Hanalei

National Wildlife Refuge

Environmental Assessment for

Draft Wetlands Management and

Waterbird Conservation Plan

U.S. Fish & Wildlife Service

ENVIRONMENTAL ASSESSMENT FOR 

DRAFT WETLANDS MANAGEMENT AND 

WATERBIRD CONSERVATION PLAN

Hanalei National Wildlife Refuge

HAWAI’I

AUGUST 2020 

Prepared by

U.S. Fish and Wildlife Service - Pacific Region

911 NE 11th Avenue 

Portland, Oregon 97232 

and 

Hanalei National Wildlife Refuge

Kaua‘i National Wildlife Refuge Complex 

P.O. Box 1128 

Kīlauea, Hawai‘i 96754

Estimated Lead Agency Total Costs (Rounded to Nearest Thousand) Associated with Developing 

and Producting this Environmental Assessment: $50,000
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

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Availability of Environmental Assessment and Draft Plan

We are requesting public comments on the Draft Wetlands Management and Waterbird Conservation 

Plan (dWMWCP) and Environmental Assessment (EA), draft Appropriate Use Findings (AUFs), and 

draft Compatibility Determinations (CDs). Availability of materials for review and comment will be 

announced via direct mailings, media releases, and public meetings. The plan, AUFs, and CDs may 

be modified between the draft and final depending upon comments received from the public or other 

agencies and organizations. As part of the public notice and review process, the dWMWCP and EA 

will be available for a 30-day review. Comments or requests for additional information may be 

submitted through any of the following methods: 

Email: hanalei@fws.gov. Include “Hanalei NWR Wetlands Management and Waterbird 

Conservation Plan” in the subject line of the message. 

U.S. Mail: U.S. Fish and Wildlife Service, Attn: Heather Tonneson, Project Leader, P.O. Box 1128, 

Kīlauea, Hawaii 96754. 

Fax: Attn: Hanalei NWR Wetlands Management and Waterbird Conservation Plan, (808) 828-6634. 

All comments received from individuals become part of the official public record. We will handle all 

requests for such comments in accordance with the Freedom of Information Act and CEQ’s NEPA 

regulations in 40 CFR 1506.6(f). Our practice is to make comments, including names and home 

addresses of respondents, available for public review during regular business hours. Individual 

respondents may request that we withhold their home address from the record, which we will honor 

to the extent allowable by law. If you wish us to withhold your name and/or address, you must state 

this prominently at the beginning of your comments.

Determination: 

This section will be filled out upon completion of any public comment period and at the time of 

finalization of the Environmental Assessment.

☐ The Service’s action will not result in a significant impact on the quality of the human 

environment. See the attached “Finding of No Significant Impact”. 

☐ The Service’s action may significantly affect the quality of the human environment and the 

Service will prepare an Environmental Impact Statement.

Preparer Signature: __________________________________________Date:________

Name/Title/Organization: __________________________________________________ 

________________________________________________________________________

Reviewer Signature: _________________________________________Date:________

Name/Title: ______________________________________________________________
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

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Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

Table of Contents i

TABLE OF CONTENTS

Table of Contents....................................................................................................................................i

Abbreviations........................................................................................................................................iv

Executive Summary...............................................................................................................................v

Section 1. Purpose and Need for the Action ..........................................................................................1

1.1 Proposed Action .....................................................................................................................1

1.2 Background.............................................................................................................................1

1.3 Purpose and Need for the Proposed Action............................................................................2

Section 2. Management Alternatives.....................................................................................................4

2.1 Actions Common to All Alternatives.....................................................................................4

2.2 Alternative A – Current Management (No-Action Alternative).............................................9

2.3 Alternative B – Implementation of Wetlands Management and Waterbird Conservation 

Plan – (Proposed Action Alternative)..............................................................................................11

2.4 Alternative(s) Considered, But Dismissed From Further Consideration..............................16

2.4.1 Cultivation of Genetically Modified Crops ..................................................................16

2.4.2 Eliminating Kalo Farming ............................................................................................17

Section 3. Affected Environment and Environmental Consequences .................................................20

3.1 General Setting .....................................................................................................................21

3.2 Threatened and Endangered Species and Other Special Status Species...............................21

3.2.1 Affected Environment...................................................................................................21

3.2.2 Effects of Alternative A (No-action).............................................................................22

3.2.3 Effects of Alternative B (Proposed Action)..................................................................27

3.3 Other Wildlife and Aquatic Species.....................................................................................30

3.3.1 Affected Environment...................................................................................................30

3.3.2 Effects of Alternative A (No-action).............................................................................31

3.3.3 Effects of Alternative B (Proposed Action)..................................................................31

3.4 Water Resources (Hydrology, Water Quality) .....................................................................31

3.4.1 Affected Environment...................................................................................................31

3.4.2 Effects of Alternative A (No-action).............................................................................32

3.4.3 Effects of Alternative B (Proposed Action)..................................................................34

3.5 Geology and Soils.................................................................................................................36

3.5.1 Affected Environment...................................................................................................36

3.5.2 Effects of Alternative A (No-action).............................................................................36

3.5.3 Effects of Alternative B (Proposed Action)..................................................................37
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

ii Table of Contents

3.6 Visitor Use and Experience ..................................................................................................38

3.6.1 Affected Environment...................................................................................................38

3.6.2 Effects of Alternative A (No-action).............................................................................38

3.6.3 Effects of Alternative B (Proposed Action)..................................................................38

3.7 Cultural Resources................................................................................................................39

3.7.1 Affected Environment...................................................................................................39

3.7.2 Effects of Alternative A (No-action).............................................................................39

3.7.2 Effects of Alternative B (Proposed Action)..................................................................40

3.8 Land Use...............................................................................................................................40

3.8.1 Affected Environment...................................................................................................40

3.8.2 Effects of Alternative A (No-action).............................................................................41

3.8.3 Effects of Alternative B (Proposed Action)..................................................................41

3.9 Refuge Administration..........................................................................................................41

3.9.1 Affected Environment...................................................................................................41

3.9.2 Effects of Alternative A (No-action).............................................................................42

3.9.3 Effects of Alternative B (Proposed Action)..................................................................42

3.10 Local and Regional Economies............................................................................................42

3.10.1 Affected Environment...................................................................................................42

3.10.2 Effects of Alternative A (No-action).............................................................................42

3.10.3 Effects of Alternative B (Proposed Action)..................................................................43

3.11 Sector of the Economy (Agriculture) ...................................................................................44

3.11.1 Affected Environment...................................................................................................44

3.11.2 Effects of Alternative A (No-action).............................................................................45

3.11.3 Effects of Alternative B (Proposed Action)..................................................................45

3.12 Environmental Justice...........................................................................................................46

3.12.1 Affected Environment...................................................................................................46

3.12.2 Effects of Alternatives ..................................................................................................46

3.13 Cumulative Impact Analysis.................................................................................................47

3.13.1 Other Past, Present, and Reasonably Foreseeable Activity Impacting Affected 

Environment ................................................................................................................................47

3.14 Monitoring............................................................................................................................49

3.15 Summary of Analysis ...........................................................................................................49

3.15.1 Alternative A – No-Action Alternative.........................................................................49

3.15.2 Alternative B – Proposed Action Alternative ...............................................................50

List of Preparers...................................................................................................................................51

References............................................................................................................................................52
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

Table of Contents iii

Appendix A. Consultation, Coordination, and Public Outreach..........................................................57

Appendix B: Other Applicable Statutes, Executive Orders, and Regulations.....................................60

Figures

Figure 1. Alternative A (No-Action Alternative) wetland habitat units and other managed areas.....18

Figure 2. Alternative B (Proposed Action Alternative) wetland habitat units and other management 

areas. ....................................................................................................................................................19

Tables

Table 1. Summary of Differences between Alternatives A and B.......................................................13
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

iv Abbreviations

ABBREVIATIONS

AHWP annual habitat work plan

AUF appropriate use findings

AVMA American Veterinary Medical 

Association

BIDEH Biological Integrity, Diversity, and 

Environmental Health 

BMP best management practices

CAA Cooperative Agricultural Agreement

CD compatibility determinations 

CEQ Council on Environmental Quality

CFR Code of Federal Regulations 

cfs cubic feet per second

CZM Coastal Zone Management 

DM Department Manual

DO dissolved oxygen

DOI Department of the Interior 

dWMWCP Draft Wetlands Management and 

Waterbird Conservation Plan 

EA Environmental Assessment

EIS Environmental Impact Statement 

EO Executive Order

EPA Environmental Protection Agency

ESA Endangered Species Act of 1973

FONSI Finding of No Significant Impact 

FW U.S. Fish and Wildlife Service 

Manual

GMC Genetically modified crops

HDBEDT Hawai‘i Department of 

Business, Economic Development, 

and Tourism 

HDOH Hawai’i State Department of Health

HNWRHAD Hanalei National Wildlife 

Refuge Historic and Archaeological 

District

I&M Inventory & Monitoring

IMP Inventory and Monitoring Plan

IPM Integrated Pest Management 

KNWRC Kaua‘i National Wildlife 

Refuge Complex 

MBTA Migratory Bird Treaty Act of 1918

NAGPRA Native American Graves Protection 

and Repatriation Act

NEPA National Environmental Policy Act 

NHPA National Historic Preservation Act of 

1966 

NOAA National Oceanic and Atmospheric 

Administration

NTHP National Trust for Historic 

Preservation

NRCS Natural Resources Conservation 

Service

NRHP National Register of Historic Places

NWR or Refuge National Wildlife Refuge 

NWRS or Refuge System National Wildlife 

Refuge System 

ORP oxidation/reduction potential

QMUA Quarterly Management Unit 

Assessments 

Refuge Administration Act National Wildlife 

Refuge System Administration Act of 

1966

Refuge Improvement Act National Wildlife 

Refuge System Improvement Act of 

1997 

RHPO Regional Historic Preservation Office 

RM Refuge Manual

SHPD State Historic Preservation Division 

SHPO State Historic Preservation Office 

SLR Sea level rise

SUP Special Use Permit

TMDL total maximum daily loads

U.S.C. United States Code 

USFWS or Service U.S. Fish and Wildlife 

Service 

WMWCP Wetlands Management and 

Waterbird Conservation Plan
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

Executive Summary v

EXECUTIVE SUMMARY

The United States Fish and Wildlife Service (Service) is proposing to implement a Wetlands 

Management and Waterbird Conservation Plan (WMWCP) on Hanalei National Wildlife Refuge 

(Refuge), Kaua‘i County, Hawaii. In accordance with the National Environmental Protection Act 

(NEPA), this Environmental Assessment (EA) presents a need for the proposal, examines a range of 

management alternatives, analyzes possible environmental effects of the alternatives, and serves as 

the basis for a decision by the Service on which alternative to implement. The management actions 

being presented in this EA include: Alternative A (no-action alternative; continue existing 

management) and Alternative B (action alternative; modified habitat management processes and 

procedures on approximately 480 acres of rotational managed wetland [moist-soil] units, lo‘i kalo 

[wetland taro fields], ditches and dikes, fallow, riparian habitat, and associated uplands to provide for 

the life history needs of threatened and endangered Hawaiian waterbirds and other native wildlife 

and plants). Alternative B would include changes to the Refuge’s farming program, which would be

conducted by permittees/cooperators under Cooperative Agriculture Agreements (CAAs), to improve 

habitat conditions for threatened and endangered waterbirds; restoration of 3–18 acres of wetlands

and 14–24 acres of riparian grasslands; and enhancement of 21 acres of koloa maoli (Hawaiian duck, 

Anas wyvilliana) nesting habitat. Neither alternative is expected to cause significant, irreversible 

impacts to the environment; therefore, the anticipated determination is a Finding of No Significant 

Impact (FONSI).
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

vi Executive Summary

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Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

Section 1. Purpose and Need 1

SECTION 1. PURPOSE AND NEED FOR THE ACTION

This Environmental Assessment (EA) is being prepared to evaluate the effects associated with the 

Draft Wetlands Management and Waterbird Conservation Plan (dWMWCP; proposed action) and 

complies with the National Environmental Policy Act (NEPA) in accordance with Council on 

Environmental Quality (CEQ) regulations (40 Code of Federal Regulations [CFR] 1500–1509) and 

Department of the Interior (DOI; 43 CFR 46; 516 Departmental Manual [DM] 8) and United States 

Fish and Wildlife Service (USFWS or Service; 550 U.S. Fish and Wildlife Service Manual [FW] 3) 

regulations and policies. NEPA requires examination of the effects of proposed actions on the natural 

and human environment. 

1.1 PROPOSED ACTION

The Service is proposing to implement a Wetlands Management and Waterbird Conservation Plan 

(WMWCP; USFWS 2020) on Hanalei National Wildlife Refuge (NWR or Refuge) in Kaua‘i 

County, Hawaii. Under the WMWCP, the Service would modify habitat management processes and 

procedures on approximately 480 acres of rotational managed wetland (moist-soil) units, lo‘i kalo 

(wetland taro fields), ditches and dikes, fallow, riparian habitat, and associated uplands to provide for 

the life history needs of threatened and endangered Hawaiian waterbirds1 (koloa maoli [Hawaiian 

duck, Anas wyvilliana], ‘alae ke‘oke‘o [Hawaiian coot, Fulica alai], ‘alae ‘ula [Hawaiian common 

gallinule, Gallinula galeata sandvicensis], ae‘o [Hawaiian stilt, Himantopus mexicanus knudseni], 

and nēnē [Hawaiian goose, Branta sandvicensis]), and other native wildlife and plants. This would 

include changes to the Refuge’s farming program, which would be conducted by permittees/

cooperators under Cooperative Agriculture Agreements (CAAs), as required by federal law and 

policy, to improve habitat conditions for threatened and endangered waterbirds. The Service is also 

proposing to restore 3–18 acres of wetlands, restore 14–24 acres of riparian grasslands for nēnē 

breeding and foraging, and enhance 21 acres of koloa maoli nesting habitat. 

A proposed action is often iterative and may evolve during the NEPA process as the agency refines 

its proposal and gathers feedback from the public and other agencies. Therefore, the final proposed 

action may be different from the original. The proposed action will be finalized at the conclusion of 

the public comment period for the EA.

1.2 BACKGROUND

NWRs are guided by the mission and goals of the National Wildlife Refuge System (NWRS or 

Refuge System), the purposes of an individual refuge, Service policy, and laws and international 

treaties. Relevant guidance includes the National Wildlife Refuge System Administration Act of 

1966 (Refuge Administration Act), as amended by the National Wildlife Refuge System 

Improvement Act of 1997 (Refuge Improvement Act), Refuge Recreation Act of 1962, and selected 

portions of the CFR and FW. 

1 Throughout the document, the term “threatened and endangered waterbirds” will be used to refer collectively to 

these five species.
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

2 Section 1. Purpose and Need

The mission of the NWRS, as outlined by the Refuge Administration Act, as amended by the Refuge 

Improvement Act (16 United States Code [U.S.C.] 668dd et seq.), is to:

“... 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 Refuge Administration Act mandates the Secretary of the Interior in administering the National 

Wildlife Refuge System to:

• Provide for the conservation of fish, wildlife, and plants, and their habitats within the NWRS;

• Ensure that the biological integrity, diversity, and environmental health of the NWRS are 

maintained for the benefit of present and future generations of Americans;

• Ensure that the mission of the NWRS described at 16 U.S.C. 668dd(a)(2) and the purposes of 

each refuge are carried out;

• Ensure effective coordination, interaction, and cooperation with owners of land adjoining 

refuges and the fish and wildlife agency of the States in which the units of the NWRS are 

located;

• Assist in the maintenance of adequate water quantity and water quality to fulfill the mission 

of the NWRS and the purposes of each refuge; and

• Monitor the status and trends of fish, wildlife, and plants in each refuge.

Hanalei NWR is located in northern Kaua‘i in Hanalei Valley and contains one of the first protected 

wetlands in the State of Hawai‘i. The 917-acre Refuge was established in 1972 under the authority of 

the Endangered Species Conservation Act of 1969 (16 U.S.C. 668aa; Statute 275) to aid in the 

recovery of federally endangered Hawaiian waterbirds through the preservation and management of 

habitat. The purpose of Hanalei NWR is to “conserve (A) fish or wildlife which are listed as 

endangered species or threatened species .... or (B) plants ...” 16 U.S.C. § 1534 (ESA; Endangered

Species Act of 1973).

Hanalei NWR is one of two Refuges in the state where wetland habitat is managed to support all life 

history needs for five of the federally listed Hawaiian waterbirds year-round. Hanalei NWR 

represents 70 percent of the core habitat on Kaua‘i designated as essential to the recovery and 

delisting of four endangered waterbirds (USFWS 2011). Hanalei NWR currently permits kalo (taro, 

Colocasia esculenta) farming as a Refuge management economic activity to provide additional 

shallow-water habitat used by threatened and endangered waterbirds for foraging, loafing, and 

breeding. Until recently, kalo farming was authorized through general Special Use Permits (SUPs). 

Under the Service’s 2017 updated Cooperative Agriculture policy (620 FW 2), CAAs must be in 

place. Kalo farming existed prior to and at the time of the establishment of the Refuge and is 

culturally and economically important both to the State of Hawai‘i and local communities. 

Approximately, 40 to 60 percent of Hawai‘i’s kalo is grown on the Refuge (Gutscher-Chutz 2011; 

NASS 2012; Cho, Yamakawa, and Hollyer 2007).

1.3 PURPOSE AND NEED FOR THE PROPOSED ACTION

The purposes of this proposed action are to protect, restore, enhance, and manage wetland habitats of 

Hanalei NWR to meet the life history needs of threatened and endangered waterbirds to promote 

their recovery; and to protect, restore, and manage the riparian ecosystem to benefit the Refuge’s 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

Section 1. Purpose and Need 3

native plant and animal communities. The proposed action would meet the Service’s priorities and 

mandates as outlined by the Refuge Administration Act to “provide for the conservation of fish, 

wildlife, and plants, and their habitats within the NWRS;” to “ensure that the biological integrity, 

diversity, and environmental health of the NWRS are maintained for the benefit of present and future 

generations of Americans;” to “assist in the maintenance of adequate water quantity and water 

quality to fulfill the mission of the NWRS and the purposes of each refuge;” and to “monitor the 

status and trends of fish, wildlife, and plants in each refuge” [16 U.S.C. 668dd(a)(4))]. 

The needs of the proposed action are to: 

(1) Improve the Refuge’s habitats for priority species and adjust habitat management processes 

and procedures to better meet life history requirements of threatened and endangered waterbirds; 

(2) Reduce losses of threatened and endangered waterbirds due to predation by, competition with, 

or hybridization with non-native species; 

(3) Reduce losses of threatened and endangered waterbirds to disease; and 

(4) Ensure that the Refuge’s farming and grazing programs are compatible with the Refuge 

purpose of recovering threatened and endangered species, and in compliance with applicable 

laws, regulations, and policies including the revised Service policy on Cooperative Agricultural 

Use (620 FW 2). 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

4 Section 2. Management Alternatives

SECTION 2. MANAGEMENT ALTERNATIVES

The Refuge has prepared a dWMWCP for the Hanalei NWR (USFWS 2020), which describes the 

proposed Action Alternative in detail. The following is a brief summary of the no-action alternative 

(Alternative A) and the action alternative (Alternative B; implementation of the dWMWCP).

2.1 ACTIONS COMMON TO ALL ALTERNATIVES

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

redundancy of the individual alternative descriptions. For more information, refer to Section 4.1 in 

the dWMWCP.

Adaptive Management. Based upon the Adaptive Management Implementation policy (522 DM 1), 

the Refuge will employ adaptive management for conserving, protecting, and where appropriate, 

restoring lands and resources. The DOI Adaptive Management Technical Guide 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. Careful monitoring of these outcomes both advances scientific understanding and helps 

adjust policies or operations as part of an iterative learning process” (Williams, Szaro, and Shapiro 

2009). 

As described in the Service’s Habitat Management Planning policy (620 FW 1), annual habitat work 

plans (AHWPs) provide the mechanism for effectively implementing adaptive management on a 

refuge over time. Specifically, adaptive management entails assessing and modifying management 

actions, as necessary, in order to achieve habitat objectives. Management strategies and prescriptions 

are evaluated by comparing results to desired outcomes to assess their effectiveness. The Refuge staff 

has articulated specific and measurable habitat management objectives associated with wetland 

management and waterbird conservation (see Sections 4.2 and 4.3 in the dWMWCP), where Refuge 

surveys within its forthcoming Inventory and Monitoring Plan would be assessing progress toward 

achieving them. Documenting survey results provides a feedback loop to inform any needed and 

timely adjustments to management actions. Because planned and implemented management actions 

to achieve habitat objectives would be documented by Refuge staff and permittees (kalo farming and 

livestock grazing) using a format consistent with specifications for AHWPs (620 FW 1, Exhibit 2), 

the Refuge staff would be supporting the fundamental components of managing Refuge resources 

adaptively (objectives, documenting management actions, and implementing surveys to evaluate 

progress) in accordance with Service and Departmental policies described herein.

Avian Botulism Surveillance and Control. Refuge staff, interns, and volunteers will continue to 

conduct regular surveillance of lo‘i kalo and rotational managed wetland units in order to control and 

minimize the outbreak of avian botulism. Research and monitoring on the potential environmental 

drivers of avian botulism outbreaks (e.g., water quality and water use) will continue. Methods for 

improving efficiency and detection of avian botulism will continue to be explored. These currently 

include the use of highly trained dogs to locate carcasses and the development of a new diagnostic 

assay, which uses samples from avian blood, native and invasive invertebrates, fish, and/or 

amphibians. Other methods for responding to avian botulism outbreaks include immediate response 

for dead bird removal and sick bird treatment, as well as working with farmers on water management 

and other best management practices (BMPs) in accordance with the avian botulism prevention and

response protocol. 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

Section 2. Management Alternatives 5

The Refuge will continue to monitor and manage water levels to provide suitable waterbird habitat 

and prevent disease outbreaks such as avian botulism. Continued efforts over the life of this plan to 

improve various aspects of the Refuge water delivery infrastructure (e.g., supply pipelines, ditches 

and valves, water control structures, drains) will increase water quantity, improve water flushing 

ability, and reduce water temperatures where they are most needed. These efforts will help to 

minimize the presence of conditions conducive to botulism spore germination and with proper water 

management, will reduce the severity of outbreaks as they occur, especially in the northern kalo 

farming units on Hanalei NWR, which have been identified as avian botulism hotspots.

Cooperative Agricultural Use. In August 2017, the Service finalized the revised Cooperative 

Agricultural Use policy, which outlines objectives for the use of cooperative agriculture on Refuge 

System lands and provides an open, transparent, and competitive process for CAAs on refuges in 

compliance with the DOI policy on procurement contracts, grants, and cooperative agreements (505 

DM 2). Additional federal laws providing authorities for this policy include the Federal Grant and 

Cooperative Agreement Act (31 U.S.C. 6301–6308), Fish and Wildlife Coordination Act (16 U.S.C.

661–667e), Migratory Bird Conservation Act (16 U.S.C. 715), Refuge Administration Act (16 U.S.C.

668dd), Refuge Revenue Sharing Act (16 U.S.C. 715s), and Refuge System regulations on economic 

uses and cooperative land management (50 CFR 29.1–29.2). Per policy, cooperative agriculture is 

when a person or entity uses agricultural practices on Refuge System lands in support of objectives 

for target species or their associated habitats that represent the biological outcomes the Service 

desires, and there is substantial involvement between the Service and the person or entity. Our policy 

is to use cooperative agriculture as a habitat management tool only in situations where we cannot 

meet our resource management objectives through maintenance, management, or mimicking of 

natural ecosystem processes or functions. 

All agricultural uses on Hanalei NWR which are appropriate and compatible, specified in a current 

management plan for the refuge, and cooperative in nature must be documented and awarded using a 

CAA through an open and competitive process. All CAAs must be in compliance with legal 

requirements for federal actions (e.g., NEPA; National Historic Preservation Act of 1966 [NHPA] 

Section 106; ESA Section 7). This EA, along with associated documents (e.g., the dWMWCP and 

compatibility determinations) will fulfill the prerequisites for initiating an open and competitive 

process for selecting and awarding CAAs.

Under both alternatives, existing permittees who currently farm kalo on the Refuge and new CAA 

permit applicants would be required to apply for permits through a competitive application process. 

The Cooperative Agricultural Use policy allows for permits with terms of up to five years, subject to 

regular ongoing compliance review. Formerly, permits were allocated based on prior historic use and 

yearly compliance with permit terms. Under the revised policy, permits would be allocated based on 

farming experience and history, capacity (e.g., equipment), and ability and willingness to work with 

the Service to implement requirements and BMPs for farming in sustainable and wildlife-compatible 

ways. 

Cost-sharing and Fair Market Value Study. Per the Cooperative Agricultural Use policy (620 FW 

2), cost-sharing is defined as the portion of the costs for cooperative agriculture on Refuge System 

lands that are borne by the cooperator. Cost-sharing can vary depending on the needs and objectives 

of the particular refuge land. For example, the Service may provide the cooperator with the right to 

perform agricultural practices on Refuge land and a percentage of any resulting crop yield, as well as 

the ability to use Service allocated water, equipment, or Refuge staff time, depending on alignment 

with USFWS mandates and agreement structure. In exchange, the cooperator may provide the 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

6 Section 2. Management Alternatives

Service with labor, equipment, and materials; a percentage of any resulting crop yield; or 

maintenance, rehabilitation, or reestablishment of specific habitat conditions on Refuge lands.

The Service policy on the administration of specialized uses (5 Refuge Manual [RM] 17) requires 

that specialized uses, which include economic, recreational, right-of-way, and other privileged uses, 

must be accompanied by a fee or cooperative exchange to recover the costs of administering the 

special use permit and use and/or the fair market value of the benefit received.

To comply with these above policies, under all alternatives, the Service will continue to work 

cooperatively with kalo farmers to describe and quantify the costs of the goods and services the 

Service provides to the farmers, the benefits the Service receives as a result of allowing kalo farming 

on the Refuge, and the fair market value for kalo farming (including evaluation of land rents for 

comparable agriculture-related residential and farm-storage uses) to develop a fair and rational costsharing program related to kalo farming. This study will facilitate collaboration between the Service 

and the kalo farmers by providing cost-benefit analysis and illustrating both parties’ responsibilities 

and contributions towards kalo farming on the Refuge. The details of the cost-sharing program are 

not determined at this time and will be developed and shared with the public prior to the application 

process.

Cultural and Historic Resource Protection and Section 106 Compliance. Cultural and historic 

resources on refuges receive protection and consideration in accordance with federal cultural 

resources laws, Executive Orders, regulations, and policies and procedures established by the DOI 

and the Service. Actions with the potential to affect cultural and historic resources will undergo a 

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

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

archaeological and cultural surveys) under Section 106 of the NHPA. The Service will provide our 

Regional Historic Preservation Officer (RHPO) a description and location of projects and activities 

that affect ground and structures, including project requests from third parties. Information will 

include any alternatives being considered. We will also coordinate and consult with the State Historic 

Preservation Division (SHPD) and seek assistance from the Native Hawaiian community and 

organizations on issues related to cultural resources, education, and interpretation; special programs;

and NHPA. 

Implementation Subject to Funding Availability. After the WMWCP is completed, actions will be 

implemented as funding becomes available. Draft project priorities and projected staffing/funding 

needs are in Appendix E of the WMWCP, although special funding initiatives, unforeseeable 

management issues, and other budget issues will likely require adjustments to the implementation 

schedule in the future. The WMWCP assumes adequate staffing and funding for implementation. 

However, without these resources some strategies may be deferred or modified.

Integrated Pest Management (IPM). Pests are defined as “living organisms that may interfere with 

the site-specific purposes, operations, or management objectives or that jeopardize human health or 

safety” from Department policy 517 DM 1 (Integrated Pest Management Policy). Similarly, 569 FW 

1 defines pests as “invasive plants and introduced or native organisms that may interfere with 

achieving our management goals and objectives on or off our lands, or that jeopardize human health 

or safety.” 517 DM 1 also defines an invasive species as “a species that is non-native to the 

ecosystem under consideration and whose introduction causes or is likely to cause economic or 

environmental harm or harm to human health.” Throughout the remainder of this EA, the terms pest 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

Section 2. Management Alternatives 7

and invasive species are used interchangeably because both can prevent/impede achievement of 

refuge wildlife and habitat objectives and/or degrade environmental quality.

In accordance with DOI and Service policies 517 DM 1 and 569 FW 1 respectively, an IPM 

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

(herein collectively referred to as pests) on the Refuge. IPM uses methods based upon effectiveness, 

cost, and minimal ecological disruption, while minimizing potential effects to nontarget species and 

the Refuge environment. Pesticides may be used where mechanical/physical (e.g., mowing, brushcutting, excavation, prescribed fire), cultural (e.g., water levels), and/or biological methods are 

impractical or incapable of providing adequate control, eradication, or containment. If a pesticide 

would be needed on Refuge lands or waters, the most specific (selective) chemical available for the 

target species would be used unless considerations of persistence or other environmental or biotic 

hazards would preclude it. In accordance with 517 DM 1, pesticide usage would be further restricted 

because only pesticides registered with the Environmental Protection Agency (EPA) in full 

compliance with the Federal Insecticide, Fungicide, and Rodenticide Act and as provided in 

regulations, orders, or permits issued by EPA may be applied on lands and waters under Refuge 

jurisdiction.

The Refuge’s year-round program to control introduced predators is aimed at minimizing entry of 

species that threaten threatened and endangered species populations and native ecosystems. Methods 

include exclusion (e.g., fences, fish screens), habitat modification (e.g., removal of nonnative trees 

used by introduced cattle egrets for roosting, water drawdowns), hazing (e.g., for nonnative animal 

species), and control/eradication (e.g., reducing or eliminating populations of ants, mice, rats, barn 

owls, feral cats, feral dogs, feral pigs, and mongooses, if they are detected). 

Pesticides, including periodic use of five percent borax (sodium tetraborate decahydrate), will 

continue to be used to control invasive ants that threaten threatened and endangered nesting birds. 

Humane kill traps will continue to be used to control rats and mice. Live traps will be used to capture 

nonnative animals such as bullfrogs, barn owls, and feral domestic animals (chickens, cats, dogs, and 

pigs). In addition to other methods, pellet guns may be used to humanely dispatch nonnative trapped 

rats, feral chickens, amphibians, and small reptiles. When other methods are impractical or unsafe, 

firearms will be employed to humanely dispatch introduced predators and other nonnative animals 

such as feral cats, feral pigs, feral chickens, barn owls, and cattle egrets. Given the need to minimize 

stress on animals, shooting at times is the most practical, humane, and effective method, particularly 

for wild or free-ranging animals. All methods of animal dispatch will follow the American 

Veterinary Medical Association (AVMA) guidelines for euthanasia (AVMA 2013). Firearms, which 

include pellet guns, will only be used by highly skilled shooters trained and federally certified in their 

use (USFWS 2017). Control of introduced predators and pests will be conducted by trained Service 

staff, volunteers, or contractors. 

See Appendix D in the dWMWCP for the Refuge’s IPM program documentation to manage pests. 

Inventory, Monitoring, and Research. Inventory and monitoring (I&M) is required on Refuge 

System units based on legal mandates including the Refuge Improvement Act; NEPA final rule (43 

CFR 46); and NEPA and agency decision-making (40 CFR 1505); as well as DOI and Service 

policies such as Habitat Management (620 FW 1); Biological Integrity, Diversity, and Environmental 

Health (BIDEH; 601 FW 3); Compatibility (603 FW 2); Fire Management (621 FW 1); IPM (517 

DM 1, 569 FW 1); and Adaptive Management (522 DM 1). 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

8 Section 2. Management Alternatives

Inventory and monitoring on refuges is intended to: 

(1) Gather baseline data and record benchmark conditions used to support refuge planning; 

(2) Estimate the status of and trends in fish, wildlife, plant populations, and their habitats; 

(3) Assess trends in biological integrity, biological diversity, and environmental health (601 FW 

3); 

(4) Evaluate the effectiveness of management actions in contributing to established goals for fish 

and wildlife conservation by using adaptive management (522 DM 1); 

(5) Provide surveillance to detect changes in the structure and function of ecological systems; 

(6) Establish baseline measures and monitor wilderness character of designated wilderness on 

refuges to evaluate the effects of refuge management activities and uses (610 FW 2); 

(7) Record impacts of environmental stressors, including climate change, on natural resources 

and ecological processes; and 

(8) Support the Service’s goal of landscape conservation by assessing similar management 

actions across refuges and with Service partners, including actions by multiple refuges, one 

or more Regions, Joint Ventures, and Landscape Conservation Cooperatives (701 FW 2).

High-priority research is facilitated on Refuge lands to provide the best science for habitat and 

wildlife management. Examples of research projects include habitat use and life history requirements 

for specific species/species groups, practical methods for habitat management and 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, and modeling 

of wildlife populations. Projects may be species-specific, Refuge-specific, or evaluate the relative 

contribution of the Refuge to larger landscape (ecoregion, region, flyway, national, international) 

issues and trends. Like monitoring, results of research projects would expand the best available 

scientific information and potentially reduce uncertainties to promote transparent decision-making 

processes for resource management over time on Refuge lands and waters. In combination with 

results of I&M, research would promote adaptive management on Refuge lands and waters and be 

used to refine management strategies to achieve resource objectives. Scientific publications resulting 

from research on Refuge lands and waters will help increase the visibility of the Refuge System as a 

leader in the development of the best science for resource conservation and management.

In accordance with the Inventory and Monitoring policy (701 FW 2), Hanalei NWR is developing an 

Inventory and Monitoring Plan (IMP). The IMP will present current and expected I&M activities 

(surveys) for Hanalei NWR. Most surveys in the IMP will be Refuge-specific. They evaluate efficacy

of resource management actions and measure progress toward resource management objectives in 

refuge planning documents. Some surveys gather baseline data to develop practical and measurable 

objectives for restoration projects or provide baseline data on biological integrity of the Refuge. The 

IMP will also include cooperative surveys addressing resource issues of the Service at larger 

landscape scales beyond the Refuge boundary or needs of other agencies and organizations. For 

cooperative surveys, Refuge lands are one of multiple sites, including other Refuges, to address 

broad-scale resource information needs. Key components of the IMP will include a comprehensive 

list of surveys, prioritization of these surveys, surveys selected for implementation, status of 

protocols for surveys, a rationale for each survey including its connection with management 

objectives, and a signature page documenting IMP review and approval. Although the IMP will 

identify many surveys needed on the Refuge, the number of surveys implemented on an annual basis 

is contingent upon a number of factors, including available Refuge funding and staffing as well as 

support from partners. 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

Section 2. Management Alternatives 9

Feral Mallard and Mallard/Koloa Hybrid Removal. Feral mallards are one of the most serious 

threats to the continued existence of endangered koloa maoli throughout its geographic distribution 

(USFWS 2011). Feral mallards threaten koloa maoli with extinction through hybridization, which 

could lead to loss of koloa maoli as a unique Hawaiian species after only a few generations. DNA 

analysis indicates nonmigratory feral mallards (domesticated mallards that have escaped or been 

released into the wild) are cross-breeding with endangered koloa maoli (Uyehara, Engilis Jr., and 

Reynolds 2007; Fowler, Eadie, and Engilis Jr. 2009). In addition, feral mallards likely threaten koloa 

maoli and other threatened and endangered waterbirds by competing with them for limited wetlands 

resources, such as food and nesting sites. Removal of the threat of hybridization is a primary 

recovery action in the Hawaiian Waterbird Recovery Plan (USFWS 2011). DNA analysis indicates a 

very low level of hybridization is present on Hanalei and Hulē'ia Refuges (Malachowski et al. 2013). 

However, the status of the O‘ahu population is uncertain and the potential threats of new sources of 

feral or hybrid ducks flying or being shipped to Kaua‘i needs further evaluation. 

Fish Screening. The presence and abundance of exotic fish species such as tilapia (Oreochromis 

mossambicus, Sarotherodon melanotheron) and poeciliid fish (Poecilia hybrid sp., Gambusia affinis) 

in coastal wetlands depletes food resources (e.g., aquatic insects) for native birds (McGuire 2006), 

degrades water quality (MacKenzie and Bruland 2012), introduces parasites (Font 2007), and 

increases the risk of avian botulism. Native ‘o‘opu can also enter wetlands, where they may become 

trapped and are unlikely to fulfill their lifecycles. The Service will continue to install and use fish 

screens at Hanalei NWR as a non-lethal method excluding both exotic and native fish from areas 

managed for threatened and endangered waterbirds. Where possible, barriers would be installed at 

the intake pipe of a given unit prior to the opening of the intake valves and subsequent re-inundation 

of the wetland.

Partnerships. Partnerships are critical components in maintaining and continuing efforts to 

implement resource management improvements (such as restoring habitat for threatened and 

endangered species). These partnerships typically involve joining forces with Federal, State, and 

local agencies as well as nongovernmental organizations, schools, and Friends of the Refuge groups. 

2.2 ALTERNATIVE A – CURRENT MANAGEMENT (NO-ACTION

ALTERNATIVE)

Alternative A describes current management activities—the baseline or “no-action” alternative for 

analysis of effects under NEPA. This alternative assumes little to no change in current management 

programs, based on pre-existing initiatives at the Refuge, and also includes actions identified in 

Section 2.1. A summary of differences between Alternatives A and B is provided in Table 1.

Currently, the Refuge provides a mosaic of approximately 209 acres of rotational managed wetlands 

and lo‘i kalo (ponds for wetland taro that are enclosed by earthen banks) for threatened and 

endangered waterbirds, as part of a statewide effort to implement the Hawaiian Waterbird and draft 

Nēnē Recovery Plans (USFWS 2004; USFWS 2011). Of the 209 acres, the Service currently 

manages 86 acres as rotational managed wetland (moist-soil) units (not including dikes and ditches). 

In addition to these managed wetland units, there is currently approximately 123 acres in lo‘i kalo of 

various crop stages and rotations at any point in time, including wet or dry fallows (Figure 1). A total 

of 160 acres is permitted for kalo farming, which includes associated dikes and ditches. 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

10 Section 2. Management Alternatives

Under Alternative A, the Service would continue current management practices which include, but 

are not limited to, monitoring and managing protected bird species and associated habitats; 

coordinating, permitting, and overseeing kalo farming operations by permitees in the Refuge which 

provide habitat for protected bird species; maintaining 76 acres of in-use dikes and ditches; managing 

irrigation systems; providing law enforcement protection; and managing limited public uses and 

volunteer programs. 

In rotational managed wetland units, moist-soil management involves the manipulation of soils, 

hydrology, and vegetation to mimic the natural dynamics of seasonally flooded natural wetlands. 

These techniques would continue to be used and improved upon in these units. Techniques such as 

mowing, disking, tilling, and water level management would be used to control pest species, provide 

forage, and create suitable habitat structure including a mosaic of native and naturalized beneficial 

plants. Water level management would continue to be used to provide suitable habitat and prevent 

disease outbreaks such as avian botulism. Measures to minimize adverse impacts to threatened and 

endangered waterbirds include a nest/brood search with an established protocol prior to 

implementing maintenance.

The provision of threatened and endangered waterbird habitat is a primary stipulation for being able 

to farm in the Refuge. The Service works with local farmers to continue the tradition of kalo farming 

in the Refuge while ensuring that the farming remains compatible with the conservation and recovery 

of the threatened and endangered birds that the Refuge was established to protect. Under Alternative

A, permittees under CAAs would continue current kalo farming practices, which include providing a 

minimum 30-day wet fallow period, followed by optional dry fallow period of up to six months;

reporting threatened and endangered waterbird nests within 48 hours of discovery; and maintaining a 

minimum three-foot radius buffer around threatened or endangered waterbird nests, leaving kalo and 

non-kalo plants in lo‘i during harvest, until waterbirds have fledged.

The Service would continue to work with the Natural Resources Conservation Service (NRCS), kalo 

farmers, and other partners to develop kalo farming BMPs for improving water quality and flow and, 

in turn, reducing the number and severity of avian botulism outbreaks. The Service would conduct

annual coordination meetings with each kalo farming permittee/cooperator (hereafter kalo 

permittees). Kalo permittees cooperate with the Service to implement several management activities 

across kalo farms in the Refuge. These include pest removal and management; avian botulism 

reporting and response; assistance with research and monitoring; and maintenance of fencing and

water control infrastructure (dikes and ditches). Additionally, kalo permittees would continue to be

required to provide records for fallow periods, herbicide and fertilizer use, ditch cleaning, and road 

maintenance to Refuge management annually.

If a kalo permittee has an existing residence on the Refuge, then only the permittee and their

immediate family (legal parents, spouse, children) may reside in the residence. Use of Refuge lands 

for permittee-owned residences, storage sheds, and other facilities would not be allowed in situations 

where associated kalo farming CAAs are terminated.

Working with partners and stakeholders, 2–5 acres of hau (Hibiscus tiliaceus) would be removed per 

year in priority areas to enhance river corridor habitat, dependent on available funding. The Refuge 

would maintain fences, gates, roads, water control structures, and signs in partnership with the kalo 

farming permittees. The Kaua‘i NWR Complex (KNWRC) law enforcement officer would patrol the 

Refuge. 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

Section 2. Management Alternatives 11

2.3 ALTERNATIVE B – IMPLEMENTATION OF WETLANDS 

MANAGEMENT AND WATERBIRD CONSERVATION PLAN –

(PROPOSED ACTION ALTERNATIVE)

The chief distinction of this alternative from Alternative A is increased protection and management 

of biological resources, particularly regarding the kalo farming program. This alternative also 

includes actions identified in Section 2.1. A summary of differences between Alternatives A and B is 

provided in Table 1.

Under Alternative B, the Service would provide a mosaic of approximately 209–249 acres of wetland 

habitat (rotational managed wetlands and lo‘i kalo) for foraging, loafing, and breeding threatened and 

endangered waterbirds throughout the year. Assignment of available lowland/wetland areas for 

rotational managed wetland units, lo‘i kalo (via CAA), fallow, or upland habitat (e.g., koloa nesting 

habitat, dWMWCP Objective 2.3) would use a decision flowchart (dWMWCP, Figure 4-2) and be 

re-evaluated periodically using adaptive management. This flowchart allows for a more transparent 

decision-making framework for land use and management, while ensuring the USFWS is meeting 

legal mandates for recovering threatened and endangered species. 

An additional 3–18 acres of rotational managed wetlands would be restored and managed as part of 

the above 209–249 acres (Figure 2). In rotational managed wetland units, the Refuge would focus on 

wetland management techniques (i.e., moist-soil management) that optimize threatened and 

endangered waterbird habitat such as high quality forage during critical life history periods. A range 

of 76–85 acres of dikes and ditches, including those in unallocated kalo farming areas and those 

associated with proposed wetland restoration areas, would be managed for improved water delivery 

and quality; and foraging and breeding waterbirds.

Under Alternative B, the Service would work with kalo permittees under CAAs and other experts to 

find or refine strategies that (1) benefit threatened and endangered waterbirds in support of BIDEH

and the Refuge purpose and (2) take into consideration site characteristics and required kalo farming 

techniques. Specific strategies under Alternative B to improve waterbird habitat in lo‘i kalo include: 

enhancement of vegetation structure during all crop stages by not intensively clearing selected nonkalo plant species that are beneficial to birds; maintaining a minimum 6-foot radius unharvested 

vegetation buffer around threatened or endangered waterbird nests and coordinating with Refuge 

staff on additional protective measures, as needed; protecting nests and broods during the harvest 

stage; reducing the number of drawdowns when nests are present; and managing suitable plant cover 

on dikes and ditches to provide food, cover, and nesting material. The amount of time stipulated for 

kalo permittees to report threatened or endangered waterbird nests to Refuge staff would be changed 

from 48 to 24 hours. 

Additionally, the Service would work with NRCS and kalo permittees to develop and implement 

fertilizer and herbicide management plans. Kalo permittees would be required to participate in 

relevant aspects of the Avian Botulism Prevention and Response Protocol as part of their CAA, 

including thoroughly draining and aerating lo‘i kalo after the wet fallow period, prior to replanting. 

Incentive mechanisms for kalo farmers would be explored to encourage the use of more sustainable 

practices above and beyond the required permit stipulations. For example, using a 60 day or longer 

wet fallow followed by a two to six month dry fallow after tilling organic matter into soil; 

experimenting with ecologically friendly alternatives to traditional chemical fertilizers; and exploring 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

12 Section 2. Management Alternatives

organic kalo farming and “wildlife-friendly” BMPs or certifications. See the dWMWCP for more 

background information on kalo farming.

Farmers would be invited to bi-annual meetings/workshops; would meet quarterly with the Service 

on avian botulism response; participate in a water budget analysis; and assist the Service in 

developing a plan of operations for ditch cleaning and fence maintenance. Proposed changes 

regarding on-Refuge residences include: (1) No new farm residences on Refuge property, (2) At least 

one permit holder must live in the residence, and (3) Size of use area by permittee would be 

delimited in CAA.

Law enforcement would assist Refuge staff in developing a compliance monitoring system. The 

Refuge would focus on more partnering, workshops, outreach, and training for Refuge staff, 

permittees/cooperators, partners, and the community.

Mowing and using of prescriptive seasonal livestock grazing, without compromising water quality or 

riparian habitat, would enhance grasslands habitat for nēnē on approximately 14–24 new acres. In 

addition, approximately 21 acres would be enhanced as koloa maoli nesting habitat (Figure 2).

For full details on Alternative B, see the dWMWCP (USFWS 2020).
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

Section 2. Management Alternatives 13

TABLE 1. SUMMARY OF DIFFERENCES BETWEEN ALTERNATIVES A AND B

Alternative A (Current Management) Alternative B (Proposed Action)

Habitat Quantity

86 acres of rotational managed wetland (moistsoil) units

160 total acres of kalo farms (9 parties), 

including dikes and ditches:

• 123 acres of allocated lo‘i kalo

• 13 acres of unallocated lo‘i kalo

Provide a mosaic of 209–249 acres of wetland 

habitat (rotational managed wetlands and lo‘i 

kalo). The upper bound of acreage includes 

unallocated lo‘i kalo and enhanced or restored 

seasonal/rotational wetlands.

Assignment of acreage among rotational 

managed wetland units, lo‘i kalo (via 

cooperative agriculture agreement [CAA]), 

fallow, or upland habitat (e.g., koloa nesting 

habitat) would be based on a decision flowchart 

and reevaluated periodically using an adaptive 

management framework

76 total acres of in-use dikes and ditches 76–85 acres of dikes and ditches (including 

within unallocated kalo farming areas and 

associated with proposed wetland restoration 

areas) managed under BMPs to improve 

waterbird habitat and water quality

Enhance or restore 3–18 acres of 

seasonal/rotational wetlands

Use mowing and livestock grazing to enhance 

and manage 14–24 acres of riparian habitat for 

nēnē breeding and foraging

Develop prescribed grazing and monitoring 

plan 

Enhance and manage 21 acres of upland habitat 

for nesting koloa maoli

Reduce hau by 2–5 acres/year in priority areas Same as current

Permits for Cooperative Kalo Farming; Residences and Farm Storage Areas

Currently permitted annually under general 

SUP but transition to CAAs, awarded through 

competitive application

Implement CAAs, awarded through competitive 

application, with terms up to five years subject 

to regular ongoing compliance review
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

14 Section 2. Management Alternatives

Alternative A (Current Management) Alternative B (Proposed Action)

Develop cost-sharing program through CAA

Current SUP fee of $25/cultivated acre/year 

(does not apply to other farm use areas used for 

houses, storage, etc.) may or may not be waived 

or increased

Same as current

If permittee has an existing residence on the 

Refuge, then only immediate family (legal 

parents, spouse, children) may reside in the 

residence

Same as current, but also:

• No new farm residences are authorized 

on Refuge property

• At least one permit holder must live in 

the residence.

• Size of use area by permittee would be 

delimited in CAA/SUP

Use of Refuge lands for permittee-owned 

residences, storage sheds, and other facilities 

would no longer be allowed when associated 

kalo farming CAAs and SUPs are terminated

Same as current

Develop compliance monitoring system that is 

reviewed and updated annually

Kalo Farming Stipulations

Minimum requirement of 30-day wet fallow 

followed by optional dry fallow <180 days total

Same as current

Enhance vegetation structure of lo‘i habitat (all 

stages) by maintaining either:

• ≥10% cover of beneficial non-kalo 

emergent plants in understory within 

each lo‘i;

• ≥20% cover of beneficial non-kalo 

emergent plants in understory on ≥50% 

of lo‘i; or

• ≥10% of total lo‘i acreage in vegetated 

wet fallow to promote growth of nonkalo emergent plants
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

Section 2. Management Alternatives 15

Alternative A (Current Management) Alternative B (Proposed Action)

Permittees are to report threatened or 

endangered waterbird nests within 48 hours of 

discovery

3-foot radius buffer around threatened or 

endangered waterbird nests in lo‘i kalo

Permittees are to report threatened or 

endangered waterbird nests within 24 hours of

discovery

Minimum 6-foot radius buffer around 

threatened or endangered waterbird nests in lo‘i 

kalo. Permittees are to coordinate with Refuge 

staff to minimize impacts or take of birds by 

implementing additional protective measures as 

needed, such as delaying harvest in areas where 

nests are known to occur until the young birds 

fledge or leave the loʻi on their own accord

Initiate a study of the relative effectiveness of 

different size nest buffers on nest and fledging 

success of threatened and endangered 

waterbirds within three years; modify buffer 

requirements and compatibility stipulations if 

necessary

Permittees are required to maintain vegetation 

4–6 inches in height on ≥75% of dike tops in 

each permit area using mowing or brush-cutting

Permittees provide to the Refuge logs of:

• Specific dates and locations of wet and 

dry fallow periods

• Herbicide and fertilizer application 

dates, types, and amounts

• Ditch cleaning and road maintenance or 

repair

Same as current

Each permittee must cooperate with the Refuge 

on developing fertilizer and herbicide 

management plans

Work with NRCS, farmers, and other partners 

to develop kalo farming BMPs, for improving 

water quality and flow and stemming avian 

botulism mortalities

Same as current
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

16 Section 2. Management Alternatives

Alternative A (Current Management) Alternative B (Proposed Action)

Permittees are to report sick/dead birds within 

24 hours of discovery

Permittees are encouraged to participate in 

relevant aspects of the Avian Botulism 

Prevention and Response Protocol as part of 

their SUP. If a given kalo patch is identified as 

an avian botulism hotspot, then work with 

Refuge staff to change environmental 

conditions.

Same as current but also: Permittees will be 

required to participate in relevant aspects of the 

Avian Botulism Prevention and Response 

Protocol as part of their CAA and SUP.

In avian botulism prone areas, implement BMPs 

which include reconfiguring pipelines to 

remove all flow-through drains and draining, 

harvesting, and dry fallowing lo’i for ≥30 days, 

pending Refuge request

Thoroughly drain and aerate every kalo patch 

after the 30-day wet fallow period prior to 

replanting

Regular coordination meetings (e.g., avian 

botulism-related) and cooperation on 

maintaining infrastructure; IPM; monitoring and 

research

Same as current

Within three years of WMWCP completion, 

develop incentive mechanisms for the use of 

more sustainable and wildlife-friendly farming 

practices (e.g., maintaining larger nest buffers 

and use of ≥60-day vegetated wet-fallow period 

followed by a 2–6-month dry fallow period 

after tilling organic matter into soil

2.4 ALTERNATIVE(S) CONSIDERED, BUT DISMISSED FROM 

FURTHER CONSIDERATION

2.4.1 CULTIVATION OF GENETICALLY MODIFIED CROPS

In accordance with BIDEH policy (601 FW 3), the Service would not allow cultivation of genetically 

modified crops (GMCs) on the Refuge unless their use is essential to accomplishing the Refuge 

purpose and the Director approves the use. In order to consider GMC use, an Eligibility 

Questionnaire for Genetically Modified Crops must be completed and refuge compliance documents 

(e.g., Appropriate Use [603 FW 1], Compatibility Determination [CD; 603 FW 2], NEPA, and ESA 

Section 7) must be updated. Additionally, several other factors may prevent approval of the use of 

GMCs such as state or local laws. Currently, GMCs are not cultivated on Hanalei NWR. The use of 

GMCs is not essential for accomplishing the Refuge’s purpose and consequently it is not included in 

the proposed action. 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

Section 2. Management Alternatives 17

2.4.2 ELIMINATING KALO FARMING

Kalo farming in the Hanalei Valley existed prior to and at the time of establishment of Hanalei NWR 

and has continued under SUPs since that time. Kalo farms offer shallow-water habitat that can satisfy 

some of the life history requirements of threatened and endangered waterbirds (Gee 2007; GutscherChutz 2011) and provide a means to manage supplemental waterbird habitat on Hanalei NWR. Kalo 

farming currently provides up to 160 acres of supplemental habitat (including dikes and ditches) in 

addition to the 86 acres of rotational managed wetland units on the Refuge. Along with associated 

upland and riverine habitats, the Refuge’s lo‘i kalo and rotational managed wetland units represent 

70 percent of the core habitat on Kaua‘i designated as essential to the recovery and delisting of 

endangered waterbirds (USFWS 2011).

Both historically and in the present day, kalo has cultural, spiritual, economic, and political 

significance in Hawaiian society. During the 1980s, the Hanalei Valley was identified by the 

National Trust for Historic Preservation (NTHP) as an important site for rural preservation. Farming 

on Hanalei NWR represents a substantial portion of kalo acreage and production statewide, estimated 

at 40–60 percent (Cho, Yamakawa, and Hollyer 2007; Gutscher-Chutz 2011; NASS 2017). Kalo 

farming on the Refuge is of economic importance to the State of Hawai‘i, including to the tourism 

industry and the local communities. The Service recognizes and values these cultural and historical 

dimensions of kalo farming on the Refuge. For these reasons, and in the context of current and 

anticipated staffing and resources limitations, the Service dismissed the alternative of eliminating 

kalo farming on the Refuge from further consideration.
 

 

r e iv

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R

el ana H

‘Ōhiki Rd

Hanalei River 

Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan 

Figure 1. Alternative A (No-Action Alternative) wetland habitat units and other management 

areas. 

560

KU1

KU2 56

C3

C5 C1

C4

B1 R2 R1

B4 B3

KU3

DU3 A1

A3 DU1 DU2 A2 KU4

A4

Obj. 2.1 Protect and enhance 

river corridor habitat 

Refuge Boundary Obj. 1.3 Maintain 76 acres of dikes and ditches

Alternative A Obj. 2.1 Reduce hau by 2–5 acres/year in priority

Obj. 1.1 Provide mosaic of 209 acres of areas then restore

wetland habitat

Rotational managed wetland

(moist-soil) units

Lo‘i kalo

0 500 1,000 

Feet 

Meters 

0 250 500 

Map Date: 7/9/2019 File: 11-102-1a.mxd USFWS R1 Refuge Inventory and Monitoring Branch 

Data Source: USFWS 2019; Imagery from DigitalGlobe 6/3/2019 

18 Section 2. Management Alternatives 
 

 

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R

el ana H

‘Ōhiki Rd

Hanalei River 

Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan 

Figure 2. Alternative B (Proposed Action Alternative) wetland habitat units and other 

management areas. 

560

KU1

KU2 56

C3

C5 C1

C4

B1 R2 R1

B4 B3

KU3

DU3 A1

A3 DU1 DU2 A2 KU4

A4

Obj. 2.1 Protect and enhance 

river corridor habitat 

Refuge Boundary Obj. 1.2 Restore/enhance 3–18 acres of

Alternative B rotational managed wetland (moist-soil) units

Obj. 1.1 Provide mosaic of 209–249 acres

of wetland habitat within areas currently:

Rotational managed wetland

(moist-soil) units

Lo‘i kalo

Unallocated (fallow)

Map Date: 7/9/2019 File: 11-102-1b.mxd 

Data Source: USFWS 2019; Imagery from DigitalGlobe 6/3/2019 

Obj. 1.3 Maintain 76–85 acres of dikes and ditches

Obj. 2.1 Reduce hau by 2–5 acres/year in priority

areas then restore

Obj. 2.2 Enhance and manage 14–24 acres of 0 500 1,000 

Feet riparian habitat for nēnē breeding and foraging Meters Obj. 2.3 Enhance and manage 21 acres of upland 0 250 500 

areas for koloa maoli nesting

USFWS R1 Refuge Inventory and Monitoring Branch 

Section 2. Management Alternatives 19 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

20 Section 3. Affected Environment and Environmental Consequences

SECTION 3. AFFECTED ENVIRONMENT AND ENVIRONMENTAL 

CONSEQUENCES

This section describes the existing environmental and socioeconomic settings in the affected area and 

also analyzes the environmental consequences of the action on each affected resource, including 

direct and indirect effects. The affected environment for each affected resource is summarized first, 

followed by the effects of Alternative A, the effects of Alternative B. Cumulative impacts are 

described in Section 1.13. For more information regarding the affected environment, please see 

Chapter 2 of the Refuge’s dWMWCP (USFWS 2020).

This EA includes analyses of the environmental consequences on a resource only when the effects on 

that resource could be more than negligible and therefore considered an “affected resource,” or are 

otherwise considered important as related to the proposed action (even if the effects are negligible). 

The proposed action would have negligible effects to air quality and visual quality; these have 

therefore been dismissed from further analyses. Consequences are analyzed based on the following 

effect types:

• Direct effects are those which are caused by the action and occur at the same time and place. 

• Indirect effects are those which are caused by the action and are later in time or farther 

removed in distance but are still reasonably foreseeable. 

• Cumulative impacts result from the incremental impact of the action when added to other 

past, present, and reasonably foreseeable future actions regardless of what agency (federal or 

non-federal) or person undertakes such other actions.

The terms below were used to describe the scope, scale, and intensity of effects on natural, cultural, 

social (including recreational), and economic resources. Effects may be identified further as 

beneficial or negative.

• Neutral or Negligible. Resources would not be affected (neutral effect), or the effects would 

be at or near the lowest level of detection (negligible effect). Resource conditions would not 

change or would be so slight there would not be any measurable or perceptible consequence 

to a population, wildlife or plant community, recreation opportunity, visitor experience, or 

cultural resource. If a resource is not discussed, impacts to that resource are assumed to be 

neutral.

• Minor. Effects would be detectable within the Refuge, but localized, small, and of little 

consequence to a population, wildlife or plant community, other natural resources; social and 

economic values, including recreational opportunity and visitor experience; or cultural 

resources. Mitigation, if needed to offset adverse effects, would be easily implemented and 

successful based on knowledge and experience.

• Intermediate or Moderate. Effects would be readily detectable and localized with 

measurable consequences to a population, wildlife or plant community, or other natural 

resources; social and economic values, including recreational opportunity and visitor 

experience; or cultural resources. Mitigation measures would likely be needed to offset 

adverse effects, and could be extensive, moderately complicated to implement, and probably 

successful based on knowledge and experience.

• Significant (major). Region-wide effects would be obvious and would result in substantial 

consequences to a population, wildlife or plant community, or other natural resources; social 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

Section 3. Affected Environment and Environmental Consequences 21

and economic values, including recreational opportunity and visitor experience; or cultural 

resources. Extensive mitigating measures may be needed to offset adverse effects and would 

be large-scale in nature, possibly complicated to implement, and may not have a high 

probability for success. In some instances, major effects would include the irretrievable loss 

of the resource.

Time and duration of effects have been defined as follows:

• Short-term or Temporary. An effect that generally would last less than a year or season.

• Long-term. A change in a resource or its condition that would last longer than a single year 

or season.

3.1 GENERAL SETTING

Hanalei NWR consists of approximately 917 acres in Kaua‘i County in the State of Hawai‘i. The 

Refuge lies in a relatively flat river valley ranging in elevation from 20 to 40 feet above sea level and 

includes some steep wooded hillsides reaching up to 1,600 feet. A portion of the Hanalei River, 

which is a designated American Heritage River, runs through the Refuge before emptying into 

Hanalei Bay. This river is perennial and low-gradient in this section of the Refuge. The proposed 

action is located in approximately 480 acres, including 86 acres of rotational managed wetland 

impoundments; 123 acres of lo‘i kalo (wetland taro fields); and 189 acres of riparian habitat. (Figure

1). Approximately 80 acres of dikes and ditches and canals (range of 76–85 acres) are used to supply 

water to, and manage water in, rotational managed wetland units and lo‘i. These are included in the 

acreage totals above. 

3.2 THREATENED AND ENDANGERED SPECIES AND OTHER SPECIAL 

STATUS SPECIES

3.2.1 AFFECTED ENVIRONMENT

Five species of federally listed Hawaiian waterbirds use the Refuge’s rotational managed wetlands, 

lo‘i kalo, fallow, and riparian habitat for foraging, nesting, and brood rearing: endangered koloa 

maoli, endangered ‘alae ke‘oke‘o, endangered ‘alae ‘ula, endangered ae‘o, and threatened nēnē. 

Adjacent upland habitat is also used by koloa maoli for nesting. Endangered ‘ōpe‘ape‘a (Hawaiian 

hoary bats, Lasiurus cinereus semotus) use the Refuge as a day roost. No critical habitat designations 

have been identified for these species. 

Listed species receive special consideration in terms of refuge management. Federally listed species 

are trust resources that require additional consultation whenever an activity conducted by or 

permitted by the Refuge may have an effect on these species or their habitats. For Hawai‘i, if a 

species is federally listed, it is also state listed. The following is summarized from the dWMWCP, 

Section 2.5.1:

Koloa maoli: The population size of koloa maoli is about 2,200 birds, including 2,000 on Kaua‘i and 

Ni‘ihau and 200 on Hawai‘i Island. However, current population estimates are unreliable because 

detection rates and montane habitats were not included in calculations. Hanalei and Hulē‘ia NWRs 

are the only NWRs and some of the only prime habitat currently supporting true (not hybridized with 

feral mallard) koloa maoli populations, elevating the importance of these Refuges in the species’ 
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22 Section 3. Affected Environment and Environmental Consequences

recovery. From 2010 to 2015, the average number of koloa maoli counted during monthly population 

monitoring at Hanalei NWR was 388 (range 131–817, SE 16.1) (dWMWCP, Figure 2-3). 

‘Alae ke‘oke‘o: The statewide population is estimated to range between 2,000 and 4,000 birds. From 

2010 to 2015, the average number of ‘alae ke‘oke‘o counted during monthly population monitoring 

at Hanalei NWR was 254 (range 35–641, SE 16.2) (dWMWCP, Figure 2-5).

‘Alae ‘ula: The total population size is currently unknown; however, it is believed to be less than 

2,000 individuals, but stable. From 2010 to 2015, the average number of ‘alae ‘ula counted during 

surveys at Hanalei NWR was 391 (range 203–675, SE 11.3) (dWMWCP, Figure 2-6).

Ae‘o: Recent estimates place the population at approximately 1,400–2,200 birds. From 2010 to 2015, 

the average number of ae‘o counted during monthly population monitoring at Hanalei NWR was 233 

(range 40–362, SE 9.0) (dWMWCP, Figure 2-8).

Nēnē: The 2017 statewide population of wild nēnē was estimated to be 3,252 individuals with 1,482 

(46 percent) on Kaua‘i (USFWS unpublished). From 2010 to 2015, the average number of nēnē 

counted during monthly population monitoring at Hanalei NWR was 115 (range 40–211, SE 4.7) 

(dWMWCP Figure 2-10). On January 21, 2020, the Service reclassified nēnē from endangered to 

threatened status because species’ status has improved such that it is not currently in danger of 

extinction throughout all or a significant portion of its range (84 FR 69918).

‘Ōpe‘ape‘a: The population size of ‘ōpe‘ape‘a is unknown. Resident populations occur on Kaua‘i, 

Maui, and Hawai‘i and possibly other main islands, with the highest abundance on Kaua‘i and 

Hawai‘i. These bats have been observed on the Refuge, and an ongoing acoustic call detection study 

initiated in 2016 indicate bats are roosting on the Refuge during the day.

A significant proportion of threatened ‘a‘o (Newell’s shearwater; Puffinus newelli) and ‘ua‘u 

(Hawaiian petrel; Pterodroma sandwichensis) were using the Hanalei Valley flyway (Cooper and 

Day 1995). Radar surveys showed ‘a‘o and ‘ua‘u transiting to and from breeding colonies in the 

morning and evening hours directly over the Refuge (Andre Raine 2012, pers. comm.). The 

endangered Hawai‘i Distinct Population Segment of ‘akē‘akē (band-rumped storm-petrel) may also 

use the Hanalei Valley flyway. 

3.2.2 EFFECTS OF ALTERNATIVE A (NO-ACTION)

THREATENED AND ENDANGERED HAWAIIAN WATERBIRDS

Habitat Quality/Rotational Managed Wetlands 

Under Alternative A, current acreage and management of rotational managed wetlands would 

continue. No new wetlands would be created. Moist-soil management techniques used within 

rotational managed wetland units to manipulate native and naturalized beneficial nonnative 

vegetation provide important structure for threatened and endangered waterbird nesting, foraging, 

brooding, loafing, and thermal/escape cover. Annual plants resulting from moist-soil management 

produce an abundance of seeds that are readily available and consumed by waterbirds. As moist-soil 

annuals decompose, they provide substrate and forage for aquatic invertebrates which are also an 

important food resource for waterbirds, particularly young waterbirds and pre-laying hens.
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Section 3. Affected Environment and Environmental Consequences 23

The Refuge works to minimize direct or indirect mortality of threatened and endangered waterbirds 

(e.g., accidental destruction of nests, disturbance of young broods, flooding of nests) during habitat 

management such as mowing, disking, tilling, spraying herbicide, and pulsing water. For example, as 

possible, maintenance activities are scheduled outside of peak rail (‘alae ke‘oke‘o and ‘alae ‘ula) 

breeding and koloa maoli molting season (May–July). Additionally, waterbird nest/brood searches 

are conducted, commensurate with breeding activity, prior to habitat management. If nests or broods 

are discovered, maintenance schedules are shifted with other work to avoid or minimize adverse 

impacts to threatened and endangered species. Without the habitat management described above, the 

managed wetlands units could become overgrown with invasive plants, such as California grass,

within 1–2 years and would be of little value to waterbirds. 

Water level drawdowns may result in die-offs of tilapia and other introduced fish species (e.g., 

Chinese catfish, mosquitofish), which could increase the risk of avian botulism outbreaks by 

providing a protein substrate for pathogens. However, this type of water level manipulation in 

managed wetland units is typically short (several days) and management units are re-inundated with 

freshwater afterwards. Thus, these techniques are overall beneficial and a necessary part of Refuge 

operations to provide functional wetlands habitat to meet the needs of the threatened and endangered 

waterbirds. 

Overall, continuation of current management under Alternative A would result in minor to 

intermediate long-term benefits to threatened and endangered waterbirds since the amount and 

quality of habitat, and management techniques would remain the same as present.

Habitat Quality/Dikes and Ditches

Although the importance of dikes in meeting the life history needs of wetland birds is uncertain, 

dikes may provide opportunities for ‘alae ke‘oke‘o and ‘alae ‘ula to establish pair bonds. Koloa 

maoli use dikes for resting (Malachowski and Dugger 2018). Dikes are elevated and often provide 

good visibility, which possibly aids in predator detection, and quick access to escape cover. Dikes 

provide forage for grazers like nēnē, ‘alae ‘ula, and ‘alae ke‘oke‘o. ‘Alae ‘ula forage on California 

grass shorter than four inches tall, which is a good source of protein and carbohydrates (DesRochers 

et al. 2009). Maintaining dikes with low to intermediate growing grasses and leafy forbs also helps to 

control pest plants and reduces concealment cover for introduced predators. Vegetated ditches 

supporting macroinvertebrates provide supplemental foraging and breeding habitat for ‘alae ‘ula and 

koloa maoli.

Dikes are currently maintained by periodic mowing and ditches are maintained by using approved 

mechanical vegetation cutting and/or herbicides. Without maintenance, dikes and ditches become 

overgrown within months, limiting the value of the habitat and ability to manage wetlands, especially 

to properly drain and aerate units. Under Alternative A, continued maintenance of dikes and ditches 

would facilitate water level management within both rotational managed wetlands and kalo farms 

and provide minor to intermediate habitat benefits.

Habitat Quality/Riparian and Upland

Hanalei NWR has approximately 189 acres of degraded riparian habitat which extends from the 

active river channel to the upland edge of the 100-year floodplain. Under Alternative A, no additional 

riparian habitat would be managed as nēnē foraging and breeding habitat or upland koloa maoli 

nesting areas. Therefore, effects to threatened and endangered waterbirds would be neutral.
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24 Section 3. Affected Environment and Environmental Consequences

Habitat Quality/Kalo Farms

As currently practiced, kalo farming meets some of the life history needs of threatened and 

endangered waterbirds (Gee 2007; Gutscher-Chutz 2011) and supplements the native and naturalized 

habitats provided by the neighboring, rotational wetland (moist-soil) management units. However, 

lo‘i kalo provides unstable (e.g., fluctuating water levels, artificial additives) and thus lower quality 

habitat for threatened and endangered waterbirds when compared to wetlands managed for a varied 

moist-soil plant community, carefully designed topography features and water depth, and less 

disturbance. Some kalo farming practices reduce food and cover, and cause disturbance to threatened 

and endangered birds. See dWMWCP Section 2.3 and Appendix B, Draft CD for Cooperative Kalo 

Farming; Residences and Farm Storage Areas (Residential [other] and Farming), for additional 

information.

Under both alternatives, CAAs would include stipulations designed to ensure compatibility. Without 

adherence to stipulations, kalo farming practices could conflict with the establishment purpose of 

Hanalei NWR and other legal mandates such as the ESA. For example, Refuge kalo farming CAAs 

require that following harvest, lo‘i be kept in wet fallow for a minimum of 30 days; however, field 

observations reveal that this is not always occurring (Gee 2007). 

Under Alternative A, current management practices would continue, including potentially conflicting 

practices such as flooding and drying cycles timed to benefit kalo, rather than threatened and 

endangered waterbirds, their nesting requirements, or production of invertebrate and plant foods. 

Kalo farming often involves control of non-kalo plants through hand-weeding, mowing, dewatering 

lo‘i, or application of pesticides. While these practices enhance kalo production, they reduce the 

value of habitat to threatened and endangered waterbirds (less forage, reduced cover, reduced 

availability of nesting structure and materials, and reduced invertebrate production) compared to less 

intensively managed lo‘i and fallow lo‘i where non-kalo emergent vegetation was present. 

Therefore, under Alternative A, lo‘i kalo would continue to provide for some life history needs of 

threatened and endangered waterbirds, but to a lesser degree than under Alternative B. Continuation 

of current management practices would result in less vegetative cover for nests and broods, and less 

available food resources (both non-kalo plants and invertebrates) compared to Alternative B.

Disease Mortality 

Although the first case was reported in the late 1970s, outbreaks of avian botulism type C, a paralytic 

disease caused by ingestion of a toxin produced by the bacterium Clostridium botulinum, have 

occurred with regularity at Hanalei NWR since November/December 2011. Between 2011–2018, 

1342 cases of avian botulism were recorded on the Refuge (Reynolds et al. 2019). These botulism 

outbreaks have killed individuals of all five federally listed waterbird species occurring on the 

Refuge and have been particularly detrimental to koloa maoli, which represents 62% of birds affected 

(Reynolds et al. 2019). Unlike mainland avian botulism events, outbreaks on the Refuge can occur 

year-round due to lack of seasonal variability in temperatures; however, they have been most 

prevalent in the northern lo‘i kalo during the winter months.

Environmental conditions associated with avian botulism outbreaks include temperatures between 

20– 40°C, low dissolved oxygen, pH between 7.5 and 9.0, negative redox potential, and sources of 

decaying organic matter (especially protein such as decaying fish) (Rocke and Bollinger 2007; Rocke 

and Samuel 1999). The hydrological infrastructure and management of the Refuge, particularly 

within certain areas of lo‘i kalo, might influence the abiotic growth factors for C. botulinum, alter the 
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Section 3. Affected Environment and Environmental Consequences 25

availability of growth media, or lead to buildups of the toxin in areas with less water flow to flush the 

toxin. Factors leading to C. botulinum growth might also vary naturally or with other management 

practices, such as lo‘i kalo drawdowns, fertilization, or pesticide application. Hotspot (density) 

mapping of avian botulism cases based on data from 2011–2015 showed that although the location of 

hotspots varied somewhat from year to year, the most severe outbreaks (i.e., highest density botulism 

hotspot) occurred in lo‘i kalo in the northern part of the Refuge. The kalo regions Refuge-wide had 

similar densities of live/healthy koloa maoli; however, the northern kalo regions (northeast and west) 

contained more dead/sick koloa maoli relative to the numbers of live/healthy koloa maoli using these 

areas (McDonald 2016).

Under Alternative A, current avian botulism surveillance and control, conducted by both Refuge staff 

and kalo permittees, would continue. Improved compliance with permit terms would have minor 

positive impacts to water quality, which may slightly reduce outbreaks. However, we would expect 

that under current management, there would be only minor improvements to water quality, and 

therefore the frequency and severity of avian botulism outbreaks are expected to remain similar to the 

present. 

Predation 

Under both alternatives, the Service would continue to use fencing, live trapping, and bait stations to 

control or exclude vertebrate pests. Feral mallards and other vertebrate pests are removed by Refuge 

staff and permittees, and three miles of protective fencing is maintained to exclude pigs and dogs. 

This fencing is, however, insufficient to exclude other vertebrate pests such as cats and rats. 

Resident farmers are allowed to keep some domesticated animals on the lands they occupy associated 

with their houses (their permit areas). Because Hawai‘i’s threatened and endangered waterbirds 

evolved in the absence of mammalian predators and some birds nest directly on the ground, domestic 

animals, especially cats and dogs, running loose (i.e., feral animals) or being kept in areas that

waterbirds use regularly on the Refuge, pose a threat to waterbird recovery, and can result in 

unlawful wildlife disturbance.

Storage of abandoned equipment and nonhazardous waste within or adjacent to permit areas, and 

improper disposal of organic material can attract pests, such as rats. These pests can prey on

threatened and endangered waterbirds and be disease vectors. Under both alternatives, the Service 

would continue to work with kalo permittees to ensure compliance with permit stipulations regarding 

pets, livestock, proper disposal of trash and non-organic waste, and reducing the sources of vertebrate 

pests.

Under Alternative A, predation of threatened and endangered waterbirds by vertebrate pests is likely 

to continue at current levels.

Disturbance

Disturbance can cause both direct mortality (e.g., through nest abandonment) and reduced fitness 

(greater energy expenditure, reduced foraging) of wildlife. Currently, public use of the Refuge is 

extremely limited. Most disturbance occurs as a result of wetland management and kalo cultivation 

by Service staff and permittees. Refuge staff presence is consistent with a level necessary to conduct 

biological monitoring, botulism surveillance and response, predator control, water management, 

Refuge operations, and maintenance (under normal circumstances, one to five visits per week). Many 

of the activities associated with kalo farming disturb or have the potential to disturb wildlife, 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

26 Section 3. Affected Environment and Environmental Consequences

including threatened and endangered waterbirds that use the lo‘i and surrounding areas as habitat 

(Gee 2007). 

The Hanalei Valley’s warm and wet climate allows kalo farming to occur year-round, so lo‘i kalo 

and associated features (e.g., dikes, ditches, and banks) are manipulated year-round. This includes 

numerous farm production activities, such as plowing, tilling, fertilizing, liming, planting, weeding, 

mowing, applying pesticides, managing water levels, and harvesting. Some activities (e.g., flooding 

and dewatering, weeding, and application of fertilizer and lime) are repeated multiple times 

throughout the production cycle (Gee 2007). 

During nonbreeding periods, nēnē, ae‘o, and ‘alae ke‘oke‘o appear to be fairly tolerant of 

disturbance. However, when birds are breeding or in heavy molt, they are all more vulnerable to 

disturbance and predation. Koloa maoli and ‘alae‘ula are very wary and often flush or move quickly 

into dense cover when disturbed (Gutscher-Chutz 2011). Flushing of birds or even raising their alert 

levels creates stress and requires animals to expend energy that would otherwise be invested in 

essential life history activities such as foraging, mating, nesting, brood-rearing, and predator 

avoidance. Disturbance can cause nest desertion; affect survival of individual birds, eggs, nestlings, 

or broods; and alter behavior of nonbreeding waterbirds. Overall, koloa maoli were disturbed less 

often in rotational managed wetlands than in kalo farms; however, the difference in human-related 

disturbances between wetland types was comparatively small (10 percent vs. 14 percent) and of 

uncertain biological significance (Malachowski and Dugger 2018). 

Lo‘i water levels are fluctuated and kalo corms, stalks, and leaves are harvested during times when 

some waterbirds are nesting over water in mature kalo plants. This can increase nest flooding, nest 

desertion, and increase the vulnerability of nesting waterbirds, their eggs, and their chicks to 

predation. Gee (2007) followed ‘alae ‘ula nests that were primarily found during kalo harvest on the 

Refuge. These nests experienced average nest success, but low fledging success. Nest failure was 

attributed to predation, abandonment, and flooding.

Some kalo farming on the Refuge includes management or removal of unwanted vegetation from 

banks, ditches, and dikes. Dike top mowing allows enhanced predator visibility for foraging ‘alae 

ke‘oke‘o, ‘alae ‘ula, koloa maoli, and nēnē (Gee 2007). However, these management practices also 

create wildlife disturbance.

Under both alternatives, public use is minimal and most disturbance is associated with wetland 

management or kalo cultivation activities. A waterbird nest/brood search is done prior to 

maintenance or water level changes in rotational managed wetlands and maintenance is scheduled 

outside of peak rail breeding and koloa molting periods. In managed wetland units, Refuge staff 

minimize water level fluctuations during threatened and endangered waterbird laying and incubation 

periods. Requirements for dike maintenance (mowing) would assist waterbirds in detecting and 

avoiding non-native predators. 

Overall, disturbance would be greater under Alternative A than under Alternative B. 

Disturbance and Predation during Kalo Harvest

Under Alternative A, kalo permittees are required to maintain an unharvested vegetation buffer with 

at least three feet (radius) around threatened and endangered waterbird nests to provide concealment 

and protect breeding birds, nests, and young from weather, disturbance, and introduced predators.

This nest buffer is not based on empirical data and appears to be inadequate (Gee 2007) and in need 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

Section 3. Affected Environment and Environmental Consequences 27

of expansion and re-evaluation (Paveglio et al. 1999) to prevent detrimental effects on breeding 

adults and offspring. Thus, nest failure rates in loʻi kalo are likely to be higher under Alternative A 

than under Alternative B.

EFFECTS TO OTHER LISTED SPECIES

Effects to Other Listed Species 

Alternative A should result in negligible impacts to other listed species. There is no evidence of 

wetlands management conflicts with the endangered ‘ōpe‘ape‘a, which is a solitary tree-roosting 

species, or to listed seabirds that fly over the affected area.

3.2.3 EFFECTS OF ALTERNATIVE B (PROPOSED ACTION)

THREATENED AND ENDANGERED HAWAIIAN WATERBIRDS

Habitat Quantity and Quality/Rotational Managed Wetlands 

Under Alternative B, increased management to benefit threatened and endangered waterbirds would 

occur primarily through increasing the amount of and improving the quality of habitats provided to 

meet the species’ life history needs. An additional 3-18 acres of wetlands would be enhanced or 

restored under this alternative. Further, the transition of management paradigm to an adaptive 

management framework would promote the purpose of the Refuge by providing habitats that meet 

life history requirements for threatened and endangered waterbirds, while allowing for management 

flexibility to adjust to changing conditions (e.g., additional information from inventory and 

monitoring, disease outbreaks, availability of funding and resources, compliance with conditions of 

CAAs). This framework would also enable the spatial reconfiguration of management strategies; for 

example, retired or unallocated acreage could be allocated to rotational managed wetlands or 

exchanged for existing lo‘i kalo acreage depending upon soil, hydrological, and other environmental 

conditions.

Overall, compared with both baseline conditions and Alternative A, there would be more 

opportunities under Alternative B for threatened and endangered waterbirds to survive and reproduce 

and establish self-sustaining populations, thus assisting with their recovery (and eventual downlisting 

and delisting from the Endangered Species List). The beneficial effects would be minor to 

intermediate and long-term. 

Habitat Quantity and Quality/Dikes and Ditches

Under Alternative B, the acreage of dikes and ditches would be increased from 76 to a range of 76–

85 acres, including those acres within unallocated kalo farming areas and those associated with 

proposed wetland restoration areas. In addition to an increase in area, dike habitat and some ditches 

would be enhanced with herbaceous vegetation and provide more forage and nesting cover (e.g., for 

‘alae ‘ula and koloa maoli [Gee 2007]). The development and implementation of BMPs for ditch 

maintenance would also improve water quality within the ditches themselves. In addition, a Plan of 

Operations associated with CAAs would be developed to document ditch cleaning responsibilities. 

This would enhance water delivery to both lo‘i and rotational managed wetlands, facilitate drying 

and aerating of soils, and provide benefits to threatened and endangered waterbirds (improved ability 

to flood or dewater wetlands, improved water quality/quantity). Consequently, Alternative B would 

result in minor to intermediate benefits.
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

28 Section 3. Affected Environment and Environmental Consequences

Habitat Quantity and Quality/Riparian and Upland

Under Alternative B, additional habitat would be managed for foraging and breeding nēnē and 

nesting koloa maoli. For nēnē, there would be 14–24 acres of floodplain habitat mowed or managed 

with seasonal livestock grazing. For koloa maoli, there would be 21 acres of upland habitat also 

mowed or managed with seasonal livestock grazing. Due to the increase in managed acreage and 

habitat quality, this alternative is expected to have overall beneficial and minor to intermediate longterm effects. 

Habitat Quality/Kalo Farms

Lo‘i kalo in post-harvest wet fallow are heavily used by threatened and endangered waterbirds, in 

part because this stage generates substantial invertebrate biomass. Its shallowly flooded sediments 

are easily accessed by wildlife and potential predators are clearly seen (Broshears and Parrish 1980; 

Gutscher-Chutz 2011). Under Alternative B, there would be incentive mechanisms in place for 

farmers to provide longer wet fallow and dry fallow periods compared to current management under 

Alternative A (60 days or more of vegetated wet-fallow, followed by a two to six month dry fallow 

period). This would result in longer periods of invertebrate availability for foraging ‘alae ‘ula, ‘alae 

ke‘oke‘o, and koloa maoli. This would also result in reduced predation during foraging, since 

foraging birds can detect predators more easily in fallow lo‘i. 

Under Alternative B, the vegetation structure of lo‘i habitat (all stages) would be enhanced by 

requiring kalo permittees to manage for one of the following: 

• ≥10% cover of beneficial non-kalo emergent plants (≥3 species of low-growing annuals, <6–

12 inches tall; e.g., Fimbristylis littoralis, Cyperus spp., Eleocharis spp., Ludwigia spp., 

Schoenoplectus juncoides) in understory within each lo‘i;

• ≥20% cover of beneficial non-kalo emergent plants in understory on ≥50% of lo‘i; or

• ≥10% of total lo‘i acreage in vegetated wet fallow to promote growth of non-kalo emergent 

plants.

Waterbirds are generally opportunistic and use plants that are available for foraging and breeding. 

Many kalo farmers intensively remove non-kalo emergent vegetation during the first 4–6 months of 

growth to prevent these plants from out-competing kalo, which can provide more open water habitat 

for ae‘o. However, this practice also decreases vegetative structure available to invertebrates, nesting 

‘alae ‘ula and ‘alae ke‘oke‘o, and foraging ‘alae ‘ula, ‘alae ke‘oke‘o, and koloa maoli. Less intensive 

removal of selected emergent plants would provide additional seeds, leaves, and invertebrate food 

resources for threatened and endangered waterbirds and enhance visual obscurity for breeding ‘alae 

‘ula. Byrd and Zeillemaker (1981) found ‘alae ‘ula favored grasses, sedges, and ferns over kalo to 

build their nests when these plants were available nearby, and Gee (2007) found 46% of 48 nests 

built in patches of annuals (S. juncoides, C. difformis, L. palustris) beneath the kalo canopy. 

Allowing non-kalo emergent plants beneficial to waterbirds would diversify invertebrates available 

for food (Gutscher-Chutz 2011) and increase the quantity and quality of plants available for forage, 

nesting material, and nest anchors for multiple waterbird species. In addition, non-kalo emergent 

plants would assist with filtration, assimilation, and retaining nutrients and sediments on land. In less 

intensively managed lo‘i and fallow lo‘i where non-kalo emergent vegetation was present, koloa 

maoli engaged in foraging behaviors similar to those used in rotational managed wetlands 

(Malachowski and Dugger 2018). Collectively, implementation of these options would result in 

enhanced habitat, while also maintaining open water habitat for shorebirds. Providing “non-kalo food 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

Section 3. Affected Environment and Environmental Consequences 29

sources” and nesting material in and around the existing lo‘i kalo would also reduce the potential for 

crop depredation. 

The increase in plant diversity in lo‘i, combined with longer fallow periods, would result in increased 

invertebrate diversity and an increase in habitat suitability for threatened and endangered waterbirds

under Alternative B. Additional measures under Alternative B would provide enhanced benefits to 

threatened and endangered waterbirds compared to Alternative A by increasing habitat quality and 

reducing disturbance and predation by pest vertebrates.

Disease Mortality 

Under Alternative B, measures to improve water quality (e.g., improving water capacity, reducing 

fertilizer use; see below) would be expected to reduce the frequency and severity of botulism 

outbreaks. Additional strategies would be implemented in the short- to medium-term to reduce the 

frequency and severity of outbreaks, including implementing avian botulism protocol BMPs in 

botulism-prone areas, which may include draining, harvesting, and dry fallowing lo‘i for 30 days or 

more. Keeping ditches well-maintained and intakes flowing contributes to oxygenation of the water 

in the ditch and lo‘i, and combined with cooler water temperatures would reduce the potential for 

botulism outbreaks, since this bacterium needs an anaerobic environment to thrive.

Conducting quarterly meetings with permittees on avian botulism and response under Alternative B 

would likely reduce lag times on response to botulism outbreaks and therefore limit the spread of 

disease. Compared to Alternative A, we expect reduced frequency and severity of avian botulism 

compared to current levels, with a resulting decrease in botulism mortality.

In summary, increased availability of natural waterbird foods, cover types, nesting materials, and 

roost sites for waterbirds and a decrease in the conditions that exacerbate avian botulism with an 

improved response efficacy within kalo habitat would be expected under Alternative B. Therefore, 

we would expect increased benefit of lo‘i to threatened and endangered waterbirds. Improved 

quantity and quality of food resources would be expected to have beneficial effects to threatened and 

endangered waterbirds, including improved body condition and enhanced production, and support 

recovery goals for these species.

Predation

Under Alternative B, efforts to control and exclude vertebrate pests through fencing, trapping and 

removal, and permit stipulations would continue (i.e., same as Alternative A), but kalo permittees 

would also be required to report stray dogs or cats found on the Refuge to the Refuge manager or 

biologist as soon as possible, no longer than within eight hours of discovery. In addition, under 

Alternative B, the Service would conduct bi-annual meetings with kalo permittees and develop a 

compliance monitoring system. With increased communication and collaboration between the 

Service and permittees, we expect increased compliance with permit stipulations, and collaboration 

on other conservation measures for threatened and endangered waterbirds. Consequently, predation 

of threatened and endangered waterbirds by vertebrate pests would likely be lower in Alternative B, 

compared to Alternative A.

Disturbance and Predation during Kalo Harvest

Factors involved in depredation of Hawaiian waterbird nests are complex and include amount of 

vegetative cover, nest distance from dike, size of pond, linear feet of dike (predator travel lanes) in 

habitat. The occurrence of endangered waterbird nest failures within the 3-foot unharvested 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

30 Section 3. Affected Environment and Environmental Consequences

vegetation buffer area could also be related to drawdowns and lack of camouflage, which could also 

be mitigated by no drawdowns after harvest until birds have left on their own accord, and moist-soil 

vegetation in harvested fields for plant and invertebrate forage and nest camouflage.

Under Alternative B, water level fluctuations in lo‘i where waterbird nests are detected would be 

minimized. The current three-foot radius threatened and endangered waterbird nest buffer is likely 

insufficient to result in significant reductions in nest disturbance and predation compared to current 

levels (Paveglio et al. 2000). Therefore, we would initiate a study of the relative effectiveness of 

different radius nest buffers on nest and fledging success of threatened and endangered waterbirds 

within three years and modify buffer requirements and compatibility stipulations if necessary. Nest 

disturbance and predation would decrease in the long term as this new buffer size is determined and 

implemented. In the interim, in lo‘i where threatened or endangered waterbird nests are found, the 

current three-foot radius buffer would be changed to a minimum six-foot radius buffer around nests. 

Kalo farmers would be required to keep the lo‘i flooded and coordinate with Refuge staff to 

minimize impacts or take of birds by implementing additional protective measures as needed, such as 

delaying harvest in areas where nests are known to occur until the young birds fledge or leave the lo‘i 

of their own accord. Additionally, Alternative B would require reporting of threatened and 

endangered waterbird nests within 24 hours of discovery, rather than 48 hours. Overall, fewer 

impacts to threatened and endangered waterbirds from disturbance and/or predation would be 

expected under Alternative B than Alternative A.

EFFECTS TO OTHER LISTED SPECIES

Effects to Other Listed Species 

The proposed action would likely have negligible effects to other listed species. Actions taken to 

minimize disturbance to threatened and endangered waterbirds (e.g. during construction) would be 

likely to minimize effects to other listed species as well.

3.3 OTHER WILDLIFE AND AQUATIC SPECIES

3.3.1 AFFECTED ENVIRONMENT

In addition to the threatened and endangered waterbirds listed above, the habitats of Hanalei NWR 

within the scope of the WMWCP provide feeding, resting, or breeding habitat for a variety of both 

resident and migratory species. ‘Auku‘u (black-crowned night-herons, Nycticorax nycticorax hoactli) 

use wetland habitats for foraging. Of the 36 migratory waterfowl species documented for the 

Hawaiian Islands, at least 29 have been observed at Hanalei NWR. There are 27 species of migratory 

waterfowl (ducks, geese, swans) from both North America and Asia that use the Refuge as 

wintering/stopover habitat from approximately October–April. Koloa mohā (northern shoveler, Anas 

clypeata), koloa māpu (northern pintail, Anas acuta), and American and Eurasian wigeon, and greenwinged teal represent 95 percent of the migratory waterbird records. 

Twenty-three species of migratory shorebirds have been observed at Hanalei NWR. Of these, the 

most common are kōlea (Pacific golden-plovers, Pluvialis fulva), ‘ūlili (wandering tattlers,

Heteroscelus incanus), and ‘akekeke (ruddy turnstones, Arenaria interpres). Kōlea are by far the 

most numerous species, accounting for 90 percent of migratory shorebirds. They primarily forage on 

mowed dikes, but also use shallow wetlands and lo‘i kalo. Fallow units with open mudflats are used 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

Section 3. Affected Environment and Environmental Consequences 31

by shorebirds for night roosting, stopover, and rest/post-migration. Kōlea use the Refuge mainly 

August through April. 

All five species of endemic Hawaiian ‘o‘opu (amphidromous gobies) inhabit the Hanalei River. Two 

species (‘o‘opu akupa [akupa sleeper, Eleotris sandwicensis] and ‘o‘opu naniha [naniha goby, 

Stenogobius hawaiiensis]) use the lower reach for spawning and maturation. Species that inhabit the 

middle and upper reaches of the river pass through the Refuge during larval outmigration and 

juvenile upstream migration. Endemic Hawaiian shrimp (‘ōpae ‘oeha‘a, Macrobrachium 

grandimanus) occupy the lower reach (Yamamoto and Tagawa 2000). Native insects include the 

pinao (dragonflies) species Pantala flavescens, Anax junius, and A. strenuus. Refuge wetlands

support at least three orders of annelids, five orders of mollusks, and 16 orders of arthropods. 

3.3.2 EFFECTS OF ALTERNATIVE A (NO-ACTION)

Since current habitat management would continue, we would expect current use of the Refuge by 

these species to continue at current levels. Thus, effects to other native waterbirds and shorebirds 

would be minor positive. 

3.3.3 EFFECTS OF ALTERNATIVE B (PROPOSED ACTION)

Proposed changes to management of loʻi would result in more diverse plant communities and 

increased food resources for other resident waterbirds (e.g. ‘auku‘u) and migratory waterfowl and 

shorebirds (e.g. kōlea). More diverse plant communities, combined with longer fallow periods, would 

result in increased invertebrate production, and likely higher use of the Refuge by all of these 

species. Changes in wetland management to improve water quality (see below) would likely reduce 

the incidence and severity of avian botulism outbreaks, which would benefit native waterfowl and 

waterbirds.

3.4 WATER RESOURCES (HYDROLOGY, WATER QUALITY)

3.4.1 AFFECTED ENVIRONMENT

A majority of Hanalei NWR lies on the floor of the Hanalei Valley, which contains the Hanalei 

River. The Hanalei watershed extends from Mount Wai‘ale‘ale (elevation 5,148 feet) to the sea and

has a drainage area of about 23 square miles (Timbol 1977). Approximately 3.1 miles of the 15.7-

mile perennial Hanalei River flows through Hanalei NWR. It is the largest river in this watershed and 

has the greatest average discharge of any river or stream on Kaua‘i (HDBEDT 2009). The Hanalei 

River is characterized by good flow volumes throughout the year and from year to year. Monthly and 

yearly average discharge generally exceeds 150 cubic feet per second (cfs) (mean for both: 212 cfs), 

and on 60% of days, mean flow is above 100 cfs (USGS 2017; Pilson 2017). River flows are 

extremely flashy in nature, and substantial floods can occur during prolonged rains. Approximately 

189 acres of riparian habitat extends from the active river channel to the upland edge of the 100-year 

floodplain. Vegetation in riparian habitat is currently dominated by invasive hau along river and ditch 

margins, and California grass and Guinea grass throughout. Hau, in particular, can exacerbate effects 

of flooding and quickly form dense stands of vegetation that are impassible. 

Because of elevated levels of Enterococci and turbidity (total suspended solids), the State of Hawai‘i 

Department of Health (HDOH) identified the Hanalei Bay Watershed as water quality limited under 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

32 Section 3. Affected Environment and Environmental Consequences

Section 303(d) of the Clean Water Act (HDOH 2008). Elevated levels of nutrients (total nitrogen and 

total phosphorus) were also identified as a concern (Tetra Tech and HDOH 2008). HDOH 

established total maximum daily loads (TMDL) for the Hanalei River and Hanalei Estuary (HDOH 

2008). The HDOH identified no dischargers with National Pollutant Discharge Elimination System 

permits or other point sources of pollution in the Hanalei River Watershed, so the TMDL address 

non-point sources. Lo‘i kalo and several other anthropogenic and natural sources of pollutants were 

identified as sources of constituents of concern to the Hanalei River (Tetra Tech and HDOH 2008). 

Data collected over many years and used in the TMDL process have shown frequent exceedances of 

water quality standards for bacteria and turbidity and occasional exceedances for nutrients (nitrogen 

and phosphorus) in the Hanalei River. 

A portion of the flow from the Hanalei River is diverted into wetland management units and loʻi kalo 

on the Refuge. Much of the flow is redirected back into the river after passing through the Refuge. 

Wetlands on the Refuge are highly managed using a system of dikes, ditches, and water control 

structures. For a detailed description of water control infrastructure and management of Refuge 

wetlands and lo‘i kalo, see the dWMWCP, Section 2.2.

3.4.2 EFFECTS OF ALTERNATIVE A (NO-ACTION)

EFFECTS TO HYDROLOGY

Under Alternative A, the current acreage and configuration of lo‘i kalo and rotational managed 

wetlands would be maintained. Wetland management strategies that would have effects to hydrology 

and water quality include mowing, disking, rototilling, herbicide spraying, and water level 

management. Under both alternatives, hau removal along river banks may reduce flood severity. 

However, this effect would be negligible due to the small acreage of hau removed annually compared 

to its prevalence in the watershed. Overall, effects to hydrology under Alternative A are minor, both 

beneficial and negative, and long-term for wetlands management actions.

EFFECTS TO WATER QUALITY

Section 2.2.7 in the dWMWCP summarizes water quality studies conducted on the Refuge. 

Historically and currently, kalo farmers typically use conventional, chemical fertilizers year‐round. 

The exact amount of fertilizer applied differs from farmer to farmer. However, analysis of the 

nitrogen cycle in kalo ponds suggests that the conventional fertilization methods applied throughout 

most of the lo‘i kalo are prone to loss and runoff over time and can lead to elevated nutrient levels in 

receiving waters.

Additional water quality concerns related to kalo farming are the prevalence of wet tilling and other 

soil disturbance during kalo production, which can cause turbid water to flow back into the river. 

Results from water quality monitoring conducted during spring (March–April) and summer (June–

September) 2015, winter (January–March) 2016 in randomly selected managed wetland units and lo‘i 

kalo in the northeast and southeast indicated differences between water quality in managed wetland 

units and lo‘i kalo (Feddern 2016). The largest differences were dissolved oxygen (DO) and 

oxidation/reduction potential (ORP), both of which were lower in loʻi kalo than in the managed 

wetland units. Additionally, a strong correlation between low DO and low ORP was observed 

suggesting anoxic conditions contribute to negative ORP and thus higher avian botulism risk 

(Feddern 2015). In both lo‘i kalo and managed wetlands, summer DO was lower than winter DO. DO 
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Section 3. Affected Environment and Environmental Consequences 33

saturation and concentrations in the northeast lo‘i kalo in winter were greatly lower than in southeast 

lo‘i kalo. 

Additional observations were made regarding algal and plant abundance in loʻi compared to managed 

wetlands. In some loʻi, large mats of Azolla filiculoides (a nitrogen-fixing aquatic fern) and algae 

were present, while in other loʻi and managed wetlands Azolla was absent and algal abundance was 

minimal. Azolla grows best in high-phosphorus conditions and at depths of 0.5 to 0.833 ft (Uchida et 

al. 2008). Based on this information it was hypothesized fertilization in loʻi kalo causes Azolla and 

algal blooms in response to nutrient inputs. It is likely plant and algae die-offs follow these blooms as 

nutrients are consumed and loʻi water depth decreases (water draw-downs typically follow kalo 

fertilization). 

Kalo farmers routinely control unwanted vegetation using, among other methods, application of 

herbicides. Glyphosate is the only herbicide currently approved for use by kalo permittees per SUP. 

Wet tilling of farm soils; addition of fertilizer and pesticides; and ditch cleaning and removal of 

vegetation along ditch banks (depending upon the method used) may all contribute to this water 

quality impairment. Some kalo farming on the Refuge includes management or removal of unwanted 

vegetation from ditches and dikes. While these management practices provide loafing and foraging 

habitat for threatened and endangered waterbirds, they also potentially enhance sedimentation while 

reducing vegetative filtering of discharge water.

Other sources of water quality impairment along the Hanalei River include cesspools and 

contamination from farm equipment and farming-related supplies such as fertilizers, pesticides, and 

petroleum products. The Hanalei River watershed is large and steeply sloped in many areas. Flows in 

the lower river—which runs through a portion of the Refuge—are flashy, and the Refuge lands used 

for permittee residences, storage sheds, other facilities, and storage of equipment and supplies are 

subject to periodic flooding. This increases the risks to soil and water quality associated with 

flooding, either by washing fertilizer, pesticide, and petroleum residues into lo‘i kalo and rotational 

managed wetland units, or through leaching into groundwater. This is a special concern for 

equipment, supplies, and other materials stored outdoors or in sheds and other buildings with dirt 

floors. Under Alternative A, the Refuge would continue to work with farmers to reduce these sources 

of contamination by authorizing the upgrading of septic systems as needed and improving storage 

sheds and buildings to include impervious floors, drains, and containment/filtering systems. 

Ditch maintenance and cleaning is expected to have a positive effect on allowing water to flow more 

freely. The minor to moderate beneficial effects of the cleaning are not anticipated to negate flooding 

associated with major flood events.

Under both alternatives, vegetation removal (e.g., hau bush along river banks) could, in the shortterm, have negative effects to water quality as soils may be disturbed at the root zone or if herbicides 

are applied to kill pest plants or suppress regrowth. However, based on past vegetation removal by 

the Refuge, the small acreages proposed (e.g., 2–5 acres of hau per year in priority areas), impacts to 

water quality are anticipated to be negligible. BMPs would be implemented to prevent sedimentation 

of waterways.

As noted above, Hanalei NWR has been identified as a contributor of elevated levels of sediment and 

nutrients to Hanalei River, and the impact of kalo farming (sediment, fertilizers, and herbicides) and 

outdated septic systems on water quality is a major area of concern (Tetra Tech and HDOH 2008). 

Overall, under Alternative A, sediment and nutrient discharge to the Hanalei River is likely to remain 
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34 Section 3. Affected Environment and Environmental Consequences

similar to current levels, and would be likely to be have at least intermediate, negative long-term 

effects on water quality in the lower reach of the river.

EFFECTS OF FERAL PIG REMOVAL

Under both alternatives, the removal of feral pigs (through fencing, trapping, and shooting) as well as 

other vertebrate pests (e.g., rats, mice, cats, dogs, bullfrogs, chickens, barn owls, cattle egrets) would 

benefit water quality by reducing direct fecal contamination of water. This would indirectly benefit 

human health since human diseases such as leptospirosis have been linked to some of these animals. 

Other indirect effects associated with removal of pigs would be less ground disturbance associated 

with pig grubbing, rooting, and wallowing activities and less bare soil that could increase sediment 

loads in the Hanalei River. This effect, while beneficial, would be minor.

3.4.3 EFFECTS OF ALTERNATIVE B (PROPOSED ACTION)

EFFECTS TO HYDROLOGY

Effects to hydrology under Alternative B could include changes to the water table caused by 

contouring pond bottoms and creating sloughs in new wetland management units. These actions, if 

the unit is dry, may tap into water tables that are close to the surface, potentially lowering the water 

table. If the wetland units have water in them, they would probably feed the water table rather than 

tap into it since water moves along a gradient, from high potential energy (wetland) to lower 

potential energy (underlying aquifer) (T. Mayer pers. comm 2011). The enhancement of riparian 

zones and creation of new wetlands under this alternative would be beneficial to the floodplain as 

these habitats provide the ability to capture, hold, and attenuate flood waters, nutrients, and the 

erosive properties of moving water.

Given climate change, the availability of future water resources is uncertain. However, based on 

current hydrological data and studies, effects to hydrology under both alternatives are anticipated to 

be beneficial and minor, but long-term as these management strategies are ongoing. Additionally, 

Alternative B includes the development of a water budget and water efficiency study to gain a better 

understanding of water use and improve efficiency. Wetlands provide multiple functions and values 

including the ability to capture, hold, and attenuate flood waters, nutrients, and the erosive properties 

of moving water. Indirect effects caused by these minor direct effects may include loss of surface and 

groundwater for those downriver who may be using these existing resources, including river waters 

which exit to the ocean; however, these effects are anticipated to be negligible. 

EFFECTS ON WATER QUALITY - WETLANDS MANAGEMENT AND NEW WETLAND UNITS

The management strategies used for rotational managed wetlands that would have effects to water 

quality include mowing, disking, rototilling, herbicide spraying, water level management, contouring 

pond bottoms, and creating sloughs. Currently, Hanalei has 86 acres of rotational managed wetlands. 

Under Alternative B, an additional 3–18 acres (up to an eight percent increase) is proposed. These 

new units would require installation of water control structures as well as water delivery systems. 

The creation of new wetland management units at Hanalei would not require additional water from 

Hanalei River. The primary water sources would be direct rainfall, runoff, and the existing ditch 

system and water allocation. Management strategies used to create new wetland units and that would 

have effects to water quality include dike removal and contouring of pond bottoms. However, effects 

would be temporary, occurring only during the activity period. Additionally, since the Refuge has 
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Section 3. Affected Environment and Environmental Consequences 35

control over the hydrology in these units, sediment would be allowed to settle before resuming water 

management of these ponds and allowing outflow back to the Hanalei River. Therefore, effects to 

water quality are anticipated to be temporary and negligible. Overall, the addition of new wetlands 

results in more settling of suspended solids and more nutrient removal (by plants, by settling of 

solids, or by nitrification/denitrification). 

EFFECTS ON WATER QUALITY - KALO FARMING

Kalo farming activities that affect hydrology and water quality include cultivation, adding fertilizer 

and lime, disking and/or tilling of the soil, and flooding to prepare lo‘i for planting; planting of cut 

kalo plants (huli) or underground shoots (‘oha); flooding, dewatering, and reflooding; removal of 

unwanted vegetation; harvesting; and dry and wet fallowing. Hanalei NWR has been identified as a 

contributor of elevated levels of sediment and nutrients to Hanalei River. In addition to other 

contributors (e.g., ungulates, road and trail erosion), kalo farming (e.g., herbicide, sewer system) on 

water quality is a major area of concern (Tetra Tech and HDOH 2008) and likely to be having at least 

intermediate, negative long-term effects. 

Under Alternative B, lower levels of sediment, nutrient, and contaminant inputs to the Hanalei River 

resulting from kalo farming would be expected due to: (1) Developing, implementing, and 

monitoring effectiveness of BMPs to improve water quality and flow; (2) Developing and 

implementing fertilizer and herbicide management plans to minimize runoff of excess fertilizer and 

herbicide; (3) Working with kalo permittees to ensure accurate and specific annual fertilizer and 

herbicide reporting; (4) Encouraging the use of ecologically friendly alternatives to traditional 

fertilizers; and (5) Developing and utilizing BMPs for ditch maintenance to minimize adverse water 

quality impacts (reduce herbicide use, mechanically hedge, maintain vegetated banks, and explore 

methods to remove nutrients and sediment). Under Alternative B, permittees would be required to 

implement activities that would improve water quality. Examples include the use of IPM, reduced 

use of chemicals, less intense weeding, and developing and implementing BMPs with Refuge staff. 

For example, kalo farmers would be required to allow a portion of native and naturalized wetland 

plants to grow in lo‘i, which would assist with sediment trapping and soil retention in the lo‘i and 

nutrient conversion into bio-available forms for uptake by other plants and animals. As in Alternative 

A, we would enforce federal regulations, Service policies, and permit conditions related to storage of 

equipment and supplies, and the disposal of non-composted organic materials and nonhazardous 

solid waste. As in Alternative A, we would continue to work with farmers to reduce these sources of 

contamination by upgrading septic systems and improving storage shed and buildings to include 

impervious floors, drains, and containment/filtering systems.

EFFECTS ON WATER QUALITY - RIPARIAN HABITAT MANAGEMENT (MOWING, GRAZING) 

Under Alternative B, there would be 14–24 acres of floodplain grasslands managed as nēnē foraging 

and breeding habitat, using mowing and/or seasonal livestock grazing. Seasonal grazing is not 

currently used on the Refuge and its use will be explored for managing these floodplain grasslands, 

as well as to create new managed wetland units. In areas transitioning to upland, native shrublands 

would be restored for additional foraging, nesting, and brood-rearing habitat. 

Potential negative impacts to water quality from initial clearing and grubbing of existing invasive 

vegetation and installation of structures (e.g., pipelines, fencing) would be minimized by conducting 

these activities during the drier months in phases to allow for regeneration of native or naturalized 
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36 Section 3. Affected Environment and Environmental Consequences

riparian vegetation from the existing seedbank. A ≥150-foot riparian and wildlife buffer zone would 

be established to reduce any unanticipated run-off from these activities.

Negative effects to water quality could result from the use of livestock (manure deposits in the river, 

compaction, or erosion). However, if this management strategy is employed, conservation measures 

and BMPs would be developed to reduce these effects. These measures include establishing the use 

of a buffer zone, fencing, watering troughs to keep livestock away from the river, and development 

of a prescribed grazing plan that would identify additional measures such as stocking rates and 

seasons (e.g., drier months May–Oct.) to enhance waterbird habitat and protect river resources. 

Therefore, negative water quality effects associated with grazing are anticipated to be minor and 

short-term. For more information, see dWMWCP, Appendix B, Draft Compatibility Determination 

for Cooperative Grazing.

SUMMARY

Under Alternative B, there would be a slight increase in the scope, scale, and intensity of effects to 

water quality due to habitat management actions. Overall, effects to water quality are anticipated to 

be beneficial, minor, and long-term. Additional riparian management actions proposed under 

Alternative B would result in short term negative impacts, but negligible to minor beneficial effects 

in the long term. Alternative B would result in improved water quality in the Hanalei River, 

benefitting native fish (‘o‘opu), shrimp (‘ōpae ‘oeha‘a), and invertebrates.

3.5 GEOLOGY AND SOILS

3.5.1 AFFECTED ENVIRONMENT

The affected area is the northwest section of the Refuge, an open flat alluvial plain (floodplain) that 

extends west toward Hanalei Bay from the north end of the valley. Soils fall predominantly in the 

Hanalei soil series (Foote et al. 1972; NRCS 2017), formed in alluvium deposited by the Hanalei 

River in this low gradient and meandering section of the river. These silty clays and silty loams 

underlie most of the wetlands and loʻi and are characterized by poor drainage and moderate 

permeability. Soils in the northwest portion of the Refuge are sandier, indicative of former 

shoreline(s) when the sea level was higher (Chadd Smith 2017, pers. comm.). Finer silts are found in 

areas of the floodplain where settling occurs. Coarser, gravelly textures dominate point bars on the 

Hanalei River.

3.5.2 EFFECTS OF ALTERNATIVE A (NO-ACTION)

Wetland management activities involve using heavy equipment to till or disk and control pest plants 

(see dWMWCP, Appendix C for photos). During this process, large soil particles are broken up and 

soils are contoured to create variable shallow topographic features and microhabitats. Moist soils are 

worked within management units or basins impounded by dikes; thus, soil erosion effects are 

negligible. If units are wet-tilled, sediments and nutrients are allowed to settle for 1–2 weeks and pest 

plants are allowed to decompose before draining. When dikes are removed, soils would be disturbed 

through digging, plant removal, relocation, and compaction. These soils would be used to maintain 

other dikes as part of wetlands management. If heavy rainfall occurs when wetland management 

units are at a stage where there is substantial bare ground (soils are unvegetated or recently tilled), 

soils may be more vulnerable to erosion. However, water control structures would be set to impound 

water versus allowing it to run off, and most wetland management units are vegetated with wetland 
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Section 3. Affected Environment and Environmental Consequences 37

plants that trap sediments and assimilate nutrients. Installation of new water control structures affects 

soil resources through disturbance of soils and removal of plant cover. However, based on past 

Refuge experience with wetlands management and installation of related structures, soil disturbance 

would be short-term, and revegetation of bare soil begins to occur within days in these fertile valleys. 

Therefore, negative impacts are anticipated to be minor and short-term. 

Lo‘i kalo management involves numerous actions affecting soils, including cultivation, adding 

fertilizer and lime, disking and/or tilling of the soil, and flooding to prepare lo‘i for planting; planting 

of cut kalo plants (huli) or underground shoots (‘oha); flooding, dewatering, and reflooding; removal 

of unwanted vegetation; harvesting; and dry and wet fallowing. Fallowing and aerating helps 

increase yield per acre by resting lo‘i, improving soil health, and breaking disease and pest cycles 

(NRCS 2009). 

The removal of pigs under both alternatives has a beneficial impact on soils, since pigs grub and root 

in search of food and create wallows. Removal of pigs would reduce such ground disturbance, 

including potential sedimentation of streams, which would be long-term beneficial for both soils and 

water quality. 

Under both alternatives, invasive vegetation management (e.g., hau bush along river banks) could 

result in short-term negative effects as soils may be disturbed at the root zone or if herbicides are 

applied to kill pest plants or suppress regrowth. However, based on past invasive vegetation removal 

by the Refuge, the small acreages proposed (e.g., 2–5 acres of hau per year in priority areas), soil 

effects are anticipated to be negligible. BMPs would be implemented to prevent sedimentation of 

waterways.

Fallowing helps increase yield per acre by resting lo‘i, improving soil health, and breaking disease 

and pest cycles (NRCS 2009). Alternative A would have smaller acreages of fallow kalo habitat at 

any given time, which leads to slightly greater negative impacts to soils than under Alternative B.

Overall, negative impacts due to soil disturbance are anticipated to be minor and short-term.

3.5.3 EFFECTS OF ALTERNATIVE B (PROPOSED ACTION)

As under Alternative A, management strategies that would affect soils include wetlands management 

(e.g., mowing, disking, rototilling, water level management, contouring pond bottoms, creating 

sloughs, and ditch maintenance); lo‘i kalo management; pig removal; and hau bush removal. In 

addition, under Alternative B, the following proposed actions would have effects to soils: the 

development of new wetland management units and related water control/delivery structures; and

seasonal livestock grazing explored on an experimental basis, including pre- and post-monitoring. 

Livestock grazing can be used as a valuable tool to manage grassland habitats. However, unless 

properly managed, livestock grazing can cause a variety of undesirable effects (Kirby et al. 1992), 

including soil compaction. Livestock can graze pastures unevenly. Negative impacts associated with 

use of livestock be minimized by requiring monitoring by a qualified biologist and adopting a 

prescribed grazing plan that would identify stocking rates and seasons (e.g., drier months May–Oct.). 

The provision of an in-pasture water supply and salt blocks would deter livestock from riparian areas 

and, as necessary, encourage more consistency in grazing pressure. Additionally, BMPs such as cross 

fencing and pasture rotations would also be considered and used, as appropriate. The acreage of 

potential seasonal livestock grazing at Hanalei NWR proposed under Alternative B is small, 

therefore leading to a minor long-term negative impact to soils. 
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38 Section 3. Affected Environment and Environmental Consequences

Alternative B proposes greater acreages of fallow kalo habitat, which would lead to a greater 

beneficial effect on soil quality than under Alternative A. Overall, impacts under Alternative B are 

anticipated to be minor and short-term.

3.6 VISITOR USE AND EXPERIENCE

3.6.1 AFFECTED ENVIRONMENT

Visitor activities within the affected area include wildlife observation and photography, and fishing. 

Visitors access wildlife observation and photography opportunities via the Hanalei River, which runs 

through the Refuge but is not under Refuge jurisdiction, and the 2-mile long ‘Ōhiki Road, a countymaintained road which bisects the Refuge and also provides access to the State ‘Ōkolehao Trail. The 

interior areas of the Refuge are not open to the general public. Public access in closed areas may be 

authorized via SUP in situations where such access is compatible with the Refuge purpose and for 

compatible uses (e.g., National Wildlife Refuge Week, environmental education, and wildlife 

observation). The scenic valley in the heart of the Refuge is a popular subject of photographers on 

Kaua‘i and is often best captured from above at the Hanalei Valley Scenic Overlook located along 

Kūhiō Highway on Refuge land (outside of the action area), which is open to the public and available 

year-round for interpretation, wildlife viewing, and photography.

Environmental education has been offered at the Refuge in the past; however, due to funding and 

staffing cuts, it is provided only on a limited basis as noted above. The non-profit Ho‘opulapula 

Haraguchi Rice Mill organization, a 501(c)3 nonprofit, conducts limited commercial tours of the 

historic Haraguchi Rice Mill under a SUP. The rice mill was built in the 1880s, operated until the 

1960s, and is listed on the National Register of Historic Places (NRHP). The rice mill buildings are 

privately owned by the Haraguchi family and are located on Hanalei NWR lands. 

Fishing occurs on a limited basis on the Refuge from the banks of the Hanalei River. The majority of 

the use occurs along the banks of the Hanalei River, adjacent to the first half-mile of ‘Ōhiki Road.

Fishing methods include hook and line, and net consistent with Hawai‘i Fishing Regulations. Most 

river fishing occurs from boats and is not under Refuge jurisdiction. Canoeing, paddle boarding, and 

kayaking also occur on the Hanalei River. 

3.6.2 EFFECTS OF ALTERNATIVE A (NO-ACTION)

Under Alternative A, habitat management would remain the same as present, and while existing 

habitat would be maintained, no new habitat would be created. Therefore, opportunities to view or 

photograph native wildlife would remain the same as present. Water quality would remain the same 

as present, and therefore there would be negligible changes in effects to fish populations or fishing 

opportunities.

Overall, current management has negligible to minor impacts to the limited amount of public use 

occurring on the Refuge. Continuation of current management would not be expected to reduce the 

potential for high-quality, compatible, wildlife-dependent recreation into the future.

3.6.3 EFFECTS OF ALTERNATIVE B (PROPOSED ACTION)

Alternative B strategies would enhance existing and create new habitat for threatened and 

endangered Hawaiian and migratory waterbirds. These strategies would indirectly increase 
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Section 3. Affected Environment and Environmental Consequences 39

opportunities for wildlife observation and photography, environmental education, and interpretation, 

and/or increase the quality of these opportunities (e.g. number of native birds seen from designated 

parking along the ‘Ōhiki Road, the Hanalei Valley Scenic Overlook, or during guided tours or special 

events). These indirect effects are anticipated to be beneficial and minor. 

Proposed strategies to reduce sediment and nutrient inputs to the Hanalei River would be expected to 

improve water quality of the river and may be beneficial to the species that are fished. Therefore, 

there may be minor, indirect beneficial effects to fishing opportunities. Hunting does not occur on the 

Refuge, but pigs are a hunted species on lands adjacent to the Refuge. Efforts to control feral pigs on 

the Refuge would have negligible effects to off-Refuge hunting opportunities, given the large 

population and high reproductive rates of pigs.

3.7 CULTURAL RESOURCES

3.7.1 AFFECTED ENVIRONMENT

Archaeological investigations (1979–1993) on the Refuge identified lo‘i, ‘auwai, stacked stone wall 

and historic concrete structure foundations, terraces, pondfields, habitation areas, religious structures 

(e.g., heiau), a Chinese cemetery still in use, trash deposits, the Miko taro house, rock ovens, the 

Princeville ranch headquarters, the Haraguchi Rice Mill, and a possible imu (underground oven) pit

(Shapiro and Shapiro 1995). Most of these features are concentrated on the valley floor and eastern 

side of the Refuge and are either pre-European contact or historic, with agriculture being the primary 

function of most of the 43 sites. 

The Hanalei National Wildlife Refuge Historic and Archaeological District (HNWRHAD; State Site 

50-30-03-304) includes over 20 individually recorded archaeological sites. The HNWRHAD was 

listed on the NRHP in 1980. The significance of the district is based on archaeological evidence 

indicating that Hanalei Valley has been continuously occupied for over 1,300 years. Evidence 

indicates that the entire alluvial plain had been cultivated in pre-European contact times; however, 

there is limited evidence of actual habitation. Shortly following European contact, the valley came 

under the influence of foreigners, and physical evidence, such as the historic Haraguchi Rice Mill 

(State Site 50-30- 03-9385), provides an understanding of the economy of post-contact cultures in the 

valley. For example, the historic Hanalei Valley is one of the few remaining areas of significant kaloproducing acreage in the state, continuing the practice that dominated the valley for hundreds of 

years prior to European contact. Within the Refuge are also two historical irrigation systems (China 

and Kuna Ditches), which continue to supply the Refuge wetland management units and lo‘i kalo. In 

the 1980s, the NTHP declared Hanalei Valley as one of the 10 most important sites for rural 

preservation in the western United States.

Kalo farming on Hanalei NWR is of cultural interest and importance to Native Hawaiians across the 

state and the general public. Farmers living in modest residences adjacent to the lo‘i kalo where they 

work is representative of a traditional, tenant-farming system that has mostly disappeared in Hawai‘i. 

3.7.2 EFFECTS OF ALTERNATIVE A (NO-ACTION)

Under both alternatives, supporting lo‘i kalo on the Refuge at Hanalei has beneficial impacts for 

cultural resources. Also under both alternatives, prior to undertaking any ground-disturbing or other 

activities that could affect cultural resources, the Service would continue to undertake appropriate 

surveys and engage in consultations as required by the NHPA (see Section 2.1). Where practicable, 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

40 Section 3. Affected Environment and Environmental Consequences

cultural sites would be avoided. Mitigation of effects (e.g., through excavation and recording of data) 

and minimization of effects would be secondary choices. In the event that human bones, burial 

remains, or other archaeological or historic resources were inadvertently disturbed in the course of 

conducting Refuge management, maintenance, repair, construction, or other activities, the disturbing 

activity would be immediately discontinued and the relevant state, federal, and/or Native Hawaiian 

authorities would be notified. Refuge activities in the affected area would not be resumed until 

appropriate clearance had been obtained. Routine maintenance activities common to all alternatives 

(e.g., maintenance of existing ditches, dikes, and wetlands) are undertakings of the type that have no 

potential to cause effects to historic properties that may exist in the maintenance location (36 CFR 

800.3.a.1). Therefore, it is anticipated that effects to cultural resources would be negligible.

3.7.2 EFFECTS OF ALTERNATIVE B (PROPOSED ACTION)

Under Alternative B, several ground-disturbing activities are proposed that may affect cultural and 

historic resources. These actions revolve primarily around restoring seasonal wetlands, creating new 

wetland management units, installation of water control structures and related pipelines, 

improvements to the existing maintenance facility, mowing, livestock grazing, and invasive plant 

management. Since an archaeological investigation has been conducted and Refuge policy outlines 

procedures that stop all activities should cultural and historic resources be inadvertently discovered 

(as well as notify State Historic Preservation Office and RHPO), it is anticipated that effects to these 

resources would be negligible. However, when a ground-disturbing project described in this EA is 

specifically identified for implementation, the Service will follow the NHPA Section 106 process and 

consider the potential effect of the project on historic properties, if present in the project area.

3.8 LAND USE

3.8.1 AFFECTED ENVIRONMENT

The predominant land uses in the vicinity of the Refuge are agriculture (primarily grazing/pasture), 

resorts, golf courses, diversified agriculture, and residential. Nine permittees (individuals or families) 

farm kalo on the Refuge. There are currently 287 individual loʻi kalo with a total footprint of 160 

acres (i.e. including dikes, ditches, and canals). There are 14.2 miles of ditches and approximately 15 

miles of pipe on the Refuge, with a portion of that owned/maintained by kalo farmers. There are six 

primary residences that are owned and occupied by five of the nine permittees/cooperators 

(individuals or families) who farm kalo on the Refuge. The lands occupied by these residences and 

surrounding areas range in size from 0.4–2.8 acres each. There are three storage sheds on the Refuge 

used by Refuge kalo farmers who reside off-Refuge. The lands occupied by these storage sheds and 

surrounding areas range in size from 0.04–0.06 acres each. The kalo farming-related residences, 

storage sheds, and outbuildings on the Refuge (but not the underlying land) are the property of the 

kalo farmers. Most of these buildings were constructed prior to Service acquisition of the Refuge.

‘Ōhiki Road, a 2-mile, dead-end, one-lane road, runs approximately northwest to southeast, splitting 

Hanalei NWR in two, with the Refuge boundary adjacent to both sides of the road. The road is 

maintained by the County of Kaua‘i. This public road is primarily used by tourists, Refuge staff, and 

local residents who live either on the Refuge or in the back of the valley. This road provides access to 

an adjacent historic rice mill, the Service’s maintenance baseyard, a dirt/gravel parking area where 

people park to access the ‘Ōkolehao Trail (a state hiking trail), of which 1⁄4 mile is on Refuge land,

and private residences.
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Section 3. Affected Environment and Environmental Consequences 41

3.8.2 EFFECTS OF ALTERNATIVE A (NO-ACTION)

Under Alternative A the number of acres in cooperative agriculture would remain the same as 

current, unless acreage was given up or forfeited by existing farmers. Under both alternatives, if a 

kalo farming CAA and SUP is terminated for a given permittee, then the associated use of Refuge 

lands for permittee-owned residences, storage sheds, and other facilities would no longer be allowed 

and the permittee would need to remove their improvements (residences, storage sheds, outbuildings, 

and other structures), equipment, supplies, and other personal property from the Refuge. This 

scenario would result in a decrease in the number and footprint of structures on the Refuge.

No new wetlands would be developed, and there would be no new construction. Therefore, under 

Alternative A, there would be negligible to intermediate effects to land use.

3.8.3 EFFECTS OF ALTERNATIVE B (PROPOSED ACTION)

Alternative B would support the continuation of cooperative kalo farming on the Refuge and include

exploration of cooperative livestock grazing as a habitat management tool. The number of acres of 

cooperative kalo farming would be subjected to decision-making under an adaptive management 

framework and may vary between years. Cooperative kalo farming CAAs and SUPs would be 

clarified such that no new farm residences are authorized on Refuge property.

Under Alternative B, creation of 3–18 acres of new wetlands would occur, including supporting 

infrastructure (e.g. pipe, water control structures). Consequently, under Alternative B, there would be 

minor to intermediate effects to land use.

3.9 REFUGE ADMINISTRATION

3.9.1 AFFECTED ENVIRONMENT

During fiscal year 2018, the equivalent of five full-time Service staff were involved in managing 

farming in the Refuge as part of their regular duties. Staff activities included fence construction and 

maintenance for feral pig control, avian botulism surveillance and response, water infrastructure 

improvement, general and special use permit coordination, ditch cleaning and maintenance, response 

to media, response to official inquiries, invasive tree removal, and other assistance. In addition to 

coordinating with kalo permittees, the Service also provides law enforcement protection against 

trespassers and other issues regarding human safety, helps coordinate disaster relief and reparation, 

controls invasive plants and wildlife, rescues sick and injured wildlife, constructs fencing, maintains 

ditches, and manages the irrigation system. We estimate that the Service provided the equivalent of 

approximately $132,656 in salaries or work time for staff, interns, biotechnicians, and volunteers for 

work related to kalo farming on the Refuge, based on the average wage rate and total logged hours

(DJL Economic Consulting 2019). Equipment and material costs for habitat management in the 

Refuge including, but not limited to, fencing material, excavator, and water infrastructure materials 

has cost the Service $420,000 over the past several years. Based on estimated durability of purchased 

machinery, annualized machinery expenditures are approximately $25,833 per year. The cost of tree 

removal is approximately $1,250 per year (DJL Economic Consulting 2019). 
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42 Section 3. Affected Environment and Environmental Consequences

3.9.2 EFFECTS OF ALTERNATIVE A (NO-ACTION)

Due in part to implementing the Service’s revised cooperative agriculture policy, additional staffing 

would be required compared to current levels. $606,877 would be needed annually for staff salaries, 

(see WMWCP Appendix E for more information). Equipment and material costs for habitat 

management in the Refuge including, but not limited to, fencing material, excavator, and water 

infrastructure materials would be expected to remain similar to present. Therefore, there would be an 

anticipated minor to moderate impact to Refuge administration from implementing Alternative A.

3.9.3 EFFECTS OF ALTERNATIVE B (PROPOSED ACTION)

Implementation of Alternative B would require greater total costs for the Service as Alternative B

includes more habitat management and species protection measures, which would result in the need 

for additional labor costs, supplies, and services. For example, the costs associated with restoring and 

enhancing the 3 to 18 acres of existing lowland in the Refuge to additional wetland management 

units. Alternative B also calls for the development of several additional management plans for the 

Refuge, such as fertilizer and herbicide management plans and a prescribed grazing plan. Additional 

labor and equipment costs would also result from increased resource monitoring and management 

requirements, e.g., grazing, CAAs, additional areas to manage invasive species and avian disease,

and proposed drainage improvements included in Alternative B, such as contouring pond bottoms, 

installing water control infrastructure, and creating sloughs. Fully implementing this alternative 

would require the equivalent of 2.3 additional full-time Service staff members, and a $244,453 

increase in annual staffing costs as compared Alternative A (see WMWCP Appendix E for more 

information). Thus, there would be an anticipated moderate impact to Refuge administration from 

implementing this alternative.

3.10 LOCAL AND REGIONAL ECONOMIES

3.10.1AFFECTED ENVIRONMENT

The Refuge is adjacent to Hanalei Town, Kaua‘i County, Hawai‘i, with a population of 254 in 2017. 

The nearest large town is Princeville with a population of 1,945 in 2017 (U.S. Census Bureau 2019a).

Kaua‘i’s economy was founded on agriculture, which produced crops such as sugarcane and kalo. 

Although agriculture is still an important industry on the island, tourism has far surpassed agriculture 

as the county’s leading industry. Kaua‘i County relies heavily on tourism for employment, with the 

service industry accounting for 57 percent of all non-farm jobs (IMPLAN 2011). The service 

industry includes hotel accommodations, restaurants, and visitor services such as tours or guided 

activities. Government, including federal, state, and local, accounts for 14 percent of employment 

and the trade industry makes up 13 percent of non-farm employment (IMPLAN 2011).

3.10.2EFFECTS OF ALTERNATIVE A (NO-ACTION)

Under Alternative A, $337,150 would be spent annually for staff salaries, which is a $204,494 

increase over current conditions. Equipment and material costs for habitat management in the Refuge 

including, but not limited to, fencing material, excavator, and water infrastructure materials has cost 

the Service $420,000 over the past several years. Based on estimated durability of purchased 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

Section 3. Affected Environment and Environmental Consequences 43

machinery, annualized machinery expenditures associated with the kalo farming program are 

approximately $25,833 per year. The cost of tree removal is approximately $1,250 per year. 

In 2009, total labor income in Kaua‘i County was estimated at $1.6 billion and total employment was 

estimated at 38,050 jobs (IMPLAN 2009 data; IMPLAN 2011). Thus, total economic impacts 

associated with Hanalei NWR operations under Alternative A represent less than one percent of total 

income (0.02 percent) and total employment (0.02 percent) in the Kaua‘i County economy. 

Therefore, although Alternative A would provide economic benefits, the impact would be 

insignificant as a percentage of total economic output for Kauai County

As with Alternative B, indirect benefits would result from ecosystem services. The Service manages 

wetlands in the Refuge, which provide critical ecosystem services, serving as filters, purifying, and 

improving the water quality of Hanalei River. The plant communities and soil within wetlands also 

sequester carbon, helping to moderate global climate change conditions. Other benefits to wetlands 

include: 

• Dissipate energy: During heavy rainfall wetlands reduce stream speed and act as natural 

sponges that absorb water

• Improve water quality: wetlands purify water, filter out sediments and contaminants

• Control erosion: wetlands buffer shorelines against erosion and bind the soil with their roots

• Provide fish and wildlife habitat 

• Supply ground waterflow: wetlands contribute to base flow of streams

• Reduce flooding: wetlands soak up and store water and slowly release into streams

• Protect the coast from storms: coastal wetlands buffer the large wave energy we receive 

during winter swells

These would provide indirect socioeconomic benefits such as improved recreational opportunities 

(e.g., bird-watching, fishing), better water quality, and reduced costs of replacing or repairing 

culverts and other public infrastructure due to a reduced frequency and intensity of high volume 

events (The Trust for Public Land 2010). Overall, conservation lands and other protected open space 

can reduce the need for costly public services and provide regional socioeconomic benefits.

Water quality in the Hanalei River has indirect effects to the economy by affecting river and oceanbased recreation. Sediment and nutrient inputs to the Hanalei River from the Refuge would be 

expected to be higher under Alternative A than under Alternative B, which would impact the lower 

reach of the river, and Hanalei Bay. Indirect negative effects to the bay and associated recreational 

activities would be expected to by slightly higher than under Alternative B, but still minor.

3.10.3EFFECTS OF ALTERNATIVE B (PROPOSED ACTION)

Direct effects of Alternative B on local and regional economies would be minor and beneficial, and 

slightly greater than under Alternative A. Implementation of Alternative B would include 

significantly more habitat management and species protection measures, which would result in 

greater expenditures by the Refuge for salaries, labor, supplies, and services, and greater benefits to 

the local economy that under Alternative A. Fully implementing Alternative B would require the 

equivalent of 2.3 additional Service staff members and a $244,453 increase in annual staffing costs as 

compared Alternative A.
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44 Section 3. Affected Environment and Environmental Consequences

Total labor income in Kaua‘i County was estimated at $1.6 billion and total employment was 

estimated at 38,050 jobs (IMPLAN 2009 data; IMPLAN 2011). Total economic impacts associated 

with Hanalei NWR operations under Alternative B represent less than one percent of total income 

(0.03 percent) and total employment (0.02 percent) in the Kaua‘i County economy. Therefore, 

although the economic benefits of Alternative B would be greater than under Alternative A, the 

impact would be insignificant as a percentage of total economic output for Kauai County. As with the 

implementation of Alternative A, the regional socioeconomic conditions under Alternative B would 

remain similar to existing regional socioeconomic conditions.

Indirect economic benefits would result from improved ecosystem services provided by the Refuge 

(discussed under Alternative A). Neighboring landowners would continue to benefit from additional 

stormwater mitigation from the additional wetland acreage, drainage improvements, and ditch 

maintenance. 

The largest non-wildlife-dependent recreation on Kaua‘i by its visitors tends to be sightseeing, selfguided tours, beach activities, and ocean recreation. Indirect beneficial effects to these uses and the 

associated tourism economy may result from proposed management strategies under Alternative B

that would improve water quality of the Hanalei River, which feeds the Hanalei Bay. Poor water 

quality could affect Hanalei Bay through loss of important spawning and nursery habitat for native 

fishes including ‘ama‘ama, ‘o‘opu, and āholehole and other coral reef species. Closure of beaches 

due to water quality issues would have negative effects to the tourism industry. However, 

development of BMPs and other minimization measures under Alternative B would minimize 

negative effects to water quality resulting from kalo farming and other wetland management 

operations; therefore, indirect effects to the estuarine and nearshore environment are anticipated to be 

negligible. Overall, the indirect benefits to the local economy from improved ecosystem services and 

water quality would be greater under Alternative B than Alternative A, but the increase is difficult to 

quantify.

3.11SECTOR OF THE ECONOMY (AGRICULTURE)

3.11.1AFFECTED ENVIRONMENT

Kalo was ranked 20th in Hawai‘i agricultural commodities in 2014 ($1.9 million) (NASS 2015). In 

the last four available Censuses of Agriculture (1997, 2002, 2007, and 2012), between 481 and 604 

acres of kalo were harvested in Hawaii, producing between 3.5 and 6.5 million pounds of kalo 

(NASS 2017a). Of this, Kaua‘i County accounted for 32 to 56 percent of the state’s kalo acreage and 

produced between 43 and 75 percent of the state’s total production (NASS 2017a). On Kaua‘i there 

are 459 acres of farmland in wetland kalo production with about 65% (299 acres) of the acreage off 

the Refuge and 35% (160 acres) in the Refuge. Kalo production on the Refuge is estimated at 

2,235,496 pounds per year or 13,799 pounds per acre farmed (DJL Economic Consulting 2019). 

From 2000 to 2015, kalo production in Hawai‘i decreased from 7 million pounds to 3.5 million 

pounds, and average yields per acre fell from about 15,000 pounds per acre to 10,300 pounds per 

acre. Although production has declined, price received has increased 130 percent from 29¢ per pound 

in 2000 to 68¢ per pound in 2015 (NASS 2017b, 2018). Overall, kalo production on Hanalei NWR 

represented about 1.5 percent of Kaua‘i County’s total agricultural market value and utilized 0.1 

percent of Kaua‘i County’s agricultural land (NASS 2012).
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Section 3. Affected Environment and Environmental Consequences 45

Total revenues from sales of kalo grown on the Refuge are estimated at $1,437,230 or $8,983 per 

acre2

. The cost of producing kalo in the Refuge, including growing, harvesting, and farm 

management, are $951,848 or $5,949 per acre. The cost of growing kalo includes land preparation, 

planting, fertilization, pest control, and irrigation. Harvesting costs include labor, shipping, transport, 

and fuel, as well as maintaining equipment. Farm management costs include office labor, capital 

resource costs, and land resource costs. Net revenue from farming on the Refuge is $485,382 per year 

or $3,034 per acre (DJL Economic Consulting 2019). 

3.11.2EFFECTS OF ALTERNATIVE A (NO-ACTION)

Under Alternative A, the Service and kalo permittees living and working in the Refuge would 

continue current wetland management and kalo farming practices. The total acreage of wetland 

habitat (lo‘i kalo and managed wetlands) would remain the same as present. Both costs to produce 

kalo, and income from kalo production, would remain the same as present. As a result, the total 

economic benefit is expected to be between $1,500,000 and $2,000,000, with the net economic 

benefit between $500,000 and $1,000,000. 

However, under both alternatives, permits would no longer be allocated based on prior historic use, 

but rather would be allocated based on references, compliance (if already farming on the Refuge), a 

proven track record of experience and capacity (e.g., equipment) for farming in sustainable and 

wildlife-compatible ways, and willingness and ability to work with the Refuge on recovery and 

ongoing management priorities necessary to continue to meet the establishment purpose of the 

Refuge for recovery of federally listed species. Both existing kalo permittees and new CAA permit 

applicants would be required to apply through the competitive application process. The new policy 

would allow for permits with terms of up to five years, subject to regular compliance review. The 

updated CAA policy would allow for farming permits lasting up to five years, which could improve 

the ability of future kalo permittees to obtain business loans, an economic benefit under both 

alternatives. The intent of the CAA is to establish a fair and rational cost-sharing program for use by 

the Service and permittees in the future; however, the details of this program are not determined at 

this time and will be developed prior to the application process.

3.11.3EFFECTS OF ALTERNATIVE B (PROPOSED ACTION)

Implementation of Alternative B would have slightly greater economic impacts on kalo permittees 

than under Alternative A due to the additional farming stipulations and management services 

required to ensure compatibility of farming in the Refuge to allow its continuation. For example, 

instead of the 3-foot radius buffer surrounding bird nests in lo‘i kalo mandated under Alternative A, 

Alternative B would require a minimum 6-foot radius nest buffer. While this increased buffer would 

provide greater protection to threatened and endangered waterbirds, it would also result in slightly 

lower kalo production in lo`i where nests occur. There may be additional costs to farmers associated 

with developing and implementing fertilizer and herbicide management plans, and implementing 

avian botulism BMPs, which may include draining, harvesting, and dry fallowing lo‘i for more than 

30 days. However, these potential additional costs are difficult to quantify because the details of the

proposed additional requirements under Alternative B remain under consideration. Therefore, total 

2 We computed total revenues per farm based on reported sales and reported sales price for each farmer then summed across all 

farmer to obtain total revenue for the entire refuge. Average sales price = total revenue ÷ total pounds.
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

46 Section 3. Affected Environment and Environmental Consequences

annual costs to kalo permittees for the production of kalo (i.e., growing, harvesting, and managing) 

under Alternative B would be slightly greater than the $951,848 total annual costs under Alternative 

A. 

However, economic benefits to kalo permittees would remain similar to existing conditions due to 

additional benefits to the farmers under implementation of Alternative B. Kalo permittees would 

receive a similar net revenue from kalo sales, pay below market lease rents for farmland, and existing 

farmers and their immediate families would have access to their pre-existing housing in the Refuge

under the CAAs. Additional drainage maintenance proposed under Alternative B would reduce 

flooding impacts to lo‘i kalo in the Refuge and avian botulism and could also help further mitigate 

any potential property damage resulting in economic losses. Losses in production may be offset by 

lower cost of production over time (e.g. lower chemical inputs), or potentially higher prices for 

“wildlife friendly” or sustainable kalo. Further, the Service would incentivize additional management 

activities that would protect threatened and endangered waterbird species, such as establishing a wet 

fallow period of at least 60 days followed by a 2- to 6-month dry fallow period after tilling organic 

matter into the soil, as compared to the 30-day wet fallow period in lo`i kalo mandated by existing 

CAA permits. Similar to Service staffing, the economic benefit for kalo permittees living and 

working in the Refuge is expected to be similar to benefits under Alternative A, but some changes in 

costs and benefits would be expected due to factors beyond the Service’s control (changes in market 

prices and supply costs). As a result, the total economic benefit is expected to be in a similar range to 

Alternative A (between $1,500,000 and $2,000,000, with the net economic benefit between $500,000 

and $1,000,000). 

3.12ENVIRONMENTAL JUSTICE

3.12.1AFFECTED ENVIRONMENT

Executive Order (EO) 12898, Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations, requires all federal agencies to incorporate environmental 

justice into their missions by identifying and addressing disproportionately high or adverse human 

health or environmental effects of their programs and policies on minorities and low-income 

populations and communities. 

The Refuge is located within Census Tracts 401.03 (Princeville-Kīlauea) and 401.04 (Ha‘enaHanalei) in Kaua‘i County, Hawai`i. The percentage of population below the poverty level in this 

area (11.3±3.3% and 21.3±8.4%, respectively) is higher than the percentage below poverty level for 

Kaua‘i County (9.1±1.0%) as well as within the State of Hawai‘i (10.3±0.3%). By comparison, the 

percentage of population below the poverty level within the U.S. is 14.6±0.1 percent (U.S. Census 

Bureau 2019b). Within the census tracts that encompasses the Refuge, 76.4 percent of the population 

is reported to be primarily Caucasian or Caucasian in combination with one or more other races. 

Approximately 15.1 percent of the population is reported to be primarily Asian or Asian in 

combination with other races and 5.1 percent of the population is Native Hawaiian or Pacific Islander 

(U.S. Census Bureau 2019c). 

3.12.2EFFECTS OF ALTERNATIVES

The Service has identified a low-income community, specifically within Census Tract 401.04. 

However, the Service has not identified any potential high and adverse environmental or human 
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Section 3. Affected Environment and Environmental Consequences 47

health impacts from any of the alternatives. Conversely, the proposed action would be likely to 

improve water quality, including reducing coliform bacteria or other pathogens that would affect 

human health.

3.13 CUMULATIVE IMPACT ANALYSIS

Cumulative impacts are defined as “the impact on the environment which results from the 

incremental impact of the action when added to other past, present, and reasonably foreseeable future 

actions regardless of what agency (federal or non-federal) or person undertakes such other actions” 

(40 CFR 1508.7). We expect agricultural land use in the project area to remain similar to current 

levels in the foreseeable future; therefore, cumulative impacts to land use will not be considered 

further.

3.13.1OTHER PAST, PRESENT, AND REASONABLY FORESEEABLE ACTIVITY 

IMPACTING AFFECTED ENVIRONMENT

DEVELOPMENT AND POPULATION INCREASE

Summary

In 2010, the U.S. Census Bureau estimated the total population of Kaua‘i to be 71,093 residents, or 

roughly five percent of Hawai‘i’s total population (U.S. Census Bureau 2019a). Kaua‘i’s population 

grew by 14.8 percent from 2000 to 2010, outpacing the 12.3 percent growth rate for the state as a 

whole. Over the same period, the island’s population density increased from 104 persons per square

mile to 119 persons per square mile; meanwhile, the State of Hawai‘i’s population density increased 

from 189 to 212 persons per square mile (U.S. Census Bureau 2000, 2011). The Hawai‘i Department 

of Business, Economic Development, and Tourism (HDBEDT) predicts that the population of Kaua‘i 

will continue to grow at an annual rate close to one percent through 2040, resulting in an estimated 

2040 population of 93,000 (HDBEDT 2012). 

Anticipated Cumulative Impacts

Non-native invasive species and water quantity and quality are the factors that are most likely to 

affect threatened and endangered waterbirds. Population growth will continue to place stress upon 

Hawaiian ecosystems, both through direct loss of remaining habitats and indirectly through 

fragmentation and degradation of wildlife habitat and demands on water. Management can do 

nothing to stem the trend of continuing loss and degradation of wetland habitat outside the Refuge to 

development over time, but Hanalei NWR and other tracts of habitats will become even more 

important as repositories of biodiversity and to maintaining populations of native waterbirds.

CLIMATE CHANGE

Summary

The following is summarized from the 4th National Assessment (Keener et al. 2008): 

In Hawai‘i, temperature has risen by 0.76 degrees F over the past century (and 2019 was the warmest 

year on record). Rainfall has decreased, but the frequency of severe weather events has increased.

While rainfall in Hawai‘i generally has been decreasing, it is also becoming more extreme. Both 

extreme heavy rainfall events (causing increased runoff, erosion, and flooding) and droughts (causing 
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48 Section 3. Affected Environment and Environmental Consequences

water shortages) have become more common. The number of consecutive wet days and the number 

of consecutive dry days are both increasing in Hawaiʻi. However, rain intensity (the type of rainfall 

that contributes to stream overflow and flooding and is not beneficial for aquifer replenishment) has 

increased by approximately 12 percent from 1958 to 2007 (Fletcher 2010). 

Most climate projections suggest that more intense wind speeds and precipitation amounts will 

accompany more frequent tropical typhoons/cyclones and increased tropical sea surface temperatures 

in the next 50 years. The intensity of tropical cyclones is likely to increase by 10–20 percent in the 

Pacific region when atmospheric levels of CO2 reach double preindustrial levels (McCarthy et al. 

2001). One model projects a doubling of the frequency of rainfall events of four inches per day and a 

15–18 percent increase in rainfall intensity over large areas of the Pacific.

On Kaua‘i, based on monthly mean sea level data from 1955 to 2015, the mean sea level trend at 

Nāwiliwili is 0.056 inch per year with a 95 percent confidence interval of ±0.017 inch per year, 

which is equivalent to a change of approximately +0.46 foot in 100 years (NOAA 2017).

Anticipated Cumulative Impacts

Rising temperatures, decreasing average rainfall, and increasing rainfall extremes will place 

increasing pressure on the water resources throughout the Hawaiian Islands. However, in the 

foreseeable future (though approximately 2030), flows of the Hanalei River are expected to be 

adequate to maintain water diversions for Refuge wetlands. Measures to develop water budgets and 

use water more efficiently will allow the Refuge to maintain wetland habitat year-round in the 

foreseeable future.

Conditions which favor the development of avian botulism (e.g. higher water temperatures in the 

river and Refuge wetlands and lo‘i) will become more common. Improved water management and 

changes to ditch management under the proposed action would help to partially mitigate these 

effects. 

Increased extreme rainfall events would make flooding of Refuge lowlands and infrastructure more 

frequent and severe, resulting in cumulative rates of reproductive failure for threatened and 

endangered waterbirds and instability of recovery of populations. The proposed action would slightly 

mitigate these effects but continued increases in staff and financial resources would likely be 

required to maintain and rebuild wetland management infrastructure. Although wetland kalo farmers 

are experienced in working in a flood-prone environment, flooding associated with extreme rainfall 

events damages infrastructure, homes, and equipment. Additional drainage maintenance under the 

proposed action would reduce flooding impacts to lo‘i kalo in the Refuge; however, the trend of 

increasing impacts would be likely to continue.

Because it is a few miles upstream from Hanalei Bay and protected by levees, Hanalei NWR is not 

likely to see changes in the location of its shoreline from sea level rise (SLR). However, SLR may 

impact the groundwater table and increase its salinity (saltwater intrusion) (Sustainable Resources 

Group International Inc. 2012). Also, if groundwater tables rise with sea level, flooding could be 

exacerbated, particularly during high tides that resist the flow of the river. Refuge wetlands may 

provide a source of groundwater recharge that could partially mitigate this effect. 

Overall, the proposed action will help to mitigate the effects of climate change on threatened and 

endangered waterbirds and other native wildlife.
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

Section 3. Affected Environment and Environmental Consequences 49

3.14 MONITORING

An Inventory and Monitoring Plan is being developed via a separate but related planning process to 

further describe survey activities and priorities. See Section 2.1 for a description of the role of 

adaptive management and inventory, monitoring, and research within the context of the dWMWCP. 

The following list of monitoring activities would be conducted to facilitate adaptive management by 

documenting wildlife and habitat response to management actions, and to ensure that the proposed 

action would have acceptable levels of effects on the environment. This list is not all inclusive:

• Avian botulism disease monitoring

• Nutrient and sediment analysis in lo‘i kalo and rotational managed wetland units

• Water quality, water flow, and water level monitoring

• Waterbird reproductive success

• Waterbird distribution and index of abundance

• Quarterly Management Unit Assessments (QMUA)

• Invasive plant species presence, distribution, and abundance

• Mammalian predator relative abundance and control efficacy

• Barn owl detection and control efficacy

• Compliance monitoring

3.15 SUMMARY OF ANALYSIS

The purpose of this EA is to briefly provide sufficient evidence and analysis for determining whether 

to prepare an Environmental Impact Statement (EIS) or a FONSI. 

3.15.1ALTERNATIVE A – NO-ACTION ALTERNATIVE

This alternative meets the purpose and need of the Service as described above, because it would meet 

life history needs of threatened and endangered waterbirds and promote their recovery. However, 

compared to Alternative B, this alternative would provide fewer acres of wetland habitat that meets 

all life history needs of threatened and endangered waterbirds. Lo‘i kalo would continue to provide 

for the some life history needs of threatened and endangered waterbirds, but to a lesser degree 

compared with Alternative B. Current management practices, including possible continued noncompliance with 30-day wet fallow requirement and intensive removal of non-kalo emergent plants 

used as food, cover, and nesting material by threatened and endangered waterbirds. This would result 

in less vegetative cover for nests and young and less available food resources (both non-kalo plants 

and invertebrates) compared to Alternative B. Factors involved in failure (e.g., depredation) of 

Hawaiian waterbird nests are complex; however, the nest buffer size of three-feet is inadequate and

depredation rates of nests are likely to remain similar to current levels and be higher than under 

Alternative B. Water quality, and therefore the frequency and severity of avian botulism outbreaks, is 

expected to remain the same as present. Without additional resources to properly administer the 

Refuge farming permit program, there would likely to be some continued compliance issues (e.g.,

permittees not keeping dogs contained near residence, storage of refuse and abandoned vehicles on 

site, incomplete reporting of fertilizer, pesticide use, or discovered threatened and endangered bird 

nests).

Effects to Refuge wetlands and associated species would be expected to be negligible to minor 

positive. Existing water quality issues (e.g. sedimentation and nutrient enrichment of receiving 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

50 Section 3. Affected Environment and Environmental Consequences

waters) would be expected to continue, similar to current levels. Effects to opportunities for wildlifedependent recreation would be negligible. 

Implementation of Alternative A would have a negligible change to economic impacts on kalo 

permittees, since the requirements for farming on the Refuge and the associated economic impacts of 

those requirements would remain similar to the current condition. Economic benefits to kalo 

permittees would remain similar to existing conditions. Refuge staffing would increase over current 

levels. Overall, the proposed action would be beneficial to Kauai’s economy, but the effect would be 

negligible because Refuge staffing, purchases, and economic output (from kalo farming) represent a 

tiny fraction of the total jobs and economic output.

3.15.2ALTERNATIVE B – PROPOSED ACTION ALTERNATIVE

This alternative helps meet the purpose of the Refuge and mission of the Service as described above, 

because it would meet life history needs of threatened and endangered waterbirds and promote their 

recovery. The Service has determined that the proposed action is compatible with the purposes of the 

Hanalei NWR and the mission of the NWRS. The Compatibility Determinations for cooperative kalo 

farming and grazing are included in the dWMWCP (Appendix B). Compared to Alternative A, 

Alternative B would better meet life history needs of threatened and endangered waterbirds and 

promote their recovery, for the following reasons:

1. Due to restoration of 3–18 acres, more habitat is proposed to be in rotational managed 

wetlands, which provide for all life history needs of waterbirds. Minimal water level 

fluctuations would occur in these wetlands during peak nesting periods, thereby minimizing 

nest losses.

2. A transparent decision-making framework would be used to assign wetlands for rotational 

management, lo‘i kalo, or other habitat, thereby maximizing utilization of available habitat, 

and increasing efficient use of water resources.

3. Lo‘i would have enhanced vegetation structure and composition, resulting in increased 

availability of nesting and foraging habitat. An increase in water availability, combined with 

improved vegetation cover (larger nest buffers and allowing non-kalo plants in lo‘i), and 

decrease in water level manipulation during nesting and incubation would reduce nest 

depredation and disturbance. 

4. Water level control (ability to drawdown and inundate wetlands manually) through the use of 

water control structures helps to quickly respond to avian botulism outbreaks by maintaining 

circulation and the ability to change hydrological conditions to arrest disease cycles. 

Improved water quality (e.g., cooler water temperatures, higher oxygen levels) reduce the 

potential for and severity of botulism outbreaks. Alternative B is preferred for its beneficial 

effects and this long-term, beneficial effect would be intermediate. There would be reduced 

pesticide and fertilizer use in Alternative B compared to Alternative A, with consequent 

improvement in water quality. This, combined with implementation of avian botulism 

protocol BMPs in the short to medium term, would be likely to reduce the frequency and 

severity of avian botulism outbreaks compared to Alternative A. Reducing threatened and 

endangered waterbird mortality from botulism would further add to recovery of these 

imperiled species.

5. Under Alternative B, strategies to incentivize cooperative wildlife-friendly farming would be 

implemented. There would be reduced nest losses from water level fluctuations and improved 

quality of both foraging and brood-rearing habitat. These improvements include increased 

availability of non-kalo plants for both food and cover and increased invertebrate production. 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

Section 3. Affected Environment and Environmental Consequences 51

Increased body condition, reproductive fitness, and brood survival would be expected

compared to the Alternative A.

6. For Alternative B, there would be reduced depredation of threatened and endangered

waterbirds, young, and nests by feral cats and other pest vertebrates due to changes in water 

and vegetation management and improved coordination with permittees. Improved 

compliance with SUP terms would result in reduced disturbance of waterbirds by dogs, with 

a consequent reduction of nest abandonment and increased reproductive success. Research 

into the effectiveness of nest buffer size, in addition to better understanding of factors related 

to nest/fledging success would be initiated, which may improve nest and fledging success in 

the long term. 

Reduced pesticide and fertilizer use under Alternative B, as a result of implementing fertilizer and 

herbicide management plans, and increased compliance with permit terms would result in lower 

inputs of sediments, nutrients, fecal bacteria (e.g., humans, ungulates), and other contaminants into 

receiving waters, with minor, positive effects to water quality in the lower reach of the Hanalei River. 

Development and implementation of a water quality and flow monitoring program and working with 

partners to implement a community-based watershed management and aquatic resources 

management plan would ensure that water quality issues are promptly identified and addressed.

Implementation of Alternative B would have slightly greater economic impacts on kalo permittees 

than under Alternative A due to the additional farming stipulations and management services 

required to ensure compatibility of farming in the Refuge to allow its continuation. Total annual costs 

to kalo permittees for the production of kalo (i.e., growing, harvesting, and managing) under 

Alternative B would be slightly greater than the total annual costs to kalo permittees under 

Alternative A. However, economic benefits to kalo permittees would remain similar to existing 

conditions due to additional benefits to the farmers under implementation of Alternative B. Overall, 

the proposed action would be beneficial to Kauai’s economy, but the effect would be negligible 

because Refuge staffing, purchases, and economic output (from kalo farming) represent a tiny 

fraction of the total jobs and economic output.

LIST OF PREPARERS

• Ken Morris, Conservation Planner, Branch of Visitor Services and Planning, U.S. Fish and 

Wildlife Service, DOI Regions 9 and 12

• Khemarith So, Inventory and Monitoring Data Manager, Branch of Refuge Biology, U.S. 

Fish and Wildlife Service, DOI Regions 9 and 12
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

52 References

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Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

Appendix A. Consultation, Coordination, and Public Outreach 57

APPENDIX A. CONSULTATION, COORDINATION, AND PUBLIC 

OUTREACH

The Refuge’s Comprehensive Conservation Plan (CCP), which is currently being developed, will 

cover all aspects of Refuge management, including those outside of the scope of the WMWCP such 

as forest management, visitor services, cultural and historic resources, facilities, and law 

enforcement. Habitat management goals, objectives, and strategies described in the WMWCP will be 

revised as appropriate and incorporated into the CCP. Per 43 CFR 46.305, public scoping is not 

required for EAs. However, since the planning processes for the WMWCP and CCP overlap, some 

issues and priorities raised during public scoping for the CCP have been considered in development 

of the WMWCP. This section describes the cumulative public outreach efforts relevant to wetlands 

management and waterbird conservation planning at Hanalei NWR. 

Public scoping for the CCP process for the KNWRC, which includes three national wildlife 

refuges—Hanalei, Hulē‘ia, and Kīlauea Point—began in the fall of 2009 with a notice in the Federal 

Register (74 FR 49399). Public meetings and talk story sessions were held in Hanalei, Hulē‘ia, 

Kīlauea, and Līhu‘e from October 2009–January 2010. In all, over 80 people participated. Public 

input was also solicited through planning updates distributed to our mailing list. Additionally, 

workshops/meetings with local, state, federal agencies, community groups, Refuge users, nonprofits, 

and others were held. This helped us to further identify issues and priorities to consider during plan 

development. Following is a brief summary of public involvement for CCP-related efforts for the 

KNWRC:

• September 28, 2009 – Federal Register Notice announcing a notice of intent to prepare the 

draft CCP/EA and public open house meetings;

• October 8, 2009 – Talk story session at Hanalei;

• November 4, 2009 – Talk story session at Kīlauea; 

• January 2010 – Planning Update 1 announcing the official start of public scoping with public 

open house meetings, summarizing talk story sessions already held, and previewing 

preliminary issues and goals for CCP consideration; 

• January 12, 2010 – Talk story session at Hulē‘ia; 

• January 22, 2010 – News release to announce public open house meetings;

• January 26, 2010 – Public open house at Līhu‘e Public Library; 

• January 28, 2010 – Public open house at Kīlauea Elementary School cafeteria;

• February 2011 – Planning Update 2 summarized the public scoping efforts and outlined the 

next steps in CCP development;

• 2010–2011 – Refuge staff also held specific meetings to provide updates and discuss 

management considerations with partners and interested parties (e.g., Division of Forestry 

and Wildlife, kalo farmers, Kīlauea Point Natural History Association (KPNHA), National 

Oceanic and Atmospheric Administration (NOAA), Hanalei Watershed Hui, elected 

officials); 

• January 2013 – Refuge staff met with Refuge kalo farmers to discuss the draft CD for kalo 

farming on the Refuge, and new permit requirements; and

• 2016 – Refuge staff met with the DOI’s Office of Native Hawaiian Relations to discuss the 

use of kalo farming on the Refuge and the draft CCP.
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan 

58 Appendix A. Consultation, Coordination, and Public Outreach

Distribution and notification of the opportunities above was accomplished using multiple methods, 

including news releases; a mail/email list of over 500 people, including interested individuals, 

kūpuna, local conservation and interest groups, research organizations, Native Hawaiian 

organizations, and local, state, and federal government agencies and elected officials; community and 

association events/meetings; and CCP-specific websites.

In 2015, due to staff and funding resource limitations, planning for the Hanalei and Hulē‘ia NWR

CCP was put on hold in order to complete the Kīlauea Point NWR CCP. Upon finalization of the 

Kīlauea Point NWR CCP in July 2016, planning for the other two refuges in the Complex (Hanalei 

and Hulē‘ia NWRs) resumed. In August 2017, the Service finalized the revised Cooperative 

Agricultural Use policy, which outlines objectives for the use of cooperative agriculture on Refuge 

System lands and provides an open, transparent, and competitive process for awarding CAAs on 

refuges in compliance with the DOI policy on procurement contracts, grant and cooperative 

agreements (505 Department Manual [DM] 2). In order to comply with this revised policy, the 

WMWCP process was initiated. Following is a brief summary of public involvement for WMWCPrelated efforts for Hanalei NWR:

• 2017 – Refuge staff, interns and/or volunteers met with Refuge kalo farmers to discuss and 

gather information about the relationships between kalo farming practices and avian 

botulism;

• 2018 – Refuge staff met with Refuge kalo farmers to discuss and gather information on the 

economic costs and benefits of kalo farming on the Refuge; and 

• Annual – Special use permit meetings with all Refuge kalo farmers to discuss current permit 

requirements, compliance, and other issues and draft proposed changes to Refuge kalo 

farming program.

WMWCP goals, objectives, strategies, and alternatives were shaped by the issues identified and 

feedback received during public involvement. The following table summarizes the comments 

received during public involvement and identifies where and/or how it was addressed in the draft 

WMWCP and EA.

SUMMARY OF SCOPING COMMENTS

Issue Where/How Addressed in Draft WMWCP and EA 

Elevate species recovery (especially for koloa 

maoli) as a higher priority within KNWRC 

(includes imbalance of staff and funding for 

wetland habitat management and enhancement).

Koloa maoli focus can be found in Goal 1. 

Focus additional effort on water security and 

quality for wetland Refuges. 

This issue is addressed in Goal 2. 

Protection of culturally significant farming in 

the Hanalei Valley and the role of the valley in 

providing food security for Kaua‘i. 

The significance of farming in the valley is 

discussed under Goal 1. 

Recognition of symbiotic relationship between 

farmers and birds. 

The Service recognizes that kalo farming does 

provide habitat for wetland birds, which is 

addressed in in Chapter 4, under Goal 1 and 

Appendix B (CD on kalo farming).

Recognition of Hanalei River as an American 

Heritage River and conservation of the river’s 

All points can be found under Goal 2. 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan 

Appendix A. Consultation, Coordination, and Public Outreach 59 

Issue Where/How Addressed in Draft WMWCP and EA

water quality, instream flow, and water 

quantity; a water budget for the Refuge and 

farming operations and riverine resources.

Identification of partnership opportunities to Partnering is a critical component of achieving 

meet species and habitat goals for endangered Refuge goals (as stated in the first part of Chapter 

species both on the Refuge and other areas 4). Specific partnering opportunities can be found 

throughout the island. in Goals 1 and 2.

Concern that impoundments have changed Hydrology discussion can be found in Chapter 2.

hydrology of the river and worsened effects of 

flooding.

‘O‘opu habitat protection study needed. Will be considered through in-progress related 

Inventory and Monitoring Plan and future planning 

efforts to address water management control 

structures. 

More emphasis on managing the Hanalei River Identified under Goals 1 and 2.

for biological values and reducing invasive 

species populations (e.g., hau bush, mangroves).

Historic intent of the Refuge creation and Refuge establishment and purpose can be found in 

clarifying what records say about kalo farming Chapter 1. Specific information on kalo farming 

and what part kalo farming would play in the and its future can be found in Chapter 4, under 

future of the Refuge. Goal 1 in the rationale sections as well as in 

Appendix B (CD on kalo farming).

Improve the Refuge’s coordination with the See above. Continued coordination with kalo 

kalo farmers. The plan should articulate the past farmers are specifically identified as strategies

and current role of kalo farming at the Refuge, under Goal 1. 

from both a cultural and biological perspective.

Concern about kalo mutation/genetically Control of lands outside of Refuge boundaries is 

modified organism hybridization from adjacent not in the jurisdiction of the Service. However, the 

lands. issue of kalo mutation/genetically modified 

organisms on the Refuge is addressed as part of the 

CD addressing kalo farming (Appendix B).

Potential use of cattle as a wetland management Strategy identified under Goal 1.

tool (is it effective for waterbird habitat 

improvement?).
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

60 Appendix B. Other Applicable Statutes, Executive Orders, and Regulations

APPENDIX B: OTHER APPLICABLE STATUTES, EXECUTIVE

ORDERS, AND REGULATIONS

Resource Area and Statutes Relevance Summary

Cultural Resources

American Indian Religious 

Freedom Act, as amended, 42 

USC 1996 – 1996a; 43 CFR Part 

7

Antiquities Act of 1906, 16 USC

431-433; 43 CFR Part 3

Archaeological Resources 

Protection Act of 1979, 16 USC

470aa – 470mm; 18 CFR Part 

1312; 32 CFR Part 229; 36 CFR 

Part 296; 43 CFR Part 7 

National Historic Preservation 

Act of 1966, as amended, 16 USC

470-470x-6; 36 CFR Parts 60, 63, 

78, 79, 800, 801, and 810

Paleontological Resources 

Protection Act, 16 USC 470aaa –

470aaa-11

Native American Graves 

Protection and Repatriation Act, 

25 USC 3001-3013; 43 CFR Part 

10

Executive Order 11593 –

Protection and Enhancement of 

the Cultural Environment, 36 Fed. 

Reg. 8921 (1971)

Executive Order 13007 – Indian 

Sacred Sites, 61 Fed. Reg. 26771 

(1996)

Section 106 of the National Historic Preservation Act 

(NHPA) requires federal agencies to take into account the 

effects of their undertakings on historic properties. This 

includes complying with the NHPA and other cultural 

resource preservation laws and consulting with the State 

Historic Preservation Division (SHPD) and appropriate 

Native Hawaiian organizations over management actions 

which may affect cultural resources. 

Pursuant to Section 106 of the NHPA and promulgated regulations, 

the Service has determined the proposed action constitutes an 

undertaking under the NHPA (36 CFR 800.3(a)) but would not 

adversely affect cultural resources/historic properties. When 

projects described in this EA are specifically identified for 

implementation, the FWS will carry out the NHPA Section 106 

process and take into account the potential effects of the project on 

historic properties. The proposed action would comply with the 

NHPA because the Service would follow established procedures for 

protecting archaeological and cultural resources if encountered 

during ground-disturbing activities. If a cultural resource were 

inadvertently discovered, activities in the area of the resource 

would be stopped and the SHPD would be contacted to determine 

how to proceed. The presence of human remains or graves in the 

project area (floodplain) is unlikely, but we would comply with 

Native American Graves Protection and Repatriation Act

(NAGPRA) if these are inadvertently discovered.

Implementing the proposed action would not hamper, impede, or 

otherwise limit the exercise of traditional, customary, or religious 

practices of Native Hawaiians in the immediate area, to the extent 

the practices are provided for by the Constitution of the State of 

Hawaii and by Hawaii statutory and case law.

Executive Order (EO) 11593 established the policy that the federal 

government provides leadership in preserving, restoring, and 

maintaining the historic and cultural environment of the United 

States. The Service would comply with EO 11593. 

The Refuge contains no known paleontological resources and is 

unlikely to contain such resources.

Fish & Wildlife

Endangered Species Act of 1973, 

as amended, 16 USC 1531-1544; 

The ESA directs all federal agencies to work to conserve 

endangered and threatened species and to use their authorities to 

further the purposes of the ESA. Section 7 of the ESA is the 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

Appendix B. Other Applicable Statutes, Executive Orders, and Regulations 61

Resource Area and Statutes Relevance Summary

36 CFR Part 13; 50 CFR Parts 10, 

17, 23, 81, 217, 222, 225, 402, 

and 450

Fish and Wildlife Act of 1956, 16 

USC 742 a-m

Lacey Act, as amended, 16 USC

3371 et seq.; 15 CFR Parts 10, 11, 

12, 14, 300, and 904 

Migratory Bird Treaty Act, as 

amended, 16 USC 703-712; 50 

CFR Parts 10, 12, 20, and 21

Executive Order 13186 –

Responsibilities of Federal 

Agencies to Protect Migratory 

Birds, 66 Fed. Reg. 3853 (2001)

mechanism by which federal agencies ensure their actions do not 

jeopardize the existence of any listed species. Under Section 7, 

federal agencies consult with the Service or the National Marine 

Fisheries Service when any action they carry out, fund, or 

authorize may affect a listed species. 

The Section 7 consultation associated with the WMWCP will be 

concluded after the EA public review and prior to the finalization of 

a NEPA decision document. This project would comply with the 

ESA because of the consultations performed and the incorporation 

of minimization measures.

Migratory bird conventions and the Migratory Bird Treaty Act 

(MBTA) impose substantive obligations on the United States for 

the conservation of migratory birds and their habitats. EO 13186 

directs executive departments and agencies to take certain actions 

to further implement the MBTA, including supporting the 

conservation intent of the migratory bird conventions, restoring and 

enhancing the habitat of migratory birds, as practicable, and 

preventing or abating detrimental alteration of the environment for 

the benefit of migratory birds, as practicable. The proposed action

is consistent with both the MBTA and EO 13186 because the 

proposed action would maintain and enhance habitat for migratory 

birds.

Natural Resources

Clean Air Act, as amended, 42 

USC 7401-7671q; 40 CFR Parts 

23, 50, 51, 52, 58, 60, 61, 82, and 

93; 48 CFR Part 23

Wilderness Act, 16 USC 1131 et 

seq.

Wild and Scenic Rivers Act, 16 

USC 1271 et seq.

Executive Order 13112 – Invasive 

Species, 64 Fed. Reg. 6183 

(1999)

The proposed action would have negligible effects to air quality. 

Any actions that have the potential to negatively affect air quality 

would be temporary and short-term, and BMPs would be used to 

minimize these effects.

The Refuge contains no areas suitable for wilderness designation.

An American Heritage river (the Hanalei River) runs through the 

Refuge. The river is not under the jurisdiction of the Service, and 

the Service has no control over navigation or recreation that occur 

on the river. Water is withdrawn from and returned to the Hanalei 

River to provide wetland habitat for threatened and endangered

waterbirds. The proposed action would conserve the river’s water 

quality, instream flow, and water quantity.

EO 13112 requires federal agencies to prevent the introduction of 

invasive species and provide for their control and minimize the 

economic, ecological, and human health impacts that invasive 

species cause. The proposed action would be consistent with this 

EO because non-native invasive plant and animal species would be 

removed as part of habitat management actions.

Water Resources

Coastal Zone Management Act of 

1972, 16 USC

1451 et seq.; 15 CFR Parts 923, 

930, 933

Hawaii Coastal Zone Management Program (1990) describes the 

state’s response to the Coastal Zone Management Act of 1972. The 

objectives of Hawaii’s Coastal Zone Management (CZM) program 

are to protect and manage Hawaii’s coastal resources. The Refuge 
Hanalei NWR Environmental Assessment for Wetlands Management and Waterbird Conservation Plan

62 Appendix B. Other Applicable Statutes, Executive Orders, and Regulations

Resource Area and Statutes Relevance Summary

Federal Water Pollution Control 

Act of 1972 (commonly referred 

to as Clean Water Act), 33 USC

1251 et seq.; 33 CFR Parts 320-

330; 40 CFR Parts 110, 112, 116, 

117, 230-232, 323, and 328 

Rivers and Harbors Act of 1899, 

as amended, 33 USC 401 et seq.; 

33 CFR Parts 114, 115, 116, 321, 

322, and 333

Safe Drinking Water Act of 1974, 

42 USC 300f et seq.; 40 CFR 

Parts 141-148

Executive Order 11988 – 

Floodplain Management, 42 Fed. 

Reg. 26951 (1977) 

Executive Order 11990 – 

Protection of Wetlands, 42 Fed. 

Reg. 26961 (1977)

lies within the state’s CZM area. The CZM Act notes that federal 

lands and lands subject solely to the discretion of the federal 

government are excluded from the state’s CZM area. A review of 

the project for CZM consistency will be conducted by the State of 

Hawai‘i Office of Planning, the state agency administering the 

state’s CZM program. 

The proposed action is consistent with state objectives for 

managing recreational resources, scenic and open space resources, 

and coastal ecosystems. The Refuge’s wetland 

habitats are not located in an area not subject to tsunamis or storm 

waves. Measures to minimize pollution or hazardous materials that 

could affect public health are in place. The 

Refuge would continue to provide wildlife-dependent recreation 

opportunities that are free to the public and would support 

native Hawaiian wildlife for the benefit of all Americans. 

The Hanalei River runs through the Refuge. The river is not under 

the jurisdiction of the Service, and the Service has no control over 

navigation or recreation that occur on the river. Water is withdrawn 

from and returned to the Hanalei River to provide wetland habitat 

for threatened and endangered waterbirds. The proposed action 

would not interfere with or impede navigation of the river, and 

would conserve the river’s water quality, instream flow, and water 

quantity. 

EO 11988 requires federal agencies to avoid to the extent possible 

long-and short-term adverse impacts associated with the occupancy 

and modification of floodplains and to avoid direct or indirect 

support of floodplain development wherever there is a practicable 

alternative. The wetland and riparian areas of the Refuge lie within 

the Hanalei River floodplain. The proposed action is consistent 

with EO 11988 because Alternative B (preferred) is not anticipated 

to result in adverse impacts to the floodplain, such as raising the 

elevation of the floodplain or constructing impervious surfaces that 

would affect drainage, as a result of these modifications. However, 

beneficial minor effects to the riparian zone and floodplain would 

occur. If adverse effects become anticipated to occur during the 

course of plan implementation, the planned strategy would be 

designed to avoid or have minimal adverse effects or be mitigated 

under EO 11988 and other applicable laws.

EO 11990 requires federal agencies to avoid to the extent possible 

long-and short-term adverse impacts associated with the destruction 

or modification of wetlands and to avoid direct or indirect support 

of new construction in wetlands wherever there is a practicable 

alternative. The National Wetlands Inventory map identifies the 

Hanalei Valley floor as a complex mix of palustrine and riverine 

wetlands. The proposed action would maintain and enhance these 

existing wetlands, and additional wetlands would be restored.

U.S. Department of the Interior

U.S. Fish & Wildlife Service

Kaua‘i National Wildlife Refuge Complex 

3500 Kı ̄lauea Road; P.O. Box 1128

Kı ̄lauea, HI 96754

Phone: 808/828 1413

Fax: 808/828 6634

http://www.fws.gov

National Wildlife Refuge System Information

1 800/344 WILD

August 2020

The mission of the U.S. Fish & Wildlife 

Service is working with others to conserve, protect, 

and enhance fish, wildlife, and plants and their habitats 

for the continuing benefit of the American people.

Cover: 

Hanalei National Wildlife Refuge. Photo: USFWS

‘Alae ke’oke’o (Hawaiian coot). Photo: Dan Clark/USFWS

Ae’o (Hawaiian stilt). Photo: Gary Kramer/USFWS