determining the distribution and extent of 

littoral forests is the ocean. Common characteristics for tree species in the community include 

tolerance of bright sunny conditions; dispersal by buoyant, salt-tolerant seeds (or hitchhiking on 

seabirds); and tolerance to salt spray and wind. However, most species are not tolerant of standing 

water or frequent incursions of salt water (Amerson et al. 1982). Typically, the forest floor is open 

due to the lack of bright sunlight required for germination and growth of most herbs and shrubs 

growing on the beach strand (Whistler 1992). The limiting factor for tree species is substrate and 

soils (Amerson et al. 1982). The dominant tree species of Samoa include: Barringtonia asiatica and 

Portulaca lutea growing on a block at Rose Atoll. Jiny Kim, USFWS. 

Boerhavia (left photo). Jiny Kim, USFWS. Seabirds using beach strand habitat (middle photo). Jiny Kim, 

USFWS. Coenobita crab (right photo). Kelsie Ernsberger, USFWS.
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-16 Chapter 4. Biological Environment 

Calophyllum inophyllum in certain beach areas and 

historically Pisonia grandis on Rose Atoll. But 

other tree species that may also thrive in this forest 

type include Hernandia nymphaeifolia, Terminalia 

catappa, Cordia subcordata, Neisosperma 

oppositifolium, Guettarda speciosa, Thespesia 

populnea, Tournefortia argentea, and Cocos 

nucifera. Although common and sometimes 

dominant on Polynesian shores, coconut trees have 

presumably been planted or are remnants of former 

cultivation due to their presence mostly in or near 

villages and coastal plantations. 

A map made in 1839 shows Rose Island extended 

across the width of the atoll rim and was covered by 

forests (Keating 1992). When Alfred Goldsborough 

Mayor did the first scientific account of Rose Atoll 

in 1920, he found the southern and southeastern half 

of Rose Island covered with a dense Pisonia 

grandis-dominated forest, with no other understory 

plants, except a single coconut tree. The largest 

trees were found near the southern end of the forest. Plant observations from 1974-1988 have 

documented at least 10 additional species that were established at one point (Wegmann and 

Holzwarth 2006). However, during the visit in 2010, eight species (Boerhavia repens, Tournefortia 

argentea, Pisonia grandis, Portulaca lutea, Hibiscus tiliaceus, Nephrolepis hirsutula, Cocos 

nucifera, Cordia subcordata) were documented. Appendix A lists the plant species of Rose Atoll, 

collections or first observations, and most recent information about current presence or absence. Rose 

Atoll’s littoral forest is currently dominated by Tournefortia argentea which forms a forest up to 25 

feet tall. Historically Rose Island supported a mature stand of Pisonia grandis. 

Pisonia grandis, found almost exclusively in Indo-Pacific islands from tropical Africa to eastern 

Polynesia and Micronesia is spread by sticky fruits that become attached to seabirds. It is a shadeintolerant plant that thrives on sandy shores and islands, particularly in soil enriched with guano from 

Left photo: Rose Island from the sea in 1939, dominated by Pisonia. National Archives. Right photo: Rose Island 

from the lagoon in 2007 with just a few unhealthy Pisonia trees remaining. USFWS. 

Pisonia. USFWS. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Biological Environment 4-17 

seabirds. The distinct soil in the Pisonia grandis grove on Rose Island consists of an upper layer of 

rich chocolate-colored humus, which extends to over six feet in depth (Mayor 1921, Lipman and 

Taylor 1924) overlying the calcium carbonate bedrock. Pisonia grandis is considered “one of the 

most salt-tolerant plants of which we have record at present” that is able to inhabit the unusually high 

salt concentrations in the soil on Rose Island (Lipman and Shelley 1924). The lack of fresh surface 

water and the properties of the soil most likely explain the limited number of plant species that are on 

the atoll (Amerson et al. 1982). 

Pisonia forests are declining throughout the Pacific. Historically, the best example of a Pisonia forest 

in American Samoa, Rose Island’s Pisonia forest has undergone several gradual periods of dieback 

and regeneration. The dieback was noted in the early 1970s but was regenerating by 1976 (Amerson 

et al. 1982). The cause of this dieback was unknown, but thought to be disease, drought, or an insect 

attack (Amerson et al. 1982). First documented in 2002, the soft scale insect (Pulvinaria urbicola) is 

associated with the once healthy forest’s decline (Wegmann and Holzwarth 2006). In May 2004, 10 

of the remaining 11 mature Pisonia trees were treated with injections of a systemic pesticide called 

imidacloprid (Trade name Imicide ®). Loss of trees 

continued so it appeared as if the response came too 

late and this approach alone has not significantly 

deterred the scale infestation. Scale insect infestation 

is associated with significant loss of Pisonia forests 

worldwide (Queensland Parks and Wildlife Service 

2006, 2007). Since the Polynesian rat was eradicated 

in 1993 coconut palms have been released from rat 

herbivory and have increased to a population size 

that threatens to shade out recruitment of native 

canopy trees. 

The Pisonia trees along with tree heliotrope serve as important nesting and roosting habitat for the 

red-footed booby, great and lesser frigatebird, black noddy, and white tern, which prefer to nest 

above the ground on trees. Tree heliotrope also provide cover for red-tailed tropicbirds, brown 

noddies, sooty terns, and brown boobies which nest directly on the ground. Shrubs and rock piles 

also provide shade and daytime cover for the numerous land hermit crabs that inhabit the island. 

Thick vegetation and rock crevices also provide shelter and protection for the largest land crab, the 

coconut crab (Birgus latro). This species seems to have increased in density since the eradication of 

rats at Rose Atoll. The relatively open understory of the Pisonia forest is also favored habitat for 

Pacific golden-plovers, wandering tattlers, and ruddy turnstones (Engilis and Naughton 2004). 

Littoral forests were at one time a common habitat in the Pacific; however, human alteration of island 

landscapes has limited this forest type. The eradication of rats from Rose Atoll by 1993 provides 

important habitat for plant species that will be able to recolonize the atoll and perpetuate the littoral 

habitats that are in decline throughout the Pacific region. 

4.4 Threatened, Endangered, and Sensitive Species 

One goal of the Refuge System is “to conserve, restore where appropriate, and enhance all species of 

fish, wildlife, and plants that are endangered or threatened with becoming endangered.” In the policy 

Scale insect on Pisonia leaf. Kelsie Ernsberger, 

USFWS. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-18 Chapter 4. Biological Environment 

clarifying the mission of the Refuge System, it is stated, “we protect and manage candidate and 

proposed species to enhance their status and help preclude the need for listing.” In accordance with 

this policy, the CCP planning team considered species with Federal or State/Territory status, and 

other special status species, in the planning process. 

4.4.1 Tuli (Numenius tahitiensis) or Bristle-thighed Curlew 

Bristle-thighed curlews breed in western Alaska and migrate during the winter to remote, small 

islands and atolls in the tropical Pacific Ocean (Marks and Redmond 1994). The beaches and littoral 

forest of the atoll are important wintering ground for bristle-thighed curlews. This rare shorebird is 

the only migratory species whose entire population is restricted to the insular Pacific (Hayman et al. 

1986, Marks et al. 1990). Marks and Redmond (1996) documented the strong fidelity shown by 

bristle-thighed curlews to wintering sites. At Laysan Island in the Northwestern Hawaiian Islands 

(NWHI), only 1 of 16 marked adult bristle-thighed curlews changed its wintering home range area in 

3 years of study (Marks and Redmond 1996).

This species undergoes a molt-induced flightless period (unique in shorebirds) and leaves many birds 

more susceptible to predatory attacks during that time (Marks 1993, Marks and Redmond 1994). 

Therefore, predator-free islands to which these birds are adapted have become increasingly important 

as competition for space increases and less habitat is available due to an increasing human 

population. With a global population of approximately 10,000 individuals (Morrison et al. 2006), the 

Service (USFWS 2008) has designated the curlew as a Bird of Conservation Concern and it is also 

ranked as Vulnerable by the International Union for Conservation of Nature (IUCN) (Engilis and 

Naughton 2004, IUCN 2008). It is also highlighted as a globally threatened species in need of 

regional action by the South Pacific Regional Environmental Programme. 

4.4.2 Tuli (Pluvialis fulva) or Pacific Golden Plover 

The Pacific golden plover breeds in western Alaska and Siberia and winters throughout the Pacific 

Islands. Plovers foraging at Rose Atoll likely come from the Alaskan breeding population, however, 

these affinities are still poorly understood (Engilis and Naughton 2004). Pacific golden plovers are 

widespread across the Pacific region in any open habitat from beach strands to upland pastures, 

occurring in good numbers on remote islands and atolls. Amerson et al. (1982) estimated 4,500 

Pacific golden plovers in American Samoa, a small population number relative to the total United 

States Pacific Islands (USPI) populations (Engilis and Naughton 2004). Johnson et al. (2008) studied 

migration behavior of Pacific golden plover in American Samoa and were able to confirm that at 

least 1 of the 30 birds they tagged on Tutuila Island was breeding in Alaska. The birds departed 

Samoa for the northward migration in mid-April. The return of the plovers began in late August and 

peaked in mid-September. This represents at least a 5,594 mile trip from American Samoa. Johnson 

et al. (2008) estimated there were 500 golden plovers on Tutuila. The largest count of Pacific golden 

plovers recorded at Rose Atoll was 49 individuals in 1984. The USPI Regional Shorebird 

Conservation Plan (Engilis and Naughton 2004) identified the plover as a species of High 

Conservation Concern.
Rose Atoll National Wildlife Refuge 

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Chapter 4. Biological Environment 4-19 

4.4.3 I’a sa (Chelonia mydas) or Green Turtle 

I’a sa is listed as threatened under the ESA. Adults can weigh up to 500 pounds and are often found 

living near tropical reefs and rocky shorelines. Females may lay up to 6 clutches per season in pits 

excavated in soft beach sand, with each clutch containing about 100 eggs. Hatchlings and juveniles 

live in pelagic waters. Little information exists on the feeding behavior of post-hatchlings and 

juveniles living in pelagic habitats, but most likely they are exclusively carnivorous (e.g., soft-bodied 

invertebrates, jellyfish, and fish eggs). Subadult and adult turtles residing in nearshore benthic 

environments are almost completely herbivorous; their common name is derived from the color of 

the animals’ body fat, which is green from the marine algae and sea grasses they eat. 

I’a sa use the protected habitats of Rose Atoll for feeding and nesting. Their numbers have declined 

throughout the south Pacific due to the combined effects of habitat destruction, human harvest for 

meat and shells, depredation by introduced predators, and incidental drowning in fishing gear (Kinan 

2005, Craig 2002). The isolated beaches on Rose Atoll provide an important nesting ground for green 

turtles. The number of green turtles nesting annually at Rose Atoll has been estimated at 24-36 

(Tuato’o-Bartley et al. 1993). The total number of turtles using Rose Atoll as a nesting ground would 

actually be several fold higher, since females only nest every 2-5 years (Spotila 2004, NMFS and 

USFWS 1998a), and thus a different set of turtles nest each season. Given the scarcity of beaches 

where turtles can nest and their eggs hatch unmolested, the value of the isolated beaches at Rose 

Atoll is considerable, even if only 120 or so turtles nest there. 

The Historical Summary of Turtle Observations 

at Rose Atoll, American Samoa, 1839-1991 

(Balazs 1991) is a compilation of historical data 

and notations. The document lists a total of 47 

entries for that time period, most of the earlier 

ones simply reporting presence or absence of 

turtles. From 1970 onward, turtle observations 

were more quantitative, if no less sporadic and 

opportunistic due to the expense of reaching the 

remote atoll. Aerial, land-based, and waterbased surveys recorded the number of turtles, 

their tracks, nest pits, eggs, hatchlings, and 

nesting and mating behaviors (Balazs 1991). An 

estimated 200 turtles were counted in the 

lagoon during an aerial survey in August 1974, 

the highest value recorded. A total of 406 pits 

were counted on both Rose and Sand Islands during a survey in October 1976. A decade later, in fall 

1985, biologists counted a total of 244 pits on both islands, and a decade after that, in fall 1992, the 

total count was 81 nesting pits. However, the problem with nest pit counts is that female turtles often 

dig test pits before actually laying eggs, and they lay multiple clutches the year they make the long 

migration to their natal nesting beach. Also, unless there is a major storm event that wipes the beach 

clean, it is difficult to reliably discern if a pit was dug that season or the season before (Ponwith 

1990). These limitations, as well as uneven survey effort, should be taken into account when 

comparing pit counts from various years, and it should be recognized that pit counts are not the 

equivalent of a population count. 

Green turtle swimming in Rose Atoll lagoon. Kelsie 

Ernsberger, USFWS. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-20 Chapter 4. Biological Environment 

The green turtles that visit Rose do so seasonally for reproduction, and spend the rest of their time in 

other parts of the south Pacific. Metal flipper tags were applied to a total of 46 nesting females from 

1971-1996 in order to see where they traveled (Balazs 1991). Three of these tags were re-sighted 

after the turtles were killed for food or fatally injured from a hunting attempt. Two were located in 

Fiji at the time of tag recovery and one in Vanuatu (both island groups to the west of Samoa). A 

fourth turtle was re-sighted at Rose Atoll, 9 years after she was initially tagged (Ponwith 1990), 

making multiple visits to the beach to nest. 

Given the limited re-sighting rate of flipper tags, satellite tagging was subsequently employed in an 

effort to better comprehend the migration routes of green turtles in the south Pacific (Craig et al. 

2004). Seven females at Rose Atoll were outfitted with satellite tags during the nesting seasons of 

1993-1995. After 2 months of nesting at Rose, 6 of the turtles traveled to feeding grounds in Fiji. The 

seventh turtle traveled due east to Raiatea, an island in French Polynesia. The turtles’ migration route 

crossed 994 miles of ocean and took an average of 40 days. The route followed prevailing surface 

currents as recorded by satellite-linked ocean drifters deployed from Rose in February 2002, though 

the drifters traveled more slowly (net rate of 0.3 meter per hour [1.0 foot per hour]) than the turtles 

(1.1 meters per hour [3.6 feet per hour]). While these green turtles spend the majority of their life in 

Fiji, accumulating the fat stores that will enable them to reproduce, the remote beaches at Rose Atoll 

provide invaluable undisturbed nesting habitat (Craig et al. 2004). 

Unlike many places in their range, at Rose Atoll, turtles can approach the beach without risk of being 

harvested for meat or drowned in nets, and eggs and hatchlings are free from depredation by wild 

pigs, rats, dogs, and humans. Marine debris can also prove deadly when it entangles turtles or is 

mistaken for food and ingested. Plastics are particularly harmful as they may remain in the turtle’s 

stomach for long periods of time, releasing toxic substances, and can clog the digestive system. 

Natural predators and dangers inherent to the human populated areas east of Samoa where the turtles 

feed continue to impact turtle populations. Craig et al. (2004) stresses the importance of working 

towards protection for turtles in their foraging waters east of Samoa, since this is where turtles spend 

90 percent of their adult life. Continued monitoring of the nesting beaches at Rose Atoll will give 

researchers a proxy for population trends of green turtles in the region. 

4.4.4 Hawksbill Turtle (Eretmochelys imbricata) 

Hawksbill turtles use the protected habitats of Rose Atoll. Similar to i’a sa, their numbers have 

declined throughout the south Pacific, impacted by the combined effects of habitat destruction, 

human harvest for meat and tortoise shell, depredation by introduced predators, and incidental 

drowning in fishing gear (Kinan 2005; Craig 2002). Although it is not clear if hawksbills nest at Rose 

Atoll, they are consistently sighted using the lagoon and open water habitats around the atoll. 

The hawksbill turtle is listed as endangered under the ESA. It is one of the smaller turtles and takes 

its species name (imbricata) from the overlapping plates on its upper shell and its common name 

from the shape of its hooked jaw. The carapace (top shell) of an adult ranges from 25-35 inches in 

length and has a “tortoiseshell” coloring, ranging from dark to golden brown, with streaks of orange, 

red, and/or black. Hawksbill turtles use different habitats at different stages of their life cycle, but are 

typically found around coastal reefs, rocky areas, estuaries, and lagoons. Their narrow head and jaws, 

shaped like a beak, allow them to get food from crevices in tropical reefs. They eat sponges, 

anemones, squid, and shrimp. Hawksbills have been consistently reported at Rose Atoll in historical 
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accounts (Setchell 1924), as well as more recent surveys (Sekora 1974, Ludwig 1981, Amerson et al. 

1982, Morrell et al. 1991, Flint 1992, NMFS PIFSC 2006).

4.4.5 Faisua (Tridacna maxima) or Giant Clam 

The colloquial term “giant clam” refers to eight species of marine bivalves found in two genera 

(Hippopus and Tridacna) of the molluscan subfamily Tridacninae. Surveys of faisua populations at 

Rose Atoll have identified a single species, Tridacna maxima (Wass 1981, Green and Craig 1999). 

Less than a third of the size of the “true” giant clam Tridacna gigas, T. maxima is commonly referred 

to as the “small giant clam,” with shells generally not exceeding 9 inches in length. Found living on 

the surface of reefs or sand, or partly embedded in coral, the faisua occupies well-lit areas, due to the 

symbiotic relationship with single-celled photosynthetic algae (zooxanthellae) found in its fleshy 

mantle that require sunlight for energy 

production. Faisua also filter-feed on 

phytoplankton extracted from seawater 

siphoned through their body. 

Mature faisua are hermaphrodites that 

reproduce by broadcast spawning, releasing 

sperm first, followed by eggs. The fertilized 

egg develops into a larva within 3 hours and 

passes through two additional larval stages 

before undergoing metamorphosis after 8-10 

days into a juvenile, sessile faisua that acquires 

zooxanthellae. Reproductive and growth studies 

at Rose Atoll (Radtke 1985) showed the clams 

reach maturity at about 10 years of age 

corresponding to a shell size of 3-5 inches. 

Young faisua are male and put most of their 

energy into growth, becoming hermaphrodites upon maturity and accompanied by a slower growth 

phase. Reproduction is stimulated by the lunar cycle, the time of day, and the presence of others eggs 

and sperm in the water. Faisua lifespan at Rose Atoll is estimated to be approximately 28 years. 

Tridacna maxima has the widest geographic range of all giant clam species. It is found in the oceans 

surrounding east Africa, India, China, Australia, Southeast Asia, and the islands of the Pacific. 

Although classified as Least Concern on the IUCN Red List, this culturally and ecologically 

important marine animal has declined precipitously from overharvesting in many populated areas 

including the high islands of American Samoa, but remains abundant at Rose Atoll (Green and Craig 

1999). Tridacna maxima is listed under Appendix II of CITES meaning it is not necessarily 

threatened but that trade must be controlled in order to avoid use incompatible with its survival. 

The first survey of faisua at Rose was undertaken by the American Samoa DMWR in an attempt to 

quantify the resource in response to requests by the Samoans that they be allowed to harvest the 

clams (Wass 1981). The study found faisua to be uncommon in the ava and fore reef but abundant in 

the lagoon. Distribution in the lagoon was patchy, with faisua abundant on solid substrate in the 

shallow, relatively clear parts of the lagoon, but with lower densities in the southern lagoon and 

below approximately 45 feet where water became more turbid. Constraints of time as well as the 

uneven distribution of suitable clam substrate in the lagoon made density determinations difficult, 

Giant clams (Tridacna maxima) embedded in 

Astreopora coral. Kelsie Ernsberger, USFWS. 
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with the single transect survey in the southwestern lagoon yielding an average density of 0.33 clam 

per square yard. Size frequency data were collected at four lagoon locations; shell measurements 

ranged from 0.4-9 inches, with approximately 31 percent being greater than 5.5 inches, the size at 

which all clams are fully hermaphroditic. 

More extensive transects by Radtke (1985) in various habitats showed marked differences related to 

depth and substrate. Lagoon patch reefs in 20-40 feet of water were concluded to be prime habitat for 

faisua, with densities of 3.6-7.2 clams per square yard and 40-50 percent of the area colonized. 

Smaller coral patches (with up to 3.6 clams per square yard) and lagoon substrate (with up to 6 clams 

per square yard) were colonized at approximately 20 percent. Shell measurement ranged from 0.4-9 

inches, with bimodal peaks around 1-2 inches and 6-7 inches. Radtke’s total estimated number of 

faisua in the lagoon was approximately 1,338,000. Unlike Wass (1981) Radtke did not favor 

controlled harvesting, stating, “they have a respectable number of organisms in this ecosystem, but 

due to their slow growth would have a small sustainable yield ... quantitative balance of production 

of Tridacna maxima at Rose Atoll does not appear to be within the scope of rational exploitation and 

exploitation could endanger the perpetuity of the unique environment”. 

A pivotal study by Green and Craig (1999) highlights the importance of Rose Atoll as a refuge for 

faisua. In 1994-1995 they surveyed all 6 islands of American Samoa and recorded a total of 2,853 

clams in survey transects, 97 percent of which were found at Rose. The majority were located in the 

lagoon, with faisua favoring areas at the base of pinnacle patch reefs. Roughly a quarter of the clams 

were mature in size, and mortality was estimated as being very low, due mostly to natural causes. 

The largest clam recorded was 11 inches across the widest part of the shell. Given the mean density 

of faisua, the population at Rose was estimated to be approximately 27,800 clams. The dramatically 

lower estimate than that provided by Radtke (1985) was considered to be the result of differences in 

sampling design rather than a population decline. The authors theoretically considered Rose to be a 

potential source of faisua recruits to other islands in the Samoan archipelago, given larval longevity 

(approximately 8 days, range 5-15 days) and water currents flowing westward from Rose at 16 miles 

per day. 

Towed-diver surveys conducted by NMFS PIFSC in 2006 recorded more than 1,100 giant clams on 

30 linear miles of transect, with approximately 95 percent recorded on reefs inside the lagoon 

(NMFS PIFSC 2006). Researchers have noted that the pinnacle just inside the ava had a markedly 

lower density of faisua than the rest of the lagoon and it seems likely that this is where illegal 

harvesting has taken place (Wegmann and Holzwarth 2006). 

4.5 Seabirds 

Rose Atoll’s importance to seabirds in the South central Pacific is disproportionately large relative to 

size of the populations breeding there. There are very few uninhabited islands in the region so Rose 

provides habitat for species that do not thrive in proximity to human settlements. Seabirds and 

migratory shorebirds are the numerically dominant terrestrial vertebrates. Since 1975, 16 species of 

seabirds have been recorded on land and 12 species are known to breed there. Efforts to eradicate the 

island of Polynesian rats began in 1991, with eradication declared in 1993. This enhanced the value 

of the atoll for seabird conservation and has increased the possibilities that other Pacific seabird 

species that are currently threatened from habitat loss, predation, and invasive species, such as 

wedge-tailed shearwaters, Christmas shearwaters, Bulwer’s petrel, Phoenix petrel, and the 
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Polynesian storm petrel might someday colonize the site. Social attraction methods may accelerate or 

facilitate this process of recruitment. Rose Atoll falls into the North American Bird Conservation 

Region called “Other U.S. Pacific Islands” and is now considered separately from sites in the 

Caribbean (USFWS 2008). 

For most if not all of the seabirds listed, habitat destruction, invasive weeds, disturbance, ungulates, 

and introduced predators limit populations (Metz and Schreiber 2002). Introduced predators such as 

rats, mongoose, and cats have reduced populations at many sites worldwide (Harrison 1990). El 

Niño-Southern Oscillation conditions can cause total or partial breeding failure in some locations 

(Schreiber and Schreiber 1989, Schreiber 1994, Orta 1992b). 

4.5.1 Tava’e’ula (Phaethon rubricauda) or Red-tailed Tropicbird 

The tava’e’ula is a medium-sized bird with shining pinkish-white feathers and red tail plumes. They 

breed mainly on oceanic islands and coral atolls in the Indian and Pacific oceans. Breeding adults are 

mostly sedentary; however, they avoid land when not breeding and are among the most pelagic and 

solitary of seabirds (Schreiber and Schreiber 1993, Harrison 1990, Harrison et al. 1983). At sea, 

tava’e’ula are evenly distributed throughout their range (Schreiber and Schreiber 1993, King 1970). 

Little is known about their movements outside the breeding season. 

The world population is estimated at 17,000-21,000 pairs; with an estimated 12,000-14,000 pairs in 

the Pacific (Schreiber and Schreiber 1993, Gould et al. 1974). Small colonies exist in American 

Samoa and other remote Pacific islands. The largest number of active nests observed at Rose on any 

particular visit was 38 in 2002. The world population seems stable in many areas and may be 

increasing in some areas, but there is a lack of information on past population estimates so 

comparisons are difficult (Schreiber and Schreiber 1993). Within the USPI, tava’e’ula populations 

appear stable overall. 

Tava’e’ula nest on the ground under vegetation in the understory and base of trees, among rocks, 

roots, or logs and less commonly in the cavities of cliff faces (Schreiber and Schreiber 1993, Orta 

1992a). At Rose red-tailed tropicbirds chose to nest under Tournefortia or Pisonia (Morell and 

Aquilani 2000). Nests are scrapes that vary from a shallow depression in the sand to more elaborate 

structures consisting of twigs and leaves (Schreiber and Schreiber 1993, Harrison 1990, Fleet 1974). 

Breeding occurs annually, but timing varies depending on locality (Schreiber and Schreiber 1993, 

Harrison 1990). First breeding usually occurs around 2-4 years (Schreiber and Schreiber 1993, 

Harrison 1990). The oldest-living bird was 23 years (Klimkiewicz and Futcher 1989). 

Tava’e’ula are attracted to ships, presumably because flyingfish, their main prey, are scattered by 

ships (Harrison et al. 1983). Previously the tava’e’ula also nested on Tutuila, however the abundance 

of introduced animals such as rats, cats, and dogs that attack ground nesting birds likely led to their 

extirpation. Introduced ants have been recorded attacking incubating adults, chicks, and eggs at some 

colonies in the Pacific. 

4.5.2 Atafa (Fregata minor) or Great Frigatebird 

The great frigatebird has a pantropical distribution that overlaps with lesser frigatebirds (Orta 1992b) 

and breeds mainly on small remote islands, typically within regions with tradewinds in the tropical 

Atlantic, Indian, and Pacific Oceans. At sea, birds can be found any distance from land but they are 
Rose Atoll National Wildlife Refuge 

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most abundant within 50 miles of breeding and roosting sites (King 1967). Adults, juveniles, and 

nonbreeders disperse widely throughout the tropical seas. 

The world population is estimated at 500,000-

1,000,000 birds (Orta 1992b). A small population of 

fewer than 50 pairs nests on Rose Island. They are 

colonial nesters, often constructing platform nests 

in the tops of bushes and trees. At Rose Island they 

nest in Tournefortia and Pisonia trees. Breeding 

occurs throughout the year depending on locality, 

with egg laying primarily in the dry season (Orta 

1992b). Great frigatebirds are sexually dimorphic; 

females tend to be 25 percent heavier than males 

(Orta 1992b) and males are almost entirely black, 

with varying amounts of dark metallic green and 

purple feathers and a large, red gular pouch that 

they inflate during courtship. Females are black 

with a white breast patch. Great frigatebirds are seasonally monogamous; it is extremely rare for 

pairs to remain together for subsequent breeding attempts (Orta 1992b). Females breed biannually, 

sometimes every 3-4 years (Orta 1992b). Post-fledging care, which continues for up to 18 months, is 

provided by females. Sexual maturity begins around 8-10 years and most birds return to the natal 

colony to breed (Orta 1992b). 

Great frigatebirds usually feed in mixed-species flocks over tuna schools (Orta 1992b, King 1967). 

Their diet consists mostly of flying fish and squid which they capture at or above the water’s surface 

(Harrison et al. 1983). Frigatebirds are notorious for their kleptoparasitism (a form of feeding where 

one animal takes prey from another that has caught or killed it), but most of their food is obtained by 

fishing (Harrison et al. 1983). 

Tuna fisheries exploitation likely could lead to the decrease in availability of prey for great 

frigatebirds (Metz and Schreiber 2002). 

4.5.3 Atafa (Fregata ariel) or Lesser Frigatebird 

The lesser frigatebird has a pantropical distribution that coincides with, but is smaller than that of the 

great frigatebird (Orta 1992b, Clements 2000). At sea, birds are most abundant within 50 miles of 

breeding and roosting islands although they can be found any distance from land (King 1967). 

Juveniles and non-breeders disperse throughout tropical seas (Harrison 1990). 

The species’ world population is estimated at several hundred thousand birds (Orta 1992b). Small 

colonies exist in American Samoa (Amerson et al. 1982) with fewer than 100 pairs nesting at Rose 

Atoll. Within the USPI, lesser frigatebird populations have significantly declined due to the 

introduction of cats and rats; however eradication of cats at Howland and Jarvis Islands seems to 

have resulted in an increase in lesser frigatebird populations at those sites (USFWS 2005, Rauzon et 

al. 2011). Human exploitation of tuna fisheries could potentially affect prey availability for lesser 

frigatebirds because they rely upon the large subsurface predators to push the species they use to the 

surface (Orta 1992b). 

Great frigatebird. Jim Maragos, USFWS. 
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Breeding takes place on small remote tropical islands. Nests and stick platforms are constructed on 

trees and bushes (e.g., Pisonia and Tournefortia bushes and trees on Rose Island) but when suitable 

vegetation is not available birds nest on bare ground (Orta 1992b). Lesser frigatebirds are sexually 

dimorphic; females tend to be heavier than males and males have a scarlet gular pouch that is inflated 

during courtship displays (Orta 1992b). They are seasonally monogamous; it is unlikely that pairs 

remain together for future breeding attempts (Orta 1992b). If successful, females can only breed 

successfully every 2-3 years since post-fledging care is provided by the female and can last 4-6+ 

months (Orta 1992b). Age to sexual maturity is unknown (Orta 1992b) but probably similar to that of 

great frigatebird at 8-10 years. 

Lesser frigatebirds feed in pelagic waters, usually in mixed-species flocks over tuna schools (Orta 

1992b, King 1967). Their diet consists primarily of flying fish and squid that they capture at or above 

the water’s surface (Nelson 1976). Lesser frigatebirds are notorious for kleptoparasitism but obtain 

most of their food by direct capture (Nelson 1976). 

4.5.4 Fua’o (Sula dactylatra) or Masked Booby 

Masked boobies have a pantropical distribution (Anderson 1993, Woodward 1972). There are four 

subspecies; S. d. personata breeds on islands in the central and western Pacific (Clements 2000). 

Within the USPI, the largest colonies are on Howland, Baker, and Jarvis, but a significant portion of 

the population nests on the NWHI. Birds forage in offshore and pelagic waters (King 1967). They are 

most abundant in the vicinity of breeding islands, but they can be encountered far out at sea (King 

1967). During nonbreeding periods, adults may visit sites 622-1,243 miles from breeding colonies 

(Woodward 1972, Clapp and Wirtz 1975, O’Brien and Davies 1990). 

The world population is widely distributed and 

therefore difficult to estimate but is thought to be 

several hundred thousand birds (Anderson 1993). 

Within the USPI, there are approximately 8,300 

breeding pairs with 1,200 pairs on Jarvis Island and 

over 1,500 pairs each on Howland and Baker Islands 

(Forsell 2002). Small colonies occur in American 

Samoa and Palmyra Atoll (Woodward 1972, King 

1967, Anderson et al. 1982) and Wake Atoll was 

recently recolonized by birds banded at Johnston 

Atoll (Rauzon et al. 2011). Rose Atoll is home to 

approximately 25 pairs. 

Masked boobies breed on oceanic islands and atolls. They tend to nest on open ground often near a 

cliff edge or on low sandy beaches or rocky ground (Anderson 1993, Harrison 1990). At Rose Atoll, 

they nest in open areas on the ground. They also form “clubs” or aggregations of nonbreeding birds 

on the fringe of breeding colonies (Woodward 1972). Breeding is fairly synchronous but timing 

varies depending on locality (Harrison 1990). Masked boobies are seasonally monogamous and at 

least 45 percent of pairs at Kure Atoll retained their mates through a second breeding season (Kepler 

1969). Two eggs are laid but broods are typically reduced to one chick by siblicide (Anderson 1993). 

Sexual maturity begins around 3-4 years and most birds return to their natal colony to breed 

(Anderson 1993, Nelson 1978, Kepler 1969). Adults sometimes skip a year between breeding 

attempts (Woodward 1972, Harrison 1990). 

Fua’o chick testing its wings. Jiny Kim, USFWS. 
Rose Atoll National Wildlife Refuge 

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Masked boobies feed by plunge-diving and can be found more than 93 miles from land (Harrison 

1990). They forage singly or in mixed-species flocks associated with schooling tuna (King 1967, 

Harrison et al. 1983). In Hawai‘i, fish constituted greater than 97 percent of the diet and squid less 

than 3 percent; flyingfish and jacks were the most important prey (Harrison et al. 1983). The oldestknown bird was 25 years. On Kure Atoll, annual adult mortality was less than 8.6 percent; mortality 

between independence and age 4 was 72 percent (Harrison et al. 1983). 

Masked boobies breed on a few islands with human populations but they are vulnerable to human 

disturbance (Anderson 1993). Overfishing of tuna could potentially have an impact on the 

availability of prey (Harrison 1990). Commercial-size mackerel scad were important in the diet of 

masked boobies at some locations, and potential effects of commercial fisheries are unknown 

(Harrison 1990). 

4.5.5 Fua’o (Sula leucogaster) or Brown Booby 

Brown boobies have a pantropical distribution (Schreiber and Norton 2002). There are four 

subspecies; S. l. plotus breeds on islands in the central and western Pacific (Clements 2000). In the 

USPI, brown boobies occur in the greatest numbers in the Hawaiian Islands. Breeding adults are 

mostly sedentary and juveniles disperse throughout the tropical seas (Carboneras 1992, Harrison 

1990). At sea they occur more nearshore than the other booby species (Sula dactylatra) and they are 

rarely seen over 50 miles from the nearest land (King 1967). Little is known of movements during 

nonbreeding periods but adults have been found up to 1,802 miles from breeding sites (Schreiber and 

Norton 2002). 

Worldwide, the number of brown boobies is estimated at 221,000-275,000 pairs, which includes 

50,000-70,000 pairs of S. l. plotus (Schreiber and Norton 2002). About 3,700 pairs nest in the USPI; 

approximately 700 nest in American Samoa. At Rose there are approximately 375 breeding pairs of 

brown boobies. The world population has 

declined dramatically over the past 200 years 

and possibly only 1-10 percent of historic 

populations remain (Schreiber and Norton 

2002). Currently the USPI population appears 

stable, with populations on Wake Atoll and 

Howland and Baker Islands gradually 

rebounding following eradication or control of 

cats (Rauzon et al. 2011). 

Brown booby breeding range overlaps with 

that of the other two species of booby on 

oceanic islands and atolls (Carboneras 1992, 

Harrison 1990). Nesting occurs on flat 

ground, often on cliff ledges, but they will 

also nest on sandy islands and bare coral 

atolls (Schreiber and Norton 2002). At Rose Atoll, brown boobies nest on the ground under the 

canopy of Pisonia and Tournefortia trees. Nests vary from a scrape in the sand to a fairly wellformed pile of twigs and grasses. Breeding is synchronous but timing varies depending on locality 

and occurs throughout the year (Schreiber and Norton 2002). Brown boobies are monogamous but 

maintenance of long-term pair bonds varies by location (Schreiber and Norton 2002). Pairs lay two 

Brown and red-footed boobies. USFWS. 
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(vary rarely three) eggs but the brood is often reduced to one chick as a result of siblicide (Schreiber 

and Norton 2002). Age of first breeding is typically 4-5 years (Schreiber and Norton 2002, Harrison 

1990). 

Brown boobies feed by plunge-diving and feeding is often solitary, but they may be found in feeding 

flocks with other species (Schreiber and Norton 2002, Harrison 1990). They forage in nearshore 

waters, ranging from 5-44 miles from land, and feed mostly on flyingfish, squid, mackerel scad, 

juvenile goatfish, and anchovy (Harrison 1990, Harrison et al. 1983). The oldest-known bird was 26 

years, but they probably live to at least 30 years (Schreiber and Norton 2002, Simmons 1967). Adult 

survivorship was 93.2 percent at Kure Atoll (Tershey 1998). At Johnston Atoll, survival from 

fledging to breeding ranged from 30-40 percent in an 18-year study (Schreiber and Norton 2002). 

A major threat to brown boobies has been the loss of habitat to development and human disturbance; 

newer pairs are especially vulnerable at the beginning of the breeding season (Schreiber and Norton 

2002). In American Samoa, hunting pressure on brown boobies was high during historic times and 

this may still occur on occasion (Amerson et al. 1982). 

4.5.6 Fua’o (Sula sula) or Red-footed Booby 

Red-footed boobies have a pantropical distribution that overlaps other booby species (Sula dactylatra

and Sula leucogaster) (Schreiber et al. 1996, Carboneras 1992). There are three subspecies; S. s. 

rubripes breeds in the central and western Pacific (Clements 2000). Red-footed boobies nest 

throughout the USPI. Distribution at-sea is pelagic; feeding flocks occur hundreds of miles from land 

(Harrison 1990). Breeding adults are mostly sedentary but juveniles roost near colonies on islands 

other than their natal island (Schreiber et al. 1996, Harrison 1990). Little is known about adult 

movements outside of the nesting season (Schreiber et al. 1996). 

The world population was estimated at less than 300,000 pairs in 1996 (Schreiber et al. 1996). In the 

USPI, there are approximately 19,000 pairs. Approximately 2,000 pairs nest in American Samoa 

(Amerson et al. 1982). Rose Atoll hosts 700 pairs of this species. The world population has been 

severely reduced over the last two centuries (Schreiber et al. 1996) and few data exist on current 

numbers (Cao et al. 2005). Cao et al. (2005) suggest the present day population size has declined to 

10 percent of their historical values. 

This species of booby is the smallest of the booby species and breeds on oceanic islands and atolls 

(Schreiber et al. 1996, Carboneras 1992). Unlike the masked and brown boobies, these boobies roost 

and nest on shrubs and trees but will use bare ground or low piles of vegetation (Schreiber et al. 

1996, Carboneras 1992, Harrison 1990). On Rose Island, red-footed boobies build nests in 

Tournefortia and Pisonia trees. Nests are made of twigs, grass, and other vegetation. Breeding is 

fairly synchronous but occurs throughout the year and timing varies by locality (Schreiber et al. 

1996, Harrison 1990). Several color phases exist, ranging from all brown to all white (Schreiber et al. 

1996, Nelson 1978). The most common color morph at Rose is the intermediate form. They are 

monogamous and generally retain their mates throughout subsequent breeding seasons (Schreiber et 

al. 1996). They lay one egg and continue to feed the young 1-2 months after fledging (Schreiber et al. 

1996, Carboneras 1992). Sexual maturity begins around 3-4 years and most birds return to their natal 

colony to breed (Schreiber et al. 1996, Harrison 1990). Adults usually breed every year but 

sometimes take a “rest” year (Schreiber et al. 1996, Harrison 1990). 
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Nesting black noddy. USFWS. 

Red-footed boobies feed on flyingfish, squid, mackerel scads, saury, and anchovies (Harrison 1990). 

Red-footed boobies often depart the colony to feed well before daylight but most return to the colony 

to roost at night (Carboneras 1992, Harrison 1990). Red-footed boobies feed by plunge-diving and 

may feed solitarily or in mixed-species foraging flocks (Au and Pitman 1986). They forage further 

from land than other boobies except possibly the masked booby (Nelson 1978). Annual adult survival 

was estimated at 90 percent in a 2-year study at French Frigate Shoals in the NWHI (Hu 1991). At 

Johnston Atoll, survival of chicks to breeding ranged from 27-52 percent depending on the year 

(Schreiber et al. 1996). The oldest-known bird was 22 year (Clapp et al. 1982). 

The large areas of mangrove forests destroyed in American Samoa may have once been important 

habitat for this species. Introduced scale insects and other factors at Rose Island are destroying the 

Pisonia forest. Human predation on adults, chicks, and eggs may occur in parts of American Samoa 

(Amerson et al. 1982). El Niño-Southern Oscillation conditions can cause total or partial breeding 

failure in some locations (Schreiber and Schreiber 1989, Schreiber 1994). 

4.5.7 Gogo Uli (Anous minutus) or Black Noddy 

The black noddy is an abundant and gregarious, 

medium-sized bird with a pantropical 

distribution (Gauger 1999, Clements 2000). 

Adults are sooty black with a white cap on the 

top of the head. There are seven recognized 

subspecies and at least three breed in the USPI: 

A. m. melanogenys in the main Hawaiian 

Islands; A. m. marcusi in the NWHI, Wake, and 

throughout Micronesia; and A. m. minutus in 

Samoa (Gauger 1999, Gochfeld and Burger 

1996). Breeding adults are mostly sedentary 

remaining at colonies year-round and foraging 

within approximately 50 miles of nesting 

islands (Gauger 1999, Ashmole and Ashmole 1967, King 1967). Juveniles probably remain at 

breeding colonies or travel to nearby roosting sites (Gauger 1999). 

The world population is estimated to be 1,000,000-1,500,000 pairs (Gauger 1999). In the USPI, there 

are approximately 22,400 pairs. An estimated 12,000 pairs nest in the Hawaiian Islands, and smaller 

colonies exist in American Samoa, Palmyra, Johnston, and Wake Atolls and the Marianas. 

Approximately 750 pairs use Rose Atoll. Worldwide population trends are unknown. 

The black noddy nest on oceanic and offshore islands (Gauger 1999). They place their nests on trees 

and bushes (Howard and Moore 1984, Harrison 1990); the nests on Rose Island are in Tournefortia 

branches. Breeding is asynchronous and aseasonal. Birds are monogamous, mate retention is high, 

and pairs retain their territory from year to year, often reusing the same nest (Gauger 1999, Schreiber 

and Ashmole 1970). The black noddy are capable of producing more than one brood per year and 

some lay a second egg while still tending the first chick (Gauger 1999, USFWS unpubl. data). Sexual 

maturity begins around 2-3 years (Gauger 1999). The oldest-known bird was 25 years (Gauger 

1999). 
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Nesting brown noddy. USFWS. 

Black noddies feed by hover-dipping and contact-dipping, and typically forage in multi-species 

flocks over schools of predatory fish, especially tunas and jacks (Ashmole and Ashmole 1967). They 

feed mainly inshore (<6 miles from shore) and sometimes within several feet of the shoreline 

(Harrison 1990, Gauger 1999). Black noddies eat fish almost exclusively and very small amounts of 

squid and crustaceans (Gauger 1999). In the central Pacific, flyingfish, blennies, mackerel, and 

anchovies are important components of the diet (Gauger 1999). 

Predation by introduced mammals limits populations and overfishing of large predatory fish may 

reduce feeding opportunities (Gauger 1999). 

4.5.8 Gogo (Anous stolidus) or Brown Noddy 

The brown noddy is a medium-sized tern 

with a pantropical distribution (Chardine 

and Morris 1996), dark brown in color all 

over except for the whitish-gray cap on the 

top of its head. There are five subspecies; 

A. s. pileatus breed in the central and 

western Pacific (Harrison and Stoneburner 

1981). Brown Noddies have been shown to 

breed more than once per year in the 

Northwestern Hawaiian Islands (Megyesi 

and Griffin 1996). Breeding adults remain 

within sight of the colony, foraging in 

waters several tens-of-miles from the 

colony (Morris and Chardine 1992, 

Clements 2000). During nonbreeding 

periods, brown noddy have been shown to 

stay within 62 miles of colonies (Clapp et al. 1983, Harrison 1990) or to migrate out of the area for 

several months (Murphy 1936, Morris and Chardine 1992). Little is known of the movements of 

juveniles (Chardine and Morris 1996). 

The world population is estimated at 500,000-1,000,000 pairs (Chardine and Morris 1996). Within 

the USPI, there are about 135,000 pairs (Harrison et al. 1983). Approximately 9,000-11,000 pairs 

nest in American Samoa, the Marianas, and Johnston Atoll (Amerson et al. 1982, Reichel 1991, 

USFWS unpubl. data). Approximately 200 pairs nest at Rose Atoll. The population trend is probably 

stable, but increasing in areas where predators were removed (e.g., Midway, Kure) (Chardine and 

Morris 1996). 

Brown noddies usually nest in loose groups or colonies and are flexible in nesting behavior. Nests are 

on the ground, often on open slopes or under vegetation but the brown noddy also nest on cliffs and 

in trees, especially where introduced mammalian predators are present (Harrison 1990, USFWS 

1983). Brown noddy pairs stay together throughout the year, but there is little information on mate 

retention in subsequent years (Chardine and Morris 1996). Sexual maturity begins around 3-7 years 

and it is unknown whether birds return to their natal colony to breed (Chardine and Morris 1996, 

Harrison 1990). The oldest-known bird was 25 years (Chardine and Morris 1996). 
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Nesting manu sina with egg on Tournefortia branch. 

USFWS. 

Brown noddies feed by hover and contact-dipping in nearshore and off-shore waters (Harrison et al. 

1983). They often feed in association with tuna schools and can be found in mixed-species feeding 

flocks. 

The greatest threat is introduced predators, and where there are predators, brown noddy often nest in 

trees (Chardine and Morris 1996, Harrison et al. 1983). Predation by introduced mammals, such as 

the Polynesian rat, has contributed to the extirpation of brown noddy from islands where they 

formerly nested (e.g., Lehua) (VanderWerf et al. 2004). Disturbance of the colonies can lead to 

increased predation by native predators: unprotected eggs are taken by atafa and shorebirds, 

especially when adults are flushed from nests by human disturbance. 

4.5.9 Manu Sina (Gygis alba) or White Tern 

The manu sina is small and entirely white, 

with a pantropical distribution (Niethammer 

and Patrick 1998, Gochfeld and Burger 1996). 

The manu sina has adapted well to humanaltered landscapes better than many other 

seabirds. It is perhaps the most familiar bird in 

Samoa (Craig 2002). There are four 

subspecies; G. a. alba breed in the central and 

western Pacific (Gochfeld and Burger 1996, 

Clements 2000). Breeding adults remain close 

to colonies, foraging primarily inshore in 

shoals and banks but sometimes in offshore 

waters (Niethammer and Patrick 1998). 

During nonbreeding periods they disperse 

from breeding grounds to sea but their range 

in unknown (Niethammer and Patrick 1998). Some adults are year-round residents on the colony 

(Harrison 1990). Little is known of the movements of immature manu sina. 

World population is unknown but probably exceeds 100,000 pairs (Gochfeld and Burger 1996). In 

the USPI, there are about 17,000 pairs. Large colonies exist in American Samoa (3,900 pairs) 

(Amerson et al. 1982). Rose Atoll supports at least 60 pairs. World and USPI population trends are 

unknown. 

Manu sina nest on volcanic pinnacles, cliffs, rocky slopes, in large bushes or trees, or on artificial 

substrates (Niethammer and Patrick 1998, Rauzon and Kenyon 1984). They do not build nests but lay 

a single egg on a suitable depression, sometimes precariously balancing on small tree branches. 

Manu sina are monomorphic and monogamous, and partners remain together for several seasons, 

often returning to the same nest site (Niethammer and Patrick 1998, Harrison 1990). Clutch size is 

one egg and some breeding pairs may successfully raise two or even three broods within a nesting 

season (Niethammer and Patrick 1998, VanderWerf 2003, Miles 1985). 

Manu sina feed primarily by dipping- and surface-diving (Niethammer and Patrick 1998). They often 

occur in mixed feeding flocks and usually in association with predatory fish (Niethammer and 

Patrick 1998, Harrison 1990). Prey items include juvenile goatfish, flyingfish, squid, needlefishes, 

halfbeaks, dolphinfishes, and blennies (Niethammer and Patrick 1998, Harrison et al. 1983). 
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Although manu sina exhibit lower vulnerability to introduced predators than most seabirds because 

of their ability to use inaccessible (e.g., trees and sheer cliffs) nesting sites, introduced predators such 

as rats and cats have been the primary factor affecting populations (Niethammer and Patrick 1998). 

Scale insects have been introduced to Kure, Rose, and Palmyra Atolls where they attack native 

vegetation and reduce the number of nest sites in the native forest; the effects on manu sina nesting 

populations are not known. Overfishing of large predatory fish stocks that drive prey to the surface 

may reduce foraging opportunities for manu sina (Niethammer and Patrick 1998, Gochfeld and 

Burger 1996). 

4.5.10 Gogosina, Gogo Uli (Onychoprion fuscatus) or Sooty Tern 

Sooty terns have a pantropical distribution (Gochfeld and Burger 1996, Clements 2000, Schreiber et 

al. 2002). There are eight subspecies; O. f. oahuensis breed in the central and south Pacific (Gochfeld 

and Burger 1996, Clements 2000). Breeding adults remain relatively close to colonies and forage up 

to 311 miles from breeding islands (Flint 1991, Gould 1974). During nonbreeding periods, they are 

highly pelagic and tend to avoid regions with cold-water upwelling (Gochfeld and Burger 1996, 

Schreiber et al. 2002). Juveniles disperse widely after fledging and remain at sea, sometimes not 

touching land for several years (Schreiber et al. 2002). 

The world population is estimated to range from 60-80 million pairs with 18-23 million pairs 

breeding each year (Schreiber et al. 2002). In the USPI, there are approximately 3.2 million pairs. A 

large colony of more than 100,000 pairs breeds at Rose Atoll (Amerson et al. 1982, USFWS unpubl. 

data). Sooty tern nest on oceanic islands and atolls in large dense colonies (Gochfeld and Burger 

1996, Schreiber et al. 2002). A colony usually consists of several subcolonies and each subcolony 

breeds very synchronously. Sooty tern nest on the ground in sandy substrate with sparse vegetation 

(Schreiber et al. 2002). On Rose Island sooty terns also move into the forest and lay eggs in the open 

understory there. Sexual maturity begins around age 4-10 years (Schreiber et al. 2002, Harrington 

1974). The oldest-known bird was 32 years (Harrison 1990). 

Sooty terns, the most pelagic of the tropical terns (King 1967), feed mainly by aerial-dipping, 

contact-dipping, and aerial capture, although they will plunge-dive (Gochfeld and Burger 1996, 

Schreiber et al. 2002). Sooty terns tend to feed in large flocks with other species in association with 

predatory fishes, such as yellowfin and skipjack tunas (Schreiber et al. 2002, Harrison 1990, USFWS 

1983). El-Niño-Southern Oscillation conditions can cause breeding failure in the Pacific (Schreiber 

and Schreiber 1989). 

Native predators such as great frigatebirds and tuli take chicks and eggs (Schreiber et al. 2002, 

Harrison 1990). Sooty terns are vulnerable to oil pollution from tankers and spills. Over-fishing of 

tuna could potentially have an impact on the availability of prey (Schreiber et al. 2002). 

4.5.11 Gogosina (Onychoprion lunatus) or Gray-backed Tern 

Gray-backed terns are endemic to the tropical and subtropical Pacific but are most common in the 

Central Pacific (Mostello et al. 2000, Harrison 1990). Breeding adults are mostly sedentary and 

forage up to 230 miles from land (Harrison 1990, Dixon and Starrett 1952). During nonbreeding 

periods, they are highly pelagic and occur far from breeding colonies, but their range is unknown 

(Mostello et al. 2000). At sea, gray-backed terns are found in highly saline waters (Ainley and 
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Gogosina (black-naped tern) in flight. 

Joshua Fisher, USFWS. 

Boekelheide 1983). There are limited data on movements but juveniles travel great distances after 

leaving the natal colony (Mostello et al. 2000). 

The world population size is unknown but possibly on the order of 70,000 pairs (Mostello et al. 

2000). Lack of adequate information on breeding phenology in many areas complicates estimates 

(Mostello et al. 2000). In the USPI there are approximately 48,000 pairs and 30 pairs nesting on Sand 

Island at Rose Atoll. The global population trend is difficult to assess, but probably has declined 

since some colonies have been extirpated (Mostello et al. 2000). In the USPI, the population appears 

stable or increasing, but historical declines occurred at remote Pacific islands due to introduced 

predators. Trends in the USPI may be increasing with the removal of predators such as cats from 

many islands such as Howland, Jarvis, and Wake Atoll (Rauzon et al. 2011). 

Gray-backed terns breed on remote islands and atolls, on rocky ledges or sandy beaches often along 

vegetated edges bordering open areas (Amerson 1971, Ely and Clapp 1973). Their nests are shallow 

depressions in sand or gravel. Breeding occurs throughout the year (USFWS unpubl. data). The 

clutch is one egg and chicks are semi-precocial when hatched (Mostello et al. 2000). Fledglings may 

remain at the colony up to 6 weeks after first flight (Harrison 1990). The oldest known gray-backed 

tern was 25 years (Mostello et al. 2000). 

Gray-backed terns feed mainly by plunge-diving or contact/hover-dipping. They are described as an 

inshore, offshore, or pelagic feeder due to the geographical and seasonal differences in foraging 

habitat (Mostello et al. 2000). Gray-backed terns eat five-horned cowfish, juvenile flyingfish, 

goatfish, herring, dolphinfish, squid, crustaceans, mollusks, and marine and terrestrial insects 

(Harrison 1990). Gray-backed terns can be found foraging in mixed-species flocks, especially with 

sooty terns and sometimes with wedge-tailed shearwaters (Gould 1971). 

In the USPI, their gravest threat is predation by introduced mammals such as rats and cats (Harrison 

1990, Woodward 1972, Harrison et al. 1983). They are sensitive to disturbance, leaving their eggs 

when humans approach (Harrison 1990). Unattended eggs and chicks are vulnerable to predators 

such as great frigatebirds and ruddy turnstones and curlews (Mostello et al. 2000). Gray-backed terns 

tend to nest near the surf zone and nests are often lost to storm tides (Mostello et al. 2000, Harrison 

1990). 

4.5.12 Gogosina (Sterna sumatrana) or Black-naped Tern 

The black-naped tern is a white small sized bird with 

grayish-white back and wings and black beak and legs. 

This species has only recently (2010) been observed at 

Sand Island when a single adult individual was seen acting 

as if it might have a nest territory. No egg or chick was 

found. They breed on tropical and subtropical islands 

throughout the Indian and western Pacific Oceans. 

Breeding takes place on small offshore islands, reeds, sand 

spits, and rocky cays (Bird Life International 2011). 

Breeding season depends on locality (Bird Life 

International 2011) but have been recorded at breeding 

stations throughout the year, suggesting mainly sedentary 

habits (Harrison 1985). Colonies of 5-20 pairs are formed, 
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but sometimes up to 200 pairs can be formed (Bird Life International 2011). Colonies tend to be 

linear, or parallel to the water’s edge, (Hulsman and Smith 1988) in the sand or gravel pockets on 

coral banks close to the high tide line and monospecific (del Hoyo et al. 1996). They are also known 

to form colonies on ship wrecks (Hulsman and Smith 1988). One to two eggs, but occasionally three, 

are laid in either a shallow scrape on open ground or no nest is made (Hulsman and Smith 1988). 

Hulsman and Smith (1988) found that pebbles and small debris were thrown up toward the nest, 

having the effect of building up the nest edge, during nesting relief ceremonies. 

Black-naped terns hunt singly or in loose groups (Hulsman 1979) in atoll lagoons and nearshore, but 

they occasionally join flocks of black noddies when predatory fish were active near the reef 

(Hulsman and Smith 1988). Black-naped terns feed predominantly by plunging or air diving directly 

onto prey (Hulsman and Smith 1988, Bird Life International 2011), but become only semisubmerged (Harrison 1985). 

Both parents feed their young and make frequent flights to hunting grounds and young. Hulsman 

(1979) found anchovy to be a main food source for adults, but adults also consumed flying fish, 

mullet, barracuda, trevally or jack, tuna, damselfish, sardines, dolphinfish, grubfish, goby, blennies, 

and wrasse. Chicks were fed principally on the silver schooling fish belonging to the hardyheads and 

sprats, anchovies, and garfish. 

Black-naped terns are sensitive to human disturbance, either in terms of reduced breeding success or 

colony desertion. Black-naped terns nest in the open, which exposes their eggs and young to the 

weather. Adults must, therefore, shelter their eggs and chicks from the wide range of weather 

conditions experienced in tropical and sub-tropical areas. On two islands in Australia, the major 

causes of mortality of eggs and chicks were predation by gulls and flooding of nesting areas 

(Hulsman and Smith 1988), indicating that any introduced predators or excessive human disturbance 

would cause birds to flush, rendering chicks vulnerable to non-native predators as well as native 

birds like tuli or atafa. 

4.6 Shorebirds and Wading Birds

The Pacific Island Region functions as an essential migratory habitat for maintaining global 

shorebird populations. Rose Atoll is an important wintering ground for shorebirds in the Pacific. 

Seven species have been recorded at Rose Atoll. The most common migratory shorebirds are the 

Pacific golden plover, ruddy turnstone, and wandering tattler. Some shorebirds primarily use the 

beach strand habitat; however, the littoral forest also serves as important habitat. The Pacific golden 

plover is the most abundant of the shorebird species in American Samoa (Engilis and Naughton 

2004) and also the species that has been seen in largest numbers at Rose Atoll. 

Information on the status, trends, and ecology of shorebirds in the Pacific and their use of Rose Atoll 

is lacking in published literature (Engilis and Naughton 2004). Information needs include assessment 

of population sizes and trends; assessment of the timing and abundance of birds at key wintering and 

migration stopover sites; assessment of habitat use and requirements at wintering and migration 

areas; exploration of the geographic linkages between wintering, stopover and breeding areas; and 

evaluation of habitat restoration and management techniques to meet the needs of resident and 

migratory species (Engilis and Naughton 2004). 
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Many shorebirds wintering in the Pacific migrate over 2,486-7,458 miles of open ocean. Based on 

banding recoveries, patterns of distribution, and species assemblages, the following three flyways 

have been proposed: Asiatic – Palauan Flyway (birds move from Asia to Western Pacific and 

Philippine Sea Islands), Japanese – Mariana Flyway (mostly Asian birds move through Japan into the 

Mariana Islands and Caroline Islands), Nearctic – Hawaiian Flyway (birds breeding in Alaska and 

Eastern Siberia [Beringia] move through Hawai‘i to Marshalls and Polynesia) (Baker 1953). 

The Service developed the USPI Regional Shorebird Conservation Plan (Engilis and Naughton 2004) 

over concerns of declining shorebird populations and loss of habitat. Threats to shorebirds in the 

Pacific region include loss of habitat, non-native plants, non-native animals (predation, disease, and 

competition), human disturbance, and environmental contaminants. 

Conservation and restoration of shorebird habitats in the USPI is a growing effort and essential for 

the protection of endangered and declining shorebird populations. Wetlands, beach strand, coastal 

forests, and mangrove habitats are particularly vulnerable on Pacific islands due to increasing 

development pressures and limited acreage. 

Table 4-3. Shorebirds and Wading Birds of Primary Conservation Importance in the U.S. 

Pacific Region 

Species Regional Trend Conservation category 

Pacific golden plover Unknown High concern 

Bristle-thighed curlew Unknown High concern 

Sanderling Unknown High concern (?) 

Wandering tattler Unknown Moderate concern 

Ruddy turnstone Unknown Low concern 

Pacific reef heron Unknown IUCN Least Concern 

Source: Engilis and Naughton 2004; USFWS 2008. 

4.6.1 Tuli (Arenaria interpres) or Ruddy Turnstone 

The ruddy turnstone is a common shorebird throughout the Pacific Islands; however, it is recognized 

as a species of Low Concern (Engilis and Naughton 2004) because the vast majority of its world 

population uses other areas for wintering grounds. Remote sandy islands appear to support the largest 

numbers of turnstones in the USPI, but there are no available survey estimates for the wintering 

population at American Samoa (Engilis and Naughton 2004). The largest group ever recorded at 

Rose Atoll was 45 in 1982. Ruddy turnstones use sandy and rocky beaches, reefs, and mudflats. 

4.6.2 Tuli (Calidris alba) or Sanderling 

The sanderling is widespread and locally common throughout the Pacific Islands. In the USPI, the 

sanderling is less often seen than wandering tattlers and bristle-thighed curlews. The USPI Regional 

Shorebird Conservation Plan (Engilis and Naughton 2004) designated this shorebird as a species of 

limited importance in the Pacific Islands since the vast majority of sanderlings overwinter in other 

regions of the world. They are usually found on the water’s edge in small groups where they run back 

and forth from the waves to feed on the small invertebrates exposed by the retreating waves. 
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4.6.3 Tuli (Tringa incana) or Wandering Tattler 

The wandering tattler is nowhere common but is ubiquitous throughout the Pacific region. 

Predominantly nearctic breeders, wandering tattlers migrate from their breeding grounds in Alaska 

and northwest Canada (Gill et al. 2002) to islands throughout the Pacific. During winter, they are 

solitary or occur in small groups of two to three birds throughout the Pacific Basin (Gill et al. 2002). 

They are most common on rocky beaches but they also use a wide range of habitats including 

exposed reefs, sandy beaches, and mudflats (Engilis and Naughton 2004, Gill et al. 2002). The USPI 

Regional Shorebird Conservation Plan (Engilis and Naughton 2004) estimated the total population of 

wandering tattlers between 10,000- 25,000 individuals. There are an estimated 900 wandering tattlers 

wintering in American Samoa (Amerson et al. 1982). 

4.6.4 Matu’u (Egretta sacra) or Pacific Reef Heron 

The matu’u is a common bird in Samoa, with long legs and a long neck that is often curved in an Sshape. There are three color morphs: dark gray, pure white, or a combination of both colors in 

patches, and all have been observed at Rose Atoll. The herons forage across the reef crest for a wide 

variety of reef fish, crabs, and snails, as well as freshwater streams for food. Matu’u construct their 

large nests in trees that are safe from predators. At Rose Island nests have been found in coconut 

palms and Cordia surrounded by thick ferns (Nephrolepis hirsutula). In the 2010 field visit to Rose 

Atoll, there were two nests, one with two chicks and one with one chick. The white and dark color 

morphs were both seen on this visit. Population numbers in American Samoa are not known. 

4.7 Land Birds 

Rose serves as nonbreeding habitat for one austral migrant, the long-tailed cuckoo or aleva 

(Eudynamis taitensis). Vagrant birds are those that occasionally are blown off course by storms or by 

faulty directional decision during migration. Three vagrant species have been sighted at Rose Atoll 

cattle egret (Bubulcus ibis), snowy egret (Egretta thula), and the wattled honeyeater (Foulehaio 

carunculata). 

4.7.1 Aleva (Eudynamis taitensis) or Long-tailed Cuckoo 

The aleva migrates from New Zealand in the winter and forages toward the southwest Pacific. The 

center of its winter range lies in central Polynesia (Kepler et al. 1994). On Rose Island, its habitat is 

in dense and thick cover of the littoral forest. Single birds have been sighted 1976, 1980, 1990, and 

1992. Two were observed in 1984. The very cryptic and stealthy behavior of this species makes it 

likely that it is more common than field observations would indicate and on some visits the bird is 

heard but not seen as in 2010. 

4.8 Invertebrates 

4.8.1 Tuitui (Sea Urchin) 

Tuitui are marine animals that belong to the phylum Echinodermata (meaning “spiny skin”), a group 

that includes sea stars (also called starfish), sea cucumbers, sand dollars, brittle stars, and sea 
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feathers. All tuitui are in the Class Echinoidea. Sea urchins are important herbivores in reef and other 

marine habitats, grazing on a variety of benthic algae. An urchin’s mouth lies on the undersurface of 

its hard shell; the jaws of the mouth are made from five teeth held in a muscular sling. Together these 

teeth form a 5-pointed beak that is very effective at scraping algae from rocks and other hard 

surfaces. The scraping jaws of rock-boring urchins are also used to enlarge natural cavities or holes 

in the hard substrate, providing the animal with shelter from the full force of waves on exposed reef 

flats and the wave-swept surge zone. 

Tuitui feeding has two important consequences. First, 

their grazing reduces the total amount of fleshy algae 

on a reef, which enables corals and CCA (which 

compete with algae and cyanobacteria for space and 

sunlight) to grow better. Second, when they scrape 

algae from the substrate, they create vacant spaces 

that can then be colonized by the larvae of other 

bottom-dwelling marine animals. This helps to keep 

the diversity of marine animals high. In the absence 

of such grazing, reefs may become overgrown with 

algae, and the diversity of reef animals may be 

reduced. The important ecological role of tuitui 

became apparent on Caribbean reefs after a disease 

outbreak in 1983-84 killed more than 93 percent of 

the long-spined urchins (Diadema antillarum). During the following years, coral abundance 

decreased and reefs were covered with unprecedented levels of algal growth. 

Tuitui in the genera Heterocentrotus, Diadema, Echinometra, Echinothrix, and Echinostrephus have 

been recorded from Rose Atoll (Swerdloff and Needham 1970, Green et al. 1997, NMFS PIFSC 

2008). Following the longliner grounding in 1993, biologists documented an extensive area where oil 

caused high mortality to tuitui as well as CCA, marine snails, and faisua. Surveys in 1993 revealed 

that boring tuitui were extirpated from a zone 295 feet north and 197 feet south of the spill site 

(Molina 1994, Green et al. 1997). Surveys conducted in 1995 and 1996 revealed that tuitui densities 

had declined along the atoll’s entire southwest arm (Green et al. 1997). As of 1997, the tuitui 

population continued to be reduced within 3,279 feet of the grounding site, and remained depressed 

as of 2001 (USFWS and DMWR 2001). 

4.8.2 Terrestrial Invertebrates 

With the exception of scale insect documentation in reports from 2002-2005, few observations of 

terrestrial invertebrates were reported by visitors to Rose Atoll. In his 1980 trip report, Shallenberger 

notes that Darrell Herbst collected “various insects” while on Rose and Sand Islands. Shallenberger 

also states that the strawberry hermit crab (Coenobita perlatus) gather under the T. argentea during 

the day, and forage across the island at night. Strawberry hermit crabs were observed foraging on 

dead birds, fish, coconut meat, and bird eggs (Shallenberger 1980). Though found in smaller 

numbers than the strawberry hermit, purple hermits (Coenobita brevimanus) were also extremely 

common until the mid- nineties when densities of both hermit species appeared to decline. With the 

coincident decline in overall numbers came a change in the quality of the gastropod shells these crabs 

were using. It became more common to see highly worn shells and a lower proportion of the favored 

Turbo shells in the population. The largest terrestrial arthropod on earth, the coconut crab (Birgus 

Tuitui. Jean Kenyon, USFWS. 
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latro), ranges throughout the tropical Indo-Pacific. 

Due to its popularity as a food source, coconut crabs 

are rare or absent on most inhabited islands (Kepler 

and Kepler 1994). A single small coconut crab was 

captured in a live trap set for rats in 1991. Possibly 

related to the elimination of rats and the subsequent 

increase in coconut palms two dens and a large adult 

Birgus was observed on Rose Island during the 2010 

Refuge visit. 

Terrestrial invertebrates also observed on a Service 

trip to Rose Atoll led by Flint (Flint 1990) 

documented fruit flies, crickets, scales, wasps, 

houseflies, ants, earwigs, beetles, moths, 

cockroaches, orb-weaving spiders, wolf spiders, jumping spiders, and red spider mites. However, 

they were not collected or identified to species. 

In April 2012 a team of five entomologists from the USGS, American Samoa Community College 

(ASCC), DMWR, and the Service spent five days surveying invertebrates on Rose Island. They set 

out a variety of traps in about 100-foot grids covering the island. At the time of this draft the report of 

their findings was not yet available. 

4.9 Reef Building Species 

Coral reefs can be considered geologic structures built by countless generations of corals, coralline 

algae, and other calcifying marine organisms. While coral reefs are the world’s largest structures 

made by living organisms, an individual coral polyp is a tiny animal. What many people think of as a 

single coral is actually a colony of hundreds to thousands of tiny coral animals living side by side on 

a colonial skeleton they have excreted. Since many of these organisms are attached to the substrate 

their skeletons remain in that position after they die. Loose pieces of coral, shells, and other hard 

building blocks can be cemented together by coralline algae to build the reef. New reef organisms 

settle on or grow over the remains of the previous generation and deposit their skeletal material over 

the older surface. By this process a wave-resistant reef builds upward and outward. 

Due to the critical symbiosis between stony corals and their photosynthetic zooxanthellae, reef 

construction requires warm, clear, well-lighted marine waters. Coral reefs are mostly found between 

30o

N and 25oS latitude where the surface water temperature ranges between 77oF and 86oF 

throughout the year. In deep water (164-328 feet), where much of the sunlight is filtered out, the 

number of reef-building species of corals is greatly reduced, and at deeper depths (greater than 328 

feet) most reef builders disappear altogether. 

Darwin’s idea that atolls were perched atop sinking volcanoes was verified when scientists drilled 

through more than 4,000 feet of calcium carbonate reef to hit basalt from an creation of ancient 

volcano. However, today we know that the creation of atolls is a more complex process, which has 

happened over the last several thousands of years, not over the millions of years that it takes a 

volcano to sink. The creation of atolls as we know them today, a ringed–reef surrounding a lagoon 

often with sand islets, is the result of changes in sea levels that have occurred during glacial and 

Coconut crab. USFWS. 
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interglacial times. During the last glacial period about 20,000 years ago, sea level was over 328 feet 

lower than it is today. Reefs that had grown during times of higher sea level protruded out of the sea 

and were subject to thousands of years of erosion and subsidence. As the sea rose again these eroded 

reefs began to grow again, but now their centers had been eroded. Five thousand years ago, sea levels 

were about 7 feet higher than today, so these reefs grew higher than present day sea level. As sea 

levels have gone down, several feet of reef have been exposed, and islands have formed on some of 

these newly exposed reefs (Dickinson 2009, Woodroffe 2007). 

Figure 4-2. Atoll formation. 

 

Source: Woodroffe 2007 

Atolls vary in the degree to which their annular reef encloses the central lagoon and are sometimes 

further described on a gradient of “open” to “classical” as the perimeter reef becomes more fully 

enclosing. An operational definition of a classical atoll, therefore, is a reef formation atop a subsiding 

extinct volcano that includes a lagoon surrounded by a shallow perimeter reef, at least one emergent 

island, and regular surface water exchange between the lagoon and the open ocean (Woodroffe and 

Biribo 2011, Maragos and Williams 2011). In this regard, Rose Atoll, despite its small size, meets 

this definition of a classical atoll and also has all the major habitats and associated biological groups 

found on Pacific atolls: 

 Perimeter (annular) reef enclosing the lagoon; 

 Reef crest (reef flat); 

 Back reef (slopes facing the lagoon); 

 Lagoon; 

 Lagoon reefs; 

 Islands; 

 Natural channel (ava); and 

 Fore reef (slopes facing the ocean). 
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4.9.1 Coral 

Corals and reefs in many regions of the world are reported to be in a state of decline due to numerous 

local and global anthropogenic stressors including coastal point source pollution, agricultural and 

land use practices, overuse for commercial or recreational purposes, disease and predation, and 

impacts of climate change including increased sea surface temperature and ocean acidification 

(Wilkinson 2004). While the reefs of Rose Atoll have been spared many of the anthropogenic threats 

and impacts that afflict reefs located closer to human population centers, some threats such as climate 

change are very widespread and challenge the ability of protected areas to limit their effects. Veron et 

al. (2009) state that “reefs are likely to be the first major planetary-scale ecosystem to collapse in the 

face of climate changes now in progress”. 

4.9.1.1 Taxonomy 

Stony corals are marine invertebrates in the 

phylum Cnidaria that secrete a calcium carbonate 

exoskeleton. The basic soft body form of a coral is 

called a polyp, consisting of a sac-like cavity with 

only one opening that serves as both mouth and 

anus. This opening is surrounded by tentacles that 

have stinging cells called nematocysts. The 

skeleton secreted by an individual polyp is called a 

corallite. Some corals are solitary, consisting of a 

single polyp and its corallite, but most are 

colonial, consisting of multiple interconnected 

polyps that developed by a process of budding 

from an original parent polyp. 

From a taxonomic perspective, stony corals 

include members of both the Class Hydrozoa (fire corals) and the Class Anthozoa, Order Scleractinia 

(true stony corals). From a functional perspective, corals that contain single-celled, endosymbiotic, 

photosynthetic algae known as zooxanthellae in their gastrodermal tissues are called hermatypic or 

reef-building corals. The rapid calcification rates of these corals have been linked to their mutualistic 

association with the zooxanthellae. 

One hundred forty-five stony corals (143 scleractinian and 2 hydrozoan) (Appendix A) have been 

reported from the Refuge and the adjoining fore-reef slopes (Kenyon et al. 2010, and further 

unpublished updates by Maragos). Higher coral diversity than expected at Rose Atoll may result 

from its proximity to the high islands in American Samoa where 326 scleractinian species have been 

recorded (Birkeland et al. 2008) and from its additional lagoon habitats compared to those islands. 

4.9.1.2 Conservation 

Of these 145 stony coral species at Rose Atoll, 21 are listed as Vulnerable according to the IUCN 

Red List Categories and Criteria. These criteria have been widely used to classify, in an objective 

framework, the extinction risk of a broad range of species and rely primarily on population size 

reduction and geographic range information. Categories used to classify species for which adequate 

data exist range from “Least Concern” (with very little probability of extinction) to high risk 

Each small bump on the branches of this coral 

colony (Acropora humilis) is a corallite that protects 

a soft-bodied polyp inside. Jean Kenyon, USFWS. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-40 Chapter 4. Biological Environment 

“Critically Endangered.” The categories collectively considered as “threatened” (Vulnerable, 

Endangered, Critically Endangered) are intended to serve as one means of setting priority measures 

for biodiversity conservation (Carpenter et al. 

2008). Of these 21 species at Rose Atoll listed 

as Vulnerable, 19 are being evaluated by 

NOAA NMFS for possible listing in 

accordance with the ESA, in response to a 

petition in 2009 from the non-governmental 

organization (NGO) Center for Biological 

Diversity (Kenyon et al. 2011). Of the 

remaining 124 stony coral species at Rose 

Atoll, 36 are listed by the IUCN as “Near 

Threatened,” 78 as “Least Concern,” 2 as 

“Data Deficient,” and 8 are not found in the 

Red List. 

4.9.1.3 Zooxanthellae 

In addition to enhancing calcification, zooxanthellae provide a substantial phototrophic contribution 

to the coral’s energy budget and give the coral most of its color. Those corals that lack zooxanthellae 

deposit mineralized skeletal materials at a lower rate and are called ahermatypic or nonreef-building 

corals. The largest colonial members of the Scleractinia help produce the carbonate structures known 

as coral reefs in shallow tropical and subtropical seas around the world. Stony corals with massive 

and branching growth forms are the major framework builders and a source of carbonate sediment on 

the reef. Corals provide substrate for colonization by other benthic organisms, construct complex 

protective habitats for a myriad of other species including commercially important invertebrates and 

fishes, and serve as food resources for a variety of animals. 

4.9.1.4 Rose Atoll Coral Distribution 

Coral cover and composition naturally vary among atoll habitats because species show differential 

growth and survivorship responses to different environmental circumstances including wave energy, 

depth and turbidity (light penetration), and temperature range tolerance. In 2002, average coral cover 

derived from quantitative analysis of imagery recorded during towed-diver surveys that 

circumnavigated the Rose Atoll fore reef in 3 depth strata was 23 percent (Kenyon et al. 2010); 

average coral cover was highest (38 percent) on the deep (greater than 59 feet) southeast fore-reef 

slope but lowest (13 percent) on the same slope at moderate depths (30-59 feet). Site-specific transect 

and photoquadrat surveys show that Pocillopora, Montipora, and Montastrea are the most abundant 

genera on the fore reef. Along the soft, unconsolidated floor of the lagoon, coral is found only on 

isolated patches of firm substrate, averaging only 0.9 percent cover. Average coral cover on the 

sloping rubble back reef inside the lagoon is also low (0.1 percent). Coral cover is higher on the 

limestone pinnacles scattered within the lagoon, averaging 10 percent, with the genera Favia, 

Montipora, Porites, and Astreopora as the primary components. 

4.9.1.5 Reproduction 

Corals reproduce both sexually and asexually. Sexual reproduction involves the process of 

gametogenesis (generation of gametes), which may require from a few weeks for sperm to more than 

The fore reef slope supports a diverse assemblage of 

corals, other invertebrates, and coralline algae. Jean 

Kenyon, USFWS. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Biological Environment 4-41 

10 months for eggs. The dominant reproductive mode of scleractinian (true stony) corals in the 

Pacific Ocean is broadcast spawning of gametes followed by external fertilization. Subsequent cell 

divisions of the fertilized eggs result in small, dispersive propagules (planula larvae) which may 

settle, metamorphose, and develop into primary polyps. The phenology of spawning and degree of 

synchrony within and between species can vary widely among locations and along latitudinal 

gradients, ranging from annual multi-species mass spawning events on the Great Barrier Reef in late 

austral spring to little apparent synchrony among species in Hawai‘i or the Red Sea. 

Relatively little is known of the phenology of coral spawning in American Samoa. Seven species 

have been observed spawning off Tutuila in the week following the October or November full moon 

(Itano and Buckley 1988, Mundy and Green 1999), and measurements of the sizes of developing 

eggs from two additional species off Tutuila also suggest spawning occurs after the October or 

November full moon (Kenyon n.d.). However, egg size data from several other species sampled off 

Tutuila suggest spawning is more spread out through the year and that some species may have at 

least two spawning periods in different seasons. 

Limited sampling of four Acropora species on the back reef and fore reef at Rose Atoll in late 

February revealed that colonies of one species would spawn within the following month, two other 

species were nearing maturity, and one species had no gravid polyps (Kenyon n.d.). Clearly, much 

remains to be determined concerning coral spawning cycles at Rose Atoll and within the larger 

region of American Samoa. 

The gametes and developing embryos of most broadcast-spawning corals are positively buoyant and 

therefore vulnerable to natural and anthropogenic disturbances that can substantially impact 

successful reproduction, including lowered salinity, extremes of temperature or irradiance, turbidity, 

eutrophication, and pollution. The capacity to maintain or renew genetically diverse coral 

populations through sexual reproduction is a key attribute of reef resilience; consequently, reef 

managers’ understanding of regeneration and recovery processes is informed by knowledge of the 

timing of coral sexual reproduction. 

Asexual reproduction from coral fragments is a common process of colony replication. Asexual 

reproductive results in a new coral colony that is genetically identical to the parent colony (a clone). 

Colonies started from fragments have the advantages of large initial size and locally adapted 

genotypes. The ability of some species of 

Acropora to survive fragmentation and rapidly fill 

space has led to an interest in using these species 

for programs of reef restoration. 

4.9.1.6 Threats to Corals at Rose Atoll 

The grounding of a large steel-hulled Taiwanese 

long-line fishing vessel in October 1993 resulted 

in a fuel and ammonia spill and break-up of the 

ship into thousands of pieces during the following 

years. The cumulative impacts included massive 

kills of corals and coralline algae from the spills 

and subsequent invasion of cyanobacteria that 

were increasingly stimulated by the corrosion and 

Cyanobacteria stimulated by the 1993 shipwreck 

continue to overgrow the substrate. Jean Kenyon, 

USFWS. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-42 Chapter 4. Biological Environment 

release of dissolved iron from the metallic components of the wreckage. The invasive cyanobacteria 

also displaced other indigenous marine species over a broader area including reef areas beyond the 

spill and grounding zone. Collectively the ship grounding and its breakup fueled the demise of many 

species in the affected habitats concentrated along the southwest perimeter reef and adjacent lagoon 

where the ship struck the reef. 

From 1999-2007, seven visits to the Refuge by Samoan salvagers, supported by NWR funds and the 

Oil Spill Liability Trust Fund Act managed by the USCG, succeeded in removing more than 99 

percent of the ship debris. Monitoring efforts since 1999, coinciding with debris cleanup efforts as 

well as cooperative surveys conducted with NMFS PIFSC, have revealed slow but persistent 

recovery of corals, coralline algae, and echinoderms that normally dominate the affected reef crests, 

shallow fore reefs, back reefs, and lagoon reefs near the grounding site (Green et al. 1997, Maragos 

1994, Schroeder et al. 2008, Kenyon et al. 2010). 

Maragos (1994) noted widespread bleaching of numerous species of scleractinian corals in several 

environments at Rose Atoll in March 1994 to depths of 66 feet. Concurrent widespread bleaching at 

Tutuila suggested the bleaching was a regional phenomenon related to increases in surface water 

temperatures associated with ENSO rather than the result of local perturbations caused by the 

October 1993 ship grounding and chemical spill. Nonetheless, bleaching was most pronounced along 

the southwest fore reef, and its severity increased slightly when moving towards the wreckage, a sign 

that stress to corals from the shipwreck may have contributed to the severity of the bleaching event. 

Though quantitative observations of the severity and geographical extent of bleaching at Rose Atoll 

could not be made during the 1994 event, qualitative snorkeling observations revealed that most of 

the outside perimeter of the atoll reef was consistently bleached to depths of 66 feet (Maragos 1994). 

Although the extent of subsequent mortality is unknown due to a hiatus in scientific surveys between 

1994-1999, quantitative observations from NMFS PIFSC monitoring surveys in 2002 and 2004 

indicate coral populations in the early stages of recovery from both the 1993 ship grounding and 

1994 bleaching event (Kenyon et al. 2010). Although the bleaching event did not result in chronic 

Rose Atoll before the grounding (left) and Rose Atoll after the grounding (1994). Note the discoloration 

(circled in yellow) where the cyanobacteria impacted the CCA. USFWS. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Biological Environment 4-43 

damage to the reefs at Rose Atoll, some reef communities shifted to other species from what was 

observed in 1994. 

The size and depth of the ava connecting the lagoon to the ocean is very important to maintaining the 

coral and other communities of Rose Atoll. Any modification to the ava would change the water flow 

regime and could exacerbate the effects of climatic warming and lead to permanent losses of corals 

during future bleaching events, especially within the lagoon where ambient temperatures are 

naturally slightly higher than deeper waters on the ocean side of the atoll (NMFS PIFSC 2008). This 

type of occurrence has already been documented at Palmyra Atoll (Williams et al. 2010). There were 

no bleaching events reported at Rose between 1995 and 2011. 

Pacificwide, there is growing concern pertaining to the threat of increased prevalence, geographic 

distribution, and host range of coral diseases. Disease is defined as any impairment that interferes 

with or modifies the performance of normal physiological functions, including responses to 

environmental factors, toxicants, and climate; infectious agents; inherent or congenital defects; or a 

combination of these factors (Wobeser 2006). Quantitative coral disease assessments conducted by 

NMFS PIFSC at 40 different U.S. Pacific coral islands, banks, and atolls between 2006-2007 

revealed Pacific-wide mean disease prevalence (proportion of colonies affected) was low (regional 

means less than 5 percent), but site-specific hotspots occurred at Rose Atoll (11.7 percent) and four 

other islands/atolls (Vargas-Ángel and Wheeler 2008). In addition to minor bleaching, white 

syndrome, pigmentation responses, and other lesions were documented, with algal/cyanophyte 

infestions accounting for greater than 75 percent of all disease cases, most notably abundant in the 

vicinity of the 1993 shipwreck site. 

4.9.2 Coralline Algae 

Crustose coralline algae are an important component of reef systems, and the reefs at Rose Atoll are 

dominated by CCA. Together with hard corals, CCA represent a major source of reef limestone. The 

CCA cement and consolidate carbonate material, thus contributing to the growth and persistence of 

tropical reef structures. The capacity of coral communities on fore reefs to recover from disturbances 

is probably partially a result of the ability of CCA to 

bind loose rubble into a stable substratum (Birkeland et 

al. 2008). Settlement and metamorphosis of many key 

benthic reef elements, including scleractinian corals 

and octocorals, are induced by external biochemical 

cues associated with live CCA (Heyward and Negri 

1999, Harrington et al. 2004). In addition, CCA are 

important sources of primary production. Water 

temperature and motion, light availability, 

sedimentation, and predation represent major 

influential factors determining patterns of CCA 

distribution, abundance, and zonation on tropical reef 

ecosystems (Littler and Doty1975, Fabricius and 

De’ath 2001). 

Although the critical importance of CCA to the formation and ecology of tropical reefs is well 

documented, many aspects of the biology, ecology, and taxonomy of this flora are still poorly 

understood (Chisholm 2003). The CCA only live in marine waters, and they are hard because of 

A diver conducts a quantitative survey of 

corals and CCA along a transect line. Jean 

Kenyon, USFWS. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-44 Chapter 4. Biological Environment 

calcareous deposits contained within the cell walls. They are typically pink or some other shade of 

red. Coralline algae are in the order Corallinales, in the red algal division Rhodophyta. Coralline 

algae have typically been divided into two groups based on their morphological form, though this 

division does not constitute a taxonomic grouping: the geniculate (articulated or connected by a 

flexible joint) corallines and the nongeniculate (nonarticulated) corallines. Geniculate corallines (e.g., 

Jania sp.) are branching, tree-like plants that are attached to the substratum by calcified, root-like 

holdfasts. The plants are made flexible by having noncalcified sections (genicula) separating longer 

calcified sections (intergenicula). Nongeniculate corallines range from a few micrometers to severalcentimeter-thick crusts; there are more than 1,600 described species of nongeniculate coralline algae. 

Those with a growth habit that closely adheres the thallus to the substrate are commonly called CCA 

(Porolithon sp., Hydrolithon sp., Lithothamnion sp.). 

Mayor (1924) noted that the exceptionally well-developed shallow calcareous algal ridge at Rose 

Atoll had the densest growth of calcareous algae he had encountered anywhere, and suggested it 

could be called a “Lithothamnion-atoll rather than a coral atoll”. Observations following the 1993 

longliner grounding indicated that the reef flat coralline algal community was severely affected and 

significantly altered by the petroleum released during the grounding. A massive die-off of CCA, 

extending approximately 3,279 feet along the reef flat and reef margin, occurred on the southwest 

arm of the atoll where the vessel grounded (Maragos 1994). The large-scale die-off of the CCA was 

accompanied by a bloom of invasive cyanobacteria that were previously uncommon on the atoll. 

Within a year, the cyanobacteria had spread across the atoll’s entire southwest arm and had begun to 

invade adjacent areas of the lagoon as well as portions of the northwest arm (Green et al. 1997). 

Quantitative surveys of CCA and cyanobacteria cover using transects along the seaward, mid reef, 

and lagoon edge of the southwest arm of the reef flat were conducted in 1995, 1996, 1998, and 2002. 

In contrast to other arms of the atoll, which are pink in color due to the dominance of CCA, in 1995, 

2 years after the spill, the southwest arm had very low abundance (less than 20 percent cover) of this 

key algal group. On the outer (seaward) reef edge CCA was absent except at the northern end of the 

arm. In 1996, 1998, and 2002 CCA abundance had steadily increased on the outer edge, except near 

the wreck site; an area of low CCA cover (approximately 10 percent) had persisted near the wreck 

even following debris removal efforts. On the inner (lagoon) edge of the reef flat, cover of CCA was 

highly variable in the survey years and in 2002 had dropped to low levels (less than 30 percent), 

especially at the southern end of the southwest arm (Burgett 2003). Removal of remaining visible 

metallic debris from the grounding was completed in 2007, and the last transect surveys to monitor 

whether a more natural algal community is developing on this arm of the reef flat were done in 2010. 

Although the fore-reef slopes are not included within the Refuge boundaries, its biological 

communities serve as sources of colonizing propagules to those protected within the Refuge. In 2002, 

average CCA cover derived from quantitative analysis of imagery recorded during towed-diver 

surveys that circumnavigated the Rose Atoll fore reef in 3 depth strata was 48 percent (Kenyon et al. 

2010), more than twice the average cover provided by corals (23 percent). Mean CCA cover was 

highest (65 percent) on the shallow (less than 30 feet) southwest fore-reef slope and lowest (27 

percent) on the deep (greater than 59 feet) northeast fore reef. On all 4 fore-reef exposures (northeast, 

southeast, southwest, northwest), mean CCA cover decreases as depth increases from shallow to 

moderate (30-59 feet) to deep depth strata (Kenyon et al. 2010). 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Biological Environment 4-45 

Although there is growing consensus pertaining to the increased threat of disease to corals, little is 

known about coralline algal disease distribution, abundance, and the potential implications to 

declining CCA flora. Quantitative coral disease assessments conducted by NMFS PIFSC at 42 

different U.S. Pacific coral islands, banks, and atolls between 2006-2008 revealed the highest 

average CCA percent cover occurred at Rose Atoll (Vargas-Ángel 2010). In 2006, of the 

islands/atolls in American Samoa, Rose Atoll had the lowest ratio of the number of cases of CCA 

disease relative to percent cover (0.1), but in 2008 this ratio had significantly increased to 0.8. While 

this U.S. Pacific-wide study could not make clear large-scale patterns linking CCA disease 

occurrence with natural reef physiographic or geomorphological features (e.g., carbonate vs. volcanic 

islands; windward vs. leeward wave exposures), the author noted that at Rose Atoll and a few other 

locations, leeward and protected habitats exhibited 60 percent more CCA disease cases when 

compared to exposed windward sites. 

4.10 Fish 

The number of reef fish species at Rose Atoll is 

estimated to be 272, based upon surveys 

conducted from 1981-2004 (Wegmann and 

Holzwarth 2006) (Appendix A). While this is a 

subset of the 991 reef fish species listed for all of 

American Samoa and Samoa in Wass (1984), the 

proportion found at Rose is substantial given that 

the atoll has less than 1 percent of the total reef 

habitat in the archipelago. 

Reef fish living amongst or in close proximity to 

tropical reefs have evolved many specializations 

adapted to survival on the reef. Their range of 

feeding strategies includes herbivores that graze 

on benthic algae, corallivores that feed on coral 

polyps, generalized carnivores that feed on a 

The distinctive crustose coralline algal reef crest, with Rose Island in the background (left photo). Close up of 

CCA (right photo). Jean Kenyon, USFWS. 

Herbivorous fishes (here, a school of surgeonfishes) 

are abundant where cyanobacteria and turf algae have 

proliferated as a long-term response to shipwreck 

metallic debris. Jean Kenyon, USFWS. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-46 Chapter 4. Biological Environment 

variety of animal prey, and specialized carnivores with more focused animal prey preferences such as 

zooplankton. 

Reef fish surveys at Rose Atoll have documented an assortment of reef fish families and genera 

similar to other central Pacific shallow reefs (Green 1996, Whaylen 2005, NMFS PIFSC 2008). 

Damselfishes, surgeonfishes, wrasses, and parrotfishes were the most common families of small (less 

than 8 inches total length [TL]) to medium (8-20 inches TL) reef fish encountered. Snappers 

(Lutjanidae), groupers (Serranidae), and jacks (Carangidae) were the most common large (greater 

than 20 inches TL) reef fishes observed at Rose Atoll. Sharks (Carcharhinidae) were present but 

uncommon, mainly seen in shallow water on the 

fore reef just below the surf. 

Reef fish surveys conducted by NMFS PIFSC 

using standardized methods showed that mean 

fish biomass per reef area at Rose Atoll is higher 

than at Tutuila but significantly lower than at 

other Pacific Remote Island refuges distant from 

human population (Howland, Baker, and Jarvis 

Islands, Johnston, Palmyra, and Wake Atolls, 

Kingman Reef) (Williams et al. 2011). At Rose 

Atoll, fish biomass appears to be highest inside 

the lagoon and on the southwest fore reef 

compared to other areas of the atoll (NMFS 

PIFSC 2008). Small to medium-sized fish were 

very abundant around several of the larger 

pinnacle patch reefs inside the lagoon, where 

parrotfish, snapper, emperor, goatfish, and jacks 

were common. Herbivores (surgeonfish, parrotfish, and angelfish) were abundant on the southwest 

fore reef, with significantly greater numbers and biomass at the site of the 1993 longliner grounding 

than at neighboring sites (Schroeder et al. 2008). This greater abundance of herbivores at the impact 

site was associated with significantly greater substrate cover of turf algae and cyanobacteria. The 

highest densities of large fish (greater than 20 inches TL), such as jacks and barracuda, were 

recorded just outside the ava along the northwest fore reef. This may be a preferred site for feeding 

on prey or plankton flowing out of the lagoon or may be a preferred site for spawning activity 

(NMFS PIFSC 2008). 

Of concern is the recent disappearance of two species that were once present at Rose Atoll: the Maori 

wrasse, Cheilinus undulatus and the bumphead parrotfish, Bolbometapon muricatum. Both of these 

species have been depleted by fishing throughout their Pacific range. The NOAA NMFS is 

evaluating the status of the bumphead parrotfish for possible listing as endangered or threatened in 

accordance with the ESA. 

The peppered moray (Gymnothorax pictus) is commonly found in shallow water up on the reef flat at 

Rose where it feeds on crustaceans and fish (Lieske and Myers 1994). Its size, (up to 4.5 feet long), 

its abundance at Rose, and habit of coming out of the water in pursuit of prey makes it a good 

candidate for long-term monitoring. It is distributed throughout the Indo-Pacific and Eastern Pacific: 

East Africa to the Galapagos, Cocos, and Clipperton islands, north to the Hawaiian and Ryukyu 

islands, south to Australia and the Kermadec Islands (Chen et al. 1994). 

Divers from NMFS PIFSC conduct surveys for reefassociated fish along transect lines. Jean Kenyon, 

USFWS.
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Biological Environment 4-47 

Sharks are a group of fishes characterized by a cartilaginous skeleton and 5-7 gill slits on the sides of 

the head. There are more than 440 species of sharks belonging to 8 taxonomic orders. The three 

species of shark that have been recorded at 

Rose Atoll NWR (gray reef shark, blacktip 

reef shark, and whitetip reef shark; 

Carcharhinus amblyrhychos, Carcharhinus 

melanopterus, and Triaenodon obesus, 

respectively) belong to the order 

Carcharhiniformes, family Carcharhinidae, 

commonly known as requiem sharks. They 

are distinguished by an elongated snout, a 

nictitating membrane that protects the eyes 

during an attack, and viviparity (live birth). 

These three species are the most common 

sharks inhabiting Indo-Pacific reefs. 

The gray reef shark, which is found as far east as Easter Island and as far west as South Africa, is 

most often seen in shallow water near the drop-offs of coral reefs, and less commonly within lagoons 

or open ocean. They are agile predators that feed primarily on bony fishes and cephalopods (e.g., 

octopi, squid). Despite their moderate size, their aggressive demeanor enables them to dominate 

many other shark species on the reef. Many gray reef sharks have a home range on a specific area of 

the reef to which they continually return. Gray reef sharks were the first shark species known to 

perform a threat display, a stereotypical behavior warning that it is prepared to attack. The display 

involves a hunched posture with dropped fins and an exaggerated, side-to-side swimming motion. 

They do so if they are cornered by divers, indicating they perceive a threat. This species has been 

responsible for a number of attacks on humans, so should be treated with caution, especially if they 

begin to display. They are caught in many fisheries and are susceptible to local population depletion 

due to their low reproductive rate (litters of one to six pups are born every other year) and limited 

dispersal. As a result the IUCN has assessed this species as Near Threatened (Smale 2009). 

The blacktip reef shark, found throughout the nearshore waters of the tropical and subtropical IndoPacific, prefers shallow, inshore waters. It is usually found in water only a few meters deep and can 

often be seen swimming close to shore with its black-tipped dorsal fin exposed. Younger sharks 

prefer shallow, sandy flats, while older sharks are most common around reef ledges and near reef 

drop-offs. A tracking study off Palmyra Atoll in the central Pacific found the blacktip reef shark had 

a home range of about 0.21 square mile, among the smallest of any shark species (Papastamatiou et 

al. 2009). Often the most abundant apex predator in its ecosystem, the blacktip reef shark plays a 

major role in structuring inshore ecological communities. Its diet is composed primarily of small 

bony fish, though cephalopods are also consumed. Sharks off Palmyra Atoll have been documented 

preying on seabird chicks that have fallen out of their nests into the water (Papastamatiou et al. 

2009). Under most circumstances, the blacktip reef shark has a timid demeanor and is easily 

frightened away by swimmers. However, its inshore habitat preferences bring it into frequent contact 

with humans, and thus it is regarded as potentially dangerous. Though it remains widespread and 

common overall, substantial local declines due to overfishing have been documented in many areas. 

This species has a low reproductive rate, with a litter size of 2-5 pups, limiting its capacity for 

recovering from depletion. The IUCN has assessed the blacktip reef shark as Near Threatened 

(Heupel 2009). 

Blacktip reef shark in Rose Atoll lagoon. Kelsie Ernsberger 

USFWS. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-48 Chapter 4. Biological Environment 

The whitetip reef shark, which is found as far east as Central America and as far west as South 

Africa, is typically found on or near the bottom in clear, shallow water. The habitat preferences of 

this species overlap those of the blacktip reef shark and the gray reef shark, though it does not tend to 

frequent very shallow water like the blacktip reef shark or the outer reef like the gray reef shark. 

Unlike other requiem sharks, which rely on ram ventilation and must constantly swim to breathe, the 

whitetip reef shark can pump water over its gills and lie still on the bottom. During the day whitetip 

reef sharks spend much of their time resting beneath overhangs or in caves, emerging at night to hunt 

bony fishes, octopi, and crustaceans. Individual whitetip reef sharks may stay within a particular area 

of the reef for months to years, returning time and again to the same shelter. Females give birth to 1-6 

pups every other year. Whitetip reef sharks are rarely aggressive towards humans, though they may 

investigate swimmers closely. The IUCN has assessed the whitetip reef shark as Near Threatened, 

noting that its numbers are dwindling due to increasing levels of unregulated fishing activity across 

its range (Smale 2005). The slow reproductive rate and limited habitat preferences of this species 

renders its global populations vulnerable to over-exploitation. 

4.11 Invasive and Nuisance Species 

Invasive species displace native vegetation, alter the composition and structure of vegetation 

communities, affect food webs, and modify ecosystem processes, resulting in considerable impacts to 

native wildlife. For the purpose of this CCP, “invasive” is a subset of non-native species or 

indigenous species that have started to proliferate and modify the species composition or function of 

the existing native community, typically due to some human action. An invasive species is defined as 

a species whose migration and growth within a new range is causing detrimental effects on the native 

biota in that range. These species become invasive because their population and growth are no longer 

balanced by natural predators or biological processes that kept them in balance in their native 

ecosystems. In the absence of these restraints, invasive species have the potential to compete with 

native species for limited resources, alter or destroy habitats, shift ecological relationships, and 

transmit diseases. The cyanobacteria previously discussed is an example of a native species that has 

become invasive. 

Invasive species are one of the most serious problems in conserving and managing natural resources. 

In particular, the ecological integrity of Pacific Island environments is greatly threatened by invasive 

species. Islands which have existed in isolation for millions of years are ideal environments for 

invasive species. Most native species have evolved without the necessity and therefore lost their 

natural defense mechanisms and are more vulnerable to introduced species. Island ecosystems are 

key areas for conservation of global biological diversity. While islands make up only about 3 percent 

of the earth’s surface, they are home to 15-20 percent of all plant, reptile, and bird species (Whittaker 

1998). Small population sizes and limited habitat availability make species endemic to islands 

especially vulnerable to extinction and their adaptation to isolated environments makes them 

especially vulnerable to aggressive introduced species (Diamond 1985, Diamond 1989, Olson 1989). 

Of the 484 recorded animal species extinctions since 1600, 75 percent were species endemic to 

islands (World Conservation Monitoring Center 1992). 

4.11.1 Mammals 

The impacts from invasive predatory mammals are one of the leading causes of species extinction on 

islands (Blackburn et al. 2004, Duncan and Blackburn 2007). Rats living in close association, or 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Biological Environment 4-49 

commensally, with humans (Norway rat, Rattus norvegicus; black rat, R. rattus; and Polynesian rat, 

R. exulans) have been introduced to about 90 percent of the world’s islands and have a pronounced 

effect on island ecosystems (Towns et al. 2006). In addition, the extinction of many island species of 

mammal, bird, reptile, and invertebrate have been attributed to the impacts of invasive rats (Andrews 

1909, Daniel and Williams 1984, Meads et al. 1984, Atkinson 1985, Tomich 1986, Hutton et al. 

2007), and estimates of 40-60 percent of all recorded bird and reptile extinctions globally were 

directly attributable to invasive rats (Atkinson 1985, Island Conservation n.d.). 

Even if species are not extirpated, rats can have negative direct and indirect effects on native species 

and ecosystem functions. For example, a comparison of rat-infested and rat-free islands, and pre- and 

post-rat eradication experiments have shown that rats depressed the population size and recruitment 

of birds (Campbell 1991, Thibault 1995, Jouventin et al. 2003), reptiles (Whitaker 1973, Bullock 

1986, Towns 1991, Cree et al. 1995), plants (Pye et al. 1999), and terrestrial invertebrates (Bremner 

et al. 1984, Campbell et al. 1984). In particular, rats have significant impacts on seabirds, preying 

upon eggs, chicks, and adults and causing population declines, with the most severe impacts on 

burrow-nesting seabirds (Atkinson 1985, Towns et al. 2006, Jones et al. 2008). 

In addition to preying on seabirds, introduced rats feed opportunistically on plants, and alter the flora 

communities of island ecosystems (Campbell and Atkinson 2002); in some cases degrading the 

quality of nesting habitat for birds that depend on the vegetation. Small, oceanic islands have 

simplified seed dispersal systems that generally lack mammalian vectors and are vulnerable to 

disruption by invasive species (Drake et al. 2002). Rats can disrupt seed dispersal mutualisms by 

depositing seeds in microhabitats that are ill-suited for germination or subsequent growth. Native 

crab species prey on seeds as well, although they only eat the fleshy pulp, leaving the seed coat 

intact, allowing the seed to germinate. Rats are able to consume the fleshy pulp and chew through the 

seed coat killing the existing seed and preventing germination and recruitment of native plants. It is 

possible that rats can also indirectly reduce plant fitness by reducing the effectiveness or numbers of 

native dispersers through competition and predation (Wegmann 2009). On Tiritiri Matangi Island, 

New Zealand, ripe fruits, seeds, and understory vegetation underwent significant increases after rats 

were eradicated from the island, indicating the rats’ previous impacts on the vegetation (Graham and 

Veitch 2002). At Palmyra Atoll, in a very similar Pisonia-dominated coastal strand forest ecosystem, 

an eradication project to eliminate Rattus rattus was implemented in June 2011. By August of that 

year total counts of all tree seedlings in 56 transects had increased significantly, including those of 

native Pisonia grandis changing from no seedlings detected before eradication to 12.3 seedlings per 

transect post-eradication. Seedling censuses under five rare native tree species showed significant 

increases between 2004 and post eradication, including the first ever documentation of seedling 

Cordia subcordata at Palmyra. This species was first detected at Rose in 1994 after Rattus exulans

was removed there (USFWS 2011). 

Rats are documented to affect the abundance and age structure of intertidal invertebrates directly 

(Navarrete and Castilla 1993), indirectly affect species richness and abundance of a range of 

invertebrates (Towns et al. 2009), and contribute to the decline of endemic land snails in Hawai‘i 

(Hadfield et al. 1993), Japan (Chiba 2010), and American Samoa (Cowie 2001). 

Polynesian rats are speculated to have been a contributing factor in the large-scale extinctions of 

Hawaiian bird species during Polynesian settlement prior to European contact. Rats are known 

predators of eggs, nestlings, young, and occasionally adults of seabirds, migratory shorebirds, and 

other birds. Ground- and burrow-nesting seabirds are particularly vulnerable to rat predation. Rats 
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also consume plants, insects, mollusks, herpetofauna, and other invertebrates (Olson and James 1982, 

Brisbin et al. 2002, Engilis et al. 2002, Mitchell et al. 2005). 

Polynesian rats and humans are the only known terrestrial mammals to reach Rose Atoll. The rats 

were first documented in 1920 (Mayor 1924). Rats have a varied diet that includes seabirds and turtle 

eggs and juveniles as well as a variety of plants and their seeds. The population of rats on Rose 

Island was estimated to be 1,000-1,600 in 1990. Rats were eradicated in an operation beginning in 

1990 by the Service under the guidance of U.S. Department of Agriculture Wildlife Services using 

live traps, kill traps, and bait stations armed with Talon ® anti-coagulant rodenticide containing 

brodifacoum spaced 82 feet apart over the entire island. No rats have been detected on the island 

since. 

Subsequent to the eradication of Polynesian rats at Rose the number of plant species has increased 

from only four species on the Rose Island in 1990 to at least eight species in 2010. While it is likely 

that rat eradication provided a beneficial effect for all nesting seabirds at Rose, the only species for 

which adequate pre- and post-eradication data exist to demonstrate a statistically significant effect 

was the red-tailed tropicbird (Wegmann and Holzwarth 2006). 

4.11.2 Reptiles 

Reptiles have not been well studied at Rose Atoll. There are 

at least two species of gecko on Rose Island; the Oceanic 

gecko (Gehyra oceanica) and the mourning gecko 

(Lepidodactylus lugubris) (Amerson et al. 1982) which were 

likely introduced by humans but are indigenous to the 

central tropical Pacific and at present do not show signs of 

posing a threat to BIDEH. 

4.11.3 Invertebrates 

Invasive ants and scale insects (Pulvenaria urbicola) have contributed to mortality of Pisonia 

grandis at Rose Island. These insects work together to invade and feed on sap from the leaves and 

petioles of the trees. The ants defend the scale insects and “farm” them for the concentrated liquid 

that they exude. This weakens the trees and may cause them to repeatedly shed their foliage until 

they eventually die. In 1994 Rose Island was covered with a thick forest of Pisonia, but by 2005, all 

but about 11 trees had perished. The surviving trees were treated with systemic imidacloprid. In 

2010, three of the treated trees remained alive but not healthy. The ants and scale invaders may have 

reached Rose Island on plantings and food or packing material of human visitors in recent decades. 

4.11.4 Vegetation 

Coconut trees were first observed on Rose Island in the mid-19th century and were likely planted by 

Samoan visitors (Setchell 1924). Mayor’s 1920 scientific account of Rose Atoll recorded about 6 

coconut trees remaining of about 15 that were planted in 1902 and 1920 by Governors Tilly and 

Terhune (Mayor 1921). Amerson and colleagues (Amerson et al. 1982) mapped 13 trees on the island 

in the mid-1970s. The Department of Agriculture visited Rose Atoll in 1957 and planted 50 coconut 

seedlings (Swerdloff and Needham 1970). In 1987, a DMWR expedition mapped 30 coconut trees on 

Gecko. USFWS. 
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Rose including several trees planted around the island by a “vessel crew” the previous year. Several 

trip reports make note of the coconut infestation and call for management (Shallenberger 1980). The 

elimination of rats in 1991 allowed many more nuts to germinate than had previously because 

coconuts were almost invariably eaten by rats. In 2005, Hurricane Olaf uprooted many of the native 

canopy trees (Tournefortia argentea and Pisonia grandis) on Rose Island. Three dense patches of 

adult coconut trees survived and by 2010 had spread. Coconut palms are very aggressive in 

displacing indigenous shrubs and trees because the nuts form an impenetrable mat over the ground 

and form a shading canopy monoculture that prevents the recruitment of native canopy trees. 

Wegmann and Holzwarth (2006) predicted that Rose 

Island’s vegetation was on the brink of a major 

composition change from a native Pisonia forest. They 

also facilitate unauthorized human visitors as the coconut 

juice stored in the nuts of the palm trees provides a 

source of liquid on an atoll where no freshwater exists for 

human consumption. In 2010 Refuge and DMWR staff 

and 3 contractors removed and destroyed 1,038 sprouted 

nuts, 94 green nuts from the trees, and 38 young palms 

using machetes. An additional 42 large palms were 

treated with glyphosate by drilling holes in the stem and 

applying the herbicide. They left one large coconut tree 

undisturbed in each of the three patches. 

In 1994, patches of the non-native grasses Cenchrus 

echinatus and Chloris barbata were removed from Rose 

Island (Craig et al. 1994), and a few individuals have had 

to be removed since then. No plants of either species 

were detected in 2010. 

4.12 Wildlife and Habitat Research Inventory and Monitoring 

Several scientific expeditions to Rose Atoll took place during the 1930s. In 1937 and 1938, Wray 

Harris, a scientist at the Bishop Museum, visited Rose Atoll to collect samples of mollusks and plants 

(Sachet 1954). The USCG brought a group of scientists to Rose Atoll in 1938; the observations were 

published by E.H. Bryan in 1939 and 1942 and W. Donaggho in 1953. In 1939, the U.S.S. Bushnell

conducted a survey of islands in the Pacific and 11 days were spent collecting specimens of fish from 

Rose Atoll (Sachet 1954). Under Executive Order 8683, President Franklin Delano Roosevelt 

designated Rose Island as a Naval Defense Sea Area on February 14, 1941. The United States Navy 

Hydrographic Office published a map of Tutuila, the Manu’a islands, and Rose Island in 1941. The 

data were gathered between 1901 and 1939 (Hudson and Hudson 1994). 

In February 1953, the Office of the Territories, DOI conducted a fishing survey in Rose Atoll (Sachet 

1954). In 1968, Rose Atoll was proposed as an “Island for Science” under the International 

Biological Programme (UNEP and IUCN 1988, IUCN 1991). The American Samoa Government 

sponsored a 1970 survey of Rose and Sand Islands, the reef flats, and the surrounding lagoon. The 

1970 survey stressed the importance of Rose Atoll to breeding seabirds and green turtles and 

recommended the atoll be designated a wildlife preserve (Swerdloff and Needham 1970). 

Niu on Rose Island. D. Palawski, 

USFWS. 
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Between the years 1973 (the Refuge’s establishment) and 2005, 49 documented expeditions visited 

Rose Atoll (Wegmann and Holzwarth 2006). The Service and American Samoa Government have 

cooperated on scientific visits and aerial reconnaissance trips to the Refuge. Between 2002 and 2012, 

the NMFS PIFSC organized and conducted biennial American Samoa Reef Assessment and 

Monitoring research cruises. 
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Chapter 5. Social and Economic Environment 

5.1 Cultural Resources 

Archaeological and other cultural resources are important components of our nation’s heritage. The 

Service is committed to protecting valuable evidence of plant, animal, and human interactions with 

each other and the landscape over time. These may include previously recorded or yet undocumented 

historic, cultural, archaeological, and paleontological resources as well as traditional cultural 

properties and the historic built environment. Protection of cultural resources is legally mandated 

under numerous Federal laws and regulations. Foremost among these are the NHPA as amended, the 

Antiquities Act, the Historic Sites Act, the Archaeological Resources Protection Act as amended, and 

the Native American Graves Protection and Repatriation Act. Additionally, the Refuge seeks to 

maintain a working relationship and consult on a regular basis with villages that are or were 

traditionally tied to Rose Atoll. 

5.1.1 Historical Background 

The seafaring Polynesians settled the Samoan archipelago about 3,000 years ago. They are thought to 

have been from Southeast Asia, making their way through Melanesia and Fiji to Samoa and Tonga. 

They brought with them plants, pigs, dogs, chickens, and likely the Polynesian rat. Most settlement 

occurred in coastal areas and other islands, resulting in archaeological sites lost to ocean waters. 

Early archaeological sites housed pottery, basalt flakes and tools, volcanic glass, shell fishhooks and 

ornaments, and faunal remains. Stone quarries (used for tools such as adzes) have also been 

discovered on Tutuila and basalt from Tutuila has been found on the Manu’a Islands. Grinding stones 

have also been found in the Manu’a Islands. Despite surveys, no quarries have been identified in 

Manu’a (ASHPO 2012). 

In the later period of Samoan pre-contact, warfare for titled positions was frequent in Samoa and it 

likely influenced Tutuila and Manu’a. Oral traditions in the Manu’a Islands refer to leaders of islands 

to the west (Fiji, Samoa, etc.) visiting on sometimes hostile missions. Defensive fortification sites, 

often located high on ridges and mountains, define this period, with one such structure in Tutuila (a 

large defensive wall) on the National Register of Historic Places and another structure (fortification) 

on Ofu Island planned for nomination to the National Register. There are also late pre-contact village 

sites in Tutuila and Faga on Ta’ū that are being nominated to the National Register. A typical layout 

of a Samoan village was a central open space (malae), surrounded by meeting houses, chiefs’ houses, 

other residences and cooking houses (ASHPO 2012). 

European contact occurred in 1722, with Dutch navigator Jacob Roggeveen followed by French 

explorers Louis-Antoine de Bougainville in 1768 and Jean-Francois de La Perouse in 1787. 

Englishman John Williams of the London Missionary Society arrived in 1830, bringing with him 

Christianity which changed Samoan culture and ways. It was also when Westerners started to settle 

these islands. European traders and military personnel also changed Samoan society. Local warfare 

ceased, quarries were abandoned with the introduction of metal tools, and local customs and 

practices changed (ASHPO 2012). 

The Tripartite Convention of 1899 formally partitioned the Samoan archipelago into a German 

colony and a U.S. territory. This convention resulted from several years of civil war among Samoan 

factions and the larger rivalry between the U.S., Germany, and Britain. The U.S. acquired the eastern 
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islands, while Germany took control of what now comprise Samoa, which New Zealand forces took 

from the Germans in 1914 until 1962 (ASHPO 2012). 

American Samoa, under U.S. Naval control from 1900 to 1951, was a coaling station for its fleets. 

World War II (WWII) began the transition of the economy from subsistence toward commercial. The 

U.S. Naval Station Tutuila (now a Historic District listed on the National Register) was the 

headquarters of the Samoan Defense Group, which included several adjacent island groups. Historic 

properties from WWII are found throughout the islands. Post WWII, American Samoa’s military 

importance declined and the 1940s and 1950s saw severe economic distress with the Navy leaving. 

This period started the exodus of the Samoan workforce to Hawai‘i and the mainland U.S. In 1951, 

the administrative responsibility for coordinating Federal policy to the Territory was transferred to 

the DOI, where it remains today. Between 1951 and 1977, Territorial Governors were appointed by 

the Secretary of the Interior; but since 1977, they have been elected by universal suffrage (ASHPO 

2012). American Samoa has its own constitution, its own legislature, its own court system, and a 

non-voting delegate in the U.S. House of Representatives. 

Starting in 1954, the tuna industry started to invest in American Samoa with the opening of canneries 

by the Van Camp Seafood Company of California and Starkist Incorporated. It became a major 

industry for the Territory, attracting workers from Samoa as well as China. This last decade has seen 

a decline, however, with the canneries downsizing or shutting down (ASHPO 2012). 

Despite its post-contact history and Western interactions, the Samoan culture and societal structure 

remains strong (often reflected in the phrase fa’a Samoa or the Samoan way of life). Communal or 

aiga (family) land and matai (chief) systems remain intact. The matai are divided into ali’i (high 

chiefs) and tulafale (talking chiefs or orators who usually serve as executive agents for ali’i). The 

basic unit of Samoan society, the aiga or extended family group, is a group of people related by 

blood, marriage, or adoption. This family group can number from a few to several hundred who also 

acknowledge a common allegiance to a particular matai. The matai possesses some authority over 

the members of his family and regulates some of their activities as well as family resources 

(especially land—up to 90 percent of land in American Samoa is communally owned). However, 

traditionally, the matai consults the aiga before exercising his authority. The matai title holder will 

always be from the same family line. A non-family/descent line cannot hold a ranking matai title 

within a family. The resilience of the Samoan culture also has to do with its preservation being 

codified in its Bill of Rights (Article 3) and American Samoa Code Annotated (Title 1, section 

1.0202). 

5.1.2 Rose Atoll and Manu’a Islands 

The Manu’a Islands are comprised of Ofu, Olosega, and Ta’ū Islands and Rose Atoll. Manu’a 

contains the origins of Samoans and the genealogy of Polynesians east of Samoa is said to have 

originated here. The Solo’o Va recounts the creation of Samoa and Manu’a is described as the first of 

lands and the high peak of the island of Ta’ū, home of Tagaloa (the earthly offspring of the creator 

god). As such, the islands of Manu’a are considered sacred and the title of Tuimanu’a, seen as being 

the highest in rank of all the chiefly titles of Samoa. When the last Tui Manu’a died in 1909, the Tui 

Manu’a title was distributed amongst the different villages in Manu’a (e.g., Tui Olosega, Ofu). 

The Manu’a islands were always independent of the other Samoan Islands, though songs, stories and 

genealogies show contact occurred among all the islands. It was known that De Bougainville had 

traded with Manuans at Ofu in 1768, but did not land (Taomia 1997). John Williams and other 
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Christian missionaries arrived in Manu’a in 1832. The cession of the Manu’a Islands to the U.S. 

occurred in 1904 and included Rose Atoll (though it is said that the Tuimanu’a at the time traveled to 

Rose Atoll after this partition and took with him a flag representing the five islands of Ofu, Fo’isia, 

Olosega, Ta’ū, and Rose Atoll which he staked at the atoll to reassert his authority [SSI 2012]). The 

Manu’a Islands form, administratively, the Manu’a District, one of three districts in American 

Samoa. Ofu, Olosega, and Ta’ū are all high islands and all lands are communally owned (Ta’ū is 

physically the largest island). Villages in Manu’a usually number about 300 people. Local farming 

and fishing is prevalent. The Manu’a Islands were also where famed anthropologist Margaret Mead 

did her research (in the village of Ta’ū) and based her 1928 book Coming of Age in Samoa. 

Although archaeological studies have been conducted on the Manu’a Islands, prior to 2012, none of 

the studies included Rose Atoll. The Manuan people call the atoll Muliāva, which means “the end of 

the reef” or Muli A’au which means “the last reef” (Gray 1960, Krämer 1995). Other names used are 

Motu o Manu (island of seabirds) and Nu’umanu (place of the sea monsters) and Nu’u o Manu, 

meaning “village of seabirds” (Krämer 1995, Maragos, pers. comm. 2010). Written documentation of 

historical uses of Rose Atoll by the Samoans is extremely limited, as the primary method of passing 

down information through the generations was through oral tradition. However, in general, Samoans 

believe that their relationship to lands and contiguous reefs and seas is a covenant with the Almighty. 

Samoans were gifted these resources to use for sustenance and their perpetuation, but also given the 

responsibility to properly conserve and husband these resources (SSI 2012). It is said that the 

Tuimanu’a routinely visited the Manu’a Islands and often ended his trip at the atoll. The kings of 

Samoa would assemble near the atoll and often participated in games and leisurely activities, which 

included the snaring of terns. Due to the use of the atoll by the high chiefs, it was considered sacred 

and visitors were forbidden from setting foot on the atoll. The atoll was also believed to be guarded 

by ilamutu (supernatural protectors) (SSI 2012). 

According to local knowledge, the Manuans used celestial navigation to reach Rose Atoll. Rose Atoll 

is featured in a Manuan chant entitled “O le Solo a Fitiaumua” (Krämer 1995). The song tells the 

story of a husband and wife chased away from their home in Fitiuta after the husband stole food from 

a chief’s taro plantation for his starving pregnant wife. The couple was banished, set adrift on the 

ocean where they landed at Rose Atoll, where they had a son, Fitiaumua. When the boy became an 

adult, he learned of his parents’ story and sought revenge. He overran and conquered Samoa, Fiji, 

and Tonga in a war, and became a successful king residing in Manu’a. 

Samoan islanders visited Rose Atoll to fish and collect birds (including feathers for cultural 

adornments and handicrafts, the most prized of which came from the red and white-tailed 

tropicbirds), turtles, giant clams and other resources (Amerson et al. 1982). Terns were especially 

used to direct fishermen to schools of fish. It was customary for the strongest males of Manu’a to go 

out with the tautai (master fishermen), to fish for sharks and skipjack tuna. However, the SSI report 

notes that of the fishermen who had been interviewed (all in their 60s), none had been to Rose Atoll 

until the 2011 trip and that it had been their father’s generation who had first-hand experience fishing 

at the atoll. The report also noted that a village men’s group described that fishing trips to Rose Atoll 

were only conducted when season fish were not abundant in immediate waters and reefs (SSI 2012). 

Many of the seabirds found at Rose Atoll are also reflected in Samoan sayings, such as: Seu le manu 

ae taga’i i le galu (refers to the boobies)—applied in advising one to take caution; Taape le 

fuāmanusina (refers to the tropicbirds)—used at the closing of meetings to mean that everyone will 

depart together; Ua pafuga le ā e pei o le faiva o le seugā gogo (refers to terns and the sound of their 
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calls) when a school—said in happy salutations and occasions. There are also similar sayings related 

to sharks (SSI 2012). 

Samoans also brought volcanic rocks to use as cooking stones when they fished and hunted turtles 

(Keating 1992). However, because Rose Island has no fresh water, visitors likely stayed for short 

durations. The first recorded Western sighting of Rose occurred in July 1722 by Dutch explorer 

Jacob Roggeveen, who referred to the atoll as “foul island” after observing the island was surrounded 

by a reef of rocks and had a low elevation (Sharp 1970, Krämer 1995). However, the atoll was given 

its lasting Western name in 1819 by French navigator Louis de Freycinet who named it after his wife. 

Louis de Freycinet was the Commander of the French vessel L’Uranie on a voyage of discovery that 

circumnavigated the globe. The 22-year-old Rose de Freycinet was a smuggled on board dressed as a 

man and also has Cape Rose in Western Australia named after her (Bassett 1962, Western Australia 

Museum 2012, Sharp 1970). 

Additional western observations came in 1824 by Russian explorer Otto von Kotzebue and 

Frenchman Dumont D’Urville in 1838. The first recorded landing at Rose was documented by 

Captain Charles Wilkes of the U.S. Navy. He led an expedition to the atoll in 1839 where botanists 

and an anthropologist collected specimens. Two plants, Portulaca and Pisonia grandis were 

recorded. 

The only documented case of people living on Rose 

Atoll came in the 1860s when a German company 

bought the right to establish a fishing station and 

coconut plantation from the Tui Manu’a (High 

Chief of the Manu’a Islands) and a Samoan family 

was stationed on Rose Island for a few years (Gray 

1960, Sachet 1954). In 1990 the remains of the 

foundation of a fale (traditional Samoan house) that 

could have dated to the 1860s was located by David 

Herdrich from ASHPO (Herdrich, pers. comm. 

2011). In January 1920, Governor Terhune went to 

Rose Island and erected a concrete monument 

commemorating the visit with the words “Rose 

Island, American Samoa, Trespassing Prohibited, 

Warren J. Terhune Governor, January 10, 1920”. 

The monument is 4 feet high, 4 feet wide and 1 foot 

thick. It is still on the island but is no longer 

standing upright due to unstable ground. The area is 

presently a Tournefortia forest and the monument is 

no longer visible from the water or beach. There is a second, smaller concrete U.S. Navy survey 

marker. It had fallen over as well, but was righted in March 2008 during a NOAA CRED mission 

which included Governor Tulafono. 

Fallen monument and location of former Refuge 

sign. USFWS. 
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Rose Island is subject to wash overs by waves during hurricanes, making it a poor environment for 

maintaining archeological artifacts. There are no historic properties at the atoll. 

There are four known records of ship wrecks in the area; schooner Friendship (1849), schooner 

Wakulla (1853), schooner Good Templar (1868), and the fishing vessel Jin Shiang Fa (1993). The 

Jin Shiang Fa ran into the southwest section of the atoll and broke apart. The largest sections of it 

were towed off the reef and dumped in the deep ocean, but pieces of it may still wash up on the reef 

in hurricanes to this day. There are no signs of the older wrecks. 

A pre-contact canoe anchor was found at Rose Atoll 

and given to the National Park of American Samoa and 

displayed in their visitor center. The anchor was lost in 

the September 2009 tsunami that destroyed the visitor’s 

center. 

In March 2011, 12 Manu’a community representatives, 

and 5 students and 5 teachers from Manu’a schools 

attended a trip to the Refuge. The purpose of the trip 

was documenting the oral history of Rose Atoll. It was 

sponsored by the IGC (consisting of the DMWR, the 

Service, ONMS, NMFS and ASDOC) and was funded 

by a grant from the NMFS to the DMWR. The SSI 

completed a report (entitled “Oral Traditions of Rose Atoll (Muliava)”), along with a bilingual 

brochure and DVD, to document the trip as well as the connections between the people of Manu’a 

and Rose Atoll (Muliava, Nu’u o Manu). 

The information generated from this trip will be used to produce EE and cultural interpretation 

materials for use by communities and outreach to the larger public. 

In February 2012, 3 archeologists (including lead archaeologist David Herdrich from ASHPO) 

conducted a 5-day survey of Rose Atoll on a Service-sponsored trip. This was the first in-depth 

archeology trip to Rose Atoll conducted. At the time of this writing their results are still being 

analyzed, which will be available to the public when completed. 

A canoe anchor that was found on Sand 

Island by David Herdrich, ASHPO, in 

1990. NPS. 

Fallen monument (archaeological team visit with USFWS and NPS staff) and Navy survey marker (right photo). 

USFWS. 
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5.2 Refuge Facilities 

Refuge facilities are usually structures that support both visitor services and biological management 

at a refuge. However, Rose Atoll NWR is closed to general public use and has no permanent 

infrastructure such as roads, fences, trails, etc. At one time, the Refuge did have a sign at Rose Island 

identifying the atoll as a NWR and being closed to visitors, however, due to weather conditions and 

storm events, it has since fallen into disrepair and is no longer on the island. 

Though the Refuge does not have facilities at the atoll, it does have office space co-located with the 

National Park of American Samoa in Tutuila and also contracts a boat for transportation to the atoll 

for management purposes. 

5.3 Public Use Overview 

The Refuge is closed to general public use to protect the sensitive habitats and wildlife at the atoll. Its 

remote location, logistical challenges, and safety issues also substantiate its closure to the general 

public. 

5.4 Wildlife-Dependent Public Uses 

The Improvement Act identified wildlife observation and photography, hunting and fishing, and EE 

and interpretation as Wildlife-Dependent, priority public uses for the Refuge System. A SUP is 

required to enter the Refuge for any purpose. 

5.4.1 Hunting 

The Refuge is not open for hunting due to the sensitive wildlife found at the atoll. 

5.4.2 Fishing 

In the 1980s, the Refuge’s Public Use Policy permitted fishing in the Refuge as long as the fish were 

released or consumed within the Refuge (USFWS 1987). However, this policy was discontinued in 

the early 1990s. The Refuge continues to be closed for fishing due to the small size of the lagoon and 

its limited fish and invertebrate community. The ecological limits of these populations make them 

particularly vulnerable to fishing pressure. Closure to fishing also adheres to the Monument 

Proclamation, meets the Refuge’s purposes, and fulfills the Governor of American Samoa’s support 

for a no-take area to protect the coral reef ecosystem. Fishing is offered in other parts of American 

Samoa. 

5.4.3 Wildlife Viewing and Photography 

The Refuge is not open to wildlife viewing or photography and no SUP have been issued in the past 

for this activity. Wildlife viewing and photography opportunities are offered on the high islands of 

American Samoa (e.g., National Park of American Samoa). 
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5.4.4 Environmental Education 

During the 1980s and 1990s, field trips for students and teachers to the Refuge occurred. However, 

given the disturbance to wildlife, logistical difficulties, safety issues, and lack of available staff, such 

opportunities were discontinued and there is no EE currently offered at this Refuge. However, other 

types of EE about the Refuge are offered on Tutuila and the Manu’a Islands (see Chapter 2 regarding 

the future focus of EE on bringing the Refuge to the people, not bringing the people to the Refuge). 

5.4.5 Interpretation/Outreach 

Prior to the 2009 tsunami, there was interpretive information about Rose Atoll and the Refuge at the 

National Park of American Samoa visitor center. The Service is presently working with NPS to have 

displays again in their new visitor center. The Service maintains a Website 

(http://www.fws.gov/roseatoll/), and we have given regular talks about Rose Atoll to students at the 

American Samoa Community College. 

5.4.6 Cultural Resources Interpretation 

Currently no cultural resources interpretation is conducted. However, the March 2011 and February 

2012 trips identified in the previous section will provide information that can be used for these 

purposes in the future. 

5.5 Illegal Uses 

Due to the remoteness of the Refuge, systematically documenting illegal use is challenging. 

Documented cases between 1973 and 2005 (Wegmann and Holzwarth 2006) recorded two illegal 

incidents. Additionally, according to the annual law enforcement NWRS reports, one incident of 

trespass was recorded in 2010. However, given accounts provided to Refuge staff and encounters 

during Refuge visits, it is known that recreational boaters and fishermen enter the Refuge illegally. In 

June 2009, Service staff were called upon to help 

rescue a grounded boat in the lagoon. On a 

September 2010 trip to Rose Atoll conducted by the 

Service and the DMWR, two private vessels 

expecting to enter the Refuge were turned away. 

Vessels over 50 feet are excluded from fishing 

within 50 nautical miles of Rose Atoll. During the 

writing of this CCP the NOAA NMFS is developing 

fishing regulations for the Monument, and the 

Service is working with partners to develop 

enforcement options. 

The Service law enforcement issues on lands and 

waters of the Refuge are under the jurisdiction of the 

Refuge Zone Officer based in Honolulu. The role of this officer is to conduct and document law 

enforcement incidents and coordinate and/or meet with Refuge staff as well as law enforcement 

partners. Primary laws and regulations enforced include, but are not limited to, the: 

 Administration Act; 

Yacht being towed out of the Refuge. Wally 

Thompson. 
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5-8 Chapter 5. Social and Economic Environment 

 Lacey Act; 

 Archaeological Resource Protection Act; 

 ESA; 

 MBTA; and 

 Marine Mammal Protection Act. 

Zone officers are also empowered to enforce all criminal laws and often partner with other law 

enforcement agencies. The USCG enforces natural resource laws by providing patrol and 

surveillance of the Refuge, both on site and through remote sensing. The Refuge Zone Officer 

coordinates with the USCG on issues of trespass and illegal activities. 

5.6 Social/Economic Environment 

5.6.1 Communities near Rose Atoll National Wildlife Refuge 

The nearest community to the Refuge is the Manu’a Islands, approximately 80 miles away. The next 

group of islands closest to the Refuge is Tutuila and Aunu’u, approximately 180 miles away. Tutuila 

is where the main population, government, and industries are for American Samoa. 

5.6.2 Population, Housing, and Income 

In 2010, the population of American Samoa was around 65,000 and growing at 1.5 percent annually. 

A majority of this population lives on Tutuila with only about 1,100 people living in the Manu’a 

Islands. In 2000, the median household income was $17,000 (Craig 2009, CIA 2011, Pacificweb 

2011). For Si’ufaga (Ta’ū Village) and Leusoali’i (Faleasao) on Ta’ū Island, median household 

income was $12,500 and $15,625 respectively (U.S. Census Bureau 2003). The total population of 

American Samoa is comprised of approximately 92 percent native Pacific islanders, 3 percent Asian, 

1 percent white, and 2 percent other ethnic origin. The median age is 23 years (OIA 2012). For 

people on Si’ufaga (Ta’ū Village) and Leusoali’i (Faleasao), there was a high percentage of high 

school graduates or higher (70.5 percent and 56.8 percent respectively). These two villages also were 

overwhelmingly Samoan in terms of population composition (91.3 percent and 99.4 percent 

respectively) (U.S. Census Bureau 2003). 

Measuring economic welfare in American Samoa is challenging due to lack of data. It should also be 

noted that cost of living and income cannot be compared to the continental U.S. as American Samoa 

still maintains traditional lifestyles where subsistence living is a common way of life. Three common 

measures of economic welfare are the unemployment rate, per capita income, and gross domestic 

product per worker; however, there are almost no data on these measures. Based on a study that was 

done for the American Samoa Department of Commerce (McPhee et al. 2008), the unemployment 

rate in 2002 was in the vicinity of 7 percent, roughly one-half the rate in 1977, real per capita income 

rose at a 2.1 percent annual rate between 1977 and 2002, and nominal-dollar gross domestic product 

(GDP) per worker increased from $6,054 in 1977 to $27,048 in 2002. The study found that 

employment had doubled between 1977 and 2002, the unemployment rate had fallen, and per capita 

income rose by about 2 percent. 
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5.6.3 Employment and Business 

Major employers are the American Samoa Government and a tuna cannery. One of two tuna 

canneries closed in 2009, leaving only TriMarine (or Samoa Tuna Processors) as the only cannery 

(CIA 2011). The American Samoa economy is not well diversified leaving the Territory very 

dependent on the tuna industries and Federal grants and aid. 

According to the U.S. Census Bureau’s 2007 Economic Census for Island Areas, the Manu’a District 

had 12 establishments with payroll which qualified for this census. A majority of this (8) was 

identified as retail trade. However, construction and educational, health, and social services were the 

industries which employed the largest percentage of workers in both Si’ufaga and Leusoali’i. About 

51.9 percent and 47.1 percent of Si’ufaga and Leusoali’i, respectively, were in the labor force and 

14.3 percent of Si’ufaga people unemployed (there are no data for Leusoali’i) (U.S. Census Bureau 

2003). 

Table 5-1. Employment and Labor Income 2002 

Source: McPhee et al. 2008 
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Table 5-2. Economic Projections 2000-2015 

Note: Projections in the table above may have been affected by the 2008 economic downturn. 

Source: McPhee et al. 2008 

5.6.4 Refuge Impact on Local Economies 

The Refuge has no substantial impact on the local economy. There is no visitation by the general 

public allowed to the Refuge so impacts to the surrounding community economies does not exist as 

they do for other refuges. However, permitted activities, such as research can contribute to the local 

economy via purchase of supplies, contracts for transportation and personnel, housing, food, etc. 

There is only one Refuge employee, a Refuge/Monument Manager based out of Tutuila so staff 

contribution to the local economy is negligible (e.g., personal expenditures such as rent, groceries, 

and work related expenditures such as operational supplies). Related Refuge personnel based in 

Honolulu, Hawai‘i sometimes assist with Refuge management and can contribute to the local 

economy similar to research activities. The Fiscal Year (FY) 11 budget for the Refuge was $141,145. 
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5.6.5 Additional Economic Contributions 

It is important to note that the economic value of the Refuge encompasses more than just the impacts 

on the regional economy. The Refuge also provides substantial nonmarket values (values for items 

not exchanged in established markets) that should also be considered. Examples include maintaining 

endangered species, preserving habitats, educating future generations, and adding stability to the 

ecosystem (Carver and Caudill 2007). According to a recent report, the total value of ecosystem 

services provided by natural habitats in the Refuge System in the contiguous states totaled $32.3 

billion per year, or $2,900 thousand per acre per year (Southwick Associates 2011). 

 
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Chapter 6. Summary of Effects 6-1 

Chapter 6. Summary of Effects 

This chapter provides an analysis of the environmental consequences of implementing the 

alternatives described in Chapter 2. Impacts are described for the main aspects of the environments 

described in Chapters 3-5, including physical, biological, cultural, and socio-economic resources. 

The potential effects to these resources as a result of implementing the strategies described under 

each alternative were then assessed. In addition to Chapters 3-5, Refuge staff experience, existing 

databases and inventories, relevant plans, studies, and past and current research were used for this 

analysis. We also used public scoping during 2009 to assess effects. 

The alternatives are compared “side by side” under each topic, and both the positive and negative 

effects of implementing each alternative are described. Table 6-1 provides an overview of the effects 

under each alternative by indicator. Alternative B (Preferred Alternative) is compared to Alternative 

A (the No Action Alternative), which presents current management strategies. Effects are described 

in terms of the change from current conditions. Therefore, the consequences of implementing 

Alternative A usually result in negligible effects as they already reflect current conditions. 

For the most part, boundaries for analysis (direct, indirect, cumulative) were at the Refuge level, but 

for the socio-economic resources, nearby communities (e.g., Manu’a Islands), were included and 

some biological resources took into account species ranges as they can move beyond the Refuge. 

Subheadings (e.g., habitat, research, cultural resources) have been included to guide the reader in 

understanding which types of management strategies are likely to affect each resource. However, not 

all management strategies affect each resource so only relevant subheadings are identified for each 

resource. Cumulative impacts, including impacts to Refuge resources from reasonably foreseeable 

events and impacts resulting from interaction of Refuge actions with actions taking place outside the 

Refuge, are addressed in the final section of this chapter. 

Effects were assessed for scope, scale, and intensity of impacts. Although the analysis shows that 

neither of the alternatives would be expected to result in significant effects, some positive 

(beneficial) or negative (adverse) effects are expected. The terms intermediate, minor, and negligible 

are used to describe the magnitude of the effect. To interpret these terms, intermediate is a higher 

magnitude than minor, which is of a higher magnitude than negligible. The word negligible is used to 

describe a neutral or unnoticeable effect compared to the current situation. 

Scope, scale, and intensity can be defined on a range from negligible to major. 

 Negligible. Resources would not be affected, or the effects would be at or near the lowest 

level of detection. Resource conditions would not change or would be so slight there would 

not be any measurable or perceptible consequence to a population, wildlife or plant 

community, recreation opportunity, visitor experience, or cultural resource. 

Major Intermediate Minor Negligible Minor Intermediate Major

Negative Beneficial 
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 Minor. Effects would be detectable but localized, small, and of little consequence to a 

population, wildlife or plant community, recreation opportunity, visitor experience, or 

cultural resource. Mitigation, if needed to offset adverse effects, would be easily 

implemented and successful. 

 Intermediate. Effects would be readily detectable and localized; with consequences to a 

population, wildlife, or plant community, recreation opportunity, visitor experience, or 

cultural resource. Mitigation measures would be needed to offset adverse effects and would 

be extensive, moderately complicated to implement, and probably successful. 

 Major (significant). Effects would be obvious and would result in substantial consequences 

to a population, wildlife or plant community, recreation opportunity, visitor experience, or 

cultural resource within the local area and region. Extensive mitigating measures may be 

needed to offset adverse effects and would be large scale in nature, very complicated to 

implement, and may not have a guaranteed probability of success. In some instances, major 

effects would include the irretrievable loss of the resource. 

Time and duration of effects have been defined as follows. 

 Short-term or Temporary. An effect that generally would last less than 1 year or season. 

 Long-term. A change in a resource or its condition that would last longer than a single year 

or season. 

Table 6-1. Summary of Effects under CCP Alternatives 

Alternative A 

(No Action) 

Alternative B 

(Preferred) 

EFFECTS TO PHYSICAL ENVIRONMENT 

Effects to Soils Negligible Negligible to minor, long-term, and beneficial 

Effects to 

Water Quality 

Minor, 

beneficial 

Negligible to minor, beneficial 

Effects to Air 

Quality 

Negligible Negligible 

EFFECTS TO WILDLIFE AND HABITATS 

Effects to Ava Negligible Negligible 

Effects to 

Lagoon 

Negligible Negligible 

Effects 

Perimeter Reef 

Negligible Long-term, beneficial minor to intermediate 

Effects to 

Beach Strand 

Minor, 

beneficial 

Minor, beneficial 

Effects to 

Littoral Forest 

Negligible Negligible to intermediate, short-term negative, long-term beneficial 

Effects to 

Federally 

Listed 

Negligible Beneficial, long-term, minor 
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Alternative A 

(No Action) 

Alternative B 

(Preferred) 

Effects to 

Seabirds 

Negligible Beneficial, negligible to minor, long-term 

Effects to 

Shore, Wading, 

and Land 

Birds 

Negligible Beneficial, negligible to minor, long-term 

Effects to 

Invertebrates 

Negligible Negligible to minor, beneficial, long-term 

Effects to Reef 

Building 

Species 

Negligible Negligible to minor, beneficial, long-term 

Effects to Fish Negligible Negligible 

Effects to Pest 

Species 

Negligible Negligible 

EFFECTS TO CULTURAL AND HISTORIC RESOURCES 

Effects to 

Cultural and 

Historic 

Resources 

Negligible Negligible 

EFFECTS TO SOCIAL AND ECONOMIC RESOURCES 

Effects to 

Quality 

Environmental 

Education 

Negligible Beneficial, intermediate, long-term 

 

Effects to 

Quality 

Interpretation 

Negligible Beneficial, intermediate, long-term 

Effects to 

Illegal Use 

Negligible Beneficial, intermediate, long-term 

Effects to 

Environmental 

Justice 

Negligible Negligible 

Effects to 

Economics 

Negligible Beneficial, long-term, but negligible 

ADDITIONAL EFFECTS 

Effects to 

Adjacent 

Lands 

Negligible Negligible 
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Alternative A 

(No Action) 

Alternative B 

(Preferred) 

Effects to 

Nearby 

Residents 

Negligible Beneficial, minor, long-term 

Cumulative 

Effects 

Negligible Negligible 

6.1 Effects Common to All Alternatives 

Integrated Pest Management (IPM). Potential effects to the biological and physical environment 

associated with the proposed site-, time-, and target-specific use of pesticides (Pesticide Use 

Proposals [PUP]) on refuge lands are evaluated using scientific information and analyses 

documented in “Chemical Profiles” (see Appendix G). These profiles provide quantitative 

assessment/screening tools and threshold values to evaluate potential effects to species groups (birds, 

mammals, and fish) and environmental quality (water, soil, and air). The PUP (including appropriate 

best management practice [BMP]) would be approved where the Chemical Profiles provide scientific 

evidence that potential impacts to refuge biological resources and its physical environment are likely 

to be only minor, temporary, or localized in nature. Along with the selective use of pesticides, a PUP 

would also describe other appropriate IPM strategies (biological, physical, mechanical, and cultural 

methods) to eradicate, control, or contain pest species in order to achieve resource management 

objectives. 

The effects of these non-pesticide IPM strategies (e.g., mechanical control or removal of an unnatural 

nutrient source exacerbating the growth of an undesirable species) to address pest species on Refuge 

lands and waters would be similar to those effects described elsewhere within this chapter, where 

they are discussed specifically as habitat management techniques to achieve resource management 

objectives on the Refuge. 

Based on scientific information and analyses documented in “Chemical Profiles,” most pesticides 

allowed for use on refuge lands and waters would be of relatively low risk to non-target organisms as 

a result of low toxicity or short-term persistence in the environment. Thus, potential impacts to 

Refuge resources and neighboring natural resources from pesticide applications would be expected to 

be minor, temporary, or localized in nature. 

6.2 Effects to the Physical Environment 

Topics addressed under the physical environment section include effects (direct and indirect) to water 

quality, air quality, and soils. 

Continuing the current management (Alternative A) generally has negligible, if any, effects because 

little or no change to current conditions is proposed. The effects for Alternative B are described in 

terms of the change from current conditions and given the increased management level is more 

beneficial than Alternative A. 
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6.2.1 Effects to Soils 

Effects from Habitat Management Strategies: Under Alternative A and B, several habitat 

management strategies involve monitoring. Depending on the type of monitoring conducted, there 

could be effects to soils from the equipment used and its installation, both terrestrially on the two 

islands and to the sandy bottom of the lagoon. Examples of such equipment that may disturb soils 

include the stakes used to mark out a grid on Rose Island, pitfall traps for insect collection, and 

anchors that might be used to secure a science buoy in the lagoon. Soils may also be collected. The 

trampling of soils by those conducting the monitoring (e.g., 6 people for 15 days per year) may also 

either shift or compact the humus or sand. Such activities (and therefore effects) may be short- or 

long-term depending on the monitoring objective. However, given similar monitoring activities 

already conducted at the Refuge and other refuge atolls and that the two islands experience wash 

overs during storms, it is anticipated that effects to soils would be negligible. 

Teams monitoring the terrestrial system and the reef flats need to camp on the island in order to do 

their work at the appropriate time relative to diel and tidal cycles. Setting up temporary tents may 

disturb soil with tent stakes but the disruption is minimal and temporary. 

Under Alternative B, restoration of the littoral forest may also have effects to soil through changes in 

vegetation cover type and input of guano by the birds. The objective of forest restoration is to 

increase the Pisonia population and inhibit the niu population. This increase in vegetation could also 

lead to more available habitat for nesting seabirds, thereby increasing the amount of guano input into 

soils. 

However, given that historical data show the littoral forest having had larger coverage than it does 

today, it is anticipated that this would be a beneficial effect that could restore the soil structure to 

previous conditions (the combination of guano and Pisonia growing on coralline substrate produces a 

rich peat-like acidic humus called phosphatic cay rock [Fosberg 1957]). Additional restoration work 

could be removal of pest species, such as the patches of non-native grasses that were removed in 

1994. Very temporary disturbance of the soil occurs when such plants are removed (e.g., roots 

uprooted); however, given they were not part of the original habitat, their removal could be beneficial 

for soils in returning soil chemistry to a previous state. Therefore, effects are anticipated to be minor, 

but beneficial. 

Installation of remote sensing is proposed under Alternative B. Depending on the type of system 

used, installation of such equipment may affect soils similar to the monitoring activities (e.g., stakes 

Examples of temporary tents used for field work. USFWS. 
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or poles into the ground for sensors, solar panel, antenna, battery pack, camera, etc.). Installation of 

the system would be only a temporary disturbance, however, this would be a long-term, beneficial 

effect as the system would be in use for the duration of the CCP and would help to deter illegal 

trespass and people trampling on the soils. It is anticipated that the effects to soils would be 

negligible to minor based on similar technologies already used on the islands of Kaua‘i, O‘ahu, and 

Maui in Hawai‘i and northern California. 

Effects from Research Management Strategies: Similar to the monitoring activities identified in 

the habitat management section above, identified research projects may involve installation of 

equipment or stakes and soil collection. Research activities may be short- or long-term depending on 

the research objective. However, these effects are anticipated to be negligible given the experience of 

staff with similar research projects conducted at the Refuge and other refuge atolls. Additionally, 

permitted research also undergoes a review of possible impacts before they are issued to help ensure 

effects are negligible (for further information, see related CD in Appendix C). 

Effects from Cultural Resource, Outreach, and EE Management Strategies: Under both 

Alternatives A and B, reinstituting minimal signage is proposed. Soil disturbance would occur related 

to installation (staking poles into the ground). It is proposed under Alternative B to restore the 

cement monument erected by the Governor in 1920. Soil disturbance would occur to resurrect this 

fallen monument as it would need to be placed back into the ground with appropriate structures to 

keep it upright. Under this alternative, archaeological surveys as well as visits by cultural 

practitioners may occur. The trampling of soils by those conducting such activities could be 

experienced. However, given that the restoration would occur in the same area where the monument 

still exists and where soils are already disturbed and that Refuge-authorized personnel would 

accompany archaeologists and cultural practitioners to educate on minimizing such impacts, it is 

anticipated that effects to soils would be negligible. 

For EE, it is proposed to bring a small group of teachers and students (<10 people and <once every 3 

years) to the Refuge. Similar to management effects already identified, trampling of soils and 

disturbance of soils either through camping or walking around would be the effects most related to 

EE. However, similar to the other management effects, Refuge-authorized personnel would 

accompany this group to educate on minimizing such impacts or the group may be required to stay 

on the boat rather than camp so it is anticipated that effects to soils would be negligible. 

Conclusion: Overall effects to soil from commonly proposed management actions under both 

Alternatives A and B would be negligible. The additional actions proposed under Alternative B 

(namely littoral forest restoration) effects would be minor, long-term, and beneficial. 

6.2.2 Effects to Water Quality 

Effects from Habitat Management Strategies: Under both Alternatives A and B, proposed 

management actions which may affect water quality are removal of the iron and related 

cyanobacteria. Cyanobacteria blooms and mats that negatively affect reefs by smothering corals and 

other invertebrates have been documented in coral reef and seagrass habitats (Richardson 1995, Paul 

et al. 2005, Kelly et al. 2012) but effective means of removing them have not been developed. It is 

generally accepted that iron limits primary production by algae and cyanobacteria on central Pacific 

coral atolls, where sediments consist mostly of calcium carbonate generated through the erosion of 

calcifying organisms, and that shipwreck-associated iron releases these primary producers from 

bottom-up controls and enables their proliferation (Kelly et al. 2012). Removing the exogenous 
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source of the iron (i.e., metallic debris from the shipwreck), is clearly the first management action to 

be undertaken to control the proliferation, and at Rose Atoll all visible metallic debris was removed 

by 2007. Nonetheless, effects can be persistent and such “black reefs” can extend large distances 

from the wreck site, suggesting that the iron is being rapidly complexed and recycled in the marine 

environment. 

Ecological disturbances on reefs can reach critical thresholds resulting in a shift to an alternative 

stable state (“phase shift”), which is then maintained by self-reinforcing feedback mechanisms. On 

coral reefs, it has been posited that phase shifts could be irreversible even after a disturbance is 

resolved (Knowlton 1992, Norstrom et al. 2009). With this caveat, the potential for recovery at Rose 

Atoll is promising because these remote reefs are spared many anthropogenic impacts, such as 

overfishing and pollution, and because high densities of coral cover and CCA nearby increase the 

likelihood of repopulation by stony corals and CCA (Schroeder et al. 2008). 

Despite biological sequestration, the amount of iron entering the atoll ecosystem from the shipwreck 

was likely low, given the mixing effects of waves, tides, and currents. Thus, it is anticipated that 

effects to water quality from iron removal and related cyanobacteria control would be beneficial but 

minor. 

The use of small boats with outboard motors in the Refuge may affect water quality related oil 

emissions. However, this would be minimized by requiring all outboard motors be 4-stroke engines. 

Effects from Research Management Strategies: During post-management of the 1993 ship wreck, 

it was discovered that the reinforcing bar (rebar) rods used for marking monitoring sites were 

leaching iron and causing tiny cyanobacteria blooms in halos around each stake. Since then, all 

research equipment left in the water is required to be made of stainless steel or other non-reactive 

materials to avoid such incidents. Monitoring for climate change variables is proposed, which would 

include water quality. It is anticipated that this would be beneficial as it would provide a baseline for 

water quality monitoring and alert the Refuge staff of any changes where management actions may 

need to be implemented. Given the very minor water quality work proposed and biosecurity 

measures currently in place, it is anticipated that effects to water quality from research would be 

negligible. 

Conclusion: Overall effects to water quality would be minor and beneficial under both Alternatives 

A and B due to the continued removal of iron and related cyanobacteria. Water quality effects 

resulting from the additional monitoring proposed under Alternative B would be negligible. 

6.2.3 Effects to Air Quality 

Effects from Habitat Management Strategies: Under both Alternatives A and B, any activities 

conducted would follow Federal standards of ambient air quality to assess air quality effects. 

Management strategies that could have air quality effects are mainly related to application of 

herbicides. Though it is anticipated that any use of herbicides would be directly applied to the target 

species (e.g., hand application or squirt bottles), should any spraying (e.g., backpack spraying) occur, 

to avoid spray drift, approved herbicides would be used in accordance with recommendations on the 

label attached to the product (e.g., applying large droplets for sufficient coverage, avoid application 

of herbicides on windy days or certain times of day). 
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Given the lack of data on ambient air quality specific to the atoll, it is difficult to assess the 

magnitude of effects this action on air quality, especially since tradewinds blow out to sea and 

dissipate such spray. However, given that we anticipate not using spraying as a primary herbicide use 

and have protocols in place, it is anticipated the effects would be negligible. 

The use of small boats with outboard motors in the Refuge would result in some exhaust being 

emitted. This would be minimized by requiring all outboard motors be 4-stroke engines. 

Conclusion: Effects to air quality from proposed management actions under both Alternatives A and 

B are negligible. 

6.3 Effects to Wildlife and Habitats 

Topics addressed under the wildlife and habitats section include direct and indirect effects to the 

perimeter reef, ava, lagoon, beach strand, littoral forest and the species supported by these habitats 

such as CCA, turtles, corals, fish, other invertebrates, birds, and Pisonia grandis and other 

indigenous plant species. 

The ESA, MBTA, and related recovery and conservation plans (e.g., green and hawksbill turtles, 

seabirds, shorebirds) were used to assess thresholds of significance for these analyses. 

Unless otherwise stated, continuing the current management (Alternative A) generally has negligible, 

if any, effects because little or no change to current conditions is proposed. Alternative A continues 

the beneficial effects of management. The effects for Alternative B are described in terms of the 

change from current conditions and given the increased management level is more beneficial than 

Alternative A. 

6.3.1 Effects to Habitats 

6.3.1.1 Effects to Ava 

Effects from Habitat Management Strategies: Monitoring to assess ava health and integrity is 

proposed under Alternatives A and B. Installation of oceanographic instruments such as current 

meters would require some small disturbance to the substrate to attach the device. Current anchoring 

devices used by NOAA CRED for instrumentation to monitor water flow rate and direction in the 

ava has had no discernible effect on the depth, topography, or other features of the ava; thus, effects 

are anticipated to be negligible as these activities would not widen or alter the ava in any way. 

Effects from Research Management Strategies: New research strategies proposed under 

Alternative B may increase boat traffic going through the ava. However, it is anticipated that this 

would have negligible effects to the ava as these activities would neither widen nor alter the ava. 

Effects from Cultural Resource and EE Management Strategies: See previous analysis for 

research management. 

Conclusion: Effects to the ava from proposed management actions are negligible. 
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6.3.1.2 Effects to Lagoon 

Effects from Habitat Management Strategies: Under Alternatives A and B, proposed monitoring 

to assess climate change variables as well as key focal species in this habitat would be important to 

assess the overall health of the lagoon. Additionally, under Alternative B, installation of remote 

sensing equipment may, depending on the system selected, require equipment be anchored in the 

lagoon and on the sandy bottom. However, it is anticipated that these activities would have negligible 

effects as they are minimal in scale and would adhere to Refuge protocols concerning use of 

equipment and habitat/species interactions (see previous sections such as 6.2.1 where examples of 

monitoring activities are provided). 

Implementation of Alternative B would involve more 

frequent visits to the Refuge by staff, researchers, and 

cultural practitioners and increased use of anchors to hold 

boats in place while management activities are conducted. 

Anchors and the anchor chain that are improperly placed in 

hard-bottom habitat can cause localized damage to corals, 

faisua, and other sessile organisms when the boat swings 

on the anchor in response to wind and waves, drags due to 

insufficient anchor line scope, or fouls when pulled up 

from the surface. Far less damage is potentially done by 

anchors on sand and other soft bottom, but such substrates provide poor holding power and the 

anchor would drag unless there is no wind or water motion affecting the boat. These effects can be 

mitigated by live-boating (i.e., not using an anchor, but keeping a coxswain aboard to maintain boat 

position in the vicinity of snorkelers/divers); using a diver to hand-place the anchor; using a diver to 

clear the anchor from the bottom before it is hauled up; and frequently checking the position of the 

boat for drift or anchor drag. These practices are already utilized by the Refuge. Additionally, a 

mooring buoy is also being considered. This would greatly reduce impacts compared to anchoring 

because the impacted area would be less in size and it would only be in one spot (installing would 

require sand screws to anchor the mooring in the sand bottom). Mooring buoys have been shown to 

minimize damage from frequent anchoring in places such as the Florida Keys National Marine 

Sanctuary and the Molokini Islet off of Maui. Site selection would be based on little to no impact to 

resources. Based on these measures, effects of securing boats are anticipated to be negligible. 

Effects from Research Management Strategies: Same as above in habitat management strategies. 

Conclusion: Effects to lagoon from proposed management actions under both Alternatives A and B 

are negligible. 

6.3.1.3 Effects to Perimeter Reef 

Effects from Habitat Management Strategies: Under Alternative A, the Service would continue to 

monitor the abundance and distribution of the cyanobacterial community. This monitoring would 

also occur under Alternative B and similar to the lagoon, various monitoring and survey work is 

proposed to ensure the continued health and functionality of the reef. Examples of proposed items to 

be monitored include the reef’s growth, elevation, and holes available to sea urchins; the benthic 

succession as cyanobacteria recede; survey and removal of marine debris; and density and biomass of 

focal species such as fish, corals, tuitui, and so on. Monitoring the shallow perimeter reef requires 

reef-walking, which has the capacity for damaging soft-bodied animals (e.g., sea cucumbers) or 

Management boats used. USFWS. 
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breaking the branches of calcified organisms such as corals and the coralline red alga Jania. 

However, selection of careful footing on hard, even substrate such as CCA, barren substrate, or 

substrate covered with turf algae, serves to protect the safety of the reef-walker as well as the habitat 

and its living biota. Stakes that may be installed to mark transects or quadrat locations to return to on 

future monitoring surveys would be stainless steel or other durable material (e.g., PVC), which have 

been shown in previous work at the Refuge and other atolls to have no impact on the marine 

environment. Nylon, plastic, or fiberglass transect lines and lightweight quadrats composed of PVC 

pipe, which are briefly placed to delineate a sample area, are widely used in coral reef survey work 

throughout the Pacific and have no impact on the substrate or biota. If samples of living biota or 

abiotic substrate are required for identification or other analytic work, the minimum number of 

samples necessary for statistical purposes is collected, and the location of samples is spatially 

dispersed so as to minimize the effect on substrate cover, integrity of the biological community, and 

reproduction/recruitment processes. Based on similar monitoring already conducted at the Refuge 

and other atolls, it is anticipated that these activities would have minor effects as they are minimal in 

scale. 

Additional habitat management proposed under Alternative B is the establishment of a systematic 

marine debris removal program. Derelict fishing gear, fish aggregation devices and other marine 

debris that snags on reefs can cause substantial damage by breaking corals through wind- and tidedriven water motion, smothering and crushing soft-bodied organisms, and potentially introducing 

alien marine biota that have grown on or become entrapped within the debris. Careful removal of 

debris involves application of techniques that do not cause further damage to the reef, e.g., cutting 

nets that are snagged around corals so the colonies are not broken or snapped off when the net is 

removed. Marine debris removal, when carefully conducted, would have a minor to intermediate 

benefit, depending on the quantity and type of debris involved. 

Effects from Research Management Strategies: Same as above in habitat management. 

Conclusion: Under Alternative A, the proposed monitoring program would have negligible effects to 

the perimeter reef. Long-term beneficial minor to intermediate effects are expected from the 

proposed management actions under Alternative B such as the systematic marine debris removal 

program. 

6.3.1.4 Effects to Beach Strand 

Effects from Habitat Management Strategies: See 6.2.1 effects to soils concerning monitoring 

activities. Under both Alternatives A and B, restoring native coastal plants is proposed. This action 

would improve the beach strand habitat by restoring former vegetation which may have been lost or 

impeded by the presence of rats. Such native coastal plants would also provide habitat for seabirds 

(e.g., sooty terns and noddies). Additionally, surveying for marine debris (and removing anything 

found) would help to keep this habitat from becoming degraded. Therefore, effects to beach strand 

are anticipated to be beneficial and minor. 

Effects from Research Management Strategies: Same as above in habitat management. 

Effects from Cultural Resources and EE Management Strategies: See 6.2.1 effects to soils. 

Conclusion: Effects to beach strand from proposed management actions are beneficial and minor 

under both alternatives. 
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6.3.1.5 Effects to Littoral Forest 

Effects from Habitat Management Strategies: Proposed actions under Alternative B that may 

affect this habitat include increased monitoring of wildlife populations, effectiveness of restoration 

efforts, climate change effects, effectiveness of pest species eradication and control, outplanting, and 

the installation of remote surveillance and monitoring equipment. The necessity to camp on the 

island in order to do many of the surveys that occur at night or at dawn and dusk or during particular 

parts of the tidal cycle on the reef flat would affect the littoral forest habitat as well by possibly 

disturbing or trampling vegetation. 

Outplantings as part of restoration includes such activities as collection of seeds or immature 

seedlings and replanting them in identified area. Monitoring of such restoration efforts includes 

growth and survivorship and could include actions such as installing permanent grid or transect 

markers. Control of niu populations by mechanical control may result in damage to adjacent trees or 

loss of branches as coconut trees or nuts are removed. Removal of any undesirable plant species may 

temporarily affect habitat values by removing cover that could be used by nesting birds. Eradication 

of introduced scale insects or other insect herbivores or a new infestation of rodents would 

temporarily increase physical disturbance from injections of systemic pesticides or the use of traps or 

bait stations but all of these actions would be beneficial to restore the extent and composition of the 

littoral forest habitat to a state prior to disturbance. Effects are anticipated to be intermediate and 

beneficial and short- to long-term. 

Effects from Research Management Strategies: Same as above in habitat management. 

Effects from Cultural Resources and EE Management Strategies: Archaeological surveys as well 

as visits by cultural practitioners may occur under Alternative B. The trampling of littoral forest 

vegetation by those conducting such activities could be experienced. However, given that Refugeauthorized personnel would accompany archaeologists and cultural practitioners to educate on 

avoiding such impacts, it is anticipated that effects to this habitat would be negligible. 

Conclusion: Effects to littoral forest would be beneficial, short- to long-term, and negligible and 

intermediate. 

6.3.2. Effects to Wildlife

6.3.2.1 Effects to Federally Listed Species 

Listed species receive special consideration in terms of Refuge management. Federally listed species 

are trust resources that require additional consultation whenever an activity conducted by or 

permitted by the Refuge may have an effect on these species or their habitats. Impacts associated 

with the use of herbicides and pesticides are assessed in the IPM program (Appendix G). 

Effects to Threatened Green Turtle and Endangered Hawksbill Turtle 

Effects from Habitat Management Strategies: Under Alternative B, new management related to 

working with NOAA to develop and implement monitoring protocol to track turtle abundance and 

movements is proposed. Additionally, instituting rapid response to eradicate pest species once 

detected would secondarily benefit these species by removing threats that could affect them (e.g., rats 

eating eggs or newly hatched turtles; pest plants degrading beach strand habitat by removing 
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6-12 Chapter 6. Summary of Effects 

available areas for nesting or hampering movement of turtles on the beach and hatchlings making 

their way to the lagoon). Removing marine debris, which can be potentially hazardous to adults and 

hatchlings, is also proposed. These actions are beneficial for turtles and are anticipated to have minor 

effects. Alternative B also calls for additional management visits to the atoll. The artificial lights 

associated with camping on shore and vessels may cause disorientation to hatchling turtles as they 

emerge from the nest. Control and minimization of artificial light around the atoll at night would 

alleviate that concern. Section 7 consultation would be done with NOAA with respect to the 

monitoring management action if required. 

Effects from Research Management Strategies: See habitat management above. 

Effects from Cultural Resources Management Strategies: Archaeological surveys as well as visits 

by cultural practitioners may occur under Alternative B. The trampling of beach strand habitat and 

nest disturbance by soil compacting or excavation by those conducting such activities is possible. 

However, given that Refuge-authorized personnel would accompany archaeologists and cultural 

practitioners to educate on avoiding such impacts, it is anticipated that effects would be negligible. 

Conclusion: Effects to threatened green turtle and endangered Hawksbill turtle from proposed 

management actions are beneficial, long-term, and minor. 

6.3.2.2 Effects to Seabirds 

Effects from Habitat Management Strategies: Under Alternative B, proposed management actions 

that may affect seabirds include increased activity in the colony while monitoring, installation of 

remote sensing, and rapid response to eradicate pest species. Secondary effects may occur from 

proposed habitat restoration of the native vegetation on the beach strand and in the littoral forest and 

surveying for marine debris. By providing managers with better data for management, enhancing 

existing habitat used by these species, and addressing potential threats, proposed management actions 

are beneficial and minor for these species as these activities would support their life-history needs. 

Negative effects could result from handling the birds for tagging, disturbing nest sites to check for 

chicks, and accidental damage to or exposure of nest sites during mechanical control of pest species. 

These actions could result in elevated stress levels or abandonment of nests. However, given the very 

temporary nature of these disturbances and the level of experience of staff who have previously 

conducted such activities, it is anticipated that these effects would be negligible. 

Additional foot traffic in the beach strand habitat would increase the probability of accidental 

crushing the very cryptic eggs and chicks of brown noddies (gogo) and sooty terns (gogo uli). 

Training of field personnel to recognize and avoid nest areas would reduce this risk. 

The necessity to camp on shore during management and monitoring work may also cause nest 

abandonment by boobies and ground-nesting terns if the temporary camp site and activity center is 

located too close those nests. Artificial light from camp activities may startle tree-nesting boobies 

and terns and cause them to panic and lose eggs or small chicks from nests. Careful minimization and 

control of artificial lights in camp and during nocturnal work would reduce this impact. 

Increased frequency or duration of vessels standing offshore of Rose Atoll would result in greater 

incidence of bird collisions with the lighted vessel at night. Especially on rainy nights deck lights can 

cause birds to become disoriented and crash into the boat causing injury, plumage soiling, or death. 
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Chapter 6. Summary of Effects 6-13 

This problem can be minimized by requiring the vessel to steam away from the atoll at night and 

restricting lighting on board to the minimum running lights required by law. 

Effects from Research Management Strategies: See habitat management above. 

Effects from Cultural Resources Management and EE Strategies: Archaeological surveys as well 

as visits by cultural practitioners and EE groups may occur under Alternative B. The trampling of 

beach strand and littoral forest habitats and nest disturbance by those conducting such activities could 

be experienced. Similarly, as mentioned under habitat management, increased frequency or duration 

of lighted vessels standing offshore at night could increase bird collisions. However, given that 

Refuge-authorized personnel would accompany archaeologists and cultural practitioners to educate 

on avoiding such impacts, it is anticipated that effects would be negligible. Night activities should be 

minimized to reduce artificial light impacts and accidental trampling of nests of seabirds. 

Conclusion: Effects to seabirds from proposed management actions are beneficial, negligible to 

minor, and long-term. 

6.3.2.3 Effects to Shore, Wading, and Land Birds 

See effects to seabirds 6.3.2.2 above. Response to an incursion of rodents using rodenticide, live 

traps, or kill traps may affect migratory shorebirds and landbirds by accidental poisoning if they 

ingest bait pellets, and injury or death in live traps and kill traps designed for rodents. Mitigation for 

these effects would include the use of tamper-proof bait stations for rodenticide and for kill traps and 

careful monitoring of any live-traps deployed. 

Conclusion: Same as 6.3.2.2. 

6.3.2.4 Effects to Native Invertebrates

Effects from Habitat Management Strategies: Primary species analyzed are for effects include 

tuitui, marine gastropods, Turbo spp., Coenobita perlatus and C. brevimanus, and faisua. Under 

Alternative B, new proposed management includes direct monitoring of species and habitat 

monitoring (e.g., climate change variables, nutrient budget, benthic succession, pest species, etc.). 

Monitoring activities are typically on the low end of impacts activities as they can usually be 

conducted without disturbance to species. Typical monitoring of such species could include 

measuring taxonomic diversity, association with substrate type, spatial distribution, abundance, 

density, and biomass. Monitoring of these species is a long-term action and beneficial because it 

would provide managers with data to enhance management as well as address any potential threats. 

The installation of remote sensing may, depending on the type of system chosen, also include buoys 

or hydrophones. However, it is anticipated that effects from proposed actions would be beneficial, 

negligible to minor, and long-term because comparable monitoring activities are undertaken at atolls 

throughout the world without disturbance to the environment while providing critical information on 

status and trends of populations. 

Eradication of species such as the scale insect or ants could include additional injections of 

insecticide imidacloprid Imicide ® into the tree or deploying insecticide bait. Use of insecticides 

comes at the risk of exposure to native arthropods that may also be sensitive to them. These risks can 

be minimized by employing IPM and careful application. 
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Effects from Research Management Strategies: See habitat management above. 

Conclusion: Effects to native invertebrates from proposed management actions are beneficial, 

negligible to minor, and long-term. 

6.3.2.5 Effects to Coral

Effects from Habitat Management Strategies: See 6.3.2.4 related to monitoring. Increased 

monitoring of all species and habitats in the lagoon, on the reef flat, or in the ava would increase the 

chances of physical damage to coral by small boats transporting staff, snorkelers, or divers using 

SCUBA. All participants in these activities would be trained and evaluated by the Refuge/Monument 

Manager to ensure their skills in boat driving and working in the water would enable them to avoid 

physical contact with live coral. 

Effects from Research Management Strategies: See 6.3.2.4 and above. 

Conclusion: Same as 6.3.2.4. 

6.3.2.6 Effects to Coralline Algae

Effects from Habitat Management Strategies: See 6.3.2.4 related to monitoring. 

Effects from Research Management Strategies: See habitat management above. 

Conclusion: Anticipated effects from proposed management actions are beneficial, negligible to 

minor, and long-term. 

6.3.2.7 Effects to Fish 

Effects from Habitat Management Strategies: See 6.3.2.4 related to monitoring. Sharks are 

cartilaginous fishes whose abundance and biomass, as apex predators, are frequently cited as an 

indicator of the health status of a coral reef ecosystem (Friedlander and DeMartini 2002, DeMartini 

et al. 2008, Sandin et al. 2008). The greatest difference between populated areas and largely intact 

reef systems at extremely remote locations tends to be in the abundance and size of large predatory 

fishes such as sharks and jacks. Those groups often comprise a large portion of total fish biomass 

estimated from visual surveys at remote coral reefs, but are infrequently encountered and constitute a 

small portion of biomass on reefs close to even fairly small human populations (Williams et al. 2011, 

Nadon et al. 2012). Under Alternative B, predators such as sharks and prey fish species would be 

visually surveyed around the opening of the ava. Surveys for sharks and other large fish predators 

have been conducted by the NOAA CRED using SCUBA and small boats along the outer reef and in 

the lagoon since 2002 without adverse effect. Consequently, the effects of surveys conducted at the 

mouth of the ava are anticipated to be negligible but would contribute to knowledge of predator and 

prey fish populations at the Refuge. 

Effects from Research Management Strategies: Same as above in habitat management. 

Conclusion: Effects to fish from proposed management actions are anticipated to be negligible. 
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6.3.2.8 Effects to Pest Species 

Effects from Habitat Management Strategies: Proposed habitat management strategies for all 

alternatives have components of either controlling or eradicating pest species (both flora and fauna). 

Control of these pests is critical for recovery of listed species and continuation of other native species 

at the Refuge. Under Alternative B, new proposed management with regard to pest species includes 

addressing existing pests such as the cyanobacteria (through iron removal) and introduced scale 

insects, and using a rapid response system to eradicate any new pests discovered (e.g., plants, rats, 

etc.). Eradication can involve any number of tools from hand-pulling plants, to traps, to chemicals 

such as herbicides or rodenticides. The increased level of effort under Alternative B is more 

beneficial than A. Given that the non-native species were introduced to the Refuge, opportunistic 

species such as cyanobacteria were not dominant at the Refuge, these species exist outside the 

Refuge, and an IPM is in place (see previous section 6.1 effects common to all) control or eradication 

of these species is anticipated to be negligible. 

Effects from Research Management Strategies: Visits by researchers and related personnel would 

occur under Alternative B. With increased visitation to the Refuge for these uses, there is potential 

for pest species to be transported to the Refuge on the boat or on the persons themselves and the 

equipment/tools brought with them. However, given the existing biosecurity protocols in place, 

stipulations in the SUP, and the fact that people would be accompanied by a Refuge-authorized 

agent, it is anticipated that this impact would be negligible. 

Effects from Cultural Resources and EE Management Strategies: Same as research management 

strategies. 

Conclusion: Effects to pest species from proposed management actions are negligible. 

6.4 Effects to Cultural and Historic Resources 

The NHPA, as amended, establishes the Federal government’s policy on historic preservation and the 

programs through which that policy is implemented. An impact to cultural resources would be 

considered significant if it adversely affects a resource listed in or eligible for listing in the National 

Register of Historic Places. In general, an adverse effect may occur if a cultural resource would be 

physically damaged or altered, isolated from the context considered significant, or affected by project 

elements that would be out of character with the significant property or its setting. Title 36 CFR Part 

800 defines effects and adverse effects on historic resources. 

At the time of writing this draft CCP/EA, results from an archaeological survey that was conducted 

in February of 2012 were not complete. However some preliminary information received indicates 

some sites could be eligible for listing on the National Register of Historic Places. Once the Refuge 

receives the final report and it confirms eligibility status on identified sites, we would undertake 

Section 106 for any management actions which may affect these resources. 

Currently, no resources are eligible or listed on the National Register of Historic Places at the time of 

writing, some historical and cultural resources have been identified, and Refuge staff would conduct 

management activities in a way that appropriate procedures and protocols would be followed to 

protect the cultural resources. Wherever possible, cultural resources would be avoided or minimized. 

Minimization options, in addition to site avoidance by relocating activities, would include data 

recovery, using either collection techniques or in-situ site stabilization protection. 
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Allowing cultural practitioners to access the Refuge for traditional uses would also be beneficial as it 

would support and perpetuate fa’a Samoa. 

Conclusion: Effects to cultural and historic resources from proposed management actions are 

negligible. 

6.5 Effects to Social Resources 

Unless otherwise stated, continuing the current management (Alternative A) generally has negligible 

effects because little or no change to current conditions is proposed. The effects for Alternative B are 

described in terms of the change from current conditions and given the increased management level 

is more beneficial than Alternative A. 

6.5.1 Opportunities for Quality Environmental Education and Interpretation 

and Outreach 

Since EE is not currently offered at the Refuge, there are no user numbers to assess for possible 

change. Similarly, other than a Website, there is no active interpretation occurring of the Refuge. 

Effects from Outreach, Interpretation, and EE Management Strategies: Under Alternative B, 

strategies for increasing off-site opportunities are proposed. They include developing brochures, 

displays, social media, outreach messages, interpretive videos, developing a Refuge Friends group, 

volunteer, and student intern program, participating in community meetings and local events, 

creating EE materials, partnering with schools on research, and developing EE curriculum and 

related classroom materials. All of these actions would be beneficial and intermediate. 

Conclusion: Effects to quality EE and interpretation and outreach from proposed management 

actions are beneficial, long-term, and intermediate. 

6.5.2 Extent of Illegal Use 

Under Alternative B, new management actions to deter illegal uses have been proposed. They 

include re-installation of Refuge signage, development of informational materials such as brochures 

to targeted audiences such as the yachting community, increased collaboration with the USCG and 

NOAA enforcement, working with the Manu’a community to increase awareness of illegal activities, 

installation of remote sensing (e.g., cameras), designating the Refuge as an area to be avoided by the 

maritime community, and vessel acquisition or contract. Effects under Alternative B are anticipated 

to be beneficial, long-term, and intermediate. 

Conclusion: Effects to illegal use from proposed management actions are beneficial, long-term, and 

intermediate. 

6.5.3 Environmental Justice 

The EPA oversees environmental justice compliance and defines environmental justice as: “the fair 

treatment and meaningful involvement of all people regardless of race, color, national origin, or 

income with respect to the development, implementation, and enforcement of environmental laws, 

regulations, and policies.” Further, EPA defines a community with potential environmental justice 
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Chapter 6. Summary of Effects 6-17 

populations as one that has a greater percentage of minority or low-income populations than does an 

identified reference community (identified reference community is the Manu’a Islands). Minority 

populations are those populations having 1) 50 percent minority population in the affected area 

(USEPA 1998a); or 2) a significantly greater minority population than the reference area. There are 

no specific thresholds provided for low-income or poverty populations. 

There is no population at the Refuge or directly adjacent to it. The closest populated community, at 

almost 80 miles away, is located in the Manu’a Islands. Development of this CCP was done with 

public input from these islands, which involved local chiefs, residents, teachers, and others from the 

community (see Appendix J for further details). None of the proposed strategies would negatively 

affect environmental justice because activities would provide “fair treatment and meaningful 

involvement of all people regardless of race, color, national origin, or income with respect to the 

development, implementation, and enforcement of environmental laws, regulations, and policies.” 

Therefore, it is anticipated that proposed actions under Alternative B would have negligible 

environmental justice effects. 

Conclusion: Effects to environmental justice from proposed management actions under both 

alternatives is negligible. 

6.6 Effects to Economic Resources 

This economic analysis provides a means of estimating how current management and proposed 

management activities affect the local economy. This type of analysis provides two critical pieces of 

information: 1) it illustrates the Refuge’s contribution to the local community; and 2) it can help in 

determining whether economic effects are a real concern in choosing among management 

alternatives. 

For the purposes of this analysis, a region (and its economy) is defined as American Samoa given 

that Refuge spending occurs mainly in Tutuila where Refuge staff reside and work and that the 

purchase of most expenditures occurs there. 

The analysis for this section is divided into 1) economic resources specific to management strategies 

and 2) additional economic impacts specific to Refuge employment and personnel salary spending, 

and Refuge purchase of goods and services within the local economy. 

Unless otherwise stated, continuing the current management (Alternative A) generally has negligible, 

if any, effects because little or no change to current conditions is proposed. The effects for 

Alternative B are described in terms of the change from current conditions and given the increased 

management level is more beneficial than Alternative A. 

6.6.1 Management Strategies 

Effects from Habitat and Research Management Strategies: Under Alternative B, increased 

habitat management and new research and monitoring strategies are proposed to enhance Refuge 

management and decision-making. Some of this research is conducted collaboratively with other 

agencies or educational institutions. These partners and collaborators could purchase supplies, 

transport, or temporary help locally. Examples of large purchases include (in 1 year) $60,000 for boat 

charters and $6,000 for food and other supplies. 
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Effects from Cultural Resources Management Strategies: Under Alternative B, those engaging in 

cultural practices are required to secure their own transport to the Refuge. This could result in some 

revenue for boating operations. 

6.6.2 Additional Economic Impacts 

6.6.2.1 Impacts from Refuge Administration 

Staff – Personal Spending 

Employees of the Refuge reside and spend their salaries on daily living expenses in the local area, 

thereby generating impacts within the local economy. 

Table 6-2. Annual Salaries (including locality pay and COLA and benefits) for Refuge 

Employees by Alternative 

Staff Alt A Alt B 

Refuge/Monument Manager (GS-12) – Permanent $117,392 $117,392 

*Superintendent/Project Leader (GS-14) - Permanent $16,309 $16,309 

*Wildlife Biologist (GS-12) - Permanent $12,594 $12,594 

*Administrative Officer (GS-9) - Permanent $8,859 $8,859 

Wildlife Biologist (GS-11) - Permanent $84,411 

Biological Technician (GS-7) - Permanent $57,404 

Admin officer (GS-5/7) $57,404 

Park Ranger (GS-5/7) – Half time $28,702 

Total: $155,154 $383,075 

* Staff at the Honolulu Complex Headquarters also support Rose Atoll NWR (expenditure reflects the percentage of time spent 

supporting the Refuge, but does not translate into local expenditures). 

Salary spending by Rose NWR personnel could generate secondary impacts by providing jobs in 

other industries where monies are spent (e.g., boat rental). Personal spending could include rent, 

utilities, food, entertainment, food services, gas, etc. If spending were large enough, jobs in these 

related sectors could be produced through revenue generated. Under Alternative A with only one 

employee, spending would likely not be enough to generate additional jobs in the economy. 

However, under Alternative B, a total of three employees would be needed to support Refuge 

management. When comparing this total salary expenditure against the average labor income by 

industries in Chapter 5, salary expenditure could result in new job creation. 

Work-related Purchases 

A wide variety of supplies and services are purchased for Refuge operations and maintenance 

activities. Refuge purchases made in American Samoa contribute to the local economic impacts 

associated with the Refuge. The Refuge incurs both annual (recurring) operational costs and one-time 

expenditures. 

Over the 15-year span of the CCP, to implement Alternative A, management actions would require 

$916,000 (not including staffing). For Alternative B, it would be either $11,319,125; $11,044,125; or 
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Chapter 6. Summary of Effects 6-19 

$10,829,125 (not including staffing) depending on the vessel option chosen. How much of these 

expenditures would be spent in American Samoa would vary depending on the activity so the exact 

effects on the local economy cannot be ascertained. However, it is likely that some of these 

expenditures would be spent in American Samoa (please refer to Appendix D, Tables D-1 and D-2 

for a detailed list of expected annual operating costs and one-time expenditures for the Refuge and 

each alternative). 

Conclusion: Effects to economic resources from proposed management actions are beneficial and 

long-term. However, given the size of the Refuge budget relative to other industries and economic 

inputs into the local economy on American Samoa, effects to economic resources is likely negligible. 

6.7 Other Effects 

Unless otherwise stated, continuing the current management (Alternative A) generally has negligible, 

if any, effects because little or no change to current conditions is proposed. The effects for 

Alternative B are described in terms of the change from current conditions and given the increased 

management level is more beneficial than Alternative A. 

6.7.1 Potential Impacts on Adjacent Lands and their Associated Natural 

Resources 

There are no adjacent lands, but there are adjacent waters and associated natural resources. It is not 

anticipated that there would be effects to adjacent waters and their associated natural resources given 

that both areas are protected areas. 

Conclusion: Effects to adjacent waters from proposed management actions is negligible. 

6.7.2 Potential Impacts to Nearby Residents 

The nearest populated area is Ta’ū Island, almost 80 miles away. In addition to effects already 

discussed previously (e.g., habitat management, cultural resources management, outreach, 

interpretation, and EE), potential effects, under Alternative B would be beneficial as there are several 

strategies to directly engage the Manu’a communities with EE, outreach, interpretation, cultural 

practices, and law enforcement that would strengthen their connection to Rose Atoll and shared 

stewardship of the ecological, geologic, and cultural richness of the Refuge. Effects are anticipated to 

be minor. 

Conclusion: Effects to nearby residents from proposed management actions is beneficial, minor, and 

long-term. 

6.8 Cumulative Effects 

Cumulative effects can result from the incremental effects of a project when added to other past, 

present, and reasonably foreseeable future projects in the area. Cumulative impacts can result from 

individually minor but cumulatively significant actions over a period of time. This analysis is 

intended to consider the interaction of activities at the Refuge and with other actions occurring over a 

larger spatial and temporal frame of reference. 
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The Council on Environmental Quality (CEQ) regulations for implementing the provisions of NEPA 

defines several different types of effects that should be evaluated in an EA including direct, indirect, 

and cumulative. Direct and indirect effects are addressed in the resource-specific sections of this 

Draft CCP/EA. This section addresses cumulative effects. 

The CEQ (40 CFR § 1508.7) provides the following definition of cumulative effects: 

“The impact on the environment which results from the incremental impact of the action 

when added to other past, present, and reasonably foreseeable future actions regardless of 

what agency (Federal or non-Federal) or person undertakes such other actions.” 

It should be noted that the cumulative effects analysis has essentially been completed by virtue of the 

comprehensive nature by which direct and indirect effects associated with implementing the various 

alternatives was presented. The analysis in this section primarily focuses on effects associated with 

reasonably foreseeable future events and/or actions regardless of what entity undertakes that action. 

6.8.1 Protected Areas 

At press time of this CCP, Fagatele Bay National Marine Sanctuary (Sanctuary) was considering 

adding the Monument waters outside of the Refuge to the Sanctuary. Additionally, NMFS is also 

reviewing proposed Monument fishing regulations that include establishing a 12-nmi no-take area 

around Rose Atoll NWR and would establish regulations to permit sustenance and traditional 

indigenous fishing in the 12-50 nmi zone of the Monument. 

Both processes are still not completed so it is difficult to assess with certainty what cumulative effect 

these actions may have. However, should the fishing regulations and addition to the Sanctuary move 

forward, though the addition of the 12-nmi no-take zone adjacent to the Refuge would be beneficial, 

it is likely cumulative effects would be negligible given the projected low harvest associated with 

sustenance and traditional indigenous fishing for pelagic species in the Monument. Increases in 

capacity for management by any of the resource protection agencies in the area would result in more 

opportunities for synergy and shared costs. 

6.8.2 Climate Change 

The background and biotic and abiotic effects of climate change are discussed in Chapter 3 section 

3.1.2 including atmospheric events and precipitation, rising temperatures, SLR, ocean acidification, 

and expected ecological responses. 

Though nothing the Refuge proposes would have an impact on climate change, the data collected 

through proposed strategies of monitoring for climate change variables may inform about the impacts 

of climate change on atoll resources and provide for larger scale climate change analysis as well as 

provide information that may help managers develop mitigation or adaptation strategies for 

protection of Refuge species from some of the anticipated effects of climate change. Alternative B 

would also help restore ecosystem and species resilience to climate change by reducing or 

eliminating other stressors (e.g., pest species). 

Conclusion: Cumulative effects are negligible. 

 
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Appendix A. Species List A-1

Appendix A. Rose Atoll NWR Species Lists 

A.1 Lists of Observed Species 

Table A-1. Stony Coral List for Rose Atoll 

Species* IUCN Status** 

Acanthastrea brevis VU 

Acanthastrea echinata LC 

Acropora aspera VU 

Acropora cerealis LC 

Acropora digitifera NT 

Acropora exquisita DD 

Acropora gemmifera LC 

Acropora globiceps VU 

Acropora granulosa NT 

Acropora humilis NT 

Acropora kirstyae VU 

Acropora latistella LC 

Acropora longicyathus LC 

Acropora loripes NT 

Acropora nana NT 

Acropora nasuta NT 

Acropora paniculata VU 

Acropora retusa VU 

Acropora samoensis LC 

Acropora selago NT 

Acropora sp. not listed 

Acropora squarrosa LC 

Acropora tenuis NT 

Acropora valida LC 

Alveopora verrilliana VU 

Astreopora cucullata VU 

Astreopora listeri LC 

Astreopora myriophthalma LC 

Astreopora ocellata LC 

Barabattoia laddi VU 

Coeloseris mayeri LC 

Coscinaraea columna LC 

Coscinaraea exesa LC 

Cycloseris fragilis LC 

Cyphastrea chalcidicum LC 

Cyphastrea decadia LC 

Cyphastrea microphthalma LC 

Cyphastrea serailia LC 

Echinophyllia aspera LC 

Echinopora lamellosa LC 

Favia favus LC 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment

A-2 Appendix A. Species List 

Species* IUCN Status** 

Favia matthaii NT 

Favia maxima NT 

Favia pallida LC 

Favia rotumana LC 

Favia speciosa LC 

Favia stelligera NT 

Favites flexuosa NT 

Favites halicora NT 

Favites russelli NT 

Favites sp. not listed 

Fungia concinna LC 

Fungia granulosa LC 

Fungia repanda LC 

Fungia scutaria LC 

Galaxea fascicularis NT 

Goniastrea pectinata LC 

Goniastrea retiformis LC 

Goniopora somaliensis LC 

Herpolitha limax LC 

Hydnophora exesa NT 

Isopora brueggemanni VU 

Isopora palifera NT 

Leptastrea bewickensis NT 

Leptastrea pruinosa LC 

Leptastrea purpurea LC 

Leptastrea sp. [small round calices] not listed 

Leptoseris foliosa LC 

Leptoseris incrustans VU 

Leptoseris mycetoseroides LC 

Leptoseris scabra LC 

Leptoseris sp. [small round calices] not listed 

Leptoseris yabei VU 

Lobophyllia corymbosa LC 

Lobophyllia hemprichii LC 

Merulina ampliata LC 

Millepora platyphylla*** LC 

Montastrea annuligera NT 

Montastrea curta LC 

Montipora aequituberculata LC 

Montipora angulata VU 

Montipora calcarea VU 

Montipora caliculata VU 

Montipora danae LC 

Montipora efflorescens NT 

Montipora foliosa NT 

Montipora foveolata NT 

Montipora hoffmeisteri LC 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix A. Species List A-3

Species* IUCN Status** 

Montipora incrassata NT 

Montipora informis LC 

Montipora lobulata VU 

Montipora nodosa NT 

Montipora peltiformis NT 

Montipora sp. [bright blue] not listed 

Montipora spumosa LC 

Montipora tuberculosa LC 

Montipora undata NT 

Montipora venosa NT 

Montipora verrucosa LC 

Oulophyllia crispa NT 

Oxypora glabra LC 

Pavona chriquiensis LC 

Pavona clavus LC 

Pavona decussata VU 

Pavona explanulata LC 

Pavona maldivensis LC 

Pavona minuta NT 

Pavona varians LC 

Pavona venosa VU 

Platygyra carnosus NT 

Platygyra contorta LC 

Platygyra daedalea LC 

Platygyra lamellina NT 

Platygyra pini LC 

Platygyra ryukyuensis NT 

Plesiastrea versipora LC 

Pocillopora brevicornis not listed 

Pocillopora damicornis LC 

Pocillopora eydouxi NT 

Pocillopora meandrina LC 

Pocillopora molokensis DD 

Pocillopora verrucosa LC 

Porites australiensis LC 

Porites lichen LC 

Porites lobata NT 

Porites lutea LC 

Porites rus LC 

Porites solida LC 

Porites superfusa not listed 

Porites vaughani LC 

Psammocora contigua NT 

Psammocora haimeana LC 

Psammocora nierstraszi LC 

Psammocora profundacella LC 

Scapophyllia cylindrica LC 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment

A-4 Appendix A. Species List 

Species* IUCN Status** 

Stylaster cf. elegans*** not listed 

Stylocoeniella armata LC 

Stylocoeniella guentheri LC 

Stylophora pistillata NT 

Symphyllia agaricia LC 

Symphyllia recta LC 

Turbinaria frondens LC 

Turbinaria mesenterina VU 

Turbinaria reniformis VU 

Turbinaria stellulata VU 

* The 19 species in bold were petitioned by the Center for Biological Diversity for listing under the U.S. 

Endangered Species Act and are presently being evaluated by NOAA. 

** DD = Data Deficient, LC = Least Concern, NT = Near Threatened, and VU = Vulnerable. 

***Hydrozoan coral. 

Sources: Kenyon et al. (2010, 2011), IUCN (2008), Maragos unpubl. data. 

Table A-2. Fish List for Rose Atoll (281 species) 

Scientific Name* Common Names Samoan Names Wass Habitats** 

Abudefduf spp. Sergeant major 

Acanthurus achilles Achilles tang CB, P 

Acanthurus albipectoralis Whitefin surgeonfish 

Acanthurus blochii Ringtail surgeonfish 

Acanthurus glaucoparieus 

(or A.nigricauda?) CB 

Acanthurus guttatus Whitespotted surgeonfish 

Acanthurus lineatus Striped surgeonfish 

Acanthurus mata CB, P 

Acanthurus nigricans Whitecheek surgeonfish pone-i’usina 

Acanthurus nigricauda Blackstreak surgeonfish pone-i’usina 

Acanthurus nigrofuscus Brown surgeonfish ponepone CB 

Acanthurus nigroris CB, RF, P 

Acanthurus olivaceus Orangeband surgeonfish pone-apasama, 

afinamea RF 

Acanthurus pyroferus Mimic surgeonfish pone-i’usama LF, P 

Acanthurus thompsoni P 

Acanthurus triostegus Convict tang manini CB, RF 

Acanthurus xanthopterus Yellowfin surgeonfish 

Adioryx microstomus CB 

Adioryx spinifer CB, P 

Adioryx tiere Lagoon 

Aluterus scriptus Scrawled filefish 

Amphiprion chrysopterus Reef front 

Anampses twistii Yellowbreasted wrasse sugale-tatanu 

Anthias lori Reef front 

Anthias pascalus Reef front 

Aphareus furca Smalltooth jobfish palu-aloalo 

Aphareus furcatus P 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix A. Species List A-5

Scientific Name* Common Names Samoan Names Wass Habitats** 

Apogon apogonides Goldbelly cardinalfish 

Aprion virescens Green jobfish asoama, utu LF, P 

Arothron meleagris Guineafowl pufferfish sue-puleuli (dark), suelega (yellow) 

Balistapus undulatus Orange-lined triggerfish sumu-aimaunu CB, LF, P 

Balistoides viridescens Reef front 

Belonidae RF 

Belonoperca chabanaudi Reef front 

Bodianus anthioides Reef front 

Bodianus axillaris 

Bodianus diana 

Bodianus loxozonus Blackfin hogfish 

Bolbometopon muricatum Bumphead parrotfish 

Caesio teres Yellow and bluebackfusilier 

Calotomus carolinus Carolines parrotfish 

Calotomus zonarchus Yellowbar parrot 

Cantherhines dumerili Barred filefish pa’umalō

Canthidermis dumerili Yelloweye filefish Reef front 

Canthigaster solandri Spotted toby sue-mimi CB 

Canthigaster valentini Black-saddled toby sue-mu 

Caracanthus maculatus Spotted croucher 

Carangoides ferdau Blue trevally (Barred 

trevally) 

Carangoides 

orthogrammus 

Yellow-spotted trevally 

(Island jack) 

Caranx ignoblis Giant trevally 

Caranx lugubris Black trevally P 

Caranx melampygus Bluefin trevally malauli-matalapo’a RF 

Caranx sexfasciatus Bigeye trevally 

Carcharhinus 

amblyrhynchos Gray reef shark RF 

Carcharhinus 

melanopterus Blacktip reef shark apeape, maliealamata RF 

Triaenodon obesus Whitetip reef shark RF, P 

Centropyge bispinosus Two-spined angelfish 

(Dusky angelfish) tu’u’u-alomu CB 

Centropyge flavissimus Lemonpeel angelfish tu’u’u-sama, tu’u’ulega CB, P 

Centropyge heraldi CB 

Centropyge loriculus Flame angelfish tu’u’u-tusiuli 

Centropyge multifasciata Barred angelfish 

Cephalopholis argus Peacock grouper gatala-uli CB, LF, P 

Cephalopholis guttatus Reef front 

Cephalopholis leopardus Leopard grouper 

Cephalopholis miniata 

Cephalopholis n. sp. Reef front 

Cephalopholis spiloparaea Strawberry grouper 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment

A-6 Appendix A. Species List 

Scientific Name* Common Names Samoan Names Wass Habitats** 

Cephalopholis urodelus CB, LF, P 

Cephalopholis urodeta Flagtail grouper mata’ele 

Chaetodon auriga Threadfin butterflyfish si’u, i’uusamasama CB, LF, P 

Chaetodon bennetti Reef front 

Chaetodon citrinellus Speckled butterflyfish tifitifi-moamanu CB, LF 

Chaetodon ephippium Saddled butterflyfish tifitifi-tauli CB, LF, P 

Chaetodon flavirostris Lagoon 

Chaetodon kleinii 

Chaetodon lineolatus Lined butterflyfish 

Chaetodon lunula Raccoon butterflyfish tifitifi-laumea CB, LF, P 

Chaetodon lunulatus Redfin butterflyfish tifitifi-manifi 

Chaetodon mertensii Oval butterflyfish 

Chaetodon ornatissimus Ornate butterflyfish 

Chaetodon pelewensis Dot & dash butterflyfish tifitifi-tusiloloa CB RF LF P 

Chaetodon 

quadrimaculatus Fourspot butterflyfish tifitifi-segasega CB, LF, P 

Chaetodon reticulatus Reticulated butterflyfish tifitifi-maono CB, P 

Chaetodon speculum 

Chaetodon trifascialis LF 

Chaetodon trifasciatus CB, LF 

Chaetodon ulietensis Pacific double-saddle 

butterflyfish tifitifi-gutu’uli CB 

Chaetodon unimaculatus LF 

Chaetodon vagabundus Vagabond butterflyfish tifitifi-matapua’a CB 

Chanos chanos Milkfish 

Cheilinus chlorourus LF 

Cheilinus oxycephalus LF 

Cheilinus rhodochrous CB, LF 

Cheilinus trilobatus LF 

Cheilinus undulatus Maori wrasse 

Cheilio inermis 

Cheliodipterus 

quinquelineatus Fivelined cardinalfish fō CB 

Chlorurus frontalis Tan-faced parrotfish 

(Reefcrest parrotfish) 

Chlorurus japanensis Japanese parrotfish fuga-si’umū (IP), laeaulusama (TP) 

Chlorurus microrhinos Steephead parrotfish laea (sm), ulumato 

(med), galo (lg) 

Chlorurus sordidus Bullethead parrotfish fuga-gutumū (IP), 

fugausi-tuavela (TP) 

Chromis acares Midget chromis tu’u’u-fō

Chromis agilis Reef chromis 

(Agile chromis) 

Chromis caerulea RF, LF, P 

Chromis iomelas Pacific half-&-half 

chromis tu’u’u-i’usina CB, P 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix A. Species List A-7

Scientific Name* Common Names Samoan Names Wass Habitats** 

Chromis margaritifer Bicolor chromis tu’u’u-I’usina P 

Chromis vanderbilti Vanderbilt’s chromis Tu’u’u-fō

Chromis viridis Blue-green chromis i’alanumoana, tu’u’usegasega 

Chromis xanthura Pale-tail chromis 

Chrysiptera biocellata Twospot demoiselle 

Chrysiptera brownriggii Surge damselfish 

Chrysiptera glauca Gray demoiselle 

Chrysiptera taupou South sea devil tu’u’u-mo’o, vaiulisama 

Cirrhilabrus punctatus Dotted wrasse 

Cirrhilabrus scottorum Redtailed wrasse 

(Scott’s wrasse) 

Cirrhilabrus sp. RF, LF 

Cirrhitus pinnulatus Stocky hawkfish 

Cirripectes polyzona Barred blenny mano’o 

Cirripectes stigmaticus Red-streaked blenny 

Cirripectes variolosus Red-speckled blenny mano’o CB 

Coris aygula Clown coris sugale-uluto’i RF 

Coris gaimard Yellowtail coris sugale-mūmū, sugaletala’ula RF 

Coryphopterus duospilus Twospot sand goby 

Ctenochaetus cyanocheilus Bluelipped bristletooth 

Ctenochaetus flavicauda Whitetail bristletooth 

Ctenochaetus striatus Striped bristletooth 

(Lined bristletooth) 

pone (adults), pala’ia, 

logoulia (schooling 

juv) 

CB, LF, P 

Ctenochaetus strigosus Spotted surgeonfish CB 

Ctenogobiops pomastictus Gold-speckled 

shrimpgoby 

Dascyllus aruanus Humbug dascyllus mamo RF, LF, P 

Dascyllus reticulatus Reticulated dascyllus RF 

Dascyllus trimaculatus Threespot dascyllus tu’u’u-pulelua 

Diodon hystrix Porcupinefish tauta, tautu CB, P 

Echeneis naucrates Sharksucker 

Ecsenius fourmanoiri Fourmanoir’s blenny 

Elagatis bipinnulata Rainbow runner 

Epibulus insdiator Slingjaw wrasse 

Epinephelus hexagonatus Honeycomb grouper 

Epinephelus merra Dwarf spotted grouper gatala-aloalo, gatalapulepule CB, RF, LF 

Epinephelus tauvina 

Eviota guttata Spotted pygmy goby 

Eviota punctulata Green bubblegoby 

Fistularia commersonii Cornetfish taoto-ama, taotao 

Flammeo opercularis Lagoon 

Flammeo sammara CB 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment

A-8 Appendix A. Species List 

Scientific Name* Common Names Samoan Names Wass Habitats** 

Forcipiger flavissimus Longnose butterflyfish 

(Forcepsfish) gutumanu CB, P 

Forcipiger longirostris Big longnose butterflyfish gutumanu 

Glyphidodontops cyaneus CB, RF, P 

Gnathodentex 

aureolineatus 

Yellowspot emperor 

(Striped large-eye bream) mumu, tolai CB, P 

Gnatholepis cauerensis Shoulderspot goby 

Gomphosus varius Bird wrasse gutusi’o, gutu’umi, 

sugale-lupe CB, LF, P 

Gracila albomarginata Masked grouper 

Gymnosarda unicolor Reef front 

Gymnothorax javanicus Giant moray 

Gymnothorax meleagris Turkey moray 

Gymnothorax pictus Peppered moray 

Halichoeres hortulanus Checkerboard wrasse sugale-a’au, sugalepagota, ifigi CB, RF 

Halichoeres 

melasmapomus Reef front 

Halichoeres ornatissimus Ornate wrasse 

Halichoeres trimaculatus Threespot wrasse lape, sugale-pagota RF, LF 

Hemigymnus fasciatus Barred thicklip sugale-gutumafia 

Hemitaurichthys polylepis Reef front 

Hemitaurichthys thompsoni 

Gray butterflyfish 

(Thompson’s 

butterflyfish) 

Heniochus chrysostomus Pennant bannerfish laulaufau-laumea 

Heniochus monoceros Masked bannerfish 

Heniochus varius 

Kyphosus sp. Chub nanue 

Labrichthys unilineatus 

Labroides bicolor Bicolor cleaner wrasse sugale-i’usina CB, P 

Labroides dimidatus Bluestreak cleaner wrasse sugale-mo’otai CB, LF, P 

Labroides praetextatus Knife razorfish 

Labroides rubrolabiatus Redlip cleaner wrasse CB, P 

Labropsis sp. Reef front 

Labropsis xanthonota 

Wedgetail wrasse 

(Yellowback tubelip 

wrasse) 

Lethrinus erythracanthus Yellowfin emperor 

Lethrinus rubrioperculatus RF, LF, P 

Lethrinus xanthochilus Yellowlip emperor 

Lutjanus bohar Red snapper (Twinspot 

snapper) mū RF, P 

Lutjanus fulvus Blacktail snapper tamala, tāiva CB, P 

Lutjanus gibbus Humpback snapper mala’ī CB, P 

Lutjanus kasmira Bluestripe snapper savane CB, P 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix A. Species List A-9

Scientific Name* Common Names Samoan Names Wass Habitats** 

Lutjanus monostigmus Onespot snapper 

(Bluelined snapper) tāiva, feloitega CB 

Macolor niger Reef front 

Macolor spp. Black or Midnight snapper matala’oa 

Malacanthus latovittatus Blue blanquilllo 

Melichthys niger Black triggerfish sumu-uli 

Melichthys vidua Pinktail triggerfish sumu-apa’apasina, 

Sumu-si’umumu CB, P 

Monotaxis grandoculis Bigeye emperor 

(Humpnose bigeye bream) mū-matavaivai CB, LF, P 

Mulloidichthys 

flavolineatus 

Yellowstripe goatfish 

 P 

Mulloidichthys 

vanicolensis Yellowfin goatfish i’asina, vete, afulu, 

afolu CB, P 

Myripristis berndti Big-scale soldierfish CB 

Myripristis kuntee Epaulet soldierfish 

Myriprstis vittata Whitetip soldierfish Reef front 

Naso brevirostris Spotted unicornfish ume-ulutao 

Naso hexacanthus Sleek unicornfish Reef front 

Naso lituratus Orangespine unicornfish ili’ilia (sm) umelei 

(large) CB, LF 

Naso tuberosus Humpnose unicornfish 

Naso unicornis Bluespine unicornfish ume-isu P 

Naso tonganus Bulbnose unicornfish 

Naso vlamingii Bignose unicornfish ume-masimasi CB, LF, P 

Nemateleotris magnifica Fire goby 

Neocirrhites armatus Flame hawkfish Reef front 

Neomyxus leuciscus Sharpnose mullet 

Neoniphon opercularis Blackfin squirrelfish 

Novaculichthys taeniourus Rockmover wrasse sugale-la’o (juv), 

sugale-tāili (adult), RF 

Ostorhincus apogonides sugale-gasufi 

Ostorhincus leslie New cardinalfish species 

Ostracion meleagris RF, P 

Oxycheilinus digrammus Cheeklined wrasse lalafi-gutu’umi 

Oxycheilinus unifasciatus Ringtail wrasse lalafi 

Paracirrhites arcatus Arceye hawkfish lausiva RF 

Paracirrhites forsteri Freckled hawkfish lausiva 

Paracirrhites hemistictus Halfspotted hawkfish 

Parapercis 

cephalopunctata RF 

Parapercis clathrata Latticed sandperch ta’oto 

Parapercis millepunctata Black dotted sand perch 

Parupeneus barberinus Dash-dot goatfish tusia RF, LF 

Parupeneus bifasciatus Doublebar goatfish matūlau-moana RF 

Parupeneus chryserydros RF, LF, P 

Parupeneus cyclostomus Goldsaddle goatfish moana 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment

A-10 Appendix A. Species List 

Scientific Name* Common Names Samoan Names Wass Habitats** 

Parupeneus insularis Twosaddle goatfish 

Parupeneus multifasciatus Manybar goatfish 

Parupeneus pleurostigma Sidespot goatfish matūlau-ilamutu RF, LF 

Parupeneus trifasciatus RF, LF, P 

Pempheris oualensis Copper sweeper 

Plagiotremus tapeinosoma Piano fangblenny mano’o-to’ito’i CB 

Plectroglyphidodon dickii Dick’s damselfish tu’u’u-i’usina P 

Plectroglyphidodon 

johnstonianus Johnston damselfish tu’u’u-I’uuli 

Plectroglyphidodon 

lacrymatus Jewel damselfish tu’u’u-lau, 

i’usamasama 

Plectroglyphidodon 

phoenixensis Phoenix devil 

Pomacentrus brachialis Charcoal damselfish tu’u’u-faga 

Pomacentrus coelestis Neon damselfish tu’u’u-segasega 

Pomacentrus vaiuli Princess damselfish tu’u’u-vaiuli CB, RF, P 

Pomocanthus imperator Emperor angelfish 

Pristiapogon exostigma Narrowstripe cardinalfish 

Pristiapogon fraenatus Spurcheek cardinalfish 

Pristiapogon kallopterus Iridescent cardinalfish 

Pseudanthias pascalus Purple queen 

Pseudobalistes 

flavimarginatus Yellow-margin triggerfish sumu-laulau (<20cm) 

Umu (>20cm) RF, LF, P 

Pseudochelinus evanidus Disappearing wrasse 

(Striated wrasse) RF, LF 

Pseudochelinus hexataenia Sixstripe wrasse sugale-manifi CB, LF, P 

Pseudochelinus ocotaenia Eightstripe wrasse sugale-manifi 

Pseudochelinus tetrataenia Fourstripe wrasse 

Pseudodax moluccanus Chiseltooth wrasse 

Ptereleotris evides Twotone dartfish 

(Blackfin dartfish) ma’ulu RF, LF, P 

Ptereleotris microlepis Pearly dartfish 

Ptereleotris zebra Zebra dartfish 

Pterocaesio kohleri P 

Pterocaesio tile Bluestreak fusilier P 

Pterois antennata Antenna turkeyfish 

(Spotfin lionfish) 

Pterois volitans Turkeyfish 

Pygoplites diacanthus Regal angelfish tu’u’u-moana CB, P 

Remora remora Remora 

Rhinecanthus aculeatus Picasso triggerfish 

(Lagoon triggerfish) sumu-uo’uo RF, LF 

Rhinecanthus rectangulus Wedgetail triggerfish sumu-aloalo 

Sargocentron microstoma Smallmouth squirrelfish malau-tianiu 

Sargocentron spiniferum Sabre squirrelfish 

tāmalau (<30cm), mumalau (>30cm), malautoa 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix A. Species List A-11

Scientific Name* Common Names Samoan Names Wass Habitats** 

Sargocentron tiere Tahitian squirrelfish 

Saurida gracilis Slender lizardfish P 

Scarus (uniden, Juvs.) RF 

Scarus altipinnis 

Scarus atropectoralis 

(S. caudofasicatus) Filament-fin parrotfish CB, P 

Scarus festivus Festive parrotfish 

Scarus forsteni Bluepatch parrotfish 

(Rainbow parrotfish) 

Scarus frenatus Bridled parrotfish laea-mea (IP), laeasi’umoano (TP) 

Scarus ghobban RF 

Scarus gibbus RF 

Scarus globiceps Violet-lined parrotfish 

(Roundhead parrotfish) 

Scarus oviceps Dark capped parrotfish 

Scarus psittacus Palenose parrotfish 

fuga-matapua’a (juv), 

fugausi-matapua’a 

(IP), laea-matapua’a 

(TP) 

Scarus rubroviolaceus Redlip parrotfish laea-mea (IP), laeamala (TP) 

Scarus schlegeli Yellowbar parrotfish fuga-matapua’a (IP), 

laea-tusi (TP) RF, LF, P 

Scarus sordidus CB RF LF P 

Scarus tricolor Reef front 

Scarus xanthopleura Red parrotfish 

Scomberoides lysan Doublespotted queenfish 

Sphryaena helleri Heller’s barracuda 

Sphyraena barracuda Barracuda sapatū

Sphyraena sp. Reef front 

Sphyraena qenie Blackfin barracuda 

Spratelloides sp. RF 

Stegastes albifasciatus Whitebar gregory tu’u’u-pa, ulavapua 

Stegastes nigricans Dusky gregory tu’u’u-moi 

Stethojulis bandanensis Redshoulder wrasse lape-a’au 

Sufflamen bursa Scythe triggerfish 

(Lei triggerfish) sumu-pa’epa’e LF 

Sufflamen chrysopterus Flagtail triggerfish sumu-gasemoana LF 

Synodus variegatus Reef lizardfish ta’oto 

Taeniura meyeni 

Thalassoma 

amblycephalum 

Bluehead wrasse 

(Two-tone wrasse) sugale-aloama CB 

Thalassoma hardwicke Sixbar wrasse sugale-a’au, lapeele’ele CB, P 

Thalassoma lutescens Sunset wrasse sugale-samasama LF, P 

Thalassoma nigrofasciatum Blackbar wrasse 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment

A-12 Appendix A. Species List 

Scientific Name* Common Names Samoan Names Wass Habitats** 

Thalassoma purpureum Surge wrasse uloulo-gatal (IP), 

patagaloa (TP) RF 

Thalassoma 

quinquevittatum 

Fivestripe wrasse 

(Redribbon wrasse) lape-moana CB, RF, P 

Thalassoma trilobatum Christmas wrasse 

Trachinotus baillonii Small-spotted dart 

(Small-spotted pompano) 

Trimma sp. Goby 

Valenciennea strigata Bluestreak goby mano’o-sina RF, LF 

Zanclus cornutus Moorish idol pe’ape’a, laulaufau CB, LF, P 

Zebrasoma rostratum Reef front 

Zebrasoma scopas Brushtail tang pitopito, pe’ape’a CB, LF 

Zebrasoma veliferum Pacific sailfin tang iliū CB, P 

* Bolded font = fish species IUCN listed. 

** Wass (1981) habitats: CB = coral blocks; RF = rubble flats; LF = lagoon floor; P = pinnacle.

Table A-3. Flora List for Rose Atoll 

Species Common Name Samoan Name Invasive 

Terrestrial: 

Auricularia polytricha Wood fungus 

Nephrolepis hirsutula Fern 

Barringtonia asiatica Fish-poison tree Futu 

Boerhavia repens Boerhavia, Alena Ufi’atuli 

Calophyllum inophyllum Alexandrian laurel Fetau 

Cenchrus echinatus Southern sandbur Invasive 

Chloris barbata Swollen fingergrass Invasive 

Cocos nucifera Coconut palm Niu Invasive 

Cordia subcordata Cordia, Kou Taukanave 

Gossypium hirsutum Polynesian cotton Vavae 

Hibiscus tiliaceus Beach hibiscus Fau 

Ipomoea macrantha Morning glory 

Ipomoea pes-caprae Beach morning glory Fue moa 

Pisonia grandis Pisonia Pu’a vai 

Portulaca sp. Purslane Tamole 

Suriana maritima Bay-cedar 

Terminalia sp. Talie 

Tournefortia argentea Tree heliotrope Tausuni 

Marine:* 

Bryoposis pennata 

Halimeda taenicola 

Halimeda fragilis 

Halimeda micronesica 

Halimeda minima 

Halimeda opuntia 

Ostreobium queketti 

Valonia fastigiata 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix A. Species List A-13

Species Common Name Samoan Name Invasive 

Microdictyon setchellianum 

Dictyosphaeria versluysii 

Caulerpa cupressoides (West) 

Caulerpa cupressoides var. 

lycopodium 

Lobophora variegata 

Galaxaura filamentosa 

Porolithon onkodes, P. craspedium, 

P. gardineri Crustose coralline algae 

Jania spp. Coralline red algae 

Peyssonnelia 

Turf algae 

Lyngbya, Oscillotoria, Symploca, 

Calothrix spp. Cyanobacteria Can become invasive 

*For the marine flora, the list is preliminary. 

Source: USFWS, CRED surveys (Brainard et al. 2008, Vroom, pers. comm. 2012, Burgett 2003) 

Table A-4. Bird List for the Refuge 

Species Common Name Samoan Name 

Fregata ariel Lesser frigatebird Atafa 

Fregata minor Great frigatebird Atafa 

Puffinus pacificus Wedge-tailed shearwater Ta’i’o 

Phaethon rubricauda Red-tailed tropicbird Tava’e’ula 

Phaethon lepturus White-tailed tropicbird Tava’e 

Sula sula Red-footed booby Fua’o 

Sula leucogaster Brown booby Fua’o 

Sula dactylatra Masked booby Fua’o 

Egretta sacra Pacific reef heron Matu’u 

Pluvialis fulva Pacific golden plover Tuli 

Arenaria interpres Ruddy turnstone Tuli’alomalala 

Numenius phaeopus Whimbrel Tuli 

Numenius tahitiensis Bristle-thighed curlew Tuli’olovalu 

Calidris alba Sanderling Tuli 

Tringa incana Wandering tattler Tuli 

Sterna sumatrana Black-naped tern Gogosina 

Onychoprion lunatus Gray-backed tern Gogosina 

Onychoprion fuscatus Sooty tern Gogosina, Gogo uli 

Procelsterna cerulea Blue noddy Laia 

Anous minutus Black noddy Gogo uli 

Anous stolidus Brown noddy Gogo 

Gygis alba White tern Manusina 

Eudynamis taitensis Long-tailed cuckoo Aleva 
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Draft Comprehensive Conservation Plan and Environmental Assessment

A-14 Appendix A. Species List 

Table A-5. Reptile List for the Refuge 

Species* Common Name* Samoan Name 

Chelonia mydas Green turtle I’a sa 

Eretmochelys imbricata Hawksbill turtle 

Gehyra oceanica Oceanic gecko 

Lepidodactylus lugubris Mourning gecko 

* Bold = listed under the Endangered Species Act. 

Table A-6. Invertebrates for the Refuge 

Species Common Name Samoan Name Introduced 

Tridacna maxima Giant clam Faisua 

Heterocentrotus, Diadema, 

Echinometra, Echinothrix, and

Echinostrephus spp.

Sea urchins Tuitui 

Ocypoda spp. Ghost crabs 

Coenobita perlatus and 

Coenobita brevimanus Land hermit crabs 

Birgus latro Coconut crab 

Pulvinaria urbicola Scale insect Introduced 

Pheidole megacephala Ant Introduced and 

Invasive 

Tetramorium bicarinatum Ant Introduced and 

Invasive 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix B. Appropriate Use Findings B-1

Appendix B. Appropriate Use Findings 

B.1 Introduction 

The Appropriate Refuge Uses policy outlines the process that the Service uses to determine when general 

public uses on refuges may be considered. Priority public uses previously defined as wildlife-dependent 

uses (hunting, fishing, wildlife observation and photography, and environmental education and 

interpretation) under the National Wildlife Refuge System Improvement Act of 1997 are generally 

exempt from appropriate use review. Other exempt uses include those where the Service does not have 

adequate jurisdiction to control the activity and refuge management activities. In essence, the Appropriate 

Refuge Use policy, 603 FW 1 (2006), provides refuge managers with a consistent procedure to first 

screen and then document decisions concerning a public use. When a use is determined to be appropriate, 

a refuge manager must then decide if the use is compatible before allowing it on a refuge. During the CCP 

process the Refuge Manager evaluated all existing and proposed refuge uses at Rose Atoll National 

Wildlife Refuge using the following guidelines and criteria as outlined in the Appropriate Refuge Use 

policy: 

 Do we have jurisdiction over the use? 

 Does the use comply with applicable laws and regulations (Federal, State, tribal and local)? 

 Is the use consistent with applicable Executive orders and Department and Service policies? 

 Is the use consistent with public safety? 

 Is the use consistent with goals and objectives in an approved management plan or other 

document? 

 Has an earlier documented analysis not denied the use or is this the first the use has been 

proposed? 

 Is the use manageable within available budget and staff? 

 Will this be manageable in the future within existing resources? 

 Does the use contribute to the public’s understanding and appreciation of the refuge’s natural or 

cultural resources, or is the use beneficial to the refuge’s natural or cultural resources? 

 Can the use be accommodated without impairing existing wildlife-dependent recreational uses or 

reducing the potential to provide quality (see section 1.6D, 603 FW 3, for description), 

compatible, wildlife-dependent recreation into the future? 

Using this process and these criteria, and as documented on the following pages, the Refuge Manager 

determined the following uses are appropriate: 

Refuge Use – Rose Atoll NWR Appropriate? 

Research, Survey, and Scientific Collections Yes 

 
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B-2 Appendix B. Appropriate Use Findings 

FINDING OF APPROPRIATENESS OF A REFUGE USE 

Refuge Name: Rose Atoll National Wildlife Refuge, Manu’a District, American Samoa 

Use: Research, Surveys, and Scientific Collections 

This form is not required for wildlife-dependent recreational uses, take regulated by the Territory, or uses already described in a 

refuge CCP or step-down management plan approved after October 9, 1997. 

Decision criteria: YES NO 

(a) Do we have jurisdiction over the use? X 

(b) Does the use comply with applicable laws and regulations (Federal, State, tribal, and local)? X 

(c) Is the use consistent with applicable Executive orders and Department and Service policies? X 

(d) Is the use consistent with public safety? X 

(e) Is the use consistent with goals and objectives in an approved management plan or other document? X 

(f) Has an earlier documented analysis not denied the use or is this the first time the use has been proposed? X 

(g) Is the use manageable within available budget and staff? X 

(h) Will this be manageable in the future within existing resources? X 

(i) Does the use contribute to the public’s understanding and appreciation of the refuge’s natural or cultural 

resources, or is the use beneficial to the refuge’s natural or cultural resources? 

X 

(j) Can the use be accommodated without impairing existing wildlife-dependent recreational uses or reducing 

the potential to provide quality (see section 1.6D, 603 FW 1, for description), compatible, wildlife-dependent 

recreation into the future? 

X 

Where we do not have jurisdiction over the use (“no” to (a)), there is no need to evaluate it further as we cannot control the use. 

Uses that are illegal, inconsistent with existing policy, or unsafe (“no” to (b), (c), or (d)) may not be found appropriate. If the 

answer is “no” to any of the other questions above, we will generally not allow the use. 

If indicated, the refuge manager has consulted with Territorial fish and wildlife agencies. Yes X No __ 

When the refuge manager finds the use appropriate based on sound professional judgment, the refuge manager must justify the 

use in writing on an attached sheet and obtain the refuge supervisor’s concurrence. 

Based on an overall assessment of these factors, my summary conclusion is that the proposed use is: 

Not Appropriate_____ Appropriate X 

Refuge Manager: ___________________________________________________ Date: _________ 

If found to be Not Appropriate, the refuge supervisor does not need to sign concurrence if the use is a new use. 

If an existing use is found Not Appropriate outside the CCP process, the refuge supervisor must sign concurrence. 

If found to be Appropriate, the refuge supervisor must sign concurrence. 

Refuge Supervisor: __________________________________________________ Date: _________ 

A compatibility determination is required before the use may be allowed. FWS Form 3-2319 

02/06 

 
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Appendix B. Appropriate Use Findings B-3

Justification for “Appropriate” finding. 

The proposed use evaluated herein for appropriateness is more fully described and evaluated in the 

compatibility determination (CD) for this use and the documents referenced in that CD. 

a. Do we have jurisdiction over the use? 

The area proposed for this use lies within Rose Atoll National Wildlife Refuge (Refuge). The Refuge 

lands and waters are administered by the U.S. Fish and Wildlife Service (Service), consistent with Title 

50 of the Code of Federal Regulations (CFR). The Service has jurisdiction over public uses of the Refuge. 

b. Does the use comply with applicable laws and regulations (Federal and territorial)? 

This use would comply with applicable laws and regulations. Permittees would be required to obtain 

necessary Territorial and Federal permits. 

c. Is the use consistent with applicable Executive orders and Department and Service policies? 

This use would be consistent with applicable Executive orders and U.S. Department of the Interior and 

Service policies, including the policies on Research and Management Studies (4 Refuge Manual [RM] 6) 

and Administration of Specialized Uses (5 RM 17). 

d. Is the use consistent with public safety? 

This use would be consistent with public safety. Permittees would be required to limit their use of the 

Refuge to specifically designated areas, and review and understand Refuge rules and regulations, and any 

hazardous conditions. 

e. Is the use consistent with goals and objectives in an approved management plan or other 

document? 

This use would not be inconsistent with any Refuge goals, and would usually support several goals. Each 

research proposal would need to be evaluated individually to determine the degree of support. 

f. Has an earlier documented analysis not denied the use or is this the first time the use has been 

proposed? 

Earlier documented analysis has not denied this use. 

g. Is the use manageable within available budget and staff? 

Research, surveys, and scientific collections would be manageable within available budget and staff. 

Stipulations contained within the compatibility determination would help ensure that administration of the 

uses remained manageable within available budget and staff. 

h. Will this be manageable in the future within existing resources? 

The proposed activity would be manageable in the future with existing resources. Research, surveys, and 

collections would be conducted by the Service, partnering agencies, and other research institutions. 

i. Does the use contribute to the public’s understanding and appreciation of the Refuge’s natural or 

cultural resources, or is the use beneficial to the Refuge’s natural or cultural resources? 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

B-4 Appendix B. Appropriate Use Findings 

The Service believes that wildlife and habitat conservation and management on the Refuge should be 

based upon statistically viable scientific research combined with long-term monitoring. The information 

gained through appropriate, compatible research on Refuge lands would be beneficial to the Refuge’s 

natural resources through application of this information into adaptive management strategies. The 

Refuge would also distribute any information gained to the public or incorporate into environmental 

education and interpretation programs and products, which would allow them to better understand and 

appreciate the Refuge resources and the need for protecting them. 

j. Can the use be accommodated without impairing existing wildlife-dependent recreational uses or 

reducing the potential to provide quality (see section 1.6D, 603 FW 1, for description), compatible, 

wildlife-dependent recreation into the future? 

Research activities as described would not impair quality wildlife-dependent recreation should it be 

permitted in the future. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix C. Compatibility Determinations C-1

Appendix C. Compatibility Determinations 

C.1 Introduction 

The compatibility determinations (CD) we developed during the Comprehensive Conservation Plan 

(CCP) planning process evaluate uses as projected to occur under Alternative B, the Preferred Alternative 

in the Draft CCP/Environmental Assessment (EA) for the Rose Atoll National Wildlife Refuge (the 

Refuge). The evaluation of funds needed for management and implementation of each use also assumes 

implementation as described under Alternative B, the Preferred Alternative (also see Appendix D). 

Chapter 6 of the Draft CCP/EA also contains analysis of the impacts of public uses to wildlife and 

habitats. That portion of the document is incorporated through reference into this set of CDs. 

C.2 Uses Evaluated At This Time 

The following section includes full CDs for uses at the Refuge that are required to be evaluated at this 

time. According to Service policy, CDs are to be completed for all uses proposed under a CCP that have 

been determined to be appropriate. Existing wildlife-dependent recreational uses must also be reevaluated and new CDs prepared during development of a CCP. According to the Service’s Compatibility 

policy, uses other than wildlife-dependent recreational uses are not explicitly required to be re-evaluated 

in concert with preparation of a CCP, unless conditions of the use have changed or unless significant new 

information relative to the use and its effects have become available or the existing CDs are more than 10 

years old. However, the Service planning policy recommends preparing CDs for all individual uses, 

specific use programs, or groups of related uses associated with the proposed action. Accordingly, the 

following CDs are included in this document for public review. 

Refuge Use – Rose Atoll NWR Compatible Year Due for 

Re-evaluation 

Research, Surveys, and Scientific Collections Yes 2022 

Environmental Education Yes 2027 

C.3 Compatibility–Legal and Historical Context 

Compatibility is a tool refuge managers use to ensure that recreational and other uses do not interfere with 

wildlife conservation, the primary focus of refuges. Compatibility is not new to the Refuge System and 

dates back to 1918, as a concept. As policy, it has been used since 1962. The Refuge Recreation Act of 

1962 directed the Secretary of the Interior to allow only those public uses of Refuge lands that were 

“compatible with the primary purposes for which the area was established.” 

Legally, refuges outside of Alaska are closed to all public uses until officially opened through a CD. 

Regulations require that adequate funds be available for administration and protection of refuges before 

opening them to any public uses. However, wildlife-dependent recreational uses (hunting, fishing, 

wildlife observation and photography, environmental education (EE) and interpretation) are to receive 

enhanced consideration and cannot be rejected simply for lack of funding resources unless the refuge has 

made a concerted effort to seek out funds from all potential partners. Once found compatible, wildlifedependent recreational uses are deemed the priority public uses at the refuge. If a proposed use is found 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

C-2 Appendix C. Compatibility Determinations 

not compatible, the refuge manager is legally precluded from approving it. Economic uses that are 

conducted by or authorized by the refuge also require a CD. 

Under the Compatibility policy, uses are defined as recreational, economic/commercial, or management 

use of a refuge by the public or a non-Refuge System entity. Uses generally providing an economic return 

(even if conducted for the purposes of habitat management) are also subject to CD. The Service does not 

prepare CD for uses when the Service does not have jurisdiction. For example, the Service may have 

limited jurisdiction over refuge areas where property rights are vested by others; where legally binding 

agreements exist; or where there are treaty rights held by tribes. In addition, aircraft overflights, 

emergency actions, some activities on navigable waters, and activities by other Federal agencies on 

“overlay refuges” are exempt from the CD process. 

New compatibility regulations, required by the National Wildlife Refuge System Improvement Act of 

1997 (Improvement Act), were adopted by the Service in October 2000 (http://refuges.fws.gov/ 

policymakers/nwrpolicies.html). The regulations require that a use must be compatible with both the 

purpose(s) of the individual refuge and the Refuge System mission. This standard helps to ensure 

consistency in application across the Refuge System. The Improvement Act also requires that CD be in 

writing and that the public have an opportunity to comment on most use evaluations. 

The Refuge System mission emphasizes that the needs of fish, wildlife, and plants must be of primary 

consideration. The Improvement Act defined a compatible use as one that “... in the sound professional 

judgment of the Director, will not materially interfere with or detract from the fulfillment of the mission 

of the System or the purposes of the Refuge.” Sound professional judgment is defined under the 

Improvement Act as “... a finding, determination, or decision, that is consistent with principles of sound 

fish and wildlife management and administration, available science and resources ...” Compatibility for 

priority wildlife-dependent uses may depend on the level or extent of a use. 

Court interpretations of the compatibility standard have found that compatibility is a biological standard 

and cannot be used to balance or weigh economic, political, or recreational interests against the primary 

purpose of the refuge (Defenders of Wildlife v. Andrus [Ruby Lake Refuge]). The Service recognizes that 

CDs are complex. For this reason, refuge managers are required to consider “principles of sound fish and 

wildlife management” and “best available science” in making these determinations (House of 

Representatives Report 105-106). Evaluations of the existing uses on Rose Atoll National Wildlife 

Refuge is based on the professional judgment of Refuge and planning personnel including observations of 

Refuge uses and reviews of relevant scientific literature. 

In July 2006, the Service published its Appropriate Refuge Uses policy (603 FW 1). Under this policy, 

most proposed uses must also undergo a review prior to compatibility. Uses excepted from the policy 

include wildlife-dependent recreational uses and uses under reserved rights (see policy for more detail). 

Appropriate Refuge Uses Findings are included in Appendix B.

 
Rose Atoll National Wildlife Refuge 

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Appendix C. Compatibility Determinations C-3

Compatibility Determination 

Use: Research, Surveys, and Scientific Collections. 

Refuge Name: Rose Atoll National Wildlife Refuge, Manu’a District, American Samoa. 

Establishing and Acquisition Authority(ies): Fish and Wildlife Act of 1956. 

 

Refuge Purpose(s):

“... for the development, advancement, management, conservation, and protection of fish and 

wildlife resources ...” 16 USC § 742f (a)(4); “... for the benefit of the United States Fish and 

Wildlife Service, in performing its activities and services. Such acceptance may be subject to the 

terms of any restrictive or affirmative covenant, or condition of servitude ...” 16 USC § 

742f(b)(1) (Fish and Wildlife Act of 1956, 16 U.S.C. §742(a)-754, as amended). 

National Wildlife Refuge System (Refuge System or NWRS) Mission: 

“The mission of the [National Wildlife Refuge] System is to administer a national network of lands and 

waters for the conservation, management, and where appropriate, restoration of the fish, wildlife, and 

plant resources and their habitats within the United States for the benefit of present and future generations 

of Americans” (National Wildlife Refuge System Improvement Act). 

Other Management Direction: 

Presidential Proclamation 8337 

“... for the purposes of protecting the objects identified in the above preceding paragraphs ...” “For the 

purposes of protecting the objects identified above, the Secretaries of the Interior and Commerce, 

respectively, shall not allow or permit any appropriation, injury, destruction, or removal of any feature of 

this monument except as provided for by this proclamation or as otherwise provided for by law.” 

Secretarial Order 3284 

“... For each of the areas subject to this delegation, the [Fish and Wildlife Service] Director shall provide 

for the proper care and management of the monument, including all objects of scientific and historic 

interest therein; the conservation of fish and wildlife; and the development of programs to assess and 

promote national and international monument-related scientific exploration and research.” (Section 

4.a.(2). “... The Director shall manage the emergent and submerged lands and waters out to 50 nautical 

miles from the mean low water line at Rose Atoll as the Rose Atoll Marine National Monument. The 

Director shall continue to manage the existing wildlife refuge at Rose Atoll within the boundaries set 

forth in the Notice of Establishment, 71 FR 13183 (April 5, 1974). Those areas beyond such mean low 

water line for which NOAA has the primary management responsibility for fishery-related activities are 

not included in the National Wildlife Refuge System.” (Section 4.c.). 

Description of Use(s): 

This use involves research, surveys, and scientific collections conducted by non-National Wildlife Refuge 

System (Refuge System) parties on Rose Atoll National Wildlife Refuge (NWR or Refuge). 
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C-4 Appendix C. Compatibility Determinations 

Research refers to a planned, organized, and systematic investigation of a scientific nature. Such studies 

are designed to determine the cause(s) of observed biotic or abiotic phenomenon over a finite time period, 

where cause and effect relationships usually can be inferred through statistical analyses. 

Survey activities include scientific inventories and monitoring of fish, wildlife and plants, public use, and 

abiotic refuge resources (e.g., soils, water). 

Scientific collecting involves gathering of refuge natural resources or cultural artifacts for scientific 

purposes. Examples include collection of vegetation, marine invertebrates, and soils; contaminant 

sampling; adult and larval insect collection; and collection and curation of cultural resources. 

Refuge staff periodically receive requests from outside parties (e.g., universities, Territorial agencies, 

other Federal agencies, and nongovernmental organizations) to conduct research, surveys, and scientific 

collecting on Refuge lands and waters. These project requests can involve a wide range of natural and 

cultural resources as well as public-use management issues such as basic absence/presence surveys, 

collection of undescribed species for identification, study of habitat use and life-history requirements for 

specific species or species groups, evaluation of practical methods for habitat restoration, documenting 

extent and severity of environmental contaminants, testing techniques to control or eradicate pest species, 

measuring effects of climate change on environmental conditions and associated wildlife and habitat 

response, identification and analyses of paleontological specimens, documenting wilderness character, 

modeling wildlife populations, and assessing response of habitat and wildlife to disturbance from public 

uses. Projects may be species-specific, Refuge-specific, or evaluate the relative contribution of Refuge 

lands and waters to larger landscapes (e.g., ecoregion, region, flyway, national, and international) issues 

and trends. 

The US Fish and Wildlife Service’s (Service’s) Research and Management Studies (4 RM 6) and 

Appropriate Refuge Uses (603 FW 1) policies indicate priority for scientific investigatory studies that 

contribute to the enhancement, protection, use, preservation, and management of native wildlife 

populations and their habitat as well as their natural diversity. Projects that contribute to refuge-specific 

needs for resource management goals and objectives, where applicable, would be given a higher priority 

over other requests. Attached to this compatibility determination (CD) are examples of high-priority 

research, survey, and scientific collection topics for Rose Atoll NWR. 

This use is a privilege and not a right. It is not a wildlife-dependent recreational use. Research, surveys, 

and scientific collections on the Refuge would generally be authorized through individual Special Use 

Permits (SUP) consistent with Refuge regulations (Title 50 of the Code of Federal Regulations Parts 25- 

37) and Service policy (5 Refuge Manual [RM] 17). Applicants would also be required to obtain any 

other relevant permits. Within the SUP, conditions would be clearly defined so as to protect and conserve 

the existing resources found within the Refuge. Before being allowed on the Refuge, this use would need 

to be found appropriate (603 FW 1) and then be determined compatible (603 FW 2). 

Research and exploration proposals may be for any time of the year and may be requested for any area of 

the Refuge. The Service in consultation with the National Oceanic and Atmospheric Administration 

(NOAA) and others, as applicable, would evaluate each proposal and may put limits on the activities to 

ensure that negative impacts to resources are avoided or limited. 

Each research, survey, or scientific collections project would likely have different protocols and methods; 

therefore, each study necessitates its own scientific review. Each project would be carefully reviewed to 

prevent any significant short-term, long-term, or cumulative impacts. New research or exploration 

requests would be evaluated by Service staff, applicable scientific partners at NOAA and American 

Samoa government, as well as other subject-matter experts if determined necessary by the Service. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix C. Compatibility Determinations C-5

Evaluations and reviews would be conducted to determine if the species studied, methods used, or habitat 

type and locations affected may lead to undesirable cumulative impacts. Some of the standard and 

specific conditions are included in this Compatibility Determination (CD) under Stipulations Necessary to 

Ensure Compatibility. 

Collections of scientific specimens would be closely monitored and tracked as donations or loans to the 

permittee. Requirements for entering biological data or metadata into a national open-access database 

may be specified on SUPs. Donations or loans of collections would be managed in accordance with Title 

50 of the Code of Federal Regulations, sections 12.35-12.38, FWS Manual 701 FW 5, and Director’s 

Order No. 109, as amended. Permittees may use specimens collected under a permit, any components of 

any specimens (including natural organisms, enzymes, genetic materials or seeds), and research results 

derived from collected specimens for scientific or educational purposes only, and not for commercial 

purposes unless they have entered into a Cooperative Research and Development Agreement (CRADA) 

with the Service. The Service prohibits the sale of collected research specimens and other transfers to 

third parties must have Service authorization prior to any transfer. Permittees may be also required to 

transfer specimens to a museum or other curator, as identified by the Service.

Projects that involve public or private economic use of the natural resources of the Refuge would need to 

comply with relevant Federal regulations for such uses (50 CFR 29.1). In such cases, the Refuge would 

need to first determine that the use contributed to the achievement of Refuge purpose or the Refuge 

System mission prior to making a determination regarding the project’s compatibility. Public or private 

economic uses of specimens collected are not considered in this CD. 

This use has been primarily proposed because the collection and analysis of scientific data are extremely 

valuable to the Service for its ongoing management of the Refuge. The gathered information would also 

be used by other scientists, managers, decision-makers, and educators around the world. The published 

manuscripts from this research help to disseminate the Service mission and the significance of the Refuge 

resources to other researchers and the public. 

This programmatic CD has been developed and made publicly available concurrent with the Draft 

Comprehensive Conservation Plan (CCP) and associated Environmental Assessment (EA) for Rose Atoll 

NWR. Much of the information and some of the analyses contained in this CD are addressed in greater 

detail in the CCP/EA, which are incorporated through reference herein. 

Availability of Resources: 

Refuge responsibilities for research, surveys, and scientific collections by non-Refuge System entities are 

primarily limited to the following: review of proposals, preparation of an SUP(s) and reviewing other 

appropriate compliance documents submitted (pursuant to the National Environmental Policy Act, 

Endangered Species Act (ESA), National Historic Preservation Act, etc.), and monitoring project 

implementation to ensure that impacts and conflicts remain within acceptable levels (remain compatible) 

over time, and review scientific results. Additional administrative, logistical, and operational support 

could also be provided depending on each specific request. Law enforcement and dissemination of 

information about research and surveys in the Refuge are not included in these cost estimates. Estimated 

costs for one-time and annually re-occurring tasks by Refuge staff are determined on a project-by-project 

basis. Sufficient funding in the Refuge’s general operating budget would need to be available to cover 

expenses for these projects. The terms and conditions for funding and staff support necessary to 

administer each project on the Refuge would be clearly stated in the SUP(s). 

The Refuge has the following staffing and funding to administratively support and monitor research, 

surveys, and scientific collections that are currently taking place on Rose Atoll NWR (see table below). 
Rose Atoll National Wildlife Refuge 

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C-6 Appendix C. Compatibility Determinations 

Within the past 5 years, no more than 3 SUPs have been issued in a calendar year for Rose Atoll NWR. 

We would manage this use at the projected level with current capabilities of the Rose Atoll NWR and the 

Pacific Reefs NWR Complex. Any substantial increase in the number of projects would create a need for 

additional resources to satisfy administrative and monitoring needs to ensure the projects were 

implemented in a compatible manner. Any substantial additional costs above those itemized below could 

result in determining a project not compatible unless expenses were offset by the investigator, sponsoring 

organization, or other party. 

Following is an estimate of costs associated with administering this use on the Refuge. 

Category and Itemization One-time ($) Annual ($/yr) 1

Administration and management $7,000 

Monitoring and Adaptive Management $6,800 

Refuge overhead costs associated with the above-listed 

work2 $3,000 

Offsetting revenues $16,800 

1 Annual costs. Annual personnel costs include salary, locality pay and COLA, and benefits for a GS-12 Refuge manager, GS-12 

Refuge biologist, and GS-7 biological technician. 

2 Overhead costs include overhead expenses such as support personnel and do not include salary-related benefits. 

Anticipated Impacts of the Use(s): 

Use of the Refuge to conduct research, surveys, or scientific collecting would generally provide 

information of benefit to native fish, wildlife, plants, and their habitats or cultural resources. Scientific 

findings gained through these projects could provide important information regarding life-history needs of 

species and species groups as well as identify or refine management actions to achieve natural or cultural 

resource management objectives. Reducing uncertainty regarding wildlife and habitat responses to refuge 

management actions undertaken in order to achieve desired outcomes (objectives) is essential for adaptive 

management (522 Departmental Manual [DM] 1). 

Potentially, some projects’ methods could cause impacts to or conflict with Refuge-specific natural or 

cultural resources, priority wildlife-dependent public uses, other high-priority research, or Refuge 

management programs. In such cases, in order for the project to be determined compatible in the SUP 

review, it would need to be clearly demonstrated that the project’s scientific findings would contribute to 

Refuge management and that the project could not be conducted off-Refuge. The investigator(s) would 

need to identify approaches, methods, and strategies in advance to minimize or eliminate potential 

impacts and conflicts. If unacceptable impacts, including long-term and cumulative impacts, could not be 

avoided, then the project could not be determined compatible. 

Refuge Goals and NWRS Mission 

It is likely that most proposed research, survey, or scientific collection projects would support one or 

more of the Refuge goals (particularly Goal 6), but each would need to be evaluated separately. Projects 

that were determined supportive of Refuge purposes, goals, and the Refuge System mission would have a 

greater chance of being found appropriate, determined compatible, and authorized for implementation. 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix C. Compatibility Determinations C-7

Fish, Wildlife, Plants, and Their Habitats 

Impacts would be project- and site-specific, and would vary depending upon the nature and scope of the 

field work. Data collection techniques would generally have minimal animal mortality or disturbance, 

habitat destruction, no introduction of contaminants, and no introduction of non-indigenous species. In 

contrast, projects involving the collection of biotic samples (plants or animals) or requiring intensive 

ground-based data or sample collection would at least have short-term, localized impacts. 

Disturbance to seabirds would likely be one of the greatest wildlife effects caused by terrestrial and 

nearshore research, surveys, and scientific collections. When birds are breeding they are all more 

vulnerable to disturbance. Flushing of birds or even raising their alert levels creates stress and requires 

animals to expend energy that would otherwise be invested in essential life-history activities such as 

foraging, mating, nesting, brood-rearing, and predator avoidance. Disturbance can cause nest desertion; 

affect survival of individual birds, eggs, nestlings, or broods; and alter behavior of non-breeding birds. 

Sea turtles that have come ashore to dig nests and lay eggs are highly focused on their reproductive 

objective and are not easily deterred from this ancient imperative. Hatchlings may have difficulty 

emerging from the nest, if the overlying sand has been compacted by human trampling and activities that 

introduce artificial light into the environment such as camping may disorient them on their way to the 

water. Disturbance and physical damage to fish, marine invertebrates, and corals may result during 

snorkeling, swimming, or diving activities. 

Field research could also cause trampling of native plants and benthic marine biota, erosion, and 

introduction or spread of exotic species, including microbes, invertebrates, terrestrial plants, algae, and 

other pest species. All of these impacts could adversely affect native fish, wildlife, plants, and their 

habitats. 

Improper boat operation could result in localized impacts to the coral reef from anchoring, touching, or 

other avoidable physical disturbance to the benthos including coral and CCA. 

Spread of non-native or pest plants, invertebrates, or pathogens is possible from ground disturbance and 

transportation of project equipment and personnel. These effects would be minimized or eliminated by 

requiring proper cleaning of investigator equipment and adherence to quarantine protocols for clothing 

and camping gear and supplies. Restoration or mitigation plans in place and regular surveillance for new 

invasions would minimize damage from accidental introductions. 

Increased use of waters also increases the potential for introductions of nonnative species and interactions 

(some negative) by boats or snorkelers/divers with sea turtles, fish, cetaceans, and live corals. One 

accidental introduction of a nonnative species on a boat or dive equipment could devastate the Refuge. 

Groundings by inappropriate boat operation could cause physical damage and introduce elements to 

enhance the spread of invasive species, such as was the case with the Jin Shiang Fa. 

There also could be localized and temporary effects from collecting of soil, plant, and algal samples, or 

trapping, handling, or collection of fish and wildlife. Impacts could also occur from infrastructure 

necessary to support a project (e.g., permanent transects or plot markers, exclosure devices). 

All of these impacts could adversely affect native fish, wildlife, plants, and their habitats. Increased 

activity increases risk of adverse impacts also. Individual circumstances associated with specific studies 

would determine the degree of actual effects upon reproduction, survival of individuals, and diversity and 

abundance of native species (community health). 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

C-8 Appendix C. Compatibility Determinations 

However, given the experience of staff with similar research projects conducted at the Refuge and other 

refuge atolls it is anticipated that these impacts can be avoided altogether or minimized. Examples 

includes avoiding nesting areas, minimizing lights utilized at night, Refuge-authorized personnel 

accompanying researchers and educating them on minimizing such impacts, requiring existing biosecurity 

protocols be followed, live-boating, using a diver to hand-place the anchor, using a diver to clear the 

anchor from the bottom before it is hauled up, and frequently checking the position of the boat for drift or 

anchor drag. 

Public Review and Comment: 

Public availability of this CD has been widely announced together with announcement of the availability 

of the Refuge’s Draft CCP/EA. The review and comment period has also been the same as for the Draft 

CCP/EA. 

Determination: (check one below) 

 Use is Not Compatible 

 X Use is Compatible with following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

Permission to use the Refuge for research, surveys, or scientific collections would be officially authorized 

through issuance of a SUP. Generally, SUP would be issued on a year-to-year basis. The SUP would 

cover use by a specified individual or organization and could not be assigned or sub-permitted to others. 

These permits may stipulate more detailed access restrictions and regulations to protect wildlife or Refuge 

integrity from anticipated site-specific negative effects caused by the research project. At the discretion of 

the Refuge manager, Refuge-approved staff may be assigned to accompany researchers. 

Prior to potential SUP renewal, Refuge staff would communicate with researchers to share new 

information, discuss results of monitoring, review compliance with SUP conditions, and address other 

issues. Other meetings would be scheduled as needed. 

The Refuge staff would supply researchers with information about the Refuge; its purposes and goals; 

natural and cultural resources of concern; rules and regulations; and any hazardous conditions. 

Researchers are responsible for reviewing and understanding this information and ensuring that any 

associates entering the Refuge also received, reviewed, understood, and complied with this information. 

General 

1. In addition to the stipulations listed here, the general SUP conditions and requirements, and the 

special SUP conditions, researchers and their colleagues are required to comply with Refuge Systemrelated and other applicable laws, regulations, and policies including “Prohibited Acts” listed in 50 

Code of Federal Regulations (CFR) 27. 

2. Only activities specifically authorized in a SUP would be permitted. Other activities are prohibited, 

for example (but not limited to): 

a. Rose Atoll NWR is closed to general public use, so the SUP would include maps clearly 

depicting the areas researchers are authorized to access and use, including the Refuge entry 

point(s). Permittees are prohibited from straying outside the areas depicted on the maps. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix C. Compatibility Determinations C-9

b. Researchers are prohibited from constructing new or maintaining existing structures on the 

Refuge without specific, prior written approval of the Refuge Manager. 

c. Consistent with Service policy regarding management of non-hazardous solid waste on refuges 

(561 FW 5), permittees are prohibited from littering, dumping refuse, abandoning equipment or 

materials, or otherwise discarding any items on the Refuge. 

d. Unless it was an element included in their approved project proposal, researchers and their 

colleagues are prohibited from collecting and removing any archaeological or historic artifacts, 

abiotic or biological specimens or samples, or mementos from the Refuge. 

3. No changes could be made to any of these stipulations without specific, prior written approval of the 

Refuge Manager. 

Specific Terms and Conditions (include but are not limited to): 

1. All scientific specimens are the property of the U.S. and collections are required to comply with 

Service regulations and policy as donations or loans to the permittee. Donations or loans of collected 

specimens would be managed in accordance with Title 50 of the CFR, sections 12.35-12.38, FWS 

Manual 701 FW 5, Director’s Order No. 109 (as amended), and any other applicable Service or 

Department of the Interior regulation or guidance. Collections shall not be shared or distributed 

beyond the permittee without the expressed permission of the Service. Any loan remains the property 

of the U.S. and the Service may require its return at any time. The Service reserves the right to require 

the permittee to enter specimen data and metadata into a national, open-access database. 

2. All research permit holders would be required to submit an annual report to the Refuge Manager that 

summarizes their activities for a given year and a final report when the project is completed. The 

report would include at a minimum the following: study title, SUP number, fiscal year, progress, 

important findings, and problems encountered, proposed resolution to problems, disposition of any 

collected samples, preparer, and date prepared. Final project reports are due in January following at 

least 1 year after expiration of the SUP. 

3. All publications and products derived from the SUP would appropriately acknowledge the Service 

and state the activities were conducted under National Wildlife Refuge System SUP. Appropriate 

acknowledgement should also be given to NOAA when applicable. All reports, publications, or 

products would reference the Rose Atoll National Wildlife Refuge and Rose Atoll Marine National 

Monument. 

4. Researchers are required to provide Refuge staff with the following: 

a. An opportunity to review and comment on draft manuscripts prior to their submittal to a scientific 

journal for consideration for publication. 

b. At least two copies (reprints) of all publications articles, or other product created as a result of 

information gained or work completed under this permit, including materials generated at any 

time in the future following expiration of this permit. 

c. At the conclusion of the project, raw data (preferably in an electronic database format) or 

unrestricted access to the raw data upon request. 

5. Upon completion of the project or annually, the researcher is required to remove all equipment and 

physical markers (unless required for long-term projects) and restore sites to the Refuge manager’s 

satisfaction. The SUP would specify conditions for removal and clean up. 
Rose Atoll National Wildlife Refuge 

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C-10 Appendix C. Compatibility Determinations 

6. The SUP does not remove the permittees’ obligation to obtain all additional permits, authorizations, 

or regulatory compliance, including but not limited to local, Territorial, and Federal permits for 

collections, or ESA or MMPA consultation. 

7. To reduce impacts, the minimum number of samples (e.g., water, soils, vegetative litter, plants, 

macroinvertebrates, vertebrates, and artifacts) adequate for addressing the question in a credible 

manner would be collected for identification or experimentation. 

8. If the proposed research methods would materially impact, or cause appropriation, injury, destruction, 

or removal of any Refuge resource, the permittee must identify the issues in advance. Highly intrusive 

or manipulative research is generally not permitted. As much of this work would be experimental due 

to the extreme environment, any non-anticipated disturbance would immediately be brought to the 

attention of the Refuge Manager. 

9. Where possible, researchers would be required to coordinate and share collections with other 

investigators. This could reduce sampling needed for multiple projects and any associated mortality 

and disturbance. For example, if one investigator collected fish for a diet study and another researcher 

was examining otoliths, then it could be possible to accomplish sampling for both projects with one 

collection effort. 

10. To minimize the introduction of pests, sampling equipment as well as researcher’s clothing and 

vehicles (e.g., boats) need to be thoroughly cleaned (free of marine fouling organisms, dirt and plant 

material) before being used on the Refuge. Depending on the project, quarantine protocols may be 

necessary. 

11. Researchers are required to secure approval from the Service prior to use of any pesticides (including 

uses of herbicides, fungicides, and insecticides) on the Refuge. This would involve researchers 

submitting to the Refuge Manager a completed Pesticide Use Proposal (PUP) for each proposed 

pesticide use. These PUPs would need to be submitted at least 90 days prior to proposed use of the 

pesticide to allow adequate time for evaluation and processing. 

12. At any time, Refuge staff could accompany researchers in the field, with the researcher required to 

provide transportation unless other arrangements are made prior to the trip. The Refuge Manager or 

designee can suspend or modify a SUP or its conditions or terminate research, surveys, or collections 

that are already permitted and in progress should unacceptable, unforeseen, or unexpected impacts or 

issues arise or be noted. 

13. Violation of any of these stipulations could result in temporary or permanent withdrawal of official 

permission to continue research, surveys, or scientific collections on the Refuge. The SUP could be 

revoked by the Refuge Manager immediately for non-compliance with these stipulations. 

Monitoring, Adaptive Management, and Enforcement 

1. The Refuge has the right to add to or otherwise modify the stipulations listed herein in order to ensure 

the continued compatibility of this use. 

2. Failure to complete administrative and reporting requirements may be used as a reason to deny future 

permit requests. 
Rose Atoll National Wildlife Refuge 

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Appendix C. Compatibility Determinations C-11

Justification: 

Most all research, surveys, and scientific collections on refuges are inherently valuable to the Service 

because they expand scientific information available for resource management decisions about fish, 

wildlife, plants, and their habitats; cultural resources; or public use. In many cases, if it were not for the 

refuge staff providing access to refuge lands and waters along with some support, the project would never 

occur and less scientific information would be available to aid the Service in managing and conserving 

refuge resources. 

By allowing the use to occur under the stipulations described above, it is anticipated that wildlife which 

could be disturbed by this use would find sufficient food resources and resting places so their abundance 

and use would not be measurably lessened on the Refuge. Additionally, it is anticipated that monitoring, 

as needed, would prevent unacceptable or irreversible impacts to fish, wildlife, plants, and their habitats; 

cultural resources; and public use. Where this was not the case, the proposed project would likely not be 

compatible and would not be authorized for implementation. The Refuge staff would also monitor habitat 

quantity and quality, wildlife use and productivity, water quality, cultural resources, and other relevant 

endpoints to determine if stipulations associated with research, surveys, and scientific collections were 

resulting in expected and desirable outcomes. In consultation with researchers, the Refuge staff would 

apply adaptive management principles to modify stipulations or adjust objectives, as necessary, to achieve 

desirable results. 

As a result, potential research, surveys, and scientific collections, consistent with the stipulations 

described herein, would not materially interfere with or detract from maintenance of the Refuge’s 

biological integrity, diversity, and environmental health; fulfillment of the Rose Atoll NWR purposes; or 

the Refuge System mission. 

Mandatory 10- or 15-Year Re-evaluation Date: 

 Mandatory 15-year reevaluation date (for wildlife-dependent public uses) 

 2022 Mandatory 10-year reevaluation date (for all uses other than wildlife-dependent public uses) 

NEPA Compliance for Refuge Use Decision: (check one below) 

 Categorical Exclusion without Environmental Action Statement 

 Categorical Exclusion and Environmental Action Statement 

 X Environmental Assessment and Finding of No Significant Impact 

 Environmental Impact Statement and Record of Decision 

This CD has been developed and issued concurrent with the CCP/EA for Rose Atoll NWR. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

C-12 Appendix C. Compatibility Determinations 

Refuge Determination: 

 

Prepared by: __________________________________ ______________ 

 (Signature) (Date) 

 

Approved by 

Refuge Manager 

Rose Atoll 

National Wildlife 

Refuge __________________________________ ______________ 

 (Signature) (Date) 

Concurrence: 

Project Leader 

Pacific Reefs 

National Wildlife 

Refuge Complex: __________________________________ ______________ 

 (Signature) (Date) 

 

Refuge Supervisor 

Hawaiian and 

Pacific Islands 

National Wildlife 

Refuge Complex: __________________________________ ______________ 

 (Signature) (Date) 

 

Regional Chief, 

National Wildlife 

Refuge System 

Pacific Region: __________________________________ ______________ 

 (Signature) (Date) 

 

 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix C. Compatibility Determinations C-13

References Used and Cited, and Glossary of Acronyms and Terms: 

Adaptive Management (522 DM 1). 

Administration of Specialized Uses (5 RM 17). 

Appropriate Refuge Uses (603 FW 1). 

National Historic Preservation Act of 1966, as amended (16 U.S.C. 470). 

National Wildlife Refuge System Administration Act of 1966, as amended (16 U.S.C. 668dd-668ee). 

(NEPA) National Environmental Policy Act of 1969, as amended (42 U.S.C. 4321-4347). 

Prohibited Acts (50 CFR 27). 

Refuge Compatibility (603 FW 2). 

Solid Waste (Nonhazardous) (561 FW 5). 
Rose Atoll National Wildlife Refuge 

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C-14 Appendix C. Compatibility Determinations 

High-Priority Research, Surveys, and Scientific Collections 

Following are examples of high-priority research, survey, and scientific collection topics for Rose Atoll 

NWR. They are not listed in priority order. 

Work with partners to deploy an Ecological Acoustic Recorder (EAR) in the ava to collect biological data 

that may improve monitoring of behavior and abundance of marine organisms 

Within 5 years, begin to monitor climate change variables and responses including: sea level, 

temperature, water quality (pH, conductivity, dissolved oxygen, nitrogen, photosynthetically available 

light (PAR), phosphorus, iron) and the frequency and duration of extreme storm events 

Work with partners to monitor status and trends of focal communities (hard corals, algae), including the 

incidence and severity of coral and algal disease and bleaching 

Within 5 years, monitor the growth and survival rate of coral colonies at different depths 

Work with partners to conduct REA to document habitat associations and species distribution, density, 

and diversity in marine habitats 

Work with NOAA’s CRED and other partners to collect oceanographic and water quality data in order to 

track changes that could affect the reef or wildlife 

Within 5 years, develop and implement monitoring protocols to track populations of focal lagoon species 

including: fish, corals, giant clams (faisua), other invertebrates, and marine pests to determine abundance, 

density, and biomass of each at selected sites 

Work with partners to collect bathymetry data every 10 years in order to document changes in the lagoon, 

reef, or ava that could affect hydrography or habitat characteristics 

Within 5 years, develop and implement monitoring protocols to track abundance and distribution of focal 

perimeter reef species including eels and urchins to determine abundance, density, and biomass of each at 

selected sites 

Continue monitoring abundance and distribution of the cyanobacterial community which became 

dominant on a section of the southwest arm of the atoll due to elevated iron levels following a 1993 

shipwreck 

Monitor benthic succession of the reef which was damaged due to the 1993 shipwreck 

Within 5 years, work with partners to develop and implement reef monitoring program, including rate of 

growth, elevation change, chemical composition, and other variables related to reef growth and the atoll’s 

ability to maintain itself in an anticipated environment of climate change and ocean acidification 

Within 5 years, work with partners to monitor water flow rate and direction in the ava using archival 

pressure and flow rate instruments that can be downloaded at every visit in order to document any 

changes in flow through the ava 

Within 5 years, develop and implement monitoring protocol to track abundance and biomass of fish, 

including predatory and prey fish species, around the opening of the ava to detect any changes in structure 

or function of this important geological feature for large predators in the Refuge 

Within 2 years, working with NOAA/NMFS and other partners, develop and implement monitoring 

protocol to track turtle abundance and movements using field counts, tagging, remote sensing and satellite 

telemetry 
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Appendix C. Compatibility Determinations C-15

Within 2 years, use GPS to map the perimeter of the islands at high and low tide on each visit to the 

Refuge and obtain any available satellite imagery for incorporation into GIS in order to document 

changes in island size and location 

Monitor survivorship, growth, and maturation of outplanted tamole 

Within 2 years, prepare and implement a monitoring plan and rapid response program for terrestrial nonnative species and respond immediately if detected 

Within 2 years, review existing vegetation community distribution data and develop GIS database of 

terrestrial and marine habitats and update them every 5 years 

Within 4 years, review available vegetation data and develop and implement a monitoring protocol to 

track changes in numbers, cover, and basal area of different species 

Within 3 years, develop and implement a monitoring protocol to track seabird abundance, nesting rates, 

and feeding territories. Include remote sensing observations to improve future monitoring efforts 

Within 2 years, develop and implement a monitoring protocol to track changes in numbers, cover and 

basal area of different plant species 

Within 10 years, characterize nutrient budgets and dynamics at Rose Atoll and evaluate them relative to 

data from other similar reef sites to identify possible stressors and the positive effects of healthy seabird 

colonies adjacent to living reefs 

Within 5 years, work with universities and other partners to evaluate the geomorphology, hydrology, and 

sediment budget of Rose Atoll to understand the processes that have maintained the islands as dynamic 

units 

Within 10 years, investigate the ecological relationships between marine gastropods such as turban shells 

(Turbo spp.), and land hermit crabs (Coenobita perlatus and C. brevimanus). Evaluate factors affecting 

crab populations, including observed reduction in availability of shells to crabs at the Refuge and what 

management may improve mollusk shell availability to the Coenobita spp. which are important 

scavengers and herbivores on both islands 

Within 3 years, work with universities and other partners to investigate composition and structure of 

terrestrial communities on Rose Island prior to the introduction of rats to inform ecological restoration 

activities 

 
Rose Atoll National Wildlife Refuge 

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C-16 Appendix C. Compatibility Determinations 

Compatibility Determination 

Use: Environmental Education. 

Refuge Name: Rose Atoll National Wildlife Refuge, Manu’a District, American Samoa. 

Establishing and Acquisition Authority(ies): Fish and Wildlife Act of 1956. 

Refuge Purpose(s):

“... for the development, advancement, management, conservation, and protection of fish and 

wildlife resources ...” 16 USC § 742f(a)(4); “... for the benefit of the United States Fish and 

Wildlife Service, in performing its activities and services. Such acceptance may be subject to the 

terms of any restrictive or affirmative covenant, or condition of servitude ...” 16 USC § 

742f(b)(1) (Fish and Wildlife Act of 1956, 16 U.S.C. §742(a)-754, as amended). 

National Wildlife Refuge System (Refuge System or NWRS) Mission: 

“The mission of the [National Wildlife Refuge] System is to administer a national network of lands and 

waters for the conservation, management, and where appropriate, restoration of the fish, wildlife, and 

plant resources and their habitats within the United States for the benefit of present and future generations 

of Americans” (National Wildlife Refuge System Improvement Act). 

Other Management Direction: 

Presidential Proclamation 8337 

“... for the purposes of protecting the objects identified in the above preceding paragraphs ...” “For the 

purposes of protecting the objects identified above, the Secretaries of the Interior and Commerce, 

respectively, shall not allow or permit any appropriation, injury, destruction, or removal of any feature of 

this monument except as provided for by this proclamation or as otherwise provided for by law.” 

Secretarial Order 3284 

“... For each of the areas subject to this delegation, the [Fish and Wildlife Service] Director shall provide 

for the proper care and management of the monument, including all objects of scientific and historic 

interest therein; the conservation of fish and wildlife; and the development of programs to assess and 

promote national and international monument-related scientific exploration and research.” (Section 

4.a.(2). “... The Director shall manage the emergent and submerged lands and waters out to 50 nautical 

miles from the mean low water line at Rose Atoll as the Rose Atoll Marine National Monument. The 

Director shall continue to manage the existing wildlife refuge at Rose Atoll within the boundaries set 

forth in the Notice of Establishment, 71 FR 13183 (April 5, 1974). Those areas beyond such mean low 

water line for which NOAA has the primary management responsibility for fishery-related activities are 

not included in the National Wildlife Refuge System.” (Section 4.c). 

Description of Use(s): 

Environmental education is a wildlife-dependent general public use and is to be given special 

consideration in refuge planning and management when compatible. When determined compatible on a 

refuge-specific basis, a wildlife-dependent use becomes a priority public use for that refuge and is to be 

facilitated (see 16 U.S.C. 668dd-668ee). 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix C. Compatibility Determinations C-17

Service policy defines environmental education (EE) to be “a process designed to teach citizens and 

visitors the history and importance of conservation and the biological and the scientific knowledge of our 

... natural resources. Through this process ... [the Service] ... can help develop a citizenry that has the 

awareness, knowledge, attitudes, skills, motivation, and commitment to work cooperatively towards the 

conservation of our ... environmental resources. Environmental education within the Refuge System 

incorporates onsite, offsite, and distance learning materials, activities, programs, and products that 

address the audience’s course of study, refuge purpose(s), physical attributes, ecosystem dynamics, 

conservation strategies, and the Refuge System mission” (605 Fish and Wildlife [FW] 6). 

Environmental education is a formal, structured program that incorporates measurable learning objectives 

and uses audience-appropriate curricula to satisfy Territorial or other standards. Environmental education 

activities can be provided by Refuge personnel, a volunteer(s), or other Service-authorized agent(s); or 

through partnerships with groups that share similar goals (e.g., a new Refuge friends group, partners, or 

others). For purposes of this compatibility determination (CD), EE includes education regarding natural, 

historic, and cultural resources and values. 

Although there were some activities in the past, the U.S. Fish and Wildlife Service (Service) currently 

offers no EE program for the Rose Atoll National Wildlife Refuge (NWR or Refuge). It is proposed that 

the Service provide EE, with an objective of eventually serving EE once every 3 years for on-site 

opportunities in small groups less than 10 people. These visits would be led by a Refuge-authorized agent 

with the stipulations identified to ensure compatibility with this activity. 

Other EE opportunities would be provided offsite in the form of materials developed, classroom 

instruction and curriculum, student intern programs, satellite transmissions to schools, and partnering. 

This CD has been developed and made publicly available concurrent with the Draft Comprehensive 

Conservation Plan (CCP) and associated Environmental Assessment (EA) for Rose Atoll NWR. Much of 

the information and some of the analyses contained in this CD are addressed in greater detail in the 

CCP/EA, which are incorporated through reference herein. 

Availability of Resources: 

Following is an estimate of costs associated with administering this use on the Refuge. 

Tasks Estimated Costs 

per Year1 

Oversight of program by Refuge Manager GS-12 (5%); $5,870 

Biological monitoring by Biologist GS-12 (1%) $1,260 

Supplies and equipment $500 

Refuge overhead costs associated with the above-listed work2 $1,000 

Total Costs $8,630 

1 Annual costs. Annual personnel costs include salary, locality pay and COLA, and benefits. 

2 Overhead costs include overhead expenses such as support personnel and do not include salary-related benefits. 

The Refuge does not currently have adequate budget and staff to support the annual costs associated with 

the full proposed EE program for the Refuge. Smaller components of it are feasible with the existing 

budget, however it would be necessary to recruit, train, and utilize the assistance of volunteers, an intern, 

or other partners to fully support all the proposed activities. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

C-18 Appendix C. Compatibility Determinations 

Additional funding for specialized telepresence technology would need to be made available (either 

through the Service budget system or from an outside source) in order to allow this use to occur in a 

compatible manner. Should internal funding not materialize, the Service would seek outside funding (e.g., 

from other agency partners or private conservation organizations). 

Transportation costs to reach the Refuge, costs of upkeep and replacement of Refuge special equipment, 

and costs of activities on the Refuge are paid for by the participant or covered through grants or partners. 

Anticipated Impacts of the Use(s): 

Refuge Goals and Refuge System Mission 

Environmental education would support Refuge Goal 7. 

Fish, Wildlife, Plants, and Their Habitats 

The Refuge purpose is for the development, advancement, management, conservation, and protection of 

fish and wildlife resources. The focus of management is on supporting the unique habitats and species 

found at Rose Atoll (e.g., Pisonia forest, lagoon habitat, perimeter reef, ava, seabirds, faisua, turtles, 

corals, fishes, etc.). 

On-site EE activities would be expected to cause some wildlife disturbance. Disturbance to nesting and 

resting seabirds and other migratory birds can include flushing of birds or even raising their alert levels, 

creating stress and requiring animals to expend energy that would otherwise be invested in essential lifehistory activities such as foraging, mating, nesting, brood-rearing, and predator avoidance. Such stress 

reactions (elevated heart rate, elevated levels of corticosterone, and behavioral responses) have been 

documented in several species of nesting seabirds at several ecotourism locations as a result of human 

activities in nesting colonies (Jungius and Mirsch 1979, Fowler 1995, Nimon et al. 1995, Kitaysky et al., 

2003). Disturbance can cause nest desertion; reduce survival of individual birds, eggs, nestlings, or 

broods; and alter behavior of non-breeding birds (Trulio 2005). Kitaysky et al. (2003) showed that limited 

duration disturbance, however, has only minor, short-term effects. Observation periods for any particular 

bird or group of birds would be kept to 15 minutes or less for this reason. Bright lights from the ship may 

cause birds returning to the island at night to collide with the vessel. 

Sea turtles coming ashore to dig nests and lay eggs are highly focused on their reproductive behavior and 

are not easily deterred from this ancient imperative. Hatchlings may have difficulty emerging from the 

nest, however, if the overlying sand has been compacted by considerable human trampling. Artificial light 

from night activities on shore or ship lights offshore may disorient hatchlings as they make their way to 

the ocean from their nest. Disturbance to fish, marine invertebrates, and corals may result during 

snorkeling, swimming, or diving activities (Hawkins et al. 1999). 

As educators and students walk on the islands, trampling of native plants, benthic marine biota, erosion, 

and introduction or spread of exotic species, including microbes, invertebrates, plants, algae, and other 

pest species could occur. All of these impacts would adversely affect native wildlife, plants, and their 

habitats; and would be of special concern in Refuge areas struggling with re-establishment of native plant 

communities. The degree of actual effects upon reproduction, survival of individuals, and diversity and 

abundance of native species (community health) would depend on specific circumstances. 

Improper boat operation could result in localized impacts to the coral reef from anchoring, touching, or 

other avoidable physical disturbance to the benthos including coral and CCA. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix C. Compatibility Determinations C-19

Inexperienced or inattentive snorkelers and divers can also cause localized damage by standing on the 

reef, flushing sediment onto living reef biota, and breaking coral and CCA with hands or fins. 

Spread of non-native or pest plants, invertebrates, or pathogens is possible from ground disturbance or 

transportation of equipment and personnel. These effects would be minimized or eliminated by requiring 

proper cleaning of investigator equipment and clothing as well as adhering to quarantine methods and 

possibly restoration or mitigation plans, where appropriate. 

Due to the very limited nature of this activity (<once every 3 years), the small group size (<10 people), 

accompaniment by Refuge-authorized personnel, selection of terrestrial and marine viewing areas based 

on limiting wildlife and habitat disturbance; and instruction and training provided prior and during the trip 

(including biosecurity protocols), we do not expect any additional short-term, long-term, or cumulative 

and indirect or secondary impacts from this use. 

Public Review and Comment: 

Public availability of this CD has been widely announced together with announcement of the availability 

of the Refuge’s Draft CCP/EA. The review and comment period has also been the same as for the Draft 

CCP/EA. 

Determination: (check one below) 

 Use is Not Compatible 

 X Use is Compatible with following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

Permission to use the Refuge for EE would be officially authorized through issuance of a SUP. Generally, 

SUP would be issued on a year-to-year basis. The SUP would cover use by a specified individual or 

organization and could not be assigned or sub-permitted to others. These permits may stipulate more 

detailed access restrictions and regulations to protect wildlife or Refuge integrity from anticipated sitespecific negative effects caused by the EE project. At the discretion of the Refuge manager, Refugeapproved staff may be assigned to accompany EE participants. 

The Refuge staff would supply EE participants with information about the Refuge; its purpose and goals; 

natural and cultural resources of concern; rules and regulations; and any hazardous conditions. 

Participants are responsible for reviewing and understanding this information and ensuring that any 

people entering the Refuge also received, reviewed, understood, and complied with this information. 

General 

1. In addition to the stipulations listed here, the general SUP conditions and requirements, and the 

special SUP conditions, EE participants are required to comply with Refuge System-related and other 

applicable laws, regulations, and policies including “Prohibited Acts” listed in 50 Code of Federal 

Regulations (CFR) 27. 

2. Only activities specifically authorized in a SUP would be permitted. Other activities are prohibited, 

for example (but not limited to): 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

C-20 Appendix C. Compatibility Determinations 

a. Rose Atoll NWR is closed to general public use, so the SUP would include maps clearly 

depicting the areas educators and students are authorized to access and use, including the Refuge 

entry point(s). Permittees are prohibited from straying outside the areas depicted on the maps and 

would be accompanied by a Refuge-authorized agent during their stay. 

b. Educators and students are prohibited from constructing new or maintaining existing structures on 

the Refuge without specific, prior written approval of the Refuge Manager. 

c. Consistent with Service policy regarding management of non-hazardous solid waste on refuges 

(561 FW 5), permittees are prohibited from littering, dumping refuse, abandoning equipment or 

materials, or otherwise discarding any items on the Refuge. 

d. Unless it was an element included in their approved project proposal, educators and their students 

are prohibited from collecting and removing any archaeological or historic artifacts, abiotic or 

biological specimens or samples, or mementos from the Refuge. 

3. Only educators who had successfully participated in an EE Refuge program would be allowed to lead 

EE groups at the Refuge. For activities at the Refuge, EE group size (including students, educators, 

parents, and others participating in the activity) would be limited to no more than 10 individuals in 

the group per visit. 

4. To minimize the introduction of pests, equipment as well as educator’s and student’s clothing and 

vehicles (e.g., boats) need to be thoroughly cleaned (free of marine fouling organisms, dirt and plant 

material) before being used on the Refuge. Depending on the activity, quarantine protocols may be 

necessary. 

5. No changes could be made to any of these stipulations without specific, prior written approval of the 

Refuge Manager. 

Monitoring, Adaptive Management, and Enforcement 

1. The Refuge Manager has the right to add to or otherwise modify the stipulations listed herein in order 

to ensure the continued compatibility of this use. 

2. Violation of any of these stipulations could result in temporary or permanent withdrawal of official 

permission to continue EE on the Refuge. The Refuge Manager may also suspend or revoke the SUP 

if unacceptable impacts were occurring to native wildlife, plants, or their habitats, cultural resources, 

or other Refuge visitors. The SUP could be revoked by the Refuge Manager immediately for noncompliance with these stipulations. 

Justification: 

Service policy states that EE programs can “... promote understanding and appreciation of natural and 

cultural resources and their management on all lands and waters in the Refuge System” (605 FW 6). 

Service policy strongly encourages refuge managers to provide quality, compatible EE programs. 

There would be some potential for wildlife disturbance at the on-site location. Effects would be mitigated 

through timing of visits, instruction of participants, Refuge-authorized attendant, and other measures as 

identified previously. Proposed stipulations would ensure that any other effects of EE would be minor or 

not measurable. 

Mandatory 10- or 15-Year Re-evaluation Date: 

 2027 Mandatory 15-year reevaluation date (for wildlife-dependent public uses) 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix C. Compatibility Determinations C-21

 Mandatory 10-year reevaluation date (for all uses other than wildlife-dependent public uses) 

NEPA Compliance for Refuge Use Decision: (check one below) 

 Categorical Exclusion without Environmental Action Statement 

 Categorical Exclusion and Environmental Action Statement 

 X Environmental Assessment and Finding of No Significant Impact 

 Environmental Impact Statement and Record of Decision 

This CD has been developed and issued concurrent with the CCP/EA for Rose Atoll NWR. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

C-22 Appendix C. Compatibility Determinations 

Refuge Determination: 

 

Prepared by: __________________________________ ______________ 

 (Signature) (Date) 

 

Approved by 

Refuge Manager 

Rose Atoll 

National Wildlife 

Refuge __________________________________ ______________ 

 (Signature) (Date) 

Concurrence: 

Project Leader 

Pacific Reefs 

National Wildlife 

Refuge Complex: __________________________________ ______________ 

 (Signature) (Date) 

 

Refuge Supervisor 

Hawaiian and 

Pacific Islands 

National Wildlife 

Refuge Complex: __________________________________ ______________ 

 (Signature) (Date) 

 

Regional Chief, 

National Wildlife 

Refuge System 

Pacific Region: __________________________________ ______________ 

 (Signature) (Date) 

 

 

 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix C. Compatibility Determinations C-23

References Used and Cited, and Glossary of Acronyms and Terms: 

Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1544). 

Environmental Education (605 FW 6). 

Fowler, G.S. 1995. Ecotourism, field studies and stress: behavioral and hormonal responses of Magellanic 

penguins to nest site disturbance. In: Abstracts to Pacific Seabird Group Annual Meeting, 1995. 

Hawkins, J.P., C.M. Roberts, T.V.T. Hof, K.D. Meyer, J. Tratalos, and C. Aldam. 1999. Effects of 

recreational scuba diving on Caribbean coral and fish communities. Conservation Biology 13(4):888-897. 

Jungius, H. and U. Mirsch. 1979. Changes in heartbeats in nesting birds at Galapagos by human 

disturbance. Journal of Field Ornithology 120:299-310. 

Kitaysky, A., M. Benowitz-Fredericks, Z. Kitaiskaia, M. Shultz, and B. Zaun. 2003. Effects of tourist 

disturbance on stress physiology of wedge-tailed shearwaters (Puffinus pacificus) chicks at Kilauea Point 

National Wildlife Refuge, Kauai, Hawaii. Unpublished report. Kilauea Point National Wildlife Refuge. 

Kauai, HI. 

National Wildlife Refuge System Administration Act of 1966, as amended (16 U.S.C. 668dd-668ee). 

Nimon, A.J., R.C. Schroter, and B. Stonehouse. 1995. Heart rate of disturbed penguins. Nature 374:415. 

Prohibited Acts (50 CFR 27). 

Refuge System-authorized agents: Include “... contractors, cooperating agencies, cooperating 

associations, refuge support groups, and volunteers” (603 FW 2). 

Trulio, L. 2005. Science syntheses for Issue 9: understanding the effects of public access and recreation 

on wildlife and their habitats in the restoration project area. Available at: 

http://www.southbayrestoration.org/pdf_files/Issue%209%20Public%20Access%20&%20Wildlife.pdf. 

 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

C-24 Appendix C. Compatibility Determinations 

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Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix D. Implementation D-1

Appendix D. Implementation 

D.1 Overview 

Implementation of the entire CCP would require increased funding which would be sought from a variety 

of sources. This plan would depend on additional appropriations, partnerships, and grants. There are no 

guarantees that additional Federal funds would be made available to implement all of these projects so 

other sources of funds would also be sought (both public and private). Activities and projects identified 

would be implemented as funds become available. Funding for Rose Atoll NWR for Fiscal Year 2011 

was $141,145. 

The CCP proposes several projects to be implemented over the next 15 years. All of these projects are 

included in the Refuge Management Information System (RONS [Refuge Operational Needs System] or 

MMS [Maintenance Management System]), which are used to request funding from Congress. 

Monitoring activities would be conducted on a percentage of all new and existing projects and activities 

to document wildlife populations and changes across time, habitat conditions, and responses to 

management practices. Actual monitoring and evaluation procedures would be detailed in SDMP (see 

below). 

In addition to the actual strategies outlined in the CCP, some activities would require more detailed plans. 

An Inventory and Monitoring Plan (by 2017) has been identified as an SDMP that would be developed as 

part of implementation. 

D.2 Costs to Implement CCP 

The following sections detail both one time and recurring costs for various projects. One-time costs 

(Table D-1) reflect the initial costs associated with a project, such as the purchase of equipment, 

contracting services, etc. Recurring costs (Tables D-2 and D-3) reflect the future operational and 

maintenance costs associated with the project. Table D-4 summarizes the total budgets needed to 

implement the CCP across the different alternatives. The potential funding sources identify both base 

funding that is appropriated by Congress as part of the NWRS budget (e.g., 1261=operations, 

1262=maintenance, 1263=visitor services, etc.) and grants/external funds received (e.g., Endangered 

Species [ES], Deferred Maintenance [DFM], etc.). Note that for both tables D-1 and D-2, only costs the 

Refuge is directly responsible for have been identified. For partnering strategies identified, due to the 

unknown costs associated and timing, these costs have not been identified in the tables below. However 

some partnering costs have been identified in section D.4 (partnering opportunities). 

Table D-1. One-Time Costs in Thousands 

CCP Objective/Strategy Alt A 

($K) 

Alt B 

($K) 

Potential Fund 

Source 

Obj. 1.1: Within 10 years characterize nutrient budgets and dynamics 

at Rose Atoll and evaluate them relative to data from other similar 

reef sites to identify possible stressors and the positive effects of 

healthy seabird colonies adjacent to living reefs 

 $30 1261 

Obj. 1.1: Within 4 years, install remote sensing systems to document 

boat traffic in the lagoon $100 1265 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

D-2 Appendix D. Implementation 

CCP Objective/Strategy Alt A 

($K) 

Alt B 

($K) 

Potential Fund 

Source 

Obj. 4.1: Within 10 years, investigate the ecological relationships 

between marine gastropods such as turban shells (Turbo spp.), and 

land hermit crabs (Coenobita perlatus and C. brevimanus). Evaluate 

factors affecting crab populations, including observed reduction in 

availability of shells to crabs at the Refuge and what management 

may improve mollusk shell availability to the Coenobita spp. which 

are important scavengers and herbivores on both islands 

 $100 1261 

Obj. 7.1: Install minimal signage on Rose Island to inform people of 

Refuge boundary and regulations $1 $1 1263 or DM 

Obj. 7.1: Develop brochures, Website, and utilize social media and 

other outreach tools specifically designed to communicate Refuge 

protection and safety issues and make these available to mariners $30 1263 

Obj. 7.1: Develop outreach messages using social media such as 

blogs or interpretive videos on line to “bring the Refuge to the 

people” 

 $30 1263 

Obj. 7.1: Enhance law enforcement through the production of 

interpretive brochures for distribution in American Samoa and to the 

yachting community and collaboration with the USCG and NOAA 

for enforcement 

 $150 1263 or 1265 

Obj. 7.2: Create EE materials such as DVDs and posters for use with 

school groups $30 1263 

Obj. 8.1: Restore the cement monument erected on Rose Island 

during the Governor’s 1920 visit $100 DM 

To support strategies, purchase of one vehicle for Refuge staff $30 1261 

TOTAL: $1 $601 

Table D-2. Recurring Operational Recurring Costs Annual in Thousands 

CCP Objective/Strategy (these costs would run through the entire 

15 year plan and are annual) 

Alt A 

($K) 

Alt B 

($K) 

Potential 

Fund 

source 

Obj. 1.1: Identify, prioritize, and implement restoration needs such as 

debris removal in lagoon habitats affected by anthropogenic impacts 

such as iron contamination from shipwrecks 

$10 $20 NRDA 

Obj. 1.1: Within 5 years, develop and implement monitoring protocols 

to track populations of focal lagoon species including: fish, corals, 

faisua, other invertebrates, and marine pests to determine abundance, 

density, and biomass of each at selected sites 

 $20 I&M grant 

or 1261 

Obj. 2.1: Continue monitoring abundance and distribution of the 

cyanobacteria community which became dominant on a section of the 

southwest arm of the atoll due to elevated iron levels following a 1993 

shipwreck 

$20 $60 NRDA 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix D. Implementation D-3

CCP Objective/Strategy (these costs would run through the entire 

15 year plan and are annual) 

Alt A 

($K) 

Alt B 

($K) 

Potential 

Fund 

source 

Obj. 2.1: Within 5 years, develop and implement monitoring protocols 

to track abundance and distribution of focal perimeter reef species 

including eels and urchins to determine abundance, density, and 

biomass of each at selected sites 

 $20 I&M grant 

or 1261 

Obj. 2.1: Monitor benthic succession of the reef which was damaged 

due to the 1993 shipwreck $20 NRDA 

Obj. 2.1: Within 2 years, establish systematic marine debris removal 

program 

 $10 NRDA 

Obj. 3.1: Within 5 years, develop and implement monitoring protocol 

to track abundance and biomass of fish, including predatory and prey 

fish species, around the opening of the ava to detect any changes in 

structure or function of this important geological feature for large 

predators in the Refuge 

 $10 I&M grant 

or 1261 

Obj. 3.1: Work toward the inclusion of better warnings about the 

hazard to mariners of waters in and near the ava to prevent vessel 

groundings, and improve public communications about the Refuge 

being closed 

 $10 1263 

Obj. 4.1: Within 2 years, use GPS to map the perimeter of the islands 

at high and low tide on each visit to the Refuge and obtain any 

available satellite imagery for incorporation into GIS in order to 

document changes in island size and location 

 $5 PICCC 

grant 

Obj. 4.1: Within 15 years, restore and protect native coastal plants 

using best available information about original indigenous ecosystem. 

Restore native tamole (Portulaca lutea) population that was extirpated 

on Rose Atoll by introduced rats (Rattus exulans) but survived on an 

offshore coral block. Monitor survivorship, growth, and maturation of 

planted tamole 

$5 $5 1261 

Obj. 4.1 & 5.1: Within 2 years, prepare and implement a monitoring 

plan and rapid response program for terrestrial nonnative pest species 

and respond immediately if detected 

 $35 ISST 

Obj. 5.1: Within 10 years, eradicate the scale insect (Pulvenaria 

urbicola) and any other nonnative insects, specifically focusing on 

eradicating introduced ant species that facilitate scale growth and 

spread 

 $40 ISST 

Obj. 5.1: Continue monitoring presence or absence of breeding bird 

populations (annual or less often depending on visit schedule to the 

Refuge) as one indicator of the success of habitat restoration measures 

$5 1261 

Obj. 5.1: Within 3 years, develop and implement a monitoring 

protocol to track seabird abundance, nesting rates, and feeding 

territories. Include remote sensing observations to improve future 

monitoring efforts 

 $10 I&M grant 

or 1261 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

D-4 Appendix D. Implementation 

CCP Objective/Strategy (these costs would run through the entire 

15 year plan and are annual) 

Alt A 

($K) 

Alt B 

($K) 

Potential 

Fund 

source 

Obj. 5.1: Within 4 years, develop and implement a monitoring 

protocol to track changes in numbers, cover, and basal area of different 

plant species 

 $3 1261 

Obj. 5.1: Within 2 years, review existing vegetation community 

distribution data and develop GIS database of terrestrial and marine 

habitats and update them every 5 years 

 $4 I&M grant 

or 1261 

Obj. 5.1: Maintain cover of niu (Cocos nucifera) at or below 5% using 

mechanical or direct application of herbicides as appropriate $1 $1 ISST or 1262 

Obj. 5.1: Within 5 years, implement restoration design and begin 

outplanting vegetation TBD 1261 

Obj. 6.1: Within 5 years, monitor climate change variables and 

responses including: sea level, temperature, water quality (pH, 

conductivity, dissolved oxygen, nitrogen, photosynthetically available 

light [PAR], phosphorus, iron) and the frequency and duration of 

extreme storm events 

 $15 

PICCC 

grant or 

I&M 

Obj. 6.1: Within 5 years, monitor the growth and survival rate of coral 

colonies at different depths $10 I&M 

Vessel acquisition and maintenance for management, law 

enforcement, and monitoring: 

full ownership; 

partial ownership; or 

contract of a vessel for management. 

$20 

- $550 

- $275 

- $60 

1262 

TOTAL: $61 $294 + 

$12 (5 year 

interval veg. 

mapping) + 

 $550

 $275

 $60

(vessel 

options) 

Costs identified below in Table D-3 include salary, COLA, and benefits (applicable only to Federal 

employees). The Refuge/Monument Manager is supported by staff in Honolulu (notably the biologist) 

that are part of the larger Pacific Reefs National Wildlife Refuge Complex (Complex). Therefore (*) 

positions are these Complex positions and staffing costs identified for these positions is equally 

proportioned among the other refuges in the Complex. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix D. Implementation D-5

Table D-3. Staffing Costs (annual in thousands) 

Staff Alt A 

($K) 

Alt B 

($K) 

Potential Funding 

Source 

Current Staff 

Refuge/Monument Manager (GS-12) – Permanent $117,392 $117,392 1261 

Staff at Honolulu Complex Headquarters also supporting Rose Atoll NWR 

Superintendent/Project Leader (GS-14)* – Permanent $16,309 $16,309 1261 

Wildlife Biologist (GS-12)* – Permanent $12,594 $12,594 1261 

Administrative Officer (GS-9)* – Permanent $8,859 $8,859 1261 

Proposed Additional Staff 

Wildlife Biologist (GS-11) $84,411 1261 

Biological Technician (GS-7) $57,404 1261 

Admin officer (GS-5/7) $57,404 1261 

Park Ranger (GS-5/7) – Half time $28,702 1261 

TOTAL: $155,154 $383,075 

In 2008, the Refuge System undertook a comprehensive review of staffing needs on all refuges based on a 

set of 15 standard criteria (e.g., acreage, annual public visitation, number of invasive species populations, 

etc.). The staffing needs identified under this review (National Staffing Model) for Rose NWR/MNM was 

4.5. 

The following table summarizes data from Tables D-1 through D-3 and displays the overall funding 

needed for the Refuge to implement the CCP across the different alternatives. 

Table D-4. Budget Summary (annual in thousands/millions)

Budget Category 

Alt A Alt B 

One time cost Annual 

recurring cost 

One time cost Annual recurring 

cost 

Management Actions $1,000 $61,000 x 15 

years = $915,000 

$601,000 $294,000 x 15 years 

+ 

$12,000 (5 year 

interval veg. 

mapping) + 

$550,000 

$275,000 

$60,000 

(vessel option range) 

= 

$4,972,000 

$4,697,000 

$4,482,000 

Staffing $155,154 x 15 years = $2,327,310 $383,075 x 15 years = $5,746,125 

TOTAL: $3,243,310 $11,319,125 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

D-6 Appendix D. Implementation 

Budget Category 

Alt A Alt B 

One time cost Annual 

recurring cost 

One time cost Annual recurring 

cost 

$11,044,125 

$10,829,125 

D.3 Timeline for CCP Implementation 

The following table depicts the timeline for implementing the preferred strategies outlined in Chapter 2. 

As stated previously, the timeline is funding dependent but does reflect Refuge priorities. 

Table D-4. Timeline for Implementation of Preferred Alternative Strategies

CCP objective/strategy Implementation Year 

Obj. 4.1: Within 6 months, revise existing biosecurity measures to comprehensively 

address prevention of introducing nonnative pest species to the atoll 6 months (2013) 

Obj. 1.1: Identify, prioritize, and implement restoration needs such as debris removal in 

lagoon habitats affected by anthropogenic impacts such as iron contamination from 

shipwrecks 

Year 1 (2013) to 

identify/prioritize 

(implementation TBD 

based on findings) 

Obj. 6.1: Finalize Memorandum of Understanding (MOU) with DMWR to coordinate 

data collection and management activities at the Refuge Year 1 (2013) 

Obj. 8.1: Work with the American Samoa Historical Preservation Office to conduct an 

archaeological survey at Rose Atoll Year 1 (2013) 

Obj. 8.1: Work with partners to create information materials such as videos, reports, 

and pamphlets regarding cultural uses and the oral history of Rose Atoll Year 1 (2013) 

Obj. 2.1: Within 2 years, establish systematic marine debris removal program Year 2 (2014) 

Obj. 4.1 and 6.1: Within 2 years, use GPS to map the perimeter of the islands at high 

and low tide on each visit to the Refuge and obtain any available satellite imagery for 

incorporation into GIS in order to document changes in island size and location 

Year 2 (2014) 

Obj. 4.1 and 6.1: Within 2 years, working with NOAA/NMFS and other partners, 

develop and implement monitoring protocol to track turtle abundance and movements 

using field counts, tagging, remote sensing, and satellite telemetry 

Year 2 (2014) 

Obj. 4.1, 5.1, and 6.1: Within 2 years, prepare and implement a monitoring plan and 

rapid response program for terrestrial nonnative species and respond immediately if 

detected 

Year 2 (2014) 

Obj. 5.1 and 6.1: Within 2 years, review existing vegetation community distribution 

data and develop GIS database of terrestrial and marine habitats and update them every 

5 years 

Year 2 (2014) 

Obj. 8.1: Research the history of Samoan names for Rose Atoll and consider changing 

Refuge name accordingly Year 2 (2014) 

Obj. 1.1 and 6.1: Work with partners to conduct REA to document habitat associations 

and species distribution, density, and diversity in marine habitats Year 3 (2015) 

Obj. 3.1: Work toward the inclusion of better warnings about the hazard to mariners of 

waters in and near the ava to prevent vessel groundings, and improve public 

communications about the Refuge being closed 

Year 3 (2015) 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix D. Implementation D-7

CCP objective/strategy Implementation Year 

Obj. 5.1: Within 3 years and working with experts, prepare a restoration design that 

identifies which desired species would require active propagation and outplanting and 

which would recruit naturally now that rat herbivory has been eliminated. Part of this 

strategy would be to work with universities and other partners to investigate 

composition and structure of terrestrial communities on Rose Island prior to the 

introduction of rats to inform ecological restoration activities (see Objective 6.2) 

Year 3 (2015) 

Obj. 5.1: and 6.1: Within 3 years, develop and implement a monitoring protocol to 

track seabird abundance, nesting rates, and feeding territories. Include remote sensing 

observations to improve future monitoring efforts 

Year 3 (2015) 

Obj. 7.1: Explore opportunities and community interest for supporting the development 

of a Refuge “Friends” group to help with interpretation, outreach, and other Refuge 

needs 

Year 3 (2015) 

Obj. 7.1: Install minimal signage on Rose Island to inform on Refuge boundary and 

regulations Year 3 (2015) 

Obj. 7.1: Develop brochures, Website, social media, and other outreach tools 

specifically designed to communicate Refuge protection and safety issues and make 

these available to mariners 

Year 3 (2015) 

Obj. 7.2: Create EE materials such as DVDs and posters for use with school groups Year 3 (2015) 

Obj. 7.2: Develop a brief, picture-oriented Powerpoint presentation describing the 

ecology of the Refuge and present this to three American Samoa schools each year Year 3 (2015) 

Obj. 7.2: Develop a student intern program with the Refuge office to introduce students 

to protected areas and wildlife management Year 3 (2015) 

Obj. 1.1: Within 4 years, install remote sensing systems to document boat traffic in the 

lagoon Year 4 (2016) 

Obj. 5.1 and 6.1: Within 4 years, develop and implement a monitoring protocol to track 

changes in numbers, cover, and basal area of different plant species Year 4 (2016) 

Obj. 7.1: Work with partners to develop interpretive displays and printed materials to 

provide outreach messages at visitor centers as well as mobile displays for traveling 

exhibits 

Year 4 (2016) 

Obj. 7.2: Explore appropriate on-site EE opportunities (<once every 3 years) to allow a 

small group of teachers and students (<10 people) to visit the Refuge for specific EE 

purposes developed with the Refuge’s EE program 

Year 4 (2016) 

Obj. 1.1 and 6.1: Within 5 years, develop and implement monitoring protocols to track 

populations of focal lagoon species including: fish, corals, giant clams (faisua), other 

invertebrates, and marine pests to determine abundance, density, and biomass of each 

at selected sites 

Year 5 (2017) 

Obj. 2.1 and 6.1: Within 5 years, work with partners to develop and implement reef 

monitoring program, including rate of growth, elevation change, chemical composition 

and other variables related to reef growth and the atoll’s ability to maintain itself in an 

anticipated environment of climate change and ocean acidification 

Year 5 (2017) 

Obj. 2.1 and 6.1: Within 5 years, develop and implement monitoring protocols to track 

abundance and distribution of focal perimeter reef species including eels and urchins to 

determine abundance, density, and biomass of each at selected sites 

Year 5 (2017) 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

D-8 Appendix D. Implementation 

CCP objective/strategy Implementation Year 

Obj. 3.1 and 6.1: Within 5 years, work with partners to monitor water flow rate and 

direction in the ava using archival pressure and flow rate instruments that can be 

downloaded at every visit in order to document any changes in flow through the ava 

Year 5 (2017) 

Obj. 3.1 and 6.1: Within 5 years, develop and implement monitoring protocol to track 

abundance and biomass of fish, including predatory and prey fish species, around the 

opening of the ava to detect any changes in structure or function of this important 

geological feature for large predators in the Refuge 

Year 5 (2017) 

Obj. 4.1 Within 5 years, working with NOAA/NMFS and other partners, develop a 

cooperative management plan with Fiji to protect shared stocks of threatened green 

turtles that migrate between Rose Atoll (to nest) and Fiji (to feed). Meet with 

appropriate Fiji managers as needed 

Year 5 (2017) 

Obj. 4.1 and 6.2: Within 5 years, work with universities and other partners to evaluate 

the geomorphology, hydrology, and sediment budget of Rose Atoll to understand the 

processes that have maintained the islands as dynamic units 

Year 5 (2017) 

Obj. 5.1: Within 5 years, implement restoration design and begin outplanting 

vegetation Year 5 (2017) 

Obj. 6.1: Within 5 years, begin to monitor climate change variables and responses 

including: sea level, temperature, water quality (pH, conductivity, dissolved oxygen, 

nitrogen, photosynthetically available light [PAR], phosphorus, iron) and the frequency 

and duration of extreme storm events 

Year 5 (2017) 

Obj. 6.1: Within 5 years, monitor the growth and survival rate of coral colonies at 

different depths Year 5 (2017) 

Obj. 7.1: Develop outreach messages using social media such as blogs or interpretive 

videos on line to “bring the Refuge to the people” Year 5 (2017) 

Obj. 7.1: Enhance law enforcement through the production of interpretive brochures 

for distribution in American Samoa and to the yachting community and collaboration 

with the USCG and NOAA for enforcement 

Year 5 (2017) 

Obj. 7.1: Develop a Refuge volunteer program to provide local and national 

stewardship opportunities and assist in Refuge management activities Year 5 (2017) 

Obj. 1.1 and 6.2: Within 10 years characterize nutrient budgets and dynamics at Rose 

Atoll and evaluate them relative to data from other similar reef sites to identify possible 

stressors and the positive effects of healthy seabird colonies adjacent to living reefs 

Year 10 (2022) 

Obj. 4.1 and 6.2: Within 10 years, investigate the ecological relationships between 

marine gastropods such as turban shells (Turbo spp.), and land hermit crabs (Coenobita 

perlatus and C. brevimanus). Evaluate factors affecting crab populations, including 

observed reduction in availability of shells to crabs at the Refuge and what 

management may improve mollusk shell availability to the Coenobita spp. which are 

important scavengers and herbivores on both islands 

Year 10 (2022) 

Obj. 5.1: Within 10 years, eradicate the scale insect (Pulvenaria urbicola) and any 

other nonnative insects, specifically focusing on eradicating introduced ant species that 

facilitate scale growth and spread 

Year 10 (2022) 

Obj. 8.1: Restore the cement monument erected on Rose Island during the Governor’s 

1920 visit Year 10 (2022) 

Obj. 1.1 and 6.1: Work with NOAA’s CRED and other partners to collect 

oceanographic and water quality data in order to track changes that could affect the 

reef or wildlife 

Ongoing 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix D. Implementation D-9

CCP objective/strategy Implementation Year 

Obj. 1.1, 3.1, and 6.1: Work with partners to collect bathymetry data every 10 years in 

order to document changes in the lagoon, reef, or ava that could affect hydrography or 

habitat characteristics 

Ongoing 

Obj. 2.1: Continue monitoring abundance and distribution of the cyanobacterial 

community which became dominant on a section of the southwest arm of the atoll due 

to elevated iron levels following a 1993 shipwreck 

Ongoing 

Obj. 2.1 and 6.1: Monitor benthic succession of the reef which was damaged due to the 

1993 shipwreck Ongoing 

Obj. 4.1 and 6.1: Within 15 years, restore and protect native coastal plants using best 

available information about original indigenous ecosystem. Restore native tamole 

(Portulaca lutea) population that was extirpated on Rose Atoll by introduced rats 

(Rattus exulans) but survived on an offshore coral block. Monitor survivorship, 

growth, and maturation of planted tamole 

Ongoing 

Obj. 5.1: Continue monitoring presence or absence of breeding bird populations 

(annual or less often depending on visit schedule to the Refuge) as one indicator of the 

success of habitat restoration measures 

Ongoing 

Obj. 5.1: Maintain cover of niu (Cocos nucifera) at or below 5% using mechanical or 

direct application of herbicides as appropriate Ongoing 

Obj. 6.1: Work with partners to monitor status and trends of focal communities (hard 

corals, algae), including the incidence and severity of coral and algal disease and 

bleaching 

Ongoing 

Obj. 6.1: Work with partners to deploy an Ecological Acoustic Recorder (EAR) in the 

ava to collect biological data that may improve monitoring of behavior and abundance 

of marine organisms 

Ongoing 

Obj. 7.1: Maintain Refuge Website and update at least annually with current 

information such as species lists, interactive tools, management updates, news releases, 

science reports, etc. 

Ongoing 

Obj. 7.1: Participate in community meetings and local events to educate people about 

the Refuge, especially within the Manu’a Islands Ongoing 

Obj. 7.1: Work with partners to deploy an EAR in the ava to collect data on boat entry 

into the lagoon Ongoing 

Obj. 7.2: Work with partners to develop EE curriculum and classroom materials that 

introduce students to American Samoa wildlife, protected areas, and conservation of 

natural resources, especially in relation to effects from man-made climate change 

Ongoing 

Obj. 7.2: Partner with schools and universities to conduct surveys and/or relevant 

research Ongoing 

Obj. 8.1: Consult with the OSA and local villagers to understand and perpetuate 

Refuge-appropriate traditional cultural practices related to Rose Atoll Ongoing 

D.4 Partnering Opportunities 

Partnerships are an important component of the implementation of this CCP. The Refuge has never been 

fully funded to accomplish adequate Refuge management. Towards this end, we rely on partnering 

opportunities to assist with this shortfall, both in terms of funding and personnel. Partnering opportunities 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

D-10 Appendix D. Implementation 

are reflected in the goals, objectives, and strategies identified in Chapter 2. Coordinated partnership 

efforts focus on species and habitat restoration and protection; surveys, inventories, and research; and 

cultural resources management. Refuge staff would work to strengthen existing partnerships and would 

actively look for new partnerships to assist in achieving the goals, objectives, and strategies in this CCP. 

The following list of partners and recently funded projects provides some information on how the Refuge 

has benefitted from partnerships for Refuge management. This information illuminates how partnering is 

critical for the Refuge to accomplishing species and habitat restoration and protection. 

 Refuge Inventory and Monitoring Program has funded a survey of arthropods and distribution of 

invasive ants on Rose Atoll and development of methods ($38,437); 

 The ASCC, USGS, and AmeriCorps provided entomologists to conduct arthropod surveys; 

 The NOAA CRED has conducted coral reef assessment and monitoring surveys in the Refuge 

and adjoining fore reef biannually since 2002, providing more than a dozen specialists each 

survey period in oceanography, fishes, corals, other invertebrates, algae, and data management. 

NOAA vessels have also provided Refuge access for Service terrestrial biologists and American 

Samoa government representatives, including the Governor; 

 The DMWR has provided biologists for monitoring and management actions, as well as assisting 

with transportation to the Refuge; 

 The NMFS provided funds for a trip to Rose Atoll for Manu’a chiefs, teachers and students; 

 The ONMS and ASDoC provided staff on the trip funded by NMFS; 

 The NPS and ASHPO provided archeologists to conduct the first in-depth archeology survey of 

Rose Island; 

 The NPS provided experienced scuba divers to conduct coral surveys; 

 The NPS provides office space and support for the Refuge/Monument office. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix E. Wilderness Review E-1

Appendix E. Wilderness Review for Rose Atoll National 

Wildlife Refuge 

E.1 Policy and Direction for Wilderness Reviews 

U.S. Fish and Wildlife Service policy (Part 602 FW 3.4 C.(1) (c)) requires that wilderness reviews be 

completed as part of the CCP process. This review includes the re-evaluation of refuge lands existing 

during the initial 10-year review period of The Wilderness Act of 1964, as amended (16 U.S.C. 1131-

1136) as well as new lands and waters added to the Refuge System since 1974. A preliminary inventory 

of the wilderness resources is to be conducted during pre-acquisition planning for new or expanded 

refuges (341 FW 2.4 B., “Land Acquisition Planning”). Refuge System policy on Wilderness Stewardship 

(610 FW 1-5) includes guidance for conducting wilderness reviews (610 FW 4 – Wilderness Review and 

Evaluation). 

A wilderness review is the process of determining whether the Service should recommend Refuge System 

lands and waters to Congress through the Department of the Interior and President for wilderness 

designation. The wilderness review process consists of three phases: wilderness inventory, wilderness 

study, and wilderness recommendation. 

E.1.1 Wilderness Inventory 

The inventory is a broad look at a refuge to identify lands and waters that meet the minimum criteria for 

wilderness: size, naturalness, and outstanding opportunities for solitude or primitive and unconfined type 

of recreation. All areas meeting the criteria are preliminarily classified as Wilderness Study Areas (WSA). 

If WSA are identified, the review proceeds to the study phase. 

E.1.2 Wilderness Study 

During the study phase, WSAs are further analyzed: 

1) For all values ecological, recreational, cultural, economic, symbolic; 

2) For all resources, including wildlife, vegetation, water, minerals, soils; 

3) For existing and proposed public uses; 

4) For existing and proposed refuge management activities within the area; and 

5) To assess a refuge’s ability to manage and maintain the wilderness character in perpetuity, 

given the current and proposed management activities. Factors for evaluation may include, 

but are not limited to staffing and funding capabilities, increasing development and 

urbanization, public uses, and safety. 

We evaluate at least an “All Wilderness Alternative” and a “No Wilderness Alternative” for each WSA to 

compare the benefits and impacts of managing the area as wilderness as opposed to managing the area 

under an alternate set of goals, objectives, and strategies that do not involve wilderness designation. We 

may also develop “Partial Wilderness Alternatives” that evaluate the benefits and impacts of managing 

portions of a WSA as wilderness. 

In the alternatives, we evaluate: 

1) The benefits and impacts to wilderness values and other resources; 

2) How each alternative would achieve the purposes of the Wilderness Act and the National 
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E-2 Appendix E. Wilderness Review 

Wilderness Preservation System (NWPS); 

3) How each alternative would affect achievement of refuge purpose(s) and the Refuge System 

mission; 

4) How each alternative would affect maintaining and, where appropriate, restoring BIDEH at 

various landscape scales; 

5) Other legal and policy mandates; and 

6) Whether a WSA can be effectively managed as wilderness by considering the effects of 

existing private rights, land status and Service jurisdiction, refuge management activities and 

refuge uses and the need for or possibility of eliminating Section 4(c) prohibited uses. 

E.1.3 Wilderness Recommendation 

If the wilderness study demonstrates that a WSA meets the requirements for inclusion in the NWPS, a 

wilderness study report should be written that presents the results of the wilderness review, accompanied 

by a Legislative Environmental Impact Statement (LEIS). The wilderness study report and LEIS that 

support wilderness designation are then transmitted through the Secretary of the Interior to the President 

of United States, and ultimately to the Congress for action. Refuge lands recommended for wilderness 

consideration by the wilderness study report would retain their WSA status and be managed as “... 

wilderness according to the management direction in the final CCP until Congress makes a decision on 

the area or we amended the CCP to modify or remove the wilderness recommendation” (610 FW 4.22B). 

When a WSA is revised or eliminated, or when there is a revision in “wilderness stewardship direction, 

we include appropriate interagency and tribal coordination, public involvement, and documentation of 

compliance with NEPA” (610 FW 3.13). 

The following constitutes the wilderness inventory phase of the wilderness review for the Rose Atoll 

NWR. 

E.2 Wilderness Inventory 

E.2.1 Criteria for Evaluating Lands for Possible Inclusion in the National 

Wilderness Preservation System 

The Wilderness Act of 1964, as amended (16 U.S.C. 1131-1136) provides the following description of 

wilderness: 

“A wilderness, in contrast with those areas where man and his own works dominate the 

landscape, is hereby recognized as an area where the earth and its community of life are 

untrammeled by man, where man himself is a visitor who does not remain. An area of wilderness 

is further defined to mean in this Act as an area of undeveloped Federal land retaining its 

primeval character and influence, without permanent improvements or human habitation, which 

is protected and managed so as to preserve its natural conditions...” 

The following criteria for identifying areas as wilderness are outlined in Section 2(c) of the Act and are 

further expanded upon in NWRS policy (610 FW 4). The first three criteria are evaluated during the 

wilderness inventory phase; the fourth criterion is evaluated during the wilderness study phase: 

1) Generally appears to have been affected primarily by the forces of nature, with the imprint of 

man’s work substantially unnoticeable; 

2) Has outstanding opportunities for solitude or a primitive and unconfined type of recreation; 

3) Has at least 5,000 acres of land or is of a sufficient size as to make practicable its preservation 
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Appendix E. Wilderness Review E-3

and use in an unimpaired condition; and 

4) May also contain ecological, geological, or other features of scientific, educational, scenic, or 

historic value. 

Criterion 3 is further defined in Section 3(c) of the Act as 1) a roadless area of 5,000 contiguous acres or 

more, or 2) a roadless island. Roadless is defined as the absence of improved roads suitable and 

maintained for public travel by means of four-wheeled, motorized vehicles that are intended for highway 

use. 

E.3 Process of Analysis 

The following evaluation process was used in identifying the suitability of refuge units for wilderness 

designation: 

 Determination of refuge unit sizes; 

 Assessment of the units’ capacity to provide opportunities for solitude or primitive and 

unconfined recreation; and 

 Assessment of “naturalness” of refuge units. 

More detail on the actual factors considered and used for each assessment step follows. 

Unit Size: Roadless areas meet the size criteria if any one of the following standards apply: 

 An area with over 5,000 contiguous acres solely in Service ownership. 

 A roadless island of any size. A roadless island is defined as an area surrounded by permanent 

waters or an area that is markedly distinguished from the surrounding lands by topographical or 

ecological features. 

 An area of less than 5,000 contiguous Federal acres that is of sufficient size as to make 

practicable its preservation and use in an unimpaired condition, and of a size suitable for 

wilderness management. 

 An area of less than 5,000 contiguous Federal acres that is contiguous with a designated 

wilderness, recommended wilderness, or area under wilderness review by another Federal 

wilderness managing agency such as the Forest Service, National Park Service, or Bureau of 

Land Management. 

Inventory Unit A consists of the entire Rose Atoll NWR (Figure E-1) at 1,613 acres. As a low-lying atoll 

with two roadless islands, Rose Atoll NWR meets the size criteria for a wilderness study area. 

Outstanding Solitude or Primitive or Unconfined Recreation. 

A designated wilderness area must provide outstanding opportunities for solitude, or a primitive and 

unconfined type of recreation. Possession of only one of these outstanding opportunities is sufficient for 

an area to qualify as wilderness, and it is not necessary for one of these outstanding opportunities to be 

available on every acre. Furthermore, an area does not have to be open to public use and access to qualify 

under these criteria. 

Opportunities for solitude refer to the ability of a visitor to be alone and secluded from other visitors in 

the area. Primitive and unconfined recreation means non-motorized, dispersed outdoor recreation 

activities that are compatible and do not require developed facilities or mechanical transport. Primitive 
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E-4 Appendix E. Wilderness Review 

recreation activities may provide opportunities to experience challenge and risk, self-reliance, and 

adventure. 

Solitude is an overwhelming force that visitors experience on Rose Atoll. The atoll is over 2,700 miles to 

Sydney, Australia; 4,700 to Los Angeles, California; and 6,000 miles to Peru. The closest inhabited area 

is Ta’u Island at almost 80 miles away. Expanses of open ocean with no other landform are visible from 

every angle. Since its establishment as a refuge, Rose Atoll has been closed to general public access in 

order to conserve the unique and valuable fish and wildlife resources. Research, survey, and management 

activities involving human presence are infrequent and temporary and thus would not detract from 

opportunities for solitude or primitive and unconfined recreation. With no freshwater or facilities, a 

challenging channel crossing, extreme isolation, and sharks present in the lagoon, opportunities to 

experience challenge and risk, self-reliance, and adventure are present. 

The Rose Atoll NWR inventory unit thus meets the criteria for solitude as well as primitive and 

unconfined recreation. 

Naturalness and Wildness: the area generally appears to have been affected primarily by the forces 

of nature, with the imprint of man’s work substantially unnoticeable. 

This criterion must be evaluated in the context of current natural conditions and societal values and 

expectations without compromising the original intent of the Wilderness Act. It is well recognized that 

there are few areas remaining on the planet that could be truly classified as primeval or pristine, with even 

fewer, if any, existing in the conterminous U.S. Likewise, few areas exist that do not exhibit some impact 

from anthropogenic influences, be it noise, light, or air pollution; water quality or hydrological 

manipulations; past and current land management practices; road or trails, suppression of wildfires; 

invasions by pest species of plants and animals; or public uses. While allowing for the near-complete 

pervasiveness of modern society on the landscape, the spirit of the Wilderness Act is to protect lands that 

still retain the wilderness qualities of: 1) natural, 2) untrammeled, 3) undeveloped. These three qualities 

are cornerstones of wilderness character. For areas proposed or designated as wilderness, wilderness 

character must be monitored to determine baseline conditions and thereafter be periodically monitored to 

assess the condition of these wilderness qualities. Proposed and designated wilderness areas by law and 

policy are required to maintain wilderness character through management and/or restoration in perpetuity. 

Defining the first two qualities (natural and untrammeled) requires a knowledge and understanding of the 

ecological systems which are being evaluated as potential wilderness. Ecological systems are comprised 

of three primary attributes: composition, structure, function. Composition is the components that make up 

an ecosystem, such as the habitat types, native species of plants and animals, and abiotic (physical and 

chemical) features. These contribute to the diversity of the area. Structure is the spatial arrangement of the 

components that contribute to the complexity of the area. Composition and structure are evaluated to 

determine the naturalness of the area. Function is the processes that result from the interaction of the 

various components both temporally and spatially, and the disturbance processes that shape the landscape. 

These processes include but are not limited to predator-prey relationships, insect and disease outbreaks, 

nutrient and water cycles, decomposition, fire, windstorms, flooding, and both general and cyclic weather 

patterns. Ecological functions are evaluated to determine the wildness or untrammeled quality of the area. 

The third quality assessment is whether an area is undeveloped. Undeveloped refers to the absence of 

permanent structures such as roads, buildings, dams, fences, and other human alterations to the landscape. 

Exceptions can be made for historic structures or structures required for safety or health considerations, 

providing they are made of natural materials and relatively unobtrusive on the landscape. 
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Appendix E. Wilderness Review E-5

General guidelines used for evaluating areas for wilderness potential during this wilderness inventory 

process include: 

1) The area should provide a variety of habitat types and associated abiotic features, as well as a 

nearly complete complement of native plants and wildlife indicative of those habitat types. 

Pest species should comprise a negligible portion of the landscape. 

2) The area should be spatially complex (vertically and/or horizontally) and exhibit all levels of 

vegetation structure typical of the habitat type, have an interspersion of these habitats, and 

provide avenues for plant and wildlife dispersal. 

3) The area should retain the basic natural functions that define and shape the associated habitats 

including but not limited to flooding regimes, fire cycles, unaltered hydrology and flowage 

regimes, and basic predator-prey relationships including herbivory patterns. 

4) Due to their size, islands may not meet the habitat guidelines in 1 and 2 above. Islands 

should, however, exhibit the natural cover type with which it evolved and continue to be 

shaped and modified by natural processes. Islands should be further analyzed during the 

study portion of the review, if they provide habitat for a significant portion of a population, or 

key life cycle requirements for any resources of concern, or listed species. 

5) Potential wilderness areas should be relatively free of permanent structures or human 

alterations. Areas may be elevated to the study phase if existing structures or alterations can 

be removed or remediated within a reasonable timeframe, and prior to wilderness 

recommendation to the Secretary of the Interior. 

Rose Atoll’s remote location and difficult access have allowed nature to remain the primary sculpting 

force of the atoll’s resources, leaving ecological composition, structure, and function intact. Crustose 

coralline algae continue to build up the reef crest on the perimeter reef. The littoral forest and beach 

strand host colonies of seabirds and migratory shorebirds and nesting green turtles. Underwater, patch 

coral reefs and pinnacles support a dense community of fish, foraging green and hawksbill turtles, and 

faisua. There is a complete complement of native plants and wildlife indicative of habitat types with pest 

species comprising a negligible portion of the landscape. 

The 1993 grounding of the longliner Jin Shiang Fa and resultant oil spill and wreckage have not affected 

the Refuge’s overall naturalness, despite damages on the southwestern side of the perimeter reef. All 

visible debris from the grounding has been removed as of 2007 and the atoll continues to recover. Other 

forms of marine debris have been rarely observed and do not constitute a significant visual presence in the 

atoll. There is only one monument, which cannot be seen from the lagoon. 

Physical evidence of management and research activities are limited to a few monitoring plots on Rose 

Island and in reef areas, composed of PVC and steel, as well as infrequent, temporary field camps. These 

features are substantially unnoticeable in the Refuge as a whole. 

The Rose Atoll NWR meets the naturalness criteria for a wilderness study area. 

Evaluation of Supplemental Values 

Supplemental values are defined by the Wilderness Act as “ecological, geological, or other features of 

scientific, educational, scenic, or historic value.” 

One of the smallest atolls in the world, Rose supports the largest populations of giant clams, nesting sea 

turtles, nesting seabirds, and rare species of fish in American Samoa. The diversity of coral species in the 

atoll is significant given its small size. Rose Island is home to the only remaining Pisonia forest 

community in Samoa, and is also the most important seabird colony in the region due to the rat-free 
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E-6 Appendix E. Wilderness Review 

habitat. These resources, along with the atoll’s small size, well-defined boundaries, and limited 

anthropogenic influence make it of significant value for studying the processes of atoll systems. Healthy 

crustose coralline algae, the primary reef-building species, give Rose a striking pink hue. More water 

pours into the lagoon over the reef crest than exits the ava and causes the reef crest to grow higher, which 

makes it one of the few atolls with an elevated lagoon and enriches its scenic quality. The Refuge has 

ecological, geological, or other features of scientific and educational values which enhance wilderness 

characteristics. 

E.4 Inventory Summary and Conclusion 

Based on the analysis conducted above, Unit A meet the wilderness inventory criteria, therefore a 

wilderness study is recommended. 

Wilderness Inventory Analysis Inventory Unit A: Rose 

Atoll NWR (1,613 ac) 

(1) Has at least 5,000 acres of land or is of sufficient size to make 

practicable its preservation and use in an unconfined condition, or is a 

roadless island. 

Yes 

(2) Generally appears to have been affected primarily by the forces of 

nature, with the imprint of man’s work substantially unnoticeable. Yes 

(3a) Has outstanding opportunities for solitude. Yes 

(3b) Has outstanding opportunities for a primitive and unconfined type 

of recreation. Yes 

(4) Contains ecological, geological, or other features of scientific, 

educational, scenic, or historical value. 

Yes (ecological, geologic, 

scientific, educational value) 

Parcel qualifies as a wilderness study area (meets criteria 1, 2 & 3a or 

3b). Yes 

 
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Appendix E. Wilderness Review E-7

Figure E-1. Wilderness Inventory Unit A, Rose Atoll NWR. 

 
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E-8 Appendix E. Wilderness Review 

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Appendix F. Biological Resources of Concern F-1

Appendix F. Biological Resources of Concern 

F.1. Introduction 

Early in the planning process, the team cooperatively identified species, species groups, and communities 

of concern for the Refuge. A comprehensive list of these resources was compiled based on review of 

numerous plans, many of which highlight priority species or habitats for conservation. The 

Comprehensive Resources of Concern table was further culled in developing a more targeted assemblage 

of Priority Resources of Concern. Most of the biological emphasis of the CCP is focused on maintaining 

and restoring these priority resources. 

Definitions for the column headings in Table F-2 are as follows: 

 Focal Species: Species selected as representatives or indicators for the overall condition of the 

conservation target. In situations where the conservation target may include a broad variety of 

habitat structures and plant associations, several different conservation focal species may be 

listed. In addition, species with specific “niche” ecological requirements may be listed as a focal 

species. Management would be focused on attaining conditions required by the focal species. 

Other species utilizing the conservation target would generally be expected to benefit as a result 

of management for the focal species. 

 Habitat Type: The general habitat description utilized by the focal species. 

 Habitat Structure: The specific and measurable habitat attributes considered necessary to support 

the focal species. 

 Life-History Requirement: The general reason of use for the focal species. 

 Other Benefiting Species: Other species that are expected to benefit from management for the 

selected focal species. The list is not comprehensive; see Appendix A for a more complete list. 

Table F-1. Biological Integrity, Diversity, and Environmental Health 

Habitats Population/Habitat 

Attributes 

Natural processes 

responsible for these 

conditions 

Limiting Factors 

Lagoon Lagoon floor (to ~98 feet 

depth) and back reef 

composed of carbonate 

sand and rubble, with low 

coral and CCA cover (< 

1%). Hard-substrate 

pinnacles and patch reefs 

with moderate coral and 

CCA cover (>10%), 

supporting diverse fish 

assemblage and faisua 

Potential conservation 

species: faisua, sea turtles, 

candidate ESA coral 

species 

Intact perimeter reef 

(present-day height, 

width, biotic construction) 

and ava (present-day 

depth, width, location 

unblocked flow) that 

regulate seawater 

exchange with 

surrounding ocean and 

seawater flow inside 

lagoon; natural 

breakdown of calcifying 

organisms providing 

carbonate sediment 

Proliferation of cyanobacteria; 

illegal fishing and faisua 

poaching; reduced calcification 

linked to ocean acidification 
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F-2 Appendix F. Biological Resources of Concern 

Habitats Population/Habitat 

Attributes 

Natural processes 

responsible for these 

conditions 

Limiting Factors 

Perimeter 

Crustose 

Coralline 

Algal Reef 

Living reef dominated by 

CCA, with intact 

geomorphic structure 

providing mosaic of 

microhabitats for 

invertebrates including 

corals and sea urchins 

Potential conservation 

species: candidate ESA 

coral species 

Growth of CCA and other 

calcifying organisms, and 

accretion of carbonate 

through geochemical 

processes, maintains 

constructional platform 

between open ocean and 

inner lagoon 

Rate of SLR relative to natural 

capacities for growth and 

accretion; reduced calcification 

linked to ocean acidification; 

overgrowth by nonconstructional cyanobacteria 

Ava Unobstructed channel 

between lagoon and fore 

reef with present-day 

depth, width, and location 

Potential conservation 

species: faisua, sea turtles, 

candidate ESA coral 

species 

Natural hydrological 

regimes of oceanic and 

lagoonal seawater flow 

Impedance of natural flow 

patterns by boat grounding or 

other obstacles 

Beach 

Strand 

Beach strand habitat clear 

of invasive introduced 

plants and marine debris 

that provides nesting sites 

for ground-nesting seabirds 

and turtles and foraging 

sites for migratory 

shorebirds 

Sand and rubble formed 

by the action of storms 

and bio-erosion of living 

CCA reef community is 

deposited and re-arranged 

by ocean waves. Plant 

community on the beach 

strand areas are kept at 

seral stage by repeated 

overwashing and storms. 

Current sea level 

Non-native invasive species of 

plants and animals; human 

disturbance and trampling; 

interruption in the supply of 

gastropod shells from the reef 

that are used by land hermit 

crabs; sea level rise; reduced 

calcification linked to ocean 

acidification; increased storm 

frequency and intensity 

changing sediment distribution 

patterns 

Littoral 

Forest 

South Central tropical 

Pacific littoral forest with a 

native species composition 

typical of other intact 

habitats of similar rainfall 

and soil type. This forest 

provides nesting sites for 

arboreal and groundnesting seabirds as well as 

native land crabs, insects, 

and migratory shorebirds 

Nutrient input from 

seabird guano and 

precipitation favor pu’a 

vai and other species of 

plants dispersed by birds 

or ocean currents 

Non-native invasive species of 

plants, animals, and pathogens, 

human disturbance; SLR; 

reduced calcification linked to 

ocean acidification; increased 

storm frequency and intensity; 

changing sediment distribution 

patterns 
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Appendix F. Biological Resources of Concern F-3

Table F-2. Priority Resources of Concern 

Focal Species Habitat Type Habitat Structure Life History 

Requirements 

Other Benefiting 

Species 

Pu’a vai 

(Pisonia) 

Littoral Forest Sandy and phosphate 

soils with elevation 

sufficient to avoid 

overwashing in all but 

the largest storms (> 

6.6 feet) 

All Tree-nesting seabirds 

fua’o (red-footed 

booby), atafa (lesser 

frigatebird), atafa 

(great frigatebird), 

gogo (black noddy), 

white tern (manu 

sina) 

Littoral forest 

tree species – 

Cordia 

subcordata, 

Tournefortia 

argentea, 

Hernandia 

nymphaeifolia, 

Terminalia 

samoensis, 

Neisosperma 

oppositifolium, 

and Hibiscus 

tiliaceus

Littoral forest 

(mesic) 

Sandy and phosphate 

soils with elevation 

sufficient to avoid 

overwashing in all but 

the largest storms (> 

6.6 feet) 

All Matu’u (Pacific reef 

heron) for nesting 

habitat and aleva 

(long-tailed cuckoo) 

for wintering, 

molting, and foraging 

Tava’e’ula 

(red-tailed 

tropicbird) 

Littoral forest Ground under 

vegetation in 

understory and base of 

trees; sites that 

provide adequate 

shade for nestling for 

the duration of the 

growth period

Nesting Gogo (brown noddy), 

fua’o (brown booby)

Fua’o (redfooted booby)Littoral forest Tournefortia and 

Pisonia trees that 

provide appropriate 

structure for nest 

construction above the 

ground

Nesting Atafa (lesser 

frigatebird), atafa 

(great frigatebird), 

gogo (black noddy)

Land hermit 

crabs 

Coenobita 

perlatus and 

Coenobita 

brevimanus

Littoral forest Sandy and phosphate 

soils, vegetation and 

shade protection from 

tropical sun 

Reproduction – 

aquatic larvae, 

terrestrial adults, 

foraging, proximity 

to sea water source 

for osmoregulation 

and gill 

maintenance

Bristle-thighed 

curlews prey upon 

land hermit crabs. 

Entire forest 

community benefits 

from Coenobita

acting as scavengers 

and nutrient recyclers 
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F-4 Appendix F. Biological Resources of Concern 

Focal Species Habitat Type Habitat Structure Life History 

Requirements 

Other Benefiting 

Species 

Gogo uli 

(sooty tern)

Beach strand 

and littoral 

forest 

Open beach habitat or 

forest sites with 

minimal understory 

that provide open 

access for landing and 

takeoff and visibility 

for these highly social 

nesters 

Nesting Gogosina (graybacked tern), 

gogosina (blacknaped tern), bristlethighed curlews, 

ruddy turnstones that 

prey on sooty tern 

eggs

Tuli (bristlethighed 

curlew) 

Beach strand 

and littoral 

forest 

Open beach habitat or 

open forest 

Wintering, molting, 

feeding 

Tuli (ruddy 

turnstone), tuli 

(sanderling), tuli 

(wandering tattler), 

tuli (whimbrel), tuli 

(Pacific golden 

plover) 

I’a sa (green 

turtle) and 

laumei uga 

(hawksbill 

turtle) 

Beach 

strand/littoral 

forest/lagoon 

Sand with access to 

the water but above 

the high tide line 

Nesting (green 

turtle only), resting, 

feeding 

Tamole 

(yellow 

purslane, 

Portulaca 

lutea) 

Beach strand Open sand, no over 

story 

All 

Malie (gray 

reef shark) 

Lagoon, ava Pinnacles, patch reefs, 

back reefs 

All Malie alamata 

(blacktip reef shark), 

whitetip reef shark 

(Triaenodon obesus), 

Bumphead parrotfish, 

Maori wrasse, gatalauli (Peacock 

grouper), Leopard 

grouper, Coral hind, 

Strawberry grouper, 

mata’ele (Flagtail 

grouper), 

Honeycomb grouper, 

gatala-aloalo (Dwarf 

spotted grouper), 

Masked grouper 
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Appendix F. Biological Resources of Concern F-5

Focal Species Habitat Type Habitat Structure Life History 

Requirements 

Other Benefiting 

Species 

Amu (stony 

corals) 

Acropora, 

Astreopora, 

Cyphastrea, 

Favia, 

Leptastrea, 

Montastrea, 

Montipora, 

Pavona, 

Platygyra, 

Porites, 

Psammocora, 

Stylocoeniella 

spp. 

Reef crest, 

back reef, 

lagoon 

pinnacles and 

patch reefs 

Hard substrate, depth 

and water clarity 

sufficient for light 

penetration, moderate 

temperatures, seawater 

immersion time 

sufficient to prevent 

desiccation, low 

nutrients, low algae 

and cyanobacteria, 

herbivorous fish and 

invertebrates 

All (growth, feeding 

(endosymbiosis, and 

plankton capture), 

reproduction) 

Reef-associated fish; 

other benthic 

invertebrates (soft 

corals, mollusks, 

crustaceans, worms, 

echinoderms, 

tunicates) 

Faisua (giant 

clam) 

(Tridacna 

maxima) 

Lagoon 

pinnacles and 

patch reefs 

Hard substrate, water 

depth and clarity 

sufficient for light 

penetration 

All (growth, feeding 

(endosymbiosis, and 

filter-feeding), 

reproduction 

Sea urchins 

(tuitui) 

Reef crest, 

back reef, 

lagoon 

pinnacles and 

patch reefs 

Hard substrate, 

available holes for 

occupancy, algal films 

and turf for grazing

All (growth, 

grazing, 

reproduction) 

Corals, CCA 

Turban shells 

(Turbo 

crassus, Turbo 

setosus, Turbo 

argyrostomus)

Reef and 

lagoon habitats

CCA reef flats with 

epilithic algae for 

grazing

Foraging 

(herbivores and 

detritus feeders)

Land hermit crabs 

(Coenobita perlatus

and C. brevimanus) 

that use shells of 

these gastropods

Crustose 

coralline algae 

(Porolithon 

spp., 

Hydrolithon

spp.) 

Reef Hard substrate, 

moderate 

temperatures, low 

cyanobacteria, 

herbivorous fish and 

invertebrates 

All (growth, 

photosynthesis, 

reproduction) 

Stony corals 

 
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Appendix G. Integrated Pest Management Program G-1

Appendix G. Integrated Pest Management (IPM) Program 

G.1 Background 

The IPM is an interdisciplinary approach utilizing methods to prevent, eliminate, contain, and/or control 

pest species in concert with other management activities on refuge lands and waters to achieve wildlife 

and habitat management goals and objectives. IPM is also a scientifically based, adaptive management 

process where available scientific information and best professional judgment of the refuge staff as well 

as other resource experts would be used to identify and implement appropriate management strategies that 

can be modified and/or changed over time to ensure effective, site-specific management of pest species to 

achieve desired outcomes. In accordance with 43 CFR 46.145, adaptive management would be 

particularly relevant where long-term impacts may be uncertain and future monitoring would be needed to 

make adjustments in subsequent implementation decisions. After a tolerable pest population (threshold) is 

determined considering achievement of refuge resource objectives and the ecology of pest species, one or 

more methods, or combinations thereof, would be selected that are feasible, efficacious, and most 

protective of non-target resources, including native species (fish, wildlife, and plants), and Service 

personnel, Service authorized agents, volunteers, and the public. Staff time and available funding would 

be considered when determining feasibility/practicality of various treatments. 

IPM techniques to address pests are presented as CCP strategies (see Chapter 2 of this CCP) in an 

adaptive management context to achieve refuge resource objectives. In order to satisfy requirements for 

IPM planning as identified in the Director’s Memo (dated September 9, 2004) entitled Integrated Pest 

Management Plans and Pesticide Use Proposals: Updates, Guidance, and an Online Database, the 

following elements of an IPM program have been incorporated into this CCP: 

 Habitat and/or wildlife objectives that identify pest species and appropriate thresholds to indicate the 

need for and successful implementation of IPM techniques; and 

 Monitoring before and/or after treatment to assess progress toward achieving objectives including 

pest thresholds. 

Where pesticides would be necessary to address pests, this Appendix provides a structured procedure to 

evaluate potential effects of proposed uses involving ground-based applications to refuge biological 

resources and environmental quality in accordance with effects analyses (environmental consequences) of 

this CCP. Only pesticide uses that likely would cause minor, temporary, or localized effects to refuge 

biological resources and environmental quality with appropriate best management practices (BMPs), 

where necessary, would be allowed for use on the refuge. 

This Appendix does not describe the more detailed process to evaluate potential effects associated with 

aerial applications of pesticides. However, the basic framework to assess potential effects to refuge 

biological resources and environmental quality from aerial application of pesticides would be similar to 

the process described in this Appendix for ground-based treatments of other pesticides. 

G.2 Pest Management Laws and Policies 

In accordance with Service policy 569 FW 1 (Integrated Pest Management), plant, invertebrate, and 

vertebrate pests on units of the National Wildlife Refuge System can be controlled to ensure balanced 

wildlife and fish populations in support of refuge-specific wildlife and habitat management objectives. 

Pest control on Federal (refuge) lands and waters also is authorized under the following legal mandates: 
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 National Wildlife Refuge System Administration Act of 1966, as amended (16 USC 668dd-668ee); 

 Plant Protection Act of 2000 (7 USC 7701 et seq.); 

 Noxious Weed Control and Eradication Act of 2004 (7 USC 7781-7786, Subtitle E); 

 Federal Insecticide, Fungicide, and Rodenticide Act of 1996 (7 USC 136-136y); 

 National Invasive Species Act of 1996 (16 USC 4701); 

 Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990 (16 USC 4701); 

 Food Quality Protection Act of 1996 (7 USC 136); 

 Executive Order 13148, Section 601(a); 

 Executive Order 13112; and 

 Animal Damage Control Act of 1931 (7 USC 426-426c, 46 Stat. 1468). 

Pests are defined as “... living organisms that may interfere with the site-specific purposes, operations, or 

management objectives or that jeopardize human health or safety” from Department policy 517 DM 1 

(Integrated Pest Management Policy). Similarly, 569 FW 1 defines pests as “... invasive plants and 

introduced or native organisms that may interfere with achieving our management goals and objectives on 

or off our lands, or that jeopardize human health or safety.” 517 DM 1 also defines an invasive species as 

“a species that is non-native to the ecosystem under consideration and whose introduction causes or is 

likely to cause economic or environmental harm or harm to human health.” Throughout the remainder of 

this CCP, the terms pest and invasive species are used interchangeably because both can prevent/impede 

achievement of refuge wildlife and habitat objectives and/or degrade environmental quality. 

In general, control of pests (vertebrate or invertebrate) on the refuge would conserve and protect the 

nation’s fish, wildlife, and plant resources as well as maintain environmental quality. From 569 FW 1, 

animal or plant species, which are considered pests, may be managed if the following criteria are met: 

 Threat to human health and well being or private property, the acceptable level of damage by the pest 

has been exceeded, or State or local government has designated the pest as noxious; 

 Detrimental to resource objectives as specified in a refuge resource management plan (e.g., 

comprehensive conservation plan, habitat management plan), if available; and 

 Control would not conflict with attainment of resource objectives or the purpose(s) for which the 

refuge was established. 

The specific justifications for pest management activities on the refuge are the following: 

 Protect human health and well being; 

 Prevent substantial damage to important to refuge resources; 

 Protect newly introduced or re-establish native species; 

 Control non-native (exotic) species in order to support existence for populations of native species; 

 Prevent damage to private property; and 

 Provide the public with quality, compatible wildlife-dependent recreational opportunities. 

In accordance with Service policy 620 FW 1 (Habitat Management Plans), there are additional 

management directives regarding invasive species found on the refuge: 

 “We are prohibited by Executive Order, law, and policy from authorizing, funding, or carrying out 

actions that are likely to cause or promote the introduction or spread of invasive species in the United 

States or elsewhere.” 

 “Manage invasive species to improve or stabilize biotic communities to minimize unacceptable 

change to ecosystem structure and function and prevent new and expanded infestations of invasive 
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species. Conduct refuge habitat management activities to prevent, control, or eradicate invasive 

species...” 

Animal species damaging/destroying Federal property and/or detrimental to the management program of 

a refuge may be controlled as described in 50 CFR 31.14 (Official Animal Control Operations). For 

example, on the mainland, the incidental removal of beaver damaging refuge infrastructure (e.g., clogging 

with subsequent damaging of water control structures) and/or negatively affecting habitats (e.g., removing 

woody species from existing or restored riparian areas) managed on refuge lands may be conducted 

without a pest control proposal. Exotic nutria, whose denning and burrowing activities in wetland dikes 

causes cave-ins and breaches, can be controlled using the most effective techniques considering sitespecific factors without a pest control proposal. Along with the loss of quality wetland habitats associated 

with breaching of impoundments, the safety of refuge staffs and public (e.g., auto tour routes) driving on 

structurally compromised levees and dikes can be threaten by sudden and unexpected cave-ins. 

Trespass and feral animals also may be controlled on refuge lands. Based upon 50 CFR 28.43 

(Destruction of Dogs and Cats), dogs and cats running at large on a national wildlife refuge and observed 

in the act of killing, injuring, harassing or molesting humans or wildlife may be disposed of in the interest 

of public safety and protection of the wildlife. Feral animals should be disposed by the most humane 

method(s) available and in accordance with relevant Service directives (including Executive Order 

11643). Disposed wildlife specimens may be donated or loaned to public institutions. Donation or loans 

of resident wildlife species would only be made after securing State approval (50 CFR 30.11 [Donation 

and Loan of Wildlife Specimens]). Surplus wildlife specimens may be sold alive or butchered, dressed 

and processed subject to federal and state laws and regulations (50 CFR 30.12 [Sale of Wildlife 

Specimens]).

G.3 Strategies 

To fully embrace IPM as identified in 569 FW 1, the following strategies, where applicable, would be 

carefully considered on the refuge for each pest species: 

 Prevention. This is would be the most effective and least expensive long-term management option 

for pests. It encompasses methods to prevent new introductions or the spread of the established pests 

to un-infested areas. It requires identifying potential routes of invasion to reduce the likelihood of 

infestation. Hazard Analysis and Critical Control Points (HACCP) planning can be used determine if 

current management activities on a refuge may introduce and/or spread invasive species in order to 

identify appropriate BMPs for prevention. See http://www.haccp-nrm.org/ for more information about 

HACCP planning. 

Prevention may include source reduction, using pathogen-free or weed-free seeds or fill; exclusion 

methods (e.g., barriers) and/or sanitation methods (e.g., wash stations) to prevent re-introductions by 

various mechanisms including vehicles, personnel, livestock, and horses. Because invasive species 

are frequently the first to establish newly disturbed sites, prevention would require a reporting 

mechanism for early detection of new pest occurrences with quick response to eliminate any new 

satellite pest populations. Prevention would require consideration of the scale and scope of land 

management activities that may promote pest establishment within un-infested areas or promote 

reproduction and spread of existing populations. Along with preventing initial introduction, 

prevention would involve halting the spread of existing infestations to new sites (Mullin et al. 2000). 

The primary reason for prevention would be to keep pest-free lands or waters from becoming 

infested. Executive Order 11312 emphasizes the priority for prevention with respect to managing 

pests. 
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The following would be methods to prevent the introduction and/or spread of pests on refuge lands: 

o Before beginning ground-disturbing activities (e.g., disking, scraping), inventory and 

prioritize pest infestations in project operating areas and along access routes. Refuge staff 

would identify pest species on site or within reasonably expected potential invasion vicinity. 

Where possible, the refuge staff would begin project activities in un-infested areas before 

working in pest-infested areas. 

o The refuge staff would locate and use pest-free project staging areas. They would avoid or 

minimize travel through pest-infested areas, or restrict to those periods when spread of seed 

or propagules of invasive plants would be least likely. 

o The refuge staff would determine the need for, and when appropriate, identify sanitation sites 

where equipment can be cleaned of pests. Where possible, the refuge staff would clean 

equipment before entering lands at on-refuge approved cleaning site(s). This practice does not 

pertain to vehicles traveling frequently in and out of the project area that will remain on 

roadways. Seeds and plant parts of pest plants would need to be collected, where practical. 

The refuge staff would remove mud, dirt, and plant parts from project equipment before 

moving it into a project area. 

o The refuge staff would clean all equipment, before leaving the project site, if operating in 

areas infested with pests. The refuge staff would determine the need for, and when 

appropriate, identify sanitation sites where equipment can be cleaned. 

o Refuge staffs, their authorized agents, and refuge volunteers would, where possible, inspect, 

remove, and properly dispose of seed and parts of invasive plants found on their clothing and 

equipment. Proper disposal means bagging the seeds and plant parts and then properly 

discarding of them (e.g., incinerating). 

o The refuge staff would evaluate options, including closure, to restrict the traffic on sites with 

on-going restoration of desired vegetation. The refuge staff would revegetate disturbed soil 

(except travel ways on surfaced projects) to optimize plant establishment for each specific 

site. Revegetation may include topsoil replacement, planting, seeding, fertilization, liming, 

and weed-free mulching as necessary. The refuge staff would use native material, where 

appropriate and feasible. The refuge staff would use certified weed-free or weed-seed-free 

hay or straw where certified materials are reasonably available. 

o The refuge staff would provide information, training and appropriate pest identification 

materials to permit holders, and recreational visitors. The refuge staff would educate them 

about pest identification, biology, impacts, and effective prevention measures. 

o The refuge staff would require grazing permittees to utilize preventative measure for their 

livestock while on refuge lands. 

o The refuge staff would inspect borrow material for invasive plants prior to use and transport 

onto and/or within refuge lands. 

o The refuge staff would consider invasive plants in planning for road maintenance activities. 

o The refuge staff would restrict off road travel to designated routes. 

The following would be methods to prevent the introduction and/or spread of pests into refuge waters: 

o The refuge staff would inspect boats (including air boats), trailers, and other boating 

equipment. Where possible, the refuge staff would remove any visible plants, animals, or 

mud before leaving any waters or boat launching facilities. Where possible, the refuge staff 

would drain water from motor, live well, bilge, and transom wells while on land before 

leaving the site. 

o If possible, the refuge staff would wash and dry boats, downriggers, anchors, nets, floors of 

boats, propellers, axles, trailers, and other boating equipment to kill pests not visible at the 

boat launch. 
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o Where feasible, the refuge staff would maintain a 100-foot buffer of aquatic pest-free 

clearance around boat launches and docks or quarantine areas when cleaning around culverts, 

canals, or irrigation sites. Where possible, the refuge staff would inspect and clean equipment 

before moving to new sites or one project area to another. 

These prevention methods to minimize/eliminate the introduction and/or spread of pests were taken 

verbatim or slightly modified from Appendix E of USFS (2005). 

 Mechanical/Physical Methods. These methods would remove and destroy, disrupt the growth of, or 

interfere with the reproduction of pest species. For plants species, these treatments can be 

accomplished by hand, hand tool (manual), or power tools (mechanical) and include pulling, 

grubbing, digging, tilling/disking, cutting, swathing, grinding, sheering, girdling, mowing, and 

mulching of the pest plants. 

For animal species, Service employees or their authorized agents could use mechanical/physical 

methods (including trapping) to control pests as a refuge management activity. Based upon 50 CFR 

31.2, trapping can be used on a refuge to reduce surplus wildlife populations for a “balanced 

conservation program” in accordance with Federal or state laws and regulations. In some cases, nonlethally trapped animals would be relocated to off-refuge sites with prior approval from the state. 

Each of these tools would be efficacious to some degree and applicable to specific situations. In 

general, mechanical controls can effectively control annual and biennial pest plants. However, to 

control perennial plants, the root system has to be destroyed or it would resprout and continue to grow 

and develop. Mechanical controls are typically not capable of destroying a perennial plant’s root 

system. Although some mechanical tools (e.g., disking, plowing) may damage root systems, they may 

stimulate regrowth producing a denser plant population that may aid in the spread depending upon the 

target species. In addition, steep terrain and soil conditions would be major factors that can limit the 

use of many mechanical control methods. 

Some mechanical control methods (e.g., mowing), which would be used in combination with 

herbicides, can be a very effective technique to control perennial species. For example, mowing 

perennial plants followed sequentially by treating the plant regrowth with a systemic herbicide often 

would improve the efficacy of the herbicide compared to herbicide treatment only. 

 Cultural Methods. These methods would involve manipulating habitat to increase pest mortality by 

reducing its suitability to the pest. Cultural methods would include water-level manipulation, 

mulching, winter cover crops, changing planting dates to minimize pest impact, prescribed burning 

(facilitate revegetation, increase herbicide efficacy, and remove litter to assist in emergence of 

desirable species), flaming with propane torches, trap crops, crop rotations that would include nonsusceptible crops, moisture management, addition of beneficial insect habitat, reducing clutter, proper 

trash disposal, planting or seeding desirable species to shade or out-compete invasive plants, applying 

fertilizer to enhance desirable vegetation, prescriptive grazing, and other habitat alterations. 

 Biological Control Agents. Classical biological control would involve the deliberate introduction 

and management of natural enemies (parasites, predators, or pathogens) to reduce pest populations. 

Many of the most ecologically or economically damaging pest species in the United States originated 

in foreign countries. These newly introduced pests, which are free from natural enemies found in their 

country or region of origin, may have a competitive advantage over cultivated and native species. 

This competitive advantage often allows introduced species to flourish, and they may cause 

widespread economic damage to crops or out compete and displace native vegetation. Once the 

introduced pest species population reaches a certain level, traditional methods of pest management 
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may be cost-prohibitive or impractical. Biological controls typically are used when these pest 

populations have become so widespread that eradication or effective control would be difficult or no 

longer practical. 

Biological control has advantages as well as disadvantages. Benefits would include reducing pesticide 

usage, host specificity for target pests, long-term self-perpetuating control, low cost/acre, capacity for 

searching and locating hosts, synchronizing biological control agents to hosts’ life cycles, and the 

unlikelihood that hosts would develop resistance to agents. Disadvantages would include the 

following: limited availability of agents from their native lands, the dependence of control on target 

species density, slow rate at which control occurs, biotype matching, the difficulty and expense of 

conflicts over control of the target pest, and host specificity when host populations are low. 

A reduction in target species populations from biological controls is typically a slow process, and 

efficacy can be highly variable. It may not work well in a particular area although it does work well in 

other areas. Biological control agents would require specific environmental conditions to survive over 

time. Some of these conditions are understood; whereas, others are only partially understood or not at 

all. 

Biological control agents would not eradicate a target pest. When using biological control agents, 

residual levels of the target pest typically are expected; the agent population level or survival would 

be dependent upon the density of its host. After the pest population decreases, the population of the 

biological control agent would decrease correspondingly. This is a natural cycle. Some pest 

populations (e.g., invasive plants) would tend to persist for several years after a biological control 

agent becomes established due to seed reserves in the soil, inefficiencies in the agents search 

behavior, and the natural lag in population buildup of the agent. 

The full range of pest groups potentially found on refuge lands and waters would include diseases, 

invertebrates (insects, mollusks), vertebrates, and invasive plants (the most common group). Often it 

is assumed that biological control would address many if not most of these pest problems. There are 

several well-documented success stories of biological control of invasive weed species in the Pacific 

Northwest including Mediterranean sage, St. Johnswort (Klamath weed) and tansy ragwort. Emerging 

success stories include Dalmatian toadflax, diffuse knapweed, leafy spurge, purple loosestrife, and 

yellow star thistle. However, historically, each new introduction of a biological control agent in the 

United States has only about a 30% success rate (Coombs et al. 2004). Refer to Coombs et al. (2004) 

for the status of biological control agents for invasive plants. 

Introduced species without desirable close relatives in the United States would generally be selected 

as biological controls. Natural enemies that are restricted to one or a few closely related plants in their 

country of origin are targeted as biological controls (Center et al. 1997, Hasan and Ayres 1990). 

The refuge staff would ensure introduced agents are approved by the applicable authorities. Except 

for a small number of formulated biological control products registered by EPA under FIFRA, most 

biological control agents are regulated by the US Department of Agriculture (USDA)-Animal Plant 

Health Inspection Service, Plant Protection and Quarantine (APHIS-PPQ). State departments of 

agriculture and, in some cases, county agricultural commissioners or weed districts, have additional 

approval authority. 

Federal permits (USDA-APHIS-PPQ Form 526) are required to import biocontrols agents from 

another state. Form 526 may be obtained by writing: 
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Appendix G. Integrated Pest Management Program G-7

 USDA-APHIS-PPQ 

 Biological Assessment and Taxonomic Support 

 4700 River Road, Unit 113 

 Riverdale, MD 20737 

Or through the internet at http://www.aphis.usda.gov/ppq/permits/bioligical/weedbio.html. 

The Service strongly supports the development, and legal and responsible use of appropriate, safe, 

and effective biological control agents for nuisance and non-indigenous or pest species. 

State and county agriculture departments may also be sources for biological control agents or they 

may have information about where biological control agents may be obtained. Commercial sources 

should have an Application and Permit to Move Live Plant Pests and Noxious Weeds (USDA-PPQ 

Form 226 USDA-APHIS-PPQ, Biological Assessment and Taxonomic Support, 4700 River Road, 

Unit 113, Riverdale, MD 20737) to release specific biological control agents in a state and/or county. 

Furthermore, certification regarding the biological control agent’s identity (genus, specific epithet, 

sub-species and variety) and purity (e.g., parasite free, pathogen free, and biotic and abiotic 

contaminants) should be specified in purchase orders. 

Biological control agents are subject to 7 RM 8 (Exotic Species Introduction and Management). In 

addition, the refuge staff would follow the International Code of Best Practice for Classical Biological 

Control of Weeds (http://sric.ucdavis.edu/exotic /exotic.htm) as ratified by delegates to the X 

International Symposium on Biological Control of Weeds, Bozeman, MT, July 9, 1999. This code 

identifies the following: 

o Release only approved biological control agents; 

o Use the most effective agents; 

o Document releases; and 

o Monitor for impact to the target pest, and non-target species and the environment. 

Biological control agents formulated as pesticide products and registered by the USEPA (e.g., Bti) are 

also subject to PUP review and approval (see below). 

A record of all releases would be maintained with date(s), location(s), and environmental conditions 

of the release site(s); the identity, quantity, and condition of the biological control agents released; 

and other relevant data and comments such as weather conditions. Systematic monitoring to 

determine the establishment and effectiveness of the release is also recommended. 

The NEPA documents regarding biological and other environmental effects of biological control 

agents prepared by another federal agency, where the scope is relevant to evaluation of releases on 

refuge lands, would be reviewed. Possible source agencies for such NEPA documents include the 

Bureau of Land Management, US Forest Service, National Park Service, US Department of 

Agriculture-Animal Plant Health Inspection Service, and the military services. It might be appropriate 

to incorporate by reference parts or all of existing document(s) from the review. Incorporating by 

reference (43 CFR 46.135) is a technique used to avoid redundancies in analysis. It also can reduce 

the bulk of a Service NEPA document, which only must identify the documents that are incorporated 

by reference. In addition, relevant portions must be summarized in the Service NEPA document to the 

extent necessary to provide the decision maker and public with an understanding of relevance of the 

referenced material to the current analysis. 
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 Pesticides. The selective use of pesticides would be based upon pest ecology (including mode of 

reproduction), the size and distribution of its populations, site-specific conditions (e.g., soils, 

topography), known efficacy under similar site conditions, and the capability to utilize best 

management practices (BMPs) to reduce/eliminate potential effects to non-target species, sensitive 

habitats, and potential to contaminate surface and groundwater. All pesticide usage (pesticide, target 

species, application rate, and method of application) would comply with the applicable federal 

(FIFRA) and state regulations pertaining to pesticide use, safety, storage, disposal, and reporting. 

Before pesticides can be used to eradicate, control, or contain pests on refuge lands and waters, 

pesticide use proposals (PUPs) would be prepared and approved in accordance with 569 FW 1. The 

PUP records would provide a detailed, time-, site-, and target-specific description of the proposed use 

of pesticides on the Refuge. All PUPs would be created, approved or disapproved, and stored in the 

Pesticide Use Proposal System (PUPS), which is a centralized database only accessible on the 

Service’s intranet (https://systems.fws.gov/pups). Only Service employees would be authorized to 

access PUP records for a refuge in this database. 

Application equipment would be selected to provide site-specific delivery to target pests while 

minimizing/eliminating direct or indirect (e.g., drift) exposure to non-target areas and degradation of 

surface and groundwater quality. Where possible, target-specific equipment (e.g., backpack sprayer, 

wiper) would be used to treat target pests. Other target-specific equipment to apply pesticides would 

include soaked wicks or paint brushes for wiping vegetation and lances, hatchets, or syringes for 

direct injection into stems. Granular pesticides may be applied using seeders or other specialized 

dispensers. In contrast, aerial spraying (e.g., fixed wing or helicopter) would only be used where 

access is difficult (remoteness) and/or the size/distribution of infestations precludes practical use of 

ground-based methods. 

Because repeated use of one pesticide may allow resistant organisms to survive and reproduce, 

multiple pesticides with variable modes of action would be considered for treatments on refuge lands 

and waters. This is especially important if multiple applications within years and/or over a growing 

season likely would be necessary for habitat maintenance and restoration activities to achieve 

resource objectives. Integrated chemical and non-chemical controls also are highly effective, where 

practical, because pesticide resistant organisms can be removed from the site. 

Cost may not be the primary factor in selecting a pesticide for use on a refuge. If the least expensive 

pesticide would potentially harm natural resources or people, then a different product would be 

selected, if available. The most efficacious pesticide available with the least potential to degrade 

environment quality (soils, surface water, and groundwater) as well as least potential effect to native 

species and communities of fish, wildlife, plants, and their habitats would be acceptable for use on 

refuge lands in the context of an IPM approach. 

 Habitat restoration/maintenance. Restoration and/or proper maintenance of refuge habitats 

associated with achieving wildlife and habitat objectives would be essential for long-term prevention, 

eradication, or control (at or below threshold levels) of pests. Promoting desirable plant communities 

through the manipulation of species composition, plant density, and growth rate is an essential 

component of invasive plant management (Masters et al. 1996, Masters and Sheley 2001, Brooks et 

al. 2004). The following three components of succession could be manipulated through habitat 

maintenance and restoration: site availability, species availability, and species performance (Cox and 

Anderson 2004). Although a single method (e.g., herbicide treatment) may eliminate or suppress pest 

species in the short term, the resulting gaps and bare soil create niches that are conducive to further 

invasion by the species and/or other invasive plants. On degraded sites where desirable species are 

absent or in low abundance, revegetation with native/desirable grasses, forbs, and legumes may be 

necessary to direct and accelerate plant community recovery, and achieve site-specific objectives in a 
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reasonable time frame. The selection of appropriate species for revegetation would be dependent on a 

number of factors including resource objectives and site-specific, abiotic factors (e.g., soil texture, 

precipitation/temperature regimes, and shade conditions). Seed availability and cost, ease of 

establishment, seed production, and competitive ability also would be important considerations. 

G.4 Priorities for Treatments 

For many refuges, the magnitude (number, distribution, and sizes of infestations) of pest problems is too 

extensive and beyond the available capital resources to effectively address during any single field season. 

To manage pests on the Refuge, it would be essential to prioritize treatment of infestations. Highest 

priority treatments would be focused on early detection and rapid response to eliminate infestations of 

new pests, if possible. This would be especially important for aggressive pests potentially impacting 

species, species groups, communities, and/or habitats associated refuge purpose(s), NWRS resources of 

concern (Federally listed species, migratory birds, selected marine mammals, and interjurisdictional fish), 

and native species for maintaining/restoring biological integrity, diversity, and environmental health. 

The next priority would be treating established pests that appear in one or more previously un-infested 

areas. Moody and Mack (1988) demonstrated through modeling that small, new outbreaks of invasive 

plants eventually would infest an area larger than the established, source population. They also found that 

control efforts focusing on the large, main infestation rather than the new, small satellites reduced the 

chances of overall success. The lowest priority would be treating large infestations (sometimes monotypic 

stands) of well established pests. In this case, initial efforts would focus upon containment of the 

perimeter followed by work to control/eradicate the established infested area. If containment and/or 

control of a large infestation is not effective, then efforts would focus upon halting pest reproduction or 

managing source populations. Maxwell et al. (2009) found treating fewer populations that are sources 

represents an effective long-term strategy to reduce of total number of invasive populations and 

decreasing meta population growth rates. 

Although state-listed noxious weeds would always be of high priority for management, other pest species 

known to cause substantial ecological impact would also be considered. For example, cheatgrass may not 

be listed by a state as noxious, but it can greatly alter fire regimes in shrub steppe habitats resulting in 

large monotypic stands that displace native bunch grasses, forbs, and shrubs. Pest control would likely 

require a multi-year commitment from the refuge staff. Essential to the long-term success of pest 

management would be pre- and post-treatment monitoring, assessment of the successes and failures of 

treatments, and development of new approaches when proposed methods do not achieve desired 

outcomes. 

G.5 Best Management Practices (BMPs) 

The BMPs can minimize or eliminate possible effects associated with pesticide usage to non-target 

species and/or sensitive habitats as well as degradation of water quality from drift, surface runoff, or 

leaching. Based upon the Department of the Interior Pesticide Use Policy (517 DM 1) and the Service 

Integrated Pest Management policy (569 FW 1), the use of applicable BMPs (where feasible) also would 

likely ensure that pesticide uses may not adversely affect federally listed species and/or their critical 

habitats through determinations made using the process described in 50 CFR part 402. 

The following are BMPs pertaining to mixing/handling and applying pesticides for all ground-based 

treatments of pesticides, which would be considered and utilized, where feasible, based upon target- and 

site-specific factors and time-specific environmental conditions. Although not listed below, the most 
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important BMP to eliminate/reduce potential impacts to non-target resources would be an IPM approach 

to prevent, control, eradicate, and contain pests. 

G.5.1 Pesticide Handling and Mixing 

 As a precaution against spilling, spray tanks would not be left unattended during filling. 

 All pesticide containers would be triple rinsed and the rinsate would be used as water in the sprayer 

tank and applied to treatment areas. 

 All pesticide spray equipment would be properly cleaned. Where possible, rinsate would be used as 

part of the make-up water in the sprayer tank and applied to treatment areas. 

 The refuge staff would dispose of triple rinse and recycle (where feasible) pesticide containers. 

 All unused pesticides would be properly discarded at a local “safe send” collection. 

 Pesticides and pesticide containers would be lawfully stored, handled, and disposed of in accordance 

with the label and in a manner safeguarding human health, fish, and wildlife and prevent soil and 

water contaminant. 

 The refuge staff would consider the water quality parameters (e.g., pH, hardness) that are important to 

ensure greatest efficacy where specified on the pesticide label. 

 All pesticide spills would be addressed immediately using procedures identified in the refuge spill 

response plan. 

G.5.2 Applying Pesticides 

 Pesticide treatments would only be conducted by or under the supervision of Service personnel and 

non-Service applicators with the appropriate, state or Bureau of Land Management certification to 

safely and effectively conduct these activities on refuge lands and waters. 

 The refuge staff would comply with all federal, state, and local pesticide use laws and regulations as 

well as Departmental, Service, and Refuge System pesticide-related policies. For example, the refuge 

staff would use application equipment and apply rates for the specific pest(s) identified on the 

pesticide label as required under FIFRA. 

 Before each treatment season and prior to mixing or applying any product for the first time each 

season, all applicators would review the labels, MSDSs, and PUPs for each pesticide, determining the 

target pest, appropriate mix rate(s), PPE, and other requirements listed on the pesticide label. 

 A 1-ft no-spray buffer from the water’s edge would be used, where applicable, and where it does not 

detrimentally influence effective control of pest species. 

 Use low impact herbicide application techniques (e.g., spot treatment, cut stump, oil basal, Thinvert 

system applications) rather than broadcast foliar applications (e.g., boom sprayer, other larger tank 

wand applications), where practical. 

 Use low volume rather than high volume foliar applications where low impact methods above are not 

feasible or practical, to maximize herbicide effectiveness and ensure correct and uniform application 

rates. 

 Applicators would use and adjust spray equipment to apply the coarsest droplet size spectrum with 

optimal coverage of the target species while reducing drift. 

 Applicators would use the largest droplet size that results in uniform coverage. 

 Applicators would use drift reduction technologies such as low-drift nozzles, where possible. 

 Where possible, spraying would occur during low (average <7 mph and preferably 3-5 mph) and 

consistent direction wind conditions with moderate temperatures (typically <85o

F). 

 Where possible, applicators would avoid spraying during inversion conditions (often associated with 

calm and very low wind conditions) that can cause large-scale herbicide drift to non-target areas. 
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Appendix G. Integrated Pest Management Program G-11

 Equipment would be calibrated regularly to ensure that the proper rate of pesticide is applied to the 

target area or species. 

 Spray applications would be made at the lowest height for uniform coverage of target pests to 

minimize/eliminate potential drift. 

 If windy conditions frequently occur during afternoons, spraying (especially boom treatments) would 

typically be conducted during early morning hours. 

 Spray applications would not be conducted on days with >30% forecast for rain within 6 hours, 

except for pesticides that are rapidly rain fast (e.g., glyphosate in 1 hour) to minimize/eliminate 

potential runoff. 

 Where possible, applicators would use drift retardant adjuvants during spray applications, especially 

adjacent to sensitive areas. 

 Where possible, applicators would use a non-toxic dye to aid in identifying target area treated as well 

as potential over spray or drift. A dye can also aid in detecting equipment leaks. If a leak is 

discovered, the application would be stopped until repairs can be made to the sprayer. 

 For pesticide uses associated with cropland and facilities management, buffers, as appropriate, would 

be used to protect sensitive habitats, especially wetlands and other aquatic habitats. 

 When drift cannot be sufficiently reduced through altering equipment set up and application 

techniques, buffer zones may be identified to protect sensitive areas downwind of applications. The 

refuge staff would only apply adjacent to sensitive areas when the wind is blowing the opposite 

direction. 

 Applicators would utilize scouting for early detection of pests to eliminate unnecessary pesticide 

applications. 

 The refuge staff would consider timing of application so native plants are protected (e.g., senescence) 

while effectively treating invasive plants. 

 Rinsate from cleaning spray equipment after application would be recaptured and reused or applied to 

an appropriate pest plant infestation. 

 Application equipment (e.g., sprayer, all-terrain vehicle, tractor) would be thoroughly cleaned and 

personal protective equipment (PPE) would be removed/disposed of on-site by applicators after 

treatments to eliminate the potential spread of pests to un-infested areas. 

G.6 Safety 

G.6.1 Personal Protective Equipment 

All applicators would wear the specific PPE identified on the pesticide label. The appropriate PPE would 

be worn at all times during handling, mixing, and applying. PPE can include the following: disposable 

(e.g., Tyvek) or laundered coveralls; gloves (latex, rubber, or nitrile); rubber boots; and/or an NIOSHapproved respirator. Because exposure to concentrated product is usually greatest during mixing, extra 

care should be taken while preparing pesticide solutions. Persons mixing these solutions can be best 

protected if they wear long gloves, an apron, footwear, and a face shield. 

Coveralls and other protective clothing used during an application would be laundered separately from 

other laundry items. Transporting, storing, handling, mixing and disposing of pesticide containers would 

be consistent with label requirements, EPA and OSHA requirements, and Service policy. 

If a respirator is necessary for a pesticide use, then the following requirements would be met in 

accordance with Service safety policy: a written Respirator Program, fit testing, physical examination 

(including pulmonary function and blood work for contaminants), and proper storage of the respirator. 
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G-12 Appendix G. Integrated Pest Management Program 

G.6.2 Notification 

The restricted entry interval (REI) is the time period required after the application at which point someone 

may safely enter a treated area without PPE. Refuge staff, authorized management agents of the Service, 

volunteers, and members of the public who could be in or near a pesticide treated area within the stated 

re-entry time period on the label would be notified about treatment areas. Posting would occur at any site 

where individuals might inadvertently become exposed to a pesticide during other activities on the 

Refuge. Where required by the label and/or state-specific regulations, sites would also be posted on its 

perimeter and at other likely locations of entry. The refuge staff would also notify appropriate private 

property owners of an intended application, including any private individuals who have requested 

notification. Special efforts would be made to contact nearby individuals who are beekeepers or who have 

expressed chemical sensitivities. 

G.6.3 Medical Surveillance 

Medical surveillance may be required for Service personnel and approved volunteers who mix, apply, 

and/or monitor use of pesticides (see 242 FW 7 [Pesticide Users] and 242 FW 4 [Medical Surveillance]). 

In accordance with 242 FW 7.12A, Service personnel would be medically monitoring if one or more of 

the following criteria is met: exposed or may be exposed to concentrations at or above the published 

permissible exposure limits or threshold limit values (see 242 FW 4); use pesticides in a manner 

considered “frequent pesticide use”; or use pesticides in a manner that requires a respirator (see 242 FW 

14 for respirator use requirements). In 242 FW 7.7A, “Frequent Pesticide Use means when a person 

applying pesticide handles, mixes, or applies pesticides, with a Health Hazard rating of 3 or higher, for 8 

or more hours in any week or 16 or more hours in any 30-day period.” Under some circumstances, 

individuals may be medically monitored who use pesticides infrequently (see Section G.7.7), experience 

an acute exposure (sudden, short-term), or use pesticides with a health hazard ranking of 1 or 2. This 

decision would consider the individual’s health and fitness level, the pesticide’s specific health risks, and 

the potential risks from other pesticide-related activities. Refuge cooperators (e.g., cooperative farmers) 

and other authorized agents (e.g., state and county employees) would be responsible for their own medical 

monitoring needs and costs. 

Standard examinations (at refuge expense) of appropriate refuge staff would be provided by the nearest 

certified occupational health and safety physician as determined by Federal Occupational Health. 

G.6.4 Certification and Supervision of Pesticide Applicators 

Appropriate refuge staff or approved volunteers handling, mixing, and/or applying or directly supervising 

others engaged in pesticide use activities would be trained and state or federally (BLM) licensed to apply 

pesticides to refuge lands or waters. In accordance with 242 FW 7.18A and 569 FW 1.10B, certification is 

required to apply restricted use pesticides based upon EPA regulations. For safety reasons, all individuals 

participating in pest management activities with general use pesticides also are encouraged to attend 

appropriate training or acquire pesticide applicator certification. The certification requirement would be 

for a commercial or private applicator depending upon the state. New staff unfamiliar with proper 

procedures for storing, mixing, handling, applying, and disposing of herbicides and containers would 

receive orientation and training before handling or using any products. Documentation of training would 

be kept in the files at the refuge office. 
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Appendix G. Integrated Pest Management Program G-13

G.6.5 Record Keeping 

G.6.5.1 Labels and material safety data sheets 

Pesticide labels and material safety data sheets (MSDSs) would be maintained at the refuge shop and 

laminated copies in the mixing area. These documents also would be carried by field applicators, where 

possible. A written reference (e.g., note pad, chalk board, dry erase board) for each tank to be mixed 

would be kept in the mixing area for quick reference while mixing is in progress. In addition, approved 

PUPs stored in the PUPS database typically contain website links (URLs) to pesticide labels and MSDSs. 

G.6.5.2 Pesticide use proposals (PUPs) 

A PUP would be prepared for each proposed pesticide use associated with annual pest management on 

refuge lands and waters. A PUP would include specific information about the proposed pesticide use 

including the common and chemical names of the pesticide(s), target pest species, size and location of 

treatment site(s), application rate(s) and method(s), and federally listed species determinations, where 

applicable. 

In accordance with Service guidelines (Director’s memo [December 12, 2007]), a refuge staff may 

receive up to 5-year approvals for Washington Office and field reviewed proposed pesticide uses based 

upon meeting identified criteria including an approved IPM plan, where necessary 

(http://www.fws.gov/contaminants/Issues/IPM.cfm). For a refuge, an IPM plan (requirements described 

herein) can be completed independently or in association with a CCP or HMP if IPM strategies and 

potential environmental effects are adequately addressed within appropriate NEPA documentation. 

The PUPs would be created, approved or disapproved, and stored as records in the Pesticide Use Proposal 

System (PUPS), which is centralized database on the Service’s intranet (https://systems.fws.gov/pups). 

Only Service employees can access PUP records in this database. 

G.6.5.3 Pesticide usage 

In accordance with 569 FW 1, the refuge project leader would be required to maintain records of all 

pesticides annually applied on lands or waters under refuge jurisdiction. This would encompass pesticides 

applied by other Federal agencies, state and county governments, non-government applicators including 

cooperators and their pest management service providers with Service permission. For clarification, 

pesticide means all insecticides, insect and plant growth regulators, desiccants, herbicides, fungicides, 

rodenticides, acaricides, nematicides, fumigants, avicides, and piscicides. 

The following usage information can be reported for approved PUPs in the PUPS database: 

 Pesticide trade name(s); 

 Active ingredient(s); 

 Total acres treated; 

 Total amount of pesticides used (lbs or gallons); 

 Total amount of active ingredient(s) used (lbs); 

 Target pest(s); and 

 Efficacy (% control). 

To determine whether treatments are efficacious (eradicating, controlling, or containing the target pest) 

and achieving resource objectives, habitat and/or wildlife response would be monitored both pre- and 

post-treatment, where possible. Considering available annual funding and staffing, appropriate monitoring 
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G-14 Appendix G. Integrated Pest Management Program 

data regarding characteristics (attributes) of pest infestations (e.g., area, perimeter, degree of infestationdensity, % cover, density) as well as habitat and/or wildlife response to treatments may be collected and 

stored in a relational database (e.g., Refuge Habitat Management Database), preferably a geo-referenced 

data management system (e.g., Refuge Lands GIS [RLGIS]) to facilitate data analyses and subsequent 

reporting. In accordance with adaptive management, data analysis and interpretation would allow 

treatments to be modified or changed over time, as necessary, to achieve resource objectives considering 

site-specific conditions in conjunction with habitat and/or wildlife responses. Monitoring could also 

identify short- and long-term impacts to natural resources and environmental quality associated with IPM 

treatments in accordance with adaptive management principles identified in 43 CFR 46.145. 

G.7 Evaluating Pesticide Use Proposals 

Pesticides would only be used on refuge lands for habitat management as well as facilities maintenance 

after approval of a PUP. In general, proposed pesticide uses on refuge lands would only be approved 

where there would likely be minor, temporary, or localized effects to fish and wildlife species as well as 

minimal potential to degrade environmental quality. Potential effects to listed and non-listed species 

would be evaluated with quantitative ecological risk assessments and other screening measures. Potential 

effects to environmental quality would be based upon pesticide characteristics of environmental fate 

(water solubility, soil mobility, soil persistence, and volatilization) and other quantitative screening tools. 

Ecological risk assessments as well as characteristics of environmental fate and potential to degrade 

environmental quality for pesticides would be documented in Chemical Profiles (see Section G.7.5). 

These profiles would include threshold values for quantitative measures of ecological risk assessments 

and screening tools for environmental fate that represent minimal potential effects to species and 

environmental quality. In general, only pesticide uses with appropriate BMPs (see Section G.4) for habitat 

management and cropland/facilities maintenance on refuge lands that would potentially have minor, 

temporary, or localized effects on refuge biological and environmental quality (threshold values not 

exceeded) would be approved. 

G.7.1 Overview of Ecological Risk Assessment 

An ecological risk assessment process would be used to evaluate potential adverse effects to biological 

resources as a result of a pesticide(s) proposed for use on refuge lands. It is an established quantitative 

and qualitative methodology for comparing and prioritizing risks of pesticides and conveying an estimate 

of the potential risk for an adverse effect. This quantitative methodology provides an efficient mechanism 

to integrate best available scientific information regarding hazard, patterns of use (exposure), and doseresponse relationships in a manner that is useful for ecological risk decision-making. It would provide an 

effective way to evaluate potential effects where there is missing or unavailable scientific information 

(data gaps) to address reasonable, foreseeable adverse effects in the field as required under 40 CFR Part 

1502.22. Protocols for ecological risk assessment of pesticide uses on the refuge were developed through 

research and established by the USEPA (2004). Assumptions for these risk assessments are presented in 

Section G.7.2.3. 

The toxicological data used in ecological risk assessments are typically results of standardized laboratory 

studies provided by pesticide registrants to the EPA to meet regulatory requirements under the Federal 

Insecticide, Fungicide and Rodenticide Act of 1996 (FIFRA). These studies assess the acute (lethality) 

and chronic (reproductive) effects associated with short- and long-term exposure to pesticides on 

representative species of birds, mammals, freshwater fish, aquatic invertebrates, and terrestrial and 

aquatic plants. Other effects data publicly available would also be utilized for risk assessment protocols 

described herein. Toxicity endpoint and environmental fate data are available from a variety of resources. 

Some of the more useful resources can be found at the end of Section G.7.5. 
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Appendix G. Integrated Pest Management Program G-15

Table G-1. Ecotoxicity Tests Used to Evaluate Potential Effects to Birds, Fish, and Mammals to 

Establish Toxicity Endpoints for Risk Quotient Calculations 

Species Group Exposure Measurement endpoint 

Bird 

Acute Median Lethal Concentration (LC50) 

Chronic No Observed Effect Concentration (NOEC) or 

No Observed Adverse Effect Concentration (NOAEC)1 

Fish 

Acute Median Lethal Concentration (LC50) 

Chronic No Observed Effect Concentration (NOEC) or 

No Observed Adverse Effect Concentration (NOAEC)2

Mammal 

Acute Oral Lethal Dose (LD50) 

Chronic No Observed Effect Concentration (NOEC) or 

No Observed Adverse Effect Concentration (NOAEC)3

1

Measurement endpoints typically include a variety of reproductive parameters (e.g., number of eggs, number of offspring, 

eggshell thickness, and number of cracked eggs). 2

Measurement endpoints for early life stage/life cycle typically include embryo hatch rates, time to hatch, growth, and time to 

swim-up. 

3

Measurement endpoints include maternal toxicity, teratogenic effects or developmental anomalies, evidence of mutagenicity or 

genotoxicity, and interference with cellular mechanisms such as DNA synthesis and DNA repair. 

G.7.2 Determining Ecological Risk to Fish and Wildlife 

The potential for pesticides used on the refuge to cause direct adverse effects to fish and wildlife would be 

evaluated using EPA’s Ecological Risk Assessment Process (2004). This deterministic approach, which is 

based upon a two-phase process involving estimation of environmental concentrations and then 

characterization of risk, would be used for ecological risk assessments. This method integrates exposure 

estimates (estimated environmental concentration (EEC) and toxicological endpoints [e.g., LC50 and oral 

LD50]) to evaluate the potential for adverse effects to species groups (birds, mammals, and fish) 

representative of legal mandates for managing units of the Refuge System. This integration is achieved 

through risk quotients (RQs) calculated by dividing the EEC by acute and chronic toxicity values selected 

from standardized toxicological endpoints or published effect (Table G-1). 

RQ = EEC/Toxicological Endpoint 

The level of risk associated with direct effects of pesticide use would be characterized by comparing 

calculated RQs to the appropriate Level of Concern (LOC) established by EPA (1998b) (Table G-2). The 

LOC represents a quantitative threshold value for screening potential adverse effects to fish and wildlife 

resources associated with pesticide use. The following are four exposure-species group scenarios that 

would be used to characterize ecological risk to fish and wildlife on the Refuge: acute-listed species, 

acute-nonlisted species, chronic-listed species, and chronic-nonlisted species. 

Acute risk would indicate the potential for mortality associated with short-term dietary exposure to 

pesticides immediately after an application. For characterization of acute risks, median values from LC50

and LD50 tests would be used as toxicological endpoints for RQ calculations. In contrast, chronic risks 

would indicate the potential for adverse effects associated with long-term dietary exposure to pesticides 

from a single application or multiple applications over time (within a season and over years). For 

characterization of chronic risks, the no observed concentration (NOAEC) or no observed effect 
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G-16 Appendix G. Integrated Pest Management Program 

concentration (NOEC) for reproduction would be used as toxicological endpoints for RQ calculations. 

Where available, the NOAEC would be preferred over a NOEC value. 

Listed species are those federally designated as threatened, endangered, or proposed in accordance with 

the Endangered Species Act of 1973 (16 USC 1531-1544, 87 Stat. 884, as amended-Public Law 93-205). 

For listed species, potential adverse effects would be assessed at the individual level because loss of 

individuals from a population could detrimentally impact a species. In contrast, risks to nonlisted species 

would consider effects at the population level. A RQ<LOC would indicate the proposed pesticide use 

“may affect, not likely to adversely affect” individuals (listed species) and it would not pose an 

unacceptable risk for adverse effects to populations (non-listed species) for each taxonomic group (Table 

G-2). In contrast, a RQ>LOC would indicate a “may affect, likely to adversely affect” for listed species 

and it would also pose unacceptable ecological risk for adverse effects to nonlisted species. 

Table G-2. Presumption of Unacceptable Risk for Birds, Fish, and Mammals (USEPA 1998b) 

Risk Presumption 

Level of Concern 

Listed Species Non-listed Species 

Acute Birds 0.1 0.5 

Fish 0.05 0.5 

Mammals 0.1 0.5 

Chronic Birds 1.0 1.0 

Fish 1.0 1.0 

Mammals 1.0 1.0 

G.7.2.1 Environmental exposure 

Following release into the environment through application, pesticides would experience several different 

routes of environmental fate. Pesticides which would be sprayed can move through the air (e.g., particle 

or vapor drift) and may eventually end up in other parts of the environment such as non-target vegetation, 

soil, or water. Pesticides applied directly to the soil may be washed off the soil into nearby bodies of 

surface water (e.g., surface runoff) or may percolate through the soil to lower soil layers and groundwater 

(e.g., leaching) (Baker and Miller 1999, Pope et al. 1999, Butler et al. 1998, Ramsay et al. 1995, 

EXTOXNET 1993). Pesticides which would be injected into the soil may also be subject to the latter two 

fates. The aforementioned possibilities are by no means complete, but it does indicate movement of 

pesticides in the environment is very complex with transfers occurring continually among different 

environmental compartments. In some cases, these exchanges occur not only between areas that are close 

together, but it also may involve transportation of pesticides over long distances (Barry 2004, Woods 

2004). 

G.7.2.1.1 Terrestrial exposure 

The estimated environmental concentration (ECC) for exposure to terrestrial wildlife would be quantified 

using an USEPA screening-level approach (USEPA 2004). This screening-level approach is not affected 

by product formulation because it evaluates pesticide active ingredient(s). This approach would vary 

depending upon the proposed pesticide application method: spray or granular. 
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Appendix G. Integrated Pest Management Program G-17

G.7.2.1.1.1 Terrestrial-spray application 

For spray applications, exposure would be determined using the Kanaga nomogram method (USEPA 

2005a, USEPA 2004, Pfleeger et al. 1996) through the USEPA’s Terrestrial Residue Exposure model (TREX) version 1.2.3 (USEPA 2005b). To estimate the maximum (initial) pesticide residue on short grass 

(<20 cm tall) as a general food item category for terrestrial vertebrate species, T-REX input variables 

would include the following from the pesticide label: maximum pesticide application rate (pounds active 

ingredient [acid equivalent]/acre) and pesticide half-life (days) in soil. Although there are other food item 

categories (tall grasses; broadleaf plants and small insects; and fruits, pods, seeds and large insects), short 

grass was selected because it would yield maximum EECs (240 ppm per lb ai/acre) for worst-case risk 

assessments. Short grass is not representative of forage for carnivorous species (e.g., raptors), but it would 

characterize the maximum potential exposure through the diet of avian and mammalian prey items. 

Consequently, this approach would provide a conservative screening tool for pesticides that do not 

biomagnify. 

For RQ calculations in T-REX, the model would require the weight of surrogate species and Mineau 

scaling factors (Mineau et al. 1996). Body weights of bobwhite quail and mallard are included in T-REX 

by default, but body weights of other organisms (Table G-3) would be entered manually. The Mineau 

scaling factor accounts for small-bodied bird species that may be more sensitive to pesticide exposure 

than would be predicted only by body weight. Mineau scaling factors would be entered manually with 

values ranging from 1 to 1.55 that are unique to a particular pesticide or group of pesticides. If specific 

information to select a scaling factor is not available, then a value of 1.15 would be used as a default. 

Alternatively, zero would be entered if it is known that body weight does not influence toxicity of 

pesticide(s) being assessed. The upper bound estimate output from the T-REX Kanaga nomogram would 

be used as an EEC for calculation of RQs. This approach would yield a conservative estimate of 

ecological risk. 

Table G-3. Average Body Weight of Selected Terrestrial Wildlife Species Frequently Used in 

Research to Establish Toxicological Endpoints (Dunning 1984) 

Species Body Weight (kg) 

Mammal (15 g) 0.015 

House sparrow 0.0277 

Mammal (35 g) 0.035 

Starling 0.0823 

Red-winged blackbird 0.0526 

Common grackle 0.114 

Japanese quail 0.178 

Bobwhite quail 0.178 

Rat 0.200 

Rock dove (aka pigeon) 0.542 

Mammal (1,000 g) 1.000 

Mallard 1.082 

Ring-necked pheasant 1.135 
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G.7.2.1.1.2 Terrestrial – granular application 

Granular pesticide formulations and pesticide-treated seed would pose a unique route of exposure for 

avian and mammalian species. The pesticide is applied in discrete units which birds or mammals might 

ingest accidentally with food items or intentionally as in the case of some bird species actively seeking 

and picking up gravel or grit to aid digestion or seed as a food source. Granules may also be consumed by 

wildlife foraging on earthworms, slugs or other soft-bodied soil organisms to which the granules may 

adhere. 

Terrestrial wildlife RQs for granular formulations or seed treatments would be calculated by dividing the 

maximum milligrams of active ingredient (a.i.) exposed (e.g., EEC) on the surface of an area equal to 1 

square foot by the appropriate LD50 value multiplied by the surrogate’s body weight (Table G-3). An 

adjustment to surface area calculations would be made for broadcast, banded, and in-furrow applications. 

An adjustment also would be made for applications with and without incorporation of the granules. 

Without incorporation, it would be assumed that 100% of the granules remain on the soil surface 

available to foraging birds and mammals. Press wheels push granules flat with the soil surface, but they 

are not incorporated into the soil. If granules are incorporated in the soil during band or T-band 

applications or after broadcast applications, it would be assumed only 15% of the applied granules remain 

available to wildlife. It would be assumed that only 1% of the granules are available on the soil surface 

following in-furrow applications. 

EECs for pesticides applied in granular form and as seed treatments would be determined considering 

potential ingestion rates of avian or mammalian species (e.g., 10-30% body weight/day). This would 

provide an estimate of maximum exposure that may occur as a result of granule or seed treatment spills 

such as those that commonly occur at end rows during application and planting. The availability of 

granules and seed treatments to terrestrial vertebrates would also be considered by calculating the loading 

per unit area (LD50/ft2

)for comparison to USEPA Level of Concerns (USEPA 1998b). The T-REX 

version 1.2.3 (USEPA 2005b) contains a submodel which automates Kanaga exposure calculations for 

granular pesticides and treated seed. 

The following formulas would be used to calculate EECs depending upon the type of granular pesticide 

application: 

 In-furrow applications assume a typical value of 1% granules, bait, or seed remain unincorporated. 

mg a.i./ft.

2 

= [(lbs. product/acre)(% a.i.)(453,580 mg/lbs)(1% exposed))] / {[(43,560 ft.

2

/acre)/(row 

spacing (ft.))] / (row spacing (ft.)} 

or 

mg a.i./ft

2 

= [(lbs product/1,000 ft. row)(% a.i.)(1,000 ft row)(453,580 mg/lb.)(1% exposed) 

EEC = [(mg a.i./ft.

2

)(% of pesticide biologically available)] 

 Incorporated banded treatments assume that 15% of granules, bait, and seeds are unincorporated. 

mg a.i./ft.

2 

= [(lbs. product/1,000 row ft.)(% a.i.)(453,580 mg/lb.)(1-% incorporated)] / (1,000 ft.)(band 

width (ft.)) 

EEC = [(mg a.i./ft.

2

)(% of pesticide biologically available)] 

 Broadcast treatment without incorporation assumes 100% of granules, bait, seeds are unincorporated. 
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Appendix G. Integrated Pest Management Program G-19

mg a.i./ft.

2 

= [(lbs. product/acre)(% a.i.)(453,590 mg/lb.)] / (43,560 ft.

2

/acre) 

EEC = [(mg a.i./ft.

2

)(% of pesticide biologically available)] 

Where: 

 % of pesticide biologically available = 100% without species specific ingestion rates 

 Conversion for calculating mg a.i./ft.2 using ounces: 453,580 mg/lb. /16 = 28,349 mg/oz. 

The following equation would be used to calculate a RQ based on the EEC calculated by one of the above 

equations. The EEC would divided by the surrogate LD50 toxicological endpoint multiplied by the body 

weight (Table G-3) of the surrogate. 

RQ = EEC / [LD50 (mg/kg) * body weight (kg)] 

As with other risk assessments, a RQ>LOC would be a presumption of unacceptable ecological risk. A 

RQ<LOC would be a presumption of acceptable risk with only minor, temporary, or localized effects to 

species. 

G.7.2.1.2 Aquatic exposure 

Exposures to aquatic habitats (e.g., wetlands, meadows, ephemeral pools, water delivery ditches) would 

be evaluated separately for ground-based pesticide treatments of habitats managed for fish and wildlife 

compared with cropland/facilities maintenance. The primary exposure pathway for aquatic organisms 

from any ground-based treatments likely would be particle drift during the pesticide application. 

However, different exposure scenarios would be necessary as a result of contrasting application 

equipment and techniques as well as pesticides used to control pests on agricultural lands (especially 

those cultivated by cooperative farmers for economic return from crop yields) and facilities maintenance 

(e.g., roadsides, parking lots, trails) compared with other managed habitats on the Refuge. In addition, 

pesticide applications may be done <25 feet of the high water mark of aquatic habitats for habitat 

management treatments; whereas, no-spray buffers (≥25 feet) would be used for croplands/facilities 

maintenance treatments. 

G.7.2.1.2.1 Habitat treatments 

For the worst-case exposure scenario to non-target aquatic habitats, EECs (Table G-4) would be would be 

derived from Urban and Cook (1986) that assumes an intentional overspray to an entire, non-target water 

body (1-ft depth) from a treatment <25 ft from the high water mark using the max application rate (acid 

basis [see above]). However, use of BMPs for applying pesticides (see Section G.4.2) would likely 

minimize/eliminate potential drift to non-target aquatic habitats during actual treatments. If there would 

be unacceptable (acute or chronic) risk to fish and wildlife with the simulated 100% overspray 

(RQ>LOC), then the proposed pesticide use may be disapproved or the PUP would be approved at a 

lower application rate to minimize/eliminate unacceptable risk to aquatic organisms (RQ=LOC). 
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G-20 Appendix G. Integrated Pest Management Program 

Table G-4. Estimated Environmental Concentrations (ppb) of Pesticides in Aquatic Habitats (1 foot 

depth) Immediately after Direct Application (Urban and Cook 1986) 

Lbs/acre EEC (ppb) 

0.10 36.7 

0.20 73.5 

0.25 91.9 

0.30 110.2 

0.40 147.0 

0.50 183.7 

0.75 275.6 

1.00 367.5 

1.25 459.7 

1.50 551.6 

1.75 643.5 

2.00 735.7 

2.25 827.6 

2.50 919.4 

3.00 1,103.5 

4.00 1,471.4 

5.00 1,839 

6.00 2,207 

7.00 2,575 

8.00 2,943 

9.00 3,311 

10.00 3,678 

G.7.2.1.2.2 Cropland/facilities maintenance treatments 

Field drift studies conducted by the Spray Drift Task Force, which is a joint project of several agricultural 

chemical businesses, were used to develop a generic spray drift database. From this database, the 

AgDRIFT computer model was created to satisfy USEPA pesticide registration spray drift data 

requirements and as a scientific basis to evaluate off-target movement of pesticides from particle drift and 

assess potential effects of exposure to wildlife. Several versions of the computer model have been 

developed (i.e., v2.01 through v2.10). The Spray Drift Task Force AgDRIFT® model version 2.01 (SDTF 

2003, AgDRIFT 2001) would be used to derive EECs resulting from drift of pesticides to refuge aquatic 

resources from ground-based pesticide applications >25 feet from the high water mark. The Spray Drift 

Task Force AgDRIFT model is publicly available at http://www.agdrift.com. At this website, click 

“AgDRIFT 2.0” and then click “Download Now” and follow the instructions to obtain the computer 

model. 

The AgDRIFT model is composed of submodels called tiers. Tier I Ground submodel would be used to 

assess ground-based applications of pesticides. Tier outputs (EECs) would be calculated with AgDRIFT 

using the following input variables: max application rate (acid basis [see above]), low boom (20 inches), 

fine to medium droplet size, EPA-defined wetland, and a ≥25-foot distance (buffer) from treated area to 

water. 
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Appendix G. Integrated Pest Management Program G-21

G.7.2.2 Use of information on effects of biological control agents, pesticides, degradates, and 

adjuvants 

NEPA documents regarding biological and other environmental effects of biological control agents, 

pesticides, degradates, and adjuvants prepared by another federal agency, where the scope would be 

relevant to evaluation of effects from pesticide uses on refuge lands, would be reviewed. Possible source 

agencies for such NEPA documents would include the Bureau of Land Management, US Forest Service, 

National Park Service, US Department of Agriculture-Animal and Plant Health Inspection Service, and 

the military services. It might be appropriate to incorporate by reference parts or all of existing 

document(s). Incorporating by reference (40 CFR 1502.21) is a technique used to avoid redundancies in 

analysis. It also would reduce the bulk of a Service NEPA document, which only would identify the 

documents that are incorporated by reference. In addition, relevant portions would be summarized in the 

Service NEPA document to the extent necessary to provide the decision maker and public with an 

understanding of relevance of the referenced material to the current analysis. 

In accordance with the requirements set forth in 43 CFR 46.135, the Service would specifically 

incorporate through reference ecological risk assessments prepared by the US Forest Service 

(http://www.fs.fed.us/r6/invasiveplant-eis/Risk-Assessments/Herbicides-Analyzed-InvPlant-EIS.htm) and 

Bureau of Land Management (http://www.blm.gov/wo/st/en/prog/more/veg_eis.html). These risk 

assessments and associated documentation also are available in total with the administrative record for the 

Final Environmental Impact Statement entitled Pacific Northwest Region Invasive Plant Program – 

Preventing and Managing Invasive Plants (USFS 2005) and Vegetation Treatments Using Herbicides on 

Bureau of Land Management Lands in 17 Western States Programmatic EIS (PEIS) (BLM 2007). In 

accordance with 43 CFR 46.120(d), use of existing NEPA documents by supplementing, tiering to, 

incorporating by reference, or adopting previous NEPA environmental analyses would avoid redundancy 

and unnecessary paperwork. 

As a basis for completing “Chemical Profiles” for approving or disapproving refuge PUPs, ecological risk 

assessments for the following herbicide and adjuvant uses prepared by the US Forest Service would be 

incorporated by reference: 

 2,4-D; 

 Chlorsulfuron; 

 Clopyralid; 

 Dicamba; 

 Glyphosate; 

 Imazapic; 

 Imazapyr; 

 Metsulfuron methyl; 

 Picloram; 

 Sethoxydim; 

 Sulfometuron methyl; 

 Triclopyr; and 

 Nonylphenol polyethylate (NPE) based surfactants. 

As a basis for completing “Chemical Profiles” for approving or disapproving refuge PUPs, ecological risk 

assessments for the following herbicide uses as well as evaluation of risks associated with pesticide 

degradates and adjuvants prepared by the Bureau of Land Management would be incorporated by 

reference: 
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G-22 Appendix G. Integrated Pest Management Program 

 Bromacil; 

 Chlorsulfuron; 

 Diflufenzopyr; 

 Diquat; 

 Diuron; 

 Fluridone; 

 Imazapic; 

 Overdrive (diflufenzopyr and dicamba); 

 Sulfometuron methyl; 

 Tebuthiuron; 

 Pesticide degradates and adjuvants (Appendix D – Evaluation of risks from degradates, 

polyoxyethylene-amine (POEA) and R-11, and endocrine disrupting chemicals). 

G.7.2.3 Assumptions for ecological risk assessments 

There are a number of assumptions involved with the ecological risk assessment process for terrestrial 

and aquatic organisms associated with utilization of the USEPA’s (2004) process. These assumptions 

may be risk neutral or may lead to an over- or under-estimation of risk from pesticide exposure depending 

upon site-specific conditions. The following describes these assumptions, their application to the 

conditions typically encountered, and whether or not they may lead to recommendations that are risk 

neutral, underestimate, or overestimate ecological risk from potential pesticide exposure. 

 Indirect effects would not be evaluated by ecological risk assessments. These effects include the 

mechanisms of indirect exposure to pesticides: consuming prey items (fish, birds, or small mammals), 

reductions in the availability of prey items, and disturbance associated with pesticide application 

activities. 

 Exposure to a pesticide product can be assessed based upon the active ingredient. However, exposure 

to a chemical mixture (pesticide formulation) may result in effects that are similar or substantially 

different compared to only the active ingredient. Non-target organisms may be exposed directly to the 

pesticide formulation or only various constituents of the formulation as they dissipate and partition in 

the environment. If toxicological information for both the active ingredient and formulated product 

are available, then data representing the greatest potential toxicity would be selected for use in the 

risk assessment process (USEPA 2004). As a result, this conservative approach may lead to an 

overestimation of risk characterization from pesticide exposure. 

 Because toxicity tests with listed or candidate species or closely related species are not available, data 

for surrogate species would be most often used for risk assessments. Specifically, bobwhite quail and 

mallard duck are the most frequently used surrogates for evaluating potential toxicity to federally 

listed avian species. Bluegill sunfish, rainbow trout, and fathead minnow are the most common 

surrogates for evaluating toxicity for freshwater fishes. However, sheep’s head minnow can be an 

appropriate surrogate marine species for coastal environments. Rats and mice are the most common 

surrogates for evaluating toxicity for mammals. Interspecies sensitivity is a major source of 

uncertainty in pesticide assessments. As a result of this uncertainty, data are selected for the most 

sensitive species tested within a taxonomic group (birds, fish, and mammals) given the quality of the 

data is acceptable. If additional toxicity data for more species of organisms in a particular group are 

available, the selected data would not be limited to the species previously listed as common 

surrogates. 

 The Kanaga nomogram outputs maximum EEC values that may be used to calculate an average daily 

concentration over a specified interval of time, which is referred to as a time-weighted-average 

(TWA). The maximum EEC would be selected as the exposure input for both acute and chronic risk 

assessments in the screening-level evaluations. The initial or maximum EEC derived from the Kanaga 
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Appendix G. Integrated Pest Management Program G-23

nomogram represents the maximum expected instantaneous or acute exposure to a pesticide. Acute 

toxicity endpoints are determined using a single exposure to a known pesticide concentration 

typically for 48 to 96 hours. This value is assumed to represent ecological risk from acute exposure to 

a pesticide. On the other hand, chronic risk to pesticide exposure is a function of pesticide 

concentration and duration of exposure to the pesticide. An organism’s response to chronic pesticide 

exposure may result from either the concentration of the pesticide, length of exposure, or some 

combination of both factors. Standardized tests for chronic toxicity typically involve exposing an 

organism to several different pesticide concentrations for a specified length of time (days, weeks, 

months, years, or generations). For example, avian reproduction tests include a 10-week exposure 

phase. Because a single length of time is used in the test, time response data are usually not available 

for inclusion into risk assessments. Without time response data it is difficult to determine the 

concentration which elicited a toxicological response. 

 Using maximum EECs for chronic risk estimates may result in an overestimate of risk, particularly 

for compounds that dissipate rapidly. Conversely, using TWAs for chronic risk estimates may 

underestimate risk if it is the concentration rather than the duration of exposure that is primarily 

responsible for the observed adverse effect. The maximum EEC would be used for chronic risk 

assessments although it may result in an overestimate of risk. TWAs may be used for chronic risk 

assessments, but they would be applied judiciously considering the potential for an underestimate or 

overestimate of risk. For example, the number of days exposure exceeds a Level of Concern may 

influence the suitability of a pesticide use. The greater the number of days the EEC exceeds the Level 

of Concern translates into greater the ecological risk. This is a qualitative assessment, and is subject 

to reviewer’s expertise in ecological risk assessment and tolerance for risk. 

 The length of time used to calculate the TWA can have a substantial effect on the exposure estimates 

and there is no standard method for determining the appropriate duration for this estimate. The TREX model assumes a 21-week exposure period, which is equivalent to avian reproductive studies 

designed to establish a steady-state concentration for bioaccumulative compounds. However, this 

does not necessarily define the true exposure duration needed to elicit a toxicological response. 

Pesticides, which do not bioaccumulate, may achieve a steady-state concentration earlier than 21 

weeks. The duration of time for calculating TWAs would require justification and it would not exceed 

the duration of exposure in the chronic toxicity test (approximately 70 days for the standard avian 

reproduction study). An alternative to using the duration of the chronic toxicity study is to base the 

TWA on the application interval. In this case, increasing the application interval would suppress both 

the estimated peak pesticide concentration and the TWA. Another alternative to using TWAs would 

be to consider the number of days that a chemical is predicted to exceed the LOC. 

 Pesticide dissipation is assumed to be first-order in the absence of data suggesting alternative 

dissipation patterns such as bi-phasic. Field dissipation data would generally be the most pertinent for 

assessing exposure in terrestrial species that forage on vegetation. However, these data are often not 

available and it can be misleading particularly if the compound is prone to “wash-off.” Soil half-life is 

the most common degradation data available. Dissipation or degradation data that would reflect the 

environmental conditions typical of refuge lands would be utilized, if available. 

 For species found in the water column, it would be assumed that the greatest bioavailable fraction of 

the pesticide active ingredient in surface waters is freely dissolved in the water column. 

 Actual habitat requirements of any particular terrestrial species are not considered, and it is assumed 

that species exclusively and permanently occupy the treated area, or adjacent areas receiving pesticide 

at rates commensurate with the treatment rate. This assumption would produce a maximum estimate 

of exposure for risk characterization. This assumption would likely lead to an overestimation of 

exposure for species that do not permanently and exclusively occupy the treated area (USEPA 2004). 

 Exposure through incidental ingestion of pesticide contaminated soil is not considered in the USEPA 

risk assessment protocols. Research suggests <15% of the diet can consist of incidentally ingested 

soil depending upon species and feeding strategy (Beyer et al. 1994). An assessment of pesticide 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

G-24 Appendix G. Integrated Pest Management Program 

concentrations in soil compared to food item categories in the Kanaga nomogram indicates incidental 

soil ingestion would not likely increase dietary exposure to pesticides. Inclusion of soil into the diet 

would effectively reduce the overall dietary concentration compared to the present assumption that 

the entire diet consists of a contaminated food source (Fletcher et al. 1994). An exception to this may 

be soil-applied pesticides in which exposure from incidental ingestion of soil may increase. Potential 

for pesticide exposure under this assumption may be underestimated for soil-applied pesticides and 

overestimated for foliar-applied pesticides. The concentration of a pesticide in soil would likely be 

less than predicted on food items. 

 Exposure through inhalation of pesticides is not considered in the USEPA risk assessment protocols. 

Such exposure may occur through three potential sources: spray material in droplet form at time of 

application, vapor phase with the pesticide volatilizing from treated surfaces, and airborne 

particulates (soil, vegetative matter, and pesticide dusts). The USEPA (1990) reported exposure from 

inhaling spray droplets at the time of application is not an appreciable route of exposure for birds. 

According to research on mallards and bobwhite quail, respirable particle size (particles reaching the 

lung) in birds is limited to maximum diameter of 2 to 5 microns. The spray droplet spectra covering 

the majority of pesticide application scenarios indicate that less than 1% of the applied material is 

within the respirable particle size. This route of exposure is further limited because the permissible 

spray drop size distribution for ground pesticide applications is restricted to ASAE medium or coarser 

drop size distribution. 

 Inhalation of a pesticide in the vapor phase may be another source of exposure for some pesticides 

under certain conditions. This mechanism of exposure to pesticides occurs post application and it 

would pertain to those pesticides with a high vapor pressure. The USEPA is currently evaluating 

protocols for modeling inhalation exposure from pesticides including near-field and near-ground air 

concentrations based upon equilibrium and kinetics-based models. Risk characterization for exposure 

with this mechanism is unavailable. 

 The effect from exposure to dusts contaminated with the pesticide cannot be assessed generically as 

partitioning issues related to application site soils and chemical properties of the applied pesticides 

render the exposure potential from this route highly situation specific. 

 Dermal exposure may occur through three potential sources: direct application of spray to terrestrial 

wildlife in the treated area or within the drift footprint, incidental contact with contaminated 

vegetation, or contact with contaminated water or soil. Interception of spray and incidental contact 

with treated substrates may pose risk to avian wildlife (Driver et al. 1991). However, available 

research related to wildlife dermal contact with pesticides is extremely limited, except dermal toxicity 

values are common for some mammals used as human surrogates (rats and mice). The USEPA is 

currently evaluating protocols for modeling dermal exposure. Risk characterization may be 

underestimated for this route of exposure, particularly with high risk pesticides such as some 

organophosphates or carbamate insecticides. If protocols are established by the USEPA for assessing 

dermal exposure to pesticides, they would be considered for incorporation into pesticide assessment 

protocols. 

 Exposure to a pesticide may occur from consuming surface water, dew or other water on treated 

surfaces. Water soluble pesticides have the potential to dissolve in surface runoff and puddles in a 

treated area may contain pesticide residues. Similarly, pesticides with lower organic carbon 

partitioning characteristics and higher solubility in water have a greater potential to dissolve in dew 

and other water associated with plant surfaces. Estimating the extent to which such pesticide loadings 

to drinking water occurs is complex and would depend upon the partitioning characteristics of the 

active ingredient, soils types in the treatment area, and the meteorology of the treatment area. In 

addition, the use of various water sources by wildlife is highly species-specific. Currently, risk 

characterization for this exposure mechanism is not available. The USEPA is actively developing 

protocols to quantify drinking water exposures from puddles and dew. If and when protocols are 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix G. Integrated Pest Management Program G-25

formally established by the USEPA for assessing exposure to pesticides through drinking water, these 

protocols would be incorporated into pesticide risk assessment protocols. 

 Risk assessments are based upon the assumption that the entire treatment area would be subject to 

pesticide application at the rates specified on the label. In most cases, there is potential for uneven 

application of pesticides through such plausible incidents such as changes in calibration of application 

equipment, spillage, and localized releases at specific areas in or near the treated field that are 

associated with mixing and handling and application equipment as well as applicator skill. 

Inappropriate use of pesticides and the occurrence of spills represent a potential underestimate of risk. 

It is likely not an important factor for risk characterization. All pesticide applicators are required to be 

certified by the state in which they apply pesticides. Certification training includes the safe storage, 

transport, handling, and mixing of pesticides, equipment calibration, and proper application with 

annual continuing education. 

 The USEPA relies on Fletcher (1994) for setting the assumed pesticide residues in wildlife dietary 

items. The USEPA (2004) “believes that these residue assumptions reflect a realistic upper-bound 

residue estimate, although the degree to which this assumption reflects a specific percentile estimate 

is difficult to quantify.” Fletcher’s (1994) research suggests that the pesticide active ingredient 

residue assumptions used by the USEPA represent a 95th percentile estimate. However, research 

conducted by Pfleeger et al. (1996) indicates USEPA residue assumptions for short grass was not 

exceeded. Baehr and Habig (2000) compared USEPA residue assumptions with distributions of 

measured pesticide residues for the USEPA’s UTAB database. Overall residue selection level tends to 

overestimate risk characterization. This is particularly evident when wildlife individuals are likely to 

have selected a variety of food items acquired from multiple locations. Some food items may be 

contaminated with pesticide residues whereas others are not contaminated. However, it is important to 

recognize differences in species feeding behavior. Some species may consume whole above-ground 

plant material, but others will preferentially select different plant structures. Also, species may 

preferentially select a food item although multiple food items may be present. Without species 

specific knowledge regarding foraging behavior characterizing ecological risk other than in general 

terms is not possible. 

 Acute and chronic risk assessments rely on comparisons of wildlife dietary residues with LC50 or 

NOEC values expressed as concentrations of pesticides in laboratory feed. These comparisons assume 

that ingestion of food items in the field occurs at rates commensurate with those in the laboratory. 

Although the screening assessment process adjusts dry-weight estimates of food intake to reflect the 

increased mass in fresh-weight wildlife food intake estimates, it does not allow for gross energy and 

assimilative efficiency differences between wildlife food items and laboratory feed. Differences in 

assimilative efficiency between laboratory and wild diets suggest that current screening assessment 

methods are not accounting for a potentially important aspect of food requirements. 

 There are several other assumptions that can affect non-target species not considered in the risk 

assessment process. These include possible additive or synergistic effects from applying two or more 

pesticides or additives in a single application, co-location of pesticides in the environment, 

cumulative effects from pesticides with the same mode of action, effects of multiple stressors (e.g., 

combination of pesticide exposure, adverse abiotic and biotic factors) and behavioral changes induced 

by exposure to a pesticide. These factors may exist at some level contributing to adverse effects to 

non-target species, but they are usually characterized in the published literature in only a general 

manner limiting their value in the risk assessment process.

 It is assumed that aquatic species exclusively and permanently occupy the water body being assessed. 

Actual habitat requirements of aquatic species are not considered. With the possible exception of 

scenarios where pesticides are directly applied to water, it is assumed that no habitat use 

considerations specific for any species would place the organisms in closer proximity to pesticide use 

sites. This assumption produces a maximum estimate of exposure or risk characterization. It would 

likely be realistic for many aquatic species that may be found in aquatic habitats within or in close 
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G-26 Appendix G. Integrated Pest Management Program 

proximity to treated terrestrial habitats. However, the spatial distribution of wildlife is usually not 

random because wildlife distributions are often related to habitat requirements of species. Clumped 

distributions of wildlife may result in an under- or over-estimation of risk depending upon where the 

initial pesticide concentration occurs relative to the species or species habitat. 

 For species found in the water column, it would be assumed that the greatest bioavailable fraction of 

the pesticide active ingredient in surface waters is freely dissolved in the water column. Additional 

chemical exposure from materials associated with suspended solids or food items is not considered 

because partitioning onto sediments likely is minimal. Adsorption and bioconcentration occurs at 

lower levels for many newer pesticides compared with older more persistent bioaccumulative 

compounds. Pesticides with RQs close to the listed species level of concern, the potential for 

additional exposure from these routes may be a limitation of risk assessments, where potential 

pesticide exposure or risk may be underestimated. 

 Mass transport losses of pesticide from a water body (except for losses by volatilization, degradation, 

and sediment partitioning) would not be considered for ecological risk assessment. The water body 

would be assumed to capture all pesticide active ingredients entering as runoff, drift, and adsorbed to 

eroded soil particles. It would also be assumed that pesticide active ingredient is not lost from the 

water body by overtopping or flow-through, nor is concentration reduced by dilution. In total, these 

assumptions would lead to a near maximum possible water-borne concentration. However, this 

assumption would not account for the potential to concentrate pesticide through the evaporative loss. 

This limitation may have the greatest impact on water bodies with high surface-to-volume ratios such 

as ephemeral wetlands, where evaporative losses are accentuated and applied pesticides have low 

rates of degradation and volatilization. 

 For acute risk assessments, there would be no averaging time for exposure. An instantaneous peak 

concentration would be assumed, where instantaneous exposure is sufficient in duration to elicit acute 

effects comparable to those observed over more protracted exposure periods (typically 48 to 96 

hours) tested in the laboratory. In the absence of data regarding time-to-toxic event, analyses, and 

latent responses to instantaneous exposure, risk would likely be overestimated. 

 For chronic exposure risk assessments, the averaging times considered for exposure are 

commensurate with the duration of invertebrate life-cycle or fish-early life stage tests (e.g., 21-28 

days and 56-60 days, respectively). Response profiles (time to effect and latency of effect) to 

pesticides likely vary widely with mode of action and species and should be evaluated on a case-bycase basis as available data allow. Nevertheless, because the USEPA relies on chronic exposure 

toxicity endpoints based on a finding of no observed effect, the potential for any latent toxicity effects 

or averaging time assumptions to alter the results of an acceptable chronic risk assessment prediction 

is limited. The extent to which duration of exposure from water-borne concentrations overestimate or 

underestimate actual exposure depends on several factors. These include the following: localized 

meteorological conditions, runoff characteristics of the watershed (e.g., soils, topography), the 

hydrological characteristics of receiving waters, environmental fate of the pesticide active ingredient, 

and the method of pesticide application. It should also be understood that chronic effects studies are 

performed using a method that holds water concentration in a steady state. This method is not likely 

to reflect conditions associated with pesticide runoff. Pesticide concentrations in the field increase 

and decrease in surface water on a cycle influenced by rainfall, pesticide use patterns, and degradation 

rates. As a result of the dependency of this assumption on several undefined variables, risk associated 

with chronic exposure may in some situations underestimate risk and overestimate risk in others. 

 There are several other factors that can affect non-target species not considered in the risk assessment 

process. These would include the following: possible additive or synergistic effects from applying 

two or more pesticides or additives in a single application, co-location of pesticides in the 

environment, cumulative effects from pesticides with the same mode of action, effects of multiple 

stressors (e.g., combination of pesticide exposure, adverse abiotic [not pesticides] and biotic factors), 

and sub-lethal effects such as behavioral changes induced by exposure to a pesticide. These factors 
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Appendix G. Integrated Pest Management Program G-27

may exist at some level contributing to adverse effects to non-target species, but they are not routinely 

assessed by regulatory agencies. Therefore, information on the factors is not extensive limiting their 

value for the risk assessment process. As this type of information becomes available, it would be 

included, either quantitatively or qualitatively, in this risk assessment process. 

 USEPA is required by the Food Quality Protection Act to assess the cumulative risks of pesticides 

that share common mechanisms of toxicity, or act the same within an organism. Currently, USEPA 

has identified four groups of pesticides that have a common mechanism of toxicity requiring 

cumulative risk assessments. These four groups are: the organophosphate insecticides, N-methyl 

carbamate insecticides, triazine herbicides, and chloroacetanilide herbicides. 

G.7.3 Pesticide Mixtures and Degradates 

Pesticide products are usually a formulation of several components generally categorized as active 

ingredients and inert or other ingredients. The term active ingredient is defined by the FIFRA as 

preventing, destroying, repelling, or mitigating the effects of a pest, or it is a plant regulator, defoliant, 

desiccant, or nitrogen stabilizer. In accordance with FIFRA, the active ingredient(s) must be identified by 

name(s) on the pesticide label along with its relative composition expressed in percentage(s) by weight. In 

contrast, inert ingredient(s) are not intended to affect a target pest. Their role in the pesticide formulation 

is to act as a solvent (keep the active ingredient is a liquid phase), an emulsifying or suspending agent 

(keep the active ingredient from separating out of solution), or a carrier such as clay in which the active 

ingredient is impregnated on the clay particle in dry formulations. For example, if isopropyl alcohol 

would be used as a solvent in a pesticide formulation, then it would be considered an inert ingredient. 

FIFRA only requires that inert ingredients identified as hazardous and associated percent composition, 

and the total percentage of all inert ingredients must be declared on a product label. Inert ingredients that 

are not classified as hazardous are not required to be identified. 

The USEPA (September 1997) issued Pesticide Regulation Notice 97-6 which encouraged manufacturers, 

formulators, producers, and registrants of pesticide products to voluntarily substitute the term “other 

ingredients” for “inert ingredients” in the ingredient statement. This change recognized that all 

components in a pesticide formulation potentially could elicit or contribute to an adverse effect on nontarget organisms and, therefore, are not necessarily inert. Whether referred to as “inerts” or “other 

ingredients,” these constituents within a pesticide product have the potential to affect species or 

environmental quality. The USEPA categorizes regulated inert ingredients into the following four lists 

(http://www.epa.gov/opprd001/inerts/index.html): 

 List 1 – Inert Ingredients of Toxicological Concern; 

 List 2 – Potentially Toxic Inert Ingredients; 

 List 3 – Inerts of Unknown Toxicity; 

 List 4 – Inerts of Minimal Toxicity. 

Several of the List 4 compounds are naturally-occurring earthen materials (e.g., clay materials, simple 

salts) that would not elicit toxicological response at applied concentrations. However, some of the inerts 

(particularly the List 3 compounds and unlisted compounds) may have moderate to high potential toxicity 

to aquatic species based on MSDSs or published data. 

Comprehensively assessing potential effects to non-target fish, wildlife, plants, and/or their habitats from 

pesticide use is a complex task. It would be preferable to assess the cumulative effects from exposure to 

the active ingredient, its degradates, and inert ingredients as well as other active ingredients in the spray 

mixture. However, it would only be feasible to conduct deterministic risk assessments for each 

component in the spray mixture singly. Limited scientific information is available regarding ecological 
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G-28 Appendix G. Integrated Pest Management Program 

effects (additive or synergistic) from chemical mixtures that typically rely upon broadly encompassing 

assumptions. For example, the USFS (2005) found that mixtures of pesticides used in land (forest) 

management likely would not cause additive or synergistic effects to non-target species based upon a 

review of scientific literature regarding toxicological effects and interactions of agricultural chemicals 

(ATSDR 2004). Moreover, information on inert ingredients, adjuvants, and degradates is often limited by 

the availability of and access to reliable toxicological data for these constituents. 

Toxicological information regarding “other ingredients” may be available from sources such as the 

following: 

 TOMES (a proprietary toxicological database including USEPA’s IRIS, the Hazardous Substance 

Data Bank, the Registry of Toxic Effects of Chemical Substances [RTECS]). 

 USEPA’s ECOTOX database, which includes AQUIRE (a database containing scientific papers 

published on the toxic effects of chemicals to aquatic organisms). 

 TOXLINE (a literature searching tool). 

 Material Safety Data Sheets (MSDSs) from pesticide suppliers. 

 Other sources such as the Farm Chemicals Handbook. 

Because there is a lack of specific inert toxicological data, inert(s) in a pesticide may cause adverse 

ecological effects. However, inert ingredients typically represent only a small percentage of the pesticide 

spray mixture, and it would be assumed that negligible effects would be expected to result from inert 

ingredient(s). 

Although the potential effects of degradates should be considered when selecting a pesticide, it is beyond 

the scope of this assessment process to consider all possible breakdown chemicals of the various product 

formulations containing an active ingredient. Degradates may be more or less mobile and more or less 

hazardous in the environment than their parent pesticides (Battaglin et al. 2003). Differences in 

environmental behavior (e.g., mobility) and toxicity between parent pesticides and degradates would 

make assessing potential degradate effects extremely difficult. For example, a less toxic and more mobile, 

bioaccumulative, or persistent degradate may have potentially greater effects on species and/or degrade 

environmental quality. The lack of data on the toxicity of degradates for many pesticides would represent 

a source of uncertainty for assessing risk. 

An USEPA-approved label specifies whether a product can be mixed with one or more pesticides. 

Without product-specific toxicological data, it would not be possible to quantify the potential effects of 

these mixtures. In addition, a quantitative analysis could only be conducted if reliable scientific 

information allowed a determination of whether the joint action of a mixture would be additive, 

synergistic, or antagonistic. Such information would not likely exist unless the mode of action would be 

common among the chemicals and receptors. Moreover, the composition of and exposure to mixtures 

would be highly site- and/or time-specific and, therefore, it would be nearly impossible to assess potential 

effects to species and environmental quality. 

To minimize or eliminate potential negative effects associated with applying two or more pesticides as a 

mixture, the use would be conducted in accordance with the labeling requirements. Labels for two or 

more pesticides applied as a mixture should be completely reviewed, where products with the least 

potential for negative effects would be selected for use on the Refuge. This is especially relevant when a 

mixture would be applied in a manner that may already have the potential for an effect(s) associated with 

an individual pesticide (e.g., runoff to ponds in sandy watersheds). Use of a tank mix under these 

conditions would increase the level of uncertainty in terms of risk to species or potential to degrade 

environmental quality. 
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Appendix G. Integrated Pest Management Program G-29

Adjuvants generally function to enhance or prolong the activity of pesticide. For terrestrial herbicides, 

adjuvants aid in the absorption into plant tissue. Adjuvant is a broad term that generally applies to 

surfactants, selected oils, anti-foaming agents, buffering compounds, drift control agents, compatibility 

agents, stickers, and spreaders. Adjuvants are not under the same registration requirements as pesticides 

and the USEPA does not register or approve the labeling of spray adjuvants. Individual pesticide labels 

identify types of adjuvants approved for use with it. In general, adjuvants compose a relatively small 

portion of the volume of pesticides applied. Selection of adjuvants with limited toxicity and low volumes 

would be recommended to reduce the potential for the adjuvant to influence the toxicity of the pesticide. 

G.7.4 Determining Effects to Soil and Water Quality 

The approval process for pesticide uses would consider potential to degrade water quality on and off 

refuge lands. A pesticide can only affect water quality through movement away from the treatment site. 

After application, pesticide mobilization can be characterized by one or more of the following (Kerle et 

al. 1996): 

 Attach (sorb) to soil, vegetation, or other surfaces and remain at or near the treated area; 

 Attach to soil and move off-site through erosion from runoff or wind; 

 Dissolve in water that can be subjected to runoff or leaching. 

As an initial screening tool, selected chemical characteristics and rating criteria for a pesticide can be 

evaluated to assess potential to enter ground and/or surface waters. These would include the following: 

persistence, sorption coefficient (Koc), groundwater ubiquity score (GUS), and solubility. 

Persistence, which is expressed as half-life (t1⁄2), represents the length of time required for 50% of the 

deposited pesticide to degrade (completely or partially). Persistence in the soil can be categorized as the 

following: non-persistent <30 days, moderately persistent = 30 to 100 days, and persistent >100 days 

(Kerle et al. 1996). Half-life data are usually available for aquatic and terrestrial environments. 

Another measure of pesticide persistence is dissipation time (DT50). It represents the time required for 

50% of the deposited pesticide to degrade and move from a treated site; whereas, half-life describes the 

rate for degradation only. As for half-life, units of dissipation time are usually expressed in days. Field or 

foliar dissipation time is the preferred data for use to estimate pesticide concentrations in the environment. 

However, soil half-life is the most common persistence data cited in published literature. If field or foliar 

dissipation data are not available, soil half-life data may be used. The average or representative half-life 

value of most important degradation mechanism would be selected for quantitative analysis for both 

terrestrial and aquatic environments. 

Mobility of a pesticide is a function of how strongly it is adsorbed to soil particles and organic matter, its 

solubility in water, and its persistence in the environment. Pesticides strongly adsorbed to soil particles, 

relatively insoluble in water, and not environmentally persistent would be less likely to move across the 

soil surface into surface waters or to leach through the soil profile and contaminate groundwater. 

Conversely, pesticides that are not strongly adsorbed to soil particles, are highly water soluble, and are 

persistent in the environment would have greater potential to move from the application site (off-site 

movement). 

The degree of pesticide adsorption to soil particles and organic matter (Kerle et al. 1996) is expressed as 

the soil adsorption coefficient (Koc). The soil adsorption coefficient is measured as micrograms of 

pesticide per gram of soil (μg/g) that can range from near zero to the thousands. Pesticides with higher 

Koc values are strongly sorbed to soil and, therefore, would be less subject to movement. 
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Water solubility describes the amount of pesticide that will dissolve in a known quantity of water. The 

water solubility of a pesticide is expressed as milligrams of pesticide dissolved in a liter of water (mg/l or 

ppm). Pesticide with solubility <0.1 ppm are virtually insoluble in water, 100-1,000 ppm are moderately 

soluble, and >10,000 ppm highly soluble (USGS 2000). As pesticide solubility increases, there would be 

greater potential for off-site movement. 

The Groundwater Ubiquity Score (GUS) is a quantitative screening tool to estimate a pesticide’s potential 

to move in the environment. It utilizes soil persistence and adsorption coefficients in the following 

formula. 

GUS = log10 (t1⁄2) x [4 - log10 (Koc)] 

The potential pesticide movement rating would be based upon its GUS value. Pesticides with a GUS <0.1 

would considered to have an extremely low potential to move toward groundwater. Values of 1.0-2.0 

would be low, 2.0-3.0 would be moderate, 3.0-4.0 would be high, and >4.0 would have a very high 

potential to move toward groundwater. 

Water solubility describes the amount of pesticide dissolving in a specific quantity of water, where it is 

usually measured as mg/l or parts per million (ppm). Solubility is useful as a comparative measure 

because pesticides with higher values are more likely to move by runoff or leaching. GUS, water 

solubility, t1⁄2, and Koc values are available for selected pesticides from the OSU Extension Pesticide 

Properties Database at http://npic.orst.edu/ppdmove.htm. Many of the values in this database were 

derived from the SCS/ARS/CES Pesticide Properties Database for Environmental Decision Making 

(Wauchope et al. 1992). 

Soil properties influence the fate of pesticides in the environment. The following six properties are mostly 

likely to affect pesticide degradation and the potential for pesticides to move off-site by leaching (vertical 

movement through the soil) or runoff (lateral movement across the soil surface). 

 Permeability is the rate of water movement vertically through the soil. It is affected by soil texture 

and structure. Coarse textured soils (e.g., high sand content) have a larger pore size and they are 

generally more permeable than fine textured soils (i.e., high clay content). The more permeable soils 

would have a greater potential for pesticides to move vertically down through the soil profile. Soil 

permeability rates (inches/hour) are usually available in county soil survey reports. 

 Soil texture describes the relative percentage of sand, silt, and clay. In general, greater clay content 

with smaller the pore size would lower the likelihood and rate water that would move through the soil 

profile. Clay also serves to adsorb (bind) pesticides to soil particles. Soils with high clay content 

would adsorb more pesticide than soils with relatively low clay content. In contrast, sandy soils with 

coarser texture and lower water holding capacity would have a greater potential for water to leach 

through them. 

 Soil structure describes soil aggregation. Soils with a well-developed soil structure have looser, more 

aggregated, structure that would be less likely to be compacted. Both characteristics would allow for 

less restricted flow of water through the soil profile resulting in greater infiltration.

 Organic matter would be the single most important factor affecting pesticide adsorption in soils. 

Many pesticides are adsorbed to organic matter which would reduce their rate of downward 

movement through the soil profile. Also, soils high in organic matter would tend to hold more water, 

which may make less water available for leaching. 

 Soil moisture affects how fast water would move through the soil. If soils are already wet or saturated 

before rainfall or irrigation, excess moisture would runoff rather than infiltrate into the soil profile. 

Soil moisture also would influence microbial and chemical activity in soil, which affects pesticide 

degradation. 
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Appendix G. Integrated Pest Management Program G-31

 Soil pH would influence chemical reactions that occur in the soil which in turn determines whether or 

not a pesticide would degrade, rate of degradation, and, in some instances, which degradation 

products are produced. 

Based upon the aforementioned properties, soils most vulnerable to groundwater contamination would be 

sandy soils with low organic matter. In contrast, the least vulnerable soils would be well-drained clayey 

soils with high organic matter. Consequently, pesticides with the lowest potential for movement in 

conjunction with appropriate best management practices (see below) would be used in an IPM framework 

to treat pests while minimizing effects to non-target biota and protecting environmental quality. 

Along with soil properties, the potential for a pesticide to affect water quality through runoff and leaching 

would consider site-specific environmental and abiotic conditions including rainfall, water table 

conditions, and topography (Huddleston 1996). 

 Water is necessary to separate pesticides from soil. This can occur in two basic ways. Pesticides that 

are soluble move easily with runoff water. Pesticide-laden soil particles can be dislodged and 

transported from the application site in runoff. The concentration of pesticides in the surface runoff 

would be greatest for the first runoff event following treatment. The rainfall intensity and route of 

water infiltration into soil, to a large extent, determine pesticide concentrations and losses in surface 

runoff. The timing of the rainfall after application also would have an effect. Rainfall interacts with 

pesticides at a shallow soil depth (1⁄4 to 1⁄2 inch), which is called the mixing zone (Baker and Miller 

1999). The pesticide/water mixture in the mixing zone would tend to leach down into the soil or 

runoff depending upon how quickly the soil surface becomes saturated and how rapidly water can 

infiltrate into the soil. Leaching would decrease the amount of pesticide available near the soil surface 

(mixing zone) to runoff during the initial rainfall event following application and subsequent rainfall 

events. 

 Terrain slope would affect the potential for surface runoff and the intensity of runoff. Steeper slopes 

would have greater potential for runoff following a rainfall event. In contrast, soils that are relatively 

flat would have little potential for runoff, except during intense rainfall events. In addition, soils in 

lower areas would be more susceptible to leaching as a result of receiving excessive water from 

surrounding higher elevations. 

 Depth to groundwater would be an important factor affecting the potential for pesticides to leach into 

groundwater. If the distance from the soil surface to the top of the water table is shallow, pesticides 

would have less distance to travel to reach groundwater. Shallower water tables that persist for longer 

periods would be more likely to experience groundwater contamination. Soil survey reports are 

available for individual counties. These reports provide data in tabular format regarding the water 

table depths and the months during which it is persists. In some situations, a hard pan exists above the 

water table that would prevent pesticide contamination from leaching. 

G.7.5 Determining Effects to Air Quality 

Pesticides may volatilize from soil and plant surfaces and move from the treated area into the atmosphere. 

The potential for a pesticide to volatilize is determined by the pesticide’s vapor pressure which would be 

affected by temperature, sorption, soil moisture, and the pesticide’s water solubility. Vapor pressure is 

often expressed in mm Hg. To make these numbers easier to compare, vapor pressure may be expressed 

in exponent form (I x 10-7), where I represents a vapor pressure index. In general, pesticides with I<10 

would have a low potential to volatilize; whereas, pesticides with I>1,000 would have a high potential to 

volatilize (Oregon State University 1996). Vapor pressure values for pesticides are usually available in 

the pesticide product MSDS or the USDA Agricultural Research Service (ARS) pesticide database. 
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G-32 Appendix G. Integrated Pest Management Program 

G.7.6 Preparing a Chemical Profile 

The following instructions would be used by Service personnel to complete Chemical Profiles for 

pesticides. Specifically, profiles would be prepared for pesticide active ingredients (e.g., glyphosate, 

imazapic) that would be contained in one or more trade name products that are registered and labeled with 

USEPA. All information fields under each category (e.g., Toxicological Endpoints, Environmental Fate) 

would be completed for a Chemical Profile. If no information is available for a specific field, then “No 

data are available in references” would be recorded in the profile. Available scientific information would 

be used to complete Chemical Profiles. Each entry of scientific information would be shown with 

applicable references. 

Completed Chemical Profiles would provide a structured decision-making process utilizing quantitative 

assessment/screening tools with threshold values (where appropriate) that would be used to evaluate 

potential biological and other environmental effects to refuge resources. For ecological risk assessments 

presented in these profiles, the “worst-case scenario” would be evaluated to determine whether a pesticide 

could be approved for use considering the maximum single application rate specified on pesticide labels 

for habitat management and croplands/facilities maintenance treatments pertaining to refuges. Where the 

“worst-case scenario” likely would only result in minor, temporary, and localized effects to listed and 

non-listed species with appropriate BMPs (see Section G.5), the proposed pesticide’s use in a PUP would 

have a scientific basis for approval under any application rate specified on the label that is at or below 

rates evaluated in a Chemical Profile. In some cases, the Chemical Profile would include a lower 

application rate than the maximum labeled rate in order to protect refuge resources. As necessary, 

Chemical Profiles would be periodically updated with new scientific information or as pesticides with the 

same active ingredient are proposed for use on the refuge in PUPs. 

Throughout this section, threshold values (to prevent or minimize potential biological and environmental 

effects) would be clearly identified for specific information presented in a completed Chemical Profile. 

Comparison with these threshold values provides an explicit scientific basis to approve or disapprove 

PUPs for habitat management and cropland/facilities maintenance on refuge lands. In general, PUPs 

would be approved for pesticides with Chemical Profiles where there would be no exceedances of 

threshold values. However, BMPs are identified for some screening tools that would minimize/eliminate 

potential effects (exceedance of the threshold value) as a basis for approving PUPs. 

Date: Service personnel would record the date when the Chemical Profile is completed or updated. 

Chemical Profiles (e.g., currently approved pesticide use patterns) would be periodically reviewed and 

updated, as necessary. The most recent review date would be recorded on a profile to document when it 

was last updated. 

Trade Name(s): Service personnel would accurately and completely record the trade name(s) from the 

pesticide label, which includes a suffix that describes the formulation (e.g., WP, DG, EC, L, SP, I, II or 

64). The suffix often distinguishes a specific product among several pesticides with the same active 

ingredient. Service personnel would record a trade name for each pesticide product with the same active 

ingredient. 

Common chemical name(s): Service personnel would record the common name(s) listed on the pesticide 

label or material safety data sheet (MSDS) for an active ingredient. The common name of a pesticide is 

listed as the active ingredient on the title page of the product label immediately following the trade name, 

and the MSDS, Section 2: Composition/ Information on Ingredients. A Chemical Profile is completed for 

each active ingredient. 
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Appendix G. Integrated Pest Management Program G-33

Pesticide Type: Service personnel would record the type of pesticide for an active ingredient as one of 

the following: herbicide, desiccant, fungicide, fumigant, growth regulator, insecticide, piscicide, or 

rodenticide. 

EPA Registration Number(s): This number (EPA Reg. No.) appears on the title page of the label and 

MSDS, Section 1: Chemical Product and Company Description. It is not the EPA Establishment Number 

that is usually located near it. Service personnel would record the EPA Reg. No. for each trade name 

product with an active ingredient based upon PUPs. 

Pesticide Class: Service personnel would list the general chemical class for the pesticide (active 

ingredient). For example, malathion is an organophosphate and carbaryl is a carbamate. 

CAS (Chemical Abstract Service) Number: This number is often located in the second section 

(Composition/Information on Ingredients) of the MSDS. The MSDS table listing components usually 

contains this number immediately prior to or following the % composition. 

Other Ingredients: From the most recent MSDS for the proposed pesticide product(s), Service personnel 

would include any chemicals in the pesticide formulation not listed as an active ingredient that are 

described as toxic or hazardous, or regulated under the Superfund Amendments and Reauthorization Act 

(SARA), Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), Toxic 

Substances Control Act (TSCA), Occupational Safety and Health Administration (OSHA), State Right-toKnow, or other listed authorities. These are usually found in MSDS sections titled “Hazardous 

Identifications”, “Exposure Control/Personal Protection”, and “Regulatory Information”. If 

concentrations of other ingredients are available for any compounds identified as toxic or hazardous, then 

Service personnel would record this information in the Chemical Profile by trade name. MSDS(s) may be 

obtained from the manufacturer, manufacturer’s website or from an on-line database maintained by Crop 

Data Management Systems, Inc. (see list below). 

Toxicological Endpoints 

Toxicological endpoint data would be collected for acute and chronic tests with mammals, birds, and fish. 

Data would be recorded for species available in the scientific literature. If no data are found for a 

particular taxonomic group, then “No data are available in references” would be recorded as the data 

entry. Throughout the Chemical Profile, references (including toxicological endpoint data) would be cited 

using parentheses (#) following the recorded data. 

Mammalian LD50: For test species in the scientific literature, Service personnel would record available 

data for oral lethal dose (LD50) in mg/kg-bw (body weight) or ppm-bw. Most common test species in 

scientific literature are the rat and mouse. The lowest LD50 value found for a rat would be used as a 

toxicological endpoint for dose-based RQ calculations to assess acute risk to mammals (see Table G-1 in 

Section G.7.1). 

Mammalian LC50: For test species in the scientific literature, Service personnel would record available 

data for dietary lethal concentration (LC50) as reported (e.g., mg/kg-diet or ppm-diet). Most common test 

species in scientific literature are the rat and mouse. The lowest LC50 value found for a rat would be used 

as a toxicological endpoint for diet-based RQ calculations to assess acute risk (see Table G-1 in Section 

G.7.1). 

Mammalian Reproduction: For test species listed in the scientific literature, Service personnel would

record the test results (e.g., Lowest Observed Effect Concentration [LOEC], Lowest Observed Effect 

Level [LOEL], No Observed Adverse Effect Level [NOAEL], No Observed Adverse Effect 
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Concentration [NOAEC]) in mg/kg-bw or mg/kg-diet for reproductive test procedure(s) (e.g., 

generational studies [preferred], fertility, new born weight). Most common test species available in 

scientific literature are rats and mice. The lowest NOEC, NOAEC, NOEL, or NOAEL test results found 

for a rat would be used as a toxicological endpoint for RQ calculations to assess chronic risk (see Table 

G-1 in Section G.7.1). 

Avian LD50: For test species available in the scientific literature, Service personnel would record values 

for oral lethal dose (LD50) in mg/kg-bw or ppm-bw. Most common test species available in scientific 

literature are the bobwhite quail and mallard. The lowest LD50 value found for an avian species would be 

used as a toxicological endpoint for dose-based RQ calculations to assess acute risk (see Table G-1 in 

Section G.7.1). 

Avian LC50: For test species available in the scientific literature, Service personnel would record values 

for dietary lethal concentration (LC50) as reported (e.g., mg/kg-diet or ppm-diet). Most common test 

species available in scientific literature are the bobwhite quail and mallard. The lowest LC50 value found 

for an avian species would be used as a toxicological endpoint for dietary-based RQ calculations to assess 

acute risk (see Table G-1 in Section G.7.1). 

Avian Reproduction: For test species available in the scientific literature, Service personnel would

record test results (e.g., LOEC, LOEL, NOAEC, NOAEL) in mg/kg-bw or mg/kg-diet consumed for 

reproductive test procedure(s) (e.g., early life cycle, reproductive). Most common test species available in 

scientific literature are the bobwhite quail and mallard. The lowest NOEC, NOAEC, NOEL, or NOAEL 

test results found for an avian species would be used as a toxicological endpoint for RQ calculations to 

assess chronic risk (see Table G-1 in Section G.7.1). 

Fish LC50: For test freshwater or marine species listed in the scientific literature, Service personnel would

record a LC50 in ppm or mg/L. Most common test species available in the scientific literature are the 

bluegill, rainbow trout, and fathead minnow (marine). Test results for many game species may also be 

available. The lowest LC50 value found for a freshwater fish species would be used as a toxicological 

endpoint for RQ calculations to assess acute risk (see Table G-1 in Section G.7.1). 

Fish Early Life Stage (ELS)/Life Cycle: For test freshwater or marine species available in the scientific 

literature, Service personnel would record test results (e.g., LOEC, NOAEL, NOAEC, LOAEC) in ppm 

for test procedure(s) (e.g., early life cycle, life cycle). Most common test species available in the scientific 

literature are bluegill, rainbow trout, and fathead minnow. Test results for other game species may also be 

available. The lowest test value found for a fish species (preferably freshwater) would be used as a 

toxicological endpoint for RQ calculations to assess chronic risk (see Table G-1 in Section G.7.1). 

Other: For test invertebrate as well as non-vascular and vascular plant species available in the scientific 

literature, Service personnel would record LC50, LD50, LOEC, LOEL, NOAEC, NOAEL, or EC50 

(environmental concentration) values in ppm or mg/L. Most common test invertebrate species available in 

scientific literature are the honey bee and the water flea (Daphnia magna). Green algae (Selenastrum 

capricornutum) and pondweed (Lemna minor) are frequently available test species for aquatic nonvascular and vascular plants, respectively. 

Ecological Incident Reports: After a site has been treated with pesticide(s), wildlife may be exposed to 

these chemical(s). When exposure is high relative to the toxicity of the pesticides, wildlife may be killed 

or visibly harmed (incapacitated). Such events are called ecological incidents. The USEPA maintains a 

database (Ecological Incident Information System) of ecological incidents. This database stores 

information extracted from incident reports submitted by various federal and state agencies and nongovernment organizations. Information included in an incident report is date and location of the incident, 
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Appendix G. Integrated Pest Management Program G-35

type and magnitude of effects observed in various species, use(s) of pesticides known or suspected of 

contributing to the incident, and results of any chemical residue and cholinesterase activity analyses 

conducted during the investigation. 

Incident reports can play an important role in evaluating the effects of pesticides by supplementing 

quantitative risk assessments. All incident reports for pesticide(s) with the active ingredient and 

associated information would be recorded. 

Environmental Fate 

Water Solubility: Service personnel would record values for water solubility (Sw), which describes the 

amount of pesticide that dissolves in a known quantity of water. Sw is expressed as mg/L (ppm). Pesticide 

Sw values would be categorized as one of the following: insoluble <0.1 ppm, moderately soluble = 100 to 

1,000 ppm, highly soluble >10,000 ppm (USGS 2000). As pesticide Sw increases, there would be greater 

potential to degrade water quality through runoff and leaching. 

Sw would be used to evaluate potential for bioaccumulation in aquatic species [see Octanol-Water 

Partition Coefficient (Kow) below]. 

Soil Mobility: Service personnel would record available values for soil adsorption coefficient (Koc

[μg/g]). It provides a measure of a chemical’s mobility and leaching potential in soil. Koc values are 

directly proportional to organic content, clay content, and surface area of the soil. Koc data for a pesticide 

may be available for a variety of soil types (e.g., clay, loam, sand). 

Koc values would be used in evaluating the potential to degrade groundwater by leaching (see Potential to 

Move to Groundwater below).

Soil Persistence: Service personnel would record values for soil half-life (t1⁄2), which represents the length 

of time (days) required for 50% of the deposited pesticide to degrade (completely or partially) in the soil. 

Based upon the t1⁄2 value, soil persistence would be categorized as one of the following: non-persistent <30 

days, moderately persistent = 30 to 100 days, and persistent >100 days (Kerle et al. 1996). 

Threshold for Approving PUPs: 

If soil t1⁄2 ≤100 days, then a PUP would be approved without additional BMPs to protect water quality. 

If soil t1⁄2 >100 days, then a PUP would only be approved with additional BMPs specifically to protect 

water quality. One or more BMPs such as the following would be included in the Specific Best 

Management Practices (BMPs) section to minimize potential surface runoff and leaching that can 

degrade water quality: 

 Do not exceed one application per site per year. 

 Do not use on coarse-textured soils where the ground water table is <10 feet and average annual 

precipitation >12 inches. 

 Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is saturated. 

Along with Koc, soil t1⁄2 values would be used in evaluating the potential to degrade groundwater by 

leaching (see Potential to Move to Groundwater below). 

Soil Dissipation: Dissipation time (DT50) represents the time required for 50% of the deposited pesticide 

to degrade and move from a treated site; whereas, soil t1⁄2 describes the rate for degradation only. As for t1⁄2, 
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units of dissipation time are usually expressed in days. Field dissipation time would be the preferred data 

for use to estimate pesticide concentrations in the environment because it is based upon field studies 

compared to soil t1⁄2, which is derived in a laboratory. However, soil t1⁄2 is the most common persistence 

data available in the published literature. If field dissipation data are not available, soil half-life data 

would be used in a Chemical Profile. The average or representative half-life value of most important 

degradation mechanism would be selected for quantitative analysis for both terrestrial and aquatic 

environments. 

Based upon the DT50 value, environmental persistence in the soil also would be categorized as one of the 

following: non-persistent <30 days, moderately persistent = 30 to 100 days, and persistent >100 days. 

Threshold for Approving PUPs: 

If soil DT50 ≤100 days, then a PUP would be approved without additional BMPs to protect water quality. 

If soil DT50 >100 days, then a PUP would only be approved with additional BMPs specifically to protect 

water quality. One or more BMPs such as the following would be included in the Specific Best 

Management Practices (BMPs) section to minimize potential surface runoff and leaching that can 

degrade water quality: 

 Do not exceed one application per site per year. 

 Do not use on coarse-textured soils where the ground water table is <10 feet and average annual 

precipitation >12 inches. 

 Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is saturated. 

Along with Koc, soil DT50 values (preferred over soil t1⁄2) would be used in evaluating the potential to 

degrade groundwater by leaching (see Potential to Move to Groundwater below), if available. 

Aquatic Persistence: Service personnel would record values for aquatic t1⁄2, which represents the length 

of time required for 50% of the deposited pesticide to degrade (completely or partially) in water. Based 

upon the t1⁄2 value, aquatic persistence would be categorized as one of the following: non-persistent <30 

days, moderately persistent = 30 to 100 days, and persistent >100 days (Kerle et al. 1996). 

Threshold for Approving PUPs: 

If aquatic t1⁄2 ≤100 days, then a PUP would be approved without additional BMPs to protect water quality. 

If aquatic t1⁄2 >100 days, then a PUP would only be approved with additional BMPs specifically to protect 

water quality. One or more BMPs such as the following would be included in the Specific Best 

Management Practices (BMPs) section to minimize potential surface runoff and leaching that can 

degrade water quality: 

 Do not exceed one application per site per year. 

 Do not use on coarse-textured soils where the ground water table is <10 feet and average annual 

precipitation >12 inches. 

 Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is saturated. 

Aquatic Dissipation: Dissipation time (DT50) represents the time required for 50% of the deposited 

pesticide to degrade or move (dissipate); whereas, aquatic t1⁄2 describes the rate for degradation only. As 

for t1⁄2, units of dissipation time are usually expressed in days. Based upon the DT50 value, environmental 
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Appendix G. Integrated Pest Management Program G-37

persistence in aquatic habitats also would be categorized as one of the following: non-persistent <30 days, 

moderately persistent = 30 to 100 days, and persistent >100 days. 

Threshold for Approving PUPs: 

If aquatic DT50 ≤100 days, then a PUP would be approved without additional BMPs to protect water 

quality. 

If aquatic DT50 >100 days, then a PUP would only be approved with additional BMPs specifically to 

protect water quality. One or more BMPs such as the following would be included in the Specific Best 

Management Practices (BMPs) section to minimize potential surface runoff and leaching that can 

degrade water quality: 

 Do not exceed one application per site per year. 

 Do not use on coarse-textured soils where the ground water table is <10 feet and average annual 

precipitation >12 inches. 

 Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is saturated. 

Potential to Move to Groundwater: Groundwater Ubiquity Score (GUS) = log10(soil t 1⁄2) x [4 – 

log10(Koc)]. If a DT50 value is available, it would be used rather than a t 1⁄2 value to calculate a GUS score. 

Based upon the GUS value, the potential to move toward groundwater would be recorded as one of the 

following categories: extremely low potential <1.0; low = 1.0 to 2.0; moderate = 2.0 to 3.0; high = 3.0 to 

4.0; or very high >4.0. 

Threshold for Approving PUPs: 

If GUS ≤4.0, then a PUP would be approved without additional BMPs to protect water quality. 

If GUS>4.0, then a PUP would only be approved with additional BMPs specifically to protect water 

quality. One or more BMPs such as the following would be included in the Specific Best Management 

Practices (BMPs) section to minimize potential surface runoff and leaching that can degrade water 

quality: 

 Do not exceed one application per site per year. 

 Do not use on coarse-textured soils where the ground water table is <10 feet and average annual 

precipitation >12 inches. 

 Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is saturated. 

Volatilization: Pesticides may volatilize (evaporate) from soil and plant surfaces and move off-target into 

the atmosphere. The potential for a pesticide to volatilize is a function of its vapor pressure that is affected 

by temperature, sorption, soil moisture, and the pesticide’s water solubility. Vapor pressure is often 

expressed in mm Hg. To make these values easier to compare, vapor pressure would be recorded by 

Service personnel in exponential form (I x 10-7), where I represents a vapor pressure index. In general, 

pesticides with I<10 would have low potential to volatilize; whereas, pesticides with I >1,000 would have 

a high potential to volatilize (Oregon State University 1996). Vapor pressure values for pesticides are 

usually available in the pesticide product MSDS or the USDA Agricultural Research Service (ARS) 

pesticide database (see References). 
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Threshold for Approving PUPs: 

If I ≤1,000, then a PUP would be approved without additional BMPs to minimize drift and protect air 

quality. 

If I>1,000, then a PUP would only be approved with additional BMPs specifically to minimize drift and 

protect air quality. One or more BMPs such as the following would be included in the Specific Best 

Management Practices (BMPs) section to reduce volatilization and potential to drift and degrade air 

quality: 

 Do not treat when wind velocities are <2 or >10 mph with existing or potential inversion conditions. 

 Apply the large-diameter droplets possible for spray treatments. 

 Avoid spraying when air temperatures >85o

F. 

 Use the lowest spray height possible above target canopy. 

 Where identified on the pesticide label, soil incorporates pesticide as soon as possible during or after 

application. 

Octanol-Water Partition Coefficient (Kow): The octanol-water partition coefficient (Kow) is the 

concentration of a pesticide in octanol and water at equilibrium at a specific temperature. Because octanol 

is an organic solvent, it is considered a surrogate for natural organic matter. Therefore, Kow would be used 

to assess potential for a pesticide to bioaccumulate in tissues of aquatic species (e.g., fish). If Kow >1,000 

or Sw<1 mg/L and soil t1⁄2>30 days, then there would be high potential for a pesticide to bioaccumulate in 

aquatic species such as fish (USGS 2000). 

Threshold for Approving PUPs: 

If there is not a high potential for a pesticide to bioaccumulate in aquatic species, then the PUP would be 

approved. 

If there is a high potential to bioaccumulate in aquatic species (Kow>1,000 or Sw<1 mg/L and soil t1⁄2>30 

days), then the PUP would not approved, except under unusual circumstances where approval would 

only be granted by the Washington Office. 

Bioaccumulation/Bioconcentration: The physiological process where pesticide concentrations in tissue 

would increase in biota because they are taken and stored at a faster rate than they are metabolized or 

excreted. The potential for bioaccumulation would be evaluated through bioaccumulation factors (BAFs) 

or bioconcentration factors (BCFs). Based upon BAF or BCF values, the potential to bioaccumulate 

would be recorded as one of the following: low = 0 to 300; moderate = 300 to 1,000; or high >1,000 

(Calabrese and Baldwin 1993). 

Threshold for Approving PUPs: 

If BAF or BCF≤1,000, then a PUP would be approved without additional BMPs. 

If BAF or BCF>1,000, then a PUP would not approved, except under unusual circumstances where 

approval would only be granted by the Washington Office. 

Worst-Case Ecological Risk Assessment 

Max Application Rates (acid equivalent): Service personnel would record the highest application rate 

of an active ingredient (ae basis) for habitat management and cropland/facilities maintenance treatments 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix G. Integrated Pest Management Program G-39

in this data field of a Chemical Profile. These rates can be found in Table CP.1 under the column heading 

“Max Product Rate – Single Application (lbs/acre – AI on acid equiv basis)”. This table would be 

prepared for a Chemical Profile from information specified in labels for trade name products identified in 

PUPs. If these data are not available in pesticide labels, then write “NS” for “not specified on label” in 

this table. 

EECs: An estimated environmental concentration (ECC) represents potential exposure to fish and 

wildlife (birds and mammals) from using a pesticide. EECs would be derived by Service personnel using 

an USEPA screening-level approach (USEPA 2004). For each max application rate [see description under 

Max Application Rates (acid equivalent)], Service personnel would record 2 EEC values in a Chemical 

Profile; these would represent the worst-case terrestrial and aquatic exposures for habitat management 

and croplands/facilities maintenance treatments. For terrestrial and aquatic EEC calculations, see 

description for data entry under Presumption of Unacceptable Risk/Risk Quotients, which is the next 

field for a Chemical Profile. 

Presumption of Unacceptable Risk/Risk Quotients: Service personnel would calculate and record 

acute and chronic risk quotients (RQs) for birds, mammals, and fish using the provided tabular formats 

for habitat management and/or cropland/facilities maintenance treatments. RQs recorded in a Chemical 

Profile would represent the worst-case assessment for ecological risk. See Section G.7.2 for discussion 

regarding the calculations of RQs. 

For aquatic assessments associated with habitat management treatments, RQ calculations would be based 

upon selected acute and chronic toxicological endpoints for fish and the EEC would be derived from 

Urban and Cook (1986) assuming 100% overspray to an entire 1-foot deep water body using the max 

application rate (ae basis [see above]). 

For aquatic assessments associated with cropland/facilities maintenance treatments, RQ calculations 

would be done by Service personnel based upon selected acute and chronic toxicological endpoints for 

fish and an EEC would be derived from the aquatic assessment in AgDRIFT® model version 2.01 under 

Tier I ground-based application with the following input variables: max application rate (acid basis [see 

above]), low boom (20 inches), fine to medium/coarse droplet size, 20 swaths, EPA-defined wetland, and 

25-foot distance (buffer) from treated area to water. 

See Section G.7.2.1.2 for more details regarding the calculation of EECs for aquatic habitats for habitat 

management and cropland/facilities maintenance treatments. 

For terrestrial avian and mammalian assessments, RQ calculations would be done by Service personnel 

based upon dietary exposure, where the “short grass” food item category would represent the worst-case 

scenario. For terrestrial spray applications associated with habitat management and cropland/facilities 

maintenance treatments, exposure (EECs and RQs) would be determined using the Kanaga nomogram 

method through the USEPA’s Terrestrial Residue Exposure model (T-REX) version 1.2.3. T-REX input 

variables would include the following: max application rate (acid basis [see above]) and pesticide half-life 

(days) in soil to estimate the initial, maximum pesticide residue concentration on general food items for 

terrestrial vertebrate species in short (<20 cm tall) grass. 

For granular pesticide formulations and pesticide-treated seed with a unique route of exposure for 

terrestrial avian and mammalian wildlife, see Section G.7.2.1.1.2 for the procedure that would be used to 

calculate RQs. 

All calculated RQs in both tables would be compared with Levels of Concern (LOCs) established by 

USEPA (see Table G-2 in Section G.7.2). If a calculated RQ exceeds an established LOC value (in 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

G-40 Appendix G. Integrated Pest Management Program 

brackets inside the table), then there would be a potential for an acute or chronic effect (unacceptable risk) 

to federally listed (T&E) species and nonlisted species. See Section G.7.2 for detailed descriptions of 

acute and chronic RQ calculations and comparison to LOCs to assess risk. 

Threshold for approving PUPs: 

If RQs≤LOCs, then a PUP would be approved without additional BMPs. 

If RQs>LOCs, then a PUP would only be approved with additional BMPs specifically to minimize 

exposure (ecological risk) to bird, mammal, and/or fish species. One or more BMPs such as the following 

would be included in the Specific Best Management Practices (BMPs) section to reduce potential risk 

to non-listed or listed species: 

 Lower application rate and/or fewer number of applications so RQs≤LOCs 

 For aquatic assessments (fish) associated with cropland/facilities maintenance, increase the buffer 

distance beyond 25 feet so RQs≤LOCs. 

Justification for Use: Service personnel would describe the reason for using the pesticide based control 

of specific pests or groups of pests. In most cases, the pesticide label will provide the appropriate 

information regarding control of pests to describe in the section. 

Specific Best Management Practices (BMPs): Service personnel would record specific BMPs necessary 

to minimize or eliminate potential effects to non-target species and/or degradation of environmental 

quality from drift, surface runoff, or leaching. These BMPs would be based upon scientific information 

documented in previous data fields of a Chemical Profile. Where necessary and feasible, these specific 

practices would be included in PUPs as a basis for approval. 

If there are no specific BMPs that are appropriate, then Service personnel would describe why the 

potential effects to refuge resources and/or degradation of environmental quality is outweighed by the 

overall resource benefit(s) from the proposed pesticide use in the BMP section of the PUP. See Section 

G.4 of this document for a complete list of BMPs associated with mixing and applying pesticides 

appropriate for all PUPs with ground-based treatments that would be additive to any necessary, chemicalspecific BMPs. 

References: Service personnel would record scientific resources used to provide data/information for a 

chemical profile. Use the number sequence to uniquely reference data in a chemical profile. 

The following on-line data resources are readily available for toxicological endpoint and environmental 

fate data for pesticides: 

1. California Product/Label Database. Department of Pesticide Regulation, California Environmental 

Protection Agency. (http://www.cdpr.ca.gov/docs/label/labelque.htm#regprods) 

2. ECOTOX database. Office of Pesticide Programs, US Environmental Protection Agency, 

Washington, D.C. (http://cfpub.epa.gov/ecotox/) 

3. Extension Toxicology Network (EXTOXNET) Pesticide Information Profiles. Cooperative effort of 

University of California-Davis, Oregon State University, Michigan State University, Cornell 

University and University of Idaho through Oregon State University, Corvallis, Oregon. 

(http://extoxnet.orst.edu/pips/ghindex.html) 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix G. Integrated Pest Management Program G-41

4. FAO specifications and evaluations for plant protection products. Pesticide Management Unit, Plant 

Protection Services, Food and Agriculture Organization, United Nations. 

(http://www.fao.org/WAICENT/FAOINFO/AGRICULT/AGP/AGPP/Pesticid/) 

5. Human health and ecological risk assessments. Pesticide Management and Coordination, Forest 

Health Protection, US Department of Agriculture, US Forest Service. 

(http://www.fs.fed.us/foresthealth/pesticide/risk.htm) 

6. Pesticide Chemical Fact Sheets. Clemson University Pesticide Information Center. 

(http://entweb.clemson.edu/pesticid/Document/Labels/factshee.htm) 

7. Pesticide Fact Sheets. Published by Information Ventures, Inc. for Bureau of Land Management, 

Dept. of Interior; Bonneville Power Administration, U.S. Dept. of Energy; and Forest Service, US 

Department of Agriculture. (http://infoventures.com/e-hlth/pesticide/pest-fac.html) 

8. Pesticide Fact Sheets. National Pesticide Information Center. (http://npic.orst.edu/npicfact.htm) 

9. Pesticide Fate Database. US Environmental Protection Agency, Washington, D.C. 

(http://cfpub.epa.gov/pfate/home.cfm) 

10. Pesticide product labels and material safety data sheets. Crop Data Management Systems, Inc. 

(CDMS) (http://www.cdms.net/pfa/LUpdateMsg.asp) or multiple websites maintained by 

agrichemical companies. 

11. Registered Pesticide Products (Oregon database). Oregon Department of Agriculture. 

(http://www.oda.state.or.us/dbs/pest_products/search.lasso) 

12. Regulatory notes. Pest Management Regulatory Agency, Health Canada, Ontario, Canada. 

(http://www.hc-sc.gc.ca/pmra-arla/) 

13. Reptile and Amphibian Toxicology Literature. Canadian Wildlife Service, Environment Canada, 

Ontario, Canada. (http://www.cws-scf.ec.gc.ca/nwrc-cnrf/ratl/index_e.cfm) 

14. Specific Chemical Fact Sheet – New Active Ingredients, Biopesticide Fact Sheet and Registration 

Fact Sheet. U.S. Environmental Protection Agency, Washington, D.C. 

(http://www.epa.gov/pestidides/factsheets/chemical_fs.htm) 

15. Weed Control Methods Handbook: Tools and Techniques for Use in Natural Areas. The Invasive 

Species Initiative. The Nature Conservancy. (http://tnsweeds.ucdavis.edu/handbook.html) 

16. Wildlife Contaminants Online. US Geological Survey, Department of Interior, Washington, D.C. 

(http://www.pwrc.usgs.gov/contaminants-online/) 

17. One-liner database. 2000. US Environmental Protection Agency, Office of Pesticide Programs, 

Washington, D.C. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

G-42 Appendix G. Integrated Pest Management Program 

Chemical Profile 

Date: 

Trade Name(s): Common Chemical 

Name(s): 

Pesticide Type: EPA Registration 

Number: 

Pesticide Class: CAS Number: 

Other Ingredients: 

Toxicological Endpoints

Mammalian LD50: 

Mammalian LC50: 

Mammalian Reproduction: 

Avian LD50: 

Avian LC50: 

Avian Reproduction: 

Fish LC50: 

Fish ELS/Life Cycle: 

Other: 

Ecological Incident Reports 

Environmental Fate 

Water solubility (Sw): 

Soil Mobility (Koc): 

Soil Persistence (t1⁄2): 

Soil Dissipation (DT50): 

Aquatic Persistence (t1⁄2): 

Aquatic Dissipation (DT50): 

Potential to Move to Groundwater 

(GUS score): 

Volatilization (mm Hg): 

Octanol-Water Partition Coefficient 

(Kow): 

Bioaccumulation/Bioconcentration: BAF:` 

BCF: 

Worst Case Ecological Risk Assessment

Max Application 

Rate 

(ai lbs/acre – ae 

basis) 

Habitat Management: 

Croplands/Facilities Maintenance: 

EECs Terrestrial (Habitat Management): 

Terrestrial (Croplands/Facilities Maintenance): 

Aquatic (Habitat Management): 

Aquatic (Croplands/Facilities Maintenance): 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix G. Integrated Pest Management Program G-43

Habitat Management Treatments: 

Presumption of Unacceptable Risk Risk Quotient (RQ) 

Listed (T&E) 

Species 

Nonlisted Species 

Acute Birds [0.1] [0.5] 

Mammals [0.1] [0.5] 

Fish [0.05] [0.5] 

Chronic Birds [1] [1] 

Mammals [1] [1] 

Fish [1] [1] 

Cropland/Facilities Maintenance Treatments: 

Presumption of Unacceptable Risk Risk Quotient (RQ) 

Listed (T&E) 

Species Nonlisted Species 

Acute Birds [0.1] [0.5] 

Mammals [0.1] [0.5] 

Fish [0.05] [0.5] 

Chronic Birds [1] [1] 

Mammals [1] [1] 

Fish [1] [1] 

Justification for Use: 

Specific Best 

Management Practices 

(BMPs): 

References: 

 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

G-44 Appendix G. Integrated Pest Management Program 

Table CP.1 Pesticide Name 

Trade Namea

Treatm

ent 

Typeb 

Max Product 

Rate – Single 

Application 

(lbs/acre or 

gal/acre) 

Max 

Product 

Rate -Single 

Application 

(lbs/acre - 

AI on acid 

equiv basis) 

Max Number 

of 

Applications 

Per Season 

Max Product 

Rate Per 

Season 

(lbs/acre/seas

on or 

gal/acre/seaso

n) 

Minimum 

Time 

Between 

Application

s (Days) 

 

a

From each label for a pesticide identified in pesticide use proposals (PUPs), Service personnel would 

record application information associated with possible/known uses on Service lands.

b

Treatment type: H – habitat management or CF – cropland/facilities maintenance. If a pesticide is labeled 

for both types of treatments (uses), then record separate data for H and CF applications. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix G. Integrated Pest Management Program G-45

G.8 References 

AgDrift. 2001. A user’s guide for AgDrift 2.04: a tiered approach for the assessment of spray drift of 

pesticides. Spray Drift Task Force. Macon, MO. 

ATSDR (Agency for Toxic Substances and Disease Registry) U.S. Department of Health and Human 

Services. 2004. Guidance manual for the assessment of joint toxic action of chemical mixtures. 

U.S. Department of Health and Human Services, Public Health Service, ATSDR, Division of 

Toxicology. 62 pp. (+ appendices). 

Baehr, C.H. and C. Habig. 2000. Statistical evaluation of the UTAB database for use in terrestrial 

nontarget organism risk assessment. Presentation at the American Society for Testing and 

Materials (ASTM) Tenth Symposium on Environmental Toxicology and Risk Assessment, April 

2000, Toronto, Canada. 

Baker, J. and G. Miller. 1999. Understanding and reducing pesticide losses. Extension Publication PM 

1495. Iowa State University Extension. Ames, IA. 6 pp. 

Barry, T. 2004. Characterization of propanil prune foliage residues as related to propanil use patterns in 

the Sacramento Valley, CA. Proceedings of the International Conference on Pesticide Application 

for Drift Management. Waikoloa, HI. 15 pp. 

Battaglin, W.A., E.M. Thurman, S.J. Kalkhoff, and S.D. Porter. 2003. Herbicides and transformation 

products in surface waters of the midwestern United States. Journal of the American Water 

Resources Association (JAWRA) 39(4):743-756. 

Beyer, W.N., E.E. Connor, and S. Gerould. 1994. Estimates of soil ingestion by wildlife. Journal of 

Wildlife Management 58:375-382. 

BLM (Bureau of Land Management). 2007. Vegetation treatments using herbicides on Bureau of Land 

Management Lands in 17 western states Programmatic EIS (PEIS). Bureau of Land Management. 

Washington, D.C. 539 pp. 

Brooks, M.L., C.M. D’Antonio, D.M. Richardson, J.B. Grace, J.E. Keeley, J.M. DiTomaso, R.J. Hobbs, 

M. Pellant, and D. Pyke. 2004. Effects of invasive alien plants on fire regimes. BioScience 54:77-

88. 

Butler, T., W. Martinkovic, and O.N. Nesheim. 1998. Factors influencing pesticide movement to ground 

water. Extension Publication PI-2, University of Florida, Cooperative Extension Service, 

Gainesville, FL. 4 pp. 

Calabrese, E.J. and L.A. Baldwin. 1993. Performing ecological risk assessments. Chelsea, MI: Lewis 

Publishers. 

Center, T.D., J.H. Frank, and F.A. Dray, Jr. 1997. Biological control. Pages 245-263 in: D. Simberloff, 

D.C. Schmitz, and T.C. Brown, eds. Strangers in paradise: impact and management of 

nonindigenous species in Florida. Washington, D.C.: Island Press. 

Coombs, E.M., J.K. Clark, G.L. Piper, and A.F. Cofrancesco, Jr. 2004. Biological control of invasive 

plants in the United States. Corvallis, OR: Oregon State University Press. 

Cox, R.D. and V.J. Anderson. 2004. Increasing native diversity of cheatgrass-dominated rangeland 

through assisted succession. Journal of Range Management 57:203-210. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

G-46 Appendix G. Integrated Pest Management Program 

Driver, C.J., M.W. Ligotke, P. Van Voris, B.D. McVeety, B.J. Greenspan, and D.B. Brown. 1991. Routes 

of uptake and their relative contribution to the toxicologic response of northern bobwhite 

(Colinus virginianus) to an organophosphate pesticide. Environmental Toxicology and Chemistry 

10:21-33. 

Dunning, J.B. 1984. Body weights of 686 species of North American birds. Western Bird Banding 

Association. Monograph No. 1. Cave Creek, AZ: Eldon Publishing. 

EXTOXNET. 1993. Movement of pesticides in the environment. Pesticide Information Project of 

Cooperative Extension Offices of Cornell University, Oregon State University, University of 

Idaho, University of California – Davis, and the Institute for Environmental Toxicology, 

Michigan State University. 4 pp. 

Fletcher, J.S., J.E. Nellessen, and T.G. Pfleeger. 1994. Literature review and evaluation of the EPA foodchain (Kanaga) nomogram, and instrument for estimating pesticide residue on plants. 

Environmental Toxicology and Chemistry 13:1381-1391. 

Hasan, S. and P.G. Ayres. 1990. The control of weeds through fungi: principles and prospects. Tansley 

Review 23:201-222. 

Huddleston, J.H. 1996. How soil properties affect groundwater vulnerability to pesticide contamination. 

EM 8559. Oregon State University Extension Service. Corvallis, OR. 4 pp. 

Kerle, E.A., J.J. Jenkins, and P.A. Vogue. 1996. Understanding pesticide persistence and mobility for 

groundwater and surface water protection. EM 8561. Oregon State University Extension Service. 

Corvallis, OR. 8 pp. 

Masters, R.A. and R.L. Sheley. 2001. Invited synthesis paper: principles and practices for managing 

rangeland invasive plants. Journal of Range Management 54:502-517. 

Masters, R.A., S.J. Nissen, R.E. Gaussoin, D.D. Beran, and R.N. Stougaard. 1996. Imidazolinone 

herbicides improve restoration of Great Plains grasslands. Weed Technology 10:392-403. 

Maxwell, B.D., E. Lehnhoff, and L.J. Rew. 2009. The rationale for monitoring invasive plant populations 

as a crucial step for management. Invasive Plant Science and Management 2:1-9 

Mineau, P., B.T. Collins, and A. Baril. 1996. On the use of scaling factors to improve interspecies 

extrapolation to acute toxicity in birds. Regulatory Toxicology and Pharmacology 24:24-29. 

Moody, M.E. and R.N. Mack. 1988. Controlling the spread of plant invasions: the importance of nascent 

foci. Journal of Applied Ecology 25:1009-1021. 

Mullin, B.H., L.W. Anderson, J.M. DiTomaso, R.E. Eplee, and K.D. Getsinger. 2000. Invasive plant 

species. Council for Agricultural Science and Technology Issue Paper (13):1-18. 

Oregon State University. 1996. EXTOXNET-Extension Toxicology Network, Pesticide Information 

Profiles. Oregon State University. Corvallis, OR. 

Pfleeger, T.G., A. Fong, R. Hayes, H. Ratsch, and C. Wickliff. 1996. Field evaluation of the EPA 

(Kanaga) nomogram, a method for estimating wildlife exposure to pesticide residues on plants. 

Environmental Toxicology and Chemistry 15:535-543. 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix G. Integrated Pest Management Program G-47

Pope, R., J. DeWitt, and J. Ellerhoff. 1999. Pesticide movement: what farmers need to know. Extension 

Publication PAT 36. Iowa State University Extension, Ames, IA, and Iowa Department of 

Agriculture and Land Stewardship, Des Moines, IA. 6 pp. 

Ramsay, C.A., G.C. Craig, and C.B. McConnell. 1995. Clean water for Washington—protecting 

groundwater from pesticide contamination. Extension Publication EB1644. Washington State 

University Extension. Pullman, WA. 12 pp. 

SDTF 2003 (Spray Drift Task Force 2003). 2003. A summary of chemigation application studies. Spray 

Drift Task Force. Macon, MO. 

Urban, D.J. and N.J. Cook. 1986. Ecological risk assessment. EPA 540/9-85-001. U.S. Environmental 

Protection Agency, Office of Pesticide Programs. Washington, D.C. 94 pp. 

USEPA (U.S. Environmental Protection Agency). 1990. Laboratory test methods of exposure to 

microbial pest control agents by the respiratory route to nontarget avian species. EPA/600/3-

90/070. Environmental Research Laboratory. Corvallis, OR. 82 pp. 

USEPA. 1998b. A comparative analysis of ecological risks from pesticides and their uses: background, 

methodology and case study. Environmental Fate and Effects Division, Office of Pesticide 

Programs, U.S. Environmental Protection Agency. Washington, D.C. 105 pp. 

USEPA. 2004. Overview of the ecological risk assessment process in the Office of Pesticide Programs, 

U.S. Environmental Protection Agency: endangered and threatened species effects 

determinations. Office of Pesticide Programs. Washington, D.C. 101 pp. 

USEPA. 2005a. Technical overview of ecological risk assessment risk characterization; approaches for 

evaluating exposure; granular, bait, and treated seed applications. Available at: 

http://www.epa.gov/oppefed1/ecorisk_ders/toera_analysis_exp.htm. 

USEPA. 2005b. User’s guide TREX v1.2.3. Available at: 

http://www.epa.gov/oppefed1/models/terrestrial/trex_usersguide.htm. 

USFS (U.S. Forest Service). 2005. Pacific Northwest Region invasive plant program preventing and 

managing invasive plants final environmental impact statement. U.S. Forest Service. Portland, 

OR. 359 pp. 

USGS (U.S. Geological Survey). 2000. Pesticides in stream sediment and aquatic biota—current 

understanding of distribution and major influences. USGS Fact Sheet 092-00. U.S. Geological 

Survey. Sacramento, CA. 4 pp. 

Wauchope, R.D., T.M. Buttler, A.G. Hornsby, P.M. Augustijn-Beckers, and J.P. Burt. 1992. The 

SCS/ARS/CES pesticide properties database for environmental decision making. Reviews of 

Environmental Contamination and Toxicology 123:1-155. 

Woods, N. 2004. Australian developments in spray drift management. Proceedings of the International 

Conference on Pesticide Application for Drift Management. Waikoloa, HI. 8 pp. 

 
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G-48 Appendix G. Integrated Pest Management Program 

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Appendix H. Statement of Compliance H-1

Appendix H. Statement of Compliance 

STATEMENT OF COMPLIANCE 

for Implementation of the 

Rose Atoll National Wildlife Refuge, American Samoa 

Comprehensive Conservation Plan 

The following Executive orders and legislative acts have been reviewed as they apply to implementation 

of the Rose Atoll National Wildlife Refuge CCP. 

Coastal Zone Management Act, Section 307. Section 307(c)(1) of the Coastal Zone 

Management Act of 1972 as amended, requires each Federal agency conducting or supporting 

activities directly affecting the coastal zone, to conduct or support those activities in a manner 

which is, to the maximum extent practicable, consistent with approved U.S. Territory coastal 

management programs. 

Endangered Species Act of 1973. This Act provides for the conservation of threatened and 

endangered species of fish, wildlife, and plants by Federal action and by encouraging the 

establishment of state programs. It provides for the determination and listing of endangered and 

threatened species and the designation of critical habitats. The CCP implementation is expected to 

result in supporting listed species and their recovery. Section 7 requires refuge managers to 

perform consultation before initiating projects that affect or may affect endangered species. The 

Refuge would conduct consultation under Section 7 of the Endangered Species Act for any 

Refuge management program actions that have the potential to affect listed species. 

Executive Order 12372. Intergovernmental Review. Coordination and consultation with 

affected Tribal, local and State/Territorial governments, other Federal agencies, and the 

landowners has been completed through personal contact by the Refuge/Monument Manager. 

Executive Order 12898. Federal Actions to Address Environmental Justice in Minority and 

Low-Income Populations. All Federal actions must address and identify, as appropriate, 

disproportionally high and adverse human health or environmental effects of its programs, 

policies, and activities on minority populations, low-income populations, and Indian Tribes in the 

United States. The CCP was evaluated and no adverse human health or environmental effects 

were identified for minority or low-income populations, Indian Tribes, or anyone else. 

Executive Order 13186. Responsibilities of Federal Agencies to Protect Migratory Birds. 

The CCP is consistent with Executive Order 13186 because the CCP and NEPA analyses evaluate 

the effects of agency actions on migratory birds and also, through its proposed actions, supports 

conservation of these species. 

Integrated Pest Management (IPM), 517 DM 1 and 7 RM 14. In accordance with 517 DM 1 

and 7 RM 14, an IPM approach has been adopted to eradicate, control, or contain pest and 

invasive species. In accordance with 517 DM 1, only pesticides registered with the EPA in full 

compliance with FIFRA and as provided in regulations, orders, or permits issued by EPA may be 

applied on lands and waters under refuge jurisdiction. 

Magnuson-Stevens Fishery Conservation and Management Act ((MSA; 16 U.S.C. 1855(b))) 

provisions (§305(b)). Essential fish habitat (EFH) for federally managed marine species. The 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

H-2 Appendix H. Statement of Compliance 

EFH is defined as “those waters and substrates necessary to fish for spawning, breeding, feeding, 

or growth to maturity.” The Refuge would conduct consultation for any Refuge management 

program actions that have the potential to adversely affect EFH. 

Migratory Bird Treaty Act. Established in 1918 with subsequent amendments and provisions 

following, this Act protects migrating birds between the U.S. and Canada. Mexico, Union of 

Soviet Republics, and Japan. This Act makes it illegal for people to “take” migratory birds, their 

eggs, feathers or nests (take is any means or in any manner, any attempt at hunting, pursuing, 

wounding, killing, possessing or transporting any migratory bird, nest, egg, or part thereof). 

National Environmental Policy Act of 1969. The planning process has been conducted in 

accordance with the NEPA Implementing Procedures, Department of the Interior and Service 

procedures, and has been performed in coordination with the affected public. 

An environmental assessment (EA) was prepared that integrated the CCP into the NEPA 

document and process. The Draft CCP/EA was released for a 30-day public comment period. The 

affected public was notified of the availability of the Draft CCP/EA through a Federal Register 

notice, news release to local media outlets, the Service’s refuge and refuge planning Websites, 

and a planning update. Copies of the Draft CCP/EA and/or planning update were distributed to an 

extensive mailing list. 

The CCP is programmatic in many respects and specific details of certain projects and actions 

cannot be determined until a later date depending on funding and implementation schedules. 

Certain projects or actions may require additional NEPA compliance. 

National Historic Preservation Act of 1966. The implementation of the CCP should not affect 

cultural resources. The Service would comply with the NHPA if any management actions have 

the potential to affect any historic properties which may be present. 

National Wildlife Refuge System Administration Act of 1966, as amended (16 U.S.C. 668dd668ee). Appropriate Refuge Use Findings and Compatibility Determinations have been prepared 

and can be found under Appendices B and C of this CCP. 

Wilderness Act of 1964. The Service has evaluated the suitability of the Refuge for wilderness 

designation and recommended a wilderness study.

 _______________________________ _________________________ 

Chief, Division of Refuge Planning, Date 

Visitor Services, and Transportation 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix I. Common Acronyms and Abbreviations I-1

Appendix I. Common Acronyms and Abbreviations 

Ac Acres 

Administration Act National Wildlife Refuge System Administration Act of 1966 (16 U.S.C. 668dd668ee) 

AHPA Archaeological and Historic Preservation Act 

AM Adaptive Management 

ASCC American Samoa Community College 

ASG American Samoa Government 

ASCC American Samoa Community College 

ASDOC American Samoa Department of Commerce 

ASHPO American Samoa Historic Preservation Office 

ATSDR Agency for Toxic Substances and Disease Registry 

AUF Appropriate Use Findings 

BIDEH Biological Integrity, Diversity, and Environmental Health 

CCA Crustose coralline algae 

CCP Comprehensive Conservation Plan 

CD Compatibility Determination 

CEQ White House Council on Environmental Quality 

CFR Code of Federal Regulations 

CRED Coral Reef Ecosystem Division 

CO2 Carbon Dioxide 

CWCS Comprehensive Wildlife Conservation Strategy 

DM Departmental Manual 

DMWR American Samoa Department of Marine and Wildlife Resources 

DO U.S. Fish and Wildlife Service Director’s Order 

DOI Department of the Interior 

Draft CCP/EA Draft Comprehensive Conservation Plan and Environmental Assessment 

EA Environmental Assessment 

EAR Ecological Acoustic Recorder 

EE Environmental Education 

EFH Essential Fish Habitat 

ENSO El Niño Southern Oscillation 

EO Executive Order 

ES Ecological Services 

ESA Endangered Species Act of 1973 

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act 

FONSI Finding of No Significant Impact 

FUDS Formerly Used Defense Sites 

FW U.S. Fish and Wildlife Service Manual 

FY Fiscal Year 

Ft Feet (Foot) 

GDP Gross Domestic Product 

GHG Greenhouse Gases 

GPRA Government Performance Results Act 

HPINWRC Hawaiian and Pacific Islands National Wildlife Refuge Complex 

I&M Inventory and Monitoring 

IGC Inter-governmental Committee 

Improvement Act National Wildlife Refuge System Improvement Act of 1997 

In Inch(es) 
Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

I-2 Appendix I. Common Acronyms and Abbreviations 

IPCC Intergovernmental Panel on Climate Change 

IPM Integrated Pest Management 

ISST Invasive Species Strike Team 

IUCN International Union for Conservation of Nature 

LCC Landscape Conservation Cooperative 

LE Law Enforcement 

LEIS Legislative Environmental Impact Statement 

MBCA Migratory Bird Conservation Act 

MBTA Migratory Bird Treaty Act 

Mi Mile(s) 

MLLW Mean Lower Low Water 

MMPA Marine Mammal Protection Act 

MNMP NOAA’s Marine National Monument Program 

Monument Rose Atoll Marine National Monument 

MOU Memorandum of Understanding 

MPA Marine Protected Area 

NEPA National Environmental Policy Act 

NGO Nongovernmental organization 

NHPA National Historic Preservation Act 

NMI Nautical Miles 

NMFS National Marine Fisheries Service 

NOAA National Oceanic and Atmospheric Administration 

NOI Notice of Intent 

NPS National Park Service 

NRDA Natural Resource Damage Assessment 

NRHP National Register of Historic Places 

NWR National Wildlife Refuge 

NWPS National Wilderness Preservation System 

NWRS or 

Refuge System National Wildlife Refuge System 

ONMS Office of National Marine Sanctuaries 

OSA Office of Samoan Affairs 

PICCC Pacific Islands Climate Change Cooperative 

PIFSC Pacific Islands Fisheries Science Center 

PIFWO Pacific Islands Fish and Wildlife Office 

PUP Pesticide Use Proposal 

RAMP Reef Assessment Monitoring Program 

RAPP Refuge Annual Performance Plan 

REA Rapid Ecological Assessment 

RHPO Regional Historic Preservation Officer 

RM National Wildlife Refuge System Manual 

RO Regional Office 

ROC Resources of Concern 

RONS Refuge Operational Needs System 

SAMMS Service Asset Maintenance and Management System 

SDMP Step-down Management Plan 

SLR Sea Level Rise 

SOC Species of Concern 

SSI Samoan Studies Institute 

SUP Special Use Permit 

T&E Threatened and Endangered 
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Appendix I. Common Acronyms and Abbreviations I-3

TL Total Length 

USC United States Code 

USCG U.S. Coast Guard 

USEPA U.S. Environmental Protection Agency 

USFWS, FWS, 

the Service U.S. Fish and Wildlife Service 

USGS U. S. Geological Survey 

USPI U.S. Pacific Islands 

WSA Wilderness Study Area 

 
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Appendix J. CCP Team Members and Public Involvement J-1

Appendix J. CCP Team Members and Public Involvement 

J.1 CCP Team Members 

The Draft CCP/EA was developed and prepared primarily by a core team made up of refuge staff (both 

local and at the Honolulu and Regional offices [RO]). The core team sought expertise and review from 

other professionals from several different agencies and organizations. The List of Preparers below 

includes core team members as well as other persons responsible for writing specific portions of the plan. 

Many others provided assistance in developing and reviewing the Draft CCP/EA and associated products 

and in providing advice through the planning process. These people are captured in the List of Reviewers 

and Advisors. 

Table J-1. List of Preparers (in alphabetical order) 

Name and Title CCP Contributions 

Liz Cruz, Geographer/GIS Specialist, RO 

replaced, 

David Hoy, Geographer/GIS Specialist, RO 

GIS data gathering and analysis (e.g., habitats and 

vegetation, infrastructure, alternatives development); 

development of maps for public involvement and 

documents 

Beth Flint, Biologist, Pacific Reefs NWRC Writer of biological affected environment; reviewer: 

lead on biological goals/objectives/strategies, 

biological component on affected environment and 

related environmental consequences; biological 

resources of concern, taxa lists and habitats, 

integrated pest management; research/analysis; 

coordinate with biological and natural resource 

management partners; reviewed AUFs/CDs 

Sandra Hall, External Affairs, HPINWRC Layout and reviewer of planning updates; assisted 

with formatting of CCP document 

Jean Kenyon, Biologist, Inventory and 

Monitoring Program, HPINWRC 

 

Writer of biological affected environment; reviewer: 

lead on marine biological goals/objectives/ strategies, 

biological component on affected environment and 

related environmental consequences; biological 

resources of concern, taxa lists and habitats; 

research/analysis; reviewed AUFs/CDs 

Jiny Kim, Biologist, Pacific Reefs NWRC Writer of biological affected environment; reviewer 

biological goals/objectives/strategies, biological 

environmental consequences; biological resources of 

concern, taxa lists and habitats; research/analysis 

Jim Maragos, Marine Biologist, Pacific Reefs 

NWRC (retired) 

 

Writer of biological affected environment; reviewer: 

on marine biological goals/objectives/strategies, taxa 

lists and habitats 
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J-2 Appendix J. CCP Team Members and Public Involvement 

Name and Title CCP Contributions 

Christine Ogura, Natural Resource Planner, 

HPINWRC replaced, 

Bill Perry, Refuge Conservation Planner, 

HPINWRC replaced, 

Charlie Pelizza, Refuge Conservation Planner, 

HPINWRC 

CCP team leader responsible for RO and Honolulu 

office coordination and process and policy guidance 

for CCP development; CCP schedule manager; 

facilitator of team, partner, and public 

meetings/workshops; document and related product 

management (including planning record), format and 

review; writer of affected environment and 

environmental consequences and planning updates; 

public involvement and communications 

Frank Pendleton, Refuge/Monument Manager, 

Rose Atoll NWR and Marine National 

Monument 

Decision-maker and document quality reviewer; 

writer of affected environment, public involvement 

and communications (including coordination of 

Federal, Territorial, partner, and community 

organizations); compatibility determinations and 

implementation; overall guidance for CCP 

development and coordination with staff 

Susan White, Project Leader, Pacific Reefs 

NWRC replaced, 

Don Palawski, Project Leader, Pacific Reefs 

NWRC 

Decision-maker and document quality reviewer; 

overall guidance for CCP development and 

coordination with staff 

Table J-2. List of Reviewers and Advisors (in alphabetical order) 

Name and Title CCP Contributions 

Midori Akamine, Director, Marine National 

Monument Program in the Pacific Islands Region 

Review of Chapter 2 and entire document 

Gene Brighouse, Superintendent, Fagatele Bay 

National Marine Sanctuary 

Review of Chapter 2 and entire document 

Samantha Brooke, Fishery Policy Analyst, 

NOAA Fisheries Pacific Islands Regional Office, 

Marine National Monument Program 

Review of Chapter 2 and entire document 

Tim Clark, Marine Ecologist, National Park of 

American Samoa 

Review of Chapter 2 and entire document 

Peter Craig, Chief of Natural Resources, National 

Park of American Samoa (retired) 

Review of Chapter 2 and entire document 

Sean Eagan, Chief of Resources Management, 

National Park of American Samoa 

Review of Chapter 2 and entire document 

Joe Engler, Assistant Regional Biologist, RO Review of biological goals/objectives/strategies; 

AUFs and CDs 

Bridgette Flanders-Wanner, Assistant Regional 

Refuge Biologist and Regional IPM Coordinator, 

RO 

Lead reviewer of biological 

goals/objectives/strategies; AUFs and CDs; IPM 
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Appendix J. CCP Team Members and Public Involvement J-3

Name and Title CCP Contributions 

Holly Freifeld, Biologist, Division of Migratory 

Birds and Habitat Programs, RO 

Reviewer of biological goals/objectives/strategies 

Kevin Grant, Deputy Superintendent, Fagatele 

Bay National Marine Sanctuary 

Review of Chapter 2 and entire document 

Richard Hall, Fishery Policy Analyst, NOAA, 

Pacific Islands Region, National Marine 

Fisheries Service 

Review of entire document, coordinated comments 

from NOAA’s PIRO’s Protected Resources, Habitat 

Conservation, and Sustainable Fisheries Divisions, 

and the National Marine Monument Program 

Ben Harrison, Deputy Regional Chief of 

Refuges, RO 

CCP Advisor, reviewer of policy, AUF, CDs, 

environmental consequences 

Charles Houghten, Division Chief Planning, 

Visitor Services, Transportation, RO 

CCP Advisor for planning policy and guidance; 

reviewer (including wilderness); coordination with 

other divisions and the Washington D.C. office 

Kay Kier-Haggenjos, Writer/Editor, RO Technical edit review and processing of Federal 

Register notices; review and processing of document 

and related products (e.g., planning updates); 

Website management 

Nicole McCarthy, Writer/Editor, RO Assist with public comment period coordination 

Scott McCarthy, Branch Chief Planning, RO CCP Advisor for planning policy and guidance; 

planning workload priorities; coordination with other 

divisions 

Mike Marxen, Branch Chief Visitor Services, RO Visitor Services review and guidance on public use 

goals/objectives/strategies; assistance with related 

alternatives development workshop 

Kevin O’Hara, Planner Reviewed Chapter 6 effects analysis 

Domingo Ochavillo, DMWR Fisheries Biologist Review of Chapter 2 and entire document 

Don Palawski, Deputy Project Leader, 

HPINWRC replaced, 

Jerry Leinecke, Deputy Project Leader, 

HPINWRC (retired) 

Assist with regional office coordination; reviewer of 

document and related products; guidance on overall 

process and components 

Charles Parrot, Realty Specialist, RO Realty analysis, review of related sections in 

document, assisted with verifying map accuracy 

Lelei Peau, Deputy Director, American Samoa 

Department of Commerce 

Review of Chapter 2 and entire document 

Anan Raymond, Regional Archaeologist, RO Review of cultural and historic resources 

goals/objectives/strategies and affected environment 

and environmental consequences 

Mike Reynolds, Superintendent, National Park of 

American Samoa 

Review of Chapter 2 and entire document 
Rose Atoll National Wildlife Refuge 

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J-4 Appendix J. CCP Team Members and Public Involvement 

Name and Title CCP Contributions 

Patrick Stark, Visitor Services and 

Communication, RO 

Document and related products (e.g., planning 

update) print management; CCP cover design 

Barry Stieglitz, Project Leader, HPINWRC Decision-maker; reviewer of document and related 

products 

Robyn Thorson, Regional Director, RO Final decision-maker, CCP/EA and Federal Register 

Notice approvals 

Ray Tulafono, Director, DMWR Review of Chapter 2 and entire document; 

coordinated and assisted with public meetings and 

document translations 

Jared Underwood, Zone Inventory and 

Monitoring Biologist, HPINWRC 

Reviewer of biological inventory and monitoring 

strategies 

Robin West, Regional Chief of Refuges, RO Major decisions on CCP direction, CCP/EA and 

Federal Register Notice approvals 

Lee Ann Woodward, Resource Contaminants 

Specialist, Pacific Reefs NWRC 

Reviewer of goals/objectives/strategies; contaminants 

section in affected environments 

J.2 Summary of Public Involvement 

The initial CCP planning process for the Refuge began in 2005. However, due to staff turnover and 

change in management, efforts did not truly get underway again until 2009. Public scoping began in the 

fall of 2009 with a notice in the Federal Register (November 9, 2009) and a total of three public meetings 

held in November 2009 at Manu’a Islands and on the Island of Tutuila. In all, over 60 people participated. 

Public input was also solicited through distribution of planning updates to our mailing list. Additionally, 

meetings with American Samoa and Federal agencies and elected officials, villages and chiefs, 

community groups, non-profit organizations, and others were also held. The comments and suggestions 

made through this process helped further develop and refine the management alternatives for the CCP, 

including the preferred alternative. It also helped to identify the top priority species, groups, and 

communities for the Refuge. 

Following is a brief summary of public involvement: 

 2005 – CCP process briefing to DMWR; 

 November 9, 2009 – Federal Register Notice (Vol. 74, No. 215) announcing a notice of intent to 

prepare the Draft CCP/EA and public open house meetings; 

 November 2009 – Planning Update 1 announcing the official start of public scoping with public 

open house meetings and previewing preliminary issues and goals for CCP consideration; 

 November 2009 – Public scoping meetings on Ofu Island (November 14), Ta’u Island (November 

16), and on the Island of Tutuila (November 19); 

 2010-2011 – Refuge staff also held specific meetings to provide updates and discuss management 

considerations with partners and interested parties (e.g., DMWR, Office of Samoan Affairs, etc.); 

 March-April 2011– formal letters inviting IGC members to participate sent (though briefings had 

been provided to individual members since 2005 even before the IGC had been formed); 

 May 2011 – Planning Update 2 summarizing public scoping comments and identifying issues 

outside the scope of the CCP; 

 March 2012 – IGC review of draft Chapter 2 (Management Actions and Alternatives); 

 June 2012 – ICG review of Draft Rose Atoll NWR CCP/EA; 
Rose Atoll National Wildlife Refuge 

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Appendix J. CCP Team Members and Public Involvement J-5

 Fall 2012 – Release of Draft Rose Atoll NWR CCP/EA for 30-day comment period to the public 

and partners, which included general public open houses and targeted meetings with interested 

groups/individuals. 

Distribution and notification of the opportunities above was accomplished using multiple methods 

including news releases, a mail/email list of over 200 people which included interested individuals, local 

conservation and interest groups, research organizations, and Territorial and Federal government agencies 

and elected officials; community events/meetings; and CCP-specific Website 

(http://www.fws.gov/roseatoll/planning.html). 

The Draft CCP/EA reflects this extensive public involvement in all chapters as issues identified and 

related goals/objectives/strategies and alternatives drafted were shaped by the feedback received during 

public involvement. The following table summarizes the comments heard during public scoping and 

identifies where and/or how it was addressed in the Draft CCP/EA. 

For all comments related to the Monument areas outside of the Refuge, the CCP only addresses the 

Refuge so these non-Refuge areas would be addressed through a later Monument planning process if 

necessary. The NOAA has management responsibility for fisheries outside of the Refuge area. 

Issue Where/How Addressed in Draft CCP/EA 

Protection and Management 

How will the unique status of the coral reef fish and 

invertebrates at Rose Atoll both inside and outside the 

lagoon be considered? The atoll is one of the smallest in 

the world and only the upper 300 feet of the pinnacle 

forming Rose Atoll receives enough light to support 

significant coral growth. This small extent of habitat does 

not provide the resilience afforded to larger coral reefs that 

have more habitat complexity and larger fish populations 

to maintain the natural replenishment populations. Small 

areas like Rose Atoll are easily fished out. Rose Atoll 

should be viewed in its regional context – it is part of a 

remote group of Pacific Islands (the Samoan Archipelago) 

that form an integrated biological unit that is critical to the 

continuity of local coral reef ecosystems. 

Proposed management actions can be found 

in Chapter 2 addressing protection of the 

unique coral reef fish and invertebrates at 

Rose Atoll; recognition of Rose’s small area 

and fishing concerns can be found in 

Chapter 4. 

Create an effective management strategy that multiple 

government agencies with competing mandates and 

priorities will adhere to, in order to provide effective 

oversight and protection of the area. 

Proposed management actions highlighting 

partnering can be found in Chapter 2. 

Include a comprehensive threats section and concrete steps 

to address these threats. The threats to consider should 

include, but are not limited to, illegal foreign/domestic 

fishing; potential ship groundings; by‐catch of monument 

seabirds, sea turtles and migratory fishes in waters 

adjacent to monument boundaries; invasive species; 

altered and disrupted landscapes and habitats; land and 

marine debris; and global warming impacts. 

Threats to habitats and species can be found 

in Chapter 4; proposed management actions 

to address threats can be found in Chapter 2. 
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J-6 Appendix J. CCP Team Members and Public Involvement 

Issue Where/How Addressed in Draft CCP/EA 

Research and Monitoring 

Encourage and support research to document the condition 

of the ecosystems in the monument, track resource trends, 

and identify the connections between the island and its 

surrounding pelagic waters and seafloor. 

Proposed management actions highlighting 

such research can be found in Chapter 2 

under goal 6. 

How will the CCP consider and analyze the impacts of 

climate change? The CCP should outline a plan to 

inventory and monitor climate change-related variables 

and trends. The CCP should include climate change 

information in environmental education programs. The 

CCP must address non-climate stressors (climate change 

will add to existing stressors such as invasive species, 

habitat fragmentation, overharvesting so these issues must 

also be addressed). The CCP vision should acknowledge 

important role that climate change will play in future 

conditions of Rose Atoll NWR. Refuge should promote 

ecosystem resiliency. 

Climate change is analyzed as part of 

affected environment Chapter 3, biological 

environment Chapter 4, environmental 

consequences Chapter 6 as well as proposed 

management actions in Chapter 2. 

Enforcement 

How will the enforcement of the atoll be conducted [the 

commitment was made that the need for a boat for 

enforcement will be identified in the CCP] and will 

Manu’a residents be considered to conduct enforcement 

(e.g., as first responders)? 

Enforcement, a need for a boat, and 

considering Manu’a residents are all 

identified in Chapter 2. 

Include a realistic plan for effective surveillance and 

enforcement of the monument. 

Surveillance and enforcement of the Refuge 

(which is part of the Monument) is 

identified in Chapter 2. 

Visitor Services and Education 

What educational opportunities can be provided? 

Education can be used to gain support and participation of 

youth in Manu’a on the conservation of Rose Atoll. There 

is a need to send over educational materials and resources 

to help enhance community awareness and understanding. 

A science education program for local students to learn 

more about the marine environment and resources would 

help encourage Manu’a students to pursue interest in 

science and to become scientists (marine biologists) in the 

future. Fish and habitats of Rose Atoll should be in DVDs 

and posters. Hold community workshops to educate about 

the resources [at the meeting, the commitment was made 

that education programs and opportunities would be 

developed and included in the plan]. 

Educational opportunities are identified in 

Chapter 2. 
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Appendix J. CCP Team Members and Public Involvement J-7

Issue Where/How Addressed in Draft CCP/EA 

What opportunities for tourism can be developed and will 

there be opportunities for touring the atoll? 

Tourism does not meet the Refuge purpose 

(outlined in Chapter 1). Therefore, tourism 

was not considered (see Chapter 2). 

Cultural 

The name of Rose Atoll could be changed back to the 

original Samoan name to protect the culture and heritage. 

This is identified as a strategy under Goal 8 

in Chapter 2. 

Discussion of subsistence, sustenance, and recreational 

fishing opportunities should be discussed. 

For areas within the Refuge, this issue is 

addressed in Chapter 2, with biological 

justifications outlined in Chapter 4. The 

conclusion was that fishing was considered, 

but not developed further in the CCP. For 

areas outside the Refuge (and therefore 

outside the scope of the CCP), a separate 

process through NMFS is underway. 

Local participation should be included in management of 

the atoll (e.g., jobs for ASCC and high school students). 

Through cultural practices, enforcement, 

and environmental education, outreach, and 

research, local participation was integrated 

into proposed management actions found in 

Chapter 2. 

Issues Outside the Scope of the CCP 

 How can the boundary of the Rose Atoll National Monument be changed? Please consider our request 

to reduce the area closure around Rose Atoll National Monument to 12 miles. 

 Will the Manu’a people, especially those in Ta’u Island, be allowed to fish at the atoll? Can the 

Manu’a people be allowed to fish within the 50-nmi zone? There were a number of individuals that 

expressed concern that the waters of Manu’a should be kept for the people of Manu’a to carry on their 

tradition of fishing and allow them to develop their fisheries. 

 Will the establishment of the Monument provide jobs for the Manu’a people? NOAA should establish 

an office in the Manu’a Islands to assist the community in enforcement and management of the 

Monument. 

 
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Appendix K. Cooperative Agreement and Presidential Proclamation K-1

Appendix K. Cooperative Agreement and Presidential 

Proclamation 

This cooperative agreement was the basis for the establishment of Rose Atoll National Wildlife Refuge.
Rose Atoll National Wildlife Refuge 

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K-2 Appendix K. Cooperative Agreement and Presidential Proclamation 
Rose Atoll National Wildlife Refuge 

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Appendix K. Cooperative Agreement and Presidential Proclamation K-3
Rose Atoll National Wildlife Refuge 

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K-4 Appendix K. Cooperative Agreement and Presidential Proclamation 
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Appendix K. Cooperative Agreement and Presidential Proclamation K-5

 
Rose Atoll National Wildlife Refuge 

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K-6 Appendix K. Cooperative Agreement and Presidential Proclamation 

Presidential Proclamation 4347 establishing additional jurisdiction. 
Rose Atoll National Wildlife Refuge 

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Appendix K. Cooperative Agreement and Presidential Proclamation K-7

 
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Rose Atoll National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

L-24 Appendix L. References 

This page was intentionally left blank. 
Pink algae found on the coral 

throughout the Refuge gives 

Rose Atoll its name. 

USFWS

U.S. Department of the Interior

U.S. Fish & Wildlife Service

Rose Atoll National Wildlife Refuge

c/o National Park Service

Pago Pago, AS 96799

Phone: 684/633-7082 ext. 15

Fax: 684/699-3986

October 2012

Font Cover Photos

Main: An array of seabirds find refuge

at Rose Atoll

USFWS

Inset: Pisonia tree

JE Maragos/USFWS

Red-tailed tropic bird chick

Greg Sanders/USFWS

Tridacna maxima

JE Maragos/USFWS