Finding of No Significant Impact 

for the 

Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Maui County, Hawai‘i

The U.S. Fish and Wildlife Service (Service) has completed a Comprehensive Conservation Plan 

(CCP) and Environmental Assessment (EA) for Kakahai‘a National Wildlife Refuge (Refuge). 

The CCP will guide management of the Refuge for 15 years. The CCP/EA describes our 

proposals for managing the Refuge and their effects on the human environment under three 

alternatives, including the no action alternative. 

Decision 

Based on our comprehensive review and analysis in the CCP/EA, we selected Alternative C for 

implementation, because it will guide management of the Refuge in a manner that: 

Achieves the mission of the National Wildlife Refuge System, and the purposes, vision, 

and goals of the Refuge. 

Maintains and restores the ecological integrity of the Refuge habitats and populations. 

Addresses the important issues identified during the CCP scoping process. 

Addresses the legal mandates of the Service and the Refuge. 

Is consistent with the scientific principles of sound wildlife management and endangered 

species recovery. 

Facilitates priority public uses appropriate and compatible with the Refuge purpose and 

the Refuge System mission. 

Summary of the Actions to be Implemented 

Implementing the selected alternative will have no significant impacts on the environmental 

resources identified in the CCP/EA. Refuge management under the selected alternative will 

restore habitat for endangered species and resources of concern, and improve the Refuge’s 

capability to provide food for migrating and wintering waterbirds, including shorebirds and 

waterfowl. Improving the Refuge’s coastal and wetland habitats will increase the value of these 

lands and waters for a variety of native plants and wildlife. 

The availability and quality of wildlife-dependent recreation on the Refuge will improve under 

the selected alternative, but within a regional context, the cumulative change would be small. A 

summary of the CCP actions we will implement follows. 

Under Alternative C, we will restore the 15-acre Old Pond and 5.5 acres of New Pond. Physical 

restoration of the Old Pond will include: removal of aggressive pest species, dredging 

accumulated sediment, reconfiguring bathymetry and radial levees, reconstructing perimeter 

levees, replacing the water control structure, and replacing the pump between the two ponds. 

Restoration of Old Pond will provide open water and emergent habitat for breeding, foraging, 

and nesting ‘alae ke‘oke‘o with minimum supplemental water due to the presence of natural 

groundwater springs. 

Supporting References 

U.S. Fish and Wildlife Service. July 2011. Kakahai‘a National Wildlife Refuge, Draft 

Comprehensive Conservation Plan and Environmental Assessment. 

U.S. Fish and Wildlife Service. September 2011. Kakahai‘a National Wildlife Refuge 

Comprehensive Conservation Plan. 

Note: This Finding of No Significant Impact and supporting references are available for public 

review at Maui National Wildlife Refuge Complex, Milepost 6 Mokulele Highway, Kīhei, 

Hawai‘i 96753, and U.S. Fish and Wildlife Service, Hawaiian and Pacific Islands National 

Wildlife Refuge Complex, 300 Ala Moana Boulevard, Room 5-231, Honolulu, Hawai‘i 96850. 

These documents can also be found on the Internet at http://pacific.fws.gov/planning/. Interested 

and affected parties are being notified of our decision. 

Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Table of Contents i 

Table of Contents 

Readers’ Guide ..................................................................................................................................... v

Chapter 1. Introduction ................................................................................................................... 1-1 

 1.1 Purpose and Need for the CCP ........................................................................................... 1-1 

 1.2 Planning and Management Guidance ................................................................................ 1-2

 1.2.1 U.S. Fish and Wildlife Service Mission ....................................................................... 1-2 

 1.2.2 National Wildlife Refuge System ................................................................................. 1-2 

 1.2.3 National Wildlife Refuge System Mission and Goals .................................................. 1-2 

 1.2.4 National Wildlife Refuge System Administration Act of 1966 ................................... 1-3 

 1.3 Relationship to Previous and Future Refuge Plans .......................................................... 1-4

 1.3.1 Future Planning ............................................................................................................ 1-4 

 1.4 Refuge Establishment and Purposes ................................................................................... 1-5 

 1.4.1 Legal Significance of the Refuge Purpose ................................................................... 1-5 

 1.4.2 Refuge Establishment and Purpose .............................................................................. 1-5 

 1.5 Refuge Goals ......................................................................................................................... 1-5

 1.6 Relationship to Ecosystem Planning Efforts ..................................................................... 1-7 

 1.7 Planning and Issue Identification ....................................................................................... 1-9 

 1.7.1 Public Scoping Sessions ............................................................................................... 1-9

 1.7.2 Issues Addressed in the CCP ...................................................................................... 1-10 

 

Chapter 2. Refuge Management Direction .................................................................................... 2-1

 2.1 Considerations in the Design of the CCP ......................................................................... 2-1 

 2.2 General Guidelines .............................................................................................................. 2-1 

 2.2.1 Implementation Subject to Funding Availability ......................................................... 2-1 

 2.2.2 Interagency Coordination and Collaboration ............................................................... 2-1 

 2.2.3 Threatened and Endangered Species Protection and Recovery .................................... 2-1 

 2.2.4 Historic and Cultural Resource Protection ................................................................... 2-2 

 2.2.5 Fire Management .......................................................................................................... 2-2 

 2.2.6 Participation in Planning and Review of Regional Development Activities ................ 2-3 

 2.2.7 Adaptive Management .................................................................................................. 2-3 

 2.2.8 Integrated Pest Management ........................................................................................ 2-3 

 2.2.9 National Environmental Policy Act Compliance ......................................................... 2-4 

 2.2.10 Law Enforcement ....................................................................................................... 2-4 

 2.2.11 Refuge Revenue Sharing Payments ............................................................................ 2-5 

 2.2.12 Regulatory Compliance .............................................................................................. 2-5 

 2.2.13 Volunteer Opportunities ............................................................................................. 2-5

 2.2.14 Climate Change .......................................................................................................... 2-5 

2.3 Summary of CCP Actions ................................................................................................... 2-6

2.4 Kakahai‘a NWR Management ........................................................................................... 2-8

 2.4.1 Goal 1 ........................................................................................................................... 2-9

 2.4.2 Goal 2 ......................................................................................................................... 2-13

 2.4.3 Goal 3 ......................................................................................................................... 2-14

 2.4.4 Goal 4 ......................................................................................................................... 2-15

 2.4.5 Goal 5 ......................................................................................................................... 2-18

 2.4.6 Goal 6 ......................................................................................................................... 2-20
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

ii Table of Contents 

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

 3.1 Refuge Introduction ............................................................................................................. 3-1 

 3.2 Climate .................................................................................................................................. 3-1 

 3.2.1 Global Climate Change ................................................................................................ 3-3

 3.2.2 Ecological Responses to Climate Change .................................................................... 3-4 

3.3 Geology and Soils ................................................................................................................. 3-5

 3.4 Hydrology ............................................................................................................................. 3-6 

3.5 Topography/Bathymetry ..................................................................................................... 3-9 

 3.6 Environmental Contaminants .......................................................................................... 3-10 

3.7 Land Use ............................................................................................................................. 3-10 

 3.7.1 Previous Land Uses .................................................................................................... 3-10

Chapter 4: Refuge Biology and Habitat ......................................................................................... 4-1 

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

 4.2 Conservation Target Selection and Analysis ..................................................................... 4-1 

 4.2.1 Conservation Target Selection ...................................................................................... 4.1 

 4.3 Wetland Habitat .................................................................................................................... 4-2 

4.4 Grassland Habitat ................................................................................................................. 4-2 

4.5 Coastal Dry Forest ................................................................................................................ 4-5

 4.6 Coastal Beach Strand ........................................................................................................... 4-5 

 4.7 Endangered Hawaiian Waterbirds .................................................................................... 4-6

 4.7.1 Ae‘o (Himantopus mexicanus knudseni) or Hawaiian Stilt.......................................... 4-6

 4.7.2 ‘Alae ke‘oke‘o (Fulica alai) or Hawaiian Coot ........................................................... 4-6 

4.8 Migratory Waterfowl .......................................................................................................... 4-7 

 4.9 Migratory Shorebirds .......................................................................................................... 4-7 

 4.10 Pest Species .......................................................................................................................... 4-8 

 4.10.1 Mammals .................................................................................................................... 4-8 

 4.10.2 Birds ......................................................................................................................... 4-10 

 4.10.3 Amphibians............................................................................................................... 4-10

 4.10.4 Invertebrates ............................................................................................................. 4-11 

 4.10.5 Plants ........................................................................................................................ 4-11 

 4.11 Wildlife and Habitat Research and Monitoring Efforts .............................................. 4-13 

Chapter 5. Refuge Facilities and Public Use Programs ................................................................ 5-1

 5.1 Refuge Infrastructure and Operational Facilities ............................................................ 5-1 

 5.1.1 Refuge Operations ........................................................................................................ 5-1 

 5.1.2 Maintenance Facilities .................................................................................................. 5-1 

 5.1.3 Dempster Windmill ...................................................................................................... 5-1 

 5.1.4 Roads ............................................................................................................................ 5-1 

 5.1.5 Constructed Ponds and Levees ..................................................................................... 5-2

 5.1.6 Wells, Pumps, Water Distribution Lines, and Water Control Structures ..................... 5-2 

 5.1.7 Kamehameha V Highway Culvert ................................................................................ 5-3 

 5.1.8 Fences and Gates ......................................................................................................... 5-3 

 5.2 Public Use ............................................................................................................................. 5-4 

 5.2.1 Special Use Permits ...................................................................................................... 5-4 

 5.2.2 Kakahai‘a Park ............................................................................................................. 5-4 

 5.2.3 Wildlife Observation and Photography ........................................................................ 5-4 

 5.2.4 Environmental Education ............................................................................................. 5-5
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Table of Contents iii

 5.2.5 Volunteers..................................................................................................................... 5-5 

 

Chapter 6. Cultural Resources, Social, and Economic Environment ......................................... 6-1 

 6.1 Refuge Cultural Resources ................................................................................................. 6-1 

 6.1.1 Native Hawaiian Cultural History ................................................................................. 6-1 

 6.1.2 Euro-American Cultural History ................................................................................... 6-2 

 6.1.3 The Mahele, 1848-1851 ................................................................................................. 6-4 

 6.1.4 Post-1850s History ........................................................................................................ 6-4 

 6.1.5 Archaeological/Cultural Surveys ................................................................................... 6-6 

 6.1.6 Paleontological Resources ............................................................................................ 6-7 

 6.2 Social and Economic Setting ............................................................................................... 6-8 

 6.2.1 Population ...................................................................................................................... 6-8

 6.2.2 Housing.......................................................................................................................... 6-9

 6.2.3 Education ....................................................................................................................... 6-9 

 6.2.4 Economics ................................................................................................................... 6-10

Tables 

Table 1.1 Refuge Acquisition History for Kakahai‘a NWR ............................................................... 1-5 

Table 2.1 Management Summary .................................................................................................... 2-7 

Table 3.1. Monthly stream flow data for Kawela Gulch ................................................................... 3-8 

Table 3.2 Monthly streamflow data for Kaunakakai ........................................................................ 3-8 

Table 4.1 Conservation targets for the CCP ..................................................................................... 4-1 

Table 6.1 Population figures for selected areas ................................................................................ 6-9 

Table 6.2 Census Bureau estimated median and per capita income figures, 2009 ........................... 6-9 

Figures 

Figure 1.1 Main Hawaiian Islands ................................................................................................... 1-11 

Figure 1.2 Refuge Land Status & Boundary .................................................................................... 1-13 

Figure 2.1 Habitat Management....................................................................................................... 2-21 

Figure 3.1 Annual cycle of average monthly precipitation and total annual precipitation ............... 3-2 

Figure 3.2 Annual cycle of average monthly temperature and annual temperature ......................... 3-3 

Figure 3.3 Old Pond water levels and groundwater levels, 2000-2010 ............................................. 3-7 

Figure 3.4 Annual stream discharge at USGS stream flow gage Halawa Stream ............................. 3-9 

Figure 4.1 Land Cover Types ............................................................................................................ 4-3 

Appendices 

Appendix A: Kakahai‘a National Wildlife Refuge Species Lists .................................................... A-1 

Appendix B: Compatibility Determinations and Appropriate Uses Findings ................................. B-1 

Appendix C: Plan Implementation and Costs .................................................................................. C-1 

Appendix D: Wilderness Review for Kakahai‘a National Wildlife Refuge .................................... D-1 

Appendix E: Integrated Pest Management Program ........................................................................ E-1 

Appendix F: Fire Management Plan 2004 ....................................................................................... F-1 

Appendix G: Statement of Compliance ........................................................................................... G-1 

Appendix H: Common Acronyms and Abbreviations .................................................................... H-1 

Appendix I: Literature Cited ............................................................................................................ I-1 

Appendix J: Planning Team Members ............................................................................................ J-1 

Appendix K: Public Comments and Service Responses ................................................................... K-1 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

iv Table of Contents 

 

Note to Reviewers: Throughout the CCP document, all attempts have been made 

to use appropriate diacriticals related to the Hawaiian language (i.e., ‘okina and 

kahakō). However, places where diacriticals may not appear occur in the maps 

and literature cited. Due to limitations of the Geospatial Information System 

software used for the maps developed in the plan, some diacriticals may be 

missing where place names or legend text appear. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Readers’ Guide

Native species discussed in this document are referred to by their Hawaiian names. Common English

names and scientific nomenclature can also be found in the glossary in Appendix A. The U.S. Fish and

Wildlife Service endeavors to be accurate in its use of the Hawaiian language and correctly spell

Hawaiian words, including the diacritical marks that affect the meaning and aid in pronunciation. This

guide is provided to simplify pronunciation for the reader.

When Captain Cook arrived in the Hawaiian Islands in 1778, the Hawaiians had a totally oral tradition. In 

1820, missionaries standardized a written version of the Hawaiian language that features eight consonants 

and five vowels.

Special Symbols 

Two symbols appear frequently in Hawaiian words: the ‘okina and the kahakō. These two symbols change 

how words are pronounced. The ‘okina itself looks like an upside-down apostrophe and is a glottal stop – 

or a brief break in the word. An example of this in English is in the middle of the expression “uh-oh.” The 

‘okina is an official consonant – just as any of the other consonants.

The kahakō is a stress mark (macron) that can appear over vowels only and serve to make the vowel sound 

slightly longer. The vowels ā, ē, ī, ō, and ū sound just like their non-stress Hawaiian vowels with the 

exception that the sound is held slightly longer. Missing the ‘okina or kahakō can greatly change not only 

the how a word sounds, but also its basic meaning. A popular example of how an ‘okina and a kahakō can 

change the meaning of a word is “pau”:

• pau = finished, ended, all done

• pa‘u = soot, smudge, ink powder

• pa‘ū = moist, damp

• pā‘ū = skirt

Refuge Place Names

Kakahai‘a (kah-kah-hah-EE-ah) meaning: fish slicing

Kawela (kah-VEH-lah) meaning: the heat

Consonants

H - as in English

K - as in English

L - as in English

M - as in English

N - as in English

P - as in English

W - after i and e pronounced v

 - after u and o pronounced like w

 - at the start of a word or after a, 

 pronounced like w or v

(‘) - ‘okina - a glottal stop

Vowels

A - pronounced like the a in far

E - pronounced like the e in bet

I - pronounced like the ee in beet

O - pronounced like the o in sole

U - pronounced like the oo in boot

Readers’ Guide v
Ae‘o (EYE oh)

Hawaiian Stilt Himantopus mexicanus knudseni

SPECIES STATUS:

Federally listed as Endangered

State listed as Endangered

State recognized as Indigenous

‘Alae ke‘oke‘o (ah-lye KAY oh KAY oh)

Hawaiian Coot Fulica alai

SPECIES STATUS:

Federally listed as Endangered

State listed as Endangered

State recognized as Endemic

‘Auku‘u (ow-KOO oo)

Black-crowned Night-Heron Nycticorax nycticorax 

hoactli

SPECIES STATUS:

State recognized as Indigenous

Koloa maoli (ko-LOWah MAOW-lee)

Hawaiian Duck Anas wyvilliana

SPECIES STATUS:

Federally listed as Endangered

State listed as Endangered

State recognized as Endemic

Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan

vi Readers ’ Guide

Waterbirds

Laura Beauregard

Laura Beauregard

Laura Beauregard

Brenda Zaun
‘Akekeke (ah-kay-KAY-kay)

Ruddy Turnstone Arenaria interpres

SPECIES STATUS:

State recognized as Indigenous

U.S. Shorebird Conservation Plan - High Concern

Hunakai (hoo-nah-KYE)

Sanderling Calidris alba

SPECIES STATUS:

State recognized as Indigenous 

Hunakai means “sea foam.” Their habit of running along 

the receding waves on the shore in search of small sand 

crabs apparently reminded early Hawaiians of the sea foam 

or hunakai left behind by the waves. It shares the name with 

a coastal plant. 

Kōlea (KOHH-lay-ah)

Pacific Golden Plover Pluvialis fulva

SPECIES STATUS:

State recognized as Indigenous 

U.S. Shorebird Conservation Plan - High Concern

‘Ūlili (OOO-lee-lee)

Wandering Tattler Heteroscelus incanus

SPECIES STATUS:

State recognized as Indigenous

U.S. Shorebird Conservation Plan - Moderate 

Concern

Michael Walther

Michael Walther

Michael Walther

Michael Walther

Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan

Migrant Shorebirds

Readers’ Guide vii
‘Ākulikuli (AAH-koo-lee-KOO-lee)

Sea Purslane Sesuvium portulacastrum

SPECIES STATUS:

State recognized as Indigenous

Hala (HAH-lah)

Screw Pine Pandanus tectorius

SPECIES STATUS:

State recognized as Indigenous

Kaluhā (kah-loo-HAHH)

Saltmarsh Bulrush Bolboschoenus maritimus

SPECIES STATUS:

State recognized as Indigenous

Kīpūkai (KEE-POO-kye)

Seaside Heliotrope Heliotropium curassavicum

SPECIES STATUS:

State recognized as Indigenous

Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan

Native Plants

Laura Beauregard

Laura Beauregard

Laura Beauregard

Forest & Kim Starr

viii Readers ’ Guide
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 1. Introduction and Background 1-1 

‘Alae ke‘oke‘o chick Laura Beauregard/USFWS

Chapter 1. Introduction 

Kakahai‘a National Wildlife Refuge (NWR or Refuge) is a coastal freshwater pond situated along the 

south coast of Moloka‘i (Figure 1.1, page 1-13). The Refuge is managed as part of the Maui 

National Wildlife Refuge Complex (Complex) headquartered on the Island of Maui. This 44.6 acre 

Refuge was set aside in 1976 to protect and manage endangered Hawaiian waterbirds ae‘o (Hawaiian 

stilt) and ‘alae ke‘oke‘o (Hawaiian coot) and their habitats. 

1.1 Purpose and Need for the CCP

The purpose of the CCP is to provide the Service, the Refuge System, partners, and citizens with a 

management plan for improving fish and wildlife habitat conditions and Refuge infrastructure, for 

wildlife and public use on Kakahai‘a NWR over the next 15 years. An approved CCP will ensure 

that the Service manages to achieve the Refuge purpose, vision, goals, and objectives to help fulfill 

the mission of the Refuge System. 

The CCP is needed for a variety of reasons. Primary among these is the need to establish improved 

habitat conditions on the Refuge’s wetland habitats, which are degraded by invasive plants and 

animals. The plan also recognizes and identifies threats to the endangered ae‘o and ‘alae ke‘oke‘o, 

including predation by nonnative mammals, limited water supply, and human disturbance. There is 

also a need to analyze potential Refuge public use programs for wildlife-dependent priority public 

uses and to determine what improvements or alterations should be made in the pursuit of a highquality visitor experience. Finally, there is a need to describe the steps that should be taken to better 

protect the habitats and wildlife through strategies to accomplish our goals. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

1-2 Chapter 1. Introduction and Background 

1.2 Planning and Management Guidance

The Service, an agency within the Department of the Interior, is the principal Federal agency 

responsible for conserving, protecting, and enhancing fish, wildlife, and plants and their habitats. 

Refuge management is guided by Federal laws, Executive orders, Service policies, and international 

treaties. Fundamental guidelines are found in the mission and goals of the Refuge System and the 

designated purpose of the Refuge 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 National Wildlife Refuge System 

Administration Act of 1966 (16 U.S.C. 668dd-668ee) (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 (FW). The Administration Act is 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. 

1.2.1 U.S. Fish and Wildlife Service Mission 

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

wildlife and their habitats for the continuing benefit of the American people.” National natural 

resources entrusted to the Service for conservation and protection include migratory birds, 

endangered and threatened species, interjurisdictional fish, wetlands, and certain marine mammals. 

The Service also manages national fish hatcheries, enforces Federal wildlife laws and international 

treaties on importing and exporting wildlife, assists with State and Territorial fish and wildlife 

programs, and helps other countries develop wildlife conservation programs. 

1.2.2 National Wildlife Refuge System 

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

for conserving wildlife and protecting ecosystems. From its inception in 1903, the Refuge System 

has grown to encompass over 550 national wildlife refuges in all 50 States, and waterfowl production 

areas in 10 States, covering more than 150 million acres of public lands and waters. More than 

40 million visitors annually fish, hunt, observe and photograph wildlife, or participate in 

environmental education (EE) and interpretive activities on national wildlife refuges. 

1.2.3 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.” The goals of the Refuge System, as articulated in the Mission, Goals, and Purposes 

policy (601 FW1), follow: 

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

endangered or threatened with becoming endangered; 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 1. Introduction and Background 1-3 

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 EE and interpretation); and 

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

wildlife, and plants and their habitats. 

1.2.4 National Wildlife Refuge System Administration Act of 1966 

The Administration Act, as amended by the National Wildlife Refuge System Improvement Act of 

1997 (Improvement Act), requires us to develop a CCP for each national wildlife refuge in an open 

public process. The Administration Act states that the Secretary shall provide for the conservation of 

fish, wildlife, plants, and their habitats within the Refuge System, and 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.’’ As later made clear in the 

Biological Integrity, Diversity, and Environmental Health (BIDEH) policy (601 FW 3), “the highest 

measure of biological integrity, diversity, and environmental health is viewed as those intact and selfsustaining habitats and wildlife populations that existed during historic conditions.”

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 on every refuge. Additionally, six wildlife-dependent recreational 

uses are granted special consideration in the planning, management, establishment, and expansion of 

units of the Refuge System: hunting, fishing, wildlife observation and photography, and EE and 

interpretation. When determined compatible on a refuge-specific basis, these six uses assume priority 

status among all public uses of the refuge in question. The overarching goal is to enhance wildlifedependent recreation opportunities and access to high-quality visitor experiences on refuges, while 

managing refuges to conserve fish, wildlife, plants, and their habitats. The Service is directed to 

make extra efforts to facilitate wildlife-dependent visitor opportunities. 

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

economic uses 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 refuge purposes, the Refuge System mission, or 

goals and objectives described in an approved refuge management plan. A compatible use is defined 

as a use that, in the sound professional judgment of the refuge manager, will not materially interfere 

with or detract from the fulfillment of the mission of the Refuge System or the purpose(s) of the 

refuge. Current Appropriate Use Findings and Compatibility Determinations for existing and 

proposed uses for Kakahai‘a NWR are in Appendix B. 

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

must be developed with the participation of the public. Public comments play a role in identifying 

issues, guiding alternatives considered during development of the CCP, and selecting a preferred 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

1-4 Chapter 1. Introduction and Background 

alternative. It is Service policy to develop CCPs in an open public process; the agency is committed 

to securing public input throughout the process. 

1.3 Relationship to Previous and Future Refuge Plans

Planning has been a part of Refuge operations since establishment. Current management plans 

include: 

Interim Management Plan - 2001 

Wildland Fire Management Plan - 2005 

Integrated Pest Management Plan - 2008 

Refuge Safety Plan - 2010 

Highly Pathogenic Avian Influenza Disease Contingency Plan - 2009

Avian Botulism Disease Contingency Plan - 2008 

Emergency Preparedness Response Plan (updated annually) - 2011 

Continuity of Operations Plan (updated annually) - 2011 

Station Hazardous Communications Plan (updated annually) - 2011 

1.3.1 Future planning 

The CCP will be revised every 15 years or earlier if monitoring and evaluation determine that 

changes are needed to achieve the Refuge purposes, vision, goals, or objectives. The CCP provides 

guidance in the form of goals, objectives, and strategies for Refuge program areas but may lack some 

of the specifics needed for implementation. Step-down management plans will therefore be 

developed for individual program areas, as needed, following completion of the CCP. Step-down 

plans require appropriate NEPA compliance. 

1.4 Refuge Establishment and Refuge Purpose

1.4.1 Legal Significance of the Refuge Purpose 

The purpose for which a refuge was established or acquired must form the foundation for planning 

and management decisions. 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. 

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. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 1. Introduction and Background 1-5 

1.4.2 Refuge Establishment and Purpose 

Kakahai‘a NWR was established in 1976 under the authority of the Endangered Species Act of 1973 

(ESA). The Refuge was funded through the Land and Water Conservation Act of 1965. Refuge 

purposes are the driving force in the development of the refuge vision statements, goals, objectives, 

and strategies in the CCP and are critical to determining the appropriateness and compatibility of all 

existing and proposed refuge uses. Kakahai‘a NWR was established with the purpose “... to 

conserve (A) fish or wildlife which are listed as endangered species or threatened species, or (B) 

plants.” 

Table 1.1 Refuge Acquisition History for Kakahai‘a NWR

Date Acquisition Authority Comments

03/15/1976 Endangered Species Act of 1973 Fee title acquisition of 41.95 acres. 

Initial acquisition.

10/17/1977 Endangered Species Act of 1973 Conservation Easement on 2.31 acres.

06/21/1978 Endangered Species Act of 1973 Conservation Easement on 0.35 acres.

1.5 Refuge Goals 

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

focus management priorities, resolve issues, and link to refuge purpose(s), Service policy, and the 

Refuge System mission. A CCP describes management actions that help bring a refuge closer to its 

vision. A vision broadly reflects refuge purpose(s), Refuge System mission and goals, other statutory 

requirements, and larger-scale plans as appropriate. Wildlife, habitat, and visitor services 

management goals then define general targets in support of the vision, followed by objectives that 

direct efforts into incremental and measurable steps toward achieving those goals. Finally, strategies 

identify specific tools and actions to accomplish objectives. The Refuge vision statement is found on 

the inside front cover of this document. The following are our goals; their order does not imply any 

priority in this CCP. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

1-6 Chapter 1. Introduction and Background 

Nā Pahuhopu Pu‘uhonua Holoholona

1. Kīa‘i a mālama i nā ‘āina pālialia a me ālialia wai maoli nohokau a me nā pālialia noho manawa 

no ka mālama ‘ana i ka mō‘aukala ola pono o nā manuwai Hawai‘i ‘ane make loa.

2. Kīa‘i, ho‘ōla hou, a mālama i nā kaianoho lihikai no ka pono no ka ho‘opunana ‘ana o nā honu 

kai, manu kai, a me ka kūkahi o kēia mau kaiaola pio pau wale. 

3. Ho‘ola hou, kīa‘i, a ho‘oponopono in ā ululā‘au ʻoiwi i mea e pale ho‘oka‘awale ai i nā pilikia o uka 

mai nā ‘āina kumu wai mai.

4. ‘Ohi‘ohi i nā waiwai ‘epekema (nānā, noi‘i, a me ka ho‘ā‘o ‘ana) no ke kāko‘o ‘ana i nā 

makemake o ka mālama ‘ia ‘ana ma ka pahuhopu helu 1 a helu 3 no ka pu‘uhonua holoholona.

5. Ho‘omākaukau i kumu waiwai nui no nā kaianoho mākaukau no na holoholona ‘āhiu, a e kokua 

ho‘i i ka lehulehu ma ka ho‘onā‘auao a a‘o mai iā lākou e pili ana i nā i‘a, nā holoholona hihiu, a 

me nā waiwai nohona ‘ōiwi o kēia wahi nei i kapa ‘ia o Kakahai‘a NWR. 

6. Ho‘omākaukau ho‘i i polokalamu waiwai loa no ke a‘o ‘ana i nā haumāna e pili ana i nā 

kumuhana kūpono a me ka hana lima pu ma nā kaianoho holoholona hihiu.

Refuge Goals 

1. Restore and maintain seasonal and permanent wetland habitats to meet the life history needs of 

endangered Hawaiian waterbirds. 

2. Protect, restore, and manage coastal habitat for the integrity of the fragile ecosystem. 

3. Protect, restore, and manage forest habitat to provide a buffer from upper watershed impacts. 

4. Gather scientific information (survey, research, and assessments) in support of adaptive 

management decisions on the Refuge under goals 1-3. 

5. Provide high-quality wildlife-dependent recreation, interpretation, and outreach opportunities to 

enhance public understanding, appreciation, and enjoyment of the native wildlife, natural 

communities, and cultural history of the Kakahai‘a NWR.

6. Provide students and teachers high-quality hands-on environmental education programs that 

foster a connection with nature and the Refuge.
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 1. Introduction and Background 1-7 

1.6 Relationship to Ecosystem Planning Efforts 

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

regional, and ecosystem plans; State/Territorial fish and wildlife conservation plans; and other 

landscape-scale plans developed for the same watershed or ecosystem in which the refuge is located. 

To the extent possible, the CCP is expected to be consistent with these existing plans and assist in 

meeting their conservation goals and objectives (602 FW 3.3). This section summarizes some of the 

key plans that were reviewed by members of the planning team during CCP development. 

Hawai‘i’s Comprehensive Wildlife Conservation Strategy, 2005. With passage of the Commerce, 

Justice, and State Appropriations Act of 2001, Congress mandated each State and Territory to 

develop its own comprehensive wildlife conservation strategy. Hawai‘i’s Comprehensive Wildlife 

Conservation Strategy thoroughly reviews the status of the full range of the State’s native terrestrial 

and aquatic species, over 10,000 of which are found nowhere else on Earth. Hawai‘i’s Species of 

Greatest Conservation Need include all native terrestrial animals, all endemic aquatic animals, 

additional indigenous aquatic animals identified as in need of conservation attention, a range of 

native plants identified as in need of conservation attention, and all identified endemic algae. This list 

includes: a terrestrial mammal (1), birds (77), terrestrial invertebrates (~5,000), freshwater fishes (5), 

freshwater invertebrates (12), anchialine pond-associated fauna (20), marine mammals (26), marine 

reptiles (6), marine fishes (154), marine invertebrates (197), and flora (over 600). Details on all the 

listed wildlife taxa are provided in fact sheets that contain information for taxa, closely related 

groups of species, and species facing similar threats. 

Hawai‘i Nongame Management Program (Draft), 2000. The goal of the Hawai‘i Nongame 

Management Program is to manage, preserve, and protect the native avifauna and their habitats for 

their intrinsic, recreational, scientific, and educational values and to provide opportunities for the 

residents and visitors to Hawai‘i to use and enjoy these resources. A major focus of the program is 

on management and recovery of endangered species, including projects to monitor, manage habitat, 

and recover populations and control of predators affecting endangered species. Other nongame 

projects include increased surveillance of nonnative pests, construction of facilities and infrastructure 

to promote management or recreational opportunities to enjoy nongame resources, and maintenance 

of those facilities. 

Draft Revised Recovery Plan for Hawaiian Waterbirds, (Second Draft of Second Revision), May 

2005. The ultimate goal of the recovery program is to restore and maintain multiple self-sustaining 

populations of Hawaiian waterbirds within their historic ranges. The recovery of the endangered 

waterbirds focuses on the following objectives: 

Increasing population numbers to Statewide baseline levels (consistently stable or increasing 

with a minimum of 2,000 birds for each species); 

Establishing multiple, self-sustaining breeding populations throughout each species’ historic 

range; 

Establishing and protecting a network of both core and supporting wetlands that are managed 

as habitat suitable for waterbirds, including the maintenance of appropriate hydrological 

conditions and control of pest plants; 

For all four species, eliminating or controlling the threats posed by introduced predators, 

avian diseases, and contaminants; and 

For the koloa maoli (Hawaiian duck), removing the threat of hybridization with feral 

mallards. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

1-8 Chapter 1. Introduction and Background 

U.S. Pacific Islands Regional Shorebird Conservation Plan, 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 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. 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, 

nongovernmental organizations, and the scientific community. On a larger scale, coordination at the 

international level will be key to the conservation of vulnerable species, both migratory and resident. 

Pacific Coast Joint Venture, Hawai‘i, 2006. This strategic plan for waterbirds and wetlands 

identifies management strategies for a diversity of resident and migratory species with varying life 

history requirements across multiple sites to fulfill archipelago-wide conservation goals to “protect, 

restore, increase, and enhance all types of wetlands, riparian habitats, and associated uplands 

throughout the Pacific Coast region to benefit birds, fish and other wildlife” (Henry 2006). To 

accomplish this goal, six strategies are employed: protection, restoration, enhancement and 

management advocacy, outreach, and research. 

Habitat goals for the Pacific Coast Joint Venture (PCJV) strategic conservation plan in Hawai‘i 

represent long ranging concepts that provide direction for conservation objectives and actions. They 

are based on the strategies identified by the PCJV and support goals identified by other avian 

conservation plans for Hawai‘i. 

Moloka‘i Community Plan, 2001. One of nine community plans for the County of Maui describing 

planning goals, objectives, policies and implementation strategies to guide decision-making, this plan 

is currently under revision. It provides specific direction in addressing the goals, objectives and 

policies contained in the County’s General Plan, while recognizing the values and unique attributes 

of Moloka‘i in order to enhance the region's overall living environment. The environmental goal is to 

“Preserve, protect and manage Moloka‘i’s exceptional natural land and water resources to ensure 

that future generations may continue to enjoy and protect the island environment.” Many of the 

Moloka‘i Community Plan objectives apply to the Refuge, including: 

Protect and encourage the restoration of native habitats through government and private 

conservation, land management and educational programs. 

Restore the environmental integrity of Moloka‘i’s land resources through development of a 

comprehensive reforestation program utilizing native species. 

Manage, protect and preserve shoreline dune formations throughout the region. 

Manage, protect, and where appropriate, restore reef habitats, fish ponds and other 

coastal resources unique to the Island of Moloka‘i.

Protect and manage coastal water quality through best management land treatment 

practices. 

Recognize and preserve traditional access and uses of the environment to address 

subsistence needs of the residents of Moloka‘i.
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 1. Introduction and Background 1-9 

Encourage the development of environmentally sensitive drainage master plans which 

consider development opportunities and constraints in flood prone areas, stream channels 

and gulches. 

Encourage alternative means of pest control in order to limit the use of chemical pesticides. 

Require fire prevention and suppression strategies as a means of protecting and preserving 

Moloka‘i’s land and coastal water resources.

Promote the inclusion of environmental education within the curriculum at all educational 

levels to foster respect for Moloka‘i’s land, water and marine resources.

1.7 Planning and Issue Identification 

In September 2009, approximately 250 copies of Planning Update 1 were mailed and handdistributed to interested individuals, local conservation groups, research organizations; County, State, 

and Federal government agencies; and the Office of Hawaiian Affairs (OHA). 

Planning Update 1 described the planning process, Refuge purpose, and draft wildlife and habitat, 

and public use goals, and preliminary issues to be considered in the CCP. 

1.7.1 Public Scoping Sessions 

The public scoping period for this CCP opened November 2009. A public meeting was held in 

Kaunakakai, Moloka‘i on November 4, 2009. At the meeting, the Refuge staff explained the CCP 

planning process; the Refuge purpose(s), vision, and management; and preliminary management 

issues, concerns, and opportunities. We received written comments and answered questions that 

addressed a number of issues and concerns from residents. Planning Update 2 (mailed February 

2010) summarized the comments we received and listed preliminary management issues we used to 

draft alternatives and refine goals and objectives. 

The core planning team evaluated the issues and the topics documented during scoping. Issues

(defined as matters of controversy, dispute, or general concern over resource management activities, 

the environment, land uses, or public use activities) are important to the planning process to help 

identify topics to be addressed in the plan, pinpoint the types of information to gather, and help 

define alternatives for the plan. In Planning Update 3 (mailed March 2011), we described the three 

alternatives being considered with the preferred alternative identified. 

Planning Update #4 and the Draft CCP and Environmental Assessment (EA) were published in 

August 2011 with a public comment period running from August 19-September 19, 2011. A public 

meeting on the Draft CCP/EA was held in Kaunakakai, Moloka‘i on September 7, 2011. Concurrent 

with mailing, Planning Updates 1-4 were also posted on the Refuge Website 

(http://www.fws.gov/Kakahaia). 

1.7.2 Issues Addressed in the CCP 

Restoration of the Wetlands: The continuous encroachment of pest plants, particularly California 

bulrush, has been a serious dilemma. Strategic planning is needed to efficiently remove and restore 

the wetlands and provide for endangered waterbirds and migratory species that once thrived. The 

Refuge will prepare a comprehensive Habitat Management Plan that will outline the restoration 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

1-10 Chapter 1. Introduction and Background 

activities needed to remove and reconfigure Old Pond back to an open water pond that is naturally 

fed by springs. This work is likely to include deconstruction of the radial levees that were 

constructed in 1983; these levees pose a threat to the integrity of the pond by limiting water flow, 

capturing sediment, and are host to non-wetland vegetation. 

New Pond was intended to provide shallow water habitat for wading birds, primarily ae‘o; however, 

the original plan to receive water from Old Pond is not ideal and requires a separate source of water. 

Prior to construction of a water source, we need to identify the soil type and New Pond’s capability 

to hold water. 

Staff Presence on the Refuge and in the Community: Refuge staff, operation, and management of 

Kakahai‘a NWR are based at Keālia Pond NWR on Maui. A Maintenance Worker makes a day trip 

to Moloka‘i every other week to check on the property and perform work, primarily pest plant 

control (fence line, New Pond). When the wetland is restored, the Refuge will need on-site staff or 

increased visits to maintain the wetlands and ensure the habitat does not revert to its existing 

condition. Strategic and efficient planning to restore Old Pond is necessary given the year-round 

growing season for California bulrush and natural source of underground springs. 

Wildlife and Habitat Resources: In the absence of quality habitat, endangered waterbirds are no 

longer present on the Refuge, except after heavy rains when water pools in New Pond for a short 

period of time (typically less than 1 week). The Service is concerned with threats posed to native 

habitats and wildlife at Kakahai‘a from pest plants like California bulrush and pickleweed, and pest 

animals such as rats, Indian mongooses, and cats. 

Coastal Erosion: The coastal property within the Refuge has undergone heavy erosion over the past 

decade. The reasons are unknown and emphasize the need to consult with coastal geologists and 

identify methods of securing the integrity of the coastal property without impacts to other adjacent 

areas. Refuge staff will seek partnerships to address effects of climate change. 

Information about unlawful removal of sand at the culvert adjacent to the Refuge road was revealed 

at the scoping meeting. Whether or not the removal is being performed by the State, County, or 

individuals, the Refuge will investigate this to ensure the proper information is distributed and install 

signs along the Refuge’s coastal property citing County ordnance.

Visitor Services Activities: The absence of staff at Kakahai‘a NWR makes it difficult to allow public 

access on a daily basis and the Refuge will continue issuing Special Use Permits (SUP) to allow nongovernment educational organizations to provide school group access. Within the past number of 

years, these groups have decreased due to the absence of waterbirds. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 1. Introduction and Background 1-11

Figure 1.1 – Main Hawaiian Islands 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

1-12 Chapter 1. Introduction and Background 

To preserve the quality of the map, this side was left blank intentionally. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 1. Introduction and Background 1-13

Figure 1.2 – Refuge Land Status & Boundary 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

1-14 Chapter 1. Introduction and Background 

To preserve the quality of the map, this side was left blank intentionally.
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-1

Chapter 2. Refuge Management Direction 

2.1 Considerations in the Design of the CCP

In thinking through appropriate actions for this long-term conservation plan, the planning team 

reviewed and considered a variety of resource, social, economic, and organizational aspects 

important for managing the Refuge. As is appropriate for a national wildlife refuge, resource 

considerations were fundamental in developing the CCP. 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.”

Local, State, and Federal agencies and elected officials were contacted by the planning team to 

ascertain priorities and problems as perceived by others. The team also contacted Refuge users, 

nonprofit groups, and community organizations to ensure that their comments and ideas were 

considered during CCP development. 

2.2 General Guidelines

To reduce the length and redundancy of the individual objective descriptions, common elements are 

presented below. 

2.2.1 Implementation Subject to Funding Availability 

Actions will be implemented over a period of 15 years as funding becomes available. Routine 

maintenance, repair, replacement, and improvement of existing facilities will continue, also 

dependent on funding. Annual priorities will follow CCP guidelines, although funding initiatives, 

unforeseen management issues, and budgets may vary from year to year. The CCP will be reviewed 

every year and updated as necessary throughout its life. 

2.2.2 Interagency Coordination and Collaboration

Ecosystem planning efforts discussed in Chapter 1, Section 1.6 involve collaboration among Federal, 

State, and local agencies toward mutual goals. The Service will continue to maintain regular 

discussions and partnership with the DLNR, and we will seek out other State and local agencies, nonprofit, and private individuals. Topics for discussion continue to be the endangered waterbirds at 

Kakahai„a NWR and surrounding private and public lands, wetland restoration, and wildlife 

monitoring. Current partners include: U.S. Geological Survey (USGS), the Nature Conservancy 

(TNC), Moloka„i Invasive Species Committee (MoISC), the Natural Resource Conservation Service 

(NRCS) and the Moloka„i-Lana„i Soil and Water Conservation District.

2.2.3 Threatened and Endangered Species Protection and Recovery

Protection of threatened and endangered (T&E) species is common across all alternatives. It is 

Service policy to give priority consideration to the protection, enhancement, and recovery of these 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

2-2 Chapter 2. Refuge Management Direction

species on national wildlife refuges. The protection of federally listed species is mandated through 

Section 7 of the ESA, called “Interagency Cooperation,” is the mechanism by which Federal 

agencies ensure the actions they take, including those they fund or authorize, do not jeopardize the 

existence of any listed species. To ensure adequate protection, the Refuge is required to review all 

activities, programs, and projects occurring on lands and waters of the Refuge to determine if they 

may affect listed species. If the determination is that an action may affect an endangered species, 

then the Refuge conducts a formal review, known as a consultation, to identify those effects and 

means to mitigate those effects. 

2.2.4 Historic and Cultural Resource Protection

Cultural resources on refuge lands 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. Refuge management actions will 

support the State of Hawai„i‟s vision statement “to promote the use and conservation of historic and 

cultural resources for the education, inspiration, pleasure and enrichment of the public in a spirit of 

stewardship and trusteeship for future generations” (State Historic Preservation Plan 2010-2014). 

The Native American Graves Protection and Repatriation Act (NAGPRA) is a Federal law passed in 

1990 that provides a process for museums and Federal agencies to return certain Native American 

cultural items — human remains, funerary objects, sacred objects, or objects of cultural patrimony —

to lineal descendants, and culturally affiliated Indian tribes and Native Hawaiian organizations. A 

Native Hawaiian organization includes any organization that: (a) serves and represents the interests 

of Native Hawaiians, (b) has as a primary and stated purpose of the provision of services to Native 

Hawaiians, and (c) has expertise in Native Hawaiian Affairs, and includes the Office of Hawaiian 

Affairs and Hui Malama i na Kupuna „o Hawai„i Nei. The DOI has interpreted this definition to also 

include the Hawaiian island burial councils and various „ohana (extended families).

During early planning of any projects, the Refuge will provide the Service 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. The RHPO will analyze these undertakings for potential to affect 

historic properties and enter into consultation with the State Historic Preservation Officer (SHPO) 

and other parties as appropriate. The Refuge will also ask the public and local government officials to 

identify any cultural resource impact concerns. This notification is generally done in conjunction 

with the review required by NEPA or Service regulations on compatibility of uses. 

2.2.5 Fire Management

The suppression of wildfires and the use of prescribed or controlled fire are a long-standing part of 

resource protection, public safety, and habitat management on national wildlife refuges. The Fire 

Management Plan (Appendix F) provides detailed guidance for the suppression and use of prescribed 

fire. That plan's actions and effects are incorporated through reference in this CCP. The plan outlines 

wildfire response and prescribed fire objectives, strategies, responsibilities, equipment and staffing; 

burn units; implementation; monitoring; and evaluation. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-3

2.2.6 Participation in Planning of Regional Development Activities

The Service will actively participate in planning and studies for ongoing and future industrial and 

urban development, contamination, and other potential concerns that may affect the Refuge‟s wildlife 

resources and habitats. The Service will continue to cultivate working relationships with pertinent 

State and Federal agencies to stay abreast of current and potential developments and will utilize 

effective outreach tools and technologies and EE as needed to raise awareness of the Refuge‟s 

resources. The Refuge will participate in local community initiatives to protect, steward, and enhance 

natural landscapes and wildlife habitat. 

2.2.7 Adaptive Management 

Based upon 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 43 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). The recently published DOI Adaptive 

Management Technical Guide also defines adaptive management as a decision process that 

“promotes flexible decision making that can be adjusted in the face of uncertainties as outcomes from 

management actions and other events become better understood.” 

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

habitats, and the ecological processes supporting them may be lacking. The role of natural variability 

contributing to ecological resilience also is recognized as an important principle of adaptive 

management. It is not a “trial and error” process, but rather emphasizes learning while doing based 

upon available scientific information and best professional judgment considering site-specific biotic 

and abiotic factors on Refuge lands. Adaptive management results in effective monitoring and 

evaluation of the CCP. 

Part of measuring the success of and adaptively managing the Refuge also includes the formal 15-

year revision of the CCP. The revision will be initiated by the Service and will involve many of the 

same steps as this CCP, including comprehensive review of management plans and research; 

working closely with partners; and engaging the public. 

2.2.8 Integrated Pest Management 

In accordance with DOI policy 517 DM 1 and Service policy 569 FW 1, an integrated pest 

management (IPM) approach will be utilized, where practicable, to eradicate, control, or contain pest 

and invasive species (herein collectively referred to as pests) on Refuge lands. The IPM will involve 

using methods based upon effectiveness, cost, and minimal ecological disruption, which considers 

minimum potential effects to nontarget 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 will be needed on Refuge 

lands, the most specific chemical available for the target species will be used unless considerations of 

persistence or other environmental and/or biotic hazards will preclude it. In accordance with 517 DM 

1, pesticide usage will be further restricted because only pesticides registered with the Environmental 

Protection Agency (EPA) in full compliance with the Federal Insecticide, Fungicide, and Rodenticide 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

2-4 Chapter 2. Refuge Management Direction

Act and as provided in regulations, orders, or permits issued by EPA, that it is registered for use in 

the State of Hawai„i, may be applied on lands and waters under Refuge jurisdiction. 

Environmental harm by pest species refers 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/or 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; preventing them from reproducing; 

outcompeting 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 waterfowl use may result from pest plant infestations reducing the availability and/or 

abundance of native wetland plants that provide forage during the winter. 

Throughout the life of the CCP, most proposed pesticide uses on Refuge lands will be evaluated for 

potential effects to Refuge biological resources and environmental quality. Pesticide uses with 

appropriate and practical best management practices (BMP) for habitat management as well as 

facilities maintenance will be approved for use on Refuge lands where there likely will be only 

minor, temporary, and localized effects to species and environmental quality based upon nonexceedance of threshold values in chemical profiles. However, pesticides may be used on Refuge 

lands where substantial effects to species and the environment are possible (exceed threshold values) 

in order to protect human health and safety (e.g., mosquito-borne disease). For more information on 

strategies related to control of pests, see Appendix E. 

2.2.9 National Environmental Policy Act Compliance 

Since this CCP is programmatic in many issue areas, it may not contain the necessary detail on every 

future action outlined to adequately present and evaluate all physical, biological and socioeconomic 

impacts. Thus, before certain objectives or actions are implemented, a decision will be made in 

coordination with the Regional NEPA Coordinator on whether separate step-down NEPA 

compliance (categorical exclusions, environmental assessments, or an environmental impact 

statement) are needed. 

2.2.10 Law Enforcement

Officers’ Responsibilities 

Fish and wildlife law enforcement issues on lands and waters of the Kakahai„a NWR are under the 

jurisdiction of the Service Zone Officer based in Honolulu. The role of the Zone Officer is to conduct 

and document law enforcement incidents and coordinate and/or meet with all refuge project leaders, 

law enforcement supervisors, and refuge officers. The Hawaiian and Pacific Islands Zone Officer is 

highly mobile and is frequently deployed temporarily to various areas throughout the State of 

Hawai„i and across the Pacific Region. The need for a dedicated Refuge Officer for the Complex has 

been identified in the Implementation Plan (Appendix C). 

Officers’ Authority

The Zone and Refuge Officers are primarily responsible for enforcing refuge and wildlife laws, 

including but not limited to the: 

Administration Act; 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-5

Lacey Act; 

Archaeological Resources Protection Act; 

Endangered Species Act; 

Migratory Bird Treaty Act; and 

Marine Mammal Protection Act. 

Zone and Refuge Officers are also empowered to enforce all criminal laws, including traffic 

violations, drugs, and warrants for arrest as they relate to trespass, hunting, fishing, and the taking of 

wildlife on Federal lands, and in some instances boating safety related to refuge lands and waters. 

Service Officers work joint patrols and coordinate with the State Division of Conservation and 

Resources Enforcement (DOCARE), Maui Police Department, and the Sheriff Division of the State 

Department of Public Safety.

2.2.11 Refuge Revenue Sharing Payments 

Annual payments to the County of Maui under the Refuge Revenue Sharing Program in lieu of 

property taxes will continue according to the established formula and subject to payments authorized 

by Congress. 

2.2.12 Regulatory Compliance 

Activities under all alternatives requiring additional review, permits and clearances (e.g., Section 106 

of the National Historic Preservation Act, ESA Section 7 endangered species consultation, 401 water 

quality permits, etc.) will undergo appropriate review and obtain permits and/or clearances as 

needed. 

2.2.13 Volunteer Opportunities 

Volunteer opportunities occur in all alternatives. These are recognized as components of the 

successful management of public lands and may become vital to the implementation of refuge 

programs, plans, and projects, especially in times of declining budgets. Currently, the Refuge hosts 

intermittent volunteer projects with 40 volunteers. 

2.2.14 Climate Change 

Climate change is expected to place enormous pressure on coastal refuges particularly vulnerable to 

sea level rise (SLR) resulting from melting glaciers and thermal expansion of oceans. Estimates by 

the Intergovernmental Panel on Climate Change (IPCC) project that global sea level will rise 0.6-2 

feet by the end of the century. This threatens to erode shorelines, inundate low-lying areas, and 

contaminate freshwater resources through saltwater intrusion. Other impacts of climate change 

include species‟ range shifts, phenological changes, decoupling of species assemblages, hydrological 

changes, and changes in disturbance regimes. Such impacts could result in dramatically different 

ecosystem compositions than currently exist on the refuges, and planning decisions will consider this 

issue. 

There is overwhelming scientific consensus that the earth‟s climate is rapidly changing and that the 

primary cause of global warming is human-caused increases in greenhouse gas emissions. Much less 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

2-6 Chapter 2. Refuge Management Direction

is understood about the complex effects that a rapidly changing climate will have on ecosystems and 

wildlife. The Service is participating in the Pacific Islands Climate Change Cooperative (PICCC) to 

develop protocols for monitoring the status and trends of fish, wildlife, and plants in relation to 

climate changes. A collaborative program throughout the region will best equip stakeholders to 

discern changes in abundance or distribution of indicator species. Because regional data 

accumulation and analysis is requisite, we will coordinate efforts with other Federal agencies, State 

agencies, conservation organizations, universities, local landowners, and climate change scientists. 

Such coordinated studies and monitoring data benefit our understanding and appropriate response to 

changes throughout the region. 

2.3 Summary of CCP Actions

As funding and staffing levels permit, we will restore the 15-acre Old Pond and 5.5 acres of New 

Pond. Physical restoration of the Old Pond will include: removal of California bulrush and other 

aggressive pest species, dredging accumulated sediment, reconfiguring bathymetry and radial levees, 

reconstructing perimeter levees, replacing the water control structure, and replacing the pump 

between the two ponds. Restoration of Old Pond will provide open water and emergent habitat for 

breeding, foraging, and nesting „alae ke„oke„o with minimum supplemental water due to the presence 

of natural groundwater springs. 

Management actions include a compilation of available data on the ecology of the wetlands and 

initiation of research to evaluate the geomorphology, hydrology, and elevation in preparation for a 

restoration design that would meet the needs of two focal species: ae„o and „alae ke„oke„o. A new 

well, pump, water distribution line, and control outlet for New Pond will be constructed and existing 

levees will be reconstructed. The capability of flooding and dewatering the ponds will provide 

permanent and seasonal habitat for ae„o and „alae ke„oke„o, and indirectly benefit migratory 

waterbirds. All monitoring activities would resume with the presence of wetland function. If feasible, 

a predator-proof fence will be installed to minimize or eliminate predators from entering the 

wetlands. 

The Service will work with the Hawai„i Department of Transportation (HDOT) on planning and 

design to modify the culvert passing under Kamehameha V Highway to allow water from the upper 

watershed and periodic dewatering of the wetlands to flow to the ocean naturally without blockage 

from sand. We will contract a comprehensive archaeological and cultural investigation for the 

Refuge and surrounding lands prior to expanding restoration efforts beyond previously disturbed 

lands. 

Maintaining the wetlands at Kakahai„a NWR will require a regular on-site staff presence. The 

opportunities for visitors to engage in wildlife-dependent recreation may expand depending on 

staffing, and, at a minimum, a kiosk will be constructed on the earthen platform along the Refuge 

entrance road. Volunteer groups will be coordinated to assist staff with restoration and maintenance 

activities.
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-7

Table 2.1. 

Kakahai‘a NWR Management Summary

Key 

Themes

Objectives Target Acreage Restored and 

Management Actions

HABITATS

1.1 Seasonal wetland habitat for ae‘o 5.5-7 acres

1.2 Permanent wetland habitat for ‘alae ke‘oke‘o 14 acres

2.1 Coastal strand 2 acres

2.2 Grassland 2.3 acres

3.1 Dry forest 7 acres

SCIENTIFIC DATA

4.1 Conduct inventory and monitoring

Monitor nesting success; impacts of pest plants 

& animals; water quantity and quality; and 

abundance of endangered waterbirds

4.2 Conduct research projects

Study most effective IPM strategies; climate 

change research projects 

4.3 Conduct scientific assessments

Assess water resources, assess bathymetric 

configurations; develop climate change 

assessment protocols; evaluate SLAMM 

analyses; and conduct comprehensive cultural 

resource survey

VISITOR SERVICES

5.1 Wildlife observation and photography Up to 500 visitors/year

5.2 Interpretation, outreach, partnerships, and 

volunteer programs Up to 10 programs/year

6.1 Expand EE partnerships

5-12 programs/year
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

2-8 Chapter 2. Refuge Management Direction

2.4 Kakahai‘a NWR Management

Goals and objectives are the unifying elements for 

successful, adaptive refuge management. They 

identify and focus management priorities, resolve 

issues, and link to refuge purpose(s), Service 

policy, and the Refuge System mission. The goals 

for the Kakahai„a NWR are presented on the 

following pages. Each goal is followed by one or 

more objectives that pertain to it. The goal order 

does not imply any priority in this CCP. Some 

objectives pertain to multiple goals and have simply 

been placed in the most reasonable spot. Similarly, 

some strategies pertain to multiple objectives and 

for clarity these strategies are listed under each 

relevant objective. 

Following the goals, objectives, and strategies, a brief rationale is provided. This rationale generally 

describes how management strategies will be implemented to achieve the intended objectives. The 

rationale may also, where necessary, discuss means to minimize potential impacts to nontarget 

species and habitats. It also provides further background information pertaining to the importance of 

an objective relative to legal mandates for managing units of the Refuge System, including refuge 

purpose, trust resource responsibilities (federally listed threatened and endangered species and 

migratory birds), and maintaining/restoring biological integrity, diversity, and environmental health. 

‘Alae ke‘oke‘o nest USFWS
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-9

2.4.1 GOAL 1. 

Restore and maintain seasonal and permanent wetland habitats to meet the 

life history needs of endangered Hawaiian waterbirds. 

Objective 1.1: Restore and maintain seasonal wetland habitat for ae„o.

Restore and maintain 5.5 acres of seasonal wetland habitat for ae„o throughout the year in New 

Pond with the following characteristics:

A mix of saturated and dry mudflat with small, low islands with dimensions of at least 30

ft diameter and 5:1 side slopes;

75% of the bottom with undulating, irregular topography that creates exposed unsaturated 

substrate (e.g., shoreline, islands) with gradual slopes during drawdown for nesting sites 

adjacent to foraging habitat;

Levees with 4:1 slopes to provide loafing and foraging habitat;

Open water (<4-6 in. depth) and mudflat (saturated and unsaturated) with <30% cover of 

vegetation (e.g., sprangletop, kaluhā, makaloa) as a mosaic to provide protection from 

wind and adequate foraging areas;

80% water coverage for breeding ae„o; 

Predation of less than 1% of ae„o adults documented per year, to achieve nest success of 

70% or greater;

<10% pest plants (California bulrush, California grass, and Indian marsh fleabane); 

No tilapia present;

Abundant aquatic invertebrates with densities of 400-600 invertebrates/yd2; and

No human disturbance during ae„o breeding season (April-July).

Strategies for Achieving the Objective

Control pest plants using mowing, brush cutting, excavation, water level management, prescribed 

fire, and herbicides (see IPM, Appendix E) 

Propagate and plant native species to establish natural vegetative cover on pond levees and slopes 

Use IPM techniques to promote a mosaic of vegetation/open water 

Develop wetland restoration plan and design

Construct water source (well, pump, water distribution line) for supplemental flooding by 2014

Pulse water during flooding, drawdown, and nonbreeding season to promote abundance and 

availability of invertebrates

Allow periodic dewatering from September-December to recycle nutrients and promote 

invertebrate abundance and diversity

Control predators using spring traps, bait stations, and water level management

Eliminate visitor access to nesting areas during breeding activity 

Use heavy equipment to rebuild levees (4:1 slopes) by 2015

Use heavy equipment to form and maintain islands by 2015

Replace New Pond water control structures by 2015

Install new piezometers by 2013

Slow drawdown of water to eliminate fish and promote invertebrate/algal growth and plant 

response

Station employee (Maintenance Worker or Biologist) at Kakahai„a NWR to oversee Refuge 

programs by 2014
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

2-10 Chapter 2. Refuge Management Direction

Rationale

Originally, New Pond was flooded from water pumped from Old Pond; however, the 

encroachment of California bulrush throughout Old Pond has resulted in an unavailability of water. 

Construction of a well and installation of a pump with electrical service is needed to provide 

forage, resting, and nesting habitat as well as use water level to control pest plants and promote 

invertebrate diversity and abundance. Ae„o require different loafing and foraging habitats during 

the breeding and nonbreeding seasons. Recently hatched chicks (less than 14 days old) require 

shallow water of less than 2 inches to forage. During the remainder of the year, fledglings and 

adults can forage in water as deep as 6 inches.

Seasonally regulating water depth stimulates germination of desirable and beneficial plant species, 

controls pest plants, and provides a variety of macroinvertebrates for young and adult ae„o to feed 

upon, thereby creating and maintaining maximized production and carrying capacity of the 

wetlands. In addition to providing forage, seasonally regulated water depths provide a mosaic of

open water and vegetation as microhabitat for thermoregulation. Dewatering the pond during 

nonbreeding season is beneficial for recycling nutrients and allowing staff to perform IPM 

(herbicide and mechanical treatment) before flooding. This drying cycle enhances soil aeration 

and invertebrate productivity. Invertebrates are the primary food source for waterbirds but labor 

intensive to monitor. Random sampling and subsampling of sieved invertebrates will provide 

densities of species composition and abundance, and response to IPM techniques. 

Management techniques including, mowing, herbicide application, prescribed fire, rototilling and 

water level management are all techniques suitable for creating the desired mosaic of vegetation, 

open water, and mudflats. These practices also benefit a variety of other wetland-dependent 

species including „alae ke„oke„o, wintering waterfowl (dabbling ducks), and shorebirds. The pond 

would be flooded from a groundwater well or from Old Pond, and ocean water is not likely to 

inundate the pond.

Declining water levels increase areas of suitable nesting habitat. Ae„o breeding season drawdowns 

maximize the number of nests that an area can support. The target distance between nest site to 

vegetation and water is approximately 0-20 feet. These slow breeding season drawdown rates also 

stimulate ample numbers and diversity of invertebrates throughout the brood rearing period, 

allowing adults with broods to establish feeding territories and reduce inter-brood conflicts that can 

result in injury or death to young chicks.

Ae„o are very easily disturbed during the nesting season. One behavior of the adult is to depart the 

nest when perceived danger is detected, leaving the nest, eggs, or young exposed to ground or 

avian predators and the weather. Eggs can also be destroyed by prolonged exposure to high 

temperature, wind chill, and rain, all of which occur frequently in Hawai„i. Human disturbance 

must be minimized during the nesting period to reduce the risk of nest abandonment. 

Ae„o nests, eggs, and young are vulnerable to a variety of predators including rats, mongooses, 

dogs, cats, cattle egrets, and „auku„u. It is critical to control predators during the nesting season, 

thereby increasing nesting and fledging success. During this period, control will include two 

layers of perimeter trapping at a maximum distance of 218 yards apart, with traps placed 109 yards 

apart, or less. Predator control during the nonbreeding season is reliant on available staff 

(permanent or contracted) to monitor the program; therefore, trapping effort will be minimal (live 

traps and bait stations) along the perimeter of the ponds.
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-11

Objective 1.2: Restore and maintain permanent wetland habitat for „alae ke„oke„o.

Restore and manage 15 acres of permanent wetland habitat for loafing and foraging „alae ke„oke„o 

in Old Pond throughout the year with the following characteristics: 

Low native, vegetation cover (<4 in) on levees for foraging and loafing;

Abundant aquatic invertebrates with densities of 400-600 invertebrates/yd2;

<50 ft. width of emergent vegetation along shorelines; 

Open water (<18 in.) and/or mudflat interspersed with 30-60% cover of emergent 

vegetation and algae that provides seeds and green browse, concealment, and thermal 

cover;

20 ft. of open water between levees and emergent vegetation to protect nests from 

predation;

4:1 slope on levees;

>90% reduction of marsh fleabane, California bulrush, and California grass; 

50:50 percentage of open water to emergent vegetation;

Extended hydro periods to promote epiphytic invertebrates (e.g., dragonflies);

<25% cover of annual pest plants;

Documented predation level of less than 1% „alae ke„oke„o annually;

Brood rearing within 150 ft. from nesting habitat ; 

Stable water levels (1.0-2.5 ft. depth) during „alae ke„oke„o laying and incubation 

(December-April); and

No human disturbance during nesting season.

Strategies Applied to Achieve Objectives

Prepare restoration plan for Old Pond with engineering specifications and estimated costs by 2013

Clear vegetation and maintain open water around staff gages and piezometers

Implement partial to complete access closures on levees to minimize human disturbance during 

breeding season

Use IPM strategies including mechanical/physical, water levels, prescribed fire, chemical, and 

biological to control pest plants (Appendix E) 

Identify methods to isolate groundwater springs 

Implement predator controls including spring traps, bait stations, shooting, vegetation 

management, and water level management

Repair and maintain boundary fence and wetland perimeter fence

Install predator-proof fence along perimeter of ponds by 2016

Remove interior levees and accumulated sediment in Old Pond and recontour pond bottom to 

create microtopography for varying water level conditions by 2015

Remove pest plant species from levees and restore elevation, width, and slopes by 2015

Replace Old Pond water control structures by 2015

Install additional piezometers to monitor groundwater levels by 2013

Install water level recorder in Old Pond by 2015

Replace pump between Old and New Ponds, if feasible, by 2015

Propagate and plant native species on levees, levee slopes, and within ponds for erosion control 

and forage

Periodic dewatering areas of the pond to recycle nutrients, aerate soil, manage vegetation, and 

stimulate invertebrate response

Design and construct sediment basin along north boundary to minimize sedimentation entering the 

ponds by 2014
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

2-12 Chapter 2. Refuge Management Direction

Rationale

Natural weather patterns, runoff, and subsurface ground water movement control the hydrology of 

the wetlands. Old Pond is naturally fed by groundwater springs resulting in a permanent 

hydrological unit. This natural watering is advantageous in that pumping is not required; however, 

California bulrush has become well established and currently covers more than 90 percent of the 

pond. The pond currently has no open water available to „alae ke„oke„o. Restoration of Old Pond 

for endangered and migratory waterbirds needs to incorporate an evaluation of the groundwater 

aquifer, topography, geotechnical data, and identification of methods to isolate the springs (e.g.,

temporary cofferdams) to allow the enclosed area to be pumped out, creating a dry work 

environment for the major work to proceed. The levees extending into the pond (radials) produce 

exposed areas where dryland species (e.g., kiawe, monkeypod, and Indian marsh fleabane) have 

become established. These radial levees need to be removed to improve the function of the 

wetland.

The ideal wetland, a mosaic of open water and native vegetation, provides thermoregulation cover 

during periods of high wind and rain, as well as increasing pair bond and brood rearing habitat. 

Where possible, drawdown of water will promote growth of native sedges and invertebrates. 

Eradicating California bulrush and obtaining water control will result in proper management of the 

soils to enhance macro and other aquatic invertebrate production. 

Low vegetation on levees creates important habitat for „alae ke„oke„o as well as other species. 

Maintaining vegetation height of less than 4 inches provides foraging areas where „alae ke„oke„o 

can graze on short grass and feed on associated invertebrates. Levees are used as loafing habitat 

by shorebirds. Planting of native vegetation along levee slopes also prevents erosion and provides 

nesting structure and visual obscurity for nest territories.

A diversity of wetland habitats are beneficial for „alae ke„oke„o during the nonbreeding season, 

from saturated mudflats to emergent wetlands where birds can forage on seeds and seek cover.

„Alae ke„oke„o are primarily herbivores, but opportunistically forage on epiphytic invertebrates, 

especially during egg laying and early growth (chick) stages. When preparing the pond for 

nesting, water levels are maintained at a constant level to provide adequate nest sites that are 

secure from predation. Fluctuating water levels would require nesting adults to continually 

expend energy to build the nest up or have it isolated on dry ground and subject to greater 

predation. 

During brood-rearing periods, however, water levels would be pulsed to provide physical barriers 

between brood territories and stimulate macroinvertebrates that are eaten by adults in breeding 

condition and also fed to developing chicks. These invertebrates are an important protein source 

for proper development. Water levels are managed to help achieve a ratio of 50:50 vegetation to 

open water. Providing a mosaic of open water and desirable plant species promotes the greatest 

number of nesting and brood-rearing territories, while minimizing intraspecific strife between 

family units. It is important to maintain restricted access to minimize human disturbance during 

the nesting period. This includes visits from the general public, tours/educational groups, and 

Refuge staff. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-13

2.4.2 GOAL 2. 

Protect, restore, and manage coastal habitat for the integrity of the fragile 

ecosystem. 

Objective 2.1: Protect and maintain ocean shoreline habitat.

First restore and thereafter maintain 2 acres of the ocean shoreline habitat along Kamehameha V 

Highway. Implement methods to protect the coastal strand from further erosion to provide a protective 

barrier to the Refuge wetlands and highway. The coastal strand will be restored and maintained for the 

following characteristics: 

Patchy distribution of low growing (2-8 in), native woody species (e.g., „ilima, naupaka 

kahakai, and pilo) as a mosaic to naturally construct a dune system;

30-40% cover of native grasses (e.g., „aki„aki) and herbaceous vegetation (e.g., „akulikuli and 

kīpūkai) along shoreline;

<25% of woody pest plant species (e.g., Indian marsh fleabane, kiawe, and koa haole); and

<70% cover of herbaceous pest plant species (saltbush) and grasses (buffel grass, swollen 

finger grass).

Strategies Applied to Achieve Objectives

Install signs referencing regulations prohibiting removal of sand from shoreline by 2012

Use appropriate IPM techniques to eradicate pest plant species that would not result in additional 

erosion

Plant native coastal species to ameliorate erosion

Install temporary sand fencing to facilitate restoration of impacted shoreline by 2013

Consult with coastal specialists on the future impacts of climate change 

Rationale

Management of Kakahai„a NWRs coastal property is a collaborative effort with the County of Maui

and has been managed as a park since the Refuge‟s establishment in 1976. Nonnative grasses, kiawe 

trees, coconut trees, and marsh fleabane are currently maintaining the integrity of the soils/sand. 

Removing all of these established (rooted) plants from the coast without immediate replacement would 

be detrimental to the integrity of this site. Additional planting of native species along the beach will

protect the existing area and provide structure upon which sand can build.

Coastal dune communities are important to several rare and endangered plant and (potentially) animal 

species. Coastal dunes are also fragile and easily altered by human activity. Coastal strand habitat also 

provides foraging and loafing habitat for migratory bird species such as the „ulili (wandering tattler), 

kōlea (Pacific golden plover), hunakai (sanderling), and „akekeke (ruddy turnstone). Given the soil 

texture, relative position to the shoreline, and desirable plant species; the strand provides suitable 

subterranean nest burrow habitat for „ua„u kani. The coastal strand habitat at Kakahai„a may also be 

suitable for „īlio-holo-i-ka„uaua pupping and rearing and by honu „ea (hawksbill sea turtle) and honu 

(Hawaiian green turtle) for laying eggs and basking. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

2-14 Chapter 2. Refuge Management Direction

Objective 2.2: Restore and maintain coastal grassland habitat.

First restore and thereafter maintain 2.3 acres of grassland habitat along both sides of the entrance road 

on the west side of the Refuge with the following characteristics: 

Patchy distribution of low growing (2-8 in), native woody species (e.g., ‘ilima and pilo);

30-40% cover of native grasses (e.g., ‘aki‘aki and pili);

<25% of woody pest plant species (e.g., Indian marsh fleabane, kiawe, and koa haole); and

<70% cover of herbaceous pest plant species (e.g., saltbush) and grasses (buffel grass, swollen 

finger grass).

Strategies Applied to Achieve Objectives

Remove/control pest plant species by 2013

Plant native species 

Implement native hydroseeding and/or hydromulching project, if feasible, by 2014

Rationale

The dominant grass in Hawai‘i prior to nonnative grasses was probably pili. ‘Aki‘aki grass is salttolerant and can be grown adjacent to the beach and for roads that use nonpotable water, which

tends to have higher salinity in Hawai‘i (pers. comm. Chris Dacus). Hydroseeding can be 

significantly less expensive than hand planting. HDOT has provided grant funding for University 

of Hawai‘i Professor Joe DeFrank for native hydroseed experiments, currently underway at other 

locations on the Island. There is potential for a future collaboration opportunity at the Refuge. 

Restoration of native grassland plants within the fenced area of the Refuge will benefit ‘alae 

ke‘oke‘o that graze on grass adjacent to wetlands.

2.4.3 GOAL 3. 

Protect, restore, and manage forest habitat to provide a buffer from upper 

watershed impacts. 

Objective 3.1: Restore and maintain native dry forest habitat.

Restore and maintain up to 7 acres of native dry forest habitat with the following characteristics:

50 ft width of trees around ponds to protect from upper watershed impacts;

>40% native plants consistent with historic dry forest habitats; and

<60% pest plants and annual grasses.

Strategies Applied to Achieve Objectives

Maintain 50 ft buffer zone of kiawe trees around ponds until replacement with native plants is 

feasible

Use IPM techniques to control/eradicate pest plants in buffer zone

Develop/implement restoration program, to include outplanting of native species by 2016

Rationale 

Much of the Refuge is currently covered with pest trees and shrubs which provide a buffer from the 

upper watershed (e.g., slows down water and allows groundwater seepage, filters sediments and 

pollutants before entering the ponds). This area is dominated by dense stands of nonnative kiawe and 

haole koa trees. The seed dispersal from these nonnative pest species does have a negative impact on 

the wetland habitat. While native plants are desirable, the existing vegetation provides a buffer to 

shield endangered waterbird habitats from urban disturbances. Suspended 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-15

sediments in stream flows from the upper watershed primarily derive from urban development and 

settle in the Refuge wetlands. 

One of the most significant influences leading to the degradation and loss of native Hawaiian 

habitats has been the relentless influx of pest plants, many of these highly invasive. The Refuge 

plans to work with partners to gradually restore a viable natural native plant community through 

removal of pest plants and outplanting of native plants that were part of the historic vegetative 

community. 

2.4.4 GOAL 4. 

Gather scientific information in support of adaptive management decisions on 

the Refuge under Goals 1-3. 

Objective 4.1: Conduct inventory, monitoring, and research to document progress and 

evaluate management strategies to guide management decisions.

Conduct high-priority inventory and monitoring activities that evaluate resource management and 

public use activities to facilitate adaptive management. These surveys contribute to the 

enhancement, protection, use, preservation, and management of wildlife populations and their 

habitats on- and off-refuge. Specifically, they can be used to evaluate achievement of resource 

management objectives identified in this CCP. These surveys have the following attributes: 

Data collection techniques would have zero to minimal animal mortality or disturbance and 

zero to minimal habitat destruction;

Collect minimum number of samples (i.e., water, soils, vegetative litter, plants, 

macroinvertebrates, vertebrates) to meet statistical analysis requirements for identification 

and/or experimentation in order to minimize long-term or cumulative impacts;

Use proper cleaning of investigator equipment and clothing as well as quarantine methods, 

where necessary, to minimize the potential spread or introduction of pest species; and

Projects will adhere to scientifically defensible protocols for data collection, where 

available and applicable.

The following is a prioritized list of survey activities to support resource management decisions on the 

Refuge

Monitor water quantity (surface water and groundwater)

Identify the primary sources of sediment loads and solutions to minimize accumulation at lower 

elevations 

Identify the sources of water entering the Refuge and mechanisms to enhance water quantity

Inventory and monitor bird abundance with monthly census to obtain descriptive statistics of

counts and trends

Monitor breeding „alae ke„oke„o from December-March for reproductive success (incubation 

period is 25 days-requires on-site staff)

Monitor breeding ae„o from April-July for reproductive success (requires on-site staff)

Research potential for hydroseeding/mulching native grasses

Monitor vegetation response to IPM techniques

Monitor mongoose and rat abundance with tracking tunnel surveys at least every 60-90 days

Conduct studies to determine desirable native plant community based on local site conditions (e.g., 

soil type, elevation, groundwater table, and proximity to shore)
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

2-16 Chapter 2. Refuge Management Direction

Prioritized list of survey activities (continued)

Contract a comprehensive archaeological and cultural investigation for the Refuge and surrounding 

lands

Monitor human activities at the coastal park for potential effects that jeopardize the integrity of the 

coastal strand (e.g., erosion)

Monitor banded ae„o and „alae ke„oke„o

Monitor water quality (abiotic parameters: pH, temperature, salinity, conductivity, turbidity, 

dissolved O2)

Maintain and monitor weather station

Rationale

The Administration Act requires us to „„... monitor the status and trends of fish, wildlife, and 

plants in each refuge.‟‟ Surveys are used primarily to evaluate resource response to assess 

progress toward achieving Refuge management objectives derived from the Refuge System 

mission, refuge purpose(s), and maintenance of biological integrity, diversity, and environmental 

health. Determining resource status and evaluating progress toward achieving objectives is 

essential to implementing adaptive management on DOI lands as required by policy (522 DM 1). 

Specifically, results of surveys would be used to refine management strategies, where necessary, 

over time in order to achieve resource objectives. Surveys would provide the best available 

scientific information to promote transparent decisionmaking processes for resource management 

over time on Refuge lands. 

Inventory, monitoring, and research studies are essential to high-quality habitat and population 

management. Conducting censuses for endangered waterbirds and compiling data is critical to 

evaluate population status and measure progress towards goals. Similarly, other waterbird 

populations, habitat conditions and habitat management practices, including restoration efforts 

must be monitored to evaluate their status and effectiveness. Population trends can be used to 

evaluate habitat effectiveness and guide management actions.

Refuges must collect site-specific information and conduct defensible research to provide 

information for devising, guiding and adapting management practices. Monitoring habitat 

conditions provides valuable support and sound decisionmaking as applied to Refuge resource 

management and also contributes to the Service‟s ability to modify management practices 

(adaptive management). Applied research on the Refuge will help address management issues and 

questions, in theory, will result in improved management decisions on both the Refuge and on a 

regional basis. The Refuge has always maintained a close working relationship with several State 

and local agencies, and universities to advance the knowledge base of a variety of habitats and 

plant and wildlife species.

Kakahai„a NWR is bisected by Kamehameha V Highway resulting in a coastal area set apart from 

the wetlands. This area is not fenced and is accessible to the public. Use of this area includes: 

picnicking (currently two concrete picnic tables) and access to the ocean for kayaking and fishing. 

Human activities in the coastal area will be monitored to ensure the impacts are not detrimental to 

the habitat (e.g., erosion, vandalism).
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-17

Objective 4.2: Conduct scientific assessments.

Throughout the life of the CCP, conduct scientific assessments to provide baseline information to 

expand knowledge regarding the status of Refuge resources to better inform resource management 

decisions. These scientific assessments will 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.

Utilize accepted standards, where available, for completion of assessments; and

Scale and accuracy of assessments would appropriate for development and implementation 

of Refuge habitat and wildlife management actions.

Strategies Applied to Achieve Objectives

Coordinate with Regional Office staff to adjudicate water rights (surface and groundwater)

Complete a water resources assessment, to include natural springs

Evaluate SLAMM analyses (and other studies) for climate change planning

Conduct a full topographic survey for habitat restoration design

Analyze and evaluate sediment cores for profiling, soil composition, and characteristics

Collaborate with HDOT to evaluate, design, and reconstruct the Kamehameha V Hwy. culvert to 

prevent flooding and allow natural drainage from the upper watershed 

Initiate sampling of invertebrates (sieve) to assess species composition and density by 2016

Investigate the pros and cons of allowing high storm surges from the ocean to periodically 

inundate the wetland

Rationale

In accordance with a policy for implementing adaptive management on DOI 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 1-3. 

Kawela‟s upper watershed has undergone changes in land use over the decade with increased 

housing development. High volumes of suspended sediments in flood waters enter the north side 

of Kakahai„a NWR during winter months resulting in levee damage and sedimentation in the 

ponds. A comprehensive hydrological assessment at Kakahai„a NWR is needed to evaluate 

wetland needs. An evaluation of the groundwater source is essential since Old Pond receives its 

water from this source.

The culvert under Kamehameha V Highway that connects the upper watershed and pond drainages 

to the ocean is naturally plugged by sand due to its low elevation. This sand plug blocks the flow 

of water, resulting in flooding of the Refuge‟s road and the highway. During periods of heavy 

precipitation, the DOT removes the sand plug to allow drainage. Unless the highway and culvert 

is redesigned this flooding will continue to occur. In efforts to reach the objective of restoring Old 

and New Ponds for the benefit of endangered waterbirds and the need to control water levels, this 

issue will be a hindrance and needs to be addressed.
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

2-18 Chapter 2. Refuge Management Direction

2.4.5 GOAL 5. 

Provide high-quality wildlife-dependent recreation, interpretation, and 

outreach opportunities to enhance public understanding, appreciation, and 

enjoyment of the native wildlife, natural communities, and cultural history of 

the Kakahai‘a NWR. 

Objective 5.1: Provide opportunities for wildlife observation and photography.

Provide visitors with the opportunity for self-guided wildlife observation and photography to 

increase their knowledge and appreciation for wetland ecosystems and endangered species. 

Focus on wetland ecology and the endangered waterbirds that rely upon these wetlands;

Provide viewing opportunities from outside the fence when the Refuge is unstaffed; and

Directly link opportunities to EE and interpretation programs.

Strategies Applied to Achieve Objectives

Develop a Visitor Services Plan (VSP) by 2016

Install Kakahai„a NWR entrance sign 

Complete the Refuge brochure and bird species checklist

Replace two Refuge signs at the coastal property in collaboration with County of Maui (Kakahai„a 

Park)

Construct elevated platform (earthen) and kiosk along Refuge entrance road for wildlife viewing

Construct parking area along entrance road for kiosk 

Design interpretive panels for kiosk

Open Refuge to the public when staff is present

Evaluate the need, location, and logistics for photo blinds on/adjacent to the ponds. 

Rationale

Currently, Kakahai„a NWR is unstaffed and closed to the public. Refuge staff (1-2 people) make 

day trips from Maui every other week to perform habitat management activities. In past years, 

endangered Hawaiian waterbirds and migratory species were prevalent in the wetlands. Future 

public use is contingent on the level of habitat restoration that is completed because without the 

wetlands and presence of waterbirds, there is no viewing opportunity.

A step-down VSP is needed to evaluate the existing and potential public uses on the Refuge. As 

part of the VSP, a viewing area and interpretive panels will be incorporated into the Kakahai„a 

NWR entrance road design. During the nesting seasons for endangered „alae ke„oke‟o (DecemberMay) and ae„o (April-August), human activities at the viewing area will be evaluated to determine 

whether or not waterbirds are impacted, and if disturbance is observed, the area may need to be 

blocked from access. Opportunities for recreational wildlife photographers at Kakahai„a NWR will 

be authorized in the form of a SUP during the nonbreeding season only because staff may not be 

present to monitor impacts to waterbirds.

Staff oversight of the Refuge is from the headquarters located at Keālia Pond NWR on Maui. The 

addition of one employee (e.g., Maintenance Worker or Biologist) to work 90% of the time at 

Kakahai„a NWR with duties including habitat management, predator control, and working with 

volunteers would facilitate oversight of proposed increases in public use. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-19

Objective 5.2: Provide interpretation, outreach, and volunteer programs.

Expand the Refuge‟s interpretation and outreach programs to foster appreciation and stewardship 

for the wetland resources and reach a wider diverse audience. Participate in partnerships and other 

collaborative efforts that incorporate Refuge restoration into other ecosystem-based opportunities.

Strategies Applied to Achieve Objectives

Maintain agreement with the County of Maui to assist with management of the coastal park

Work cooperatively with the Sedimentation Partnership 

Participate in off-site community events including the annual Earth Day event on Moloka„i, beach

cleanups with Community Work Day Program, etc.

Support volunteerism through partnerships with The Nature Conservancy, AmeriCorps, and other 

community groups

Maintain and update the information on the Refuge website 

Work with Kokua Kakahai„a to engage new volunteers to promote and assist with the Refuge‟s 

purpose and vision

Work with partners in the East Moloka„i watershed to implement studies and monitoring projects 

Recruit and maintain a volunteer program to assist with habitat, biological, maintenance, visitor 

services, and EE programs

Install and maintain panels interpreting the wetlands, waterbirds, historical and cultural information

in the Kakahai„a viewing kiosk

Incorporate Refuge interpretive information into the Maui Visitors Bureau products

Provide public presentations and interpretive tours on wetland ecology and wildlife, coastal 

habitats, and cultural history

Rationale

Restoration of the Refuge to a viable healthy wetland with waterbird habitat is a prerequisite to 

public use and volunteer programs. Many local residents are unfamiliar with Kakahai„a NWR and 

do not know where the Refuge is located. The Refuge should be visible within the community to

help foster support for the Refuge. Moloka„i residents have a fairly strong volunteer ethic and they 

are willing to help out if they know what is available to them. 

The Refuge‟s support group, Kokua Kakahai‘a, is comprised of long-time residents with a 

common interest in the restoration of the wetlands. This group has provided critical support for the 

Refuge in the past and would be an asset to help achieve our goals in the future. The Refuge‟s 

volunteer opportunities need to be advertised, and we should continue to participate in community 

events. Interpretive panels at Kakahai„a will offer messages to viewers about the importance of 

wetlands and information about the wildlife that depend upon them.
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

2-20 Chapter 2. Refuge Management Direction

2.4.6 GOAL 6. 

Provide a quality environmental education program with specific learning 

objectives and diverse hands-on opportunities. 

Objective 6.1: Provide quality environmental education (EE).

Expand EE partnerships that connect children with nature and focus on the functions of wetlands 

and coastal ecosystems as part of watersheds. Quality curriculum includes:

Supports national and State Department of Education (DOE) Standards;

Provides interdisciplinary opportunities that link natural resources through all subject 

areas;

Incorporates the Refuge System mission and Refuge purpose;

Involves the local community, volunteers, friends group, and partners;

Involves hands-on learning opportunities and stewardship components;

Incorporates current conservation issues and concerns; and

Located both on- and off-Refuge.

Strategies Applied to Achieve Objectives

Evaluate and provide SUPs to agencies and nongovernmental organizations providing EE on the 

Refuge

Participate in partnerships to provide educational opportunities focusing on island ecosystems 

Participate in workshops to present teachers with the tools and resources available to them on natural 

resource topics

Develop site-specific materials and tools for educators‟ use

Provide formal learning experiences in support of teachers‟ curricula and DOE requirements

Rationale

Many opportunities exist for us to work together with educational partners to enhance Refuge programs 

and also provide coordination and assistance to other local programs, with respect to watersheds and 

ecosystems. School groups on Moloka„i do not have the same opportunities for diverse learning 

experiences as the other main Hawaiian Islands so teachers may welcome a chance to engage the 

students at the Refuge. Teachers may not have the time and resources to compile pre- and post-visit 

materials; therefore, the Refuge can provide packets geared for different age groups for teachers to 

incorporate the visit into their curriculum. Hands-on experiences and inclusion of career opportunities 

into presentations can help direct students into natural resource disciplines. 

Over the past 10 years, there have been inquiries from teachers interested in accessing Kakahai„a 

NWR, many of which were forwarded to our EE partners under a SUP. Currently, the primary 

environmental focus is on invasive species. The potential for the teachers and students to connect with 

nature at Kakahai„a NWR is a feasible goal once the wetlands are restored. The Complex has limited 

staffing and is only able to accommodate teachers‟ requests on a case-by-case basis. Partnerships with 

EE organizations have been an effective tool to promote the Refuge System mission with outside 

educators who have been thoroughly trained to instruct students. Refuge staff work with partners to 

ensure the information is appropriate and updated. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-21

Figure 2.1 –Habitat Management 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

2-22 Chapter 2. Refuge Management Direction

To preserve the quality of the map, this side was left blank intentionally. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 3. Physical Environment 3-1 

Chapter 3. Physical Environment

3.1 Refuge Introduction 

Kakahai„a NWR is located in East Moloka„i along the southeastern coast of the island, in the rain 

shadow of the mountains. The Refuge contains a 15-acre coastal freshwater marsh with a spring-fed 

pond on a narrow plain just above sea level at the foot of volcanic hills. An additional 5.5-acre 

managed impoundment was constructed in 1983 to provide shallow-water habitat for wading birds. 

Kamehameha V Highway bisects the southern ocean shoreline portion of the Refuge. 

3.2 Climate

The Island of Moloka„i is approximately 38 miles long and 10 miles wide and is oriented east to 

west. The island is mountainous in its eastern part, with a maximum elevation of 4,970 feet; however 

most of the island is less than 1,000 feet above sea level. There are three general regions: East 

Moloka„i, which includes Wailau (East Moloka„i volcano), the highest point on the island; the 

Hoolehua Plain; and West Moloka„i, which includes the much smaller Maunaloa (West Moloka„i

volcano). The topography and orientation of the island have a profound influence on climate. The 

Kakahai‘a overview USFWS
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

3-2 Chapter 3. Physical Environment 

northeastern side of the island is exposed to prevailing trade winds and is very wet and forested. 

There is a rain shadow effect from the mountain range, creating arid conditions elsewhere. 

Native Hawaiians recognized only two 6-month seasons: a warm season with drier weather and more 

reliable trade winds and a cooler wetter season with more storms and fewer trade winds. Modern 

analysis of climate records indicates the soundness of the Hawaiian system of seasons. The wet 

season is now considered to extend seven months from October-April and the dry season from MaySeptember. During the wet season, there may be two, three, or as many as seven major storm events 

a year. Such storms typically bring heavy rains and are often accompanied by strong Kona winds that 

blow from the south. Rainfall is rare during the May-September dry season, which is typically warm 

and windy. 

Maximum mean annual rainfall is more than 150 in/yr near the summit of Wailau in the northeastern 

part of the island (Giambelluca et al. 1986). Over Maunaloa, maximum mean annual rainfall is about 

25 in/yr. Mean annual rainfall is less than 16 in/yr along the coastal areas of the southern and western 

parts of the island. There is no weather data available for the Refuge itself. The only local weather 

station with a fairly complete record is the Moloka„i Airport COOP station, located in the center of 

the island in the Hoolehua Plain area. Annual precipitation for 1958-2009 averaged about 26 in/yr 

but has varied greatly from 11-43 in/yr (Figure 3.1). Gaps represent years with missing data. 

Figure 3.1. Annual cycle of average monthly precipitation (top) and total annual precipitation with 5-year 

moving average (bottom) at Moloka‘i Airport, HI 1958-2009. 

Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep

Precipitation (in)

0

1

2

3

4

1950 1960 1970 1980 1990 2000 2010 2020

0

10

20

30

40

50
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 3. Physical Environment 3-3 

Figure 3.2. Annual cycle of average monthly temperature (top) and average annual temperature with 5-year 

moving average (bottom) at Moloka‘i Airport, HI 1958-2009. 

Average monthly temperatures for 1958-2009 (Figure 3.2) were fairly constant throughout each 

month of the year at 75 degrees F. Maximum monthly temperatures occured July-September and 

average 77-79 degrees F and minimum monthly temperatures occured January-March and average 

70-72 degrees F. 

Both short-term interannual climate variability and long-term decadal variability affect water 

resources and streamflows on Moloka„i. Many of the droughts in Hawai„i are related to El Niño 

events, which are associated with drier than normal winters (Oki 2004). The Pacific Decadal 

Oscillation (PDO) also influences Hawaiian climate. The pattern of ocean-atmosphere variability 

associated with El Niño-Southern Oscillation phenomenon occurs on a relatively short time scale of 

one to several years while the PDO is a longer term phenomenon occurring over one to several 

decades. Rainfall and streamflow tends to be low in winter during El Niño periods and high during 

La Niña periods, especially during positive (warm) phases of the PDO. Temperature may be affected 

by PDO phases, too. 

3.2.1 Global Climate Change

The future climate change impacts expected for Hawai„i are warmer temperatures (air and ocean), 

more severe droughts and floods, and a rise in sea levels (Mimura et al. 2007). More recent 

observations and re-analyses of temperatures averaged over land and ocean surfaces show consistent 

warming trends in all small-island regions over the 1901-2004 period (Mimura et al. 2007). 

Giambelluca et al. (2008) reported that air temperatures at 21 weather stations in Hawai„i have 

increased at a rate of 0.3 degrees F/decade since 1975, which is comparable to the rate of increase in 

global temperatures. Rainfall intensity has reportedly increased 12 percent in Hawai„i between 1958-

2006 (Fletcher 2010) but total rainfall has decreased about 15 percent over the last 20 years (Chu 

1950 1960 1970 1980 1990 2000 2010

72

73

74

75

76

77

Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep

Temperature (F)

65

70

75

80

85
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

3-4 Chapter 3. Physical Environment 

and Chen, 2005). These changes have and will continue to affect biologic and water resources on 

Moloka„i and the other islands (Oki 2004). 

The low resolution of many global circulation models is problematic for representing Hawai„i which 

is strongly influenced by steep topography, aspect, and location. This information is not included in 

global climate models. Typically, the models represent the islands as a single grid cell or ignore the 

islands completely. Higher resolution regional climate models project increasing temperature and 

precipitation for the islands in the future, with an increase in extreme events such as floods and 

droughts. Temperatures for the North Pacific region are forecast to increase 0.9-1.1 degrees F from 

2010-2039 relative to the 1961-1990 period (Mimura et al. 2007). 

Precipitation is forecast to change by -6.3 to +9.1 percent for the same region relative to the same 

period. Timm and Diaz (2009) were the first authors to evaluate global climate model performance 

for Hawai„i and downscale climate scenarios for Hawaiian rainfall. Based on statistical downscaling 

of climate model output, they concluded that the most likely scenario is a 5-10 percent reduction of 

wet-season precipitation and a 5 percent increase during the dry season, as a result of changes in the 

wind field. Future changes in precipitation are less certain because they depend on how El Niño 

might change which is unknown. Warmer air temperatures will increase water use and demand 

(evaporation and consumptive use), which will exacerbate water supply concerns and environmental 

stresses. A number of studies suggest that climate change could be a major factor in accentuating the 

current climate regimes and the changes that come with ENSO events (Mimura et al. 2007). 

The Service is supporting the development of regional Landscape Conservation Cooperatives (LCC) 

that will integrate local climate models with models of climate-change responses by species, habitats, 

and ecosystems. The regional version of these 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 non-governmental conservation organizations and academic 

institutions, forming a cooperative partnership. 

3.2.2 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 

composition and interaction; and ecosystem structure and dynamics. The reproductive physiology 

and population dynamics of amphibians and reptiles are highly influenced by environmental 

conditions such as temperature and humidity. For example, 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 and waterbirds (Duffy 1993, Walther et al. 2002, Baker et al. 2006). 

Changes in ocean temperature, circulation, and storm surge due to climate change will impact seabird 

breeding and foraging. The ENSO has been shown to cause seabirds to abandon habitats, nest sites, 

and foraging areas for colder/warmer waters. Studies have found that nesting success is reduced for 

some species during this climatic event. Oceanographic changes associated with ENSO may also 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 3. Physical Environment 3-5 

increase or decrease food supply for seabirds and subsequently impact populations that forage 

offshore. Shifts in marine temperature, salinity, turbidity, currents, depth, and nutrients will have an 

impact on seabird and water bird prey composition and availability. Although these potential changes 

may impact seabirds throughout the Hawaiian Islands, contrary evidence suggests that seabirds may 

have coped with and evolved around climatic changes in the past (Duffy 1993). 

Warming has also caused species to shift toward the poles or higher altitudes and changes in climatic 

conditions can alter community composition. For example, increases in nitrogen availability can 

favor those plant species that respond to nitrogen rises. Similarly, increases in CO2 levels can impact 

plant photosynthetic rates, decrease nutrient levels, and lower herbivore weights. 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). 

Climate change has the potential to influence two important ecological issues in the State of Hawai„i: 

endangered species and pest species. The majority of U.S. endangered species are found in the State 

of Hawai„i. Species declines have resulted from habitat loss, introduced diseases, and impacts from 

pest species. Changes in climate will add an additional threat to the survival of these species. For 

example, warmer night temperatures can increase the rate of respiration for native vegetation, 

resulting in greater competition from pest plants. Furthermore, climate change may enhance existing 

pest species issues because alterations in the environment may increase the dispersal ability of flora 

or fauna. Species response to climate change will depend on the life history, distribution, dispersal 

ability, and reproduction requirements of the species (DBEDT and DOH 1998, Middleton 2006, 

Giambelluca 2008). 

3.3 Geology and Soils

The Hawaiian Islands were created by a geologic hot spot underneath the surface of the earth. As the 

earth‟s crust has moved over this spot, magma has created new islands in the form of volcanoes. 

Iron-rich, quartz-poor rock flowed out of thousands of vents as highly fluid lava. The Island of 

Moloka„i is the fifth largest of the Hawaiian Islands. The island was formed by volcanic activity at 

Wailau (elev. 4970 ft) and Maunaloa (elev. 1430 ft). The two volcanoes are connected by the 

Hoolehua Plain, created by lava flows from Wailau. Most of the island‟s population and development 

occurs in this area and along the south shore of the island. No perennial streams exist in the Hoolehua 

Plain, water is supplied from diverted streamflow from East Moloka„i and from groundwater 

development. 

The exposed rocks of East Moloka„i are classified as East Moloka„i volcanics and Kalaupapa 

volcanics. Kaunakakai Stream flows over the East Moloka„i volcanics, which is divided into two 

informal members—a lower member consisting of shield-stage tholeiitic, olivine-tholeiitic, and 

picritic-tholeiitic basalts and postshield-stage alkalic basalt; and an upper member consisting of 

postshield-stage mugearite and lesser amounts of hawaiite and trachyte (Langenheim and Clague 

1987). The upper member forms a relatively thin (50-500ft thick) veneer over the lower member 

(Stearns and Macdonald 1947). The northeastern part of Wailau contains numerous intrusive 

volcanic dikes, which form a dike complex and reduce bulk permeability of the rocks in the area. The 

volcanic rocks of West Moloka„i are separated from the East Moloka„i volcanics by an erosional 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

3-6 Chapter 3. Physical Environment 

surface that forms a hydrologic confining unit over the West Moloka„i volcanics (Langenheim and 

Clague 1987). 

3.4 Hydrology

Precipitation is the source of all freshwater on Moloka„i. The windward (northeast) side is wettest, 

due to the orographic lifting of moisture-laden northeasterly trade winds along the windward slope of 

Wailau. Maunaloa is considerably drier because it does not extend upward into the cloud-forming 

zone at higher altitudes. Most of the fresh groundwater on the island is in East Moloka„i because of 

the higher precipitation in this area. Groundwater levels are highest in the mountainous interior parts 

of the island, particularly in the northeast, and lowest near the coast. Freshwater floats on top of 

saltwater near sea level within the more permeable lava flows on the flanks of the volcanoes (Shade 

1997). 

The State Commission on Water Resource Management (CWRM) designated the Island of Moloka„i 

as a Groundwater Management Area in 1992. With this designation, the State was authorized to 

protect the groundwater resources of Moloka'i by managing groundwater withdrawals from the 

aquifer through a permitting process. Most of the groundwater withdrawn on Moloka„i is from 

Kualapu„u in the southeast coastal area and the dike complex in the northeastern part of the island

(Oki 2007). Several existing production wells have experienced rising salinity as a result of the 

declining water levels and a rising brackish-water transition zone caused by the cumulative effect of 

withdrawals. Any new groundwater development must be approved by the CWRM, and the State 

manages groundwater withdrawals from the aquifer through a permitting process. There are several 

existing groundwater wells in the vicinity of Kakahai„a NWR (Oki 2007).

Stearns and Macdonald (1974) indicated that several streams on the southern slope of Wailau are 

perennial in their upper reaches but do not flow continuously to the coast because of seepage loss and 

evaporation. These streams are generally perennial where they flow over lavas of the upper member 

of the East Moloka„i Volcanics and where water discharges from springs or drains swamps. Where 

streams flow over the more permeable lower member, surface water is more readily lost to 

infiltration. 

Kakahai„a NWR is in the driest part of the island and is underlain by the Kawela groundwater aquifer 

(Shade 1997). The Refuge consists of two wetlands: Old Pond is a natural wetland and New Pond is 

a constructed wetland. For some years, New Pond was supplied with water by a pump from Old 

Pond. However, thick vegetation growth in Old Pond began to impede the movement of water, 

drying out the area around the supply pump, so this was discontinued. For most of the year, New 

Pond is now dry. 

Old Pond depends on groundwater in the form of natural spring discharge for its water supply. 

Occasional runoff from the surrounding hills is secondary source of water. Spring discharge into the 

pond is diffuse and cannot be measured directly but we have regularly recorded groundwater levels 

in three piezometers on the Refuge since 2002. This is an indirect measurement of hydrologic 

conditions and spring discharge at the Refuge. The record of measurements is shown below (Figure 

3.3). Gaps represent years with missing data. The less frequent measurements in P2 shown in recent 

years are because that piezometer has been dry more frequently recently. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 3. Physical Environment 3-7 

The record shows seasonal and annual variability but little long-term change in water levels. 

However, there has been an increasing frequency of “dry” measurements in one of the piezometers, 

P2, in recent years. These water level measurements are useful in terms of detecting changes and 

impacts to Refuge hydrology. 

Figure 3.3 Old Pond water levels and groundwater levels, 2000-2010.

The closest streamflow gage is the USGS gage at Kawela Gulch (Site No. 16415600), located about 

1,500 feet west of the Refuge at the mouth of Kawela Stream. The site elevation is 40 feet above sea 

level, the drainage area above the gage is 5.3 square miles, and the period of record is 2004-present. 

The stream has been dry 60 percent of the time, based on daily flow records. The monthly flows are 

shown in Table 3.1. Flow is greater during the winter months in response to greater rainfall. 

Another USGS streamflow gage close to the Refuge is at Kaunakakai Gulch (Site No. 16414200), 

located about 6 miles west of the Refuge and just north of the town of Kaunakakai at an elevation of 

75 feet. Hydrologic conditions at this site are likely very similar to the Refuge, although the area is 

underlain by a different aquifer system (Shade 1997). The period of record for this site is from 2003 

to the present (Figure 3.2). Streamflow is sporadic and seasonal and most common during the wetter 

winter months in response to rainfall. The stream was estimated to be dry 91 percent of the time 

during water years 2004-2006 (Oki 2007). No known diversions exist upstream from the gauging 

station. Oki (2007) reports that the stream becomes perennial further downstream near the coast, 

where it is hydraulically connected to the groundwater system. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

3-8 Chapter 3. Physical Environment 

Table 3.1. Monthly streamflow data for Kawela Gulch(USGS Site No. 16415600), located just west of 

Kakahai'a NWR. . 

YEAR

Monthly mean in cfs (Calculation Period: 2004- 2009)

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

2004 0.12 2.94 3.6

2005 12.7 1.82 6.85 3.67 0.36 0.53 1.52 0.03 2.59 3.71 4.01 0

2006 2.69 3.16 11 10.6 2.66 0 0.83 0.1 0 1.77 7.37 1.4

2007 1.99 1.38 4.95 1.73 0.13 0.25 3.79 0.93 0.2

2008 0.13 1.76 7.6

2009 4.31 2.48 2.29 0.22 0 0.6 0.08 2.07 0.01

Mean of

5.4 2.2 6.3 4.1 0.79 0.34 1.6 0.78 0.7 1.4 4 3.1

Monthly

Discharge

Blank boxes indicate missing data due to malfunctioning equipment. 

Table 3.2 Monthly streamflow data for Kaunakakai Gulch (USGS Site No. 16414200).. 

YEAR

Monthly mean in cfs (Calculation Period: 2003- 2009)

Calculation period restricted by USGS staff due to special conditions at/near site

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

2003 0.392 0 0 0 1.54 2.61

2004 12.3 1.7 8.3 3.4 0.9 0.0 0.0 0.0 0.0 0.0 1.1 0.6

2005 6.2 0.1 4.4 0.4 0.0 0.0 0.0 0.0 0.0 0.4 0.0 0.0

2006 0.0 0.4 0.4 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.2 0.0

2007 0.0 0.0 1.1 0.0 0.0 0.0 0.0 0.0 0.0 0.6 0.4 13.3

2008 1.7 1.8 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.8 1.6

2009 0.5 0.3 0.3 0.0 0.0 0.0 0.0 0.4 0.0

Mean of

3.5 0.72 2.1 0.63 0.16 0 0.01 0.06 0 0.17 0.83 3

Monthly

Discharge

Near the coast in this area, the main groundwater-flow system consists of a freshwater lens system 

(Gingerich and Oki 2000) within dike-free rocks. In general, a freshwater-lens system includes a 

lens-shaped freshwater body, an intermediate transition zone of brackish water, and underlying salt 

water. In the Kaunakakai Stream area, the freshwater-lens system exists in the volcanic rocks and 

sedimentary deposits near the coast. Alluvium overlies the volcanic rocks near the mouth of 

Kaunakakai Stream, where groundwater levels probably range from near sea level to about 2 feet 

above mean sea level. Both groundwater levels and stream stage are expected to be affected by ocean 

tides and longer-term variations in sea level. On the basis of water quality information from nearby 

wells, the salinity of groundwater near the mouth of Kaunakakai Stream is likely brackish because of 

mixing with saltwater from the ocean. Hydrologic conditions at Kakahai„a NWR are likely very 

similar to this location. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 3. Physical Environment 3-9 

The only long-term streamflow gage on the Island of Moloka„i is at Halawa Stream, located on the 

northeastern tip of the island at an elevation of 210 feet above sea level. The drainage area above the 

stream is 4.62 square miles and the period of record is 1918- present. It is useful to look at the annual 

flows for any long-term trends or changes, since this gage reflects the response to climate rather than 

anthropogenic activities (Figure 3.4). The streamflow data confirms the drying trend since 1990 that 

can be observed in the precipitation data from the airport. The 1970s were also quite dry, according 

to the streamflow data. Precipitation data from these years was missing at the airport. Oki (2004) 

reported a statistically significant decrease in annual median flow and annual baseflow for this site 

for the period of record. 

Figure 3.4 Annual stream discharge at USGS streamflow gage Halawa Stream, 1918-2009. The line is a 5-

year centered moving average. 

Mass erosion caused by large goat populations in the uplands allow for flash flooding to occur on the 

Refuge during heavy rains. Poor drainage due to residential retaining walls and recurring blockages 

along the Kawela Stream and bridge has compounded the problem.

3.5 Topography/Bathymetry 

We have no data on the current bathymetry of the ponds. The upper watershed has undergone 

changes in land use over the decade resulting in flood waters with a high volume of suspended 

sediments that enter the north side of the Refuge during winter months. Surface water drainage from 

the Kawela watershed is not a major factor in water levels in Old and New Ponds because the ponds 

are disconnected from surface flows; however, large amounts of water flow into other areas of the 

Refuge and have damaged the levees. We have identified the need for a comprehensive hydrological 

assessment to evaluate wetland needs in relation to upper watershed land-use changes. An evaluation 

of the groundwater source is essential as Old Pond receives its water from this source. 

Water Year Mean Discharge

USGS 16400000 Halawa Stream near Halawa, Molokai, HI

0

5

10

15

20

25

30

35

40

45

50

1900 1910 1920 1930 1940 1950 1960 1970 1980 1990 2000 2010

Water Year

Discharge (cfs)
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

3-10 Chapter 3. Physical Environment 

3.6 Environmental Contaminants

The Maui Department of Water Supply (DWS) conducts annual testing of groundwater wells in the 

Kawela watershed. The most recent report is a review of testing conducted and compiled in 2009 for 

reporting in July 2010. The DWS tested for more than 100 substances in the water, including 

bacteria, pesticides and herbicides, asbestos, lead, copper, and petroleum products. The only 

measurable contaminant found was nitrate (as N) with the highest detection level of 0.31 ppm, well 

below the EPA allowable limit of 10.0 ppm. The typical source of this trace contaminant is from 

erosion of natural deposits. In summary, no sources of environmental contamination have been 

detected or are suspected of adversely affecting the Refuge (DWS 2010). 

3.7 Land Use

Immediately above and adjacent to Kakahai„a NWR is the residential development of Kawela 

Plantations, which spans 6000 acres of former Moloka„i Ranch agricultural land with 210 1-acre 

residential/agricultural lots. Kamehameha V Highway bisects the wetland area from the makai 

(ocean-side) section of the Refuge. This shoreline area is operated as Kakahai„a Park through a 

cooperative agreement with Maui County. Located just 5.5 miles east of the main city of 

Kaunakakai, the park is used primarily for picnicking and shoreline fishing. 

3.7.1 Previous Land Uses 

Moloka„i was first settled 450-650 CE. As agriculture developed, the landscape began to transform 

and has undergone alterations throughout its history of human settlement. Polynesian voyagers 

stocked their canoes with pigs, chickens, and dogs as well as crops needed for colonization. The 

native lowland forests were cleared and replaced with taro, sweet potato, yam, banana, sugarcane, 

breadfruit, and coconut. The land was modified with advanced farming practices that included 

irrigation from streams, terracing, mulching, and use of green manure. Slash and burn techniques 

were used to clear land for crops and to encourage the growth of pili grass used in house thatching 

(Roberts 2000, Ross 2011). 

Significant sections of the coastline were modified between 1000-1400 CE with the creation of over 

50 coastal fishponds ranging in size from a few acres to several hundreds of acres across and 1-30 

feet deep. Native Hawaiians used lava boulders and coral to build the semi-circular walls of the 

ponds which would keep the fish inside while allowing the sea water to ebb in and out. The fish from 

these ponds were only eaten by the ali„i (chiefs and royalty). Both down-slope and along-shore 

sediment transport patterns were altered. Many of these fishponds formed catchment basins for 

sediments coming off the expanded terraces and agricultural lands (Roberts 2000, Hawaiianweb 

2006). 

Prior to the fishpond construction, it is likely that the marsh was located closer to the springs along 

the present inland margin of the pond. The fishpond was created by removing vegetation, excavating 

the pond, and using the mud to form an earthen berm. A rock wall was constructed in areas where 

the earthen berm was not a sufficient barrier (Weisler 1983). A ditch was built between the pond and 

the sea in order to permit the flow of seawater and young fish. This flow was regulated by a gate, or 
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Chapter 3. Physical Environment 3-11

makaha (Summers 1964). Small fry were introduced to the pond including awa (milkfish), „ama„ama 

(mullet), aholehole, and „o„opu (gobies). Similar to other Hawaiian fishponds, the perimeter may 

have been planted with taro, sweet potato, sugarcane, or ti (Weisler 1983). 

The thin sandy strip of land separating the pond from the sea suggests that the area was formerly a 

bay open to the sea (Estioko-Griffin 1987). Numerous rounded basalt boulders located along the 

strip of land, which are facilitating beach erosion, resemble boulders found in the Kawela Gulch 

stream course. Weisler (1983) suggests that due to the historic and current location of Kawela 

Stream, these boulders were intentionally brought from the gulch to construct a seaward boundary for 

the pond. Thus, Kakahai„a may have initially been a loko kuapa, a fishpond composed of a 

continuous stone wall connecting two protruding points along the shoreline, which has subsequently 

been buried due to sand accretion (Weisler 1983). 

The arrival of Europeans in the 1770s brought the the introduction of goats, horses, cattle, and sheep. 

Ellis (1827) was the first to provide a written description of the island and estimated the population 

not to exceed 3,000. In 1828, Reverends Green and Andrews, while on a tour of Moloka„i, estimated 

that the population was 5,000 and that there were 1,000 houses, although only 700 houses were 

actually counted (Missionary Herald 1829). 

The Kawela ahupua„a became part of King Kamehameha V‟s ranch in the 1850s and was used as 

grazing land for cattle. The Duke of Edinburgh had deer transported from Japan to Moloka„i as a gift 

to Kamehameha V in 1870. The growing herds quickly increased and endemic plants quickly 

declined, leaving vast areas barren due to soil compaction that increased runoff and accelerated 

erosion (Roberts 2000). 

The Hawaiian Sugar Planters‟ Association leased the Kawela lands in 1928, constructed a quarantine 

station for imported experimental varieties of sugarcane, and planted cane on the alluvial flats which 

was immediately flooded by heavy rains. To mitigate future flooding, the Planters‟ relocated the 

stream to its present location by dozing boulders and river rocks in a straight line to the ocean. In 

1935, the sugarcane fields were tilled-under and planted in mango trees, which remain today. 

Weisler and Kirch (1982) estimated that since 1880, the Kawela shoreline increased by 1 foot per 

year. Although some farmers remained on ancestral land east and west of Kawela Stream, upland 

residences gave way to Western-style habitation along the coast. In 1901, Kakahai„a Pond was used 

to produce rice and several residences were established along the pond edges to facilitate cultivation 

(Weisler 1983, Shallenberger 1977). During this time, the pond was much larger, with surface water 

areas estimated at 31 acres. A 1940, USGS aerial (page 3-12) shows much of the pond in rice 

production, which continued until 1950, at which time the Yuen family leased the pond from the 

McCorriston Trust and excavated the area to cultivate catfish and seabass. The surrounding area was 

used to raise pigs and produce kiawe charcoal until 1975. Five years later, the Kawela Plantation 

Development began construction on the upland ridges above the pond, further increasing siltation to 

the pond. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

3-12 Chapter 3. Physical Environment 

Kakahai‘a aerial view, 1975 Air Survey Hawai‘i

Kakahai‘a aerial view, 1940 USGS
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan

Chapter 4 Refuge Biology and Habitat 4-1 

Chapter 4. Refuge Biology and Habitat 

4.1 Biological Integrity Analysis

Kakahai‘a NWR is located within the Kawela watershed. The drainage basin has changed 

considerably due to agricultural activities. Cattle, deer, and goats have denuded much of Kawela and 

accelerated soil erosion along the lower elevations. Old Pond was once an inland freshwater fish 

pond and New Pond was created in 1983 to provide shallow water habitat for ae‘o. Adjacent lands 

include both agricultural and residential properties. 

Little is known about the historic pristine coastal wetland vegetation due to its conversion by early 

Hawaiians into fishponds and irrigated farmlands. A small number of native plants still occur at the 

Refuge, but their distribution before introduction of nonnative species is difficult to reconstruct. 

Recent vegetation changes followed the creation of New Pond. Although wetland plant species 

initially thrived in the 1980s and 1990s, these plants died out as the pond lost water. Due to its 

dewatered condition since the early 2000s, the New Pond acreage is now dominated by dry upland 

pest species. The remaining vegetated wetlands of Old Pond are dominated by California bulrush 

with small stands of kaluha (alkali bulrush) and patches of ‘ākulikuli (sea purslane). The latter two 

species and kīpūkai (seaside heliotrope) are the only common native plants on the Refuge. 

4.2 Conservation Target Selection and Analysis

Endangered Hawaiian waterbirds, migratory birds, and their associated wetland habitat are the 

conservation targets of this plan (Table 4.1). They are consistent with the purpose of the Refuge, the 

Hawaiian waterbird recovery plan and the shorebird conservation plan. The objectives as described 

in Chapter 2 were developed based on desired outcomes, biological and abiotic factors as well as 

feasibility to meet those objectives (USFWS 2005, Engilis and Naughton 2004). 

Table 4.1. Conservation targets for the CCP. 

System targets Benefiting Resources

Wetland habitat All wetland habitat species 

Grassland habitat Native plants and birds that graze on grasses

Dry forest habitat Native plants

Coastal strand habitat Migratory shorebirds and native plants

Species Group Targets Benefiting Resources

Endangered Hawaiian Waterbirds All listed waterbird species

Migratory birds All migratory waterfowl and shorebirds
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4-2 Chapter 4. Refuge Biology and Habitat 

Kiawe has spread across dried-out New Pond USFWS

4.3 Wetland Habitat

Palustrine wetlands (non-tidal and dominated by trees, shrubs, and emergent vegetation) cover 20.5 

acres at Kakahai‘a NWR as delineated by the National Wetlands Inventory program (Cowardin et al. 

1979). A spring provides water for Old Pond, which is dominated by California bulrush with small 

stands of great bulrush. When the Refuge was acquired in 1976, Old Pond had 15 acres of open 

water. By 1991, open water was reduced to 4 acres and by 2010 it had diminished to less than an 

acre. 

Water pumped from Old Pond was the primary water source for New Pond, created in 1983 to 

provide shallow water habitat. The wetland was heavily impacted by residential development and 

overgrazing higher in the watershed. Associated water withdrawals from the aquifer and soil erosion 

amplified sediment buildup in Old Pond which reduced our ability to pump water. Old Pond 

vegetation could not be controlled without heavy equipment. By 1997, New Pond was overgrown 

with vegetation. In 1999, an attempt was made to clear the dikes and margins, but vegetation quickly 

returned. In 2000, the intake area began to dry out after just a few hours of pumping. By 2002, the 

intake area dried out completely except after periods of heavy rainfall. 

As a result, New Pond remains dry for most of the 

year. Nearly all of the vegetation is comprised of 

pest species (Indian marsh fleabane, kiawe, swollen 

finger grass, and Australian saltbush). Kīpūkai is 

the only native species currently present. In the past, 

the Refuge provided year-round habitat for the 

endangered ‘alae ke‘oke‘o and ae‘o. A few 

migratory waterfowl and shorebirds also used the 

wetland. Currently, waterbirds occur only when 

heavy rainstorms replenish New Pond. ‘Ama‘ama 

(mullet), Oreochromis, Poecilia, and mosquitofish 

are found in Old Pond. 

4.4 Grassland Habitat

Over 90 percent of this ecoregion in Hawai‘i has 

been lost due to human development and pest 

vegetation. The dominant grass in Hawai‘i prior to 

nonnative grasses was probably pili. ‘Aki‘aki is 

another native grass that is salt-tolerant and can be 

grown adjacent to the coastline. Restoration of 

native grassland plants such as these within the 

fenced area of the Refuge will benefit native birds 

that graze on grass. 

Grassland adjacent to entry road Mike Nishimoto/USFWS
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Chapter 4 Refuge Biology and Habitat 4-3 

Figure 4.1. Land Cover Types. 
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4-4 Chapter 4. Refuge Biology and Habitat 

This page left blank to preserve the integrity of our map. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan

Chapter 4 Refuge Biology and Habitat 4-5 

4.5 Coastal Dry Forest

Dry forest covers 22.1 acres along the upland areas 

of the Refuge, mostly occurring to the north and east 

of the wetlands. Trees are 30-40 feet tall. The forest 

is species poor with most plants introduced since the 

19th century. This habitat is dominated by nonnative 

kiawe and monkey pod with an understory of Indian 

marsh fleabane. The inland kiawe subtype occurs 

especially in dry areas on all of the main Hawaiian 

Islands usually below the 1,000 foot elevation. 

Much of this habitat had been cleared in 1999, but 

70 percent has since grown back. A portion of the 

area north of New Pond is relatively open and typically with scattered trees about 10-15 feet tall. 

Floods that result in pools of standing water may kill upland vegetation that reduces water velocity 

allowing sediments and vegetative debris to settle out. 

A variety of nonnative birds inhabit the dry coastal forest. Gray francolins commonly occur at the 

forest edge while passerines such as the white-rumped shama, northern cardinal, red-crested cardinal, 

and house finch are found in amongst the kiawe trees. Terrestrial pest mammals commonly observed 

include house mouse, Norway rat, black rat, dog, mongoose, cat, and axis deer.

4.6 Coastal Beach Strand

Coastal beach strand covers 2.0 acres of the Refuge on the south side of Kamehameha V Highway. 

This habitat is dominated by nonnative grasses, coconut trees, and kiawe. Indian fleabane and milo 

also occur in this habitat. The entire shoreline has been affected by beach erosion with the west side 

more severely impacted. Few migratory birds inhabit the coastal strand. The beach does provide 

some foraging habitat for hunakai (sanderling), while the grassy area is used by kōlea (Pacific 

golden-plovers) and ‘akekeke (ruddy turnstone). 

Pest mammals present in this habitat include house 

mice, Norway rats, black rats, dogs, small Indian 

mongooses, and cats. Shoreline erosion that converts 

uplands to submerged lands with the associated 

sedimentation of adjacent reefs is a recognized 

threat to the coastal beach strand. 

Kiawe dominates the forest USFWS

Kakahai‘a coastal beach strand USFWS
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4-6 Chapter 4. Refuge Biology and Habitat 

4.7 Endangered Hawaiian Waterbirds

Kakahai‘a NWR was established to provide protected habitat for two of Hawai‘i’s endangered 

waterbirds, the ae‘o and ‘alae ke‘oke‘o. Statewide, the primary causes of their population decline 

include loss of wetland habitat, predation by introduced animals, altered hydrology, habitat alteration 

by pest plants, and disease. In addition, environmental contaminants may also potentially threaten 

populations in certain areas. No critical habitat has been designated for any of Hawai‘i’s endangered 

waterbirds. 

4.7.1 Ae‘o (Himantopus mexicanus knudseni) or 

Hawaiian Stilt 

The ae‘o is an endangered subspecies endemic to the Hawaiian 

Islands, which is part of a superspecies complex of stilts found in 

various parts of the world. The State population of this nonmigratory shorebird fluctuates between 1,200-1,500 birds with a 5-

year average of 1,350 birds. Refuge counts of up to 40 birds were 

observed in the early 1990s at New Pond. These counts were down 

to 20 in the late 1990s and now a few ae‘o are seen around the 

Refuge only after heavy rains (FWS 2005, Robinson et al. 1999). 

Ae‘o favor open wetland habitats with minimal vegetative cover 

and water depths less than 9.4 inches, as well as tidal mudflats. Due 

to the deeper water, they did not use Old Pond. Ae‘o nest AprilAugust with nesting sites consisting of simple scrapes on low relief 

islands within or adjacent to ponds. They tend to be opportunistic 

users of ephemeral wetlands to exploit seasonal abundance of food, feeding on small fish, crabs, 

polychaete worms, and insects. Ongoing threats to foraging and breeding birds on Refuge lands 

include predation by owls, mongooses, cats, rats, dogs, ‘auku‘u (black-crowned night-heron), cattle 

egrets, common mynas, ‘akekeke, and laughing gulls (Robinson et al. 1999, Rauzon and Drigot 

2002). 

4.7.2 ‘Alae ke‘oke‘o (Fulica alai) or Hawaiian Coot 

The ‘alae ke‘oke‘o is an endangered species 

endemic to all the main Hawaiian Islands except 

Kaho‘olawe. The State population has fluctuated 

between 2,000-4,000 birds. Nesting occurred 

around Old Pond in the late-1970s through the 

1980s when there was open-water habitat. New 

Pond provided nesting and feeding habitat for a 

small number in the late 1990s with counts up to 50 

birds. Only 2 ‘alae ke‘oke‘o are currently 

occasionally present at the Refuge (Brisbin et al 

2002, USFWS 2005). 

Ae‘o pair © Brian Barker

‘Alae ke‘oke‘o Laura Beauregard/USFWS
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Chapter 4 Refuge Biology and Habitat 4-7 

‘Alae ke‘oke‘o are usually found on island coastal plains and prefer freshwater ponds or wetlands, 

brackish wetlands, and manmade impoundments. They prefer open water that is less than 12 inches 

deep for foraging and nesting habitat that has open water with emergent aquatic vegetation or heavy 

stands of grass. ‘Alae ke‘oke‘o feed on seeds and leaves of aquatic and terrestrial plants, freshwater 

snails, crustaceans, tadpoles of marine toads, small fish, and aquatic and terrestrial insects (Schwartz 

and Schwartz 1949, Brisbin et al. 2002). 

Nesting occurred November-April during the late 1990s, with opportunistic nesting occurring yearround depending on rainfall. ‘Alae ke‘oke‘o will construct floating nests of aquatic vegetation, semifloating nests attached to emergent vegetation, or in clumps of wetland vegetation. Cats, dogs, and 

mongooses are the main predators of ‘alae ke‘oke‘o. Other predators include ‘auku‘u, cattle egrets, 

and large fish. ‘Alae ke‘oke‘o are also susceptible to avian botulism outbreaks (Brisbin et al. 2002). 

4.8 Migratory Waterfowl

Migratory waterfowl winter over in the Hawaiian 

Islands from September-May. They used the open 

waters of New Pond until it began to dry out in the 

late 1990s. Species recorded at the Refuge included 

koloa māpu (northern pintail), koloa mohā 

(Northern shoveler), green-winged teal, and koloamallard hybrids. Our observations through the 

1990s noted migratory waterfowl were more 

prevalent during the winter months, with numbers 

exceeding 15 birds comprised of a few different 

species. 

4.9 Migratory Shorebirds

 

Shorebirds use mudflats and dikes in the wetlands 

and along the coastal strand area of Refuge during 

the winter months. Although their numbers have 

declined significantly due to lack of water, they are 

still seen after heavy rains at New Pond. Occasional 

sightings include the kōlea, ‘akekeke, hunakai, and 

‘ūlili (wandering tattler). The only resident 

shorebird is the ae‘o.

‘Ūlili © Michael Walther

Koloa māpu © Tom Dove
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4-8 Chapter 4. Refuge Biology and Habitat 

4.10 Pest Species 

A pest 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 pests 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, they have the potential 

to compete with native species for limited resources, alter or destroy habitats, shift ecological 

relationships, and transmit diseases. Native species as well as nonnative species can become pests 

when their natural ecosystem is out of balance. 

Pest 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 pest 

species. Hawai‘i, which existed in isolation for millions of years, is an exceptionally ideal 

environment for these species. Most native species lost their natural defense mechanisms and are 

more vulnerable to introduced species (Pattison et al. 1998, Ikuma et al. 2002, Middleton 2006). 

4.10.1 Mammals

Rat (Rattus spp.)

Three pest rat species are found throughout the 

Hawaiian Islands. Polynesian rats arrived from the 

central Pacific 1,500 years ago with the Polynesians; 

Norway rats reached the Hawaiian Islands after the 

arrival of Captain Cook in the 1770s; and black rats 

most likely arrived in the 1870s. 

All three species in Hawai‘i are known predators of 

eggs, nestlings, young, and occasionally adults of 

endangered waterbirds, seabirds, migratory shorebirds, and forest birds. Ground- and burrow-nesting 

seabirds are particularly vulnerable to rat predation, even by the arboreal black rat. Rats also 

consume plants, insects, mollusks, and other invertebrates. Because these species are also eaten by 

birds, a reduction in these populations may indirectly affect avian populations (Olson and James 

1982, Harrison et al. 1984, Brisbin et al. 2002, Engilis et al. 2002, Mitchell et al. 2005). 

The use of snap traps and ground-based application of diphacinone rodenticide to control rats in the 

main Hawaiian Islands has shown a positive effect in native bird survival. After wetland restoration, 

rat control will be conducted at the Refuge with various methods including the use of rodenticide 

placed in tamper-resistant bait stations, live traps, and snap traps. 

Black rat © Jack Jeffrey
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Chapter 4 Refuge Biology and Habitat 4-9 

Neutered & released cat w/ waterbird © Michael Walther

Small Indian mongoose 

(Herpestes javanicus) 

The small Indian mongoose was introduced to the 

main Hawaiian Islands in 1883 as a bio-control 

agent against rats in sugarcane fields. The mongoose 

inhabits all habitat types from 0-10,000 feet on the 

islands of Hawai‘i, Maui, O‘ahu, and Moloka‘i. In 

other areas of the world, mongooses appear to avoid 

wet areas; however, in Hawai‘i, dense populations 

of mongooses are concentrated in wet habitats. 

The home range of a female in Hawai‘i is about 3.5 

acres, and the main reproductive period occurs February-August. The high density of mongooses is 

due to abundant food and the lack of natural predators. They are voracious omnivores, consuming 

insects, reptiles, mammals, amphibians, crabs, plants, and birds. They are a major threat to any 

ground dwelling and nesting species in Hawai‘i, known to eat eggs, young, and adults of endangered 

waterbirds, seabirds, and shorebirds. After wetland restoration, the mongoose population will be 

managed using traps and diphacinone rodenticide (Staples and Cowie 2001, Mitchell et al. 2005, 

Hays and Conant 2007). 

Cat (Felis catus) 

Cats arrived in Hawai‘i in the early 1800s on 

European ships and are now found on all the main 

Hawaiian Islands from 0-10,000 feet. Cats are 

natural hunters with their sharp teeth; the upper 

teeth overlap the lower, giving them a firm grasp to 

shake or tear prey to death. Food habits of cats in 

Hawai‘i include insects, centipedes, crustaceans, 

lizards, mice, rats, bird eggs, and birds (Scott and 

Thomas 2000, Mitchell et al. 2005). 

Dog (Canis lupus familiaris)

The dog is a domesticated form of the gray wolf, a member of the Canidae family of the order 

Carnivora. Abandoned, escaped, or pet dogs allowed to run loose can cause great harm to native 

species and ecosystems. Dogs have caused terrible damage to native ground-nesting birds. Dogs can

attack a large number of birds in a single incident by grabbing and shaking the birds around with 

their mouths and leaving them for dead before heading to another nest or burrow. 

Axis Deer (Axis axis) 

Eight axis deer were brought to the Hawaiian Islands in December 1867 and released on Moloka‘i in 

January 1868. That number has risen to over 8,000 today. Axis deer originate from India and are also 

known as cheetal deer. They stand about 3 feet tall at the shoulder and weigh about 185 lb. with a 

lifespan of 20-30 years. Axis deer have a protracted breeding season in our tropical climate, and 

births can occur throughout the year. Males do not have their antler cycles in synchrony and there are 

some fertile females at all times of the year. The growing population of axis deer has created a 

number of concerns ranging from vehicle accidents and poaching to crop and ecosystem damage 

(Waring 1996, Maui Axis Deer Group 2002, Stephenson 2010). 

Small Indian mongoose USFWS
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4-10 Chapter 4. Refuge Biology and Habitat 

4.10.2 Birds 

There are a number of nonnative species that have been introduced through human activity. 

Moloka‘i’s native birds coevolved in isolation and developed specialized life history requirements in 

order to minimize competition. Most of the nonnative birds have been introduced just within the last 

100 years and use the same habitats, eat the same foods, and use similar foraging strategies as our 

native birds. Direct competition for limited food and habitat may be a serious issue. These species are 

resistant to avian pox and malaria and may serve as carriers for transmitting these devastating 

diseases. Nonnative bird species are fairly common to abundant, and also play a role in spreading the 

seeds of pest plants into native habitats. 

Cattle egret (Bubulcus ibis) 

The cattle egret was introduced to Hawai‘i in 1959 from Florida for 

insect control on cattle and has become widespread. Rookeries 

were documented on Ni‘ihau, Kaua‘i, O‘ahu, Hawai‘i Island, 

Moloka‘i, Lana‘i, and Maui by the mid-1980s. 

Its diet primarily consists of grasshoppers, crickets, spiders, flies, 

frogs, and nocturnal moths, but the bird will also consume prawns, 

mice, crayfish, and the young of native waterbirds. Cattle egrets 

have been documented taking chicks of all endangered waterbird 

species occurring on the Refuge. After wetland restoration and if 

predation on endangered waterbirds exceeds our target limit, 

population control measures as identified in the IPM would be 

implemented ( Engilis et al. 2002, Hawaii Audubon Society 2005). 

4.10.3 Amphibians

Cane toad (Bufo marinus) 

Cane toads or Pacific giant toads are native to Latin 

America and were brought to the Hawaiian Islands 

in 1932 to control insect pests. The adults only 

require water for breeding, an event which results in 

thousands of eggs per mating occurrence. Cane 

toads are active at night and primarily feed on 

cockroaches, crickets, grasshoppers, grubs, 

earthworms, slugs, spiders, centipedes, and snails. In 

addition, these highly invasive amphibians are 

potential predators of endangered waterbird eggs 

and young (Yamamoto & Tagawa 2000, Staples & 

Cowie 2001). Cane toad Laura Beauregard/USFWS

Cattle egret Laura Beauregard/USFWS
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Chapter 4 Refuge Biology and Habitat 4-11

4.10.4 Invertebrates 

Ants 

Hawai‘i is one of the few places on Earth believed to harbor no native ant species. Today, at least 47 

ant species in 7 subfamilies and 24 genera have become established. Ants are a growing concern 

since they can have negative effects on native and endangered plants and animals. Ants are known to 

attack, injure, or kill young birds. Ants are also implicated in having negative effects on native and 

endangered plants. Control of ants has potential on the Refuge to protect trust resources. The Service 

is currently studying the efficacy of various baits and approved toxins on pest ants on O‘ahu and 

Johnston Atoll. After wetland restoration, it is anticipated that the Refuge will adopt IPM methods to 

control ants based on the results of these studies.

4.10.5 Plants 

At the ecosystem level, pest plants have been shown to be capable of changing fire regimes, altering 

nutrient cycling patterns, and modifying the surface runoff of water. Nonnative plants can physically 

displace native species, and/or supersede them in competition for water, nutrients, or other limited 

resources. They can also be vectors and hosts for introduced pests and diseases to which the native 

species lack natural defenses (Jui Min et al. 2007). 

Almost half the flora of the Hawaiian Islands is comprised of naturalized nonnative plants, 

approximately 1,100 species. According to Staples et al. (2000), pest plants in Hawai‘i share the 

following biological and reproductive characteristics: 

Adaptable to and capable of thriving in different habitats; 

Tolerant of variable conditions (such as light, temperature, moisture); 

Fast growing; 

Tolerant of disturbance; 

Easily dispersible to new localities by seeds, fruits, spores, or vegetative parts; 

Produce small seeds/spores early in life; 

Long reproductive periods; and 

Dispersed by animals and with no special germination requirements. 

The control and eradication of pest plants has been the top priority of natural resource managers in 

Hawai‘i. Pest species out-compete more desirable plant species here, as well as invade open water 

and mudflat habitats. In addition, the high biomass characteristic of pest grasses produces a high 

amount of fuel for fire. Pest plants on the Refuge include California grass, California bulrush, Indian 

marsh fleabane, kiawe, and long thorn kiawe. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

4-12 Chapter 4. Refuge Biology and Habitat 

California grass (Brachiaria mutica) 

California grass is a sprawling perennial with culms 

up to 19 feet long. Stolons and leaf sheaths are 

densely hairy. It is suspected to have originated in 

Africa and occurs pantropically as a pasture grass, 

well adapted to a wide range of soil conditions 

(sandy to clay). It tolerates moderate shade but 

prefers full sun (Cook et al. 2005). 

It grows prolifically in wetland habitats, but it can 

also withstand severe drought. In addition to 

displacing native plants, California grass alters and 

destroys wetlands, causing a reduction in bird habitat. The Hawai‘i-Pacific Weed Risk Assessment, 

conducted by the University of Hawai‘i and the U.S. Forest Service, identifies California grass as 

“documented to cause significant ecological or economic harm in Hawai‘i” (Stone et al. 1999, 

Motooka et al. 2003). 

Indian marsh fleabane (Pluchea indica) 

Indian fleabane is an erect shrub that grows up to 6.6 

feet tall. It is native to temperate and tropical Asia, 

northern Australia, and is naturalized elsewhere. In 

Hawai‘i, it occurs in lowland, coastal habitats such 

as wetlands and fishponds (GRIN Online Database). 

Indian fleabane out-competes native sedges on the 

Refuge, reducing forage and nesting habitats for 

native birds. The understory and open areas of the 

coastal dry forest habitat are dominated by this pest 

species. It tends to harbor huge nests of paper wasps, 

which are a hazard to Refuge staff. The Refuge uses 

mechanical, chemical, and prescribed burning IPM 

techniques to control this pest species. 

California bulrush (Schoenoplectus californicus) 

California bulrush is a perennial sedge native to 

marshes of the tropical and subtropical Americas. It 

was first found on Moloka‘i in 1912. It has tall, thin, 

dark green stems which are usually triangular in 

cross-section and woolly, bristly tan or brown 

flowers in panicle inflorescences. It has 

characteristics common in the sedge family, such as 

creeping. It is intolerant of shade, but can spread 

rapidly by vegetative means (Wagner et al. 1999, 

Erickson and Puttock 2006).

California grass Mike Silbernagle/USFWS

Indian marsh fleabane Mike Silbernagle/USFWS

California bulrush Mike Silbernagle/USFWS
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Chapter 4 Refuge Biology and Habitat 4-13

Kiawe (Prosopis pallida) 

Kiawe is native to Peru, Colombia, and Ecuador. More than 

150,000 acres of kiawe forests in Hawai‘i are descended from a 

single tree planted in 1828 by Father Bachelot, the first Catholic 

priest in the Hawaiian Islands. By 1840, progeny of the tree were 

already spreading to dry, leeward plains on all of the islands 

(Nelson and Wheeler 1963). 

Most kiawe have thorns with strong, 1 inch-long spines. It usually 

flowers January-March, but in years with wet summers it also 

flowers September-October. Kiawe overshadows native plants and 

deep taproots use all available water. Dense kiawe thickets have 

replaced native plants in the coastal dry forest at the Refuge. 

Long thorn kiawe (Prosopis juliflora)

Related to the common kiawe, long thorn kiawe differs in that it is sprawling in nature (rather than an 

upright tree), has a larger leaf structure and, most notably, thorns up to several inches long which are 

sharp enough to pierce vehicle tires. Long thorn 

kiawe has been known to hybridize with common 

kiawe. It has many seeds and grows rapidly, 

impeding access in New Pond with its sprawling 

branches and long sharp thorns. The Moloka‘i/Maui 

Invasive Species Committee has identified long 

thorn kiawe as a target pest species for removal. Our 

control options include hand pulling new shoots as 

soon as they have emerged and are large enough to 

grip. Cutting the plant at the base and treating with 

herbicide will effectively stop it from re-sprouting. 

Constant monitoring is needed to watch for new 

growth (MoMISC 2010). 

4.11 Wildlife and Habitat Research and Monitoring Efforts

A research project on wetland ecology has been conducted at Kakahai‘a NWR for the past several 

years. It included a study on nitrogen source tracking through wetland plants. It showed low values 

from wetlands on Moloka‘i and higher values at wetlands on O‘ahu and Maui. The higher values 

were attributed to more developed and densely populated watersheds (Bruland and MacKenzie 

2010). 

Kiawe thorns & seed pods 

© F & K Starr

Long thorn kiawe © F & K Starr
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

4-14 Chapter 4. Refuge Biology and Habitat 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 5. Refuge Facilities and Public Use Programs 5-1 

Chapter 5. Refuge Facilities and Public Use Programs 

5.1 Refuge Infrastructure and Operational Facilities

There are few facilities at Kakahai‘a NWR due to the limited space available and the need to only 

secure equipment and supplies at this unstaffed Refuge. The Refuge is provided with electrical 

service from Maui Electric Company, Inc. Water and septic services are not available. 

5.1.1 Refuge Operations 

The administrative functions and staff for Kakahai‘a NWR are located at the Maui NWR Complex 

office located at Kealia Pond NWR on the island of Maui. All staff have dual responsibilities for the 

oversight of both Refuges. Trips to Kakahai‘a NWR are regularly scheduled for every other week 

and is typically made by the maintenance worker to inspect the Refuge condition and perform 

maintenance and habitat improvement tasks. Periodically, volunteers or other Refuge staff is sent to 

assist with projects. The maintenance worker makes 26 trips per year on average; however, 

overnight trips are made to complete priority and time-sensitive projects (fence repairs, road work). 

5.1.2 Maintenance Facilities 

The primary maintenance facilities include a metal 

container and shed to secure equipment and 

supplies. This minimal storage is sufficient given 

the amount of non-wetland area available and the 

unstaffed Refuge status. 

5.1.3 Dempster Windmill 

The metal Dempster windmill located between Old and New Ponds was erected when Moloka‘i 

Ranch was using the wetland for rice production from the late 1800s-1950. When the Refuge was 

acquired by the Service, the windmill was being used for fish production by the Yuen family. After 

acquisition, the windmill pump was used to deliver water from Old Pond to New Pond and was still 

in operation in 1988. At that time, Refuge staff reported considerable savings in electric pumping 

cost; however, the seasons when winds along the Moloka‘i shoreline were fairly constant (10-15 mph 

spring-summer) were not when water was needed most (fall). 

Today, the windmill frame is still in place but the blades have long been removed because of 

disrepair. This structure has become a local landmark and a signature feature of the Refuge. 

Moloka‘i residents have requested the Service retain and repair the windmill even if it no longer 

operates as source of electricity. 

Kakahai‘a storage units USFWS
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5-2 Chapter 5. Refuge Facilities and Public Use Programs

5.1.4 Roads 

The Refuge has one access road located off Kamehameha V Highway approximately 5.4 miles from 

the main town of Kaunakakai. The entrance road also serves as a right-of-way for five (5) residents 

north of the boundary. Through the years, the original dirt road had become eroded and susceptible to 

flooding from upper watershed draining and Kawela Stream overflow. From 2000-2009, flooding of 

the road increased dramatically and prompted efforts to secure funding, reconfigure and repair the 

road, and evaluate the flooding issue. In June 2010, the road was elevated and paved to allow safe, 

reliable access for staff and the adjacent neighbors. A slight modification to the road alignment 

allows for minimal parking for future wildlife observation from outside the fence. 

5.1.5. Constructed Ponds and Levees 

Old Pond covers about 15 acres. The levees around the perimeter are currently eroded and impacted 

by invasive woody and annual plants making it impenetrable for access by foot. When this levee is 

reconstructed it will provide access for staff, visitors, and Refuge vehicles. In 1984, radial levees 

were constructed inside the pond; these levees will be removed to allow natural flooding and 

eliminate the high elevation inside the pond where invasive plant growth is an existing problem. 

The 5.5-acre New Pond was constructed in 1984 for shallow water habitat; however, the lack of 

water has greatly decreased its value to endangered waterbirds. The inner pond and perimeter levees 

are currently covered with pest plants, a majority of which is woody vegetation that impairs the 

integrity of the pond. The levees around this pond were accessible in the past and will continue to be 

used for EE and interpretation when restored. This pond is visible from the Refuge entrance road 

and would be a key area for wildlife observation and photography in the future. 

5.1.6 Wells, Pumps, Water Distribution Lines, and Water Control Structures 

In 1984 (when New Pond was constructed), a water control structure was installed to connect both 

ponds and a pump located at the windmill was used to pump water from Old Pond into New Pond. 

This pump was in use until 2003; however, it is no longer functional because there is not enough 

water on the west side of Old Pond to pump into New Pond. At one time, the wind-driven pump was 

operational at all times of the year. Once the wetlands are restored, the Refuge would replace the 

pump to take advantage of the natural flooding from groundwater springs in Old Pond. Previous 

owners of the property had drilled modest wells, one of which has a coral lining above ground that is 

still visible. The Refuge will evaluate the feasibility of using these borings to install a casing and 

outfit it with a pump before drilling a new well. A new water supply is needed for New Pond to 

create and maintain shallow water habitat for endangered ae‘o and to help control pest plants. 

Old Pond has an old water control structure with a connection to the makai side via a culvert under 

Kamehameha V Highway. This structure is degraded and is intended to be removed and closed 

because the culvert is lower than the shoreline and covered with sand, preventing natural flow of 

water to the ocean. Both Old and New Ponds should have separate water control structures located at 

the lower elevation of each pond and connected to a ditch running along the south side of New Pond. 

This ditch intersects with the drainage ditch and culvert under the highway and exiting to the ocean. 
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Chapter 5. Refuge Facilities and Public Use Programs 5-3 

Currently, there are no water distribution lines dedicated to habitat management. The Refuge has 

initiated preliminary investigation into the re-establishment of an existing well or construction of a 

new well to provide an alternative water source for New Pond. The pump outfitted on this well 

would have water distribution lines, primarily to feed into New Pond but a valve to Old Pond would 

also be constructed to provide alternative flooding capabilities. 

5.1.7. Kamehameha V Highway Culvert 

A concrete culvert under Kamehameha V Highway is located on the east side of the entrance road 

and provided drainage to the ocean. At the time of construction, the culvert may have been 

appropriate for drainage and situated at an elevation that allowed unimpeded flow to the ocean; 

however, that is no longer the case. The existing elevation of the culvert is below the mean tide 

resulting in sand buildup in front of the opening and prevention of appropriate drainage. This 

condition is similar to other culverts along the southeastern shore of Moloka‘i causing occasional 

flooding of the highway and private property. During and after winter rains, HDOT uses heavy 

equipment to remove sand from culvert openings and plows sediment runoff from the highway. 

Unfortunately, once most water is drained, the culvert openings become plugged with sand with the 

next high tides. 

The flooding along the highway and entrance road at Kakahai‘a NWR has been an issue not only 

because of the culvert but also due to drainage problems at Kawela Bridge, approximately 0.3 miles 

west of the entrance road. Debris and sediment blocking water flow under the bridge results in 

overflow along the highway that eventually reaches the Refuge entrance road, adding water to an 

already flooded area. Although, the culverts are the responsibility of the State, the flooding is a 

Refuge issue that not only impacts staff access onto the Refuge but also impacts the five property 

owners who have a right of access along the Refuge road to their property. 

In 2004, the Service collaborated with the Federal Highway Administration to address flooding at the 

culvert with the intention of developing a design to resolve the sand blockage problem. The options 

were limited due to feasibility, collaboration with other agencies, and the potential impacts to areas 

further down the shoreline. The flooding issue is prevalent along the entire southeastern shoreline of 

Moloka‘i and is an issue that the Refuge will continue to investigate to develop solutions that are 

agreeable with all agencies and adjacent landowners. 

5.1.8 Fences and Gates 

There are two fences at Kakahai‘a NWR. One 

fence encompasses both Old and New Ponds, 

coastal forest habitat, open grassland areas, and the 

maintenance area. Although in fairly good condition

along the highway, along the eastern boundary it is 

susceptible to sediment buildup from runoff and 

erosion. It is also heavily impacted by axis deer and 

it requires periodic repairs. The portion of this 

fence that is parallel with the entrance road was 

replaced in 2010-11 when the Refuge entrance road 

Damaged fence along the northern boundary USFWS
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5-4 Chapter 5. Refuge Facilities and Public Use Programs

was paved. The north side of the fence, along its entire length, is in need of replacement. 

A second fence used to be on the west and north sides of the Refuge road and provided a physical 

boundary with the neighboring private lands. Through the years, portions of this fence were removed 

due to disrepair and lack of funds to replace. Only small sections are remaining. The Refuge intends 

to replace this fence in its entirety throughout the length of the entrance road. 

5.2 Public Use

5.2.1 Special Use Permits

The wetland areas of the Refuge are closed to the general public. Specific proposed public activities 

on the Refuge are evaluated to ensure they are compatible with the Refuge's purposes and permitted 

on a case-by-case basis. Special Use Permits for EE and interpretation are provided to qualified 

organizations. 

5.2.2 Kakahai‘a Park 

Kakahai‘a Park, a day-use picnic area, was developed in 1978 makai of the highway bisecting the 

Refuge and continues to be maintained by the County of Maui. Concrete tables and metal barbeque 

grills are used on a limited basis by local residents and tourists. As the Refuge is currently unstaffed, 

we only have anecdotal information on the uses going on in the park. Park use will be evaluated as 

part of a step-down VSP (to include a new CD if needed). 

5.2.3 Wildlife Observation and Photography 

From 1976-2003, when the wetlands were habitable for endangered and migratory waterbirds, 

wildlife observation and photography opportunities were also available. Prior to the encroachment of 

California bulrush in Old Pond, the number and diversity of endangered and migratory waterbirds 

made for quality viewing experiences and is still remembered by the older generation of Moloka‘i

residents. The Complex office receives an average of 30 e-mails and telephone inquiries each year 

for access to view wildlife and for classroom visits. The quality of wildlife observation has declined 

County park sign USFWS Picnic area and shoreline USFWS
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Chapter 5. Refuge Facilities and Public Use Programs 5-5 

significantly with the loss of water and open habitat leading to absence of waterbirds, except for the 

2-4 days after a rainstorm. 

When wetlands are restored and the endangered and migratory birds are once again using the Refuge 

for foraging, nesting, and resting, there will be an increased opportunities for wildlife observation 

and photography. A component of the VSP will include plans for an elevated area and kiosk along 

the entrance road that would provide viewing when the Refuge is closed and when staff is not 

present. 

5.2.4 Environmental Education 

In past years, the Refuge hosted EE groups, primarily from the local community and schools, as a 

supplement to the teacher/leader’s in-class curriculum. The hands-on experiences were valuable for 

students with such limited access to wetland areas. Nēnē O Moloka‘i is a non-profit corporation 

created to establish and preserve wild nēnē on the island of Moloka‘i, while emphasizing education 

through community involvement. They currently have a SUP to access the Refuge and host school 

and other EE groups. The organization provides educational and volunteer opportunities to groups 

that include a well-rounded overview of the different types of wetland habitats on Moloka‘i with 

emphasis on the endangered waterbirds. 

Refuge-specific EE programs will be developed for local school groups of varying age levels as part 

of the VSP. Volunteers would be recruited and trained to assist with the program. All EE programs 

will have a stewardship component where students would participate in a wetland restoration project. 

5.2.5 Volunteers 

After the Refuge was established in 1976, residents on Moloka‘i formed the group Kokua Kakahai‘a

to provide support for the Refuge and help define and develop goals for wetland restoration, bringing 

back the diversity of waterbirds at the Refuge, and develop a conceptual design that would include 

restoration by staff and community involvement. From 1998-2009, annual Kokua Kakahai‘a

luncheons at the Moloka‘i Historical Museum were coordinated and funded by group leader Kenneth 

Fiske. These meetings were an opportunity for the Refuge Project Leader and group to gather and 

discuss Refuge issues and updates. 
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5-6 Chapter 5. Refuge Facilities and Public Use Programs
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 6. Cultural Resources, Social, and Economic Environment 6-1 

Chapter 6. Cultural Resources, Social, and Economic 

Environment 

6.1 Refuge Cultural Resources

The Service defines cultural resources as archaeological sites, historic places, objects of antiquity, 

cultural items, or traditional/religious values. This section provides a summary of the cultural and 

historic resources at Kakahai„a NWR and the surrounding Kawela ahupua„a. A discussion of the 

Native Hawaiian and Euro-American cultural history of the area is provided within the context of the 

broader history of Moloka„i and the State of Hawai„i. 

6.1.1 Native Hawaiian Cultural History 

The early settlement history of the island is a subject of some debate. Some believe that the first 

Polynesians arrived in Hawai„i around 100-300 BCE from the Marquesas and were followed by 

Tahitian settlers around 1100-1300 CE who conquered the original inhabitants. Others believe that 

there was only a single, extended period of settlement. Polynesians developed a new Hawaiian 

culture while maintaining much of the social and political structure of their homeland. 

Moloka„i was first settled around 450-650 CE and was divided into two main districts – Ko„olau, 

which comprised the northeastern side, and Kona, which made up the remainder of the island. These 

districts were further divided into ahupua„a, a wedge-shaped Hawaiian land unit that traditionally 

subdivided resources from the uplands to the shore. Summers (1971) states that the “surviving 

traditional history of Moloka„i is fragmentary” since the island‟s smaller size rendered it “not of 

major political importance.” In ancient times, Moloka„i was also referred to as Pule-o„o (effective 

prayer). This name was acquired because the small population could not compete with larger islands 

during war periods and therefore the ali„i of Moloka„i largely relied on prayer for safety (Handy and 

Handy 1972). 

The Kawela ahupua„a, which means “the heat,” is an arid region on the southeastern portion of the 

island. Prehistoric use of Kawela is dated to approximately 1500 CE. During the 16th and 17th

centuries, people used the coastal area for fishing and aquaculture (Weisler 1983). The broad fringing 

reef offshore contained abundant shellfish, seaweed, and fish. A low sand dune midden located west 

of Kakahai„a Pond contains cultural remains of these groups including small scoop hearths with 

associated fishbone, marine and brackish-water mollusks, and crustaceans (Weisler 1983). In 

addition, Weisler and Kirch (1982) observed bone in the stratified layer from several bird species, 

including nēnē (Hawaiian goose), koloa mapū, pueo (Hawaiian short-eared owl), and „alae ke„oke„o. 

The presence of these particular species implies that marshlands were present in the area at that time. 

Permanent, large-scale occupation of the Kawela area began in the 18th century. Residences were 

mostly concentrated along the ridgelines below the 115-foot contour. This elevation offered safety 

from flooding, exposure to the tradewinds, and allowed for high agricultural productivity along the 

Kawela Gulch and on the adjacent coastal flats (Weisler and Kirch 1982). Individual kauhale 

(housing complexes) within the community contained from 6-35 architectural features constructed of 
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6-2 Chapter 6. Cultural Resources, Social, and Economic Environment

stacked, dry-laid unmodified stone. A residential complex consisted of several structures ranging 

from pole-and-thatch houses to cooking shelters and craft areas. Despite limited water supply, 

Hawaiians used the well-drained soil of the Kawela Stream delta to cultivate sweet potatoes. Weisler 

and Kirch (1985) suggest that the two water ditches in the Kawela floodplain did not have continuous 

discharge and therefore the irrigation system probably only intermittently supported sweet potato 

plantings, but not wetland taro. Slash-and-burn agriculture for sweet potato cultivation was also 

conducted on land above the residences (Weisler 1983). 

Early Hawaiians constructed one inland fishpond (Kakahai„a) as well as four coastal fishponds 

(Kanoa, Kaoaini, and two unnamed ponds) in the Kawela region (Weisler and Kirch 1985). 

Fishponds, which were considered sacred due to their spiritual power, were an important element of 

Hawaiian social and cultural life (Farber 1997). The Kakahai„a fishpond is located in the 

southeastern corner of the Kawela ahupua„a. This small inland fishpond, or loko pu‟uone, is a 

brackish pond connected to the sea by a ditch and fed by several flowing inland streams (Weisler 

1983, Estioko-Griffin 1987). Radiocarbon dating suggests that the pond area was initially used by 

Hawaiians as early as 1500 CE; however, stata analysis shows that the area was probably not utilized 

as a fishpond until the early 1700s when more permanent settlement occurred in the adjacent uplands 

(Weisler 1983). 

In 1736, the final battle of a failed takeover by Kapi„ioho o Kalani, son of Kuali„i, the chief of O„ahu, 

and Alapainui from Hawai„i Island, was fought on the plains of Kawela. Fornander (1880) wrote: 

„This famous battlefield may still be seen in the place described, where the bones of the slain 

are the sports of the winds that sweep over the sandy plain, and cover or uncover them, as the 

case may be. The numerical strength of the two opposing armies is not mentioned in the 

legends; but to judge from the multitude of bones and the number of skulls that are bleaching 

in the sun when a strong north wind has removed their sand covering, the numbers engaged 

on each side must have been reckoned by thousands.‟

Weisler (1983) theorizes that use of the fishpond ceased in the early 1800s. This idea is supported by 

the presence of nonmarine mollusks in the upper stratigraphic layer. Although the species were not 

positively identified, two species (Thiara granifera and T. tuberculata) “not proven to be native in 

Hawai„i” are present at Kakahai„a and also found in other southern fishponds along the coast of 

Moloka„i (Weisler 1983). By 1851, the traditional system of fishponds throughout the Hawaiian 

Islands was largely abandoned (Farber 1997). 

6.1.2 Euro-American Cultural History 

British explorer Captain James Cook is credited with being the first European to visit Hawai„i in 

1778 on the H.M.S. Resolution. There is some evidence that Spaniards, who first crossed the Pacific 

Ocean in 1522, also made landfall in Hawai„i but they never correctly mapped or claimed credit for 

their accomplishment. The first interaction between residents of Moloka„i and Europeans occurred 

in 1786 when Captain George Dixon anchored off the coast.The island was rarely visited by 

foreigners until the establishment of a Protestant mission in 1832 (Spalding 1983). 
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Chapter 6. Cultural Resources, Social, and Economic Environment 6-3 

Contact with Europeans irrevocably changed the lives of Native Hawaiians. These contacts began a 

series of serious plagues for which they had no immunities. In time, the Native Hawaiian population 

would plummet from 300-500,000 in 1778 to only 30,000 by 1900. Moloka„i experienced a smaller 

population decline after western contact compared to other Hawaiian islands which can be attributed 

to the minimal interaction with westerners and subsequent smaller percentage of disease transferral. 

Summers (1964) argued that the population decrease may have been attributed to natives leaving to 

larger islands in the archipelago. 

As trade and shipping brought Hawai„i into contact with a wider world, it also enabled the 

acquisition of Western goods, including arms and ammunition. In 1795, Kamehameha I from the 

Island of Hawai„i assembled the largest army the Hawaiian Islands had ever seen, with over 10,000 

men and 1,200 war canoes, equipping them with European muskets and cannon. He established the 

Kingdom of Hawai„i with the subjugation of the smaller independent chiefdoms of O„ahu, Maui, 

Moloka„i, Lāna„i, Kaua„i, and Ni„ihau into one unified government over the period 1795-1810. On 

Moloka„i, Kamehameha I landed his invading force near Kawela. It is estimated that his canoes 

stretched for over four miles. Local legends tell of ghost warriors (known as night marchers) still 

walking the ancient paths with their torches, talking and making noises on their way to battle 

(Crowe 2002). The defeated warriors took refuge at the pu„uhonua (place of refuge) in Kawela. A 

burial mound of the warriors killed in this battle is located in the eastern portion of the Kawela 

ahupua„a (Summer 1971). 

Kamehameha made Lahaina, Maui, the new capital of the Kingdom of Hawai„i. For nearly 5 

decades, Lahaina served as the center of government. Although salt was an early island export, „iliahi 

(sandalwood) was the first major item of external trade. By 1805, „iliahi had begun to reach China, 

and by 1809 it was a regular trade commodity. In 1810 American merchants reached an agreement 

with Kamehameha for a monopoly on the „iliahi trade in exchange for a quarter of the profits. These 

merchants took a convoy of „iliahi ships to China in 1812, making a good profit on their sales. This 

agreement stood for only one shipment, though, and shortly thereafter the War of 1812 resulted in a 

British blockade of Hawai„i for 2 years (Daws 1989). 

When trade resumed in 1814, King Kamehameha claimed the trees as his own in a near-monopoly 

and organized the cutting and transport of „iliahi under his public works program. A 75-foot long 

boat-shaped “lua na moku „iliahi” (sandalwood measuring pit) still remains in central Moloka„i. A 

boat of foreign goods was bought by exchanging the amount of „iliahi that would fill the pit. The 

„iliahi trade had serious consequences on Hawaiian culture. The income encouraged the transition to 

a cash economy, the purchase of luxury goods, and became the main source of revenue for the ali„i. 

(Gast and Conrad 1973). 

Kamehameha I's death in 1819 triggered a dramatic change in the social, political, and religious 

systems of the country. Members of the ali„i had acquired many of the outward manners and dress of 

European civilization during the final years of Kamehameha's reign. His successor Liholiho 

(Kamehameha II) ended the kapu system and ordered the destruction of images and heiau throughout 

the Kingdom (Gast and Conrad 1973, Judd 1966). 

Kamehameha II fell into debt with „iliahi traders and by 1826, a general tax on the Hawaiian people 

was imposed to pay off some of the collective debt of the king and ali„i. As logging continued, stands 

of „iliahi were harder to find. Fires were set in forested areas to detect the „iliahi trees by their sweet 
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6-4 Chapter 6. Cultural Resources, Social, and Economic Environment

scent. While mature trees could withstand the fire, the flames wiped out new seedlings. By 1830, the 

‘iliahi trade had completely collapsed (Judd 1966). 

6.1.3 The Mahele, 1848-1851 

Among other things, foreigners speculating in Hawaiian commodities demanded private ownership 

of land to insure their investments. Influenced by these foreign investors, King Kamehameha III 

instigated the Great Mahele of 1848 and drastically altered the Hawaiian land system by 

redistributing land ownership between the kings, ali‘i, foreigners, and maka‘ainana (common people 

who were fishermen, craftsmen, and farmers). Once lands were made available and private 

ownership was instituted, the maka‘ainana were able to claim the plots on which they had been 

cultivating and living, if they had been made aware of the foreign procedures for Land Commission 

Awards (LCA). These claims could not include any previously cultivated or presently fallow land, 

stream fisheries or many other resources necessary for traditional survival (Kelly 1983, 

Kame‘eleihiwa 1992, Kirch and Sahlins 1992). 

This division transformed a vast majority of Moloka‘i into pastureland grazed by sheep and cattle 

(Spalding 1983). Furthermore, the division affected the social and cultural environment since 

individuals were allowed to own private property for the first time (Weisler and Kirch 1985, Farber 

1997). Land claims to the Board of Commissioners in the Kawela ahupua‘a offer written records and 

insight into the historic land use during the mid-1800s. Claims were concentrated on the immediate 

area of the floodplain and delta (Weisler and Kirch 1985). In 1859, the two districts were abolished 

and the entire island was classified as the Moloka‘i district (Greene 1985). 

6.1.4 Post-1850s History 

Moloka‘i achieved notoriety in 1865 when King Kamehameha V approved An Act to Prevent the 

Spread of Leprosy, instituting a century-long policy of forced segregation of persons afflicted with 

Hansen’s disease to a remote, fairly inaccessible finger of land on the north side of the Island. To the 

south, the Kalaupapa Peninsula was cut off from the rest of Moloka‘i by a sheer cliff about 2,000 feet 

high. Once the law passed, the government proceeded to purchase lands in the isolated Kalaupapa 

area and move the residents to other homes. The village of Kalawao became home to thousands of 

Hansen’s disease victims forcibly moved there from throughout the Kingdom. Father Damien 

deVeuster, a Catholic missionary priest from Belgium, arrived at Kalaupapa in 1873 and served the 

patients until his death in 1889 (he was canonized as a saint in 2009). The forced segregation policy 

continued until 1969 (NPS 2010). 

In the 1880s, George Trimble owned a parcel adjacent to Kakahai‘a Pond, and leased 50 acres nearby 

in the alluvial plain for the cultivation of sugarcane (Cooke 1949) for the Kamalo Sugar Mill (Judd 

1936:10). Trimble would load his sugarcane onto a small flatbed barge and tow the cargo by draft 

animals along the shallow shoreline to the mill 5 miles east at Kamalo (Cooke 1949). In 1897, the 

remaining Moloka‘i holdings of the Bernice P. Bishop Estate were purchased by the newly formed 

Moloka‘i Ranch and immediately its headquarters were built on the Kawela flats. A year later, the 

ranch formed the American Sugar Company, and leased all of its lands to the new corporation with 

the intent to establish a sugar plantation. The venture failed within a year, and efforts shifted towards 

the raising of cattle and sheep. 
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Chapter 6. Cultural Resources, Social, and Economic Environment 6-5 

The Kingdom of Hawai„i lasted throughout most of the 19th century, when the expansion of the sugar 

industry meant increasing U.S. business and political involvement. Through the Reciprocity Treaty 

between the United States of America and the Hawaiian Kingdom of 1875, the United States obtained 

exclusive rights to Pearl Harbor in exchange for allowing Hawaiian sugar to enter the United States 

duty-free. In 1893, Queen Lili„uokalani was deposed in a coup d‟état led by American citizens 

supported by U.S. Marines. The sovereignty of the Kingdom of Hawai„i was lost to a Provisional 

Government led by the conspirators, later briefly becoming the Republic of Hawaii [sic], before 

eventual annexation in 1898 as a U.S. territory (Greene 1985).

The introduction of horses and cattle at the end of the 19th century spurred new ranching operations. 

Cattle hides, tallow, and meat became important commodities of local and international trade. In 

1897, a group of businessmen purchased 70,000 acres on the western half of Moloka„i and leased 

another 30,000 acres from the government to raise cattle, horses, mules, and sheep. They leased some 

of their property to Libby and Del Monte for pineapple cultivation between 1923 and 1985 (CowanSmith and Stone 1988). 

Beginning in the mid to late 1800s, changing land uses in the region resulted in significant landscape 

alterations. Vegetation removal by cattle, sheep, goats, and deer caused extensive erosion from 

upland areas, shoreline accretion, extension of the alluvial plain, and infilling the pond. Weisler and 

Kirch (1982) estimated that since 1880, the Kawela shoreline increased by 1 foot per year. Although 

some farmers remained on traditional land east and west of Kawela Stream, upland residences gave 

way to Western-style habitation along the coast. In 1901, Kakahai„a pond was utilized to produce 

rice and several residences were established along the pond edges to facilitate cultivation 

(Shallenberger 1977). During this time, the pond was much larger, with surface water areas 

estimated at 31 acres. Rice production in Kawela ceased in the late 1940s, although the pond is still 

referred to as “rice patch” by local island residents (Weisler 1983). 

Moloka‘i 1897, surveyed by W.D. Alexander and M.D. Monsarrat
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6-6 Chapter 6. Cultural Resources, Social, and Economic Environment

The Moloka„i District was incorporated into the County of Maui in 1909 (with the exception of the 

Kalaupapa Penisula which became the Kalawao District). Inter-island steamers began carrying 

freight, produce and passengers to and from Moloka„i in the early 1900s. Ship travel became less 

popular with the opening of Ho„olehua airport in 1928; and in 1929, the Inter-Island Airways 

inaugurated their first regular air service to other islands (Maui County Planning Department 

(MCPD) 2001). In 1959, Hawai„i became the 50th state of the United States. 

The Kawela area was used to raise pigs and produce kiawe charcoal until 1975. In 1980, the Kawela 

Plantation Development Associates began construction of a 6,000-acre farming community on the 

upland ridges of the watershed, further increasing siltation to the pond (Shallenberger 1977, Greene 

1985).

6.1.5 Archaeological/ Cultural Surveys 

Few archaeological and cultural investigations had been conducted on the southeastern portion of 

Moloka„i and throughout the entire island prior to the 1980s (Weisler and Kirch 1982). An early 

study by Stokes (1909) surveyed the heiau and ko„a 

of Moloka„i. Phelps (1937) conducted a study of 

regional settlement patterns on the island during the 

early 1800s. This study noted the remains of Kawela 

Pu„uhonua, which was used by defeated warriors 

from the nearby battlegrounds. Summers (1971) 

recorded many cultural sites throughout Moloka„i, 

including nine sites in the Kawela ahupua„a. Among 

those listed were the Kawela battlefield, a heiau, 

petroglyphs, a family residence and shrine, a burial 

mound, a pu„uhonua and/or pu„ukaua (a 

fortification), three coastal fishponds, and Kakahai„a

fishpond. 

Six archaeological studies have been conducted in the Kawela area. Environmental Impact Study 

Corp. (1979) conducted both surface and subsurface testing near the Kanoa fishpond for the 

development of the Kanoa Beach lots. No cultural material was encountered during this study, 

besides the known fishpond. 

Weisler and Kirch (1982, 1980) conducted an extensive survey of the Kawela and Makakupa„ia Iki 

ahupua„a for the Kawela Plantation Development Associates. Identifying 499 late prehistoric 

Hawaiian features and recording 182 sites, the “Kawela Archaeological Project” documents an 

exceptionally high density of archaeological remains in the dry upland ridge environment. 

Archaeological features in the immediate vicinity of Kakahai„a Pond NWR include petroglyphs, 

stone platforms (structures and burials), shelters for temporary and permanent habitation, natural 

cave shelters, agriculture terraces, a holua slide, and numerous religious shrines. The Kawela 

Complex is listed on both the National and Hawai„i State Register of Historic Places (MCPD 1984).

Weisler (1983, 1981a) also conducted a pedestrian surface survey and excavated 11 subsurface auger 

holes in two transects specifically for Kakahai„a NWR. Besides the fishpond, no prehistoric sites 

were documented within the Refuge boundaries. Sedimentation from upland habitats and seasonal 

flooding of the pond area is suspected to have buried any potential resources (Weisler 1983). 

Residence site near Kakahai‘a Pond © Arleone DibbenYoung
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 6. Cultural Resources, Social, and Economic Environment 6-7 

However, archaeologists at the State Historical Preservation Division stated that because Weisler‟s 

(1983) report was drafted prior to current State standards, restoration work conducted on the Refuge 

property may require an additional archaeological inventory survey (Kirckendall pers. com.). 

Estioko-Griffin (1987) conducted an islandwide inventory of fishponds, listing Kakahai„a as a loko 

pu„uone (fishpond isolated from the ocean by a mound of sand). DHM Planning Inc. et al. (1990) 

conducted an extensive Hawaiian fishpond study for the DLNR Historic Preservation Division. 

While this inventory also listed Kakahai„a as a loko pu„uone, it did not provide an in-depth study of 

the fishpond. 

Three recent sites, dated post-1940, were recorded during a Refuge boundary survey in 1975 and 

1976 by R.M. Towill Corporation. Weisler (1983) revisited these locations and suggested they be 

avoided during any land modification on the Refuge. The historical sites include the following: 

Abandoned Residence: An abandoned residence was found immediately east of the pond. 

The site includes a small, wood-frame house, a separate cookhouse, and a small shack; 

however, because the structures were demolished around 1976, only the foundation of a 

barbeque remains. 

Piggery and Charcoal Production: North of the abandoned house and east of the pond, is a 

piggery and charcoal manufacturing site. The 10 portable ovens noted during the 1976 

boundary survey were removed prior to the 1983 survey, leaving only piles of small kiawe 

charcoal fragments. The ovens mostly likely burned kiawe into charcoal for export to 

Honolulu markets. The site also includes a 40 foot by 20 foot concrete foundation that has a 

pair of parallel troughs for feeding and watering pigs. 

Residence and Piggery: In the northwest corner of Refuge, a residence, piggery, and well 

were documented. A narrow dirt road separates the well from the property and an earthen 

berm which probably created a pond for rice cultivation. The berm is bisected by a ditch 

from the well to the residence. Also observed at the site was a hand-carved wooden net float, 

as well as cans and bottles dated between 1943-1983. 

6.1.6 Paleontological Resources 

Unless found in an archaeological context, “nonfossilized and fossilized paleontological specimens, 

or any portion or piece thereof,” are not considered archaeological resources (16 U.S.C. 470bb(1)). 

Paleontology resources include life forms that existed in prehistoric or geologic times, as represented 

by the fossils of plants, animals, and other organisms. Ziegler (2002) defines fossils as “biological 

remains, whether permineralized or not,” that were “deposited in the islands before the time of 

European Contact (1778 CE) and are not definitely components of prehistoric archaeological midden 

(human food refuse and other cultural debris).” Paleontological fossils have been uncovered in a 

variety of sites throughout Hawai„i, including sand dunes, sinkholes, lava tubes, and pond deposits 

(Ziegler 2002). 

Ziegler (2002) states that the only fossiliferous sites on the island of Moloka„i are coastal sand dunes. 

The remains of several bird bone species dating back to 1500 CE were uncovered by Weisler (1983) 

at a low sand dune west of Kakahai„a pond. Avifaunal species identified from prehistoric deposits 

within the dune include the koloa mapū and „alae ke„oke„o, which were probably confined to the 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

6-8 Chapter 6. Cultural Resources, Social, and Economic Environment

marsh habitat, as well as nēnē and pueo, which may have utilized the surrounding grassy area. 

Because Rallidae birds prefer marshes, ponds, and lakes, Weisler (1983) believed that the presence of 

these bones implied that the area contained marshlands during and prior to 1500 CE. Prehistoric 

deposits within the dune also contained evidence of other bird species; however, Weisler (1983) 

concluded that these birds were not associated with the pond area. Although Weisler (1983) does not 

provide a thorough analysis of whether the avifaunal remains uncovered in the Kawela were 

considered cultural debris, his later critical review (1989) stated that nēnē bones found in the dune 

“may have been culturally deposited.” 

Auger holes excavated by Weisler (1983) showed that the pond layer (Stratum II), although 

predominantly composed of sand and silt, also consisted of nonmarine mollusks and seeds of the 

genus Spirpus. The nonmarine mollusks identified include Theodoxus neglectus, Tryonia protea, 

Thiara granifera, and Thiara tuberculata. The thickness of the nonmarine mollusk layer increases 

toward the pond area. In addition, the marine layer (Stratum III) of the most inland auger hole 

contained two chunks of coral (Porites sp.) at 10 feet below the surface dating between 1560-1875 

BCE (Weisler 1983). 

6.2 Social and Economic Setting

This section discusses the social and economic environment surrounding the Kakahai„a NWR, within 

the context of the island of Moloka„i, the County of Maui, and the State of Hawai„i. Kaunakakai, the 

island's major population and commercial center, is located about midway along the south coast. A 

major tourist destination area is located at Kaluakoi, on the western end of the island. There are small 

plantation communities of Maunaloa and Kualapu„u in the central plain, as well as rural Hawaiian 

homestead settlements of Ho„olehua and Kalamaula. There is also a settlement pattern along the 

southeast coast which becomes more rural and dispersed as it extends from Kaunakakai to Halawa 

Valley (MCPD 2001). 

6.2.1 Population 

The 2010 Census data shows the population of Moloka„i has decreased over the past decade with a 

decline from 7,404 to 7,345 since 2000. Much of the decline is attributed to Kalaupapa, where only 

about 18 patients remain in the Hansen‟s disease settlement. Because Kalaupapa is located in 

Kalawao County, its census figures are not part of Maui County. Kaunakakai, which is located 5 

miles east of the Refuge, is the main population and commercial center of Moloka„i. Approximately 

2,726 people resided in the 2.03 square miles of Kaunakakai in 2000. Data for 2010 shows a decrease 

to 2,603 (U.S. Census Bureau 2010). 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 6. Cultural Resources, Social, and Economic Environment 6-9 

Table 6.1. Population figures for selected areas. 

Area Population 

(1990)

Population 

(2000)

Population 

(2010)

Moloka„i Island 6,587 7,404 7,345

Kaunakakai 2,658 2,726 2,603

Maui County 100,374 128,094 154,834

Hawai„i State 1,108,229 1,211,537 1,360,301

Source: U.S. Census Bureau 2010

6.2.2 Housing 

In Kaunakakai, the estimated median house or condo value in 2009 was $298,765 (it was $148,500 in 

2000). The median family income for the Island of Moloka„i in 2009 was $41,528. At 12 percent in 

January of 2011, Moloka„i has the highest unemployment rate of all the Hawaiian Islands. The 

most recent income figures around the region of the Refuge are shown below in Table 6.2 (DBEDT 

2010, Census 2010).

Table 6.2. Census Bureau estimated median and per capita income figures, 2009. 

Area Median Family

Income

Per Capita

Income

Kaunakakai $47,863 $20,112

Island of Moloka„i $41,528 $20,126

Maui County $72,367 $29,121

Source: U.S. Census Bureau 2010

The Census Bureau estimated that Maui County residents paid an average of $24,204 per year in 

mortgage costs, consuming 42.04 percent of their income. The generally accepted definition of 

affordability is for a household to pay no more than 30 percent of its annual income on housing. 

Families who pay more than 30 percent of their income for housing are considered cost burdened and 

may have difficulty affording necessities such as food, clothing, transportation and medical care. The 

majority of Maui County residents are paying an unsustainably high percentage of their income 

toward housing (MCPD 2006, 2010). 

6.2.3 Education 

The following schools are located on the island of Moloka„i: one preschool, four public elementary 

schools, one private school grades K-8, one public intermediate school, one public high school, and 

one private school with preschool to high school students (Maui County Office of Economic 

Development 2005). 

In 2005, the Census Bureau estimated that 86.6 percent of County residents age 25 or older have 

graduated high school and 23.8 percent have a bachelor‟s degree or higher. While the high school 

graduation rate of Maui County is slightly higher than that of the remainder of the United States, the 

percentage of residents with higher-level degrees is lower. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

6-10 Chapter 6. Cultural Resources, Social, and Economic Environment

The University of Hawai„i (UH) Maui College, Moloka„i education center in Kaunakakai offers 

courses leading towards certificates and associate degrees in five primary majors: Liberal Arts, 

Agriculture and Natural Resources, Business Careers, Human Services, and Allied Health/Nurse 

Aide Training. It also serves as a receive site for selected bachelors and masters degree programs 

from UH Mānoa, UH West O„ahu, and UH Hilo via interactive television classes. Of the 225 

students, 75 percent are of Native Hawaiian ancestry – the highest percentage of any campus in the 

UH system. 

6.2.4 Economics 

Moloka„i has Hawai„i‟s highest rate of residents – estimated at 30 percent – who rely at least in part 

on subsistence practices to feed themselves through farming, fishing, and hunting. Cattle ranching 

and farming, mostly on the central and western portions of the island, are currently the central 

components of the Island‟s economy. Small-scale agricultural patches growing coffee beans, papaya, 

macadamia nuts, vegetables, and melons can be found scattered throughout Moloka„i (Moloka„i 

Community 2008). 

Since its collapse in the early 1980s, no large-scale agriculture has been able to replace the pineapple 

industry on Moloka„i, which was historically the central element of the island‟s economy. More 

recently, the agricultural industry, especially vegetable and melon farms, has been have adversely 

impacted by farming developments on O„ahu. However, the MCPD reported that some growth in the 

sector has occurred from seed corn farming, aquaculture, and forestry. The Moloka„i Ranch closure 

in 2008 devastated the community when it laid off more than 120 people, representing nearly the 

entire labor force of the island‟s largest private employer at the time (MCPD 2010). 

Tourism does not generate significant income to the Moloka„i economy as it does on the other 

Hawaiian Islands, the Hawai„i Department of Business, Economic Development, and Tourism 

estimated that the number of visitors to the island in 2009, including domestic and international 

guests, was 48,339, down 29.8 percent compared to the previous year. The average daily census fell 

22.2 percent to 647 visitors per day in 2009. Total visitor expenditures for the island in 2010 were 

estimated at only $2.5 million (DBEDT 2010). 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix A: Species List A-1 

Appendix A. Kakahai‘a NWR Species List* 

*Species currently present and/or historically recorded on the Refuge 

Animal Species

Common Name Scientific Name Hawaiian Name

Invertebrates, Aquatic

Dragonfly Anax junius Pinao

Orange-black Hawaiian damselfly Megalagrion xanthomelas Pinapinao

Invertebrates, Terrestrial

Paper wasp Polistes exclamans

Centipede Scolopendra subspinipes Kanapī

Cockroach Periplaneta americana

Scorpion Isometrus maculatus Kopiana

Fish

Liberty/Mexican molly Poecilia ssp

Mosquito fish Gambusia affinis

Striped mullet Mugil cephalus ‘Ama ‘ama

Tilapia Oreochromis ssp

Reptiles and Amphibians

American toad Bufo americanus

Common house gecko Hemidactylus frenatus Mo‘o ‘alā

Green anole lizard Anolis carolinensis porcatus

Mammals

Axis deer Axis axis Kia

Cat Felis catus Popoki

Dog Canis familiaris ‘Īlio

House mouse Mus musculus ‘Iole

Rat, Polynesian Rattus exulans ‘Iole

Rat, Norway Rattus norvegicus ‘Iole

Rat, Black Rattus rattus ‘Iole

Small Indian mongoose Herpestes auropunctatus Manakuke

Hawaiian Waterbirds

Black-crowned night heron Nycticorax nycticorax hoactli ‘Auku‘u

Hawaiian coot Fulica alai ‘Alae ke‘oke‘o

Hawaiian duck Anas wyvilliana Koloa maoli

Hawaiian moorhen Gallinula chloropus sandvicensis ‘Alae ‘ula

Hawaiian stilt Hemantopus mexicanus knudseni Ae‘o

Migratory Birds

Herons

Cattle egret Bubulcus ibis

Great blue heron Ardea herodias

Geese and Ducks

American wigeon Anas americana

Blue-winged teal Anas discors

Brant Branta bernicla
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

A-2 Appendix A: Species List 

Common Name Scientific Name Hawaiian Name

Bufflehead Bucephala albeola

Canada goose Branta canadensis

Canvasback Aythya valisineria

Eurasian wigeon Anas penelope

Fulvous whistling duck Dendrocygna bicolor

Gadwall Anas strepera

Greater white-fronted goose Anser albifrons

Green-winged teal Anas crecca

Lesser scaup Aythya affinis

Northern pintail Anas acuta Koloa māpu

Northern shoveler Anas clypeata Koloa mohā

Ring-necked duck Aythya collaris

Shorebirds

Long-billed dowitcher Limnodromus scolopaceus

Pacific golden plover Pluvialis fulva Kōlea

Pectoral sandpiper Calidris melanotos

Ruddy turnstone Arenaria interpres ‘Akekeke

Sanderling Calidris alba Hunakai

Short-billed dowitcher Limnodromus griseus

Wandering tattler Heteroscelus incanus ‘Ūlilī

Raptors

Barn owl Tyto alba

Hawaiian short-eared owl Asio flammeus sandwichensis Pueo

Non-Native Passerine Birds

Gallinaceous Birds

Black francolin Francolinus francolinus

Gray francolin Francolinus pondicerianus

Mynas

Common myna Acridotheres tristis

White-Eyes

Japanese white-eye Zosterops japonicas

Northern mockingbird Mimus polyglottos

White-rumped shama Copsychus malabaricus

Cardinals and Sparrows

House sparrow Passer domesticus

Northern cardinal Cardinalis cardinalis

Red-crested cardinal Paroaria coronate

Finches

House finch Carpodacus mexicanus

Waxbills and Mannikins

African silverbill Lonchura cantans

Nutmeg manikin Lonchura punctulata

Doves

Rock dove Columba livia

Spotted dove Streptopelia chinensis

Zebra dove Geopelia striata
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix A: Species List A-3 

Plant Species

Common Name Scientific Name Hawaiian Name

Australian saltbush Atriplex sp.

Bassia Bassia hyssopifolia

Bermuda grass Cynodon dactyron Manienie

Buffel grass Cenchrus ciliaris 

California bulrush Schoenoplectus californicus ‘Aka‘akai

California grass Brachiaria mutica

Castor bean Ricinus communis

Coconut Cocos nucifera Niu

Coral vine Antigonon leptopus

Cuba jute Sida rhombifolia

Duckweed Azolla sp.

False daisy Eclipta alba (prostrate)

False kamani Calophyllum inophyllum

False mallow Malvastrum coromandelianum

Fingergrass Chloris sp.

Goosefoot Chenopodium murale

Grass Echinochloa sp.

Guinea grass Panicum maximum

Hibiscus Hibiscus tiliaceus Hau

Java plum Syzygium cumini

Khaki Alternanthera pungens

Leucaena Leucana leucocephala Koa haole

Long thorn kiawe Prosopis juliflora Kiawe

Marsh fleabane Pluchea indica

Marsh fleabane hybrid Pluchea x fosbergii

Mesquite Prosopis pallida Kiawe

Monkeypod Samanea saman

Native bulrush Schoenoplectus tabernaemontani Kaluhā

Pickleweed Batis maritima ‘Akulikuli kai

Portia tree Thespesia populnea Milo

Primrose willow Ludwigia octovalvis

Saltmarsh bulrush Bolboschoenus maritimus Kaluhā 

Screw pine Pandanus tectorius Hala 

Sea purslane Sesuvium portulacastrum ‘Akulikuli

Seaside heliotrope Heliotropium curassavicum Kīpūkai

Sedge Pycreus (Cyperus) polystachyos

Scarlet spiderling Boerhavia coccinea

Slender mimosa Desmanthus virgatus

Smooth flatsedge Cyperus laevigatus Makaloa 

Sourbush Pluchea odorata

Sprangletop Leptochloa uninervia

Torpedo grass Panicum repens

Uhaloa Waltheria indica ‘Uhaloa

Yellow ilima Sida fallax ‘Ilima 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

A-4 Appendix A: Species List 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

 

Appendix B: Compatibility Determinations and Appropriate Use Findings B-1 

Appendix B. Compatibility Determinations and Appropriate Use

Findings

B.1 Introduction

The compatibility determinations (CD) developed during the CCP planning process evaluate uses 

projected to occur at the Kakahai‘a NWR over the next 15 years. The evaluation of funds needed for 

management and implementation of each use also assumes implementation as described in Chapter 2. 

B.1.1 Uses Evaluated At This Time 

The following CD are included in this CCP: 

Table B.1. Summary of Compatibility Determinations. 

Refuge Use Page Compatible? Year Due for 

Reevaluation

Wildlife Observation, Photography, and 

Interpretation

B-5 Yes 2026

Environmental Education B-11 Yes 2026

Research, Scientific Collecting, and Surveys B-13 Yes 2021

B.1.2 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. 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, 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, wildlife-dependent recreational 

uses are deemed the priority public uses at the refuge. If a proposed use is found not compatible, the 

refuge manager is legally precluded from approving it. Economic uses that are conducted by or 

authorized by the refuge also require CD. 

Under 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. In addition, 

aircraft overflights, emergency actions, some activities on navigable waters, and activities by other 

Federal agencies on “overlay Refuges” are exempt from the compatibility review process.
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

B-2 Appendix B: Compatibility Determinations and Appropriate Use Findings 

New compatibility regulations were adopted by the Service in October 2000. The regulations require 

that a use must be compatible with both the Refuge System mission and the purpose(s) of the 

individual refuge. This standard helps to ensure consistency in application across the Refuge System. 

The Administration Act also requires that CD be in writing and that the public have an opportunity to 

comment on all use evaluations. 

The Refuge System mission emphasizes that the needs of fish, wildlife, and plants must be of 

primary consideration. The Administration 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 Administration 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 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). 

The Service recognizes that CD 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 

the Kakahai‘a NWR are based on the professional judgment of Refuge and planning personnel 

including observations of Refuge uses and reviews of relevant scientific literature. 

B.1.3 Appropriate Use Findings 

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 wildlifedependent uses (hunting, fishing, wildlife observation and photography and EE and interpretation) 

under the Administration Act are generally exempt from appropriate use review. Other exempt uses 

include situations 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. The policy also requires review of 

existing public uses. During the CCP process, the refuge manager evaluated all existing and proposed 

refuge uses at Kakahai‘a NWR using the guidelines and criteria as outlined in the appropriate use 

policy. 

Using this process, and as documented on the following pages, the refuge manager determined the 

following use is appropriate for the purposes of the Refuge System and Kakahai‘a NWR, and 

directed that a CD be completed for these uses: research, scientific collecting, and surveys. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

 

Appendix B: Compatibility Determinations and Appropriate Use Findings B-3 

B.1.4 References 

Compatibility regulations, adopted by the Service in October 2000: 

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

Defenders of Wildlife v. Andrus (Ruby Lake Refuge I). 11 Envtl. Rptr. Case 2098 (D.D.C. 1978), 

p. 873. 

Fish and Wildlife Service. 2011. Kakahai‘a National Wildlife Refuge: Draft Comprehensive 

Conservation Plan and Environmental Assessment. 

House of Representatives Report 105-106 

http://refuges.fws.gov/policyMakers/mandates/HR1420/part1.html 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

B-4 Appendix B: Compatibility Determinations and Appropriate Use Findings 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

 

Appendix B: Compatibility Determinations and Appropriate Use Findings B-5 

B.2 Compatibility Determination for Wildlife Observation, Photography,

and Interpretation

Refuge Name(s): Kakahai‘a National Wildlife Refuge 

 

County and State: Maui County, Hawai‘i

Establishing and Acquisition Authority(ies):

Kakahai‘a NWR was established in 1976 under the authority of the: 

Fish and Wildlife Coordination Act of 1956, as amended (16 U.S.C. 742a – 742j) 

Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1544) 

Refuge Purpose(s):

“...to conserve (A) fish and wildlife which, are listed as endangered or threatened species... or (B) 

Plants ...” 16 U.S.C. 1534, Endangered Species Act of 1973.

National Wildlife Refuge System 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.”

Description of Use(s): 

The National Wildlife Refuge System Administration Act of 1966 (16 U.S.C. 668dd-668ee), as 

amended by the National Wildlife Refuge System Improvement Act of 1997 identifies wildlife 

observation, photography, and interpretation among wildlife-dependent public uses which, when 

compatible with the purpose(s) of the refuge, are priority public uses and receive special 

consideration in planning for and management of the Refuge System. 

Wildlife observation, photography, and interpretation are non-consumptive, wildlife-dependent 

public uses with similar elements and so are considered together in this CD. Kakahai‘a NWR is 

unstaffed and not currently open to the public except for special events, under Special Use Permits 

(SUP), and individual group requests. Viewing of waterbirds and wetland habitats is accessible from 

the Refuge entrance road and from Old and New Pond levees. Wildlife observation opportunities are 

limited with the loss of water and open habitat leading to absence of waterbirds, except for the 2-4 

days after a rainstorm. 

If wetlands are restored and the endangered and migratory birds are once again using the Refuge for 

foraging, nesting, and resting, there will be an increased opportunities for wildlife observation, 

photography, and interpretation. With the addition of on-site staff under our preferred management 

strategy, construction of an elevated viewing platform and kiosk along the entrance road outside the 

fence has been proposed. Wildlife observation from the Refuge entrance road would provide yearround opportunities because it is not reliant on whether or not staff members are on-site or the 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

B-6 Appendix B: Compatibility Determinations and Appropriate Use Findings 

Refuge gates are open. With construction of a viewing platform, Kakahai‘a NWR would have one 

primary area where the public could engage in wildlife observation and photography. From this 

vantage point, the public could see into all of New Pond and portions of Old Pond. The viewing 

platform would be located 50-75 feet from New Pond and the fence would provide a physical barrier 

for protecting waterbirds and minimize disturbance. In the event birds are nesting on the western 

edge of New Pond and negative impacts are observed, the area would be closed. 

Both New Pond and Old Pond levees serve as trails to view wetland habitats. Because of the 

relatively small size of the ponds (5.5 and 15 acres, respectively), it may be necessary to block 

portions of the southeastern levees to minimize disturbance to birds. Although this means the ponds 

cannot be circumvented, it will retain quality wildlife observation opportunities for the majority of 

viewers. Maintenance of the earthen levees is an on-going activity that will require pest plant 

control and periodic repairs to retain their integrity and provide the public unobstructed and safe 

access. Compaction of the levees will allow wheelchair accessibility, as well. 

Disturbance to endangered and migratory waterbirds will be monitored and areas will be closed from 

public access, particularly during ae‘o and ‘alae ke‘oke‘o nesting. If necessary, the Refuge would be 

closed to all access during these critical periods. 

Future opportunities to develop interpretive panels, particularly on the outside of the fence along the 

entrance road are planned. These panels will introduce the wetlands and endangered waterbirds 

present on the Refuge and will enhance public viewing opportunities. 

Availability of Resources:

Category and Itemization

One-time

$

Annual

$/yr

Administration and management: $0 $2,600

Maintenance: $0 $5,400

Monitoring costs: $0 $3,600

Special equipment, facilities, or improvements: $50,000 $2,600

Offsetting revenues: $0 $0

The Refuge Complex has a minimal budget and staff to manage this use, at this time. Although 

wildlife observation, photography, and interpretation on the Refuge require minimal resources when 

the public is on their own, the absence of staff on Moloka‘i limits accessibility. Future wetland 

restoration, additional staff, and volunteer recruitment will enable an expansion of these programs.

Anticipated Impacts of the Use(s): 

There are different types of human-wildlife conflicts (direct or indirect; human-caused or wildlifecaused) that occur when people are in nature. Public use activities at Kakahai‘a NWR would be 

planned and designed to eliminate direct conflicts (e.g., harassment, direct mortality) and minimize 

indirect conflicts (disturbance as defined by a change in the wildlife’s behavior). Wildlife 

observation, photography, and interpreation is identified as a priority use because of the importance 

of sharing what is being protected and the opportunities to increase visitors’ awareness, appreciation 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

 

Appendix B: Compatibility Determinations and Appropriate Use Findings B-7 

for, and stewardship towards the natural resources. A balance needs to be attained in order for 

human activities to coexist with waterbird needs. This can be accomplished by minimizing activities 

and designing public use facilities that allow birds to engage in their natural behaviors. 

Human activities on unconfined trails may result in direct effects on wildlife through harassment, a 

form of disturbance that can cause physiological effects or varying levels of behavioral modifications 

(Smith and Hunt 1995). Various studies have shown that the severity of the effects depends upon the 

distance to the disturbance and its duration, frequency, predictability, and visibility to wildlife 

(Knight and Cole 1991). The variables found to have the greatest influence on wildlife behavior are: 

a) the distance from the animal to the disturbance and b) duration of the disturbance. In addition, the 

type of movement by people elicits different responses; for examples, birds show a greater flight 

response from a human moving quickly and unpredictably (erratic) than to humans moving slowly 

following a distinct path. Excessive human noises, especially with erratic behavior, are also a factor 

in bird disturbance by humans. 

Short-term impacts: Kakahai‘a NWR has been closed to the public except for special events 

and/or under SUP since its inception as a national wildlife refuge. If the wetland is restored and the 

endangered species return to the Refuge, the presence of people observing or photographing wildlife 

has potential to cause short-term disturbance to wildlife. Large non-wildlife-dependent groups are 

not the norm; however, if excessive disturbance is observed, the Refuge would close the area and 

mitigate through group education and interpretation. In order to minimize negative impacts to

endangered waterbirds, it's important that the groups understand the causes of their endangerment, 

such as habitat loss and human disturbance. By explaining the negative consequences of disturbance, 

we strive to change the behavior and instill positive stewardship ethics. 

The potential impact of human activities to endangered waterbirds is well documented at Keālia 

Pond NWR on Maui where strategies to minimize those impacts are implemented. These same 

restrictions apply to Kakahai‘a NWR whereby areas are closed during critical periods in the 

waterbirds life history (e.g., nesting and brood rearing). New Pond and the adjacent grassland are 

open and unimpeded by vegetation allowing public to view birds from a distance without 

disturbance. Activities are limited to pedestrian access only. Vehicles and bikes are not allowed on 

the levees and pets (even on leashes) are not permitted. With additional on-island staff, the Refuge 

would be able to monitor public use, identify when birds are most susceptible to human disturbance, 

and implement measures to eliminate and/or minimize the human activities for the benefit of 

endangered waterbirds. 

Long-term impacts: Wildlife disturbance can be minimized when planning the restoration of 

wetlands or facilities. Refuge staff will evaluate potential disturbance in future planning and design 

of public use facilities such as the proposed viewing platform. During nesting season, trails are 

closed to public access to eliminate disturbance to waterbirds incubating eggs and rearing young. In 

the past, this closure has occurred during ‘alae ke‘oke‘o nesting period as needed; however, this is not 

necessary every year, likely due to the location of their nests (in emergent vegetation) hidden from 

view. In addition, during brood rearing, the young have the capability of swimming into the 

vegetation away from people. In contrast, closures are more typical during ae‘o nesting season 

(May-June) because of the location of their nests (on the ground, adjacent to water) and the chicks’ 

limited ability to escape. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

B-8 Appendix B: Compatibility Determinations and Appropriate Use Findings 

Restoration of the ponds will be based on the needs of endangered waterbirds; therefore, specific 

planning and design of non-wetland areas will simultaneously occur to evaluate options for public 

access that minimizes impacts to waterbirds yet increases the quality of the viewing experiences. 

Areas outside of the perimeter levees for both ponds will be planted with native species to provide a 

barrier between the public and waterbirds. This natural blind will minimize disturbance to waterbirds 

and provide quality viewing opportunities by the public. A viewing platform along the entrance road 

will be designed to provide a higher vantage point for the viewing public but not at such a height that 

would minimize their exposure from the waterbirds’ vantage point. This type of planning is expected 

to minimize short- and long-term effects to waterbirds. 

Refuge staff will continue to monitor public use activities and evaluate potential disturbance in future 

planning and design of public use facilities. Future planning will also include methods to provide a 

high-quality experience to the public. 

Cumulative impacts: The level and type of use from activities described in this CD is not expected 

to result in any significant cumulative impacts. 

Public Review and Comment: 

Public review and comments were solicited in conjunction with release of the draft Kakahai‘a NWR 

draft CCP/ EA (2011) in order to comply with the National Environmental Policy Act and Service 

policy. This CD was released as integral part of the CCP and received the same level of public 

review and comments as the CCP, in accordance with Service planning policy. 

Determination: (check one below) 

 Use is Not Compatible 

 ✓ Use is Compatible With Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

Visitors under SUP are required to stay on trails and designated paths throughout the year; 

Use of proposed viewing platform would be restricted to daylight hours only; 

Pets are not allowed; 

Regulations and information will be available to the public through a Refuge brochure and 

interpretive kiosk; 

Directional, informational, and interpretive signs will be available and maintained to help 

educate the public on minimizing wildlife and habitat disturbance; 

Human use levels will be monitored by Refuge staff during SUP programs, as well as 

periodic site visits; and 

Temporary closure of trails will occur during waterbird nesting season, if necessary, to 

eliminate disturbance.
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

 

Appendix B: Compatibility Determinations and Appropriate Use Findings B-9 

Justification: 

Wildlife observation, photography, and interpretation are three of the six wildlife-dependent 

recreational uses of the Refuge System identified in the Administration Act as legitimate and 

appropriate priority general public uses. The six uses — hunting, fishing, wildlife observation and 

photography, and EE and interpretation — are to receive enhanced consideration in planning and 

management over all other general public uses of the Refuge System. Wildlife observation, 

photography, and interpretation receive enhanced consideration in the CCP process, and are 

considered priority public uses when determined compatible. Although these activities can result in 

disturbance to wildlife, these activities would occur on a small percentage of Refuge acres. The 

relatively limited number of individual plants and animals expected to be adversely affected will not 

cause wildlife populations to materially decline, the physiological condition and production of 

Refuge species will not be impaired, their behavior and normal activity patterns will not be altered 

dramatically, and their overall welfare will not be negatively impacted. Thus, allowing wildlife 

observation, photography, and interpretation to occur under the stipulations described above will not 

materially detract or interfere with the purpose for which the Refuge was established or the Refuge 

System mission. Wildlife observation, photography, and interpretation programs complement the 

Refuge purpose, vision, and goals, and help fulfill the mission of the Refuge System. 

Mandatory Reevaluation Date:

September 

 2026 Mandatory 15-year reevaluation date (for wildlife-dependent public uses) 

 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 

✓ Environmental Assessment and Finding of No Significant Impact 

 Environmental Impact Statement and Record of Decision 

Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

 

Appendix B: Compatibility Determinations and Appropriate Use Findings B-11

B.3 Compatibility Determination for Environmental Education

Refuge Name(s): Kakahai‘a National Wildlife Refuge 

 

County and State: Maui County, Hawai‘i

Establishing and Acquisition Authority(ies):

Kakahai‘a NWR was established in 1976 under the authority of the: 

Fish and Wildlife Coordination Act of 1956, as amended (16 U.S.C. 742a – 742j) 

Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1544) 

Refuge Purpose(s):

“...to conserve (A) fish and wildlife which, are listed as endangered or threatened species... or (B) 

Plants ...” 16 U.S.C. 1534, Endangered Species Act of 1973.

National Wildlife Refuge System 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.” 

Description of Use(s): 

The National Wildlife Refuge System Administration Act of 1966 (16 U.S.C. 668dd-668ee), as 

amended by the National Wildlife Refuge System Improvement Act of 1997 identifies environmental 

education among wildlife-dependent public uses which, when compatible with the purpose(s) of the 

refuge, are priority public uses and receive special consideration in planning for and management of 

the Refuge System. 

Environmental education is a non-consumptive, wildlife-dependent public use. Environmental 

education programs at Kakahai‘a NWR are conducted by nongovernmental organizations (Nēnē O 

Moloka‘i, Maui Digital Bus) under a Special Use Permit (SUP). All outdoor classes are coordinated 

to not impact the Refuge’s management programs (e.g., maintenance). Nēnē O Moloka‘i is a nonprofit corporation that emphasizes education through community involvement. They have a 

longstanding relationship with the Refuge and SUP approvals since 1997 to access the Refuge to host 

school and other EE groups. The organization provides educational and volunteer opportunities to 

groups that include a well-rounded overview of the different types of wetland habitats on Moloka‘i 

with emphasis on the endangered waterbirds. Learning activities include wetland ecology, biology, 

cultural history, and the life history of endangered waterbirds, as well as volunteer efforts. A 

majority of the organization’s participants are from the local community and although the number of 

students is less than 100 each year, the value in exposing students to Moloka‘i’s natural resources is 

invaluable. 

As the Refuge currently has a degraded wetland without suitable habitat for endangered waterbirds, 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

B-12 Appendix B: Compatibility Determinations and Appropriate Use Findings 

EE programs lately have been focusing on pest species and how they impact wetlands. Kakahai‘a 

NWR is used as a comparison to functional wetlands on the Island such as ‘Ōhi‘apilo Pond Bird 

Sanctuary, Kaunakakai Wastewater Reclamation Facility, and Kōheo Wetland.

The Maui Digital Bus is in the process of developing and implementing their program on Moloka‘i 

and once it is operational, the program is expected to reach more students. Both programs have 

quality EE programs that have shown to be successful on Maui. With the addition of a new visitor 

services manager for the Maui NWR Complex, Refuge-specific EE programs will be developed for 

local school groups of varying age levels. Volunteers would be recruited and trained to assist with 

the program. All EE programs will have a stewardship component where students would participate 

in a wetland restoration project. 

Availability of Resources:

Category and Itemization

One-time

$

Annual

$/yr

Administration and management: $0 $1,000

Maintenance: $0 $900

Materials: $0 $1,000

Special equipment, facilities, or improvements: $0 $1,000

Offsetting revenues: $0 $

Minimal costs of EE will be covered by Refuge visitor services funding provided in the annual 

Refuge budget. 

Anticipated Impacts of the Use(s):

Short-term impacts: The number of school groups and students visiting the Refuge may vary from 

year to year but this variation is already considered in the guidelines and structure established for the 

program. There is a limit of 25 people per group and no more than 5 group visits are allowed 

annually, during the non-breeding season only. To date, the highest number of students to visit in one 

year was 35. A Refuge staff member or Refuge-approved volunteer docent accompanies each group 

under SUP to monitor the activity. The primary impacts come from temporary disturbance to 

individual animals (primarily birds) due to the presence and activity of the students as they are 

guided around the wetlands. The animals may flush, swim away, or seek cover and hide in 

vegetation. These impacts are mitigated by restricting the days, maximum number of students, and 

routes that EE activities take place. This allows the students to participate in the EE experience while 

causing temporary disturbance over the smallest area and to the fewest birds. 

Because we anticipate 5 visitor groups of no more than 25 people each will visit the Refuge over the 

course of the school year and EE groups will only be allowed access to designated levee trails during 

non-breeding seasons, wildlife will have ample quantities of sanctuary for feeding and resting. 

Thus, allowing EE to occur under the described program will not result in any significant short-term 

impacts. 

Long-term impacts: The current, ongoing EE program covered by this CD will not cause any 

significant long-term impacts. The EE program is expected to increase with restoration of the 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

 

Appendix B: Compatibility Determinations and Appropriate Use Findings B-13

wetlands, recruitment of a Visitor Services Manager, and development of a formal program designed 

to meet Hawai‘i Department of Education curriculum requirements. A thorough evaluation of the 

impacts to existing resources and capability of the site to withstand additional groups will be 

reviewed in a Visitor Services Plan within 5 years. 

Cumulative impacts: This EE program has been conducted in the current manner since 1997 and no 

cumulative impacts to wildlife resources on the Refuge have been observed or are anticipated. 

 

Public Review and Comment:

Public review and comments were solicited in conjunction with release of the draft CCP/EA (2011) 

in order to comply with the NEPA and Service policy. 

Determination: (check one below) 

 Use is Not Compatible 

 ✓ Use is Compatible with Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

User stipulations: 

Groups are required to stay on trails and designated paths throughout the year; 

Use is restricted to daylight hours only; 

Groups are limited to 25, including students, chaperones, and teachers; 

Special Use Permits will only be issued during non-breeding seasons and when no nesting is 

occurring; 

Use levels will be monitored by Refuge staff and/or approved volunteer docents; and 

Refuge staff periodically participates with the group to ensure compliance with Refuge’s 

conditions and accuracy of information is maintained. 

Justification: 

Environmental education is one of the six wildlife-dependent recreational uses of the Refuge System 

as stated in the Improvement Act. The six uses — hunting, fishing, wildlife observation and 

photography, and EE and interpretation — are to receive enhanced consideration in planning and 

management over all other general public uses of the Refuge System. Environmental education 

receives enhanced consideration in the CCP process, and is considered a priority public use when 

determined compatible. By limiting the size of groups, providing structured activities, and providing 

closed areas for wildlife away from human disturbance, this program would limit disturbance to 

wildlife. There is a sufficient amount of undisturbed habitat available to Refuge wildlife for escape 

and cover, and wildlife populations will find sufficient food resources and resting places. The 

relatively limited number of individual plants and animals expected to be adversely affected will not 

cause wildlife populations to materially decline, the physiological condition and production of 

Refuge species will not be impaired, their behavior and normal activity patterns will not be altered 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

B-14 Appendix B: Compatibility Determinations and Appropriate Use Findings 

dramatically, and their overall welfare will not be negatively impacted. Thus, allowing EE to occur 

under the stipulations described above will not materially detract or interfere with the purposes for 

which the Refuge was established or the Refuge System mission. Environmental education 

contributes to the mission of the Refuge System by providing wildlife-dependent educational benefits 

to visitors. Environmental education programs on Refuge lands are inherently valuable to the Service 

because they will enhance the public’s knowledge of the Refuge and its resources, and expand the

number of visitors who engage in the Refuge’s conservation mission. 

Mandatory Reevaluation Date: (provide month and year for “allowed” uses only)

September 

 2026 Mandatory 15-year reevaluation date (for wildlife-dependent public uses) 

 Mandatory 10-year reevaluation date (for 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 

 ✓ Environmental Assessment and Finding of No Significant Impact 

 Environmental Impact Statement and Record of Decision

Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

B-16 Appendix B: Compatibility Determinations and Appropriate Use Findings 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

 

Appendix B: Compatibility Determinations and Appropriate Use Findings B-17

B.4 Compatibility Determination for Research, Scientific Collecting,

and Surveys

CD Terminology: 

Research: Planned, organized, and systematic investigation of a scientific nature. 

Scientific collecting: Gathering of Refuge natural resources or cultural artifacts for scientific 

purposes. 

Surveys: Scientific inventory or monitoring. 

Refuge Name(s): Kakahai‘a National Wildlife Refuge

 

County and State: Maui County, Hawai‘i

Establishing and Acquisition Authority(ies): 

Kakahai‘a NWR was established in 1976 under the authority of the: 

Fish and Wildlife Coordination Act of 1956, as amended (16 U.S.C. 742a – 742j) 

Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1544) 

Refuge Purpose(s): 

“...to conserve (A) fish and wildlife which, are listed as endangered or threatened species... or (B) 

Plants ...” 16 U.S.C. 1534, Endangered Species Act of 1973.

National Wildlife Refuge System 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.” 

Description of Use(s): 

The Refuge staff receives periodic requests from non-Service entities (e.g., universities, State 

agencies, other Federal agencies, nongovernmental organizations) to conduct research, scientific 

collecting, and surveys on Refuge lands. These project requests can involve a wide range of natural 

and cultural resources as well as public use management issues, including basic absence/presence 

surveys, collection of new species for identification, habitat use and life-history requirements for 

specific species/species groups, practical methods for habitat restoration, extent and severity of 

environmental contaminants, techniques to control or eradicate pest species, effects of climate 

change on environmental conditions and associated habitat/wildlife response, identification and 

analyses of paleontological specimens, modeling wildlife populations, and assessing response of 

habitat/wildlife to disturbance from public uses. Projects may be species-specific, Refuge-specific, or 

evaluate the relative contribution of the Refuge to larger landscapes (e.g., eco-region, region, flyway, 

national, international) issues and trends. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

B-18 Appendix B: Compatibility Determinations and Appropriate Use Findings 

The Service’s research and management and Appropriate Refuge Uses (603 FW1.10D(4)) 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. 

Availability of Resources: 

Refuge staff responsibilities for projects by non-Service entities will primarily be limited to the 

following: review of proposals, prepare Special Use Permits (SUP) and other compliance documents 

(e.g., Section 7 of the ESA, Section 106 of the National Historic Preservation Act), and monitor 

project implementation to ensure that impacts and conflicts remain within acceptable levels 

(compatibility) over time. Additional administrative support, logistical and operational support may 

also be provided depending on each specific request. Estimated costs for one-time (e.g., prepare 

SUP) and annually recurring tasks by Refuge staff and other Service employees will be determined 

for each project. Sufficient funding in the general operating budget of the Refuge must 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 will be clearly stated in the SUP. 

The Refuge has the following staffing and funding to administratively support and monitor research 

that is currently taking place on Refuge lands (see table below). Any substantial increase in the 

number of projects would create a need for additional resources to oversee the administration and 

monitoring of the investigators and their projects. Any substantial additional costs above those 

itemized below may result in finding a project not compatible unless expenses are offset by the 

investigator(s), sponsoring agency, or organization. 

Category and Itemization One-time

$

Annual 

$/yr

Administration and management $0 $4,000

Maintenance $0 $0

Monitoring $0 $6,900

Special equipment, facilities, or improvement $0 $0

Offsetting revenues $0 $0

Anticipated Impacts of the Use: 

Use of the Refuge(s) to conduct research, scientific collecting, and surveys will generally provide 

information that would benefit fish, wildlife, plants, and their habitats. Scientific findings gained 

through these projects provide important information regarding life-history needs of species and 

species groups as well as identify or refine management actions to achieve resource management 

objectives in Refuge management plans (especially CCPs). Reducing uncertainty regarding wildlife 

and habitat responses to management actions in order to achieve desired outcomes reflected in 

resource management objectives is essential for adaptive management in accordance with 

Department of Interior (DOI) policy 522 DM 1. 

If project methods impact or conflict with Refuge-specific resources, priority wildlife-dependent 

public uses, other high-priority research, and Refuge habitat and wildlife management programs, then 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

 

Appendix B: Compatibility Determinations and Appropriate Use Findings B-19

it must be clearly demonstrated that the scientific findings will contribute to resource management 

and that the project cannot be conducted off-Refuge for the project to be compatible. The 

investigator(s) must identify methods/strategies in advance required to eliminate or minimize the 

potential impact(s) and conflict(s). If unacceptable impacts cannot be avoided, then the project will 

not be compatible. 

Impacts would be project- and site-specific, where they will vary depending upon nature and scope 

of the field work. Data collection techniques will generally have minimal animal mortality or 

disturbance, habitat destruction, no introduction of contaminants, or no introduction of nonnative 

species. In contrast, projects involving the collection of biotic samples (plants or animals) or 

requiring intensive ground-based data or sample collection will have short-term impacts. To reduce 

impacts, the minimum number of samples (e.g., water, soils, vegetative litter, plants, 

macroinvertebrates, vertebrates) will be collected for identification and/or experimentation and 

statistical analysis. Where possible, researchers would coordinate and share collections to reduce 

sampling needed for multiple projects. 

Investigator(s) obtaining required State and Federal collecting permits will also ensure minimal 

impacts to fish, wildlife, plants, and their habitats. If, after incorporating the above strategies, the 

project results in long-term or cumulative effects, it will not be deemed compatible. A Section 7 

consultation under the ESA will be required for activities that may affect a federally listed species 

and/or critical habitat. Only projects that have no effect or will result in not likely to adversely affect 

determinations will be considered compatible. 

Spread of pest plants and/or pathogens is possible from ground disturbance and/or transportation of 

project equipment and personnel, but it will be minimized or eliminated by requiring proper cleaning 

of investigator equipment and clothing as well as quarantine methods, where necessary. If after all 

practical measures are taken, an unacceptable spread of pest species is anticipated to occur, then the 

project will be found not compatible without a restoration or mitigation plan. 

Localized and temporary effects may occur from vegetation trampling, collecting of soil and plant 

samples, or trapping and handling of wildlife. Impacts may also occur from infrastructure necessary 

to support a project (e.g., permanent transects or plot markers, exclosure devices, monitoring 

equipment, solar panels to power unattended monitoring equipment). Some level of disturbance is 

expected with these projects, especially if investigator(s) enter areas closed to the public and collect 

samples or handle wildlife. However, wildlife disturbance (including altered behavior) will usually 

be localized and temporary in nature. Where long-term or cumulative unacceptable effects cannot be 

avoided, the project will not be found compatible. Project proposals will be reviewed by Refuge staff 

and others, as needed, to assess the potential impacts (short-term, long-term, and cumulative) relative 

to benefits of the investigation to Refuge management issues and understanding of natural systems. 

At least 6 months before initiation of field work (unless an exception is made by prior approval of the 

refuge manager), project investigator(s) must submit a detailed proposal. Project proposals will be 

reviewed by Refuge staff and others, as needed, to assess the potential impacts (short-term, longterm, and cumulative) relative to benefits of the investigation to Refuge management issues and 

understanding of natural systems. This assessment will form the primary basis for allowing or 

denying a specific project. Projects that result in unacceptable Refuge impacts will not be found 

compatible. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

B-20 Appendix B: Compatibility Determinations and Appropriate Use Findings 

If the proposal is approved, then the refuge manager will issue a SUP(s) with required stipulations 

(terms and conditions) of the project to avoid and/or minimize potential impacts to Refuge resources 

as well as conflicts with other public-use activities and Refuge field management operations. After 

approval, projects also are monitored during implementation to ensure impacts and conflicts remain 

within acceptable levels based upon documented stipulations. 

Projects that are not covered by the CCP will require additional NEPA documentation. 

Public Review and Comment: 

Public review and comments were solicited in conjunction with release of the draft CCP/EA (2011) 

in order to comply with the NEPA and Service policy. 

Determination: (check one below) 

 The use is not compatible. 

 ✓ The use is compatible with the following stipulations. 

Stipulations Necessary to Ensure Compatibility: 

Each project will require an SUP. Annual or other short-term SUPs are preferred; however, some 

permits will be a longer period, if needed, to allow completion of the project. All SUPs will have a 

definite termination date. Permit renewals will be subject to Refuge Manager review and approval 

based on timely submission of and content in progress reports, compliance with SUP stipulations, 

and required permits. Other stipulations and provisions would include the following:

Projects will adhere to scientifically defensible protocols for data collection, where available 

and applicable. 

Investigators must possess appropriate and comply with conditions of State and Federal 

permits for their projects. 

If unacceptable impacts to natural resources or conflicts arise or are documented by the 

Refuge staff, then the refuge manager can suspend, modify conditions of, or terminate an ongoing project already permitted by SUP(s) on a Refuge. 

Progress reports are required at least annually for multiple-year projects. 

Final reports are due 1 year after completion of the project unless negotiated otherwise with 

the refuge manager. 

Continuation of existing projects will require approval by the refuge manager. 

The Refuge staff will be given the opportunity to review draft manuscript(s) from the project 

before being submitted to a scientific journal(s) for consideration of publication. 

The Refuge staff will be provided with copies (including, but not limited to: reprints, videos, 

and CD) of all publications resulting from a Refuge project. 

The Refuge staff will be provided with copies of raw data (preferably electronic database 

format) at the conclusion of the project. 

Upon completion of the project or annually, all equipment and markers (unless required for 

long-term projects), must be removed and sites must restored to the refuge manager’s 

satisfaction. Conditions for clean-up and removal of equipment and physical markers will be 

stipulated in the SUP(s). 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

 

Appendix B: Compatibility Determinations and Appropriate Use Findings B-21

All samples collected on Refuge lands are the property of the Service even while in the 

possession of the investigator(s). Any future work with previously collected samples not 

clearly identified in the project proposal will require submission of a subsequent proposal for 

review and approval. In addition, a new SUP will be required for additional project work. For 

samples or specimens to be stored at other facilities (e.g., museums), a memorandum of 

understanding will be necessary. 

Sampling equipment as well as investigator(s) clothing and vehicles (e.g., ATV, boats) will 

be thoroughly cleaned (free of dirt and plant material) before being allowed for use on 

Refuge lands and/or waters to prevent the introduction and/or spread of pests. 

The Service, specific Refuge unit, names of Refuge staff and other Service personnel who 

supported or contributed to the project will be appropriately cited and acknowledged in all 

written and oral presentations resulting from projects on Refuge lands. 

At any time, Refuge staff may accompany investigator(s) in the field. 

Investigator(s) and support staff will follow all Refuge-specific regulations that specify 

access and travel on the Refuge. 

Justification: 

Research, scientific collecting, and surveys on Refuge lands are inherently valuable to the Service 

because they will expand scientific information available for resource management decisions. In 

addition, only projects that directly or indirectly contribute to the enhancement, protection, use, 

preservation, and management of Refuge wildlife populations and their habitats generally will be 

authorized on Refuge lands. In many cases, if it were not for the Refuge staff providing access to 

Refuge lands and waters along with some support, the research project would likely not occur and 

less scientific information would be available to the Service to aid in managing and conserving 

resources. By allowing the use to occur under the stipulations described above, it is anticipated that 

wildlife species that could be disturbed during the use would find sufficient food resources and 

resting places so their abundance and use will not be measurably lessened on the Refuge. 

Additionally, it is anticipated that monitoring, as needed, will prevent unacceptable or irreversible 

impacts to fish, wildlife, plants, and their habitats. The combination of stipulations identified above 

and conditions included in any SUP(s) will ensure that proposed projects contribute to the 

enhancement, protection, conservation, and management of native wildlife populations and their 

habitats on the Refuge. As a result, these projects will not materially interfere with or detract from 

fulfilling Refuge purpose(s); contributing to the mission of the Service and Refuge System; and 

maintaining the biological integrity, diversity, and environmental health of the Refuge. 

Mandatory Re-evaluation Date: (provide month and year for “allowed” uses only)

 Mandatory 15-year re-evaluation date (wildlife-dependent public uses) 

September 

 2021 Mandatory 10-year re-evaluation date (uses other than wildlife-dependent public uses) 

NEPA Compliance for Refuge Use Decision: (check one below) 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

B-22 Appendix B: Compatibility Determinations and Appropriate Use Findings 

 Categorical Exclusion without Environmental Action Statement 

 Categorical Exclusion and Environmental Action Statement 

 ✓ Environmental Assessment and Finding of No Significant Impact 

 Environmental Impact Statement and Record of Decision


Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

 

Appendix B: Compatibility Determinations and Appropriate Use Findings B-25

FWS Form 3-2319 

A compatibility determination is required before the use may be allowed. 02/06 

Attachment 1: Appropriate Uses Justification 

Date: May 5, 2011 

Refuge: Kakahai‘a National Wildlife Refuge (Refuge) 

Project: Research, Scientific Collecting, and Surveys 

Summary: The Refuge receives requests to conduct scientific research on Refuge lands and waters. 

Research applicants must submit a proposal that would outline: 1) objectives of the study; 

2) justification for the study; 3) detailed methodology and schedule; 4) potential impacts on Refuge 

wildlife and/or habitat, including disturbance (short-term and long-term), injury, or mortality; 

5) personnel required; 6) costs to Refuge, if any; and 7) end products (i.e., reports, publications). 

Research proposals would be reviewed by Refuge staff, Regional Office Branch of Refuge Biology, 

and others as appropriate prior to the Refuge issuing a SUP. Projects will not be open-ended, and, at 

a minimum, will be reviewed annually. 

For each of the findings listed on FWS Form 3-2319, a justification has been provided below: 

a. Do we have jurisdiction over the use? 

Some or all of the proposed activities would take place within Refuge boundaries. The Refuge has 

jurisdiction over those research projects that are sited within Refuge boundaries. 

b. Does the use comply with applicable laws and regulations (Federal, State, tribal, and local)? 

Proposed research activities should comply with all applicable laws and regulations. Any restrictions 

or qualifications that are required to comply with law and regulations would be specified in the SUP. 

The State of Hawai‘i DLNR was invited on two occasions to participate on core planning teams, but 

declined due to insufficient staffing. However, as this Appropriate Use Justification does not propose 

a significant deviation from the status quo, and no comments on this topic were received from the 

State during the comment period, we believe additional coordination is not necessary. 

c. Is the use consistent with applicable Executive orders and Department and Service policies? 

Through the review of individual projects, the Refuge would ensure that they are consistent with 

applicable policies, especially Research on Service Lands Policy (803 FW 1). 

d. Is the use consistent with public safety? 

Through individual project review, the Refuge will ensure that each project is consistent with public 

safety. If necessary, stipulations to ensure public safety will be included in the project’s SUP. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

B-26 Appendix B: Compatibility Determinations and Appropriate Use Findings 

e. Is the use consistent with goals and objectives in an approved management plan or other 

document? 

Research activities are approved in instances where they can provide meaningful data that may 

contribute to Refuge management and public appreciation of natural resources. 

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 approved the use and touted the benefits of research, scientific 

collecting, and surveys on national wildlife refuges. 

g. Is the use manageable within available budget and staff? 

The Refuge receives <10 requests per year for this activity, and it is manageable with available 

budget and staff. 

h. Will this be manageable in the future within existing resources? 

The proposed activity at current levels would be manageable in the future with the existing resources. 

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? 

The proposed use is beneficial to the Refuge’s natural and cultural resources because the types of 

research projects approved are those that have the distinct likelihood to help achieve Refuge purposes 

by providing information useful for the management of trust resources and may contribute to the 

public’s understanding and appreciation of natural and/or cultural resources.

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? 

The Refuge will ensure that the research activities will not impair existing or future wildlifedependent recreational use of the Refuge during individual project review, prior to issuing a SUP for 

the project. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix C: Plan Implementation and Costs C-1 

Appendix C. Plan Implementation and Costs 

C.1 Administration

Kakahai‘a NWR is administered as part of the Maui National Wildlife Refuge Complex (Complex). 

The Complex also includes the Keālia Pond NWR comprised of a large natural wetland with 

associated flats, constructed ponds, and forested habitats on the south-central coast of Maui. The 

Complex office is located at Keālia Pond NWR, where all administrative functions for Kakahai‘a 

NWR are based. The current staff of five is stationed on Maui and has shared responsibilities for the 

operation and maintenance of Kakahai‘a NWR. The Service is currently in the process of 

establishing Molokini Islet as an overlay refuge unit of the Keālia Pond NWR that will also have 

oversight from the Complex office. 

C.2 Staffing

All staff positions share responsibilities and duties for two refuges, in addition to Molokini Islet Unit, 

once established; e.g., no staff is assigned or performs duties only on specific refuges within the 

Complex. Due to projected Complex-wide workload, priorities, Federal budget, logistics, and 

supervisory considerations, this arrangement is expected to continue. However, when more 

personnel are added to the Complex (e.g., a Maintenance Worker or Equipment Operator), staff may 

be assigned more specific duties on individual refuges. 

At a minimum, the Maintenance Worker makes trips every other week to check on the property and 

perform habitat and maintenance duties. Unfortunately, the only airline flying direct between Maui 

and Moloka‘i has limited flights and frequent delays or cancellations resulting in relatively short days 

to accomplish work. In addition, this limited number of days on Moloka‘i makes it difficult to 

coordinate community work projects. Periodically, the entire Refuge staff travel to Moloka‘i to 

assist with large projects (e.g., fence construction). 

The Service’s National Staffing Model generated eight positions for the Complex, one of which 

would have primary responsibility for field work at Kakahai‘a NWR. The existing, core-funded 

staff is five. The additional staffing would provide increased capacity to conduct biological 

inventory and monitoring, and research; increased visitor opportunities; EE and interpretation of 

Refuge resources; collaborative efforts with other Federal, State, and County agencies in addition to 

non-government organizations; improved maintenance facilities; and increase invasive species 

control efforts for the benefit of endangered waterbirds. 

A new visitor center is currently under construction for Keālia Pond NWR. It was not planned when 

staffing models were finalized; therefore, the need for staff to operate and maintain the new building 

was not included. Increased staffing with specific responsibilities in the development of the visitor, 

volunteer, and education programs, and maintaining the new facility is necessary to provide quality 

customer service and ensure safe conditions for visitors. Although these staff would be stationed on 

Maui, their responsibilities would extend to the public use programs at Kakahai‘a NWR, including 

volunteer, EE, and interpretation programs.
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

C-2 Appendix C. Plan Implementation and Costs 

Current and Necessary Permanent Full-time Staffing for Maui NWR Complex, including 

Kakahai‘a NWR (Current staff positions are highlighted) 

Staff Position Salary Rating

Identified in 

National Staffing 

Model

HQ/VC

Project Leader GS-12 

Deputy Project Leader GS-9/11 

Wildlife Biologist GS-11 

Biological Science Technician GS-5/7 

Visitor Services Manager GS-7/9/11  

Refuge Ranger GS-5/7 

Administrative Support Assistant GS-7 

Maintenance Worker (Habitat & Facilities) WG-8 

Maintenance Worker (Facilities) WG-7/8 

Equipment Operator WG-6/7 

Law Enforcement Officer GS-7/9 

C.3 Refuge Funding and Budget Requests

Successful implementation of the CCP relies on our ability to secure funding, personnel, 

infrastructure, and other resources to accomplish the actions identified. Full implementation of the 

actions and strategies in this CCP will incur costs including staffing, construction projects, and 

individual resource program expansions. In addition to annual budget allocations, funding can be 

received through special funding sources and programs geared toward specific resource issues/needs. 

Examples include grants or project specific funding for endangered species, pest species control, 

wetlands, coastal habitats, climate change, and Service initiatives (Youth in the Great Outdoors, 

Connecting People with Nature). 

Currently there are two sources of funding that will enable Kakahai‘a NWR to carry out its plans 

under the CCP, including additional staff; these sources includes the Refuge Operating Needs System 

(RONS) and Service Asset Maintenance Management System (SAMMS) for repair/renovation of 

existing facilities. The RONS and SAMMS systems will be updated with new/additional projects 

that are approved under this CCP. 

Project Dates Cost Estimate

Grub and dredge Old Pond 2012 $ 846,000

Restore Old Pond levees with 4:1 slopes 2012 $ 554,976

Rehabilitate 0.9 mile boundary fence 2012 $ 40,000

Restore New Pond 2013 $ 376,000

Grub and restore New Pond Levees 2013 $ 650,000

Relocate and replace Old Pond water control structure 2015 $ 12,600

Construct viewing platform and interpretive kiosk 2016 $ 40,000

Interpretive signs for fence 2017 $ 10,000
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix C: Plan Implementation and Costs C-3 

C. 4 Stepdown Plans

The CCP is one of several plans necessary for Refuge management. The CCP provides guidance in 

the form of goals, objectives, and strategies for several Refuge program areas may lack some of the 

specifics needed for implementation. Stepdown management plans will be developed for individual 

program areas within approximately 5 years after CCP completion. Stepdown plans, where feasible, 

will be prepared to cover all Refuges in the Complex. All stepdown plans require appropriate NEPA 

compliance and implementation may require additional permits. Stepdown plans for the Refuge 

follow in the table below. Project-specific plans, with appropriate NEPA compliance, may be 

prepared outside of these stepdown plans. 

Stepdown Management Plan Status

Completed

Habitat Management Plan

Integrated Pest Management Plan

Fire Management Plan

Occupational Safety and Health Plan

Scheduled

Inventory and Monitoring Plan

Visitor Services Plan

Archeological and Cultural Investigation

 

Studies Identified in CCP Strategies

Topographical mapping 

Comprehensive Water Resources Assessment

Soils and Geomorphological Assessment

Climate Change Monitoring Plan

Date

2011 (CCP meets requirements for HMP)

2011 (Prepared concurrently with CCP, Appendix E)

2004 (Appendix G)

2009

Initiated by 2013

Initiated by 2013

Initiated by 2013

2012

2012

2012

2012-2014
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

C-4 Appendix C. Plan Implementation and Costs 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix D. Wilderness Review D-1 

Appendix D. Wilderness Review for Kakahai‘a NWR

General Information on Wilderness Reviews 

Wilderness review is the process used to determine whether or not to recommend lands or waters in 

the Refuge System to the Congress for designation as wilderness. Planning policy for the Refuge 

System (602 FW 3) mandates conducting wilderness reviews every 15 years through the CCP 

process. 

The wilderness review process has three phases: inventory, study, and recommendation. After first 

identifying lands and waters that meet the minimum criteria for wilderness, the resulting wilderness 

study areas (WSA) are further evaluated to determine if they merit recommendation from the Service 

to the Secretary of the Interior for inclusion in the National Wilderness Preservation System 

(NWPS). Areas recommended for designation are managed to maintain wilderness character in 

accordance with management goals, objectives, and strategies outlined in the final CCP until 

Congress makes a decision or the CCP is amended to modify or remove the wilderness proposal. A 

brief discussion of wilderness inventory, study, and recommendation follows. 

Wilderness Inventory 

The wilderness inventory consists of identifying areas that minimally meet the requirements for 

wilderness as defined in the Wilderness Act of 1964 (Wilderness Act). Wilderness is defined as an 

area which: 

Has at least 5,000 acres of land or is of sufficient size as to make practicable its 

preservation and use in an unimpaired condition, or be capable of restoration to wilderness 

character through appropriate management at the time of review, or be a roadless island; 

Generally appears to have been affected primarily by the forces of nature, with the imprint 

of man’s work substantially unnoticeable; 

Has outstanding opportunities for solitude or a primitive and unconfined type of recreation; 

and 

May also contain ecological, geological, or other features of scientific, educational, scenic, 

or historic value. These features and values, though desirable, are not necessary for an area 

to qualify as a wilderness.

Wilderness Study 

During the study phase, lands and waters qualifying for wilderness as a result of the inventory are 

studied to analyze values (ecological, recreational, cultural, spiritual), resources (wildlife, water, 

vegetation, minerals, soils), and uses (habitat management, public use) within the area. The findings 

of the study help determine whether to recommend the area for designation as wilderness. 

Wilderness Recommendation 

Once a wilderness study determines that a WSA meets the requirements for inclusion in the NWPS, a 

wilderness study report that presents the results of the wilderness review, accompanied by a 

Legislative Environmental Impact Statement (LEIS), is prepared. The wilderness study report and 

LEIS that support wilderness designation are then transmitted through the Secretary of the Interior to 

the President of the United States, and ultimately to the Congress for approval. 

The following section summarizes the inventory phase of the wilderness review for Kakahai‘a NWR. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

D-2 Appendix D. Wilderness Review 

Wilderness Inventory 

The wilderness inventory is a broad look at the planning area to identify WSAs. These WSAs are 

roadless areas within refuge boundaries, including submerged lands and their associated water 

column, that meet the minimum criteria for wilderness identified in Sect. 2. (c) of the Wilderness 

Act. A WSA must meet the minimum size criteria (or be a roadless island), appear natural, and 

provide outstanding opportunities for solitude or primitive recreation. Other supplemental values are 

evaluated, but not required. 

Evaluation of Size Criteria for Roadless Areas, Roadless Islands, and Submergent Lands and 

Associated Water Column 

Identification of roadless areas, roadless islands, and submerged lands and associated water column, 

required gathering land status maps, land use and road inventory data, satellite imagery, aerial 

photographs, and personal observations of areas within refuge boundaries. “Roadless” refers to the 

absence of improved roads suitable and maintained for public travel by means of motorized vehicles 

primarily intended for highway use. 

Inventory units meet the size criteria for a WSA if any one of the following standards applies: 

An area with over 5,000 contiguous acres. State and private lands are not included in making 

this acreage determination. 

A roadless island of any size. A roadless island is defined as an area surrounded by 

permanent waters or 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. 

Kakahai‘a NWR is a highly modified 44.6-acre parcel of land which does not meet the size criteria. 

Evaluation of the Naturalness Criteria 

A WSA must meet the naturalness criteria. Section 2.(c) of the Wilderness Act defines wilderness as 

an area that “...generally appears to have been affected primarily by the forces of nature with the 

imprint of man’s work substantially unnoticeable.” The area must appear natural to the average 

visitor rather than “pristine.” The presence of ecologically accurate, historical landscape conditions is 

not required. An area may include some manmade features and human impacts provided they are 

substantially unnoticeable in the unit as a whole. Human-caused hazards, such as the presence of 

unexploded ordnance from military activity, and the physical impacts of refuge management 

facilities and activities are also considered in the evaluation of the naturalness criteria. An area may 

not be considered unnatural in appearance solely on the basis of “sights and sounds” of human 

impacts and activities outside the boundary of the unit. The cumulative effects of these factors were 

considered in the evaluation of naturalness for each wilderness inventory unit. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix D. Wilderness Review D-3 

In the wilderness inventory, specific manmade features and other human impacts need to be 

identified that affect the overall apparent naturalness of the tract. The following factors were primary 

considerations in evaluating the naturalness of the Refuge: 

Storage container, shed, refuge boundary sign; 

Pumps, earthen dikes, water control structures; and 

Fences, gates, parking lots, and roadways. 

Kakahai‘a NWR is bounded and bisected by State-owned and Refuge-owned roadways maintained 

for travel by passenger vehicles. This inventory unit contains numerous earthen dikes, ditches, a 

perimeter roadway, water control structures, and storage sheds. Although the shed and storage 

container could be moved, the other infrastructure cannot as it is absolutely required to achieve the 

refuge’s purpose. It does not meet the naturalness criteria. 

Evaluation of Outstanding Opportunities for Solitude or Primitive and Unconfined Recreation 

In addition to meeting the size and naturalness criteria, a WSA must provide outstanding 

opportunities for solitude or primitive recreation. The area does not have to possess outstanding 

opportunities for both solitude and primitive and unconfined recreation, and does not need to have 

outstanding opportunities on every acre. Further, an area does not have to be open to public use and 

access to qualify under these criteria. Congress has designated a number of wilderness areas in the 

NWPS that are closed to public access to protect ecological resource values. 

Opportunities for solitude refers 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 do not require developed facilities or mechanical transport. These primitive recreation 

activities may provide opportunities to experience challenge and risk, self-reliance, and adventure. 

These two opportunity “elements” are not well defined by the Wilderness Act but in most cases can 

be expected to occur together. However, an outstanding opportunity for solitude may be present in an 

area offering only limited primitive recreation potential. Conversely, an area may be so attractive for 

recreation use that experiencing solitude is not an option. 

This inventory unit does not offer opportunities for solitude or primitive and unconfined recreation. 

Recreational and educational activities are only conducted in group settings, and only allowed as 

staff-guided activities. 

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.” Based upon the findings of the required 

components for WSA designation, supplemental values were not evaluated. 

Findings 

Kakahai‘a NWR does not meet the minimum criteria for consideration as WSA (see Table D.1, next 

page). 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

D-4 Appendix D. Wilderness Review 

Table D.1 Wilderness Inventory Summary

Wilderness Inventory Summary

Kakahai‘a NWR (44.6 acres)

Required Components

(1) Has at least 5,000 ac of land or is of sufficient 

size to make practicable its preservation and use in 

an unconfined condition, or is a roadless island.

No. Does not contain 5,000 acres, is not a 

roadless island, and is not practicable to 

manage as a wilderness.

(2) Generally appears to have been affected 

primarily by the forces of nature, with the imprint 

of man’s work substantially unnoticeable.

No. Landscape is highly modified and 

actively managed.

(3a) Has outstanding opportunities for solitude. No. Refuge is immediately adjacent to a 

State highway and residential development.

(3b) Has outstanding opportunities for a primitive 

and unconfined type of recreation.

No. Recreation is highly regulated and 

requires staff presence. 

Other Components

(4) Contains ecological, geological or other 

features of scientific, educational, scenic, or 

historic value.

Not evaluated.

Summary

Parcel qualifies as a wilderness study area (meets 

criteria 1, 2 & 3a or 3b).

No.
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-1 

Appendix E. Integrated Pest Management Program, 

Kakahai‘a NWR

1.0 Background 

Integrated Pest Management (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. The 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 longterm 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, are selected that are feasible, efficacious, and most protective of 

nontarget resources, including native species (fish, wildlife, and plants), and Service personnel, 

Service authorized agents, volunteers, and the public. Staff time and available funding will be 

considered when determining feasibility/practicality of various treatments. 

Our IPM techniques to address pests are presented as CCP strategies prescriptions (see Section 2.0 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. 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. Moreover, it does not address effects of mosquito control with 

pesticides (larvicides, pupacides, or adulticides) based upon identified human health threats and 

presence of disease-carrying mosquitoes in sufficient numbers from monitoring conducted on a 

Refuge. However, the basic framework to assess potential effects to Refuge biological resources and 

environmental quality from aerial application of pesticides or use of insecticides for mosquito 

management would be similar to the process described in this Appendix for ground-based treatments 

of other pesticides. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

E-2 Appendix E. Integrated Pest Management Program 

2.0 Pest Management Laws and Policies 

In accordance with 517 DM and 569 FW 1(Integrated Pest Management), plant, invertebrate, and 

vertebrate pests on units of the National Wildlife Refuge System can be controlled to assure 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: 

National Wildlife Refuge System Administration Act of 1966, as amended (16 USC 668dd668ee); 

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 nonnative 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 purposes 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; 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-3 

Control nonnative (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 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). 

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 will 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]). 

3.0 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 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. 

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 reintroductions by various mechanisms including vehicles and personnel. 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 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

E-4 Appendix E. Integrated Pest Management Program 

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 of 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. 

The following would be methods to prevent the introduction and/or spread of pests on Refuge 

lands: 

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, Refuge staff would begin project activities in un-infested areas 

before working in pest-infested areas. 

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. 

Refuge staff would determine the need for, and when appropriate, identify sanitation sites 

where equipment can be cleaned of pests. Where possible, 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. Refuge staff would remove mud, dirt, and plant parts from project 

equipment before moving it into a project area. 

Refuge staff would clean all equipment, before leaving the project site, if operating in 

areas infested with pests. Refuge staff would determine the need for, and when 

appropriate, identify sanitation sites where equipment can be cleaned. 

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). 

Refuge staff would evaluate options, including closure, to restrict the traffic on sites with 

on-going restoration of desired vegetation. 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. Refuge staff would use native 

material, where appropriate and feasible. Refuge staff would use certified weed-free or 

weed-seed-free hay or straw where certified materials are reasonably available. 

Refuge staff would provide information, training and appropriate pest identification 

materials to Refuge staffs, permit holders, and recreational visitors. Refuge staff would 

educate them about pest identification, biology, impacts, and effective prevention 

measures. 

Refuge staff would inspect borrow material for invasive plants prior to use and transport 

onto and/or within Refuge lands. 

Refuge staff would consider invasive plants in planning for road maintenance activities. 

Refuge staff would restrict off road travel to designated routes. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-5 

The following would be methods to prevent the introduction and/or spread of pests into Refuge 

waters: 

Refuge staff would inspect boats (including air boats), trailers, and other boating 

equipment and, where possible, remove any visible plants, animals, or mud before 

leaving any waters or boat launching facilities. Where possible, staff would drain water 

from motor, live well, bilge, and transom wells while on land before leaving the site. 

If possible, 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. 

These prevention methods to minimize/eliminate the introduction and/or spread of pests were 

taken verbatim or slightly modified from Appendix E of US Forest Service (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 plants 

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, , prescribed burning (facilitate revegetation, increase herbicide efficacy, and 

remove litter to assist in emergence of desirable species), planting or seeding desirable species to 

shade or out-compete invasive plants, applying fertilizer to enhance desirable vegetation, 

irrigation, 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 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

E-6 Appendix E. Integrated Pest Management Program 

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 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 will 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 (most common group). 

Often it is assumed that biological control would address many if not most of these pest 

problems. 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 Hawai‘i Department of Agriculture (HDOA) has a highly successful bio-control program for 

the erythrina gall wasp which has resulted in the rebounding of the native wiliwili trees. In June 

2010, HDOA began another biological control program that releases a tiny parasitic insect to 

control the stinging Nettle Caterpillar. The release of Brazilian scale to slow the growth rate and 

spread of strawberry guava has recently been proposed to give Hawai‘i’s native plants a chance 

for survival, protect the ability of the forests to provide water, and provide better protection for 

agricultural crops from the fruit flies that breed in the overabundance of strawberry guava fruit. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-7 

Due to the success of Hawai‘i’s biocontrol programs, the State has become a leader in the world 

on the use of biological control to fight invasive pests. 

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 U.S. 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 biocontrol agents from 

another State. Form 526 may be obtained by writing: 

USDA-APHIS-PPQ 

 Biological Assessment and Taxonomic Support 

 4700 River Road, Unit 113 

 Riverdale, MD 20737 

or 

through the internet at URL address: 

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 nonindigenous 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 569 FW 1. In addition, 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: 

Release only approved biological control agents, 

Use the most effective agents, 

Document releases, and 

Monitor for impact to the target pest, nontarget species and the environment. 

Biological control agents formulated as pesticide products and registered by the EPA (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 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

E-8 Appendix E. Integrated Pest Management Program 

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. 

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 (BLM), U.S. Forest Service, National Park Service, 

U.S. 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) 

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. 

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 BMPs to 

reduce/eliminate potential effects to nontarget 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. PUP records 

would provide a detailed, time-, site-, and target-specific description of the proposed use of 

pesticides on 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 nontarget 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 nonchemical controls also are highly 

effective, where practical, because pesticide resistant organisms can be removed from the site. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-9 

Cost may not be the primary factor in selecting a pesticide for use on the 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 

Shelly 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 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. 

Predator Control. The predator management plan for Kakahai‘a NWR is implemented to reduce 

depredation of endangered waterbirds. Control measures would include indirect, non-lethal and 

lethal techniques in addition to prevention and direct control measures that would have minimal 

effects on the human environment. 

Indirect Measures at Kakahai‘a NWR will include installation of a perimeter predator proof 

fence (Alternative C). In the absence of this fence, dense vegetation will remain to discourage 

visitors from disturbing endangered waterbirds and nesting areas will be temporarily closed to 

access. Cattle egret roost trees will be mechanically removed or treated with herbicides. 

Most cats and dogs will be removed by cage traps and transported to an animal shelter. Other 

predators (mongooses, rats) would be controlled by cage traps or humane lethal means. Control 

measures will minimize loss of non-target native wildlife. Except for nuisance alien species, all 

uninjured non-target species captured will be released near the site of capture or at a suitable 

location at the discretion of Refuge staff. 

Most of Kakahai‘a NWR is closed to the public and posted. In public access areas (Kakahai‘a

Beach Park), rodenticides would be placed in tamper-resistant bait boxes and the area signed. 

Egret control by firearms will occur when the Refuge is closed to the public. 

Direct Measures include a range of predator management equipment and methods . The 

preferred control method will be cage traps for dogs and cats. Mongooses and rodents will be 

controlled by a combination of cage traps, lethal traps, and rodenticides. Direct control of cattle 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

E-10 Appendix E. Integrated Pest Management Program 

egrets would be with firearms. In rare instances, a TimmsTM kill trap (a type of snap trap) or 

padded leghold trap would be used on cats that avoid cage traps. All cage traps will be checked 

every 48 hours or less. Trapping will occur seasonally just prior to the ae‘o nesting season 

through the end of the breeding/chick rearing period (April-September). Spot trapping may 

occur when signs of depredation of endangered species are observed outside the nesting season. 

Predator monitoring will occur throughout the year by direct observations, tracks, tracking 

tunnels, and trail cameras. Cage trapped dogs and cats will be transported to a local animal 

shelter. Any cage trapped birds will be released at the trap site. Live trapped mongooses will the 

euthanized using approved humane methods. 

4.0 Priorities for Treatments 

The magnitude (number, distribution, and sizes of infestations) for pest problems is too extensive and 

beyond the available capital resources to effectively address during any single field season. To 

manage pests in 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), System 

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 uninfested 

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 of high priority for management, other pest 

species known to cause substantial ecological impact would also be considered. For example, shortspined kiawe may not be listed by a State as noxious, but it can greatly alter fire regimes in the 

coastal dryland shrub habitat resulting in large monotypic stands that displace native bunch grasses, 

forbs, and shrubs. Pest control would likely require a multi-year commitment from 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. 

5.0 Best Management Practices 

Best Management Practices (BMPs) can minimize or eliminate possible effects associated with 

pesticide usage to nontarget 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 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-11

Policy (517 DM 1) and the Service Pest Management Policy and Responsibilities (30 AM 12), 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 targetand site-specific factors and time-specific environmental conditions. Although not listed below, the 

most important BMP to eliminate/reduce potential impacts to nontarget resources would be an IPM 

approach to prevent, control, eradicate, and contain pests. 

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. 

Refuge staff would empty, triple rinsed pesticide containers that can be recycled at local 

herbicide container collections. 

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 contaminanation. 

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 Refuge spill 

respond plan. 

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 BLM certification to safely and 

effectively conduct these activities on Refuge lands and waters. 

Refuge staff would comply with all Federal, State, and local pesticide use laws and regulations as 

well as Service pesticide-related policies. For example, 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 Pesticide Use Proposal (PUPs) for 

each pesticide, determining the target pest, appropriate mix rate(s), PPE, and other requirements 

listed on the pesticide label. 

A 1’ no-spray buffer from the water’s edge would be used, where applicable, and 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. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

E-12 Appendix E. Integrated Pest Management Program 

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<7mph and preferably 3-5 mph) and 

consistent direction wind conditions with moderate temperatures (typically <85 oF). 

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 nontarget 

areas. 

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 nontoxic 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 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. 

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. 

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, ATV, tractor) would be thoroughly cleaned and PPE would 

be removed/disposed of on-site by applicators after treatments to eliminate the potential spread of 

pests to un-infested areas. 

6.0 Safety 

6.1 Personal Protective Equipment 

All applicators would wear the specific personal protective equipment (PPE) identified on the 

pesticide label. The appropriate PPE will 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 NIOSH-approved respirator. Because exposure to 

concentrated product is usually greatest during mixing, extra care should be taken while preparing 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-13

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 will 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. 

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. Refuge staff would also 

notify appropriate private property owners of an intended application, including any private 

individuals have requested notification. Special efforts would be made to contact nearby individuals 

who are beekeepers or who have expressed chemical sensitivities. 

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 1 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 FW7.7A, 

“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 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 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. 

6.4 Certification and Supervision of Pesticide Applicators 

Appropriate Refuge staff or approved volunteers handling, mixing, and/or applying or directly 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

E-14 Appendix E. Integrated Pest Management Program 

supervising others engaged in pesticide use activities would be trained and State or federally licensed 

to apply pesticides to Refuge lands or waters. In accordance with 242 FW7.18A and 569 FW 1, 

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. 

6.5 Record Keeping 

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. 

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 30 AM 12 and 7 RM 14, PUPs would be required for the following: 

Uses of pesticides on lands and facilities owned or managed by the Service, including properties 

managed by Service personnel as a result of the Food Security Act of 1985; 

Service projects by non-Service personnel on Service owned or controlled lands and facilities and 

other pest management activities that would be conducted by Service personnel; and 

Where the Service would be responsible or provides funds for pest management identified in 

protective covenants, easements, contracts, or agreements off Service lands. 

In accordance with Service guidelines (Director’s memo [December 12, 2007]), 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 (see 

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. 

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. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-15

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, nongovernment 

applicators including cooperators and their pest management service providers with Service 

permission. For clarification, pesticide means all insecticides, insect and plant growth regulators, 

dessicants, 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) 

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 data regarding characteristics (attributes) of pest infestations (e.g., area, 

perimeter, degree of infestation-density, % 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. 

7.0 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 nonlisted 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 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 4.0) for habitat management and facilities 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

E-16 Appendix E. Integrated Pest Management Program 

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. 

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 dose-response 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 US Environmental Protection Agency (EPA). Assumptions for these risk 

assessments are presented in Section 6.2.3. 

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 (Section 7.6). 

Table E.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

1Measurement endpoints typically include a variety of reproductive parameters (e.g., number of 

eggs, number of offspring, eggshell thickness, and number of cracked eggs). 

2Measurement endpoints for early life stage/life cycle typically include embryo hatch rates, time 

to hatch, growth, and time to swim-up. 

3Measurement 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. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-17

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 (EPA 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 NWRS. 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 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 (1998 [Table 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: acutelisted 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 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 effect” individuals (listed species) and it 

would not pose an unacceptable risk for adverse effects to populations (nonlisted species) for each 

taxonomic group (Table E.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. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

E-18 Appendix E. Integrated Pest Management Program 

Table E.2. Presumption of unacceptable risk for birds, fish, and mammals (US EPA 1998). 

Risk Presumption Level of Concern

Listed Species Nonlisted 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

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 

nontarget 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 1993a). 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). 

7.2.1.1 Terrestrial exposure 

The estimated environmental concentration (ECC) for exposure to terrestrial wildlife would be 

quantified using an EPA screening-level approach (EPA 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. 

7.2.1.1.1 Terrestrial-spray application 

For spray applications, exposure would be determined using the Kanaga nomogram method (EPA 

2005a, EPA 2004, Pfleeger et al. 1996) through the EPA’s Terrestrial Residue Exposure model (TREX) version 1.2.3 (EPA 2005b). To estimate the maximum (initial) pesticide residue on short 

grass (<8”m 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 worse-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 TREX by default, but body weights of other organisms (Table e.3) would be entered manually. The 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-19

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 TREX Kanaga nomogram would be used as an EEC for calculation of RQs. This approach would 

yield a conservative estimate of ecological risk. 

Table E.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 (1000 g) 1.000 

Mallard 1.082 

Ring-necked pheasant 1.135 

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 (ai) 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 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. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

E-20 Appendix E. Integrated Pest Management Program 

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 EPA Level of Concerns (EPA 

1998). The T-REX version 1.2.3 (EPA 2005b) contains a submodel which automates Kanaga 

exposure calculations for granular pesticides and treated seed. 

The following formulas will 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/1000 ft. row)(% a.i.)(1000 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, seeds are unincorporated. 

mg a.i./ft.

2 

= [(lbs. product/1000 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. 

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 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 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. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-21

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 

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’of the high water mark of 

aquatic habitats for habitat management treatments; whereas, no-spray buffers (≥25’) would be used 

for facilities maintenance treatments. 

Table E.4. Estimated Environmental Concentrations (ppb) of pesticides in aquatic habitats (1’ 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 1103.5

4.00 1471.4

5.00 1839

6.00 2207

7.00 2575

8.00 2943

9.00 3311

10.00 3678

7.2.1.2.1 Habitat treatments 

For the worst-case exposure scenario to nontarget aquatic habitats, EECs (Table E. 4) would be 

would be derived from Urban and Cook (1986) that assumes an intentional overspray to an entire, 

nontarget water body (1-foot depth) from a treatment <25’ from the high water mark using the max 

application rate (acid basis [see above]). However, use of BMPs for applying pesticides (see Section 

4.2) would likely minimize/eliminate potential drift to nontarget 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). 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

E-22 Appendix E. Integrated Pest Management Program 

7.2.1.2.2 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 EPA 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’ 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”), fine to medium droplet size, EPA-defined wetland, and a 

≥25-foot distance (buffer) from treated area to water. 

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 BLM , 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-InvPlantEIS.htm) and BLM (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 (US Forest Service 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. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-23

As a basis for completing “Chemical Profiles” for approving or disapproving PUPs, ecological risk 

assessments for the following herbicide and adjuvant uses prepared by the USFS would be 

incorporated by reference: 

2,4-D 

Chlorosulfuron 

Clopyralid 

Dicamba 

Glyphosate 

Imazapic 

Imazapyr 

Metsulfuron methyl 

Picloram 

Sethoxydim 

Sulfometuron methyl 

Triclopyr 

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 BLM would be incorporated by reference: 

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) 

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 EPA ’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. Nontarget 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 (EPA 2004). As a result, this 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

E-24 Appendix E. Integrated Pest Management Program 

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 is 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 will 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-weightedaverage (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 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 is 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 will 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 T-REX 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 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-25

concentration earlier than 21 weeks. The duration of time for calculating TWAs will require 

justification and it will 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, this 

data is 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 (EPA 2004). 

Exposure through incidental ingestion of pesticide contaminated soil is not considered in the 

EPA 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 concentrations in soil compared to food item categories in the Kanaga nomogram 

indicates incidental soil ingestion will 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 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 EPA 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 EPA (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 EPA is 

currently evaluating protocols for modeling inhalation exposure from pesticides including near-
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

E-26 Appendix E. Integrated Pest Management Program 

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 EPA 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 EPA for assessing dermal exposure to pesticides, they will 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 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 speciesspecific. Currently, risk characterization for this exposure mechanism is not available. The EPA 

is actively developing protocols to quantify drinking water exposures from puddles and dew. If 

and when protocols are formally established by the EPA for assessing exposure to pesticides 

through drinking water, these protocols will 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 EPA relies on Fletcher (1994) for setting the assumed pesticide residues in wildlife dietary 

items. The EPA (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 EPA represent a 95th percentile estimate. However, 

research conducted by Pfleeger et al. (1996) indicates EPA residue assumptions for short grass 

was not exceeded. Baehr and Habig (2000) compared EPA residue assumptions with 

distributions of measured pesticide residues for the EPA’s UTAB database. Overall residue 

selection level will tend to overestimate risk characterization. This is particularly evident when 
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Appendix E. Integrated Pest Management Program E-27

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 nontarget 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 affects to nontarget 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 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 
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E-28 Appendix E. Integrated Pest Management Program 

reduced by dilution. In total, these assumptions would lead to a near maximum possible waterborne concentration. However, this assumption would not account for 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 caseby-case basis as available data allow. Nevertheless, because the EPA 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 nontarget 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 may exist at some level contributing to adverse affects to 

nontarget 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. 

EPA 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, EPA 

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. 
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Appendix E. Integrated Pest Management Program E-29

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 EPA (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 EPA 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 nontarget 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 effects (additive or synergistic) from chemical mixtures that typically 

rely upon broadly encompassing assumptions. For example, the US Forest Service (2005) found that 

mixtures of pesticides used in land (forest) management likely would not cause additive or 

synergistic effects to nontarget 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. 
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E-30 Appendix E. Integrated Pest Management Program 

Toxicological information regarding “other ingredients” may be available from sources such as the 

following: 

• TOMES (a proprietary toxicological database including EPA’s IRIS, the Hazardous Substance 

Data Bank, the Registry of Toxic Effects of Chemical Substances [RTECS]). 

• EPA’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 EPA-approved label specifies whether a product can be mixed with one or more pesticides. 

Without product-specific toxicological data, it would not 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. 

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 EPA does not register or approve the labeling of spray adjuvants. 
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Appendix E. Integrated Pest Management Program E-31

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. 

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 run-off or wind; 

Dissolve in water that can be subjected to run-off 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: nonpersistent <30 days, moderately persistent = 30 to 100 days, and persistent >100 

days (Kerle et. al. 1996). Half-life data is 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 is not available, soil half-life data may 

be used. The average or representative half-life value of most important degradation mechanism will 

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. 

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 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

E-32 Appendix E. Integrated Pest Management Program 

(mg/l or ppm). Pesticide with solubility <0.1 ppm are virtually insoluble in water, 100-1000 ppm are 

moderately soluble, and >10,000 ppm highly soluble (US Geological Survey 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 run-off 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 

effects pesticide degradation. 
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Appendix E. Integrated Pest Management Program E-33

Soil pH would influence chemical reactions that occur in the soil which in turn determines 

whether or not a pesticide will 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 welldrained 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 nontarget biota and protecting 

environmental quality. 

Along with soil properties, the potential for a pesticide to affect water quality through run-off 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. 

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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E-34 Appendix E. Integrated Pest Management Program 

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 EPA. 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 is 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 nonlisted species with appropriate BMPs (see Section 

5.0), 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 
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Appendix E. Integrated Pest Management Program E-35

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. 

Pesticide Type: Service personnel would record the type of pesticide for an active ingredient as one 

of the following: herbicide, dessicant, fungicide, fumigant, growth regulator, insecticide, pisicide, 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-to-Know, 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 available is 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 1 in Section 7.1). 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

E-36 Appendix E. Integrated Pest Management Program 

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 1 in Section 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 

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 1 in Section 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 1 in Section 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 1 in Section 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 1 in Section 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 1 in Section 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 1 in Section 7.1). 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-37

Other: For test invertebrate as well as nonvascular 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 EPA 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, type and magnitude of affects 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 1000 ppm, highly soluble >10,000 ppm (US Geological Survey 2000). As pesticide 

Sw increases, there would be greater potential to degrade water quality through run-off 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: 

nonpersistent <30 days, moderately persistent = 30 to 100 days, and persistent >100 days (Kerle et. 

al. 1996). 

Threshold for Approving PUPs: 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

E-38 Appendix E. Integrated Pest Management Program 

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 section to minimize potential surface run-off 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’ and average annual 

precipitation >12”. 

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, 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 is not 

available, soil half-life data would be used in a Chemical Profile. The average or representative halflife 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: nonpersistent <30 days, moderately persistent = 30-100 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 section to minimize potential surface run-off 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’ and average annual 

precipitation >12”. 

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 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-39

water. Based upon the t1⁄2 value, aquatic persistence would be categorized as one of the following: 

nonpersistent <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 section to minimize potential surface run-off 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’ and average annual 

precipitation >12”. 

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 persistence in aquatic habitats also would be categorized as one of the following: 

nonpersistent <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 section to minimize potential surface run-off 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’ and average annual 

precipitation >12”. 

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. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

E-40 Appendix E. Integrated Pest Management Program 

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 section to minimize potential surface run-off 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’ and average annual 

precipitation >12”. 

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 offtarget 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). 

Threshold for Approving PUPs: 

If I ≤1000, then a PUP would be approved without additional BMPs to minimize drift and protect air 

quality. 

If I>1000, 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 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 >85oF.

Use the lowest spray height possible above target canopy. 

Where identified on the pesticide label, soil incorporate 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 >1000 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 (US Geological Survey 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. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-41

If there is a high potential to bioaccumulate in aquatic species (Kow>1000 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 1000, or high >1000 (Calabrese and Baldwin 1993). 

Threshold for Approving PUPs: 

If BAF or BCF≤1000, then a PUP would be approved without additional BMPs. 

If BAF or BCF>1000, 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 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 EPA screening-level approach (EPA 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 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]). 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

E-42 Appendix E. Integrated Pest Management Program 

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”), fine to medium/coarse droplet size, 20 swaths, EPA-defined 

wetland, and 25-foot distance (buffer) from treated area to water. 

See Section 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 EPA’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 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 

EPA (see Table 2 in Section 7.2). If a calculated RQ exceeds an established LOC value (in 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 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 section to reduce potential 

risk to nonlisted 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’ 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: Service personnel would record specific BMPs necessary to 

minimize or eliminate potential effects to nontarget 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. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-43

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 4.0 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, chemical-specific 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, EPA , Washington, DC. 

(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) 

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 BLM , 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, DC. 

(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. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

E-44 Appendix E. Integrated Pest Management Program 

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, DC. 

(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. EPA , Office of Pesticide Programs, Washington, D.C. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-45

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/Biocentration: 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): 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

E-46 Appendix E. Integrated Pest Management Program 

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:

Table CP.1 Pesticide Name 

Trade 

Namea

Treatment 

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/season 

or 

gal/acre/season)

Minimum 

Time 

Between 

Applications 

(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.

bTreatment 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. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-47

7.7 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, PO Box 509, Macon, Missouri. 

ATSDR (Agency for Toxic Substances and Disease Registry) US Department of Health and Human 

Services. 2004. Guidance Manual for the Assessment of Joint Toxic Action of Chemical 

Mixtures. US Department of Health and Human Services, Public Health Service, ATSDR, 

Division of Toxicology. 62 pages plus Appendices. 

Baehr, C.H., and C. Habig. 2000. Statistical evaluation of the UTAB database for use in terrestrial 

nontarget organism risk assessment. 10th Symposium on Environmental Toxicology and Risk 

Assessment, American Society of Testing and Materials. 

Baker, J. and G. Miller. 1999. Understanding and reducing pesticide losses. Extension Publication 

PM 1495, Iowa State University Extension, Ames, Iowa. 6 pages. 

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 pages. 

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, S. Gerould. 1994. Estimates of soil ingestion by wildlife. Journal of 

Wildlife Management 58:375-382. 

Brooks, M.L., D'Antonio, C.M., Richardson, D.M., Grace, J.B., Keeley, J.E. and others. 2004. 

Effects of invasive alien plants on fire regimes. BioScience 54:77-88. 

BLM . 2007. Vegetation treatments using herbicides on BLM Lands in 17 western states 

Programmatic EIS (PEIS). Washington Office, BLM . 

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 pages. 

Calabrese, E.J. and L.A. Baldwin. 1993. Performing Ecological Risk Assessments. Lewis 

Publishers, Chelsea, MI. 

Center, T.D., Frank, J.H., and Dray Jr., F.A. 1997. Biological Control. Strangers in Paradise: Impact 

and Management of Nonindigenous Species in Florida. P.245-263. 

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. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

E-48 Appendix E. Integrated Pest Management Program 

Coombs, E.M., J.K Clark, G.L. Piper, and A.F. Cofrancesco Jr. 2004. Biological control of invasive 

plants in the United States. Oregon State University Press, Corvallis, 467 pages. 

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. 

EXTOXNET. 1993a. 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 pages. 

Fletcher, J.S., J.E. Nellessen, and T.G. Pfleeger. 1994. Literature review and evaluation of the EPA 

food-chain (Kenaga) 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. 4 pages. 

Kerle, E.A., J.J. Jenkins, P.A. Vogue. 1996. Understanding pesticide persistence and mobility for 

groundwater and surface water protection. EM 8561. Oregon State University Extension 

Service. 8 pages. 

Masters, R.A, and R.L. Sheley. 2001. Invited synthesis paper: principles and practices for managing 

rangeland invasive plants. Journal of Range Manage 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, 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. 

Morse, L.E., J.M. Randall, N. Benton, R. Hiebert, and S. Lu. 2004. An Invasive Species Assessment 

Protocol: NatureServe. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-49

Mullin, B.H., L.W. Anderson, J.M. DiTomaso, R.E. Eplee, and K.D. Getsinger. 2000. 

Invasive Plant Species. Issue Paper (13):1-18. 

Oregon State University. 1996. EXTOXNET-Extension Toxicology Network, Pesticide Information 

Profiles. Oregon State University, Corvallis, Oregon. 

Pfleeger, T.G., A. Fong, R. Hayes, H. Ratsch, 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.

Pope, R., J. DeWitt, and J. Ellerhoff. 1999. Pesticide movement: what farmers need to know. 

Extension Publication PAT 36, Iowa State University Extension, Ames, Iowa and Iowa 

Department of Agriculture and Land Stewardship, Des Moines, Iowa. 6 pages. 

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, Washington. 12 pages. 

SDTF 2003 Spray Drift Task Force. 2003. A summary of chemigation application studies. Spray 

Drift Task Force, Macon, Missouri. 

Teske, M.E., S.L. Bird, D.M. Esterly, S.L. Ray, S.G. and Perry. 1997. A User's Guide for 

AgDRIFTTM 1.0: A Tiered Approach for the Assessment of Spray Drift of Pesticides, 

Technical Note No. 95-10, CDI, Princeton, New Jersey. 

Teske, M.E., S.L. Bird, D.M. Esterly, T.B. Curbishley, S.L. Ray, and S.G. Perry. 2002. 

AgDRIFT®: a model for estimating near-field spray drift from aerial applications. 

Environmental Toxicology and Chemistry 21: 659-671. 

Urban, D.J and N.J. Cook. 1986. Ecological risk assessment. EPA 540/9-85-001. EPA , Office of 

Pesticide Programs, Washington D.C. 94 pages. 

EPA . 1990. Laboratory Test Methods of Exposure to Microbial Pest Control Agents by the 

Respiratory Route to Nontarget Avian Species. Environmental Research Laboratory, 

Corvallis, OR. EPA/600/3-90/070. 

EPA . 1998. A Comparative Analysis of Ecological Risks from Pesticides and Their Uses: 

Background, Methodology & Case Study. Environmental Fate & Effects Division, Office of 

Pesticide Programs, U.S. Environmental Protection Agency, Washington, D.C. 105 pages. 

EPA . 2004. Overview of the ecological risk assessment process in the Office of Pesticide 

Programs, EPA : endangered and threatened species effects determinations, Office of 

Pesticide Programs, Washington, DC. 101 pages. 

EPA . 2005a. Technical overview of ecological risk assessment risk characterization; Approaches 

for evaluating exposure; Granular, bait, and treated seed applications. EPA , Office of 

Pesticide Programs, Washington, DC. 

http://www.epa.gov/oppefed1/ecorisk_ders/toera_analysis_exp.htm. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

E-50 Appendix E. Integrated Pest Management Program 

EPA . 2005b. User’s Guide TREX v1.2.3. EPA , Office of Pesticide Programs, Washington, DC. 

22 pages. http://www.epa.gov/oppefed1/models/terrestrial/trex_usersguide.htm. 

U.S. Geological Survey. 2000. Pesticides in stream sediment and aquatic biota – current 

understanding of distribution and major influences. USGS Fact Sheet 092-00, US Geological 

Survey, Sacramento, California. 4 pages. 

U.S. Forest Service. 2005. Pacific Northwest Region Invasive Plant Program 

Preventing and Managing Invasive Plants Final Environmental Impact Statement. 359 pages. 

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 

pages. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-1 

WILDLAND FIRE MANAGEMENT PLAN 

KAKAHAI„A NATIONAL WILDLIFE REFUGE 

2004
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-2 Appendix F. Wildland Fire Management Plan 2004 

2004 WILDLAND FIRE MANAGEMENT PLAN 

KAKAHAI„A NATIONAL WILDLIFE REFUGE 

Prepared: 

Glynnis L. Nakai, Refuge Manager Date 

Maui National Wildlife Refuge Complex 

Concurred: 

Jerry Leinecke, Project Leader Date 

Hawaiian and Pacific Islands National Wildlife Refuge Complex 

Concurred: 

Pamela Ensley, Regional Fire Management Coordinator Date 

Pacific Region, U.S. Fish and Wildlife Service 

Approved: 

David B. Allen, Regional Director Date 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-3 

TABLE OF CONTENTS 

LIST OF FIGURES ...................................................................................... Error! Bookmark not defined.

LIST OF TABLES ........................................................................................ Error! Bookmark not defined.

INTRODUCTION ....................................................................................................................................... 6

COMPLIANCE WITH USFWS POLICY ............................................................................................... 7

Refuge Purpose ............................................................................................................................................. 7

Refuge Goals ................................................................................................................................................. 7

FIRE MANAGEMENT OBJECTIVES .................................................................................................... 9

DESCRIPTION OF REFUGE ................................................................................................................. 10

General Description .................................................................................................................................... 10

Climate ........................................................................................................................................................ 10

Vegetation ................................................................................................................................................... 10

Fish and Wildlife......................................................................................................................................... 10

Threatened and Endangered Species ........................................................................................................... 11

Cultural Resources ...................................................................................................................................... 11

Physical Resources ...................................................................................................................................... 11

Structures and Facilities .............................................................................................................................. 12

Public Access .............................................................................................................................................. 12

WILDLAND FIRE MANAGEMENT SITUATION .............................................................................14

Historic Role of Fire ................................................................................................................................... 14

Pre-settlement Fires ....................................................................................................................................14

Post-settlement Fire History ....................................................................................................................... 14

Prescribed Fire History ............................................................................................................................... 14

Responsibilities ........................................................................................................................................... 14

Refuge Manager ..........................................................................................................................................14

Biologist ...................................................................................................................................................... 15

Zone Fire Management Officer................................................................................................................... 15

Incident Commander ................................................................................................................................... 15

Resource Advisor ........................................................................................................................................ 15

Interagency Operations ............................................................................................................................... 16

Protection of Sensitive Resources ............................................................................................................... 17

WILDLAND FIRE SUPPRESSION ACTIVITIES ............................................................................... 19

Fire Management Strategies ....................................................................................................................... 19

Preparedness ............................................................................................................................................... 19

Historical Weather Analysis ....................................................................................................................... 19

Fire Prevention ............................................................................................................................................ 20

Hazard Reduction for Structure Protection ................................................................................................. 20

Staffing Priority Levels ............................................................................................................................... 20

Training ....................................................................................................................................................... 20

Supplies and Equipment ............................................................................................................................. 21

Detection ..................................................................................................................................................... 21

Communications ......................................................................................................................................... 21
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-4 Appendix F. Wildland Fire Management Plan 2004 

Pre-Attack Plan ........................................................................................................................................... 21

Fire Management Units ............................................................................................................................... 21

Fuels and Fire Behavior .............................................................................................................................. 21

Fuel Types and Fire Behavior ..................................................................................................................... 21

Fire Effects .................................................................................................................................................. 23

Suppression Tactics ....................................................................................................................................23

Suppression Conditions .............................................................................................................................. 23

Wildland Fire Situation Analysis ................................................................................................................ 24

Aircraft Operations ..................................................................................................................................... 25

Burned Area Emergency Stabilization and Rehabilitation ......................................................................... 25

Policy and Implementation Guidance ......................................................................................................... 25

Compliance ................................................................................................................................................. 25

Required Reporting ..................................................................................................................................... 25

Fire Investigation ........................................................................................................................................ 25

HAZARD FUEL REDUCTION .............................................................................................................. 27

Hazard Fuel Reduction Strategies ............................................................................................................... 27

Pile Burning Guidelines .............................................................................................................................. 27

Pile Burn Plan ............................................................................................................................................. 27

Pile Burning Strategies and Personnel ........................................................................................................ 28

Monitoring and Evaluation ......................................................................................................................... 28

Required Reports ........................................................................................................................................29

AIR QUALITY / SMOKE MANAGEMENT GUIDELINES .............................................................. 30

FIRE RESEARCH .................................................................................................................................... 30

PUBLIC SAFETY ..................................................................................................................................... 31

PUBLIC INFORMATION AND EDUCATION .................................................................................... 31

FIRE CRITIQUES AND ANNUAL PLAN REVIEW .......................................................................... 32

Fire Critiques .............................................................................................................................................. 32

Annual Fire Summary Report ..................................................................................................................... 32

Annual Fire Management Plan Review ...................................................................................................... 32

CONSULTATION AND COORDINATION ......................................................................................... 32

APPENDICES ........................................................................................................................................... 33

Appendix A: References Cited .................................................................................................. 33

Appendix B: Definitions ........................................................................................................... 34

Appendix C: Fire Dispatch Plan ................................................................................................ 37

Appendix D: NEPA Compliance ............................................................................................... 41

Appendix E: ESA Section 7 Compliance .................................................................................. 43

Appendix F: Request for Cultural Resource Compliance ......................................................... 46

Appendix G: Interagency Agreements ...................................................................................... 48

Appendix H: Pile Burn Plan Template ...................................................................................... 49

Appendix I: Delegation of Authority ....................................................................................... 58

Appendix J: Wildland Fire Situation Analysis ......................................................................... 59
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-5 

LIST OF FIGURES 

Figure 1. Kakahaia National Wildlife Refuge............................................................................................ 13

Figure 2. Fire Response Zones for the Island of Maui ............................................................................... 17

LIST OF TABLES 

Table 1. Threatened and Endangered Species found at Kakahaia NWR ................................................... 11

Table 2. Habitat types and fuel models on Kakahaia NWR ...................................................................... 22

Table 3. Backing fire behavior predictions for Kakahaia NWR in Fuel Models 1 and 3 .......................... 22

Table 4. Kakahaia NWR Wildland Fire Suppression Guidelines. ............................................................. 24

Table 5. Maui National Wildlife Refuge Complex Staff. .......................................................................... 40

Table 6. Landowners adjacent to Kakahaia NWR ..................................................................................... 40
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-6 Appendix F. Wildland Fire Management Plan 2004 

INTRODUCTION 

This document will establish a Fire Management Plan for Kahahaia National Wildlife Refuge (NWR), of 

the Maui NWR Complex. This plan will meet the requirements of the National Environmental Policy Act 

(NEPA), the Endangered Species Act (ESA) and the National Historic Preservation Act (NHPA). 

Compliance with NEPA was met through a Categorical Exclusion and associated Environmental Action 

Statement (Appendix D). For ESA Section 7 compliance, informal consultation with Ecological Services 

led to a “May Affect, Not Likely to Adversely Affect” determination (Appendix E). Compliance with the 

NHPA will be accomplished at the project level through submission of a Request for Cultural Resources 

Compliance form (Appendix F) to the Regional Archaeologist. 

This plan is written as an operational guide for managing the refuge‟s wildland fire and prescribed fire 

programs. It defines levels of protection needed to provide for safety, protect facilities and resources, and 

restore and perpetuate natural processes, given current understanding of the complex relationships in 

natural ecosystems. It is written to comply with a service-wide requirement that refuges with burnable 

vegetation develop a fire management plan (620 DM 1). 

This plan will outline a program of suppression of all wildland fires and pile burning (as a limited form of 

prescribed fire). These piles will be generated from habitat enhancement and maintenance activities 

covered within the refuge‟s ESA compliance documentation.

There is no dedicated fire management staff on the refuge. Fire Management oversight is provided by the 

Regional Office located in Portland. Day-to-day fire management responsibilities are provided by the 

Refuge Manager located onsite. Suppression of wildland and structural fires on the refuge will be 

provided by Maui County Fire Department, Keonakakai Station, based on County of Maui emergency 

policy. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-7 

COMPLIANCE WITH USFWS POLICY 

Kakahaia National Wildlife Refuge was established in 1976 to provide habitat for endangered Hawaiian 

waterbirds, and migratory waterfowl and shorebirds. The endangered resident species on the 44.6-acre 

wetland include the Hawaiian stilt (Himantopus mexicanus knudseni), Hawaiian coot (Fulica alai), and 

possibly the Hawaiian duck (Anas wyvilliana).

This plan meets NEPA / NHPA compliance and will be implemented in cooperation with the Endangered 

Species Act of 1973, as amended, and will take appropriate action to identify and protect from adverse 

effects on any rare, threatened, or endangered species. Compliance with NEPA was met through a 

Categorical Exclusion and associated Environmental Action Statement (Appendix D). For ESA Section 7 

compliance, informal consultation with Ecological Services led to May Affect, Not Likely to Adversely 

Affect determination (Appendix E). Compliance with the NHPA will be accomplished at the project level 

through submission of a Request for Cultural Resources Compliance form (Appendix F) to the Regional 

Archaeologist. 

At this time, no Master Plan or Comprehensive Conservation Plan (CCP) exists for the Refuge. 

Development of a CCP for the entire complex is scheduled to begin in 2006. The Refuge purpose and 

goals can be found in the Maui National Wildlife Refuge Complex‟s Refuge Management Information 

System, and are as follows: 

Refuge Purpose 

“to conserve (A) fish or wildlife which are listed as endangered species or threatened species...or 

(B) plants.” 16 U.S.C. § 1534 (Endangered Species Act of 1973).

Refuge Goals 

Endangered Species: Promote the conservation of endangered species, especially native 

Hawaiian coot and Hawaiian stilt through healthy functioning of this wetland floodplain. 

Habitat: Optimize water levels for maximum habitat size and value for endangered, resident, 

and migrating waterfowl and shorebirds while reducing the growth and reproduction of 

problematical exotic species. 

Visitor Use: Expand understanding and appreciation of the environment through wildlifeoriented educational opportunities. Provide opportunities for quality, wildlife-dependent 

recreation, education, and research to enhance public appreciation, understanding, and enjoyment 

of refuge wildlife and habitats. 

Habitat Restoration: Restore and maintain the diversity and abundance of native species 

naturally occurring on the Refuge. 

Authority and guidance for implementing this plan are found in: 

Protection Act of September 20, 1922 (42 Stat. 857; 16 U.S.C.594): authorizes the Secretary of 

the Interior to protect from fire, lands under the jurisdiction of the Department directly or in 

cooperation with other Federal agencies, states, or owners of timber. 

Economy Act of June 30, 1932: authorizes contracts for services with other Federal agencies. 

Reciprocal Fire Protection Act of May 27, 1955 (69 Stat. 66, 67; 42 U.S.C. 1856, 1856a and b): 

authorizes reciprocal fire protection agreements with any fire organization for mutual aid with or 

without reimbursement and allows for emergency assistance in the vicinity of agency lands in 

suppressing fires when no agreement exists. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-8 Appendix F. Wildland Fire Management Plan 2004 

Disaster Relief Act of May 22, 1974 (88 Stat. 143; 42 U.S.C. 5121): authorizes Federal agencies 

to assist state and local governments during emergency or major disaster by direction of the 

President. 

National Wildlife Refuge System Administrative Act of 1966 as amended by the National 

Wildlife Refuge System Improvement Act of 1997, 16 U.S.C. 668dd et seq.: defines the National 

Wildlife Refuge System as including wildlife refuges, areas for the protection and conservation of 

fish and wildlife which are threatened with extinction, wildlife ranges, game ranges, wildlife 

management areas and waterfowl production areas. It also establishes a conservation mission for 

the Refuge System, defines guiding principles and directs the Secretary of the Interior to ensure 

that biological integrity and environmental health of the system are maintained and that growth of 

the system supports the mission. 

Federal Fire Prevention and Control Act of October 29, 1974 (88 Stat. 1535; 15 U.S.C.2201): 

provides for reimbursement to state or local fire services for costs of firefighting on federal 

property. 

Wildfire Suppression Assistance Act of 1989. (Pub.L. 100-428, as amended by Pub.L 101- 11, 

April 7, 1989). 

Departmental Manual (Interior), Part 620 DM, Chapter 1, Wildland Fire Management: General 

Policy and Procedures (April 10, 1998): defines Department of Interior fire management policies. 

Service Manual, Part 621, Fire Management (February 7, 2000): defines U.S. Fish and Wildlife 

Service fire management policies. 

National Environmental Policy Act of 1969: regulations implementing the National 

Environmental Policy Act (NEPA) encourages the combination of environmental comments with 

other agency documents to reduce duplication and paperwork (40 CFR 1500.4(o) and 1506.4). 

Clean Air Act (42 United State Code (USO) 7401 et seq.): requires states to attain and maintain 

the national ambient air quality standards adopted to protect health and welfare. This encourages 

states to implement smoke management programs to mitigate the public health and welfare 

impacts of Wildland and prescribed fires managed for resource benefit. 

Endangered Species Act of 1973. 

U.S. Fish & Wildlife Service Fire Management Handbook. 

The authority for funding (normal fire year programming) and all emergency fire accounts is found in the 

following authorities: 

Section 102 of the General Provisions of the Department of Interior's annual Appropriations Bill 

provides the authority under which appropriated monies can be expended or transferred to fund 

expenditures arising from the emergency prevention and suppression of wildland fire. 

P.L. 101-121, Department of the Interior and Related Agencies Appropriation Act of 1990, 

established the funding mechanism for normal year expenditures of funds for fire management 

purposes. 

31 US Code 665(E)(1)(B) provides the authority to exceed appropriations due to wildland fire 

management activities involving the safety of human life and protection of property. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-9 

FIRE MANAGEMENT OBJECTIVES 

The overall objective for fire management on Kakahaia NWR is to promote a program to provide for 

firefighter and public safety, reduce the incidence of human-caused fires, and ensure appropriate 

suppression response capability to meet expected wildland fire complexity. Specific fire management 

objectives are: 

Promote a fire management program and control all wildland fires.

Provide for the protection of life, property, and resources from wildland fires at costs 

commensurate with resource values at risk. 

Use appropriate suppression tactics and strategies that minimize long-term impacts of suppression 

actions. 

Use pile burning to safely and efficiently remove debris from resource management activities and 

reduce hazardous fuels. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-10 Appendix F. Wildland Fire Management Plan 2004 

DESCRIPTION OF REFUGE 

General Description 

Kakaha‟ia National Wildlife Refuge is a coastal freshwater wetland situated along the south coast of the 

island of Moloka‟i, County of Maui, Hawai‟i (Figure 1). The 44.6-acre wetland refuge is owned in fee 

title by the Federal Government and administered by the Maui National Wildlife Refuge Complex. The 

southern portion of the refuge is bisected by Kamehameha V Highway (State Route 450) and separates 

the main wetland from the 2-acre coastal property. The nearest community is Kaunakakai, which lies 

approximately 5.5 miles northwest of the refuge boundary. 

The refuge is comprised of a 15-acre freshwater marsh which is remnant of an ancient Hawaiian fishpond 

and a 5.5 acre pond constructed in 1983 to provide additional shallow water habitat for endangered 

Hawaiian stilts. The old fishpond receives water from at least two underground springs that maintains 

water level at approximately 2.6 feet. The smaller, shallow water pond receives water from the Old Pond, 

as needed. The public is allowed access to the coastal property (2 acres) which is managed as parkland by 

the County of Maui. Aside from intermittent moist soil areas adjacent to the ponds there is approximately 

22 acres of scrub-shrub/forested habitat along the refuge‟s north, east, and west boundaries.

Climate 

The average daily temperatures are in the 80s (°F) (range 54 to 94°F). Average annual temperature is 

75°F with warmest temperatures occurring in August and September. The refuge is located in a dry area 

of the island and receives 10 to 20 inches of rain annually. The prevailing wind over the island is the 

northeasterly trades. The refuge is sheltered on the leeward side of the island where average annual wind 

speed is seven knots (8 mph); however, maximum speed reaches 40 knots (46 mph) during weather 

fronts. Relative humidity recorded on the refuge ranges from 64% to 98%. 

Vegetation 

The refuge‟s upland areas are covered with dense stands of koa-haole (Leucaena leucocephala), kiawe 

trees (Prosopis pallida), and Indian marsh fleabane (Pluchea indica). Currently, these species also occur 

on the pond levees from which they will be removed. The 15-acre pond contains 98% California bulrush 

(Schoenoplectus californicus) which is a non-native species that requires intensive management once 

established. The encroachment of this noxious weed results in decreased availability of deep water 

habitat for waterbird use. The 5.5-acre shallow water pond is maintained with a diversity of native and 

non-native grasses (Brachiaria mutica, Cenchrus ciliaris, Cynodon dactylon, and Leptochloa uninervia) 

but continuously needs control of non-native woody vegetation such as kiawe and fleabane, particularly 

on the islands. The weather conditions on Molokai result in year-round growth of most vegetation. 

Fish and Wildlife 

Kakaha‟ia NWR was established to protect and manage endangered waterbird populations (Hawaiian stilt 

and Hawaiian coot) and their habitats. The larger of the ponds would typically have deeper water levels 

(2 ft) from October through March for resident native Hawaiian coots and migratory waterfowl, 

including: Northern shoveler (Anas clypeata) Northern pintail (A. acuta), and green-winged teal (A. 

crecca). The 5.5-acre pond contains shallower water conditions to host Hawaiian stilts nesting and 

foraging and migratory shorebirds during winter months. Typical shorebird species include lesser golden 

plover (Pluvialis fulva), ruddy turnstone (Arenaria interpres), sanderling (Calidris alba), and wandering 

tattler (Heteroscelus incanus). Black-crowned night herons (Nycticorax nycticorax hoactli) are regularly 

observed around the edge of the open water areas or roosting in nearby trees. Cattle egrets (Bubulcus 

ibis) are introduced species that are common inhabitants observed on the periphery of the wetlands. 

Upland bird species also occur on the refuge and include: gray francolin (Francolinus pondicerianus), 

black francolin (F. francolinus), spotted doves (Streptopelia chinensis), zebra doves (Geopelia striata), 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-11

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. 

common myna (Acridotheres tristis), Northern cardinal (Cardinalis cardinalis), and house finch 

(Carpodacus mexicanus).

Mammals found on the refuge are all non-native and include black rat (Rattus rattus), Norwegian rat, 

feral cats, and mongoose, all of which are controlled to protect endangered waterbirds. Introduced Axis 

deer frequent the refuge (tracks observed) in the thick kiawe forest. 

Threatened and Endangered Species 

Endangered waterbirds occur in both Old and New Ponds depending upon water level. Hawaiian coots 

prefer water depth less than 18 inches and will also occur along the water edges in moist soil areas. Nests 

are built in emergent vegetation from December through March if water level remains constant. 

Hawaiian stilts are waders and prefer water no more than approximately seven inches in depth. The stilts 

nest on the ground adjacent to water and vegetation. Typically, this occurs from April through August. A 

majority of the foraging and nesting areas for stilts occurs in New Pond which has variable topography 

for nesting islands when water level is low. The critical nesting period for both endangered waterbirds is 

from December through August. Hawaiian ducks possibly use the refuge, but identification has been 

difficult due to hybridization. 

A majority of the vegetation present on the refuge is non-native, invasive species; there are no threatened 

or endangered plant species recorded. The refuge does not contain designated Critical Habitat or portions 

thereof. 

Table 1. Threatened and Endangered Species found at Kakahaia NWR.

Common Name Scientific Name Federal Status

Hawaiian Coot Fulica alai Endangered

Hawaiian Stilt Himantopus mexicanus knudseni Endangered

Hawaiian Duck Anas wyvilliana Endangered

Cultural Resources 

The Service has not conducted a comprehensive archaeological survey on the refuge. Site-specific 

surveys will be conducted prior to any land-altering activities on the refuge. The larger pond, “Old 

Pond”, is an Hawaiian fishpond and may be eligible for listing; however, the pond has not yet undergone 

a comprehensive cultural assessment and has not been designated an historic site. 

Physical Resources 

Elevation of Kakahaia National Wildlife Refuge ranges from sea level to approximately 10 feet. The 

soils are poorly drained, except for most of the upland areas. During periods of heavy rain, erosion from 

the upper watershed has delivered large amounts of soil to the northern (upper) edges of the wetlands and 

will, with time, promote increased sedimentation into the larger pond due to the large stand of bulrush. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-12 Appendix F. Wildland Fire Management Plan 2004 

Structures and Facilities 

Kakahaia NWR is an unstaffed refuge which is visited twice a month to census birds, perform 

light maintenance duties and to check water conditions. Limited presence at the site results in 

minimal structures and facilities. To secure property there is one metal storage container (20 ft x 

12 ft) and pre-fabricated shed. Other structures include a windmill between the ponds, a 

submersible pump to draw water from Old to New Pond, and various hydrological staff gages 

and piezometers. The staff has one refuge vehicle which is parked at the Hoolehua airport 

between visits. 

An electric line is buried within the north levee of New Pond and extends from the entrance road 

to the maintenance area and ends at the windmill pump. 

Public Access 

Kakahaia NWR is an un-staffed refuge and has limited public access, except to the coastal 

property (2 acres) across Kamehameha V Highway which is not fenced. Refuge staff performs 

maintenance and restoration activities twice per month. Environmental education and public 

access is limited to pre-arranged days when appropriate staff are available to travel for the day. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-13

Figure 1. Kakahaia National Wildlife Refuge. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-14 Appendix F. Wildland Fire Management Plan 2004 

WILDLAND FIRE MANAGEMENT SITUATION

Historic Role of Fire 

Historic natural fires on Moloka‟i have been limited to volcanic eruptions and lightning and are very 

infrequent. In general the native vegetation is not well adapted to fire disturbances. Non-native (invasive) 

species typically colonize burned areas to the exclusion of native species. 

Pre-settlement Fires 

There is no clear indication that fire was an integral part of the native ecosystem. There are no records 

indicating fire frequency prior to settlement, although rare fire events likely occurred as a result of 

volcanic activity and lightning. 

Post-settlement Fire History 

No wildland fires are known to have occurred on the Refuge. The grassy slope inland of the refuge 

experienced some small wildfires prior to 1984. In 1980, a human-caused wildfire occurred one mile 

west of the refuge and quickly spread through the dryland vegetation. In 1988, an extensive fire (9,500 

acres) occurred through an open kiawe grassland eight miles to the west. Throughout the state, fire 

season is considered by the Hawaii Department of Forestry and Wildlife (DOFAW) to occur during a 

three-month period in late summer. However, given the extreme variability of weather in Hawaii, fires 

may occur at any time during the year. There is no clearly-defined fire season for the refuge. 

Prescribed Fire History 

There is no history of prescribed fire use on the refuge. Pile burning will occur in September after 

endangered waterbird breeding season and before winter rains. 

Responsibilities 

Kakahaia NWR does not have a dedicated fire management organization. The Project Leader and Refuge 

Manager are responsible for planning and implementing the fire management program on the Refuge. 

Staff from the Regional Office in Portland will act as the Zone Fire Management Officer (FMO), and are 

responsible for fire management program oversight. The Project Leader will assign fire management 

responsibilities as collateral duties to staff who possess appropriate training, experience, and incident 

qualifications. Preparedness planning and work is accomplished by Refuge staff in accordance with 

national and regional fire management direction under guidance from the Regional Office. Emergency 

fire management actions will be handled by Refuge staff according to training and incident qualifications. 

The Regional Office will be immediately notified of all emergency actions. Additional information and 

direction is included in the Fire Dispatch Plan (Appendix C). 

Refuge Manager 

Is responsible for implementation of all fire management activities within the Refuge and will 

ensure compliance with Department and Service policies. 

Selects the appropriate management responses to wildland fires. 

Approves any Pile Burn Plan. 

Coordinates Complex programs to ensure personnel and equipment are made available and 

utilized for fire management activities. 

Ensures that the fire management program is considered during refuge-related planning and 

project implementation. 

Acts as the primary Resource Advisor during fire management planning and operations. 

Coordinates with cooperators to ensure adequate resources are available for fire operational 

needs. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-15

Biologist 

Coordinates through Project Leader to provide biological input for the fire program. 

Participates, as requested in fire suppression and rehabilitation projects according to level of 

training and qualifications. 

May act as primary Refuge Resource Advisor for the Project Leader. 

Zone Fire Management Officer 

Responsible for all fire-related planning for the Refuge. 

Solicits program input from the Project Leader and Biologist. 

Coordinates fire related training. 

Coordinates with cooperators to ensure adequate resources are available for fire operational 

needs. 

Is responsible for preparation of fire reports following the suppression of wildland fires. 

Prepares an annual report detailing fire activities undertaken in each calendar year. This report 

will serve as a post-year‟s fire management activities review, as well as provide documentation 

for development of a comprehensive fire history record for the Complex. 

Submits budget requests and monitors FIREBASE funds. 

Maintains records for all personnel involved in related activities, detailing each individual's 

qualifications and certifications for such activities. 

Incident Commander 

Incident Commanders (ICs) of any level use strategies and tactics as directed by the Project Leader and 

WFSA where applicable to implement selected objectives on a particular incident. A specific Limited 

Delegation of Authority (Appendix I) will be provided to each Incident Commander prior to assuming 

responsibility for an incident. Major duties of the Incident Commander are given in the National Wildfire 

Coordinating Group (NWCG) Fireline Handbook, including: 

Brief subordinates, direct their actions, and provide work tools. 

Ensure that safety standards identified in the Fire Orders, the Watch Out Situations, and agency 

policies are followed at all times. 

Personally scout and communicate with others to be knowledgeable of fire conditions, fire 

weather, tactical progress, safety concerns and hazards, condition of personnel, and needs for 

additional resources. 

Order resources to implement the management objectives for the fire. 

Inform appropriate dispatch of current situation and expected needs. 

Coordinate mobilization and demobilization with dispatch and the Zone FMO. 

Perform administrative duties, i.e., approving work hours, completing fire reports for command 

period, maintaining property accountability, providing or obtaining medical treatment, and 

evaluating performance of subordinates. 

Assure aviation safety is maintained to the highest standards. 

Resource Advisor

The Resource Advisor (RA) is a technical specialist appointed by the Agency Administrator and reports 

to the IC or designee and provides guidance for natural and cultural resource protection from suppression 

operations. The RA provides input to the IC in the development of fire suppression strategies and tactics 

to minimize or mitigate the expected impacts of fire and fire and fire suppression actions upon natural and 

cultural resources. The RA also provides input required for the development of rehabilitation plans. 

Resource Advisor responsibilities include (NWCG 1996): 

Provides analysis, information, and advice to fire managers for areas of concern, including critical 

watersheds, riparian areas, fisheries, and water sources; threatened or endangered species; 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-16 Appendix F. Wildland Fire Management Plan 2004 

prehistoric and historic archaeological sites and cultural landscapes; fuel breaks B locations and 

specifications; urban interface impact B structures and improvements; and hazardous materials 

Assists the planning function in developing fire maps and identifying areas of concern 

Determines environmental restrictions commensurate with FMP resource protection in the fire 

area 

Provides recommendations to fire management personnel and agency administrators for fire 

suppression rehabilitation needs 

Documents potential and actual suppression/fire-related resource impacts and the rationale for 

protection of priority areas 

Provides resource information to local initial attack ICs, dispatchers, or other fire personnel 

during pre-season training and planning meetings. 

Interagency Operations 

Maui County Fire Department (Keonakakai Station) will provide initial attack response to wildland and 

structural fires on the refuge (Figure 2). If qualified resources are not available, resources will be ordered 

through proper dispatch procedures (Appendix C). The Hawaii Department of Fish and Wildlife 

(DOFAW) would be able to respond to fires in the white areas of the figure below only under specific 

conditions (i.e., extreme threats to public safety, local resources fully committed, extreme fire behavior, 

etc.). In this case, the request for assistance must come from the County Fire Department through the 

County Civil Defense to State Civil Defense. No formal cooperative agreements exist with these 

agencies. When they are developed, they will be added to Appendix G. 

Kealia Pond will use the Incident Command System (ICS) as a guide for fireline organization. 

Qualifications for individuals are per DOI Wildland Fire Qualifications and Certification System, part of 

NIIMS and the National Wildland Fire Coordination Group (NWCG) Prescribed Fire Qualification 

Guide. Depending on fire complexity, some positions may be filled by the same person. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-17

Kakahaia NWR

Figure 2. Fire Response Zones for the Island of Maui. 

Protection of Sensitive Resources 

Resource Advisors will be required for all wildland fires on the refuge. The advisor will work with the 

suppression resources to limit environmental impact. 

The Regional Archaeologist will work with fire staff, Project Leaders, and Incident Commanders to 

ensure that cultural resources are protected from fire and fire management activities. The “Request For

Cultural Resource Compliance” (RCRC) form (Appendix F) will be used to inform the Regional 

Archaeologist of impending activities, thereby meeting the regulations and directions governing the 

protection of cultural resources as outlined in Departmental Manual Part 519, National Historic 

Preservation Act (NHPA) of 1966, Code of Federal Regulations (36CFR800), the Archaeological 

Resources Protection Act of 1979, as amended, and the Archaeological and Historic Preservation Act of 

1974. The NHPA Section 106 clearance will be followed for any fire management activity that may affect 

historic properties (cultural resources listed or eligible for listing on the National Register of Historic 

Places). 

Impacts to archaeological resources by fire resources vary. The four basic sources of damage are (1) fire 

intensity, (2) duration of heat, (3) heat penetration into soil, and (4) suppression actions. Of the four, the 

most significant threat is from equipment during line construction for prescribed fires or wildfire holding 

actions (Anderson 1983). 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-18 Appendix F. Wildland Fire Management Plan 2004 

The following actions will be taken to protect archaeological and cultural resources: 

Wildland Fires 

Minimum impact fire suppression tactics will be used to the fullest extent possible. 

The Resource Advisor will inform fire suppression personnel of any areas with cultural resources. 

The Resource Advisor should contact the Regional Archaeologist for more detailed information. 

Foam use will be minimized in areas known to harbor surface artifacts. 

Mechanized equipment should not be used in areas of known cultural significance. 

The location of any sites discovered as the result of fire management activities will be reported to 

the Regional Archaeologist. 

Rehabilitation plans will address cultural resources impacts and will be submitted to the Regional 

Archaeologist using the RCRC. 

Pile Burns 

The refuge fire staff will submit a completed RCRC to the Regional Archaeologist as soon as the 

burn area is identified (i.e., as soon as feasible). 

Upon receipt of the RCRC, the Regional Archaeologist will be responsible for consulting with the 

Zone FMO and evaluating the potential for adverse impacts to cultural resources. 

When necessary, the Regional Archaeologist will coordinate with the State Historic Preservation 

Officer (SHPO). The SHPO has 30 days to respond. The Refuge will consider all SHPO 

recommendations. 

Mechanized equipment should not be used in areas of known cultural significance. 

The location of any sites discovered as the result of fire management activities will be reported to 

the Regional Archaeologist. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-19

WILDLAND FIRE SUPPRESSION ACTIVITIES 

Fire program management describes the operational procedures necessary to implement fire management 

at Kakahaia NWR. Program management includes fire prevention, preparedness, emergency 

preparedness, fire behavior predictions, fire detection, minimum impact fire suppression, minimum 

impact rehabilitation, and documentation. 

All fires not classified as prescribed fires are wildland fires and will be appropriately suppressed. Maui 

County will provide wildland fire suppression resources under most circumstances. Most suppression 

activities will necessitate the use of heavy equipment to create firebreaks or allow the fire to burn to the 

water. 

There is no clearly defined fire season for the refuge and records show that fires may occur at any during 

the year. 

Fire Management Strategies 

Although resource impacts of suppression alternatives must always be considered in selecting a fire 

management strategy, managing fire for resource benefit is not authorized on this refuge. Appropriate 

suppression action will be taken to provide for firefighter safety, public safety, and protection of 

resources. 

Critical protection areas, including all refuge structures and facilities, will receive priority consideration 

in fire control planning efforts. In all cases, the primary concerns of fire suppression personnel will be 

safety. If needed, all individuals not involved in the suppression effort will be evacuated. 

Suppression strategies should be applied so that the equipment and tools used to meet the desired 

objectives are those that inflict the least impacts upon the natural and cultural resources. Minimum 

impact suppression tactics (MIST) will be employed to protect all resources. Natural and artificial 

barriers will be used as much as possible for containment. When necessary, fire line construction will be 

conducted in such a way as to minimize long-term impacts to resources. Sites impacted by fire 

suppression activities or by the fire will be rehabilitated as necessary, based on an approved course of 

action for each incident. 

Specific wildland fire management and suppression strategies for Kakahaia NWR are: 

All wildland fires will be controlled using the appropriate suppression strategy which considers 

safety, property, natural and cultural resources, and economics. 

Mechanical treatment will be used to reduce hazardous fuels around structures and 

improvements. 

Preparedness 

Preparedness is the work accomplished prior to fire occurrence to ensure that the appropriate response, as 

directed by the Fire Management Plan, can be carried out. Preparedness activities include: budget 

planning, equipment acquisition, equipment maintenance, dispatch (initial attack, extended, and 

expanded), equipment inventory, personnel qualifications, and training. The preparedness objective is to 

have a well trained and equipped fire management organization to manage all fire situations within the 

monument. Preparedness efforts are to be accomplished in the time frames outside the normal fire season 

dates. 

Historical Weather Analysis

There is no clearly defined fire season for the refuge and records show that fires may occur at any 

during the year. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-20 Appendix F. Wildland Fire Management Plan 2004 

General fire weather information can be obtained through the National Oceanic and Air 

Administration (NOAA) at fire.boi.noaa.gov. Kakahaia NWR is located in the area serviced by the 

National Weather Service (NWS) office in Honolulu, Hawaii. The Fire Weather section of the 

Honolulu NWS website, www.prh.noaa.gov/hnl/pages/firewx.php, contains zone maps, fire weather 

forecasts, and instructions for requesting a spot weather forecast. The refuge falls within the Molokai 

Leeward (013) Fire Weather Zone. 

Fire Prevention 

An active fire prevention program will be conducted, as needed, in conjunction with other agencies to 

protect human life and property, and prevent damage to cultural resources or physical facilities. 

A program of internal and external education regarding potential fire danger may be implemented. 

Visitor contacts, bulletin board materials, handouts and interpretive programs can be utilized to 

increase visitor and neighbor awareness of fire hazards. 

During periods of extreme or prolonged fire danger area closures or emergency restrictions regarding 

refuge operations may become necessary. Such restrictions, when imposed, will usually be consistent 

with those implemented by cooperators. 

Hazard Reduction for Structure Protection 

Hazard reduction is conducted to prevent wildland fires from spreading onto structures owned by the 

FWS and adjacent structures. Vegetation around structures (metal container and shed) is cleared a 

minimum of two feet. Currently, this vegetation must be hauled to the dump for removal. Non-FWS 

structures include privately-owned residences (seven) located along all but the south boundary. 

Staffing Priority Levels 

No dedicated fire staff exists on the refuge. If drought conditions require additional fire preparedness 

and funding, addition qualified fire personnel may be assigned to the refuge. 

Training 

Departmental policy requires that all personnel engaged in suppression and prescribed fire duties 

meet the standards set by the National Wildfire Coordinating Group (NWCG), in addition to Servicespecific standards. Kakahaia NWR will conform strictly to the requirements of the wildland fire 

management qualification and certification system and USFWS guidelines. 

Basic wildland fire training refreshers are offered annually for red-carded firefighters through 

surrounding agencies, and records are kept in a centralized database. Additional training is available 

from surrounding agencies in pump and engine operation, power saws, firefighter safety, fire weather 

and fire behavior, helicopter safety and prescribed fire objectives and activities. On-the-job training 

is encouraged and will be conducted at the field level. Whenever appropriate, the use of fire 

qualification task books will be used to document fire experience of trainees. The Zone FMO will 

coordinate fire training needs with those of other nearby refuges, cooperating agencies, and the 

Regional Office. 

The refuge supports the development of individual Incident Command System (ICS) overhead 

personnel from among qualified and experienced refuge staff for assignment to overhead teams at the 

local, regional, and national level. 

Fire suppression is an arduous duty. On pile burns, personnel may be required to shift from 

implementation and/or monitoring activities to suppression. Poor physical condition of crew members 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-21

can endanger safety and lives during critical situations. Personnel performing fire management duties 

will maintain a high level of physical fitness. This requires successful completion of a fitness pack test. 

Personnel must complete a three mile hike with a 45 pound pack in less than 45 minutes. Employees 

participating in any wildland fire activities on Fish and Wildlife Service or cooperators= lands will meet 

fitness requirements established in PMS 310-1, except where Service-specific fitness requirements apply. 

Supplies and Equipment 

Currently, the refuge does not possess any fire equipment or maintain a fire cache. Equipment and 

supplies are available through the interagency cache system. 

Detection 

Fires are generally reported by the public to the Maui County Fire Department. The Fire Department 

notifies refuge staff of any suppression operations on the refuge. 

Communications 

Currently, refuge communications are limited to telephones (Appendix C). No personnel will be on-site 

at a wildland fire without direct communications with the suppression resources. 

Pre-Attack Plan 

Upon discovery of a fire, all subsequent actions will be based on the following: 

The Incident Commander (IC) will locate, size-up, and coordinate suppression actions. The IC 

will complete the pre-attack planning checklist. 

Provide for public safety. 

Considering the current and predicted fire conditions, the Incident Commander will assess the 

need for additional suppression resources and estimate the final size of the fire. The potential for 

spread outside of the refuge should be predicted, as well as the total suppression force required to 

initiate effective containment action at the beginning of each burning period. 

The Incident Commander will assess the need for law enforcement personnel for traffic control, 

investigations, evacuations, etc., and make the request to the FMO. 

Document decisions and complete the fire report (DI-1202). 

Should a wildland fire move into an extended attack a Delegation of Authority will be invoked. 

Once a Delegation of Authority has been authorized the Incident Commander will make the final 

decisions pertaining to the fire. A copy of the Delegation of Authority is in Appendix ?. 

Fire Management Units 

Fire Management Units (FMUs) are areas on a refuge which have common wildland fire management 

objectives and strategies, are manageable units from a wildland fire standpoint, and can be based on 

natural or man-made fuel breaks. Kakahaia NWR will be managed as a single FMU. 

Due to staff limitations, relatively small land management parcels, long response times, valuable 

resources, and values at risk on neighboring lands, this plan does not authorize managing wildland fire for 

resource benefit. Wildland fires will be suppressed using the appropriate suppression response. Pile 

burning, as a limited form of prescribed burning, will be used to reduce hazardous fuels and to meet 

resource management objectives. 

Fuels and Fire Behavior 

Fuel Types and Fire Behavior 

There are two general fuel types on the refuge. These fuel types correspond to Anderson‟s (1982) 

Fuel Models 3 and 6 (Table 2). These types of fuels promote rapid spread and flame heights that 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-22 Appendix F. Wildland Fire Management Plan 2004 

may exceed 20 feet, thus causing control problems. Steady trade winds help promote rapid fire 

growth. 

Table 2. Habitat types and fuel models on Kakahaia NWR.

Habitat Type Fuel Model* Acres

Wetlands 1/3 20.5

Uplands 6 22.0

Open Water/Roads N/A 5.0

* NFFL Fuel Model (Anderson 1982)

Fuel Model 3. The 20.5 acres of wetlands on the refuge are characteristic of Fuel Model 3. The 5.5-acre 

shallow water pond is maintained with a diversity of native and non-native grasses, including Brachiaria 

mutica, Cenchrus ciliaris, Cynodon dactylon, and Leptochloa uninervia. Depending on flooding and 

climatic conditions, the vegetation in some areas of this pond may be shorter and more closely resemble 

Fuel Model 1. The 15-acre pond contains 98% California bulrush (Schoenoplectus californicus). 

Between the two ponds, approximately 3 acres are open water and unburnable. Fires in this fuel are the 

most intense of the grass group and display high rates of spread under the influence of wind. Wind may 

drive fire into the upper heights of the grass and across standing water. Approximately one-third of the 

stand is considered dead or cured and maintains the fire. Table 3 shows predicted flame lengths and rates 

of spread in Fuel Models 1 and 3 under varying conditions from an old burn plan for the former Hawaiian 

Wetlands NWRC. These predictions are only for backing fires, which assumes no wind. Wind will cause 

heading fires and may significantly increase flame lengths and rates of spread for these fuel models. 

Table 3. Backing fire behavior predictions for Kakahaia NWR in Fuel Models 1 and 3.

Parameter Fuel Model 1 Fuel Model 3

20-ft Windspeed 0-10 mi/hr 0-10 mi/hr

Effective Midflame 

Windspeed*

0 mi/hr 0 mi/hr

Time of Day 0800 1000 0800 0800 1000 1000

Cloud Canopy Cover (%) Clear Clear Clear Clear Clear Clear

Temperature (°F) 70 90 70 70 90 90

Relative Humidity (%) 65 20 65 65 20 20

Dead Fuel Moisture (%) 12 5 12 13 5 6

Slope (degrees) Flat Flat Flat Flat Flat Flat

Flame Length (ft) 0 1 2 2 3 3

Rate of Spread (ch/hr) 0 5 4 3 5 5

* Backing fire assumes effective mid-flame wind speed = 0. 

. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-23

Fuel Model 6. The refuge‟s 22 acres of uplands are covered with dense stands of koa-haole (Leucaena 

leucocephala), kiawe trees (Prosopis pallida), and Indian marsh fleabane (Pluchea indica). Fires carry 

through the shrub layer, but this requires moderate winds. Fire will drop to the ground at low wind 

speeds or at openings in the stand. With winds of 5 miles/hour, dead fuel moisture content of 8%, and 

live fuel moisture content of 100%, predicted flame length is 6 feet, and rate of spread is 32 chains/hour 

(Anderson 1982). 

Fire Effects 

Fire can promote non-native species, but can be an effective management tool to reduce the density and 

complexity of these species and enhance endangered waterbird habitat. If a wildland fire were to occur 

on the refuge, other than short-term impacts, no negative ecological impacts would be anticipated from 

either suppression methods or the fire itself. A fire during peak Hawaiian stilt or coot nesting could 

account for some nesting failure; however, the benefits to waterbirds of reducing coverage by rank stands 

of non-native species would outweigh any immediate negative effects. 

The ecological effect of the 1980 fire near the refuge was limited to minor erosion problems. Native 

vegetation quickly re-established within 6 months. 

Suppression Tactics 

Suppression involves a wide range of possible tactics from the initial attack to final control. To this end, 

all wildland fires will be suppressed in a safe, aggressive, and cost-effective manner to produce efficient 

action with minimal resource damage and limit smoke impacts to local communities. 

Typically, initial attack suppression actions are conducted by the Maui County Fire Department. All fires 

will be assessed by the initial on-scene Incident Commander and attacked using minimum impact fire 

suppression tactics for the Refuge. Roads and natural barriers will be used as much as possible to reduce 

fireline construction. Fireline and mop-up through riparian areas should consider long-term damage to 

vegetation. Unnecessary cutting and bucking should be replaced with alternative actions whenever 

possible. Where wildland fires cross roads, the burned area adjacent to the road should be mopped up and 

dangerous snags felled. 

A Resource Advisor should be assigned to the incident from the beginning to assist with on-the-ground 

tactical decisions and to document rehabilitation needs. There will be only one Incident Commander who 

will be responsible to the Refuge Project Leader. The Incident Commander will designate all overhead 

positions on fires requiring extended attack. Reference should be made to a Delegation of Authority 

(Appendix G).

Suppression Conditions 

A full suppression alternative was selected for this refuge which requires containment and control of all 

wildland fires. Wildland fires will not be managed to achieve resource objectives, although impacts to 

resources may be considered in selecting suppression strategies. Suppression guidelines and restrictions 

(Table 4) were developed for this refuge to protect natural and cultural resources. These guidelines will 

be discussed annually with Maui County Fire Department to ensure their compliance. The Refuge 

Manager should review these guidelines annually and document any changes. 

A Resource Advisor will be used to ensure impacts to natural and cultural resources are minimized. The 

use of heavy, ground-disturbing equipment (including bulldozers) is prohibited for normal fire 

suppression operations. The use of foams and retardants is also prohibited due to the presence of 

endangered waterbirds and extensive wetlands. Off-road travel and firelines constructed with hand tools 

and/or chainsaws must be approved by the Resource Advisor at all times. Low-flying aircraft and 

helicopter water drops must be approved by the Resource Advisor from December through August; the 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-24 Appendix F. Wildland Fire Management Plan 2004 

Incident Commander has approval authority all other times. Hose lays from engines must be approved by 

the Resource Advisor from April through August due to the presence of nesting endangered waterbirds; 

the Incident Commander has approval authority all other times. 

Table 4. Kakahaia NWR Wildland Fire Suppression Guidelines. 

Kakahaia National Wildlife Refuge – Wildland Fire Suppression Guidelines

NOTE:If human life is threatened, the Incident Commander has the authority to order any 

suppression strategy or tactic available to mitigate the threat.

FIRE MANAGEMENT UNIT – KAKAHAIA NWR

FMU Description All lands within Kakahaia National Wildlife Refuge, Molokai, Hawaii.

Special Considerations Smoke/fire may cause a health hazard to neighboring communities.

Endangered waterbirds present in wetlands.

Preferred Suppression 

Strategies

Aggressively suppress fire, holding it to the fewest burned acres possible 

within safety constraints, with minimal effect on endangered species and their 

habitats.

TACTIC MUST BE APPROVED BY:

Hand line/Chainsaws Resource Advisor

Heavy Equipment Prohibited

Off-road Travel Resource Advisor

Hose Lays Resource Advisor (April – August); Incident Commander otherwise

Foam/Retardant Prohibited

Water Drops Resource Advisor (December – August); Incident Commander otherwise

Helicopters, other AC Resource Advisor (December – August); Incident Commander otherwise

Safety Considerations High rates of fire spread, especially in windy conditions.

Wildland Fire Situation Analysis 

For fires that cannot be contained in one burning period, a Wildland Fire Situation Analysis (WFSA) 

must be prepared. In the case of a wildland fire, the Project Leader, in conjunction with the Zone FMO, 

will prepare the WFSA. Approval of the WFSA resides with the Project Leader. 

The purpose of the WFSA is to allow for a consideration of alternatives by which a fire may be 

controlled. Damages from the fire, suppression costs, safety, and the probable character of suppression 

actions are all important considerations. 

Public safety will require coordination between all refuge staff and the IC. Notices should be posted to 

warn visitors, trails may be closed, traffic control will be necessary where smoke crosses roads, etc. 

Where wildland fires cross roads, the burned area adjacent to the road should be mopped up and 

dangerous snags felled. Every attempt will be made to utilize natural and constructed barriers, including 

changing fuel complexes, in the control of wildland fire. Rehabilitation efforts will concentrate on the 

damages done by suppression activities rather than on the burned area itself.
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-25

Aircraft Operations 

Aircraft may be used in all phases of fire management operations. All aircraft must be Office of Aircraft 

Services (OAS) or Forest Service approved. An OAS Aviation Policy Department Manual will be 

provided by OAS. As in all fire management activities, safety is the primary consideration. Qualified 

aviation personnel will be assigned to all flight operations. 

Helicopters may be used for reconnaissance, bucket drops and transportation of personnel and equipment. 

Natural helispots and parking lots are readily available in most cases. Clearing for new helispots should 

be avoided where possible. Improved helispots will be rehabilitated following the fire.

Burned Area Emergency Stabilization and Rehabilitation 

There are three methods of repairing damage caused by wildland fires and wildland fire suppression 

activities – emergency stabilization, rehabilitation, and fire suppression activity damage repair. 

Policy and Implementation Guidance 

Departmental policy for emergency stabilization and rehabilitation (ESR) on Service lands following 

wildland fire, including objectives, implementation, plan submittal, monitoring, and funding, is found in 

the Department Manual (620 DM 3). Service ESR supplemental policy can be found in the Service 

Manual (095 FW 3.9), with policy implementation guidance provided in Chapter 5 of the FWS Fire 

Management Handbook. More detailed guidance for can be found in the Interagency Burned Area 

Emergency Stabilization and Rehabilitation Handbook (2002) and Technical Reference (2002). The 

Service maintains an internet web site (http://fire.fws.gov/ifcc/rehab/) that provides access to these and 

several other guidance documents. 

Any treatment or activity will have an approved plan developed prior to implementation. Monitoring 

specifications will be included in the plan for each treatment or activity. Emergency stabilization and 

rehabilitation treatments and activities will be written in separate plans. The Project Leader, Biologist, 

and FMO will review all plans. The final plans will be submitted to the Region for review prior to 

submission to the Washington Office. 

Compliance 

Implementation activities will be conducted in a manner that is compatible with long-term goals and 

approved land management plans (e.g., Comprehensive Conservation Plan, Habitat Management Plan, 

Fire Management Plan), in compliance with applicable law and policy, including the National 

Environmental Policy Act, Endangered Species Act, Clean Water Act, and National Historic Preservation 

Act. 

Required Reporting 

The IC will be responsible for documenting decisions and completing the fire report (e.g., ICS-214, DI1202). The Zone FMO will be responsible for any additional required reports. 

Fire Investigation 

Fire management personnel will attempt to locate and protect the probable point of origin and record 

pertinent information required to determine fire cause. They will be alert for possible evidence, protect 

the scene and report findings to the fireline supervisor. 

Prompt and efficient investigation of all suspicious fires will be carried out. However, fire management 

personnel should not question suspects or pursue the fire investigation unless they are currently Law 

Enforcement Commission qualified. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-26 Appendix F. Wildland Fire Management Plan 2004 

Personnel and services of other agencies may be utilized to investigate wildland fire arson or fire 

incidents involving structures. All fire investigations should follow the guidelines outlined in the Fire 

Management Handbook (2004). 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-27

HAZARD FUEL REDUCTION 

Hazard fuel is vegetation which presents a risk of ignition and sustaining spread of a wildland fire in 

relationship to a threat to some value. Hazard fuel reduction is both a fire prevention activity and a 

wildland fire protection measure. The objectives of this activity are: 

Reduce the hazard risk to service structures and facilities from an approaching wildland fire. 

Reduce the risk of fire spreading to the wildland from a fire originating in a Service owned 

structure or facility. 

Provide defensible space and safety to personnel at those facilities during a wildland fire. 

Meet federal, state and local fire hazard reduction ordinances. 

Hazard Fuel Reduction Strategies 

Strategies include mechanical treatment of the hazard fuels and the debris disposal. Mechanical treatment 

is accomplished using minimal maintenance procedures (herbicide treatment, mowing). Clearing of 

vegetation is primarily for wetland enhancement/restoration and to provide vehicle access to remote areas 

of the refuge. Vegetation clearing associated with habitat restoration occurs during summer months when 

water levels are low and ponds are accessible. Debris would be piled within the ponds and burned in 

September. These areas are open and do not have upper canopies. Trimming around the structures is 

completed to provide a minimum two-foot buffer. Clearing of upland vegetation was performed in 1999 

to open up habitat; however, much of the vegetation (trees) has filled in. Since then, clearing of upland 

vegetation has not been performed. 

Debris must be disposed of to complete the mitigation of the hazard. Debris disposal may be 

accomplished by scattering, chipping or pile burning. The quantity of vegetation, diameter size, crew 

availability, and logistical support will dictate the method used. If scattering of cut vegetation is used, an 

evaluation of the overall fuel loading needs to be considered so as to not add to the hazard fuel problem. 

Pile Burning Guidelines 

When planning to dispose of debris by pile burning, specific guidelines must be followed in order to 

provide for safety and reduce the escape potential. General guidelines for pile burning are the same as for 

prescribed burning. Service guidelines are found in the FWS Fire Management Handbook, Section 2. 

This section of the Fire Management Plan is for the purpose of outlining the steps to take when 

conducting pile burning only. No prescribed burning of standing vegetation will be conducted. 

References to a burn plan and burn boss are only for the purpose of pile burning. 

Pile burning will be used to dispose of cut vegetation resulting from refuge activities such as annual 

hazard reduction around structures. Limbs and branches of overhanging trees and brush will annually 

need to be trimmed back. At times trees may have been blown down during storms which will require 

debris removal. The most economical and expedient method is through burning of the piled vegetation on 

site. Pile burning is typically rated as complexity level 3 due to the low risk of escape, limited control 

forces, and time of year conducted. Safety concerns are still present even at the low complexity level. 

Careful consideration must be given to smoke management, escape potential and resource benefit 

when planning and rating the pile burn. The complexity of each pile burn would be evaluated 

using the NWCG Prescribed Fire Complexity Rating System Guide. 

Pile Burn Plan 

A Burn Boss will conduct a field reconnaissance of the proposed pile burn location with the Refuge 

Manager to discuss objectives, special concerns, and gather all necessary information to write the burn 

plan. After completing the reconnaissance, a qualified Burn Boss will write the Pile Burn Plan. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-28 Appendix F. Wildland Fire Management Plan 2004 

All pile burning will have a Pile Burn Plan. The Pile Burn Plan is a site-specific action plan describing 

the purpose, objectives, prescription, and operational procedures needed to prepare and safely conduct the 

burn. The project area, objectives, and constraints will be clearly outlined. No piles will be ignited unless 

all prescriptions of the plan are met. Fires not within those parameters will be suppressed. Pile Burn 

Plans will follow the format found in the FWS Fire Management Handbook, Section 2.2. Pile burning is 

considered a complexity level 3 prescribed burn (in most cases) and should use the plan format contained 

in Appendix C. Each burn plan will be reviewed by the Project Leader, Refuge Manager, Refuge 

Biologist, Zone FMO, and Burn Boss. The Project Leader has the authority to approve the burn plan. 

The Pile Burn Plan requires the following items to be completed prior to ignition: 

Contingency plan 

Complexity analysis 

Review and approval signatures 

Go/no go checklist 

Spot weather forecast 

Pile Burning Strategies and Personnel 

Pile burning will only be executed by qualified personnel. Pile burning requires a qualified Burn Boss. 

The Burn Boss will fill all required positions to conduct the burn with qualified personnel. All positions 

listed in the burn plan must be available for the duration of the pile burn or it will not be initiated. 

Weather and fuel moisture conditions must be monitored closely in the project area to determine when the 

prescription criteria are met. A belt weather kit may also be utilized to augment monitoring. 

When pertinent prescription criteria are within the acceptable range, the Burn Boss will select an ignition 

time based on current and predicted weather forecasts. A thorough briefing will be given by the Burn 

Boss on the day of the burn and specific assignments and placement of personnel will be discussed. An 

updated spot weather forecast will be obtained on the day of ignition and all prescription elements will be 

re-checked to determine if all elements are still within the approved ranges. If all prescription elements 

are met, a test fire will be ignited to determine on-site fire behavior conditions as affected by current 

weather. If conditions are not satisfactory, the test fire will be suppressed and the burn will be 

rescheduled. If conditions are satisfactory, the burn will continue as planned. 

Maui County Fire Department will be made aware of any planned burn. If the burn pile escapes the 

predetermined burn area, all further ignition will be halted except as needed for suppression efforts. 

Suppression efforts will be initiated, as discussed in the pre-burn briefing. The Zone FMO will be 

notified immediately of any control actions on a prescribed burn. If the burn exceeds the initial 

suppression efforts, the burn will be declared a wildland fire and suppressed using guidelines established 

in the burn plan. A WFSA will be completed and additional personnel and resources ordered as 

determined by the Incident Commander. If the fire continues to burn out of control, additional resources 

based on the contingency plan will be called from the local cooperating agencies via the servicing 

dispatch. A management overhead team may be requested to assume command of the fire if necessary. 

Each Pile Burn Plan will detail the contingency plan with identified resources for suppression. This plan 

will serve as the incident action plan during the initial attack phase of an escape. 

Monitoring and Evaluation 

During pile burns, monitoring can serve as a precursor to invoking suppression action by determining if 

the burn is in prescription, assessing its overall potential, and determining the effects of the pile burn. 

Pile burning does not usually require extensive monitoring. Weather, fire behavior, and smoke 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-29

management are elements that require monitoring. The Burn Boss will assume responsibility for 

coordinating and implementing this section. Personnel may be assigned specific tasks such as weather 

monitoring to document these elements and keep the Burn Boss informed of conditions. Special 

situations or projects may dictate more extensive monitoring and evaluation. 

Required Reports 

All forms will be completed as outlined by the Pile Burn Plan. Accomplishments, costs, fire report (DI1202), weather data, and first order fire effects monitoring are the responsibility of the Burn Boss. The 

Burn Boss may prepare a final report on the project for the Refuge Manager as requested. Information 

should include a narrative of the burn operation, a determination of whether objectives were met, weather 

and fire behavior data, number of work hours, and final cost of the burn. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-30 Appendix F. Wildland Fire Management Plan 2004 

AIR QUALITY / SMOKE MANAGEMENT GUIDELINES 

An annual burn permit is required by the State of Hawaii, Department of Health for each prescribed burn. 

This permit process evaluates the burn in relation to emissions and local air quality standards. Typically, 

smoke from fires does not significantly affect air quality standards. The Refuge is required to report the 

schedule of each burn to the Department of Health and is also required to follow permit conditions 

provided by the Department of Health that are designed to minimize effects on air quality. These 

conditions include a specified time period when burns are permitted and attention to not burning on 

specified “no-burn” days for specified islands as provided on or before 1600 hr by radio broadcast 

through the National Weather Service, or other appropriate means, applicable for the succeeding day. 

The State of Hawaii, Department of Health, Agricultural Burn Permit along with an approved Prescribed 

Burn Plan for the refuge are maintained in the Refuge Complex office. The Agricultural Burn Permit 

must be renewed annually and in possession at the burn site while burning. 

FIRE RESEARCH 

There are no ongoing fire research projects at Kakaha‟ia NWR.

rat would be used as a toxicological endpoint for diet-based RQ calculations to assess acute risk (see 

Table 1 in Section 7.1). 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-31

PUBLIC SAFETY 

Kakahaia NWR is dedicated to ensuring the safety of each visitor and to all residents and property 

adjacent to the refuge's boundary. The refuge will be closed to the public during suppression and possibly 

during pile burn activities.

Areas of fire activity may be clearly signed at the refuge entrance gate. Residents adjacent to the refuge 

(Appendix C, Table 6) will be notified in advance of any pile burn and if any fire poses a threat to burn 

outside the refuge boundaries. 

During pile burns at least one burn team member will have first aid training. A first aid kit will be on-site 

for prescribed burns as well as wildland fires. The local police, fire, and emergency medical services will 

be notified prior to the ignition. They will also be notified of the location of any wildland fires. 

PUBLIC INFORMATION AND EDUCATION 

Educating the public on the value of fire as a natural process is important to increasing public 

understanding and support for the fire management program. The refuge will use the most appropriate 

and effective means to explain the overall fire and smoke management program. This may include 

supplemental handouts, signing, personal contacts, auto tour routes, or media releases. When deemed 

necessary, interpretive presentations will address the fire management program and explain the role of 

fire in the environment. 

The public information program will be developed as follows: 

The fire management program may be incorporated into visitor contacts. Particular attention will 

be given when fires are conspicuous from roads or visitor use areas. 

News releases will be distributed to the media as appropriate. 

The public information outlets of neighboring and cooperating agencies and the regional office 

will be provided with all fire management information. 

The fire management program will be discussed in informal talks with all employees , volunteers, 

residents, and neighbors. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-32 Appendix F. Wildland Fire Management Plan 2004 

FIRE CRITIQUES AND ANNUAL PLAN REVIEW 

Fire Critiques 

Fire reviews will be documented and filed with the final fire report. The Refuge Manager will 

retain a copy for the refuge files. 

Annual Fire Summary Report 

The Refuge Manager will be responsible for completing an annual fire summary report. The 

report will contain the number of fires by type, acres burned by fuel type, cost summary (pile 

burns and wildland fires), personnel utilized, and fire effects. 

Annual Fire Management Plan Review 

The Fire Management Plan will be reviewed annually. Necessary updates or changes will be 

accomplished prior to the next fire season. Any additions, deletions, or changes will be reviewed 

by the Project Leader to determine if such alterations warrant a re-approval of the plan. 

CONSULTATION AND COORDINATION 

The following agencies, organizations and/or individuals were consulted in preparing this plan. 

Bruce Babb, Wildland/Urban Interface Coordinator, Pacific Region, USFWS, Portland, 

OR. 

Forrest Cameron, Refuge Supervisor, USFWS, Portland, OR. 

Jerry Leinecke, Project Leader, Hawaii/Pacific Islands NWR Complex, Honolulu, HI. 

Amanda McAdams, (former) Fire Ecologist, Pacific Region, USFWS, Portland, OR. 

Mike Nishimoto, Wildlife Biologist, Maui NWR Complex, Kihei, HI. 

James Roberts, Fire Planner, Pacific Region, USFWS, Portland, OR. 

Roger Spaulding, Fire Management Officer, Pacific Region, USFWS, Portland, OR. 

Linda Watters, Assistant Refuge Supervisor, USFWS, Portland, OR. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-33

APPENDICES 

Appendix A: References Cited 

Anderson, H.E. 1983. Aids to determining fuel models for estimating fire behavior. USDA Forest 

Service General Technical Report INT-122, 22p. 

Armstrong, R.W. and J.A. Bier. 1983. Atlas of Hawaii. Second Edition. University of Hawaii Press. 

Honolulu, Hawaii. 

National Wildfire Coordinating Group. 1996. Resource advisor=s guide for wildland fire. PMS 313/ 

NFES 1831. 

Pratt, H.D., P.L. Bruner, and D.G. Berrett. 1987. The Birds of Hawaii and the tropical Pacific. Princeton 

University Press, Princeton, New Jersey. 

U.S. Department of the Interior. 1997. Department Manual. Washington, D.C. 

U.S. Fish and Wildlife Service. 1975. Kakahaia National Wildlife Refuge: Final Environmental 

Assessment. U.S. Department of the Interior. Honolulu, Hawaii. 

U.S. Fish and Wildlife Service. 1991. Kakaha‟ia National Wildlife Refuge, Annual Narrative.
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-34 Appendix F. Wildland Fire Management Plan 2004 

Appendix B: Definitions 

Agency Administrator. The appropriate level manager having organizational responsibility for 

management of an administrative unit. May include Director, State Director, District Manager or Field 

Manager (BLM); Director, Regional Director, Complex Manager or Project Leader (FWS); Director, 

Regional Director, Park Superintendent, or Unit Manager (NPS), or Director, Office of Trust 

Responsibility, Area Director, or Superintendent (BIA). 

Appropriate Management Action. Specific actions taken to implement a management strategy. 

Appropriate Management Response. Specific actions taken in response to a wildland fire to implement 

protection and fire use objectives. 

Appropriate Management Strategy. A plan or direction selected by an agency administrator which 

guides wildland fire management actions intended to meet protection and fire use objectives. 

Appropriate Suppression. Selecting and implementing a prudent suppression option to avoid 

unacceptable impacts and provide for cost-effective action. 

Bureau. Bureaus, offices or services of the Department. 

Class of Fire (as to size of wildland fires). 

Class A - 3 acre or less. 

Class B - more than 3 but less than 10 acres. 

Class C - 10 acres to 100 acres. 

Class D - 100 to 300 acres. 

Class E - 300 to 1,000 acres. 

Class F - 1,000 to 5,000 acres. 

Class G - 5,000 acres or more. 

Emergency Fire Rehabilitation/Burned Area Emergency Rehabilitation (EFR/BAER). Emergency 

actions taken during or after wildland fire to stabilize and prevent unacceptable resource degradation or to 

minimize threats to life or property resulting from the fire. The scope of EFR/BAER projects are 

unplanned and unpredictable requiring funding on short notice. 

Energy Release Component (ERC). A number related to the available energy (BTU) per unit area 

(square foot) within the flaming front at the head of a fire. It is generated by the National Fire Danger 

Rating System, a computer model of fire weather and its effect on fuels. The ERC incorporates thousand 

hour dead fuel moistures and live fuel moistures; day to day variations are caused by changes in the 

moisture content of the various fuel classes. The ERC is derived from predictions of (1) the rate of heat 

release per unit area during flaming combustion and (2) the duration of flaming. 

Extended Attack. A fire on which initial attack forces are reinforced by additional forces. 

Fire Suppression Activity Damage. The damage to lands, resources and facilities directly attributable to 

the fire suppression effort or activities, including: dozer lines, camps and staging areas, facilities (fences, 

buildings, bridges, etc.), handlines, and roads. 

Fire Effects. Any consequences to the vegetation or the environment resulting from fire, whether neutral, 

detrimental, or beneficial. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-35

Fire Intensity. The amount of heat produced by a fire. Usually compared by reference to the length of 

the flames. 

Fire Management. All activities related to the prudent management of people and equipment to prevent 

or suppress wildland fire and to use fire under prescribed conditions to achieve land and resource 

management objectives. 

Fire Management Plan. A strategic plan that defines a program to manage wildland and prescribed fires 

and documents the Fire Management Program in the approved land use plan. The plan is supplemented by 

operational procedures such as preparedness plans, preplanned dispatch plans, prescribed fire plans and 

prevention plans. 

Fire Prescription. A written direction for the use of fire to treat a specific piece of land, including limits 

and conditions of temperature, humidity, wind direction and speed, fuel moisture, soil moisture, etc., 

under which a fire will be allowed to burn, generally expressed as acceptable range of the various firerelated indices, and the limit of the area to be burned. 

Fuels. Materials that are burned in a fire; primarily grass, surface litter, duff, logs, stumps, brush, foliage, 

and live trees. 

Fuel Loadings. Amount of burnable fuel on a site, usually given as tons/acre. 

Hazard Fuels. Those vegetative fuels which, when ignited, threaten public safety, structures and 

facilities, cultural resources, natural resources, natural processes, or to permit the spread of wildland fires 

across administrative boundaries except as authorized by agreement. 

Initial Attack. An aggressive suppression action consistent with firefighter and public safety and values 

to be protected. 

Maintenance Burn. A fire set by agency personnel to remove debris; i.e., leaves from drainage ditches 

or cuttings from tree pruning. Such a fire does not have a resource management objective. 

Natural Fire. A fire of natural origin, caused by lightning or volcanic activity. 

NFDRS Fuel Model. One of 20 mathematical models used by the National Fire Danger Rating System 

to predict fire danger. The models were developed by the U.S. Forest Service and are general in nature 

rather than site-specific. 

NFFL Fuel Model. One of 13 mathematical models used to predict fire behavior within the conditions of 

their validity. The models were developed by US Forest Service personnel at the Northern Forest Fire 

Laboratory, Missoula, Montana. 

Prescription. Measurable criteria which guide selection of appropriate management response and 

actions. Prescription criteria may include safety, public health, environmental, geographic, administrative, 

social, or legal considerations. 

Prescribed Fire. A fire ignited by agency personnel in accord with an approved plan and under 

prescribed conditions, designed to achieve measurable resource management objectives. Such a fire is 

designed to produce the intensities and rates of spread needed to achieve one or more planned benefits to 

natural resources as defined in objectives. Its purpose is to employ fire scientifically to realize maximize 

net benefits at minimum impact and acceptable cost. A written, approved prescribed fire plan must exist 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-36 Appendix F. Wildland Fire Management Plan 2004 

and NEPA requirements must be met prior to ignition. NEPA requirements can be met at the land use or 

fire management planning level. 

Preparedness. Actions taken seasonally in preparation to suppress wildland fires, consisting of hiring 

and training personnel, making ready vehicles, equipment, and facilities, acquiring supplies, and updating 

agreements and contracts. 

Prevention. Activities directed at reducing the number or the intensity of fires that occur, primarily by 

reducing the risk of human-caused fires. 

Rehabilitation. Actions to (1) limit the adverse effects of suppression on soils, watershed, or other 

values, or (2) to mitigate adverse effects of a wildland fire on the vegetation-soil complex, watershed, and 

other damages. 

Suppression. A management action intended to protect identified values from a fire, extinguish a fire, or 

alter a fire's direction of spread. 

Unplanned Ignition. A natural fire that is permitted to burn under specific conditions, in certain 

locations, to achieve defined resource objectives. 

Wildfire. An unwanted wildland fire. 

Wildland Fire. Any non-structure fire, other than prescribed fire, that occurs in the wildland. 

Wildland Fire Situation Analysis (WFSA). A decision-making process that evaluates alternative 

management strategies against selected safety, environmental, social, economical, political, and resource 

management objectives as selection criteria. 

Wildland/Urban Interface Fire. A wildland fire that threatens or involves structures. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-37

Appendix C: Fire Dispatch Plan 

2004 Fire Dispatch Plan 

Kakahaia National Wildlife Refuge 

FIRE SIZE-UP 

 

Use the following or the card, pocket guide, fireline handbook or red book guides. 

Reporting party‟s name and phone number:

Time discovered: 

Location of smoke or fire (plot on map; legal description): 

Fire Behavior: Smoldering Creeping Running Crowning Spotting 

Estimated size (acres): Spot 1/4-1/2 1/2-3/4 1 1-5 5+ 

Wind (midflame speed & direction): 

Dry Bulb Temperature (°F): Relative Humidity (%): 

Fuel Type: Grass Brush Timber Slash 

Adjacent Fuels: Grass Brush Timber Slash 

Aspect: Percent Slope: 

Additional Resources Needed: 

Special Considerations: 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-38 Appendix F. Wildland Fire Management Plan 2004 

NOTIFICATION

Upon report of a wildland fire, follow these procedures: 

1. Call Maui County Fire Department (911) – request response, ambulance if necessary, traffic 

control. 

2. Notify Refuge Manager/Resource Advisor, Glynnis Nakai, at the Refuge Office (808-875-1582), 

residence (808-878-3269), or cell phone (808-281-9698). Assignments will be made at this time 

to notify other personnel and agencies. 

3. Notify other Refuge personnel at the Refuge Office (808-875-1582) or at their residence: 

 Mike Nishimoto, Wildlife Biologist/Resource Advisor Residence: (808) 873-9315

 Cell: (808) 870-6461

 Calvin Willis, Maintenance Worker Residence: (808) 873-0070 

 Cell: (808) 870-6450

 Pat Savino, Admin. Support Asst. Residence: (808) 878-2880 

 Nicole Davis, Biological Technician Residence: (808) 875-0099 

4. Notify Project Leader, Jerry Leinecke, at the Hawaiian and Pacific Islands NWRC Office in 

Honolulu (808-792-9540) or at his residence (808-395-6227). 

5. Contact one of the following Regional FWS Duty Officers: 

 Pam Ensley – Regional Fire Management Coordinator Work: (503) 231-6174

 Cell: (503) 781-7978

 Home: (360) 835-7004 

 Roger Spaulding – Regional Fire Management Officer Work: (503) 231-6175

 Cell: (503) 816-7054

 (vacant) – Regional Prescribed Fire Specialist Work: (503) 231-2075

 Cell: 

 Bruce Babb – Fire Management Specialist/Regional WUI Coordinator Work: (503) 231-6234 

 Cell: (503) 703-5823
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-39

ESTABLISHED SUPPRESSION GUIDELINES

Suppression Conditions 

A full suppression alternative was selected for this refuge which requires containment and control of all 

wildland fires. Wildland fires will not be managed to achieve resource objectives, although impacts to 

resources may be considered in selecting suppression strategies. Suppression guidelines and restrictions 

(see table below) were developed for this refuge to protect natural and cultural resources. These 

guidelines will be discussed annually with Maui County Fire Department to ensure their compliance. The 

Refuge Manager should review these guidelines annually and document any changes. 

A Resource Advisor will be used to ensure impacts to natural and cultural resources are minimized. The 

use of heavy, ground-disturbing equipment (including bulldozers) is prohibited for normal fire 

suppression operations. The use of foams and retardants is also prohibited due to the presence of 

endangered waterbirds and extensive wetlands. Off-road travel and firelines constructed with hand tools 

and/or chainsaws must be approved by the Resource Advisor at all times. Low-flying aircraft and 

helicopter water drops must be approved by the Resource Advisor from December through August; the 

Incident Commander has approval authority all other times. Hose lays from engines must be approved by 

the Resource Advisor from April through August due to the presence of nesting endangered waterbirds; 

the Incident Commander has approval authority all other times. 

Kakahaia National Wildlife Refuge – Wildland Fire Suppression Guidelines

NOTE:If human life is threatened, the Incident Commander has the authority to order any 

suppression strategy or tactic available to mitigate the threat.

FIRE MANAGEMENT UNIT – KAKAHAIA NWR

FMU Description All lands within Kakahaia National Wildlife Refuge, Molokai, Hawaii.

Special Considerations Smoke/fire may cause a health hazard to neighboring communities.

Endangered waterbirds present in wetlands.

Preferred Suppression 

Strategies

Aggressively suppress fire, holding it to the fewest burned acres possible 

within safety constraints, with minimal effect on endangered species and their 

habitats.

TACTIC MUST BE APPROVED BY:

Hand line/Chainsaws Resource Advisor

Heavy Equipment Prohibited

Off-road Travel Resource Advisor

Hose Lays Resource Advisor (April – August); Incident Commander otherwise

Foam/Retardant Prohibited

Water Drops Resource Advisor (December – August); Incident Commander otherwise

Helicopters, other AC Resource Advisor (December – August); Incident Commander otherwise

Safety Considerations High rates of fire spread, especially in windy conditions.
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-40 Appendix F. Wildland Fire Management Plan 2004 

COMMUNICATIONS

Currently, refuge communications are limited to telephones. No personnel will be on-site at a wildland 

fire without direct communications with the suppression resources. 

CONTACT LIST

Table 5. Maui National Wildlife Refuge Complex Staff.

Maui NWRC P.O. Box 1042

(Mile 6 Mokulele Hwy.)

Kihei, HI 96753

Phone: (808) 875-1582

Fax: (808) 875-2945

Glynnis Nakai

Refuge Complex Manager

95 Mano Drive

Kula, HI 96790

Work: (808) 792-9548

Cell: (808) 753-0627

Home: (808) 395-6227

Michael Nishimoto

Wildlife Biologist

Kihei, HI Work: (808) 875-1582

Cell: (808) 870-6461

Home: (808) 873-9315

Calvin Willis

Maintenance Worker 

Kihei, HI Work: (541) 867-4550

Cell: (808) 870-6450

Home:

Patricia Savino

Administrative Officer

Kihei, HI Work: (808) 875-1582

Home: (808) 878-2880

Nicole Davis

Biological Science Technician

Kihei, HI Work: (808) 875-7258

Cell: (808) 870-6457

Home: (808) 875-0099

ADJACENT LANDOWNERS 

Table 6. Landowners adjacent to Kakahaia NWR.

Landowner Address Phone 

Number

Claude Sutcliffe and Brigid Mulloy P.O. Box 280, Kaunakakai, HI 96748 (808 553-3380)

Melvin Perrells P.O. Box 651, Kaunakakai, HI 96748 (808 553-3442)

Beth and Bob Johnson 104 Onioni Place, Kaunakakai, HI 96748 (808 553-5228)

Edwin and Diane Medeiros 249 Kamehameha V Hwy., Kaunakakai, HI 96748 (808 553-5702)

Gene and Carolyn Anderson P.O. Box 1748, Kaunakakai, HI 96748 (808 553-5563)
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-41

Appendix D: NEPA Compliance 

UNITED STATES FISH AND WILDLIFE SERVICE

ENVIRONMENTAL ACTION STATEMENT FOR CATEGORICAL EXCLUSION

Within the spirit and intent of the Council on Environmental Quality's regulations for implementing the 

National Environmental Policy Act of 1969 (NEPA), and other statutes, orders, and policies that protect 

fish and wildlife resources, I have established the following administrative record and determined that the 

action of: 

Implementation of the 2004 Wildland Fire Management Plan for Kakahaia National Wildlife 

Refuge, which includes guidance for wildland fire suppression, hazard fuel reduction, and pile 

burning as a limited form of prescribed fire

Check One: 

 X Is a categorical exclusion as provided by 516 DM 6, Appendix 1.4. No further NEPA 

documentation will be made. 

 Is found not to have significant environmental effects as determined by the attached 

Environmental Assessment and Finding of No Significant Impact. 

 Is found to have significant effects and, therefore, further consideration of this action will require 

a notice intent to be published in the Federal Register announcing the decision to prepare an 

environmental impact statement. 

 Is not approved because of unacceptable environmental damage, or violation of Fish and Wildlife 

Service mandates, regulations, or procedures. 

 Is an emergency action within the context of 40 CFR 1506.11. Only those actions necessary to 

control the immediate impacts of the emergency will be taken. Other related actions remain 

subject to NEPA review. 

Proposed Action and Alternatives: Use of prescribed fire to reduce fuels, restore the natural processes 

and vitality of ecosystems, improve wildlife habitat, remove or reduce non-native species and noxious 

weeds, and/or conduct research. 

Categorical Exclusions: The specific categorical exclusions from NEPA allowing for this action 

pursuant to 516 DM 6, Appendix 1.4 are: 

B.(4) The use of prescribed burning for habitat improvement purposes, when conducted in 

accordance with departmental and Service procedures. 

B.(5) Fire management activities, including prevention and restoration measures, when 

conducted in accordance with departmental and Service procedures. 

Permits/Approvals: The Wildland Fire Management Plan for Kakahaia National Wildlife Refuge must 

be approved by the Refuge Manager, Project Leader, Regional Fire Management, and Regional Director. 

All prescribed fire projects require a burn plan approved by the Project Leader. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-42 Appendix F. Wildland Fire Management Plan 2004 

Public Involvement/Interagency Coordination: Maui County Fire Department Keonakakai 

Station is notified prior to any prescribed burning. 

Supporting Documents: 

2004 Wildland Fire Management Plan for Kakahaia National Wildlife Refuge. 

ESA Section 7 Biological Evaluation for pile and debris burning for refuges within the 

Maui National Wildlife Refuge Complex (Kealia Pond NWR and Kakahaia NWR) 

(Appendix E of this FMP). 

Signature Approval: 

 

Jerry Leinecke, Project Leader Date 

Hawaiian and Pacific Islands National Wildlife Refuge Complex 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-43

Appendix E: ESA Section 7 Compliance 

INTRA-SERVICE SECTION 7 BIOLOGICAL EVALUATION 

Pile and Debris Burning for refuges within the Maui National Wildlife Refuge Complex 

(Kealia Pond NWR and Kakahaia NWR) 

 Originating Person: Glynnis Nakai 

 Telephone Number: (808) 875-1582 

 Date: July 13, 2003 

I. Region: Pacific (Region 1), Portland Oregon. 

II. Service Activity:

Pile and debris burning as a marsh vegetation management technique at Kealia Pond National 

Wildlife Refuge on Maui and Kakahaia National Wildlife Refuge on Molokai. 

III. Pertinent Species and Habitat: 

A. Listed species and/or their critical habitat within the action area: 

 Hawaiian coot (Fulica alai) – Endangered 

 Hawaiian stilt (Himantopus mexicanus knudseni) – Endangered 

B. Proposed species and/or proposed critical habitat within the action area: NONE 

C. Candidate species within the action area: NONE

IV. Geographic area or station name and action:

Refuges of this Complex are located in the state of Hawaii, County of Maui: Kealia Pond NWR on 

the island of Maui and Kakahaia NWR on the island of Molokai. 

Pile and debris burning to control and remove non-native vegetation in wetland marsh and 

mudflats. 

V. Location (attach map):

A. County and State: Maui County, State of Hawai‟i

B. Distance (miles) and direction to nearest town: 

 Ma‟alaea is 1.5 miles southwest of Kealia Pond NWR 

 Kaunakakai is approximately 5.5 miles northeast of Kakahaia NWR. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-44 Appendix F. Wildland Fire Management Plan 2004 

VI. Action Objectives: 

Pile and debris burning will be conducted on these wetland refuges as a means of controlling 

noxious and exotic vegetation that interferes with nesting and maintenance of endangered and 

migratory waterbirds. Control of the establishment and spread of these species is required to 

provide secure, viable, adequate habitat for endangered waterbirds, migratory waterfowl and 

shorebirds. Specific goals include: providing open water areas interspersed with escape, nesting, 

and maintenance cover; limiting predator cover and access; providing mudflat areas for nesting 

(Hawaiian stilts) and feeding; and promotion of desirable wetland plant species with water areas 

for Hawaiian coot nesting and maintenance. 

VII. Explanation of Impacts of Action:

This action will result in enhanced wetlands for endangered and other species using the refuge. 

Undesirable plant species will be controlled encouraging growth of more beneficial species. 

Dense predator concealment cover will be reduced making it more difficult for predators to prey 

on endangered species and allow waterbirds to detect predators at a greater distance, reducing 

predation. Increased habitat for a diversity of species, both resident and migratory, will be made 

available. The ratio of open water to vegetation will be altered to provide additional habitat 

diversity within the wetlands. 

All burns will be conducted outside major endangered species nesting seasons. Burns will 

normally be conducted between August and October. Burns will not be initiated when prefledgling birds are present. A check of each burn site will be made to determine the presence of 

waterbirds, young, and/or nests. If any of the above are discovered, no burning in that area of the 

wetlands will be undertaken. To provide necessary foraging habitat while burning, not all areas 

will be drawn down or dry at the same time. Wetland habitat on the refuge will continue to be 

provided for endangered and other waterbirds to utilize until worked ponds are re-flooded. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-45

VIII. Effect determination and response requested: [* = optional]

A. Listed species/designated critical habitat: 

Determination Response requested 

No effect/no adverse modification ____*Concurrence 

May affect, but is not likely to adversely affect species/adversely X Concurrence 

modify critical habitat 

 Hawaiian coot (Fulica alai) – Endangered 

 Hawaiian stilt (Himantopus mexicanus knudseni) – Endangered 

May affect, and is likely to adversely affect species/adversely modify ____Formal Consultation 

critical habitat 

B. Proposed species/proposed critical habitat: NONE

C. Candidate species: NONE

IX. Signature 

 

 Glynnis Nakai, Refuge Manager Date 

 Maui National Wildlife Refuge Complex 

X. Reviewing ESO Evaluation: 

 A. Concurrence Nonconcurrence 

 

 B. Formal consultation required 

 C. Conference required 

 D. Informal conference required 

 E. Remarks (attach additional pages as needed): 

 

 Field Supervisor Date 

 Ecological Services, Pacific Islands Field Office 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-46 Appendix F. Wildland Fire Management Plan 2004 

Appendix F: Request for Cultural Resource Compliance 

REQUEST FOR CULTURAL RESOURCE COMPLIANCE

Project Name: 

USFWS Unit: 

Org Code: 

Ecoregion: 

(By ARD; CBE, IPE, KCE, NCE) 

Program: 

(Partners, WSECP, Refuges, Hatcheries, Jobs, Federal Aid, Other) 

Location: County: State: 

(nearest town) 

Township(s): Range(s): Section(s): Meridian: 

7.5‟ USGS Quad(s): 

(Name, Date) 

Project acres or linear meters/feet: 

Date you want to start the project: Date of this request: 

USFWS Contact: Phone: 

Address: Fax: 

Directions to project (if not obvious): 

Attach to this form: 

A project (sketch) map showing the Area of Potential Effect with locations of specific ground altering activities

(required).

A photocopy of the USGS quad clearly marking the project area (required).

A photocopy of an air photo showing the project may be attached (if available).

Return form and direct questions to: 

USFWS Region 1 Cultural Resources Team 

c/o Tualatin River NWR 

20555 SW Gerda Lane 

Sherwood, OR 97140 

Phone: (503) 625-4377 

Fax: (503) 625-4887 

NHPA COMPLIANCE

 Appendix Item 

 of the Programmatic Agreement applies. 

 36CFR800.4 to 800.6 applies. 

Cultural Resources Team Date
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-47

The Undertaking: Describe the proposed project and means to facilitate it (e.g., provide funds to revegetate 1 

mile of riparian habitat, restore 250 acres of seasonal wetlands, and construct a 5-acre permanent pond). How 

is the project designed (e.g., install 2 miles of fence and create approximately 25 feet of 3 foot high check 

dam)? 

Area of Potential Effect: Describe where disturbance of the ground will occur. What are the 

dimensions of the area to be disturbed? How deep will you excavate? How long is the ditch, fence, 

etc? Where will fill be obtained? Where will spoil be dumped? What tools or equipment will be used? 

Are you replacing or repairing a structure? Are you moving dirt in a relatively undisturbed area? Will 

the project reach below or beyond the limits of prior land disturbance? Differentiate between areas 

slated for earth movement versus areas to be inundated only. Is the area to be inundated different from 

the area inundated today, in the recent past, or under natural conditions? Provide acres and/or linear 

meters or feet for all elements of the undertaking.

Environmental Setting: Describe the environmental setting of the Area of Potential Effect. A) What 

was the natural habitat prior to modifications, reclamation, agriculture, settlement? B) What is the landuse history? When was it first settled, modified? How deep has it been cultivated? Grazed? etc. C) 

What is the land-use and habitat today? What natural agents (e.g., sedimentation, or vegetation) or 

cultural agents (e.g., cultivation) might affect the ability to discover cultural resources? D) Do you (or 

does anybody else) know of cultural resources in or near the project area?
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-48 Appendix F. Wildland Fire Management Plan 2004 

Appendix G: Interagency Agreements 

No interagency agreements have been developed. When completed, they will be added here. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-49

Appendix H: Pile Burn Plan Template 

REFUGE OR 

STATION: UNIT:

Prepared By:

Prescribed Fire Specialist Date

Reviewed By:

Refuge Biologist Date

Reviewed By:

Prescribed Fire Burn Boss Date

Reviewed By:

Fire Management Officer Date

Reviewed By:

Biological Investigation Unit Date

Reviewed By:

Refuge Manager Date

The approved Pile Burn Plan constitutes the authority to burn, pending approval of Section 7 

Consultations, Environmental Assessments or other required documents. No one has the authority 

to burn without an approved plan or in a manner not in compliance with the approved plan. Pile 

burning conditions established in the plan are firm limits. Actions taken in compliance with the 

approved Pile Burn Plan will be fully supported, but personnel will be held accountable for actions 

taken which are not in compliance with the approved plan.

Approved By:

Project Leader Date
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-50 Appendix F. Wildland Fire Management Plan 2004 

PILE BURN PLAN 

Note: This plan is intended for burning debris and piles (activity fuels) from refuge operations such 

as fuel break construction and hazard reduction. This plan format should only be used outside of 

declared fire season for the area considered. THIS PLAN IS FOR COMPLEXITY LEVEL 3 PILE 

BURNING. 

Refuge: Refuge Burn Number:

Substation: Fire Number:

Name of Area: Unit Number:

Legal Description: T R S Meridian:

Latitude: Longitude:

County: State:

Checklist: 

1. EA optional. 

2. Resource objectives. 

3. Less than 1 ton per pile, completely dried. 

4. Has minimum resources (equipment & personnel) required. 

5. Has weather parameters been established 

6. Low potential for escape. Good clearance. 

7. No fire behavior prediction required 

8. Can be written to be good up to 3 years per site, with annual review. 

9. Burn day required. 

10. Less than (<) one acre in size. 

11. Complexity level should rate as level 3 

12. Intended for admin sites, campgrounds, occupancy trespass, etc. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-51

Environmental Assessment Met (where documented): 

Estimated Cost: 1202: Funding Code: 

Project Area Description (Attach Map of Burn Area) 

Burn Objectives: 

Number, Species, and Size of Piles: 

Adjacent Fuel Description: 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-52 Appendix F. Wildland Fire Management Plan 2004 

Weather Forecasts 

The Pile Burn Boss is responsible for weather being taken every hour while burning to ensure prescription 

compliance. Contact the Emergency Communications Center (ECC) for weather forecasts and burn day 

designation. Contact ECC by radio when ignition is starting, giving legal description of area burning; and 

when burning is over, giving number of acres or piles burned. 

Prescription: 

Season of Burn (Fall, Spring, Summer, Winter): 

Acceptable Range Desired 

Air Temperature 

Relative Humidity 

Wind Speed 

Fuel Moisture 1 Hour T.L. 

10 Hour T.L. 

100 Hour T.L. 

Adjacent Live Fuel Moisture 

Wind Direction Preferred Acceptable: Unacceptable: 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-53

Smoke Management 

Permitting Agency: 

Total Tons Per Acre Emissions: 

Distance and Direction from Smoke Sensitive Area(s): 

Necessary Transport Wind Direction(s): 

Visibility Hazard(s) (i.e., roads, airports, etc.): 

Actions to Reduce Visibility Hazard(s): 

Can Residual Smoke Be a Problem? 

Other Considerations: 

Special Constraint(s)/Consideration(s): 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-54 Appendix F. Wildland Fire Management Plan 2004 

Firing Technique: 

Holding Force Instructions: 

Mop Up Instructions 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-55

Contact Plan 

Who will notify the following and when? 

Key People: 

Local Landowners: 

Private Land Within Proposed Burn (Identify on Map): 

Fire Protection Agencies: 

Dispatcher: 

Public Affairs Officer: 

News Releases to Local Papers and News Media: 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-56 Appendix F. Wildland Fire Management Plan 2004 

Safety Plan 

All line employees involved in the actual burning of standing and/or piled fuels will have on their person 

and use as necessary the following protective clothing: 

Hard hat 

Goggles 

Gloves 

Fire resistant pants 

Fire resistant shirt 

Fire shelter 

Laced boots as used in fire suppression 

Employees involved in a project with an assignment not related to actual burning should have with them 

all of the above safety equipment and be so equipped if their unplanned duties expose them to line work 

and/or the actual burning. 

Each burning plan will designate fire safety responsibility. This designation should include the following 

considerations: 

Escape routes 

Safety areas 

Closest recognized burn treatment facility and specific methods of travel to burn center or 

hospital 

Hospitals 

Travel Time Helipad Burn 

Center Name Address Air/Ground Phone Yes/No Yes/No 

 

 

 

 

 

 

 

 

Medical Emergency Procedures 

Give First Aid at scene. 

Contact Maui County Fire Department 

Make transportation arrangements. 

Comments: 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-57

Debris & Pile Burning Checklist 

A “NO” response to any item means STOP! 

YES NO

1. Are all fire prescriptions met?

2. Has dispatch been notified?

3. Is it a permissive burn day?

4. Is fire weather forecast favorable?

5. Are all personnel required in the burn plan on site?

6. Have all personnel been briefed on the burn plan requirements?

7. Have all personnel been briefed on safety hazards, escape routes and safety orders?

8. Is all the required equipment in place an in working order?

9. Are all personnel aware of mop up requirements before abandonment?

10. Are all answers to all the above questions “Yes”?

If all ten questions have been answered “Yes”, you may proceed with lighting
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-58 Appendix F. Wildland Fire Management Plan 2004 

Appendix I: Delegation of Authority 

DELEGATION OF AUTHORITY 

Region 1, U.S. Fish and Wildlife Service 

Maui National Wildlife Refuge Complex 

 , you are assigned as Incident Commander of the 

 Incident on the National Wildlife Refuge. You have full 

authority and responsibility for managing the fire suppression operation on this incident within the 

framework of legal statute, current policy, broad direction, and the Wildland Fire Situation Analysis 

(WFSA). Your primary responsibility is to achieve complete control of the fire by organizing and 

directing the fire suppression organization in an effective, efficient, economical and most importantly, 

safe manner. 

You should be guided in your duties by the fire job descriptions relating to Incident Commander, as found 

in the Fireline Handbook. Strongly consider long-term ecosystem health, and the effects of suppression 

actions in the development of appropriate suppression responses. These issues are to be addressed and 

documented in the WFSA. 

You are accountable to the Refuge Manager, of the 

Maui National Wildlife Refuge Complex, who is the Line Officer. may 

serve as the Line Officer Designee for this incident. 

You will immediately notify me in person in the event of: 

(1) a serious injury or fatality, 

(2) threat to private property, 

(3) if the incident exceeds the limits of the selected alternative of the WFSA. 

Much of the Refuge Complex is home to endangered species. Your job as Incident Commander is 

critical, as you must minimize damage to the habitats, as well as provide for firefighter safety. Minimum 

environmental suppression tactics shall be used, commensurate with forecasted and threatened resource 

values. 

You are to be guided by the Wildland Fire Situation Analysis, approved by , 

Project Leader. 

The Resource Advisor assigned to your incident will be .

 

Glynnis Nakai, Refuge Manager Date 

Maui National Wildlife Refuge Complex 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-59

Appendix J: Wildland Fire Situation Analysis 

WILDLAND FIRE 

SITUATION ANALYSIS 

Incident Name: 

Jurisdiction: 

Date and Time Completed: 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-60 Appendix F. Wildland Fire Management Plan 2004 

I. WILDLAND FIRE SITUATION ANALYSIS

A. Jurisdiction(s) B. Geographic Area

C. Unit(s) D. WSFA #

E. Fire Name F. Incident #

G. Accounting Code: 

H. Date/Time Prepared: @

I. Attachments: 

Complexity Matrix/Analysis *

Risk Assessment/Analysis *

Probability of Success *

Consequences of Failure *

Maps *

Decision Tree **

Fire Behavior Projections *

Calculations of Resource Requirements *

Other (specify)

* Required

** Required by FWS

This page is completed by the Agency Administrator(s)
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-61

II. OBJECTIVES AND CONSTRAINTS

A. Objectives (must be specific and measurable)

1. Safety

- Public

- Firefighter

2. Economic

3. Environmental

4. Social

5. Other

B. Constraints
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-62 Appendix F. Wildland Fire Management Plan 2004 

This page is completed by the Agency Administrator(s)
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-63

III. ALTERNATIVES

A B C

A. Wildland Fire Strategy

B. Narrative

C. Resources Needed

Handcrews

Engines

Dozers

Airtankers

Helicopters

D. Final Size

E. Estimated Contain/

Control Date

F. Costs

G. Risk Assessment

Probability of 

Success

Consequences of 

Failure

H. Complexity

I. Attach maps for each alternative
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-64 Appendix F. Wildland Fire Management Plan 2004 

This page is completed by the Agency Administrator(s) and FMO/Incident Commander
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-65

IV. EVALUATION OF ALTERNATIVES

A. Evaluation Process A B C

Safety

Firefighter

Aviation

Public

Sum of Safety Values

Economic

Forage

Improvements

Recreation

Timber

Water

Wilderness

Wildlife

Other (specify)

Sum of Economic Values

Environmental

Air

Visual

Fuels

T & E Species

Other (specify)

Sum of Environmental Values

Social

Employment

Public Concern

Cultural

Other (specify)

Sum of Social Values
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-66 Appendix F. Wildland Fire Management Plan 2004 

Other

This page is completed by the Agency Administrator(s) and FMO/Incident Commander
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-67

V. ANALYSIS SUMMARY

Alternatives A B C

A. Compliance with Objectives

Safety

Economic

Environmental

Social

Other (specify)

B. Pertinent Data

Final Fire Size

Complexity

Suppression Cost

Resource Values

Probability of Success

Consequences of Failure

C. External/Internal Influences

National & Geographic Preparedness Level: 

Incident Priority: 

Resource Availability: 

Weather Forecast (long range): 

Fire Behavior Projections: 

This page is completed by the Agency Administrator(s) and FMO/Incident Commander
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-68 Appendix F. Wildland Fire Management Plan 2004 

VI. DECISION

The Selected Alternative is: 

Rationale: 

 

Agency Administrator’s Signature

 

Date/Time

This page is completed by the Agency Administrator(s) or designate
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-69

VII. DAILY REVIEW

To be reviewed daily to determine if still valid until containment or control

P

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IF WFSA IS NO LONGER VALID, A NEW WFSA WILL BE COMPLETED!
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-70 Appendix F. Wildland Fire Management Plan 2004 

This page is completed by the Agency Administrator(s) or designate
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-71

VIII. FINAL REVIEW

The elements of the selected alternative were met on:

Date Time

By: 

Agency Administrator(s)
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-72 Appendix F. Wildland Fire Management Plan 2004 

INSTRUCTIONS

Section I. WFSA Information Page

A. Jurisdiction(s): Assign the agency or agencies that have or could have fire protection 

responsibility, e.g., USFWS, BLM, etc. 

B. Geographic Area: Assign the recognized "Geographic Coordination Area" the fire is located 

in, e.g., Northwest, Northern Rockies, etc. 

C. Unit(s): Designate the local administrative unit(s), e.g., Hart Mountain Refuge Area, 

Flathead Indian Reservation, etc. 

D. WFSA #: Identify the number assigned to the most recent WFSA for this fire. 

E. Fire Name: Self-explanatory. 

F. Incident #: Identify the incident number assigned to the fire. 

G. Accounting Code: Insert the local unit's accounting code. 

H. Date/Time Prepared: Self-explanatory. 

I. Attachments: Check here to designate items used to complete the WFSA. "Other could 

include data or models used in the development of the WFSA. Briefly describe the "other" 

items used. 

Section II. Objectives and Constraints

A. Objectives: Specify objectives that must be considered in the development of alternatives. 

Safety objectives for firefighter, aviation, and public must receive the highest priority. 

Suppression objectives must relate to resource management objectives in the unit resource 

management plan. 

Economic objectives could include closure of all or portions of an area, thus impacting the 

public, or impacts to transportation, communication, and resource values. 

Environmental objectives could include management objectives for airshed, water quality, 

wildlife, etc. 

Social objectives could include any local attitudes toward fire or smoke that might affect 

decisions on the fire. 

Other objectives might include legal or administrative constraints which would have to be 

considered in the analysis of the fire situation, such as the need to keep the fire off other 

agency lands, etc. 

B. Constraints: List constraints on wildland fire action. These could include constraints to 

designated wilderness, wilderness study areas, environmentally or culturally sensitive areas, 

irreparable damage to resources or smoke management/air quality concerns. Economic 

constraints, such as public and agency cost, could be considered here. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-73

Section III. Alternatives

A. Wildland Fire Management Strategy: Briefly describe the general wildland fire strategies for 

each alternative. Alternatives must meet resource management plan objectives. 

B. Narrative: Briefly describe each alternative with geographic names, locations, etc., that 

would be used when implementing a wildland fire strategy. For example: "Contain within 

the Starvation Meadows' watershed by the first burning period." 

C. Resources Needed: Resources described must be reasonable to accomplish the tasks 

described in Section III.B. It is critical to also look at the reality of the availability of these 

needed resources. 

D. Final Fire Size: Estimated final fire size for each alternative at time of containment. 

E. Estimated Contain/Control Date: Estimates of each alternative shall be made based on 

predicted weather, fire behavior, resource availability, and the effects of suppression efforts. 

F. Cost: Estimate all incident costs for each alternative. Consider mop-up, rehabilitation, and 

other costs as necessary. 

G. Risk Assessment - Probability of Success/Consequences of Failure: Describe probability as 

a percentage and list associated consequences for success and failure. Develop this 

information from models, practical experience, or other acceptable means. Consequences 

described will include fire size, days to contain, days to control, costs, and other information 

such as park closures and effect on critical habitat. Include fire behavior and long-term fire 

weather forecasts to derive this information. 

H. Complexity: Assign the complexity rating calculated in "Fire Complexity Analysis" for each 

alternative, e.g., Type II, Type I. 

I. A map for each alternative should be prepared. The map will be based on the "Probability of 

Success/Consequences of Failure" and include other relative information. 

Section IV. Evaluation of Alternatives

A. Evaluation Process: Conduct an analysis for each element of each objective and each 

alternative. Objectives shall match those identified in Section II.A. Use the best estimates 

available and quantify whenever possible. Provide ratings for each alternative and 

corresponding objective element. Fire effects may be negative, cause no change, or may 

be positive. Examples are: 1) a system which employs a "-" for negative effect, a "0" for no 

change, and a "+" for positive effect; 2) a system which uses a numeric factor for importance 

of the consideration (soils, watershed, political, etc.) and assigns values (such as -1 to +1, - 

100 to +100, etc.) to each consideration, then arrives at a weighted average. If you have the 

ability to estimate dollar amounts for natural resource and cultural values, this data is 

preferred. Use those methods which are most useful to managers and most appropriate for 

the situation and agency. To be able to evaluate positive fire effects, the area must be 

included in the resource management plan and consistent with prescriptions and objectives 

of the Fire Management Plan. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-74 Appendix F. Wildland Fire Management Plan 2004 

Sum of Economic Values: Calculate for each element the net effect of the rating system 

used for each alternative. This could include the balance of pluses (+) and minuses (-), 

numerical rating (-3 and +3), or natural and cultural resource values in dollar amounts. 

(Again, resource benefits may be used as part of the analysis process when the wildland fire 

is within a prescription consistent with approved Fire Management Plans and in support of 

the unit's Resource Management Plan.) 

Section V. Analysis Summary

A. Compliance with Objectives: Prepare narratives that summarize each alternative's 

effectiveness in meeting each objective. Alternatives that do not comply with objectives are 

not acceptable. Narrative could be based on effectiveness and efficiency. For example: 

"most effective and least efficient," "least effective and most efficient," or "effective and 

efficient." Or answers could be based on a two-tiered rating system such as "complies with 

objective" and "fully complies with or exceeds objective." Use a system that best fits the 

manager's needs. 

B. Pertinent Data: Data for this Section has already been presented, and is duplicated here to 

help the Agency Administrator(s) confirm their selection of an alternative. Final Fire Size is 

displayed in Section III.D. Complexity is calculated in the attachments and displayed in 

Section III.H. Costs are displayed on page 4. Probability of Success/Consequences of 

Failure is calculated in the attachments and displayed in Section III.G. 

C. External and Internal Influences: Assign information and data occurring at the time the 

WFSA is signed. Identify the Preparedness Index (1 through 5) for the National and 

Geographic levels. If available, indicate the Incident Priority assigned by the MAC Group. 

Designate the Resource Availability status. This information is available at the Geographic 

Coordination Center, and is needed to select a viable alternative. Designate "yes," 

indicating an up-to-date weather forecast has been provided to, and used by, the Agency 

Administrator(s) to evaluate each alternative. Assign information to the "Other" category as 

needed by the Agency Administrator(s). 

Section IV. Decision

Identify the alternative selected. Must have clear and concise rationale for the decision, and a 

signature with date and time. Agency Administrator(s) is mandatory. 

Section VII. Daily Review 

The date, time, and signature of reviewing officials are reported in each column for each day of 

the incident. The status of Preparedness Level, Incident Priority, Resource Availability, Weather 

Forecast, and WFSA validity is completed for each day reviewed. Ratings for the Preparedness 

Level, Incident Priority, Resource Availability, Fire Behavior, and Weather Forecast are 

addressed in Section V.C. Assign a “yes” under "WFSA Valid" to continue use of this WFSA. A 

"no" indicates this WFSA is no longer valid and another WFSA must be prepared or the original 

revised. 

Section VIII. Final Review 

This Section is completed by the Agency Administrator(s). A signature, date, and time are 

provided once all conditions of the WFSA are met. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-75

A GUIDE FOR ASSESSING FIRE COMPLEXITY

The following questions are presented as a guide to assist the Agency Administrator(s) and staff 

in analyzing the complexity or predicted complexity of a wildland fire situation. Because of the 

time required to assemble or move an Incident Management Team to wildland fire, this checklist 

should be completed when a wildland fire escapes initial attack and be kept as a part of the fire 

records. This document is prepared concurrently with the preparation of (and attached to) a 

new or revised Wildland Fire Situation Analysis. It must be emphasized this analysis should, 

where possible, be based on predictions to allow adequate time for assembling and transporting 

the ordered resources. 

Use of the Guide:

1. Analyze each element and check the response "yes" or "no." 

2. If positive responses exceed, or are equal to, negative responses within any primary 

factor (A through G), the primary factor should be considered as a positive response. 

3. If any three of the primary factors (A through G) are positive responses, this indicates 

the fire situation is, or is predicted to be, Type I. 

4. Factor H should be considered after all the above steps. If more than two of these items 

are answered "yes," and three or more of the other primary factors are positive 

responses, a Type I team should be considered. If the composites of H are negative, 

and there are fewer than three positive responses in the primary factors (A-G), a Type II 

team should be considered. If the answers to all questions in H are negative, it may be 

advisable to allow the existing overhead to continue action on the fire.

GLOSSARY OF TERMS 

Potential for blow-up conditions - Any combination of fuels, weather, and topography 

excessively endangering personnel. 

Rate or endangered species - Threat to habitat of such species or, in the case of flora, threat 

to the species itself. 

Smoke management - Any situation which creates a significant public response, such as 

smoke in a metropolitan area or visual pollution in high-use scenic areas. 

Extended exposure to unusually hazardous line conditions - Extended burnout or backfire 

situations, rock slide, cliffs, extremely steep terrain, abnormal fuel situation such as frost killed 

foliage, etc. 

Disputed fire management responsibility - Any wildland fire where responsibility for 

management is not agreed upon due to lack of agreements or different interpretations, etc. 

Disputed fire policy - Differing fire policies between suppression agencies when the fire 

involves multiple ownership is an example. 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-76 Appendix F. Wildland Fire Management Plan 2004 

Pre-existing controversies - These may or may not be fire management related. Any 

controversy drawing public attention to an area may present unusual problems to the fire 

overhead and local management. 

Have overhead overextended themselves mentally or physically - This is a critical item that 

requires judgment by the responsible agency. It is difficult to write guidelines for this judgment 

because of the wide differences between individuals. If, however, the Agency Administrator 

feels the existing overhead cannot continue to function efficiently and take safe and aggressive 

action due to mental or physical reasons, assistance is mandatory
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-77

FIRE COMPLEXITY ANALYSIS 

A. FIRE BEHAVIOR: Observed or Predicted YES/NO 

 1. Burning Index (from on-site measurement of weather conditions) predicted 

 to be above the 90% level using the major fuel model in which the fire is 

 burning. 

 2. Potential exists for “blowup” conditions (fuel moisture, winds, etc.). 

 3. Crowning, profuse or long-range spotting. 

 4. Weather forecast indicating no significant relief or worsening conditions. 

Total 

B. RESOURCES COMMITTED 

 1. 200 or more personnel assigned. 

 2. Three or more divisions. 

 3. Wide variety of special support personnel. 

 4. Substantial air operation which is not properly staffed. 

 5. Majority of initial attack resources committed. 

Total 

C. RESOURCES THREATENED 

 1. Urban interface. 

 2. Developments and facilities. 

 3. Restricted, threatened, or endangered species habitat. 

 4. Cultural Sites. 

 5. Unique natural resources, special designation zones, or wilderness. 

 6. Other special resources. 

Total 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-78 Appendix F. Wildland Fire Management Plan 2004 

D. SAFETY YES/NO 

 1. Unusually hazardous fire line conditions. 

 2. Serious accidents or fatalities. 

 3. Threat to safety of visitors from fire and related operations. 

 4. Restricted and/or closures in effect or being considered. 

 5. No night operations in place for safety reasons. 

Total 

E. OWNERSHIP 

 1. Fire burning or threatening more than one jurisdiction. 

 2. Potential for claims (damages). 

 3. Conflicting management objectives. 

 4. Disputes over fire management responsibility. 

 5. Potential for unified command. 

Total 

F. EXTERNAL INFLUENCES 

 1. Controversial wildland fire management policy. 

 2. Pre-existing controversies/relationships. 

 3. Sensitive media relationships. 

 4. Smoke management problems. 

5. Sensitive political interests. 

 6. Other external influences. 

Total 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Wildland Fire Management Plan 2004 F-79

G. CHANGE YES/NO 

 1. Change in strategy to confine/contain to control. 

 2. Large amount of unburned fuel within planned perimeter. 

 3. WFSA invalid or requires updating. 

Total 

H. EXISTING OVERHEAD 

 Worked two operational periods without achieving initial objectives. 

 Existing management organization ineffective. 

 IMT overextended themselves mentally and/or physically. 

 Incident action plans, briefings, etc. missing or poorly prepared. 

Total 

I. SIGNATURE 

 

Name and Title Date and Time 
Kakahai„a National Wildlife Refuge Comprehensive Conservation Plan 

F-80 Appendix F. Wildland Fire Management Plan 2004 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Statement of Compliance G-1 

Appendix G. STATEMENT OF COMPLIANCE 

for Implementation of the 

Kakahai‘a National Wildlife Refuge, Maui County, Hawai‘i

Comprehensive Conservation Plan 

The following Executive orders and legislative acts have been reviewed as they apply to 

implementation of the Kakahai‘a NWR CCP. 

National Environmental Policy Act (1969). The planning process has been conducted in 

accordance with NEPA Implementing Procedures, Department of the Interior and Service 

procedures, and has been performed in coordination with the affected public. 

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 (1966). The implementation of the CCP should not affect 

cultural resources. The proposed action does not meet the criteria of an effect or adverse effect as 

an undertaking defined in 36 CFR 800.9 and 614 FW 2. The Service will comply with the 

National Historic Preservation Act if any management actions have the potential to affect any 

historic properties which may be present. 

Executive Order 12372. Intergovernmental Review. Coordination and consultation with 

affected Tribal, local, and State governments, other Federal agencies, and the landowners has 

been completed through personal contact by Service planners, refuge managers, and supervisors. 

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. 

Wilderness Preservation Act of 1964. The Service has evaluated the suitability of the Refuge 

for wilderness designation and determined it does not qualify.

National Wildlife Administration Act of 1966, as amended by the National Wildlife Refuge 

System Improvement Act of 1997 (16 U.S.C. 668dd-668ee). Appropriate Use findings and 

Compatibility Determinations have been prepared for the following uses: Wildlife Observation, 

Interpretation and Photography; Environmental Education; and Research. 

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. 

Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix H. Acronyms and Abbreviations H-1 

Appendix H. Common Acronyms and Abbreviations 

ac acre(s) 

Administration Act National Wildlife Refuge System Administration Act of 1966 

BCE Before Common Era 

BIDEH Biological Integrity, Diversity, and Environmental Health 

BMPs Best Management Practices 

CCP Comprehensive Conservation Plan 

CD Compatibility Determination 

CE Common Era 

CFR Code of Federal Regulations 

cfs cubic feet per second 

CO2 carbon dioxide 

Complex Maui National Wildlife Refuge Complex 

CWRM Commission on Water Resource Management

DBEDT Hawai‘i Department of Business, Economic Development, and Tourism 

DIN dissolved inorganic N concentration 

DLNR Hawai‘i Department of Land and Natural Resources 

DM Department Manual 

DO dissolved oxygen 

DOA Hawai‘i Department of Agriculture

DOCARE Hawai‘i Division of Conservation and Resource Enforcement

DOE Hawai‘i Department of Education 

DOFAW Hawai‘i Division of Forestry and Wildlife 

DOH Hawai‘i Department of Health 

DOI U. S. Department of the Interior 

EA Environmental Assessment 

EE environmental education 

e.g. exempli gratia, “for example”

ENSO El Niño Southern Oscillation 

EPA Environmental Protection Agency 

ESA Endangered Species Act 

F Fahrenheit 

FONSI Finding of No Significant Impact 

ft Feet (Foot) 

GAO Government Accountability Office

GHG greenhouse gas(es) 

gpm gallon (U.S. fluid) per minute

HDOT Hawai‘i Department of Transportation

Improvement Act National Wildlife Refuge System Improvement Act of 1997 

I&M inventory and monitoring 

in inch(es) 

IPCC Intergovernmental Panel on Climate Change 

IPM Integrated Pest Management 

lb(s) pound(s) 

LCA Land Commission Awards 

MCPD Maui County Planning Department 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

H-2 Appendix H. Acronyms and Abbreviations 

mgd million gallons per day 

mi mile(s) 

MLLW mean lower low water 

mm millimeter(s) 

MOA Memorandum of Agreement 

N Nitrogen 

NAGPRA Native American Graves Repatriation Act 

NEPA National Environmental Policy Act 

NOAA National Oceanic and Atmospheric Administration 

NOI Notice of Intent 

NRCS Natural Resources Conservation Service 

NWHI Northwestern Hawaiian Islands 

NWR National Wildlife Refuge 

OPIC Overseas Private Investment Corporation 

PCJV Pacific Coast Joint Venture 

PDO Pacific Decadal Oscillation 

PICCC Pacific Islands Climate Change Cooperative 

ppb parts per billion 

ppm parts per million 

ppt parts per trillion 

PVC polymerizing vinyl chloride

Refuge System National Wildlife Refuge System 

RHPO Regional Historic Preservation Officer 

Service, USFWS U.S. Fish and Wildlife Service 

SHPO State Historic Preservation Officer 

SLAMM Sea Levels Affecting Marshes Model 

SLR Sea Level Rise 

SUP Special Use Permit 

T&E Threatened and Endangered 

USACE U.S. Army Corps of Engineers 

USCG U.S. Coast Guard 

USDA U.S. Department of Agriculture 

USGS U.S. Geological Survey 

WWII World War II 

YCC Youth Conservation Corps 

yd(s) yard(s) 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

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Climate 22: 4261-4280, doi: 10.1175/2009JCLI2833.1 
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compendium for resource managers. Texas Agricultural Extension Service, Kerrville, TX. 

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the Endangered Hawaiian Duck. The Wilson Journal of Ornithology 120(2):311–319. 

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389-395. 

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Honolulu, HI. 

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Yamamoto, Mike N. & Annette W. Tagawa. 2000. Hawai‘i’s native & exotic freshwater animals. 

Mutual Publishing. Honolulu, HI. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix J. Planning Team Members J-1 

Appendix J. Planning Team Members 

The following members of the core planning team were responsible for preparing the CCP. 

Glynnis Nakai Project Leader, Maui NWRC 

Michael Nishimoto Wildlife Biologist, Maui NWRC 

Laura Beauregard Refuge Planner, Hawaiian and Pacific Islands NWRC 

Tim Mayer Hydrologist, Region 1 

The following members of the extended planning team provided assistance and analysis to the core 

planning team of the CCP. 

Arleone Dibben-Young Nēnē o Moloka‘i

Sandra Hall External Affairs Specialist, Hawaiian and Pacific Islands NWRC 

Ben Harrison Deputy Regional Chief, Region 1 

David Hoy GIS Specialist, Region 1 

Kevin Kilbride Wildlife Biologist, Refuge Biology, Region 1 

Mike Marxen Chief, Visitor Services and Communications Division, Region 1 

Barbara Maxfield (former) External Affairs Specialist, Hawaiian and Pacific Islands 

NWRC 

Scott McCarthy Chief, Planning Division, Region 1 

Lisa Oshiro Native Hawaiian Liaison, DOI, Honolulu 

Donald Palawski Deputy Project Leader, Hawaiian and Pacific Islands NWRC 

Benton Pang Native Hawaiian Liaison, Ecological Services, Honolulu 

Fred Paveglio (former) Chief, Branch of Refuge Biology, Region 1 

Anan Raymond Regional Archaeologist, Region 1 

Pat Savino Administrative Assistant, Maui NWRC 

Barry Stieglitz Project Leader, Hawaiian and Pacific Islands NWRC 

Calvin Willis Maintenance Worker, Maui NWRC 

Maps were prepared by David Hoy. 

Graphic design of cover by Patrick Stark. 

Graphic design of Readers Guide by Sandra Hall. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

J-2 Appendix J. Planning Team Members 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix K. Public Comments and Service Responses K-1 

Appendix K. Public Comments and Service Responses 

In this appendix the Service responds to comments that were received on the Keālia Pond NWR 

Draft CCP/EA, August 2011) during the official public comment period from August 19-September 

19, 2011. Comments were received via letter, comment card, and e-mail. All substantial comments 

regarding the Draft CCP/EA are presented below. Some comments have had formatting changes and 

other minor edits to correct spelling or punctuation, but the majority of comments are as received. 

Service responses indicate where changes were made to the CCP based on specific comments. 

Index

1. Claud Sutcliffe, Ph.D. ................................................................................................................... K-1 

2. Gene Anderson .............................................................................................................................. K-2 

3. Arleone Dibben-Young ................................................................................................................ K-2 

4. Bill Feeter ...................................................................................................................................... K-6 

5. Skippy Hau .................................................................................................................................... K-8 

6. Ken Fiske ...................................................................................................................................... K-9 

Comments and Responses

1. Claud Sutcliff, Ph.D. 

Comment: 

I have read the draft CCP and love the Vision (and that it is in Hawaiian first) and preferred 

alternative for Kakahai'a, but understand the realities you face financially, particularly if Fish 

and Wildlife succeeds in getting stewardship for Molokini (which sounds like a good 

idea). For the record, I very much would like to see USFW get the funding necessary to implement 

the preferred alternative for Kakahai'a! p. 3-1 (and the pages that follow) says that Wailau is the East 

Moloka‘i volcano; that's wrong, Kamakou is the volcano, and Wailau is the main valley on the north 

shore... 

Service Response: 

We appreciate the support expressed by these comments. While there is also a “Wailau Valley” on 

this shield volcano, the entire East Moloka‘i volcano is named “Wailau,” according to the U.S. 

Geological Survey (Fields et al. 2008). The place name “Kamakou” is officially designated as the 

summit of Wailau, the highest peak on the southern rim. Please see the following references: 

Feature Detail Report for: Kamakou [http://geonames.usgs.gov/pls/gnispublic]

Field, Michael E., Cochran, Susan A., Logan, Joshua B., and Storlazzi, Curt D., 2008, The south 

Moloka‘i reef; origin, history and status, U.S. Geological Survey Scientific Investigations 

Report 2007-5101, p. 3-10 [http://pubs.usgs.gov/sir/2007/5101/sir2007-5101_intro.pdf] 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

K-2 Appendix K. Public Comments and Service Responses 

Comment: 

p. 3-10 says that Moloka‘i "was first settled in approximately 600 BCE;" some families may claim 

that (and it may even be right), but the earliest date I've ever read in the archeological literature says 

450 CE... 

Service Response: 

We apologize for the typographical error in the Draft CCP/EA. It should have read “600 CE.” The 

text has been revised to “...450-650 CE.”

2. Gene Anderson 

Comment: 

Prefers Alternative C and suggests adding Pueo to species list. 

Service Response: 

We appreciate the support expressed for our preferred alternative. Pueo has been added to our 

species list.

3. Arleone Dibben-Young 

Comment: 

Pg 2-17 Correct the use of ‘okina for ‘Alae ke‘oke‘o 

Pg 5-1 Yuen family, not Ewing. 

Pg 6-7 Estioko-Griffin (1987) reference is missing from Literature Cited 

The commenter also provided substantial historical information on the area.

Service Response: 

Thank you, typographical corrections have been made. Preliminary investigation of the cultural 

history of the Kakahai‘a NWR area will be verified and augmented in a formal archaeological and 

cultural investigation.

Comment: 

Regarding Alternative C as proposed, I ask that reconfiguring the pond to its pre-1900 

shape and size be investigated, not only to increase year round habitat, but to reduce refuge 

operation costs (pumping = costly electricity), perhaps thereby freeing funds for a full-time 

on-island refuge staff. The current practice of managing the water levels of the existing two pond 

system is to pump water year round from the well into the impoundments. In this way, the 

water levels can be managed when necessary, such as during an avian botulism outbreak or 

to kill vegetation that has regenerated when the ponds have dried by flooding. Water level 

management, however, could also be done by pumping water out, when required, to an upland 

containment pond. Re-exposing the fresh water lens floating atop the water table would 

provide year round habitat, and although a botulism outbreak can occur with permanently open 

water, an outbreak could be managed quickly by carcass salvage and without altering the 

water level. 

Service Response: 

The Refuge plans to collect as much data (soils, water resources, etc.) as possible to evaluate and 

design the restoration plan. These data will identify the feasibility of retaining the existing pond 

configurations. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix K. Public Comments and Service Responses K-3 

Comment: 

Although there is the Moloka‘i Human Society on island, their policy is to spay/neuter/release feral 

cats. I suggest a written agreement with the MHS to euthanize predators captured at the refuge or to 

dispatch any such predators on premises. 

Service Response: 

Feral animals will be euthanized upon capture on the Refuge. As identified in this CCP, establishing 

fences to reduce predators (including cats) will be a critical management strategy. 

4. Bill Feeter 

Comment: 

It is not coordinated with other agencies to the fullest and is not holistically planned. Since there is 

no hope for funding I suggest that the USFWS consider private enterprise to operate the reserve. 

Service Response: 

In section 2.3.2 Interagency Coordination and Collaboration we highlighted ecosystem planning 

efforts involve collaboration among Federal, State, and local agencies. We recognize that 

implementation of some strategies in the plan will require this same type of broad collaboration with 

others. We have revised this section to acknowledge that we will strive to collaborate with other 

public and private organizations, as appropriate, to achieve the goals identified in the plan. 

5. Skippy Hau 

Comment: 

I support Alternative C. 5-4. I strongly support maintaining shoreline access to fish and picnic. 

Involving the local community in implementing the proposed plan could be a win-win situation. I 

suggest the predator-proof fencing and its effectiveness in reducing predation could help with 

educating the public. I suggest stressing that visitors will be made up of local classes, teachers, and 

students. 

Service Response: 

More detailed information on interpretation, EE, and target groups will be included in the VSP. 

Chapter 5 has language regarding interpretation, EE, volunteering, and other opportunities for 

island residents. 

Comment: 

Having clear guidelines for flash photography and video cameras would be helpful to explain why 

we prohibit them during turtle nest excavations and their distraction for emerging hatchlings. 

Service Response: 

There is no documented evidence of turtles nesting along the Refuge shoreline but if there should be, 

we would develop guidelines to minimize impacts to adult nesting females and hatchlings at that 

time. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

K-4 Appendix K. Public Comments and Service Responses 

5. Ken Fiske 

Comment: 

This bird list, along with the latter one, includes birds not found on Darlene Fiske’s bird survey. I 

was surprised to see the area along the beach now included as part of the Refuge. Thus, different 

birds not found within the Refuge are included. At one time, site was home to moorhens and they 

need to be reintroduced. 

Service Response: 

The Appendix A Species List is a compilation of species found on the Refuge at various times by 

multiple individuals, dating back to 1981. As such, it is likely to include more species than those 

identified by any one individual. 

The coastal area was included with the acquisition in 1976 and has always been part of the Refuge. 

The direction of this first 15 year plan is to restore the wetlands. Once restored and managed, 

moorhens can be evaluated for repatriation to the Refuge – if they don’t voluntarily return. This 

would likely be included in the next 15-year plan. 

Comment: 

Alternate C is the best plan. Forest habitat should be all native trees. 

Service Response: 

All native species would be ideal; however, restoration of the wetlands is a priority. The forest 

habitat is essential for protecting the wetland from sedimentation from the upper watershed. The 

Refuge will strategically plan the replacement of the invasive pest species with native species while 

preparing the wetland restoration plan and ensure impacts to the wetlands are not exacerbated. 

Comment: 

Restoration of wetland is of first importance, along with a need for permanent staff presence on the 

site. There is a need to involve the Natural Resource Conservation Service and 

the Moloka‘i-Lana‘i Soil and Water Conservation District, which can address the alternate 

components not within the scope of the Fish and Wildlife Service. 

Service Response:

An onsite employee is a need identified in the preferred alternative, Alt. C., and similar to other 

strategies, is dependent upon future funding. Both agencies identified by the commenter are partners 

within the East Moloka‘i Watershed Committee and the Sedimentation Committee, partners have 

been identified in 2.2.2 Interagency Coordination and Collaboration.

Comment: 

Information from the airport does not transpose to the Refuge. 

Service Response:

The weather data from the airport is of importance even though the distance is away from the 

Refuge. The weather station at the airport is the closest monitoring system and we need to know how 

it differs from the Refuge. This information will remain in the final CCP as a future reference. The 

Refuge used to have a weather station and it will need to be reinstalled as the wetlands are restored. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

Appendix K. Public Comments and Service Responses K-5 

Comment: 

Herbicides were once applied to the bulrush and were ineffective. Any pesticide application should 

have assurance of working and a label which will not endanger the birds for which the Refuge is 

being created. 

Service Response:

The Refuge is cognizant of label restrictions and proper applications. The plan is to remove 

California bulrush as completely as possible. Herbicides would be used to hold back and prevent reestablishment of invasive pest species. 
Kakahai‘a National Wildlife Refuge Comprehensive Conservation Plan 

K-6 Appendix K. Public Comments and Service Responses