Finding of No Significant Impact 

for the 

James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Honolulu County, Hawai‘i 

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

(CCP) and Environmental Assessment (EA) for James Campbell National Wildlife Refuge 

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

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

alternatives, including the no action alternative. 

Decision 

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

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

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

and goals of the Refuge. 

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

 Addresses the important issues identified during the CCP scoping process. 

 Addresses the legal mandates of the Service and the Refuge. 

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

species recovery. 

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

the Refuge System mission. 

Summary of the Actions to be Implemented 

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

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

protect, maintain, and enhance habitat for endangered species and resources of concern, and 

improve the Refuge’s capability to provide food for migrating and wintering waterbirds, 

including shorebirds and waterfowl. Improving the Refuge’s coastal and wetland habitats will 

increase the value of these lands and waters for a variety of native plants and wildlife. 

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

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

summary of the CCP actions we will implement follows. 

Under Alternative C, intensive management of threatened and endangered waterbird species and 

their habitat at the Ki‘i and Punamanō Units of the Refuge will continue to focus on protection 

and successful nesting as part of the Statewide effort to implement the Hawaiian Waterbird 

Recovery Plan. Management of the unique and sensitive coastal sand dunes and coastal strand 

will be undertaken to protect and enhance the area for native vegetation, seabirds, other 

migratory birds, endangered Hawaiian Monk seals and Green turtles. A Visitor Services Plan 

(VSP) will be developed to identify, evaluate, and select sites for infrastructure needed to fully 

implement a safe and compatible program for the public (to include roads, parking areas, trails, 

Supporting References 

U.S. Fish and Wildlife Service. July 2011. James Campbell National Wildlife Refuge, Draft 

Comprehensive Conservation Plan and Environmental Assessment. 

U.S. Fish and Wildlife Service. September 2011. James Campbell National Wildlife Refuge 

Comprehensive Conservation Plan. 

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

review at O‘ahu National Wildlife Refuge Complex, 66-590 Kamehameha Highway, Room 2C 

Hale‘iwa, Hawai‘i 96712, and U.S. Fish and Wildlife Service, Hawaiian and Pacific Islands 

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

96850. These documents can also be found on the Internet at http://pacific.fws.gov/planning/. 

Interested and affected parties are being notified of our decision. 

 

James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Table of Contents i 

Table of Contents 

Reader’s Guide ..................................................................................................................................... v

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

 1.1 Purpose and Need for the CCP ........................................................................................... 1-2 

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

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

 1.2.2 National Wildlife Refuge System ............................................................................... 1-3 

 1.2.3 National Wildlife Refuge System Mission and Goals ................................................ 1-3 

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

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

 1.3.1 Previous Plans ............................................................................................................. 1-4 

 1.3.2 Future Planning ........................................................................................................... 1-5 

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

 1.4.1 General ........................................................................................................................ 1-5 

 1.4.2 James Campbell Establishment ................................................................................... 1-5 

 1.4.3 James Campbell Purpose ............................................................................................ 1-6 

 1.5 Refuge Goals ......................................................................................................................... 1-6 

 1.6 Relationship to Ecosystem Planning Efforts ..................................................................... 1-8 

 1.7 Planning and Issue Identification ..................................................................................... 1-10 

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

 1.7.2 Issues Outside the Scope of the CCP ........................................................................ 1-10 

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

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

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

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

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

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

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

 2.2.5 Fire Management ....................................................................................................... 2-3 

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

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

 2.2.8 Integrated Pest Management ...................................................................................... 2-4

 2.2.9 Law Enforcement ....................................................................................................... 2-4 

 2.2.10 Permanent Full-time Staffing Positions ..................................................................... 2-5 

 2.2.11 Summary of CCP Actions .......................................................................................... 2-5

 2.3 James Campbell NWR Management ................................................................................. 2-7 

 2.3.1 Goal 1. ........................................................................................................................ 2-7 

 2.3.2 Goal 2. ...................................................................................................................... 2-16 

 2.3.3 Goal 3. ...................................................................................................................... 2-18 

 2.3.4 Goal 4. ...................................................................................................................... 2-22 

 2.3.5 Goal 5. ...................................................................................................................... 2-24 

 2.3.6 Goal 6. ...................................................................................................................... 2-27 

 2.3.7 Goal 7. ...................................................................................................................... 2-29 

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

 3.1 Refuge Introduction ............................................................................................................. 3-1 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

ii Table of Contents 

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

 3.2.1 Global Climate Changes and Projections .................................................................. 3-2 

 3.2.2 Climate Change in Hawai‘i ........................................................................................ 3-3 

 3.2.3 Sea Level Rise ........................................................................................................... 3-4 

 3.2.4 Climate Change Effects on Water Resources ........................................................... 3-5 

 3.2.5 Ecological Responses to Climate Change ................................................................. 3-6 

 3.3 Geology and Soils ................................................................................................................. 3-8 

 3.4 Hydrology ............................................................................................................................. 3-9 

 3.5 Topography/Bathymetry ................................................................................................... 3-19 

 3.6 Environmental Contaminants .......................................................................................... 3-20 

 3.7 Land Use ............................................................................................................................. 3-21 

 3.7.1 Historic Land Divisions ............................................................................................ 3-22 

 3.7.2 Ranching ................................................................................................................... 3-22 

 3.7.3 Sugar, Pineapples, and Trains ................................................................................... 3-23

 3.7.4 Military Use .............................................................................................................. 3-23 

 3.7.5 Land Use Today ........................................................................................................ 3-24 

 3.8 Refuge Facilities ................................................................................................................. 3-25

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

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

 4.2 Conservation Targets .......................................................................................................... 4-3

 4.3 Endangered Hawaiian Waterbirds .................................................................................... 4-5 

 4.3.1 Ae‘o (Himantopus mexicanus knudseni) or Hawaiian Stilt ........................................ 4-5 

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

 4.3.3 ‘Alae ‘ula (Gallinula chloropus sandvicensis) or Hawaiian Moorhen ....................... 4-8 

 4.3.4 Koloa maoli (Anas wyvilliana) or Hawaiian Duck ..................................................... 4-9 

 4.4 Other Hawaiian Waterbirds ............................................................................................. 4-10 

 4.4.1 ‘Auku‘u (Nycticorax nycticorax hoactli) or Black-crowned Night-heron ................ 4-10 

 4.5 Migratory Waterfowl ........................................................................................................ 4-10 

 4.6 Migratory Shorebirds ........................................................................................................ 4-11 

 4.7 Seabirds .............................................................................................................................. 4-12 

 4.8 Raptors................................................................................................................................ 4-12 

 4.8.1 Pueo (Asio flammeus sandwichensis) or Hawaiian Short-eared Owl ...................... 4-12 

 4.9 Endangered Mammals ...................................................................................................... 4-13

 4.9.1 ‘Ōpe‘ape‘a (Lasiurus cinereus semotus) or Hawaiian Hoary Bat ............................ 4-13 

 4.9.2 ‘Īlio-holo-i-ka-uaua (Monachus schauinslandi) or Hawaiian Monk Seal ................ 4-13 

 4.10 Invertebrates .................................................................................................................... 4-14

 4.10.1 ‘Ōpae ‘ula (Halocaridina rubra) or Hawaiian Red Shrimp ................................... 4-14 

4.11 Marine Reptiles ................................................................................................................. 4-14 

 4.11.1 Honu (Chelonia mydas) or Hawaiian Green Turtle ................................................ 4-14 

 4.12 Native Plants ..................................................................................................................... 4-15 

 4.12.1 Naupaka Kahakai (Scaevola taccada) or Beach Naupaka ..................................... 4-16 

 4.12.2 ‘Ilima (Sida fallax) or Yellow Ilima ...................................................................... 4-16 

 4.12.3 Hala (Pandanus tectorius) or Screw-pine .............................................................. 4-16 

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

 4.13.1 Mammals ................................................................................................................ 4-18 

 4.13.2 Birds ........................................................................................................................ 4-20 

 4.13.3 Amphibians ............................................................................................................. 4-21 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Table of Contents iii 

 4.13.4 Invertebrates ............................................................................................................ 4-22 

 4.13.5 Plants ....................................................................................................................... 4-22 

 4.13.6 Diseases................................................................................................................... 4-25 

 4.14 Habitats ............................................................................................................................. 4-26 

 4.14.1 Coastal Dune/Beach Strand .................................................................................... 4-26 

 4.14.2 Wetlands ................................................................................................................. 4-28 

 4.14.3 Exposed Coral Shelf and Anchialine Pools ............................................................ 4-29 

 4.14.4 Coastal Shrubland (Scrub/Shrub) ........................................................................... 4-30 

Chapter 5. Outdoor Recreation, Social, and Economic Factors .................................................. 5-1 

 5.1 Outdoor Recreation ............................................................................................................. 5-1 

 5.1.1 Federal, State, and County Recreational Parks ........................................................... 5-1 

 5.1.2 Historic/Cultural Sites ................................................................................................. 5-2 

 5.1.3 Ocean Recreation ........................................................................................................ 5-3 

 5.1.4 Wildlife Observation, Photography, Interpretation, and Environmental Education ... 5-3 

 5.1.5 Fishing ........................................................................................................................ 5-4 

 5.1.6 Hunting ....................................................................................................................... 5-4 

 5.2 Social and Economic Conditions ........................................................................................ 5-5 

 5.2.1 Population ................................................................................................................... 5-5 

 5.2.2 Education .................................................................................................................... 5-5 

 5.2.3 Economy ..................................................................................................................... 5-6 

 5.2.4 Refuge Contribution.................................................................................................... 5-7 

Tables 

Table 2.1 James Campbell NWR Management Summary ................................................................ 2-6 

Table 4.1 Biological Integrity, Diversity, and Environmental Health ............................................... 4-2 

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

Table 4.3 Shorebirds of Primary Conservation Importance in the Pacific Region .......................... 4-11 

Figures 

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

Figure 2.1 Habitat Management....................................................................................................... 2-31 

Figure 2.2 Habitat Management - Ki‘i Unit .................................................................................... 2-33 

Figure 3.1 Historic Land Divisions .................................................................................................. 3-11 

Figure 3.2 Refuge Land Status & Boundary .................................................................................... 3-13 

Figure 3.3 Soils ................................................................................................................................ 3-15 

Figure 3.4 Flood Hazard Zones........................................................................................................ 3-17 

Figure 3.5 Hydrologic features of the Ki‘i Unit ............................................................................... 3-19 

Figure 4.1 Ae‘o Survey Numbers on the Refuge ............................................................................... 4-6 

Figure 4.2 ‘Alae ke‘oke‘o Survey Numbers on the Refuge ............................................................... 4-7 

Figure 4.3 ‘Alae ‘ula Survey Numbers on the Refuge ....................................................................... 4-8

Appendices 

Appendix A: Species Lists ................................................................................................................ A-1 

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

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

Appendix D: Wilderness Review for James Campbell NWR .......................................................... D-1 

Appendix E: Integrated Pest Management Program ......................................................................... E-1 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

iv Table of Contents 

Appendix F: Literature Cited ........................................................................................................... F-1 

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

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

Appendix I: Public Involvement ...................................................................................................... I-1 

Appendix J: Public Comments and Service Responses ................................................................... J-1 

Appendix K: Endangered Species Act Section 7 Consultation ....................................................... K-1 
Readers’ Guide

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

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

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

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

guide is provided to simplify pronunciation for the reader.

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

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

and five vowels.

Special Symbols 

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

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

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

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

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

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

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

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

change the meaning of a word is “pau”:

• pau = finished, ended, all done

• pa‘u = soot, smudge, ink powder

• pa‘ū = moist, damp

• pā‘ū = skirt

Unit Names

Punamanō (POO-nah mah-NOHH) meaning: shark spring

Ki‘i (KEE-ee) meaning: image

Consonants

H - as in English

K - as in English

L - as in English

M - as in English

N - as in English

P - as in English

W - after i and e pronounced v

 - after u and o pronounced like w

 - at the start of a word or after a, 

 pronounced like w or v

(‘) - ‘okina - a glottal stop

Vowels

A - pronounced like the a in far

E - pronounced like the e in bet

I - pronounced like the ee in beet

O - pronounced like the o in sole

U - pronounced like the oo in boot

Readers ’ Guide v

James Campbell National Wildlife Refuge Comprehensive Conservation Plan 
Ae‘o (EYE oh)

Hawaiian Stilt Himantopus mexicanus knudseni

SPECIES STATUS:

Federally listed as Endangered

State listed as Endangered

State recognized as Indigenous

‘Alae ke‘oke‘o (ah-lye KAY oh KAY oh)

Hawaiian Coot Fulica alai

SPECIES STATUS:

Federally listed as Endangered

State listed as Endangered

State recognized as Endemic

‘Alae ‘Ula (ah-lye OO-lah)

Hawaiian Moorhen Gallinula chloropus sandvicensis

SPECIES STATUS:

Federally listed as Endangered

State listed as Endangered

State recognized as Indigenous

‘Auku‘u (ow-KOO oo)

Black-crowned Night Heron Nycticorax nycticorax 

hoactli

SPECIES STATUS:

State recognized as Indigenous

Koloa Maoli (ko-LOWah MAOW-lee)

Hawaiian Duck Anas wyvilliana

SPECIES STATUS:

Federally listed as Endangered

State listed as Endangered

State recognized as Endemic

Waterbirds

Laura Beauregard

Laura Beauregard

Laura Beauregard

Brenda Zaun

James Campbell National Wildlife Refuge Comprehensive Conservation Plan

vi Readers ’ Guide 

Michael Silbernagle
‘Akekeke (ah-kay-KAY-kay)

Ruddy Turnstone Arenaria interpres

SPECIES STATUS:

State recognized as Indigenous

U.S. Shorebird Conservation Plan - High Concern

Hunakai (hoo-nah-KYE)

Sanderling Calidris alba

SPECIES STATUS:

State recognized as Indigenous 

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

the receding waves on the shore in search of small sand 

crabs apparently reminded early Hawaiians of the sea 

foam or hunakai left behind by the waves. It shares the 

name with a coastal plant. 

Kioea (kee-oh-AY-ah)

Bristle-thighed Curlew Numenius tahitiensis

SPECIES STATUS:

State recognized as Indigenous

IUCN Red List Ranking - Vulnerable

Kōlea (KOHH-lay-ah)

Pacific Golden Plover Pluvialis fulva

SPECIES STATUS:

State recognized as Indigenous 

U.S. Shorebird Conservation Plan - High Concern

‘Ūlili (OOO-lee-lee)

Wandering Tattler Heteroscelus incanus

SPECIES STATUS:

State recognized as Indigenous

U.S. Shorebird Conservation Plan - Moderate Concern

Migrant Shorebirds

Laura Beauregard

Michael Walther

Michael Walther

Michael Walther

Michael Walther

James Campbell National Wildlife Refuge Comprehensive Conservation Plan

Readers ’ Guide vii
‘Ka‘upu (kah OO-poo)

Black-footed Albatross Phoebastria nigripes

SPECIES STATUS:

State listed as Threatened

State recognized as Indigenous

IUCN Red List Ranking - Endangered 

Mōlī (MOE-lee)

Laysan Albatross Phoebastria immutabilis

SPECIES STATUS:

State recognized as Indigenous

North American Waterbird Conservation Plan - High 

concern

‘Ua‘u Kani (OO-ah oo KAH-nee)

Wedge-tailed Shearwater Puffinus pacificus

SPECIES STATUS:

State recognized as Indigenous

Koa‘e‘ula (KOH-ah ay OO-lah)

Red-tailed Tropicbird Phaethon rubricauda

SPECIES STATUS:

State recognized as Indigenous

North American Waterbird Conservation Plan - Moderate 

concern

‘Ā (AHH)

Red-footed Booby Sula sula

SPECIES STATUS:

State recognized as Indigenous

Seabirds

David Leonard

Linday Young

Laura Beauregard

Laura Beauregard

NPS

viii Readers ’ Guide

James Campbell National Wildlife Refuge Comprehensive Conservation Plan
Honu (HO-noo)

Hawaiian Green Turtle Chelonia mydas

SPECIES STATUS:

Federally listed as Threatened

State recognized as Indigenous

IUCN Red List Ranking - Endangered 

‘Īlio-holo-i-ka-uaua (EEE-lee-oh HO-loh EE kah 

OO-ah OO-ah)

Hawaiian Monk Seal Monachus schauinslandi

SPECIES STATUS:

Federally listed as Endangered

‘Ōpae‘ula (OHH-pye OO-lah)

Hawaiian Red Shrimp Halocaridina rubra

SPECIES STATUS:

State recognized as Indigenous

‘Ōpe‘ape‘a (OHH-pay ah-PAY ah)

Hawaiian Hoary Bat Lasiurus cinereus semotus

SPECIES STATUS:

Federally listed as Endangered

Pueo (poo-AY-oh)

Hawaiian Short-eared Owl Asio flammeus 

sandwichensis

SPECIES STATUS:

State recognized as Endangered on O‘ahu

State recognized as Endemic

Other Native Animals

Laura Beauregard

NOAA

Tom DeGuiar

Tom Dove

Mike Yamamoto

Readers ’ Guide ix

James Campbell National Wildlife Refuge Comprehensive Conservation Plan 
‘Ākulikuli (AAH-koo-lee-KOO-lee)

Sea Purslane Sesuvium portulacastrum

SPECIES STATUS:

State recognized as Indigenous

‘Āki‘aki (AH-kee AH-kee)

Beach Dropseed Sporobolus virginicus

SPECIES STATUS:

State recognized as Endemic

Pōhuehue (POHH-hoo-ay-HOO-ay)

Railroad Vine, Beach Morning Glory Ipomoea 

pescaprae

SPECIES STATUS:

State recognized as Indigenous

Native Plants - Herbs

‘Ilima (ee-LEE-mah)

Yellow Ilima Sida Fallax

SPECIES STATUS:

State recognized as Indigenous

Pōhinahina (POHH-hee-nah HEE-nah)

Beach Vitex Vitex rotundifolia

SPECIES STATUS:

State recognized as Indigenous

Laura Beauregard

Laura Beauregard

Laura Beauregard

Laura Beauregard

Laura Beauregard

x Readers ’ Guide

James Campbell National Wildlife Refuge Comprehensive Conservation Plan
Hala (HAH-lah)

Beach Vitex Pandanus tectorius

SPECIES STATUS:

State recognized as Indigenous

‘Iliahiao‘e (ee-lee-AH-hee-ah-LOW ay)

Coastal Sandalwood Santalum ellipticum

SPECIES STATUS:

State recognized as Endemic

Naio (NYE-oh)

False Sandalwood Myoporum sandwicense

SPECIES STATUS:

State recognized as Indigenous

Naupaka Kahakai (now-PAH-kah kah-HAH-kye)

Beach Naupaka Scaevola taccada

SPECIES STATUS:

State recognized as Indigenous

Wiliwili (VEE-lee-VEE-lee)

Hawaiian Coral Tree Erythrina sandwicensis

SPECIES STATUS:

State recognized as Endemic

Native Plants - Shrubs & Trees

Laura Beauregard

Forest & Kim Starr

DOFAW

Laura Beauregard

Forest & Kim Starr

Readers ’ Guide xi

James Campbell National Wildlife Refuge Comprehensive Conservation Plan 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

xii Readers ’ Guide
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 1. Introduction 1-1 

Ka‘āina me ke wai, ka nohona i ka nāhelehele laha ‘ole o Hawai‘i 

“...land and water, home to Hawai‘i’s unique wildlife...” 

Chapter 1. Introduction

The O‘ahu National Wildlife Refuge Complex (Complex) is located on the Island of O‘ahu, within 

the State of Hawai‘i. The Complex consists of James Campbell National Wildlife Refuge (NWR or 

Refuge), Pearl Harbor NWR, and O‘ahu Forest NWR. Management of the Complex is conducted 

from the U.S. Fish and Wildlife Service (Service) office located in Hale‘iwa (Figure 1.1, page 1-11). 

James Campbell NWR is located in the Kahuku ahupua‘a of the Ko‘olauloa district. One of the few 

scattered remnants of natural wetlands that still exist on O‘ahu, the Refuge was established in 1976 

for the purpose of providing habitat for endangered Hawaiian waterbirds. Further expansion was 

authorized in 2005 for the purposes of providing additional habitat for endangered waterbirds, 

migratory shorebirds, waterfowl, seabirds, endangered and native plant species, endangered ‘īlioholo-i-ka-uaua (Hawaiian monk seal), and threatened honu (Hawaiian green turtle); providing 

increased wildlife-dependent public uses; and assisting with flood damage reduction in the local area. 

NOTE TO READERS 

The Service has an agreement with the James Campbell Company to purchase land from the 

company to expand the James Campbell NWR. At print time for this Comprehensive 

Conservation Plan (CCP), the process to complete the purchase of these lands is still 

ongoing. Because this plan is intended to cover a 15-year time period and the final purchase of 

these lands is anticipated in 2012, the expansion lands have been incorporated into this plan. All 

strategies for Refuge management described in this plan related to the expansion lands are 

contingent upon the successful completion of the purchase of those lands and construction of 

new facilities. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

1-2 Chapter 1. Introduction 

1.1 Purpose and Need for the CCP 

The purpose of the CCP is to provide the National Wildlife Refuge System (Refuge System), the 

Service, partners, and citizens with a management plan for improving fish and wildlife habitat 

conditions and infrastructure for wildlife, staff, and Refuge visitors for 15 years. The CCP will help 

ensure that the Service manages James Campbell NWR to achieve its purpose, vision, goals, and 

objectives. Another purpose of the CCP is to provide reasonable, scientifically grounded guidance for 

improving the Refuge’s subterranean, upland, coastal, surface water and wetland habitats for the 

long-term conservation of native plants and animals. The CCP identifies appropriate actions for 

protecting and sustaining the cultural and biological features of coastal communities; endangered, 

threatened, or rare species populations and habitats; and migratory shorebirds. 

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

habitat conditions by removing pest plants and animals, such as kiawe shrubs, rats, and mongooses. 

There is also a need to address James Campbell NWR’s contributions to aid in the recovery of 

endangered species, and assess and possibly mitigate potential impacts of global climate change to 

Refuge resources. The Service should continue to effectively work with current partners such as the 

State of Hawai‘i and National Oceanic and Atmospheric Administration (NOAA), as well as seek 

new partnerships to restore habitats, improve environmental education and interpretive opportunities 

and volunteer programs, and recover endangered species populations. 

1.2 Planning and Management Guidance 

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

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

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

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

designated purposes of the Refuge as described in establishing legislation, Executive Orders, or other 

documents establishing, authorizing, or expanding a refuge. 

Key concepts and guidance of the Refuge System derive from the National Wildlife Refuge System 

Administration Act of 1966 (Administration Act), the Refuge Recreation Act of 1962 (16 U.S.C. 

460k-460k-4), as amended, Title 50 of the Code of Federal Regulations (CFR), and the Fish and 

Wildlife Service Manual (FW). The Administration Act is implemented through regulations covering 

the Refuge System, published in Title 50, subchapter C of the CFR. These regulations govern general 

administration of units of the Refuge System. 

1.2.1 U.S. Fish and Wildlife Service Mission 

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

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

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

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

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

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

programs, and helps other countries develop wildlife conservation programs. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 1. Introduction 1-3 

1.2.2 National Wildlife Refuge System 

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

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

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

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

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

environmental education and interpretive activities on national wildlife refuges. 

1.2.3 National Wildlife Refuge System Mission and Goals 

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

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

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

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

policy (601 FW1), follow: 

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

endangered or threatened with becoming endangered; 

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

interjurisdictional fish, and marine mammal populations that is strategically distributed and 

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

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

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

underrepresented in existing protection efforts; 

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

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

interpretation); and 

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

wildlife, and plants and their habitats. 

1.2.4 National Wildlife Refuge System Administration Act of 1966 

Of all the laws governing activities on national wildlife refuges, the Administration Act exerts the 

greatest influence. The Administration Act was amended by the National Wildlife Refuge System 

Improvement Act of 1997 (Improvement Act). The Improvement Act included a unifying mission for 

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

requirement that each refuge will be managed under a CCP developed in an open public process. The 

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

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

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

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

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

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

Biological Integrity, Diversity, and Environmental Health (BIDEH) policy, “the highest measure of 

biological integrity, diversity, and environmental health is viewed as those intact and self-sustaining 

habitats and wildlife populations that existed during historic conditions.” 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

1-4 Chapter 1. Introduction 

Ae‘o chick tests the water Laura Beauregard/USFWS

Each refuge must be managed to fulfill the Refuge System mission as well as the specific purpose for 

which it was established. The Administration Act requires the Service to monitor the status and 

trends of fish, wildlife, and plants on every refuge. 

Additionally, six wildlife-dependent recreational 

uses are granted special consideration in the 

planning, management, establishment, and 

expansion of units of the Refuge System: hunting, 

fishing, wildlife observation and photography, and 

environmental education (EE) and interpretation. 

When determined compatible on a refuge-specific 

basis, these six uses assume priority status among all 

public uses of the refuge in question. The 

overarching goal is to enhance wildlife-dependent 

recreation opportunities and access to quality visitor 

experiences on refuges, while managing refuges to 

conserve fish, wildlife, plants, and their habitats. 

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

economic uses proposed or occurring on a refuge for appropriateness and compatibility. No refuge 

use may be allowed or continued unless it is determined to be appropriate and compatible. Generally, 

an appropriate use is one that contributes to fulfilling refuge purposes, the Refuge System mission, or 

goals and objectives described in a refuge management plan. A compatible use is defined as a use 

that, in the sound professional judgment of the refuge manager, will not materially interfere with or 

detract from the fulfillment of the mission of the Refuge System or the purpose of the refuge. 

Updated Appropriate Use Findings and Compatibility Determinations for existing and proposed uses 

for James Campbell NWR are in Appendix B. 

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

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

issues, guiding alternatives considered during development of the CCP, and selecting a preferred 

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

to securing public input throughout the process. 

1.3 Relationship to Previous and Future Refuge Plans 

Planning has been a part of refuge operations since establishing refuges began. However, not all 

plans were completed in a comprehensive fashion or with public participation considered adequate 

today. 

1.3.1 Previous Plans 

Previous plans that provided guidance for managing James Campbell NWR include: 

 Master Plan for the Hawaiian Wetlands National Wildlife Refuge Complex (USFWS 1985); and 

 Draft Revised Recovery Plan for Hawaiian Waterbirds, Second Draft of Second Revision 

(USFWS 2005). 
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Chapter 1. Introduction 1-5 

1.3.2 Future Planning 

The CCP will be revised every 15 years or earlier if environmental conditions significantly change or 

monitoring and evaluation determine that changes are needed to achieve refuge purposes, vision, 

goals, or objectives. The CCP provides guidance in the form of goals, objectives, and strategies for 

refuge program areas but may lack some of the specifics needed for implementation. Stepdown 

management plans will be developed for individual program areas, as needed. Stepdown plans 

require appropriate National Environmental Policy Act (NEPA) compliance. All of the stepdown 

plans should be based on the management goals, objectives, and strategies outlined in the CCP. A list 

of proposed stepdown plans is provided in Appendix C. 

1.4 Refuge Establishment and Purposes 

1.4.1 General 

Lands within the Refuge System are acquired and managed under a variety of legislative acts, 

administrative orders, and legal authorities. The official purpose or purposes for a refuge are 

specified in or derived from the law, Presidential proclamation, Executive order, agreement, public 

land order, donation document, or administrative memorandum establishing, authorizing, or 

expanding a refuge, refuge unit, or refuge subunit. The Service defines the purpose of a refuge when 

it is established or when new land is added to an existing refuge. When an addition to a refuge is 

acquired under an authority different from the authority used to establish the original refuge, the 

addition takes on the purposes of the original refuge, but the original refuge does not take on the 

purposes of the addition. Refuge managers must consider all of the purposes. However, purposes 

dealing with the conservation, management, and restoration of fish, wildlife, and plants and their 

habitats take precedence over other purposes in the management and administration of a refuge.

1.4.2 James Campbell NWR Establishment

The earliest document proposing land for protection and management in the James Campbell NWR 

area is Hawai‘i’s Endangered Waterbirds (U.S. Bureau of Sport Fisheries and Wildlife 1971*). It 

identified three small ponds, Ki‘i, Punamanō, and Punaho‘olapa, as well as adjacent marshes, as 

being valuable to waterbirds. Shortly thereafter, the area was identified and proposed for acquisition 

as a Refuge with the purpose: To preserve habitat vital to the rare and endangered species ae‘o 

(Hawaiian stilt), ‘alae ke‘oke‘o (Hawaiian coot), and provide habitat for other shorebirds and 

waterfowl on the Island of O‘ahu. 

The Refuge was established in 1976 with approximately 150 acres under a $1 a year lease with the 

Estate of James Campbell. Over the last several years, through the leadership of Senator Daniel 

Inouye and Hawai‘i’s congressional delegation, Congress appropriated a total of $22 million to 

expand the Refuge to a total of approximately 1,100 acres. 

* The Fish and Wildlife Act of 1956 created the U. S. Fish and Wildlife Service and established two bureaus, Sport 

Fish and Wildlife and Commercial Fisheries. In 1970, the Bureau of Commercial Fisheries was transferred to the 

Department of Commerce and renamed the National Marine Fisheries Service. The remaining Bureau of Sport 

Fisheries and Wildlife became today’s U.S. Fish and Wildlife Service. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

1-6 Chapter 1. Introduction 

In 2005, Public Law 109-225 authorized expansion of the James Campbell NWR and identified 

management focus areas for the Refuge expansion lands as to: 

 Promote the recovery of four species of endangered Hawaiian waterbirds; 

 Permanently protect endangered species habitat; 

 Improve management of the Refuge; 

 Protect coastal dunes, coastal wetlands, and coastal strand habitats that promote biological 

diversity, including the four species of endangered Hawaiian waterbirds, migratory 

shorebirds, waterfowl, seabirds, endangered and native plant species, endangered Hawaiian 

monk seals, and green turtles; 

 Provide increased opportunities for wildlife-dependent public uses, including wildlife 

observation, photography, and environmental education and interpretation; 

 Create a single, large, manageable, and ecologically-intact unit that includes sufficient buffer 

land to reduce impacts on the Refuge; and 

 Reduce flood damage following heavy rainfall to residences, businesses, and public buildings 

in the town of Kahuku. 

1.4.3 James Campbell NWR Purpose 

The official purpose of the James Campbell NWR is “... to conserve (A) fish or wildlife which are 

listed as endangered species or threatened species .... or (B) plants ...”. 

1.5 Refuge Goals 

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

focus management priorities, resolve issues, and link to refuge 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 refuge purposes, Refuge System mission and goals, other statutory 

requirements, and larger-scale plans as appropriate. Visitor services and wildlife/habitat management 

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

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

specific tools and actions to accomplish objectives. The James Campbell NWR vision statement is 

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

imply any priority in this CCP. 

 

‘Alae ‘ula Mike Silbernagle/USFWS
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 1. Introduction 1-7 

Nā Pahuhopu o ka Pu‘uhonua

1. Kīa ‘i a mālama i nā ‘āina pālielie no ka holomua ‘ana o ka nohona a me ke ola ‘ana o na manu 

wai a me nā manu kai i holo mua ho‘i ko lākou ola ‘ana. 

2. Ho‘‘opa‘a inā lāwena ‘āina no ka hui ka Pu‘uhonua ‘o James Campbell e hiki ai ke ho‘ ‘onui aku i 

ia ‘āina no ka ho‘iho ‘ ‘i hou, kīa ‘i a e mālama ho ‘i i nā kaianoho a e like ho‘i me ka makemake o 

ka hui Ho‘omalu holoholona a e loa ‘a pu ho ‘i nā makemake a nā limahana ho ‘omalu holoholona 

kekahi. 

3. Ho‘iho‘i hou a kīa ‘i i nā lihi kahakai‘a me nā kaianoho pu‘e one a e malama ho ‘i i wahi noho 

maluhia no nā ‘ilio holo i ka uaua ‘ane make loa, a me nā Honu a e mālama pū hoi i wahi noho no nā

manu kai, nā manu lihikai, a me manu ne ‘ekau. 

4. E ‘ohi‘ohi ho‘i i nā mana ‘o ‘epekema e pili ana i ia wahi no ka ho ‘omākaukau ‘ana a e ho‘okupu 

ho‘i i ha‘awina e holomua ai nā mana‘o mālama ‘āina a e kōkua pū ho‘i i ka pahu hopu 1 a me ka 

pahu hopu 3. 

5. E ho‘omākaukau ho‘i i kumuwaiwai no ka wehewehe ‘ana a e ho‘omaopopo pū ho ‘i i nā kānaka e 

pili ana i ka waiwai o ia ‘ āina, nā pilina mālama ‘āina, a me nā mo’aukala e pili ana ho‘i no ia wahi 

‘āina ho‘omalu holoholona lōhiu Pu‘uhonua ‘o James Campbell. 

6. E mālama ho‘i i nā mo‘aukala a me nā mo‘omeheu ‘o ia wahi no ka pono o nā kānaka mai kēia au 

a ia au a‘e e hiki mai ana. 

7. E kōkua ho‘i ma ke kōkua ‘ana e ho‘emi i ka nui pilikia i ke kaiaulu ke loa‘a mai ka wai hālana a i 

‘ole kekahi ino ua nui paha. 

Refuge Goals 

1. Protect and manage seasonal wetland habitats to meet the life-history needs of endangered 

waterbirds to promote their recovery. 

2. Complete acquisition of the James Campbell National Wildlife Refuge expansion to restore, 

protect, and manage habitats according to Refuge purposes and to meet Refuge staff facility needs. 

3. Restore and protect coastal strand/dune and upland scrub/shrub habitats to provide safe refuge for 

endangered ‘īlio-holo-i-ka-uaua and threatened honu, as well as provide habitat for seabirds, 

shorebirds, and migratory birds. 

4. Collect scientific information necessary to guide management decisions in support of Goals 1-3. 

5. Provide wildlife-dependent public use and educational opportunities to enrich public appreciation 

of the natural resources of James Campbell NWR and the National Wildlife Refuge System. 

6. Protect historic and cultural resources for the benefit of present and future generations. 

7. Assist partner agencies and the local community with planning and implementation of flood 

damage reduction measures for the Town of Kahuku. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

1-8 Chapter 1. Introduction 

1.6 Relationship to Ecosystem Planning Efforts 

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

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

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

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

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

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

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

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

develop its own comprehensive strategy. Hawai‘i’s Comprehensive Wildlife Conservation Strategy

thoroughly reviews the status of the full range of the State’s native terrestrial and aquatic species, 

over 10,000 of which are found nowhere else on Earth. Hawai‘i’s Species of Greatest Conservation 

Need include all native terrestrial animals, all endemic aquatic animals, additional indigenous aquatic 

animals identified as in need of conservation attention, a range of native plants identified as in need 

of conservation attention, and all identified endemic algae. This list includes: terrestrial mammal (1), 

birds (77), terrestrial invertebrates (~5,000), freshwater fishes (5), freshwater invertebrates (12), 

anchialine pond-associated fauna (20), marine mammals (26), marine reptiles (6), marine fishes 

(154), marine invertebrates (197), and flora (over 600). Details on all the listed wildlife taxa are 

provided in fact sheets that contain information for taxa, closely related groups of species, and 

species facing similar threats. 

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

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

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

waterbirds focuses on the following objectives: 

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

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

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

range; 

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

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

conditions and control of invasive nonnative plants; 

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

avian diseases, and contaminants; and 

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

mallards. 

U.S. Pacific Islands Regional Shorebird Conservation Plan, 2004. Conservation and restoration of 

shorebird habitats is essential for the protection of endangered and declining shorebird populations. 

Wetlands, beach strand, coastal forests, and mangrove habitats are particularly vulnerable on Pacific 

islands due to increasing development pressures and already limited acreage. Monitoring and 

research needs include assessment of population sizes and trends; assessment of the timing and 

abundance of birds at key wintering and migration stopover sites; assessment of habitat use and 

requirements at wintering and migration areas; exploration of the geographic linkages between 

wintering, stopover, and breeding areas; and evaluation of habitat restoration and management 

techniques to meet the needs of resident and migratory species. Education and public outreach are 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 1. Introduction 1-9 

critical components of this plan. Resource management agencies of Federal, Territorial, 

Commonwealth, and State governments will need to work together with military agencies, 

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

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

Ko‘olau Loa Sustainable Communities Plan, 1999. This update reaffirms Ko‘olau Loa’s role in 

O‘ahu’s development pattern as intended in the General Plan policies by establishing principles for 

future land use and development: 

 Recognize traditional ahupua‘a divisions and distinctions and incorporate the ahupua‘a 

concept as the primary basis for land use planning in Ko‘olau Loa; 

 Maintain and, where possible, expand critical open space areas and shoreline views between 

the existing pattern of community development so as to preserve a separation between the 

natural and built environment within each ahupua‘a; 

 Preserve the existing strong relationship between the natural landscape of the mountains to 

the ocean, and the manmade landscape of agricultural fields and small rural communities; 

 Promote diversified agriculture and aquaculture on existing agricultural lands in accordance 

with the General Plan policy to support agricultural diversification in all rural areas on 

O‘ahu; 

 Preserve continuous coastal views and scenic views of ridges, valley slopes, and prominent 

land features; 

 Provide for new employment-based development that will offer quality jobs and be 

compatible with the existing communities’ rural fabric and the natural environment; 

 Limit future resort development to the existing zoned lands in secondary resort areas at 

Kahuku Point-Kawela Bay area and Lā‘ie; and 

 Support and encourage improvements at existing educational and recreational facilities. 

The vision for Ko‘olau Loa seeks to preserve the region’s rural character and its natural, cultural, 

scenic, and agricultural resources. The region will remain country, characterized by small towns and 

villages with distinct identities that exist in harmony with the natural settings of mountain ridges and 

winding coastline. 

Recovery Plan for the Hawaiian Monk Seal (Monachus schauinslandi), 2007. The ‘īlio-holo-i-kauaua has the distinction of being the only endangered marine mammal whose entire species range – 

historic and current – lies within the United States. The majority of the population of seals now lies 

in the Northwestern Hawaiian Islands (NWHI) with six main breeding subpopulations. The species is 

also found in lower numbers in the main Hawaiian Islands where the population size and range both 

appear to be expanding. The main terrestrial habitat requirements include haul-out areas for pupping, 

nursing, molting, and resting. These are primarily sandy beaches, but virtually all substrates are used 

at various islands. The goal of this revised recovery plan is to assure the long-term viability of the 

‘īlio-holo-i-ka-uaua in the wild, allowing initially for reclassification to threatened status and, 

ultimately, removal from the List of Endangered and Threatened Wildlife. 

Recovery Plan for U.S. Pacific Populations of the Green Turtle (Chelonia mydas), 1997. The honu 

is listed as threatened throughout its Pacific Range, except for the endangered population nesting on 

the Pacific coast of Mexico, which is covered under the Recovery Plan for the East Pacific green 

turtle. By far, the most serious threat to these honu is from direct take of turtles and eggs, both within 

U.S. jurisdiction and on shared stocks that are killed when they migrate out of U.S. jurisdiction. In 

Hawai‘i, honu populations appear to have a somewhat less dire status, probably due to effective 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

1-10 Chapter 1. Introduction 

protection at the primary nesting areas of the NWHI and better enforcement of regulations 

prohibiting take of the species. However, an increase in the incidence of the tumorous disease, 

fibropapillomatosis (FP), in the Hawaiian honu threatens to eliminate improvements in the status of 

the stock. Another serious threat to honu populations throughout the Pacific is associated with 

increasing human populations and development. In particular, human development is having an 

increasingly serious impact on nesting beaches. 

1.7 Planning and Issue Identification 

1.7.1 Issues Addressed in the CCP 

The following issues were addressed in the planning process: 

Wildlife and Habitat Resources: Endangered waterbirds and plants are the primary management 

focus, but management also considers and includes endangered ‘īlio-holo-i-ka-uaua, threatened honu, 

migratory shorebirds, waterfowl, seabirds, and native plant species. 

Facilities and Maintenance: Facilities maintenance includes vehicles; heavy equipment; fencing; 

weather stations; ditches, dikes, and impoundments; and water control structures, wells and pumps. 

Due to the coastal environmental conditions (e.g., constant wind containing salt spray, precipitation, 

warm temperatures, and high humidity), degradation of equipment and facilities is accelerated and 

often exceeds normally acceptable Mainland standards for maintenance costs and schedules. The 

Refuge office is in Hale‘iwa at a General Services Administration rental site roughly 20 miles from 

the Refuge, which contributes to transportation costs. 

Visitor Services Activities: Environmental education, interpretation, and wildlife observation are 

currently offered on a limited basis through special use permits and/or volunteer docent-led tours. 

The presence of nesting endangered species throughout much of the calendar year restricts public 

access. Sensitive areas will be closed to the public as new lands are acquired. 

Law Enforcement: Refuge officers are responsible for upholding Federal laws and regulations that 

protect natural resources, the public, and employees. The sole Zone Officer is stationed in Honolulu 

and has responsibilities that extend to all of the Hawaiian and Pacific Islands refuges. 

1.7.2 Issues Outside the Scope of the CCP 

Neighboring Development: New construction proposed or associated with Turtle Bay Resort or 

Kahuku First Wind turbine project adjacent to the Refuge is outside our jurisdiction. Cumulative 

effects to air quality have been considered in the EA. 

Fishing Regulations: State fishing regulations and access to the ocean (via the State’s public beach 

corridor on private lands) are outside of the jurisdiction of the Refuge; and will not be addressed in 

the CCP. 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 1. Introduction 1-11 

Figure 1.1 The Main Hawaiian Islands 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

1-12 Chapter 1. Introduction 

This side left blank intentionally to preserve the quality of the map. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-1

A honu hatchling scoots its way to the sea Mike Silbernagle/USFWS 

Chapter 2. Refuge Management Direction 

2.1 Considerations in the Design of the CCP 

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

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

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

considerations were fundamental in developing this CCP. House Report 105-106 accompanying the 

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

and wildlife conservation must come first.” 

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

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

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

considered during CCP development. Details of public participation can be found Appendix I. 

2.2 General Guidelines 

General guidelines for implementing the CCP follow. To reduce the length and redundancy of the 

descriptions for individual strategies, common features are presented below. 

2.2.1 Implementation Subject to Funding Availability 

Action strategies will be implemented over a period of 15 years as funding becomes available. 

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

dependent on funding. 
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2-2 Chapter 2. Refuge Management Direction 

2.2.2 Interagency Coordination and Collaboration 

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

State, and local agencies toward mutual goals. 

2.2.3 Threatened and Endangered Species Protection and Recovery

Protection of threatened and endangered species is common across all alternatives. It is Service 

policy to give priority consideration to the protection, enhancement, and recovery of these species on 

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

Endangered Species Act of 1973 (ESA). Section 7 of the ESA, called "Interagency Cooperation," is 

the mechanism by which Federal agencies ensure the actions they take, including those they fund or 

authorize, do not jeopardize the existence of any listed species. To ensure adequate protection, the 

Refuge is required to review all activities, programs, and projects occurring on lands and waters of 

the Refuge to determine if they may affect listed species. If the determination is that an action may 

adversely affect an endangered species, then the Refuge conducts a formal review, known as a 

consultation, to identify those effects and means to mitigate those effects. Completed consultations 

are included in Appendix K. 

2.2.4 Historic and Cultural Resource Protection

Cultural resources on Refuge lands receive protection and consideration in accordance with Federal 

cultural resources laws, Executive orders, and regulations, as well as policies and procedures 

established by the Department of the Interior and the Service. Although the presence of cultural 

resources, including historic properties, does not preclude a Federal activity, the Refuge will seek to 

identify and protect cultural resources whenever possible. Refuge management actions will support 

the State of Hawai‘i’s vision statement “to promote the use and conservation of historic and cultural 

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

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

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

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

cultural items (human remains, funerary objects, sacred objects, or objects of cultural patrimony) to 

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

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

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

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

Affairs and Hui Malama I Na Kupuna ‘O Hawai‘i Nei. The Department of the Interior has interpreted 

this definition to also include the Hawaiian island burial councils and various ‘ohana (extended 

families). 

During early planning of any projects, the Refuge will provide the Service Regional Historic 

Preservation Officer (RHPO) a description and location of all projects and activities that affect 

ground and structures, including project requests from third parties. Information will also include any 

alternatives being considered. The RHPO will analyze these undertakings for potential to affect 

historic properties and enter into consultation with the State Historic Preservation Division and other 

parties as appropriate. The Refuge will also ask the public and local government officials to identify 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-3

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

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

2.2.5 Fire Management

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

resource protection, public safety, and habitat management on national wildlife refuges. In 2003, a 

Fire Management Plan that incorporated NEPA compliance was approved for the Refuge and 

provides detailed guidance for the suppression and use of prescribed fire. That plan's actions and 

effects are incorporated through reference in this CCP. The plan outlines wildfire response and 

prescribed fire objectives, strategies, responsibilities, equipment and staffing; burn units; 

implementation; monitoring; and evaluation. The complete Fire Management Plan is available at the 

Complex office in Hale‘iwa (USFWS 2003). 

2.2.6 Participation in Planning and Review of Regional Development 

 Activities 

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

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

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

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

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

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

natural landscapes and wildlife habitat. We will continue to identify and pursue new opportunities for 

land acquisition that will benefit Refuge purposes. 

2.2.7 Adaptive Management 

Based upon 522 Departmental Manual (DM) 1 (Adaptive Management Implementation policy), 

Refuge staff shall utilize adaptive management for conserving, protecting, and, where appropriate, 

restoring lands and resources. Within 43 CFR 46.30, adaptive management is defined as a system of 

management practices based upon clearly identified outcomes, where monitoring evaluates whether 

management actions are achieving desired results (objectives). The recently published DOI Adaptive 

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

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

management actions and other events become better understood.” 

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

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

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

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

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

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

evaluation of the CCP. 

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

year revision of the CCP. The revision will be initiated by the Service and will involve a 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

2-4 Chapter 2. Refuge Management Direction 

comprehensive review of management plans and research; working closely with partners; and 

engaging the public. 

2.2.8 Integrated Pest Management 

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

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

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

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

considers minimum potential effects to nontarget species and the refuge environment. Pesticides may 

be used where physical, cultural, and biological methods or combinations thereof are impractical or 

incapable of providing adequate control, eradication, or containment. If a pesticide would be needed 

on Refuge lands, the most specific (selective) chemical available for the target species would be used 

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

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

registered with the Environmental Protection Agency (EPA) in full compliance with the Federal 

Insecticide, Fungicide, and Rodenticide Act (FIFRA) and as provided in regulations, orders, or 

permits issued by EPA may be applied on lands and waters under Refuge jurisdiction. 

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

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

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

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

including preying and feeding on them; causing or vectoring diseases; preventing them from 

reproducing or killing their young; outcompeting them for food, nutrients, light, nest sites, or other 

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

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

species. For example, decreased waterfowl use may result from pest plant infestations reducing the 

availability and/or abundance of native wetland plants that provide forage during the winter. 

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

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

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

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

minor, temporary, and localized effects to species and environmental quality based upon 

nonexceedance of threshold values in chemical profiles. However, pesticides may be used on Refuge 

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

in order to protect human health and safety. For more information on strategies related to control of 

pests, see Appendix E. 

2.2.9 Law Enforcement

Officers’ Responsibilities 

Fish and wildlife law enforcement issues on lands and waters of the James Campbell NWR are under 

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

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

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

Officer is highly mobile and is frequently deployed temporarily to various areas throughout the State 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-5

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

has been identified in the Implementation Plan (Appendix C). 

Officers’ Authority

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

including but not limited to: 

 Administration Act; 

 The Lacey Act; 

 Archaeological Resource Protection Act; 

 Endangered Species Act; 

 Migratory Bird Treaty Act; and 

 Marine Mammal Protection Act. 

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

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

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

Service Officers work joint patrols and coordinate with the Department of Land and Natural 

Resources-Division of Conservation and Enforcement (DLNR-DOCARE), Honolulu Police 

Department (HPD), and the Sheriff Division of the State Department of Public Safety. 

2.2.10 Permanent Full-time Staffing Additions

This CCP proposes adding 13 new permanent full-time (PFT) positions to the staff of the Complex: 

a Deputy Project Leader, Supervisory Park Ranger, Wildlife Refuge Specialist, Wildlife Biologist, 

Refuge Law Enforcement Officer, Environmental Education Specialist, Park Ranger, Facility 

Manager, 3 Maintenance Workers, and 2 Biological Technicians. All staffing additions are subject to 

regional approval and allocation of additional base funding. 

2.2.11 Summary of CCP Actions 

Intensive management of threatened and endangered waterbird species and their habitat at the Ki‘i 

and Punamanō Units of the Refuge will continue to focus on protection and successful nesting as part 

of the Statewide effort to implement the Hawaiian Waterbird Recovery Plan. A Visitor Services Plan 

(VSP) will be developed to identify, evaluate, and select sites for infrastructure such as a 

headquarters/vistitor center/ EE (HQ/VC/EE) facility needed to fully implement a safe and 

compatible program for the public (to include roads, parking areas, trails, overlooks, etc.). The VSP 

will identify any new special regulations needed to protect sensitive wildlife resources, the fragile 

coastline, and the visiting public. The Refuge will cooperate with other agencies and the Kahuku 

community to develop, evaluate, and implement feasible projects to reduce projected flooding 

impacts in the local area; and both current aquaculture leases will remain in effect until 2023 at 

which time, by prior agreement, they will expire. 

All wetlands, coastal dunes/strand and scrub/shrub habitats will be restored and managed. Trial use 

of predator-proof fencing will be initiated on selected dune and/or wetland sites to protect nesting 

seabirds and waterbirds. Abandoned aquaculture facilities will be cleaned up. If we determine that 

the Service does not currently have management authority for the shoreline adjacent to the Refuge 

coastline, we will pursue an Executive Order from the Governor of Hawai‘i for jurisdiction to help 

fulfill the Refuge purpose and ensure compatibility of uses. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

2-6 Chapter 2. Refuge Management Direction 

Table 2.1 James Campbell NWR Management Summary 

Key Themes Objectives Habitat Restoration HABITATS

Intensively 

Managed 

Wetland 

1.1 Ae‘o loafing & foraging 90-115 ac 

1.2 Ae‘o breeding 20 ac 

1.3 ‘Alae ke‘oke‘o & ‘alae ‘ula loafing & 

foraging <59 ac 

1.4 ‘Alae ke‘oke‘o & ‘alae ‘ula breeding <30 ac 

Natural 

Wetland 

1.5 ‘Alae ke‘oke‘o & ‘alae ‘ula life-history 32-51 ac 

Remnant 

Wetland 

1.6 Waterbirds & migratory birds 25-67 ac 

Coastal 

Strand/ 

Dune 

3.1 Restore, protect, and manage coastal strand 100-185 ac 

3.2 Improve seabird nesting site on runway 20-28 ac 

Scrub/Shrub 

Habitat 

2.3 Restore scrub/shrub <312 ac 

 Strategies 

Expansion 

Lands 

2.1 Complete land acquisition Coordination/cooperation with 

James Campbell Co., Regional 

Office, and Washington Office 

2.2 Plan & construct Refuge facilities Design/build new HQ/VC/EE 

facility, maintenance shop, 

bunkhouse & greenhouse 

Scientific 

Data 

4.1 Conduct inventory and monitoring Track nesting success; impacts 

of pest plants & animals; and 

movements of endangered 

waterbirds. Initiate data 

collection volunteer program

4.2 Facilitate research & scientific assessments Form research partnerships 

and develop climate change 

assessment protocols 

Visitor 

Services 

5.1 Provide EE Up to 6,000 students 

with construction & staffing of 

EE facility 

5.2 Offer new visitor opportunities, primarily 

wildlife observation and photography 

5,000 visitors annually along 

coastline & Ki‘i; up to 

210,000 w/ construction & 

staffing of VC 

Cultural & 

Historic 

Resources 

6.1 Enhance awareness, protection, & 

appreciation 

Consult Native Hawaiian & 

historical societies to develop 

interpretive materials; 

NAGPRA training for staff; 

develop maps for avoidance of 

known sites 

Flood Damage 

Reduction 

7.1 Support feasible flood damage reduction 

efforts for Kahuku 

Cooperate in planning process; 

maintain Walkerville Unit as 

potential flood damage 

reduction project area 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-7

2.3 James Campbell NWR Management 

Goals and objectives are the unifying elements for 

successful, adaptive refuge management. They 

identify and focus management priorities and link to 

refuge purpose(s), Service policy, and the Refuge 

System mission. The goals for the James Campbell 

NWR are presented on the following pages. Some 

objectives pertain to multiple goals and have simply 

been placed in the most reasonable spot. Similarly, 

some strategies pertain to multiple objectives and for 

clarity these strategies are listed under each relevant 

objective. Following the goals, objectives, and 

strategies, a brief rationale is provided that describes 

how management strategies will be implemented to 

achieve the intended objectives. 

2.3.1 Goal 1. 

Protect and manage seasonal wetland habitats to meet the life-history needs of 

endangered waterbirds to promote their recovery. 

Objective 1.1. Intensively manage for ae‘o loafing and foraging habitat. 

Manage seasonal wetland habitat for loafing and foraging ae‘o throughout the year on 

approximately115 ac of the Ki‘i Unit with the following characteristics: 

 Open water (1-6 in) and mudflat (saturated and dry) interspersed with 30-60% cover of 

emergent vegetation (e.g., cattail), grasses (e.g., sprangletop, knot-grass, millet), and sedges 

(e.g., saltmarsh bulrush, Fimbrystlis sp.) providing a mosaic; 

 Less than 25% cover of pest plants including marsh fleabane, Batis, California bulrush, and 

California grass; 

 Sufficient benthic and nektonic macroinvertebrates and small fish to provide forage on a 

rotational basis for up to 200 ae‘o; 

 No cats or dogs; and 

 Documented predation below 10 individual ae‘o per year. 

Strategies Applied to Achieve Objective

Drawdown in specified impoundments from approximately March-July (control fish and promote 

invertebrates/algal growth, plant response) 

Flood after vegetation treatment (mowing, tilling, herbicide, prescribed fire) to promote foraging 

Pulse water to promote abundance and availability of invertebrates thrice monthly 

Eliminate cattle egret roost trees 

Fencing, live-trapping, snap-traps, shooting, and bait stations to reduce predation 

Control pest plants using: herbicide application, prescribed fire, mowing, rototilling, disking, and 

brush cutting 

Ae‘o ohana Laura Beauregard/USFWS
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

2-8 Chapter 2. Refuge Management Direction 

Strategies Applied to Achieve Objective

Create openings (interspersion) in dense vegetation 

Monitor predator abundance (i.e., track tunnels) to evaluate effectiveness of predator control efforts 

Rationale: Ae‘o require different loafing and foraging habitats during the breeding (late FebruaryJuly) and nonbreeding seasons. Recently hatched ae‘o (<14 days old) require shallow water of less 

than 2 inches to forage. During the remainder of the year fledgling and adult ae‘o can forage in 

water as deep as 6 inches. 

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

controls undesirable plants, and provides a variety of macroinvertebrates for young and adult ae‘o to 

feed on, thereby creating and maintaining maximized production and carrying capacity of the 

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

open water and vegetation as microhabitat for ae‘o thermoregulation and cover during inclement 

weather. 

Mowing, prescribed fire, herbicide application, rototilling, and disking are all suitable techniques for 

creating the desired mosaic of vegetation, open water, and mudflats by opening dense contiguous 

patches of Batis, California grass, marsh fleabane, California bulrush, water hyssop, or cattail. These 

management techniques also benefit a variety of other wetland-dependent species including koloa 

maoli, ‘alae ke‘oke‘o, ‘alae ‘ula, wintering waterfowl (dabbling ducks), and shorebirds. 

Objective 1.2. Intensively manage wetland habitat for ae‘o breeding. 

Provide seasonal wetland habitat for breeding ae‘o from February-July on 20 acres of the Ki‘i Unit 

with the following characteristics: 

 Open water (<3 in) and mudflat (saturated and unsaturated) with <25% cover of 

emergents, grasses, and sedges providing a mosaic; 

 Undulating, irregular bottom topography creating unsaturated mudflats with gradual 

slopes during drawdown for nesting adjacent to foraging habitat; 

 Predation limited to no more than five documented events per year; 

 Less than 25% cover of pest plants including marsh fleabane, Batis, water hyssop, 

California bulrush, and California grass; and 

 Benthic and nektonic macro-invertebrates and small fish with densities of 400-600 

invertebrates/yd2

. 

Strategies Applied to Achieve Objective

Flood for prebreeding (as a follow-up to mowing/rototilling, etc. to create nesting habitat) 

Slow drawdown rate (control fish and promote invertebrates/algal growth, plant response) 

Pulse water weekly to promote invertebrates for broods 

Control predators with fencing, live-trapping, snap-traps, and bait stations 

Control pest plants with herbicide application, prescribed fire, mowing, disking, and brush cutting 

Restricted public use (seasonal closures) and limited Refuge staff presence only at a level necessary 

to conduct monitoring and water management, under normal circumstance, 1-3 visits per week 

Monitor predator abundance to evaluate success of control efforts
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-9

Rationale: Breeding ae‘o require dry to unsaturated mudflat habitat for building nests. Prebreeding water level drawdowns help establish drier mudflats. Although saturated mudflats can be 

used as nest sites, adult ae‘o expend more energy building nests robust enough to counter the excess 

moisture. Initiation of the drawdown is timed to coincide with minimal or no ‘alae ke‘oke‘o nesting 

or chick rearing. This timing method is part of an overall cycle of wetting and drying of habitat, 

making it suitable to a greater number of birds throughout the year and increasing species diversity. 

Thus, ae‘o nesting habitat temporally follows where ‘alae ke‘oke‘o habitat existed previously. 

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

drawdowns maximize the number of nests that an area can support. The target distance between 

nest site to vegetation and water is 0-20 feet. Slow drawdown rates also stimulate ample numbers 

and diversity of invertebrates throughout the brood rearing period, allowing adult ae‘o with broods 

to establish feeding territories and reduce inter-brood conflicts that can result in injury or death to 

young chicks. 

Ae‘o are very easily disturbed during the nesting season. Since they nest in the open on exposed 

mudflats they evolved behaviors to help protect nests and young. One behavior of the adult is to 

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

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

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

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

access is generally closed during this time. 

Objective 1.3. Intensively manage seasonal wetland habitat for ‘alae ke‘oke‘o and ‘alae 

‘ula loafing and foraging. 

Provide seasonal wetland habitat for loafing/foraging ‘alae ke‘oke‘o and ‘alae ‘ula throughout the 

year on approximately 50 ac of seasonal wetlands and 9 ac of associated dikes at Ki‘i with the 

following characteristics: 

 Mudflat (dry and saturated) and open water (<1-18 in) interspersed with 30-60% cover of 

tall (3-8 ft) emergent vegetation, grasses, and sedges that provide seed and green browse 

and a mosaic of concealment cover, open water, and thermal cover; 

 <25% cover of pest plants including marsh fleabane, Batis, water hyssop, California 

bulrush, and California grass; 

 Adjacent short (<4 in), grassy uplands (especially dikes) for foraging; 

 Interspersed vegetation with sufficient edge providing visual barriers to maximize 

territories available for breeding; 

 Predation levels of no more than five individual ‘alae ke‘oke‘o and one ‘alae ‘ula per year; 

 Tilapia numbers maintained at a level promoting algal growth and other desirable plants 

such as Ruppia maritima as forage; and 

 Abundant epiphytic invertebrates (i.e., dragonflies), crayfish, and aquatic benthic/nektonic 

macroinvertebrates to support up to 200 ‘alae ke‘oke‘o and 100 ‘alae ‘ula on a seasonal 

basis. 

Strategies Applied to Achieve Objective

Extended hydroperiod to promote epiphytic invertebrates 

Flood after vegetation treatment (mowing, tilling, etc.) to promote foraging 

Slow drawdown rate (control fish and promote invertebrates/algal growth, plant response) 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

2-10 Chapter 2. Refuge Management Direction 

Strategies Applied to Achieve Objective

Control pest plants using: herbicide application, prescribed fire, mowing, rototilling, disking, and 

brush cutting 

Fencing, live-trapping, snap-traps and bait stations to reduce predation 

Rationale: While ‘alae ke‘oke‘o and ‘alae ‘ula occupy similar loafing and foraging habitat, there 

are differences between the species’ needs. ‘Alae ke‘oke‘o use earlier successional stages of 

wetland habitat with a greater open water to vegetation ratio. They also typically occupy deeper 

water than ‘alae ‘ula. ‘Alae ‘ula prefer late successional stages comprised of dense, robust 

vegetation with greater seclusion. ‘Alae ke‘oke‘o spend more time loafing in a flock on open water 

and dikes, whereas ‘alae ‘ula are more solitary and occupy areas around the base of robust emergent 

vegetation or dikes. ‘Alae ‘ula use open water primarily as a corridor between areas of suitable 

habitat. 

Ki‘i ponds A and E contain a high percentage of Batis which provides habitat for ‘alae ‘ula, while 

other ponds are managed for other species. The mosaic of open water and dense vegetation provides 

areas for thermoregulation and cover and increases habitat diversity. Mowing, disking, prescribed 

fire, herbicide application, and rototilling are all techniques suitable to open dense contiguous 

patches of Batis, California grass, marsh fleabane, California bulrush, water hyssop, or cattaildominated areas. These techniques also return nutrients to the wetland ecosystem and benefit a 

variety of other water-related species including koloa maoli, wintering waterfowl, and shorebirds. 

Objective 1.4. Intensively manage seasonal wetland habitat for ‘alae ‘ula and ‘alae 

ke‘oke‘o breeding.

Provide seasonal wetland habitat for breeding ‘alae ‘ula and ‘alae ke‘oke‘o throughout the year on 

approximately 30 ac on Ki‘i with the following characteristics: 

 Mudflat (dry and saturated) and open water (<1-18 in) interspersed with 30-60% cover of 

tall (3-8 ft) emergent vegetation, grasses, and sedges that provide seed and green browse 

and a mosaic of concealment cover, open water, and thermal cover; 

 Less than 25% cover of pest plants including marsh fleabane, Batis, water hyssop, 

California bulrush, and California grass; 

 Interspersed vegetation with sufficient edge providing visual barriers to maximize territories 

available for breeding; 

 Predation of no more than five individual ‘alae ke‘oke‘o and one ‘alae ‘ula per year; 

 Tilapia numbers constrained to a low level, promoting algal growth and other desirable 

plants such as Ruppia maritima as forage; 

 Abundant epiphytic invertebrates (e.g., dragonflies), crayfish, and aquatic benthic/nektonic 

macroinvertebrates to support up 200 ‘alae ke‘oke‘o and 100 ‘alae ‘ula on a seasonal basis; 

 Brood rearing in close proximity to nesting habitat; and 

 Stable water levels during laying and incubation. 

Strategies Applied to Achieve Objective

Extended hydroperiod to promote epiphytic invertebrates 

Flood to sufficiently inundate emergent vegetation 

Slow drawdown rate (control fish and promote invertebrates/algal growth, plant response) 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-11

Strategies Applied to Achieve Objective

Fencing, live-trapping, snap-traps, and bait stations to reduce predation 

Control pest plants using herbicide application, prescribed fire mowing, rototilling, brush cutting, 

disking 

Mowing, rototilling, brush cutting, and/or prescribed fire to create openings in dense vegetation 

Maintain stable water levels during laying and incubation 

Partial to complete public closure to minimize human disturbance 

Monitor predator abundance to evaluate effectiveness of predator control efforts 

Rationale: ‘Alae ke‘oke‘o and ‘alae ‘ula prefer stable water levels for nest building and nesting. 

When preparing an impoundment for ‘alae ke‘oke‘o and ‘alae ‘ula nesting, water levels are raised to 

a depth of 8-15 inches and maintained at a constant level to provide adequate nest sites that are 

secure from predation. Fluctuating water levels are not desirable, requiring nesting adults to 

continually build the nest up or have it isolated on dry ground and subject to greater predation. 

During brood rearing periods, however, water levels are pulsed infrequently to provide physical 

barriers between brood territories and provide greater access to macroinvertebrates that are eaten by 

adults in breeding condition and also fed to developing chicks. These invertebrates are an important 

protein source for proper development. 

The amount of vegetative cover in an impoundment varies with the duration between habitat 

management actions. As succession from open water to a more vegetation-dominated wetland 

occurs, it favors different species. ‘Alae ke‘oke‘o are adept at nesting in a more open setting where 

there is approximately 30 percent cover of emergent vegetation. ‘Alae ‘ula prefer a more vegetated 

system with about 60 percent cover. 

Because of rapid and year-long plant growth in 

Hawai‘i, habitat manipulation generally requires 

removal of all or nearly all vegetation (generally 

every 2-3 years) from a managed wetland 

impoundment to increase the time before followup management actions are needed. In the habitat 

preparation phase, dewatering followed by 

mowing, tilling, and herbicide application are used 

to achieve the mosaic. During the managing phase 

when water is in the impoundment, water level 

manipulation helps to create the desired percentage 

of vegetation and interspersion. Each impoundment 

can be managed independently in this manner, varying the habitat to meet wildlife needs. 

Ample food supply is important to build and maintain a healthy breeding population at a given site. 

Pest fish, such as Tilapia spp., are known to compete for food eaten by ‘alae ke‘oke‘o and ‘alae ‘ula. 

They also degrade water quality, which can affect invertebrate densities and plant growth. During 

habitat manipulation, slow drawdowns of water levels are used to concentrate undesirable fish and 

ultimately remove them from the environment. Following their death during dewatering, the remains 

are allowed to dry and decompose naturally or are tilled into the soil, increasing soil nutrients that aid 

in promoting invertebrate and plant response. Avian botulism is a concern so evidence of botulism 

Habitat manipulation Mike Silbernagle/USFWS
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

2-12 Chapter 2. Refuge Management Direction 

poisoning is closely monitored for during this fish decomposition period. 

‘Alae ke‘oke‘o and ‘alae ‘ula are less susceptible to disturbance during nesting compared with ae‘o 

and this relates to their nest location, nesting habitat, and response to disturbance. Since ‘alae 

ke‘oke‘o and ‘alae ‘ula nest in open water or dense vegetation with concealment, their response to 

disturbance is to remain motionless on the nest. As a result, public use is limited during the ‘alae 

ke‘oke‘o and ‘alae ‘ula nesting season. Most of the time it is difficult to see a nest even at a relatively 

close distance. 

Recognizing public tours and educational programs are important, there is a need to restrict access 

for such activities in areas where nesting and brood rearing is concentrated. The locations of nest are 

monitored and visitors either directed away from the areas or led quickly through the area to 

minimize human disturbance. 

Objective 1.5: Manage natural wetland habitat for ‘alae ke‘oke‘o and ‘alae ‘ula. 

Provide and manage up to 51 ac of natural wetland habitat of the Punamanō Unit to meet all lifehistory needs of ‘alae ke‘oke‘o and ‘alae ‘ula throughout the year with the following characteristics: 

 Mudflat (dry and saturated) and open water (<1-18 in) interspersed with 30-60% cover of tall 

(3-8 ft.) emergents, grasses, and sedges that provide a mosaic of concealment cover, open 

water, and thermal cover; 

 Less than 40% cover of pest plants including marsh fleabane, Batis, water hyssop, California 

bulrush, California grass, Christmas berry, and koa haole; 

 Adjacent short (<3 in), grassy uplands for foraging; 

 Predation levels of no more than five ‘alae ke‘oke‘o and one ‘alae ‘ula per year. 

Strategies Applied to Achieve Objective

Fencing, live-trapping, snap-traps and bait stations to reduce predation 

Control pest plants using: herbicide application, prescribed fire, mowing, rototilling, disking, and 

brush cutting 

In selected sites, investigate and implement, if feasible, installation of small water control structures 

to partially restore water level management capability and increase habitat diversity 

Monitor predator abundance to evaluate effectiveness of predator control efforts

Rationale: Currently, with no water control structures, intensive water management capabilities are 

lacking at the Punamanō Unit. Therefore, the timing, duration, and water level cannot be managed. 

Natural weather patterns and subsurface ground water movement control the hydrology of the unit. 

Maintenance (nonbreeding) habitat is created, maintained, or enhanced mostly at the wetland/upland 

interface because mowing, tilling, and other mechanisms can be undertaken to control vegetation. 

Access to these areas is limited and most work here must be accomplished by hand. Mudflat habitat 

is only available along portions of the wetland perimeter. Presence, absence, and amount of mudflat 

are dependent on natural fluctuating water level. Natural undulating vegetation edges only create 

limited areas for thermoregulation. 

Breeding habitat for ‘alae ke‘oke‘o and ‘alae ‘ula is restricted to centrally located stands of emergent 

vegetation. Vegetation control in the wetland occurs infrequently due to unavailability of adequate 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-13

equipment (e.g., aquatic weed cutters and excavators) on a regular basis. As a result, lower numbers 

of ‘alae ke‘oke‘o and ‘alae ‘ula are supported here than in intensively managed wetland units. 

Nesting is confined to bulrush stands on this unit. Macro- and other invertebrates are produced, but 

competitive fish such as Tilapia are not controlled and likely reduce food availability for endangered 

‘alae ke‘oke‘o and ‘alae ‘ula. 

Mowing, prescribed fire, herbicide application, and rototilling are all tools that are available to open 

wetland shoreline areas of Batis, California grass, marsh fleabane, Christmas berry, and koa haole. 

Chipping can reduce the removed material that cannot be disposed of by techniques identified above. 

This will speed recovery of the area by reducing the time necessary for natural decomposition to 

occur. Controlling these species promotes a mosaic of wetland fringe and upland vegetation, open 

water, and mudflats as suitable habitat for ‘alae ke‘oke‘o and ‘alae ‘ula. Small pieces of herbaceous 

plant material created from mowing and other techniques also become available to ‘alae ke‘oke‘o 

and ‘alae ‘ula for nest construction. 

A 16-acre wetland site (currently unmanaged) in the southeast corner of the Punamanō Unit, adjacent 

to Nudist Camp Road, has been partially drained by small lateral surface ditches since the early 

1900s. This area will be investigated to determine if the installation of small water control structures 

in these lateral ditches may partially restore historic water levels and provide a minimal amount of 

water management capability that will increase overall wetland habitat diversity in this unit, 

benefitting both ‘alae ke‘oke‘o and ‘alae ‘ula. 

Objective 1.6. Manage remnant wetland habitat within acquisition area for the benefit of 

endangered waterbirds and migratory birds. 

Once acquired, protect and maintain approximately 69 ac of remnant seasonal wetlands within the 

acquisition boundary for James Campbell NWR expansion to meet these characteristics: 

 Mudflat (dry and saturated) and open water (<1-18 in) interspersed with 30-60% cover of tall 

(3-8 ft) emergent grasses and sedges that provide a mosaic of concealment cover, open water, 

and thermal cover; 

 Less than 40% cover of pest plants including marsh fleabane, Batis, water hyssop, California 

bulrush, California grass, Christmas berry, and koa haole; 

 No ironwood or kiawe; 

 Interspersed vegetation with sufficient edge providing visual barriers to maximize territories 

available for breeding; 

 Documented predation of no more than five ae‘o per year; and 

 Limited/controlled public use to minimize disturbance. 

Strategies Applied to Achieve Objective

Fencing, live-trapping, snap-traps and bait stations to reduce predation 

Control pest plants using: herbicide application, prescribed fire, mowing, rototilling, disking, and 

brush cutting 

Create desirable mosaic of openings in vegetation by mowing, rototilling, disking or prescribed fire 

Monitor predator abundance to evaluate effectiveness of predator control efforts 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

2-14 Chapter 2. Refuge Management Direction 

Rationale: Once acquired, Service management of semi-permanent and temporary wetlands within 

the approved boundary will involve controlling undesirable vegetation and, where feasible, limited 

water level management. Major alteration of the landscape is not required to enhance and maintain 

wetlands capable of supporting waterbirds because in most areas soils and hydrology are still 

functioning in a relatively natural manner. Maintenance (nonbreeding) habitat may be created, 

maintained, or enhanced in suitable and accessible wetland/upland interface where mowing, tilling 

and other mechanisms can be undertaken to control vegetation. 

Lower numbers of ‘alae ke‘oke‘o and ‘alae ‘ula will be supported here than in an intensively 

managed wetland. Nesting will be confined to emergent stands. Macro- and other invertebrates are 

produced, but competitive fish such as Tilapia are not controlled and they likely reduce food for 

endangered ‘alae ke‘oke‘o and ‘alae ‘ula. Life-history needs of endangered waterbirds will be met in 

at least part of the area throughout the year under this objective. Other benefiting species include the 

koloa maoli and a variety of migratory wintering waterfowl, primarily dabbling ducks such as koloa 

māpu (northern pintail), koloa mohā (northern shoveler), and green-winged teal. Several shorebird 

species will also benefit including ‘akekeke, kolea, and ‘ū‘lili. 

Selected sites will be investigated for the feasibility of installing small water control structures to 

partially provide water level management capability in these remnant degraded wetlands. In addition, 

several existing groundwater wells on the acquisition area have been used in the past for commercial 

aquaculture operations. These wells, as well as surface water runoff, may also be used to partially 

provide water level management capabilities. This limited capability may improve the control of pest 

species and increase habitat diversity. 

Objective 1.7. Manage aquaculture ponds, in voluntary cooperation with lessees, for 

waterbirds and shorebirds. 

Enhance, protect and manage up to 242 ac. (currently under lease until 2023) to meet these 

characteristics: 

 Mudflat (dry and saturated) and open water (<1-18 in) interspersed with 30-60% cover of tall 

(3-8 ft) emergent grasses and sedges that provide a mosaic of concealment cover, open water, 

and thermal cover; 

 Less than 40% cover of pest plants including marsh fleabane, Batis, water hyssop, California 

bulrush, California grass, Christmas berry, and koa haole; 

 No ironwood or kiawe; 

 Interspersed vegetation with sufficient edge providing visual barriers to maximize territories 

available for breeding; 

 Documented predation level of no more than 10 ‘alae ke‘oke‘o and 4 ‘alae ‘ula per year; and 

 Limited/controlled public use to minimize disturbance.

Strategies Applied to Achieve Objective

Passively manage aquaculture ponds in voluntary cooperation with lessees through water level 

management 

Conduct aquaculture ponds assessment and develop a restoration plan 

Fencing, live-trapping, snap-traps and bait stations to reduce predation 

Control pest plants with herbicide application, mowing, rototilling, disking, and brush cutting 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-15

Rationale: Aquaculture ponds are currently under lease with the Service on 242 acres of the Refuge. 

These leases are scheduled to expire in 2023, when they will permanently revert to Refuge 

management. Lessees may relinquish their leases prior to 2023 on a voluntary basis, or leases may 

be terminated if lessees fail to meet the conditions of the leases. Under current aquaculture 

operations, many of the ponds may be idle for extended periods of time (months to years). These 

idle ponds have potentially high habitat value for endangered waterbirds and migratory birds. With 

relatively little active management, primarily water level management (raising and lowering water 

levels at desirable intervals), the additional wetland habitat can benefit these species. This provides 

an opportunity for voluntary cooperative management strategies between the lessees and the Refuge. 

When the leases expire and/or when the ponds revert to Refuge management, they will be evaluated 

for more active and long-term management strategies. This process will begin with a comprehensive 

water management and resource analysis planned for 2018-2020. 

Objective 1.8. Provide wetland habitats to meet the life-history needs of koloa maoli. 

Enhance, protect and manage up to 50 acres to meet these characteristics: 

 Mudflat and open water containing an approximately 50:50 ratio of emergent plants to open 

water, with an irregular shoreline; 

 Less than 40% cover of pest plants including marsh fleabane, Batis, water hyssop, California 

bulrush, California grass, Christmas berry, and koa haole; 

 Abundant small invertebrates such as aquatic insects, snails and crustaceans (400-600 

invertebrates/yd2

); 

 No introduced aquatic vertebrates; and 

 Limited/controlled public use to minimize disturbance.

Strategies Applied to Achieve Objective

Support inter-agency efforts to promote the recovery of pure koloa maoli 

Monitor, research, and survey koloa maoli population 

Pulse water to promote abundance and availability of invertebrates thrice monthly 

Control pest plants using: herbicide application, prescribed fire, mowing, rototilling, disking, and 

brush cutting

Rationale: The koloa maoli is an endangered waterfowl endemic to the Hawaiian Islands. Koloa 

maoli eat primarily small invertebrates such as aquatic insects, snails, and crustaceans. They also eat 

freshwater limu (algae) and seeds of grasses, sedges, and other plants. They sometimes graze on 

grasses and legumes similar to geese. Pest fish (mosquito fish and Tilapia) compete with koloa maoli 

for food. Koloa maoli are more likely to use wetlands farther (more than 600 yds) from houses, larger 

(0.75 ac) wetlands, and those surrounded by more wetlands area (2.5 ac) (Uyehara et al. 2007). 

The Draft Revised Recovery Plan for Hawaiian Waterbirds lists the koloa maoli as having a high 

potential for recovery and a high degree of threat due to hybridization with mallard ducks, the 

greatest threat to this species’ continued existence. Although birds on O‘ahu and Maui are thought to 

be primarily koloa-mallard hybrids, three pure koloa maoli were found at James Campbell NWR 

during a genetic testing survey in 2008. In addition to hybridization concerns, other hazards exist for 

koloa maoli. Known predators of eggs and ducklings include mongooses, cattle egrets, cats, dogs, 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

2-16 Chapter 2. Refuge Management Direction 

and possibly rats and Samoan crabs. ‘Auku‘u and bullfrogs have been observed to take ducklings. 

Avian diseases are another threat to koloa maoli with outbreaks of avian botulism occurring annually 

throughout the State. Habitat improvements combined with feral mallard control may reduce 

extinction threats to koloa maoli (Uyehara et al 2008). 

2.6.2 Goal 2. 

Complete acquisition of the James Campbell NWR expansion to restore, 

protect and manage habitats according to Refuge purposes and to meet 

Refuge staff facility needs. 

Objective 2.1. Complete the James Campbell National Wildlife Refuge Expansion Act land 

acquisition process. 

Complete acquisition of lands identified in the Expansion Act by December 2013. 

Strategies Applied to Achieve Objective

Continue close coordination/cooperation with James Campbell Company, Regional Office, and 

Washington Office to complete terms of purchase agreement 

Monitor transfer of State Water Use Permit to meet time restrictions for administrative transfer 

Identify/pursue new opportunities for land acquisition that will serve/benefit Refuge purpose 

Pursue acquisition from willing sellers of small land inholdings within the Refuge boundary to 

complete/consolidate Refuge lands

If needed, pursue Executive Order from the State of Hawai‘i for jurisdiction to manage shoreline 

adjacent to Refuge to protect wildlife and standardize public use regulations

Rationale: The James Campbell NWR Expansion Act of 2005 authorized the expansion of the 

Refuge to 1,100 acres. The purchase agreement between the Service and James Campbell Company 

has a sunset clause that mandates the acquisition be completed by December 2013. Funding has been 

obligated to complete the purchase and as of August 2011, Parcels 1 and 4 (see Figure 3-2) have been 

purchased and are now part of the Refuge. Parcels 2 and 3 remain to be purchased. 

Management jurisdiction for the new property boundary along the shoreline is under review, subject 

to the Service solicitor’s opinion. If we determine that the Service does not currently have 

management authority for the shoreline adjacent to the Refuge, we will pursue an Executive Order 

from the Governor of Hawai‘i for jurisdiction to help fulfill the Refuge purpose and eliminate 

conflicting uses or regulations. Under State law, when a compelling need or benefit may be met, an 

Executive Order signed by the Governor may be issued to transfer management responsibility of the 

State shoreline corridor to the adjoining landowner, in this case the Refuge. This action, if approved 

and agreed upon by the State, would consolidate management and protection of highly valuable and 

sensitive coastal resources along this unique portion of coastline. 

Water rights owned by James Campbell Company will be transferred to the Refuge upon sale. State 

Water Commission regulations allow for administrative transfer of water use permits if application is 

made within 60 days of land transfer. Administrative transfer precludes the need to apply for new 

water use permits on existing permitted wells. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-17

Other lands adjacent to or in the vicinity of the Refuge with potential high value and benefit to the 

Refuge may be identified and become available for purchase. In these cases, Service procedures and 

policies, including NEPA compliance and willing seller policy, would be followed to pursue 

acquisition of these potential additional lands. 

Objective 2.2. Develop site plans and construct new Refuge facilities. 

By the year 2014, identify suitable sites for complex headquarters, visitor center, and EE 

(HQ/VC/EE), and other Refuge facilities. Develop plans for and construct HQ/VC/EE facility with 

the following attributes: 

 Leadership in Energy & Environmental Design certified; 

 Energy efficient – in operation and in construction; 

 Resource efficient – in operation and in construction; 

 Non-polluting – in operation and production; 

 Accessible – to provide equal use of the built environment for all people; 

 Native plantings – landscape uses native plants adapted to O‘ahu’s north shore; and 

 Local building materials – to minimize the energy embedded in their transportation. 

Strategies Applied to Achieve Objective

Develop site plans for areas to be managed as administrative lands 

Acquire approval and funding for Design/Build of new HQ/VC/EE facility 

Evaluate and construct, if feasible, a new Complex maintenance facility at a more desirable location 

(higher elevation, less harsh coastal environment, improved access) than current location 

Evaluate and implement, if feasible, restoration of existing residential home on Parcel 4 to provide 

adequate temporary housing for volunteers, interns, or researchers; or pursue location and 

construction of a standardized bunkhouse facility 

Construct greenhouse for native plant propagation 

Rationale: Acquisition of new land will provide opportunities to develop major Refuge facilities 

that will benefit the public and staff such as a HQ/VC/EE to serve the Complex. Suitable site 

characteristics include consideration of public road access, proximity to utilities, and ground 

elevation. For nearly 20 years, Refuge staff have worked out of a leased office space in Hale‘iwa, 20 

miles from the Refuge. This location does not serve the staff or the public well. A HQ/VC/EE 

constructed on the Refuge would be a tremendous boost to the visibility and image of the Service and 

could serve an estimated 210,000 visitors annually and up to 6,000 students. 

The current location of the Complex maintenance facility is undersized and is exposed to harsh 

marine coastal winds that are highly corrosive to equipment due to salt spray. When fully acquired, 

sites on the expansion lands will be evaluated to determine their feasibility for a new maintenance 

facility that would better serve the growing management needs of the Complex and offer greater 

protection from harsh coastal conditions. A new bunkhouse would provide onsite, affordable 

temporary housing for volunteers, researchers, or interns thereby greatly enhancing the ability of 

these persons to conduct work on the Refuge. New facilities will be designed and built to improve 

performance in metrics such as energy savings, water efficiency, CO2 emissions reduction, improved 

indoor environmental quality, and stewardship of resources and sensitivity to their impacts. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

2-18 Chapter 2. Refuge Management Direction 

2.6.3 Goal 3. 

Restore and protect coastal strand/dune habitat and upland scrub/shrub to 

provide safe refuge for endangered ‘īlio-holo-i-ka-uaua and threatened honu, 

as well as provide habitat for seabirds, shorebirds, and migratory birds. 

Objective 3.1. Restore, protect, and manage coastal strand/dune habitat. 

Restore, protect, and manage a mosaic of up to 200 acres of terrestrial habitat consisting of 

approximately 140 acres of coastal dune/strand, and up to 60 acres of adjacent coastal scrub/shrub to 

promote nesting and roosting habitat for 6 seabird species, as well as protected habitat for honu and 

‘īlio-holo-i-ka-uaua. Coastal strand/dune habitat characteristics should be: 

 Patchy distribution of low growing (2-8 ft), native woody species (e.g., ‘ilima, naupaka 

kahakai, pilo, wiliwili, naio, hala) as a mosaic; 

 30-40% cover of native grasses (e.g., ‘āki‘aki) and herbaceous vegetation (e.g.,Mau‘u, 

Pōhuehue) on dunes; 

 Less than 10% of woody pest plant species (e.g., marsh fleabane, mangrove, Christmas 

berry, and koa haole); 

 No ironwood or kiawe; 

 Less than15% cover of herbaceous pest plant species; 

 Predation limited to no more than six seabirds per year; and 

 Restricted public use to protect fragile dunes habitat, particularly native plants; and to 

minimize human disturbance to ‘īlio-holo-i-ka-uaua, honu, seabirds, shorebirds, and other 

migratory birds. 

Strategies Applied to Achieve Objective

Remove marine debris 

Periodic mowing and brush-cutting to allow for breeze flow and pathways from dune crest 

Propagation and planting of native plant species 

Control pest plants with herbicide application, prescribed fire, mechanical removal, and brush cutting 

Predator control methods for pigs, cats, and dogs include trapping, fencing, and shooting 

Support volunteers and organizations to protect wildlife and inform public along shoreline 

Predator control methods for rodents and mongooses include bait stations, trapping, and fencing 

Fencing to limit human disturbance 

Test use of predator-proof fencing to exclude all mammals; implement on a larger scale if feasible 

For nesting seabirds, minimize human disturbance until colony is well established; then provide 

appropriate viewing platforms or blinds for the public 

Refuge coastline closed to public use at night to protect nesting honu and seabirds 

Temporary or seasonal public closures in the Refuge-owned shoreline as necessary to protect nesting 

honu or pupping ‘īlio-holo-i-ka-uaua

 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-19

Rationale: Intact vegetative coastal dune communities are extremely rare throughout the main 

Hawaiian Islands and important to several rare and endangered animal and plant species. Coastal 

dune and associated beach strand habitat are used by endangered ‘īlio-holo-i-ka-uaua and threatened 

honu for hauling out, basking, and pupping or nesting respectively. This habitat also provides 

important foraging and loafing areas for migratory bird species such as the kioea, kōlea, and 

‘akekeke. Soil texture, relative position to the shoreline, and desirable plant species provide suitable 

subterranean nest burrow habitat for ‘ua‘u kani and ‘a‘o (Newell’s shearwater). 

The Refuge coastline is at the northeast tip of the island where it is highly susceptible to 

accumulation of marine debris due to ocean currents and prevailing northeast wind. Honu , ‘īlioholo-i-ka-uaua, and sea birds may be severely injured and even die after entanglement with fishing 

lines, fragments of trawl netting or plastic packing straps. Seabirds caught in this debris may lose 

their ability to move quickly through the water, reducing their ability to catch prey and avoid 

predators; or they may suffer constricted circulation, leading to asphyxiation and death. Fishing line, 

nets, and ropes cut into the skin of ‘īlio-holo-i-ka-uaua or honu, leading to infection or painful 

amputation of flippers or tails. Honu frequently eat plastic bags, confusing them with jellyfish, their 

common prey. Seabirds eat polystyrene balls and plastic buoys, confusing them with fish eggs and 

crustaceans. Beach clean-ups at the Refuge are scheduled two to four times annually, depending on 

the availability of volunteers. 

Coastal dunes are fragile and easily altered by human activity. Livestock grazing and off-roadvehicle (ORV) use was and is occurring, having an impact on the substrate and vegetative 

community. Observed changes include “blowouts” in the dunes and the occurrence of pest plant 

species that likely came in with livestock food or mud tracked in with ORVs. These activities will be 

suspended as the land is acquired by the Refuge. 

Six seabird species were selected for priority management because of their habitat preferences at 

other nesting sites in Hawai‘i that resemble the conditions at the Refuge, the proximity of possible 

sources of colonizing birds, examples of previous restoration attempts at other sites that were 

successful, and their relatively higher resistance to small mammals such as mice that may be 

impossible to control in the early stages of colony restoration. In order of feasibility of attraction and 

establishment, the species are mōlī, ‘ua‘u kani, koa‘e‘ula, ‘a, ka‘upu, and Christmas shearwater. 

Other species including the ESA-listed ‘a‘o, the ‘ou, and many of the tropical terns will more likely 

be attracted and successfully nest here once other seabirds are already established. Removal of 

woody pest plants to maintain breeze flow is critical to aid in thermoregulation of nesting adults and 

prefledgling seabirds. During periods of high temperatures, seabirds depend on airflow to help 

maintain normal body temperature. Parents have to remain on the nest during incubation, making 

departure from the area infeasible because mortality of the developing embryo could occur. Sea 

breeze/air flow is also an important component to taking-off because of wing loading. Much like 

aircraft, seabirds tend to take off into the wind because it assists them in getting airborne more 

quickly with less energy expenditure. 

Low intensity management on beach and dunes will include fencing, spot treatment of pest plants, 

and minimizing predation. For each species, the restoration methods can include manipulating the 

vegetation community; providing a mammal-free area; employing attraction techniques such as 

sound recordings, decoys, and mirrors to take advantage of the highly social nature of nesting 

seabirds; or actively translocating animals at the appropriate age, rearing them on site and releasing 

them in the hope that they will return at breeding age to the new colony. This final method has been 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

2-20 Chapter 2. Refuge Management Direction 

recently successfully employed with short-tailed albatrosses in Japan and has also been used with 

fluttering shearwaters in New Zealand and Atlantic puffins in Maine. Existing habitat for each of the 

species suggested already exists in the approved acquisition site. Additional nest sites could be 

provided for koa‘e ‘ula and ‘ua‘u kani by using slabs of concrete building material to create shelters 

and by building wooden nest site structures above the ground for ‘ā (Rauzon 1999). 

Predators such as rats, mongooses, cats, and dogs are the primary limiting factor to restoring and 

maintaining a seabird community. Predator control provides the opportunity for seabirds to 

recolonize important nesting habitat. Benefits will also be realized for wintering and resident 

shorebirds on areas managed for seabirds. Removal of pest species and increased loafing and 

foraging habitat will allow the Refuge to support a larger number of shorebirds, many coming from 

thousands of miles away. 

Objective 3.2. Improve potential seabird nesting site on abandoned Kahuku airfield 

runway. 

Restore, manage, and protect approximately 28 acres of abandoned runway to promote nesting 

habitat with the following characteristics: 

 Patchy distribution of low growing (2-8 ft) naupaka kahakai as a mosaic; 

 Less than 10% of woody pest plant species (e.g., marsh fleabane, mangrove, Christmas 

berry, and koa haole); 

 No ironwood or kiawe; 

 Less than15% cover of herbaceous pest plant species; 

 Breeze flow corridors to aid in thermoregulation; 

 Predation limited to no more than six seabirds per year; and 

 Restricted public use to minimize human disturbance to nesting seabirds. 

Strategies Applied to Achieve Objective

Remove and control invasive woody growth on and along perimeter (aprons) of runway using a 

variety of techniques including cutting, mowing, grubbing, prescribed fire, and herbicide application 

Implement control methods for nonnative predators including trapping, baiting, fencing, and 

shooting 

Test use of predator-proof fencing to exclude all mammals; implement on a larger scale if feasible 

Monitor seabird activity to determine future management actions 

Monitor encroachment of pest species 

Engage in attraction of birds using visual cues such as decoys, mirrors, and/or recorded calls of 

desired species 

Rationale: A short distance inland from the dunes, the abandoned World War II Kahuku runway 

could provide potential nesting habitat to albatross and other seabirds, similar to that found on 

abandoned runways at Midway Atoll, Tern Island, and other remote Pacific Islands. Mōlī, in 

particular, frequently and heavily use flat, open sites with low or interspersed vegetation for nesting. 

These conditions exist at several former military runways at several sites around the Pacific. The 

Kahuku runway is ideally located just a few hundred yards inland from the coast and downwind of 

the prevailing trade winds. 

 

After years of inactivity, vegetation has encroached on much of the remaining Kahuku runway. The 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-21

aprons of the runway proper, constructed primarily of compacted crushed coral, are largely covered 

with koa haole, kiawe, Pluchea, and ironwood. The runway was constructed of a light asphalt mix 

and has been invaded by pest vegetation to a lesser extent. Where small portions of the original 

runway remain open, native vegetation such as pōhuehue has become established. This low-growing 

plant is suitable for nesting habitat and will continue to be promoted. Sufficient airflow (breeze and 

wind) is a fundamental component of a suitable mōlī nesting site. Mōlī adults and chicks depend 

heavily on airflow to help regulate their body temperatures to help with takeoff and flight at inland 

sites. Removal of the existing dense woody pest vegetation along the runway will help to 

significantly restore a natural airflow over the site. 

Control of nonnative predators is essential to the establishment and success of any seabird colony on 

the main Hawaiian Islands. Several attempts by mōlī to individually colonize nearby coastal habitat 

over the past few decades have almost always resulted in the eggs, chicks, or adults being killed by 

predators, generally believed to be dogs. 

As rising sea levels begin to negatively impact important seabird nesting sites in more vulnerable 

remote Pacific islands, nesting sites on the main Hawaiian Islands (which are generally higher in 

elevation) will become increasingly important. Unfortunately, suitable potential nesting sites in the 

main Hawaiian Islands are very uncommon due to loss of habitat and impacts from pest species. 

Potential nesting sites such as the abandoned Kahuku runway may take on significantly more 

importance in future decades. 

Over the 15-year timeframe of this CCP, the use and benefits of the runway habitat for seabirds will 

be monitored and evaluated. The kioea, another important migratory bird species, is regularly 

observed using the remaining open portions of the runway for foraging and resting. This species will 

also benefit from the proposed management of the runway. 

The few species of seabirds that successfully nest in very limited areas on the Island of O‘ahu are a 

reflection of the devastating impacts from predators, including rats, mongooses, cats, dogs, and pigs. 

These pest species are the primary limiting factor to reestablishing and maintaining a successful 

nesting seabird community. Despite predator control programs, predation can still be a serious 

problem. One management strategy to reduce or eliminate the damage would be to include predator 

exclosure fences and eradicate pests from within the fenced areas. Control and management of pest 

vegetation and predators provides an opportunity for seabirds to recolonize important nesting habitat. 

 

Mōlī pair watches over chick USFWS
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

2-22 Chapter 2. Refuge Management Direction 

Objective 3.3. Restore scrub/shrub habitat within expanded boundary. 

Develop restoration plans for up to 312 acres of scrub/shrub habitat considering the following: 

 Native plants consistent with historic scrub/shrub habitats; 

 Sparsely vegetated geological formations (e.g., coral outcrops) with potential to support 

nesting seabirds; and 

 Cover plants within 30 yds of wetlands to support life history needs of waterbirds. 

Strategies Applied to Achieve Objective

Conduct surveys and studies to determine desirable native vegetation community based on local site 

conditions including soil type, elevation, groundwater table and proximity to shore 

Use IPM techniques to control/eradicate pest plants 

Work with the Bishop Museum and other partners to determine the historic plant communities 

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

Determine the feasibility of establishing populations of the endangered ‘Ewa hinahina and ‘akoko.

Develop/implement plans to conduct major cleanup of abandoned aquaculture facilities and restore to 

natural conditions or other approved uses (i.e., visitor use facilities) 

Rationale: This area in the new Refuge boundary has not previously been managed by the Service. 

Much of the scrub/shrub habitat occurs over an exposed coral shelf substrate. This habitat is limited 

on O‘ahu and supports several threatened or endangered plants. The extent of this coral substrate on 

the Refuge might be important for future restoration and recovery efforts for one or more of these 

species. 

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

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

with partners to restore a viable natural native plant community through removal of pest plants and 

outplanting of native plants that were part of the historic vegetative community. Plans to construct a 

greenhouse in Objective 2.2 will enhance the Refuge’s ability to promote native plant propagation for 

use on the Refuge. 

2.6.4 Goal 4. 

Collect scientific information necessary to support adaptive management 

decisions. 

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

evaluate management strategies to guide management decisions.

Throughout the life of the CCP, conduct high-priority inventory and monitoring (survey) activities 

that evaluate resource management and public-use activities to facilitate adaptive management. 

These surveys contribute to the enhancement, protection, use, preservation, and management of 

wildlife populations and their habitats on- and off-refuge lands. Specifically, they can be used to 

evaluate achievement of resource management objectives identified in this CCP. These surveys have 

the following attributes: 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-23

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

to minimal habitat destruction; 

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

macroinvertebrates, vertebrates) to meet statistical analysis requirements for identification and/or 

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

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

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

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

applicable. 

Strategies Applied to Achieve Objective

Continue to encourage Refuge staff to publish in peer-reviewed scientific journals and attend 

professional society and agency-sponsored meetings/conferences 

Require researchers to use regionally comparable field methods where feasible and appropriate 

Establish and develop partnerships with other agencies, organizations and universities to pursue joint 

research projects 

By 2020, in a comprehensive water resources and management plan, collect and synthesize the 

following information: hydrology (seasonal water levels, wet and dry cycles, groundwater 

resources), water chemistry, soils, and geomorphology 

By 2013 complete baseline hydro-geomorphic study of entire refuge landscape (project currently 

funded and scheduled to begin 2011)

Utilize trained volunteers, where feasible, to conduct surveys and collect data to reduce workload on 

refuge staff

Investigate and monitor the impacts of pest plants and animals on Refuge landscapes 

Investigate movements of endangered waterbirds (e.g., inter- and intra-island movement) 

Determine survival and predation rates of endangered waterbirds 

Develop GIS layer of pest species and update on a quarterly basis 

Develop GIS layer of Refuge vegetation and update on an annual basis 

Develop climate change monitoring protocols

Rationale: Monitoring projects on Refuge islands enhance scientific understanding of the 

ecosystems and lead to better management. Long-term monitoring efforts are extremely valuable in 

terms of the information provided and in adaptive management techniques. Human use issues are 

likely to increase in terms of pressures on the Refuge resources due to developing local and regional 

markets. This may lead to additional and new types of human impacts. This is likely to present 

management challenges, which can be approached with proactive applied research projects and longterm monitoring efforts. Communication of monitoring and research findings is the responsibility of 

the Service. Presentation of results and ideas helps foster the understanding and respect for Refuge 

management actions. Dissemination of scientific information also leads to conservation of natural 

resources through understanding and informed management decisions. Research presentation also 

provides a forum for research and management improvement through peer-review. 

Refuge scientists will also be encouraged to include research findings in public interpretive 

programs. Information on the location of extremely fragile natural resources or those subject to 

vandalism will not be included in final studies and reports for public distribution. Modification of 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

2-24 Chapter 2. Refuge Management Direction 

databases and methods to be comparable and compatible to other research is a cost-effective way to 

conduct comprehensive Refuge research. Being able to compare Refuge data with other local, 

regional, and even global data will help guide ecosystem management priorities for Refuge 

resources. It will also promote the Service’s ecosystem approach to resource management, as well as 

enhance worldwide scientific connection and understanding. 

A study initiated in 2011, Temporal and Spatial Pattern of Sea-level Rise Impacts to Coastal 

Wetlands and Other Ecosystems, will provide timely models for assessment of ecosystem 

vulnerability within the Refuge. Stakeholder workshops will be used to assess needs and define gaps 

to identify and design final products with place-based solutions. 

 

During the period 2018-2020, a comprehensive water resources and water management plan is 

scheduled to be developed for the entire Refuge. This time period represents an optimum schedule 

for this plan for a number of reasons. Foremost is that the major milestone will be reached in 2023 

when the long-term leases of the aquaculture ponds will expire and full management responsibility 

for these ponds will return to the Refuge. This event will have major implications across the Refuge 

landscape and habitat management programs. By initiating planning in 2018, we will be able to 

evaluate and incorporate the most recent data on a number of issues including global climate change 

and sea level rise, and the most up-to-date status of endangered waterbirds. A plan completed by 

2020 would provide Refuge staff critical and timely information needed to make decisions about 

major projects related to taking over management of the aquaculture ponds which could have 

Refuge-wide implications and enter these projects into database needs in time to be considered by 

the 2023 budget cycle. A hydro-geomorphic study planned for completion by 2013 may provide 

much of the groundwork and provide much of the baseline information for this 2020 comprehensive 

plan. 

2.6.5 Goal 5. 

Provide wildlife-dependent public use and educational opportunities to 

enhance public understanding and appreciation of the natural resources of 

James Campbell NWR and the National Wildlife Refuge System.

Objective 5.1. Provide a quality environmental education program. 

Provide a quality EE program based on Refuge and endangered species recovery management 

programs, with specific learning objectives and diverse opportunities with the following attributes: 

 Increases public awareness and knowledge of environmental issues; 

 Meets State standards for learning; 

 Provides motivation to improve or maintain environmental quality; 

 Imparts skills to identify and help resolve environmental challenges; and 

 With construction/staffing of an EE center, accommodates a year-round program that serves up to 

6,000 students per year. 

Strategies Applied to Achieve Objective

Develop a VSP within 5 years that identifies details of the Refuge EE program and evaluates EE 

facility needs, including construction of an EE center 

Promote the Refuge and the EE program with teachers during the development of the VSP 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-25

Strategies Applied to Achieve Objective

Continue current seasonal program (October 15-February 28) at Ki‘i Unit 

Seek additional partnerships and teacher volunteers for providing additional EE opportunities annually 

Hire a permanent-full time EE specialist 

Phase-in seasonal program around Punamanō Unit as facilities are developed through the VSP (with 

gradual reduction at Ki‘i Unit) 

Designate EE sites where students can participate in independent study 

Develop curricula for the EE program and provide support and resources for Refuge volunteers 

Expand and encourage other local schools such as Sunset Beach Elementary, Lā‘ie Elementary, 

Kahuku Elementary, and Hau‘ula Elementary to participate in educational programs 

Develop “teach the teacher” programs and Refuge-specific instructor training 

Develop grant proposals to strengthen outreach and education partnerships 

Participate in the Smaller Learning Communities Program at Kahuku schools 

Rationale: Environmental education does not advocate a particular viewpoint or course of action. 

Rather, it teaches individuals how to weigh various sides of an issue through critical thinking and it 

enhances their own problem-solving and decision-making skills. It is a learning process that increases 

people's knowledge and awareness about the environment and associated challenges, develops the 

necessary skills and expertise to address the challenges, and fosters attitudes, motivations, and 

commitments to make informed decisions and take responsible action. It focuses on: 

 Awareness and sensitivity about the environment and environmental challenges; 

 Knowledge and understanding about the environment and environmental challenges; 

 Attitude concern for the environment and help to maintain environmental quality; 

 Skills to mitigate the environmental problems; and 

 Participation for exercising existing knowledge and environmental related programs.

Land acquisition will expand the land base of natural 

resources, providing greater opportunities for yearround EE programs at James Campbell NWR. The 

Refuge is in a unique position to offer local education 

agencies, teachers, and students an opportunity to 

study endangered species, natural resource 

management, conservation issues, and cultural 

resources in an outdoor setting. 

The Refuge currently serves 1,500 students and 

teachers annually. We could accommodate up to 

3,000 students annually with no change in the current 

program. State budget issues during the 2009-2010 

school year resulted in teacher furloughs, 4-day school weeks, and reduced fieldtrip funding. These 

issues negatively impacted the ability of teachers to bring their students to the Refuge. We estimate 

that the Refuge could accommodate up to 6,000 on-site each year if: (1) an education staff was 

available to run the program full-time; (2) educators were trained and could be recruited to utilize the 

Refuge during all months of the school year; and (3) the proposed EE facility is funded and 

constructed. 

Ki‘i kiosk Laura Beauregard/USFWS 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

2-26 Chapter 2. Refuge Management Direction 

Objective 5.2. Offer visitors outdoor recreation opportunities to enjoy, discover, and 

encourage support for James Campbell NWR.

Provide meaningful, enjoyable outdoor experiences for people of all ages (including wildlife 

observation, photography, interpretation, and fishing) that connect them with nature and foster a 

conservation ethic. By 2016, develop a VSP and associated NEPA document to identify locations, 

facilities, and regulations needed to provide year-round opportunities with the following attributes: 

 High-quality wildlife-oriented visitor experiences; 

 Accessible to individuals with disabilities; 

 Safe environment and facilities for visitors; and 

 Visitor access to ocean shoreline is provided. 

Strategies Applied to Achieve Objective

Conduct docent-led tours at Ki‘i Unit 

Develop a VSP within 5 years that identifies new visitor facilities and features, to include self-guided 

interpretive trails 

Conduct docent-led tours at Punamanō Unit, when facilities are developed through VSP

Provide specific information for shoreline access, including ‘īlio-holo-i-ka-uaua and honu closure 

information in cooperation with other agencies (NOAA and State) 

Hire a Refuge Officer 

Develop new interpretative materials (brochures, kiosk panels, species lists) 

Rationale: We see our work resulting in all visitors and local communities gaining a greater 

connection with nature, sense of place, respect for their environment, and a lifelong interest in and 

participation in the conservation, protection, and enhancement of wildlife, plants and their habitats. 

A VSP will be developed to ensure: (1) opportunities exist to view wildlife in their habitat and in a 

natural setting; (2) observation opportunities promote public understanding of Refuge resources and its 

role in managing and protecting those resources; (3) observations occur in places with the least amount 

of disturbance to wildlife; (4) facilities are safe, fully accessible, and available to a broad spectrum of 

the public; (5) viewing opportunities are tied to interpretive and educational opportunities; and (6) 

observers have minimal conflict with other visitors or Refuge operations. Features of the VSP could 

address the following projects: 

 Develop self-guided interpretive boardwalk with observation towers, kiosks, and spur trails for 

photographers and beach access (access across the Refuge will remain closed until VSP is 

approved and necessary infrastructure is completed); 

 Design kiosks for roadside pull-offs, trail heads, and visitor contact station; and 

 Work with the Hawai‘i Department of Transportation and Federal Highway Administration to 

plan and fund safe pull-offs along Kamehameha Highway along boundary of James Campbell 

NWR. 

The Refuge is considered by many to be one of the best areas in Hawai‘i to view endangered 

waterbirds. High-quality wildlife viewing will continue and be expanded on the Refuge through the 

development and maintenance of trails, boardwalks, and observation sites (i.e., elevated viewing 

platforms). 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-27

Four species of endangered Hawaiian waterbirds are present year-round at Ki‘i Unit, which currently 

provides the visiting public with quality viewing opportunities. Ae‘o are highly susceptible to 

disturbance during their nesting season, whereas the other endangered waterbirds are more tolerant. 

Consequently, docent-led interpretative tours of Ki‘i wetlands are conducted only during the ae‘o 

nonbreeding season (October -February). During the interim between present conditions and the 

development of lands within the expansion boundary, these tours will be continued. As part of the 

VSP, we plan to develop self-guided tours in other areas of the Refuge. Once they are in place, docentled tours will be conducted at greatly reduced frequency at Ki‘i. 

Refuge law enforcement officers are responsible for upholding Federal laws and regulations that 

protect natural resources, the public, and employees. The expansion lands come with new challenges 

for law enforcement on the Refuge. A dedicated Refuge Officer is needed to protect Refuge visitors 

and employees from disturbance or harm by others; to assist visitors in understanding Refuge laws, 

regulations, and the reasons for them; to enhance the management and protection of natural resources; 

and to obtain compliance with laws and regulations necessary for the proper administration, 

management, and protection of the Refuge. 

2.6.6 Goal 6. 

Protect historic and cultural resources for the benefit of present and future 

generations. 

Objective 6.1. Enhance awareness, protection, and appreciation of historic and cultural 

resources. 

Throughout the life of this plan, increase monitoring, protection, and appreciation of all cultural 

resources and historic sites on the Refuge. Promote conservation of historic and cultural resources for 

the education, inspiration, and enrichment of the public in a spirit of stewardship and trusteeship for 

future generations. 

Strategies Applied to Achieve Objective

Comply with Section 106 of the National Historic Preservation Act (NHPA) when conducting grounddisturbing activities 

Develop and maintain liaison with Native Hawaiian organizations 

Consult with Native Hawaiian groups, historical societies, and other preservation partners to identify 

types of historic and cultural resource information appropriate for public interpretation 

Train all field personnel in Native American Grave Protection and Repatriation Act (NAGPRA) 

protocol and procedures for handling inadvertent discoveries of human remains and cultural artifacts 

Develop a Refuge GIS layer for cultural resource sites (for use in management decisions, with 

sensitive information protected) 

Develop a GIS layer for World War II remnants on Refuge lands

Rationale: The NAGPRA is a Federal law that provides, in part, a process for Federal agencies to 

transfer custody and control of certain cultural items (human remains, funerary objects, sacred objects, 

and objects of cultural patrimony) removed from federal lands to lineal descendants, Indian tribes, and 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

2-28 Chapter 2. Refuge Management Direction 

Native Hawaiian organizations. Native Hawaiians believe that the mana or spiritual essence and power 

of a person reside in the bones, their iwi. Unmarked Native Hawaiian burial sites have been exposed 

in the coastal strand/dunes area of the Refuge but can be encountered almost anywhere. Care of 

inadvertently discovered iwi kupuna (ancient bones) is an important issue for Native Hawaiians and 

the entire community in Hawai‘i. The Service has the responsibility to care for the iwi kupuna with 

utmost respect for Hawaiian protocol and the recognized lineal descendants and culturally affiliated 

Native Hawaiian organizations. Strict protocols come into force whenever human skeletal remains are 

encountered inadvertently, through maintenance activities or through natural erosion. 

When remains are encountered, all work in the immediate area is stopped, and the police as well as the 

Coroner-Medical Examiner are notified. If the remains appear to be under 50 years in age, a possible 

homicide victim, or missing person, the local police secure the scene and investigate. If the remains 

appear to be over 50 years in age since death and interment, a qualified archaeologist then examines 

the burial context to assist in determining whether they may be iwi kupuna. If they are iwi kupuna, the 

Service, in consultation with recognized descendants or Native Hawaiian organizations, determines 

whether the burial can safely remain in place where discovered or whether relocation may be needed. 

The key to protecting cultural resources is promoting knowledge of and appreciation for the resources. 

Currently, information on known cultural sites is not easily accessible to Refuge field staff responsible 

for the maintenance operations. Recognizing that sensitive information should be protected, 

knowledge of specific areas to avoid would be helpful to field staff engaging in maintenance activities 

around the Refuge. James Campbell NWR had a cultural resource overview completed by the 

National Park Service in 2005. However, a comprehensive access-protected GIS-based database is 

needed. The Zone Officer has received training in cultural resource law, but continuing education and 

coordination with State officers is needed for more staff. 

Polynesian settlement, Hawaiian legends, agricultural activities, and World War II fortifications are all 

part of the rich history within the Refuge, and it is appropriate to share these stories with the public. 

The Refuge could achieve a higher level of interpretation by partnering with Native Hawaiians and 

groups interested in local history. Protection of historic and cultural resources will be incorporated in 

the VSP. 

Kahuku Airfield, August 20, 1942 DOD archives
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 2. Refuge Management Direction 2-29

2.6.7 Goal 7. 

Assist partner agencies and local community with planning and implementing 

flood damage reduction measures for the Town of Kahuku. 

Objective 7.1. Support flood damage reduction efforts for Kahuku. 

Maintain floodwater storage function of Refuge expansion lands (when fully acquired) and support 

approved watershed flood damage reduction projects. 

Strategies Applied to Achieve Objective

Maintain 73-acre Walkerville Unit (when fully acquired) as potential flood damage reduction 

project area by removing existing encroaching woody vegetation, as feasible, and periodic disking 

or mowing to prevent further encroachment and allow more free-flowing water 

Participate in community and government planning efforts to reduce flood damages in Kahuku that 

may utilize portions of Refuge expansion lands 

Regularly maintain Refuge ditches 

Evaluate Refuge infrastructure for flood damage reduction mitigation opportunities 

Rationale: Local flooding following major rainfall is an important concern for the local Kahuku 

community. Past flooding has damaged homes and businesses and closed local roads and 

highways. Portions of the Refuge expansion lands lie within the floodplain and floodway adjacent 

to the town of Kahuku and Hospital Ditch, a vital local drainage. These lands already flood 

following heavy rain and runoff but have been identified as a site where engineered (controlled) 

flooding may offer some opportunity for flood damage reduction in the surrounding area. As 

identified in studies by the U.S. Army Corps of Engineers (USACE), flooding in the local area has 

many causes and contributing factors. Future projects will likely not completely solve this problem 

but may help to mitigate (reduce) damages under certain conditions. 

 

The James Campbell Expansion Act of 2005 did include a “finding” supporting the Act that, in 

addition to other identified management priorities, the purchase of new Refuge lands “is necessary 

to reduce flood damage following heavy rainfall to residences, businesses, and public buildings in 

the town of Kahuku.” The intent of the original language was to support projects that were being 

evaluated at that time by USACE as part of the Kahuku Watershed Feasibility Study. This study, 

completed in 2006, did not identify any comprehensive flood control or flood damage mitigation 

projects which would meet Federal cost/benefit requirements for USACE funding. Consequently, 

no flood damage reduction features were approved or funded as a result of this study. 

Due to low elevations throughout the coastal plain, including the Refuge, and the general longterm nature of drainage and flood damage reduction projects, future proposed projects will need to 

incorporate and evaluate the effects of global climate change and associated sea level rise (SLR). 

As of the date of this Plan the most recent scientific models predict a SLR of approximately 1 foot 

by the year 2050 along the Hawaiian coastlines. In addition, although average annual rainfall 

totals for Hawai‘i are expected to decline due to climate change, individual severe storm events 

with increased local rainfall totals are expected to increase. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

2-30 Chapter 2. Refuge Management Direction 

The proposed Walkerville Unit may be a suitable location for potential flood damage reduction 

projects because of its proximity to Kahuku and major drainage ditches; its relatively low-lying 

elevation; and its lower overall potential wildlife value compared to other Refuge expansion lands. 

This parcel is comprised primarily of former agricultural lands that have been idle for several 

years. As a result, much of the area is heavily encroached by woody pest vegetation which can 

hamper the flow of floodwater. Planned disking and mowing will prevent further encroachment 

and can be seasonally timed to provide short vegetation or open ground which can benefit some 

species of endangered or migratory birds. 

This designation of the Walkerville Unit for flood damage reduction project(s) is intended only as 

an interim measure until final decisions regarding such projects are made. Other adjoining Refuge 

expansion lands (primarily makai) may also be considered in future flood damage reduction 

projects and are not excluded. 

The Refuge will continue to participate and cooperate in community and agency efforts to address 

flood damage reduction for the local area. Any future proposed projects which would involve 

and/or impact Refuge lands would be subject to full engineering, environmental, regulatory review 

and compliance by the Service and other responsible agencies. We will continue to evaluate our 

infrastructure on the Refuge, particularly on newly acquired lands, to determine if further changes 

can be made to help mitigate flood damages. 

[As of September 2011, the parcel of land containing the proposed Walkerville Unit has not been 

acquired by the Service.] 
Kamehameha

Highway

P a c i f i c

O c e a n

Kahuku Village

Marconi

Road

APPROVED

REFUGE

BOUNDARY

157°57'0"W

157°57'0"W

157°58'0"W

157°58'0"W

157°59'0"W

157°59'0"W

21°42'0"N

21°42'0"N

21°41'0"N

21°41'0"N

James Campbell NWR

Habitat Management

0 250 500

Meters

0 1,000 2,000

Feet

UTM 4

NAD 83

O ' A H U

Map

Extent

P a c i f i c O c e a n

8-29-11; 10-053-20.MXD

Intensively Managed 

Wetland - see Figure 2-1a

for details.

Ae'o, 'Alae ke'oke'o, & 'Alae'ula 

Loafing & Foraging - Dikes

'Alae ke'oke'o & 'Alae'ula 

Life History

Restore Altered Wetlands

for Water & Migratory Birds

Restore, Protect, Manage 

Coastal Strand & Dunes

Improve Seabird Nesting on 

Kahuku WWII Runway

Restore Schrub / Shrub

Support Flood Damage 

Reduction Efforts

(Walkerville Unit)

Aquaculture Leases

James Campbell National Wildlife Refuge Comprehensive Conservation Plan Chapter 2. Refuge Management Direction 2-31
2-32 Chapter 2. Refuge Management Direction
Kamehameha

Highway

P a c i f i c 

O c e a n

157°57'0"W

157°57'0"W

157°57'30"W

157°57'30"W

21°41'30"N

21°41'30"N

21°41'0"N

21°41'0"N

James Campbell NWR

Habitat Management

Ki'i Unit

Ae'o Loafing & Foraging

Ae'o, 'Alae ke'oke'o, & 'Alae'ula

Loafing & Foraging - Dikes

'Alae ke'oke'o & 'Alae'ula

Loafing & Foraging

'Alae ke'oke'o & 'Alae'ula

Breeding

Ae'o Breeding

Approved Acquisition

Boundary

Intensively Managed 

Wetland Boundary

0 100 200

Meters

0 400 800

Feet

UTM 4

NAD 83

O ' A H U

Map 

Extent

P a c i f i c O c e a n

James Campbell

NWR

P a c i f i c O c e a n

8-29-11; 10-053-19.MXD

Note: 

Location of habitat types depicted

on map can vary seasonally.

James Campbell National Wildlife Refuge Comprehensive Conservation Plan Chapter 2. Refuge Management Direction 2-33
2-34 Chapter 2. Refuge Management Direction
 James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 3. Physical Environment 3-1 

Chapter 3. Physical Environment 

3.1 Refuge Introduction 

The O‘ahu National Wildlife Refuge Complex (Complex) is located on the Island of O‘ahu, within 

the State of Hawai‘i. The Complex consists of James Campbell NWR, Pearl Harbor NWR, and 

O‘ahu Forest NWR. Management of the Complex is conducted from the Service office located in 

Hale‘iwa on the north shore of O‘ahu . This CCP focuses on the James Campbell NWR. 

James Campbell NWR is located on the northeastern coast of O‘ahu near the community of Kahuku. 

As of September 2011, the Service owns 934 acres of habitat, including permanent, seasonal, and 

ephemeral wetlands, shrublands, coastal strand, sand dunes, and aquaculture ponds under lease from 

the Service. An additional 151 acres are in the process of acquisition within the approved boundary. 

3.2 Climate 

Located 2,400 miles southwest of the nearest continental landmass, the Hawaiian Islands are the 

most isolated archipelago in the world. The climate of Hawai‘i is generally constant throughout the 

year, with only minor periods of diurnal and seasonal variability. During the summer season (MaySeptember), temperatures are slightly warmer, conditions are drier, and trade winds originate from 

the northeast. The winter season (October-April) is characterized by cooler temperatures, higher 

precipitation, and gustier winds. The trade winds also produce differences within the two 

physiographic provinces. On the windward or northeastern side of O‘ahu, climatic conditions are 

relatively wet and strongly influenced by patterns of orographic rainfall. The leeward areas in the 

southern and western portion of the island experience decreased winds, less rain, and are subject to 

southerly Kona storms (Juvik and Juvik 1998). 

O‘ahu climate is influenced by three interacting climatic factors: (1) the Hadley cell, (2) the oceanic 

position of the major Hawaiian Islands, and (3) topography. The Hadley cell is a system of 

atmospheric circulation that is propelled by warm air rising near the equator and cool sinking air in 

the subtropics. In the Northern Hemisphere, air flowing within this system is reflected by the Earth’s 

rotation to create northeasterly winds referred to as trade winds. Wind patterns, rainfall distribution, 

and other climatic conditions are also affected by the geographic location of Hawai‘i (Juvik and 

Juvik 1998, Lau and Mink 2006). 

Trade winds in Hawai‘i originate from a high-pressure system located northeast of the archipelago 

called the North Pacific anticyclone. During the summer season, this system is stable and trade winds 

occur 80-95 percent of the time (Oki 2005). This high-pressure cell further regulates Hawai‘i’s 

climate because it shifts seasonally, causing trade wind and precipitation differences. During the 

winter and spring season, the North Pacific anticyclone moves further south and weakens, causing 

less persistent trade winds (50-80 percent of the time) and a greater chance of storms (Lau and Mink 

2006). 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

3-2 Chapter 3. Physical Environment 

Furthermore, the varied topography of the island affects the climate. The alignment, shape, and 

height of the mountains moderate wind patterns and cause moist air to rise near the mountain ranges. 

Excess clouds accumulate near mountain peaks and enhance precipitation amounts, referred to as 

orographic rainfall (Juvik and Juvik 1998, Lau and Mink 2006). The coastal, leeward sides of the 

mountains receive less precipitation because the air loses moisture as it ascends the windward side 

(Oki 2005). 

Prevailing ocean currents influence weather patterns by moderating the surrounding surface air 

temperatures (as a result of differential heat adsorption and advection of heat). Ocean currents around 

the Hawaiian Islands are moderated by the North Pacific anticyclone, a clockwise gyre that extends 

from the tropics to the North Pacific. The east to west flowing North Equatorial Current splits at the 

Island of Hawai‘i, creating a northern branch current that is 65 miles wide. Ocean surface water 

temperatures surrounding O‘ahu range from a mean of 75°F from February-April, to about 81°F 

between August-October (Juvik and Juvik 1998, Lau and Mink 2006). 

Located near the community of Kahuku, the Refuge has a climate characteristic of lowland areas on 

the windward side of O‘ahu. Annual temperatures on the Refuge range from 68.9-80.8°F. Annual 

precipitation in James Campbell NWR is between 26-28 inches. Evaporation rates in the area are 

dependent on cloud cover and rainfall (Hunt and De Carlo 2000, DBEDT 2007). 

Due to its location on the northern tip of O‘ahu, Kahuku is considered a high wind energy site. Wind 

speed ranges from 14.5-16.8 mph, with increasing speed on the northern portion of the Refuge. The 

prevailing northeasterly trade winds are present nearly 90 percent of the year in Kahuku and the 

southerly Kona winds are present approximately 10 percent of the year. On the northern coast of 

O‘ahu, the average humidity is roughly 74.6 percent, with slight seasonal variation (Group 70 

Limited 1989, HECO 2004, Lau and Mink 2006). 

 

Kahuku Wind turbines generate power adjacent to Refuge George Fisher/USFWS
 James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 3. Physical Environment 3-3 

3.2.1 Global Climate Changes and Projections 

Global climate change is supported by a continuously growing body of unequivocal scientific 

evidence. The Intergovernmental Panel on Climate Change (IPCC) is a scientific intergovernmental 

body organized by the World Meteorological Organization and the United Nations Environment 

Programme in order to assess the causes, impacts, and response strategies to changes in climatic 

conditions. According to the Fourth Assessment Report by the IPCC, global temperatures on the 

Earth’s surface have increased by 1.33°F over the last 100 years. This warming trend has accelerated 

within the last 50 years, increasing by 0.23°F each decade. Global ocean temperatures to a depth of 

almost 2,300 feet have also increased, rising by 0.18°F between 1961-2003 (Solomon et al. 2007). 

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

U.S. government agency Overseas Private Investment Corporation (OPIC) suggests that a further 

increase in greenhouse gas (GHG) emissions could double atmospheric concentrations of CO2 by 

2060 and subsequently increase temperatures by as much as 2-6.5°F over the next century. Recent 

model experiments by the IPCC 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 

(SLR) 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. Recent modeling projects sea level to rise 

0.59-1.93 feet by the end of the 21st century. These changes may lead to more severe weather, shifts 

in ocean circulation (currents, upwelling), as well as adverse impacts to economies and human 

health. The extent and ultimate impact these changes will have on Earth’s environment remains 

under considerable debate (OPIC 2000, Buddemeier et al. 2004, Solomon et al. 2007, IPCC 2007). 

3.2.2 Climate Change in Hawai‘i 

Small island groups are particularly vulnerable to climate change. The following characteristics 

contribute to this vulnerability: (1) small emergent land area compared to the large expanses of 

surrounding ocean; (2) limited natural resources; high susceptibility to natural disasters; and (3) 

inadequate funds to mitigate impacts (IPCC 2001). Thus, Hawai‘i is considered to have a limited 

capacity to adapt to future climate changes. The Pacific Islands Regional Integrated Science and 

Assessment is working to develop programs dealing with climate risk management in the Pacific 

region. The Service is supporting the development of regional Landscape Conservation Cooperatives 

that will integrate local climate models with models of climate-change responses by species, habitats, 

and ecosystems. The regional version of these Landscape Conservation Cooperatives is the Pacific 

Islands Climate Change Cooperative (PICCC), headquartered in Honolulu, Hawai‘i, but working 

across the Pacific. The PICCC was established in 2010 to assist those who manage native species, 

island ecosystems, and key cultural resources in adapting their management to climate change for the 

continuing benefit of the people of the Pacific Islands. The PICCC steering committee consists of 

more than 25 Federal, State, private, indigenous, nongovernmental conservation organizations, and 

academic institutions, forming a cooperative partnership that determines the overall organizational 

vision, mission, and goals (IPCC 2007). 

 

Similar to the rest of the world, temperatures in Hawai‘i are rising. The EPA has estimated that the 

average surface temperature in Honolulu, Hawai‘i has increased by 4.4°F over the last century. In 

particular, nighttime temperatures are notably warmer, increasing by about 0.5°F per decade over the 

past 30 years. Recent studies have shown that this rising average night temperature is greater at high 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

3-4 Chapter 3. Physical Environment 

elevation sites than lower areas. Sea surface temperature near the islands has been increasing 

recently, showing a 0.72°F rise between 1957-1987. Sea level around the Hawaiian Islands is rising 

by 6-14 inches per century. Over the last 90 years, precipitation has also decreased approximately 

20 percent (EPA 1998, Arakawa 2008, Giambelluca 2008). 

As a result of these shifts, Hawai‘i is developing means to reduce its GHG emissions. In 1990, it is 

estimated that 15,985,225 tons of CO2 were emitted in Hawai‘i. Other major GHG released that year 

include 75,736 tons of methane (CH4) and 690 tons of nitrous oxide (N2O). These estimates do not 

include fuels that were exported, used on international aircraft or ship operations, or used by the 

military in the State. International, military, and overseas CO2 emissions were estimated to be 

7,363,261 tons in 1990 (DBEDT and DOH 1999). In 2007, the State of Hawai‘i enacted Act 234, 

which sets the goal to reduce GHG emissions to 1990 levels by 2020. 

Global and regional predictive climate simulations may not capture unique and important features of 

the Hawaiian climate. Existing large-scale models show large variability and uncertainty for the 

Hawaiian Islands; thus, applying these models to predict local conditions must be done with caution 

until more fine-scaled models are developed. Models from the IPCC and United Kingdom Hadley 

Centre’s climate model suggested that by 2100 annual temperatures in Hawai‘i could increase by 

3°F, with a slightly higher increase in fall. Other estimates predict a 5-9°F rise by the end of the 21st

century. Future changes in precipitation are uncertain, dependent largely on shifts in El Niño/La Niña 

events. Some predictions forecast an additional rise of 17-25 inches by 2100, while others suggested 

decreased precipitation (TenBruggencate 2007, Timm 2008). 

Projected impacts that may have a significant effect on the coastal national wildlife refuges on O‘ahu 

are discussed below. 

3.2.3 Sea Level Rise 

According to the IPCC, the oceans are now absorbing more than 80 percent of the heat added to the 

Earth’s climate system. Since 1961, this absorption has caused average global ocean temperatures to 

increase and seawater to expand. Thermal expansion of the sea is the primary cause of global sea 

level changes. Melting ice-sheets, ice caps, and alpine glaciers also influence ocean levels. 

Worldwide, sea level changes have historically occurred on a small scale; however, scientific 

evidence suggests that the current, accelerated rate of global change began between the mid-1800s 

and 1900s. Similarly, sea levels in the Pacific have regularly changed over the centuries due to 

variations in solar radiation. Since 1800, sea levels in the Pacific region have been rising. During the 

last century, these levels have risen about 6 inches and this is likely to rapidly increase in the next 

century (Noye and Grzechnik 2001, GAO 2007). 

 

Due to localized geographic and oceanographic variations, it is not possible to discuss SLR on a 

global scale. Near Pacific Island ecosystems, SLR is influenced by the rate and extent of global sea 

level rise, as well as changes in episodic events, such as the El Niño Southern Oscillation and stormrelated conditions. Topography and exposure to normal and storm swell produce localized 

differences. Furthermore, it is important to note that shoreline sea levels are historically and currently 

influenced by isostatic tectonic changes as the islands move with the Pacific Plate, which are not due 

to global changes in sea level. Thus, sea level change in the Pacific is highly variable due to geologic 

uplift (Michener et al. 1997, Carter et al 2001). 
 James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 3. Physical Environment 3-5 

Hawai‘i’s sea level appears to be rising at a slower rate than the global seas. Based on tide gauge 

records at the Honolulu Harbor, the sea level surrounding O‘ahu has risen at a rate of 0.0551 inches 

per year. Geological uplift contributes about 0.0016 inches per year. The University of Hawai‘i Sea 

Level Center has estimated that from 1905-2006 mean sea level rose about 0.0417 inches per year. 

Although most of this rise is due to isostatic sinking of the tectonic plate, global-warming induced 

SLR has the potential to intensify this rise. As of the date of this CCP, the most recent scientific 

models predict a SLR of approximately 1 foot by the year 2050 along the Hawaiian coastlines. In 

addition, although average annual rainfall totals for Hawai‘i are expected to decline due to climate 

change, individual severe storm events with increased local rainfall totals are expected to increase 

 (Nakiboglu et al. 1983, Caccamise et al. 2005, Fletcher pers. comm.). 

In an effort to address the potential effects of SLR on national wildlife refuges, the Service 

contracted the application of the Sea Level Affects Marshes Model (SLAMM) 6 for several Pacific 

Region refuges. This analysis is designed to assist in development of long-term management plans. 

The SLAMM model predictions for James Campbell NWR suggest that inland inundation within this 

Refuge will occur given SLR scenarios of approximately 1.6 feet (eustatic) and beyond. There are 

two major channels through which saline inundation will occur; Bakahan ditch at the northeast of the 

site and Ki‘i Outlet channel in the region of the Refuge’s pumphouse. 

Model results suggest that much of the coastal dune area could become inundated in higher SLR 

scenarios. These inundated areas include the Kahuku Airstrip and areas south and east of the strip. 

Unlike the rest of the coast, inundated zones near the airstrip are not protected by high dunes. There 

does remain some uncertainty as to land disposition after flooding. The SLAMM assumes that land 

close to the ocean will convert to beach and inland regions will convert to transitional salt marshes, 

salt marshes, and mudflats. All of these predictions are estimated 50-100 years in the future, well 

beyond the scope of this CCP. 

There is always uncertainty about how regularly flooded wetlands will respond to the signal of 

increased SLR. The most important effects of SLR at the James Campbell NWR are the gradual 

inundation and flooding of historic wetlands and dryland areas, as well as increases in the salinity of 

wetlands. Salinity alterations have the potential to shift aquatic plants and animal communities that 

do not tolerate high salinity. Higher sea levels may inundate these low-lying land areas, potentially 

helping Refuge personnel to reclaim/restore former wetland areas for endangered waterbirds. 

A new study funded by the PICCC is currently underway which will produce the most up-to-date 

high-resolution maps depicting projected SLR impacts on James Campbell NWR. This study should 

be completed in 2012. 

3.2.4 Climate Change Effects on Water Resources 

The impact of climate change on water resources is dependent on shifts in precipitation amounts, 

evaporation rates, storms, and events such as the El Niño Southern Oscillation (ENSO). This is an 

ocean-atmosphere phenomenon in which the normal oceanic and atmospheric circulation patterns of 

the Pacific Ocean temporarily collapse. During normal years, strong trade winds move 

counterclockwise in the southern hemisphere and clockwise in the northern hemisphere, causing 

surface water to move westward. These winds also produce upwelling that brings high nutrient 

waters to the surface. During ENSO, trade winds in the western Pacific stop and the warm mass of 

water in the west moves eastward, causing shifts in the location of evaporation. As a result, heavy 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

3-6 Chapter 3. Physical Environment 

rains occur in normally dry areas such as the central Pacific islands. In addition to more precipitation, 

these winds bring upwelling of warm water, which is devoid of nutrients. This causes productive 

communities to collapse and subsequent death of fish and birds. 

While ENSO events have increased in intensity and frequency over the past decades, some longerterm records have not found a direct link to global warming and do not predict significant changes in 

ENSO; however, a majority of climate forecasts do suggest an evolution toward more “El Niño-like” 

patterns. Most climate projections reveal that this trend is likely to increase rapidly in the next 50 

years. However, other models predict more “La Niña-like” conditions in the Hawaiian Islands 

(Walther et al. 2002, Buddemeier et al. 2004, Timm 2008). 

A trend toward ENSO patterns will impact sea levels, sea temperatures, rainfall amounts, evaporation 

rates, and the occurrence of hurricanes; however, the exact impact of climate change on water 

resources is difficult to predict due to spatial variability. On a global scale, mean precipitation is 

anticipated to increase. Current climate models project that tropical Pacific and high latitude areas 

will experience increasing precipitation amounts, while precipitation is likely to decrease in most 

subtropical regions. A current trend toward this increase is supported by lowered salinity levels in 

both the mid- and high-latitude oceanic waters. If the opposite effect takes place, decreasing 

precipitation or increasing evaporation will further stress meager surface and groundwater resources. 

Lack of rain could lower the amount of freshwater lens recharge and decrease available water 

supplies. Reduced rainfall or increased evaporation will cause a corresponding increase in the 

demand for residential, commercial, or agricultural water (Giambelluca et al. 1996, Solomon et al. 

2007, Parry et al. 2007). 

 

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

accompany more frequent tropical typhoons/cyclones and increased tropical sea surface temperatures 

in the next 50 years. The Third Assessment of the IPCC (2001) has concluded with “intermediate 

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 (McCarthy et al. 2001). One 

model projects a doubling of the frequency of 4 inches per day rainfall events and a 15-18 percent 

increase in rainfall intensity over large areas of the Pacific. Solomon et al. (2007) states that it is 

“more likely than not” that the rise in intense tropical cyclones is due to anthropogenic activity 

(Walther et al. 2002, Solomon et al. 2007). 

An increase in heavy storms and surf will result in increased flood risks, sedimentation, and impeded 

drainage in Hawai‘i. In particular, the low-elevation Refuge units will be vulnerable to changes in 

storm frequency, intensity, and directionality. These events have the potential to denude vegetation 

or affect the biogeochemistry of the wetlands (DBEDT and DOH 1999). 

3.2.5 Ecological Responses to Climate Change 

Evidence suggests that recent climatic changes have affected a broad range of individual species and 

populations in both the marine and terrestrial environment. Organisms have responded by changes in 

phenology (timing of seasonal activities) and physiology; range and distribution; community 

composition and interaction; and ecosystem structure and dynamics. The reproductive physiology 

and population dynamics of amphibians and reptiles are highly influenced by environmental 

conditions such as temperature and humidity. For example, sea turtle sex is determined by the 

temperature of the nest environment; thus, higher temperatures could result in a higher female to 
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Chapter 3. Physical Environment 3-7 

male ratio. In addition, increases in atmospheric temperatures during seabird nesting seasons will 

also have an effect on seabirds and water birds (Duffy 1993, Walther et al. 2002, Baker et al. 2006). 

Changes in ocean temperature, circulation, and storm surge due to climate change will impact seabird 

breeding and foraging. The ENSO has been shown to cause seabirds to abandon habitats, nest sites, 

and foraging areas for colder/warmer waters. Studies have found that nesting success is reduced for 

some species during this climatic event. Oceanographic changes associated with ENSO may also 

increase or decrease food supply for seabirds and subsequently impact populations that forage 

offshore. Shifts in marine temperature, salinity, turbidity, currents, depth, and nutrients will have an 

impact on seabird and water bird prey composition and availability. Although these potential changes 

may impact seabirds throughout the Hawaiian Islands, contrary evidence suggests that seabirds may 

have coped with and evolved around climatic changes in the past (Duffy 1993). 

Warming has also caused species to shift toward the poles or higher altitudes and changes in climatic 

conditions can alter community composition. For example, increases in nitrogen availability can 

favor those plant species that respond to nitrogen rises. Similarly, increases in CO2 levels can impact 

plant photosynthetic rates, decrease nutrient levels, and lower herbivore weights. Although there is 

uncertainty regarding these trajectories, it is probable that there will be ecological consequences 

(Vitousek 1994, Walther et al. 2002, Ehleringer et al. 2002). 

Climate change has the potential to influence two important ecological issues in the State of Hawai‘i: 

endangered species and pest species. The majority of U.S. endangered species are found in the State 

of Hawai‘i. Species declines have resulted from habitat loss, introduced diseases, and impacts from 

pest species. Changes in climate will add an additional threat to the survival of these species as 

warmer night temperatures can increase the rate of respiration for native vegetation, resulting in 

greater competition from pest plants. Furthermore, climate change may enhance existing pest species 

issues because alterations in the environment may increase the dispersal ability of flora or fauna. 

Species response to climate change will depend on the life-history, distribution, dispersal ability, and 

reproduction requirements of the species (DBEDT and DOH 1998, Middleton 2006, Giambelluca 

2008). 

3.3 Geology and Soils 

The Hawaiian Islands were formed by a series of volcanic eruptions that occurred at hotspots beneath 

the Earth’s crust. As the tectonic plate slowly drifted, magma welled up from fixed spots creating a 

linear chain of islands. O‘ahu is the third-largest island in the chain with a total land area of 

597.1 square miles. The island is mostly composed of the heavily eroded remnants of two large 

Pliocene shield volcanoes that broke the surface of the Pacific Ocean at different times and continued 

building to eventually form a single island. The western Wai‘anae volcano is approximately 2.7-

3.4 million years old. It consists of shield lavas overlain by a thick sequence of post-shield alkalic 

basalt. The Ko‘olau Volcano on the east formed about 2.2-2.5 million years ago and is comprised of 

shield lavas (Ko‘olau Basalt) as well as rejuvenated stages, termed the Honolulu Volcanics. The sea 

level around O‘ahu has repeatedly fluctuated during various glacial epochs. During a period of higher 

sea level, a coral reef platform developed around the perimeter of the island. This platform currently 

makes up the island’s shoreline (Juvik and Juvik 1998). 
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Soils on O‘ahu were classified by the U.S. Department of Agriculture (USDA) Soil Conservation 

Service. Soils and sediments on low-lying areas of O‘ahu have been influenced primarily by periods 

of changing sea levels and human modifications (Juvik and Juvik 1998). 

The Kahuku area of O‘ahu has a complex geological history. Eroded shield volcanoes, such as the 

Ko‘olau Volcano, typically have dike complexes of basaltic material associated with active rift 

zones. These massive sheets of rock extend vertically into the lava flows, inhibiting normal 

groundwater flow. The Kahuku coastal plain is underlain by marine sediments and basaltic alluvium 

that has eroded from the Ko‘olau Mountains. Two alluvial fans, or fan shaped deposits, unfold on the 

coastal plain near the Refuge as a result of stream deposition (Hunt 1996, Hunt and De Carlo 2000). 

The ponds at the Punamanō and Ki‘i Units are underlain with black, organic-rich mud that is several 

feet thick (Hunt and De Carlo 2000). According to the Soil Conservation Service, the following soil 

classifications are found within the Refuge: 

Jaucas sand, 0-15 percent slopes (JaC): This sandy soil is single grain, pale brown to very pale 

brown, with a depth of more than 30 inches. Due to the accumulation of organic matter and alluvium, 

the surface layer may be dark brown. Narrow strips of beaches, as well as Pūlehu, Mokulē‘ia, and 

Kea‘au soils may also be present. The soil is neutral to moderately alkaline and in general the slope 

does not exceed 7 percent. Jaucas sand has rapid permeability and runoff is very slow to slow. 

Because the soil is loose, wind erosion is a severe hazard in areas without vegetation. Water erosion 

is considered a slight hazard (Foote et al. 1972). 

Kea‘au clay, saline, 0-2 percent slopes (KmbA): Found on the coastal plains of O‘ahu, this soil 

occurs in depressions near the ocean or in limestone pockets. The surface layer is very dark grayishbrown clay with a platy or vesicular structure. The subsoil is very dark grayish-brown and darkbrown, mottled clay. This soil is unique in the Kea‘au series because it is strongly affected by salts. 

Areas underlain by Kea‘au clay are often drained or filled for various uses (Foote et al. 1972). 

Fill land (Fd): This classification includes areas filled with bagasse and slurry from sugar mills, as 

well as material from dredging and soil excavations (Foote et al. 1972). 

Waialua silty clay (WkA): Characteristics of this soil type are: moderate permeability; slow runoff; 

slight erosion hazard; roots penetrate to a depth of 5 feet or more in places; surface soils are 

12 inches thick, subsoil about 26 inches thick; shrink-swell potential is moderate (Foot et al. 1972). 

Kaloko clay, noncalcareous variant (Kfb): The noncalcareous variant of the Kaloko series occurs in 

slight depressions on the coastal plains of O‘ahu. More acidic and grayer than the other soils in the 

Kaloko series, this soil is underlain by noncalcareous material. The surface layer is very dark gray 

clay, while the subsoil is gray or grayish-brown prismatic clay. The substratum is massive clay and 

silty clay. Small areas of very deep, well-drained alluvial soils were also identified in drainage ways. 

The permeability of this soil is ranked as slow, runoff is very slow, and the erosion hazard is none to 

slight (Foote et al. 1972). 

Coral outcrop (CR): Coral outcrop, which is comprised of coral or cemented calcareous sand, can be 

found on O‘ahu between 0-100 feet in elevation. It is geographically associated with Jaucas, Kea‘au, 

and Mokulē‘ia soils. Within the cracks, crevices, and depressions of the coral outcrop, a thin layer of 
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friable, red soil material can be found. Sparse vegetation typically grows in coral outcrop (Foote et al. 

1972). 

Beaches (BS): This land type consists of light-colored sands derived from coral and seashells (Foote 

et al. 1972). 

3.4 Hydrology 

The hydrologic processes that occur in the Hawaiian Islands are unique compared to continental 

landmasses or temperate zones. Drainage basins are typically small and streams are characterized by 

steep longitudinal profiles and numerous waterfalls. The Island of O‘ahu has 57 perennial streams. 

Stream flow depends on the climatic and geological features of the area. For example, some streams 

on O‘ahu have lengthy dry reaches under natural conditions due to permeable underlying rock. O‘ahu 

also has a vast amount of groundwater, which supplies most of the domestic water supply (Lau and 

Mink 2006). 

The combination of intense storms, steep terrain, and urban land uses causes flooding in certain areas 

of O‘ahu. The Flood Insurance Rate Maps prepared by the Federal Emergency Management 

Agency’s National Flood Insurance Program depict flood hazard areas throughout the State. The 

maps classify land within the Refuge boundary into four zones depending on the expectation of flood 

inundation (Figure 3-4). 

The Kahuku basin, which drains approximately 7.6 square miles, ranges in elevation from 0-1,800 

feet on the northern slopes of the Ko‘olau Mountains. This basin also includes a 3.2-square mile lowlying coastal floodplain. Streams in the Kahuku area are typically short and steep, causing periods of 

high peak floods. ‘Ōhi‘a, Kalaeokahipa, and Ho‘olapa are intermittent streams in the Kahuku area 

(Smith, Young & Assoc. 1990, Hunt and De Carlo 2000). 

Groundwater in the Kahuku area primarily occurs as a basal freshwater lens in the dike-free Ko‘olau 

Basalt and overlying unconsolidated and consolidated sedimentary deposits. This aquifer extends 

from Punalu‘u Valley to Kahuku Point. Groundwater levels in the region vary between 7-20 feet 

above mean sea level, with lower levels near the shore. Regionally, groundwater moves from the 

volcanic-rock aquifers into the overlying sedimentary deposits and eventually discharges to the 

ocean. Flow to the ocean is estimated from 2-4 million gallons per day (mgd) per mile of shoreline, 

depending on rock permeability. Mean annual groundwater recharge due to rainfall infiltration is 

approximately 3.8 mgd. Additional recharge occurs as a result of inflow from the adjacent dike 

complex. Historically, aquifers were heavily developed for agriculture in this region; however, when 

sugarcane cultivation ceased in 1971, estimated water use declined significantly (Mink 1982, Smith, 

Young & Assoc. 1990, Miller et al. 1999). 

Naturally occurring wetlands are situated along the coastal Kahuku plain. The Ki‘i Unit of the 

Refuge is a remnant of a formerly larger marsh that has been drastically modified by agriculture. In 

1976, the Service began to supply the assemblage of ponds with water from adjacent ditches and 

artesian wells. There are a total of seven ponds (identified as Ponds A-G) within the Ki‘i Unit, which 

are separated from each other by earthen berms or levees (Figure 3.5). Pond water levels generally 

average between 3-4.5 feet. The most seaward ponds (Ponds A and E) typically maintain lower water 
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3-10 Chapter 3. Physical Environment 

levels, between 1.5-3 feet. Water levels in the adjacent ditch system are lower than the pond levels, 

averaging 2 feet. The pH levels range between 6.95-8.15 (Hunt and De Carlo 2000). According to 

Hunt and De Carlo, the drainage area for the Ki‘i Unit is approximately 3.87 square miles. These 

subwatershed areas, in decreasing size, include ‘Ōhi’a Ai Gulch, Kalaeokahipa Gulch, Hospital ditch, 

and runoff from a residential subdivision. 

Ground water inflows do not substantially contribute to the ponds; rather, the primary water source 

for the ponds is a single 12-inch artesian well that is connected to a 12-inch distribution system. 

Since 2001, the average water temperature and salinity of the water in the well has been 72.5°F and 

0.41 ppt, respectively. Pipelines feed water into ponds G, F, C, and B. Subsequently, water is fed to 

ponds D and A through control structures in ponds F and B, respectively. Pond E is not supplied by 

water from the well, but is fed by control structures connected to the ditches. Direct rainfall 

supplements water provided by the well. During periods of heavy precipitation, control values are 

manually adjusted to regulate the amount of water distributed into each pond. The well is turned off 

during excessively high rain periods to prevent flooding. The Refuge is currently allotted 1 mgd. 

Prior to July 2004, the Refuge utilized 3 artesian wells of 3-inch diameter, which piped water into the 

7 impoundments. Use has ceased, but the wells remain onsite. 

An abandoned ditch system drains the seaward Kahuku coastal plain. Within the Ki‘i Unit, several 

ditches can be found including the Hospital ditch, the Punamanō ditch, the Ki‘i ditch, and the Raboy 

ditch. An outlet ditch then discharges this water to the ocean. Five of the seven ponds dump into the 

ditch system. Water from the adjacent ditch systems is not used as a supplemental water source for 

the ponds due to concern of contamination on upland properties. 

In contrast to the Ki‘i Unit, the Punamanō Unit of the Refuge is naturally fed by rainfall, runoff, 

springs and groundwater seepage. Water flows from the marsh into Punamanō ditch and continues 

easterly. Currently, the unit consists of a north and south pond that are intermittently connected. The 

north pond has a water level of 2.5 feet above sea level. The temperature in the north pond is 

measured at 74.7°F, which is colder than ponds located further south. This suggests water may be 

coming from a separate, local source derived from the Ko‘olau Mountains or it may be caused by 

evaporative cooling. The drainage area of the Punamanō Unit is 0.42 square miles (Hunt and De 

Carlo 2000). 
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 Figure 3.1. Historic Land Divisions 
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This page was left blank to maintain the readability of our map. 

 
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Figure 3.2. Refuge Land Status & Boundary 
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This page was left blank to maintain the readability of our map. 

 
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Figure 3.3. Soil Series 
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This page was left blank to maintain the readability of our map. 
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Figure 3.4. Flood Hazard Zones 
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This page was left blank to maintain the readability of our map. 

 
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Figure 3.5. Hydrologic features of the Ki‘i Unit, James Campbell NWR. 

Source: Hunt and De Carlo (2000). 

3.5 Topography/Bathymetry 

The interior portions of O‘ahu gradually slope inward to a broad central valley. In contrast, the outer 

seaward slopes are tall and steep as a result of erosion from wind, rain, and sea. Bathymetric 

mapping reveals that giant landslides and the associated slope failures are a significant component to 

the erosional history of the island. The coastal region of Kahuku is comprised of low coastal terraces 

less than 10 feet above sea level. The topography of the Refuge is nearly flat except for higher 

elevation dunes that lie seaward of the coastal terraces, inhibiting surface water flow to the ocean and 

causing ponding in the interior portions (Moore 1964, Polhemus 2007). 

 

Lithified outcrops of eolianite along Kahuku Point and Makahoa Point create a sharp and jagged 

surface that makes access to the windward shoreline difficult. Extensive ridges of beach rock on the 

foreshore are found along the entire area. Along the windward coast, limestone outcrops and offshore 

islets can be found. Offshore fringing reefs are more extensive east of Kahuku Point due to the 

decreased wave energy compared to the northern coastline (Fletcher et al 2002). 
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3.6 Environmental Contaminants 

The Agency for Toxic Substances and Disease Registry defines a contaminant as “a substance that is 

either present in an environment where it does not belong or is present at levels that might cause 

harmful (adverse) health effects.” Contaminants commonly include pesticides and pesticide residues, 

industrial chemicals, fertilizers, metals, and other toxic substances. By altering biological or physical 

processes, contaminants may produce adverse effects to an ecosystem. 

Contaminants are an important consideration of refuge management because wetlands depend on a 

constant supply of water for their maintenance. The quality of the habitat for the birds to be protected 

depends to a great extent on the quality of the water. Concern with the quality of surface and ground 

water has been the focus of extensive monitoring and study on O‘ahu for many years. 

A Level II Contaminant Survey of sediments and tissues conducted in 1991 by the Service and a 

groundwater sampling conducted by the City of Honolulu in 1996 reported no contaminants at the 

Punamanō and Ki‘i units. However, a Ki‘i surface water sample by the University of Hawai‘i 

revealed high Polychlorinated biphenyls (PCBs) concentrations. A followup Level 1 Preacquisition 

Contaminant Survey was subsequently performed in 1998 to characterize the PCB contamination. 

These PCB detections were reported in 6 soil samples in a 20 by 50 feet area. This detection was due 

to a small, inadvertent spill of transformer oil that occurred in the late 1970s near the outlet channel. 

The PCB concentrations exceeded the ecological screening value of 0.023 parts per million (ppm), 

suggesting further evaluation and potential remediation. At that time, the Service determined that it 

was safer to leave the PCBs in place than attempt to remove the contaminated soil. Follow-up 

monitoring is recommended to ensure the decision to leave the contamination in place has no 

negative impacts to endangered species in the Refuge (Harding ESE 2001). 

Hunt and De Carlo (2000) conducted inorganic and organic chemical analysis by collecting water 

and sediment samples on the Refuge during a dry season (1994) and a wet season (1997). In 1994, 

water samples were collected from five sites and sediment samples from three sites in the Ki‘i Unit 

ponds. The 1997 survey consisted of water samples from the same five sites, as well as four 

additional water sample sites located on ditches and storm drains. 

No significant water contamination by heavy metals or other potentially toxic trace elements was 

found during these studies. Elevated arsenic concentrations were detected between the dry season 

and wet season surveys, possibly due to fertilizer or pesticide runoff from upstream agricultural 

areas. In addition, a sample collected from Ki‘i Pond C during the 1994 survey had a copper 

concentration of 8.2 micrograms per liter (μg/L), which exceeds the aquatic life chronic criteria (6.5 

μg/L) within the EPA ambient water-quality criteria. However, copper is naturally abundant in 

volcanic soils and consequently also occurs in higher concentrations in many sediments and waters. 

All other concentrations were comparable to heavy metal amounts found in nonimpact or low-impact 

areas throughout O‘ahu. Trace concentrations of several pesticides (including atrazine, simazine, 

chorpyrifos, diazinon, and trifluralin) were also detected in the water samples (Hunt and De Carlo 

2000). 

In the sediment samples, the organochlorine pesticide dichloro-diphenyl-trichloroethane (DDT) and 

its breakdown products dichloro-diphenyldichloro-ethylene (DDE) and dichloro-diphenyldichloroethane (DDD) were detected at or above the minimum reporting limit in surface samples of 
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Chapter 3. Physical Environment 3-21 

bottom sediment from Ponds C and D at the Ki‘i Unit, as well as in a sediment core taken at 

Punamanō north pond. Concentrations were not at a level that posed any ecological risk. Trace 

concentrations of ametryn were detected at Pond C at Ki‘i and at Punamanō. Trace concentrations of 

bromacil, carboxin, diphenamid, and simetryn were detected in at the Punamanō core, and a trace of 

propachlor was detected at Ki‘i Pond D. The volatile organic compound toluene was detected at pond 

C (Hunt and De Carlo 2000). 

The inorganic chemical survey results from the Ki‘i and Punamanō Units were compared with 

available sediment-quality guidelines for freshwater sediments. In the Ki‘i Unit, copper and zinc 

concentrations in sediments from Ponds C and D exceeded the guidelines. Sediments from the north 

pond at the Punamanō Unit exceeded copper concentration limits. However, as these are naturally 

abundant in Hawaiian volcanic soils and are similar to concentrations found in other areas of O‘ahu, 

the Service determined that no adverse biological effects would be associated with the contaminated 

sediment (Hunt and De Carlo 2000). 

3.7 Land Use 

The Administration Act identifies six priority wildlife-dependent visitor uses on refuges: hunting, 

fishing, wildlife observation and photography, and EE and interpretation. According to the Refuge 

Recreation Act of 1962, all recreational activities must be compatible with the primary purpose of the 

Refuge. Other laws or policies that may affect land use include: the Endangered Species Act of 

1973; the Clean Water Act (CWA) or Federal Water Pollution and Control Act; the Migratory Bird 

Treaty Act of 1918; Executive Order 11988 (Floodplain Management); Executive Order 11990 

(Protection of Wetlands), the Hawai‘i Coastal Zone Management Act of 1977 (Hawai‘i Revised 

Statutes, Chapter 205A); and the Master Plan for the Hawaiian Wetland NWR Complex (1983). 

Under the State Land Use Law (Act 187), Hawai‘i Revised Statute Chapter 205, all lands and waters 

in the State are classified into four districts: Agriculture, Rural, Conservation, and Urban. 

Conservation Districts are further divided into five subzones: Protective, Limited, Resource, 

General, and Special (Hawai‘i Administration Rules, Title 13, Chapter 5). Land use is also dictated 

by zoning ordinances from the City and County of Honolulu. 

The O‘ahu General Plan is a comprehensive document with objectives and policies to address the 

physical, social, economic, and environmental concerns affecting the City and County of Honolulu. 

Island planning is further divided into eight regional areas that are guided by Development Plans or 

Sustainable Communities Plans (DPP 2006). The James Campbell NWR is located next to the 

community of Kahuku, within the Ko‘olau Loa Sustainable Community Plan area. 

3.7.1 Historic Land Divisions 

The concept of private property was unknown to Native Hawaiians prior to Western contact, but they 

did follow a complex system of land division. All land was controlled by the highest ali‘i (chief or 

king) who held it in trust for the whole population. The ali‘i designated who supervised these lands 

based on their rank and standing. Each island was divided into several moku (units). O‘ahu was 

divided into six moku. Each moku was divided into smaller units known as ahupua‘a. Shaped by 
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island geography, each ahupua‘a was a wedge-shaped area of land running from the uplands to the 

sea, following the natural boundaries of the watershed. The Refuge is located within the Kahuku 

ahupua‘a (Figure 3.1). Each ahupua‘a contained the resources the human community needed, from 

fish and salt, to fertile land for farming taro or sweet potato, to koa and other trees growing in 

upslope areas. Each ahupua‘a was ruled by an ali‘i and administered by a konohiki (headman or 

landlord) (Kamehameha 2011). 

Stewardship of the land and its resources was formalized through the kapu system. The kapu, 

enforced by konohiki and kahuna (Hawaiian priest), placed restrictions on fishing certain species 

during specific seasons, on gathering and replacing certain plants, and on many aspects of social 

interaction as well. In this way, the community maintained a sustainable lifestyle (Kamehameha 

2011). 

The native landscape described in Land Commission testimonies (circa 1848) correlates with the 

verdant lush tropical landscape that was first witnessed by European explorers a half a century 

earlier. These conditions facilitated all phases of crop procurement for Native Hawaiians and 

provided rich marine resources, salt production capabilities, spring-fed marsh areas for taro, and 

suitable fish pond locations. Numerous testimonies attest to the rich hala groves within the general 

Kahuku plain. Coastal resources provided nearly all the necessary sustenance to establish coastal 

villages; while the adjacent steep hills, ridges, and lush upland regions of the Ko‘olau Range 

provided additional forested resources (Dougherty and Moniz-Nakamura 2005). 

3.7.2 Ranching 

The Mahele of 1848 changed land tenure in the Hawaiian Islands by defining land ownership and 

providing a legal course for land exchanges and purchases. A number of influential and powerful 

individuals were poised to secure large tracts of land through their close association with King 

Kamehameha III. These foreign investors were able to secure large tracts of lands awarded to either 

the king, konohiki, and to the government and people of Hawai‘i. Robert Moffitt, an Irish cattleman, 

secured large tracts of crown and konohiki lands along the northern point of O‘ahu and quickly 

transformed the landscape into pasturelands for ranching pursuits that included sheep flocks and 

cattle herds. The pasture lands extended along the coastal plain from the shoreline to the base of the 

Ko‘olau Range (Dougherty and Moniz-Nakamura 2005). 

In 1850-51, only 3 years after the Mahele, Englishman Charles Hopkins purchased over 8,000 acres 

of Hawaiian lands and founded Kahuku Ranch for cattle and sheep. Other Englishmen who acquired 

large tracts of Kahuku lands at this time included R.C. Wyllie and H.A. Widemann. By 1873, 

Kahuku Ranch was owned solely by H.A. Widemann. In 1874, Kahuku Ranch was renamed Kahuku 

and Mālaekahana Ranch, and was sold to Julius Richardson, and in 1876, Richardson sold the ranch 

to James Campbell (Wilcox 1975). 
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Chapter 3. Physical Environment 3-23 

Private First Class Angelo Reina 

guards a lonely beach position at 

Kahuku © Rosenberg, March 1945 

3.7.3 Sugar, Pineapples, and Trains 

A consortium of interests formed during the 

following decades. Development of islandwide 

transportation routes, ranches, land colonization, and 

sugar plantations coalesced, creating the conditions 

that facilitated rapid change within Kahuku. 

Benjamin Dillingham spearheaded efforts to 

construct rail lines to Kahuku to transport raw sugar 

to the wharves in Honolulu. In 1890, James 

Campbell leased his Kahuku Ranch lands to 

Dillingham for 50 years, who then subleased these 

lands and the water rights to James Castle. The 

Kahuku Plantation Company, incorporated in 1890 

through the partnership of James Castle and 

Alexander Young, planted 2,800 acres of cane and 

produced their first harvest in 1892. The crops were hauled to the Kahuku mill and from there were 

transported to the landing where the cane was shipped to Honolulu (Kuykendall 1967, Wilcox 1975). 

The railway reached Kahuku in 1899 and remained in operation for 58 years. The Kahuku Plantation 

Co. and O‘ahu Railway & Land Co.began leasing land for pineapple cultivation during the mid1900s. Ultimately, large areas of Kahuku were leased to the California Packing Corporation that later 

became the Del Monte Corp., who later subleased lands to the U.S. government for use as military 

training areas (Smith 1989). 

Annexation of Hawai‘i to the United States and WorldWar II contributed to higher labor costs for 

plantation owners, and this combined with an expanding global sugar market reduced the plantation’s 

market competitiveness. The sugar mill was officially shut down in 1971 (Wilcox 1975). 

3.7.4 Military Use 

Land developments of the area during World War II-era military 

modification included three emergency landing airstrips at the 

northern tip of O‘ahu (Kahuku Point Airfield, Kahuku Golf 

Course, and Kahuku Village), radio tower installations, barracks, 

and concrete bunkers. 

The 18th Air Base Group, 47th Pursuit Squadron, was stationed in 

Kahuku to protect the airfield and man shoreline fortifications. B24s and B-17s were based at Kahuku for short periods of time 

during World War II. Most of the buildings and support structures 

associated with the Kahuku Air Field have been removed. A 

portion of the old runway, a few scattered concrete pillboxes, and 

antenna supports covered by low brush and debris can be found in 

the coastal shrubland (McKillop 2005). 

Kahuku Plantation Co. #1 c. 1946 

Bishop Museum Collection 
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The Kahuku Training Area is situated southwest of the Refuge on the slopes of the Ko‘olau 

Mountain Range. It remains an active training area available for military units in Hawai‘i to maintain 

their combat readiness. 

3.7.5 Land Use Today 

Modern-era activities generating further land modifications include diversified agricultural pursuits 

and extensive aquaculture farm facility construction. Hotel and golf course developments located on 

the coastal plain represent considerable land modifications of relatively large, contiguous areas. 

These activities combined with smaller developments have produced widescale land changes on the 

Kahuku Plain. The Refuge is bordered by Kamehameha Highway to the south and the Pacific Ocean 

to the north. Adjacent land uses to the south include First Wind windfarm, Kahuku Wastewater 

Treatment Plant, Kahuku Golf Course, the abandoned Kahuku sugar mill, Kahuku Hospital, Kahuku 

High School, and the northern section of the Mālaekahana State Recreation Area. Land uses to the 

northwest include kuleana lands, Links Golf Course, and the Turtle Bay Resort. Turtle Bay Resort is 

a 26-acre hotel and commercial development north of the Refuge. Potential future uses of lands 

adjacent to the Refuge include agriculture, aquaculture, golf courses, parks, conservation areas, or 

residential development. 

During the sugar cane era, the Ki‘i area was used as settling ponds to wash sugar cane at the Kahuku 

Sugar Mill. When the mill closed in 1971, the ponds dried and were no longer used by waterbirds. 

The Service entered into a long-term lease agreement with the landowner, the Estate of James 

Campbell, to increase waterbird habitat. Restoration at the Ki‘i Unit began in 1977. In addition to 

agricultural uses, Punamanō Pond was once used as a fishpond by local residents. 

On May 25, 2006, the James Campbell National Wildlife Refuge Expansion Act of 2005 (the Act), 

Public Law 109-225, expanded the existing Refuge boundary by approximately 750 acres, creating a 

total of 1,100 acres of protected wildlife habitat. The new area, which includes coastal lowland 

wetlands, dunes, and strand habitat makai (seaward) of Kamehameha Highway in the Kahuku coastal 

plain, linked the original Refuge units to the ocean shore. The Act was enacted by Congress and the 

President due to longstanding public concerns for protecting O‘ahu’s natural resources and open 

space on the Kahuku coastal plain. 

 

There are two commercial lessees on the Refuge, 

Romy’s and Ming Dynasty, that raise freshwater 

shrimp and prawns in aquaculture ponds next to 

Kamehameha Highway. They are located on a parcel 

of land acquired by the Refuge in December 2009. 

Under an agreement with the James Campbell 

Company, these leases were transferred to the 

Service and will expire in 2023. 

Two other small commercial aquaculture farms are 

also currently in operation on newly acquired 

Refuge lands. One cultivates sea asparagus on lands 

under the Ming Dynasty lease but is not covered by 

the lease and the second raises ogo (seaweed) on 

Romy's Kahuku Prawns & Shrimp 

Laura Beauregard/USFWS
 James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 3. Physical Environment 3-25 

Parcel 4 which was acquired by the Refuge in January 2011. Neither of these commercial operations 

(under a single ownership) were covered by the original purchase agreement which allowed existing 

long-term leases to remain on the property until 2023 and neither is considered appropriate uses 

under current Refuge System policy. Both ventures will need to cease operations on the Refuge. The 

Service is working cooperatively with the business owner to provide an opportunity for both 

operations to relocate off of the Refuge. 

3.8 Refuge Facilities 

Equipment storage and maintenance operations for all of the O‘ahu National Wildlife Refuge 

Complex are based out of the Ki‘i Unit of the James Campbell NWR. The baseyard is located near 

the current public entrance off Kamehameha Highway within a fence along the southwest perimeter 

of the Ki‘i Unit. The area encompassed by the facility is approximately 1 acre and consists of a 

maintenance equipment storage and office facility within a metal building (constructed in 2003). 

There is a three-sided roofed area for additional storage and four portable secured storage containers 

used to safeguard tools and other management-related equipment and materials. Two kiosks and 

interpretative signs demark a short nature walk. 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

3-26 Chapter 3. Physical Environment 
 James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

 

Chapter 4. Refuge Biology and Habitat 4-1 

Chapter 4. Refuge Biology and Habitat 

This chapter addresses the biological environment of James Campbell NWR; however, it is not an 

exhaustive overview of all species occurring within the Refuge. The chapter begins with a discussion 

of biological integrity; we then focus on the presentation of pertinent background information for the 

conservation targets designated under the CCP. The information presented was used when the CCP 

team developed goals and objectives for each of the conservation targets. 

4.1 Biological Integrity Analysis 

The Administration Act directs the Service to ensure that the biological integrity, diversity, and 

environmental health (BIDEH) of the Refuge System are maintained for the benefit of present and 

future generations of Americans. The Service’s policy on BIDEH (601 FW 3) also provides guidance 

on consideration and protection of the broad spectrum of fish, wildlife, and habitat resources found 

on refuges, and associated ecosystems that represent BIDEH on each refuge. 

Biological integrity lies along a continuum from a completely natural system to a biological system 

extensively altered by considerable human impacts to the landscape. No modern landscape retains 

complete BIDEH. However, we strive to prevent the further loss of natural biological features and 

processes. Maintaining or restoring biological integrity is not the same as maximizing biological 

diversity. Maintaining biological integrity may entail managing for a single species or community at 

some refuges and combinations of species or communities at other refuges. Maintaining critical 

habitat for a specific endangered species, even though it may reduce biological diversity at the refuge 

scale, helps maintain biological integrity and diversity at the ecosystem or national landscape scale. 

On refuges, we typically focus our evaluations of biological diversity at the refuge scale; however, 

these refuge evaluations can contribute to assessments at larger landscape scales. We strive to 

maintain populations of breeding individuals that are genetically viable and functional. Evaluations 

of biological diversity begin with population surveys and studies of flora and fauna. The Refuge 

System’s focus is on native species and natural communities such as those found under historical 

conditions. 

We evaluate environmental health by examining the extent to which environmental composition, 

structure, and function have been altered from historic conditions. Environmental composition refers 

to abiotic components such as air, water, and soils, all of which are generally interwoven with biotic 

components (e.g., decomposers live in soils). Environmental structure refers to the organization of 

abiotic components, such as atmospheric layering, aquifer structure, and topography. Environmental 

function refers to the processes undergone by abiotic components, such as wind, tidal regimes, 

evaporation, and erosion. A diversity of abiotic composition, structure, and function tends to support 

a diversity of biological composition, structure, and function. 

We strive to manage in a holistic manner the combination of BIDEH. We balance all three by 

considering refuge purpose(s), Refuge System mission, and landscape scales. Where practical, we 

support the return of extirpated native species in the context of surrounding landscapes. The BIDEH 

for James Campbell NWR is characterized in Table 4.1. 
 James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

4-2 Chapter 4. Refuge Biology and Habitat

Table 4.1. Biological Integrity, Diversity, and Environmental Health Characteristics 

Habitats Population/Habitat 

Attributes 

Natural processes 

responsible for these 

conditions 

Limiting Factors 

Emergent 

wetland 

Seasonal, semipermanent, permanent 

Potential conservation 

species: endangered 

waterbirds, migratory 

waterfowl, and 

shorebirds 

Natural springs; surface 

runoff; periodic 

flooding; seasonal 

fluctuations/drying, but 

more permanent water 

situations than typical 

seasonal wetlands 

Diked impoundments, 

human development, 

disrupted flow patterns, 

climate change, SLR, and 

pest species including 

California grass, California 

bulrush, marsh fleabane, 

Batis, water hyssop, and 

mangrove 

Dry coastal 

shrub/scrub 

community 

Mixed shrub and 

grassland 

Potential conservation 

species: endangered 

waterbirds, shorebirds, 

and seabirds 

Exposed coral shelf due 

to ancient sea level 

subsidence, low annual 

precipitation, subsurface 

sea water (tidal) 

influence 

Invasive species: kiawe, 

marsh fleabane, buffel grass, 

Verbesina, and koa haole 

Coastal 

dunes 

Beach strand/dune 

communities 

Potential conservation 

species: seabirds, 

shorebirds, endangered 

‘īlio-holo-i- ka-uaua, 

threatened honu 

Onshore winds, salt 

spray, sandy soil, wave 

and tidal action 

Pest species: tree heliotrope, 

silverhead, spiny amaranth, 

mongooses, rats, cats, dogs, 

and pigs; livestock grazing; 

human development and 

disturbance; and marine 

debris 

Exposed 

coral shelf 

and 

anchialine 

pools 

Coastal areas; shallow, 

poorly developed soil 

with a coral base; eroded 

vertical sinkholes occur 

Potential conservation 

species: Metabeteaus 

lohena, pinapinao 

Sea level subsidence, 

subterranean sea water 

influence, dry 

conditions, low amounts 

of surface organic 

matter 

Pest species: kiawe, marsh 

fleabane, Chinese violet, 

buffel grass, and koa haole 

 
 James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

 

Chapter 4. Refuge Biology and Habitat 4-3 

4.2 Conservation Targets 

Conservation targets are those species or habitats that 

are most important to the management of the Refuge. 

Management for these focal species and habitats that 

support them will benefit other native species that are 

present on the Refuge. Table 4.2 identifies the 

priority resources of concern for James Campbell 

NWR. As native species are referenced by their 

Hawaiian names, Appendix A contains a list of all 

scientific, English, and Hawaiian names. 

Table 4.2. Priority Resources of Concern. 

Focal Species Habitat Type Habitat Structure Life-history 

Requirements 

Other Benefiting 

Species 

‘Alae 

ke‘oke‘o 

Flooded 

wetlands 

Open water 

(< 18 in. depth) 

Foraging, loafing Migratory waterfowl, 

shorebirds, ‘alae ‘ula, 

ae‘o, and koloa maoli Emergent 

wetland 

Hemi-marsh with 

kaluhā sedge 

Nesting, brood 

rearing 

Mudflats Moist-saturated 

soil 

Foraging, loafing 

Levees Ground cover 

vegetation 

Foraging, loafing 

‘Alae ‘ula 

Flooded 

wetlands 

Open water 

(< 18 in. depth) 

Foraging, loafing Migratory waterfowl, 

shorebirds, ‘alae 

ke‘oke‘o, ae‘o, and 

koloa maoli Emergent 

wetland 

Hemi- to 

permanent marsh 

with sedge, cattail, 

and bulrush 

Nesting, brood 

rearing 

Mudflats Moist to saturated 

soil 

Foraging, brood 

rearing, loafing 

Levees Ground cover 

vegetation 

Foraging, loafing 

Ae‘o 

Flooded 

wetland 

Shallow water 

(< 7 in. depth) 

Foraging, loafing Migratory waterfowl, 

shorebirds, ‘alae ‘ula, 

‘alae ke‘oke‘o, and 

koloa maoli Mudflats Adjacent 

vegetation (cover) 

and shallow water 

Nesting, brood 

rearing 

 

Nesting ‘alae ‘ula Mike Silbernagle/USFWS
 James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

4-4 Chapter 4. Refuge Biology and Habitat

Focal Species Habitat Type Habitat Structure Life-history 

Requirements

Other Benefiting 

Species

Koloa maoli 

Low 

disturbance 

flooded/ 

emergent 

wetlands 

Open water < 8 in. 

depth supporting 

seed-bearing plants 

and invertebrates 

for food 

Foraging, loafing, 

and chick rearing 

yearlong 

Migratory waterfowl, 

shorebirds, ‘alae ‘ula, 

ae‘o, and ‘alae 

ke‘oke‘o 

Low 

disturbance 

grassy upland 

adjacent to/in 

wetlands 

Dry land with 

vegetative 

concealment cover 

Nesting, yearlong 

major period MarchJune 

Migratory waterfowl, 

shorebirds 

‘Īlio-holo-ika-uaua

Beach areas; 

sand spits and 

islets, 

including all 

beach crest 

vegetation; 

lagoon waters; 

inner reef 

waters; and 

open ocean 

Sandy shoreline, 

rocky areas, and 

emergent reefs; as 

well as vegetated 

areas for shelter 

Pupping, nursing, 

resting, and molting 

Honu, shorebirds, and 

seabirds 

Honu 

Shallow, 

protected water 

with abundant 

aquatic 

vegetation; 

coral reefs; 

beach areas; 

sand spits and 

islets; and open 

ocean 

Open beaches with 

a sloping platform 

and minimal 

disturbance are 

required for nesting 

Basking and nesting ‘Īlio-holo-i- ka-uaua, 

shorebirds, and 

seabirds 
 James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

 

Chapter 4. Refuge Biology and Habitat 4-5 

4.3 Endangered Hawaiian Waterbirds 

James Campbell NWR was established to provide protected managed habitat for four of Hawai‘i’s 

endangered waterbirds. According to the Draft Revised Recovery Plan for Hawaiian Waterbirds, the 

Refuge is designated as a core wetland, which is an area essential to the recovery and delisting of all 

four waterbird species. This Refuge is one of the five core wetland complexes located on O‘ahu that 

are continually managed for endangered waterbirds (USFWS 2005). 

The primary causes of Statewide population decline for these four endangered waterbirds include 

loss of wetland habitat, predation by introduced animals, altered hydrology, habitat alteration by pest 

plants, and disease. Environmental contaminants may threaten populations in certain areas. The 

general recovery objectives are: stabilize or increase species population to greater than 2,000 

individuals; establish multiple self-sustaining breeding populations throughout their historical ranges; 

protect and manage core and supporting wetlands Statewide; eliminate or control the threat of 

introduced predators, diseases, and contaminants; and remove the threat of koloa maoli hybridizing 

with non-migratory mallards. 

4.3.1 Ae‘o (Himantopus mexicanus knudseni) or Hawaiian Stilt 

The ae‘o is an endemic subspecies in the Hawaiian Islands, which 

is part of a superspecies complex of stilts found in various parts of 

the world. The U.S. Pacific Islands Regional Shorebird 

Conservation Plan considers the ae‘o as highly imperiled because of 

its low population level. The ae‘o population has shown a general 

upward trend Statewide over the past 25 years, although annual 

summer and winter counts have shown variability from year to 

year. This fluctuation can be attributed to winter rainfall and 

successful reproduction. The State population of this resident nonmigratory shorebird fluctuates between 1,200-1,500 birds with a 5-

year average of 1,350 birds. Adult and juvenile dispersal has been 

observed both intra- and inter-island (Robinson et al. 1999). 

Ae‘o numbers fluctuate seasonally with the overall population trend 

on the Refuge showing a general decline during the summer months 

and a general increase during the winter months over the past 30 

years. Annual numbers vary with habitat availability for this 

species. Peak numbers range as high as 276 birds. Ae‘o survey 

numbers are shown in Figure 4-1. With the addition of new Refuge acreage, increased year-round 

habitat for ae‘o will become available and will have a positive effect on their numbers. 

 

Ae‘o favor open wetland habitats with minimal vegetative cover and water depths less than 9.4 

inches, as well as tidal mudflats. Ae‘o nest from mid-February to late August. Nesting sites consist of 

simple scrapes on low relief islands or undulating wetland bottom topography within and/or adjacent 

to ponds. Ae‘o tend to be opportunistic users of ephemeral wetlands to exploit seasonal abundance of 

food, feeding on small fish, crabs, polychaete worms, terrestrial and aquatic insects, and tadpoles 

(Robinson et al. 1999, Rauzon and Drigot 2002). 

Ae‘o pair © Brian Barker
 James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

4-6 Chapter 4. Refuge Biology and Habitat

Although ae‘o are considered imperiled, it is believed to have high recovery potential with a 

moderate degree of threat. Barn owls and pueo (Hawaiian short-eared owl) are known predators of 

adult ae‘o. Known predators of eggs, nestlings, and young include mongooses, cats, rats, dogs, 

‘auku‘u (black-crowned night-heron), cattle egrets, common mynas, ‘akekeke (ruddy turnstone), 

laughing gulls, American bullfrogs, and large fish. Ongoing threats to foraging and breeding birds on 

Refuge lands include predation by introduced vertebrates, pest plants, disease, and potential 

environmental contaminants. 

Figure 4.1 

4.3.2 ‘Alae ke‘oke‘o (Fulica alai) or Hawaiian Coot 

The ‘alae ke‘oke‘o is an endangered species endemic 

to the main Hawaiian Islands, except Kaho‘olawe, 

and has occurred sporadically as a vagrant to the 

NWHI, as far west as Kure Atoll. The Draft Revised 

Recovery Plan for Hawaiian Waterbirds lists the 

‘alae ke‘oke‘o as having high potential for recovery 

and a low degree of threats. The North American 

Waterbird Conservation Plan considers the ‘alae 

ke‘oke‘o as a species of high concern. The State 

population has fluctuated between 2,000-4,000 birds 

with the O‘ahu population fluctuating between 500-

1,000 birds. Inter-island dispersal is most likely 

influenced by seasonal rainfall patterns, wetland 

condition and food abundance (Brisbin et al 2002). 

‘Alae ke‘oke‘o Laura Beauregard/USFWS
 James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

 

Chapter 4. Refuge Biology and Habitat 4-7 

‘Alae ke‘oke‘o numbers on the Refuge fluctuate seasonally with the overall population trend on the 

Refuge showing a moderate increase over the past 30 years. Improved predator controls as well as 

habitat and water level management that provides more suitable habitat for this species throughout 

most of the year on the Refuge have contributed to the increase. The high count for ‘alae ke‘oke‘o on 

the Refuge was 358 birds, survey numbers are shown below in Figure 4.2. With the addition of new 

Refuge acreage, increased year-round habitat for ‘alae ke‘oke‘o will become available and will have 

a positive effect on their numbers. 

Figure 4.2 

‘Alae ke‘oke‘o are usually found on island coastal plains and prefer freshwater ponds or wetlands, 

brackish wetlands, and manmade impoundments. They prefer open water that is less than 12 inches 

deep for foraging and nesting habitat that has openwater with emergent aquatic vegetation or heavy 

stands of grass. Nesting occurs mostly March-September, with opportunistic nesting occurring yearround depending on rainfall. ‘Alae ke‘oke‘o will construct floating nests of aquatic vegetation, semifloating nests attached to emergent vegetation, or in clumps of wetland vegetation. False nests are 

also sometimes constructed and used for loafing or brooding platforms. ‘Alae ke‘oke‘o feed on seeds 

and leaves of aquatic and terrestrial plants, freshwater snails, crustaceans, tadpoles of marine toads, 

small fish, and aquatic and terrestrial insects (Schwartz and Schwartz 1949, Brisbin et al. 2002). 

Cats, dogs, and mongooses are the main predators of adult and young ‘alae ke‘oke‘o. Other predators 

include the ‘auku‘u, cattle egret, and large fish. ‘Alae ke‘oke‘o are susceptible to avian botulism 

outbreaks in the Hawaiian Islands (Brisbin et al. 2002). 

 
 James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

4-8 Chapter 4. Refuge Biology and Habitat

4.3.3 ‘Alae ‘ula (Gallinula chloropus sandvicensis) or Hawaiian Moorhen 

The ‘alae ‘ula is an endemic, non-migratory 

subspecies of the common moorhen (Gallinula 

chloropus). It is believed the subspecies originated 

from stray migrants from North America that 

colonized Hawai‘i. Although it previously occurred 

on all the main Hawaiian Islands except Lana‘i and 

Kaho‘olawe, this species is currently only found on 

the islands of Kaua‘i and O‘ahu. The ‘alae ‘ula is 

considered to have a high potential for recovery with 

a moderate degree of threats (Hawai‘i Audubon 

Society 2005, Kushlan et al. 2002). 

Cats, dogs, mongooses, and bullfrogs are known 

predators with ‘auku‘u and rats as possible predators. The ‘alae ‘ula is highly susceptible to human 

and predator disturbance. ‘Alae ‘ula are very secretive; thus, population estimates and long-term 

population trends are difficult to approximate. The Statewide population appears to be stable, with an 

average annual total of 314 birds between 1977-2002. Approximately half of this population occurs 

on O‘ahu (Engilis and Pratt 1993, Bannor and Kiviat 2002, Hawai‘i Audubon Society 2005). 

‘Alae ‘ula numbers on the Refuge fluctuate seasonally with the overall population trend on the 

Refuge showing a general increase over the past 30 years. Annual numbers vary with habitat 

availability for this species, with a high count of 98 birds, as shown below in Figure 4.3. With the 

addition of new Refuge acreage, increased year-round habitat for ‘alae ‘ula will become available 

and will have a positive effect on their numbers. 

Figure 4.3 

‘Alae ‘ula Mike Silbernagle/USFWS
 James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

 

Chapter 4. Refuge Biology and Habitat 4-9 

4.3.4 Koloa maoli (Anas wyvilliana) or Hawaiian Duck 

The koloa maoli is an endangered waterfowl endemic 

to the Hawaiian Islands. The former range of the 

koloa includes all the main Hawaiian Islands except 

Lana‘i and Kaho‘olawe. Currently, the only naturally 

occurring population of koloa maoli exists on Kaua‘i 

with repatriated populations on O‘ahu, Hawai‘i, and 

Maui. The Draft Revised Recovery Plan for Hawaiian 

Waterbirds lists the koloa maoli as having a high 

potential for recovery and a high degree of threat due 

to hybridization with mallard ducks, the greatest 

threat to this species’ continued existence. The 

current Statewide population of pure koloa is 

estimated at 2,200 birds; approximately 2,000 

individuals occur on Kaua‘i and the remainder reside on the Island of Hawai‘i. Birds on O‘ahu and 

Maui are thought to be primarily koloa-mallard hybrids, with estimated counts of 300 and 50 birds, 

respectively. Although hybridization is still a threat on the islands of Kaua‘i and Hawai‘i, the koloa 

maoli population on these two islands appear to be stable. Three pure koloa maoli were found at 

James Campbell NWR during a genetic testing survey in 2008 (USFWS 2005, Engilis et al. 2002, 

Hawaii Audubon Society 2005, Uyehara et al. 2007). 

The koloa maoli uses natural and manmade lowland wetlands, flooded grasslands, river valleys, 

mountain streams, montane pools, forest swamplands, aquaculture ponds, and agricultural areas. The 

Refuge provides suitable habitat for foraging, loafing, pair formation, and breeding. The majority of 

nesting occurs from March-June with broods observed year-round. Nests are placed in dense 

shoreline vegetation of small ponds, streams, ditches, and reservoirs. Types of vegetation associated 

with the nesting sites of koloa maoli include fetched and bunch-type grasses, rhizominous ferns, and 

shrubs. The diet consists of aquatic invertebrates, aquatic plants, seeds, grains, green algae, aquatic 

mollusks, crustaceans, and tadpoles (Engilis et al. 2002, USFWS 2005a). 

In addition to hybridization concerns, other hazards exist for koloa maoli. Known predators of eggs 

and ducklings include mongooses, cattle egrets, cats, dogs; and possibly rats and Samoan crabs. 

‘Auku‘u and bullfrogs have been observed to take ducklings. Avian diseases are another threat to 

koloa maoli with outbreaks of avian botulism occurring annually throughout the State. In 1983, cases 

of adult and duckling mortality on O‘ahu were attributed to aspergillosis and salmonella. In order for 

pure koloa maoli to successfully breed on O‘ahu, the removal of all hybrids and mallard ducks will 

need to occur (Engilis et al. 2002). 

Koloa-mallard hybrids Mike Silbernagle/USFWS
 James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

4-10 Chapter 4. Refuge Biology and Habitat

‘Auku‘u looks for prey Laura Beauregard/USFWS

4.4 Other Hawaiian Waterbirds 

4.4.1 ‘Auku‘u (Nycticorax nycticorax hoactli) or Black-crowned Night-heron 

The indigenous ‘auku‘u is a cosmopolitan species 

resident to the main Hawaiian Islands. The blackcrowned night-heron is a species of moderate 

concern in North America; however, ‘auku‘u in 

Hawai‘i are not given this designation. In the past, 

this species has used the Refuge only for foraging. 

The high count for ‘auku‘u was 109 birds in the Ki‘i 

and Punamanō Units. There are breeding colonies 

within the new acquisition lands and we expect to 

maintain the current population size, which will 

result in higher numbers for the Refuge. 

‘Auku‘u use a wide range of aquatic habitat types including mountain streams, lowland ponds and 

estuaries, aquaculture farms, and suburban/urban waterways. The ‘auku‘u is diurnal in Hawai‘i and is 

known to forage on crustaceans, insects, fish, frogs, and mice. They have been observed eating the 

eggs and young of the endangered ae‘o, koloa maoli, and ‘alae ke‘oke‘o. This species may also be a 

predator of ‘alae ‘ula eggs and young. Nesting occurs in colonies in December-February in Hawai‘i. 

‘Auku‘u are susceptible to human disturbance during nesting (Davis 1993, Mitchell et al. 2005, 

USFWS 2005a). 

4.5 Migratory Waterfowl 

For centuries, migratory ducks, geese, and other 

waterfowl have wintered on the Hawaiian Islands 

from September-May. Of the nearly 30 species of 

migratory ducks and geese using the islands, the 

most common winter migrants observed at James 

Campbell NWR include koloa mohā (northern 

shoveler), koloa māpu (northern pintail), mallard, 

lesser scaup, green-winged teal, and American 

wigeon. Migratory mallards do not pose the same 

hybridization threats to koloa maoli as the domestic, 

resident mallards because they rarely breed during 

their winter stop-overs (Staples & Cowie 2001). 

Koloa mohā © Michael Walther
 James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

 

Chapter 4. Refuge Biology and Habitat 4-11 

4.6 Migratory Shorebirds 

The Pacific Island Region functions as essential 

migratory habitat for maintaining global shorebird 

populations. James Campbell NWR plays an 

important role in providing wintering grounds for 

shorebirds in the Hawaiian Islands. Thirty-five 

species of shorebirds have been recorded on the 

Refuge. The most common migratory shorebirds by 

order of abundance on O‘ahu wetland refuges are the 

kōlea (Pacific golden plovers), ‘akekeke, hunakai 

(sanderling), and ‘ūlili (wandering tattler) (Table 

4.3). The only resident shorebird is the ae‘o. 

The majority of the migratory shorebirds use the 

Refuge from August-April for loafing and foraging 

(Engilis and Naughton 2004). 

Shorebirds primarily utilize wetlands and tidal flats; however, estuaries, grasslands, and uplands are 

also important habitats. Although large portions have been altered for urban development, O‘ahu 

offers the most diverse shorebird habitat of all the Hawaiian Islands. Grasslands and beaches are 

important habitats for the kōlea and the kioea (bristle-thighed curlew). O‘ahu golf courses support an 

estimated 1,900 kōlea during the winter, and this species has even been observed roosting on urban 

rooftops (Engilis and Naughton 2004). 

Threats to shorebirds in the Pacific Region include habitat loss, pest plants and animals (predation, 

disease, and competition), human disturbance, and environmental contaminants. The kōlea is the 

most common shorebird in the Pacific Region, with Hawai‘i supporting a substantial portion of the 

Alaskan breeding population during winter. The kioea is the only migratory species that exclusively 

winters in the Pacific. Thus, the Pacific Region is considered to be a critical area for supporting 

hemispheric populations of both these species (Engilis and Naughton 2004). 

Table 4.3. Shorebirds of Primary Conservation Importance in the Pacific Region 

Species Hawai‘i Winter 

Population 

Regional 

Trend 

Conservation 

Category 

Kōlea 15,000-20,000 Unknown High Concern 

Ae‘o 1,200-1,600 Unknown Highly Imperiled 

Kioea 800 Unknown High Concern 

‘Ūlili 1,000 Unknown Moderate Concern 

‘Akekeke 5,000-7,000 Unknown Low Concern 

Source: Engilis and Naughton (2004) 

An ‘akekeke forages during visit © Michael Walther
 James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

4-12 Chapter 4. Refuge Biology and Habitat

Pueo © Tom Dove

4.7 Seabirds 

The ‘ua‘u kani is the only seabird currently known 

to nest on the Refuge. Reproductive success is 

unknown but predation appears to be a major 

limiting factor. Six seabird species have been 

selected for priority management because of their 

habitat preferences at other nesting sites in Hawai‘i 

that resemble the conditions at the Refuge. In order 

of feasibility of attraction and colony establishment, 

the species are mōlī, ‘ua‘u kani, koa‘e‘ula, ‘a, 

ka‘upu, and Christmas shearwater. These species 

are currently observed along the Refuge coastline 

and vicinity. Mōlī have attempted to nest near the 

Refuge but were killed by dogs. 

4.8 Raptors 

4.8.1 Pueo (Asio flammeus sandwichensis) or 

Hawaiian Short-eared Owl 

Pueo are hard to detect and we do not have accurate counts for their 

presence. No nests have been documented to date. The Refuge offers 

breeding and foraging habitat for the pueo. Unlike most owls, pueo 

are diurnal and are occasionally seen hovering or soaring over open 

areas. Like short-eared owls in continental environments, those in 

Hawai‘i primarily consume small rodents, insects, and, rarely, birds. 

Males perform aerial displays known as a sky dancing display to 

prospective females. 

Found on all the main Hawaiian Islands from 0-8,000 feet, pueo 

occupy a variety of habitats including wet and dry forests. 

Listed by the State as Endangered on O‘ahu, pueo are likely 

susceptible to the same factors that threaten other native Hawaiian 

birds, including loss and degradation of habitat, predation by 

introduced mammals, and disease. 

Resting ‘ua‘u kani © Michael Walther
 James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

 

Chapter 4. Refuge Biology and Habitat 4-13 

 ‘Īlio-holo-i-ka-uaua rests on beach 

© Jim Collin/ AP

‘Ōpe‘ape‘a Dan Clark/USFWS 

4.9 Endangered Mammals 

4.9.1 ‘Ōpe‘ape‘a (Lasiurus cinereus semotus) or Hawaiian Hoary Bat 

The ‘ōpe‘ape‘a is Hawai‘i’s only native terrestrial mammal. Males 

and females have a wingspan of about 1 foot, and females are 

typically larger than males. Both sexes have a coat of brown and 

gray fur. Individual hairs are tipped or frosted with white; “hoary” 

means frosted. The Hawaiian name refers to a half taro leaf or canoe 

sail shape; these being somewhat similar to the shape of the bat. 

We suspect ‘ōpe‘ape‘a may use the Refuge for foraging areas, just 

before and after sunset, feeding on night-flying insects, including 

moths, beetles, crickets, mosquitoes, and termites. They have been 

documented near the Refuge. Wetlands appear to be important 

foraging areas; they are also is attracted to insects that congregate 

near lights. Breeding has only been documented on the islands of 

Hawai‘i and Kaua‘i. Bats are affected by habitat loss, pesticides, 

predation, and roost disturbance. A reduction in tree cover (e.g., 

roost sites) might be the primary reason for the species’ decline in 

Hawai‘i. 

4.9.2 ‘Īlio-holo-i-ka-uaua (Monachus schauinslandi) or Hawaiian Monk Seal 

‘Īlio-holo-i-ka-uaua are among the most critically endangered mammals in the world. Only about 

1,200 seals are alive today. Most seals live in the NWHI, but there is a small and potentially growing 

population of seals in the main Hawaiian Islands where a 2005 survey observed 76 individuals. 

Its Hawaiian name means “the dog that runs in the rough seas.” 

They frequently haul-out on shorelines to rest and molt. Females 

also haul-out on shore for up to 7 weeks to give birth and nurse 

their pups. Pups and moms stay ashore until weaned. Gestation is 

approximately 1 year. Pupping occurs in late winter and spring. 

‘Īlio-holo-i-ka-uaua can live to 25 years of age. 

They feed on reef fishes, he‘e (octopus), squid, and lobsters down 

to depths of 1,000 feet. Food seems to be a limiting factor for 

population growth at this time. Īlio-holo-i-ka-uaua are usually 

solitary except when on preferred beaches when they may be close 

together and interact. Populations have been decreasing recently in 

the NWHI, possibly due to sea level rising above some islands. 

Terrestrial habitat is used about one-third of the time and 

requirements there include haul-out areas for pupping, nursing, and 

resting, primarily on sandy beaches, but virtually all substrates are 

used. Beachside vegetation is used for protection from wind and 

rain. 
 James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

4-14 Chapter 4. Refuge Biology and Habitat

Honu basking on the shore Laura Beauregard/USFWS

Conflicts and interactions with a variety of ocean and beach users are becoming more frequent and 

significant in the main Hawaiian Islands. Dogs have attacked ‘īlio-holo-i-ka-uaua, and they carry 

diseases that are potentially lethal to ‘īlio-holo-i-ka-uaua. Human disturbance, especially of mothers 

with pups, may be a threat at the Refuge. Prior to recent acquisition, Refuge lands did not include the 

shoreline habitat suitable for this species, therefore monitoring did not occur. Incidental observations 

over the past year have documented at least two individuals hauling-out on the shore on several 

occasions. Increased monitoring will provide a better understanding of the use; and management is 

expected to increase the likelihood of pupping along the Refuge shoreline. In recent years, pupping 

has been documented nearby on the shore between the Turtle Bay Resort and the Refuge. 

4.10 Invertebrates 

4.10.1 ‘Ōpae‘ula (Halocaridina rubra) or Hawaiian Red Shrimp 

The ‘ōpae‘ula is a tiny (less than half an inch long) reddish shrimp of the family Atyidae found only 

in Hawai‘i’s brackish water anchialine pools. It is the most common species of anchialine shrimp in 

Hawai‘i and can reach 15 years of age, an unusually long time for a tiny crustacean. This species is 

known to occur on the islands of Hawai‘i, Maui, and O‘ahu. They graze on the film of algae and 

diatoms growing on rocks and other hard surfaces. This endemic species is threatened by loss of 

habitat due to coastal development, the introduction of predatory pest fishes, and perhaps by 

collection for the pet trade. Its Hawaiian name means “red shrimp.” Eight different genetic lineages 

of ‘ōpae ‘ula exist in Hawai‘i. Data show that a lineage was confined to a particular region of a single 

Hawaiian Island, with each island harboring at least two lineages. 

‘Ōpae‘ula are known to occur in two locations on the Refuge. Due to some of the geologic features 

found in the expansion area, additional anchialine pools containing this species are anticipated. If 

degraded sites are found, habitat restoration will be pursued. 

4.11 Marine Reptiles 

4.11.1 Honu (Chelonia mydas) or Hawaiian Green Turtle 

Honu use the Refuge beach for resting and nesting. 

Mature males are distinguished from females by 

their longer, thicker tails. Little information exists 

on the feeding behavior of post-hatchlings and 

juveniles living in pelagic habitats, but most likely 

they are exclusively carnivorous (e.g., soft-bodied 

invertebrates, jellyfish, and fish eggs). Subadult and 

adult turtles residing in nearshore benthic 

environments are almost completely herbivorous; 

feeding primarily on select macroalgae and sea 

grasses. The common name “green sea turtle” is 
 James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

 

Chapter 4. Refuge Biology and Habitat 4-15 

derived from the color of their body fat, which is green from the limu (algae) they eat. Adult honu 

can weigh up to 500 pounds and are often found living near coral reefs and rocky shorelines where 

limu is plentiful. Hawaiian honu display slow growth rates, even compared to other populations, with 

an average annual growth rate of approximately 1⁄2-2 inches per year. Turtles often reach sexual 

maturity at 35-40 years of age (Gardner 1996). 

Females may lay up to 6 clutches per season, often returning to the same site for each clutch every 

12-15 days. Each clutch contains approximately 100 eggs and sex determination is temperaturedependent. Incubation takes about 60 days. Evidence shows that Hawaiian honu only migrate 

throughout the 1,500-mile expanse of the Hawaiian Archipelago, and so make up a discrete 

population. Hatchlings and juveniles live in pelagic waters, but little is known of their specific 

distribution. 

Litter and other marine debris can prove deadly when they entangle honu or are mistaken for food 

and ingested. Plastics are particularly harmful as they may remain in the honu's stomach for long 

periods of time, releasing toxic substances. Ingested plastics also can clog the digestive system. 

Noise, lights, and beach obstructions are disruptive to nesting areas and rats, mongooses, and dogs 

prey on the eggs. The Hawaiian honu is listed as threatened under the ESA (Perrine 2003). 

Human disturbance to adults coming to shore to lay eggs may be a threat at the Refuge. A first 

attempt at annual monitoring occurred in 2010, resulting in at least one successful nest with 57 

hatchlings. Increased monitoring will provide a better understanding of the use; and management is 

expected to increase the likelihood of additional nests in suitable habitat. 

4.12 Native Plants 

Native Hawaiian plants arrived to the archipelago via natural means such as wind, water, or birds. 

According to Wagner et al. (1999), the native Hawaiian flora is comprised of roughly 956 species 

within 87 families. Approximately 89 percent of these species are endemic (found only in Hawai‘i), 

while the remainder are indigenous (naturally found in Hawai‘i and elsewhere). Since their 

establishment, populations of Hawai‘i’s native vegetation have greatly declined. Few native plants 

have escaped the impacts of urbanization and agriculture on the coastal and lowland habitats. As a 

result, recent surveys conclude that 75 percent of the native plant communities in these habitats are 

considered to be rare. Coastal alterations such as agriculture, residential developments, recreational 

parks, military installations, golf courses, and roads, have permanently displaced much of the native 

flora. With expansion of the Refuge, protection and outplanting will improve the native plant 

diversity and distribution (Cuddihy and Stone 1994). 

 
 James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

4-16 Chapter 4. Refuge Biology and Habitat

‘Ilima Laura Beauregard/USFWS

Flowers and fruit of naupaka kahakai 

Laura Beauregard/USFWS

4.12.1 Naupaka Kahakai (Scaevola taccada) or Beach Naupaka 

Naupaka are indigenous shrubs that grow from 3-10 

feet tall along coasts throughout the tropical Pacific 

and Indian Oceans. They have bright green succulent 

leaves with fragrant white flowers that appear to 

have split in half with five petals remaining on one 

side. 

Part of the coastal dunes and scrub/shrub 

communities, naupaka kahakai provide cover and 

nesting substrate for seabirds and shorebirds. It is 

abundant and naturally occurring on the Refuge. 

This species is the only non-endemic naupaka, and 

the only one to produce white fruit in the Hawaiian 

Islands. The pulpy marble-sized fruits tolerate salt water and float on the ocean currents for dispersal 

to other islands. Mixed with salt, the fruit or root bark of naupaka kahakai was used for cuts, skin 

diseases, and wounds (Ka‘aiakamanu 2003). 

4.12.2 ‘Ilima (Sida fallax) or Yellow Ilima 

One of the most common native species found in 

Hawaiian coastal areas, ‘ilima have yellow-orange 

flowers with five petals. The ground-hugging plant 

has heart-shaped 1-inch-long slivery-green leaves. 

Individual plants of this species vary greatly in height, 

density of hairs, leaf size and shape, and flower color 

and size. The Refuge anticipates expansion of the 

species into additional areas of the Refuge as projects 

to remove pest plants for habitat restoration are 

implemented. 

The yellow ‘ilima is the official flower of the Island of O‘ahu; about 1,000 blooms are used to create 

a single lei. Hawaiians also used the plant for medicinal properties. Pregnant women consumed its 

juice and flowers prior to giving birth to a child. The root bark mixed with the plant’s blooms was 

used as an asthma remedy (Walther 2004). 

4.12.3 Hala (Pandanus tectorius) or Screw-pine 

Hala is a small tree growing 20-30 feet in height and from 15-35 feet in diameter. The trunk is stout 

and the branches grow at wide angles to it. It has distinctive long blade-like leaves (lau hala) about 2 

inches wide and over 2 feet long. Most varieties have spines along the edges and on the midribs of 

the leaves. The leaves are spirally arranged toward the ends of the branches and leave a spiral pattern 

on the trunk when they fall. These trees develop aerial prop roots (ule hala) at the base of the trunk 

and sometimes along the branches. It occurs in coastal sites and on the low elevation slopes of mesic 

valleys further inland to 2,000 feet elevation, and has been identified as a potential roosting site for 

‘ōpe‘ape‘a. The Refuge anticipates restoring hala as a component of native habitat restoration 

projects within the expansion lands (Walther 2004, DOFAW 2005). 
 James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

 

Chapter 4. Refuge Biology and Habitat 4-17 

Hala grove Laura Beauregard/USFWS

Female hala produce a large, segmented fruit 

somewhat resembling a pineapple. Male trees 

produce large clusters of tiny, fragrant flowers 

surrounded by white to cream-colored bracts. There 

are four types of hala based on color of fruit: 

common hala is yellow, hala ‘ula is orange, hala 

lihilihi ‘ula is red fading to yellow, and hala pia is 

small and pale yellow. Men from Kahuku were 

identified by lei of the orange hala fruit which they 

wore by order of their chief when they left their 

ahupua‘a (Wilcox 1975, Hensley 1997, Wagner 

1990). 

Historical accounts and legend emphasize the hala groves that covered the coastal plain. A Hawaiian 

chant describes the native hala of Kahuku (Elbert 1965:280-281): 

A kukui au a Kahewahewa 

Ku au nana i laila, 

Haloiloi kuu waimaka e uwe. 

Nani na hala ka oiwi o Kahuku, 

I ka lawe a ka makani he mikioi. 

As I reported to Kahewahewa 

I stood and gazed, then 

Tears filled my eyes causing me to weep. 

How beautiful are the hala, native trees of Kahuku, 

As they are fanned by the Mikioi wind. 

4.13 Invasive Species 

For the purpose of this CCP, an invasive species is defined as a species whose migration and growth 

within a new range is causing detrimental effects on the native biota in that range. Mammals, 

amphibians, invertebrates, and plants can all be considered invasive. These species become invasive 

because their population and growth are no longer balanced by natural predators or biological 

processes that kept them in balance in their native ecosystems. In the absence of these restraints, 

invasive species have the potential to compete with native species for limited resources, alter or 

destroy habitats, shift ecological relationships, and transmit diseases. Native species as well as 

nonnative species can become invasive when their natural ecosystem is out of balance. 

Invasive species are one of the most serious problems in conserving and managing natural resources. 

In particular, the ecological integrity of Pacific Island environments is greatly threatened by invasive 

species. Hawai‘i, which existed in isolation for millions of years, is an exceptionally ideal 

environment for these species. Most native species lost their natural defense mechanisms and are 

more vulnerable to introduced species. As stated earlier in this CCP, we refer in invasive species as 

“pest species” in the management strategies (Pattison et al. 1998, Ikuma et al. 2002, Middleton 

2006). 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

4-18 Chapter 4. Refuge Biology and Habitat

4.13.1 Mammals 

Rat (Rattus spp.)

Three pest rat species are found throughout the 

Hawaiian Islands. Polynesian rats arrived from the 

central Pacific 1,500 years ago with the Polynesians; 

Norway rats reached the Hawaiian Islands after the 

arrival of Captain Cook in the 1770s; and black rats 

most likely arrived in the 1870s. It is estimated that 

these three species have populated nearly 82 percent 

of the major islands. 

Black and Polynesian rats can be found from 0-10,000 feet. Norway rats are restricted to areas below 

6,000 feet. Polynesian rats and Norway rats nest exclusively in terrestrial habitats, while black rats 

are arboreal nesters. This nesting difference may contribute to a larger population of black rats in 

Hawai‘i due to the presence of nonarboreal mongoose predators (Tobin and Sugihara 1992, Hays and 

Conant 2007). 

All three species in Hawai‘i are known predators of eggs, nestlings, young, and occasionally adults 

of endangered waterbirds, seabirds, migratory shorebirds, and forest birds. Ground- and burrownesting seabirds are particularly vulnerable to rat predation, even by the arboreal black rat. Rats also 

consume plants, insects, mollusks, herpetofauna, and other invertebrates. Because these species are 

also eaten by birds, a reduction in these populations may indirectly affect avian populations (Olson 

and James 1982, Harrison et al. 1984, Brisbin et al. 2002, Engilis et al. 2002, Mitchell et al. 2005). 

The use of snap traps and ground-based application of diphacinone rodenticide to control rats in the 

main Hawaiian Islands has shown a positive effect in native bird survival. Rat control is conducted 

year-round at the James Campbell NWR with various methods including the use of rodenticide 

placed in bait stations, live traps, and snap traps. 

Small Indian Mongoose (Herpestes javanicus) 

The small Indian mongoose was intentionally 

introduced to numerous island ecosystems during the 

1800s and 1900s and has since expanded to large 

portions of Asia, Africa, Europe, Oceania, and the 

Americas. In 1883, the species was introduced to the 

main Hawaiian Islands as a biocontrol agent against 

rats in sugarcane fields. The mongoose inhabits all 

habitat types from 0-10,000 feet on the islands of 

Hawai‘i, Maui, O‘ahu, and Moloka‘i. In other areas 

of the world, mongooses appear to avoid wet areas; 

however, in Hawai‘i, dense populations of 

mongooses are concentrated in wet habitats. 

The home range of a female in Hawai‘i is about 3.5 acres, and the main reproductive period occurs 

February-August. The high density of mongooses in the Hawaiian Islands is due to abundant food 

and the lack of natural predators. They are voracious omnivores, consuming insects, reptiles, 

Black rat © Jack Jeffrey

Mongoose on the prowl © Chuck Babbitt 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Refuge Biology and Habitat 4-19 

mammals, amphibians, crabs, plants, and birds. In Hawai‘i, mongooses are diurnal predators that 

primarily eat invertebrates and secondly small mammals. They are a major threat to any ground 

dwelling and nesting species in Hawai‘i. These mammals are known to eat eggs, young, and adults of 

endangered Hawaiian waterbirds, various seabirds, and migratory shorebirds. In addition, mongooses 

are known to consume young honu (Tomich 1986, Staples and Cowie 2001, Mitchell et al. 2005, 

Hays and Conant 2007). 

Mongoose populations are managed using traps and diphacinone rodenticide. Since mongooses are a 

constant threat to waterbirds, year-round control has been conducted on the Refuge since 2004. 

Cat (Felis catus) 

Cats arrived in Hawai‘i in the early 1800s on European 

ships and are now found on all the main Hawaiian 

Islands from 0-10,000 feet. They are frequently 

observed on the Refuge and are occasionally caught in 

our trapping program. 

Cats are natural hunters with their sharp teeth; the 

upper teeth overlap the lower, giving them a firm grasp 

to shake or tear prey to death. Food habits of cats in 

Hawai‘i include insects, centipedes, crustaceans, 

lizards, mice, rats, bird eggs, birds, and ‘ōpe‘ape‘a 

(Scott and Thomas 2000, Brisbin et al. 2002, Engilis et 

al. 2002, Mitchell et al. 2005). 

Pig (Sus scrofa) 

In the wetlands at James Campbell NWR, pigs have trampled across mudflats and other habitats used 

by endangered and migratory waterbirds. Their mere presence creates a disturbance to all habitats of 

the Refuge. Uncontrolled, they have the potential to degrade wetlands, reduce nesting and fledgling 

success of endangered waterbirds, and perpetuate spread of invasive plants, mitigating our efforts to 

enhance a variety of habitats on the Refuge. 

Impacts to ecosystems can take the form of 

decreased water quality, increased propagation of 

pest plant species, increased soil erosion, 

modification of nutrient cycles, and damage to native 

plant species. Rooting, trampling, and compaction 

influence plant regeneration, community structure, 

soil properties, nutrient cycling, and water 

infiltration. Pigs may induce the spread of pest plant 

species because these plants typically favor disturbed 

areas and colonize more quickly than many native 

plants. Habitat damage is particularly important in 

wet areas where plant communities and soils tend to 

be more sensitive to disturbance. Wild pigs can be 

predators of ground-nesting birds, although the impact of this predation on the populations of 

ground-nesting birds is yet unclear (Seward et al. 2004, Kaller and Kelso 2006) 

Pigs at Punamanō Mike Sibernagle/USFWS

Neutered and released cat with ‘alae ‘ula

© Michael Walther
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

4-20 Chapter 4. Refuge Biology and Habitat

Dog (Canis lupus familiaris)

The dog is a domesticated form of the gray wolf, a 

member of the Canidae family of the order 

Carnivora. Abandoned, escaped, or pet dogs 

allowed to run loose can cause great harm to native 

species and ecosystems. Dogs have caused terrible 

damage to native ground-nesting seabird colonies. 

In 2008, almost 90 wedge-tailed ‘ua‘u kani birds 

were killed by a pack of dogs at the nearby Kahuku 

Golf Course and in 2006, dogs killed nearly 180 

‘ua‘u kani chicks at Ka‘ena Point. Dogs typically 

attack a large number of birds in a single incident 

by grabbing and shaking the birds around with their 

mouths and leaving them for dead before heading to 

another nest or burrow. The Refuge has documented cases of ‘alae ke‘oke‘o and koloa maoli killed 

by dogs. Fencing is our primary means to keep dogs off the Refuge. 

4.13.2 Birds 

Cattle Egret (Bubulcus ibis) 

The cattle egret was introduced to Hawai‘i in 1959 from Florida for 

insect control on cattle and has become widespread. Rookeries were 

documented on Ni‘ihau, Kaua‘i, O‘ahu, Hawai‘i Island, Moloka‘i, 

Lana‘i, and Maui by the mid-1980s. One of the largest and oldest 

known rookeries is on O‘ahu near Kahuku. The actual roost site has 

moved to different sites over the years, and in 1982 this roost 

contained over 3,000 birds. A roost located on a parcel of land being 

acquired and added to the Refuge has been surveyed for several 

years and numbers have ranged from 100-1,800 birds. A survey 

conducted in 2010 yielded no birds at the roost/rookery. 

Its diet primarily consists of grasshoppers, crickets, spiders, flies, 

frogs, and nocturnal moths, but the bird will also consume prawns, 

mice, crayfish, and the young of native waterbirds. Cattle egrets 

have been documented taking chicks of all endangered waterbirds 

species occurring on the Refuge. If numbers increase and predation on endangered waterbirds 

exceeds our target limit, population control measures as identified in the IPM and/or CCP strategies 

would be implemented (Brisbin et al. 2002, Engilis et al. 2002, Hawaii Audubon Society 2005). 

4.13.3 Amphibians 

Nonnative amphibians also have a negative effect on native Hawaiian species. Recent radio 

transmitter studies at James Campbell NWR provide conclusive evidence that certain nonnative 

amphibians are key predators of juvenile Hawaiian waterbirds. 

 

Dogs running through Ki‘i Unit 

Mike Silbernagle/USFWS

Cattle egret © Michael Walther
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Refuge Biology and Habitat 4-21 

Cane Toad (Bufo marinus) 

Cane toads or Pacific giant toads, which are native 

to Latin America, have a broad geographic range 

that includes a majority of the Pacific region. The 

toads were brought to the Hawaiian Islands in 1932 

to control insect pests. Both wetland units are 

infested with cane toads. The adults only require 

water for breeding, an event which results in 

thousands of eggs per mating occurrence. Cane 

toads are active at night and primarily feed on 

cockroaches, crickets, grasshoppers, grubs, 

earthworms, slugs, spiders, centipedes, and snails. In 

addition, these highly invasive amphibians could be 

a potential predator of endangered waterbird eggs 

and young (Yamamoto and Tagawa 2000, Staples and Cowie 2001). 

North American Bullfrog (Rana catesbeiana) 

North American bullfrogs were brought to Hawai‘i in the late 1800s. They have been identified as a 

major predator of ae‘o chicks and chicks of other endangered waterbirds on the Refuge. Nocturnal 

predators, they will ambush and eat insects, mice, fish, and birds. They sit quietly and wait for prey 

to pass by, then lunge with their powerful hind legs, mouths open wide. Bullfrogs compete with 

waterbirds for food. Crayfish are an important food item for ‘alae ke‘oke‘o and examination of 

bullfrog stomach contents indicates crayfish are also taken regularly. Control measures on the Refuge 

include water level management, live trapping, and shooting. 

Bullfrogs can reach 8 inches in length, with males 

weighing up to 1 pound. Typically green or graybrown with brown spots; they have easily 

identifiable circular eardrums, or tympanum, on 

either side of their heads. The bullfrog’s call is a 

deep bellow, made day and night, and can be heard 

up to 1⁄4-mile away. In breeding season, the throat 

of the male is yellow, whereas the female’s is white. 

Unlike other frogs, it spends most of its time in 

water from where it also does most of its hunting 

(National Aquarium 2010). 

4.13.4 Invertebrates 

Although the Hawaiian Islands support a large number of native invertebrates, wide arrays of pest 

invertebrates have invaded marine and freshwater habitats. Between 20-30 species of introduced 

snails are believed to have established themselves on the Hawaiian Islands (Staples and Cowie 2001). 

Apple Snail (Pomacea spp.) 

Five species of nonnative apple snails occur in the continental U.S. In Hawai‘i, only four species 

have established, including Pomacea canaliculata, P. bridgesii, P. paludosa, and Pila conica. They 

were intentionally released into taro fields as a potential human food resource. All four species have 

a similar appearance making the species difficult to distinguish. The Pomacea species in Hawai‘i are 

North American bullfrog Mike Silbernagle/USFWS

Cane toad Laura Beauregard/USFWS
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

4-22 Chapter 4. Refuge Biology and Habitat

primarily herbivores that consume aquatic and semi-aquatic 

vegetation. The presence of P. canaliculata can be detected by the 

snail’s large pink egg masses laid above water on vegetation, rocks, 

or any rigid surface (Yamamoto and Tagawa 2000, Staples and 

Cowie 2001). 

Of the four species, P. canaliculata is the most serious threat to 

wetland ecosystems and agriculture (taro and watercress) throughout 

the State. This apple snail is the most voracious plant eater. During 

feeding, P. canaliculata may consume most of the plant or make cuts, 

causing damaged plants to be highly susceptible to disease. Although 

P. canaliculata is a freshwater snail, it can tolerate low levels of 

salinity. It is sufficiently tolerant to sea water to survive long enough 

to be carried by currents from one stream mouth to another (Levin 

and ‘Onipa‘a Nā Hui Kalo 2006, Yamamoto and Tagawa 2000, 

Rawlings et al. 2007). 

Apple snails prefer slow moving, shallow water areas. They cannot 

tolerate cold waters, but can survive significant amounts of time out of water and are able to undergo 

dormancy periods by burying in mud. Field tests have shown that fields submerged for longer than 

48 hours with brackish water will kill apple snails; however, this management technique will also 

change soil productivity toward brackish water adapted vegetation. Field flushing with salt has 

successfully killed snails in some ponds at James Campbell NWR, but snails are still present in 

ditches and drainages (Cowie 2002, Levin and ‘Onipa‘a Nā Hui Kalo 2006). 

Ants 

Hawai‘i is one of the few places on Earth believed to harbor no native ant species. Today, at least 47 

ant species in 7 subfamilies and 24 genera have become established. Ants are a growing concern 

since they can have negative effects on native and endangered plants and animals. Ants are known to 

attack, injure, or kill young birds. Ants are also implicated in having negative effects on native and 

endangered plants. Control of ants has potential on the Refuge to protect trust resources. The Service 

is currently studying the efficacy of various baits and approved toxins on pest ants on O‘ahu. It is 

anticipated that over the course of this CCP, the Refuge will adopt IPM methods to control ants 

based on the results of these studies

4.13.5 Plants 

At the ecosystem level, pest plants have been shown to be capable of changing fire regimes, altering 

nutrient cycling patterns, and modifying the surface runoff of water. Pest plants can physically 

displace native species, and/or supersede them in competition for water, nutrients, or other limited 

resources. Nonnative plants can also be vectors and hosts for introduced pests and diseases to which 

the native species lack natural defenses (Jui Min et al. 2007). 

Almost half the flora of the Hawaiian Islands is comprised of naturalized nonnative plants, 

approximately 1,100 species. According to Staples et al. (2000), invasive plants in Hawai‘i share the 

following biological and reproductive characteristics: 

 

Laying eggs www.applesnail.net
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Refuge Biology and Habitat 4-23 

 Adaptable to and capable of thriving in different habitats; 

 Tolerant of variable conditions (such as light, temperature, moisture); 

 Fast growing; 

 Tolerant of disturbance; 

 Easily dispersible to new localities by seeds, fruits, spores, or vegetative parts; 

 Produce small seeds/spores early in life; 

 Long reproductive periods; and 

 Dispersed by animals and with no special germination requirements. 

The control and eradication of pest plants has been the top priority of natural resource managers in 

Hawai‘i. In the wetland habitats of the Refuge, invasive plant species can drastically reduce the value 

of wetland habitat to native species. Pest species outcompete more desirable plant species here, as 

well as invade open water and mudflat habitats. In addition, the high biomass characteristic of 

invasive grasses produces a high amount of fuel for fire. At James Campbell NWR, a combination of 

control techniques are employed for pest plant removal including chemical, mechanical (hand and 

tractor), prescribed burns, and water level manipulations. The following five introduced plant species 

are of major concern on the O‘ahu wetland refuges. 

California Grass (Brachiaria mutica) 

California grass (Family-Poacaeae) is a sprawling 

perennial with culms up to 19 feet long and rooting at 

the nodes. Stolons and leaf sheaths are densely hairy. 

It occurs pantropically as a pasture grass and its 

native range is unknown, although it is suspected to 

have originated in sub-Saharan Africa. California 

grass occurs in aquatic environments such as the 

openings of wet forests, marshes, and other open 

water areas. It is reported to be well adapted to a 

wide range of soil conditions (sandy to clay) and 

tolerates moderate shade but prefers full sun 

(Tropical Forages 2005). 

It grows prolifically in wet swampy habitats, but it can also withstand severe drought. In addition to 

displacing native plants, California grass alters and destroys aquatic environments, causing a 

reduction in bird habitat. The grass also interferes with stream flow and poses a nuisance to marine 

navigation when rafts of the grass float out to sea. The Hawai‘i-Pacific Weed Risk Assessment is a 

research project conducted by the University of Hawai‘i and the USDA Forest Service to identify 

plants that pose a high risk in Hawai‘i and other Pacific Islands. The assessment of California grass 

reflects the species is “documented to cause significant ecological or economic harm in Hawai‘i” 

(Stone et al. 1999, Motooka et al. 2003). 

An on-site study determined that this species can grow 6 feet a month at James Campbell NWR. 

Intensive control measures for California grass on the Refuge include mechanical, chemical, and 

prescribed fire as described in detail in the IPM program (Appendix E). 

 

California grass Mike Silbernagle/USFWS
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

4-24 Chapter 4. Refuge Biology and Habitat

Khaki weed (Alternanthera pungens) 

Khaki weed (Family-Amaranthaceae) is a perennial 

prostrate herb, sometimes rooting at the nodes. 

Flowers are sessile; bracts are approximately 0.16 

inch long, tipped with a 0.08-0.12 inch-long spine. 

Khaki weed is native to Venezuela, Brazil, Peru, and 

Ecuador, and is widely naturalized elsewhere in the 

world (Wagner et al 1999, USDA-GRIN Online 

Database). 

In Hawai‘i it was first recorded on O‘ahu in 1959 and 

has become naturalized on O‘ahu, Moloka‘i, and 

Hawai‘i. It is common in beach parks and other low 

elevation, dry, disturbed areas. Khaki weed is easily dispersed by numerous spiky, straw-colored 

burrs that are transported by animals, machinery, or water. The large and deep woody taproot allows 

the plant to tolerate drought and makes control difficult. These traits contribute to the plant’s invasive 

ability. To control khaki weed, the Refuge conducts spot spraying and maintains a dense 

groundcover of lowgrowing grasses or other desireable species which prevent germination and 

spread (Wagner et al. 1999, Smith 2002). 

Pluchea spp. 

Pluchea spp. (Asteraceae) is comprised of two shrub 

species in Hawai‘i – Indian marsh fleabane (P. 

indica) and sourbush (P. carolinensis) – and a hybrid 

of the two species. Indian fleabane is an erect shrub 

up to 6.6 feet tall. It is native to temperate and 

tropical Asia and northern Australia and is 

naturalized elsewhere. In Hawai‘i, it occurs in 

lowland, coastal habitats such as wetlands and 

fishponds. Initially recorded on O‘ahu in 1915, 

Indian fleabane has been identified on Maui, O‘ahu, 

Kaua‘i, and Ni‘ihau. It prefers marshes and saline 

soils (Motooka et al. 2003, USDA, GRIN Online 

Database). 

Sourbush is an erect aromatic shrub native to parts of North and South America. The species has 

naturalized in Hawai‘i, Guam, Taiwan, Africa, and other tropical and Pacific areas. It can grow in 

poor soil conditions; however, it cannot withstand shade and severe competition from brush and 

grass. In dry habitats, the fast-growing shrub can form thickets. In Hawai‘i, sourbush has spread to 

all the main Hawaiian Islands since its arrival in the 1930s. This shrub is able to grow in a wide array 

of habitats, ranging in distribution from dry coastal areas to open forests at 2,953-feet elevation. The 

plant seeds prolifically and the seeds are easily dispersed by wind (Mueller-Dombois and Fosberg 

1998, Wagner et al. 1999). 

Pluchea will outcompete native sedges on the Refuge, reducing forage and nesting habitats for birds. 

They tend to harbor huge nests of paper wasps, which are a hazard to Refuge staff and the public. 

The Refuge uses mechanical, chemical, and prescribed burning techniques to control this pest 

species. 

Khaki weed Mike Silbernagle/USFWS

Pluchea indica Mike Silbernagle/USFWS
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Refuge Biology and Habitat 4-25 

Silverhead pest plant Mike Silbernagle/USFWS

California Bulrush (Schoenoplectus californicus) 

California bulrush is a perennial sedge in the 

Cyperaceae family. This rhizomed water plant is 

found in marshy areas from southern and western 

North America to South America. It has tall, thin, 

dark green stems which are usually triangular in 

cross-section and woolly, bristly tan or brown 

flowers in panicle inflorescences. It has 

characteristics common in the sedge family, such as 

creeping. It is intolerant of shade, but can spread 

rapidly by vegetative means (Wagner et al. 1999, 

NRCS 2008).

California bulrush has almost covered the wetland 

habitat at the Punamanō Unit, significantly 

decreasing the value to waterbirds. This weed is highly successful in Hawai‘i compared to the 

continental mainland due to the lack of a winter dry cycle. The most common tactics used in the 

Refuge to control it are burning, tilling, and use of herbicides. Flooding has also been employed as a 

removal tactic during the early stages of growth, however, this method decreases bird habitat by 

changing pond salinities. Other proposed methods of removal include helicopter-applied herbicide 

and use of an amphibious excavator. 

Silverhead (Blutaparon vermiculare) 

Silverhead is a perennial herb in the Amaranthaceae 

family. It is native to Africa, the southern states of 

North America, and South America. This species 

forms dense groundcover with prostrate stems and 

ascending branches that flower year-round , 

outcompeting native plants and degrading wetland 

features important to endangered species recovery. 

Silverhead was added as a new State record to 

naturalized flora in 1994 after being found in an 

aquaculture facility at the end of the old runway in 

1991. At James Campbell NWR, this species occurs 

primarily along pond edges (Wagner and Herbst 1994). 

The primary control method used on the Refuge is chemical spraying, as detailed in the IPM program 

(Appendix E). 

4.13.6 Diseases 

Avian botulism 

Avian botulism is a paralytic disease caused by ingestion of a toxin produced by the bacteria, 

Clostridium botulinum. This bacteria is widespread in soil and requires warm temperatures, a protein 

source and an anaerobic (no oxygen) environment in order to become active and produce toxin. 

Decomposing vegetation and invertebrates combined with warm temperatures can provide ideal 

conditions for the botulism bacteria to activate and produce toxin. 

California bulrush at Punamanō Mike Silbernagle/USFWS
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

4-26 Chapter 4. Refuge Biology and Habitat

Beach strand Laura Beauregard/USFWS

Birds either ingest the toxin directly or may eat invertebrates (e.g., chironomids, fly larvae) 

containing the toxin. Invertebrates are not affected by the toxin and store it in their body. A cycle 

develops in a botulism outbreak when fly larvae (maggots), feed on animal carcasses and ingest 

toxin. Ducks that consume toxin-laden maggots can develop botulism after eating as few as three or 

four maggots. 

Outbreaks can occur most anytime on the Refuge, but typically occur during the summer months 

during warm to hot weather. Thousands of birds have been know to die during a single outbreak in 

areas of high waterfowl concentrations. In Hawai‘i there is no seasonal pattern to this disease. 

Botulism is one of the few wildlife diseases we can actually manage effectively. Although we do not 

know all the environmental triggers that cause Clostridium botulinum to start producing toxin, we do 

know that if mortalities are detected early enough, certain management techniques, if implemented 

quickly, can rapidly stop and mitigate the magnitude of waterfowl mortality. The Refuge uses carcass 

pick up and removal as well as water level management in its efforts to minimize impacts of this 

disease. Because animal carcasses are an excellent source of protein, removing them reduces the 

resources the bacterium needs to produce toxin and can help reduce or eliminate toxin production. 

Draining or flooding the wetland can change the environmental conditions sufficiently so as to stop 

the production of toxin. 

Fibropapilloma tumor disease 

Fibropapillomatosis (FP) of marine turtles is a debilitating neoplastic disease with a global 

distribution that was originally described in honu in Hawai‘i in 1958. The prevalence in certain 

coastal habitats has increased or remained high since systematic surveys were started in the early 

1980s. These tumors can result in debilitation and even death to individual animals. The Refuge will 

monitor the frequency and severity of FP occurring on honu observed along the shoreline. Research 

continues as to the cause and potential future remedies for this disease (Herbst 1994, Balazs 1991). 

4.14 Habitats 

The units of James Campbell NWR are located on lowland coastal areas. On the island of O‘ahu, 

these habitats have been severely altered by a variety of factors including pest species and land use 

changes. Continued threats to these habitats remain and conservation efforts are needed to improve 

habitat conditions. 

4.14.1 Coastal Dune/Beach Strand 

Coastal habitats are lands between 0-985 feet in 

elevation that are typically vegetated with strand 

species. The area paralleling the shoreline, also 

referred to as the beach strand, includes beaches, 

coastal dunes, and the zone immediately inland of 

the dunes. Beaches are the most seaward portion of 

the coastal region and are composed of sand or other 

loose materials that are constantly exposed to waves 

and tides. Coastal dunes are ridges or mounds of 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Refuge Biology and Habitat 4-27 

sand located immediately landward of the beach. These mounds are formed by an accumulation of 

windblown sand that is trapped via obstacles such as vegetation. Dunes are dynamic features that 

erode during periods of high waves (a process termed scarping) and rebuild when heavy wave action 

subsides. The coastal dune ecosystem is an integral part of the beach system in Hawai‘i; it functions 

as a natural, elevated buffer against erosion, flooding, high waves, storms, tsunamis, and other 

coastal hazards (Wagner et al. 1999, Char and Balakrishna 1979, University of Hawai‘i 2005). 

The natural dune and coastal beach strand habitat along the Kahuku coastal plain, including the 

seaward portion of James Campbell NWR, is one of last remaining undeveloped coastal dune areas 

on O‘ahu. Coastal communities on the windward sides of the Hawaiian Islands are exposed to a 

variety of harsh conditions including strong trade winds and high surf. As a result, vegetation tends 

to be low and wind-sheared. Strand vegetation on sandy or dune areas typically includes ‘aki‘aki, 

pōhuehue, hinahina, naupaka, pōhinahina, Bermuda grass, nanea, alena, Reichardia picroides, ‘ohai, 

nama, and Australian saltbush (Mueller-Dombois and Fosberg 1998). 

In addition to providing habitat for native flora, the coastal dune areas at James Campbell NWR 

provide resting habitat for the endangered ‘īlio-holo-i-ka-uaua, and nesting habitat for threatened 

honu. Dunes in Kahuku provide habitat for seabirds and shorebirds including the kōlea and kioea, 

two shorebird species designated as a high conservation concern. These coastal dune areas formerly 

provided nesting areas for the endemic pueo. Pueo are common on Maui, Kaua‘i, and Hawai‘i; 

however, the State of Hawai‘i has listed it as an endangered species on O‘ahu (Hawaii Audubon 

Society 2005). 

Recreational and coastal development pressures have severely impacted coastal dunes throughout the 

State of Hawai‘i and the Island of O‘ahu. Commercial and residential developments along the 

coastline level the dune environment. Grading and landscaping alter the naturally occurring 

topography and ecology of dunes. Soil filling, in order to support nonstrand vegetation, compacts and 

traps dune sands and sand that is removed by waves cannot be replaced. This trapping causes a 

continual decrease in sand and loss of the beach environment. In addition, the continuous trampling 

by vehicles and pedestrians on the dunes causes erosion and sand movement. Vogt (1979) found that 

fewer than 10,000 pedestrians walking over sand dunes during a single season can eliminate dune 

vegetation and result in erosion. Because the beach area in Hawai‘i is attractive to both visitors and 

residents, pedestrian traffic has a significant impact on these areas. Offroad recreational vehicles also 

flatten dunes and impact strand species (Tabata 1980, University of Hawai‘i and Maui Planning 

Department 1997, DLNR 1999). 

With the purchase of the expansion area, the Service plans to restore the coastal dune ecosystem at 

the James Campbell NWR. Other dune restoration projects in Hawai‘i, such as Kama‘ole and 

Memorial Beach Park, significantly enhanced the recreational value of the beach and upland areas. 

The State of Hawai‘i Coastal Erosion Management Plan (1999) lists the restoration of dune systems 

as a major component to improve Hawai‘i’s coastal region. Dune management tools include planting 

native coastal vegetation; controlling pest plants; prohibiting vehicles (including all-terrain vehicles); 

and regulating public access. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

4-28 Chapter 4. Refuge Biology and Habitat

4.14.2 Wetlands 

Wetlands typically have three distinguishing 

characteristics: (1) hydrological conditions that 

exhibit inundation or saturation; (2) unique hydric 

soil conditions; and (3) hydrophyte vegetation that is 

adapted to wet conditions. Although wetlands 

typically share these common characteristics, the 

precise definition of a wetland varies among 

managers, landowners, and agencies. The Service 

defines wetlands as “lands transitional between 

terrestrial and aquatic system where the water table 

is usually at or near the surface or the land is 

covered by shallow water.” According to this 

definition, unvegetated areas including beaches, mudflats, and ponds can be considered wetlands. 

The USACE and EPA define wetlands as “those areas that are inundated or saturated by surface or 

groundwater at a frequency and duration sufficient to support, and that under normal circumstance do 

support, a prevalence of vegetation typically adapted for life in saturated soil conditions.” Because of 

these varied definitions, three indicators are used to assess whether an area is considered a wetland: 

hydrology, vegetation, and soils (Mitsch and Gosselink 1993, Erickson and Puttock 2006). 

In the Ko‘olauloa District, we find the following wetlands: Turtle Bay Golf Course Ponds, Kuilima 

Mitigation Pond, Punaho‘olapa Marsh, James Campbell NWR, Kahuku Aquafarms, the Airstrips 

Ponds, Kahuku Prawn Farm, Lā‘ie Aquaculture Farm/Po‘ohaili Wetlands, Hau‘ula, Punalu‘u Prawn 

Farm, Kahana State Park/Huilua Pond, and Ka‘a‘awa Wetlands. Wetland areas at the Refuge are 

especially important (in regard to waterbird and seabird habitat) due to the significant management 

activities that occur. Small remnants of the Punaho‘olapa wetland, located between the Punamanō

Unit and the Turtle Bay Resort, have also been noted as providing habitat for Hawaiian waterbirds 

(DPP 1999, Levin and ‘Onipa‘a Nā Hui Kalo 2006). 

In addition to providing habitat, wetlands are critical components of an area’s hydrology by serving 

as retention areas for flood waters. These areas help reduce the velocity of water and decrease 

erosion through sediment attenuation. Reduced siltation results in decreased turbidity of ports, 

harbors, and rivers. Another value that wetlands provide is trapping pesticides and fertilizers, such as 

phosphate and nitrates. By filtering these pollutants, wetlands improve water quality in streams and 

marine areas. Wetlands also function as a groundwater recharge area for potential human use. 

Finally, the aesthetic qualities of wetlands offer recreation and leisure areas for tourists and local 

residents (USFWS 1984, Erickson and Puttock 2006). 

Wetland management at James Campell NWR will expand to more functional acreage for 

endangered, migratory, and resident bird species with the acquisition lands. 

Punamanō wetland George Fisher/USFWS
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 4. Refuge Biology and Habitat 4-29 

4.14.3 Exposed Coral Shelf and Anchialine Pools 

The exposed coral shelf consists of coral outcropping 

or cemented calcareous sand on the island of O‘ahu. 

The coral reefs formed in shallow ocean water 

during the time the ocean was at a higher level. 

Small areas of coral outcrop are exposed on the 

ocean shore, on the coastal plains, and at the foot of 

the uplands.

Sinkholes in the coral shelf often contain anchialine 

pools in Hawai‘i. Anchialine pools are exposed 

portions of the groundwater table that have a 

subsurface connection to the sea. The Hawai‘i 

Department of Health defines anchialine pools as: 

“...coastal bodies of standing waters that have no surface connections to the ocean but display both 

tidal fluctuations and salinity ranges characteristic of fresh and brackish waters, indicating the 

presence of subsurface connections to the water table and ocean.” Anchialine pools are known occur 

in two locations on the Refuge. Additional pools may be discovered as habitat restoration projects are 

implemented in the expansion area (Maciolek 1983, Char and Balakrishna 1979, Craft et al. 2008). 

These habitats represent a unique coastal ecosystem dominated by bacterial mats, algae, emergent 

aquatic plants, mollusks, and crustaceans under natural, undisturbed conditions. Anchialine ponds are 

considered to be windows into a far more extensive subterranean brackish water ecosystem that is 

home to a unique assemblage of native species. They have the potential to harbor four species of 

endemic anchialine shrimp that are listed as candidate endangered species: Metabetaeus lohena, 

Vetericaris chaceorum, Palaemonella burnsi, and Procaris hawaiiana (Maciolek and Brock 1974). 

4.14.4 Coastal Shrubland (Scrub/Shrub) 

Scrub/shrub areas are dominated by woody 

vegetation less than 20 feet tall. The species include 

true shrubs, young trees, and trees or shrubs that are 

small or stunted because of environmental 

conditions. Approximately 22 percent of native 

Hawaiian plant species are found in this ecoregion. 

Coastal and lowland dry shrublands occur on the 

lowest leeward slopes of the higher Hawaiian 

Islands. 

Clearing and burning of lowland dry shubs began 

with the arrival of Polynesians and the last remnants 

are being destroyed today through continued development, expansion of agriculture and pasture, and 

burning. This habitat in the new expansion lands of the Refuge is currently dominated by pest species 

such as kiawe, ironwood, and koa haole (WWF 2010, Walther 2004). 

Prior to human settlement, this scrub/shrub area was dominated by a dry forest with habitat for 

several forest birds, such as honeycreepers, fly catchers, flightless rails, and other flightless birds (all 

now extinct). Hawaiian dry forests have been reduced by 90 percent. Land utilization by the early 

Exposed coral shelf Mike Silbernagle/USFWS

Scrub/shrub habitat Mike Silbernagle/USFWS
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

4-30 Chapter 4. Refuge Biology and Habitat

Polynesians damaged portions of the Hawaiian landscape, but this was nothing compared to the 

devastation that followed with the introduction of herbivores. Cattle, sheep, goats, deer and the 

European pig were introduced by early European explorers in exchange for supplies. Because there 

were no natural predators, these herbivores devastated the natural ecosystems, pushing the rate of 

extinction (flora and fauna) to alarmingly high numbers (Kimura and Nagata 1980). 

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

has been the influx of pest plants. The Refuge plans to work with partners to restore a more natural 

scrub/shrub community through removal of invasive plants and outplanting of native plants that were 

part of the historic vegetative community. Where there is suitable substrate, we will determine the 

feasibility of establishing populations of the endangered ‘Ewa hinahina and ‘akoko. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 5. Outdoor Recreation, Social, and Economic Factors 5-1 

Chapter 5. Outdoor Recreation, Social, and Economic 

Factors 

5.1 Outdoor Recreation 

The climate and geography of Hawai‘i make the islands a perfect location for outdoor recreation 

activities. The State Comprehensive Outdoor Recreation Plan (2008) was developed to guide 

planning, development, and management of these outdoor recreation resources. In addition, the eight 

regional Development Plans/Sustainable Communities Plans throughout the Island of O‘ahu identify 

local recreational goals. 

As identified in the Administration Act, as amended, the Service identifies six general wildlifedependent uses on national wildlife refuges: hunting, fishing, wildlife observation and photography, 

and EE and interpretation. Similar opportunities are available on lands managed by the State and City 

and County of Honolulu. 

This section describes recreational opportunities in the areas surrounding James Campbell NWR, as 

well as recreational activities currently occurring at the Refuge units. Islandwide recreational 

demands and potential recreational opportunities are also discussed. 

5.1.1 Federal, State, and County Recreational Parks 

State parks are administered by the Hawai‘i Department of Land and Natural Resources (DLNR), 

Division of State Parks. The State park system on O‘ahu encompasses 22 parks covering 

approximately 9,900 acres. Special use permits are required for certain activities including group 

activities, pavilion usage, meetings, weddings, shows, community events, scientific research, and 

gathering of forest products. 

The City and County of Honolulu, Department of Parks and Recreation (DPR) administers an 

additional 282 parks throughout O‘ahu comprising 5,314 acres. These parks are divided into two 

groups: Island-Based Parks and Community-Based Parks. The largest and most specialized parks 

(such as regional parks, beach and shoreline parks, beach and shoreline rights-of-way, nature parks 

and reserves, botanical gardens, golf courses, and zoological parks) are classified as Island-Based 

Parks. These parks are intended to serve the needs of all O‘ahu residents. The DPR suggests 8 acres 

of Island-Based Parks for every 1,000 persons. Community-Based Parks are smaller parks designed 

to provide recreation for more localized populations. These parks include district parks, community 

parks, neighborhood parks, and mini parks. The DPR uses a standard of 2 acres of Community-Based 

Parks for every 1,000 persons (DPP 2002, DBEDT 2009). 

There are two State parks in the Ko‘olauloa region – Mālaekahana State Recreation Area (SRA) and 

Ahupua‘a O Kahana State Park. The Mālaekahana SRA is divided into two sections. The Kalanai 

Point portion is 0.6 mile north of Lā‘ie and the Kahuku portion is 1.3 miles north of Lā‘ie. 

Swimming, bodysurfing, fishing, and beach-related activities are permitted at this park. Ahupua‘a O 

Kahana State Park is located roughly 9.3 miles south of the Refuge between the communities of 

Kāne‘ohe and Lā‘ie. Recreational activities at the park include camping, hiking, and hunting in 

designated areas during weekends and holidays (Division of State Parks 2008). 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

5-2 Chapter 5. Outdoor Recreation, Social, and Economic Factors 

5.1.2 Historic/Cultural Sites 

O‘ahu has 151 State historic sites and 68 sites on the National Register of Historic Places. These 

resources have the potential to be recreational areas for local residents and tourists. There were 57 

archaeological sites identified in the region of Ko‘olauloa during a survey in the 1930s. Many of 

these sites may have since been destroyed by urban development or agriculture activities. The sites 

closest to the Refuge are the Waikane stone at Kawela, the Kalaewila heiau at Kahuku Point, and the 

Wai‘āpuka pool at Mālaekahana. Three additional archaeological/cultural sites occur in the 

community of Lā‘ie. These include the Paeo Fishpond, Nioi Heiau, and Laniloa Point, In addition to 

designated cultural sites, iwi, which are bones and other skeletal remains from traditional Hawaiian 

burials, are known to occur in sand dunes and sandy soils along coastal areas. Three such burials 

have been documented in the vicinity of the Refuge coastline as “inadvertent discoveries”. This is 

when iwi have become exposed and discovered due to wind and water erosion (DPP 2002, 

Dougherty and Moniz-Nakamura 2005). 

The Punamanō Unit is named for a legendary spring on the Refuge. The following is an account 

reported by J. Gilbert McAllister in his book Archaeology of Oahu (1933):

The Punamanō Legend

One time when the people of Kahuku were fishing they caught a small manō (shark). 

Putting him in a calabash of water they carried him to their houses near the beach. 

Here he was cared for and put in larger and larger calabashes as he grew bigger. 

Finally having outgrown even the largest calabash that could be found, it was 

decided to place him in one of the pools of brackish water which came to be known 

as Punamanō (shark spring). 

A man and woman living near the pool became the manō’s guardians. They had 

lived in their grass huts with a breadfruit tree near the pool and taro and potato 

patches near the mountains for several years when the brother of the woman came 

to live with them. Sometime after, the man and woman went to the mountains to 

gather taro and potatoes. The brother, who was staying at home, thought that he 

would like to have some food prepared when they returned. 

He climbed the breadfruit tree and gathered several, throwing the fruit into the 

water instead of on the ground, where it would have been bruised in the fall. After 

picking enough for a few days he descended the tree and gathered most of the fruit 

from the bank. Two had floated to the middle of the pond and he could not reach 

them. Now this man knew of the shark that lived in the water, but he had frequently 

bathed in the pool and no thought of fear crossed his mind as he swam to the 

breadfruit. He did not know, however, that his sister had warned the manō not to 

allow anyone to steal breadfruit when they were gone. 

When the sister and her husband returned they could not find the brother. Neither 

was the manō to be found, but they saw the breadfruit floating in the pool and a 

reddish color to the water. They guessed what had occurred. For nearly a mile they 

followed the bloody trail until they came to the spring known as Punaho‘olapa 

(restless spring). Not only was the brother never seen, but the manō has never been 

seen to this day. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 5. Outdoor Recreation, Social, and Economic Factors 5-3 

Although not designated as a historic site, a portion of the former World War II Kahuku Army 

Airfield is located within the new expansion lands. Classified as an auxiliary field, it had a very 

short lifespan, from 1942 until it was closed in the late 1940s. Ground troops were stationed in the 

area to protect the airfield and man shoreline fortifications. It is documented that the 18th Air Base 

Group, 47th Pursuit Squadron was stationed there along with B-24s and B-17s that were based at 

Kahuku for short periods of time during World War II. Most of the buildings and support structures 

associated with the Kahuku Army Air Field have been removed. A portion of the old runway, a few 

scattered concrete pillboxes, storage bunkers, and antenna supports covered by low brush and debris 

can be found in the coastal shrubland (McKillop 2005). 

5.1.3 Ocean Recreation 

Ocean recreation in Hawai‘i supports an $800 million 

industry. The Hawai‘i Division of Boating and Ocean 

Recreation manages 14 small boat harbors, 1 deep 

draft harbor, and 4 launching facilities on the Island 

of O‘ahu. The closest launch ramp to James 

Campbell NWR is located at Kahana Bay. Hale‘iwa 

Harbor is the nearest small boat harbor. This harbor 

is located on the north shore region in Waialua Bay 

(DPP 2002). 

The primary ocean recreation activities adjacent to 

the Refuge shoreline consist of fishing from the shore 

with poles and throw nets, catching ama crabs and 

he‘e, and free-dive spearfishing. Due to rough ocean 

conditions year-round (windy, choppy surf, and shallow coral), surfing in the immediate vicinity of 

the Refuge is only an occasional activity conducted by a few individuals. 

5.1.4 Wildlife Observation, Photography, Interpretation, and Environmental 

Education 

The 18 wildlife sanctuaries and refuges on O‘ahu encompass 700 acres. Opportunities for wildlife 

observation, photography, and EE are available at most of these areas, and private tour operators 

provide interpretation at some sites. Off the coast of the Ko‘olauloa area, the public can engage in 

wildlife observation at five islets designated as State Seabird Sanctuaries. 

Wildlife observation opportunities at the Ki‘i Unit 

fluctuate with the nesting season of the waterbirds 

at the Refuge, especially ae‘o. Public entry is 

limited between February and mid-July when birds 

are nesting and fledging. Following this time 

period, Refuge staff conduct intensive habitat 

maintenance work until mid-October. Seasonal 

tours of the Ki‘i Unit are available after 

maintenance work until February 28. The public 

may access the Refuge by authorization from the 

Rough north shore surf Laura Beauregard/USFWS

Wildlife viewing at the Refuge © ucdavis.edu
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

5-4 Chapter 5. Outdoor Recreation, Social, and Economic Factors 

Refuge Manager or by participating in scheduled tours. Guided tours by volunteer docents or 

knowledgeable birders occur on Thursdays and Saturdays by reservation only. 

During the nonnesting season between 2009 and 2010, more than 1,200 individuals visited the Ki‘i 

Unit of the Refuge. Two-thirds of these visitors were students participating in EE. This wetland 

education program has been occurring at James Campbell since 1985. Biweekly scheduled tours for 

the general public brought in the other visitors during the 2009-2010 nonnesting season. General 

public tours have an average of 12 people per tour, while EE tours have slightly over 30 individuals 

per tour. 

5.1.5 Fishing 

Recreational and subsistence fishing is an important 

activity to many residents of Hawai‘i, and fishing 

tourism is also an important part of the economy. 

Recreational fishing is administered by the Division 

of Aquatic Resources within DLNR. No license is 

required for recreational saltwater fishing, which 

takes place all along the coastal areas near Kahuku. 

Typically, rod and reel poles are used; however, 

spearfishing and throw-nets are also popular. The 

most coveted reef fishes are uhu, ulua, and redfish. 

The closest public shore access locations are 1 mile 

south at Mālaekahana SRA and 4 miles north at the 

Turtle Bay Resort. 

Current access to the Refuge coastal strand occurs by two primary means: (1) By entering from either 

end of the coastline along the public shoreline corridor; and (2) by crossing James Campbell 

Company land. Private access to the shoreline has occurred over many decades by persons and their 

invited guests that held leases on that land from the James Campbell Company. These leases will be 

terminated as this land is acquired by the Service and the associated private access will end as well. 

The Kahuku Village Association also allows contolled access for fishing to the public shoreline corridor 

on lands it controls near the Kahuku Golf Course. About 200 people pay an annual “fishing club” 

membership fee for this access. 

5.1.6 Hunting 

On O‘ahu, hunting is permitted in 12 public hunting areas, covering 25,000 acres. The main species 

hunted are goats and pigs. Nonnative game birds are also hunted including the ring-necked pheasant, 

Japanese quail, three francolin species, and several dove species. Personnel engaging in hunting must 

possess a valid State of Hawai‘i hunting license. A total of 8,249 hunting licenses were issued 

throughout the State in 2008. There are few game species (game birds and pigs) within the Refuge. 

Yearlong management actions for four endangered waterbirds and their associated habitat, coupled 

with low, scattered game populations on the Refuge, preclude a public hunting program. Based on 

the potential for direct harm to endangered waterbirds, the Refuge is closed to the public for hunting 

(DBEDT 2009). 

Fishing along Refuge shoreline

Mike Silbernagle/USFWS
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 5. Outdoor Recreation, Social, and Economic Factors 5-5 

5.2 Social and Economic Conditions 

The purpose of this section is to address the local economy and social environment surrounding the 

James Campbell NWR, including population estimates and economic indicators. The Refuge is 

located within the County of Honolulu, next to the community of Kahuku. 

5.2.1 Population 

The total resident population of the Hawaiian Islands according to the 2010 census was 1,360,301. 

The Island of O‘ahu is home to 73 percent of this total. In terms of population density, Hawai‘i’s 

211.8 people per square mile in 2010 is 2.42 times the U.S. population density. According to the 

Hawai‘i Department of Business, Economic Development and Tourism (DBEDT), roughly 43 

percent of the Hawai‘i population was born outside of the State of Hawai‘i. The ethnic composition 

of the City and County of Honolulu is diverse with the majority of the population identifying 

themselves as Caucasian, Hawaiian or part Hawaiian, Japanese, Filipino, or mixed ethnic 

background. 

O‘ahu is divided into eight planning areas. Each area has a Development Plan which is adopted by 

City Council ordinance and administered by the Department of Planning and Permitting. James 

Campbell NWR is located within the Ko‘olau Loa planning area. As of the census of 2000, there 

were 2,097 people, 509 households, and 401 families residing in Kahuku. Pacific Islanders lead the 

racial makeup with 27.28 percent, 26.85 percent Asian, 11.06 percent White, 0.29 percent Black or 

African American, 0.14 percent Native American, 1.05 percent from other races, and 33.33 percent 

from two or more races. A total of 8.63 percent of the population is Hispanic or Latino of any race. 

(HCDA 2005, DBEDT 2010). 

There were 509 households out of which 43.2 percent had children under the age of 18 living with 

them, 59.3 percent are married couples living together, 14.3 percent had a female householder with 

no husband present, and 21.2 percent were nonfamilies. The average household size was 3.96 and the 

average family size was 4.63. The median income for a household in 2000 was $39,135, in stark 

contrast to the islandwide median income of $70,010 (quickfacts.census.gov). 

5.2.2 Education 

Educational attainment is slightly higher on the island of O‘ahu compared to the rest of the State. In 

2000, approximately 84.8 percent of the O‘ahu population 25 years and over had received a high 

school diploma. Furthermore, approximately 27.9 percent reported to have a Bachelor’s degree or 

higher. The State averages during the same year were 84.6 and 26.2 percent, respectively (DBEDT 

2010). 

Within the University of Hawai‘i system (UH) are five community colleges and two universities on 

O‘ahu. In 2008, enrollment at UH Mānoa was 20,169 and at the West O‘ahu Campus was 

1,140 students. Approximately 21,169 students were enrolled in the community colleges throughout 

O‘ahu. Total enrollment in private universities on O‘ahu (including Brigham Young, Hawai‘i Pacific, 

and Chaminade) in 2008 was 13,293. Brigham Young University is just 3 miles south of the Refuge 

with an enrollment of 2,500 students who represent over 70 different countries and cultures from the 

Pacific Rim, the U.S. mainland, and other parts of the world. (DBEDT 2009). 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

5-6 Chapter 5. Outdoor Recreation, Social, and Economic Factors 

5.2.3 Economy 

Hawai‘i ’s economy grew at an annual rate of 4.1percent 2001-2006. Including the economic 

recession of 2008 and 2009, the economic growth rate in Hawai‘i 2000-2009 was 2.3 percent per 

year. Hawai‘i is economically dynamic with diversified agriculture and manufacturing; strategically 

important to the global defense system of the nation; a Pacific Basin transportation center; and a 

major tourism destination. The health of the State’s economy depends significantly on conditions in 

the overall U.S. economy and key international economies, especially Japan. State taxes are collected 

under a centralized tax system. The chief sources of the State’s revenue are a general excise tax, 

individual income taxes, and Federal grants-in-aid. The second largest source of income in Hawai‘i is 

the Federal government, primarily through defense expenditures (DBEDT 2010). 

Tourism is Hawai‘i’s largest industry with the majority of visitors coming from the U.S. mainland, 

Canada, Australia, and countries of the Far East, particularly Japan. Most visitors to Hawai‘i travel 

by air. The Honolulu International Airport on O‘ahu; General Lyman Field on Hawai‘i; and the 

Kahului Airport on Maui, are the major civilian airports capable of serving large-jet traffic. There are 

several smaller airports among the islands and a number of small private airfields and military 

airports throughout the State. Oceanic passenger ships also carry visitors through Honolulu, cruise 

ships travel from California to Hawai‘i and Tahiti to Hawai‘i, and there is also an interisland cruise 

line. 

Hawai‘i’s mild, year-round climate sustains many different types of agriculture, generating $2.9 

billion to the State's annual economy and directly and indirectly providing 42,000 jobs. The 

Polynesian voyagers traveled to Hawai‘i with plants such as taro, bananas, and other staples to 

sustain themselves. Agriculture began with small farms covering the islands, growing everything 

from sweet potato to rice. Fishponds were created along the coasts to raise fish and other seafood. 

The plantation era brought decades of the sugar and pineapple industries, expanding over thousands 

of acres of prime agricultural lands. Now, with the decline of the sugar industry, these agricultural 

lands are returning to a new era of small farms growing diversified agricultural products. Crops such 

as specialty fruits, coffee, macadamia nuts, flowers and foliage not only provide fresh produce and 

flowers to local markets, but also have become major exports to destinations around the world. The 

early fishponds have evolved into high-tech aquaculture ventures, farming varieties of fish, shrimp, 

lobster, abalone, and seaweed (HDA 2009). 

Hawai‘i has several hundred companies engaged in diversified manufacturing. Heavy-manufacturing 

plants, using raw materials for the most part imported from the U.S. mainland, include an oil refinery 

that produces a variety of petroleum products and chemical compounds, a steel mill manufacturing 

reinforcing bars; several cement plants, a concrete-pipe plant, and an aluminum-extrusion plant. Most 

building lumber is imported from the mainland. A number of garment manufacturers produce printed 

fabrics and apparel marketed locally, nationally, and abroad. 

The Hawai‘i film and movie industry is booming, with production expenditures expected to reach 

$391 million for 2010. The State provides competitive tax incentives, the only State-owned and 

operated film studio in the country and a growing list of production facilities, a well-established onestop process for State film permits, and a film-friendly government and community. The DBEDT 

estimates that the amount of economic activity generated by the industry will total $606.5 million for 

the year 2011. The jump in production expenditures is being driven by 10 motion pictures as well as 

the final season of TV’s “Lost” and the start of 2 network shows, “Hawai‘i Five-0” and “Off the 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Chapter 5. Outdoor Recreation, Social, and Economic Factors 5-7 

Map”. There have been a number of national and international commercials shot here, along with 

episodes for television series and a mini-series from Japan (DBEDT 2010). 

Ocean-surface transportation is critical to Hawai‘i, and Honolulu Harbor is the primary shipping 

center. A large percentage of the cargo ships traverse between Hawai‘i and California ports, a few 

between Hawai‘i and the East Coast of the U.S. via the Panama Canal, and others from western 

Pacific ports. Around-the-world passenger ships carry visitors through Honolulu, and there is an 

inter-island luxury cruise line. Tug-pulled barges and small freighters transport goods from Honolulu 

to the outer islands, returning with agricultural crops and livestock. 

A major concern is the high cost of living, due in large part to the dependence on imports. The State 

imports 85 percent of the food consumed in Hawai‘i. Transportation costs are included in the prices 

of nearly all consumer goods. As the population increases, housing grows increasingly difficult to 

acquire, and it is disproportionately expensive when compared with housing costs in many of the 

mainland States. Building materials, most of which are imported, are expensive. Residential land is 

limited and highly priced, since much of the property is owned by corporations and trusts. More than 

half the land in the State is owned by private individuals or corporations, although the State itself, 

holding more than one-third of the land, is the largest single landowner. The Federal government 

owns one-sixth of the land in the State. State and county governments are major employers 

(Britannica 2010). 

5.2.4 Refuge Contribution 

The exact economic contribution of visitors to the James Campbell NWR has not been calculated, 

although estimations have been made for other refuges in Hawai‘i. Carver and Caudill (2007) found 

that Hakalau Forest NWR had total annual recreational expenditures of $56,400 from 1,323 visitors. 

Similar to the James Campbell NWR, birding and other wildlife observations are the main attraction 

at the Hakalau Forest NWR. Based on this estimate, it is likely that the James Campbell NWR 

provides a similar contribution. Based on Fiscal Year 2011, the projected budget for the James 

Campbell NWR is $657,912, of which $415,401 is for employee salaries. The remaining $242,511 is 

for local expenditures. 

In addition to recreational expenditures, the Refuge contributes money to the local economy through 

the Refuge Revenue Sharing Act of 1978 (16 U.S.C. 715s). This Act authorizes Federal payments to 

be transferred to the County of Honolulu annually in lieu of discontinued taxation of private 

property. The amount compensated is approximately 0.75 percent of the fair market value of fee 

lands. In 2009, $3,443 was paid to the City and County of Honolulu for 222 acres owned in fee title 

at James Campbell NWR. As we acquire more parcels within the approved boundary, these payments 

will increase accordingly, subject to congressional appropriations. 

As public use facilities are developed, visitors to the north shore will be attracted to the Refuge and 

augment business revenue in Kahuku and local communities. 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

5-8 Chapter 5. Outdoor Recreation, Social, and Economic Factors 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix A. Species List A-1

Appendix A. James Campbell NWR Species List

Common Name Scientific name Hawaiian Name

Mammals

Black rat Rattus rattus ‘Iole

Cat Felis catus Pōpoki

Dog Canis familiaris ‘Īlio

Hawaiian monk seal Monachus schauinslandi ‘Īlio-holo-i-ka-uaua

Hawaiian hoary bat Lasiurus cinereus semotus ‘Ōpe‘ape‘a

House mouse Mus musculus ‘Iole

Indian mongoose Herpestes auropunctatus Manakuke

Norway rat Rattus norvegicus ‘Iole

Pig Sus scrofa Pua‘a

Polynesian rat Rattus exulans ‘Iole

Marine Reptiles

Green turtle Chelonia mydas Honu

Fish

Acute-jawed mullet Neomyxus leuciscus

Black chin tilapia Sarotherodon melanotheron

Cuban molly Limia vittata

Engel's mullet Moolgarda engeli

Giant trevally (papio) Caranx Ignobilis Ulua au kea

Gracile lizardfish Saurida gracilis

Milkfish Chanos chanos Awa

Molly Poecilia hybrid sp.

Mullet Mugil cephalus ‘Ama‘ama

Sailfin molly Poecilia latipinna

Shortfin molly Poecilia mexicana

Tilapia Oreochromis mossambicus

Tilapia Tilapia zillii

Western mosquitofish Gambusia affinis I‘a makika

Invertebrates, aquatic

Anchialine snapping shrimp Metabetaeus lohena 

Asian clam Corbicula fluminea

Clam Corbicula sp.

Crab Thalamita edwardsi

Crayfish Procambarus clarkii ‘Ōpae pake

Crenate swimming crab Thalamita crenata

Feeble shrimp Palaemon debilis ‘Ōpae huna

Freshwater prawn Macrobrachium rosenbergii

Hawaiian red shrimp Halocaradiana rubra ‘Ōpae‘ula

Limpet Pyrgophorus coronatus ‘Opihi

Mud crab Scylla serreta

Invertebrates, terrestrial

Asian tiger mosquito Aedes albopictus

Cane spider Heteropoda venatoria

Centipede Scolopendra subspinipes Kanapī
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

A-2 Appendix A. Species List 

Common Name Scientific name Hawaiian Name

Lesser brown scorpion Isometrus maculatus Kopiana

Rambur’s forktail damselfly Ischnura ramburii

Southern house mosquito Culex quinquefasciatus

Waterstrider Halobates hawaiiensis

Reptiles and Amphibians

American bullfrog Rana catesbeiana

Blind snake Ramphotyphlops braminus

Cane toad Bufo marinua Poloka

Common house gecko Hemidactylus frenatus Mo‘o ‘alā

Green anole lizard Anolis carolinensis porcatus

Garden skink Lampropholis delicata

Birds

Hawaiian Waterbirds

 Black-crowned night-heron Nycticorax nycticorax ‘Auku‘u

 Hawaiian coot Fulica alai ‘Alae ke‘oke‘o

 Hawaiian duck Anas wyvilliana Koloa maoli

 Hawaiian moorhen Gallinula chloropus sandvicensis ‘Alae ‘ula

 Hawaiian Stilt Himantopus mexicanus knudseni Ae‘o

Shorebirds

 Bar-tailed godwit Limosa lapponica 

 Black-bellied plover Pluvialis squatarola

 Bristle-thighed curlew Numenius tahitiensis Kioea

 Common snipe Gallinago gallinago

 Dunlin Calidris alpina

 Greater yellowlegs Tringa melanoleuca

 Killdeer Charadrius vociferus

 Least sandpiper Calidris minutilla

 Lesser yellowlegs Tringa flavipes

 Long-billed dowitcher Limnodromus scolopaceus

 Marsh sandpiper Tringa stagnatilis 

 Pacific golden-plover Pluvialis fulva Kōlea

 Pectoral sandpiper Calidris melanotos

 Red knot Calidris canutus

 Ruddy turnstone Arenaria interpres ‘Akekeke

 Ruff Philomachus pugnax

 Sanderling Calidris alba Hunakai

 Semipalmated plover Charadrius semipalmatus

 Sharp-tailed sandpiper Calidris acuminata

 Short-billed dowitcher Limnodromus griseus

 Semipalmated sandpiper Calidris pusilla

 Solitary sandpiper Tringa solitaria

 Spotted sandpiper Actitis maclaria

 Stilt sandpiper Calidris himantopus

 Wandering tattler Heteorscelus incanus ‘Ūlilī

 Western sandpiper Calidris mauri

 Whimbrel Numenius phaeopus
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix A. Species List A-3

Common Name Scientific name Hawaiian Name

 Wilson’s phalarope Phalaropus tricolor

Seabirds & Gulls

 Arctic tern Sterna paradisaea

 Black-footed albatross Phoebastria nigripes ‘Ka‘upu

 Bonaparte's gull Chroicocephalus philadelphia

 Caspian tern Hydroprogne caspia

 Common tern Sterna hirundo

 Franklin's gull Laris pipixcan

 Glaucous-winged gull Larus glaucescens

 Great frigatebird Fregata minor ‘Iwa

 Gull-billed tern Gelochelidon nilotica

 Herring gull Larus argentatus

 Laughing gull Leucophaeus atricilla

 Laysan albatross Phoebastria immutabilis Mōlī

 Least tern Sternula antillarum

 Red-footed booby Sula sula rubripes ‘Ā

 Red-tailed tropicbird Phaethon rubricauda Koa‘e‘ula

 Ring-billed gull Larus delawarensis

 Sandwich tern Thalasseus sandvicensis

 Thayer’s gull Larus thayeri

 Wedge-tailed shearwater Puffinus pacificus ‘Ua‘u kani

 Western gull Larus occidentalis

 White-tailed tropicbird Phaethon lepturus dorotheae Koa‘e kea

 White tern Gygis alba Manu o Kū

Herons & Ibis

 Cattle egret Bubulcus ibis

 Great blue heron Ardea herodias

 Snowy egret Egretta thula

 White-faced ibis Plegadis chihi

Geese & Ducks

 American widgeon Anas americana

 Black brant Branta bernicla 

 Blue-winged teal Anas discors

 Bufflehead Bucephala albeola

 Canvasback Aythya valisineria

 Cinnamon teal Anas cyanoptera

 Common merganser Mergus merganser

 Eurasian widgeon Anas penelope

 Cackling goose Branta hutchinsii

 Canada goose Branta canadensis

 Gadwall Anas strepera

 Green-winged teal Anas carolinensis

 Greater scaup Aythya marila

 Greater white-fronted goose Anser albifrons

 Lesser scaup Aythya affinis

 Mallard Anas platyrhynchos
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

A-4 Appendix A. Species List 

Common Name Scientific name Hawaiian Name

 Northern pintail Anas acuta Koloa māpu

 Northern shoveler Anas clypeata Koloa mohā

 Redhead Aythya americana

 Ring-necked duck Aythya collaris

 Tufted duck Aythya fuligula

Diurnal Raptors

 Northern harrier Circus cyaneus

 Osprey Pandion haliaetus

 Peregrine falcon Falco peregrinus

Upland Game Birds

 Common peafowl Pavo cristatus Pīkake

 Guinea fowl Numida meleagris

 Ring-necked pheasant Phasianus colchicus

Doves

 Mourning dove Zenaida macroura

 Rock dove Columba livia

 Spotted dove Streptopelia chinensis

 Zebra dove Geopelia striata

Parrots

 Sulphur-crested cockatoo Cacatua galerita

Owls

 Barn owl Tyto alba

 Hawaiian short-eared Owl Asio flammeus sandwichensis Pueo

Bulbuls

 Red-vented bulbul Pycnonotus cafer

Bush-warblers

 Japanese bush-warbler Cettia diphone

 White-rumped shama Copsychus malabaricus

Mynas

 Common myna Acridotheres tristis

White-eyes

 Japanese white-eye Zosterops japonicus

Cardinals

 Northern cardinal Cardinalis cardinalis

 Red-crested cardinal Paroaria coronata

Finches

 House finch Carpodacus mexicanus

Sparrows

 House sparrow Passer domesticus

 Java sparrow Padda oryzivora

Waxbills & Mannikins

 Chestnut munia Lonchura atricapilla

 Common waxbill Estrilda astrild

 Nutmeg mannikin Lonchura punctulata

 Red avadavat Amandava amandava
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix A. Species List A-5

Native Plant Species

Scientific Name Common Name Hawaiian Name

Aizoaceae

Sesuvium portulacastrum Sea purslane ‘Ākulikuli

Astererace

Lipochaeta lobata Daisy Nehe

Boraginaceae

Heliotropium anomalum var. argenterum Hinahina Hinahina

Heliotropium curassavicum Seaside heliotrope Kīpūkai

Chenopodiaceae 

Chenopodium oahuense Aheahea ‘Āheahea

Convolvulaceae

Ipomoea imperati Beach morning glory Hunakai

Ipomoea indica Koali‘awa Koali‘awa

Ipomoea pes-carprae Beach morning glory Pōhuehue

Jaquemontia ovalifolia Oval-leafed clustervine Pā‘ūohi‘iaka

Cyperaceae

Bolboschoenus maritimus Kaluha Kaluhā

Mariscus javanicus Marsh cyprus ‘Ahu‘awa

Cyperus polystachyos Manyspike flatsedge

Schoenoplectus lacustris Great bulrush ‘Aka‘akai

Fimbristylis cymosa Sand Bulrush Mau‘u

Euphorbiaceae

Chamaesyce degeneri Beach sandmat ‘Akoko

Fabaceae

Erythrina sandwicensis Hawaiian coral tree Wiliwili

Vigna marina Beach pea Nanea

Malvaceae

Gossypium tomentosum Hawaiian cotton Mao

Sida fallax Yellow ilima ‘Ilima

Thespesia populnea Milo Milo

Menispermaceae

Cocculus trilobus Huehue Huehue

Nyctaginaceae

Boerhavia repens Alena Alena 

Onagraceae

Ludwigia octovalvis Primrose willow Kāmole

Plumbaginaceae

Plumbago zeylandica ‘Ilie‘e ‘Ilie‘e

Pandanaceace

Pandanus tectorius Screw pine Hala

Poaceae

Sporobolus virginicus Beach dropseed ‘Aki‘aki

Santalaceae

Santalum ellipticum Coastal sandalwood ‘Iliahialo‘e

Scientific Name Common Name Hawaiian Name
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

A-6 Appendix A. Species List 

Scrophulariaceae

Bacopa monnieri Water hyssop ‘Ae‘ae

Solanaceae 

Lycium sandwicense Hawaiian desert-thorn ‘Ohelo kai

Solanum americanum Popolo Popolo

Sterculiaceae

Waltheria indica ‘Uhaloa ‘Uhaloa

Verbanaceae

Vitex rotundifolia Beach vitex Pōhinahina

Scaevola taccada Beach naupaka Naupaka kahakai

* The taxonomy and nomenclature of the plants are in accordance with Wagner et al. (1999).

Nonnative Plants

Scientific Name Common Name Hawaiian Name

Abutilon grandifolium Hairy abutilon

Achyranthes aspera Achyranthes

Alternanthera pungens Khaki weed 

Amaranthus viridis Slender amaranth

Amaranthus spinosus Spiny amaranth Pakai kuku

Anagallis arvensis Scarlet pimpernel

Asystasia gangetica Chinese violet 

Atriplex semibacatta Australian saltbush

Atriplex suberecta Saltbush

Batis maritima Saltwort, pickleweed, batis ‘Akulikuli

Bidens alba Beggartick

Boerhavia coccinea Red spiderling

Blutaparon vermiculare Silverhead

Brachiaria mutica California grass 

Casuarina equisetifolia Ironwood

Cenchrus echinatus Sandbur

Centaurium erythraea Bitter herb

Centella asiatica Asiatic pennywort

Chamaesyce prostrata Prostrate spurge

Chamaesyce hyssopifolia Small hyssopleaf sandmat

Chloris barbata Swollen finger grass

Coccoloba uvifera Sea grape

Cordia subcordata Sea trumpet Kou

Casuarina equisetifolia Ironwood

Coccinia grandis Ivy gourd

Cocos nucifera Coconut palm Niu

Commelina diffusa Dayflower Honohono

Cordyline fruticosa Ti Kī 

Cynodon dactylon. Bermuda grass

Cyperus sp. Sedge

Cyperus alterniflorius Umbrella sedge

Scientific Name Common Name Hawaiian Name

Cyperus difformis Variable flatsedge
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix A. Species List A-7

Echinochloa sp. Wild millet, millet

Eleocharis geniculata Spikerush, bent spikerush

Eragrostis sp. Lovegrass Kawelu

Fimbristylis milliacea Grass-like fimbry

Fimbristylis ferruginea West Indian fimbry

Fimbristylis dichotoma Forked fimbry

Lantana camera Lantana

Leonotis nepetaefolia Lion’s ear

Leptochloa uninervia Sprangletop

Leucana leucocephala White leadtree Koa haole

Macaranga tanarius Macaranga

Mimosa pudica Sensitive mimosa Hilahila

Nymphaea ssp. Water lily

Panicum maximum Guinea grass

Paspalum disticum Knot-grass

Plantago major Broad-leafed plantago Laukahi

Pluchea x fosbergii Marsh fleabane 

Pluchea indica Indian marsh fleabane 

Pluchea symphytifolia Sourbush

Prosopis pallida Mesquite Kiawe

Rhizophora mangle Red mangrove

Ricinus communis Castor bean

Schinus terebinthifolius Christmas berry

Schlefflera actinophylla Octopus tree

Schoenoplectus californicus California bulrush

Solanum torvum Turkey berry

Solanum linnaeum Apple of Sodom

Sonchus oleraceus Sow thistle

Terminalia catappa False kamani

Tournefortia argentea Tree heliotrope

Typha sp. Cattail

Verbesina enchiloides Golden crownbeard

Xanthium strumarium Cocklebur Kīkānia
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

A-8 Appendix A. Species List 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

 

Appendix B. Appropriate Uses and Compatibility Determinations B-1 

Appendix B. Compatibility Determinations and Appropriate Use 

Findings 

B.1 Introduction 

B.1.1 Uses Evaluated 

The following section includes full CDs for all Refuge uses that are required to be evaluated at this 

time. According to Service policy, CDs will be completed for all uses proposed under a CCP that 

have been determined to be appropriate. Existing wildlife-dependent recreational uses must also be 

reevaluated and new CDs prepared during development of a CCP. According to the Service’s 

compatibility policy, uses other than wildlife-dependent recreational uses are not explicitly required 

to be reevaluated in concert with preparation of a CCP, unless conditions of the use have changed or 

unless significant new information relative to the use and its effects have become available or the 

existing CDs are more than 10 years old. However, the Service planning policy recommends 

preparing CDs for all individual uses, specific use programs, or groups of related uses associated 

with the proposed action. The following CDs were included in the public review draft of the CCP/EA 

and presented as approved in this document. 

Table B.1 Summary of Compatibility Determinations. 

Refuge Use Page Compatible? Year Due for 

Reevaluation

Wildlife Observation, Interpretation, and 

Photography 

B-5 yes 2026 

Environmental Education (EE) B-11 yes 2026 

Research, Scientific Collecting, and Surveys B-17 yes 2021 

B.1.2 Compatibility – Legal and Historical Context 

Compatibility is a tool refuge managers use to ensure that recreational and other uses do not interfere 

with wildlife conservation, the primary focus of refuges. Compatibility is not new to the Refuge 

System and dates back to 1918 as a concept. As policy, it has been used since 1962. The Refuge 

Recreation Act of 1962 directed the Secretary of the Interior to allow only those public uses of 

Refuge lands that were “compatible with the primary purposes for which the area was established.” 

Legally, Refuges are closed to all public uses until officially opened. Regulations require that 

adequate funds be available for administration and protection of refuges before opening them to any 

public uses. However, wildlife-dependent recreational uses (hunting, fishing, wildlife observation 

and photography, EE and interpretation) are to receive enhanced consideration and cannot be rejected 

simply for lack of funding resources unless the refuge has made a concerted effort to seek out funds 

from all potential partners. Once found compatible, wildlife-dependent recreational uses are deemed 

the priority public uses at the refuge. If a proposed use is found not compatible, the refuge manager is 

legally precluded from approving it. Economic uses that are conducted by or authorized by the refuge 

also require CDs. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

B-2 Appendix B. Appropriate Uses and Compatibility Determinations 

Under compatibility policy, uses are defined as recreational, economic/commercial, or management 

use of a refuge by the public or a non-Refuge System entity. Uses generally providing an economic 

return (even if conducted for the purposes of habitat management) are also subject to CDs. The 

Service does not prepare CDs for uses when the Service does not have jurisdiction. For example, the 

Service may have limited jurisdiction over Refuge areas where property rights are vested by others; 

where legally binding agreements exist; or where there are treaty rights held by tribes. In addition, 

aircraft over-flights, emergency actions, some activities on navigable waters, and activities by other 

Federal agencies on “overlay Refuges” are exempt from the compatibility review process. 

New compatibility regulations were adopted by the Service in October 2000. The regulations require 

that a use must be compatible with both the Refuge System mission and the purpose(s) of the 

individual Refuge. This standard helps to ensure consistency in application across the Refuge 

System. The Administration Act also requires that CDs be in writing and that the public have an 

opportunity to comment on most use evaluations. 

The Refuge System mission emphasizes that the needs of fish, wildlife, and plants must be of 

primary consideration. The Improvement Act defined a compatible use as one that “. . . in the sound 

professional judgment of the Director, will not materially interfere with or detract from the 

fulfillment of the mission of the System or the purposes of the Refuge.” Sound professional judgment 

is defined under the Improvement Act as “. . . a finding, determination, or decision, that is consistent 

with principles of sound fish and wildlife management and administration, available science and 

resources . . .” Compatibility for wildlife-dependent uses may depend on the level or extent of a use. 

Court interpretations of the compatibility standard have found that compatibility is a biological 

standard and cannot be used to balance or weigh economic, political, or recreational interests against 

the primary purpose of the refuge (Defenders of Wildlife v. Andrus). 

The Service recognizes that CDs are complex. For this reason, refuge managers are required to 

consider “principles of sound fish and wildlife management” and “best available science” in making 

these determinations (House of Representatives Report 105-106). Evaluations of the existing uses on 

the James Campbell NWR are based on the professional judgment of Refuge and planning personnel 

including observations of Refuge uses and reviews of relevant scientific literature. 

B.1.3 Appropriate Use Findings 

The Appropriate Refuge Uses Policy outlines the process that the Service uses to determine when 

general public uses on refuges may be considered. Priority public uses previously defined as wildlifedependent uses (hunting, fishing, wildlife observation and photography, and EE and interpretation) 

under the Improvement Act are generally exempt from appropriate use review. Other exempt uses 

include situations where the Service does not have adequate jurisdiction to control the activity and 

refuge management activities. In essence, the Appropriate Use policy, 603 FW 1 (2006), provides 

refuge managers with a consistent procedure to first screen and then document decisions concerning 

a public use. When a use is determined to be appropriate, a refuge manager must then decide if the 

use is compatible before allowing it on a refuge. The policy also requires review of existing public 

uses. During the CCP process, the refuge manager evaluated all existing and proposed Refuge uses at 

James Campbell NWR using the following guidelines and criteria as outlined in the appropriate use 

policy: 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

 

Appendix B. Appropriate Uses and Compatibility Determinations B-3 

 Do we have jurisdiction over the use? 

 Does the use comply with applicable laws and regulations (Federal, State, tribal and local)? 

 Is the use consistent with applicable Executive orders and Department and Service policies? 

 Is the use consistent with public safety? 

 Is the use consistent with goals and objectives in an approved management plan or other 

document? 

 Has an earlier documented analysis not denied the use or is this the first the use has been 

proposed? 

 Is the use manageable within available budget and staff? 

 Will this be manageable in the future within existing resources? 

 Does the use contribute to the public’s understanding and appreciation of the refuge’s natural 

or cultural resources, or is the use beneficial to the refuge’s natural or cultural resources? 

 Can the use be accommodated without impairing existing wildlife-dependent recreational 

uses or reducing the potential to provide quality, compatible, wildlife dependent recreation 

into the future? 

Using this process and these criteria, and as documented on the following pages, the Refuge Manager 

determined the following uses are appropriate, and directed that a CD be completed for these uses: 

research, scientific collecting, and surveys. The Refuge Manager determined the following uses are 

not appropriate: sea asparagus farming and private aircraft operations. 

Table B.2. Summary of Appropriate Use Findings. 

Refuge Use Page Appropriate?

Research, Scientific Collecting, and Surveys B-24 yes 

Commercial Operation, Sea Asparagus Farming B-27 no 

Private Aircraft Operations B-31 no 

B.1.4 References 

Compatibility regulations, adopted by the Service in October 2000: 

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

Defenders of Wildlife v. Andrus (Ruby Lake Refuge I). 11 Envtl. Rptr. Case 2098 (D.D.C. 1978), 

p. 873. 

Fish and Wildlife Service. 2010. James Campbell National Wildlife Refuge: Draft Comprehensive 

Conservation Plan and Environmental Assessment. 109 p. + Appendices 

House of Representatives Report 105-106 (on Improvement Act): 

http://refuges.fws.gov/policyMakers/mandates/HR1420/part1.html 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

B-4 Appendix B. Appropriate Uses and Compatibility Determinations 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

 

Appendix B. Appropriate Uses and Compatibility Determinations B-5 

B.2 Compatibility Determination for Wildlife Observation, Interpretation,

and Photography 

Refuge Name(s): James Campbell National Wildlife Refuge 

 

County and State: Honolulu County, Hawai‘i 

Establishing and Acquisition Authority(ies):

James Campbell NWR was established in 1976 under the authority of the: 

 Fish and Wildlife Coordination Act of 1956, as amended (16 U.S.C. 742a – 742j) 

 Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1544) 

 James Campbell National Wildlife Refuge Expansion Act of 2005, Pub. Law 109-225 (16 

U.S.C. 668dd) 

Refuge Purpose(s):

“... to conserve (A) fish or wildlife which are listed as endangered species or threatened species .... or 

(B) plants ...”. 

National Wildlife Refuge System Mission: 

“The mission of the National Wildlife Refuge System (Refuge System) is to administer a national 

network of lands and waters for the conservation, management, and where appropriate, restoration of 

the fish, wildlife, and plant resources and their habitats within the United States for the benefit of 

present and future generations of Americans” (Administration Act). 

Description of Use(s): 

The National Wildlife Refuge System Administration Act of 1966 (16 U.S.C. 668dd-668ee), as 

amended by the National Wildlife Refuge System Improvement Act of 1997 identifies wildlife 

observation, interpretation, and photography (WO/I/P) among wildlife-dependent public uses which, 

when compatible with the purpose(s) of the refuge, are priority public uses and receive special 

consideration in planning for and management of the Refuge System. This CD addresses the Wildlife 

Observation/Interpretation/Photography program, as well as modest new increases and opportunities 

being provided on both existing refuge lands and the expansion lands planned for addition to the 

Refuge, once acquired. These activities are proposed to continue while acquisition of new Refuge 

lands is completed and a subsequent Visitor Services Plan (VSP) is developed (within 5 years of final 

land acquisition). This VSP will identify and evaluate a range of alternatives and options for new 

refuge visitor facilities and uses all across the expanded Refuge lands including the location of roads, 

parking area, overlooks, trails and possible construction of a visitor center. An updated CD, if 

needed, will be prepared in conjunction with this plan and all activities identified in this CD are 

subject to review and change at that time. 

Interpretation is the communication of information about, or the explanation of, the nature, origin, 

and purpose of historical, natural, or cultural resources, objects, sites and phenomena using various 

methods. The docent-guided tour program provides interpretive information about the identity and 

life histories of both endangered and migratory birds viewed along the tour route. Scheduled from 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

B-6 Appendix B. Appropriate Uses and Compatibility Determinations 

October 15-February 28 of each year, the tours last about 90 minutes and follow a designated route 

along dikes around a portion of the Refuge wetlands. 

Wildlife observation, interpretation, and photography are considered together in this CD because 

they are considered to be wildlife-dependent, nonconsumptive uses and many elements of these 

programs are similar. Activities would be allowed as described below: 

 On designated portions of Ki‘i Unit at designated dates, times and routes; and 

 During daylight hours on the Refuge coastal area within the beach transit corridor only. 

The Ki‘i Unit is closed to general public entry and use and the only access to the unit is through a 

coded automatic gate. Under this CD the current docent guided tour program would continue to be 

conducted on Thursdays and Saturdays providing WO/I/P opportunities up to 42 days per season for 

approximately 820 total visitors. Trained docents provide information about the identity and life 

histories of both endangered and migratory birds viewed along the tour route. In addition to these 

docent-guided tours, new individual self-guided tours will be initiated during this same season to 

allow additional visitors in small parties (1-5 of the same party) to view and photograph wildlife at 

their own pace, not in a group. This will be of particular benefit to persons wishing to photograph 

wildlife who will not have to continually move to stay with a larger group, as in the guided tours. 

While providing limited new WO/I/P opportunities this new self-guided program is small in scale by 

necessity due to the extremely small size of the Ki‘i Unit, very limited public access and facilities, 

the need to limit disturbance to wildlife and prevent scheduling conflicts with both guided tours and 

EE tours that occur in this same area during this same season. Both guided and self-guided tours will 

be conducted under a reservation system. 

Except when and where closed for protection of individual ‘īlio-holo-i- ka-uaua and/or honu, WO/I/P 

use will be permitted in the State-defined “beach access corridor” (Hawai‘i Revised Statutes §115-5) 

by public access routes at either end of the Refuge boundary. The designated open portion of the 

Refuge extends to the highest reach of the highest wash of the waves, up to the first line of naupaka 

and tree heliotrope vegetation that is well established all along the dunes. Refuge lands mauka 

(inland) of this line will remain closed to the public. 

Availability of Resources:

Category and Itemization 

One-time 

$ 

Annual 

$/yr 

Administration and management: $0 $800

Maintenance: $0 $1,400

Monitoring costs: $0 $3,600

Special equipment, facilities, or improvements: $2,000 $1,800

Offsetting revenues: $0 $0

The Refuge has sufficient budget and staff to manage this use. 

Anticipated Impacts of the Use(s): 

Short-term impacts: 

Ki‘i Unit: The continuation of the current guided tours on the Ki‘i Unit will not produce any new 

short-term impacts. The current program has been in place for many years and through observation 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

 

Appendix B. Appropriate Uses and Compatibility Determinations B-7 

the impacts to wildlife are well known and understood. The primary short-term impact is to 

individual wildlife as birds may flush, swim away or seek cover and hide in vegetation as tour groups 

pass by. These impacts are minimized by the tours being limited by following designated times, 

routes and numbers of participants. The additional new self-guided tours will result in only a small 

increase in activity over the current level of guided tours and EE programs combined that occur in 

generally the same area and during the same season. This additional activity will result in only a 

very small increase in the impacts already described, i.e., temporary disturbance to wildlife. 

Refuge coastal dunes: Currently a number of people access the coastal area by entering along the 

shoreline at either end of the property (Refuge expansion land) or by crossing over the adjacent 

private land (James Campbell Company) by either permission or trespassing. The public transit 

corridor along the shoreline is indistinguishable for most users from the adjacent private property due 

to the similarity in appearance (beach), immediate close proximity and lack of any identifiers such as 

signs or fences. Consequently current uses on the shoreline occur without regard to property 

boundaries. Under this CD, once acquired, visitor uses described as WO/I/P will continue and be 

allowed on the Refuge portion of the coastal area up to the naupaka line of vegetation. The level of 

use will actually decline in the short-term as public access along the shoreline will not change and 

should remain about the same but private access across James Campbell Company land, once 

acquired by the Refuge, will be not be allowed. 

The primary short-term impacts from this use are the possible disturbance to wildlife, primarily ‘īlioholo-i- ka-uaua and honu that may haul out on shore. Coordination and cooperation with wildlife 

monitoring groups should reduce disturbance to these individual animals due to closer monitoring. 

A particular concern is nighttime activity which can distract or disorient wildlife, particularly nesting 

turtles (which come ashore at night) or nesting and fledgling seabirds. To minimize the risk of this 

impact occurring, access to the Refuge portion of the shoreline will be open to public use such as 

WO/I/P only during daylight hours (1⁄2-hour before sunrise to 1⁄2-hour after sunset). 

Long-term impacts: 

Ki‘i Unit - As additional lands are acquired and added to the Refuge, new opportunities for WO/I/P 

will become available. These new opportunities will be identified and evaluated in the preparation of 

a VSP. As new opportunities and facilities necessary to conduct these uses are developed, the 

existing uses on the Ki‘i Unit will be re-evaluated and likely phased out or reduced. Therefore longterm impacts (occasional temporary disturbance to wildlife) of the use described in this CD are 

expected to diminish over time and will be re-evaluated for uses proposed under any new CD in 

conjunction with the preparation of the VSP. 

Refuge coastal dunes - Visitor use in this habitat is not expected to increase and should decrease 

slightly due to stricter control of access. This could result in a slight decrease of impacts over time. 

A significant long-term concern will be the presence of nesting seabirds. A few seabirds, primarily 

wedge-tailed shearwaters, attempt to nest along the coast each year, but have been generally 

unsuccessful due to the uncontrolled presence of nonnative predators. To aid in protection of 

seabirds, a predator control program will be implemented along the Refuge coastal dunes, and it is 

anticipated that a variety of seabird species will once again be able to successfully nest in this area. 

Both seabird and human activity along the shoreline will need to be monitored to determine the level 

of disturbance that may be occurring to nesting seabirds from Refuge activities, including WO/I/P. 

As described below under stipulations, the Refuge Manager has the authority to close areas open to 

public uses if the need arises to protect wildlife. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

B-8 Appendix B. Appropriate Uses and Compatibility Determinations 

Cumulative impacts: The level and type of use from activities described in this CD is not expected 

to result in any significant cumulative impacts. 

Public Review and Comment: 

Public review and comments on this CD were solicited in conjunction with the release of the James 

Campbell National Wildlife Refuge Draft CCP/EA (2011), in order to comply with NEPA and 

Service policy. This CD was released as an integral part of the CCP and received the same level of 

public review and comments as the CCP, in accordance with Service planning policy. 

Determination: (check one below) 

 Use is Not Compatible 

 ✓ Use is Compatible With Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

Ki‘i Unit - Activity (both guided and self-guided tours) is allowed only during the non-nesting 

season of ae‘o to prevent disturbance to this sensitive species (October 15-February 28). 

During this seasonal use, designated times, areas and routes established by the Refuge Manager for 

both guided and self-guided tours will be used to further minimize disturbance to all wildlife and 

prevent conflicts with Refuge management actions being conducted by the staff. Tour group sizes 

are limited to 20 for docent-guided tours and 5 for self-guided tours, limited to 1 tour per day. 

Self-guided tours will be allowed only during regular business hours Monday-Friday. Due to the 

closed nature of the Refuge it is not desirable or advisable to have persons on self-guided tours enter 

and be present on the Refuge when Refuge staff is not present. Docent-guided tours are only 

conducted on Thursday and Saturday. 

Self-guided tours would be required to register for designated areas and hear or read orientation 

materials regarding appropriate wildlife viewing behavior and Refuge regulations to protect wildlife. 

Refuge coastal area - The Refuge Manager would still maintain the authority to close any portion of 

the Refuge-owned and -managed shoreline to the public for any period of time (temporarily, 

seasonally or year-round) to protect wildlife including ‘īlio-holo-i-ka-uaua, honu, seabirds or native 

plants (CFR 25.21(e) and 25.31). Closing is generally accomplished by signing and/or fencing. 

Access along the shore is pedestrian only, no entry by horseback or motorized vehicles permitted. 

Activities would be restricted to daylight hours only (sunrise to sunset). 

Justification: 

Wildlife observation, interpretation, and photography are identified as priority public uses of the 

Refuge System and are identified in the goals of the James Campbell NWR CCP; therefore a 

program which includes these uses fulfills a part of the Refuge System mission and Refuge goals. 

The current WO/I/P program on the Ki‘i Unit has been in place many years. Even in combination 

with the EE program which occurs in the same area and during the same season, the disturbance to 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

 

Appendix B. Appropriate Uses and Compatibility Determinations B-9 

wildlife is considered to be minimal. The small increase in visitor numbers planned by adding small 

(up to 5) self-guided tours during this same timeframe and in the same area of the Refuge will not 

significantly change or increase the level of disturbance to wildlife. 

Shoreline use will continue similar to what is occurring now (pre-acquisition) but with much 

improved monitoring, closed night-time use and authority to close Refuge owned/managed portions 

of the shoreline (under 50 CFR 25.21(e)) if it becomes necessary to prevent disturbance and protect 

wildlife. The land acquisition process is ongoing and recently or soon-to-be acquired lands will 

significantly change the size and nature of the Refuge. Management jurisdiction for the new property 

boundary along the shoreline is under review, subject to the Service solicitor’s opinion. If needed, 

we will pursue an Executive Order from the Governor of Hawai‘i to transfer State management 

jurisdiction to the Refuge to help fulfill Refuge purposes and eliminate conflicting uses or 

regulations. Once acquisition of these new lands is completed, it will take careful consideration and 

planning to determine the most suitable and practical sites for new public roads, parking areas, trails, 

areas both open or closed to the public, and special regulations necessary to protect wildlife, fragile 

natural and cultural resources, and the visiting public. An updated CD for WO/I/P uses may be 

prepared at that time which will incorporate new facilities and stipulations identified in the VSP. All 

uses and stipulations identified in this CD will be subject to review and change at that time. 

Although WO/I/P activities can result in disturbance to wildlife, disturbance will be intermittent and 

short-term. There is more than adequate undisturbed habitat available to Refuge wildlife for escape 

and cover. It is anticipated that wildlife populations will find sufficient food resources and resting 

places such that their abundance and use of the Refuge will not be measurably lessened from these 

activities. The relatively limited number of individuals expected to be adversely affected due to this 

Refuge use will not cause wildlife populations to materially decline, the physiological condition and 

production of any plant or animal species will not be impaired, and their overall welfare will not be 

negatively impacted. Thus allowing WO/I/P on the Refuge will not materially interfere with or 

detract from the fulfillment of the Refuge System mission or the purposes of this Refuge. 

Mandatory Reevaluation Date: (provide month and year for “allowed” uses only) 

September 2026 Mandatory 15-year reevaluation date (for wildlife-dependent public uses) 

 Mandatory 10-year reevaluation date (for all uses other than wildlife-dependent 

public uses) 

NEPA Compliance for Refuge Use Decision: (check one below) 

 _ Categorical Exclusion without Environmental Action Statement 

_ Categorical Exclusion and Environmental Action Statement 

 ✓ Environmental Assessment and Finding of No Significant Impact 

 _ Environmental Impact Statement and Record of Decision 

James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

 

Appendix B. Appropriate Uses and Compatibility Determinations B-11 

B.3 Compatibility Determination for Environmental Education 

Refuge Name(s): James Campbell National Wildlife Refuge

 

County and State: Honolulu County, Hawai‘i 

 

Establishing and Acquisition Authority(ies):

James Campbell NWR was established in 1976 under the authority of the: 

 Fish and Wildlife Coordination Act of 1956, as amended (16 U.S.C. 742a – 742j) 

 Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1544) 

 James Campbell National Wildlife Refuge Expansion Act of 2005, Pub. Law 109-225 (16 

U.S.C. 668dd) 

Refuge Purpose(s):

“... to conserve (A) fish or wildlife which are listed as endangered species or threatened species .... or 

(B) plants ...”. 

National Wildlife Refuge System Mission: 

“The mission of the National Wildlife Refuge System is to administer a national network of lands 

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

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

generations of Americans” (Administration Act). 

Description of Use(s): 

Environmental education is defined as a wildlife-dependent recreational use under the Improvement 

Act. Environmental education consists of educational activities conducted by Refuge staff, 

volunteers, partners and teachers. This CD addresses the current EE program which is proposed to 

continue while acquisition of new Refuge lands is completed and a subsequent Visitor Services Plan 

(VSP) is developed. This plan will identify and evaluate a wide range of new EE opportunities 

associated with the expanded Refuge, including the possible construction of a dedicated EE facility. 

Currently, the EE program on the Refuge serves a range of 900-1500 students annually, depending 

on the level of participation by individual schools. The program focuses on the management and 

protection of endangered waterbirds, wetlands, and other native wildlife. The entire program is 

conducted under a Special Use Permit (SUP) issued to the non-profit organization Papahana Kuaola, 

which organizes and conducts the programs. As the Refuge currently has limited staff available for 

EE, the program could not be conducted without this cooperation/participation of Papahana Kuaola 

or other nonprofit partner. Due to a lack of suitable and safe access (roads and parking) and other 

facilities on other portions of the Refuge, all EE activities currently take place on the Ki‘i Unit 

where limited access and facilities are available. 

During the interim period after land acquisition is complete and while the VSP is being developed, 

most EE activities will continue to be conducted on the Ki‘i Unit. Additional EE activities may be 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

B-12 Appendix B. Appropriate Uses and Compatibility Determinations 

conducted on new Refuge lands but may be limited by road conditions or lack of other facilities and 

conducted on a case by case basis under a SUP or by Refuge staff, if available. 

Environmental education activities on the Ki‘i Unit will continue during the non-nesting season of 

ae’o (October 15-February 28) to minimize disturbance to this sensitive species. Programs are 

conducted with a maximum of 60 students allowed along with teachers and chaperones. These 

programs are conducted from 11:30 a.m.-1:30 p.m. Under the current EE program structure, 

approximately 55 days per year (depending on holidays) are allocated for EE programs (M,W,F, 

October 15-February 28). While the actual number of programs conducted varies from year to year, 

many dates currently identified for EE programs are not utilized. Therefore, under the current 

program structure up to approximately 3,300 students could be accommodated each EE season. 

This EE program supports the environmental/wetlands curriculum being provided by schools to 

grades 3-5. After participating in classroom learning about Hawaiian wetlands and birds, the field 

trip to the Refuge is the first opportunity for most students to visit a refuge, see endangered Hawaiian 

waterbirds, and learn first-hand about efforts to manage and protect these species and their habitats. 

Availability of Resources:

Category and Itemization 

One-time

$ 

Annual

$/yr 

Administration and management: $0 $1,000

Maintenance: $0 $900

Materials: $0 $1,000

Special equipment, facilities, or improvements: $0 $1,000

Offsetting revenues: $0 $

Minimal costs of EE will be covered by Refuge visitor services funding provided in the annual 

Refuge budget. 

Anticipated Impacts of the Use(s):

Short-term impacts: Under the current program, the number of school groups and students visiting 

the Refuge may vary from year to year but this variation is already considered in the guidelines and 

structure established for the program. The primary impacts come from temporary disturbance to 

individual animals (primarily birds) due to the presence and activity of the students as they are 

guided around the wetlands. The animals may flush, swim away or seek cover and hide in vegetation. 

These impacts are mitigated by restricting the days, times, routes and locations that EE activities take 

place. This allows the students to participate in the EE experience while causing temporary 

disturbance over the smallest area and to the fewest birds. This program has been in place many 

years and while, as noted, it does have an effect on individual birds it has not had a noticeable impact 

on bird populations using the Refuge. 

 

Long-term impacts: The current, ongoing EE program covered by this CD will not cause any 

significant long-term impacts. With the recently acquired or pending acquisition of Refuge 

expansion lands many new possibilities and opportunities for EE programs and facilities will be 

available. To identify and evaluate these new possibilities a VSP will be developed within 5 years of 

the final land acquisition. This plan will identify and evaluate major new features and facilities, such 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

 

Appendix B. Appropriate Uses and Compatibility Determinations B-13 

as roads, parking area and trails that will be developed and used to support and implement an 

expanded EE program, as well as other visitor use programs. It is anticipated that this plan will 

consider and develop EE opportunities and facilities on other areas of the refuge shifting EE 

activities away from the Ki‘i Unit in the long-term so that the current low level of disturbance 

associated with the current EE program on the Ki‘i Unit will be reduced. 

Cumulative impacts: This EE program has been conducted in the current manner for many years and 

no cumulative impacts to wildlife resources on the refuge have been observed or are anticipated. 

Although the potential of the EE program could bring 6,000 students to the Refuge, the limitation to 

60 students per day retains the current impact regime. Although these activities can result in 

disturbance to wildlife, disturbance will be intermittent and short-term. There is more than adequate 

undisturbed habitat available to Refuge wildlife for escape and cover. It is anticipated that wildlife 

populations will find sufficient food resources and resting places such that their abundance and use of 

the Refuge will not be measurably lessened from these activities. The relatively limited number of 

individuals expected to be adversely affected due to this Refuge use will not cause wildlife 

populations to materially decline, the physiological condition and production of any plant or animal 

species will not be impaired, and their overall welfare will not be negatively impacted. Thus allowing 

EE on the Refuge will not materially interfere with or detract from the fulfillment of the Refuge 

System mission or the purposes of this Refuge. 

 

Public Review and Comment:

Public review and comments on this CD were solicited in conjunction with the release of the James 

Campbell National Wildlife Refuge Draft CCP/EA (2011), in order to comply with the National 

Environmental Policy Act and Service policy. This CD was released as an integral part of the CCP 

and received the same level of public review and comments as the CCP, in accordance with Service 

planning policy. 

Determination: (check one below) 

 Use is Not Compatible 

 ✓ Use is Compatible with Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

All access to the Refuge for EE activities not directly supervised by Service personnel is regulated by 

issuance of annual SUPs. The use of SUPs allows the Refuge Manager to continually adjust the 

activity to any significant new or changing conditions on the Refuge, as needed. However, the 

current programs are well established and such changes have been infrequent. 

To prevent disturbance to sensitive ae‘o during their nesting season, regularly scheduled EE activities 

will occur during the non-nesting season (October 15-February 28) and are limited to designated 

times, locations and routes of travel to reduce overall disturbance to wildlife. Group size is limited to 

a maximum of 60 students. 

The current EE program on the Ki‘i Unit has been in place many years. Even in combination with 

the wildlife tour program which occurs in the same area and during the same season, the disturbance 

to wildlife is considered to be minimal and at an acceptable level. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

B-14 Appendix B. Appropriate Uses and Compatibility Determinations 

Justification: 

Compatible EE is a priority wildlife-dependent public use of the Refuge System and is a goal in the 

James Campbell NWR CCP; therefore, implementation of the program fulfills a part of the Refuge 

System mission and Refuge goals. The program is intended to foster a better understanding of the 

Refuge and in turn build a public that is more knowledgeable about and supportive of natural 

resource issues and needs. Minimal impacts are incurred by implementation of existing EE 

programs or expected by modest increases as proposed in the CCP and as long as the stipulations to 

ensure compatibility are followed, the benefits received through public education, participation, and 

involvement outweigh the minimal impacts. 

Although EE activities can result in disturbance to wildlife, disturbance will be intermittent and 

short-term. There is more than adequate undisturbed habitat available to Refuge wildlife for 

escape and cover. It is anticipated that wildlife populations will find sufficient food resources 

and resting places such that their abundance and use of the Refuge will not be measurably 

lessened from these activities. The relatively limited number of individuals expected to be 

adversely affected due to this Refuge use will not cause wildlife populations to materially 

decline, the physiological condition and production of any plant or animal species will not be 

impaired, and their overall welfare will not be negatively impacted. Additionally, it is anticipated 

that monitoring, as needed, will prevent unacceptable or irreversible impacts to fish, wildlife, plants, 

and their habitats. Thus conducting the EE program will not materially interfere with or detract 

from the fulfillment of the Refuge System mission or the purposes of this Refuge. 

Mandatory Reevaluation Date: (provide month and year for “allowed” uses only) 

September 2026 Mandatory 15-year reevaluation date (for wildlife-dependent public uses) 

 Mandatory 10-year reevaluation date (for uses other than wildlife-dependent public 

uses) 

NEPA Compliance for Refuge Use Decision: (check one below) 

 Categorical Exclusion without Environmental Action Statement 

 Categorical Exclusion and Environmental Action Statement 

 ✓ Environmental Assessment and Finding of No Significant Impact 

 Environmental Impact Statement and Record of Decision

James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

B-16 Appendix B. Appropriate Uses and Compatibility Determinations 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

 

Appendix B. Appropriate Uses and Compatibility Determinations B-17 

B.4 Compatibility Determination for Research, Scientific Collecting, 

 and Surveys 

CD Terminology: 

Research: Planned, organized, and systematic investigation of a scientific nature. 

Scientific collecting: Gathering of refuge natural resources or cultural artifacts for scientific 

purposes. 

Surveys: Scientific inventory or monitoring. 

Refuge Name(s): James Campbell National Wildlife Refuge

County and State: Honolulu County, Hawai‘i

Establishing and Acquisition Authority(ies):

James Campbell NWR was established in 1976 under the authority of the: 

 Fish and Wildlife Coordination Act of 1956, as amended (16 U.S.C. 742a – 742j) 

 Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1544) 

 James Campbell National Wildlife Refuge Expansion Act of 2005, Pub. Law 109-225 (16 

U.S.C. 668dd) 

Refuge Purpose(s):

“... to conserve (A) fish or wildlife which are listed as endangered species or threatened species .... or 

(B) plants ...”. 

National Wildlife Refuge System Mission: 

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

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

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

of Americans” (Administration Act). 

Description of Use(s): 

The Refuge staff receives periodic requests from non-Service entities (e.g., universities, State 

agencies, other Federal agencies, nongovernmental organizations) to conduct research, scientific 

collecting, and surveys on Refuge lands. These project requests can involve a wide range of natural 

and cultural resources as well as public use management issues, including basic absence/presence 

surveys, collection of new species for identification, habitat use and life-history requirements for 

specific species/species groups, practical methods for habitat restoration, extent and severity of 

environmental contaminants, techniques to control or eradicate pest species, effects of climate 

change on environmental conditions and associated habitat/wildlife response, identification and 

analyses of paleontological specimens, wilderness character, modeling wildlife populations, and 

assessing response of habitat/wildlife to disturbance from public uses. Projects may be speciesspecific, Refuge-specific, or evaluate the relative contribution of the Refuge lands to larger 

landscapes (e.g., ecoregion, region, flyway, national, international) issues and trends. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

B-18 Appendix B. Appropriate Uses and Compatibility Determinations 

The Service’s research and management and Appropriate Refuge Uses (603 FW1.10D(4)) policies 

indicate priority for scientific investigatory studies that contribute to the enhancement, protection, 

use, preservation, and management of native wildlife populations and their habitat as well as their 

natural diversity. Projects that contribute to refuge-specific needs for resource and/or wilderness 

management goals and objectives, where applicable, would be given a higher priority over other 

requests. 

Availability of Resources: 

Refuge staff responsibilities for projects by non-Service entities will primarily be limited to the 

following: review of proposals, prepare special use permits (SUP) and other compliance documents 

(e.g., Section 7 of the ESA, Section 106 of the National Historic Preservation Act), and monitor 

project implementation to ensure that impacts and conflicts remain within acceptable levels 

(compatibility) over time. Additional administrative support, logistical and operational support may 

also be provided depending on each specific request. Estimated costs for one-time (e.g., prepare 

SUP) and annually recurring tasks by Refuge staff and other Service employees will be determined 

for each project. Sufficient funding in the general operating budget of the Refuge must be available 

to cover expenses for these projects. The terms and conditions for funding and staff support 

necessary to administer each project on the Refuge will be clearly stated in the SUP(s). 

The Refuge has the following staffing and funding to administratively support and monitor research 

that is currently taking place on Refuge lands (see table below). Any substantial increase in the 

number of projects would create a need for additional resources to oversee the administration and 

monitoring of the investigators and their projects. Any substantial additional costs above those 

itemized below may result in finding a project not compatible unless expenses are offset by the 

investigator(s), sponsoring agency, or organization. 

Category and Itemization One-time 

$ 

Annual 

$/yr 

Administration and management $0 $4,200

Maintenance $0 $0

Monitoring $0 $3,100

Special equipment, facilities, or improvement $0 $0

Offsetting revenues $0 $0

Itemized costs in the table above are current estimates calculated using 7% of the base cost for a GS12 Refuge Biologist/Refuge Manager and a 3% cost of a GS-13 Refuge Manager. 

Anticipated Impacts of the Use: 

Use of the Refuge to conduct research, scientific collecting, and surveys will generally provide 

information that would benefit wildlife, plants, and their habitats. Scientific findings gained through 

these projects provide important information regarding life-history needs of species and species 

groups as well as identify or refine management actions to achieve resource management objectives 

in Refuge management plans (especially CCPs). Reducing uncertainty regarding wildlife and habitat 

responses to Refuge management actions in order to achieve desired outcomes reflected in resource 

management objectives is essential for adaptive management in accordance with 522 DM 1. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

 

Appendix B. Appropriate Uses and Compatibility Determinations B-19 

If project methods impact or conflict with Refuge-specific resources, priority wildlife-dependent 

public uses, other high-priority research, and Refuge habitat and wildlife management programs, then 

it must be clearly demonstrated that the scientific findings will contribute to resource management 

and that the project cannot be conducted off-Refuge for the project to be compatible. The 

investigator(s) must identify methods/strategies in advance required to eliminate or minimize the 

potential impact(s) and conflict(s). If unacceptable impacts cannot be avoided, then the project will 

not be compatible. 

Impacts would be project- and site-specific, where they will vary depending upon nature and scope 

of the field work. Data collection techniques will generally have minimal animal mortality or 

disturbance, habitat destruction, no introduction of contaminants, or no introduction of nonnative 

species. In contrast, projects involving the collection of biotic samples (plants or animals) or 

requiring intensive ground-based data or sample collection will have short-term impacts. To reduce 

impacts, the minimum number of samples (e.g., water, soils, vegetative litter, plants, 

macroinvertebrates, and vertebrates) will be collected for identification and/or experimentation and 

statistical analysis. Where possible, researchers would coordinate and share collections to reduce 

sampling needed for multiple projects. 

Investigator(s) obtaining required State and Federal collecting permits will also ensure minimal 

impacts to fish, wildlife, plants, and their habitats. If, after incorporating the above strategies, the 

project results in long-term or cumulative effects, it will not be deemed compatible. A Section 7 

consultation under the ESA will be required for activities that may affect a federally listed species 

and/or critical habitat. Only projects that have no effect or will result in not likely to adversely affect 

determinations will be considered compatible. 

Spread of pest plants and/or pathogens is possible from ground disturbance and/or transportation of 

project equipment and personnel, but it will be minimized or eliminated by requiring proper cleaning 

of investigator equipment and clothing as well as quarantine methods, where necessary. If after all 

practical measures are taken, an unacceptable spread of pest species is anticipated to occur, then the 

project will be found not compatible without a restoration or mitigation plan. 

Localized and temporary effects may occur from vegetation trampling, collecting of soil and plant 

samples, or trapping and handling of wildlife. Impacts may also occur from infrastructure necessary 

to support a project (e.g., permanent transects or plot markers, exclosure devices, monitoring 

equipment, solar panels to power unattended monitoring equipment). Some level of disturbance is 

expected with these projects, especially if investigator(s) enter areas closed to the public and collect 

samples or handle wildlife. However, wildlife disturbance (including altered behavior) will usually 

be localized and temporary in nature. Where long-term or cumulative unacceptable effects cannot be 

avoided, the project will not be found compatible. Project proposals will be reviewed by Refuge staff 

and others, as needed, to assess the potential impacts (short-term, long-term, and cumulative) relative 

to benefits of the investigation to Refuge management issues and understanding of natural systems. 

At least 6 months before initiation of field work (unless an exception is made by prior approval of the 

Refuge Manager), project investigator(s) must submit a detailed proposal. Project proposals will be 

reviewed by Refuge staff and others, as needed, to assess the potential impacts (short-term, longterm, and cumulative) relative to benefits of the investigation to Refuge management issues and 

understanding of natural systems. This assessment will form the primary basis for allowing or 

denying a specific project. Projects that result in unacceptable Refuge impacts will not be found 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

B-20 Appendix B. Appropriate Uses and Compatibility Determinations 

compatible. If allowed and found compatible after approval, all projects also will be assessed during 

implementation to ensure impacts and conflicts remain within acceptable levels. 

If the proposal is approved, then the Refuge Manager will issue a SUP(s) with required stipulations 

(terms and conditions) of the project to avoid and/or minimize potential impacts to Refuge resources 

as well as conflicts with other public-use activities and Refuge field management operations. After 

approval, projects also are monitored during implementation to ensure impacts and conflicts remain 

within acceptable levels based upon documented stipulations. 

Projects that are not covered by the CCP will require additional NEPA documentation. 

Public Review and Comment: 

Public review and comments on this CD were solicited in conjunction with the release of the James 

Campbell National Wildlife Refuge Draft CCP/EA (2011), in order to comply with the National 

Environmental Policy Act and Service policy. This CD was released as an integral part of the CCP 

and received the same level of public review and comments as the CCP, in accordance with Service 

planning policy. 

Determination: (check one below) 

 The use is not compatible. 

 ✓ The use is compatible with the following stipulations. 

Stipulations Necessary to Ensure Compatibility: 

Each project will require an SUP. Annual or other short-term SUPs are preferred; however, some 

permits will be a longer period, if needed, to allow completion of the project. All SUPs will have a 

definite termination date. Permit renewals will be subject to Refuge Manager review and approval 

based on timely submission of and content in progress reports, compliance with SUP stipulations, 

and required permits. Other stipulations and provisions would include the following:

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

and applicable. 

 Investigators must possess appropriate and comply with conditions of State and Federal 

permits for their projects. 

 If unacceptable impacts to natural resources or conflicts arise or are documented by the 

Refuge staff, then the Refuge Manager can suspend, modify conditions of, or terminate an 

on-going project already permitted by SUP(s) on a Refuge. 

 Progress reports are required at least annually for multiple-year projects. 

 Final reports are due 1 year after completion of the project unless negotiated otherwise with 

the Refuge Manager. 

 Continuation of existing projects will require approval by the Refuge Manager. 

 The Refuge staff will be given the opportunity to review draft manuscript(s) from the project 

before being submitted to a scientific journal(s) for consideration of publication. 

 The Refuge staff will be provided with copies (including, but not limited to: reprints, videos, 

and CDs) of all publications resulting from a Refuge project. 

 The Refuge staff will be provided with copies of raw data (preferably electronic database 

format) at the conclusion of the project. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

 

Appendix B. Appropriate Uses and Compatibility Determinations B-21 

 Upon completion of the project or annually, all equipment and markers (unless required for 

long-term projects), must be removed and sites must restored to the Refuge Manager’s 

satisfaction. Conditions for clean-up and removal of equipment and physical markers will be 

stipulated in the SUP(s). 

 All samples collected on Refuge lands are the property of the Service even while in the 

possession of the investigator(s). Any future work with previously collected samples not 

clearly identified in the project proposal will require submission of a subsequent proposal for 

review and approval. In addition, a new SUP will be required for additional project work. For 

samples or specimens to be stored at other facilities (e.g., museums), a memorandum of 

understanding will be necessary. 

 Sampling equipment as well as investigator(s) clothing and vehicles (e.g., ATV, boats) will 

be thoroughly cleaned (free of dirt and plant material) before being allowed for use on 

Refuge lands and/or waters to prevent the introduction and/or spread of pests. 

 The Service, specific Refuge unit, names of Refuge staff and other Service personnel who 

supported or contributed to the project will be appropriately cited and acknowledged in all 

written and oral presentations resulting from projects on Refuge lands. 

 At any time, Refuge staff may accompany investigator(s) in the field. 

 Investigator(s) and support staff will follow all Refuge-specific regulations that specify 

access and travel on the Refuge. 

Justification: 

Research, scientific collecting, and surveys on Refuge lands are inherently valuable to the Service 

because they will expand scientific information available for resource management decisions. In 

addition, only projects that directly or indirectly contribute to the enhancement, protection, use, 

preservation, and management of Refuge wildlife populations and their habitats generally will be 

authorized on Refuge lands. In many cases, if it were not for the Refuge staff providing access to 

Refuge lands and waters along with some support, the research project would likely not occur and 

less scientific information would be available to the Service to aid in managing and conserving 

resources. By allowing the use to occur under the stipulations described above, it is anticipated that 

wildlife species that could be disturbed during the use would find sufficient food resources and 

resting places so their abundance and use will not be measurably lessened on the Refuge. 

Additionally, it is anticipated that monitoring, as needed, will prevent unacceptable or irreversible 

impacts to fish, wildlife, plants, and their habitats. The combination of stipulations identified above 

and conditions included in any SUP(s) will ensure that proposed projects contribute to the 

enhancement, protection, conservation, and management of native wildlife populations and their 

habitats on the Refuge. As a result, these projects will not materially interfere with or detract from 

fulfilling Refuge purpose(s); contributing to the mission of the Service and Refuge System; and 

maintaining the biological integrity, diversity, and environmental health of the Refuge. 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

B-22 Appendix B. Appropriate Uses and Compatibility Determinations 

Mandatory Re-evaluation Date: (provide month and year for “allowed” uses only) 

 Mandatory 15-year re-evaluation date (wildlife-dependent public uses) 

September 2021 Mandatory 10-year re-evaluation date (uses other than wildlife-dependent public 

uses) 

NEPA Compliance for Refuge Use Decision: (check one below) 

 Categorical Exclusion without Environmental Action Statement 

 Categorical Exclusion and Environmental Action Statement 

 ✓ Environmental Assessment and Finding of No Significant Impact 

 Environmental Impact Statement and Record of Decision

 


James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

 

Appendix B. Appropriate Uses and Compatibility Determinations B-25 

Attachment 1: Appropriate Uses Justification 

Date: September 16, 2010 

Refuge: James Campbell National Wildlife Refuge (Refuge) 

Project: Research, Scientific Collecting, and Surveys 

Summary: The Refuge receives requests to conduct scientific research on Refuge lands and waters. 

Research applicants must submit a proposal that would outline: (1) objectives of the study; 

(2) justification for the study; (3) detailed methodology and schedule; (4) potential impacts on 

Refuge wildlife and/or habitat, including disturbance (short-term and long-term), injury, or mortality; 

(5) personnel required; (6) costs to Refuge, if any; and (7) end products (i.e., reports, publications). 

Research proposals would be reviewed by Refuge staff, Regional Office Branch of Refuge Biology, 

and others as appropriate prior to the Refuge issuing a SUP. Projects will not be open-ended, and at a 

minimum, will be reviewed annually. 

 

For each of the findings listed on FWS Form 3-2319, a justification has been provided below: 

a. Do we have jurisdiction over the use? 

Some or all of the proposed activities would take place within Refuge boundaries. The Refuge has 

jurisdiction over those research projects that are sited within Refuge boundaries. 

b. Does the use comply with applicable laws and regulations (Federal, State, tribal, and local)? 

Proposed research activities should comply with all applicable laws and regulations. Any restrictions 

or qualifications that are required to comply with law and regulations would be specified in the SUP. 

The State of Hawai‘i DLNR was invited on two occasions to participate on core planning teams, but 

declined due to insufficient staffing. However, as this Appropriate Use Justification does not propose 

a significant deviation from the status quo, and no comments on this topic were received from the 

State during the comment period, we believe additional coordination was not necessary. 

c. Is the use consistent with applicable Executive orders and Department and Service policies? 

Through the review of individual projects, the Refuge would ensure that they are consistent with 

applicable policies, especially Research on Service Lands Policy (803 FW 1). 

d. Is the use consistent with public safety? 

Through individual project review, the Refuge will ensure that each project is consistent with public 

safety. If necessary, stipulations to ensure public safety will be included in the project’s SUP. 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

B-26 Appendix B. Appropriate Uses and Compatibility Determinations 

e. Is the use consistent with goals and objectives in an approved management plan or other 

document? 

Research activities are approved in instances where they can provide meaningful data that may 

contribute to Refuge management and public appreciation of natural resources. 

f. Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? 

Earlier documented analysis has approved the use and touted the benefits of research, scientific 

collecting, and surveys on national wildlife refuges. 

g. Is the use manageable within available budget and staff? 

The Refuge receives <10 requests per year for this activity, and it is manageable with available 

budget and staff. 

h. Will this be manageable in the future within existing resources? 

The proposed activity at current levels would be manageable in the future with the existing resources. 

i. Does the use contribute to the public’s understanding and appreciation of the Refuge’s 

natural or cultural resources, or is the use beneficial to the Refuge’s natural or cultural 

resources? 

The proposed use is beneficial to the Refuge’s natural and cultural resources because the types of 

research projects approved are those that have the distinct likelihood to help achieve Refuge purposes 

by providing information useful for the management of trust resources and may contribute to the 

public’s understanding and appreciation of natural and/or cultural resources. 

j. Can the use be accommodated without impairing existing wildlife-dependent recreational 

uses or reducing the potential to provide quality (see section 1.6D, 603 FW 1, for description), 

compatible, wildlife-dependent recreation into the future? 

The Refuge will ensure that the research activities will not impair existing or future wildlifedependent recreational use of the Refuge during individual project review, prior to issuing a SUP for 

the project. 

 

James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

B-28 Appendix B. Appropriate Uses and Compatibility Determinations 

Attachment 1: Appropriate Uses Justification 

Date: June 1, 2011 

Refuge: James Campbell National Wildlife Refuge (Refuge) 

Proposed Use: Commercial operation, sea asparagus farm 

Summary: This small commercial business occupies land under the long-term Refuge lease of Ming 

Dynasty. This operation was not covered by the December 2008 purchase agreement with the James 

Campbell Company and is not covered as part of the Ming Dynasty lease and therefore does not have 

pre-existing rights. This commercial operation does not meet requirements of 50 CFR 27.92 or 50 

CFR 27.97, regarding the use of Private Structures and Private Operations (commercial enterprise), 

respectively. The owner has been advised of this circumstance and has agreed to move to a new 

location. Due to the desire of the Service not to cause this small business undue hardship, we have 

provided up to 3 years from the date of purchase of the land for this owner to find and relocate to a 

suitable alternate location off-Refuge. This land was purchased in December of 2009 and must be 

vacated by December 2012. 

For each of the findings listed on FWS Form 3-2319, a justification has been provided below: 

a. Do we have jurisdiction over the use? 

Yes. The proposed use takes place within Refuge boundaries. 

b. Does the use comply with applicable laws and regulations (Federal, State, tribal, and local)? 

No. This commercial operation does not meet requirements of 50 CFR 27.92 or 50 CFR 27.97, 

regarding the use of Private Structures and Private Operations (commercial enterprise), respectively. 

c. Is the use consistent with applicable Executive orders and Department and Service policies? 

No. This operation was not covered by the December 2008 purchase agreement with the James 

Campbell Company and is not covered as part of the Ming Dynasty lease and therefore does not have 

pre-existing rights. 

d. Is the use consistent with public safety? 

Yes. There are no public safety issues with this use. 

e. Is the use consistent with goals and objectives in an approved management plan or other 

document? 

No. The first goal is to protect and manage seasonal wetland habitats to meet the life-history needs of 

endangered waterbirds to promote their recovery.
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

 

Appendix B. Appropriate Uses and Compatibility Determinations B-29 

f. Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? 

Yes. This is the first time the use has been proposed as the land has just recently been acquired by the 

Refuge. 

g. Is the use manageable within available budget and staff? 

No. The Refuge has no staff available to manage coordination with this commercial operation. 

h. Will this be manageable in the future within existing resources? 

No. The proposed activity would not be manageable in the future with the existing resources. 

i. Does the use contribute to the public’s understanding and appreciation of the Refuge’s 

natural or cultural resources, or is the use beneficial to the Refuge’s natural or cultural 

resources? 

The proposed use does not contribute to the public’s understanding and appreciation of the Refuge’s 

natural or cultural resources. 

j. Can the use be accommodated without impairing existing wildlife-dependent recreational 

uses or reducing the potential to provide quality (see section 1.6D, 603 FW 1, for description), 

compatible, wildlife-dependent recreation into the future? 

No. Commercial sea asparagus farming operations would impair existing or future wildlifedependent recreational use of the Refuge. 

James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

 

Appendix B. Appropriate Uses and Compatibility Determinations B-31 

A compatibility determination is required before the use may be allowed.         02/06

Attachment 1: Appropriate Uses Justification

Date: June 1, 2011 

Refuge: James Campbell National Wildlife Refuge (Refuge) 

Proposed Use: Use of abandoned runway (former Kahuku Army Airfield) for operation of aircraft 

(practice landings and takeoffs or other operation) 

Summary: Remnant open portions of the former Kahuku Army Airfield runway still exist on lands 

recently purchased by the Service and now administered as part of the James Campbell NWR. 

Refuge management plans include removing existing encroaching invasive vegetation on the runway 

and aprons of the runway to improve the site as potential seabird nesting habitat. The current 

remnant runway is frequently used by migratory birds, including kioea and kōlea. 

Under Federal regulations at 50 CFR 27.34, aircraft are prohibited from operating over national 

wildlife refuges at altitudes that result in harassment of wildlife and specifically prohibits 

unauthorized landings or take-offs. Due to the designated wildlife purposes of the James Campbell 

NWR and planned habitat management on and around the runway to benefit birds any request for 

authorized use of the runway would not be an appropriate use. As provided for in 50 CFR 27.34, 

emergency aircraft operations (i.e., emergency landings) are permitted. 

For each of the findings listed on FWS Form 3-2319, a justification has been provided below: 

a. Do we have jurisdiction over the use? 

All of the proposed activities would take place within Refuge boundaries. The Refuge has 

jurisdiction over remnant open portions of the former Kahuku Army Airfield runway that are sited 

within Refuge boundaries. 

b. Does the use comply with applicable laws and regulations (Federal, State, tribal, and local)? 

No. Under Federal regulations at 50 CFR 27.34, aircraft are prohibited from operating over national 

wildlife refuges at altitudes that result in harassment of wildlife and specifically prohibits 

unauthorized landings or take-offs. 

c. Is the use consistent with applicable Executive orders and Department and Service policies? 

No. Due to the designated wildlife purpose of the James Campbell NWR and planned habitat 

management on and around the runway to benefit birds, any request for authorized use of the runway 

would not be an appropriate use. 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

B-32 Appendix B. Appropriate Uses and Compatibility Determinations 

d. Is the use consistent with public safety? 

No. All aircraft are associated with different hazards. Members of the public would likely have no 

knowledge of important safety issues specific to an aircraft using an unsecured and unmanned 

landing area. Prior to Service acquisition, private helicopters landed in the vicinity of the old runway. 

The rotor wash, or air being blown by a hovering aircraft, is roughly 80-90 mph (more than a 

Category I hurricane) and it also reaches over 50 feet away. The other hazard of particular note is 

rotor strikes. Even highly experienced aircrews sometimes blindly walk into a spinning rotor and lose 

their lives. A sudden wind gust or pilot-input can suddenly and quickly change the pitch or angle of 

the rotor blade and bring it within head-strike distance. Many helicopters have tail rotors that are 

close to the ground and well within the head-strike zone. They also spin so fast as to be nearly 

invisible. 

e. Is the use consistent with goals and objectives in an approved management plan or other 

document? 

No. The Service proposes to improve potential seabird nesting sites on and around the abandoned 

Kahuku Airfield runway.

f. Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? 

Yes. This is the first time the use has been proposed as the land has just recently been acquired by the 

Refuge. 

g. Is the use manageable within available budget and staff? 

No. The Refuge has no staff available to manage coordination with private aircraft. 

h. Will this be manageable in the future within existing resources? 

No. The proposed activity would not be manageable in the future with the existing resources. 

i. Does the use contribute to the public’s understanding and appreciation of the Refuge’s 

natural or cultural resources, or is the use beneficial to the Refuge’s natural or cultural 

resources? 

The proposed use is detrimental to seabird nesting and does not contribute to the public’s 

understanding and appreciation of the Refuge’s natural or cultural resources. 

j. Can the use be accommodated without impairing existing wildlife-dependent recreational 

uses or reducing the potential to provide quality (see section 1.6D, 603 FW 1, for description), 

compatible, wildlife-dependent recreation into the future? 

No. Private aircraft operations would impair existing or future wildlife-dependent recreational use of 

the Refuge. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix C. Plan Implementation and Costs C-1 

Appendix C. Plan Implementation and Costs 

C.1 Administration 

James Campbell NWR is administered as part of the O‘ahu NWR Complex. The Complex also 

includes the Pearl Harbor NWR, comprised of three separate units scattered along the south of O‘ahu 

and the O‘ahu Forest NWR located in the higher elevations of the Ko‘olau Mountains in central 

O‘ahu. The Complex headquarters is located in leased office space in the north shore town of 

Hale‘iwa, approximately 20 miles from the James Campbell NWR. The maintenance shop and 

equipment storage buildings that serve all three refuges in the Complex are located on the Ki‘i Unit. 

A new O‘ahu NWR Complex headquarters/visitor center/environmental education facility is 

proposed for construction on the Punamanō Unit. This facility and associated staff would also serve 

the Pearl Harbor NWR and O‘ahu Forest NWR. 

C.2 Staffing 

Out of necessity, all staff positions share responsibilities and duties across all three refuges; i.e., no 

staff is assigned and performs duties only on specific refuges within the Complex. Due to projected 

Complex-wide workload, priorities, logistics, and supervisory considerations; this arrangement is 

expected to continue. However, when more personnel are added to the Complex, staff may be 

assigned more specific duties on individual refuges. 

Necessary staffing for current Complex needs (as projected by the Service’s National Staffing 

Model) was determined to include 20.5 staff positions. Of these, 2.5 staff positions were moved to 

other offices. Therefore, with the existing core (existing) funded complex staff of 6 personnel, 

13 additional staff positions are justified under the National Staffing Model to meet current (existing) 

Refuge needs for the Complex, including James Campbell NWR. Increased staffing would allow 

more coordination with other Federal, State, and local agencies and the public; additional capacity to 

conduct biological inventory, monitoring, research, and habitat management; improved maintenance 

capability for all Refuge facilities; law enforcement; and visitor services (including interpretation and 

environmental education). 

Visitor Center and Environmental Education Center Staffing 

A critical consideration in future staffing needs is in conjunction with construction of a proposed 

Headquarters/Visitor Center/Environmental Education Center facility (HQ/VC/EE). This would be a 

large state-of-the art facility designed and planned to serve up to 200,000 visitors and up to 10,000 

students annually. This facility would be located on the James Campbell NWR but would serve all of 

the refuges of the Complex. To fully meet the operational needs and potential of this facility, three 

additional visitor services staff and one fulltime facility maintenance manager would be needed to 

maintain and operate the facility and grounds. These positions are included in the following table. 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

C-2 Appendix C. Plan Implementation and Costs 

Table C.1 Current and Necessary Permanent Full-time Staffing for O‘ahu NWR Complex, including James 

Campbell NWR (highlighted positions indicate current staff, * indicates VC/EE staff) 

Staff Position Salary 

Rating 

Staff Position Salary 

Rating 

Project Leader 

Deputy Project Leader 

Supervisory Wildlife Biologist 

Supervisory Tractor Operator 

Administrative Technician 

Supervisory Park Ranger 

Wildlife Refuge Specialist 

Wildlife Biologist 

Refuge Law Enforcement Officer 

GS-13 

GS-11/12 

GS-11/12 

WS-4 

GS-7/9 

GS-11/12* 

GS-7/9/11 

GS-5/7/9 

GS-5/7/9

Environmental Education Specialist 

Park Ranger 

Tractor Operator 

Tractor Operator 

Maintenance Worker 

Maintenance Worker 

Maintenance Worker 

Biological Technician 

Biological Technician 

Facility Manager 

GS-7/9* 

GS-5/7/9* 

WG-6 

WG-6 

WG-8 

WG-5/6/7 

WG-5/6 

GS-5/7 

GS-5/7 

WG-9/10* 

C.4 Refuge Funding and Budget Requests 

Successful and full implementation of the CCP relies on our ability to secure funding and staffing 

necessary to achieve the actions and strategies described herein. In addition to annual budget 

allocations, funding can be received through special funding sources and programs geared toward 

specific resource issues/needs. Examples include grants or project specific funding for endangered 

species, wetlands, pest species control, coastal habitats, seabirds, climate change or sea level rise. 

Currently, budget requests through the Refuge Operating Needs System (RONS) for James Campbell 

NWR include four additional staff positions as part of the necessary positions identified above. The 

RONS system will be updated with new/additional projects that are approved under this CCP. 

Table C.2 Major project implementation schedule and costs** 

Project Dates Cost Estimate 

Construct HQ/VC/EE facility Dependent on 

Funding 

$16,000,000 

Erect fences (by units) for dunes / coastal strand 

protection of seabirds and native vegetation 

2012 - 2016 $580,000 

Restore/manage vegetation on abandoned runway 2012 $40,000 

Restoration of coastal dune/coastal strand habitat for 

nesting seabirds and native vegetation 

2012 - 2016 $110,000 

Demolition/clean-up of abandoned aquaculture facilities 2012 - 2014 $450,000 

Install small water control structures to enhance 

management of degraded wetlands 

2013 - 2016 $60,000 

Construct new shop/maintenance facility 2014 - 2016 $1,100,000 

Construct bunkhouse for volunteers/researchers 2014 - 2018 $850,000 

**does not include projects, facilities (i.e., public roads, parking areas, boardwalks, trails, etc.) to be identified in 

Visitor Services Plan 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix C. Plan Implementation and Costs C-3 

C.5 Stepdown Plans 

The CCP is one of several plans necessary for refuge management. The CCP provides guidance in 

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

the specifics needed for implementation. Stepdown management plans will be developed for 

individual program areas within approximately 5 years after CCP completion. Stepdown plans, 

where feasible, will be prepared to cover all refuges of the Complex with similar planning needs. 

Others will be prepared for specific refuges in the Complex. All stepdown plans require appropriate 

NEPA compliance; implementation may require additional permits. Stepdown plans for the Refuge 

follow in the table below. Project-specific plans, with appropriate NEPA compliance, may be 

prepared outside of these stepdown plans. 

Stepdown Management Plan Status 

Completed 

Habitat Management Plan

Integrated Pest Management Plan 

Occupational Safety and Health Plan 

Fire Management Plan 

Scheduled 

Fishing Plan 

Land Protection Plan 

Climate Change Monitoring Plan 

Inventory and Monitoring Plan 

Visitor Services Plan 

Transportation Plan 

Environmental Education Plan 

Studies Identified in CCP strategies 

Hydrogeomorphic Study 

Comprehensive Water Resources Study

Date 

2011 (CCP meets requirements for HMP) 

2011 (prepared concurrently with CCP, Appendix E) 

2007 

2007 

Initiate by 2012  

Initiate by 2012

Initiate by 2012 

2014 

Complete by 2016 

2016 

2016 

Initiate by 2014 

2018-2020 

 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

C-4 Appendix C. Plan Implementation and Costs 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix D. Wilderness Review D-1 

Appendix D. Wilderness Review 

General Information on Wilderness Reviews 

Wilderness review is the process used to determine whether or not to recommend lands or waters in 

the Refuge System to the Congress for designation as wilderness. Planning policy for the System 

(602 FW 3) mandates conducting wilderness reviews every 15 years through the CCP process. 

The wilderness review process has three phases: inventory, study, and recommendation. After first 

identifying lands and waters that meet the minimum criteria for wilderness, the resulting wilderness 

study areas (WSA) are further evaluated to determine if they merit recommendation from the Service 

to the Secretary of the Interior for inclusion in the National Wilderness Preservation System 

(NWPS). Areas recommended for designation are managed to maintain wilderness character in 

accordance with management goals, objectives, and strategies outlined in the final CCP until 

Congress makes a decision or the CCP is amended to modify or remove the wilderness proposal. A 

brief discussion of wilderness inventory, study, and recommendation follows. 

Wilderness Inventory 

The wilderness inventory consists of identifying areas that minimally meet the requirements for 

wilderness as defined in the Wilderness Act of 1964 (Wilderness Act). Wilderness is defined as an 

area which: 

 Has at least 5,000 ac of land or is of sufficient size as to make practicable its preservation 

and use in an unimpaired condition, or be capable of restoration to wilderness character 

through appropriate management at the time of review, or be a roadless island; 

 Generally appears to have been affected primarily by the forces of nature, with the imprint 

of man’s work substantially unnoticeable; 

 Has outstanding opportunities for solitude or a primitive and unconfined type of recreation; 

and 

 May also contain ecological, geological, or other features of scientific, educational, scenic, 

or historic value. These features and values, though desirable, are not necessary for an area 

to qualify as a wilderness. 

Wilderness Study 

During the study phase, lands and waters qualifying for wilderness as a result of the inventory are 

studied to analyze values (ecological, recreational, cultural, spiritual), resources (wildlife, water, 

vegetation, minerals, soils), and uses (habitat management, public use) within the area. The findings 

of the study help determine whether to recommend the area for designation as wilderness. 

Wilderness Recommendation 

Once a wilderness study determines that a WSA meets the requirements for inclusion in the NWPS, a 

wilderness study report that presents the results of the wilderness review, accompanied by a 

Legislative Environmental Impact Statement (LEIS), is prepared. The wilderness study report and 

LEIS that support wilderness designation are then transmitted through the Secretary of the Interior to 

the President of the United States, and ultimately to the Congress for approval. 

The following section summarizes the inventory phase of the wilderness review for James 

Campbell NWR. 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

D-2 Appendix D. Wilderness Review 

Wilderness Inventory 

The wilderness inventory is a broad look at the planning area to identify WSAs. These WSAs are 

roadless areas within refuge boundaries, including submerged lands and their associated water 

column, that meet the minimum criteria for wilderness identified in Sect. 2. (c) of the Wilderness 

Act. A WSA must meet the minimum size criteria (or be a roadless island), appear natural, and 

provide outstanding opportunities for solitude or primitive recreation. Other supplemental values are 

evaluated, but not required. 

Evaluation of Size Criteria for Roadless Areas, Roadless Islands, and Submergent Lands 

and Associated Water Column 

Identification of roadless areas, roadless islands, and submerged lands and associated water column, 

required gathering land status maps, land use and road inventory data, satellite imagery, aerial 

photographs, and personal observations of areas within refuge boundaries. “Roadless” refers to the 

absence of improved roads suitable and maintained for public travel by means of motorized vehicles 

primarily intended for highway use. 

 

Inventory units meet the size criteria for a WSA if any one of the following standards applies: 

 An area with over 5,000 contiguous ac. State and private lands are not included in making 

this acreage determination. 

 A roadless island of any size. A roadless island is defined as an area surrounded by 

permanent waters or that is markedly distinguished from the surrounding lands by 

topographical or ecological features. 

 An area of less than 5,000 contiguous Federal acres that is of sufficient size as to make 

practicable its preservation and use in an unimpaired condition, and of a size suitable for 

wilderness management. 

 An area of less than 5,000 contiguous Federal acres that is contiguous with a designated 

wilderness, recommended wilderness, or area under wilderness review by another Federal 

wilderness managing agency such as the Forest Service, National Park Service, or Bureau of 

Land Management. 

The Refuge is composed of a highly modified land management unit totaling 934 acres on the island 

of O‘ahu and does not meet the size criteria. It is also bounded and bisected by State-owned and 

Refuge-owned roadways maintained for travel by passenger vehicles. 

Evaluation of the Naturalness Criteria 

A WSA must meet the naturalness criteria. Section 2.(c) of the Wilderness Act defines wilderness as 

an area that “...generally appears to have been affected primarily by the forces of nature with the 

imprint of man’s work substantially unnoticeable.” The area must appear natural to the average 

visitor rather than “pristine.” The presence of ecologically accurate, historical landscape conditions is 

not required. An area may include some manmade features and human impacts provided they are 

substantially unnoticeable in the unit as a whole. Human-caused hazards, such as the presence of 

unexploded ordnance from military activity, and the physical impacts of refuge management 

facilities and activities are also considered in the evaluation of the naturalness criteria. An area may 

not be considered unnatural in appearance solely on the basis of “sights and sounds” of human 

impacts and activities outside the boundary of the unit. The cumulative effects of these factors were 

considered in the evaluation of naturalness for each wilderness inventory unit. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix D. Wilderness Review D-3 

In the wilderness inventory, specific manmade features and other human impacts need to be 

identified that affect the overall apparent naturalness of the tract. The following factors were primary 

considerations in evaluating the naturalness of the Refuge: 

 Administrative and maintenance buildings, abandoned aquaculture facilities; 

 Well pumps, earthen dikes, water control structures; and 

 Gates, parking lots, and roadways. 

 

The Refuge consists of highly modified lands, containing earthen dikes, ditches, water control 

structures, buildings, and water pumping stations and does not meet the naturalness criteria. 

Evaluation of Outstanding Opportunities for Solitude or Primitive and Unconfined 

Recreation 

In addition to meeting the size and naturalness criteria, a WSA must provide outstanding 

opportunities for solitude or primitive recreation. The area does not have to possess outstanding 

opportunities for both solitude and primitive and unconfined recreation, and does not need to have 

outstanding opportunities on every acre. Further, an area does not have to be open to public use and 

access to qualify under these criteria. Congress has designated a number of wilderness areas in the 

NWPS that are closed to public access to protect ecological resource values. 

Opportunities for solitude refers to the ability of a visitor to be alone and secluded from other visitors 

in the area. Primitive and unconfined recreation means nonmotorized, dispersed outdoor recreation 

activities that do not require developed facilities or mechanical transport. These primitive recreation 

activities may provide opportunities to experience challenge and risk, self-reliance, and adventure. 

These two opportunity “elements” are not well defined by the Wilderness Act but in most cases can 

be expected to occur together. However, an outstanding opportunity for solitude may be present in an 

area offering only limited primitive recreation potential. Conversely, an area may be so attractive for 

recreation use that experiencing solitude is not an option. 

 

This Refuge does not offer opportunities for solitude or primitive and unconfined recreation. Daily 

management activities occur throughout the Refuge. These activities include road maintenance, 

mowing and disking of fields, and manipulation of water control structures. Recreational and 

educational activities are only conducted in group settings, and only allowed as staff-guided 

activities. 

Evaluation of Supplemental Values 

Supplemental values are defined by the Wilderness Act as “ecological, geological, or other features 

of scientific, educational, scenic, or historic value.” Based upon the findings of the required 

components for WSA designation, supplemental values were not evaluated. 

Findings 

James Campbell NWR does not meet the minimum criteria for consideration as a WSA (see Table 

D.1). 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

D-4 Appendix D. Wilderness Review 

Table D.1 Wilderness Inventory Summary

Wilderness Inventory Summary

James Campbell NWR (1,100 acres)

Required Components

(1) Has at least 5,000 ac of land or is of sufficient 

size to make practicable its preservation and use in 

an unconfined condition, or is a roadless island.

No. Does not contain 5,000 acres, is not a 

roadless island, and is not practicable to 

manage as a wilderness.

(2) Generally appears to have been affected 

primarily by the forces of nature, with the imprint 

of man’s work substantially unnoticeable.

No. Landscape is highly modified and 

actively managed.

(3a) Has outstanding opportunities for solitude. No. Refuge is actively and regularly 

managed.

(3b) Has outstanding opportunities for a primitive 

and unconfined type of recreation.

No. Recreation is highly regulated and 

requires staff presence. 

Other Components

(4) Contains ecological, geological or other 

features of scientific, educational, scenic, or 

historic value.

Not evaluated.

Summary

Parcel qualifies as a wilderness study area (meets 

criteria 1, 2 & 3a or 3b).

No.
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-1 

Appendix E. Integrated Pest Management Program 

1.0 Background 

Integrated Pest Management (IPM) is an interdisciplinary approach utilizing methods to prevent, 

eliminate, contain, and/or control pest species in concert with other management activities on Refuge 

lands and waters to achieve wildlife and habitat management goals and objectives. IPM is also a 

scientifically based, adaptive management process where available scientific information and best 

professional judgment of the Refuge staff as well as other resource experts would be used to identify 

and implement appropriate management strategies that can be modified and/or changed over time to 

ensure effective, site-specific management of pest species to achieve desired outcomes. In 

accordance with 43 CFR 46.145, adaptive management would be particularly relevant where longterm impacts may be uncertain and future monitoring would be needed to make adjustments in 

subsequent implementation decisions. After a tolerable pest population (threshold) is determined 

considering achievement of Refuge resource objectives and the ecology of pest species, one or more 

methods, or combinations thereof, are selected that are feasible, efficacious, and most protective of 

nontarget resources, including native species (fish, wildlife, and plants), and Service personnel, 

Service authorized agents, volunteers, and the public. Staff time and available funding will be 

considered when determining feasibility/practicality of various treatments. 

IPM techniques to address pests are presented as CCP strategies prescriptions (see Section 2.0 of this 

CCP) in an adaptive management context to achieve Refuge resource objectives. In order to satisfy 

requirements for IPM planning as identified in the Director’s Memo (dated September 9, 2004) 

entitled Integrated Pest Management Plans and Pesticide Use Proposals: Updates, Guidance, and 

an Online Database, the following elements of an IPM program have been incorporated into this 

CCP: 

 Habitat and/or wildlife objectives that identify pest species and appropriate thresholds to indicate 

the need for and successful implementation of IPM techniques; and 

 Monitoring before and/or after treatment to assess progress toward achieving objectives including 

pest thresholds. 

Where pesticides would be necessary to address pests, this Appendix provides a structured procedure 

to evaluate potential effects of proposed uses involving ground-based applications to Refuge 

biological resources and environmental quality. Only pesticide uses that likely would cause minor, 

temporary, or localized effects to Refuge biological resources and environmental quality with 

appropriate best management practices (BMPs), where necessary, would be allowed for use on the 

Refuge. 

This Appendix does not describe the more detailed process to evaluate potential effects associated 

with aerial applications of pesticides. Moreover, it does not address effects of mosquito control with 

pesticides (larvicides, pupacides, or adulticides) based upon identified human health threats and 

presence of disease-carrying mosquitoes in sufficient numbers from monitoring conducted on a 

Refuge. However, the basic framework to assess potential effects to Refuge biological resources and 

environmental quality from aerial application of pesticides or use of insecticides for mosquito 

management would be similar to the process described in this Appendix for ground-based treatments 

of other pesticides. 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

E-2 Appendix E. Integrated Pest Management Program 

2.0 Pest Management Laws and Policies 

In accordance with 517 DM and 569 FW 1(Integrated Pest Management), plant, invertebrate, and 

vertebrate pests on units of the National Wildlife Refuge System can be controlled to assure balanced 

wildlife and fish populations in support of refuge-specific wildlife and habitat management 

objectives. Pest control on Federal (Refuge) lands and waters also is authorized under the following 

legal mandates: 

 National Wildlife Refuge System Administration Act of 1966, as amended (16 USC 668dd668ee); 

 Plant Protection Act of 2000 (7 USC 7701 et seq.); 

 Noxious Weed Control and Eradication Act of 2004 (7 USC 7781-7786, Subtitle E); 

 Federal Insecticide, Fungicide, and Rodenticide Act of 1996 (7 USC 136-136y); 

 National Invasive Species Act of 1996 (16 USC 4701); 

 Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990 (16 USC 4701); 

 Food Quality Protection Act of 1996 (7 USC 136); 

 Executive Order 13148, Section 601(a); 

 Executive Order 13112; and 

 Animal Damage Control Act of 1931 (7 USC 426-426c, 46 Stat. 1468). 

Pests are defined as “...living organisms that may interfere with the site-specific purposes, 

operations, or management objectives or that jeopardize human health or safety” from Department 

policy 517 DM 1 (Integrated Pest Management Policy). Similarly, 569 FW 1 defines pests as 

“...invasive plants and introduced or native organisms, that may interfere with achieving our 

management goals and objectives on or off our lands, or that jeopardize human health or safety.” 

517 DM 1 also defines an invasive species as “a species that is nonnative to the ecosystem under 

consideration and whose introduction causes or is likely to cause economic or environmental harm or 

harm to human health.” Throughout the remainder of this CCP, the terms pest and invasive species 

are used interchangeably because both can prevent/impede achievement of Refuge wildlife and 

habitat objectives and/or degrade environmental quality. 

In general, control of pests (vertebrate or invertebrate) on the Refuge would conserve and protect the 

nation’s fish, wildlife, and plant resources as well as maintain environmental quality. From 

569 FW 1, animal or plant species, which are considered pests, may be managed if the following 

criteria are met: 

 Threat to human health and well being or private property, the acceptable level of damage by the 

pest has been exceeded, or State or local government has designated the pest as noxious; 

 Detrimental to resource objectives as specified in a Refuge resource management plan (e.g., 

comprehensive conservation plan, habitat management plan), if available; and 

 Control would not conflict with attainment of resource objectives or the purposes for which the 

Refuge was established. 

The specific justifications for pest management activities on the Refuge are the following: 

 Protect human health and well being; 

 Prevent substantial damage to important to Refuge resources; 

 Protect newly introduced or re-establish native species; 

 Control nonnative (exotic) species in order to support existence for populations of native species; 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-3 

 Prevent damage to private property; and 

 Provide the public with quality, compatible wildlife-dependent recreational opportunities. 

In accordance with Service policy 620 FW 1 (Habitat Management Plans), there are additional 

management directives regarding invasive species found on the Refuge: 

 “We are prohibited by Executive Order, law, and policy from authorizing, funding, or carrying 

out actions that are likely to cause or promote the introduction or spread of invasive species in the 

United States or elsewhere.” 

 “Manage invasive species to improve or stabilize biotic communities to minimize unacceptable 

change to ecosystem structure and function and prevent new and expanded infestations of 

invasive species. Conduct Refuge habitat management activities to prevent, control, or eradicate 

invasive species...” 

Animal species damaging/destroying Federal property and/or detrimental to the management 

program of a Refuge may be controlled as described in 50 CFR 31.14 (Official Animal Control 

Operations). 

Trespass and feral animals also may be controlled on Refuge lands. Based upon 50 CFR 28.43 

(Destruction of Dogs and Cats), dogs and cats running at large on a national wildlife refuge and 

observed in the act of killing, injuring, harassing or molesting humans or wildlife may be disposed of 

in the interest of public safety and protection of the wildlife. 

Feral animals should be disposed by the most humane method(s) available and in accordance with 

relevant Service directives (including Executive Order 11643). Disposed wildlife specimens may be 

donated or loaned to public institutions. Donation or loans of resident wildlife species will only be 

made after securing State approval (50 CFR 30.11 [Donation and Loan of Wildlife Specimens]). 

Surplus wildlife specimens may be sold alive or butchered, dressed and processed subject to Federal 

and State laws and regulations (50 CFR 30.12 [Sale of Wildlife Specimens]). 

3.0 Strategies 

To fully embrace IPM as identified in 569 FW 1, the following strategies, where applicable, would 

be carefully considered on the Refuge for each pest species: 

Prevention. This would be the most effective and least expensive long-term management option 

for pests. It encompasses methods to prevent new introductions or the spread of the established 

pests to un-infested areas. It requires identifying potential routes of invasion to reduce the 

likelihood of infestation. Hazard Analysis and Critical Control Points (HACCP) planning can be 

used determine if current management activities on a Refuge may introduce and/or spread 

invasive species in order to identify appropriate BMPs for prevention. 

Prevention may include source reduction, using pathogen-free or weed-free seeds or fill; 

exclusion methods (e.g., barriers) and/or sanitation methods (e.g., wash stations) to prevent reintroductions by various mechanisms including vehicles and personnel. Because invasive species 

are frequently the first to establish newly disturbed sites, prevention would require a reporting 

mechanism for early detection of new pest occurrences with quick response to eliminate any new 

satellite pest populations. Prevention would require consideration of the scale and scope of land 

management activities that may promote pest establishment within un-infested areas or promote 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

E-4 Appendix E. Integrated Pest Management Program 

reproduction and spread of existing populations. Along with preventing initial introduction, 

prevention would involve halting the spread of existing infestations to new sites (Mullin et al. 

2000). The primary reason of prevention would be to keep pest-free lands or waters from 

becoming infested. Executive Order 11312 emphasizes the priority for prevention with respect to 

managing pests. 

The following would be methods to prevent the introduction and/or spread of pests on Refuge 

lands: 

 Before beginning ground-disturbing activities (e.g., disking, scraping), inventory and 

prioritize pest infestations in project operating areas and along access routes. Refuge 

staff would identify pest species on site or within reasonably expected potential invasion 

vicinity. Where possible, Refuge staff would begin project activities in un-infested areas 

before working in pest-infested areas. 

 Refuge staff would locate and use pest-free project staging areas. They would avoid or 

minimize travel through pest-infested areas, or restrict to those periods when spread of 

seed or propagules of invasive plants would be least likely. 

 Refuge staff would determine the need for, and when appropriate, identify sanitation sites 

where equipment can be cleaned of pests. Where possible, Refuge staff would clean 

equipment before entering lands at on-Refuge approved cleaning site(s). This practice 

does not pertain to vehicles traveling frequently in and out of the project area that will 

remain on roadways. Seeds and plant parts of pest plants would need to be collected, 

where practical. Refuge staff would remove mud, dirt, and plant parts from project 

equipment before moving it into a project area. 

 Refuge staff would clean all equipment, before leaving the project site, if operating in 

areas infested with pests. Refuge staff would determine the need for, and when 

appropriate, identify sanitation sites where equipment can be cleaned. 

 Refuge staffs, their authorized agents, and Refuge volunteers would, where possible, 

inspect, remove, and properly dispose of seed and parts of invasive plants found on their 

clothing and equipment. Proper disposal means bagging the seeds and plant parts and 

then properly discarding of them (e.g., incinerating). 

 Refuge staff would evaluate options, including closure, to restrict the traffic on sites with 

on-going restoration of desired vegetation. Refuge staff would revegetate disturbed soil 

(except travel ways on surfaced projects) to optimize plant establishment for each 

specific site. Revegetation may include topsoil replacement, planting, seeding, 

fertilization, liming, and weed-free mulching as necessary. Refuge staff would use native 

material, where appropriate and feasible. Refuge staff would use certified weed-free or 

weed-seed-free hay or straw where certified materials are reasonably available. 

 Refuge staff would provide information, training and appropriate pest identification 

materials to Refuge staffs, permit holders, and recreational visitors. Refuge staff would 

educate them about pest identification, biology, impacts, and effective prevention 

measures. 

 Refuge staff would inspect borrow material for invasive plants prior to use and transport 

onto and/or within Refuge lands. 

 Refuge staff would consider invasive plants in planning for road maintenance activities. 

 Refuge staff would restrict off road travel to designated routes. 

The following would be methods to prevent the introduction and/or spread of pests into Refuge 

waters: 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-5 

 Refuge staff would inspect boats (including air boats), trailers, and other boating 

equipment and, where possible, remove any visible plants, animals, or mud before 

leaving any waters or boat launching facilities. Where possible, staff would drain water 

from motor, live well, bilge, and transom wells while on land before leaving the site. 

If possible, Refuge staff would wash and dry boats, downriggers, anchors, nets, floors of boats, 

propellers, axles, trailers, and other boating equipment to kill pests not visible at the boat launch. 

These prevention methods to minimize/eliminate the introduction and/or spread of pests were 

taken verbatim or slightly modified from Appendix E of US Forest Service (2005). 

 Mechanical/Physical Methods. These methods would remove and destroy, disrupt the growth 

of, or interfere with the reproduction of pest species. For plants species, these treatments can be 

accomplished by hand, hand tool (manual), or power tools (mechanical) and include pulling, 

grubbing, digging, tilling/disking, cutting, swathing, grinding, sheering, girdling, mowing, and 

mulching of the pest plants. 

For animal species, Service employees or their authorized agents could use mechanical/physical 

methods (including trapping and shooting) to control pests as a refuge management activity. 

Based upon 50 CFR 31.2, trapping can be used on a refuge to reduce surplus wildlife populations 

for a “balanced conservation program” in accordance with Federal or State laws and regulations. 

In some cases, nonlethally trapped animals would be relocated to off-refuge sites with prior 

approval from the State. 

Each of these tools would be efficacious to some degree and applicable to specific situations. In 

general, mechanical controls can effectively control annual and biennial pest plants. However, to 

control perennial plants, the root system has to be destroyed or it would resprout and continue to 

grow and develop. Mechanical controls are typically not capable of destroying a perennial plants 

root system. Although some mechanical tools (e.g., disking, plowing) may damage root systems, 

they may stimulate regrowth producing a denser plant population that may aid in the spread 

depending upon the target species. In addition, steep terrain and soil conditions would be major 

factors that can limit the use of many mechanical control methods. 

Some mechanical control methods (e.g., mowing), which would be used in combination with 

herbicides, can be a very effective technique to control perennial species. For example, mowing 

perennial plants followed sequentially by treating the plant regrowth with a systemic herbicide 

often would improve the efficacy of the herbicide compared to herbicide treatment only. 

 Cultural Methods. These methods would involve manipulating habitat to increase pest 

mortality by reducing its suitability to the pest. Cultural methods would include water-level 

manipulation, , prescribed burning (facilitate revegetation, increase herbicide efficacy, and 

remove litter to assist in emergence of desirable species), planting or seeding desirable species to 

shade or out-compete invasive plants, applying fertilizer to enhance desirable vegetation, 

irrigation, and other habitat alterations. 

 Biological Control Agents. Classical biological control would involve the deliberate 

introduction and management of natural enemies (parasites, predators, or pathogens) to reduce 

pest populations. Many of the most ecologically or economically damaging pest species in the 

United States originated in foreign countries. These newly introduced pests, which are free from 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

E-6 Appendix E. Integrated Pest Management Program 

natural enemies found in their country or region of origin, may have a competitive advantage 

over cultivated and native species. This competitive advantage often allows introduced species 

to flourish, and they may cause widespread economic damage to crops or out compete and 

displace native vegetation. Once the introduced pest species population reaches a certain level, 

traditional methods of pest management may be cost prohibitive or impractical. Biological 

controls typically are used when these pest populations have become so widespread that 

eradication or effective control would be difficult or no longer practical. 

Biological control has advantages as well as disadvantages. Benefits would include reducing 

pesticide usage, host specificity for target pests, long-term self-perpetuating control, low 

cost/acre, capacity for searching and locating hosts, synchronizing biological control agents to 

hosts’ life cycles, and the unlikelihood that hosts will develop resistance to agents. 

Disadvantages would include the following: limited availability of agents from their native 

lands, the dependence of control on target species density, slow rate at which control occurs, 

biotype matching, the difficulty and expense of conflicts over control of the target pest, and host 

specificity when host populations are low. 

A reduction in target species populations from biological controls is typically a slow process, and 

efficacy can be highly variable. It may not work well in a particular area although it does work 

well in other areas. Biological control agents would require specific environmental conditions to 

survive over time. Some of these conditions are understood; whereas, others are only partially 

understood or not at all. 

Biological control agents would not eradicate a target pest. When using biological control 

agents, residual levels of the target pest typically are expected; the agent population level or 

survival would be dependent upon the density of its host. After the pest population decreases, the 

population of the biological control agent would decrease correspondingly. This is a natural 

cycle. Some pest populations (e.g., invasive plants) would tend to persist for several years after a 

biological control agent becomes established due to seed reserves in the soil, inefficiencies in the 

agents search behavior, and the natural lag in population buildup of the agent. 

The full range of pest groups potentially found on refuge lands and waters would include 

diseases, invertebrates (insects, mollusks), vertebrates and invasive plants (most common group). 

Often it is assumed that biological control would address many if not most of these pest 

problems. Introduced species without desirable close relatives in the United States would 

generally be selected as biological controls. Natural enemies that are restricted to one or a few 

closely related plants in their country of origin are targeted as biological controls (Center et al. 

1997, Hasan and Ayres 1990). 

The Hawai`i Department of Agriculture (HDOA) has a highly successful bio-control program for 

the erythrina gall wasp which has resulted in the rebounding of the native wiliwili trees. In June 

2010, HDOA began another biological control program that releases a tiny parasitic insect to 

control the stinging Nettle Caterpillar. The release of Brazilian scale to slow the growth rate and 

spread of strawberry guava has recently been proposed to give Hawai‘i’s native plants a chance 

for survival, protect the ability of the forests to provide water, and provide better protection for 

agricultural crops from the fruit flies that breed in the overabundance of strawberry guava fruit. 

Due to the success of Hawai`i’s biocontrol programs, the State has become a leader in the world 

on the use of biological control to fight invasive pests. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-7 

Refuge staff would ensure introduced agents are approved by the applicable authorities. Except 

for a small number of formulated biological control products registered by USEPA under FIFRA, 

most biological control agents are regulated by the U.S. Department of Agriculture (USDA)-

Animal Plant Health Inspection Service, Plant Protection and Quarantine (APHIS-PPQ). State 

departments of agriculture and, in some cases, county agricultural commissioners or weed 

districts, have additional approval authority. 

Federal permits (USDA-APHIS-PPQ Form 526) are required to import biocontrol agents from 

another State. Form 526 may be obtained by writing: 

 USDA-APHIS-PPQ 

 Biological Assessment and Taxonomic Support 

 4700 River Road, Unit 113 

 Riverdale, MD 20737 

or 

through the internet at URL address: 

http://www.aphis.usda.gov/ppq/permits/bioligical/weedbio.html. 

The Service strongly supports the development, and legal and responsible use of appropriate, 

safe, and effective biological control agents for nuisance and nonindigenous or pest species. 

State and county agriculture departments may also be sources for biological control agents or 

they may have information about where biological control agents may be obtained. Commercial 

sources should have an Application and Permit to Move Live Plant Pests and Noxious Weeds 

(USDA-PPQ Form 226 USDA-APHIS-PPQ, Biological Assessment and Taxonomic Support, 

4700 River Road, Unit 113, Riverdale, MD 20737) to release specific biological control agents in 

a State and/or county. Furthermore, certification regarding the biological control agent’s identity 

(genus, specific epithet, sub-species and variety) and purity (e.g., parasite free, pathogen free, and 

biotic and abiotic contaminants) should be specified in purchase orders. 

Biological control agents are subject to 569 FW 1. In addition, Refuge staff would follow the 

International Code of Best Practice for Classical Biological Control of Weeds 

(http://sric.ucdavis.edu/exotic /exotic.htm) as ratified by delegates to the X International 

Symposium on Biological Control of Weeds, Bozeman, MT, July 9, 1999. This code identifies 

the following: 

 Release only approved biological control agents, 

 Use the most effective agents, 

 Document releases, and 

 Monitor for impact to the target pest, nontarget species and the environment. 

Biological control agents formulated as pesticide products and registered by the USEPA (e.g., 

Bti) are also subject to PUP review and approval (see below). 

A record of all releases would be maintained with date(s), location(s), and environmental 

conditions of the release site(s); the identity, quantity, and condition of the biological control 

agents released; and other relevant data and comments such as weather conditions. Systematic 

monitoring to determine the establishment and effectiveness of the release is also recommended. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

E-8 Appendix E. Integrated Pest Management Program 

NEPA documents regarding biological and other environmental effects of biological control 

agents prepared by another Federal agency, where the scope is relevant to evaluation of releases 

on Refuge lands, would be reviewed. Possible source agencies for such NEPA documents 

include the Bureau of Land Management, U.S. Forest Service, National Park Service, U.S. 

Department of Agriculture-Animal and Plant Health Inspection Service, and the military services. 

It might be appropriate to incorporate by reference parts or all of existing document(s) from the 

review. Incorporating by reference (43 CFR 46.135) is a technique used to avoid redundancies in 

analysis. It also can reduce the bulk of a Service NEPA document, which only must identify the 

documents that are incorporated by reference. In addition, relevant portions must be summarized 

in the Service NEPA document to the extent necessary to provide the decision maker and public 

with an understanding of relevance of the referenced material to the current analysis. 

 Pesticides. The selective use of pesticides would be based upon pest ecology (including mode of 

reproduction), the size and distribution of its populations, site-specific conditions (e.g., soils, 

topography), known efficacy under similar site conditions, and the capability to utilize best 

management practices (BMPs) to reduce/eliminate potential effects to nontarget species, sensitive 

habitats, and potential to contaminate surface and groundwater. All pesticide usage (pesticide, 

target species, application rate, and method of application) would comply with the applicable 

Federal (FIFRA) and State regulations pertaining to pesticide use, safety, storage, disposal, and 

reporting. Before pesticides can be used to eradicate, control, or contain pests on Refuge lands 

and waters, pesticide use proposals (PUPs) would be prepared and approved in accordance with 

569 FW 1. PUP records would provide a detailed, time-, site-, and target-specific description of 

the proposed use of pesticides on Refuge. All PUPs would be created, approved or disapproved, 

and stored in the Pesticide Use Proposal System (PUPS), which is a centralized database only 

accessible on the Service’s intranet (https://systems.fws.gov/pups). Only Service employees 

would be authorized to access PUP records for a Refuge in this database. 

Application equipment would be selected to provide site-specific delivery to target pests while 

minimizing/eliminating direct or indirect (e.g., drift) exposure to nontarget areas and degradation 

of surface and groundwater quality. Where possible, target-specific equipment (e.g., backpack 

sprayer, wiper) would be used to treat target pests. Other target-specific equipment to apply 

pesticides would include soaked wicks or paint brushes for wiping vegetation and lances, 

hatchets, or syringes for direct injection into stems. Granular pesticides may be applied using 

seeders or other specialized dispensers. In contrast, aerial spraying (e.g., fixed wing or 

helicopter) would only be used where access is difficult (remoteness) and/or the size/distribution 

of infestations precludes practical use of ground-based methods. 

Because repeated use of one pesticide may allow resistant organisms to survive and reproduce, 

multiple pesticides with variable modes of action would be considered for treatments on Refuge 

lands and waters. This is especially important if multiple applications within years and/or over a 

growing season likely would be necessary for habitat maintenance and restoration activities to 

achieve resource objectives. Integrated chemical and nonchemical controls also are highly 

effective, where practical, because pesticide resistant organisms can be removed from the site. 

Cost may not be the primary factor in selecting a pesticide for use on the Refuge. If the least 

expensive pesticide would potentially harm natural resources or people, then a different product 

would be selected, if available. The most efficacious pesticide available with the least potential 

to degrade environment quality (soils, surface water, and groundwater) as well as least potential 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-9 

effect to native species and communities of fish, wildlife, plants, and their habitats would be 

acceptable for use on Refuge lands in the context of an IPM approach. 

 Habitat restoration/maintenance. Restoration and/or proper maintenance of Refuge habitats 

associated with achieving wildlife and habitat objectives would be essential for long-term 

prevention, eradication, or control (at or below threshold levels) of pests. Promoting desirable 

plant communities through the manipulation of species composition, plant density, and growth 

rate is an essential component of invasive plant management (Masters et al. 1996, Masters and 

Shelly 2001, Brooks et al. 2004). The following three components of succession could be 

manipulated through habitat maintenance and restoration: site availability, species availability, 

and species performance (Cox and Anderson 2004). Although a single method (e.g., herbicide 

treatment) may eliminate or suppress pest species in the short term, the resulting gaps and bare 

soil create niches that are conducive to further invasion by the species and/or other invasive 

plants. On degraded sites where desirable species are absent or in low abundance, revegetation 

with native/desirable grasses, forbs, and legumes may be necessary to direct and accelerate plant 

community recovery, and achieve site-specific objectives in a reasonable time frame. The 

selection of appropriate species for revegetation would be dependent on a number of factors 

including resource objectives and site-specific, abiotic factors (e.g., soil texture, 

precipitation/temperature regimes, and shade conditions). Seed availability and cost, ease of 

establishment, seed production, and competitive ability also would be important considerations. 

4.0 Priorities for Treatments 

The magnitude (number, distribution, and sizes of infestations) for pest problems is too extensive and 

beyond the available capital resources to effectively address during any single field season. To 

manage pests in Refuge, it would be essential to prioritize treatment of infestations. Highest priority 

treatments would be focused on early detection and rapid response to eliminate infestations of new 

pests, if possible. This would be especially important for aggressive pests potentially impacting 

species, species groups, communities, and/or habitats associated Refuge purpose(s), System 

resources of concern (federally listed species, migratory birds, selected marine mammals, and 

interjurisdictional fish), and native species for maintaining/restoring biological integrity, diversity, 

and environmental health. 

The next priority would be treating established pests that appear in one or more previously uninfested 

areas. Moody and Mack (1988) demonstrated through modeling that small, new outbreaks of 

invasive plants eventually would infest an area larger than the established, source population. They 

also found that control efforts focusing on the large, main infestation rather than the new, small 

satellites reduced the chances of overall success. The lowest priority would be treating large 

infestations (sometimes monotypic stands) of well established pests. In this case, initial efforts 

would focus upon containment of the perimeter followed by work to control/eradicate the established 

infested area. If containment and/or control of a large infestation is not effective, then efforts would 

focus upon halting pest reproduction or managing source populations. Maxwell et al. (2009) found 

treating fewer populations that are sources represents an effective long-term strategy to reduce of 

total number of invasive populations and decreasing meta population growth rates. 

Although State listed noxious weeds would always of high priority for management, other pest 

species known to cause substantial ecological impact would also be considered. For example, shortspined kiawe may not be listed by a State as noxious, but it can greatly alter fire regimes in the 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

E-10 Appendix E. Integrated Pest Management Program 

coastal dryland shrub habitat resulting in large monotypic stands that displace native bunch grasses, 

forbs, and shrubs. Pest control would likely require a multi-year commitment from Refuge staff. 

Essential to the long-term success of pest management would be pre- and post-treatment monitoring, 

assessment of the successes and failures of treatments, and development of new approaches when 

proposed methods do not achieve desired outcomes. 

5.0 Best Management Practices (BMPs) 

BMPs can minimize or eliminate possible effects associated with pesticide usage to nontarget species 

and/or sensitive habitats as well as degradation of water quality from drift, surface runoff, or 

leaching. Based upon the Department of the Interior Pesticide Use Policy (517 DM 1) and the 

Service Pest Management Policy and Responsibilities (30 AM 12), the use of applicable BMPs 

(where feasible) also would likely ensure that pesticide uses may not adversely affect federally listed 

species and/or their critical habitats through determinations made using the process described in 

50 CFR part 402. 

The following are BMPs pertaining to mixing/handling and applying pesticides for all ground-based 

treatments of pesticides, which would be considered and utilized, where feasible, based upon targetand site-specific factors and time-specific environmental conditions. Although not listed below, the 

most important BMP to eliminate/reduce potential impacts to nontarget resources would be an IPM 

approach to prevent, control, eradicate, and contain pests. 

5.1 Pesticide Handling and Mixing 

 As a precaution against spilling, spray tanks would not be left unattended during filling. 

 All pesticide containers would be triple rinsed and the rinsate would be used as water in the 

sprayer tank and applied to treatment areas. 

 All pesticide spray equipment would be properly cleaned. Where possible, rinsate would be used 

as part of the make up water in the sprayer tank and applied to treatment areas. 

 Refuge staff would empty, triple rinsed pesticide containers that can be recycled at local 

herbicide container collections. 

 All unused pesticides would be properly discarded at a local “safe send” collection. 

 Pesticides and pesticide containers would be lawfully stored, handled, and disposed of in 

accordance with the label and in a manner safeguarding human health, fish, and wildlife and 

prevent soil and water contaminant. 

 Refuge staff would consider the water quality parameters (e.g., pH, hardness) that are important 

to ensure greatest efficacy where specified on the pesticide label. 

 All pesticide spills would be addressed immediately using procedures identified in Refuge spill 

respond plan. 

5.2 Applying Pesticides 

 Pesticide treatments would only be conducted by or under the supervision of Service personnel 

and non-Service applicators with the appropriate, State or BLM certification to safely and 

effectively conduct these activities on Refuge lands and waters. 

 Refuge staff would comply with all Federal, State, and local pesticide use laws and regulations as 

well as Service pesticide-related policies. For example, Refuge staff would use application 

equipment and apply rates for the specific pest(s) identified on the pesticide label as required 

under FIFRA. 

 Before each treatment season and prior to mixing or applying any product for the first time each 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-11 

season, all applicators would review the labels, MSDSs, and Pesticide Use Proposal (PUPs) for 

each pesticide, determining the target pest, appropriate mix rate(s), PPE, and other requirements 

listed on the pesticide label. 

 A 1’ no-spray buffer from the water’s edge would be used, where applicable, and it does not 

detrimentally influence effective control of pest species. 

 Use low impact herbicide application techniques (e.g., spot treatment, cut stump, oil basal, 

Thinvert system applications) rather than broadcast foliar applications (e.g., boom sprayer, other 

larger tank wand applications), where practical. 

 Use low volume rather than high volume foliar applications where low impact methods above are 

not feasible or practical, to maximize herbicide effectiveness and ensure correct and uniform 

application rates. 

 Applicators would use and adjust spray equipment to apply the coarsest droplet size spectrum 

with optimal coverage of the target species while reducing drift. 

 Applicators would use the largest droplet size that results in uniform coverage. 

 Applicators would use drift reduction technologies such as low-drift nozzles, where possible. 

 Where possible, spraying would occur during low (average<7mph and preferably 3-5 mph) and 

consistent direction wind conditions with moderate temperatures (typically <85 oF). 

 Where possible, applicators would avoid spraying during inversion conditions (often associated 

with calm and very low wind conditions) that can cause large-scale herbicide drift to nontarget 

areas. 

 Equipment would be calibrated regularly to ensure that the proper rate of pesticide is applied to 

the target area or species. 

 Spray applications would be made at the lowest height for uniform coverage of target pests to 

minimize/eliminate potential drift. 

 If windy conditions frequently occur during afternoons, spraying (especially boom treatments) 

would typically be conducted during early morning hours. 

 Spray applications would not be conducted on days with >30% forecast for rain within 6 hours, 

except for pesticides that are rapidly rain fast (e.g., glyphosate in 1 hour) to minimize/eliminate 

potential runoff. 

 Where possible, applicators would use drift retardant adjuvants during spray applications, 

especially adjacent to sensitive areas. 

 Where possible, applicators would use a nontoxic dye to aid in identifying target area treated as 

well as potential over spray or drift. A dye can also aid in detecting equipment leaks. If a leak is 

discovered, the application would be stopped until repairs can be made to the sprayer. 

 For pesticide uses associated with facilities management, buffers, as appropriate, would be used 

to protect sensitive habitats, especially wetlands and other aquatic habitats. 

 When drift cannot be sufficiently reduced through altering equipment set up and application 

techniques, buffer zones may be identified to protect sensitive areas downwind of applications. 

Refuge staff would only apply adjacent to sensitive areas when the wind is blowing the opposite 

direction. 

 Applicators would utilize scouting for early detection of pests to eliminate unnecessary pesticide 

applications. 

 Refuge staff would consider timing of application so native plants are protected (e.g., 

senescence) while effectively treating invasive plants. 

 Rinsate from cleaning spray equipment after application would be recaptured and reused or 

applied to an appropriate pest plant infestation. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

E-12 Appendix E. Integrated Pest Management Program 

 Application equipment (e.g., sprayer, ATV, tractor) would be thoroughly cleaned and PPE would 

be removed/disposed of on-site by applicators after treatments to eliminate the potential spread of 

pests to un-infested areas. 

6.0 Safety 

6.1 Personal Protective Equipment 

All applicators would wear the specific personal protective equipment (PPE) identified on the 

pesticide label. The appropriate PPE will be worn at all times during handling, mixing, and applying. 

PPE can include the following: disposable (e.g., Tyvek) or laundered coveralls; gloves (latex, 

rubber, or nitrile); rubber boots; and/or an NIOSH-approved respirator. Because exposure to 

concentrated product is usually greatest during mixing, extra care should be taken while preparing 

pesticide solutions. Persons mixing these solutions can be best protected if they wear long gloves, an 

apron, footwear, and a face shield. 

Coveralls and other protective clothing used during an application would be laundered separately 

from other laundry items. Transporting, storing, handling, mixing and disposing of pesticide 

containers will be consistent with label requirements, USEPA and OSHA requirements, and Service 

policy. 

If a respirator is necessary for a pesticide use, then the following requirements would be met in 

accordance with Service safety policy: a written Respirator Program, fit testing, physical 

examination (including pulmonary function and blood work for contaminants), and proper storage of 

the respirator. 

6.2 Notification 

The restricted entry interval (REI) is the time period required after the application at which point 

someone may safely enter a treated area without PPE. Refuge staff, authorized management agents 

of the Service, volunteers, and members of the public who could be in or near a pesticide treated area 

within the stated re-entry time period on the label would be notified about treatment areas. Posting 

would occur at any site where individuals might inadvertently become exposed to a pesticide during 

other activities on the Refuge. Where required by the label and/or State-specific regulations, sites 

would also be posted on its perimeter and at other likely locations of entry. Refuge staff would also 

notify appropriate private property owners of an intended application, including any private 

individuals have requested notification. Special efforts would be made to contact nearby individuals 

who are beekeepers or who have expressed chemical sensitivities. 

6.3 Medical Surveillance 

Medical surveillance may be required for Service personnel and approved volunteers who mix, 

apply, and/or monitor use of pesticides (see 242 FW 7 [Pesticide Users] and 242 FW 4 [Medical 

Surveillance]). In accordance with 242 FW 7.12A, Service personnel would be medically 

monitoring if 1 or more of the following criteria is met: exposed or may be exposed to 

concentrations at or above the published permissible exposure limits or threshold limit values (see 

242 FW 4); use pesticides in a manner considered “frequent pesticide use”; or use pesticides in a 

manner that requires a respirator (see 242 FW 14 for respirator use requirements). In 242 FW7.7A, 

“Frequent Pesticide Use” means when a person applying pesticide handles, mixes, or applies 

pesticides, with a Health Hazard rating of 3 or higher, for 8 or more hours in any week or 16 or more 

hours in any 30-day period.” Under some circumstances, individuals may be medically monitored 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-13 

who use pesticides infrequently (see section 7.7), experience an acute exposure (sudden, short term), 

or use pesticides with a health hazard ranking of 1 or 2. This decision would consider the 

individual’s health and fitness level, the pesticide’s specific health risks, and the potential risks from 

other pesticide-related activities. Refuge cooperators and other authorized agents (e.g., State and 

County employees) would be responsible for their own medical monitoring needs and costs. 

Standard examinations (at Refuge expense) of appropriate Refuge staff would be provided by the 

nearest certified occupational health and safety physician as determined by Federal Occupational 

Health. 

6.4 Certification and Supervision of Pesticide Applicators 

Appropriate Refuge staff or approved volunteers handling, mixing, and/or applying or directly 

supervising others engaged in pesticide use activities would be trained and State or federally licensed 

to apply pesticides to Refuge lands or waters. In accordance with 242 FW7.18A and 569 FW 1, 

certification is required to apply restricted use pesticides based upon USEPA regulations. For safety 

reasons, all individuals participating in pest management activities with general use pesticides also 

are encouraged to attend appropriate training or acquire pesticide applicator certification. The 

certification requirement would be for a commercial or private applicator depending upon the State. 

New staff unfamiliar with proper procedures for storing, mixing, handling, applying, and disposing 

of herbicides and containers would receive orientation and training before handling or using any 

products. Documentation of training would be kept in the files at the Refuge office. 

6.5 Record Keeping 

6.5.1 Labels and material safety data sheets 

Pesticide labels and material safety data sheets (MSDSs) would be maintained at the Refuge shop 

and laminated copies in the mixing area. These documents also would be carried by field 

applicators, where possible. A written reference (e.g., note pad, chalk board, dry erase board) for 

each tank to be mixed would be kept in the mixing area for quick reference while mixing is in 

progress. In addition, approved PUPs stored in the PUPS database typically contain website links 

(URLs) to pesticide labels and MSDSs. 

6.5.2 Pesticide use proposals (PUPs) 

A PUP would be prepared for each proposed pesticide use associated with annual pest management 

on Refuge lands and waters. A PUP would include specific information about the proposed pesticide 

use including the common and chemical names of the pesticide(s), target pest species, size and 

location of treatment site(s), application rate(s) and method(s), and federally listed species 

determinations, where applicable. 

In accordance with 30 AM 12 and 7 RM 14, PUPs would be required for the following: 

 Uses of pesticides on lands and facilities owned or managed by the Service, including properties 

managed by Service personnel as a result of the Food Security Act of 1985; 

 Service projects by non-Service personnel on Service owned or controlled lands and facilities and 

other pest management activities that would be conducted by Service personnel; and 

 Where the Service would be responsible or provides funds for pest management identified in 

protective covenants, easements, contracts, or agreements off Service lands. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

E-14 Appendix E. Integrated Pest Management Program 

In accordance with Service guidelines (Director’s memo [December 12, 2007]), Refuge staff may 

receive up to 5-year approvals for Washington Office and field reviewed proposed pesticide uses 

based upon meeting identified criteria including an approved IPM plan, where necessary (see 

http://www.fws.gov/contaminants/Issues/IPM.cfm). For a refuge, an IPM plan (requirements 

described herein) can be completed independently or in association with a CCP or HMP if IPM 

strategies and potential environmental effects are adequately addressed within appropriate NEPA 

documentation. 

PUPs would be created, approved or disapproved, and stored as records in the Pesticide Use Proposal 

System (PUPS), which is centralized database on the Service’s intranet 

(https://systems.fws.gov/pups). Only Service employees can access PUP records in this database. 

6.5.3 Pesticide usage 

In accordance with 569 FW 1, the Refuge Project Leader would be required to maintain records of all 

pesticides annually applied on lands or waters under Refuge jurisdiction. This would encompass 

pesticides applied by other Federal agencies, State and county governments, nongovernment 

applicators including cooperators and their pest management service providers with Service 

permission. For clarification, pesticide means all insecticides, insect and plant growth regulators, 

dessicants, herbicides, fungicides, rodenticides, acaricides, nematicides, fumigants, avicides, and 

piscicides. 

The following usage information can be reported for approved PUPs in the PUPS database: 

 Pesticide trade name(s) 

 Active ingredient(s) 

 Total acres treated 

 Total amount of pesticides used (lbs or gallons) 

 Total amount of active ingredient(s) used (lbs) 

 Target pest(s) 

 Efficacy (% control) 

To determine whether treatments are efficacious (eradicating, controlling, or containing the target 

pest) and achieving resource objectives, habitat and/or wildlife response would be monitored both 

pre- and post-treatment, where possible. Considering available annual funding and staffing, 

appropriate monitoring data regarding characteristics (attributes) of pest infestations (e.g., area, 

perimeter, degree of infestation-density, % cover, density) as well as habitat and/or wildlife response 

to treatments may be collected and stored in a relational database (e.g., Refuge Habitat Management 

Database), preferably a geo-referenced data management system (e.g., Refuge Lands GIS [RLGIS]) 

to facilitate data analyses and subsequent reporting. In accordance with adaptive management, data 

analysis and interpretation would allow treatments to be modified or changed over time, as 

necessary, to achieve resource objectives considering site-specific conditions in conjunction with 

habitat and/or wildlife responses. Monitoring could also identify short- and long-term impacts to 

natural resources and environmental quality associated with IPM treatments in accordance with 

adaptive management principles identified in 43 CFR 46.145. 

7.0 Evaluating Pesticide Use Proposals 

Pesticides would only be used on Refuge lands for habitat management as well as facilities 

maintenance after approval of a PUP. In general, proposed pesticide uses on Refuge lands would 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-15 

only be approved where there would likely be minor, temporary, or localized effects to fish and 

wildlife species as well as minimal potential to degrade environmental quality. Potential effects to 

listed and nonlisted species would be evaluated with quantitative ecological risk assessments and 

other screening measures. Potential effects to environmental quality would be based upon pesticide 

characteristics of environmental fate (water solubility, soil mobility, soil persistence, and 

volatilization) and other quantitative screening tools. Ecological risk assessments as well as 

characteristics of environmental fate and potential to degrade environmental quality for pesticides 

would be documented in Chemical Profiles (see Section 7.6). These profiles would include threshold 

values for quantitative measures of ecological risk assessments and screening tools for environmental 

fate that represent minimal potential effects to species and environmental quality. In general, only 

pesticide uses with appropriate BMPs (see Section 5.0) for habitat management and facilities 

maintenance on Refuge lands that would potentially have minor, temporary, or localized effects on 

Refuge biological and environmental quality (threshold values not exceeded) would be approved. 

7.1 Overview of Ecological Risk Assessment 

An ecological risk assessment process would be used to evaluate potential adverse effects to 

biological resources as a result of a pesticide(s) proposed for use on Refuge lands. It is an 

established quantitative and qualitative methodology for comparing and prioritizing risks of 

pesticides and conveying an estimate of the potential risk for an adverse effect. This quantitative 

methodology provides an efficient mechanism to integrate best available scientific information 

regarding hazard, patterns of use (exposure), and dose-response relationships in a manner that is 

useful for ecological risk decision-making. It would provide an effective way to evaluate potential 

effects where there is missing or unavailable scientific information (data gaps) to address reasonable, 

foreseeable adverse effects in the field as required under 40 CFR Part 1502.22. Protocols for 

ecological risk assessment of pesticide uses on the Refuge were developed through research and 

established by the US Environmental Protection Agency (2004). Assumptions for these risk 

assessments are presented in Section 7.2.3. 

The toxicological data used in ecological risk assessments are typically results of standardized 

laboratory studies provided by pesticide registrants to the US Environmental Protection Agency 

(USEPA) to meet regulatory requirements under the Federal Insecticide, Fungicide and Rodenticide 

Act of 1996 (FIFRA). These studies assess the acute (lethality) and chronic (reproductive) effects 

associated with short- and long-term exposure to pesticides on representative species of birds, 

mammals, freshwater fish, aquatic invertebrates, and terrestrial and aquatic plants. Other effects data 

publicly available would also be utilized for risk assessment protocols described herein. Toxicity 

endpoint and environmental fate data are available from a variety of resources. Some of the more 

useful resources can be found in Section 7.6. 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

E-16 Appendix E. Integrated Pest Management Program 

Table 1. Ecotoxicity tests used to evaluate potential effects to birds, fish, and mammals to establish 

toxicity endpoints for risk quotient calculations. 

Species Group Exposure Measurement endpoint 

Bird 

Acute Median Lethal Concentration (LC50) 

Chronic No Observed Effect Concentration (NOEC) or 

No Observed Adverse Effect Concentration (NOAEC)1 

Fish 

Acute Median Lethal Concentration (LC50) 

Chronic No Observed Effect Concentration (NOEC) or 

No Observed Adverse Effect Concentration (NOAEC)2

Mammal Acute Oral Lethal Dose (LD50) 

Chronic No Observed Effect Concentration (NOEC) or 

No Observed Adverse Effect Concentration (NOAEC)3

1

Measurement endpoints typically include a variety of reproductive parameters (e.g., number of 

eggs, number of offspring, eggshell thickness, and number of cracked eggs). 

2

Measurement endpoints for early life stage/life cycle typically include embryo hatch rates, time 

to hatch, growth, and time to swim-up. 

3

Measurement endpoints include maternal toxicity, teratogenic effects or developmental 

anomalies, evidence of mutagenicity or genotoxicity, and interference with cellular mechanisms 

such as DNA synthesis and DNA repair. 

7.2 Determining Ecological Risk to Fish and Wildlife 

The potential for pesticides used on the Refuge to cause direct adverse effects to fish and wildlife 

would be evaluated using USEPA’s Ecological Risk Assessment Process (US Environmental 

Protection Agency 2004). This deterministic approach, which is based upon a two-phase process 

involving estimation of environmental concentrations and then characterization of risk, would be 

used for ecological risk assessments. This method integrates exposure estimates (estimated 

environmental concentration [EEC] and toxicological endpoints [e.g., LC50 and oral LD50]) to 

evaluate the potential for adverse effects to species groups (birds, mammals, and fish) representative 

of legal mandates for managing units of the NWRS. This integration is achieved through risk 

quotients (RQs) calculated by dividing the EEC by acute and chronic toxicity values selected from 

standardized toxicological endpoints or published effect (Table 1). 

RQ = EEC/Toxicological Endpoint 

The level of risk associated with direct effects of pesticide use would be characterized by comparing 

calculated RQs to the appropriate Level of Concern (LOC) established by US Environmental 

Protection Agency (1998 [Table 2]). The LOC represents a quantitative threshold value for 

screening potential adverse effects to fish and wildlife resources associated with pesticide use. The 

following are four exposure-species group scenarios that would be used to characterize ecological 

risk to fish and wildlife on the Refuge: acute-listed species, acute-nonlisted species, chronic-listed 

species, and chronic-nonlisted species. 

Acute risk would indicate the potential for mortality associated with short-term dietary exposure to 

pesticides immediately after an application. For characterization of acute risks, median values from 

LC50 and LD50 tests would be used as toxicological endpoints for RQ calculations. In contrast, 

chronic risks would indicate the potential for adverse effects associated with long-term dietary 

exposure to pesticides from a single application or multiple applications over time (within a season 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-17 

and over years). For characterization of chronic risks, the no observed concentration (NOAEC) or no 

observed effect concentration (NOEC) for reproduction would be used as toxicological endpoints for 

RQ calculations. Where available, the NOAEC would be preferred over a NOEC value. 

Listed species are those federally designated as threatened, endangered, or proposed in accordance 

with the Endangered Species Act of 1973 (16 USC 1531-1544, 87 Stat. 884, as amended-Public Law 

93-205). For listed species, potential adverse effects would be assessed at the individual level 

because loss of individuals from a population could detrimentally impact a species. In contrast, risks 

to nonlisted species would consider effects at the population level. A RQ<LOC would indicate the 

proposed pesticide use “may affect, not likely to adversely effect” individuals (listed species) and it 

would not pose an unacceptable risk for adverse effects to populations (nonlisted species) for each 

taxonomic group (Table 2). In contrast, a RQ>LOC would indicate a “may affect, likely to adversely 

affect” for listed species and it would also pose unacceptable ecological risk for adverse effects to 

nonlisted species. 

 

Table 2. Presumption of unacceptable risk for birds, fish, and mammals (US EPA 1998). 

Risk Presumption Level of Concern 

Listed Species Nonlisted Species 

Acute Birds 0.1 0.5 

Fish 0.05 0.5 

Mammals 0.1 0.5 

Chronic Birds 1.0 1.0 

Fish 1.0 1.0 

Mammals 1.0 1.0 

7.2.1 Environmental exposure 

Following release into the environment through application, pesticides would experience several 

different routes of environmental fate. Pesticides which would be sprayed can move through the air 

(e.g., particle or vapor drift) and may eventually end up in other parts of the environment such as 

nontarget vegetation, soil, or water. Pesticides applied directly to the soil may be washed off the soil 

into nearby bodies of surface water (e.g., surface runoff) or may percolate through the soil to lower 

soil layers and groundwater (e.g., leaching) (Baker and Miller 1999, Pope et. al. 1999, Butler et. al. 

1998, Ramsay et. al. 1995, EXTOXNET 1993a). Pesticides which would be injected into the soil 

may also be subject to the latter two fates. The aforementioned possibilities are by no means 

complete, but it does indicate movement of pesticides in the environment is very complex with 

transfers occurring continually among different environmental compartments. In some cases, these 

exchanges occur not only between areas that are close together, but it also may involve transportation 

of pesticides over long distances (Barry 2004, Woods 2004). 

7.2.1.1 Terrestrial exposure 

The estimated environmental concentration (ECC) for exposure to terrestrial wildlife would be 

quantified using an USEPA screening-level approach (US Environmental Protection Agency 2004). 

This screening-level approach is not affected by product formulation because it evaluates pesticide 

active ingredient(s). This approach would vary depending upon the proposed pesticide application 

method: spray or granular. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

E-18 Appendix E. Integrated Pest Management Program 

7.2.1.1.1 Terrestrial-spray application 

For spray applications, exposure would be determined using the Kanaga nomogram method (US 

Environmental Protection Agency 2005a, US Environmental Protection Agency 2004, Pfleeger et al. 

1996) through the USEPA’s Terrestrial Residue Exposure model (T-REX) version 1.2.3 (US 

Environmental Protection Agency 2005b). To estimate the maximum (initial) pesticide residue on 

short grass (<8”m tall) as a general food item category for terrestrial vertebrate species, T-REX input 

variables would include the following from the pesticide label: maximum pesticide application rate 

(pounds active ingredient [acid equivalent]/acre) and pesticide half-life (days) in soil. Although there 

are other food item categories (tall grasses; broadleaf plants and small insects; and fruits, pods, seeds 

and large insects), short grass was selected because it would yield maximum EECs (240 ppm per lb 

ai/acre) for worse-case risk assessments. Short grass is not representative of forage for carnivorous 

species (e.g., raptors), but it would characterize the maximum potential exposure through the diet of 

avian and mammalian prey items. Consequently, this approach would provide a conservative 

screening tool for pesticides that do not biomagnify. 

For RQ calculations in T-REX, the model would require the weight of surrogate species and Mineau 

scaling factors (Mineau et. al. 1996). Body weights of bobwhite quail and mallard are included in TREX by default, but body weights of other organisms (Table E-3) would be entered manually. The 

Mineau scaling factor accounts for small-bodied bird species that may be more sensitive to pesticide 

exposure than would be predicted only by body weight. Mineau scaling factors would be entered 

manually with values ranging from 1 to 1.55 that are unique to a particular pesticide or group of 

pesticides. If specific information to select a scaling factor is not available, then a value of 1.15 

would be used as a default. Alternatively, zero would be entered if it is known that body weight does 

not influence toxicity of pesticide(s) being assessed. The upper bound estimate output from the TREX Kanaga nomogram would be used as an EEC for calculation of RQs. This approach would 

yield a conservative estimate of ecological risk. 

Table E-3. Average body weight of selected terrestrial wildlife species frequently used in research to 

establish toxicological endpoints (Dunning 1984). 

Species Body Weight (kg) 

Mammal (15 g) 0.015 

House sparrow 0.0277 

Mammal (35 g) 0.035 

Starling 0.0823 

Red-winged blackbird 0.0526 

Common grackle 0.114 

Japanese quail 0.178 

Bobwhite quail 0.178 

Rat 0.200 

Rock dove (aka pigeon) 0.542 

Mammal (1000 g) 1.000 

Mallard 1.082 

Ring-necked pheasant 1.135 

7.2.1.1.2 Terrestrial – granular application 

Granular pesticide formulations and pesticide-treated seed would pose a unique route of exposure for 

avian and mammalian species. The pesticide is applied in discrete units which birds or mammals 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-19 

might ingest accidentally with food items or intentionally as in the case of some bird species actively 

seeking and picking up gravel or grit to aid digestion or seed as a food source. Granules may also be 

consumed by wildlife foraging on earthworms, slugs or other soft-bodied soil organisms to which the 

granules may adhere. 

Terrestrial wildlife RQs for granular formulations or seed treatments would be calculated by dividing 

the maximum milligrams of active ingredient (ai) exposed (e.g., EEC) on the surface of an area equal 

to 1 square foot by the appropriate LD50 value multiplied by the surrogate’s body weight (Table 3). 

An adjustment to surface area calculations would be made for broadcast, banded, and in-furrow 

applications. An adjustment also would be made for applications with and without incorporation of 

the granules. Without incorporation, it would be assumed that 100% of the granules remain on the 

soil surface available to foraging birds and mammals. Press wheels push granules flat with the soil 

surface, but they are not incorporated into the soil. If granules are incorporated in the soil during 

band or T-band applications or after broadcast applications, it would be assumed only 15% of the 

applied granules remain available to wildlife. It would be assumed that only 1% of the granules are 

available on the soil surface following in-furrow applications. 

EECs for pesticides applied in granular form and as seed treatments would be determined 

considering potential ingestion rates of avian or mammalian species (e.g., 10-30% body weight/day). 

This would provide an estimate of maximum exposure that may occur as a result of granule or seed 

treatment spills such as those that commonly occur at end rows during application and planting. The 

availability of granules and seed treatments to terrestrial vertebrates would also be considered by 

calculating the loading per unit area (LD50/ft2

)for comparison to USEPA Level of Concerns (US 

Environmental Protection Agency 1998). The T-REX version 1.2.3 (US Environmental Protection 

Agency 2005b) contains a submodel which automates Kanaga exposure calculations for granular 

pesticides and treated seed. 

The following formulas will be used to calculate EECs depending upon the type of granular pesticide 

application: 

• In-furrow applications assume a typical value of 1% granules, bait, or seed remain 

unincorporated. 

mg a.i./ft.

2 

= [(lbs. product/acre)(% a.i.)(453,580 mg/lbs)(1% exposed))] / {[(43,560 ft.

2

/acre)/(row 

spacing (ft.))] / (row spacing (ft.)} 

or 

mg a.i./ft

2 

= [(lbs product/1000 ft. row)(% a.i.)(1000 ft row)(453,580 mg/lb.)(1% exposed) 

EEC = [(mg a.i./ft.

2

)(% of pesticide biologically available)] 

 Incorporated banded treatments assume that 15% of granules, bait, seeds are unincorporated. 

mg a.i./ft.

2 

= [(lbs. product/1000 row ft.)(% a.i.)(453,580 mg/lb.)(1-% incorporated)] / (1,000 

ft.)(band width (ft.)) 

EEC = [(mg a.i./ft.

2

)(% of pesticide biologically available)] 

• Broadcast treatment without incorporation assumes 100% of granules, bait, seeds are 

unincorporated. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

E-20 Appendix E. Integrated Pest Management Program 

mg a.i./ft.

2 

= [(lbs. product/acre)(% a.i.)(453,590 mg/lb.)] / (43,560 ft.

2

/acre) 

EEC = [(mg a.i./ft.

2

)(% of pesticide biologically available)] 

Where: 

• % of pesticide biologically available = 100% without species specific ingestion rates 

• Conversion for calculating mg a.i./ft.

2 

using ounces: 453,580 mg/lb. /16 = 28,349 mg/oz. 

The following equation would used to calculate a RQ based on the EEC calculated by one of the 

above equations. The EEC would divided by the surrogate LD50 toxicological endpoint multiplied by 

the body weight (Table 3) of the surrogate. 

RQ = EEC / [LD50 (mg/kg) * body weight (kg)] 

As with other risk assessments, a RQ>LOC would be a presumption of unacceptable ecological risk. 

A RQ<LOC would be a presumption of acceptable risk with only minor, temporary, or localized 

effects to species. 

7.2.1.2 Aquatic exposure 

Exposures to aquatic habitats (e.g., wetlands, meadows, ephemeral pools, water delivery ditches) 

would be evaluated separately for ground-based pesticide treatments of habitats managed for fish and 

wildlife compared with cropland/facilities maintenance. The primary exposure pathway for aquatic 

organisms from any ground-based treatments likely would be particle drift during the pesticide 

application. However, different exposure scenarios would be necessary as a result of contrasting 

application equipment and techniques as well as pesticides used to control pests on agricultural lands 

and facilities maintenance (e.g., roadsides, parking lots, trails) compared with other managed habitats 

on the Refuge. In addition, pesticide applications may be done <25’of the high water mark of 

aquatic habitats for habitat management treatments; whereas, no-spray buffers (≥25’) would be used 

for facilities maintenance treatments. 

7.2.1.2.1 Habitat treatments 

For the worst-case exposure scenario to nontarget aquatic habitats, EECs (Table 4) would be would 

be derived from Urban and Cook (1986) that assumes an intentional overspray to an entire, nontarget 

water body (1-foot depth) from a treatment <25’ from the high water mark using the max application 

rate (acid basis [see above]). However, use of BMPs for applying pesticides (see Section 4.2) would 

likely minimize/eliminate potential drift to nontarget aquatic habitats during actual treatments. If 

there would be unacceptable (acute or chronic) risk to fish and wildlife with the simulated 100% 

overspray (RQ>LOC), then the proposed pesticide use may be disapproved or the PUP would be 

approved at a lower application rate to minimize/eliminate unacceptable risk to aquatic organisms 

(RQ=LOC). 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-21 

Table E.4. Estimated Environmental Concentrations (ppb) of pesticides in aquatic habitats (1’ depth) 

immediately after direct application (Urban and Cook 1986). 

Lbs/acre EEC (ppb) 

0.10 36.7 

0.20 73.5 

0.25 91.9 

0.30 110.2 

0.40 147.0 

0.50 183.7 

0.75 275.6 

1.00 367.5 

1.25 459.7 

1.50 551.6 

1.75 643.5 

2.00 735.7 

2.25 827.6 

2.50 919.4 

3.00 1103.5 

4.00 1471.4 

5.00 1839 

6.00 2207 

7.00 2575 

8.00 2943 

9.00 3311 

10.00 3678 

7.2.1.2.2 Facilities maintenance treatments 

Field drift studies conducted by the Spray Drift Task Force, which is a joint project of several 

agricultural chemical businesses, were used to develop a generic spray drift database. From this 

database, the AgDRIFT computer model was created to satisfy USEPA pesticide registration spray 

drift data requirements and as a scientific basis to evaluate off-target movement of pesticides from 

particle drift and assess potential effects of exposure to wildlife. Several versions of the computer 

model have been developed (i.e., v2.01 through v2.10). The Spray Drift Task Force AgDRIFT® 

model version 2.01 (SDTF 2003, AgDRIFT 2001) would be used to derive EECs resulting from drift 

of pesticides to Refuge aquatic resources from ground-based pesticide applications >25’ from the 

high water mark. The Spray Drift Task Force AgDRIFT model is publicly available at 

http://www.agdrift.com. At this website, click “AgDRIFT 2.0” and then click “Download Now” and 

follow the instructions to obtain the computer model. 

The AgDRIFT model is composed of submodels called tiers. Tier I Ground submodel would be used 

to assess ground-based applications of pesticides. Tier outputs (EECs) would be calculated with 

AgDRIFT using the following input variables: max application rate (acid basis [see above]), low 

boom (20”), fine to medium droplet size, EPA-defined wetland, and a 

≥25-foot distance (buffer) from treated area to water. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

E-22 Appendix E. Integrated Pest Management Program 

7.2.2 Use of information on effects of biological control agents, pesticides, degradates, and 

adjuvants 

NEPA documents regarding biological and other environmental effects of biological control agents, 

pesticides, degradates, and adjuvants prepared by another Federal agency, where the scope would be 

relevant to evaluation of effects from pesticide uses on Refuge lands, would be reviewed. Possible 

source agencies for such NEPA documents would include the Bureau of Land Management, US 

Forest Service, National Park Service, US Department of Agriculture-Animal and Plant Health 

Inspection Service, and the military services. It might be appropriate to incorporate by reference 

parts or all of existing document(s). Incorporating by reference (40 CFR 1502.21) is a technique 

used to avoid redundancies in analysis. It also would reduce the bulk of a Service NEPA document, 

which only would identify the documents that are incorporated by reference. In addition, relevant 

portions would be summarized in the Service NEPA document to the extent necessary to provide the 

decision maker and public with an understanding of relevance of the referenced material to the 

current analysis. 

In accordance with the requirements set forth in 43 CFR 46.135, the Service would specifically 

incorporate through reference ecological risk assessments prepared by the US Forest Service 

(http://www.fs.fed.us/r6/invasiveplant-eis/Risk-Assessments/Herbicides-Analyzed-InvPlantEIS.htm) and Bureau of Land Management (http://www.blm.gov/wo/st/en/prog/more/veg_eis.html). 

These risk assessments and associated documentation also are available in total with the 

administrative record for the Final Environmental Impact Statement entitled Pacific Northwest 

Region Invasive Plant Program – Preventing and Managing Invasive Plants (US Forest Service 

2005) and Vegetation Treatments Using Herbicides on Bureau of Land Management Lands in 17 

Western States Programmatic EIS (PEIS) (Bureau of Land Management 2007). In accordance with 

43 CRF 46.120(d), use of existing NEPA documents by supplementing, tiering to, incorporating by 

reference, or adopting 

previous NEPA environmental analyses would avoid redundancy and unnecessary paperwork. 

As a basis for completing “Chemical Profiles” for approving or disapproving Refuge PUPs, 

ecological risk assessments for the following herbicide and adjuvant uses prepared by the US Forest 

Service would be incorporated by reference: 

 2,4-D 

 Chlorosulfuron 

 Clopyralid 

 Dicamba 

 Glyphosate 

 Imazapic 

 Imazapyr 

 Metsulfuron methyl 

 Picloram 

 Sethoxydim 

 Sulfometuron methyl 

 Triclopyr 

 Nonylphenol polyethylate (NPE) based surfactants 

As a basis for completing “Chemical Profiles” for approving or disapproving Refuge PUPs, 

ecological risk assessments for the following herbicide uses as well as evaluation of risks associated 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-23 

with pesticide degradates and adjuvants prepared by the Bureau of Land Management would be 

incorporated by reference: 

 Bromacil 

 Chlorsulfuron 

 Diflufenzopyr 

 Diquat 

 Diuron 

 Fluridone 

 Imazapic 

 Overdrive (diflufenzopyr and dicamba) 

 Sulfometuron methyl 

 Tebuthiuron 

 Pesticide degradates and adjuvants (Appendix D – Evaluation of risks from degradates, 

polyoxyethylene-amine (POEA) and R-11, and endocrine disrupting chemicals) 

7.2.3 Assumptions for ecological risk assessments 

There are a number of assumptions involved with the ecological risk assessment process for 

terrestrial and aquatic organisms associated with utilization of the US Environmental Protection 

Agency’s (2004) process. These assumptions may be risk neutral or may lead to an over- or underestimation of risk from pesticide exposure depending upon site-specific conditions. The following 

describes these assumptions, their application to the conditions typically encountered, and whether or 

not they may lead to recommendations that are risk neutral, underestimate, or overestimate ecological 

risk from potential pesticide exposure. 

 Indirect effects would not be evaluated by ecological risk assessments. These effects include the 

mechanisms of indirect exposure to pesticides: consuming prey items (fish, birds, or small 

mammals), reductions in the availability of prey items, and disturbance associated with pesticide 

application activities. 

 Exposure to a pesticide product can be assessed based upon the active ingredient. However, 

exposure to a chemical mixture (pesticide formulation) may result in effects that are similar or 

substantially different compared to only the active ingredient. Nontarget organisms may be 

exposed directly to the pesticide formulation or only various constituents of the formulation as 

they dissipate and partition in the environment. If toxicological information for both the active 

ingredient and formulated product are available, then data representing the greatest potential 

toxicity would be selected for use in the risk assessment process (US Environmental Protection 

Agency 2004). As a result, this conservative approach may lead to an overestimation of risk 

characterization from pesticide exposure. 

 Because toxicity tests with listed or candidate species or closely related species are not available, 

data for surrogate species would be most often used for risk assessments. Specifically, bobwhite 

quail and mallard duck are the most frequently used surrogates for evaluating potential toxicity to 

federally listed avian species. Bluegill sunfish, rainbow trout, and fathead minnow are the most 

common surrogates for evaluating toxicity for freshwater fishes. However, sheep’s head minnow 

can be an appropriate surrogate marine species for coastal environments. Rats and mice are the 

most common surrogates for evaluating toxicity for mammals. Interspecies sensitivity is a major 

source of uncertainty in pesticide assessments. As a result of this uncertainty, data is selected for 

the most sensitive species tested within a taxonomic group (birds, fish, and mammals) given the 

quality of the data is acceptable. If additional toxicity data for more species of organisms in a 

particular group are available, the selected data will not be limited to the species previously listed 

as common surrogates. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

E-24 Appendix E. Integrated Pest Management Program 

 The Kanaga nomogram outputs maximum EEC values that may be used to calculate an average 

daily concentration over a specified interval of time, which is referred to as a time-weightedaverage (TWA). The maximum EEC would be selected as the exposure input for both acute and 

chronic risk assessments in the screening-level evaluations. The initial or maximum EEC 

derived from the Kanaga nomogram represents the maximum expected instantaneous or acute 

exposure to a pesticide. Acute toxicity endpoints are determined using a single exposure to a 

known pesticide concentration typically for 48 to 96 hours. This value is assumed to represent 

ecological risk from acute exposure to a pesticide. On the other hand, chronic risk to pesticide 

exposure is a function of pesticide concentration and duration of exposure to the pesticide. An 

organism’s response to chronic pesticide exposure may result from either the concentration of the 

pesticide, length of exposure, or some combination of both factors. Standardized tests for 

chronic toxicity typically involve exposing an organism to several different pesticide 

concentrations for a specified length of time (days, weeks, months, years or generations). For 

example, avian reproduction tests include a 10-week exposure phase. Because a single length of 

time is used in the test, time response data is usually not available for inclusion into risk 

assessments. Without time response data it is difficult to determine the concentration which 

elicited a toxicological response. 

 Using maximum EECs for chronic risk estimates may result in an overestimate of risk, 

particularly for compounds that dissipate rapidly. Conversely, using TWAs for chronic risk 

estimates may underestimate risk if it is the concentration rather than the duration of exposure 

that is primarily responsible for the observed adverse effect. The maximum EEC would be used 

for chronic risk assessments although it may result in an overestimate of risk. TWAs may be 

used for chronic risk assessments, but they will be applied judiciously considering the potential 

for an underestimate or overestimate of risk. For example, the number of days exposure exceeds 

a Level of Concern may influence the suitability of a pesticide use. The greater the number of 

days the EEC exceeds the Level of Concern translates into greater the ecological risk. This is a 

qualitative assessment, and is subject to reviewer’s expertise in ecological risk assessment and 

tolerance for risk. 

 The length of time used to calculate the TWA can have a substantial effect on the exposure 

estimates and there is no standard method for determining the appropriate duration for this 

estimate. The T-REX model assumes a 21-week exposure period, which is equivalent to avian 

reproductive studies designed to establish a steady-state concentration for bioaccumulative 

compounds. However, this does not necessarily define the true exposure duration needed to elicit 

a toxicological response. Pesticides, which do not bioaccumulate, may achieve a steady-state 

concentration earlier than 21 weeks. The duration of time for calculating TWAs will require 

justification and it will not exceed the duration of exposure in the chronic toxicity test 

(approximately 70 days for the standard avian reproduction study). An alternative to using the 

duration of the chronic toxicity study is to base the TWA on the application interval. In this case, 

increasing the application interval would suppress both the estimated peak pesticide 

concentration and the TWA. Another alternative to using TWAs would be to consider the 

number of days that a chemical is predicted to exceed the LOC. 

 Pesticide dissipation is assumed to be first-order in the absence of data suggesting alternative 

dissipation patterns such as bi-phasic. Field dissipation data would generally be the most 

pertinent for assessing exposure in terrestrial species that forage on vegetation. However, this 

data is often not available and it can be misleading particularly if the compound is prone to 

“wash-off”. Soil half-life is the most common degradation data available. Dissipation or 

degradation data that would reflect the environmental conditions typical of Refuge lands would 

be utilized, if available. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-25 

 For species found in the water column, it would be assumed that the greatest bioavailable fraction 

of the pesticide active ingredient in surface waters is freely dissolved in the water column. 

 Actual habitat requirements of any particular terrestrial species are not considered, and it is 

assumed that species exclusively and permanently occupy the treated area, or adjacent areas 

receiving pesticide at rates commensurate with the treatment rate. This assumption would 

produce a maximum estimate of exposure for risk characterization. This assumption would 

likely lead to an overestimation of exposure for species that do not permanently and exclusively 

occupy the treated area (US Environmental Protection Agency 2004). 

 Exposure through incidental ingestion of pesticide contaminated soil is not considered in the 

USEPA risk assessment protocols. Research suggests <15% of the diet can consist of 

incidentally ingested soil depending upon species and feeding strategy (Beyer et al. 1994). An 

assessment of pesticide concentrations in soil compared to food item categories in the Kanaga 

nomogram indicates incidental soil ingestion will not likely increase dietary exposure to 

pesticides. Inclusion of soil into the diet would effectively reduce the overall dietary 

concentration compared to the present assumption that the entire diet consists a contaminated 

food source (Fletcher et al. 1994). An exception to this may be soil-applied pesticides in which 

exposure from incidental ingestion of soil may increase. Potential for pesticide exposure under 

this assumption may be underestimated for soil-applied pesticides and overestimated for foliarapplied pesticides. The concentration of a pesticide in soil would likely be less than predicted on 

food items. 

 Exposure through inhalation of pesticides is not considered in the USEPA risk assessment 

protocols. Such exposure may occur through three potential sources: spray material in droplet 

form at time of application, vapor phase with the pesticide volatilizing from treated surfaces, and 

airborne particulates (soil, vegetative matter, and pesticide dusts). The USEPA (1990) reported 

exposure from inhaling spray droplets at the time of application is not an appreciable route of 

exposure for birds. According to research on mallards and bobwhite quail, respirable particle size 

(particles reaching the lung) in birds is limited to maximum diameter of 2 to 5 microns. The 

spray droplet spectra covering the majority of pesticide application scenarios indicate that less 

than 1% of the applied material is within the respirable particle size. This route of exposure is 

further limited because the permissible spray drop size distribution for ground pesticide 

applications is restricted to ASAE medium or coarser drop size distribution. 

 Inhalation of a pesticide in the vapor phase may be another source of exposure for some 

pesticides under certain conditions. This mechanism of exposure to pesticides occurs post 

application and it would pertain to those pesticides with a high vapor pressure. The USEPA is 

currently evaluating protocols for modeling inhalation exposure from pesticides including nearfield and near-ground air concentrations based upon equilibrium and kinetics-based models. Risk 

characterization for exposure with this mechanism is unavailable. 

 The effect from exposure to dusts contaminated with the pesticide cannot be assessed generically 

as partitioning issues related to application site soils and chemical properties of the applied 

pesticides render the exposure potential from this route highly situation specific. 

 Dermal exposure may occur through three potential sources: direct application of spray to 

terrestrial wildlife in the treated area or within the drift footprint, incidental contact with 

contaminated vegetation, or contact with contaminated water or soil. Interception of spray and 

incidental contact with treated substrates may pose risk to avian wildlife (Driver et al. 1991). 

However, available research related to wildlife dermal contact with pesticides is extremely 

limited, except dermal toxicity values are common for some mammals used as human surrogates 

(rats and mice). The USEPA is currently evaluating protocols for modeling dermal exposure. 

Risk characterization may be underestimated for this route of exposure, particularly with high 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

E-26 Appendix E. Integrated Pest Management Program 

risk pesticides such as some organophosphates or carbamate insecticides. If protocols are 

established by the USEPA for assessing dermal exposure to pesticides, they will be considered 

for incorporation into pesticide assessment protocols. 

 Exposure to a pesticide may occur from consuming surface water, dew or other water on treated 

surfaces. Water soluble pesticides have potential to dissolve in surface runoff and puddles in a 

treated area may contain pesticide residues. Similarly, pesticides with lower organic carbon 

partitioning characteristics and higher solubility in water have a greater potential to dissolve in 

dew and other water associated with plant surfaces. Estimating the extent to which such 

pesticide loadings to drinking water occurs is complex and would depend upon the partitioning 

characteristics of the active ingredient, soils types in the treatment area, and the meteorology of 

the treatment area. In addition, the use of various water sources by wildlife is highly speciesspecific. Currently, risk characterization for this exposure mechanism is not available. The 

USEPA is actively developing protocols to quantify drinking water exposures from puddles and 

dew. If and when protocols are formally established by the USEPA for assessing exposure to 

pesticides through drinking water, these protocols will be incorporated into pesticide risk 

assessment protocols. 

 Risk assessments are based upon the assumption that the entire treatment area would be subject 

to pesticide application at the rates specified on the label. In most cases, there is potential for 

uneven application of pesticides through such plausible incidents such as changes in calibration 

of application equipment, spillage, and localized releases at specific areas in or near the treated 

field that are associated with mixing and handling and application equipment as well as 

applicator skill. Inappropriate use of pesticides and the occurrence of spills represent a potential 

underestimate of risk. It is likely not an important factor for risk characterization. All pesticide 

applicators are required to be certified by the State in which they apply pesticides. Certification 

training includes the safe storage, transport, handling, and mixing of pesticides, equipment 

calibration and proper application with annual continuing education. 

 The USEPA relies on Fletcher (1994) for setting the assumed pesticide residues in wildlife 

dietary items. The USEPA (2004) “believes that these residue assumptions reflect a realistic 

upper-bound residue estimate, although the degree to which this assumption reflects a specific 

percentile estimate is difficult to quantify”. Fletcher’s (1994) research suggests that the pesticide 

active ingredient residue assumptions used by the USEPA represent a 95th percentile estimate. 

However, research conducted by Pfleeger et al. (1996) indicates USEPA residue assumptions for 

short grass was not exceeded. Baehr and Habig (2000) compared USEPA residue assumptions 

with distributions of measured pesticide residues for the USEPA’s UTAB database. Overall 

residue selection level will tend to overestimate risk characterization. This is particularly evident 

when wildlife individuals are likely to have selected a variety of food items acquired from 

multiple locations. Some food items may be contaminated with pesticide residues whereas others 

are not contaminated. However, it is important to recognize differences in species feeding 

behavior. Some species may consume whole above-ground plant material, but others will 

preferentially select different plant structures. Also, species may preferentially select a food item 

although multiple food items may be present. Without species specific knowledge regarding 

foraging behavior characterizing ecological risk other than in general terms is not possible. 

 Acute and chronic risk assessments rely on comparisons of wildlife dietary residues with LC50 or 

NOEC values expressed as concentrations of pesticides in laboratory feed. These comparisons 

assume that ingestion of food items in the field occurs at rates commensurate with those in the 

laboratory. Although the screening assessment process adjusts dry-weight estimates of food 

intake to reflect the increased mass in fresh-weight wildlife food intake estimates, it does not 

allow for gross energy and assimilative efficiency differences between wildlife food items and 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-27 

laboratory feed. Differences in assimilative efficiency between laboratory and wild diets suggest 

that current screening assessment methods are not accounting for a potentially important aspect 

of food requirements. 

 There are several other assumptions that can affect nontarget species not considered in the risk 

assessment process. These include possible additive or synergistic effects from applying two or 

more pesticides or additives in a single application, co-location of pesticides in the environment, 

cumulative effects from pesticides with the same mode of action, effects of multiple stressors 

(e.g., combination of pesticide exposure, adverse abiotic and biotic factors) and behavioral 

changes induced by exposure to a pesticide. These factors may exist at some level contributing 

to adverse affects to nontarget species, but they are usually characterized in the published 

literature in only a general manner limiting their value in the risk assessment process.

 It is assumed that aquatic species exclusively and permanently occupy the water body being 

assessed. Actual habitat requirements of aquatic species are not considered. With the possible 

exception of scenarios where pesticides are directly applied to water, it is assumed that no habitat 

use considerations specific for any species would place the organisms in closer proximity to 

pesticide use sites. This assumption produces a maximum estimate of exposure or risk 

characterization. It would likely be realistic for many aquatic species that may be found in 

aquatic habitats within or in close proximity to treated terrestrial habitats. However, the spatial 

distribution of wildlife is usually not random because wildlife distributions are often related to 

habitat requirements of species. Clumped distributions of wildlife may result in an under- or 

over-estimation of risk depending upon where the initial pesticide concentration occurs relative 

to the species or species habitat. 

 For species found in the water column, it would be assumed that the greatest bioavailable fraction 

of the pesticide active ingredient in surface waters is freely dissolved in the water column. 

Additional chemical exposure from materials associated with suspended solids or food items is 

not considered because partitioning onto sediments likely is minimal. Adsorption and 

bioconcentration occurs at lower levels for many newer pesticides compared with older more 

persistent bioaccumulative compounds. Pesticides with RQs close to the listed species level of 

concern, the potential for additional exposure from these routes may be a limitation of risk 

assessments, where potential pesticide exposure or risk may be underestimated. 

 Mass transport losses of pesticide from a water body (except for losses by volatilization, 

degradation and sediment partitioning) would not be considered for ecological risk assessment. 

The water body would be assumed to capture all pesticide active ingredients entering as runoff, 

drift, and adsorbed to eroded soil particles. It would also be assumed that pesticide active 

ingredient is not lost from the water body by overtopping or flow-through, nor is concentration 

reduced by dilution. In total, these assumptions would lead to a near maximum possible waterborne concentration. However, this assumption would not account for potential to concentrate 

pesticide through the evaporative loss. This limitation may have the greatest impact on water 

bodies with high surface-to-volume ratios such as ephemeral wetlands, where evaporative losses 

are accentuated and applied pesticides have low rates of degradation and volatilization. 

 For acute risk assessments, there would be no averaging time for exposure. An instantaneous 

peak concentration would be assumed, where instantaneous exposure is sufficient in duration to 

elicit acute effects comparable to those observed over more protracted exposure periods 

(typically 48 to 96 hours) tested in the laboratory. In the absence of data regarding time-to-toxic 

event, analyses and latent responses to instantaneous exposure, risk would likely be 

overestimated. 

 For chronic exposure risk assessments, the averaging times considered for exposure are 

commensurate with the duration of invertebrate life-cycle or fish-early life stage tests (e.g., 21-28 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

E-28 Appendix E. Integrated Pest Management Program 

days and 56-60 days, respectively). Response profiles (time to effect and latency of effect) to 

pesticides likely vary widely with mode of action and species and should be evaluated on a caseby-case basis as available data allow. Nevertheless, because the USEPA relies on chronic 

exposure toxicity endpoints based on a finding of no observed effect, the potential for any latent 

toxicity effects or averaging time assumptions to alter the results of an acceptable chronic risk 

assessment prediction is limited. The extent to which duration of exposure from water-borne 

concentrations overestimate or underestimate actual exposure depends on several factors. These 

include the following: localized meteorological conditions, runoff characteristics of the 

watershed (e.g., soils, topography), the hydrological characteristics of receiving waters, 

environmental fate of the pesticide active ingredient, and the method of pesticide application. It 

should also be understood that chronic effects studies are performed using a method that holds 

water concentration in a steady state. This method is not likely to reflect conditions associated 

with pesticide runoff. Pesticide concentrations in the field increase and decrease in surface water 

on a cycle influenced by rainfall, pesticide use patterns, and degradation rates. As a result of the 

dependency of this assumption on several undefined variables, risk associated with chronic 

exposure may in some situations underestimate risk and overestimate risk in others. 

 There are several other factors that can affect nontarget species not considered in the risk 

assessment process. These would include the following: possible additive or synergistic effects 

from applying two or more pesticides or additives in a single application, co-location of 

pesticides in the environment, cumulative effects from pesticides with the same mode of action, 

effects of multiple stressors (e.g., combination of pesticide exposure, adverse abiotic [not 

pesticides] and biotic factors), and sub-lethal effects such as behavioral changes induced by 

exposure to a pesticide. These factors may exist at some level contributing to adverse affects to 

nontarget species, but they are not routinely assessed by regulatory agencies. Therefore, 

information on the factors is not extensive limiting their value for the risk assessment process. As 

this type of information becomes available, it would be included, either quantitatively or 

qualitatively, in this risk assessment process. 

 USEPA is required by the Food Quality Protection Act to assess the cumulative risks of 

pesticides that share common mechanisms of toxicity, or act the same within an organism. 

Currently, USEPA has identified four groups of pesticides that have a common mechanism of 

toxicity requiring cumulative risk assessments. These four groups are: the organophosphate 

insecticides, N-methyl carbamate insecticides, triazine herbicides, and chloroacetanilide 

herbicides. 

7.3 Pesticide Mixtures and Degradates 

Pesticide products are usually a formulation of several components generally categorized as active 

ingredients and inert or other ingredients. The term active ingredient is defined by the FIFRA as 

preventing, destroying, repelling, or mitigating the effects of a pest, or it is a plant regulator, 

defoliant, desiccant, or nitrogen stabilizer. In accordance with FIFRA, the active ingredient(s) must 

be identified by name(s) on the pesticide label along with its relative composition expressed in 

percentage(s) by weight. In contrast, inert ingredient(s) are not intended to affect a target pest. Their 

role in the pesticide formulation is to act as a solvent (keep the active ingredient is a liquid phase), an 

emulsifying or suspending agent (keep the active ingredient from separating out of solution), or a 

carrier such as clay in which the active ingredient is impregnated on the clay particle in dry 

formulations. For example, if isopropyl alcohol would be used as a solvent in a pesticide 

formulation, then it would be considered an inert ingredient. FIFRA only requires that inert 

ingredients identified as hazardous and associated percent composition, and the total percentage of 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-29 

all inert ingredients must be declared on a product label. Inert ingredients that are not classified as 

hazardous are not required to be identified. 

The USEPA (September 1997) issued Pesticide Regulation Notice 97-6 which encouraged 

manufacturers, formulators, producers, and registrants of pesticide products to voluntarily substitute 

the term “other ingredients” for “inert ingredients” in the ingredient statement. This change 

recognized that all components in a pesticide formulation potentially could elicit or contribute to an 

adverse effect on nontarget organisms and, therefore, are not necessarily inert. Whether referred to 

as “inerts” or “other ingredients,” these constituents within a pesticide product have the potential to 

affect species or environmental quality. The USEPA categorizes regulated inert ingredients into the 

following four lists (http://www.epa.gov/opprd001/inerts/index.html): 

• List 1 – Inert Ingredients of Toxicological Concern 

• List 2 – Potentially Toxic Inert Ingredients 

• List 3 – Inerts of Unknown Toxicity 

• List 4 – Inerts of Minimal Toxicity 

Several of the List 4 compounds are naturally-occurring earthen materials (e.g., clay materials, 

simple salts) that would not elicit toxicological response at applied concentrations. However, some 

of the inerts (particularly the List 3 compounds and unlisted compounds) may have moderate to high 

potential toxicity to aquatic species based on MSDSs or published data. 

Comprehensively assessing potential effects to nontarget fish, wildlife, plants, and/or their habitats 

from pesticide use is a complex task. It would be preferable to assess the cumulative effects from 

exposure to the active ingredient, its degradates, and inert ingredients as well as other active 

ingredients in the spray mixture. However, it would only be feasible to conduct deterministic risk 

assessments for each component in the spray mixture singly. Limited scientific information is 

available regarding ecological effects (additive or synergistic) from chemical mixtures that typically 

rely upon broadly encompassing assumptions. For example, the US Forest Service (2005) found that 

mixtures of pesticides used in land (forest) management likely would not cause additive or 

synergistic effects to nontarget species based upon a review of scientific literature regarding 

toxicological effects and interactions of agricultural chemicals (ATSDR 2004). Moreover, 

information on inert ingredients, adjuvants, and degradates is often limited by the availability of and 

access to reliable toxicological data for these constituents. 

Toxicological information regarding “other ingredients” may be available from sources such as the 

following: 

• TOMES (a proprietary toxicological database including USEPA’s IRIS, the Hazardous Substance 

Data Bank, the Registry of Toxic Effects of Chemical Substances [RTECS]). 

• USEPA’s ECOTOX database, which includes AQUIRE (a database containing scientific papers 

published on the toxic effects of chemicals to aquatic organisms). 

• TOXLINE (a literature searching tool). 

• Material Safety Data Sheets (MSDSs) from pesticide suppliers. 

• Other sources such as the Farm Chemicals Handbook. 

Because there is a lack of specific inert toxicological data, inert(s) in a pesticide may cause adverse 

ecological effects. However, inert ingredients typically represent only a small percentage of the 

pesticide spray mixture, and it would be assumed that negligible effects would be expected to result 

from inert ingredient(s). 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

E-30 Appendix E. Integrated Pest Management Program 

Although the potential effects of degradates should be considered when selecting a pesticide, it is 

beyond the scope of this assessment process to consider all possible breakdown chemicals of the 

various product formulations containing an active ingredient. Degradates may be more or less 

mobile and more or less hazardous in the environment than their parent pesticides (Battaglin et al. 

2003). Differences in environmental behavior (e.g., mobility) and toxicity between parent pesticides 

and degradates would make assessing potential degradate effects extremely difficult. For example, a 

less toxic and more mobile, bioaccumulative, or persistent degradate may have potentially greater 

effects on species and/or degrade environmental quality. The lack of data on the toxicity of 

degradates for many pesticides would represent a source of uncertainty for assessing risk. 

An USEPA-approved label specifies whether a product can be mixed with one or more pesticides. 

Without product-specific toxicological data, it would not possible to quantify the potential effects of 

these mixtures. In addition, a quantitative analysis could only be conducted if reliable scientific 

information allowed a determination of whether the joint action of a mixture would be additive, 

synergistic, or antagonistic. Such information would not likely exist unless the mode of action would 

be common among the chemicals and receptors. Moreover, the composition of and exposure to 

mixtures would be highly site- and/or time-specific and, therefore, it would be nearly impossible to 

assess potential effects to species and environmental quality. 

To minimize or eliminate potential negative effects associated with applying two or more pesticides 

as a mixture, the use would be conducted in accordance with the labeling requirements. Labels for 

two or more pesticides applied as a mixture should be completely reviewed, where products with the 

least potential for negative effects would be selected for use on the Refuge. This is especially 

relevant when a mixture would be applied in a manner that may already have the potential for an 

effect(s) associated with an individual pesticide (e.g., runoff to ponds in sandy watersheds). Use of a 

tank mix under these conditions would increase the level of uncertainty in terms of risk to species or 

potential to degrade environmental quality. 

Adjuvants generally function to enhance or prolong the activity of pesticide. For terrestrial 

herbicides, adjuvants aid in the absorption into plant tissue. Adjuvant is a broad term that generally 

applies to surfactants, selected oils, anti-foaming agents, buffering compounds, drift control agents, 

compatibility agents, stickers, and spreaders. Adjuvants are not under the same registration 

requirements as pesticides and the USEPA does not register or approve the labeling of spray 

adjuvants. Individual pesticide labels identify types of adjuvants approved for use with it. In 

general, adjuvants compose a relatively small portion of the volume of pesticides applied. Selection 

of adjuvants with limited toxicity and low volumes would be recommended to reduce the potential 

for the adjuvant to influence the toxicity of the pesticide. 

7.4 Determining Effects to Soil and Water Quality 

The approval process for pesticide uses would consider potential to degrade water quality on and off 

Refuge lands. A pesticide can only affect water quality through movement away from the treatment 

site. After application, pesticide mobilization can be characterized by one or more of the following 

(Kerle et al. 1996): 

 Attach (sorb) to soil, vegetation, or other surfaces and remain at or near the treated area; 

 Attach to soil and move off-site through erosion from run-off or wind; 

 Dissolve in water that can be subjected to run-off or leaching. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-31 

As an initial screening tool, selected chemical characteristics and rating criteria for a pesticide can be 

evaluated to assess potential to enter ground and/or surface waters. These would include the 

following: persistence, sorption coefficient (Koc), groundwater ubiquity score (GUS), and solubility. 

Persistence, which is expressed as half-life (t1⁄2), represents the length of time required for 50% of the 

deposited pesticide to degrade (completely or partially). Persistence in the soil can be categorized as 

the following: nonpersistent <30 days, moderately persistent = 30 to 100 days, and persistent >100 

days (Kerle et. al. 1996). Half-life data is usually available for aquatic and terrestrial environments. 

Another measure of pesticide persistence is dissipation time (DT50). It represents the time required 

for 50% of the deposited pesticide to degrade and move from a treated site; whereas, half-life 

describes the rate for degradation only. As for half-life, units of dissipation time are usually 

expressed in days. Field or foliar dissipation time is the preferred data for use to estimate pesticide 

concentrations in the environment. However, soil half-life is the most common persistence data 

cited in published literature. If field or foliar dissipation data is not available, soil half-life data may 

be used. The average or representative half-life value of most important degradation mechanism will 

be selected for quantitative analysis for both terrestrial and aquatic environments. 

Mobility of a pesticide is a function of how strongly it is adsorbed to soil particles and organic 

matter, its solubility in water, and its persistence in the environment. Pesticides strongly adsorbed to 

soil particles, relatively insoluble in water, and not environmentally persistent would be less likely to 

move across the soil surface into surface waters or to leach through the soil profile and contaminate 

groundwater. Conversely, pesticides that are not strongly adsorbed to soil particles, are highly water 

soluble, and are persistent in the environment would have greater potential to move from the 

application site (off-site movement). 

The degree of pesticide adsorption to soil particles and organic matter (Kerle et. al. 1996) is 

expressed as the soil adsorption coefficient (Koc). The soil adsorption coefficient is measured as 

micrograms of pesticide per gram of soil (μg/g) that can range from near zero to the thousands. 

Pesticides with higher Koc values are strongly sorbed to soil and, therefore, would be less subject to 

movement. 

Water solubility describes the amount of pesticide that will dissolve in a known quantity of water. 

The water solubility of a pesticide is expressed as milligrams of pesticide dissolved in a liter of water 

(mg/l or ppm). Pesticide with solubility <0.1 ppm are virtually insoluble in water, 100-1000 ppm are 

moderately soluble, and >10,000 ppm highly soluble (US Geological Survey 2000). As pesticide 

solubility increases, there would be greater potential for off-site movement. 

The Groundwater Ubiquity Score (GUS) is a quantitative screening tool to estimate a pesticide’s 

potential to move in the environment. It utilizes soil persistence and adsorption coefficients in the 

following formula. 

GUS = log10 (t1⁄2) x [4 - log10 (Koc)] 

The potential pesticide movement rating would be based upon its GUS value. Pesticides with a GUS 

<0.1 would considered to have an extremely low potential to move toward groundwater. Values of 

1.0-2.0 would be low, 2.0-3.0 would be moderate, 3.0-4.0 would be high, and 

>4.0 would have a very high potential to move toward groundwater. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

E-32 Appendix E. Integrated Pest Management Program 

Water solubility describes the amount of pesticide dissolving in a specific quantity of water, where it 

is usually measured as mg/l or parts per million (ppm). Solubility is useful as a comparative measure 

because pesticides with higher values are more likely to move by run-off or leaching. GUS, water 

solubility, t1⁄2, and Koc values are available for selected pesticides from the OSU Extension Pesticide 

Properties Database at http://npic.orst.edu/ppdmove.htm. Many of the values in this database were 

derived from the SCS/ARS/CES Pesticide Properties Database for Environmental Decision Making 

(Wauchope et al. 1992). 

Soil properties influence the fate of pesticides in the environment. The following six properties are 

mostly likely to affect pesticide degradation and the potential for pesticides to move off-site by 

leaching (vertical movement through the soil) or runoff (lateral movement across the soil surface). 

 Permeability is the rate of water movement vertically through the soil. It is affected by soil 

texture and structure. Coarse textured soils (e.g., high sand content) have a larger pore size and 

they are generally more permeable than fine textured soils (i.e., high clay content). The more 

permeable soils would have a greater potential for pesticides to move vertically down through the 

soil profile. Soil permeability rates (inches/hour) are usually available in county soil survey 

reports. 

 Soil texture describes the relative percentage of sand, silt, and clay. In general, greater clay 

content with smaller the pore size would lower the likelihood and rate water that would move 

through the soil profile. Clay also serves to adsorb (bind) pesticides to soil particles. Soils with 

high clay content would adsorb more pesticide than soils with relatively low clay content. In 

contrast, sandy soils with coarser texture and lower water holding capacity would have a greater 

potential for water to leach through them. 

 Soil structure describes soil aggregation. Soils with a well developed soil structure have looser, 

more aggregated, structure that would be less likely to be compacted. Both characteristics would 

allow for less restricted flow of water through the soil profile resulting in greater infiltration.

 Organic matter would be the single most important factor affecting pesticide adsorption in soils. 

Many pesticides are adsorbed to organic matter which would reduce their rate of downward 

movement through the soil profile. Also, soils high in organic matter would tend to hold more 

water, which may make less water available for leaching. 

 Soil moisture affects how fast water would move through the soil. If soils are already wet or 

saturated before rainfall or irrigation, excess moisture would runoff rather than infiltrate into the 

soil profile. Soil moisture also would influence microbial and chemical activity in soil, which 

effects pesticide degradation. 

 Soil pH would influence chemical reactions that occur in the soil which in turn determines 

whether or not a pesticide will degrade, rate of degradation, and, in some instances, which 

degradation products are produced. 

Based upon the aforementioned properties, soils most vulnerable to groundwater contamination 

would be sandy soils with low organic matter. In contrast, the least vulnerable soils would be welldrained clayey soils with high organic matter. Consequently, pesticides with the lowest potential for 

movement in conjunction with appropriate best management practices (see below) would be used in 

an IPM framework to treat pests while minimizing effects to nontarget biota and protecting 

environmental quality. 

Along with soil properties, the potential for a pesticide to affect water quality through run-off and 

leaching would consider site-specific environmental and abiotic conditions including rainfall, water 

table conditions, and topography (Huddleston 1996). 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-33 

 Water is necessary to separate pesticides from soil. This can occur in two basic ways. Pesticides 

that are soluble move easily with runoff water. Pesticide-laden soil particles can be dislodged 

and transported from the application site in runoff. The concentration of pesticides in the surface 

runoff would be greatest for the first runoff event following treatment. The rainfall intensity and 

route of water infiltration into soil, to a large extent, determine pesticide concentrations and 

losses in surface runoff. The timing of the rainfall after application also would have an effect. 

Rainfall interacts with pesticides at a shallow soil depth (1⁄4 to 1⁄2 inch), which is called the mixing 

zone (Baker and Miller 1999). The pesticide/water mixture in the mixing zone would tend to 

leach down into the soil or runoff depending upon how quickly the soil surface becomes 

saturated and how rapidly water can infiltrate into the soil. Leaching would decrease the amount 

of pesticide available near the soil surface (mixing zone) to runoff during the initial rainfall event 

following application and subsequent rainfall events. 

 Terrain slope would affect the potential for surface runoff and the intensity of runoff. Steeper 

slopes would have greater potential for runoff following a rainfall event. In contrast, soils that 

are relatively flat would have little potential for runoff, except during intense rainfall events. In 

addition, soils in lower areas would be more susceptible to leaching as a result of receiving 

excessive water from surrounding higher elevations. 

 Depth to groundwater would be an important factor affecting the potential for pesticides to leach 

into groundwater. If the distance from the soil surface to the top of the water table is shallow, 

pesticides would have less distance to travel to reach groundwater. Shallower water tables that 

persist for longer periods would be more likely to experience groundwater contamination. Soil 

survey reports are available for individual counties. These reports provide data in tabular format 

regarding the water table depths and the months during which it is persists. In some situations, a 

hard pan exists above the water table that would prevent pesticide contamination from leaching. 

7.5 Determining Effects to Air Quality 

Pesticides may volatilize from soil and plant surfaces and move from the treated area into the 

atmosphere. The potential for a pesticide to volatilize is determined by the pesticide’s vapor pressure 

which would be affected by temperature, sorption, soil moisture, and the pesticide’s water solubility. 

Vapor pressure is often expressed in mm Hg. To make these numbers easier to compare, vapor 

pressure may be expressed in exponent form (I x 10-7), where I represents a vapor pressure index. In 

general, pesticides with I<10 would have a low potential to volatilize; whereas, pesticides with 

I>1,000 would have a high potential to volatilize (Oregon State University 1996). Vapor pressure 

values for pesticides are usually available in the pesticide product MSDS or the USDA Agricultural 

Research Service (ARS) pesticide database. 

7.6 Preparing a Chemical Profile 

The following instructions would be used by Service personnel to complete Chemical Profiles for 

pesticides. Specifically, profiles would be prepared for pesticide active ingredients (e.g., glyphosate, 

imazapic) that would be contained in one or more trade name products that are registered and labeled 

with USEPA. All information fields under each category (e.g., Toxicological Endpoints, 

Environmental Fate) would be completed for a Chemical Profile. If no information is available for a 

specific field, then “No data is available in references” would be recorded in the profile. Available 

scientific information would be used to complete Chemical Profiles. Each entry of scientific 

information would be shown with applicable references. 

Completed Chemical Profiles would provide a structured decision-making process utilizing 

quantitative assessment/screening tools with threshold values (where appropriate) that would be used 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

E-34 Appendix E. Integrated Pest Management Program 

to evaluate potential biological and other environmental effects to Refuge resources. For ecological 

risk assessments presented in these profiles, the “worst-case scenario” would be evaluated to 

determine whether a pesticide could be approved for use considering the maximum single application 

rate specified on pesticide labels for habitat management and croplands/facilities maintenance 

treatments pertaining to Refuges. Where the “worst-case scenario” likely would only result in minor, 

temporary, and localized effects to listed and nonlisted species with appropriate BMPs (see Section 

5.0), the proposed pesticide’s use in a PUP would have a scientific basis for approval under any 

application rate specified on the label that is at or below rates evaluated in a Chemical Profile. In 

some cases, the Chemical Profile would include a lower application rate than the maximum labeled 

rate in order to protect Refuge resources. As necessary, Chemical Profiles would be periodically 

updated with new scientific information or as pesticides with the same active ingredient are proposed 

for use on the Refuge in PUPs. 

Throughout this section, threshold values (to prevent or minimize potential biological and 

environmental effects) would be clearly identified for specific information presented in a completed 

Chemical Profile. Comparison with these threshold values provides an explicit scientific basis to 

approve or disapprove PUPs for habitat management and cropland/facilities maintenance on Refuge 

lands. In general, PUPs would be approved for pesticides with Chemical Profiles where there would 

be no exceedances of threshold values. However, BMPs are identified for some screening tools that 

would minimize/eliminate potential effects (exceedance of the threshold value) as a basis for 

approving PUPs. 

Date: Service personnel would record the date when the Chemical Profile is completed or updated. 

Chemical Profiles (e.g., currently approved pesticide use patterns) would be periodically reviewed 

and updated, as necessary. The most recent review date would be recorded on a profile to document 

when it was last updated. 

Trade Name(s): Service personnel would accurately and completely record the trade name(s) from 

the pesticide label, which includes a suffix that describes the formulation (e.g., WP, DG, EC, L, SP, 

I, II or 64). The suffix often distinguishes a specific product among several pesticides with the same 

active ingredient. Service personnel would record a trade name for each pesticide product with the 

same active ingredient. 

Common chemical name(s): Service personnel would record the common name(s) listed on the 

pesticide label or material safety data sheet (MSDS) for an active ingredient. The common name of a 

pesticide is listed as the active ingredient on the title page of the product label immediately following 

the trade name, and the MSDS, Section 2: Composition/ Information on Ingredients. A Chemical 

Profile is completed for each active ingredient. 

Pesticide Type: Service personnel would record the type of pesticide for an active ingredient as one 

of the following: herbicide, dessicant, fungicide, fumigant, growth regulator, insecticide, pisicide, or 

rodenticide. 

EPA Registration Number(s): This number (EPA Reg. No.) appears on the title page of the label 

and MSDS, Section 1: Chemical Product and Company Description. It is not the EPA 

Establishment Number that is usually located near it. Service personnel would record the EPA Reg. 

No. for each trade name product with an active ingredient based upon PUPs. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-35 

Pesticide Class: Service personnel would list the general chemical class for the pesticide (active 

ingredient). For example, malathion is an organophosphate and carbaryl is a carbamate. 

CAS (Chemical Abstract Service) Number: This number is often located in the second section 

(Composition/Information on Ingredients) of the MSDS. The MSDS table listing components 

usually contains this number immediately prior to or following the % composition. 

Other Ingredients: From the most recent MSDS for the proposed pesticide product(s), Service 

personnel would include any chemicals in the pesticide formulation not listed as an active ingredient 

that are described as toxic or hazardous, or regulated under the Superfund Amendments and 

Reauthorization Act (SARA), Comprehensive Environmental Response, Compensation, and Liability 

Act (CERCLA), Toxic Substances Control Act (TSCA), Occupational Safety and Health 

Administration (OSHA), State Right-to-Know, or other listed authorities. These are usually found in 

MSDS sections titled “Hazardous Identifications”, “Exposure Control/Personal Protection”, and 

“Regulatory Information”. If concentrations of other ingredients are available for any compounds 

identified as toxic or hazardous, then Service personnel would record this information in the 

Chemical Profile by trade name. MSDS(s) may be obtained from the manufacturer, manufacturer’s 

website or from an on-line database maintained by Crop Data Management Systems, Inc. (see list 

below). 

Toxicological Endpoints 

Toxicological endpoint data would be collected for acute and chronic tests with mammals, birds, and 

fish. Data would be recorded for species available in the scientific literature. If no data are found for 

a particular taxonomic group, then “No data available is references” would be recorded as the data 

entry. Throughout the Chemical Profile, references (including toxicological endpoint data) would be 

cited using parentheses (#) following the recorded data. 

Mammalian LD50: For test species in the scientific literature, Service personnel would record 

available data for oral lethal dose (LD50) in mg/kg-bw (body weight) or ppm-bw. Most common test 

species in scientific literature are the rat and mouse. The lowest LD50 value found for a rat would be 

used as a toxicological endpoint for dose-based RQ calculations to assess acute risk to mammals (see 

Table 1 in Section 7.1). 

Mammalian LC50: For test species in the scientific literature, Service personnel would record 

available data for dietary lethal concentration (LC50) as reported (e.g., mg/kg-diet or ppm-diet). Most 

common test species in scientific literature are the rat and mouse. The lowest LC50 value found for a 

rat would be used as a toxicological endpoint for diet-based RQ calculations to assess acute risk (see 

Table 1 in Section 7.1). 

Mammalian Reproduction: For test species listed in the scientific literature, Service personnel 

would record the test results (e.g., Lowest Observed Effect Concentration [LOEC], Lowest Observed 

Effect Level [LOEL], No Observed Adverse Effect Level [NOAEL], No Observed Adverse Effect 

Concentration [NOAEC]) in mg/kg-bw or mg/kg-diet for reproductive test procedure(s) (e.g., 

generational studies [preferred], fertility, new born weight). Most common test species available in 

scientific literature are rats and mice. The lowest NOEC, NOAEC, NOEL, or NOAEL test results 

found for a rat would be used as a toxicological endpoint for RQ calculations to assess chronic risk 

(see Table 1 in Section 7.1). 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

E-36 Appendix E. Integrated Pest Management Program 

Avian LD50: For test species available in the scientific literature, Service personnel would record 

values for oral lethal dose (LD50) in mg/kg-bw or ppm-bw. Most common test species available in 

scientific literature are the bobwhite quail and mallard. The lowest LD50 value found for an avian 

species would be used as a toxicological endpoint for dose-based RQ calculations to assess acute risk 

(see Table 1 in Section 7.1). 

Avian LC50: For test species available in the scientific literature, Service personnel would record 

values for dietary lethal concentration (LC50) as reported (e.g., mg/kg-diet or ppm-diet). Most 

common test species available in scientific literature are the bobwhite quail and mallard. The lowest 

LC50 value found for an avian species would be used as a toxicological endpoint for dietary-based 

RQ calculations to assess acute risk (see Table 1 in Section 7.1). 

Avian Reproduction: For test species available in the scientific literature, Service personnel would

record test results (e.g., LOEC, LOEL, NOAEC, NOAEL) in mg/kg-bw or mg/kg-diet consumed for 

reproductive test procedure(s) (e.g., early life cycle, reproductive). Most common test species 

available in scientific literature are the bobwhite quail and mallard. The lowest NOEC, NOAEC, 

NOEL, or NOAEL test results found for an avian species would be used as a toxicological endpoint 

for RQ calculations to assess chronic risk (see Table 1 in Section 7.1). 

Fish LC50: For test freshwater or marine species listed in the scientific literature, Service personnel 

would record a LC50 in ppm or mg/L. Most common test species available in the scientific literature 

are the bluegill, rainbow trout, and fathead minnow (marine). Test results for many game species 

may also be available. The lowest LC50 value found for a freshwater fish species would be used as a 

toxicological endpoint for RQ calculations to assess acute risk (see Table 1 in Section 7.1). 

Fish Early Life Stage (ELS)/Life Cycle: For test freshwater or marine species available in the 

scientific literature, Service personnel would record test results (e.g., LOEC, NOAEL, NOAEC, 

LOAEC) in ppm for test procedure(s) (e.g., early life cycle, life cycle). Most common test species 

available in the scientific literature are bluegill, rainbow trout, and fathead minnow. Test results for 

other game species may also be available. The lowest test value found for a fish species (preferably 

freshwater) would be used as a toxicological endpoint for RQ calculations to assess chronic risk (see 

Table 1 in Section 7.1). 

Other: For test invertebrate as well as nonvascular and vascular plant species available in the 

scientific literature, Service personnel would record LC50, LD50, LOEC, LOEL, NOAEC, NOAEL, or 

EC50 (environmental concentration) values in ppm or mg/L. Most common test invertebrate species 

available in scientific literature are the honey bee and the water flea (Daphnia magna). Green algae 

(Selenastrum capricornutum) and pondweed (Lemna minor) are frequently available test species for 

aquatic nonvascular and vascular plants, respectively. 

Ecological Incident Reports: After a site has been treated with pesticide(s), wildlife may be 

exposed to these chemical(s). When exposure is high relative to the toxicity of the pesticides, 

wildlife may be killed or visibly harmed (incapacitated). Such events are called ecological incidents. 

The USEPA maintains a database (Ecological Incident Information System) of ecological incidents. 

This database stores information extracted from incident reports submitted by various Federal and 

State agencies and nongovernment organizations. Information included in an incident report is date 

and location of the incident, type and magnitude of affects observed in various species, use(s) of 

pesticides known or suspected of contributing to the incident, and results of any chemical residue and 

cholinesterase activity analyses conducted during the investigation. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-37 

Incident reports can play an important role in evaluating the effects of pesticides by supplementing 

quantitative risk assessments. All incident reports for pesticide(s) with the active ingredient and 

associated information would be recorded. 

Environmental Fate 

Water Solubility: Service personnel would record values for water solubility (Sw), which describes 

the amount of pesticide that dissolves in a known quantity of water. Sw is expressed as mg/L (ppm). 

Pesticide Sw values would be categorized as one of the following: insoluble <0.1 ppm, moderately 

soluble = 100 to 1000 ppm, highly soluble >10,000 ppm (US Geological Survey 2000). As pesticide 

Sw increases, there would be greater potential to degrade water quality through run-off and leaching. 

Sw would be used to evaluate potential for bioaccumulation in aquatic species [see Octanol-Water 

Partition Coefficient (Kow) below]. 

Soil Mobility: Service personnel would record available values for soil adsorption coefficient (Koc

[μg/g]). It provides a measure of a chemical's mobility and leaching potential in soil. Koc values are 

directly proportional to organic content, clay content, and surface area of the soil. Koc data for a 

pesticide may be available for a variety of soil types (e.g., clay, loam, sand). 

Koc values would be used in evaluating the potential to degrade groundwater by leaching (see

Potential to Move to Groundwater below).

Soil Persistence: Service personnel would record values for soil half-life (t1⁄2), which represents the 

length of time (days) required for 50% of the deposited pesticide to degrade (completely or partially) 

in the soil. Based upon the t1⁄2 value, soil persistence would be categorized as one of the following: 

nonpersistent <30 days, moderately persistent = 30 to 100 days, and persistent >100 days (Kerle et. 

al. 1996). 

Threshold for Approving PUPs: 

If soil t1⁄2 ≤100 days, then a PUP would be approved without additional BMPs to protect water 

quality. 

If soil t1⁄2 >100 days, then a PUP would only be approved with additional BMPs specifically to 

protect water quality. One or more BMPs such as the following would be included in the Specific 

Best Management Practices (BMPs) section to minimize potential surface run-off and leaching 

that can degrade water quality: 

 Do not exceed one application per site per year. 

 Do not use on coarse-textured soils where the ground water table is <10’ and average annual 

precipitation >12”. 

 Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is 

saturated. 

Along with Koc, soil t1⁄2 values would be used in evaluating the potential to degrade groundwater by 

leaching (see Potential to Move to Groundwater below). 

Soil Dissipation: Dissipation time (DT50) represents the time required for 50% of the deposited 

pesticide to degrade and move from a treated site; whereas, soil t1⁄2 describes the rate for degradation 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

E-38 Appendix E. Integrated Pest Management Program 

only. As for t1⁄2, units of dissipation time are usually expressed in days. Field dissipation time would 

be the preferred data for use to estimate pesticide concentrations in the environment because it is 

based upon field studies compared to soil t1⁄2, which is derived in a laboratory. However, soil t1⁄2 is the 

most common persistence data available in the published literature. If field dissipation data is not 

available, soil half-life data would be used in a Chemical Profile. The average or representative halflife value of most important degradation mechanism would be selected for quantitative analysis for 

both terrestrial and aquatic environments. 

Based upon the DT50 value, environmental persistence in the soil also would be categorized as one of 

the following: nonpersistent <30 days, moderately persistent = 30-100 days, and persistent >100 

days. 

Threshold for Approving PUPs: 

If soil DT50 ≤100 days, then a PUP would be approved without additional BMPs to protect water 

quality. 

If soil DT50 >100 days, then a PUP would only be approved with additional BMPs specifically to 

protect water quality. One or more BMPs such as the following would be included in the Specific 

Best Management Practices (BMPs) section to minimize potential surface run-off and leaching that 

can degrade water quality: 

 Do not exceed one application per site per year. 

 Do not use on coarse-textured soils where the ground water table is <10’ and average annual 

precipitation >12”. 

 Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is 

saturated. 

Along with Koc, soil DT50 values (preferred over soil t1⁄2) would be used in evaluating the potential to 

degrade groundwater by leaching (see Potential to Move to Groundwater below), if available. 

Aquatic Persistence: Service personnel would record values for aquatic t1⁄2, which represents the 

length of time required for 50% of the deposited pesticide to degrade (completely or partially) in 

water. Based upon the t1⁄2 value, aquatic persistence would be categorized as one of the following: 

nonpersistent <30 days, moderately persistent = 30 to 100 days, and 

persistent >100 days (Kerle et. al. 1996). 

Threshold for Approving PUPs: 

If aquatic t1⁄2 ≤100 days, then a PUP would be approved without additional BMPs to protect water 

quality. 

If aquatic t1⁄2 >100 days, then a PUP would only be approved with additional BMPs specifically to 

protect water quality. One or more BMPs such as the following would be included in the Specific 

Best Management Practices (BMPs) section to minimize potential surface run-off and leaching that 

can degrade water quality: 

 Do not exceed one application per site per year. 

 Do not use on coarse-textured soils where the ground water table is <10’ and average annual 

precipitation >12”. 

 Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is 

saturated. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-39 

Aquatic Dissipation: Dissipation time (DT50) represents the time required for 50% of the deposited 

pesticide to degrade or move (dissipate); whereas, aquatic t1⁄2 describes the rate for degradation only. 

As for t1⁄2, units of dissipation time are usually expressed in days. Based upon the DT50 value, 

environmental persistence in aquatic habitats also would be categorized as one of the following: 

nonpersistent <30 days, moderately persistent = 30 to 100 days, and 

persistent >100 days. 

Threshold for Approving PUPs: 

If aquatic DT50 ≤100 days, then a PUP would be approved without additional BMPs to protect water 

quality. 

If aquatic DT50 >100 days, then a PUP would only be approved with additional BMPs specifically to 

protect water quality. One or more BMPs such as the following would be included in the Specific 

Best Management Practices (BMPs) section to minimize potential surface run-off and leaching that 

can degrade water quality: 

 Do not exceed one application per site per year. 

 Do not use on coarse-textured soils where the ground water table is <10’ and average annual 

precipitation >12”. 

 Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is 

saturated. 

Potential to Move to Groundwater: Groundwater Ubiquity Score (GUS) = log10(soil t 1⁄2) x [4 – 

log10(Koc)]. If a DT50 value is available, it would be used rather than a t 1⁄2 value to calculate a GUS 

score. Based upon the GUS value, the potential to move toward groundwater would be recorded as 

one of the following categories: extremely low potential<1.0, low - 1.0 to 2.0, moderate - 2.0 to 3.0, 

high - 3.0 to 4.0, or very high>4.0. 

Threshold for Approving PUPs: 

If GUS ≤4.0, then a PUP would be approved without additional BMPs to protect water quality. 

If GUS>4.0, then a PUP would only be approved with additional BMPs specifically to protect water 

quality. One or more BMPs such as the following would be included in the Specific Best 

Management Practices (BMPs) section to minimize potential surface run-off and leaching that can 

degrade water quality: 

 Do not exceed one application per site per year. 

 Do not use on coarse-textured soils where the ground water table is <10’ and average annual 

precipitation >12”. 

 Do not use on steep slopes if substantial rainfall is expected within 24 hours or ground is 

saturated. 

Volatilization: Pesticides may volatilize (evaporate) from soil and plant surfaces and move offtarget into the atmosphere. The potential for a pesticide to volatilize is a function of its vapor 

pressure that is affected by temperature, sorption, soil moisture, and the pesticide’s water solubility. 

Vapor pressure is often expressed in mm Hg. To make these values easier to compare, vapor pressure 

would be recorded by Service personnel in exponential form (I x 10-7), where I represents a vapor 

pressure index. In general, pesticides with I<10 would have low potential to volatilize; whereas, 

pesticides with I >1,000 would have a high potential to volatilize (Oregon State University 1996). 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

E-40 Appendix E. Integrated Pest Management Program 

Vapor pressure values for pesticides are usually available in the pesticide product MSDS or the 

USDA Agricultural Research Service (ARS) pesticide database (see References). 

Threshold for Approving PUPs: 

If I ≤1000, then a PUP would be approved without additional BMPs to minimize drift and protect air 

quality. 

If I>1000, then a PUP would only be approved with additional BMPs specifically to minimize drift 

and protect air quality. One or more BMPs such as the following would be included in the Specific 

Best Management Practices (BMPs) section to reduce volatilization and potential to drift and 

degrade air quality: 

 Do not treat when wind velocities are <2 or >10 mph with existing or potential inversion 

conditions. 

 Apply the large-diameter droplets possible for spray treatments. 

 Avoid spraying when air temperatures >85o

F. 

 Use the lowest spray height possible above target canopy. 

 Where identified on the pesticide label, soil incorporate pesticide as soon as possible during or 

after application. 

 

Octanol-Water Partition Coefficient (Kow): The octanol-water partition coefficient (Kow) is the 

concentration of a pesticide in octanol and water at equilibrium at a specific temperature. Because 

octanol is an organic solvent, it is considered a surrogate for natural organic matter. Therefore, Kow

would be used to assess potential for a pesticide to bioaccumulate in tissues of aquatic species (e.g., 

fish). If Kow >1000 or Sw<1 mg/L AND soil t1⁄2>30 days, then there would be high potential for a 

pesticide to bioaccumulate in aquatic species such as fish (US Geological Survey 2000). 

Threshold for Approving PUPs: 

If there is not a high potential for a pesticide to bioaccumulate in aquatic species, then the PUP 

would be approved. 

If there is a high potential to bioaccumulate in aquatic species (Kow>1000 or Sw<1 mg/L AND soil 

t1⁄2>30 days), then the PUP would not approved, except under unusual circumstances where approval 

would only be granted by the Washington Office. 

Bioaccumulation/Bioconcentration: The physiological process where pesticide concentrations in 

tissue would increase in biota because they are taken and stored at a faster rate than they are 

metabolized or excreted. The potential for bioaccumulation would be evaluated through 

bioaccumulation factors (BAFs) or bioconcentration factors (BCFs). Based upon BAF or BCF 

values, the potential to bioaccumulate would be recorded as one of the following: low – 0 to 300, 

moderate – 300 to 1000, or high >1000 (Calabrese and Baldwin 1993). 

Threshold for Approving PUPs: 

If BAF or BCF≤1000, then a PUP would be approved without additional BMPs. 

If BAF or BCF>1000, then a PUP would not approved, except under unusual circumstances where 

approval would only be granted by the Washington Office. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-41 

Worst-Case Ecological Risk Assessment 

Max Application Rates (acid equivalent): Service personnel would record the highest application 

rate of an active ingredient (ae basis) for habitat management and cropland/facilities maintenance 

treatments in this data field of a Chemical Profile. These rates can be found in Table CP.1 under the 

column heading “Max Product Rate – Single Application (lbs/acre – AI on acid equiv basis)”. This 

table would be prepared for a chemical profile from information specified in labels for trade name 

products identified in PUPs. If these data are not available in pesticide labels, then write “NS” for 

“not specified on label” in this table. 

EECs: An estimated environmental concentration (ECC) represents potential exposure to fish and 

wildlife (birds and mammals) from using a pesticide. EECs would be derived by Service personnel 

using an USEPA screening-level approach (US Environmental Protection Agency 2004). For each 

max application rate [see description under Max Application Rates (acid equivalent)], Service 

personnel would record 2 EEC values in a Chemical Profile; these would represent the worst-case 

terrestrial and aquatic exposures for habitat management and croplands/facilities maintenance 

treatments. For terrestrial and aquatic EEC calculations, see description for data entry under 

Presumption of Unacceptable Risk/Risk Quotients, which is the next field for a Chemical Profile. 

Presumption of Unacceptable Risk/Risk Quotients: Service personnel would calculate and record 

acute and chronic risk quotients (RQs) for birds, mammals, and fish using the provided tabular 

formats for habitat management and/or cropland/facilities maintenance treatments. RQs recorded in 

a Chemical Profile would represent the worst-case assessment for ecological risk. See Section 7.2 

for discussion regarding the calculations of RQs. 

For aquatic assessments associated with habitat management treatments, RQ calculations would be 

based upon selected acute and chronic toxicological endpoints for fish and the EEC would be derived 

from Urban and Cook (1986) assuming 100% overspray to an entire 1-foot deep water body using 

the max application rate (ae basis [see above]). 

For aquatic assessments associated with cropland/facilities maintenance treatments, RQ calculations 

would be done by Service personnel based upon selected acute and chronic toxicological endpoints 

for fish and an EEC would be derived from the aquatic assessment in AgDRIFT® model version 2.01 

under Tier I ground-based application with the following input variables: max application rate (acid 

basis [see above]), low boom (20”), fine to medium/coarse droplet size, 20 swaths, EPA-defined 

wetland, and 25-foot distance (buffer) from treated area to water. 

See Section 7.2.1.2 for more details regarding the calculation of EECs for aquatic habitats for habitat 

management and cropland/facilities maintenance treatments. 

For terrestrial avian and mammalian assessments, RQ calculations would be done by Service 

personnel based upon dietary exposure, where the “short grass” food item category would represent 

the worst-case scenario. For terrestrial spray applications associated with habitat management and 

cropland/facilities maintenance treatments, exposure (EECs and RQs) would be determined using the 

Kanaga nomogram method through the USEPA’s Terrestrial Residue Exposure model (T-REX) 

version 1.2.3. T-REX input variables would include the following: max application rate (acid basis 

[see above]) and pesticide half-life (days) in soil to estimate the initial, maximum pesticide residue 

concentration on general food items for terrestrial vertebrate species in short (<20 cm tall) grass. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

E-42 Appendix E. Integrated Pest Management Program 

For granular pesticide formulations and pesticide-treated seed with a unique route of exposure for 

terrestrial avian and mammalian wildlife, see Section 7.2.1.1.2 for the procedure that would be used 

to calculate RQs. 

All calculated RQs in both tables would be compared with Levels of Concern (LOCs) established by 

USEPA (see Table 2 in Section 7.2). If a calculated RQ exceeds an established LOC value (in 

brackets inside the table), then there would be a potential for an acute or chronic effect (unacceptable 

risk) to federally listed (T&E) species and nonlisted species. See Section 7.2 for detailed 

descriptions of acute and chronic RQ calculations and comparison to LOCs to assess risk. 

Threshold for approving PUPs: 

If RQs≤LOCs, then a PUP would be approved without additional BMPs. 

If RQs>LOCs, then a PUP would only be approved with additional BMPs specifically to minimize 

exposure (ecological risk) to bird, mammal, and/or fish species. One or more BMPs such as the 

following would be included in the Specific Best Management Practices (BMPs) section to reduce 

potential risk to nonlisted or listed species: 

 Lower application rate and/or fewer number of applications so RQs≤LOCs 

 For aquatic assessments (fish) associated with cropland/facilities maintenance, increase the 

buffer distance beyond 25’ so RQs≤LOCs. 

Justification for Use: Service personnel would describe the reason for using the pesticide based 

control of specific pests or groups of pests. In most cases, the pesticide label will provide the 

appropriate information regarding control of pests to describe in the section. 

Specific Best Management Practices (BMPs): Service personnel would record specific BMPs 

necessary to minimize or eliminate potential effects to nontarget species and/or degradation of 

environmental quality from drift, surface runoff, or leaching. These BMPs would be based upon 

scientific information documented in previous data fields of a Chemical Profile. Where necessary 

and feasible, these specific practices would be included in PUPs as a basis for approval. 

If there are no specific BMPs that are appropriate, then Service personnel would describe why the 

potential effects to Refuge resources and/or degradation of environmental quality is outweighed by 

the overall resource benefit(s) from the proposed pesticide use in the BMP section of the PUP. See 

Section 4.0 of this document for a complete list of BMPs associated with mixing and applying 

pesticides appropriate for all PUPs with ground-based treatments that would be additive to any 

necessary, chemical-specific BMPs. 

References: Service personnel would record scientific resources used to provide data/information 

for a chemical profile. Use the number sequence to uniquely reference data in a chemical profile. 

The following on-line data resources are readily available for toxicological endpoint and 

environmental fate data for pesticides: 

1. California Product/Label Database. Department of Pesticide Regulation, California 

Environmental Protection Agency. (http://www.cdpr.ca.gov/docs/label/labelque.htm#regprods) 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-43 

2. ECOTOX database. Office of Pesticide Programs, US Environmental Protection Agency, 

Washington, DC. (http://cfpub.epa.gov/ecotox/) 

3. Extension Toxicology Network (EXTOXNET) Pesticide Information Profiles. Cooperative effort 

of University of California-Davis, Oregon State University, Michigan State University, Cornell 

University and University of Idaho through Oregon State University, Corvallis, Oregon. 

(http://extoxnet.orst.edu/pips/ghindex.html) 

4. FAO specifications and evaluations for plant protection products. Pesticide Management Unit, 

Plant Protection Services, Food and Agriculture Organization, United Nations. 

(http://www.fao.org/WAICENT/FAOINFO/AGRICULT/AGP/AGPP/Pesticid/) 

5. Human health and ecological risk assessments. Pesticide Management and Coordination, Forest 

Health Protection, US Department of Agriculture, US Forest Service. 

(http://www.fs.fed.us/foresthealth/pesticide/risk.htm) 

6. Pesticide Chemical Fact Sheets. Clemson University Pesticide Information Center. 

(http://entweb.clemson.edu/pesticid/Document/Labels/factshee.htm) 

7. Pesticide Fact Sheets. Published by Information Ventures, Inc. for Bureau of Land Management, 

Dept. of Interior; Bonneville Power Administration, U.S. Dept. of Energy; and Forest Service, 

US Department of Agriculture. (http://infoventures.com/e-hlth/pesticide/pest-fac.html) 

8. Pesticide Fact Sheets. National Pesticide Information Center. (http://npic.orst.edu/npicfact.htm) 

9. Pesticide Fate Database. US Environmental Protection Agency, Washington, DC. 

(http://cfpub.epa.gov/pfate/home.cfm). 

 

10. Pesticide product labels and material safety data sheets. Crop Data Management Systems, Inc. 

(CDMS) (http://www.cdms.net/pfa/LUpdateMsg.asp) or multiple websites maintained by 

agrichemical companies. 

11. Registered Pesticide Products (Oregon database). Oregon Department of Agriculture. 

(http://www.oda.state.or.us/dbs/pest_products/search.lasso) 

12. Regulatory notes. Pest Management Regulatory Agency, Health Canada, Ontario, Canada. 

(http://www.hc-sc.gc.ca/pmra-arla/) 

13. Reptile and Amphibian Toxicology Literature. Canadian Wildlife Service, Environment Canada, 

Ontario, Canada. (http://www.cws-scf.ec.gc.ca/nwrc-cnrf/ratl/index_e.cfm) 

14. Specific Chemical Fact Sheet – New Active Ingredients, Biopesticide Fact Sheet and Registration 

Fact Sheet. U.S Environmental Protection Agency, Washington, DC. 

(http://www.epa.gov/pestidides/factsheets/chemical_fs.htm) 

15. Weed Control Methods Handbook: Tools and Techniques for Use in Natural Areas. The Invasive 

Species Initiative. The Nature Conservancy. (http://tnsweeds.ucdavis.edu/handbook.html) 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

E-44 Appendix E. Integrated Pest Management Program 

16. Wildlife Contaminants Online. US Geological Survey, Department of Interior, Washington, D.C. 

(http://www.pwrc.usgs.gov/contaminants-online/) 

17. One-liner database. 2000. US Environmental Protection Agency, Office of Pesticide Programs, 

Washington, D.C. 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-45 

Chemical Profile 

Date: 

Trade Name(s): Common Chemical 

Name(s):

Pesticide Type: EPA Registration 

Number:

Pesticide Class: CAS Number:

Other Ingredients:

Toxicological Endpoints

Mammalian LD50:

Mammalian LC50:

Mammalian Reproduction:

Avian LD50:

Avian LC50:

Avian Reproduction:

Fish LC50:

Fish ELS/Life Cycle:

Other:

Ecological Incident Reports

Environmental Fate

Water solubility (Sw):

Soil Mobility (Koc):

Soil Persistence (t1⁄2):

Soil Dissipation (DT50): 

Aquatic Persistence (t1⁄2):

Aquatic Dissipation (DT50): 

Potential to Move to Groundwater 

(GUS score):

Volatilization (mm Hg):

Octanol-Water Partition Coefficient 

(Kow):

Bioaccumulation/Biocentration: BAF:`

BCF:

Worst Case Ecological Risk Assessment

Max Application 

Rate 

(ai lbs/acre – ae 

basis)

Habitat Management:

Croplands/Facilities Maintenance:

EECs Terrestrial (Habitat Management):

Terrestrial (Croplands/Facilities Maintenance):

Aquatic (Habitat Management):

Aquatic (Croplands/Facilities Maintenance): 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

E-46 Appendix E. Integrated Pest Management Program 

Habitat Management Treatments: 

Presumption of Unacceptable Risk Risk Quotient (RQ)

Listed (T&E) 

Species

Nonlisted Species

Acute Birds [0.1] [0.5]

Mammals [0.1] [0.5]

Fish [0.05] [0.5]

Chronic Birds [1] [1]

Mammals [1] [1]

Fish [1] [1]

Cropland/Facilities Maintenance Treatments: 

Presumption of Unacceptable Risk Risk Quotient (RQ)

Listed (T&E) 

Species Nonlisted Species

Acute Birds [0.1] [0.5]

Mammals [0.1] [0.5]

Fish [0.05] [0.5]

Chronic Birds [1] [1]

Mammals [1] [1]

Fish [1] [1]

Justification for Use:

Specific Best 

Management Practices 

(BMPs):

References:

Table CP.1 Pesticide Name 

Trade 

Namea

Treatment 

Typeb 

Max Product 

Rate – Single 

Application 

(lbs/acre or 

gal/acre) 

Max Product 

Rate -Single 

Application 

(lbs/acre - AI 

on acid equiv 

basis) 

Max Number 

of 

Applications 

Per Season 

Max Product 

Rate Per Season 

(lbs/acre/season 

or 

gal/acre/season) 

Minimum 

Time 

Between 

Applications 

(Days) 

 

a

From each label for a pesticide identified in pesticide use proposals (PUPs), Service personnel 

would record application information associated with possible/known uses on Service lands.

b

Treatment type: H – habitat management or CF – cropland/facilities maintenance. If a pesticide is 

labeled for both types of treatments (uses), then record separate data for H and CF applications. 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Integrated Pest Management Program E-47 

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Services. 2004. Guidance Manual for the Assessment of Joint Toxic Action of Chemical 

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Baehr, C.H., and C. Habig. 2000. Statistical evaluation of the UTAB database for use in terrestrial 

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PM 1495, Iowa State University Extension, Ames, Iowa. 6 pages. 

Barry, T. 2004. Characterization of propanil prune foliage residues as related to propanil use patterns 

in the Sacramento Valley, CA. Proceedings of the International Conference on Pesticide 

Application for Drift Management. Waikoloa, Hawaii. 15 pages. 

Battaglin, W.A., E.M. Thurman, S.J. Kalkhoff, and S.D. Porter. 2003. Herbicides and 

Transformation Products in Surface Waters of the Midwestern United States. Journal of the 

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Beyer, W.N., E.E. Connor, S. Gerould. 1994. Estimates of soil ingestion by wildlife. Journal of 

Wildlife Management 58:375-382. 

Brooks, M.L., D'Antonio, C.M., Richardson, D.M., Grace, J.B., Keeley, J.E. and others. 2004. 

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Butler, T., W. Martinkovic, and O.N. Nesheim. 1998. Factors influencing pesticide movement to 

ground water. Extension Publication PI-2, University of Florida, Cooperative Extension 

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Appendix F. Literature Cited F-1 

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Walker, R. 2010. Stealing with Tools. `Elepaio 70:44-47. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

F-12 Appendix F. Literature Cited 

Walther, G. R., Post, E.; Convey, P.; Menzel, A.; Parmesan, C.; Beebee, T.J.C.; Fromentin, J-M.; 

Hoegh-Guidberg, O.; Bairlein, F. 2002. Ecological responses to recent climate change. Nature. 416: 

389-395. 

Walther, Michael. 2004. A Guide to Hawai‘i’s Coastal Plants. Mutual Publishing. Honolulu, HI. 

Wilcox, Barbara S. 1975. The Kahuku Sugar Mill Story. Island Heritage Limited, Norfolk Island, 

Australia. 

Winter, L. 2003. Popoki and Hawai‘i’s Native Birds. ‘Elepaio 63:43-46. 

Wood, G. W., and R. H. Barrett. 1979. Status of the wild pig in the United States. Wildlife Society 

Bulletin 36:237–246. 

WWF (World Wildlife Fund). 2010. Terrestrial Ecoregions. Available at: 

http://www.worldwildlife.org/science/ecoregions/item1267.html. Accessed January 19, 2011. 

Yamamoto, Mike N. & Annette W. Tagawa. 2000. Hawai‘i’s native & exotic freshwater animals. 

Mutual Publishing. Honolulu, HI. 

Young, L. C., E. A. VanderWerf, D. G. Smith, J. Polhemus, N. Swenson, C. Swenson, B. R. 

Liesemeyer, B. H. Gagne, and S. Conant. 2009. Demography and Natural History of Laysan 

Albatross on Oahu, Hawai‘i. The Wilson Journal of Ornithology 121: 722-729. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

 

Appendix G. Statement of Compliance G-1 

Appendix G. Statement of Compliance

for Implementation of the James Campbell National Wildlife Refuge, 

Honolulu County, Hawai‘i, Comprehensive Conservation Plan 

The following Executive orders and legislative acts have been reviewed as they apply to 

implementation of the James Campbell NWR CCP. 

National Environmental Policy Act (1969). The planning process has been conducted in 

accordance with NEPA Implementing Procedures, Department of the Interior and Service 

procedures, and has been performed in coordination with the affected public. 

The CCP is programmatic in many respects and specific details of certain projects and actions 

cannot be determined until a later date depending on funding and implementation schedules. 

Certain projects or actions may require additional NEPA compliance. 

National Historic Preservation Act (1966). The implementation of the CCP should not affect 

cultural resources. The proposed action does not meet the criteria of an effect or adverse effect as 

an undertaking defined in 36 CFR 800.9 and 614 FW 2. The Service will comply with the 

National Historic Preservation Act if any management actions have the potential to affect any 

historic properties which may be present. 

Executive Order 12372. Intergovernmental Review. Coordination and consultation with 

affected Tribal, local, and State governments, other Federal agencies, and the landowners has 

been completed through personal contact by Service planners, refuge managers, and supervisors. 

Executive Order 12898. Federal Actions to Address Environmental Justice in Minority 

and Low-Income Populations. All Federal actions must address and identify, as appropriate, 

disproportionally high and adverse human health or environmental effects of its programs, 

policies, and activities on minority populations, low-income populations, and Indian Tribes in 

the United States. The CCP was evaluated and no adverse human health or environmental effects 

were identified for minority or low-income populations, Indian Tribes, or anyone else. 

Wilderness Preservation Act of 1964. The Service has evaluated the suitability of the Refuge 

for wilderness designation and determined it does not qualify.

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

Wildlife Refuge System Improvement Act of 1997 (16 U.S.C. 668dd-668ee). Appropriate 

Use findings and Compatibility Determinations have been prepared for the following uses: 

Wildlife Observation, Interpretation and Photography; Environmental Education; and Research, 

Scientific Collecting, and Surveys. 

Executive Order 13186. Responsibilities of Federal Agencies to Protect Migratory Birds. 

The CCP is consistent with Executive Order 13186 because the CCP and NEPA analyses 

evaluate the effects of agency actions on migratory birds. 

James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix H. Planning Team Members H-1 

Appendix H. Planning Team Members 

The following members of the core planning team were responsible for preparing the CCP. 

Laura Beauregard Refuge Planner, Hawaiian and Pacific Islands NWRC 

David Ellis Project Leader, O‘ahu NWRC 

Michael Silbernagle Wildlife Biologist, O‘ahu NWRC 

The following members of the extended planning team provided information and analysis to the core 

planning team of the CCP. 

George Fisher Supervisory Tractor Operator, O‘ahu NWRC 

Ben Harrison Chief, Natural and Cultural Resources Division, Region 1 

David Hoy GIS Specialist, Region 1 

Kevin Kilbride Wildlife Biologist, Refuge Biology, Region 1 

Mike Marxen Chief, Visitor Services and Communications Division, Region 1 

Tim Mayer Hydrologist, Region 1 

Scott McCarthy Chief, Planning Division, Region 1 

Lisa Oshiro Native Hawaiian Liaison, Department of the Interior, Honolulu 

Donald Palawski Deputy Project Leader, Hawaiian and Pacific Islands NWRC 

Benton Pang Native Hawaiian Liaison, Ecological Services, Honolulu 

Fred Paveglio (Former) Chief, Branch of Refuge Biology, Region 1 

Anan Raymond Regional Archaeologist, Region 1 

Barry Stieglitz Project Leader, Hawaiian and Pacific Islands NWRC 

Maps were prepared by David Hoy and Michael Silbernagle. 

Graphic design of cover by Patrick Stark. 

Graphic design of Readers Guide by Sandra Hall. 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

H-2 Appendix H. Planning Team Members 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix I. Public Involvement I-1 

Appendix I. Public Involvement 

Public involvement was sought throughout the development of the CCP. The public scoping period 

for preparation of the Draft CCP for James Campbell NWR opened in November 2008 when the 

Complex mailed approximately 200 copies of Planning Update #1 to local conservation and interest 

groups, conservation and research organizations, government agencies, Hawaiian groups, and others 

who expressed an interest in the planning process. The planning update was posted on the Complex 

Website. Planning Update #1 was a combined announcement for both Pearl Harbor NWR and James 

Campbell NWR CCPs. It described the CCP process, explained refuge purposes, identified 

preliminary issues, and helped us expand our mailing list. 

Two public meetings were held: in Pearl City, Hawai‘i on December 9, 2008, and Kahuku, Hawai‘i 

on January 8, 2009. At the meetings, Refuge staff and the lead planner were available to explain the 

CCP process; refuge purposes, vision, and management; and preliminary management issues, 

concerns and opportunities that had been identified early in the planning process. 

We had no attendees for the Pearl City meeting and 10 private citizens and representatives from 

various organizations attended the meeting in Kahuku. During scoping, the following issues and 

questions were identified and expressed by various constituents and Service staff. These issues were 

analyzed and addressed during CCP development. 

 Can the Service provide public access to the O‘ahu Refuges, especially during the nonnesting 

season? 

 Explore the possibility of additional units on the coastline adjacent to James Campbell NWR. 

 Can the former airfield on the James Campbell acquisition be preserved and opened for 

recreational aviation uses? 

 How would the expansion of James Campbell Refuge impact leaseholders on the lands currently 

in private ownership? 

 What is known about global climate change and how it affects the species and ecosystems that 

depend on the Refuges, which issues can be further studied at the Refuges and ecosystem level, 

and how can this information can be incorporated into wildlife management on the refuges? 

 What invasive plant and animal species are present on the Refuges, how are they impacting 

waterbird habitat, and what methods should the Refuges pursue for them? 

 What actions can the Refuges take to improve impacts from flooding in the surrounding 

communities? 

The second planning update was mailed in June 2009. This update summarized the issues, concerns, 

and opportunities identified by the Service, its partners, and the public during initial public scoping. 

A third planning update was mailed in August 2010 that provided a preview of the Draft CCP/EA. A 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

I-2 Appendix I. Public Involvement 

fourth planning update was mailed in June 2011 announcing availability of the Draft CCP/EA and 

public comment period. A public meeting was held Kahuku, Hawai‘i on July 14, 2011, with 18 

attendees. At the meeting, Refuge staff and the lead planner were available to answer questions, 

provide a brief overview of the draft management alternatives, and accept comments from the public. 

Federal and State Elected Officials or their Aides 

In November 2008, letters were sent to elected officials from the congressional districts in which the 

affected Refuge lands are located, informing them of the CCP process and inviting their 

participation. Planning Updates were also sent to these offices. 

U.S. Senator Daniel Akaka (HI) 

U.S. Senator Daniel Inouye (HI) 

(former) U.S. Representative Neil Abercrombie (1st District, HI) 

U.S. Representative Mazie Hirono (2nd District, HI) 

(former) Governor Linda Lingle (HI) 

State Senator Norman Sakamoto (HI District 15) 

State Senator Mike Gabbard (HI District 19) 

State Senator Robert Bunda (HI District 22) 

State Senator Clayton Hee (HI District 23) 

Representative Lynn Finnegan (HI House District 32) 

Representative Sharon Har (HI House District 40) 

Representative Michael Y. Magaoay (HI House District 46) 

City Government 

Mufi Hannemann, (former) Mayor of Honolulu 

Peter Carlisle, Mayor of Honolulu

State Agencies 

Coastal Zone Management Program 

Department of Hawaiian Home Lands 

Department of Land and Natural Resources, 

Division of Forestry and Wildlife 

Land Division 

State Historic Preservation Division 

Department of Transportation 

Office of Hawaiian Affairs

Federal Agencies 

U.S. Geological Survey 

National Park Service 

 U.S. Army Corps of Engineers 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix I. Public Involvement I-3 

U.S. Fish and Wildlife Service Coordination 

The core planning team members coordinated frequently during the planning process. The core team 

also relied on specialists from various Service programs in the Pacific Islands for their expertise. 

Additional coordination occurred with the Regional Office management and the Washington Office 

at key phases in the process including: 

Federal Register Notices 

 Notice of Intent to prepare a Comprehensive Conservation Plan and Environmental 

Assessment published – December 1, 2008 

 Notice of Availability of a Draft Comprehensive Conservation Plan and Environmental 

Assessment published – June 30, 2011 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

I-4 Appendix I. Public Involvement 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix J. Public Comments and Service Responses J-1 

Appendix J. Public Comments and Service Responses 

In this appendix the Service responds to comments that were received on the James Campbell NWR 

Draft CCP/EA, July 2011) during the official public comment period from June 30-August 1, 2011. 

Comments were received via letter, comment card, and e-mail. All substantial comments regarding 

the Draft CCP/EA are presented below. Some comments have had formatting changes and other 

minor edits to correct spelling or punctuation, but the majority of comments are as received. Service 

responses indicate where changes were made to the CCP based on specific comments. 

Index 

1. Ralph K. Makaiau, Jr., Kahuku Community Association .............................................................. J-1 

2. Phil Bruner, Brigham Young University Hawai‘i Museum of Natural History ............................ J-4 

3. Brian Bowers, Bowers + Kubota Consulting (for Kahuku Village Association) .......................... J-5 

4. W. Mike Ord ............................................................................................................................. J-6 

5. Peter Donaldson ............................................................................................................................. J-8 

6. Ken & Darlene Fiske ..................................................................................................................... J-9 

7. Norma Creps ................................................................................................................................ J-10 

8. Sylvia Pelizza ............................................................................................................................... J-11 

9. Meredith Speicher ........................................................................................................................ J-11 

Comments and Responses 

1. Ralph K. Makaiau, Jr., Kahuku Community Association 

Comment: 

The Kahuku Community Association (KCA) has remained supportive of further expansion of the 

refuge to > 800 acres and KCA has been consistent in its message for the USFWS to confine its 

operation within its boundaries to include area flood control. At this time the KCA can support your 

“Alternative C” plan of the James Campbell NWR Draft CCP subject to the following conditions: 

Coastal Strand Dune Habitat: 1) It was agreed that adjacent lands conditions outside 

refuge boundaries such as sea bird nesting, economic, and/or agriculture (not limited to these 

conditions) cannot become a burden to the adjacent landowners by USFWS. 2) It was agreed 

proposed land acquisition acreages were inclusive of buffer acreage or mitigation measures within 

800 acres needed to accommodate existing land owners. 3) It was agreed adjacent lands buffer 

mitigation within the refuge include east, south, and west boundaries apply. 

Service Response: 

Regarding item # 1 above, Goal 3 and its associated objectives and strategies of the Draft CCP 

outline the actions that we will undertake over the next 15 years to restore and protect coastal 

strand/dune habitat and upland scrub/shrub to provide safe refuge for endangered ‘īlio-holo-i-kauaua and threatened honu, as well as provide habitat for seabirds, shorebirds, and migratory birds. 

Based on our analysis of undertaking these activities, we do not anticipate any direct, indirect, or 

cumulative effects to adjacent landowners. Regarding items #2 and #3, it is not clear to us what is 

meant in these comments by the references to buffer acreage or mitigation measures. Language in 

the authorizing Expansion Act (Pub. Law 109-225) refers to buffer land within the Refuge to help 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

J-2 Appendix J. Public Comments and Service Responses 

protect the ecological integrity of the Refuge from surrounding development. This language does not 

establish any buffer areas within the Refuge affecting existing (i.e. adjacent) landowners and we are 

not aware of any prior agreements regarding buffer areas. The Refuge will continue to work in a 

cooperative manner with adjoining landowners to address issues or needs of mutual concern if any 

should arise in the future. Based on the goals, objectives and strategies proposed in the Draft CCP, 

we have not identified any actions that will result in significant impacts to the human environment 

that would require the implementation of mitigation measures. 

Comment: 

 Visitor Services: Visitor count greater than 5,000 and/or 210,000 for education and training 

is not an acceptable perspective in terms of additional traffic impacts, third-party independent traffic 

study should be required. It was agreed that multiple beach access routes would be provided in plan 

for community. It was agreed that multiple beach frontage parks would be provided in plan for 

community. KCA request land area for community for the purpose as a “bike path” to be set safely 

apart and paralleling Kamehameha Highway from refuge Kahuku Sugar Mill east boundary to 

Marconi Road west boundary. KCA request land area for community for purpose of a “passive path” 

to tour refuge running east to west either at coast line or midway property. 

Service Response: 

The Service understands that traffic congestion is a concern for north shore residents. Based on State 

of Hawai‘i tourism data, an average of 1 to 1 1⁄2 million people, both residents and tourists, visit the 

north shore each year. The preliminary estimate of 210,000 visitors to the Refuge reflects 

anticipated visitation only if the Visitor Center/Headquarters building is constructed. When 

constructed, we expect that the majority of visitors to the Visitor Center will be people already 

traveling along Kamehameha Highway to visit the north shore and our facility will not have a 

significant impact on the existing traffic levels along the highway. Any planning for the design and 

construction of the proposed Visitor Center will include necessary coordination with the Hawai‘i 

Department of Transportation, City and County of Honolulu and Federal Highway Administration, 

as appropriate, to address infrastructure needs such as turn lanes and acceleration lanes to minimize 

impacts to traffic flow from this project. A Visitor Services Plan (VSP) will be developed within 5 

years of Parcel 3 acquisition. It will include a transportation study which will provide a more 

detailed analysis of road, infrastructure, and visitation estimates and needs associated with this 

project, as well as the entire refuge expansion. In anticipation of this plan the Service has already 

initiated contact with the Federal Highway Administration, which provides transportation planning 

assistance to Federal agencies. 

Regarding beach access routes, the VSP will identify routes and facilities (trails, parking, roads) 

needed to provide access to the shoreline. While facilities needed to accommodate public access and 

use along the shoreline will be provided, these public uses and access must be carefully controlled. 

These facilities will enhance and support appropriate refuge uses such as wildlife observation, 

wildlife photography, fishing, and interpretation but will not support general recreation uses that 

may be associated with beach frontage parks as identified in the comment above, such as picnicking, 

sunbathing, and beach sports. 

The Service will explore the possibility of establishing a bike/pedestrian path on the Refuge during 

the development of the VSP. Any potential plans for a path on Refuge lands along Kamehameha 

Highway will have to take into consideration that these lands are under commercial leases to the 

shrimp farms until 2023. Suitable locations for potential public access paths (or trails) will be 

explored and identified as the VSP is developed. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix J. Public Comments and Service Responses J-3 

Comment:

Flood Damage Reduction for Kahuku: It was agreed that land acquisition required USFWS 

to construct east boundary, approximately 200 acre, floodway buffer zone. It was agreed east 

boundary, approximately 200 acre, to receive mauka Kahuku watershed runoff inclusive of Kahuku 

Village east runoff. It was agreed rerouting of makai Kahuku Hospital Ditch and Ō‘hia Stream east 

around Ki‘i Refuge. Ki‘i Ocean Outlet to be widened according to USACE data. 

Service Response: 

The land acquisition authorized by the James Campbell Expansion Act of 2005 (Pub. Law 109-225) 

was not contingent on any prior agreements with KCA or other parties for the Service to construct 

any of the drainage features described in the above comment. The Expansion Act did include a 

“finding” supporting the Act that in addition to other identified management priorities, the purchase 

of new Refuge lands “is necessary to reduce flood damage following heavy rainfall to residences, 

businesses, and public buildings in the town of Kahuku”. The intent of the original language was to 

support potential projects that were being evaluated at that time by USACE as part of the Kahuku 

Watershed Study and Feasibility Report. Subsequently, no flood damage reduction projects were 

identified by the USACE that would meet required Federal cost/benefit ratios and, as a result, no 

projects evaluated in the study were eligible for USACE funding. 

The Service and the Draft CCP acknowledge that approximately 120 acres along southeastern 

boundary of the proposed acquisition lands (Parcel 2) historically and currently flood following 

heavy rain events, serving as a floodwater storage area. This function will remain and a portion of 

this area is designated in the Draft CCP as the “Walkerville Unit” which is intended to be 

maintained by the Service during the lifespan of this CCP (15 years) as an area which provides 

temporary storage of floodwaters. Once all of this land is acquired, the Service will work with the 

partner agencies and the community to evaluate this area to determine if this function can be feasibly 

increased or enhanced. As specified in the Draft CCP, any proposed flood damage reduction 

projects occurring on Refuge lands would be subject to full and separate engineering, environmental, 

and regulatory review and approval. Goal 7 of the Final CCP outlines our approach for working 

with partner agencies and the local community to assist with planning and implementing flood 

damage control measures for the Town of Kahuku. 

Comment: 

KCA requires ditch maintenance to be ongoing from makai Kamehameha Highway for Ki‘i Stream, 

Kahuku Hospital Ditch, Ō‘hia Stream/Ki‘i ocean outlet, Kalaiokahepa Stream, Punamanō Springs, 

Bakahan Stream/Bakahan ocean outlet; all for purposes of flood avoidance, 

Service Response: 

The Service recognizes the important need to conduct routine and ongoing maintenance on ditches 

and drainages within the Refuge. In 2010, shortly after being purchased by the Service, major ditch 

maintenance was conducted by the Refuge on the Ki‘i ditch (referenced as Ki‘i and Ō‘hia Streams) 

and Punamanō ditch. This work substantially improved the drainage function of these important 

ditches. Additional work to improve and maintain other ditches and drainages throughout the Refuge 

will be accomplished on a continual basis. In addition, the Refuge will reevaluate existing 

infrastructure (i.e., dikes, ditches, pipes, etc.), especially on newly acquired lands, to determine if 

improvements or modifications can be made to improve drainage through the Refuge. On Bakahan 

ditch, the ocean outlet for this ditch occurs in an area of major sand accretion repeatedly blocking 

the mouth of the ditch with heavy deposits of sand. Because of this recurring condition, the ditch is 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

J-4 Appendix J. Public Comments and Service Responses 

not suited to be maintained as a major drainage outlet. Additionally, the Refuge does not own all of 

the land that the ditch crosses. Limited maintenance will occur along that portion of Bakahan ditch 

owned by the Refuge. 

Comment: 

KCA request continued engagement of aquaculture leases. 

Service Response: 

As part of the agreement under which the Service purchased these expansion lands, it is required that 

the commercial aquaculture leases (shrimp farms) expire in 2023. At that time, these lands will 

revert to full management responsibility of the Refuge. These lands will be critical to helping the 

Refuge fulfill its purposes of managing and recovering endangered Hawaiian waterbirds and 

benefitting other native wildlife. 

Comment: 

KCA requests implementation of reuse water program for City and County of Honolulu Kahuku 

Wastewater Treatment Facility. 

Service Response: 

The potential to reuse treated wastewater being released from the facility to supplement water used 

to manage Refuge wetlands was previously evaluated by the Service. Due to concerns that even 

treated water may contain undesirable levels of chemicals and hormones, the use of this water in 

breeding and foraging areas poses an unacceptable risk to endangered waterbirds, therefore the 

Service will not pursue this course of action. 

2. Phil Bruner, Brigham Young University, Hawai‘i 

Comment: 

Given that JCNWR is a major resource in the recovery plans of Hawai‘i’s endangered waterbirds, 

human activity in the wetland areas during breeding season must be strictly controlled. Any new 

public access roads through and around the wetland areas will likely create increased challenges to 

limiting disturbance to nesting waterbirds. 

Service Response: 

The Service recognizes that public access needs to be carefully considered and controlled in order to 

minimize disturbance to all native wildlife, including endangered species. During preparation of the 

VSP, avoiding and minimizing the potential impacts or disturbance to wildlife from proposed public 

uses will be a high priority. We are required to satisfy the consultation requirements of Section 7 of 

the Endangered Species Act, a process which evaluates effects of refuge management actions, 

including measures to avoid or minimize impacts to threatened and endangered species. The Service 

is also required to prepare compatibility determinations (CD) for all proposed uses and these CDs 

will identify measures to avoid or reduce disturbance to wildlife before these uses would be 

approved. 

Comment:

The greatly expanded perimeter of the Refuge created by the recent addition of surrounding lands 

will need an increase in Refuge staff not only to manage the wetland but to monitor and control 

human access on a 24/7/365 schedule. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix J. Public Comments and Service Responses J-5 

Service Response: 

The Service understands and agrees that the expansion of the Refuge increases our responsibility as 

a landowner and land manager. This Final CCP identifies additional staff and funding that are 

needed to fully implement the actions and strategies described in the plan and to meet these 

responsibilities. The Appendix C, Plan Implementation and Costs, identified the need for13 

additional staff positions, including a full-time law enforcement officer to conduct patrols and 

enforce regulations. 

Comment:

The plan to enhance the newly acquired lands for seabird nesting is commendable but brings with it a 

separate set of habitat management challenges and shoreline predator/disturbance enforcement. 

While the shoreline remains open to human activity the protection of dunes, just mauka of the 

shoreline, will be a challenge. Constant attention to repairing and maintaining the fence line against 

the effects of sand erosion and the corrosive effect of the marine environment will be itself a huge 

task. The fence line needs to not only restrict human access but equally or more importantly, restrict 

access to dogs. 

Service Response: 

As identified in this Final CCP, establishing fences to reduce predators (including dogs) will be a 

critical management strategy that needs to be implemented before seabirds can successfully nest on 

the Refuge. We recognize that proper maintenance of the fence will be an on-going requirement that 

must be considered and included during project planning. 

Comment:

The cost of effectively managing this much larger refuge was not presented in this Draft. Clearly to 

do all that this Comprehensive Management Plan Environmental Assessment proposes will require a 

significant financial as well as man-power investment. If the refuge is to protect our native water 

birds, migratory waterfowl, shorebirds, and other native species (i.e., Monk Seals and Green Sea 

Turtles). I believe this is only possible with a significant increase funding for not only materials but 

full time staff. 

Service Response: 

The Draft CCP identified additional staff and funding needed in order to fully implement the 

strategies under each alternative. Appendix C of this Final CCP, Plan Implementation and Costs, 

lists the specific staff positions needed as well as estimated costs for the major projects we have 

proposed. 

3. Brian Bowers, Kubota + Bowers Consulting (Kahuku Village Association) 

Comment: 

KVA strongly supports Alternative C (Full Restoration and Management of the Refuge Expansion Plans) 

because it best supports the vision of the Kahuku community as well as KVA. KVA is in strong support 

of Objective 7.1 in the plan concerning Flood Damage Reduction for the Town of Kahuku. This objective 

will provide flood mitigation for the Walkerville area and adjacent KVA managed property. 

Consistent with the objective of flood mitigation, I have attached a drainage study which was completed 

on behalf of KVA that shows possible grading that could be completed on the future James Campbell 

NWR land that may improve the flood mitigation in the Walkerville residential area. We request that this 

study be incorporated into the final Comprehensive Conservation Plan and the proposed grading be the 

subject of future engineering and environment studies by the Fish and Wildlife Service to meet Objective 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

J-6 Appendix J. Public Comments and Service Responses 

7.1.

Service Response: 

The Service understands the long and difficult history that the community of Kahuku has experienced 

with flooding issues. We believe with our commitment to improve and maintain drainage through 

new and existing Refuge lands that we can help alleviate and reduce damages from flooding to the 

community. However, many factors contributing to flooding in Kahuku lie outside of the Refuge and 

are beyond the control of the Service. The legislative intent of the Expansion Act in including the 

language “reduce flood damage following heavy rainfall to residences, businesses, and public buildings 

in the town of Kahuku” was intended to provide a mechanism by which USACE, a Federal agency, 

could implement flood damage reduction projects in the future on Federal land (the Refuge), if these 

projects met USACE and Service criteria. As described in the Draft CCP, the 2006 Kahuku 

Watershed Study conducted by USACE did not identify any viable flood damage reduction features at 

that time. The Service will continue to work with the local community and appropriate agencies to 

determine if appropriate and feasible flood damage reduction projects can be designed and 

constructed on the Refuge. In this regard, the drainage study and grading proposal provided by the 

commenter does not provide sufficient detail to determine if it is feasible or practical to pursue. It 

will not be the responsibility of the Service to design and engineer flood damage reduction projects. 

We have revised Section 2.6.7 of the Final CCP to clarify the strategies to be implemented by Service 

to assist partner agencies and the local community with planning and implementing flood damage 

control measures for the Kahuku area. 

4. W. Mike Ord 

Comment: 

I fully support Alternative C. The draft Revised Recovery Plan for Hawaii Waterbirds, Second Draft 

of Second Revision, 2005 called for removing the threat of hybridization with feral mallards. That 

said, feral mallards on the Refuge should be shot to minimize further hybridization. 

Service Response: 

We will support development and implementation of interagency efforts to manage the koloa maoli 

population. Currently there is no program to cull feral mallards or hybrid ducks on the Refuge. In 

order for such an effort to be most effective, the project should be Islandwide in scope. The strongest 

remaining population of pure koloa maoli is on the Island of Kaua‘i. There is on-going research 

occurring on Kaua‘i to develop strategies to address the hybridization concern. As new information 

becomes available and techniques are developed and approved, these will be implemented on the 

Refuge, as appropriate. If new information demonstrates that local (on-Refuge) control efforts may 

benefit koloa recovery then the Refuge will implement a corresponding control program as funding 

and staffing allow. Control may include shooting, trapping, or other methods to be developed. 

Comment: 

I believe USFWS should give top priority to working with the State to ban fishing, of any kind, on 

the shoreline of James Campbell Refuge because if it not implemented then you can forget hoping to 

get seabirds nesting on the Refuge in the future. 

Service Response: 

As described in the Draft CCP, the VSP will address fishing and visitor access to the Refuge-owned 

and -managed portion of the shoreline. The Service will work with the State to address needs and/or 

issues related to fishing along the State-owned portion of the shoreline. One proposal described in 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix J. Public Comments and Service Responses J-7 

the Draft CCP identifies seeking an Executive Order from the Governor of Hawai‘i which would 

transfer management authority for the State-owned portion of shoreline to the Refuge. This would 

allow all uses and regulations along the shoreline to be consolidated. The VSP will identify special 

regulations and closed areas needed to ensure successful seabird nesting. We believe we can allow 

some level of fishing and still have seabirds nesting in the dune vegetation. The shoreline will be 

managed to encourage use by nesting seabirds through fencing, predator control, vegetation 

management, and control of public access and use. Signing, regulation enforcement, and education 

of shoreline users will be used to minimize conflicts between fishing and seabird nesting. 

Comment: 

I do not know what 50.CFR27.34 says other than your comments in James Campbell Refuge CCP 

where aircraft cannot fly over a wildlife refuge but purportedly an aircraft could land in an 

emergency. Moral to the story is minimize removal of vegetation from the runway where birds can 

use it but aircraft won't land. Aircraft in trouble can either go to the U.S. Marine base or to 

Dillingham airfield in Mokuleia. 

Service Response: 

We believe we can remove pest plants from the abandoned runway to improve habitat conditions for 

seabirds and still prevent unauthorized use by aircraft. Currently, the edges of the runway are 

dominated by exotic invasive vegetation (pest plants). Most of these are thick stands of small trees or 

shrubs that disrupt and minimize airflow (breezes and wind) across the runway. Adequate airflow is 

a critical consideration for seabird management. Seabirds, both young and adult, need adequate 

airflow to help regulate their body temperatures to keep from overheating during extended periods of 

time on the ground during nesting and rearing. Current plans are to remove most of the invasive 

plants on and along the runway while also retaining the less dominant native vegetation. This will 

maximize both the surface area available for nesting seabirds as well as critical airflow across the 

runway. Since O‘ahu is a relatively small island with limited airport and flying facilities we believe 

through outreach and education of the flying community, as well as enforcement of regulations, we 

will prevent unauthorized use of the abandoned runway and potential conflicts with seabirds and 

other migratory birds. 

Comment: 

Pest management should be swift and lethal or USFWS goes into the poor house with repetitive 

actions. I would recommend absolutely minimum live trapping and maximum lethal trapping. I think 

USFWS should aggressively control the number of Cattle Egrets within the Ki‘i unit especially 

during the four waterbirds’ primary nesting time (March-September). 

Service Response: 

The Refuge will be adding and increasing the use of lethal trapping techniques. Our current pest 

(predator) management program includes a variety of control techniques for several targeted species 

but currently does not include lethal trapping. The predator control program will continue to evolve 

as new data and techniques are integrated into the program. Based on recent information, lethal 

traps will improve the program’s effectiveness and efficiency (both time and cost), which is a 

primary consideration. 

As identified in the strategy for Goal 1, Objective 1.1, it is our intention to eliminate nonnative 

roosting trees of the invasive cattle egret. Care must be taken to not also impact native ‘auku‘u 

during this process. Periodic cattle egret control, primarily by shooting, has taken place on the Ki’i 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

J-8 Appendix J. Public Comments and Service Responses 

Unit in past years and control will continue as needed to minimize the impact of these invasive 

predators to endangered waterbirds. 

Comment: 

Proposal to place new HQ/VC/EE facility in the vicinity of Marconi Road and Kamehameha Hwy 

would not be my first choice because it would be tucked away in a corner. My choice would be 

where Mings Dynasty is now where you could get a bird’s eye view of the greater majority of the 

Refuge. Second floor manager's office could give him close to a 180 degree view of the refuge. 

Service Response: 

A final location for the proposed HQ/VC/EE has not been determined. The proposed site at the 

intersection of Marconi Rd. and Kamehameha Hwy. has tentatively been identified due to several 

important site considerations. These include site elevation above the 100-year flood plain; proximity 

to utilities; potential for access via Marconi Road other than directly on/off Kamehameha Highway 

and adequate size of the site (8-12 acres)to accommodate a large building, entrance roads, and 

sufficient parking areas. The Ming Dynasty site referred to in the comment, while more centrally 

located on the refuge, is a much smaller site and currently under lease until 2023, so would not be 

available as a potential HC/VC/EE site until after that year. 

Comment: 

New Zealand style predator proof fencing is essential for Ki‘i unit (ponds A to G) to replace the 

existing fencing. Any rat or mongoose fenced in could probably be eliminated within one year with 

appropriate lethal trapping. By doing this you get two immediate benefits: (1) maximum breeding 

potential for all four waterbirds with minimal disturbance and (2) big dollar savings where refuge 

personnel can devote their energies to other parts of the refuge for maximum results. 

 

Service Response: 

The Draft CCP identifies the need to increase the use of fencing on various parts of the Refuge as an 

effective predator control tool. Specific sites and design of any new fencing has not been determined 

yet. A predator-proof fence such as suggested in the comment is a possibility and will be considered 

for Ki‘i Unit. Several important issues need to be evaluated before such a project would be initiated. 

A primary consideration is the potential effect on the endangered waterbirds themselves. ‘Alae ‘ula, 

in particular, and also ‘alae ke‘oke‘o, often pass through the existing large mesh fence to feed, nest, 

or loaf on both sides of the fence. A predator-proof fence would restrict these movements thereby 

altering territories and habits of these birds at Ki‘i. 

The increased use of fencing, including predator-proof fencing, should result in improved cost 

efficiency of the predator control program. The use of new fences will be implemented in stages so 

we can evaluate benefits and effectiveness. 

Comment: 

It is essential to prioritize what is done, when and how to maximize results and to preclude spending 

money time and time again on the same project. 

Service Response: 

We fully recognize the need to prioritize management activities to maximize results and utilize 

limited staff and funds efficiently. This Final CCP identifies additional staff needs and as well as 

funding needed for major projects. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix J. Public Comments and Service Responses J-9 

5. Peter Donaldson 

Comment: 

The #1 priority should be to provide habitat for endangered waterbirds and, if possible, to remove the 

stilt, coot, moorhen, and duck from the endangered list. Beyond that, FWS needs to increase access 

to the refuge. Without improved access, there will be little public support for the refuge. Without 

ongoing public support, it will be difficult to maintain programs to protect habitat. 

Service Response: 

Protecting and managing endangered waterbirds is the purpose of the Refuge and the majority of 

management actions are directed in support of at these species with the intention of contributing to 

supporting recovery efforts and ultimately de-listing (removing) these birds from the Endangered 

Species list. 

As discussed in the Draft CCP, the new expansion lands will offer many new opportunities for public 

use and access to the Refuge. As identified under Goal 5, Objective 5.1, a VSP will be developed 

within 5 years of the final land acquisition which will specifically evaluate and identify the facilities 

(e.g., parking, trails, and/or boardwalks) needed to provide these opportunities. Public awareness 

and support for the Refuge is a high priority in our outreach efforts. 

6. Ken & Darlene Fiske 

Comment: 

In a review of alternate plans A, B, and C, we are in favor of Intensively Managed Wetland habitat 

indicated under Alternative C; protecting Natural Wetland Habitat under Alternative C; restoring 

Remnant Wetland habitat under Alternative C; Coastal Strand Dune Habitat under Alternative C; and 

Scrub and Shrub Habitat under Alternative C. 

Scientific data: Those items under Alternative C are fine. 

Cultural and historic resources: I am in agreement with Alternative C. 

Flood damage reduction for Kahuku: I am in accord with Alternatives A, B, and C. 

Service Response: 

We appreciate the support expressed by these comments. 

Comment: 

Expansion of lands: Land acquisition should be completed or expanded to include the acreage 

fronting on Marconi Road. Acquisition is more important than building new facilities, other than the 

maintenance shop and greenhouse. 

Service Response: 

It is a high priority for the Service to complete the land acquisition as soon as possible. The current 

contract agreement with the James Campbell Company does include the land parcel adjacent to 

Marconi Road (Parcel 3) referred to in the comment above. Acquisition funds have been obligated 

and set aside for this purchase. Planning and construction of new facilities would not detract from 

the effort to complete the land acquisition. All funding for new facilities would be separate from land 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

J-10 Appendix J. Public Comments and Service Responses 

acquisition funds and therefore would not reduce the amount of funding set aside for the purchase of 

the two remaining parcels. 

Comment 

Visitor Services: I am not in agreement with Alternative C nor Alternative B. I am in accord with 

Alternative A. Alternatives B and C are not in keeping with the primary focus of restoration and 

protection of wildlife habitat. 

Service Response: 

We believe that we can achieve habitat restoration and protection while also accommodating a 

certain amount of wildlife-dependent recreation on the Refuge. This approach is consistent with the 

National Wildlife Refuge System Administration Act which encourages providing opportunities for 

wildlife-dependent recreation when compatible with refuge purposes. Public use activities will be 

incorporated into the expansion land restoration with consideration for protection of endangered 

species and habitat protection. Compatibility determinations and other environmental compliance 

requirements will be completed prior to construction of any new facilities. As previously described, 

public awareness and support for the Refuge are key aspects of outreach efforts and a critical need 

for future conservation efforts. Both environmental education and interpretation are integral to 

promoting environmental stewardship and endangered species’ protection and, as such, are 

important aspects of the visitor services program. In addition, the preferred alternative (Alternative 

C) describes full restoration and management of Refuge habitats over the next 15 years, thereby 

maximizing benefits to wildlife. 

7. Norma Creps 

Comment: 

I support Alternative C as it provides full restoration and management of Refuge expansion lands. 

Of the three choices it provides the largest protected area for endangered waterbirds and maximizes 

the acreage for seabird nesting site improvements. I also like that Alternative C includes a new 

HQ/VC/EE facility and that cultural and historic awareness and environmental education are 

included in the plan. 

Service Response: 

We appreciate the support expressed by these comments. 

Comment: 

With the loss of access to many of our public beaches here on O‘ahu due to private development of 

nearshore areas I am hesitant to support transfer of management authority over the shoreline adjacent 

to the Refuge to the USFWS, a Federal entity. Pupping monk seals are afforded protection under the 

ESA and the MMA and nesting sea turtles as well. I do not support a complete closure of the 

shoreline areas however I personally would support enforcement of current laws and regulations and 

increased education and outreach. 

Service Response: 

If this course of action is pursued, the Service will work closely with the State to develop an 

Executive Order (EO) from the Governor of Hawai‘i which would transfer management authority for 

the State-owned portion of shoreline to the Refuge. This would allow all uses and regulations along 

the shoreline to be consolidated. This EO could only be implemented with the full support and 

approval of the Governor. We do not intend to impose a complete closure of the shoreline corridor. 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix J. Public Comments and Service Responses J-11 

However, we believe that consolidating coastline regulations and management will offer greater 

benefit and protection to sensitive coastal resources. Proposed management actions (i.e., temporary 

site-specific seasonal closures to protect honu or seabird nests) will facilitate enforcement of existing 

laws for the protection of threatened, endangered, and other native species. 

8. Sylvia Pelizza 

Comment: 

Select Alternative C. It provides the greatest opportunity to benefit the resource and American 

public. 

Service Response: 

We appreciate the support expressed by these comments. 

9. Meredith Speicher 

Comment: 

As part of the refuge infrastructure, are there opportunities to explore a pedestrian and bike path that 

would allow visitors from the surrounding communities to walk or bike to and into the refuge? 

Ideally, connecting the new bike path from Lāi‘e to Mālaekahana to the north shore bike path would 

offer a unique opportunity to connect the communities and allow a non-motorized transportation 

option for those wishing to visit the refuge. A trail or path within the refuge could be done in a way 

to avoid impacts to wildlife and could reduce potential new impacts associated with visitor travel and 

parking and reduce the overall carbon footprint of visitors on the refuge. Such a path could be a key 

link in recreational opportunities for walkers, hikers, and bike riders on a safe path on the north shore 

of Oahu. 

Service Response: 

The Service will explore the possibility of establishing a bike/pedestrian path on the Refuge during 

the development of the VSP. Plans for a path will have to take into consideration that land areas 

along Kamehameha Highway will be under commercial lease until 2023. The use of bicycles on the 

Refuge in the future may be a viable alternative to motorized transportation. 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

J-12 Appendix J. Public Comments and Service Responses 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

Appendix K. ESA Section 7 Consultation K-1 

Appendix K. ESA Section 7 Consultation 

Index 

Predator Control Program for Endangered Waterbirds ................................................................. K-3 

Use of Rodeo ................................................................................................................................... K-20 

Use of Ramik Mini-bars ................................................................................................................ K-28 

Use of Habitat ................................................................................................................................. K-36 

Use of Garlon 4 .............................................................................................................................. K-44 

Use of Garlon 3A ............................................................................................................................ K-47 

Use of Aquamaster .......................................................................................................................... K-47 

Prescribed Burning ......................................................................................................................... K-64

Avian Influenza Surveillance Sampling ........................................................................................ K-68 

 
James Campbell National Wildlife Refuge Comprehensive Conservation Plan 

K-2 Appendix K. ESA Section 7 
 United States Department of the Interior

FISH AND WILDLIFE SERVICE 

Oahu National Wildlife Refuge Complex 

66-590 Kamehameha Highway, Room 2C 

Haleiwa, HI, 96712 

Phone: (808) 637-6330 FAX: (808) 637-3578

September 16, 2008 

To: Files 

From: Michael D. Silbernagle, Acting Refuge Manager, Oahu National Wildlife Refuge 

Complex 

Subject: Biological Opinion of the U.S. Fish and Wildlife Service on the Effect of the 

Predator Control Program for Endangered Waterbirds at Oahu National Wildlife 

Refuge Complex, Oahu, Hawaii 

CONSULTATION HISTORY 

The U.S. Fish and Wildlife Service (Service) Pacific Islands Fish and Wildlife Office staff 

working with the National Wildlife Refuge (NWR) Managers identified priority Hawaiian Bird 

Conservation Focal Area projects on individual Refuges in Hawaii and the Pacific Islands. 

These projects are to implement high priority recovery actions for six endangered Hawaiian 

waterbirds, Hawaii Island forest birds, and the Nihoa millerbird (Acrocephalus familiaris kingi). 

In Fiscal Year 2007, the Ecological Services Division, Pacific Islands Fish and Wildlife Office 

provided approximately $540,000 to five National Wildlife Refuge Complexes within the Pacific 

Islands to fund eight projects. 

On August 27, 2007, funds were allocated to the Oahu NWR Complex to conduct predator 

control at all of the wetland units (Pearl Harbor NWR- Honouliuli and Waiawa units; James 

Campbell NWR – Kii and Punamano units). The funds will be used to secure one full time 

equivalent position and supplies to implement predator control to include 1) live-trapping for 

small Indian mongoose (Herpestes auropunctatus), feral cats (Felis catus), feral dogs (Canis 

familiaris), rats (Rattus sp.), and American bullfrogs (Rana catesbeiana) and 2) utilize 

diaphacinone bait stations for control of rats and mongoose. 

Funds provided by the Service’s Ecological Services Division, were required to be obligated by 

December 31, 2007. This did not allow for the hiring of a Service staff person due to time 

constraints. The option to contract the work met the deadline to obligate the funds by the end of 

the calendar year. 

James Campbell National Wildlife Refuge Comprehensive Conservation Plan Appendix K. ESA Section 7 Consultation K-3
A contract was awarded to contractor Pono Pac Land Management on November 13, 2007. The 

trapping program began on January 3, 2007. 

BIOLOGICAL OPINION

PROJECT DESCRIPTION 

The Oahu National Wildlife Refuge Complex (Refuge Complex) consists of three National 

Wildlife Refuges: James Campbell NWR, Pearl Harbor NWR, and Oahu Forest NWR. Each is 

separated by approximately 25 to 30 miles on the island of Oahu, Hawaii. The goals of the Oahu 

NWR Complex are to protect, conserve, restore, and enhance native habitats to aid in the 

recovery and perpetuation of federally listed endangered and threatened species (specifically for 

four of the six endangered Hawaiian waterbirds); as well as provide migration and wintering 

habitat for migratory birds, with emphasis on seabird, shorebird, and waterfowl habitats; protect, 

conserve, manage, and restore the rare coastal dune strand and provide opportunities for 

compatible wildlife-dependent recreation and interpretation; and create partnerships and provide 

leadership in coordinating land management activities. 

A contractor will carry out the predator control program on the Kii unit of the James Campbell 

NWR (Figure 1; 117 acres) and the Honouliuli and Waiawa units of the Pearl Harbor NWR 

(Figure 2; 37 acres and Figure 3; 25 acres, respectively). Predator control is an important part of 

refuge management in the Hawaiian Islands. The ability to recover endangered avian species is 

relative to the number of individuals that can reach fledgling stage. Predators kill and/or 

consume adults, eggs, and young. The predator control contractor will deploy live traps for 

mongoose, feral cats, feral dogs and rats. Funnel type live traps will be deployed for bullfrogs. 

The contractor will capture, collect and dispatch as necessary predators caught in live traps. Bait 

stations will be deployed for rats and mongoose. Data will be collected on the number of 

targeted and incidental animals captured, amount of bait used, location of traps, and movement 

of trap locations. 

James Campbell National Wildlife Refuge Comprehensive Conservation Plan K-4 Appendix K. ESA Section 7 Consultation
James Campbell National Wildlife Refuge Comprehensive Conservation Plan Appendix K. ESA Section 7 Consultation K-5
James Campbell National Wildlife Refuge Comprehensive Conservation Plan K-6 Appendix K. ESA Section 7 Consultation
James Campbell National Wildlife Refuge Comprehensive Conservation Plan Appendix K. ESA Section 7 Consultation K-7
Live Traps – Mongoose and Feral Cats

• Traps will be strategically placed along fence lines, dikes, etc. and coordinated with the 

Refuge Complex biologist 

• Traps will be mapped using global positioning units 

• Live traps for small mammals will be checked every 48 hours while trapping activities 

occur 

• Traps will be operated five days a week, closed on weekends and holidays 

• Water bottles will be filled and bait will be replaced as needed, shade will be provided by 

concrete shingles 

• Traps will be maintained in good working order; trip pans clear and moving parts free of 

debris 

• Traps not working correctly will be restored to working condition or replaced 

immediately, if repair is not possible 

• Old bait will be bagged and disposed of in a Refuge dumpster; no bait will be scattered 

on the Refuge 

• Types of bait will be alternated and coordinated with the Refuge Complex biologist 

• Mongoose trapped will be dispatched with small caliber firearms (.22 cal.); carcasses 

measured and weighed; prepared for storage; and disposed of at appropriate municipal 

dump 

• Feral cats will be dispatched humanely; individuals with collars will be transported to the 

Hawaiian Humane Society 

• If traps catch Hawaiian moorhen, traps will be relocated with coordination from the 

Refuge Complex biologist 

Live Traps – Feral Dogs

• Traps will be deployed on an as needed basis, for instance, when there is evidence 

(tracks, sightings, bird kills, etc.) of feral dog ingress onto individual Refuge units 

• Traps will be mapped using global positioning units 

• Feral dogs captured will be transported to the Hawaiian Humane Society 

• When feral dogs are observed killing or harassing federally listed waterbirds or signs of 

dog related bird kills are found, the Refuge Complex law enforcement officer will be 

notified 

Live Traps – American Bullfrogs

• Traps will be deployed during the breeding season, hatching and fledging stages, of the 

Hawaiian stilt on the Kii Unit (April through July) 

• Funnels will be designed with a minimal diameter opening (six inches or less) to allow 

for frog capture and minimize potential for Hawaiian moorhen capture 

• Specific locations will be coordinated with Refuge Complex biologist 

• Traps will be mapped using global positioning units 

• Traps will be checked every 24 hours 

• Traps will be operated Monday through Friday, pulled from impoundments on weekends, 

holidays and periods of employee leave 

James Campbell National Wildlife Refuge Comprehensive Conservation Plan K-8 Appendix K. ESA Section 7 Consultation
• Species and numbers of all organisms caught in frog traps will be recorded 

• Bullfrogs will be dispatched; measured, weighed; stomach contents identified, 

reproductive status of females determined, presence of any conditions of biological 

significance will be recorded; and carcasses disposed of properly 

• If traps catch Hawaiian moorhen or when moorhen chicks are present, traps will be 

relocated with coordination from the Refuge Complex biologist 

Bait Stations

• Current bait application is with Ramik mini bars (active ingredient diaphacinone) 

• Stations will strategically placed along fence lines and interior of Refuge units 

coordinating with Refuge Complex biologist 

• Damaged stations will replaced immediately and reported to Refuge Complex biologist 

• Notification signs will be posted and maintained at all refuge units 

• Stations will be mapped using global positioning units 

• Stations will be visited and cleaned on seven to ten day intervals based on consumption 

rates 

• Moldy or degraded baits will be removed and disposed of according to label restrictions 

• Fresh baits will be placed in each station as needed during visits 

• Numbers of baits placed and depleted baits will be recorded 

• Diaphacinone usage is submitted annually to Pacific Islands Fish and Wildlife Office 

The federally endangered Hawaiian coot (Fulica alai), Hawaiian stilt (Himantopus mexicanus 

knudseni), Hawaiian duck (Anas wyvilliana), and Hawaiian moorhen (Gallinula chloropus 

sandvicensis) are found on all Refuge units. Based on past and ongoing work on the Oahu NWR 

Complex, the Hawaiian coot, Hawaiian stilt, and the Hawaiian duck have never been 

documented in the traps within the Refuge Complex units, during trapping efforts that have been 

implemented periodically since 1992. Although the Hawaiian duck has been caught in live traps 

on Kauai, based on current Hawaiian duck hybrid studies conducted by Andy Engilis of 

University California at Davis, it is not likely that a Hawaiian duck will be present within the 

Oahu Refuge Complex units. . 

There is a high likelihood that Hawaiian moorhen will be accidentally trapped in the predator 

live traps due to the higher densities present on Oahu and the inquisitive nature of these birds. 

The trapability of moorhen is further demonstrated by a study conducted in 2005 though 2007, 

by David DesRochers and Refuge Complex staff, as part of his doctoral program at Tufts 

University, Massachusetts. The program was designed to begin banding this species for a 

cooperative project on Improving Population Estimates of Hawaiian Moorhen with Call 

Response Surveys and Banding Data (DesRochers et al. 2006). Within a two-year time period, 

ninety Hawaiian moorhen were banded with 162 captures. The birds are naturally attracted to 

the live traps. The wetland units of the Oahu NWR Complex are all fenced and will minimize 

the potential for Hawaiian moorhen to be killed by feral dogs if moorhen are captured in live 

traps. 

The Oahu Refuge Complex has determined the predator control program will not adversely 

affect Hawaiian duck, Hawaiian coot or the Hawaiian stilt and actions will be beneficial. 

James Campbell National Wildlife Refuge Comprehensive Conservation Plan Appendix K. ESA Section 7 Consultation K-9
However, Hawaiian moorhen may be harassed due to capture in live traps which could result in 

injury or harm. 

If a Hawaiian moorhen is incidentally captured during live trapping activities the bird will be 

examined and released immediately, if unharmed. If banded: location, band numbers, colors, 

and band orientation will be recorded and reported to Refuge Complex biologist. Refuge 

Manager will be notified immediately if a moorhen is captured. 

If a Hawaiian moorhen is injured, an appropriate wildlife veterinarian will be contacted and the 

bird will be transported for care. The Refuge Manager will be notified immediately of this 

activity. Capture incidents will be evaluated within 24 hours and trapping efforts will be 

modified to assist in minimizing any future captures. 

The depository designated to receive specimens of Hawaiian moorhen that are collected is the 

B.P. Bishop Museum, 1525 Bernice Street, Honolulu, Hawaii, 96817 [phone: (808) 547-3511]. 

If the B.P. Bishop Museum does not wish to accession the specimens, the Service’s Division of 

Law Enforcement in Honolulu, Hawaii [phone: (808) 861-8525; fax: (808) 861-8515] should be 

contacted for instructions on disposition. 

STATUS OF THE SPECIES 

The Hawaiian moorhen is an endemic subspecies of the Common moorhen in the Hawaiian 

Islands. The Hawaiian moorhen was listed as an endangered species in 1967 under the 

Endangered Species Act (Act) of 1973 (16 U.S.C. 1531 et seq.), as amended. In Hawaiian 

legend, these birds were thought to have brought fire from the gods to the Hawaiian people. The 

Hawaiian moorhen is a dark gray bird with a black head and neck, and white feathers on their 

flanks and on their undertail coverts. They have a very distinctive red frontal shield, and their 

bill tip is yellow with a red base. Their legs and feet are greenish and without lobes. The 

Hawaiian moorhen usually measure about 13 inches in length. Both sexes are similar and have 

chicken-like cackles and croaks. 

Hawaiian moorhen are the most secretive of the native waterbirds, preferring to forage, nest and 

rest in dense late succession wetland vegetation. Most birds feeding along the waters edge or in 

open water will quickly seek cover when disturbed. The preferred habitat for moorhens 

includes: interspersed dense stands of robust late succession vegetation near open water 

(approximately 50 percent water to 50 percent vegetation) floating or barely emergent mats of 

vegetation and water depth less than 3 feet (Service 2005). These birds nest year-round but 

appear to have two active seasons from November through February and May through August 

(Service 2007). It is believed that the timing of nesting is related to water levels and late 

succession wetland vegetation. The Hawaiian moorhen usually lays an average of five to six 

eggs, although clutches have been up to 13 eggs, and incubation is about 25 days. Hawaiian 

moorhen consume introduced fishes, crustaceans, mollusks, insects, wetland plants and emergent 

grasses (Service 2005). 

No historical population estimates are available for the endemic Hawaiian moorhen. Because 

they are such secretive birds, it is difficult to conduct population surveys of this species. It is 

believed that they were common on the main Hawaiian Islands, except Lanai and Kahoolawe, in 

James Campbell National Wildlife Refuge Comprehensive Conservation Plan K-10 Appendix K. ESA Section 7 Consultation
the 1800’s but radically declined by the mid-1900. Surveys from the 1950’s through the 1960’s 

estimated no more than 57 individuals. Currently Hawaiian moorhen inhabit the islands of 

Kauai and Oahu (Service 2005). There was an attempted Hawaii State re-introduction of six 

moorhen (three females and three males) on May 18, 1983 to the island of Molokai at Kakahaia 

NWR. One of the banded birds was found dead January 2, 1985 and a local resident mistook the 

other five for chickens they were consumed (Dibben-Young 2007). 

Moorhens are widely distributed on Oahu, but are most prevalent between Haleiwa and 

Waimanalo. Small numbers exist in Pearl Harbor where foraging occurs in semi-brackish water. 

The population on the leeward coast is limited to Lualualei Valley. Biannual State waterbird 

surveys conducted from 1986 through 2006 show numbers of individuals detected on Oahu 

between 44 and 242 birds (Table 1 and Table 2). 

Table 1. State Waterbird Surveys 1986 – 2006 Winter Survey counts of Hawaiian moorhen. 

Data: Hawaii Waterbird Database-Hawaii Natural Heritage Program/University of Hawaii 2007 

James Campbell National Wildlife Refuge Comprehensive Conservation Plan Appendix K. ESA Section 7 Consultation K-11
Table 2. State Waterbird Surveys 1986 – 2006 Summer Survey counts of Hawaiian moorhen. 

Data: Hawaii Waterbird Database-Hawaii Natural Heritage Program/University of Hawaii 2007 

Reasons for Species Decline and Current Threats 

The primary causes of the decline of the Hawaiian moorhen are the loss of wetland habitat, 

predation by introduced animals, hunting in the late 1800's and early 1900's, disease, and 

environmental contaminants. A significant amount of Hawaii's wetlands have been lost due to 

human activities. Modification of wetlands includes filling and draining for agriculture, houses, 

hotels and golf courses. The Service estimates 22,475 acres of wetlands existed within the 

coastal plains of Hawaii circa 1780 (Service 1990). In 1990, the Service estimated only 15,474 

acres remaining, a decrease of 31 percent (Service 2005). This loss of suitable wetlands is 

compounded by the alteration of wetland plant communities due to invasion by non-native 

plants. Species such as California grass (Brachiaria mutica), pickleweed (Batis maritima), water 

hyacinth (Eichornia crassipes), Indian fleabane (Pluchea indica) and red mangrove (Rhizophora 

mangle) present a serious threat by out-competing more desirable species and eliminating open 

water habitats. Unmanaged vegetation significantly reduced open water, shallow water, bare 

ground, and exposed mudflat habitat. All of these habitats are under serious threat without 

management to control these aggressive plant species (Service 2005). 

Other major contributors to the decline of endangered Hawaiian moorhen are introduced 

predators. Mongoose, feral cats, and feral dogs are all presently found within wetlands and pose 

a serious threat to moorhen reproductive success. All three of these predatory species are known 

to take eggs, young birds, and even nesting adults. Both cats and dogs are of particular concern 

because of the close proximity of Hawaii wetlands to urban areas. Therefore, it is important that 

a predator trapping program be established and maintained to prevent the predation of all the 

Hawaiian waterbirds nesting within wetlands. Other species, such as the cattle egret (Bulbulcus 

ibis), bullfrog, and rat have been observed congregating around nesting waterbirds just prior to 

James Campbell National Wildlife Refuge Comprehensive Conservation Plan K-12 Appendix K. ESA Section 7 Consultation
chicks hatching or in areas where young chicks have suddenly disappeared from nests 

(Woodside 1997). Oahu Refuge staff have documented predation of waterbird chicks by cattle 

egret and black-crowned night heron (Nycticorax nycticorax). A bullfrog was documented 

predating a moorhen chick at Hanalei National Wildlife Refuge (Viernes 1995). More recently 

the Key Predators study of 2003 to 2004 on James Campbell National Wildlife Refuge provided 

the first observations of Hawaiian stilt chicks predation by bullfrogs, which accounted for 45 

percent of chick losses over study period (Eijzenga 2005). 

ENVIRONMENTAL BASELINE 

The environmental baseline describes the status of the species and factors affecting the 

environment of the species or critical habitat in the proposed action area contemporaneous with 

the consultation in process. The baseline includes State, local and private actions that affect a 

species at the time the consultation begins. Unrelated Federal actions that have already 

undergone formal or informal consultation are also a part of the environmental baseline. Federal 

actions within the action area that may benefit listed species or critical habitat are also included 

in the environmental baseline. 

Bi-monthly surveys were conducted for waterbirds within Refuge Complex units from 1989 

through 2007. Currently only monthly surveys are conducted due to staff constraints. Hawaiian 

moorhen numbers ranged from zero to 98 individuals counted in surveys from 1989 through 

2006 at the James Campbell National Wildlife Refuge - Kii unit (Table 3). However, these 

survey numbers are thought to be underestimates because of the moorhen’s cryptic behavior. 

Standard survey methods in these counts include visual and aural detection. Recent research 

conducted by David DesRochers in 2005 through 2007 has shown that passive surveys of cryptic 

waterbirds underestimate numbers of individuals present in the wetlands. Alternatively, 

broadcasting vocalizations of cryptic waterbirds to elicit responses increases detection. On 

average his research has shown, broadcasting calls increased moorhen detection by 30 percent. 

The Oahu Refuge Complex bi-monthly survey protocol was changed based on DesRochers 

research, and the Refuge Complex biologist began keeping track of banded versus unbanded 

moorhen observed during these surveys. With over 90 Hawaiian moorhen banded within the Kii 

unit, the number of banded birds versus unbanded birds detected during those surveys along with 

DesRochers research conservatively estimated the population of Hawaiian moorhen within the 

Kii unit between 100 to 150 birds. 

Hawaiian moorhen are currently not consistently present in the Pearl Harbor NWR units. There 

have been recent incursions into the Honouliuli unit over the last year (2007); however, they 

have observed consistently occupying that unit. Historically, in Refuge surveys conducted 

between 1989 and 2004, zero to five Hawaiian moorhen were detected in the Honouliuli unit and 

zero to 13 individuals in the Waiawa unit (Table 3). The last observations of Hawaiian moorhen 

consistently occupying these units was in the year 2000. Recent wetland management practices 

focusing on Hawaiian stilts at these units have not allowed the vegetation to mature to the late 

succession stage preferred by Hawaiian moorhen. Within the last year cattails (Typha latifolia) 

have been allowed to become more decadent at Honouliuli unit, which could explain the 

moorhen attempting to return. Hawaiian moorhen are still detected off Refuge in the vicinity of 

both units. 

James Campbell National Wildlife Refuge Comprehensive Conservation Plan Appendix K. ESA Section 7 Consultation K-13
Table 3. Endangered Hawaiian Moorhen Numbers Oahu National Wildlife Refuge 

Complex, Bimonthly Surveys Calendar Years 1989-2006 (Range/Average)

James Campbell National 

Wildlife Refuge Pearl Harbor National Wildlife Refuge 

Year Kii Unit Punamano Unit Honouliuli Unit Waiawa Unit 

1989 10-40/21 0-10/4 0/0 0/0 

1990 9-53/24 0-5/3 0-1/0 0/0 

1991 11-34/23 0-6/3 0/0 0/0 

1992 22-52/37 0-6/2 0/0 0-2/1 

1993 22-48/34 0-5/2 0-4/1 0-5/2 

1994 16-39/25 0-7/1 0-3/2 0-10/3 

1995 11-38/24 0-2/1 0-2/0 0-13/6 

1996 20-53/39 0-1/1 0-5/1 0-11/6 

1997 10-44/26 0-1/0 0-4/1 0-8/3 

1998 16-54/37 0-1/0 0-4/2 0-8/3 

1999 9-45/31 0-2/0 0-5/2 0-6/4 

2000 0-57/29 0-3/0 0-4/1 0-5/2 

2001 0-48/32 0/0 0/0 0/0 

2002 7-44/28 0/0 0-4/0 0/0 

2003 15-46/31 0/0 0/0 0/0 

2004 14-53/35 0/0 0/0 0-1/0 

2005 18-73/50 0-2/0 0-1/0 0/0 

2006 21-98/59 0-5/2 0/0 0/0 

Data: Oahu Refuge Complex 2007 

James Campbell National Wildlife Refuge Comprehensive Conservation Plan K-14 Appendix K. ESA Section 7 Consultation
EFFECTS OF THE ACTION 

The primary concern with regard to the implementation of this predator control program is the 

potential for the unintentional capture of Hawaiian moorhen in predator traps. However, the 

project will ultimately benefit all four of the endangered Hawaiian waterbirds by reducing 

predation. The small Indian mongoose has been implicated in at least two bird extinctions 

throughout the world where it was introduced (Hays 2007). The birds were the barred-wing rail 

(Nesoclopeus poecilopterus) and the Jamaica petrel (Pterodroma caribbaea) both ground nesters 

similar to the moorhen. Trapping will help to alleviate the threat of the mongoose to the ground 

nesting Hawaiian waterbirds within the units of the Oahu Refuge Complex. Nevertheless, 

trapping may impact Hawaiian moorhen. 

Take of Hawaiian moorhen may occur by harassment and/or injury and mortality from: 

• Capture in live traps. 

• Injury in live traps from entanglement in trap mechanism or components. 

• Injury, exhaustion or heat stress while confined within live traps. 

• Drowning in funnel live traps set for bullfrogs. 

• Predation by mammalian predators while confined within the live traps. 

No trap design is available that will preclude the capture of Hawaiian moorhen while still having 

the capability of capturing the targeted predators. 

CUMULATIVE EFFECTS 

Cumulative effects are those impacts of future State and private actions that are reasonably 

certain to occur within the area of action subject to consultation. Cumulative effects include the 

impacts of future State, tribal, local, or private actions that are reasonably certain to occur in the 

action area considered in this Biological Opinion. Future Federal actions that are unrelated to the 

proposed action are not considered in this section because they require separate consultation 

pursuant to Section 7 of the Endangered Species Act. There are no expected or known 

cumulative effects on the Refuge Complex lands since they are protected from future 

development or impacts from State and private parties. 

CONCLUSION 

After reviewing the current status of the species and critical habitats, the environmental baseline 

for Hawaiian moorhen in the action area, and the effects of predator control work at the Oahu 

National Wildlife Refuge Complex, including the cumulative effects, it is our biological opinion 

that implementation of predator control is not likely to jeopardize the continued existence of 

Hawaiian moorhen covered in this opinion. There is no designated critical habitat for Hawaiian 

waterbirds, so none will be affected. 

James Campbell National Wildlife Refuge Comprehensive Conservation Plan Appendix K. ESA Section 7 Consultation K-15
The no jeopardy conclusions are based on the following: Oahu Refuge Complexes’ conservation 

strategy is to continue implementing a predator control program that will increase the baseline 

number of individuals for the Hawaiian moorhen and all endangered waterbird species. 

INCIDENTAL TAKE STATEMENT 

Section 9 of the Act and Federal regulation pursuant to section 4(d) of the Act prohibit the take 

of endangered and threatened species, respectively, without special exemption. Take is defined 

as to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture or collect, or to attempt to 

engage in any such conduct. Harm is further defined (50 CFR 17.3) by the Service to include 

significant habitat modification or degradation that results in death or injury to listed species by 

significantly impairing essential behavioral patterns, including breeding, feeding, or sheltering. 

Harass is defined by the Service (50 CFR 17.3) as intentional or negligent actions that create the 

likelihood of injury to listed species to such an extent as to significantly disrupt normal behavior 

patterns which include, but are not limited to, breeding, feeding, or sheltering. Incidental take is 

defined as take that is incidental to, and not the purpose of, the carrying out of an otherwise 

lawful activity. Under the terms of section 7(b)(4) and section 7(o)(2), taking that is incidental to 

and not intended as part of the agency action is not considered to be prohibited taking under the 

Act provided that such taking is in compliance with the terms and conditions of this Incidental 

Take Statement. 

The measures described below are non-discretionary, and must be undertaken by the Oahu 

Refuge Complex so that they become binding conditions in order for the exemption in section 

7(o)(2) to apply. The Oahu Refuge Complex has a continuing duty to regulate the activity 

covered by this incidental take statement. If the Oahu Refuge Complex (1) fails to assume and 

implement the terms and conditions or (2) fails to require any contractors to adhere to the terms 

and conditions of the incidental take statement through enforceable terms that are added to any 

permit or contract, then the protective coverage of section 7(o)(2) may lapse. In order to monitor 

the impact of incidental take, the contractor must report the progress of the action and its impact 

on the species to the Refuge manager or Project leader as specified in the incidental take 

statement [50 CFR § 402.14(i)(3)]. 

Amount or Extent of Take 

This Biological Opinion anticipates the following forms of incidental take: 

The Oahu Refuge Complex anticipates that take will occur in the form of harassment (due to the 

potential capture in traps), and potential injury or death may result because of Oahu Refuge 

Complex’s activities described in this Biological Opinion. 

The Oahu Refuge Complex anticipates that the capture of not more than 25 Hawaiian moorhen 

and the injury or death of a Hawaiian moorhen family unit (unit equals up to two adults and four 

chicks) may occur annually for the duration of this action. 

The Oahu Refuge Complex will not refer the incidental take of any migratory bird for 

prosecution under the Migratory Bird Treaty Act of 1918, as amended (16 U.S.C. §703-712), if 

such take is in compliance with the terms and conditions specified herein. 

James Campbell National Wildlife Refuge Comprehensive Conservation Plan K-16 Appendix K. ESA Section 7 Consultation
Effect of Take

In this Biological Opinion, the Oahu Refuge Complex determined that this level of anticipated 

take is not likely to jeopardize the continued existence of the Hawaiian moorhen and no critical 

habitat has been designated for this species so no adverse modification of critical habitat is 

possible. 

Reasonable and Prudent Measures

The reasonable and prudent measures given below, with their implementing terms and 

conditions, are designed to minimize the impacts of incidental take that might otherwise result 

from the proposed actions. If, during the course of the actions, the level of incidental take is 

exceeded, the action agency is required to reinitiate consultation and review the reasonable and 

prudent measures provided in this Biological Opinion. In addition, the Oahu Refuge Complex 

must cease the activities that caused the taking; must immediately provide an explanation of the 

causes of the taking; and must review with the Refuge Manager and Refuge Complex biologist 

the need for possible modification of the reasonable and prudent measures. The Oahu Refuge 

Complex will offset unavoidable impacts through the implementation of the conservation 

measures as described in the Biological Opinion. The Oahu Refuge Complex will implement the 

conservation measures as identified in the Project Description of this Biological Opinion. 

The Oahu Refuge Complex will implement all the minimization and avoidance measures 

outlined in the Project Description. Therefore no reasonable and prudent measures are needed 

for this biological opinion. 

CONSERVATION RECOMMENDATIONS 

Section 7(a)(1) of the Endangered Species Act (Act) directs Federal agencies to utilize their 

authorities to further the purposes of the Act by carrying out conservation programs for the 

benefit of endangered and threatened species. Conservation recommendations are discretionary 

agency activities to minimize or avoid adverse effects of a proposed action on listed species or 

critical habitat, to help implement recovery plans, or to develop information. The 

recommendations provided relate only to the proposed action and do not necessarily represent 

complete fulfillment of the Oahu Refuge Complex’s Section 7(a)(1) responsibilities for the 

species. In order for the Pacific Islands Fish and Wildlife Office to be kept informed of actions 

minimizing or avoiding adverse effects or benefiting listed species or their habitats, the Pacific 

Islands Fish and Wildlife Office requests notification of the implementation of any conservation 

recommendations by Oahu Refuge Complex. 

1. The Pacific Islands Fish and Wildlife Office recommends that if Hawaiian moorhen are 

captured in live traps, attempts should be made to band individual birds. Refuge Complex 

biologist will be contacted immediately, and if available, will band the birds. Birds will be 

banded with color bands and U.S. Geological Service’s aluminum bands. Banding 

information will yield important life history information that will aid in recovery of the 

species. 

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REFRENCES 

DesRochers, David 2006. The first accurate census of the endangered Hawaiian Moorhen 

(Gallinula chloropus sandvicensis, unpublished. 

DesRochers, David W., Michael D. Silbernagle, Aaron Nadig, J. Michael Reed. 2006. 

Improving population estimates of Hawaiian Moorhen (Gallinula chloropus sandvicensis) with 

call response surveys and banding data, unpublished. 

Dibben-Young, Arleone. 2007. Draft Review of Thirty Years of Banding Hawaiian Coot and 

Hawaiian Moorhen, 1977 to 2007; report compiling available data and anecdotal information, 

unpublished. 

Eijzenga, Jaap. 2005. Draft Key Predators study of 2003 to 2004 on James Campbell National 

Wildlife Refuge, unpublished. 

Hawaii Biodiversity and Mapping Program. 2007. Formerly Hawaii Natural Heritage Program. 

Hawaii Natural Heritage Program database, unpublished, Center for Conservation Research and 

Training (CCRT), Pacific BioSciences Research Center (PBRC), University of Hawaii. 

Hays, Warren S.T., Sheila Conant. 2007. Biology and Impacts of Pacific Island Invasive 

Species. 1. A Worldwide Review of Effects of Small Indian Mongoose, Herpestes javanicus. 

Pacific Science (2007), vol. 61, no. 1:3-16. University Press, Honolulu, Hawaii. 

Smith, David G., John T. Polhemus. 2003. Habitat use and nesting activity by the Hawaiian Stilt 

(Himantopus Mexicanus Knudseni) and Hawaiian Moorhen (Gallinula Chloropus Sandvicensis) 

at the Hamakua Marsh State Wildlife Sanctuary, Kailua, Oahu. Elepaio 63(8):59-62. 

U.S. Fish and Wildlife Service. 1990. Amendment letter on Hawaiian wetland status to Dahl. 

1990, Honolulu, Hawaii. 

U.S. Fish and Wildlife Service. 2005. Draft Revised Recovery Plan for Hawaiian Waterbirds, 

Second Draft of Second Revision. U.S. Fish and Wildlife Service, Portland, Oregon. 155pp. 

U.S. Fish and Wildlife Service. 2007. Oahu Refuge Complex Waterbird Access database 

(birddate.mdb) maintained by the Refuge Complex Biologist. Occurrences, survey and banding 

data for Hawaiian waterbirds on Oahu Refuge Complex 1989 to current (banding records 1968 to 

current). 

Viernes, K.J.F. 1995. Bullfrog predation of an endangered Common Moorhen chick at Hanalei 

National Wildlife Refuge, Kauai. Elepaio 55:37. 

Woodside, David. 1997. Personal communication. U.S. Fish and Wildlife Service, Hawaii and 

Pacific Islands Complex; Honolulu, Hawaii. 

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