Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

FONSI-i 

FINDING OF NO SIGNIFICANT IMPACT 

Howland Island National Wildlife Refuge 

Comprehensive Conservation Plan

Unincorporated U.S. Territory, Central Pacific Ocean 

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

Plan (CCP) for Howland Island National Wildlife Refuge (Refuge). The CCP will guide 

management of the Refuge for the next 15 years. The CCP describes the Service’s preferred 

alternative for managing the Refuge and its effects on the human environment. 

Decision 

Following comprehensive review and analysis, the Service selected Alternative B in the 

Environmental Assessment (EA) for implementation because it is the alternative that best meets 

the following criteria: 

 Achieves the mission of the National Wildlife Refuge System. 

 Achieves the purposes of the Refuge. 

 Will be able to achieve the vision and goals for the Refuge. 

 Maintains and restores the ecological integrity of the habitats and plant and animal populations 

on the Refuge. 

 Addresses the important issues identified during the scoping process. 

 Addresses the legal mandates of the Service and the Refuge. 

 Is consistent with the scientific principles of sound wildlife management. 

 Can be implemented within the projected fiscal and logistical management constraints 

associated with the Refuge’s remote location. 

As described in detail in the CCP and EA, implementing the selected alternative will have no 

significant impacts on any of the natural or cultural resources identified in the CCP and EA. 

Public Review 

The planning process incorporated a variety of public involvement techniques in developing and 

reviewing the CCP. This included three planning updates, meetings with partners, and public 

review and comment on the draft planning documents. The details of the Service’s public 

involvement program are described in the CCP. 

Conclusions 

Based on review and evaluation of the information contained in the supporting references, I have 

determined that implementing Alternative B as the CCP for management of Howland Island 

National Wildlife Refuge is not a major Federal action that would significantly affect the quality 

of the human environment within the meaning of section 102(2)(C) of the National 

Environmental Policy Act of 1969. Accordingly, the Service is not required to prepare an 

environmental impact statement. 

Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

ToC-i

Table of Contents 

CHAPTER 1: INTRODUCTION

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

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

National Wildlife Refuge System ................................................................................................1-1 

National Wildlife Refuges in the Pacific ..................................................................................... 1-4 

Refuge Establishment, Purpose and Boundary............................................................................ 1-6 

Regional and Ecosystem Conservation Plans..............................................................................1-9

Refuge Vision Statement ...........................................................................................................1-10

Refuge Goals..............................................................................................................................1-11

CHAPTER 2: PLANNING PURPOSE, NEED, AND ISSUES 

Planning Process ..........................................................................................................................2-1 

Purpose and Need ........................................................................................................................2-1 

Planning Issues and Opportunities............................................................................................... 2-2 

CHAPTER 3: MANAGEMENT DIRECTION 

Overview......................................................................................................................................3-1 

Goals, Objectives, Strategies, and Rationale ............................................................................... 3-4 

CHAPTER 4: REFUGE AND RESOURCE DESCRIPTION 

Geographic/Ecosystem Setting .................................................................................................... 4-1 

Climate......................................................................................................................................... 4-1 

Global Climate Change................................................................................................................4-2 

Geology and Soils........................................................................................................................4-7 

Hydrology ....................................................................................................................................4-9 

Air and Water Quality..................................................................................................................4-9 

Environmental Contaminants.......................................................................................................4-9 

Terrestrial Vegetation and Habitats ............................................................................................. 4-9 

Terrestrial Wildlife.....................................................................................................................4-10 

Marine Habitats, Fish and Wildlife............................................................................................ 4-12 

Threatened and Endangered Species ......................................................................................... 4-16 

Invasive Species ........................................................................................................................4-17 

Wilderness Resources ................................................................................................................4-17 

Archaeology and Paleontology.................................................................................................. 4-17 

Recent Cultural History .............................................................................................................4-18 

Socio-economics........................................................................................................................4-21 

 

 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

ToC-ii 

APPENDICES 

Appendix A. Glossary of Terms and Acronyms 

Appendix B. Species Lists 

Appendix C. References 

Appendix D. Planning Team Members 

Appendix E. Quarantine Protocol 

Appendix F. Wilderness Review 

Appendix G. Statement of Compliance 

Appendix H. Plan Implementation and Costs 

Appendix I. Consultation and Coordination 

Appendix J. Responses to Comments 

LIST OF FIGURES 

Figure 1.1 National Wildlife Refuges in the Pacific................................................1-5 

Figure 1.2 Howland Island National Wildlife Refuge: Geographic Location and Boundary..1-8 

 

 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 1 - Introduction 1-1 

Chapter 1: INTRODUCTION

 

Introduction 

This document is a Comprehensive Conservation Plan (CCP) for Howland Island National 

Wildlife Refuge (Howland). It will guide management of refuge operations, site visitation, and 

habitat restoration for 15 years. Guidance within the CCP is in the form of goals, objectives, 

strategies (Chapter 3), and wilderness study findings (Appendix F). The CCP was revised as 

appropriate based upon public comments. The refuge manager of the Pacific Remote Islands 

National Wildlife Refuge Complex (Remotes Complex) in Honolulu, Hawaii, is responsible for 

implementing the CCP. 

The U.S. Fish and Wildlife Service 

Howland is managed by the Fish and Wildlife Service (Service), within the U.S. Department of 

the Interior. The Service is the primary Federal entity responsible for conserving and enhancing 

the Nation’s fish and wildlife populations and their habitats. Although the Service shares this 

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

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

anadromous fish, certain marine mammals, coral reef ecosystems, wetlands, and other special 

aquatic habitats. The Service also has similar trust responsibilities for the lands and waters it 

administers to support the conservation and enhancement of all fish and wildlife and their 

associated habitats. 

National Wildlife Refuge System 

President Theodore Roosevelt established Pelican Island, Florida as the first national wildlife 

refuge in 1903. Since that time, the number of refuges has expanded to include 548, totaling 

approximately100 million acres. These refuges, found in every state and several U.S. Territories, 

are administered collectively as a national system of lands with the specific mandate of 

managing for “wildlife first.” This System is the largest collection of lands specifically managed 

for fish and wildlife conservation in the Nation and perhaps the world. The “wildlife first” 

mandate of the System means the needs of wildlife and their habitats take priority on refuges, in 

contrast to other public lands that are managed for multiple uses. The following is a description 

of some of the most relevant acts and policies that guide the management of the System. 

National Wildlife Refuge System Administration Act of 1966, as amended 

The NWRS Administration Act defines a unifying mission for all refuges, including a process 

for determining compatible uses on refuges, and requiring that each refuge be managed 

according to a CCP. The NWRS Administration Act expressly states that wildlife conservation 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

1-2 Chapter 1 – Introduction 

is the priority of System lands and that the Secretary shall ensure that the biological integrity, 

diversity, and environmental health of refuge lands are maintained. Each refuge must be 

managed to fulfill the specific purposes for which the refuge was established and the System 

mission. The first priority of each refuge is to conserve, manage, and if needed, restore fish and 

wildlife populations and habitats according to its purpose. The Service has statutory authority 

under the NWRS Administration Act to regulate activities that occur on water bodies “within” a 

refuge. The NWRS Administration Act requires a CCP be completed for each refuge and that 

the public has an opportunity for active involvement in plan development and revision. It is 

Service policy that each CCP is developed in an open public process. 

National Wildlife Refuge System Mission and Goals and Purposes (601 FW1) 

In July 2006, the Service issued a policy (601 FW 1) which included the NWRS mission 

statement and NWRS goals, and described how refuge purposes are determined. 

 

The NWRS Administration Act established the following statutory mission for the System: 

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

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

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

and future generations of Americans.” 

The administration, management, and growth of the System are guided by the following goals 

(601 FW 1, July 2006)....” 

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

are endangered or threatened with becoming endangered. 

• Develop and maintain a network of habitats for migratory birds, anadromous and 

interjurisdictional fish, and marine mammal populations that are strategically distributed 

and carefully managed to meet important life history needs of these species across their 

ranges. 

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

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

underrepresented in existing protection efforts. 

• Provide and enhance opportunities to participate in compatible wildlife-dependent 

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

education and interpretation). 

• Foster understanding and instill appreciation of the diversity and interconnectedness of 

fish, wildlife, plants, and their habitats. 

Lastly, the NWRS Administration Act describes refuge purposes, and how these guiding 

principals for the refuge are located and documented. 

Appropriate Refuge Uses (603 FW1)

This policy (603 FW 1), published in July 2006, provides a national framework for determining 

appropriate refuge uses. Serving as a “prescreening” for proposed uses of a refuge prior to a 

compatibility determination (see below); this policy requires—for most uses—a written finding 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 1 - Introduction 1-3 

of appropriateness by the refuge manager based on 11 criteria. Findings of appropriateness 

require State concurrence for refuges located within State boundaries. These criteria include: 

• Promotes safety of participants, other visitors, and facilities. 

• Promotes compliance with applicable laws, regulations, and responsible behavior. 

• Minimizes or eliminates conflicts with fish and wildlife populations or habitat goals or 

objectives in a plan approved after 1997. 

• Minimizes or eliminates conflicts with other compatible wildlife-dependent recreation. 

• Minimizes conflicts with neighboring landowners. 

• Promotes accessibility and availability to a broad spectrum of the American people. 

• Promotes resource stewardship and conservation. 

• Promotes public understanding and increases public appreciation of America’s natural 

resources and our role in managing and protecting these resources. 

• Provides reliable/reasonable opportunities to experience wildlife. 

• Uses facilities that are accessible and blend into the natural setting. 

• Uses visitor satisfaction to help define and evaluate programs. 

Compatibility (603 FW2) 

Lands within the System are different from other multiple-use public lands, in that, with few 

exceptions, they are closed to all public access and use unless specifically and legally opened 

(603 FW 2). No refuge use may be allowed unless it is determined to be compatible. A 

compatible use is one that, in the sound professional judgment of the refuge manager, would not 

materially interfere with or detract from the fulfillment of the mission of the Service or the 

purpose of the refuge. The NWRS Administration Act identifies six wildlife-dependent 

recreational uses: hunting, fishing, wildlife observation, photography, environmental education, 

and interpretation. When compatible, these six uses become priority uses of the System. As 

priority public uses, they receive special consideration over other general public uses in refuge 

planning and management. 

Biological Integrity, Diversity, and Environmental Health (601 FW3) 

The NWRS Administration Act directs the Service to “ensure that the biological integrity, 

diversity and environmental health of the System are maintained for the benefit of present and 

future generations of Americans...” This policy (601 FW 3) is an additional directive for refuge 

managers to follow while achieving refuge purpose(s) and System mission. It provides for the 

consideration and protection of the broad spectrum of fish, wildlife, plants, and their habitat 

resources found on refuges and associated ecosystems. When evaluating the appropriate 

management direction for refuges, refuge managers would use sound professional judgment to 

determine their refuges’ contribution to maintenance and, where possible, restoration of 

biological integrity, diversity, and environmental health (BIDEH) at multiple landscape scales. 

Sound professional judgment incorporates field experience, knowledge of refuge resources, 

refuge functions within an ecosystem, applicable laws, and best available science, including 

consultation with others both inside and outside the Service. 

 
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1-4 Chapter 1 – Introduction 

Wilderness (602 FW 3) 

Service planning policy (602 FW 3) requires the conduct of a wilderness review in association 

with the development of a refuge CCP. The wilderness review process has three phases: 

inventory, study, and recommendation. After first identifying lands and waters that meet the 

minimum criteria for wilderness during the inventory phase, the resulting wilderness study areas 

are further evaluated to determine if they merit recommendation from the Service to the 

Secretary of the Interior (Secretary) for inclusion in the National Wilderness Preservation 

System. A more complete discussion of wilderness inventory, study, and recommendation is 

included in Appendix F. 

General Guidelines for Wildlife-Dependent Recreation (605 FW1) 

This set of policies (605 FW 1-7), published in July 2006, defines the System’s wildlifedependent recreation policy, provides guidelines used to manage wildlife-dependent recreation 

on refuge lands and identifies visitor service standards. 

National Wildlife Refuges in the Pacific 

Nineteen individual refuges are scattered across the central and western Pacific Ocean, with 

several refuges located on the main Hawaiian Islands and others found from Guam to American 

Samoa (Figure 1.1). The Hawaiian and Pacific Islands NWR Complex which provides 

administrative guidance and oversight for the 19 refuges, is located in Honolulu, Hawaii. This 

Complex also co-manages the newly established Papahānaumokuākea Marine National 

Monument with the National Oceanic and Atmospheric Administration and the State of Hawaii. 

Within this administrative structure is a subset of seven refuges known as the Remotes Complex. 

The Remotes Complex straddles the Equator near the center of the Pacific Ocean. They are 

farther from human population centers than any other U.S. area and represent one of the last 

frontiers and havens for fish and wildlife in the World. These remote refuges are the most 

widespread collection of coral reef and seabird/shorebird protected areas on the planet under a 

single country’s jurisdiction. Only one of these seven refuges, Palmyra Atoll NWR, has onisland dedicated staff members. Remotes Complex staff, located within the complex office in 

Honolulu, manage all the remaining refuges, including Howland. Staff, funding, and logistical 

support are often shared among these remote refuges to help defray operational costs. 

The Howland CCP identifies several management strategies that are dependent upon activities 

and staff support from the Remotes Complex office, ship transportation support from other 

Federal agencies, or the establishment of partnerships with other organizations. Because of the 

great distances involved in traveling to these remote refuges, most management activities, 

including the simple act of visiting a refuge, are sometimes planned to occur concurrently during 

the same voyage. For this reason, cost estimates for management activities at Howland are prorated amongst the seven refuges within the Remotes Complex. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 1 - Introduction 1-5 

Figure 1.1 Map of National Wildlife Refuges in the Pacific. 
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1-6 Chapter 1 – Introduction 

Refuge Establishment, Purpose, and Boundary 

Refuge Establishment 

Howland Island is an unincorporated territory under the sovereignty of the United States. The 

Secretary of the Interior has broad authority over the territories of the United States by virtue of 

the Act of March 1, 1873, (43 U.S.C. 1458) which transferred general authority “...to perform all 

duties in relation to the Territories of the United States...” from the Secretary of State to the 

Secretary of the Interior. In addition, President Franklin D. Roosevelt signed Executive Order 

7368 on May 13, 1936, also placing control and jurisdiction of Howland Island with the 

Secretary of the Interior. Further, pursuant to the provisions of the Reorganization Act of 1949, 

the Secretary of the Interior is authorized under Reorganization Plan No. 3 of 1950 to re-delegate 

to any officer or agency within the Department of the Interior any of the functions legally under 

his jurisdiction. 

Under the authority of Reorganization Plan No. 3, the Secretary of the Interior, on June 27, 1974, 

designated Howland Island and its territorial sea extending to the 3 nautical mile (nmi) limit as a 

unit of the National Wildlife Refuge System to be “administered under the general regulations 

for the National Wildlife Refuge System published in Title 50, Code of Federal Regulations” (39 

FR 27930). Section 25.21 of these regulations state that “...all areas included in the National 

Wildlife Refuge System are closed to public access until and unless we open the area for a use or 

uses in accordance with the National Wildlife Refuge System Administration Act of 1966 (16 

U.S.C. 668dd-668ee), the Refuge Recreation Act of 1962 (16 U.S.C. 460k-460k-4) and this 

subchapter C.” Howland Island National Wildlife Refuge remains closed to public access. 

 

Refuge Purpose 

Refuge purposes are often times are based upon land acquisition documents and authorities. 

These statements give indications for the biological reason or justification for the acquisition or 

land transfer. Purposes listed in acquisition authorities, or legislative acts, are often general in 

scope. For Howland, this general purpose is: 

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

wildlife resources...” (16 U.S.C. 742f (a)(4)), and “...for the benefit of the United States Fish 

and Wildlife Service, in performing its activities and services. Such acceptance may be 

subject to the terms of any restrictive or affirmative covenant, or condition of servitude...” 

(16 U.S.C. 742f (b)(1)) (Fish and Wildlife Act of 1956). 

Acquisition documents often contain more specific purpose statements. The specific purpose 

statement for establishment of Howland identified in the biological ascertainment report at the 

time of transfer to the Service is (USFWS 1973): 

“...the restoration and preservation of the complete ecosystem, terrestrial and marine. 

Special consideration must be given to the protection of nesting seabird populations.” 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 1 - Introduction 1-7 

Refuge Boundary 

Howland is located in the central equatorial Pacific Ocean (Figure 1.2). The boundary for 

Howland includes: 

“all of said island ... together with its territorial sea extending outward to the three-mile 

limit” (39 Federal Register 27930). 

The emergent land area for Howland encompasses 648 acres and submerged lands and waters 

within the 3-mile limit encompass 33,671 acres for a total of 39,319 acres. 

 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

1-8 Chapter 1 – Introduction 

Figure 1.2 Howland Island National Wildlife Refuge: Geographic Location and 

Boundary. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 1 - Introduction 1-9

Regional and Ecosystem Conservation Plans 

Regional and ecosystem conservation plans and initiatives are also important to evaluate and 

incorporate into developing each CCP. These plans typically address issues or concerns that are 

site specific or of regional concern, and address needs more current than when the refuge was 

established. 

Remote Islands Ecosystem Plan: Howland Island, Baker Island, and Jarvis Island 

National Wildlife Refuge 

The ecosystem plan for Howland, Baker, and Jarvis identifies Howland as having a reef that is 

“...healthy and provides habitat for giant clams” (USFWS 1998b). The plan further implies that 

all three islands represent models of intact ecosystem components that are either pristine in 

nature, have been, or are being managed and restored to pre-human contact conditions. 

Coral Reef Initiative in the Pacific: Howland Island, Baker Island, and Jarvis Island 

National Wildlife Refuges 

The Coral Reef Initiative for Howland, Baker, and Jarvis restates the wildlife and ecological 

values identified in the ecosystem plan (USFWS 1998a). This document identifies three 

important components of the three ecosystems: “They provide a breeding platform for pelagic 

birds using large areas of ocean surface, offer a migratory stopover for long distance migrating 

shorebirds, and furnish reef habitat for shallow water organisms.” 

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

imbricate) (NMFS and USFWS 1998) 

Although theoretically within the range for hawksbill turtle, little is known about their biology, 

foraging and nesting behavior, threats, and distribution surrounding Howland Island. Both the 

National Oceanic and Atmospheric Administration’s National Marine Fishery Service (NMFS), 

and the U.S. Fish and Wildlife Service share responsibility at the Federal level for the research, 

management, and recovery of Pacific marine turtle populations under U.S. jurisdiction. 

Recovery Plan for U.S. Pacific Populations of the Green Turtle (Celonia mydas) 

(NMFS and USFWS 1998) 

Few green turtles are known to forage in the waters surrounding Howland Island and nesting is 

not known to occur. However, data from the area is limited and use of Howland may be greater 

than currently documented. Both the NMFS and the Service share responsibility at the Federal 

level for the research, management, and recovery of Pacific marine turtle populations under U.S. 

jurisdiction. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

1-10 Chapter 1 – Introduction 

U.S. Pacific Island Regional Shorebird Conservation Plan (Engilis and Naughton 

2004) 

This regional shorebird plan identifies Howland as being within the Central Pacific Islands 

Subregion. No natural wetlands are known from this subregion; however, beaches on 

uninhabited islands are important for shorebirds. Population and habitat goals for this subregion 

state that determining population size and trends for bristle-thighed curlews and other shorebirds, 

and their habitats is a management priority. 

United States Shorebird Conservation Plan (Brown et al. 2000) 

This nationwide shorebird plan identifies the U.S. Pacific Islands being of “critical importance 

for two species of Holartic breeders, bristle-thighed curlew and Pacific golden-plover.” Further, 

this plan notes that these islands provide wintering habitat essential to the maintenance of these 

species as well as several other migratory shorebird species. 

Seabird Conservation Plan, Pacific Region (USFWS 2005) 

This plan provides an overarching review, discussion, and identification of conservation 

priorities for seabirds in the U.S Pacific Islands; ranks seabirds for conservation priority; and 

includes specific species accounts including their conservation needs. 

Central Pacific World Heritage Project 

The United Nations Educational, Scientific and Cultural Organization (UNESCO) organized and 

convened meetings in Honolulu in June 2003, and Kiritimati Atoll in October 2004, to seek input 

for a proposed multi-national World Heritage project now referred to as the Central Pacific 

World Heritage Project (CPWHP) (UNESCO World Heritage Centre, 2003; 2004). Additional 

meetings and evaluations in the U.S. and Republic of Kiribati resulted in a total of 29 atolls, 

islands, and reefs belonging to four nations (United States, Cook Islands, Republic of Kiribati, 

and French Polynesia) being proposed for the multi-site, multi-jurisdictional CPWHP. To date, 

the Service has not acted on this proposal, but may do so in the future. However, in 2006 the 

Republic of Kiribati established the world’s largest marine protected area to date that 

encompasses all eight of the nation’s Phoenix Islands and intended for nomination as a World 

Heritage site in 2009. All eight are the closest neighbors to Howland and Baker National 

Wildlife Refuges, lying 200-450 km to the southeast of both islands. 

Refuge Vision Statement 

The refuge vision statement is a broad general statement that describes what the refuge staff 

perceives as Howland’s fundamental attributes and contributions to a healthy world environment. 

This statement will guide management activities for the lifespan of this plan, as well into the near 

future. The vision statement for Howland is as follows. 

 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 1 - Introduction 1-11

Howland is one of the last places in the world where the terrestrial and marine tropical 

island ecosystems are still intact and relatively free of human impacts. Natural, physical 

and ecological processes unfold with limited human interference and support a diverse 

community of native marine organisms including seabirds, marine mammals, turtles, fish, 

plants, corals, and other invertebrates. Nesting and foraging seabirds dominate the 

landscape and seascape while sheer isolation and solitude help us see our place in the 

natural world. 

Refuge Goals 

Goal statements are succinct statements of a desired future condition of refuge resources. Goals 

comprise the whole of a refuge’s effort in pursuit of its vision and lay the foundation from which 

all refuge activities arise. The goals for Howland are as follows, and will again be presented 

along with objectives and strategies in Chapter 3. 

1. Conserve, manage, and protect native terrestrial habitats that are representative of remote 

tropical Pacific islands, primarily for the benefit of seabirds. 

2. Conserve, manage, and protect native marine communities that are representative of 

remote tropical Pacific Islands. 

3. Contribute to the recovery, protection, and management efforts for all native species with 

special consideration for seabirds, migratory shorebirds, federally listed threatened and 

endangered species, and species of management concern. 

4. Protect, maintain, enhance, and preserve the wilderness character of Howland’s terrestrial 

and marine communities. 

5. Howland’s biological, cultural and historic resources are preserved. 

6. An informed, interested, and educated public appreciates remote Pacific Island NWRs 

wilderness values, cultural and historical resources, and their ecosystems, with special 

emphasis on seabirds. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

1-12 Chapter 1 – Introduction 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2 – Planning, Purpose and Need, and Issues 2-1 

Chapter 2: PLANNING, PURPOSE, NEED, AND ISSUES 

 

Planning Process 

The CCP development process follows applicable policies contained within the Service’s Fish 

and Wildlife Manual (Part 602 FW2.1, November 1996; Part 601 FW1, Part 603 FW1, and Part 

605 FW1, June 2006), and the Wilderness Act of 1964 with respect to wilderness study and 

review. This CCP was completed in association with an EA and is intended to meet the dual 

requirements of compliance with the NWRS Administration Act and the National Environmental 

Policy Act (NEPA). Both the NWRS Administration Act and NEPA require the Service to 

actively seek public involvement in the preparation and adoption of environmental and 

conservation documents and policies. Furthermore, NEPA also requires the Service to consider 

a reasonable range of alternatives including its Preferred Alternative and the “No Action” 

alternative; the latter defined as continuation of current management practices. 

Purpose and Need 

Overall, all refuges must comply with the System mission, goals, and policies, as described in or 

promulgated by the National Wildlife Refuge System Administration Act of 1966 (NWRS 

Administration Act), as amended (16 U.S.C. 668dd-668ee). The National Wildlife Refuge 

System Improvement Act of 1997 amended the NWRS Administration Act. According to the 

NWRS Administration Act, a CCP is required to identify and describe refuge purpose(s), 

habitats and wildlife, archaeological and cultural values, administrative and visitor facilities, 

management challenges and their solutions, and opportunities for compatible wildlife-dependent 

recreation. The recreational activities referenced in the NWRS Administration Act as receiving 

special consideration during planning efforts include hunting, recreational fishing, wildlife 

observation, interpretation, environmental education, and photography. 

The purpose of this CCP is to develop a vision, goals, and objectives for Howland, which in turn 

provide guidance to identify and implement management activities, or strategies, during the next 

15 years. Specifically, the CCP: 

• sets a long term vision; 

• establishes wildlife and habitat management goals and objectives; 

• establishes goals and objectives for compatible wildlife-dependent recreational and 

educational uses; 

• identifies strategies for habitat enhancement and restoration projects; 

• describes the highest monitoring and research priorities; and 

• describes and evaluates wilderness values. 

Howland and its management and administrative activities are managed as part of the NWRS or 

System within a framework provided by legal and policy guidelines. The refuge is guided by the 

mission and goals of the NWRS, the purpose of the refuge as described in its acquisition 

authority, Service policy, Federal laws and executive orders, and international treaties. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

2-2 Chapter 2 – Planning, Purpose and Need, and Issues 

Supplemental guidance documents (e.g., resource plans) are also included in making 

management decisions but cannot replace or be in conflict with the purposes for which the refuge 

was established or the mission of the System 

Planning Issues and Opportunities 

Issues, concerns, and opportunities were identified through discussions with key contacts, core 

team members, other refuge staff, and through the public scoping process. The following section 

summarizes issues, concerns, and opportunities from all public input received throughout the 

planning efforts. Six issues were identified and are described below. 

Issue 1: Operational Limitations 

Howland is located approximately 1,815 nmi from the management staff located in Honolulu, 

Hawaii. On average, it takes 8 days to reach Howland by ship, the only method of visiting the 

island. The key issues and concerns affecting planning and management implementation are: 

• distance from refuge headquarters; 

• lack of affordable and reliable transportation; 

• lack of infrastructure to support field operations; 

• extreme environmental conditions; and 

• safety concerns and logistical capacity to land people and equipment on-island from 

small boats during limited time windows associated with low surf conditions. 

Issue 2: Biological and Ecological Resources 

Biological and ecological information sufficient for management or conservation purposes is 

lacking. Due to the infrequency and limited staff time spent on Howland, biological and 

ecological information does not allow for a detailed assessment of resources. The collection of 

baseline and long-term monitoring information should be a primary concern and the focus of 

management objectives. 

Issue 3: External Forces 

The threat of the introduction of invasive species from unauthorized visits, marine debris 

washing ashore and onto coral reefs, and vessel groundings are beyond current management 

control. Distance, lack of funds and staff, and the inability to have a more consistent presence on 

this island opens the opportunity for invasive species introductions, limits the ability to remove 

marine debris, and delays response to vessel groundings. 

Global climate change (see Chapter 4) may also affect refuge resources, but is beyond control of 

refuge management staff. It is anticipated that changes in the chemical composition of the 

atmosphere and oceans; surface temperatures of air, land, and sea; intensity and frequency of 

rainfall and storm waves; and changes in sea level would have impacts on refuge resources. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2 – Planning, Purpose and Need, and Issues 2-3 

However, the extent and nature of these impacts, if any, is unclear and the subject of 

considerable academic debate. 

Issue 4: Public Use Resources 

The key issues related to public use are: 

• adverse ecological impacts (invasive species introductions, sewage pollution, fuel spills, 

trash disposal, harassment of wildlife, damage to sensitive habitats such as coral reefs); 

• whether any on-site public use should be allowed; 

• to what extent the use should occur; and 

• how the use should be managed. 

Howland has never been formally opened to public access and use. In the past, several 

recreational user groups such as amateur radio operators, bird watchers, history enthusiasts, 

destination tourists, and commercial cruise vessels have expressed interest in visiting various 

remote Pacific island refuges. Public access to Howland would be managed through use of 

refuge-issued Special Use Permits (SUP). However, before a SUP could be issued, a request for 

public access would need to be evaluated for appropriateness and compatibility. 

Issue 5: Education and Outreach 

In general, Pacific Island refuges are poorly recognized by the public and our partner agencies. 

There are few entrance signs, no boundary signs, and little published information in popular 

literature. Refuge boundaries are rarely portrayed on nautical charts and other maps. 

The remote location and isolation of Howland and other Pacific island refuges make it difficult 

to conduct on-site visits for educational or interpretative purposes. Thus, most educational and 

interpretative opportunities are necessarily delivered remotely through various media. 

In addition, general interest by the public and requests to visit remote Pacific Island refuges by a 

growing recreational yachting community has increased recently. This interest requires the 

public to be better informed regarding sensitive refuge habitats, species, and regulations. 

Issue 6: Communication and Cooperation 

 

Howland’s remoteness compels a growing list of partners and cooperators to be kept informed of 

and included in planning and management activities at Howland. Activities that staff and partner 

agencies/organizations share include: 

• expedition planning; 

• collaborative research projects; and 

• jurisdictions of trust resources. 

Most access for refuge staff to Howland has only been possible through the cooperation and 

participation with partner agencies such as NOAA and the U.S. Coast Guard. Many research 

interests are shared between Service and NOAA scientists, and collaborative research projects 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

2-4 Chapter 2 – Planning, Purpose and Need, and Issues 

have been conducted in the past. Additionally, NOAA and the Service share trust resource 

responsibilities for marine turtles. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 3 – Management Direction 3-1 

Chapter 3: MANAGEMENT DIRECTION 

 

Overview 

The Service reviewed and considered a variety of resource, logistic, social, and economic aspects 

important for managing the refuge when developing this long-term management plan. As is 

appropriate for a National Wildlife Refuge, resource conditions were fundamental in designing 

the CCP. Marine and terrestrial resources are equally important to the management of Howland, 

and are described more fully in Chapter 4. However, the logistics of reaching the island and 

associated coral reefs is the primary constraint on increasing or modifying the level of 

management and monitoring activity that has or currently occurs. To more fully understand this 

constraint, a description of the logistical requirements and refuge management activities follows. 

Marine vessels capable of traveling the open ocean for extended periods are the only opportunity 

for transportation to Howland. In the recent years, NOAA, the U.S. Coast Guard, and private 

charter vessels have all provided transportation. A typical voyage originating from Honolulu, 

Hawaii will take approximately 8 days to arrive at Howland excluding intermediate stops at 

Palmyra Atoll or Johnston Atoll NWRs. Once on-site, if wind and wave conditions warrant the 

launch of a landing vessel (typically a small outboard type inflatable boat), the marine vessel will 

anchor or remain stationary during the deployment of the field camp, only venturing away from 

the island to complete marine surveys. The field camp itself generally consists of two 

individuals, typically biologists to carry out biological surveys and other duties, and camping 

gear consisting of tents, sleeping equipment, food, water, and needed survey equipment. 

Cooking gear is rarely deployed since staff is only on-island for 1 to 2 days with most of that 

time being engaged in work activities. 

While on-island, the biologists document all bird species present, count individuals, determine 

the stage of any nesting efforts, qualitatively describe vegetation, and record species presence or 

absence, noting in particular the presence of any invasive species. Observations regarding the 

condition of cultural sites such as the Amelia Earhart day beacon are also made. The only active 

management that occurs during these site visits is the collection and on-island stockpile of 

marine debris that washes ashore and poses a threat to seabirds and other wildlife that use 

Howland. Any evidence of illegal activity such as unauthorized access is documented. 

Photographs record general habitat conditions; however, further habitat assessment does not 

occur. Although no specific activities occur with respect to wilderness values, the simple fact 

that a 1 to 2 day field camp consisting of temporary lodging arrangements and minimal activity 

is consistent with maintaining the wilderness values of the area. 

During the period that the biologists are on Howland, marine scientists from NOAA, the Service, 

and other partner organizations such as the University of Hawaii conduct surveys and monitoring 

activities of the marine environment. Some monitoring activities occur on-board the vessel, 

while others require the use of SCUBA equipment. All of the marine scientists, however, deploy 

from the vessel conducting independent marine surveys using other skiffs and thus do not come 

ashore. Marine scientists typically collect information on currents, weather, temperature, 

chemical composition of the water, and the abundance and distribution of coral, algae, and other 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

3-2 Chapter 3 – Management Direction 

invertebrate and fish species. Specific marine-based surveys known as Rapid Ecological 

Assessments (REA) are conducted and collect ecological data such as fish species, abundance, 

and predator prey relationships. Data are also collected at permanently marked coral transects 

established in 2000-2002 that document changes in coral species, age, size, numbers, and percent 

cover over time. These data are collected over a 2-day period (six 1-hour dives). Following the 

voyage, data from marine scientists are provided to the Service that includes a full range of 

oceanographic, bathymetric, and marine biological information. 

Specific details of the management program are categorized below: 

• Baseline Monitoring of Wildlife Populations and Habitats. Staff visits to Howland 

provide baseline and temporal monitoring efforts, documenting species presence or 

absence, abundance, habitat condition, presence of invasive species and various other 

physical variables such as temperature, precipitation, wind, etc. 

• Voyage Preparation. The logistics of providing adequate field camp supplies such as 

water, food, first aid, and communications occurs for each voyage. 

• Use of extraneous unnatural lighting. Limiting and shading the lighting on vessels, 

camp, and nighttime operations minimizes the threat of collision and disorientation of 

wildlife that can be caused by light hazards.

• Quarantine protocols and use of Integrated Pest Management (IPM). Visitors to 

Howland are required to wear new and frozen clothing and other quarantine precautions 

as outlined in quarantine protocols (Appendix E). Manual pulling of weeds occurs as 

time becomes available. Selective hand spray application of herbicides or pesticides, 

where appropriate, may occur. 

• Scientific Information Exchange. Refuge staff currently attends various professional 

meetings and conferences related to Pacific island and marine resources. Additionally, a 

limited amount of staff time is devoted to the development of peer reviewed journal 

articles and contributing to NOAA and Service-sponsored Web sites and status reports. 

• Preservation of Wilderness Values. Since its establishment, Howland has been managed 

to preserve its wilderness values and characteristics even though it has never been 

proposed for wilderness designation. These values are intrinsic at this remote, 

uninhabited island and coral reef ecosystem. Management activities do not impinge on 

these values.

• Public Access. Since establishment, Howland has never been formally opened to public 

access and use. Access and public use remains closed. All individual opportunities for 

compatible use such as specific research projects are administered using individual SUPs. 

• Interpretation, Education, and Outreach. Current opportunities for off-site education 

exist at the Maritime Museum, Honolulu, Hawaii. A hands-on exhibit representing a 

Pacific island refuge is maintained to educate school-aged students about seabirds, 

invasive species, marine debris, and the National Wildlife Refuge System (System). 

Interpretative displays are also used periodically at conventions and professional 

meetings. 

• Protection and Preservation of Cultural Resources. Cultural resources remain intact and 

in situ. Field camps are situated to avoid impacts to cultural resource sites. 

Archaeological reconnaissance to avoid impacts to cultural resources is required prior to 

management activity that would potentially disturb surface or subsurface resources. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 3 – Management Direction 3-3 

• Waste Disposal at Sea. Disposal of waste in refuge waters is prohibited. 

• Waste Disposal on Island. All waste from food products, equipment, and containers that 

is brought onto the island is removed during demobilization. Depending upon the 

duration of the site visit, human excrement will be either bagged, stored in a chemical 

toilet, or decomposed using portable biodegradable toilets, all of which are subsequently 

removed during field camp demobilization. 

• Refuge Boundary. There are no changes to the refuge boundary.

• Cultural Resources Inventory. Presence and condition of cultural resources on Howland

is re-evaluated. 

• Wilderness Study Area. A recommendation for Wilderness Study Area (WSA) 

designation is postponed until a Legislative Environmental Impact Statement (LEIS) and 

wilderness proposal are developed for all other remote Pacific island national wildlife 

refuges (NWRs) as part of their CCP processes. 

• Marine ecosystem monitoring. Funding requests are required for additional exploration 

of deep slope resources by a ship equipped with a remotely operated vehicle (ROV) or 

submersible to operate at depths between 150 and 300 feet. 

• Seabird Nesting Restoration. Electronic calls are deployed and used as seabird nesting 

attraction devices designed to attract Phoenix petrels (Pterodroma alba) and Polynesian 

storm petrels (Nesofregetta fuliginosa). These electronic call devices consist of solar 

powered speakers broadcasting calls of both species in suitable areas of the island. Both 

of these small ground-nesting Procellariforms are severely depleted or extirpated 

throughout much of their range. The mammal-free status of Howland Island makes it an 

ideal site within the species’ original range to restore a breeding population of each 

species.

Once field operations are complete, or the weather becomes increasingly inclement, the field 

camp is demobilized and all equipment and personnel are transported back to the research vessel. 

Typically, the other two other equatorial island refuges (Baker and Jarvis) are also visited in this 

same manner. Travel time between Howland and Baker is 5 hours, and between Baker and 

Jarvis is 5 days. Once the three surveys are completed, or at least attempted, the voyage 

continues with approximately 6 to 7 days to travel back to Honolulu, again with intermediate 

stops at Palmyra Atoll or Johnston Atoll NWRs, or continuing on for 4 days to Rose Atoll NWR 

in American Samoa where voyage scientists and biologists can be exchanged and then fly back 

to Honolulu. In total, it is expected that in order to visit Howland, Baker, and Jarvis for 1 to 2 

days per refuge, a biologist or marine scientist needs to devote 20 to 26 days total travel. Trip 

reports are completed, distributed, and filed once field staff returns to the Honolulu office. 

The only difference between the management condition prior to the completion of the CCP, and 

the actions described in this CCP is an increase in the frequency of staff visits from once every 

two years to once every year. In order to meet the increase in the number of site visits, refuge 

staff in Honolulu is administratively burdened to seek additional funding sources and develop 

partnerships for additional visits. This may take the form of producing internal project proposals 

(RONS), or seeking funding support through grants or partnerships with other agencies, research 

institutions, and non-government organizations. Overall, wildlife and habitat management 

activities remain consistent. The only additional terrestrial management activity is promoting 

nesting use by two seabird species with the use of solar powered electronic calling devices. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

3-4 Chapter 3 – Management Direction 

Phoenix petrel calls would be placed near the kou (Cordia subcordata) grove, and the Polynesian 

storm-petrels calls would be placed near the coral slab habitat on the north beach crest. 

Increased monitoring in the marine environment depends upon partnership opportunities 

developed with NOAA, the University of Hawaii, or other partners. At a minimum, marine 

scientists would resurvey REA and other transect sites. Transportation to and from the island 

would still relies upon NOAA or other partners. Public use and access remains closed. 

 

The ability of the Service to meet the mission of the System, “...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” and the refuge purpose of “...the restoration and 

preservation of the complete ecosystem, terrestrial and marine. Special consideration must be 

given to the protection of nesting seabird populations” is limited. A one to two day visit to the 

island once every year does not provide the opportunity for refuge staff to complete anything 

other than basic biological surveys of species presence or absence. Restoration, preservation, or 

protection of terrestrial and marine ecosystems, or nesting seabirds is not possible. However, 

lack of projected budget and staffing preclude management staff from increasing management 

activity beyond what is described in this CCP. If, during the lifetime of this plan, budget and 

staffing become available to pursue an increased level of management activity then the CCP will 

be reevaluated. 

Goals, Objectives, Strategies, and Rationale 

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

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

the Refuge System Mission. 

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

broadly reflects the refuge purposes, the Refuge System mission and goals, other statutory 

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

of the vision, followed by objectives that direct effort into incremental and measurable steps 

toward achieving those goals. Finally, strategies identify specific tools and actions to 

accomplish objectives. 

 

The goals for Howland over the next fifteen years under the CCP are presented on the following 

pages. Each goal is followed by the objectives that pertain to that goal. The goal order does not 

imply any priority in this CCP. Some objectives pertain to multiple goals and have simply been 

placed in the most reasonable spot. Similarly, some strategies pertain to multiple objectives. 

Following the goals, objectives, and strategies is a brief rationale intended to provide further 

background information pertaining to importance of an objective relative to legal mandates for 

managing units of the NWRS including refuge purpose, trust resource responsibilities (federally 

listed Threatened and Endangered species and migratory birds), and maintaining/restoring 

biological integrity, diversity, and environmental health. 

 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 3 – Management Direction 3-5 

Goal 1: Conserve, manage, and protect native terrestrial habitats that are 

representative of remote tropical Pacific islands, primarily for the benefit of 

seabirds. 

Objective 1a: Conserve, manage, and protect habitat for nesting seabirds. 

Upon CCP approval and throughout the life of the CCP, conserve, manage, and protect a mosaic 

of approximately 648 acres of terrestrial habitat consisting of 30 acres of beach and beach 

strand, 500 acres as short grass and forbs, 6 acres as scrub shrub, and 112 acres as bare ground 

on Howland Island as nesting habitat for ≥ 11 seabird species. 

Strategies Applied to Achieve Objective 

Conduct and record incidental observations of invasive terrestrial species. 

Adhere to strict quarantine protocols for all island visitors (see Appendix D). 

Collect and stockpile marine and other human debris not considered to be historically important. 

Rationale: 

The 11 nesting seabird species on Howland use all island habitats (see Chapter 3.9.1 and 

Appendix B). Masked and brown boobies prefer to nest on bare open ground. Gray-backed, 

sooty, and white tern, and brown and blue grey noddy also nest on the surface, but are tolerant of 

vegetated areas. Lesser frigatebirds, typically known as a shrub nesting species, are found 

exclusively on the ground at Howland. Red-tailed tropicbirds prefer shaded areas and can be 

found nesting on the surface, under coral slabs, or in shrubs. Red-footed booby and great 

frigatebird are the only two exclusive shrub nesting species. 

The Seabird Conservation Plan (2005) recognizes remote Pacific islands as providing important 

and varied breeding habitat, specifically Howland as being important for ground nesting species. 

Additionally, the plan recognizes that near-shore waters provide areas of upwelling currents with 

important food resources for seabirds. 

Maintaining the island free of mammalian predators, invasive insects, and invasive plants is 

critical for seabird survival (USFWS 2005). Strict quarantine protocols have been previously 

established for all island visitors in order to eliminate the threat of introducing invasive plants, 

insects, and animals (see Appendix D). 

Marine and other human generated debris poses an entanglement threat for multiple wildlife 

species. Stockpiling debris can reduce the overall area impacted, thereby reducing the 

entanglement threat. 

Objective 1b: Increase baseline information on terrestrial habitat. 

Within 15 years of the CCP approval, conduct monitoring to determine vegetation species 

presence/absence and distribution on Howland Island. 

Strategies Applied to Achieve Objective 

Document presence/absence of island vegetation. 

Coordinate with Regional Office GIS staff to assess and/or develop remote sensing capability to 

map and monitor island habitats. 

Rationale: 

In general, insufficient time has been spent on Howland to adequately quantify habitat on 

Howland, and how this habitat relates to seabird biology. Collection of baseline biological 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

3-6 Chapter 3 – Management Direction 

information is essential to adequately understand and manage the refuge. Although it is known 

that the 11 nesting seabird species use all habitats on Howland, this information has only been 

obtained from the short duration, infrequent visits (1 to 2 days every 2 years) to the island. 

There has been no quantitative assessment of breeding species habitat associations. The 

distribution and delineation of habitats itself has been estimated, but never been quantified. 

Remotely collected data may provide an option for data collection in the absence of being 

capable of visiting Howland. 

Goal 2: Conserve, manage, and protect native marine communities that are 

representative of remote tropical Pacific islands. 

Objective 2a: Conserve, manage, and protect marine habitat. 

Upon CCP approval, conserve, manage, and protect approximately 33,671 acres of submerged 

lands consisting of an estimated 3,000 acres coral reef and 30,671 acres of deep water/pelagic 

habitat on Howland. 

Strategy Applied to Achieve Objective 

Continue and expand partnership with NOAA and others to manage coral reef ecosystems.

Rationale: 

The conservation and protection of the Nation’s coral reefs is becoming increasingly important 

for agencies with responsibility to manage and conserve those (Executive Orders 13089 and 

13158). Because the refuge boundary for Howland extends to 3 nmi from the island shoreline, 

all shallow water coral reefs are contained within the refuge boundary. Threats to the coral reef 

system include predatory species such as crown-of-thorns starfish, invasive species such as the 

corallimorph Rhodactis howesii, and marine debris (e.g. abandoned fishing gear) that collects on 

corals, smothering or breaking them. The responsibility for protecting, managing, and 

conserving coral reef ecosystems is shared with NOAA. The Service and NOAA often 

participate in joint management activities throughout the Pacific; however, no active 

management activities have occurred at Howland. 

Objective 2b: Increase baseline information on marine community. 

Within 15 years of CCP approval, continue monitoring coral species to determine size, cover, 

density, diversity, and distribution; fish species presence/absence and habitat associations; sea 

turtle species presence or absence; and marine mammal species presence or absence; 

oceanographic conditions in relation to climate change effects. 

Strategies Applied to Achieve Objective 

Conduct and record incidental observations of corals, fish, turtles, marine mammals, and their 

habitats. 

Accompany NOAA or other scientific partners on marine surveys. 

Conduct REA (Rapid Ecological Assessments) on at all existing survey sites to document coral, 

fish and turtle density, diversity, distribution, and habitat associations. 

Develop proposals and conduct deep slope marine surveys by ROV (remotely operated vessel) 

or submersible to document presence or absence of deep slope coral and fish species. 

Rationale: 

Responsibility for managing marine resources is shared with NOAA, and has led to many 

cooperative studies. Unlike the logistic constraints of completing terrestrial surveys, marine 

surveys are conducted throughout the entire time that the marine transport vessel is at Howland. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 3 – Management Direction 3-7 

Additionally, since most site visits to Howland are aboard NOAA research vessels, the purpose 

of these voyages is to conduct marine surveys and studies. Consequently, a full compliment of 

up to 20 marine researchers and another 20 support staff contribute to conducting marine 

surveys across all alternatives. As a result, marine surveys are more comprehensive than 

terrestrial surveys on Howland, although individual dives are limited to one hour and depths less 

than 20 m. 

REAs constitute baseline monitoring of the marine ecosystem, and are one component of all 

alternative strategies. Further expansion of REA’s could be accomplished only as a component 

of Alternative D. 

Additional surveys (marine mammals, deep slope), as described beginning with Alternative B 

can be achieved as components of cooperative efforts with other agencies or research 

organizations. As an example, little is known of marine mammal use surrounding Howland, or 

the history of sea turtle use and nesting, although it is known that some species are found in the 

vicinity. 

The Marine Mammal Commission has encouraged the Service to generate partnerships with 

NOAA to help document baseline information. Developing additional partnerships with NOAA 

or other organizations may also assist in meeting terrestrial objectives by providing the 

opportunity for additional trips to Howland. 

Goal 3: Contribute to the recovery, protection, and management efforts for all 

native species with special consideration for seabirds, migratory shorebirds, 

federally listed threatened and endangered species, and species of management 

concern. 

Objective 3a: Develop baseline migratory bird and other species information. 

Within 10 years of CCP approval, conduct monitoring (in rank order) to determine: seabird 

species presence or absence, relative abundance, breeding chronology, distribution, and habitat 

use; counts of shorebirds; presence or absence and distribution of sea turtles; and presence or 

absence of terrestrial invertebrates on Howland Island. The desired conditions by which this 

will be met is understanding of the complete annual chronology for 5 of 11 seabird species; 

population trend data over the 10-year period for all 11 seabird species; and the numbers and 

distribution of shorebirds, turtles and other terrestrial invertebrates. 

Strategy Applied to Achieve Objective 

Record incidental observations of all species’ presence or absence, relative abundance, and 

distribution. 

Rationale: 

The Seabird Conservation Plan (2005) repeatedly recognizes the importance of the U.S. Pacific 

Islands in providing predator-free seabird nesting and roosting environments. Their protected 

status, in concert with nearby marine forage resources contribute to their importance. The 

Seabird Plan further identifies infrequent inventories as insufficient to accurately detect or 

monitor populations, suggesting instead that a rigorous collection of population data is needed. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

3-8 Chapter 3 – Management Direction 

In addition to Howland being recognized as important habitat for seabirds, the U.S. Pacific 

Islands Regional Shorebird Conservation Plan (2004) lists determining baseline information for 

bristle-thighed curlews, and other species, as the goal of the Central Pacific Islands Subregion. 

The endangered species recovery plans for both species of turtles indicate that little is known 

about their biology in the central Pacific. Data on other terrestrial wildlife species found on 

Howland Island is lacking. 

 

Objective 3b: Restore breeding populations for 2 seabird species. 

Within 10 years of CCP approval, establish up to 5 nesting pairs each of Phoenix petrel 

(Pterodroma alba) and Polynesian storm-petrel (Nesofregetta fuliginosa) during a minimum of 

three consecutive years on Howland Island. 

Strategies Applied to Achieve Objective 

Implement and maintain electronic calling devices to promote nesting. 

Coordinate with RO and develop capabilities for remote surveillance equipment. 

Rationale: 

The Seabird Conservation Plan (2005) recognizes the Polynesian storm-petrel may flourish on 

Howland, as well as Baker and Jarvis, due to the removal of predators from the islands. The 

Phoenix petrel is known from the Phoenix Islands, but does not currently inhabit Howland, 

though it is thought that they did historically. A recommendation of the Seabird Conservation 

Plan (2005) is expand efforts to assess habitat suitability and restore populations through 

translocation to predator-free U.S. islands such as Howland. While the physical translocation of 

species to Howland is not being suggested, electronic calling devices are designed, and have 

been successful, in attracting and establishing nesting seabird colonies to other islands. 

 

Objective 3c: Develop baseline data and understand turtle use of Howland. 

Upon CCP approval, monitor hawksbill and green turtles to document any nesting sites, all 

adjacent coral reef and nearshore water foraging sites, and overall population density and 

distributions, and review literature to determine previous records of, and use of sea turtles during 

the guano mining and WWII eras. 

Strategies Applied to Achieve Objective 

Record incidental observations of nearshore turtle use. 

Develop partnership with NOAA for study of turtles at Howland. 

Rationale: 

There is currently little information related to use of Howland resources by sea turtles, though it 

is known that they do use refuge habitats. Sea turtles may have been collected or harvested 

during the guano and WWII eras. Sea turtles have been photographed in the water during joint 

Service/NOAA expeditions since 2000. Data collected over the life of this plan would help to 

establish a baseline understanding of sea turtle populations in the central Pacific. 

Objective 3d: Expand baseline information on marine community. 

Upon CCP approval, monitor populations of globally depleted marine species such as giant 

clams (Tridacna sp.), bumphead parrotfish (Bolbometapon muricatum), Napoleon wrasses 

(Cheilinus undulatus), large groupers (Cephalopholis sp., Epinephelus spp., Variola spp., etc.), 

sharks (Carcharhinus spp., Triaenodon spp., Negaprion spp., Galeocerdo spp., etc.), pearl 

oysters (Pinctada margaritifera), the invasive corallimorph (Rhodactis howesii) and corals 

(Anthozoa, Hydrozoa) to document their presence or absence and relative abundance on 

Howland. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 3 – Management Direction 3-9 

Strategies Applied to Achieve Objective 

Conduct marine surveys such as REA. 

Maintain the monitoring of permanent coral and macro-invertebrate transects established in 

2000-2002. 

Solicit partnership for survey of deep slope habitat. 

Rationale: 

Many marine species of commercial importance have been globally depleted. Protected areas 

such as Howland still provide sanctuary areas. However, illegal fishing activity, including 

evidence thereof, has been noted surrounding several Remotes refuges. Howland, as well as 

other remote island refuges provide the opportunity to study and protect the marine ecosystem. 

 

Objective 3e: Develop baseline scientific information on marine mammal use of Howland. 

Within 10 years of CCP approval, increase scientific understanding of marine mammal presence 

and use of Howland marine waters. The desired conditions by which this will be met will be to 

document all marine mammal use of nearshore waters. 

Strategies Applied to Achieve Objective 

Incidental observations of marine mammals. 

Solicit partnership for study of marine mammals at Howland. 

Rationale: 

NOAA, the Service, Oceanic Institute, University of Hawaii, and Bishop Museum marine 

biologists have collected data on marine species of concern since 2000. Only anecdotal 

information exists on marine mammal use of the waters surrounding Howland Island. However, 

studies elsewhere in the Pacific indicate that waters surrounding small islands may support 

distinct local populations of marine mammals. It is also important to understand the threats 

human activity may pose to this important resource (Marine Mammal Commission. pers. 

comm.), including unauthorized fishing. 

Goal 4: Protect, maintain, enhance, and preserve the wilderness character of 

Howland’s terrestrial and marine communities.

Objective 4a: Protect and maintain wilderness values. 

Upon CCP approval, continue to preserve the wilderness values (e.g. size, naturalness, solitude, 

supplemental values) of Howland. Achievement of this objective will be evaluated by assessing 

loss or degradation of values that qualified it for potential designation (see Appendix F). 

Strategies Applied to Achieve Objective 

Use minimum tools necessary to manage refuge resources. 

Continue to manage Howland as wilderness. 

Monitor values of naturalness and solitude. 

Rationale: 

Howland has been and is managed as a wild, natural area due to its remote location, historic lack 

of human impact, and limited human presence. Areas of Howland have been identified as 

meeting the criteria for a Wilderness Study Area (Appendix F). Completion of the wilderness 

review process and as appropriate development of a Legislative EIS will be pursued for all 

Pacific Remote Island Refuges once their CCP’s have been completed. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

3-10 Chapter 3 – Management Direction 

Some human generated debris remains from past occupations. Additionally, debris such as 

discarded fishing nets continuously washes ashore. This debris impinges upon wilderness 

values. 

In the interim, all areas identified as suitable WSAs would continue to be managed as 

wilderness. All management activities would be conducted in such a manner as not to detract 

from the wilderness values identified in the Wilderness Inventory. 

Goal 5: Howland’s biological, cultural and historic resources are preserved. 

Objective 5a: Protect cultural resources. 

Upon CCP approval, continue to protect existing cultural resources. The desired conditions by 

which this will be met will be to document any change in condition of Amelia Earhart day 

beacon memorial, or other recognized cultural/historical resource. 

Strategy Applied to Achieve Objective 

Record incidental observations of condition of cultural resources. 

Rationale: 

Restricting human use of Howland would maintain cultural resources by limiting the opportunity 

for invasive species establishment, and reducing the opportunity for unauthorized collection or 

disturbance. In order to keep cultural resource sites protected, the locations and descriptions of 

fragile cultural resources would not be made available to the public. 

 

Objective 5b: Enhance Law Enforcement Capabilities 

Upon CCP approval, seek to improve partnerships with the NOAA Office of Law Enforcement 

to increase enforcement capacity. The desired conditions by which this will be met will be to 

formalize interagency agreements and develop remote surveillance techniques to document 

unauthorized access to the refuge. 

Strategies Applied to Achieve Objective 

Establish joint enforcement operational protocols with NOAA Office of Law enforcement. 

Evaluate the effectiveness of deploying acoustical devices to detect ship traffic in the vicinity of 

the refuge. 

Rationale: 

Enhancing law enforcement capability to detect and prosecute unauthorized access would 

preserve biological and cultural resources by limiting the opportunity for invasive species 

establishment and deterring unauthorized collection or disturbance. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 3 – Management Direction 3-11 

Goal 6: An informed, interested, and educated public appreciates remote Pacific 

Island NWR wilderness values, cultural and historical resources, and their 

ecosystems, with special emphasis on seabirds. 

Objective 6a: Provide off-site education and interpretation opportunities. 

Within three years of CCP approval, develop an off-site educational opportunity for the public to 

learn about Pacific Island refuge wilderness values, cultural and historical resources, tropical 

island ecosystems, seabirds, and coral reef. The desired conditions by which this will be met 

will be through publications, educational programs, displays, or other media. 

Strategy Applied to Achieve Objective 

Develop, with External Affairs office, Honolulu, an interpretative brochure, display, or 

educational program for all remote Pacific Island refuges. 

Rationale: 

While it is important for the public to understand and appreciate the resource values associated 

with remote island refuges, it is logistically difficult to do this on-site at Howland and still 

protect the island’s wildlife, habitats, wilderness values, cultural and historical resources, and 

visitor’s safety. For these reasons, interpretative or educational opportunities for the public to 

learn and appreciate the values of remote Pacific Island refuges and resources will be provided 

primarily as off-site programs and interpretative brochures. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

3-12 Chapter 3 – Management Direction 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4 – Refuge and Resource Description 4-1 

Chapter 4: REFUGE AND RESOURCE DESCRIPTION 

 

Geographic/Ecosystem Setting 

Howland Island, located at approximately lat. 0o49’ N. and long. 176o38’ W is a northwestern 

outlier of the Phoenix Archipelago and is included in the Central Pacific subregion of the 

Polynesian Region of the Pacific Basin. This subregion, the largest of four in the Polynesian 

Region, is the most remote part of the tropical Pacific and includes only low-lying reef islands, 

atolls, and submerged reefs. Vegetation patterns are determined by the highly variable but 

normally low rainfall levels found along the Equator in the central Pacific. In turn, the arid 

weather and ocean circulation patterns impose limits on floating seed plant dispersal strategies. 

Howland falls in the central Pacific dry zone with rainfall less than 40 inches per year, and thus 

"cannot support any forest or closed woody vegetation" (Mueller-Dombois and Fosberg 1998). 

The nearest landmasses are Baker Island 32 nmi to the south, and McKean Island 352 nmi to the 

south southeast. Both islands are also in the Phoenix Islands. The remaining 8 Phoenix Islands 

under the jurisdiction of the Republic of Kiribati are the next closest neighbors to Howland 

Island, up to 480 nmi to the southeast. The next closest landmasses outside the Phoenix Islands 

are the Gilbert Islands, with Beru Island closest to Howland Island at 420 nmi to the southwest. 

Tarawa Atoll, the capitol of the Republic of Kiribati, is 600 nmi to the west in the central Gilbert 

Archipelago. 

Climate 

General Climate and Related Oceanographic Conditions in the Central Equatorial 

Pacific 

The climate associated with Howland Island can be generalized as being arid, warm, and tropical 

with moderate breezes and light to moderate rainfall. Although differences in climate exist 

among the islands, climate monitoring stations are not readily available in the equatorial Pacific. 

Consequently, site-specific data is lacking for most central Pacific locations, or have only been 

collected for a short period. In order to describe the weather conditions on Howland Island, 

weather monitoring data are taken from historic onsite weather data, or from the closest weather 

monitoring station, located on Kanton Island. 

There are several climatic factors that influence weather on Howland: trade winds, rainfall, and 

oceanic currents. Trade winds are surface winds that typically dominate airflow in tropical 

regions and predominate from the southeast at Howland between 12-17 miles per hour. 

Atmospheric pressure gradients range from high pressure areas located near lat. 30o N. and lat. 

30o S., to the low pressure band located near lat. 5o N., driving both the northeast and southeast 

trade winds. This area of low pressure located just north of the Equator is referred to as the 

‘doldrums’ or the Intertropical Convergence Zone (ITCZ) and lacks these prevailing trade winds 

because they converge and rise upward. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

4-2 Chapter 4 – Refuge and Resource Description 

Solar heating also allows the moist air mass of the ITCZ to rise, thus cooling the air mass and 

producing a band of heavy precipitation several degrees to either side of the ITCZ (Wallace and 

Hobbs 1977). Howland’s position near the Equator places it outside this band of heavy 

precipitation. Changes in these typical patterns occur seasonally and during periodic events 

known as the El Niño Southern Oscillation (ENSO). During an ENSO event, the ITCZ shifts 

south and east toward unusually warmer waters. At Howland, this shift typically leads to lighter 

wind speeds and more rainfall (USFWS 2001, USFWS 1998a, Vitousek et al. 1980). 

Prevailing ocean currents surrounding Howland Island also influence weather patterns on the 

island by moderating the surrounding surface air temperatures. These surface currents roughly 

mimic the direction of the trade winds. Howland is almost always within the flow regime of the 

westward flowing South Equatorial Current. 

Howland Island also lies in the path of the subsurface easterly flowing Equatorial Undercurrent 

(EUC) also referred to as the Cromwell Current. As the EUC strikes the submerged western 

slopes of Howland Island, nutrient rich waters are deflected upward, enriching the primary 

productivity of the surface waters surrounding Howland. These upwelling waters from the EUC 

are slightly cooler than adjacent sea surface waters and may moderate the effects of localized and 

periodic sea surface warming events. 

Howland Island Climate Data 

 

There is very little weather data available from Howland Island. Weather observations were 

made during the military occupation of Baker and Howland Islands from 1935-1945 (AEC 

1963). However, these military records could not be located within refuge files in Honolulu. A 

single reconnaissance trip to Howland and Baker Islands by the Logistics Planning Group of 

Holmes & Narver INC, for the U.S. Atomic Energy Commission (AEC) in October 1963 

recorded sea water temperatures between 86oF and 87oF (AEC 1963). Air temperatures during 

that time period ranged from 80oF to 94oF with an average of 85oF. Wind speeds during this visit 

averaged 13 miles per hour with a range of 6-23 miles per hour. In winter, the average daily 

range of air temperature is reported as 78-88oF, and during summer the average daily range is 78-

90oF (NOAA 1991). 

The nearest weather station to Howland is at Kanton Atoll, located in the Phoenix Islands at lat. 

02o46’ S., long. 171o43’ W., or roughly 378 nmi southeast of Howland (USFWS 1998a). This 

station reports total annual rainfall is approximately 30 inches with precipitation consistent 

throughout the year (NOAA 1991). Weather data at Kanton support the conclusions of arid 

conditions in the northern Phoenix Islands. 

Global Climate Change 

A continuously growing body of unequivocal scientific evidence has emerged supporting the 

anthropogenic nature of current global climate change. During the 20th century, the global 

environment experienced variations in average worldwide temperatures, sea levels, and chemical 

concentrations. Global air temperatures on the earth’s surface have increased by 1.3°F since the 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4 – Refuge and Resource Description 4-3 

mid-19th century (IPCC. 2007a). Eleven of 12 years from 1995 to 2006 are the warmest on 

record since 1850 (IPCC 2007b). Global water temperatures have increased by 0.31o on average 

in the upper 300 m during the past 60 years since 1948 and changes in ocean heat content have 

penetrated as deep as 3000 meters (Levitus et al. 2005). Subsequently, sea levels rose 

approximately 1.7 mm (0.07 in) ± 0.5 mm/yr during the 20th century (IPCC. 2007a); this rate 

rose dramatically to 3.1 mm (0.122 in) ± 0.7mm/yr since 1993 (IPCC 2007b). 

While the concept of climate change is now widely accepted, the extent and impact of future 

changes as well as the exact source (natural or human induced) remains a debate (OPIC 2000). 

Emerging consensus contends that increasing quantities of greenhouse gases (GHGs) in the 

atmosphere, especially carbon dioxide (CO2), are beginning to affect climate and may be the 

dominant force driving recent warming trends. The amount of GHGs globally has grown due to 

human activities since pre-industrial times, with an increase of 70% between 1970 and 2004 

(IPCC 2007b). Carbon dioxide has increased by about 80% in the same time period. The 

atmospheric concentrations of CO2 and methane in 2005 were 379 ppm3 and 1774 ppb, 

respectively. These amounts greatly exceed concentrations recorded in the global environment 

over the last 650,000 years (IPCC, 2007a). Other emissions and GHGs from human activity 

have enhanced the heat trapping capability of the earth’s atmosphere, causing warmer 

temperatures. Although the increase in carbon dioxide is largely attributed to fossil fuel use, 

land use changes have also increased the amount of cleared land surfaces, thereby reflecting 

more solar radiation (IPCC 2001, IPCC 2007a, IPCC, 2007b). 

Global forecasting models offer a variety of predictions based on different emission scenarios. 

OPIC (2000) suggests that a further increase in GHG emissions could double atmospheric 

concentrations of CO2 by 2060 and subsequently increase temperatures by as much as 2 to 6.5°F 

over the next century. Recent model experiments by the IPCC (2007a) show that if GHGs and 

other emissions remain at 2000 levels, a further global average temperature warming of about 

0.18°F per decade is expected. Sea-level rise is expected to accelerate by two to five times the 

current rates due to both ocean thermal expansion and the melting of glaciers and polar ice caps. 

Consequently, patterns of precipitation and evaporation may be altered. These changes may lead 

to more severe weather, shifts in ocean circulation (currents, upwelling), as well as adverse 

impacts to economies and human health (OPIC 2000, IPCC 2001, Buddemeier et al. 2004, IPCC 

2007a). Hansen, et al. (2008) propose that current models may underestimate the slower 

feedback processes such as ice sheet disintegration, vegetation migration, and greenhouse gas 

release from soils and that these factors may come into play in this century. These changes will 

have a significant effect on the national wildlife refuges in the tropical Pacific. The changing 

global environment and the implications this may have for ecological and geological processes in 

the Central Tropical Pacific are important considerations for future management of trust 

resources there. The four areas of impact linked to global climate change that may have the 

greatest potential effect on Howland Island NWR and its wildlife are sea level rise, weather and 

ocean circulation changes, ecological disruptions and coral bleaching due to increased ocean 

temperature, and oceanic chemical composition change. 

Vitousek (1994) reported, “Changes in both climate and biological diversity are known with less 

certainty than are changes in C02 concentrations, global biogeochemistry or land use.” Because 

temperature is more variable both spatially and temporally than C02 concentration, it is difficult 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

4-4 Chapter 4 – Refuge and Resource Description 

to separate human-caused vs. natural background variation. However, it is certain that increasing 

concentrations of C02 and other greenhouse gasses will cause increasing climate change 

(Vitousek, 1994). 

The equatorial locale for Howland places it near the path of anomalous water current and surface 

wind conditions during ENSO events, but the paucity of weather and oceanographic data at 

Howland renders it difficult to assess the impacts and trends of global climate change at the 

island. The upward deflection of cool subsurface waters into shallow water by the upwelling 

effects of the EUC further complicates an assessment of climate change effects, because this 

phenomenon has been rarely reported outside of the three equatorial refuges (Howland, Baker, 

Jarvis). 

The insular nature of both the terrestrial and coral reef habitats of Howland will result in the 

same high vulnerability of resident organisms that is seen in range restricted or mountaintop 

species elsewhere (Parmesan 2006). 

Sea Level Rise 

While global temperature is projected to rise by 3.6 to 9oF and sea level to rise by more than 31.5 

inches during the next two centuries, sea levels have fluctuated by an order of 328 feet over the 

past 18,000 years as natural background variation and thawing out from the last ice age 

(Michener et al. 1997). Contributions to sea level rise by climate change are ice-sheet melting, 

alpine glacier melting and thermal expansion of the sea. Sea levels have risen by 4-8 inches 

during the past century (Michener et al. 1997). The Intergovernmental Panel on Climate Change 

(IPCC 2001) predicted a sea level rise of 3.5 inches to 34.6 inches by the year 2100 unless 

greenhouse gas emissions were reduced substantially. They also suggested that continuing 

greenhouse gas emissions could trigger polar ice-cap melting after 2100 accompanied by sea 

level rise greater than 16 feet. More recent modeling indicates that melting could occur faster 

than the IPCC predicted (Overpeck et al. 2006). 

Evidence also suggests that the world’s oceans are regionally divisible with regard to historic 

fluctuations in sea level. Localized variations in subsidence and emergence of the sea floor and 

plate-tectonics activity prevent extrapolations in sea level fluctuations and trends between 

different regions. While researchers in IPCC (2007a) state that water levels in the equatorial 

Pacific are rising at a rate of 1.2 to 2 mm per year, it may not be possible to discuss uniform 

changes in sea level on a global scale, or the magnitude of greenhouse gas-forced changes, as 

these changes may vary regionally (Michener et al. 1997). As an example, tide gauge records on 

the Atlantic coast indicate a sea level rise of 0.06 to 0.16 in/year over the past century, whereas, 

they have indicated a 0.35 to 0.39 in/year increase along the Gulf Coast of the United States 

(Michener et al. 1997). 

Increases in sea level and associated increases in storm surges and storm intensity will affect 

Howland Island. Shoreline erosion and salt water intrusion into subsurface freshwater aquifers 

have been noted throughout the Pacific (Shea et al. 2001). Due to the deep marine slopes 

directly adjacent to Howland Island, increases in sea level could significantly erode shorelines 

and overall island surface area since opportunities for accretion of lands do not exist. Loss of 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4 – Refuge and Resource Description 4-5 

breeding habitat for seabirds, wintering grounds for migratory shorebirds, and habitat for native 

plants, and land crabs are predicted at current rates of sea level rise. 

Ocean Temperature Increases 

Most climate projections suggest that more intense wind speeds and precipitation amounts will 

accompany more frequent tropical typhoon/cyclones and increased tropical-sea surface 

temperatures in the next 50 years (Walther et al. 2002, IPCC, 2007). The third IPCC (2001) has 

concluded, with “moderate confidence” that 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 (IPCC 2001). One model projects a doubling of the frequency of 4-inch-per-day 

rainfall events and a 15–18 percent increase in rainfall intensity over large areas of the Pacific 

(IPCC 2001). The IPCCl (2007) states that it is “more likely than not” that the rise in intense 

tropical cyclones is due to anthropogenic activity. 

Above normal mean sea surface temperatures have been shown to cause bleaching and mortality 

in corals both in nature and in the laboratory with bleaching generally occurring in shallower 

waters (Floros et al. 2004). Coral bleaching, the expulsion of symbiotic zooxanthellae from 

coral polyps and subsequent loss of photosynthetic pigments is the result of both natural and 

anthropogenic stresses. Although corals may pale in response to seasonal increases in sea 

surface temperature, there has been a higher frequency of large scale bleaching events since the 

1980s (Nicholls et al. 2007). The most severe global bleaching event ever recorded occurred in 

1997-98 when over 50 countries showed signs of bleaching (Grimsditch and Salm 2005). Many 

species of coral currently exist in the upper limits of their specific temperature range; thus, an 

increase in average sea surface temperatures (even by 1.8 or 3.6oF) over a sustained period has 

been shown to cause mass bleaching, especially in shallow waters habitats (Grimsditch and Salm 

2005). Other variables have also been implicated in bleaching and mortality events, including, 

extended periods of high temperatures, low wind velocity, clear skies, calm seas, low rainfall, 

high rainfall, salinity changes, high turbidity or acute pollution. Floros et al. (2004) goes on to 

note “The causes of coral bleaching are debatable, but widely thought to be the result of a variety 

of stresses, both natural and human-induced, that cause the degeneration and the loss of the 

colored zooxanthellae from the coral tissues.” 

Bleaching episodes in equatorial islands appear to be linked to the El Niño-Southern Oscillation 

(ENSO). Widespread bleaching events occurred during the El Niños of 1982-83, 1987-88, and 

1997-98 (Buddemeier et al. 2004). During the warm phase of ENSO, or El Niño, sea-surface 

temperatures are usually warm, trade winds weak, and sea level decreases in the western Pacific 

(IPCC 2001, Buddemeier et al. 2004). These combined factors result in a dramatic increase in 

coral bleaching (Buddemeier et al. 2004). While El Niño events have increased in intensity and 

frequency over the past decades, some longer-term records have not found a direct link to global 

warming (Cobb et al. 2003) and do not predict significant changes in El Niño; however, they do 

suggest an evolution toward more “El Niño-like” patterns (Buddemeier et al. 2004). Most 

climate projections reveal that this trend is likely to increase rapidly in the next 50 years 

(Walther et al. 2002). 
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4-6 Chapter 4 – Refuge and Resource Description 

Most climate projections suggest that more intense wind speeds and precipitation amounts will 

accompany more frequent tropical typhoon/cyclones and increased tropical-sea surface 

temperatures in the next 50 years (Walther et al. 2002, IPCC. 2007a). The third IPCC (2001) 

has concluded, with “moderate confidence” that the intensity of tropical cyclones is likely to 

increase by 10 to 20 percent in the Pacific region when atmospheric levels of CO2 reach double 

pre-industrial levels (IPCC 2001). One model projects a doubling of the frequency of 4 inches 

per day rainfall events and a 15-18 percent increase in rainfall intensity over large areas of the 

Pacific (IPCC 2001). The IPCC (2007a) states that it is “more likely than not” that the rise in 

intense tropical cyclones is due to anthropogenic activity. 

If coral reef ecosystems do not acclimate to projected thermal stresses, more frequent bleaching 

events and widespread mortality will occur. The ability of coral reef ecosystems to withstand 

these impacts will depend on the extent of degradation from other anthropogenic pressures and 

the frequency of future bleaching events (Nicholls et al. 2007). 

Field observation of corals at Baker, Howland, and Jarvis during five separate expeditions from 

2000-2006 indicate that corals may be recovering from a bleaching event that took place during 

the previous few years (1997-1998). Corals continued to increase in cover and size based upon 

observations during all subsequent (post 2000) visits, including those at permanent transect sites 

(Maragos 2008; Maragos et al. 2008a & 2008b, Miller et al. 2008). Although coral bleaching 

was predicted to occur at Jarvis in 2003 based upon NOAA satellite based temperature and wind 

data, no evidence of bleaching was reported there during the early 2004 and 2006 visits 

(Maragos 2000-2006, unpublished data). One possible explanation is that the cool upwelling 

waters of the EUC are buffering the effects of the otherwise warmer seawater temperatures at the 

island. 

Tudhope (2000) sampled 6 cores obtained from 2 large, 3-4 meter Porites coral heads at Jarvis in 

1999 to track sea surface temperature and coral growth rates over several or more decades using 

stable oxygen isotope as a measure of Sea Surface Temperature. He found a good correlation 

between this measure and the NINO3.4 Index, which is one of the most widely used and reliable 

indicators of the status of ENSO. The results of their work at Jarvis and at four other tropical 

sites in the Line and Cook Islands contributed to demonstrating linkages between the tropics and 

the North Pacific over hundreds of years (D’arrigo et al 2005). Hawaii Undersea Research 

Laboratory (HURL) submersible dives at Jarvis in July 2005 revealed many deep-water corals, 

and samples of some were taken for climate change and paleo-climate analyses. The results of 

these analyses are not yet available. 

Oceanic Acidification and Atmospheric Chemistry 

Glacial and interglacial periods in the Earth’s history, as measured from deep Antarctic ice cores, 

reveal cyclical fluctuations in the concentration of global CO2. However, recent increases fall 

outside the range of peak prehistoric CO2 levels. Current atmospheric CO2 concentrations are at 

their highest levels in more than 160,000 years, with humans emitting 25 billion tons of CO2

annually (Buddemeier et al. 2004). The rate of increase is also five to ten times more rapid than 

any of the sustained changes in the ice-core record (Vitousek 1994). The higher the 

concentration of CO2 in the atmosphere, the greater the amount of CO2 dissolved in the surface 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4 – Refuge and Resource Description 4-7 

ocean. When CO2 dissolves in seawater it forms carbonic acid (H2CO3), a weak acid that 

releases additional hydrogen ions and increases the acidity of the ocean. In order to buffer this 

acidity, the hydrogen ions react with carbonate (CO3

2-) ions and convert them to bicarbonate ions 

(HCO3

-

). However, this buffering ability has diminished due to the rapid rising CO2

concentrations and the global seawater pH has decreased by 0.1 units since 1750, with regional 

variations (Royal Society 2005, IPCC 2007). Models predict that over the 21st century, average 

surface ocean pH will continue to fall between 0.14 and 0.35 units (IPCC 2007a). 

Increased atmospheric CO2 and ocean acidification affect marine organisms. As the 

concentration of carbonic acid and bicarbonate ions rises, the concentration of carbonate ions 

decreases. Many corals and marine organisms use calcium (Ca2+) and carbonate ions from 

seawater to secrete CaCO3 skeletons (Buddemeier et al. 2004, IPCC 2007). Change in CO2

levels will increase the partial pressure of CO2 in seawater, thus reducing the over-saturation of 

aragonite, a form of calcium carbonate that is the major building block for coral reefs (Vitousek, 

1994). On a transect in the Pacific Ocean that ran very near Jarvis, Feeley et al. (2004) show that 

the aragonite saturation horizon is shallow and is shoaling compared to the pre-industrial 

aragonite saturation horizon. This reduces the width of the zone in which marine organisms have 

optimum aragonite concentrations for shell-building. The result of this is uncertain but is 

thought to reduce the rate at which corals can deposit calcium carbonate, thus reducing the rate at 

which coral reefs will be able to keep up with any increases in sea level. A lowered calcification 

rate means calcifying organisms (corals) may grow skeletons at a slower rate, lower density, 

and/or decreasing strength. Thus, changes in global seawater chemistry reduce the ability of 

corals to successfully compete for space and increase susceptibility to breakage (Grimsditch and 

Salm 2005). In addition to changes in the carbonate system, changes in ocean chemistry may 

affect the availability of nutrients and toxins to marine organisms. 

It should also be noted that chemical composition changes in the atmosphere may also affect 

terrestrial ecosystems. For instance, the quantity of nitrogen available to organisms affects 

species composition and productivity. Increase in nitrogen can alter species composition by 

favoring those plant species that respond to nitrogen increases (Vitousek, 1994). Increased 

carbon dioxide can also affect photosynthetic rates in plants, change levels and characteristics of 

secondary compounds in plant tissues, change plant species composition, lower nutrient levels, 

and lower weight gain by herbivores. 

Geology and Soils 

Howland Island is a low-lying, nearly level island with a slightly depressed central area 

surrounded by a narrow shallow fringing reef. The submarine slopes descend steeply to great 

depths beyond the fringing reefs (Maragos et al. 2008a). Surface deposits on the island consist 

of calcareous sands and coral rock. Soil texture is coarse and not easily compacted. The central 

depression is likely the result of the combined effects of guano mining more than a century ago 

and wave action depositing sand rocks and boulders around the island’s fringe. The island was 

likely formed as a result of submarine volcanic activity and changes in the earth’s crust caused 

by continental tectonic plate movement, including emergence of a high volcanic island, its later 

subsidence, reef accretion, and its gradual northwesterly drift away from the East Pacific Rise 

over the past 50 to 80 million years. Although scientists since Darwin (1842) have been 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

4-8 Chapter 4 – Refuge and Resource Description 

pondering seamount, island, and atoll formation in the Pacific, the specifics of how Howland 

Island was formed have not been investigated, although they would likely follow the general 

sequence first postulated by Darwin. 

The dominant theory of atoll formation states that islands form in deep tropical oceans as a result 

of underwater volcanoes that grow to the surface to form high volcanic islands, giving coral 

polyps a foundation to grow upon and form reefs fringing the island. In the Pacific most of these 

volcanoes originated at the East Pacific Rise or at hotspots (Maragos et al. 2008a). In time, the 

volcano becomes dormant, and its mass pushes down on the earth’s crust causing it and its island 

to subside and shrink in size, while its fringing reefs continue to grow upward and maintain 

proximity to the sea surface. Coral reefs, originally fringing the edges of a large island, may 

become barrier reefs around larger islands outlining the contour of the original coastline, with a 

lagoon occupying the space vacated by the shrinking island. Eventually, further subsidence 

causes the island to disappear completely from the lagoon leaving behind an atoll. However, for 

small islands such as Howland, lagoons may not have formed at latter stages, and continued 

subsidence has left only a small low reef island in its wake. Based upon deep drilling through 

the atolls in the Marshall Islands in the 1940s and 1950s, it is believed that these processes 

occurred well before the beginning of the last ice age (approximately 115,000 years ago) and 

encompassed more than 50 to 60 million years and up to several thousand feet of reef growth 

equal to the degree of subsidence over that time span. In addition, it is hypothesized that 

changes in sea level associated with the end of the last ice age and the deposition of highly 

permeable coralline limestone (calcium carbonate) derived from the remains of marine 

organisms likely contributed to the carbonate platform that characterizes the contemporary 

geologic structure of Howland Island. 

The entire western or leeward beach of the island is sandy and low, while the eastern side, 

constantly pounded by waves generated by the trade winds, is higher, more abrupt, and covered 

with coral rubble and sandstone slabs. There is no pronounced beach crest or central basin (dry 

lagoon) typically found on some larger low-lying reef islands. Soils of low-lying atolls in the 

Pacific frequently consist of accumulations organic matter, guano, pumice, or other transported 

material on top of a calcareous sand or limestone substratum (Morrison 1990). The soil of 

Howland Island is composed of coral fragments and light brown coral sand with a low 

percentage of organic matter. 

Hutchinson (1950) concluded that phosphates accumulate preferentially on islands, such as 

Howland, Baker, and Jarvis, that are situated in climatic dry belts used by large populations of 

seabirds. Deposits of phosphate-rich soils have formed over time from guano deposited on the 

island by fish-eating seabirds. Mild acids formed from the decomposition of organic matter 

carry the guano downward in the soil to limestone soil layers where acids are neutralized and 

calcium phosphate is accumulating from the chemical changes. In addition, when guano-beds 

are exposed to rain their soluble constituents are removed and the insoluble matter is left behind. 

The soluble phosphates washed out of the guano may also become fixed to the coral sand and 

limestone by the process described above. The calcium phosphate rocks and soil occur among 

the sedimentary strata and were the principal sources of phosphate targeted for commercial 

fertilizer use during the guano mining period between 1861 and 1891 (see Chapter 3.15). Even 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4 – Refuge and Resource Description 4-9 

after the guano mining era, the soil profile still contained heavy guano deposits (Christophersen 

1927). 

Hydrology 

No information is available on the subsurface hydrology of Howland Island. However, its small 

size and prevailing arid rainfall conditions would not likely result in the formation of a drinkable 

groundwater lens. During staff visits to Howland, potable water is carried in containers to the 

island for short staff visits, and could be produced on site via reverse osmosis technology for 

prolonged staff visits, just as it is now produced for permanent field stations at other remote 

Pacific Island NWRs.

Air and Water Quality 

Due to the lack of human presence, oceanic and air quality are expected to be good and lacking 

in pollutants. Vapors from abandoned spilled fuel storage drums left behind during the World 

War II era are likely to be confined to the immediate vicinity of the drums and have probably all 

volatized. The acoustic environment at Howland is completely natural without any 

anthropogenic noise except during periodic staff visits. On the island, dominant natural sounds 

include the wind, calls of seabird and shorebirds, and seawater lapping on the shoreline with 

wave action crashing further offshore on the outer reef margin. Underwater the dominant sounds 

are wave action and surge striking the reef slopes and the sounds of thousands of feeding and 

moving invertebrates and fish. 

Environmental Contaminants 

Fuel storage drums left behind by the U.S. military during the World War II era contained 

residual aviation and motor fuel. In 1987, the U.S. Army Corps of Engineers, sponsored by 

funds from the Defense Environmental Restoration Program, organized an expedition to 

Howland and Baker to dispose of the fuel by burning it on-site while in the drums (H. Takemoto, 

per. comm.). However, the Corps efforts did not completely consume the fuel, and the burning 

left toxic residues in many of the drums and surrounding soils (Lee Ann Woodward, USFWS, 

per. comm.). At Howland Island, there were only a handful of these drums. The total area 

affected by the drums and contaminated soil is estimated at 26 yd2

. The main source of 

contamination is rusting steel and iron from various machine parts and drums. 

Terrestrial Vegetation and Habitats 

Howland Island is vegetated with grasses, herbaceous plants, and shrubs. Areas devoid of 

vegetation occur along exposed beach and shoreline areas. Only strand species able to survive 

long periods of drought and irregular opportunities to reproduce during the infrequent wet years 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

4-10 Chapter 4 – Refuge and Resource Description 

of the ENSO persist here. By 1924 when Christophersen (1927) did the first thorough survey of 

Howland Island’s vegetation, there had already been approximately a century of visits by 

Europeans and guano miners. Despite this traffic and the potential for introductions, 

Christophersen found a very depauperate flora consisting of five native species (Lepturus repens, 

Boerhavia sp., Portulaca lutea, Tribulus cistoides, and Cordia subcordata) and one that had 

probably been accidentally introduced (Portulaca oleracea). Since then at least 4 more species 

were intentionally introduced (Cocos nucifera, Casuarina sp., Pandanus sp., and Coccoloba 

uvifera) and at least 7 as wave carried adventives or additional accidental introductions by 

humans (Digitaria pacifica, Sophora tomentosa, Sida fallax, Scaevola taccada, Suriana 

maritima, and Tournefortia argentea) for a contemporary total of only 16 species (see Appendix 

B). On a short visit in 2004, only nine species of plants were located (Flint and Eggleston 2004). 

It is likely that seeds of additional species are regularly washing up on the beach and then dying 

back as conditions become too dry or high surf washes the plants away. Table B-3, Appendix B, 

lists all the plant species of Howland Island, collections or first observations, and most recent 

information about current presence or absence.

The structure of the plant community is grassland and low forbs cover. A single grove of kou 

(Cordia subcordata) in shrub growth form reaching 15 feet high grows in the interior. The kou 

along with tree heliotrope (Tournefortia) and naupaka (Scaevola) bordering the beach serve as 

important nesting and roosting habitat for the red-footed booby and cover for wintering bristlethighed curlews. Great frigatebirds and white terns also prefer to nest above the ground on the 

few shrubs available, but all the other species nest directly on the ground. Shrubs and rock piles 

also provide shade and daytime cover for the numerous land hermit crabs, Coenobita perlatus

that inhabit Howland Island. 

Terrestrial Wildlife 

Seabirds, shorebirds, lizards, vegetation, insects, crabs, and invasive rats and feral cats have been 

observed and studied at Howland Island during the current century. The Service subsequently 

eradicated all rats and cats from the island to allow repopulation by several nesting seabird 

species and greater use by all remaining indigenous terrestrial species. 

Seabirds and Land Mammals 

There are no native land mammals at Howland Island. Numerically dominant vertebrates are 

migratory seabirds and shorebirds. Howland Island falls into the North American Bird 

Conservation Region (BCR) 68 along with all the other island territories of the United States. 

Earliest ornithological surveys at Howland Island took place long after the introduction of the 

Polynesian rat (Rattus exulans) so the composition of the avian community prior to human 

contact can only be surmised by looking at other islands in the Phoenix Archipelago that did not 

suffer the invasion of rats. The findings of the ornithologist on the Whippoorwill Expedition of 

1924 are the only comprehensive ornithological records prior to 1963, when scientists from the 

Smithsonian Institution visited eight times between 1963 and 1965. Table B-4 in Appendix B 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4 – Refuge and Resource Description 4-11 

lists species and estimates of numbers for seabird species on all staff visits since 1973. Munro 

(1924) found 11 species of seabirds breeding in 1924. 

Several avian species are listed by various authorities as species of concern. Of note, seabird 

species listed by IUCN as Vulnerable include Phoenix petrel (Pterodroma alba) and the 

Polynesian storm-petrel (Nesofregetta fuliginosa), both of which probably occurred at Howland 

Island prior to the introduction of rats. The Phoenix petrel is also considered a bird of National 

Conservation Concern by the Service and the Phoenix petrel and Polynesian storm-petrel are 

classified as highly imperiled in the Pacific Region Seabird Conservation plan. The blue noddy 

(Procelsterna cerulean) and lesser frigatebird (Fregata ariel) are included in the category of 

High concern in that document (USFWS 2005). 

Cats were introduced during 1935 to 1942 resulting in decreased abundance and diversity of 

seabirds species breeding at Howland by 1963 (Sibley et al., 1965). After feral cats were 

removed in 1986, 11 seabird species are again breeding and 2 Procellariform species (Wedgetailed Shearwaters Puffinus pacificus and an unidentified storm-petrel) that likely bred there prior 

to rat introduction have been seen on the ground in the colony presaging re-colonization. The 

three most numerous breeding species at Howland are the lesser frigatebird (Fregata ariel) [a 

BCC or bird of conservation concern in BCR (Bird Conservation Region) 68 and listed as a bird 

of High concern at the Regional level], masked booby, (Sula dactylatra), and sooty tern 

(Onychoprion fuscatus). Table B-4 also provides the breeding seabird species at Howland. 

Shorebirds 

Species occurrence and counts of the eight migratory shorebird species recorded from Howland 

Island are displayed in Table B-4, Appendix B. The four most common migrants wintering at 

Howland are ruddy turnstone (Arenaria interpres), Pacific golden plover (Pluvialis fulva), 

bristle-thighed curlew (Numenius tahitiensis), and wandering tattler (Heteroscelus incanus). Of 

these, the bristle-thighed curlew and the Pacific golden plover are considered species of High 

Concern in the national conservation priority scheme for shorebirds (Engilis and Naughton 

2004). All of the species mentioned above except wandering tattler are labeled as high concern 

in the Regional shorebird plan and Bristle–thighed Curlews and Pacific Golden Plovers are Birds 

of Conservation Concern in BCR 68. These islands provide crucial wintering habitat and may 

serve as rest-stops for arctic-breeding shorebirds wintering farther south in the Pacific Islands. 

Reptiles 

Only two species of terrestrial reptiles have been reported from Howland Island: snake-eyed 

skink (Cryptoblepharus peocidopleurus) and mourning gecko (Lipidodactylus lugubris). Both 

species were first reported by Hague in 1862, and served as alternate prey for cats when they 

were present on Howland Island. Only the snake-eyed skink has been observed during recent 

visits to Howland. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

4-12 Chapter 4 – Refuge and Resource Description 

Invertebrates (crabs and insects) 

Howland Island is home to a large number of the land crab, Coenobita perlata. Their large 

biomass plays a dominant role in terrestrial food webs on the island where they consume a wide 

variety of organic matter of all types. Other terrestrial arthropods and mollusks are very poorly 

known. The entomologist Edward L. Caum visited Howland Island in 1924 and a number of 

other naturalists collected insects on subsequent trips but there are no published accounts or lists 

until Ashley Browne of the University of Hawaii visited in 1939 and published a short note 

listing 3 species of insects that were collected (Browne 1940). Recent observations, but not 

collections, during staff visits by Service biologists include house flies, small ants, moths, 

millers, butterflies, and spiders. 

Kirkpatric and Rauzon (1986) compared food habits of feral cats at Howland and Jarvis Islands. 

Although there were crickets, cockroaches and tenebrionid beetles in the stomach of Jarvis cats 

(n=73), no insect remains were found in a smaller sample (n=5) of Howland Island cats. 

Marine Habitats, Fish, and Wildlife 

Previous Surveys 

Before regular marine assessment and monitoring efforts began in 2000, marine scientists visited 

Howland to collect fish, corals, and perhaps other reef life, but there were no systematic surveys 

of the reefs in the literature. Extensive collections of reef fishes were accomplished by Fowler 

(1927), anon. (1950), Helfrich (1962), and Wass (1966). More recently, the Smithsonian 

Institution Pacific Ocean Biological Survey (SIPOBS), and others in Mundy et al (2002) 

continued this work. The dominant reef life studied during post-1997 expeditions include: 

benthic algae (Peter Vroom, Kim Paige per. comm.), corals and anemones (John Schmerfeld, Jim 

Maragos, Greta Aeby and Jean Kenyon per. comm.), other reef invertebrates (Scott Godwin, 

Dwayne Minton, and Robin Newbold per. comm.), and reef fishes (Ed DeMartini, Bruce Mundy, 

Brian Zgliczynski, Brian Green, Richard Wass, Alan Friedlander, Stephanie Holzwarth, and 

others per. comm.). 

Five sets of recent surveys through early 2006, have been accomplished in cooperation with the 

NOAA Pacific Islands Fisheries Science Center (PIFSC) and their research vessels (Townsend 

Cromwell, Oscar Elton Sette, and Hi‛ialakai), primarily through the sponsorship of the Center’s 

Coral Reef Ecosystem Division (CRED) (R. Brainard, per. comm.). The surveys since 2000, are 

of several types including oceanographic data collection, towed diver surveys, rapid ecological 

assessments (REA) at stationary sites, and collections of marine animals and plants for 

identification and description in the lab. The Service, with assistance from CRED established 

three permanently marked transects to document trends in corals and some macro-invertebrates 

over time since 2000. 

Despite these intense efforts, several important habitats at Howland have not been adequately 

surveyed. Shallow reef terraces off both the southern and northern horns of the island are bathed 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4 – Refuge and Resource Description 4-13 

in strong, turbulent and at times unpredictable currents, preventing REAs at both ends. In 

addition, the windward reefs were inaccessible during most staff visits because of heavy 

tradewind generated waves close to the reef and onshore winds that would push the dive skiffs 

too close to the reefs. Moreover, due to safety concerns, dives have generally been limited to 

depths of 65 feet and one hour duration. Because of these limitations, some important habitats 

are still poorly sampled and deep slope habitats (164 to 3,281 ft) within the refuge remain mostly 

unexplored, except for early 2006 acquisition of high resolution bathymetry of Howland from 

Multi-BeamTM surveys (S. Ferguson, per. comm.) and substantial oceanographic data (R. 

Brainard, per. comm.). 

At the time of this CCP, data from coral, other marine invertebrates, algae, and fish surveys were 

available for review and compilation, and Maragos et al. (2008a) and Miller et al. (2008) provide 

updated compilations based upon site visits through 2006. 

Submergent Habitats 

Howland’s shallow marine benthic habitats consist of fringing reef crests, shallow back reefs, 

steep fore reefs, spurs-and-grooves, and small reef terraces. The last two habitats are restricted 

to the windward (east side) of the island. In addition, a shallow short channel was blasted 

through the narrow fringing reef during the pre-World War II era to facilitate small boat access 

between the shoreline and ocean. The deep slope habitats below depths of 65-98 feet have not 

been surveyed by divers, although remotely operated vehicles (ROVs) have been launched to 

collect video- and camera-based data. Pelagic habitats occur further offshore beyond the 

influence of upwelling and nearshore oceanographic processes. Nearshore habitats include 

distinct upwelling zones off the west side of the island; oligotrophic waters off the windward 

reefs; and turbulent rip currents and possibly mesoscale eddies off the north and south ends of 

the island. The PIFSC has conducted oceanographic research off the island to contrast the 

differences between nutrient rich upwelling zones and the ambient nutrient-poor ocean 

conditions outside areas of upwelling currents. 

Reef Life 

The marine ecosystem of Howland remains mostly undisturbed and pristine. Multitudes of 

marine species inhabit and visit the shallow water habitats that surround Howland Island, several 

of which are listed or ranked by various authorities as being imperiled. Of note, the giant clam 

(Tridacna maxima) is abundant at Howland Island and is listed under the Convention on 

International Trade in Endangered Species of Wild Fauna and Flora (CITES). The humphead 

wrasse (Cheilinus undulatus) is also listed under CITES and designated as Endangered by the 

International Union for the Conservation of Nature (IUCN) and occurs in the nearshore waters of 

Howland. Nearshore waters are also home to two endangered species of sea turtles and sea 

mammals that have yet to be studied. Taken collectively with the terrestrial habitat, the coral 

reefs are an integral component of the overall health of the Howland Island ecosystem. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

4-14 Chapter 4 – Refuge and Resource Description 

Corals 

To date (January 2006), 97 species and 30 genera of corals and a few other large anthozoans 

have been reported from Howland reefs (Table B-1, Appendix B). Additional range extension 

records from collections and photographs may also exist. This compares to 92 species and 38 

genera reported at neighboring Baker, only 32 nmi to the south. These totals are in the range of 

other atolls in the Phoenix Islands (Kanton in Maragos and Jokiel 1978); lower than, or 

comparable to similarly sized islands further to the west (Marshalls, Samoa); and higher than, or 

comparable to similarly sized islands to the east (Hawaii, Line Islands). There is no credible 

explanation for the higher genera totals at Baker compared to Howland, except that geographic 

isolation may be causing differential recruitment success. Supportive of this hypothesis is that 3 

of the genera reported at Howland were missing at Baker, and 11 of the genera at Baker were 

missing from Howland. All sides of Baker have been surveyed compared to just the west and 

southeast side of Howland, and this may also be contributing to the higher generic diversity at 

Baker and discrepancies between the two reefs (Maragos per. comm.). 

Corals are generally in healthy condition at Howland, with the eight most abundant genera there 

also the same as the eight most abundant found throughout the Line, Phoenix, and eastern 

Samoan Islands: Acropora, Favia, Fungia, Leptoseris, Montipora, Pavona, Pocillopora, and 

Porites. Coral disease prevalence and predation on corals are also low (G. Aeby and B. Vargas 

per. comm.). Although dead standing corals reported during the summer of 2000 were likely 

indicative of a coral bleaching event a few years earlier, no major bleaching event has been 

reported during the 2000-2006 surveys, and corals are presumably recovering rapidly during the 

period. Of future possible concern is the rapid expansion of the corallomorpharian Rhodactis 

howesii at Howland between the 2004 and 2006 staff visits near the historic boat anchorage. 

This species has increased to “invasive” proportions at Baker and Palmyra Atoll NWR where it 

appears to be stimulated by dissolved iron from corroding anchors or shipwrecks. Thus, it raises 

the possibility of corroding steel or iron being present at Howland Island which was observed in 

the form of chains and anchors at the western boat anchorage 

Nearshore Fish 

Approximately 324 species of reef fish are known from Howland reefs (Mundy et al. 2002; 

Table B-2, Appendix B). This compares with 247 species from nearby Baker. Moreover, ten 

families of fish reported at Howland have not been reported from Baker, and six minor families 

from Baker have not been reported from Howland. Of interest is the presence of several species 

of goby and scorpion fish families at Howland and the lack of these families at Baker. Possible 

explanations for these differences may be that sampling and survey intensities may be 

insufficient and different between the two islands, or that geographic isolation may result in 

differential recruitment rates between the two islands. As noted earlier, not all habitats at 

Howland have been surveyed to the same degree as those at Baker. 

Reef fish populations appeared healthy and diverse with little indication of unauthorized harvest 

(Maragos, USFWS, per. comm.). However, during 2000 surveys Maragos noted many small 

sharks and no larger sharks at both Howland and Baker. In contrast, numerous small and some 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4 – Refuge and Resource Description 4-15 

large sharks were at both locales by 2004 and 2006. Because “shark finning” (the catching of 

sharks only to remove their fins for sale) is a growing concern in the Pacific and other oceans, it 

is possible that a pre-2000 harvest of sharks at Howland resulted in the absence of larger adult 

sharks in 2000. Larger sharks and additional recruitment by 2004 and lack of subsequent shark 

fin harvest in the area may explain the more normal size distribution in sharks observed in 2004 

and 2006 (Maragos et. al 2008b). 

The fact that the disparities for the coral genera did not track in the same direction as for the fish 

families (more coral genera at Baker versus more fish families at Howland), reinforces the 

hypothesis of geographic isolation may lead to biodiversity heterogeneity based on chance and 

differential recruitment success. Geographic isolation would require both corals and reef fish to 

rely more on local recruitment vis-à-vis external recruitment. The latter would likely play a 

much larger role where reefs and islands are larger and closer together and result in similar 

biodiversity characteristics. 

Marine Mammals 

On most staff visits to Howland Island, a group of ~approximately 40 bottle-nosed dolphins 

(Tursiops truncatus) appear as the ship approaches the island. In 1993, individuals from this 

group were observed preying on rainbow runners (Elagatis bipinnulatus) that were sheltering 

under the vessel. Formal quantitative surveys of marine mammal distribution and abundance 

have not been undertaken at the refuge. Historically, sperm whales (Physeter macrocephalus) 

were caught near Howland in the nineteenth century (Townsend, 1935, cited in Sibley and 

Clapp, 1965). 

 

Pelagic Wildlife 

Oceanic pelagic fish including skipjack, yellowfin tuna, and blue marlin prefer warm surface 

layers, where the water is well mixed by surface winds and is relatively uniform in temperature 

and salinity. Other pelagic species, such as albacore, bigeye tuna, striped marlin, and swordfish, 

prefer cooler, more temperate waters, often meaning higher latitudes or greater depths. In fact, 

the largest proportion of the tuna catch in the Pacific Ocean originates from the warm pool, even 

though paradoxically this is a region of low primary productivity. Tuna movement to upwelling 

zones at the fringe of the warm pool may be key in resolving this apparent discrepancy between 

algal and tuna production. Preferred water temperature often varies with the size and maturity of 

pelagic fish, and adults usually have a wider temperature tolerance than subadults. Thus, during 

spawning, adults of many pelagic species usually move to warmer waters, the preferred habitat 

of their larval and juvenile stages. 

Large-scale oceanographic events (such as El Niño) change the characteristics of water 

temperature and productivity across the Pacific, and these events have a significant effect on the 

habitat range and movements of pelagic species. Tuna are commonly most concentrated near 

islands and seamounts that create divergences and convergences, which concentrate forage 

species, and also near upwelling zones along ocean current boundaries and along gradients in 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

4-16 Chapter 4 – Refuge and Resource Description 

temperature, oxygen, and salinity. Swordfish and numerous other pelagic species tend to 

concentrate along food-rich temperature fronts between cold upwelled water and warmer oceanic 

water masses (NMFS 2001). These frontal zones also function as migratory pathways across the 

Pacific for loggerhead turtles (Polovina et al. 2000). Loggerhead turtles are opportunistic 

omnivores that feed on floating prey such as the pelagic cnidarian, Vellela vellela (“by the wind 

sailor”) and the pelagic gastropod Janthina spp., both of which are likely to be concentrated by 

the weak downwelling associated with frontal zones (Polovina et al. 2000). 

The estimated hundreds of thousands of seabirds breeding at national wildlife refuges in the 

Central Pacific Ocean are primarily pelagic feeders that obtain the fish and squid they consume 

by associating with schools of large predatory fish such as tuna and billfish (Fefer et al. 1984, Au 

and Pitman 1986). These fish―yellowfin tuna (Thunnus albacares), skipjack tuna (Katsuwonus 

pelamis), mahimahi (Coryphaena hippurus), wahoo (Acanthocybium solandri), rainbow runner 

(Elagatis bipinnulatus), broadbilled swordfish (Xiphias gladius), and blue marlin (Makaira 

indica)―are apex predators of a food web existing primarily in the epipelagic zone. While both 

the predatory fish and the birds are capable of foraging throughout their pelagic ranges (which 

encompass the tropical Pacific Ocean), the birds are most successful at feeding their young when 

they can find schools of predatory fish within easy commuting range of the breeding colonies 

(Ashmole 1963, Feare 1976, Flint 1991). Recently fledged birds, inexperienced in this complex 

and demanding style of foraging, rely on abundant and local food resources to survive while they 

learn to locate and capture prey. Some evidence from tagging studies done by Itano and Holland 

(2000) suggests both yellowfin and bigeye tuna aggregate around island reef ledges, seamounts, 

and fish aggregating devices and are caught at a higher rate here than in open water areas. 

Yellowfin tuna in Hawai‘i exhibit a summer island-related inshore-spawning run (Itano 2001). 

Ashmole and Ashmole (1967) and Boehlert (1993) suggest that the circulation cells and wake 

eddies found downstream of oceanic islands may concentrate plankton and therefore enhance 

productivity near islands. Higher productivity, in turn, results in greater abundance of baitfish, 

thus allowing higher tuna populations locally. Johannes (1981) describes the daily migrations of 

skipjack tuna and yellowfin tuna to and from the waters near islands and banks. The presence of 

natural densities of these tunas within the foraging radius of seabird colonies enhances the ability 

of birds to provide adequate food for their offspring (Ashmole and Ashmole 1967; Au and 

Pitman 1986, Diamond 1978, Fefer et al. 1984.) Wake eddies also concentrate the larvae of 

many reef fishes and other reef organisms and serve to keep them close to reefs, enhancing 

survivorship of larvae and recruitment of juveniles and adults back to the reefs. For at least three 

of the seabird species breeding in the Central Pacific Ocean (brown noddies, white terns, and 

brown boobies), large proportions (33 to 56 percent) of their diets originate from the surrounding 

coral reef ecosystem, in other areas where their diet has been studied (Ashmole and Ashmole 

1967; Harrison et al. 1983; King 1970; Diamond 1978). 

Threatened and Endangered Species 

Species listed under the Endangered Species Act documented at Howland include the threatened 

green turtle (Chelonia mydas) and the endangered hawksbill turtle (Eretmochelys imbricata). 

The Service shares responsibility with NMFS for these species. Both species have been 

observed and photographed foraging in the shallow water near the island. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4 – Refuge and Resource Description 4-17 

Invasive Species 

Human activities at Howland Island have resulted in various non-native species being introduced 

including the house cat (Felis catus), the Polynesian rat (Rattus exulans), various ant and 

cockroach species, and plants such as pandanus, ironwood, coconut palm, sea grape, ilima, 

Portulaca oleracea, and Pacific crabgrass. Feral cats were introduced in 1937 and finally 

eliminated in 1986. The rats were documented as early as 1854 and in many accounts were 

described as extremely abundant. Sometime after 1938, they were eliminated and have not been 

recorded since. Of the plants introduced by humans, only the Pacific crabgrass seems to have 

persisted. Although not achieving invasive proportions at Howland, the corallimorph Rhodactis 

howesii is already invasive at Baker and Palmyra and has the potential of becoming invasive at 

Howland and Kingman Reef especially near sites of metallic ship debris. 

Wilderness Resources 

Howland remains in a wilderness state in terms of its biota, seascape, and landscape except for 

the collection of abandoned fuel drums, excavations, and pits left behind from the guano mining 

era, and a small section of the reef blasted for a boat passage during the guano mining era. There 

was a makeshift airfield constructed in preparation for Amelia Earhart’s last flight but today it is 

undistinguishable on the ground. A stone monument in her honor currently exists on the island. 

Abandoned anchors and chain may occur near the western boat passage. However, the collective 

contribution of these detractions is minor compared to the otherwise overwhelming wilderness 

character of the island and surrounding reefs. Additional wilderness information and evaluation 

are covered in greater detail in Appendix F. 

Archaeology and Paleontology 

Polynesians visited Howland Island prior to its discovery by European navigators (Hague 1862). 

Hague is the first to describe artifacts left by these earlier inhabitants. Among the artifacts 

described were excavations and mounds near the kou thicket in the center of the island, 

fragments of a canoe, footpaths, a blue bead, remains of a hut, and a human skeleton. The 

largest of the excavations was "several hundred feet long, and about one hundred feet wide, and 

ten or fifteen feet deep... [on each side of which the]... sand gravel [was] carefully banked up and 

kept in its place by walls laid up of coral stone.” 

Members of the Whippoorwill Expedition reexamined the ruins in 1924. Kenneth Emory (1939) 

remarked that the central excavation was of a sort commonly used in the Tuamotu Archipelago 

for growing taro, bananas, and sugar cane and that a canoe paddle was “exactly like a Tahitian 

paddle.” 

Howland had its first and only archaeological reconnaissance survey performed in 1987 (Shun 

1987). This worked occurred on September 18-20, 1987, and consisted of only surface 

reconnaissance survey and limited subsurface testing performed as part of a U.S. Army Corps of 

Engineers Defense Environmental Restoration project to inventory and burn fuel in abandoned 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

4-18 Chapter 4 – Refuge and Resource Description 

World War II fuel drums on Baker and Howland Islands (Helene Takemoto per. comm.). The 

archaeological reconnaissance was done prior to the drum collection and burning to avoid 

possible damage to cultural resources (Shun 1987). 

Environmental conditions on Howland are inhospitable to lengthy human occupation. A lack of 

a constant supply of fresh water is the primary limiting factor for habitation by humans. It is 

conceivable that early prehistoric people could have used Howland Island as a stopping, resting, 

or gathering place during their voyages across the Pacific Ocean, including capture of nesting sea 

turtles kept alive for extended food supply during long ocean voyages. However, it is doubtful 

that voyagers would have willingly settled on this island. Landings in any vessel would have 

been difficult, although access gained by small canoe is possible. Due to Howland Island’s 

remoteness and lack of a sustainable freshwater supply, it is likely that Howland Island played a 

minimal role, if any, in the colonizing efforts of prehistoric people across the Pacific. 

No records were found of paleontological surveys, although paleontological resources could 

exist in the form of fossilized coral or algae and other invertebrates. The chances of prehistoric 

indigenous terrestrial mammals inhabiting Howland Island are non-existent due to the geological 

forces that formed the island, its remoteness, and dry climate. 

Recent Cultural History 

The occupation and use of Howland Island after post-European contact, approximately AD 1800, 

can be divided into five distinctive time periods or eras based upon alternating periods of 

occupation, use, and abandonment. The eras are categorized as whaling, guano mining, 

colonizing, military, and post military. 

Whaling Era: ca AD 1800-1850 

Howland Island was initially called by various names and its first European discoverer remains 

unknown. At least three whaling vessels sighted or visited Howland Island during this period. 

The island was also known as “Worth” after Captain George B. Worth who viewed it from the 

whaling ship Oeno around 1822. Captain Daniel McKenzie of the New Bedford whaler, 

Minerva Smith, gave the island its present name. A quotation from McKenzie (in Maude 1961) 

explicitly states that he named the island for the owners of his ship. These owners were I. 

Howland, Jr. and Company (Starbuck 1878). However, it was Captain George E. Netcher of the 

whaling vessel Isabella who is generally credited for bestowing the island with its present name 

after the lookout who first saw it on September 9, 1842 (Bryan 1974). Thus, Howland Island 

appears to have been named Howland on two separate occasions. 

Use of the island by whaling ship crews is speculative. Lacking an adequate harbor or sheltered 

bay, landings on the island are difficult to this day. However, whaling vessels may have stopped 

at Howland Island to acquire sea turtles, birds and eggs. Whalers also used nearby Baker Island 

and at times would leave letters and other correspondence. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4 – Refuge and Resource Description 4-19 

Guano Mining Era: 1850-1891 

On February 5, 1857, Alfred G. Benson and Charles H. Judd on board the Hawaiian schooner 

Liholiho officially claimed the island under the “Guano Act” of 1856 for the American Guano 

Company (Bryan 1974). Guano mining on Howland Island was delayed until after 1861 because 

of a mining rights dispute between the American Guano Company and United States Guano 

Companies, which was settled in favor of the American Guano Company. Mining on Howland 

Island peaked between 1870 and 1872 when, during a 4 month period in 1870, 7,600 tons of 

guano were off-loaded from the island in 109 working days, setting a record for guano mining in 

those days. An estimate of the total amount of guano removed varies between 85,000 to 100,000 

tons (Bryan 1974). Evidence of this era of exploitation still remains as large basins from mining 

excavations and mounds of low-grade guano mark the island landscape. 

Howland Island appears to have been abandoned from 1891 until 1935, although visits or very 

brief stopovers no doubt occurred during the interim. The Whippoorwill Expedition sponsored 

by Bishop Museum paid one such visit in September 1924. This scientific team spent 7 days on 

Howland Island, but a written record or log of the trip was not located during the development of 

this CCP. 

Colonizing Era: 1935-1942 

The establishment of trans-Pacific air routes; territorial ownership disputes over several islands 

in the Pacific between the United States and the United Kingdom in the early 1900s; and the 

threat of a second world war led to colonizing efforts by the United States on several Pacific 

Islands including Howland Island. Colonizing efforts began in March 1935. Several military 

personnel and graduates of Kamehameha Schools, Hawaii established a colony on Howland 

Island (Brown et al. 2002). After initial establishment, the colonists were comprised of 

Kamehameha graduates and were supplied with enough food, water and other necessities to 

sustain them “for a period of from six weeks to several months” (Bryan 1974). Water and bulk 

food were supplied from Hawaii. During this colonizing era, at least 26 trips were made to 

Howland Island by various United States Coast Guard (USCG) cutters. During the colonizing 

era, Howland Island was visited frequently and was often the scene of busy activity.

The colonists erected Itascatown as their place of permanent settlement. Other structures for 

water, food storage, radio equipment, and walls around the main settlement were constructed. 

Attempts to grow trees, flowers, and vegetables were tried but the climate was unfavorable for 

cultivated crops. 

 

During this era, Amelia Earhart Putnam achieved national recognition as a pioneering aviator. 

Along with navigator Fred J. Noonan, they planned a circumnavigation of the world with a 

refueling stop on Howland Island. The U.S. Government, which had been planning to build an 

airfield on Howland Island, began construction of a runway in January 1937, so that it might be 

ready for the Earhart flight (Bryan 1974). By the time the airfield was completed, it consisted of 

three runways, 150 feet wide and of varying lengths. The North-South, East-West, and 

Northeast-Southwest runways were respectively 5,200 feet, 2,400 feet, and 3,000 feet long (Shun 

1987). 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

4-20 Chapter 4 – Refuge and Resource Description 

On July 1, Amelia and Fred departed Lae, New Guinea hoping to complete the flight of 

approximately 2,250 miles to Howland Island in l8 to 20 hours. Somewhere between Lae, New 

Guinea and Howland Island, they vanished at sea. In the following 2 weeks, 10 ships and 

approximately 66 planes aided in the unsuccessful search for Amelia Earhart and Fred Noonan 

(Shun 1987). 

Construction of a memorial to Amelia Earhart began on October l6, 1937, with the placement of 

the cornerstone for the Amelia Earhart light beacon (Bryan 1974). 

Military Era: 1942-1944 

The colony on Howland Island continued undisturbed except for routine USCG staff visits until 

December 8, 1941, when the island was bombed and machine-gunned by 14 Japanese planes. 

Some 60 bombs in all were dropped, but damage to the colonists' installations was negligible 

(Bryan 1974). Sadly, two colonists were killed. The island's surface was heavily scarred with 

some of the bombs leaving craters 20 feet across and 12 feet in depth on the surface of the island 

(Bryan 1974). 

On December 10, a Japanese submarine surfaced offshore and fired approximately 50 shells into 

Itascatown, causing more damage than the initial bombing (Bryan 1974). The house and kitchen 

were destroyed and one shell hit the top of the Amelia Earhart light, rendering it useless. Two 

more aerial bombing attacks were made on the island on January 5 and January 24, 1942. The 

two survivors were removed from the island by the U.S. Navy destroyer Helm on January 31, 

1942. 

Howland Island was not visited again until September 13, 1943, when a military inspection team 

from nearby Baker Island reported that there were no bomb craters on the 2,400-foot strip and 

that all of the colonial installations had been rendered useless. The airstrip was subsequently 

readied for use for emergency landings (Shun 1987).

Post War Era: 1944 to Present 

No attempt was made to re-colonize Howland Island after the war, although the Department of 

the Interior thought of doing so. In 1948, the U.S. decided that the claim to Howland Island 

could be effectively maintained by annual USCG staff visits. Thus, a USCG vessel apparently 

first visited the island after the war. Other USCG vessels that visited Howland Island included 

the Kettle, Basswood, Buttonwood, Kukui, the Planetree, Blackhaw and Ironwood. Most staff 

visits to Howland Island usually occurred in the first 4 months of the year with the ships’ crews 

completing repairs to the day beacon and taking photographs to establish their presence on the 

Island. In 1963, the Blackhaw finally repaired the Earhart beacon destroyed 20 years earlier 

(Shun 1987).

In March 1963, and for the following 2 years, Smithsonian Institution employees made a number 

of staff visits to Howland Island as part of the SIPOBS (Sibley et al. 1965). During this period 

of investigation by the Smithsonian, a reconnaissance team of the AEC visited the island. This 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4 – Refuge and Resource Description 4-21 

group arrived on Howland Island on October 14, 1963, conducted their survey for the following 

3 days and departed. In addition, a survey by AEC was made of topographical, geological, and 

oceanographic features of the island. 

 

In recent years, sporadic staff visits have occurred in the form of USCG and NOAA patrols and 

scientific expeditions. The island and its territorial seas were transferred to the Service in 1974 

from the Department of the Interior Office of Insular Affairs. This area is now managed as a unit 

of the National Wildlife Refuge System. Refuge staff have participated in scientific expeditions, 

typically aboard NOAA vessels since 2000 and occurring once every 2 years since 2002. 

Socio-economics 

Historical Developments 

Since whaling days, Howland Island has been used for a variety of commercial enterprises. 

During the whaling era, it appears that Howland Island served as a port-in-a-storm and possible 

gathering site for provisions by harvesting seabirds, sea turtles, and their eggs. Fishing for tuna 

and other species may also have occurred. The guano-mining era provided the world with a 

nutrient-rich fertilizer. Howland and other central Pacific islands were exploited for their deep 

guano deposits. 

After the guano mining period, Howland Island was retained by the U.S. Government to aid in 

transportation and commerce during the mid-1930s. A colony was established on Howland 

Island to assert U.S. possession by placing 4 to 5 men on Howland Island from 1935 to 1942 

(Bryan 1974, Brown et al. 2002). Howland Island was also used by the military during World 

War II as an emergency landing strip for operations on nearby Baker Island. After 1945, there 

was no further military use of the island, but USCG vessels performed annual patrols to protect 

U.S. economic interests in the central Pacific. 

In modern times, a proposal to use of the island for military/atomic testing was developed in 

1963 (AEC 1963), but the proposal did not materialize. In 1974, Howland Island and its 

territorial sea was transferred to the Service as a unit of the National Wildlife Refuge System to 

preserve and restore ecosystem values, focusing on nesting seabird populations 

During the past decade, the government of Kiribati requested permission to allow their fishing 

fleets within Howland Island’s 200-mile Exclusive Economic Zone (EEZ). The Department of 

the Interior relayed their concerns about this request to the appropriate offices of the Bureau of 

East Asian and Pacific Affairs in the Department of State. As a result, the Department of State 

informed the Government of Kiribati that the U.S. Government would decline that request. 

There are no current economic uses of Howland, and the island remains unpopulated. 

Land Use 

Howland Island has been uninhabited since the World War II era and would remain so except for 

occupation during periodic field camps. As such, the future “land use” for Howland Island 

would likely include establishing a temporary field camp site that would not conflict with 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

4-22 Chapter 4 – Refuge and Resource Description 

important wildlife functions, habitat restoration, or wilderness values. Site planning would also 

identify corridors for small boat access, footpaths for regular island patrols, study sites, areas 

designated for solar power and potable water production generation, waste and trash disposal 

areas, work areas, and other needs. 

Public Access 

Howland is closed to public access. There has never been, nor are there plans to formally open 

the refuge to recreational activities by publishing public notice in the Federal Register. 

However, limited public access of Howland has been authorized in the past. Refuge access is 

managed through the issuance of a SUP when the activity is deemed compatible and appropriate 

with the purposes of refuge establishment. 

Commercial Fishing 

There has been essentially no recorded Hawaii-based longline fishing activity within the 

Howland and Baker Islands U.S. EEZs (0-200 nmi) from 1991-2007 (Hamm and Dowdell, 

2008). There has also been no commercial purse seine fishing between 0-12 nmi around 

Howland and Baker Islands from 1998 to 2007 (NMFS SWFSC 2008). Over the years, foreign 

commercial fishing vessels may have targeted uninhabited Howland for unauthorized and illegal 

fishing because of the lack of on-site surveillance and enforcement capacity. The economic 

pressure to pursue this option would likely increase in the future as commercial fishing stocks in 

Asia and the Pacific become more heavily fished and depleted. Howland is habitat to many 

commercially valuable fishery species including sharks, lobsters, groupers, giant clams, tuna, 

wahoo, swordfish, deepwater snappers, bumphead parrotfish, humphead wrasses, various 

aquarium fish, pearl oysters, sea cucumbers, and other species. The no-take mandate and 

establishment of the refuge predated the applicability of the Magnuson-Stevens Fishery 

Conservation and Management Act of 1996 as amended (16 USC 1361 et seq.) to Howland. The 

deep slope area outside the refuge is likely too small to support commercial bottomfish harvest 

especially in light of the long commuting distances between Howland and the home ports of the 

fishing vessels. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

APPENDICES 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix A – Glossary A-1 

Appendix A. Glossary of Terms and Acronyms 

ACHP. President’s Advisory Council on Historic Preservation. 

Alien species. Non-native species intentionally or accidentally introduced into habitats of the 

refuge. 

Atoll. A tropical reef formation with a shallow water lagoon, surrounding perimeter reef, and 

reef islet(s). 

Baker. Used alone in this report, it refers to the Baker Island National Wildlife Refuge. 

CCP. Comprehensive Conservation Plan. 

CCP/EA. A document that combines a Comprehensive Conservation Plan and an 

Environmental Assessment. 

CFR. Code of Federal Regulations. A comprehensive directory of all Federal regulations. 

CITES. Convention on the International Trade in Endangered Species of Wild Fauna and Flora. 

Comprehensive Conservation Plan. A document that describes the desired future conditions of 

the refuge, and provides long-range guidance and management direction for the refuge manager 

to accomplish the purposes of the refuge, contribute to the mission of the System, and to meet 

other relevant mandates (Service Manual 602 FW 1.5). 

CPWHP. Central Pacific World Heritage Project. 

CRED. The Coral Reef Ecosystem Division of NOAA’s Pacific Islands Fisheries Science 

Center. 

DLNR. Hawaii Department of Land and Natural Resources. 

DMA. Defense Mapping Agency.

EEZ. Exclusive Economic Zone. 

EIS. Environmental Impact Statement. NEPA documentation that assesses the impacts of major 

Federal actions significantly affecting the quality of the human environment. 

Environmental Assessment. A concise public document, prepared in compliance with the 

National Environmental Policy Act, that briefly discusses the purpose and need for an action, 

alternatives to such action, and provides sufficient evidence and analysis of impacts to determine 

whether to prepare an environmental impact statement or finding of no significant impact (40 

CFR 1508.9). 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

A-2 Appendix A – Glossary 

ENSO. El Niño Southern Oscillation; a periodic ocean warming anomaly in the tropics. 

EUC. Equatorial Undercurrent; a subsurface ocean current flowing east at the Equator. 

Federal Register (FR). Official bulletin publicizing notices of Federal actions. 

FMPS. Fishery Management Plans for commercial fisheries in Federal waters. 

FONSI. Finding of No Significant Impact; a federal agency notice and preliminary decision that 

its proposed action would not require preparation of an EIS. 

GIS. Geographic information system; a database integrating tabular and geographic data. 

GPS. Global Positioning System; satellite-based for accurate geographic/site positioning. 

Howland. Used alone in this report, it refers to the Howland Island National Wildlife Refuge. 

Hydrophone. Underwater microphone or listening device. 

Improvement Act. The National Wildlife Refuge System Improvement Act of 1997 

amendment to the National Wildlife Refuge System Administration Act of 1966. 

Insular Area. The current generic term used to refer to a United States possession, territory, 

Territory, freely associated state, or commonwealth under United States sovereignty. 

Invasive Species. Either an alien or native species that spreads, or achieves dominance quickly, 

resulting in undesirable effects on native species and their habitats 

ITCZ. Inter-tropical Convergence Zone; approximately along 5o N Latitude where the northeast 

and southeast tradewinds collide, rise, and create a zone of heavy rainfall and low winds; also 

known as the doldrums. 

IUCN. International Union for the Conservation of Nature. 

Jarvis. Used alone in this report, it refers to the Jarvis Island National Wildlife Refuge. 

LEIS. Legislative Environmental Impact Statement. See EIS. 

MBTA. Migratory Bird Treaty Act. 

Mesoscale Eddy. A circular flow of water near an island or reef, roughly 10 to 100 nm in 

diameter caused by the wake of currents passing the reef or island. 

μ L. Micro liter, or one-millionth of a liter. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix A – Glossary A-3 

NEC. North Equatorial Current, west-flowing surface current between 5-30oN Latitude. 

NECC. North Equatorial Countercurrent; east-flowing surface current under the ITCZ. 

NEPA. National Environmental Policy Act; establishes procedures requiring all Federal 

agencies to assess the environmental consequences of their actions. 

NMI. Nautical mile; the equivalent of 1.15 statute (land) mile or 6,000 feet. 

NMFS. The National Marine Fisheries Service of NOAA. 

NOAA. National Oceanic and Atmospheric Administration. 

NPS. National Park Service. 

NWR. National Wildlife Refuge. 

NWRS. National Wildlife Refuge System. 

Oligotrophic. Waters having low levels of the mineral nutrients required by green plants. At 

Howland, this refers to the transparent zone of nutrient-poor shallow tropical waters, bounded by 

a thermocline serving as a barrier against exchange with deeper nutrient-rich waters. 

Phenology. The study of periodic biological phenomena, such as breeding, flowering, and 

migrations, especially as related to climate. 

Preferred Alternative. This is the alternative determined [by the decision maker] to best 

achieve the refuge purpose(s), vision, and goals; contributes to the Refuge System mission, 

addresses the issues; and is consistent with principles of sound fish and wildlife management. 

Proposed Action. Preferred Alternative among several evaluated to comply with NEPA. 

Quadrat. A rigid frame used by ecologists to facilitate unit area estimates of the size and 

density of surface-dwelling plants and animals; Photo-quadrat. A photograph of the area inside 

the quadrat to allow office data analysis after field staff visits. 

PIFSC. NOAA’s Pacific Islands Fisheries Science Center. 

REA. Rapid ecological assessments. 

Reef Island. Low tropical islet resting on a coral reef and consisting of reef rock and sand. 

RONS. Refuge Operating Needs System; Service program for NWR operating funds. 

ROV. Remotely operated vehicle; mobile un-manned device for collecting deep-sea data. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

A-4 Appendix A – Glossary 

SAMMS. Service Asset Maintenance Management System; Service program to provide funds to 

maintain refuge property. 

SEC. South Equatorial Current; westward-flowing ocean current driven by the southeast 

tradewinds between Latitudes 5o N and 30o S. 

Secretary. The Secretary of the Interior. 

Service. Used alone in this report, it refers to the U. S. Fish and Wildlife Service. 

SIPOBS. Smithsonian Institution Pacific Ocean Biological Survey. 

SUP. Special Use Permit; written Service approval and conditions for conducting an activity in 

a refuge. 

System. Used alone in this report, it refers to the National Wildlife Refuge System. 

Thermocline. In oceans, it is a depth zone of rapid density and temperature change serving as a 

barrier between mixing of shallow warmer surface and deeper subsurface waters. 

Transect. A linear scientific field survey sampling design or area to facilitate repeatability, 

standard units of measurement, and future site relocation and resurvey. 

UNESCO. United Nations Educational, Scientific and Cultural Organization. 

USCG. United States Coast Guard. 

U.S. Possession. Equivalent to U.S. territory. It is no longer current colloquial usage. 

U.S. Territory. An incorporated United States insular area, of which only one currently exists, 

Palmyra Atoll, in which the United States Congress has applied the full body of the United States 

Constitution. 

U.S. territory. A United States insular area in which the United States Congress has determined 

that only selected parts of the United States Constitution apply.

WESPAC. Western Pacific Regional Fisheries Management Council. 

WSA. Wilderness Study Area. 

World Heritage Property. A protected and inscribed natural and/or cultural site with 

“outstanding universal value” and meeting one or more of the eligibility criteria of the 

International Convention on World Heritage. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B – Species Lists B-1 

Appendix B. Species Lists 

Table B-1: Corals and other cnidarians reported from Howland Island Refuge 1998-2006. After 

Maragos (2000-2003, 2004, 2006), and Maragos and Schmerfeld (1998) 

Scientific Name Common Name 

MILLEPORIDAE Fire Corals 

 Millepora platyphylla fire coral 

POCILLOPORIDAE Rose and Cauliflower Corals 

 Pocillopora eydouxi antler coral 

 Pocillopora meandrina cauliflower or rose coral 

 Pocillopora verrucosa knobby cauliflower coral 

ACROPORIDAE Table, Plate, and Rice Corals 

 Acropora cerealis 

 Acropora cf. clathrata 

 Acropora digitifera 

 Acropora formosa 

 Acropora gemmifera 

 Acropora globiceps 

 Acropora humilis 

 Acropora hyacinthus 

 Acropora latistella 

 Acropora lukteni 

 Acropora nasuta 

 Acropora polystoma 

 Acropora robusta 

 Acropora secale 

 Acropora subulata 

 Acropora surculosa 

 Acropora valida 

 Acropora vaughani Vaughan’s staghorn coral 

 Acropora verweyi Verwey’s table coral 

 Montipora aequituberculata 

 Montipora caliculata 

 Montipora danae 

 Montipora efflorescens 

 Montipora foliosa 

 Montipora foveolata 

 Montipora hispida 

 Montipora informis 

 Montipora millepora 

 Montipora cf. patula 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

B-2 Appendix B – Species Lists 

Scientific Name Common Name 

 Montipora tuberculosa 

 Montipora venosa 

 Montipora cf. verrilli 

PORITIDAE Poritid Corals 

 Porites annae 

 Porites australiensis 

 Porites lichen lichen or yellow finger coral 

 Porites lobata lobe or lobed porous coral 

 Porites lutea mound coral 

 Porites rus plate and pillar, or thin finger coral 

 Porites solida solid or boulder coral 

 Porites sp. 

 Porites vaughani 

 Porites superfusa 

AGARICIIDAE Star Corals 

 Gardineroseris planulata honeycomb coral 

 Leptoseris mycetoseroides 

 Pachyseris sp. combed coral 

 Pavona explanulata 

 Pavona minuta disk coral 

 Pavona varians corrugated coral 

 Pavona clavus disk coral 

FUNGIIDAE Mushroom Corals 

 Cycloseris vaughani Vaughan’s mushroom coral 

 Fungia scutaria mushroom coral 

 Fungia granulosa mushroom coral 

 Fungia repanda mushroom coral 

 Halomitra pileus basket coral 

 Herpolitha limax stone snake coral 

 Podabacia crustacea 

MUSSIDAE Spiny Brain Corals 

 Symphyllia recta colon coral 

MERULINIDAE Knob corals 

 Hydnophora rigida 

 Hydnophora exesa 

 Hydnophora microconos 

FAVIIDAE Brain Corals 

 Cyphastrea serailia small brain coral 

 Favia favus 

 Favia matthaii Matthai’s brain coral 

 Favia pallida 

 Favia rotumana Rotuma’s brain coral 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B – Species Lists B-3 

Scientific Name Common Name 

 Favia stelligera 

 Favites pentagona pentagonal brain coral 

 Favites complanata 

 Favites flexuosa 

 Favites russelli Russell’s brain coral 

 Favites sp. 

 Goniastrea retiformis 

 Goniastrea sp.

 Leptastrea pruinosa 

 Leptastrea transversa 

 Leptastrea bewickensis Bewick’s brain coral 

 Leptastrea purpurea purple brain coral 

 Montastrea annuligera 

 Montastrea curta 

DENDROPHYLLIIDAE Tube Corals 

 Tubastraea coccinea orange tube coral 

ZOOANTHIDAE Zoanthid soft corals 

 *Palythoa sp. 

DISCOSOMATIDAE Corallimorphs 

 *Rhodactis howesii red corallimorph 

ALCYONARIA Octocorals 

 *Lobophytum sp. leather coral 

 *Sarcophyton sp. leather coral 

SIDERASTREIDAE Sandpaper corals 

 Coscinaraea sp. 

 Psammocora nierstraszi 

 Psammocora profundacella 

 Psammocora haimeana 

 Psammocora stellata 

ANTIPATHARIA Black Corals 

Cirrhipathes sp. wire coral 

*indicates non-stony species 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

B-4 Appendix B – Species Lists 

Table B-2: Shallow water records of fish collected from or observed at Howland Island from 

1927-2002. Collected or compiled by Mundy et al. (2002). 

Scientific Name Common Name 

GINGLYMOSTOMATIDAE Nurse Sharks 

 Nebrius ferrugineus nurse shark 

CARCHARHINIDAE Requiem Sharks 

 Carcharhinus amblyrhynchos grey reef shark 

 Carcharhinus melanopterus reef blacktip shark 

 Galeocerdo cuvieri tiger shark 

HEMIGALEIDAE Weasel Sharks 

 Triaenodon obesus reef whitetip shark 

SPHYRNIDAE Hammerhead Sharks 

 Sphyrna lewini scalloped hammerhead shark 

DASYATIDAE Sand Rays 

 Taeniura meyeni 

MYLIOBATIDIDAE Eagle Rays 

 Aetobatus narinari spotted eagle ray 

MOBULIDAE Manta Rays 

 Manta sp. manta 

MURAENIDAE Moray Eels 

 Anarchias allardicei Allardice’s moray 

 Anarchias cantonenesis Canton Island moray 

 Echidna nebulosa snowflake moray 

 Echidna polyzona barred moray 

 Enchelycore pardalis 

 Gymnomuraena zebra zebra moray 

 Gymnothorax breedini 

 Gymnothorax chilospilus 

 Gymnothorax javanicus giant moray 

 Gymnothorax flavimarginatus yellow-margined moray 

 Gymnothorax marshallensis Marshall Island moray 

 Gymnothorax meleagris white-mouth moray 

 Gymnothorax picta peppered moray 

 Gymnothorax rueppelliae yellow-headed moray 

 Gymnothorax sp.

 Gymnothorax thyrsoideus 

 Gymnothorax undulatus undulated moray 

 Uropterygius sp.

 Uropterygius marmoratus marbled snake moray 

OPHICHTHIDAE 

 Myrichthys maculosus spotted snake eel 

CONGRIDAE Conger Eel 

 Conger sp.
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B – Species Lists B-5 

Scientific Name Common Name 

CHANIDAE Milkfish 

 Chanos chanos milkfish 

SYNODONTIDAE Lizardfishes 

 Synodus sp.

HOLOCENTRIDAE Squirrelfishes 

 Myripristis berndti bigscale soldierfish 

 Sargocentron caudimaculatum tailspot squirrelfish 

 Sargocentron diadema crown squirrelfish 

 Sargocentrum microstoma finelined squirrelfish 

 Sargocentrum punctatissimum speckled squirrelfish 

 Sargocentrum tiere blue-lined squirrelfish 

SYNGNATHIDAE Pipefishes and Seahorses 

 Choeroichthys sculptus sculpted pipefish 

AULOSTOMIDAE Trumpetfishes 

 Aulostomus chinensis trumpetfish 

SCORPAENIDAE Scorpionfishes 

 Pterois antennata spotfin lionfish 

 Pterois radiate clearfin lionfish 

 Petrois volitans lionfish, turkeyfish 

 unidentified scorpionfish 

CARACANTHIDAE Orbicular Velvetfishes 

 Caracanthus maculates spotted coral croucher 

SERRANIDAE Groupers & Sea Basses 

 Aethaloperca rogaa redmouth grouper 

 Cephalopholis argus peacock grouper 

 Cephalopholis aurantia 

 Cephalopholis miniata coral grouper 

 Cephalopholis urodeta flagtail grouper 

 Epinephelus fasciatus black-tipped grouper 

 Epinephelus hexagonatus hexagon grouper 

 Epinephelus howlandi 

 Epinephelus macrospilos black-spotted grouper 

 Epinephelus maculatus highfin grouper 

 Epinephelus melanostigmus blackspot honeycomb grouper 

 Epinephelus merra honeycomb merra 

 Epinephelus retouti 

 Epinephelus sp.

 Epinephelus spilotoceps four-saddle grouper 

 Epinephelus tauvina greasy grouper 

 Gracila albomarginata white-margined grouper 

 Luzonichthys whitleyi Whitley’s slender basslet 

 Plectropomus laevis Saddleback grouper 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

B-6 Appendix B – Species Lists 

Scientific Name Common Name 

 Pseudanthias bartlettorum Bartlett’s fairy basslet 

 Pseudanthias bartlettorum 

 Pseudanthias cooperi red-bar fairy basslet 

 Pseudanthias olivaceus 

 Pseudantias sp. 

 Variola louti 

ANTENNARIIDAE Frogfishes 

 Antennarius tuberosus 

BELONIDAE Needlefishes 

 Platybelone argulus platyura keeled needlefish 

 Tylosurus crocodilus crocodile needlefish 

APOGONIDAE Cardinalfishes 

 Apogon angustatus broad-striped cardinalfish 

 Apogon apogonides 

 Apogon coccineus cryptic cardinalfish 

 Apogon fraenatus bridled cardinalfish 

 Apogon luteus 

 Cheilodipterus quinquelineatus five-lined cardinalfish 

MALACANTHIDAE Sand Tilefishes 

 Malacanthus latovittatus striped blanquillo 

CORYPHAENIDAE 

 Coryphaena hippurus mahi mahi, common dolphinfish 

ECHENEIDAE Remoras 

 Echeneis sp. 

CARANGIDAE Jacks 

 Carangoides ferdau bar jack 

 Carangoides orthogrammus yellow-spotted trevally 

 Caranx ignobilis giant trevally 

 Caranx lugubris black jack 

 Caranx melampygus bluefin trevally 

 Caranx sexfasciatus bigeye trevally 

 Elegatis bipinnulata rainbow runner 

 Seriola dumerili greater amberjack 

 Trachinotus baillonii 

LUTJANIDAE Snappers 

 Aphareus furca blue smalltooth jobfish 

 Aprion virescens jobfish, uku 

 Lutjanus bohar twinspot snapper, redspot snapper 

 Lutjanus fulvus flametail snapper 

 Lutjanus gibbus humpback snapper 

 Lutjanus kasmira bluelined snapper 

 Lutjanus monostigma onespot snapper 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B – Species Lists B-7 

Scientific Name Common Name 

 Macolor niger black snapper 

CAESIONIDAE Fusiliers 

 Caesio teres yellowback fusilier 

 Pterocaesio latovittata yellowstreak fusilier 

 Pterocaesio marri twinstripe fusilier 

 Pterocaesio tile bluestreak fusilier 

LETHRINIDAE Emperors 

 Gnathodentex aureolineatus yellowspot emperor 

 Monotaxis grandoculis bigeye emperor 

MULLIDAE Goatfishes 

 Mulloides flavolineatus yellowstripe goatfish 

 Mulloides mimicus (L. kasmira) 

 Mulloides vanicolensis yellowfin goatfish 

 Parupeneus bifasciatus two-barred goatfish 

 Parupeneus cyclostomus yellowsaddle goatfish 

 Parupeneus multifasciatus multibarred goatfish 

 Parupeneus pleurostigma sidespot goatfish 

 Parupeneus trifasciatus 

PRIACANTHIDAE Bigeyes 

 Heteropriacanthus cruentatus 

PEMPHERIDAE Sweepers 

 Pempheris oualensis bronze sweeper 

KYPHOSIDAE Chubs 

 Kyphosus bigibbus brown chub 

 Kyphosus cinerascens highfin rudderfish 

 Kyphosus vaigiensis lowfin rudderfish 

 Kyphosus sp.

 Sectator ocyurus 

EPHIPPIDAE Batfishes 

 Platax orbicularis circular spadefish, batfish 

 Platax teira longfin spadefish 

CHAETODONTIDAE Butterflyfishes 

 Chaetodon auriga threadfin butterflyfish 

 Chaetodon citrinellus speckled butterflyfish 

 Chaetodon kleinii Klein’s butterflyfish 

 Chaetodon lunula racoon butterflyfish 

 Chaetodon meyeri Meyer’s butterflyfish 

 Chaedodon ornatissimus ornate butterflyfish 

 Chaetodon quadrimaculatus gourspot butterflyfish 

 Chaetodon reticulatus reticulated butterflyfish 

 Chaetodon trifascialis chevroned butterflyfish 

 Chaetodon unimaculatus teardrop butterflyfish 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

B-8 Appendix B – Species Lists 

Scientific Name Common Name 

 Chaetodon vagabundus vagabond butterflyfish 

 Forcipiger flavissimus long-nosed butterflyfish 

 Forcipiger longirostris big long-nosed butterflyfish 

 Hemitaurichthys thompsoni Thompson’s butterflyfish 

 Heniochus monoceros masked bannerfish 

 Heniochus varius humphead bannerfish 

POMACANTHIDAE Angelfishes 

 Apolemichthys griffisi Griffis angelfish 

 Apolemichthys trimaculatus three-spot angelfish 

 Apolemichthys xanthopunctatus golden spotted angelfish 

 Centropyge bicolor bicolor angelfish 

 Centropyge flavissima lemonpeel angelfish 

Centropyge flavissima vrolikii hyb. Lemonpeel and Pearlscale angelfish hybrid 

 Centropyge loricula flame angelfish 

 Centropyge vrolikii pearlscale angelfish 

 Pomacanthus imperator emporer angelfish 

Pygoplites diacanthus Regal angelfish 

POMACENTRIDAE damselfishes 

 Abudefduf notatus yellow-tail sergeant 

 Abudefduf septemfasciatus banded sergeant 

 Abudefduf sordidus black-spot sergeant 

 Amphiprion chrysopterus orange-fin anemonefish 

 Amphiprion perideraion pink anemonefish 

 Chromis acares midget chromis 

 Chromis agilis bronze reef chromis 

 Chromis analis yellow chromis 

 Chromis bicolor 

 Chromis caudalis blue axil chromis 

 Chromis margaritifer bicolor chromis 

 Chromis vanderbilti Vanderbilt’s chromis 

 Chromis viridis (caerulea) blue-green chromis 

 Chromis xanthura black chromis 

 Chrysiptera glauca gray demoiselle 

 Chry.brownriggii (leucopoma) 

 Dascyllus auripinnis (ms) 

 Lepidozygus tapeinosoma Fusilier damsel 

 Plectroglyphidodon dickii Dick’s damsel 

 Plectroglyphidodon imparipennis bright-eye damsel 

 Plectroglyphidodon johnstonianus Johnston Island damsel 

 Plectroglyphidodon lacrymatus jewel damsel 

 Plectroglyphidodon leucozonus white-band damsel 

 Plectroglyphid. phoenixensis Phoenix Islands damsel 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B – Species Lists B-9 

Scientific Name Common Name 

 Pomacentrus bankanensis speckled damsel 

 Stegastes albifasciolatus white-bar gregory 

 Stegastes aureus 

 Stegastes fasciolatus Pacific gregory 

 Stegastes nigricans dusky farmerfish 

KUHLIIDAE Flagtails 

 Kuhlia petiti 

CIRRHITIDAE Hawkfishes 

 Cirrhiticythys aprenius 

 Cirrhitichthys falco falco hawkfish 

 Cirrhitichthys oxycephalus pixy hawkfish 

 Cirrhitops hubbardsi 

 Cirrhitus pinnulatus stocky hawkfish 

 Neocirrhites armatus flame hawkfish 

 Paracirrhites arcatus arc-eye hawkfish 

 Paracirrhites forsteri freckled hawkfish 

 Paracirrhites hemistictus whitespot hawkfish 

SPHYRAENIDAE Barracudas 

 Sphyraena barracuda great barracuda 

LABRIDAE Wrasses 

 Anampses caeruleopunctatus blue-spotted wrasse 

 Anampses meleagrides yellowtail wrasse 

 Anampses twistii yellowbreasted wrasse 

 Bodianus axillaries axilspot hogfish 

 Bodianus dianna Diana’s hogfish 

 Bodianus prognathus 

 Cheilinus oxycephalus snooty wrasse 

 Cheilinus trilobatus tripletail wrasse 

 Cheilinus undulatus humphead wrasse, napoleonfish 

 Cirrhilabrus exquisitus exquisite wrasse 

 Coris aygula clown coris 

 Coris centralis 

 Coris gaimard yellowtail coris 

 Gomphosus varius bird wrasse 

 Halichoeres hortulanus checkerboard wrasse 

 Halichoeres margaritaceus weedy surge wrasse 

 Halichoeres melasmopomus black-ear wrasse 

 Halichoeres ornatissinus ornate wrasse fish 

 Halichoeres scapularis zigzag wrasse 

 Halichoeres trimaculatus three-spot wrasse 

 Hemigymnus fasciatus barred thicklip wrasse 

 Labroides bicolor bicolor cleaner wrasse 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

B-10 Appendix B – Species Lists 

Scientific Name Common Name 

 Labroides dimidiatus bluestreak cleaner wrasse 

 Labroides pectoralis black-spot cleaner wrasse 

 Labroides rubrolabiatus 

 Labropsis xanthonota wedge-tailed wrasse 

 Macropharyngodon meleagris leopard wrasse 

 Novaculichtyhs taeniourus dragon wrasse, rockmover wrasse 

 Oxycheilinus unifasciatus 

 Oxycheilinus evanidus 

 Pseudocheilinus hexataenia sixline wrasse 

 Pseudocheilinus octotaenia eightline wrasse 

 Pseudocoris heteroptera 

 Pseudodax mollucanus 

 Stethojulis bandanensis red-shoulder wrasse 

 Thalassoma amblycephalum two-tone wrasse 

 Thalassoma lutescens sunset wrasse 

 Thalassoma purpureum surge wrasse 

 Thalassoma quinquevittatum five-stripe surge wrasse 

 Thalassoma trilobatum Christmas wrasse 

SCARIDAE Parrotfishes 

 Bolbometopon muricatum humphead parrotfish 

 Calatomus carolinus bucktooth parrotfish, stareye parrotfish 

 Chlorurus microrhinus 

 Chlorurus sordidus 

 Scarus altipinnis filament-finned parrotfish 

 Scarus frenatus vermiculate parrotfish 

 Scarus niger black parrotfish 

 Scarus oviceps dark-capped parrotfish 

 Scarus rubroviolaceus red and violet parrotfish 

 Scarus tricolor 

 Scarus sp. 

TRIPTERYGIIDAE Triplefins 

 Enneapterygius sp

 Enneapterygius nigricada 

 Helcogramma chica 

BLENNIIDAE Blennies 

 Blenniela caudolineata 

 Blenniella gibbifrons 

 Blenniella paula 

 Cirripectes polyzona barred blenny 

 Cirripectes quagga squiggly blenny 

 Cirripectes sp.

 Cirripectes variolosus red-speckled blenny 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B – Species Lists B-11 

Scientific Name Common Name 

 Ecsenius midas 

 Entomacrodus sp.

 Entomacrodus striatus 

 Exallias brevis 

 Istiblennius sp.

 Istiblennius edentulous rippled rockskipper 

 Istiblennius lineatus lined rockskipper 

 Plagiotremus rhynorhynchus bluestriped blenny 

 Plagiotremus tapeinosoma piano blenny, Scale-eating blenny 

 Rhabdoblennius rhabdotrachelus 

GOBIESOCIDAE Clingfishes and Singleslits 

 Lepidichthys minor 

GOBIIDAE Gobies 

 unid. goby cf. Eviota viridis 

 Bathygobius cocosensis Cocos frill goby 

 Bathygobius fuscus fusky frill goby 

 Eviota sp. 

 Eviota epiphanies small sleeper 

 Eviota saipanensis Saipan pygmy goby 

 Eviota viridis 

 Gnatholepis sp. 

 Priolepis semidoliatus 

 Priolepis squamogena 

 Valenciennea strigata 

CALLIONYMIDAE Dragonets 

 Synchiropus sp. mandarin fish 

PTERELEOTRIDAE Dartfishes 

 Ptereleotris evides 

ACANTHURIDAE Surgeonfishes & Unicornfishes 

 Acanthurus Achilles Achilles tang 

 Acanthurus blochii (mata) ringtail surgeonfish 

 Acanthurus guttatus spotted surgeonfish 

 Acanthurus lineatus 

 Acanthurus maculiceps White-freckled surgeonfish 

 Acanthurus mata elongate surgeonfish 

 A. nigricans (glaucopareius) whitecheek surgeonfish 

 Acanthurus nigricauda epaulette surgeonfish 

 Acanthurus nigrofuscus brown surgeonfish 

 Acanthurus nigroris blue-lined surgeonfish 

 Acanthurus nubilis 

 Acanthurus olivaceus orangeband surgeonfish 

 Acanthurus pyroferus chocolate surgeonfish 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

B-12 Appendix B – Species Lists 

Scientific Name Common Name 

 Acanthurus rackliffei 

 Acanthurus triostegus 

 Acanthurus thompsoni Thompson’s surgeonfish 

 Acanthurus xanthopterus yellow-finned surgeonfish 

 Acan. achilles x nigricans 

 Acanthurus sp. 

 Ctenochaetus cyanocheilus 

 Ctenochaetus flavicaudis 

 Ctenochaetus hawaiiensis chevron tang, black surgeonfish 

 Ctenochaetus marginatus blue-spotted bristletooth 

 Ctenochaetus striatus striped bristletooth 

 Naso brevirostris spotted unicornfish 

 Naso hexacanthus blacktongue unicornfish , sleek unicornfish 

 Naso lituratus liturate surgeonfish 

 Naso vlamingii bignose unicornfish 

 Naso sp.

 Paracanthurus hepatus palette surgeonfish, hepatus tang 

 Zebrasoma rostratum 

 Zebrasoma scopas brown tang 

 Zebrasoma veliferum Sailfin tang 

ZANCLIDAE Moorish Idol 

 Zanclus cornutus moorish idol 

ISTIOPHORIDAE Billfishes 

SCOMBRIDAE Tunas 

 Euthynnus affinis kawakawa, bonito 

 Gymnosarda nuda dogtooth tuna 

 Thunnus albacares yellowfin tuna 

BOTHIDAE Left-hand Flounders 

 Bothus mancus peacock flounder 

BALISTIDAE Triggerfishes 

 Balistapus undulatus orangestriped triggerfish 

 Ballistoides conspicillum Clown triggerfish 

 Balistoides viridescens mustache triggerfish, titan triggerfish 

 Melichtys niger Black triggerfish 

 Melichtys vidua pinktail triggerfish 

 Odonus niger redtooth triggerfish 

 Pseudobalistes flavimarginatus yellowmargin triggerfish 

 Rhinecanthus rectangulus wedge picassofish, humuhumu 

 Sufflamen bursa scythe triggerfish, boomerang triggerfish 

 Sufflamen chrysopterus halfmoon triggerfish 

 Sufflamen frenatus Bridle triggerfish 

 Xanthichthys auromarginatus bluechin triggerfish, guilded triggerfish 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B – Species Lists B-13 

Scientific Name Common Name 

 Xanthichthys caeruleolineatus bluelined triggerfish 

MONACANTHIDAE Filefishes 

 Aluterus scriptus scribbled filefish 

 Amanses scopas broom filefish 

 Cantherhines dumerilii barred filefish 

 Cantherhines pardalis wire-net filefish 

OSTRACIIDAE Trunkfishes 

 Ostracion meleagris spotted trunkfish 

TETRAODONTIDAE Puffers 

 Arothron hispidus whitespotted puffer 

 Arothron meleagris guineafowl puffer 

 Canthigaster amboinensis Ambon sharpnose puffer 

 Canthigaster janthinoptera 

 Canthigaster solandri spotted sharpnose puffer 

DIODONTIDAE Porcupinefishes 

 Diodon hystrix porcupinefish 

 Diodon liturosis shortspine porcupinefish 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

B-14 Appendix B – Species Lists 

Table B-3: Plant species of Howland Island NWR. Compiled from unpublished USFWS trip 

reports. 

Scientific Name Common Name, 

(Hawaiian Name) 

Source* Observed 

by** 

Observed in 

2004 

Cocos nucifera coconut, 

(niu) 

I no 

Casuarina sp. Ironwood I no 

Pandanus sp. pandanus, 

(hala) 

I no 

Digitaria pacifica Pacific crabgrass A d,e yes 

Lepturus repens Pacific Island thintail N a,b,c,d,e yes 

Boerhavia sp. alena N a,b,c,d,e yes 

Portulaca lutea portulaca, ‘ihi N a,b,d,e yes 

Portulaca oleracea portulaca, ‘ihi A a,b,d,e yes 

Sophora tomentosa yellow neclacepod W E no 

Tribulus cistoides puncturevine, nohu N a,b,c,d,e yes 

Cordia subcordata cordia, kou N a,c,d,e yes 

Coccoloba uvifera sea grape I c,d,e no 

Sida fallax ‘ilima A E no 

Scaevola taccada naupaka W F yes 

Suriana maritime bay cedar W F yes 

Tournefortia argentea tree heliotrope W g yes 

*Source: N = native, I = introduced, A = accidentally introduced, W = wave carried 

** Collectors and Observers: 

 a - E. Christophersen 1924 e - C.R. Long 1964 

 b - E.H. Bryan 1938 f - Rauzon and Woodside 1998 

 c - F. Sibley 1963 g - Depkin and Newton 1995 

 d - P. Marshall 1963 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B – Species Lists B-15 

Table B-4: Birds of Howland Island NWR. Numbers are counts of adult birds only and 

compiled from unpublished USFWS trip reports. Note: No bird species found on Howland are 

listed according to the Endangered Species Act. 

Scientific 

Name 

Common 

Name 

Highest 

count 

since 

1973 

Birds of 

Conservation 

Concern 

Statusb

National 

Shorebird 

Prioritization 

Categorya

Regional 

Seabird 

Conservation 

Categoryc

Nesofregetta 

fuliginosa 

Polynesian 

storm-petrel 

- BCC 68 Highly Imperiled 

Pterodroma 

alba 

Phoenix 

petrel 

- BCC 68 Highly Imperiled 

Puffinus 

pacificus 

wedge-tailed 

shearwater 

1 Low 

Phaethon 

lepturus 

white-tailed 

tropicbird 

1 Low 

Phaethon 

rubricauda 

red-tailed 

tropicbird* 

496 Moderate 

Sula 

dactylatra

masked 

booby* 

3,763 Moderate 

Sula 

leucogaster 

brown 

booby* 

275 Moderate 

Sula sula red-footed 

booby* 

825 Currently not at 

Risk 

Fregata 

minor 

great 

frigatebird* 

550 Moderate 

Fregata 

ariel 

lesser 

frigatebird* 

3,850 BCC 68 High Concern 

Onychoprion 

lunata 

gray-backed 

tern* 

2,000 Moderate 

Onychoprion 

fuscatuc 

sooty tern* 150,000 Moderate 

Anous 

stolidus 

brown 

noddy* 

1,000 Currently not at 

Risk 

Procelsterna 

cerulea 

blue-grey 

noddy* 

11 BCC 68 High Concern 

Gygis alba white tern* 50 Moderate 

Pluvianlis 

dominica 

Pacific 

golden-plover 

126 BCC 68 High Concern 

Tringa 

incana 

wandering 

tattler 

27 Moderate 

Concern 

Numenius 

tahitiensis 

bristlethighed 

curlew 

62 BCC 68 High Concern 

Arenaria 

interpres 

ruddy 

turnstone 

141 High Concern 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

B-16 Appendix B – Species Lists 

Scientific 

Name 

Common 

Name 

Highest 

count 

since 

1973 

Birds of 

Conservation 

Concern 

Statusb

National 

Shorebird 

Prioritization 

Categorya

Regional 

Seabird 

Conservation 

Categoryc

Limosa 

lapponica 

bar-tailed 

godwit 

1 High Concern 

Calidris 

acuminata 

sharp-tailed 

sandpiper 

1 

Calidris 

melanotos 

pectoral 

sandpiper 

1 

Calidris 

alba 

sanderling 1 

Bubuculus 

ibis 

cattle egret - 

Anas acuta northern 

pintail 

14 

*indicates documented breeding species on Howland 

a

Species prioritization categories according to United States Shorebird Conservation Plan 

(Brown et al. 2000) 

b

Birds of Conservation Concern status according to Birds of Conservation Concern 2002 (U.S. 

Fish and Wildlife Service 2002). 

c

Conservation classification according to Seabird Conservation Plan, Pacific Region (Englis and 

Naughton 2004) 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

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C-8 Appendix C – References 

U.S. Fish and Wildlife Service. 2005. Regional Seabird Conservation Plan, Pacific Region. 

U.S. Fish and Wildlife Service, Migratory Birds and Habitat Programs, Pacific Region, Portland, 

OR. 

Vitousek, M.J., B. Kilonsky, and W.G. Leslie. 1980. Meteorological Observations in the Line 

Islands, 1972-1980. Honolulu, HI. 74 pp. 

Vitousek, P.M. 1994. Beyond global warming: ecology and global change. Ecology 75:1861-

1876. 

Walther G.R., E. Post, P. Convey, A. Menzel, C. Parmesank, T.J.C. Beebee, J. Fromentin, O. 

Hoegh-GuldbergI, and F. Bairlein. 2002. Ecological responses to recent climate change. Nature 

416: 389–395. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix D – Planning Team Members D-1 

Appendix D. Planning Team Members

The following individuals were instrumental in the development of this CCP. 

Name Position Degree(s) Years of Exp.

Charles Pelizza* Planning Team Leader BA, Enviro. Science 

MS, Biology 

26 

Don Palawski* Refuge Manager BS, Fisheries Biology 

MS, Entomology 

31 

Bob Dieli* Outdoor Recreation Planner BS, Environmental 

Education 

29 

Barbara Maxfield External Affairs Chief BA, Business 

Admin/Marketing 

27 

Barry Stieglitz Project Leader BS, Forestry and Wildlife 

MPA, Public Admin. 

18 

Michael Molina Environmental Review Coor. BS, Biology 

MS, Marine Biology 

30 

Beth Flint* Seabird Biologist BS, Wildlife Biology 

PhD, Biology 

28 

LeeAnn 

Woodward* 

Contaminant Biologist BS, Biology 

MS, Ecology 

PhD, Ecology 

30 

Jim Maragos* Coral Reef Biologist BA, Zoology, 

PhD, Oceanography 

38 

* indicates planning team member 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

D-2 Appendix D – Planning Team Members 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E – Quarantine Protocols E-1 

Appendix E. Quarantine Protocol 

The following protocol was developed to maintain consistency in quarantine procedures for all 

NWRs in the Pacific. Thus, these provisions apply to all of the Remote Island National Wildlife 

Refuges. Some refuges, including Howland, may have additional restrictions and requirements.

Pacific Remote Islands National Wildlife Refuge Complex 

Special Conditions and Rules for 

Moving Between Islands and Atolls and 

Packing for Field Camps 

The islands and atolls of the Pacific Remote Islands National Wildlife Refuge Complex are 

special places providing habitat for many rare, endemic plants and animals. Many of these 

species are formally listed as federally threatened or endangered under the Endangered Species 

Act of 1973. Endemic plants and insects, and the predators they support, are especially 

vulnerable to the introduction of competing or consuming, non-native species. Such 

introductions may cause the extinction of island endemics, or even the destruction of entire 

island ecological communities. Notable local examples include: the introduction of rabbits to 

Laysan Island in 1902 which caused the extinction of numerous plant and insect species and 3 

endemic landbird species; the introduction of rats to many Pacific Islands causing the elimination 

of many burrowing seabird colonies; the introduction of the annual grass, sandbur, to Laysan 

Island where it has out competed native bunch grass and eliminated nesting habitat for the 

Endangered Laysan finch; and the introduction and proliferation of numerous ant species 

throughout the Pacific Islands to the widespread detriment of endemic plant and insect species 

(refuge files). 

Several of the islands within the Refuge Complex are especially pristine, and, as a result, are 

diverse in terms of rare and special declining native plants and animals. Nihoa Island has 13 

potential candidate Endangered insect species, numerous Endangered plants, and 2 Endangered 

birds. Necker Island has endangered plants and 7 endemic insects that are candidates for the 

Endangered Species List. Laysan Island has endangered plants, five potential candidate, 

endangered insect species, and the Endangered Laysan finch and Laysan duck. Other islands in 

the Refuge Complex such as Lisianski, Howland, Baker, and Jarvis and islets in Atolls such as 

Rose, Pearl and Hermes Reef and French Frigate Shoals are inhabited by a variety of endemic 

and endangered species and require special protection from invasive species. 

Other Pacific Island such as Kure and the “high islands” (Oahu, Hawaii, Maui, Kauai, etc.) as 

well as, certain islands within Midway Atoll, Pearl and Hermes Reef and French Frigate Shoals 

have native plants and/or animals that are at high risk from introduction to the relatively pristine 

islands discussed above. Of special concerns are introductions of non-native snakes, rats, ants 

and a variety of other insect and plant species. Invasive plants of highest concern are Verbesina 

encelioides, Cenchrus echinatus, and Setaria verticillata.

The U.S. Fish and Wildlife Service is responsible for the management and protection of the fish, 

wildlife, plants, and their habitats associated with islands of the Pacific Remote Islands NWR 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

E-2 Appendix E – Quarantine Protocols 

Complex. No one is permitted to access any of the Refuge's islands without the express written 

permission of the Refuge Manager in the form of a Special Use Permit. Because of the above 

concerns, the following restrictions on the movement of personnel and materials to the islands of 

the Refuge Complex exist. Note: Kure Island and Midway Atoll are not part of this Refuge 

Complex. 

With the exception of Tern Island, French Frigate Shoals, the following rules apply: 

Clothing and Soft Gear: 

• Any personnel landing boats at any island should have clean clothes and shoes, meaning 

that they are free of dirt and seeds. 

• Any personnel going ashore at any island and moving inshore from the immediate area in 

which waves are breaking at the time of landing must have new footwear, new or islandspecific clothes and new or island-specific soft gear that have been frozen (<4 C) for at 

least 48 hours. 

• At the discretion of the local USFWS representative, personnel from a NOAA ship or any 

other vessel servicing the Refuge may be allowed on shore to visit predesignated areas 

for guided tours. All stipulations for clean and frozen clothes apply. 

• Otherwise, any personnel entering any vegetated area, regardless of how sparse the 

vegetation is, must have new footwear, new clothes and new soft gear all frozen for at 

least 48 hours. 

Definitions: 

• “new” means off the shelf and never used anywhere but the island in question. 

• “clothing” is all apparel , shoes, socks, over and under garments. 

• “soft gear” is all gear such as daypacks, fanny packs, camera bags, camera/binocular 

straps, microphone covers, nets, holding or weighing bags, bedding, tents, luggage, or 

any fabric or material capable of harboring seeds or insects. 

Clothing or gear coming off Kure and Midway should never be moved to any of the other refuge 

islands. 

During transit, clothing and gear coming off Kure and Midway must be carefully sequestered to 

avoid contamination of gear bound for other remote islands. Special care must be taken to avoid 

contaminating gear storage areas and quarters aboard transporting vessels with seeds or insects 

from these islands. 

General Rules: 

• Regardless of origin or destination, inspect and clean all equipment, supplies, 

immediately prior to any trip to the Refuge. Carefully clean all clothing, footwear and 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E – Quarantine Protocols E-3 

soft gear following use to minimize risk of cross contamination of materials between 

islands. 

 

• Pack supplies in plastic buckets with fitted lids or other sealable metal or plastic 

containers so they can be thoroughly cleaned inside and out. Cardboard is not 

permitted on islands. Cardboard boxes disintegrate in a short time and harbor seeds, 

animals, etc., which cannot be easily found or removed. Wood is not permitted unless 

sealed on all surfaces. 

Wooden boxes can also harbor insects and seeds and, therefore, are only allowed if well 

constructed (tight fitting seams are required). All wood must be treated, and inside and 

outside surfaces must be painted or varnished to provide a smooth, cleanable finish that 

seals all holes. 

• Freeze or tarp and fumigate then seal all equipment (clothes, books, tents) immediately 

prior to departure. Food and cooking items need not be fumigated but should be cleaned 

and frozen, if freezable. Cameras, binoculars, radios, and other electronic equipment 

must be thoroughly cleaned, including internal inspection whenever possible, but they do 

not need to be frozen or fumigated. Such equipment can only be packed in wooden 

crates if treated as in #2 above. Any containers must contain new, clean packing 

materials and be frozen or fumigated. 

• At present, Tern Island is the singular exception to the above rule having less stringent 

rules due to the large number of previously established invasive species. Careful 

inspection of all materials and containers is still required. However, it is acceptable to 

use wooden and cardboard containers for transporting supplies to Tem Island. In 

addition, there is no requirement for freezing or fumigating items disembarked at Tem. 

Although requirements for Tem Island are more lax, the Refuge is still concerned about 

the possibilities of new introductions. 

Additional Special Conditions for Restricted Access to Nihoa Island: 

Nihoa is one of the most pristine locations in the Refuge Complex. It is also inhabited by the 

highest number of federally listed endangered species. It is a small rugged island with many 

inaccessible areas. Introduction of any invasive species could have immediate, disastrous effects 

to natural resources. It would be almost impossible to mount any kind of control or eradication 

program on this island should an invasive species become established. Because of these reasons, 

access to Nihoa is strictly limited and rules governing entry are more stringent. 

• Access to Nihoa by permittees would only be allowed under the direct supervision of a 

Refuge representative. The person, who shall be appointed by the Refuge Manager, 

would work with permittees to assure careful adherence with all rules for inspection, 

handling, and preparation of equipment. The Refuge Representative would have the 

authority to control and limit access to various parts of the island to protect animals, 

plants (especially endangered species), and archaeological sites. The Refuge 

Representative would have the authority to revoke access to the island or order an 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

E-4 Appendix E – Quarantine Protocols 

immediate departure from the island if conditions for working on the island are not fully 

met or are violated in some way. 

• All field equipment made out of fabric material or wood must be new and never 

previously used in the Northwestern or main Hawaiian Islands. Equipment previously 

purchased or made for use on Nihoa that has been carefully sealed and stored while away 

from Nihoa, and not used elsewhere, may also be brought onto the island. Rules for 

freezing and/or fumigating are as described for other sites in the Refuge (see above). 

• Clothing and personal effects must be cleaned and thoroughly inspected. All footwear 

(shoes, slippers, socks, etc.) must be new, unused, or previously only used on Nihoa and 

carefully sealed and stored while off of the island. 

Rules Regarding Food: 

Fresh foods that are typically transported to island field camps (potatoes, onions, cabbage, 

apples, oranges, etc.) are not likely to become established and flourish on the Refuge Complex 

and are allowed. However, other food items such as tomatoes could easily become established. 

Soil can contain many seeds, eggs, larvae, etc., and cannot be transported to or among islands. 

Other food species such as alfalfa, mustard and cress, commonly used for sprouted greens, could 

potentially become established and cannot be brought to the islands. Other species such as mung 

beans, soybeans, and radishes would not likely survive on the islands and can be used for fresh 

greens. A list of fresh foods and seeds that are prohibited is provided below. Permittees should 

contact the Refuge Manager for more information or for questions about items not included on 

this list. 

Strictly Prohibited: 

Tomatoes (any variety), ray sunflower seeds, alfalfa seeds, mustard seeds. 

Bulk dried fruits are allowed but should be frozen solid for at least one day to kill any insects. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F – Wilderness Review F-1 

Appendix F. Wilderness Review 

I. General Information on Wilderness Reviews 

Wilderness review is the process used to determine whether or not to recommend lands or waters 

in the National Wildlife Refuge System (System) to the United States Congress (Congress) for 

designation as wilderness. Planning policy for the System (602 FW 3) mandates conducting 

wilderness reviews every 15 years through the Comprehensive Conservation Planning (CCP) 

process. 

The wilderness review process has three phases: inventory, study, and recommendation. After 

first identifying lands and waters that meet the minimum criteria for wilderness, the resulting 

wilderness study areas (WSA) are further evaluated to determine if they merit recommendation 

from the Service to the Secretary of the Interior for inclusion in the National Wilderness 

Preservation System (NWPS). Areas recommended for designation are managed to maintain 

wilderness character in accordance with management goals, objectives, and strategies outlined in 

the final CCP until Congress makes a decision or the CCP is amended to modify or remove the 

wilderness proposal. A brief discussion of wilderness inventory, study, and recommendation 

follows. 

Wilderness Inventory: The wilderness inventory consists of identifying areas that minimally 

meet the requirements for of wilderness as defined in the Wilderness Act of 1964 (Wilderness 

Act). Wilderness is defined as an area which: 

• Has at least five thousand acres of land or is of sufficient size as to make practicable its 

preservation and use in an unimpaired condition, or be capable of restoration to 

wilderness character through appropriate management at the time of review, or be a 

roadless island; 

• Generally appears to have been affected primarily by the forces of nature, with the 

imprint of man’s work substantially unnoticeable; 

• Has outstanding opportunities for solitude or a primitive and unconfined type of 

recreation; and 

• May also contain ecological, geological, or other features of scientific, educational, 

scenic, or historical value. These features and values, though desirable, are not necessary 

for an area to qualify as a wilderness. 

Wilderness Study: During the study phase, lands and waters qualifying for wilderness as a result 

of the inventory are studied to analyze values (ecological, recreational, cultural, spiritual), 

resources (e.g., wildlife, water, vegetation, minerals, soils), and uses (habitat management, public 

use) within the area. The findings of the study help determine whether to recommend the area 

for designation as wilderness. 

Wilderness Recommendation: Once a wilderness study determines that a WSA meets the 

requirements for inclusion in the NWPS, a wilderness study report that presents the results of the 

wilderness review, accompanied by a Legislative Environmental Impact Statement (LEIS), is 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

F-2 Appendix F – Wilderness Review 

prepared. The wilderness study report and LEIS that support wilderness designation are then 

transmitted through the Secretary of Interior to the President of United States, and ultimately to 

the United States Congress for approval. 

The following sections summarize the inventory and study phases of the wilderness review for 

Howland. 

II. Wilderness Inventory 

The wilderness inventory is a broad look at the planning area to identify WSAs. These WSAs 

are roadless areas within refuge boundaries, including submerged lands and their associated 

water column, that meet the minimum criteria for wilderness identified in Sect. 2(c) of the 

Wilderness Act. A WSA must meet the minimum size criteria (or be a roadless island), appear 

natural, and provide outstanding opportunities for solitude or primitive recreation. Other 

supplemental values are evaluated, but not required. In order to identify WSAs, Howland was 

divided into two inventory units based upon the differences between the terrestrial and marine 

ecological resources. Inventory Unit A is the 648-acre roadless island known as Howland Island, 

and Inventory Unit B is composed of the 34,319 combined acres of coral reefs, submergent lands 

and their associated water column lying within 3 nmi from the shoreline at the mean high water 

mark of Howland Island. The inventory of roadless areas, submerged lands, and associated 

water column of Howland and application of the wilderness criteria is described in the following 

sections and summarized in Table F-1. 

Evaluation of Size Criteria for Roadless Areas, Roadless Islands, and Submergent Lands and 

Associated Water Column

Identification of roadless areas, roadless islands, and submerged lands and associated water 

column, required gathering land status maps, land use and road inventory data, satellite imagery, 

aerial photographs, and personal observations of areas within refuge boundaries. “Roadless” 

refers to the absence of improved roads suitable and maintained for public travel by means of 

motorized vehicles primarily intended for highway use. Wilderness inventory units currently 

owned by the Service in fee title were evaluated. These units include Howland Island and the 

submergent lands and waters lying within 3 nmi of shore. 

 

Inventory units meet the size criteria for a WSA if any one of the following standards applies. 

• An area with over 5,000 contiguous acres. State and private lands are not included in 

making this acreage determination. 

• A roadless island of any size. A roadless island is defined as an area surrounded by 

permanent waters or that is markedly distinguished from the surrounding lands by 

topographical or ecological features. 

• An area of less than 5,000 contiguous Federal acres that is of sufficient size as to make 

practicable its preservation and use in an unimpaired condition, and of a size suitable for 

wilderness management. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F – Wilderness Review F-3 

• An area of less than 5,000 contiguous Federal acres that is contiguous with a designated 

wilderness, recommended wilderness, or area under wilderness review by another Federal 

wilderness managing agency such as the Forest Service, National Park Service, or Bureau 

of Land Management. 

There are no roads on Howland Island, and the submerged lands and associated water column 

meet the minimum acreage criteria, thus both inventory units within the refuge boundary meet 

one or more of the size criteria for wilderness study areas. The physical features of these units 

are described in detail in the Howland CCP Chapter 4. 

Evaluation of the Naturalness Criteria

A WSA must meet the naturalness criteria. Section 2.(c) of the Wilderness Act defines 

wilderness as an area that “...generally appears to have been affected primarily by the forces of 

nature with the imprint of man’s work substantially unnoticeable.” The area must appear natural 

to the average visitor rather than “pristine.” The presence of ecologically accurate, historic 

landscape conditions is not required. An area may include some man-made features and human 

impacts provided they are substantially unnoticeable in the unit as a whole. Human-caused 

hazards, such as the presence of unexploded ordnance from military activity, and the physical 

impacts of refuge management facilities and activities are also considered in the evaluation of the 

naturalness criteria. An area may not be considered unnatural in appearance solely on the basis 

of “sights and sounds” of human impacts and activities outside the boundary of the unit. The 

cumulative effects of these factors were considered in the evaluation of naturalness for each 

wilderness inventory unit. 

In the wilderness inventory, specific man-made features and other human impacts need to be 

identified that affect the overall apparent naturalness of the tract. Based upon the Preferred 

Alternative contained in the draft CCP/EA, the following factors were primary considerations in 

evaluating the naturalness of the inventory units: 

Historical 

• abandoned crushed coral airstrip; 

• Amelia Earhart day beacon (aid to navigation); 

• rock cairn; 

• geological monument; 

• derelict airplane wing (World War II vintage); and 

• abandoned well and mining activity. 

Little can be seen of the historical artifacts found on Howland. The airstrip, prepared as a 

waypoint for Amelia Earhart’s flight around the world has not been maintained since World War 

II. Remnants of island occupation during guano mining and World War II periods such as hand 

dug pits, wells and crumbled building walls are present on the island. However, wind erosion, 

storm activity, and vegetative growth have covered these artifacts so that they are 

indistinguishable from adjacent habitats on the island. The Amelia Earhart day beacon is the 

only visual intrusion into an otherwise natural setting. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

F-4 Appendix F – Wilderness Review 

Management Activities: 

• refuge boundary sign; 

• field camp; 

• generators; 

• control of invasive species; 

• collect and stockpile marine debris; 

• migratory bird surveys; 

• marine surveys (including SCUBA); and 

• boat transportation. 

A 4’x 8’ boundary sign announcing the name and ownership of the island is maintained on 

Howland. The sign is informational in nature, identifying the sanctuary status the island enjoys. 

The primary management intrusion to the naturalness of Howland is during the deployment and 

demobilization of field camps. Transportation from Honolulu, Hawaii across 1,600 nmi of open 

ocean to Howland is only safely and reliably possible with motorized ocean-going marine 

vessels. Once the marine transport vessel arrives at Howland, small boats with outboard motors 

are deployed to transport two biologists and their field camp gear to the island. Once on the 

island, biologists set up tents, sleeping gear, food, and other supplies. Walking surveys occur 

across the island to document bird species presence, potentially hand pull or hand spray invasive 

plant species, inventory cultural sites, and collect and stockpile marine debris. Marine surveys 

also occur. They are based from the marine vessel primarily using SCUBA. Field camps are 

planned to last for 2 days and typically occur once every two years. Occasional field camps with 

5-8 individuals staying for up to 2 weeks have occurred in the past. During these extended field 

camps, diesel-powered generators have been used to operate communication equipment. All 

other mechanical equipment such as air compressors for SCUBA equipment remains on the 

marine transport vessel. Upon demobilization of the field camp, all equipment and debris are 

removed. An indirect human impact to the naturalness of Howland is the presence of marine 

debris that washes onto coral reefs and beaches. Attempts to remove and stockpile this debris for 

eventual removal occur during field camps. Otherwise, Howland is an isolated, uninhabited 

island in the middle of the Pacific Ocean for the vast majority of time. 

Both Howland inventory units meet the naturalness criteria. Overall, the forces of nature sculpt 

the island’s resources. Wave action erodes and accretes shorelines and rearranges underwater 

coral features. Rainfall patterns either suppress or encourage vegetative growth with brown and 

barren ground during drought and lush grasses and forbs during wet periods. Bird life is the 

dominant feature with nesting seabirds common throughout the year. Occasional field camps 

infrequently intrude on this isolation. 

Although historic markers, monuments, and other signs of past human occupation exist, they do 

not detract from Howland meeting the naturalness criteria since they are a minor component of 

the landscape and are substantially unnoticeable in the area as a whole. The submerged lands, 

with the exception of scattered marine debris also meet the naturalness criteria. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F – Wilderness Review F-5 

Evaluation of Outstanding Opportunities for Solitude or Primitive and Unconfined Recreation

In addition to meeting the size and naturalness criteria, a WSA must provide outstanding 

opportunities for solitude or primitive recreation. The area does not have to possess outstanding 

opportunities for both solitude and primitive and unconfined recreation, and does not need to 

have outstanding opportunities on every acre. Further, an area does not have to be open to public 

use and access to qualify under these criteria. Congress has designated a number of wilderness 

areas in the NWPS that are closed to public access to protect ecological resource values. 

Opportunities for solitude refer to the ability of a visitor to be alone and secluded from other 

visitors in the area. Primitive and unconfined recreation means non-motorized, dispersed 

outdoor recreation activities that do not require developed facilities or mechanical transport. 

These primitive recreation activities may provide opportunities to experience challenge and risk, 

self reliance, and adventure. 

These two opportunity “elements” are not well defined by the Wilderness Act but in most cases 

can be expected to occur together. However, an outstanding opportunity for solitude may be 

present in an area offering only limited primitive recreation potential. Conversely, an area may 

be so attractive for recreation use that experiencing solitude is not an option. 

 

The following factors and their cumulative effects were the primary considerations in evaluating 

the availability of outstanding opportunities for solitude or primitive unconfined recreation at 

Howland: 

• island size, vegetation, and terrain; 

• distance to habitation, whether mainland or an inhabited island; 

• presence of operating lighthouse or aid to navigation and associated structures; and 

• viewshed within and from refuge boundary. 

Solitude is the overwhelming force that visitors experience on Howland. The island is separated 

by over 1,600 nautical miles from Hawaii, and approximately 330 nmi from Kanton Atoll, the 

nearest inhabited island. Expanses of open ocean with no other landform are visible from every 

angle. The island itself, with the exception of a few historical features, is a mixture of short 

grass and shrubs, bare ground, and shoreline beaches and cobble. In the past, field camps have 

been temporary, with only 2 individuals spending 2 days every 2 years. However, the Preferred 

Alternative in the Draft Howland CCP/EA proposed a visit to the refuge every year with the 

same number of individuals for the same duration. Underwater, coral reefs are pristine and the 

open-water depths are devoid of human presence. 

Since establishment, Howland has been and will remain closed to general public access in order 

to protect the valuable seabird and marine resource values. Thus, there are no outdoor 

recreational opportunities. 

Both Howland inventory units meet the solitude criteria, but do not meet the primitive 

unconfined recreation criteria. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

F-6 Appendix F – Wilderness Review 

Evaluation of Supplemental Values

Supplemental values are defined by the Wilderness Act as “ecological, geological, or other 

features of scientific, educational, scenic, or historic value.” Howland Island and its surrounding 

coral reefs and deep water areas compose a complete and functioning ecosystem. Isolated, 

predator-free islands are valuable and often required for successful seabird nesting. Nearshore 

waters, coral reefs, and associated currents combine and provide food resources for foraging 

seabirds and coral reef communities. The position and underwater gradient of Howland in deep 

ocean currents allows these currents to reach the surface, thereby increasing rates of productivity 

for plants, corals and vertebrate species. These rich ecological resources in a relatively pristine 

and unaltered environment provide unique opportunities for scientific study and environmental 

education. There are no known archaeological resources on Howland. Historically, Howland 

Island was important to early colonization efforts during the guano mining era, and as the illfated destination for Amelia Earhart and Fred Noonan on their around the world flight. 

Historical artifacts such as isolated building ruins, an abandoned runway, and guano mining 

excavations are present but eroded, covered by vegetation, and otherwise assimilated into the 

environment and indistinguishable from the natural environment. One historical landmark, the 

Amelia Earhart day beacon, contrasts vividly with the overall expansive vistas of open ocean and 

island habitats. These values are not required for wilderness but their presence compliments the 

requirements for wilderness designation. Please see Chapter 4 of the CCP/EA for a more 

complete description of these supplemental values. 

Inventory Findings and Wilderness Study Areas

Both inventory units meet the minimum criteria for consideration as WSAs (Figure F-1). These 

two units are either roadless islands or meet minimum size requirements, are primarily natural, 

and meet the solitude or unconfined recreation criteria. The units are identified as: 

• WSA-A: Howland Island WSA, and 

• WSA-B: Coral reefs, submergent lands, and associated water column of the Howland 

Island WSA. 

 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F – Wilderness Review F-7 

Figure F-1. Wilderness Study Areas 

•
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

F-8 Appendix F – Wilderness Review 

Table F-1 Wilderness Inventory Summary 

Inventory Unit A: 

Howland Island (330 acres)

Inventory Unit B: 

Submerged lands and waters 

to 3 nmi (34,000 acres) 

Required Components 

(1) Has at least 5000 acres of 

land or is of sufficient size to 

make practicable its 

preservation and use in an 

unconfined condition, or is a 

roadless island. 

Yes. Is a roadless island. Yes. Approximately 34,000 

acres contained within the 

territorial sea from mean high 

tide to 3 nmi. 

(2) Generally appears to have 

been affected primarily by the 

forces of nature, with the 

imprint of man’s work 

substantially unnoticeable. 

Yes. Not diminished by day 

beacon and other artifacts. 

Yes. Coral reefs and other 

underwater features untouched 

by humans. 

(3a) Has outstanding 

opportunities for solitude. 

Yes. Uninhabited island 

1000 nmi from Hawaii. 

Yes. Isolation from habitation 

both on surface and below. 

(3b) Has outstanding 

opportunities for a primitive 

and unconfined type of 

recreation. 

No. Refuge is closed to all 

recreational activities. 

No. Refuge is closed to all 

recreational activities. 

Other Components 

(4) Contains ecological, 

geological or other features of 

scientific, educational, scenic, 

or historical value. 

Earhart day beacon, WWII 

artifacts, guano mining, and 

nesting seabirds. 

Pristine coral reefs and 

associated marine fish, 

mammals, and turtles abound. 

Summary 

Parcel qualifies as a wilderness 

study area (meets criteria 1, 2 & 

3a or 3b). 

Yes Yes 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F – Wilderness Review F-9 

III. Wilderness Study 

The two WSAs identified in the Wilderness Inventory were further evaluated to determine 

suitability for designation, management, and preservation as wilderness. Considerations in this 

evaluation included: 

• quality of wilderness values; and, 

• capability for management of refuge as wilderness (or manageability) and minimum 

requirements/tools analysis. 

This information provides a basis to compare the impacts of a range of management alternatives 

and determine the most appropriate management direction for each WSA. 

Evaluation of Wilderness Values

The following information considers the quality of the WSAs’ mandatory and supplemental 

wilderness characteristics. 

Size

Both WSA-A and WSA-B meet the minimum size criteria being a 648-acre roadless island and a 

34,319-acre marine ecosystem respectively. 

Naturalness

Both of the WSAs generally appear to have been affected primarily by the forces of nature, with 

the imprint of human uses and activities substantially unnoticeable. Except for the footprint of 

the long-abandoned airstrip and the few small features mentioned in the Wilderness Inventory, 

all emergent and submerged features were entirely created by the natural processes of volcanism; 

wind erosion; wave erosion; water erosion; seabird deposits; vegetation deposits; geological 

subsidence; and reef growth and consolidation from coral, coralline algae, and giant clam 

calcification during the past 50 to 80 million years. No substantial features were constructed or 

modified by humans during the island’s entire geological history. The impacts of past human 

presence are small in terms of constructed features (beacons, monuments), and are barely 

apparent (ground-level views of the airfield, mining pits, boat channel), or transitory (marine 

debris that washes up or blows in from the surrounding sea and air). A few remnant, rusty fuel 

drums is the only trash feature that is not transient, but its overall impact to naturalness is 

minimal. See Chapter 4 of the Howland CCP/EA for a more detailed description of natural and 

cultural features. Management activities will temporarily disturb the naturalness of the area. 

Field camps lasting for 2 days will be visible across the island. Occasional use of generators will 

produce noise. However, modern generators produce decibel levels lower than speaking voice 

levels. Transportation by motorized marine vessel, the only safe, practical and reliable means 

available to arrive on the island, is equally temporary. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

F-10 Appendix F – Wilderness Review 

Outstanding Opportunities for Solitude and Primitive Recreation

Both of the WSAs offer outstanding opportunities for solitude. 

Solitude overwhelms the human spirit at Howland. The only noise on the island is from 

pounding surf, winds, buzzing insects, and the calls of birds. Underwater, all that is heard is 

one’s own breath, the surf, and the sound of fish feeding on coral. The blue of the sky and sea 

and the brightness of the stark landscape saturate the visual character; and birds, winds, and surf 

saturate the acoustic character of the refuge. It is hard to image a more remote, isolated, and 

truly more wilderness experience in the entire equatorial Pacific than when standing on the island 

or diving on adjacent reefs. 

There are no permanent improvements of any kind to accommodate visitors reaching the island. 

The capacity to reach Howland without substantial investment, preplanning, and permission is 

considerable and further restricts the capability of individuals from reaching the island and 

intruding on the opportunity for solitude. The island itself is inaccessible except by small craft 

lightered from a transport ship during calm seas. The airstrip is unusable and has never been 

maintained since World War II. Island vegetation, erosion, and accretion have reclaimed the 

airstrip and now make it unrecognizable. There are no human inhabitants on Howland. The 

nearest humans live 330 nmi to the southeast where less than 100 Kiribati people inhabit Kanton 

Atoll. There are no other inhabitants elsewhere in the Phoenix Islands. These logistical 

constraints contribute to the maintenance of solitude. 

Supplemental Values

Both of the WSAs offer outstanding ecological values with features of scientific, educational, 

scenic interest, and historical value. Pristine coral reefs, reef fish, giant clams, beaches, native 

terrestrial vegetation, unexplored deep slopes, localized upwelling currents, migratory 

shorebirds, and large populations and variety of seabirds are among the strong ecological values. 

The lack of historic and current human impact provides a rare opportunity to study unaltered 

marine ecosystems, and the impact that global climate change may have on these systems. The 

sheer vastness of the ocean landscape, punctuated by a small dot of land, and the multitude of 

bird and marine life attracted to it, provide a sense of awe and spectacular beauty to the 

landscape. The remaining features of early colonization efforts, as well as the memorial to 

Amelia Earhart, stand testament to the bravery of those early pioneers, and the ability of nature 

to endure. 

Evaluation of Manageability and Minimum Requirements/Tools Analysis 

Originally administered by the U.S. Department of Interior’s Office of Territorial Affairs, the 

Secretary of the Interior (Secretary), on June 27, 1974, designated Howland Island and its 

territorial sea extending to the 3 nautical mile (nmi) limit as a unit of the System (39 FR 27930). 

The U.S. Fish and Wildlife Service administers all units of the system pursuant to the 

Administration Act. The acquisition authority for establishing the refuge is found in the Fish and 

Wildlife Act of 1956 (16 U.S.C. 742f(b)(1)). It states the general purpose for establishing the 

refuge is “...for the development, advancement, management, conservation, and protection of 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F – Wilderness Review F-11 

fish and wildlife resources...” and “...for the benefit of the United States Fish and Wildlife 

Service, in performing its activities and services” (16 U.S.C. 742f (a) (4)). The specific purpose 

for establishing Howland is (USFWS 1973): “...the restoration and preservation of the complete 

ecosystem, terrestrial and marine. Special consideration must be given to the protection of 

nesting seabird populations.” There are no valid existing private rights, including mineral rights, 

associated with any of these WSAs. 

Several management activities are required for the Service to meet responsibilities for managing 

Howland Island and its associated marine waters as a national wildlife refuge as specified in 

relevant legislation and policies. A complete description of management activities can be found 

in Chapter 2 of the Howland CCP/EA. The following is a brief description of management 

activities as they relate to minimum requirement determinations of activities occurring within 

designated wilderness. 

Section 4(c) of the Wilderness Act of 1964 lists several generally prohibited uses including no 

temporary roads, no use of motor vehicles, no motorized equipment or motorboats, no aircraft 

landings, no other forms of mechanical transport, and no structure or installation. However, 

Section 4(c) also states an exception to these general prohibitions: “...as necessary to meet 

minimum requirements for the administration of the area for the purpose of this Act...” 

Examples of actions that may satisfy this exception include recreational developments such as 

trails, bridges, and signs. 

Each WSA on Howland can be managed to preserve its wilderness character in perpetuity, 

recognizing that using a “minimum requirements” approach would be required for all activities. 

Existing refuge management activities within the WSAs are consistent with management 

direction in the Wilderness Act and current Service wilderness stewardship policy in the Refuge 

Manual (6 RM 8). These management activities include: motorized marine vessel transportation 

to and from Howland; establishing temporary field camps (typically 2 days every other year); 

small motorboat operations used in deployment and demobilization of field camp operations; 

survey and monitoring of habitat, seabird and other wildlife monitoring activities; control of 

invasive species using hand pulling or hand spraying; use of solar powered electronic calling 

devices to encourage nesting by extirpated seabird species; use of portable generators and solar 

power to operate communications and other equipment; and monitoring the marine ecosystem 

with the use of SCUBA equipment. None of the current or expected refuge management 

activities would permanently diminish the wilderness character of Howland. Additionally, there 

are no plans to construct permanent facilities or structures to accommodate these uses or 

activities. 

Located in the central Pacific Ocean, transportation to Howland can only occur with the use of 

ocean-going marine vessels. The only practical and safe mode of vessel propulsion is gas or 

diesel powered engine. While it is possible to use sail power to navigate to the island, the 

reliability of mechanical engines provides a margin of safety to escape extreme weather hazards, 

or proceed on course and on time in the absence of wind. For the same reasons of safety and 

practicality, small motorized vessels are used to transport equipment and personnel from the 

transport vessel to the island to establish field camps and conduct biological survey and 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

F-12 Appendix F – Wilderness Review 

monitoring activities. Rough surf, shallow coral reefs, and strong winds preclude the use of nonmotorized craft to safely navigate these hazards. 

Field camps themselves are temporary, consisting of tents, portable tables, chairs, cooking gear, 

and scientific equipment. Most field camps are set up for a period of 1 to 2 days. No permanent 

structures are established, and no motorized equipment is used to transport equipment around the 

island. Field camp activities consist of monitoring habitat and nesting seabird populations, 

inventorying the condition of known historic resources, and collecting and stockpiling of marine 

debris. Portable diesel powered generators are components of field camp equipment and are 

typically used to operate two-way radio communication equipment. 

Wildlife managers often use electronic calling devices to attract nesting seabird species to 

suitable nesting locations. Powered by small solar panels, these devices can be placed in 

inconspicuous locations and produce only sounds that occur naturally on the island. Once a 

species is attracted to the island, the calling devise can then be removed. Monitoring of the 

marine ecosystem occurs from scientists based aboard the marine transportation vessel. Small 

motorboats often provide safe transportation to specific research sites near Howland. SCUBA 

equipment is often used to complete marine surveys and is the only safe and practical method of 

conducting underwater marine surveys. 

In summary, safety, practicality, and effectiveness require the occasional use of management 

programs and associated tools (some of which are generally prohibited by the Wilderness Act) to 

pursue achievement of refuge purposes, goals and objectives. Current and proposed refuge 

management would be consistent with wilderness designation and management of both WSAs. 

Although occasionally diminished, none of the resource values identified above would be 

permanently impacted because of wilderness designation and the management described herein. 

IV. Development of Alternatives 

 

After evaluating the quality of wilderness values, manageability, minimum management 

requirements, the following alternatives were developed and analyzed for wilderness 

designation. 

Alternative A (No Action). 

Under this alternative, no WSAs would be recommended as suitable for wilderness 

designation. The refuge lands and waters would be managed as they have been in the past 

to accomplish refuge purposes in accordance with legal and policy guidance for the 

System. 

Alternative B 

Only the emergent lands, WSA-A, would be recommended for inclusion in the National 

Wilderness Preservation System. 

Alternative C

Both WSA-A and WSA-B, which includes the emergent lands and the submerged lands 

and associated water column would be immediately recommended for inclusion in the 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F – Wilderness Review F-13 

National Wilderness Preservation System (NWPS). Selection of this alternative would 

require the completion of an EIS. 

Alternative D (Preferred Alternative)

Both WSA-A and WSA-B, which includes the emergent lands and the submerged lands 

and associated water column of Howland would be recommended for inclusion in the 

NWPS. Both wilderness study areas would be managed to ensure their wilderness 

character was not adversely impacted. However, the recommendation to include these 

areas in the NWPS would be postponed until such time that CCPs and their associated 

wilderness inventories and studies for remote Pacific Island NWRs were completed. At 

such a time, a wilderness study report and associated Legislative Environmental Impact 

Statement that encompasses remote Pacific Island refuges would be prepared. Alternative 

D is identified here as the Preferred Alternative for the Wilderness Review of Howland, 

and is a component of the Preferred Alternative in the Draft Howland CCP/EA. 

 

Alternatives considered but eliminated from detailed study

Federal agencies are required by NEPA to rigorously explore and objectively evaluate all 

reasonable alternatives and to briefly discuss the reasons for eliminating any alternatives 

that were not developed in detail (40 CFR 1502.14). It was determined that there was no 

benefit in analyzing partial wilderness alternatives. There are no feasible or practical 

boundary adjustments that would improve the manageability of an individual WSA. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

F-14 Appendix F – Wilderness Review 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G – Statement of Compliance G-1 

Appendix G. Statement of Compliance

STATEMENT OF COMPLIANCE 

for Implementation of the 

Howland Island National Wildlife Refuge

Comprehensive Conservation Plan 

The following executive orders and legislative acts have been reviewed as they apply to 

implementation of the Comprehensive Conservation Plan (CCP) for the Howland Island National 

Wildlife Refuge (Howland). 

National Environmental Policy Act (1969) (42 U.S.C. 4321 et seq.). The CCP planning 

process has been conducted in accordance with National Environmental Policy Act 

implementing procedures, Department of the Interior and Service procedures, and is 

performed in coordination with the affected public. Procedures used to reach this decision 

meet the requirements of the National Environmental Policy Act and its implementing 

regulations in 40 CFR Parts 1500-1508. These procedures include: the development of a 

range of alternatives for the Howland CCP; analysis of the likely effects of each alternative; 

and public involvement throughout the planning process. 

The CCP management objectives and alternatives have been integrated into an environmental 

assessment document and process, including the release of a Draft CCP/EA for a 30-day 

public comment period. Public notices of availability of the Draft CCP/EA include a Federal 

Register notice, news releases to local media outlets, the Service’s refuge planning website, 

and planning updates. Copies of the Draft CCP/EA and planning updates were distributed to 

an extensive mailing list. In addition, the Service met with staff from the Hawaii Department 

of Land and Natural Resources and the National Oceanic and Atmospheric Administration. 

Revisions to the final CCP are based on public comments received on the Draft CCP/EA. 

Comment letters and Service response to comments can be found as an Appendix in the CCP. 

National Historic Preservation Act (1966) (16 U.S. C.470 et seq.). This act requires 

Federal agencies to consult with the President’s Advisory Council on Historic Preservation 

(ACHP), State or Territorial Historic Preservation Officers, and the National Park Service 

(NPS) for any proposed actions that may affect cultural resources eligible for the National 

Register of Historic Places. Consultation has occurred with the ACHP and NPS for their 

input. Consultation with a State Historic Preservation Officer is not required for this 

proposal because Howland lies outside any state jurisdiction. No Territorial Historic 

Preservation Officer is assigned to Howland. Rather territories/possessions lie in the 

jurisdiction of the Advisory Council on Historic Preservation (ACHP). 

The management of archaeological and cultural resources of Howland complies with the 

regulations of Section 106 of the National Historic Preservation Act. No historic properties 

listed in or eligible for listing in the National Register of Historic Places have been identified 

on Howland. No historic properties are known to be affected by the proposed action based 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

G-2 Appendix G – Statement of Compliance 

on the criteria of an effect or adverse effect as an undertaking defined in 36 CFR 800.9 and 

Service Manual 614 FW 2. Determining whether a particular action has a potential to affect 

cultural resources is an ongoing process that occurs as step-down and site-specific project 

plans are developed. Should historic properties be identified in the future, the Service will 

comply with the National Historic Preservation Act if any management actions have the 

potential to affect any these properties. 

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), 

Secretarial Order 3127, and Section 211 of the Superfund Amendments and 

Reauthorization Act (SARA) of 1986 (10 U.S.C. 2701-2706, 2810-2811). Contamination 

resulting from military occupation is required to be mitigated as a Formerly Used Defense 

Site (FUDS). Any FUDS is part of the Defense Environmental Restoration Program 

(DERP), administered by the Army Corps of Engineers (ACOE). The DERP is responsible 

for the identification, investigation, research and development, and cleanup of contamination 

from hazardous substances, and pollutants and contaminants; correction of environmental 

damage such as detection and disposal of unexploded ordnance; and demolition and removal 

of unsafe buildings and structures at former Department of Defense sites. In 1986, the ACOE 

completed their responsibilities under DERP. No contaminant or hazardous waste materials 

are currently known to exist on Howland. 

 

Executive Order 13175. Consultation and Coordination with Indian Tribal 

Governments. As required under Secretary of the Interior Order 3206 American Indian 

Tribal Rights, Federal-Tribal Responsibilities, and the Endangered Species Act, the Refuge 

Manager determined that there are no tribal governments associated with Howland. Thus, 

there was no coordination with any American Indian tribe. 

Executive Order 12372. Intergovernmental Review. Coordination and consultation with 

other affected Federal agencies has been completed through personal contact by Service 

planners, refuge managers, and supervisors. In addition, the refuge manager determined 

there are no local, state or tribal governments associated with Howland. 

Executive Order 12898. Federal Actions to Address Environmental Justice in Minority 

and Low-Income Populations. All Federal actions must address and identify, as 

appropriate, disproportionately high and adverse human health or environmental effects of its 

programs, policies, and activities on minority populations, low-income populations, and 

Indian Tribes in the United States. The CCP was evaluated and no adverse human health or 

environmental effects were identified for minority or low-income populations, Indian Tribes, 

or anyone else. 

Migratory Bird Treaty Act (MBTA)(16 U.S.C. 703-712) Howland is an important site for 

migratory shorebirds and nesting seabirds. Protecting nesting seabird habitat is the major 

purpose of the refuge, and is consistent with the provisions of MBTA. All of the proposed 

alternatives would be consistent with the refuge purpose and the MBTA in protecting these 

birds. The proposed action, however, would afford more benefits. This planning effort is 

being coordinated with other offices of the Service and Interior that have responsibilities 

pertaining to the MBTA. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G – Statement of Compliance G-3 

Executive Order 13186. Responsibilities of Federal Agencies to Protect Migratory 

Birds. This Order directs departments and agencies to take certain actions to further 

implement the Migratory Bird Treaty Act. A provision of the Order directs Federal agencies 

to consider the impacts of their activities, especially in reference to birds on the Fish and 

Wildlife Service’s list of Birds of Conservation (Management) Concern (BCC). It also 

directs agencies to incorporate conservation recommendations and objectives found within 

the North American Waterbird Conservation Plan and bird conservation plans developed by 

Partners in Flight (PIF) into agency planning. Species selected as focal conservation targets 

in the CCP were identified from multiple sources including pertinent BCC lists, applicable 

Flyway Management Plans, and regional seabird and shorebird conservation plans. The 

effects of all alternatives on focal conservation targets were assessed during this planning 

process. 

Endangered Species Act (ESA) (16 U.S.C. 1531-1544). The ESA provides for the 

conservation of threatened and endangered species of fish, wildlife, and plants by Federal 

action and by encouraging the establishment of state programs. It provides for the 

determination and listing of endangered and threatened species and the designation of critical 

habitats. Section 7 of the ESA requires refuge managers to perform consultation before 

initiating projects that affect or may affect endangered species. 

Howland provides feeding and potentially nesting habitats for two species of endangered sea 

turtle: the hawksbill turtle, Eretmochelys imbricata and the green turtle Chelonia mydas. In 

accordance with section 7 of the Endangered Species Act of 1973, as amended (16 U.S.C. 

1531 et. Seq.), the Service, as a component of this CCP/EA, evaluated potential impacts to 

the two listed turtle species. It was determined that undertaking any action as part of any 

alternative in this CCP will have no affect on either of the two turtle species. Therefore, 

formal consultation with NOAA-NMFS is not required and will not be initiated. 

 

National Wildlife Administration Act of 1966, as amended by The National Wildlife 

Refuge System Improvement Act of 1997 (16 U.S.C. 668dd-668ee). The National 

Wildlife Refuge System Improvement Act requires the Service to develop and implement a 

comprehensive conservation plan for each refuge. These conservation plans identify and 

describe a refuge purpose; refuge vision and goals; fish, wildlife, and plant populations and 

related habitats; archaeological and cultural values of the refuge; issues that may affect 

populations and habitats of fish, wildlife, and plants; actions necessary to restore and 

improve biological diversity of the refuge; and opportunities for wildlife-dependent 

recreation. 

Wilderness Preservation Act of 1964 (Wilderness Act). The Wilderness Act requires the 

Service to evaluate the suitability of Howland for wilderness designation (Appendix F) and 

has found that both wilderness study areas meet wilderness criteria. Recommendation for 

Howland to be included in the Wilderness Preservation System is deferred until such time 

that other remote Pacific island refuges are evaluated for wilderness designation and a 

combined proposal as part of a larger comprehensive Legislative Environmental Impact 

Statement is prepared. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

G-4 Appendix G – Statement of Compliance 

Magnuson-Stevens Fisheries Management and Conservation Act (16 U.S.C. 1801-1882).

This act provides the guidance for sustainable management of commercial fisheries in 

Federal waters by NOAA in consultation with Regional Fisheries Management Councils that 

develop fisheries management plans (FMPS) subject to NOAA approval, monitoring and 

implementation. The Western Pacific Regional Fisheries Management Council (WESPAC) 

and NOAA have implemented and approved several FMPS that apply to U.S. insular Pacific 

island waters. The FMPS were all implemented after Howland was established in 1974 and 

include plans for: 1) pelagic fish; 2) bottom fish including some reef species; 3) crustaceans 

including lobsters; 4) precious corals and; 5) coral reef ecosystem species. Commercial 

activities including commercial fishing are prohibited in surrounding marine water and 

benthic habitat out to the 3 nmi limit because Howland Island is established as a National 

Wildlife Refuge that is closed to public uses. Moreover, the Service retains jurisdiction and 

management for any fisheries within the refuge. Available information indicates commercial 

fishing under the auspices of any of the FMPS is not and cannot be pursued within the 3 nmi 

boundary of the refuge. In addition, the Magnuson-Stevens Fisheries Management and 

Conservation Act jurisdiction is subject to other applicable laws and does not apply in 

Howland Island National Wildlife Refuge because this area is closed to public access and 

commercial fishing under the existing National Wildlife Refuge System Administration Act, 

as amended (16 U.S.C.668dd -6688ee). 

Executive Order 13089, Coral Reef Protection (June 11, 1998). The purpose of this 

Executive order is “...to preserve and protect the biodiversity, health, heritage, and social and 

economic value of U.S. coral reef ecosystems and the marine environment...” It directs all 

Federal agencies to identify actions that may affect U.S. coral reefs; utilize their programs 

and authorities to protect and enhance coral reef ecosystems; and assure their actions would 

not degrade those ecosystems. Federal agencies whose actions affect U.S. coral reef 

ecosystems are further directed to implement measures needed to research, monitor, manage, 

and restore affected ecosystems, including, but not limited to, measures reducing impacts 

from pollution, sedimentation, and fishing. This Executive Order also initially established 

the U.S. Coral Reef Task Force, co-chaired by the Secretaries of the Interior and Commerce, 

through the Administrator of NOAA. The Task Force has oversight responsibility for 

implementation of policy and Federal agency responsibilities found in this order, and support 

activities under the U.S. Coral Reef Initiative. In addition, this order directs the Task Force 

to work cooperatively with State, territory, commonwealth, and local government partners to 

map, monitor, conserve, mitigate, and restore coral reef ecosystems. 

The Proposed Action and other alternatives are fully consistent with the spirit and intent of 

the Executive order. Copies of the Draft and final CCP/EA were provided to the Directorate 

of the Coral Reef Task Force for coordination. 

Coral Reef Conservation Act and Executive Order 13158, Marine Protected Areas (16 

U.S.C. 6401-6409) (May 26, 2000). These statutes collectively direct Federal agencies to 

coordinate among themselves and State and Territorial governments via the Coral Reef Task 

Force to protect and enhance coral reefs and avoid actions that degrade reefs, promote marine 

protected area development and reef restoration, and provide conservation grants and 

cooperative agreements (including States and institutions) to conduct research and 

Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

G-6 Appendix G – Statement of Compliance 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix H – Plan Implementation and Costs H-1 

Appendix H. Plan Implementation and Costs

Introduction 

Following public review and comment, public notification of the Service’s decision, and CCP 

approval, Refuge staff will implement the CCP. This appendix describes the various 

partnerships, management plans, staffing and projects required to implement the plan over the 

next 15 years. 

Staffing 

The proportion of current staffing and proposed staffing within the Pacific Remote Islands NWR 

Complex dedicated to Howland are shown in the following tables. The proposed staffing 

indicates a 0.16 full-time-equivalent increase over current levels. This represents the difference 

in staffing needs from visiting Howland once every other year to once every year. 

Current Staffing for Howland Island NWR 

Staff Employment Status and 

Proportion of Time1 

Salary Rating

Project Leader PFT (0.01 FTE) GS 13 

Supervisory Wildlife 

Biologist 

PFT (0.07 FTE) GS 12 

Coral Reef Biologist PFT (0.07 FTE) GS 12 

Administrative Officer PFT (0.01 FTE) GS 9 

1 PFT = Permanent Full Time; FTE = Full Time Equivalent where 1.0 equals one staff year. 

Proposed Staffing for Howland Island NWR 

Staff Employment Status and 

Proportion of Time1 

Salary Rating

Project Leader PFT (0.02 FTE) GS 13 

Supervisory Wildlife 

Biologist 

PFT (0.14 FTE) GS 12 

Coral Reef Biologist PFT (0.14 FTE) GS 12 

Administrative Officer PFT (0.02 FTE) GS 9 

1 PFT = Permanent Full Time; FTE = Full Time Equivalent where 1.0 equals one staff year. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

H-2 Appendix H – Plan Implementation and Costs 

Funding 

The following table describes the estimated annual cost to implement the CCP. 

Field Camp Budget for Howland Cost 

Staff $34,000 (0.3 FTE per year) 

Supplies $7,000 

Remote Sensing equipment N/A 

Remote Sensing operations N/A 

Deep sea exploration $25,000 per submersible vessel dive 

Seabird recolonization initiative $10,000 

Vessel Charter N/A 

Vessel Purchase (one time cost) N/A 

Vessel operation N/A 

Adjusted annual personnel and operating costs $76,000/yr 

Projects 

The table below contains projects developed as part of the Refuge Operating Needs System 

(RONS) and Service Asset Maintenance Management System (SAMMS). Brief project 

descriptions and their associated costs are provided. Funding of these projects would assist 

refuge staff in achieving the goals, objectives, and strategies of the CCP for Howland Island 

NWR. 

Projects: RONS and SAMMS List 

Project 

No. Title and Description 

Cost 

Estimate 

(Thousands) 

Station

Rank 

97003 Inventory and Monitor Terrestrial Resources:

Provide a wildlife biologist to inventory and monitor 

terrestrial plants, invertebrates and nesting seabirds. 

Remote Pacific Islands provide the only secure habitat 

for nesting seabirds, sea turtles and marine life within 

thousands of square miles of ocean. 

325.25 9 

00001 Eliminate Exotic Rodent Species on Remote Pacific 

Islands: Provide biological technicians and 

transportation expenses to restore habitat for pelagic 

seabirds and terrestrial plant and animal species on 

Howland, Baker and Jarvis NWRs. 

194.0 10 

980002 Eliminate Exotic Rodent Species on Remote Pacific 

Islands: Provide Wildlife Refuge Specialist to supervise 

biological technicians and transportation expenses to 

restore habitat for pelagic seabirds and terrestrial plant/ 

animal species on Howland, Baker and Jarvis NWRs. 

174.75 10 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix H – Plan Implementation and Costs H-3 

Project 

No. Title and Description 

Cost 

Estimate 

(Thousands) 

Station

Rank 

00002 Develop interpretative program, Remote Island 

NWRs: Develop a brochure for Baker, Howland and 

Jarvis Island NWRs and host 3 special outreach events 

every year in Hawaii. 

23.9 999 

00006 Staff and maintain a new vessel to accomplish basic 

refuge operations: This vessel would provide basic 

logistical support for 16 islands and remote field stations 

on nine different national wildlife refuges across the 

Pacific Ocean. The vessel would be similar in size and 

capability to the M/V Tiglax at Alaska Maritime NWR. 

204.8 3 

00018 Inventory and monitor coral reef resources: Remote 

refuges contain some of the most valuable and 

spectacular marine and coralline resources in the 

National Wildlife Refuge System. Howland Island 

NWR is so remote that basic knowledge of marine 

resources is lacking. There is a need to perform biennial 

monitoring of the marine resources at this refuge. 

137.0 4 

98004 Install remote surveillance system: Acquire camera 

equipment and service contract with a satellite 

communications provider to detect incursion by 

unauthorized visitors, such as poachers and commercial 

fishing vessels to assist the Coast Guard and Refuge Law 

Enforcement Officers in investigating illegal activities 

within the Refuge. 

241.2 14 

90100411 Replace broken, rotten, and vandalized signs: Replace 

degraded entrance signs to deter trespass and prevent 

introduction of invasive species. 

190.0 6 

02121745 Rehabilitate historic Amelia Earhart Day Beacon: 

This beacon not only has historic significance, it is also 

used as a landmark by mariners. The beacon requires 

structural repairs and painting. 

355.0 999 

Partnerships

Partnerships are an important component of implementation of the Howland Island NWR CCP. 

Refuge staff would strengthen existing partnerships with the U.S. Coast Guard, the National 

Oceanic and Atmospheric Administration, and the University of Hawaii Undersea Research 

Laboratory to implement enhanced law enforcement coverage at this remote location and 

facilitate inventory and monitoring of marine resources. In addition, the refuge staff would seek 

to enhance its volunteer program. Volunteers are critically important in providing the logistical 

support in the Honolulu office and field support required to effectively manage and operate yearround field camps at remote locations. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

H-4 Appendix H – Plan Implementation and Costs 

Step-Down Management Plans

The CCP is one of several plans necessary for refuge management. The CCP provides guidance 

in the form of goals, objectives, and strategies for several refuge program areas but may lack 

some of the specifics need for implementation. Given the abbreviated and qualitative once-ayear management activities identified in the preferred alternative, step-down plans would not be 

developed for individual program areas after CCP completion. The Draft Seabird Monitoring 

Assessment for Hawaii and the Pacific Islands (Citta and Reynolds, 2006), U.S. Pacific Islands 

Regional Shorebird Conservation Plan, Seabird Conservation Plan for the Pacific Region, and 

U.S. Coral Reef Task Force planning efforts would be applied to refuge operations described in 

the preferred alternative. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix I – Consultation and Coordination I-1 

Appendix I. Consultation and Coordination

This section describes consultation and coordination efforts with the public, interested groups, 

and other agencies through the draft CCP/EA phase. Public involvement was sought throughout 

the planning process using meetings, newsletters, and other communication tools. All comments 

and responses to comments on the draft CCP may be found in Appendix J. 

 

Planning Updates

The first Planning Update was mailed to 249 private individuals; nongovernmental 

organizations; local, state, Federal and international governments; and members of the media 

throughout the Pacific on October 12, 2005. The comment period identified in the Planning 

Update closed on November 14, 2005. This update announced the intent of the Service to 

produce a CCP for Howland, and invited comments on issues and concerns and interest in 

attending public meetings. A total of five responses were received. 

A second planning update was mailed on May 17, 2006. This update announced the 

development of a list of alternatives and solicited comments on the draft alternatives. This 

update was mailed to 253 private individuals; non-governmental organizations; local, state, 

Federal and international governments; and members of the media throughout the Pacific. 

A third Planning Update was mailed with the Draft Howland Island Comprehensive 

Conservation Plan and Environmental Assessment in September 2007. This Planning Update 

and the Draft CCP/EA was distributed to about 190 individuals and organizations, and posted on 

Region 1’s website. Nine review comments were received during the 45-day comment period. 

Agency and Interest Group Consultation/Coordination

Members of the planning team met with NOAA staff and the Hawaii Department of Land and 

Natural Resources (DLNR) on May 31, 2005. Refuge staff also met with members of The 

Nature Conservancy on June 2, 2005. Both NOAA and DLNR informally indicated that they 

were interested in the process, wished to be kept informed of planning progress and would 

review the draft plan when it became available. 

A second meeting between State, NOAA, and Service staff was held on May 19, 2006 to discuss 

issues of mutual interest, which included their potential involvement in the Service’s CCP 

process. A follow-up formal request was sent to the agencies on June 7, 2006. 

Howland Island is uninhabited and an unincorporated U.S. territory far removed and beyond the 

jurisdiction of any State, insular area, or foreign nation. Other parties involved in 

correspondence related to this document included multiple nongovernmental organizations, U.S. 

Environmental Protection Agency; National Park Service; U.S. Geological Survey; U.S. 

Department of Defense; President’s Advisory Council on Historic Preservation; National 

Oceanic and Atmospheric Administration (NOAA); Western Pacific Regional Fishery 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

I-2 Appendix I – Consultation and Coordination 

Management Council; Hawaii Department of Land and Natural Resources; Hawaii Office of 

Hawaiian Affairs; Governor of Hawaii; the Honorary Consulate-General of the Republic of 

Kiribati; and the United Nations Educational, Scientific and Cultural Organization (UNESCO). 

Federal Register Notices

The Notice of Intent to prepare a CCP for these refuges was published in the Federal Register on 

September 14, 2005. 

The Notice of Availability of the Draft Howland Island Comprehensive Conservation Plan and 

Environmental Assessment was published in the Federal Register on September 18, 2007. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix J – Response to Comments J-1 

Appendix J. Response to Comments

 

The Refuge received four letters and five emails in response to the Draft CCP/EA. Comments 

are summarized below by topic. The comment is either quoted directly or paraphrased based 

upon the comment received. 

1. Wildlife Management 

Comment: We encourage the Service to maintain its “wildlife first” philosophy and to prescribe 

the best and most thorough protection for plants and animals. (The Wilderness Society) 

Service Response: By implementing the preferred alternative Howland Island NWR will 

continue to be managed as a wild, natural area. This management regime will contribute to the 

recovery, protection, and management efforts for all native species with special consideration for 

seabirds, migratory shorebirds, federally listed threatened and endangered species, and coral reef 

species. 

Comment: We recommend that an effort to inventory, monitor, protect and enhance habitat for 

refuge species is outlined in the CCP. (The Wilderness Society) 

Service Response: The CCP contains specific objectives and strategies to inventory, monitor, 

protect, and enhance native terrestrial habitats and marine communities that are representative of 

remote tropical Pacific Islands. 

Comment: It is not clear what the scientific basis is for the statement linking seabird health to 

pelagic fisheries in the equatorial waters surrounding the three islands. NMFS requests the FWS 

to provide NMFS and the Western Pacific Regional Fisheries Management Council more 

information, including scientific support for that statement. (National Marine Fisheries Service) 

Service Response: Information and scientific citations have been added to the plan to document 

the linkage between pelagic fish activity and its importance to seabird foraging activity. 

Comment: The CCP should include a method to inventory the impact of human activities on 

species populations. (The Wilderness Society) 

Service Response: Refuge management will be limited to monitoring terrestrial and marine 

plants and animals and removal of non-native species. The Refuges will also remain closed to 

public use to protect the extensive seabird nesting colonies, reduce the threat of introduction of 

invasive species, and conserve the pristine coral reef ecosystems. So the low level of human 

activities will have non-detectable impacts species populations. 

Comment: The Final CCPs should include monitoring and enforcement provisions. (Marine 

Conservation Biology Institute) 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

J-2 Appendix J – Response to Comments 

Service Response: We agree. Goal 5 of the CCP has been expanded to include biological 

resource preservation. An objective and associated strategy has been added to encompass 

enforcement provisions to accomplish the preservation goal. 

Comment: I highly recommend consultation with NMFS and our partners before any proposal 

for fisheries enforcement activities. (National Marine Fisheries Service) 

Service Response: We agree with this recommendation and look forward to continuing the 

existing collaborative relationship that exists among our respective agency’s law enforcement 

personnel. 

Comment: We request that the Service analyze and disclose all wildlife and fisheries 

management and conservation plans in the CCP. (The Wilderness Society) 

Service Response: Regional and Ecosystem Conservation Plans important for developing the 

CCP are summarized in Section 1.4.5 of the plan. 

Comment: The CCP and preferred alternative B do not meet the mission of the National 

Wildlife Refuge System. (Center for Biological Diversity) 

Service Response: We respectfully disagree. The goals and their respective strategies and 

activities in the CCP are designed to manage for “wildlife first” at Howland Island NWR and 

contribute to the System’s national network of lands and waters administered for “the 

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

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

generations of Americans.” 

Comment: Alternative D should be the preferred alternative. (Marine Conservation Biology 

Institute) 

Service Response: While alternative D may be preferable from a conservation standpoint, it is 

not practical either logistically or financially to implement this management regime within the 

15-year lifespan of this plan.

Comment: Hopefully more funds could make options 3 or 4 possible but at the very least option 

2 is good. (K. Stender) 

Service Response: We will use an adaptive management approach over the life of this plan. If 

additional funds unexpectedly become available, strategies and activities identified in 

alternatives C and D could be implemented. 

Comment: I support Alternative B with the addition that management responsibilities should 

extend from the shoreline seaward to 100 fathoms to cover all coral associated with each island. 

These three islands should be no-take marine protected areas. (B. Carmen) 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix J – Response to Comments J-3 

Service Response: We appreciate your support and the CCP does implement a no-take marine 

protected area management regime. In addition, the seaward boundary of the refuge is beyond 

the 100 fathom depth contour around the island. Therefore, all of the coral reefs at Howland 

Island are fully protected in accordance with the provisions of the National Wildlife Refuge 

System Administration Act of 1966, as amended. 

Comment: The Final CCPs should include a more specific provision for reevaluation. (Marine 

Conservation Biology Institute) 

Service Response: The Department of the Interior and the Service support the use of adaptive 

management to address uncertainty associated with implementing conservation activities. The 

“learning by doing” inherent in implementing activities in this CCP is central to re-evaluating the 

effectiveness of these activities and determining the need for management interventions to 

achieve the six goals identified in this plan. 

2. Wilderness Review 

Comment: We request that the Service analyze the wilderness resources in the CCP. (The 

Wilderness Society) 

Service Response: The Service completed a Wilderness Review for Howland Island NWR and 

it is found in Appendix F of the CCP. 

Comment: The CCP must also address management of both potential and designated 

wilderness lands in the CCP. (The Wilderness Society) 

Service Response: The wilderness study area for Howland Island NWR identified in the CCP 

will be managed to ensure its wilderness character is not adversely impacted by implementing 

the management activities in the CCP. 

Comment: The CCP should examine and outline a plan for off-road vehicle use. (The 

Wilderness Society) 

Service Response: Off-road vehicle use has not been determined to be a compatible use on the 

refuge and is currently prohibited. 

Comment: NMFS recommends that any wilderness-related management action requiring 

consideration and collaboration between our two agencies by fully described at the earliest 

opportunity. 

Service Response: The Service will notify NMFS at such time that we decide to move forward 

in preparing a wilderness study report and associated Legislative Environmental Impact 

Statement for Howland Island NWR. 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

J-4 Appendix J – Response to Comments 

3. Climate Change 

Comment: We believe that the Service should take a proactive approach and identify specific 

climate change concerns and formulate appropriate management strategies. (The Wilderness 

Society) 

Service Response: We have included an objective in the CCP to increase understanding of 

impacts of global climate change by working with other agencies or institutions to conduct 

baseline global climate change investigations at this refuge. 

Comment: The impacts of climate change were not adequately considered in the CCP. (Center 

for Biological Diversity) 

Service Response: New information that has recently emerged on this issue has been added to 

the CCP.

Comment: Looks like the refuges would be an ideal but remote location to study climate 

change on reefs as a control. (K. Stender) 

Service Response: We agree. 

4. Commercial Fishing and Jurisdictional Issues 

Comment: The treatment of commercial fishing and jurisdictional issues in these draft CCPs is 

incomplete. Each CCP should explain the processes and coordination necessary to achieve any 

management regime applicable to federal fisheries. (National Marine Fisheries Service) 

Service Response: The “Refuge Establishment” section of the CCP has been revised to clearly 

indicate that the National Wildlife Refuge System Administration Act of 1966, as amended 

requires that the U.S. Fish and Wildlife Service maintain sole and exclusive management 

authority over all national wildlife refuge areas. At Howland Island NWR, the refuge includes 

the island and the surrounding waters out to the 3-nautical mile boundary depicted in Figure 1.2. 

The CCP clearly indicates that the refuge will remain closed to all public uses, including 

commercial fishing. The information in Appendix G pertaining to the Magnuson-Stevens 

Fisheries Management and Conservation Act has been revised to clearly identify the jurisdiction 

of the NMFS to regulate commercial fishing outside of the refuge boundary and the requirement 

that this Act must conform to other applicable laws, including the National Wildlife Refuge 

System Administration Act of 1966, as amended. 

Comment: NMFS would like a more detailed description of FWS activities to assist the 

Department of State in negotiating a United States position on managing commercial fishing in 

the U.S. Exclusive Economic Zones adjacent to the Pacific Remote Insular Areas. (National 

Marine Fisheries Service) 

Service Response: We have clarified language and provided more detail in the document that it 

was the Department of the Interior who notified the Department of State about a request from the 
Howland Island National Wildlife Refuge Comprehensive Conservation Plan 

Appendix J – Response to Comments J-5 

Republic of Kiribati to conduct commercial fishing in the U.S. Exclusive Economic Zone 

surrounding Baker Island, Howland Island, and Jarvis Island. 

Comment: We have no record of a personal communication between Kitty Simonds and Jim 

Maragos regarding informal consultation that WESPAC continues to honor Service jurisdiction 

and authorities within the 3nmi offshore boundary of the refuge. Please provide that to us for our 

records. (Western Pacific Regional Fisheries Management Council) 

Service Response: Dr. Maragos continues to maintain that such a discussion took place with 

Ms. Kitty Simonds although a “record of a personal communication” was not prepared or filed. 

We have removed this reference from the document and clarified the legal basis for U.S. Fish 

and Wildlife Service jurisdiction to mange the 3-nautical mile territorial seas surrounding 

Howland Island in conjunction with the National Wildlife Refuge System Administration Act of 

1966, as amended. 

Comment: The Council’s Coral Reef Fisheries Management Plan needs to be included in your 

list of FMPs so as to provide complete information to readers and decision-makers. (Western 

Pacific Regional Fisheries Management Council) 

Service Response: In Appendix G, we have included the plan for coral reef species in the list of 

commercial fisheries plans developed in accordance with the Magnuson-Stevens Fisheries 

Conservation and Management Act. 

Comment: The statement that “commercial fishing under the auspices of any of the FMPs is not 

being pursued outside the 3 nmi boundary of the refuge” is erroneous and needs to be corrected. 

Service Response: This was a typographical error. The statement has been revised to read that 

“Available information indicates commercial fishing under the auspices of any of the FMPS is 

not and cannot be pursued within the 3 nmi boundary of the refuge.” 

Written Comments Received on the Draft CCP/EA 

Comment Signatory Organization 

Letter William L. Robinson National Marine Fisheries Service 

Letter Shaye Wolf Center for Biological Diversity 

Letter Keiko Bonk Marine Conservation Biology Institute 

Letter Maribeth Oakes The Wilderness Society 

Email Western Pacific Regional Fishery Management 

Council 

Email Brent Carmen 

Email pandora2@earthlink.net

Email Keoki Stender 

Email b.s achau