U.S. Department of the Interior

U.S. Fish & Wildlife Service

O‘ahu National Wildlife Refuge Complex

James Campbell National Wildlife Refuge

66-590 Kamehameha Highway, Room 2C

Hale‘iwa, Hawai‘i 96712

Phone: 808/637-6330

Fax: 808/637-3578

June 2011

Front Cover Photos

Main: ‘Alae ‘ula

©Michael Walther

Inset: ‘Ua‘u kani

©Michael Walther

Ae‘o

©Michael Walther

Honu hatchling

Mike Silbernagle, USFWS

Spring-fed Punamano ̄ wetland/George Fisher, USFWS

Ki‘i wetland and coastline/George Fisher, USFWS
Refuge Vision

The largest protected wetland in Hawai‘i, James Campbell National Wildlife Refuge adorns O‘ahu’s 

north shore, providing a haven for native Hawaiian waterbirds and migratory birds from around the 

world. The coastal dunes offer sanctuary for nesting seabirds, honu, and ‘ı ̄lio-holo-i-ka-uaua. Long-legged 

ae‘o dance on gentle breezes over the natural spring-fed Punamano ̄ as the ‘alae ‘ula build their nests in 

the native sedges below. Water ripples follow the ‘alae ke‘oke‘o and koloa maoli as they glide across the 

marsh with their broods. Visitors discover, understand, and appreciate the rare fragile environments, 

cultural resources, and open spaces. The wetland absorbs floodwaters as a natural function of a dynamic, 

healthy ecosystem. Partners, neighbors, and community work together to protect and enhance these 

unique resources.

Ka Nu‘ukia

Aia i ka hui ‘A ̄ ina Ho ‘omalu Holoholona Lo ̄hiu ‘o James Campbell i Hawai‘i ka ‘a ̄ina pa ̄lielie nui loa ma 

ka ‘ao ‘ao ‘a ̄kau ‘o O‘ahu, ko ̄kua ho ‘i ke ̄ia mau ‘a ̄ina i na ̄ manu kai Hawai‘i a me na ̄ manu ne‘ekau mai ‘o ̄ 

a ‘o ̄ o ka honua. Ko ̄kua ho ‘i a ha‘awi mai ho ‘i na ̄ pu ‘e one ma na ̄ lihi kahakai i kaianoho no na ̄ manu e 

ho‘opu ̄nana nei, na ̄ honu a me na ̄ ‘ı ̄lio-holo-i-ka-uaua. ‘Olali ho‘i na ̄ manu ae‘o wa ̄wae lo ̄‘ihi i na ̄ makani 

aheahe e puhi ma ̄lie ana ma luna o na ̄ punawai ‘o Punamano ̄ kahi a na ̄ manu ‘alae ‘ula e ku ̄kulu ana i ka ̄ 

la ̄kou mau pu ̄nana ma na ̄ mau ‘u wai ‘o ̄iwi e ulu ana ma 

na ̄ lihi wai. ‘Ale‘ale ho‘i na wai i ka pahe‘e ‘ana aku o 

ka manu ‘alae ke‘oke‘o a me ka manu koloa maoli 

ma luna o ka ili wai o na ̄ ‘a ̄ina na ̄ele me ko ̄ la ̄kou 

mau ‘o ̄hana manu. Mahalo no ho‘i na ̄ malihini 

i ka ho‘omaopopo ‘ana, ka ‘ike ‘ana i ka po ̄hea 

o na ̄ ‘a ̄ina ka ̄ka ‘ikahi, na ̄ waiwai ho‘oulu, a 

me na ̄ kula nui ‘a ̄kea o ke ̄ia mau pa ̄lielie. 

Ko ̄kua ho‘i ke ̄ia mau ‘a ̄ina a me na ̄ pa ̄lielie 

ma ke omo ‘ana i na ̄ wai ha ̄lana he nui e like 

no me kekahi mea omo wai i loa‘a maoli no ̄ 

me ke kukulu ‘ole ‘ia e kekahi, a e ‘ike pu ̄ ho‘i 

la ̄kou i na ̄ ‘a ̄ina no ̄hona holoholo ola maika‘i. 

E hana like ho‘i na ̄ hui ko ̄kua, na ̄ hoa noho, a 

me ke kaia ̄ulu ma ka ma ̄lama ‘ana i ke ̄ia mau 

kumuwaiwai nui.

‘Alae ke‘oke‘o

©Caleb Slemmons

Comprehensive Conservation 

Plans provide long-term guidance 

for management decisions and set 

forth goals, objectives, and strategies 

needed to accomplish refuge purposes 

and identify the Service’s best estimate

of future needs. These plans detail program 

planning levels that are sometimes substantially 

above current budget allocations and, as such,

are primarily for Service strategic planning and 

program prioritization purposes. The plans do not 

constitute a commitment for staffing increases, 

operational and maintenance increases, or

funding for future land acquisition.
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan 

and Environmental Assessment 

Prepared by: 

O‘ahu National Wildlife Refuge Complex 

66-590 Kamehameha Highway, Room 2C 

Hale‘iwa, Hawai‘i 96712

and 

U.S. Fish and Wildlife Service 

Pacific Islands Planning Team 

300 Ala Moana Boulevard, Room 5-231 

Honolulu, Hawai‘i 96850

June 2011 

James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Table of Contents i 

Table of Contents 

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

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

 1.1 Proposed Action ................................................................................................................... 1-2 

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

 1.3 Content and Scope of the CCP ........................................................................................... 1-3 

 1.4 Planning and Management Guidance ................................................................................ 1-4 

 1.4.1 U.S. Fish and Wildlife Service Mission ...................................................................... 1-4 

 1.4.2 National Wildlife Refuge System ............................................................................... 1-4 

 1.4.3 National Wildlife Refuge System Mission and Goals ................................................ 1-4 

 1.4.4 National Wildlife Refuge System Administration Act ............................................... 1-5 

 1.5 Relationship to Previous and Future Refuge Plans .......................................................... 1-6 

 1.5.1 Previous Plans ............................................................................................................. 1-6 

 1.5.2 Future Planning ........................................................................................................... 1-6 

 1.6 Refuge Establishment and Purposes .................................................................................. 1-7 

 1.6.1 General ........................................................................................................................ 1-7 

 1.6.2 James Campbell Establishment ................................................................................... 1-7 

 1.6.3 James Campbell Purpose ............................................................................................ 1-8 

 1.7 Refuge Goals ......................................................................................................................... 1-8 

 1.8 Relationship to Ecosystem Planning Efforts ................................................................... 1-10 

 1.9 Planning and Issue Identification ..................................................................................... 1-12 

 1.9.1 Issues to be Addressed in the Draft CCP .................................................................. 1-12 

 1.9.2 Issues Outside the Scope of the Draft CCP .............................................................. 1-12 

Chapter 2. Alternatives, Goals, Objectives, and Strategies ......................................................... 2-1 

 2.1 Introduction .......................................................................................................................... 2-1 

 2.2 Development of Alternatives ............................................................................................... 2-1 

 2.3 Alternative Components Not Considered for Detailed Analysis ..................................... 2-1 

 2.3.1 Kahuku Airfield Restoration for Private Aircraft ....................................................... 2-1 

 2.3.2 Nonlethal Techniques to Remove Mammalian Predators ........................................... 2-2 

 2.3.3 Public Trapping and Hunting to Remove Non-native Mammalian Predators ............ 2-2 

 2.4 Elements Common to All Alternatives............................................................................... 2-2 

 2.4.1 Implementation Subject to Funding Availability ........................................................ 2-2 

 2.4.2 Interagency Coordination and Collaboration .............................................................. 2-2 

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

 2.4.4 Historic and Cultural Resource Protection ................................................................. 2-3 

 2.4.5 Fire Management ........................................................................................................ 2-4 

 2.4.6 Participation in Planning and Review of Regional Development Activities .............. 2-4 

 2.4.7 Adaptive Management ................................................................................................ 2-4 

 2.4.8 Integrated Pest Management ....................................................................................... 2-5 

 2.4.9 Law Enforcement ........................................................................................................ 2-5 

 2.5 Alternative Descriptions ...................................................................................................... 2-6 

 2.5.1 Alternative A: Continue Current Management ........................................................... 2-6 

 2.5.2 Alternative B: Partial Restoration and Management of Refuge Expansion Lands ..... 2-7 

 2.5.3 Alternative C: Full Restoration and Management of Refuge Expansion Lands ......... 2-7 

 
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment

ii Table of Contents

2.6 Goals, Objectives, Strategies, and Rationale................................................................... 2-10

 2.6.1 Goal 1. Protect and manage seasonal wetland habitats to meet the life-history 

needs of endangered waterbirds to promote their recovery ..................................... 2-11

 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.................................................................................................... 2-22

 2.6.3 Goal 3. Restore and protect coastal strand/dune habitat and upland scrub/shrub to 

provide safe refuge for endangered ‘lio-holo-i-ka-uaua and threatened honu, 

as well as provide habitat for seabirds, shorebirds, and migratory birds................. 2-24

 2.6.4 Goal 4. Collect scientific information necessary to support adaptive 

management decisions ............................................................................................. 2-29

 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 Refuge System....................................................... 2-31

 2.6.6 Goal 6. Protect historic and cultural resources for the benefit of present and 

future generations..................................................................................................... 2-35

 2.6.7 Goal 7. Assist partner agencies and local community with planning and 

implementing flood damage control measures for the Town of Kahuku ................ 2-37

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

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

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

3.3 Geology and Soils............................................................................................................... 3-13

3.4 Hydrology ........................................................................................................................... 3-14

3.5 Topography/Bathymetry................................................................................................... 3-16

3.6 Environmental Contaminants .......................................................................................... 3-17

3.7 Land Use ............................................................................................................................. 3-18

 3.7.1 Historic Land Divisions............................................................................................ 3-19

 3.7.2 Ranching ................................................................................................................... 3-20

 3.7.3 Sugar, Pineapples, and Trains................................................................................... 3-20

 3.7.4 Military Use .............................................................................................................. 3-21

 3.7.5 Land Use Today........................................................................................................ 3-21

3.8 Refuge Facilities................................................................................................................. 3-22

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
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment

Table of Contents iii

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

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

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

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

 4.10.1 ‘ pae ‘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

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

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

 4.13.6 Diseases................................................................................................................... 4-26

4.14 Habitats............................................................................................................................. 4-27 

 4.14.1 Coastal Dune/Beach Strand .................................................................................... 4-27

 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 

Chapter 6. Environmental Effects Analysis .................................................................................. 6-1 

 6.1 Overview of Effects Analysis .............................................................................................. 6-1 

 6.2 Terminology ......................................................................................................................... 6-1 

6.3 Summary of Management Action Effects at the Refuge .................................................. 6-2 

6.4 Effects Analysis.................................................................................................................. 6-10 

 6.4.1 Effects of Management Actions to Protect Endangered Waterbirds........................ 6-10 

 6.4.2 Effects of Management Actions to Intensively Manage Wetland Habitat ............... 6-14 

 6.4.3 Effects of Management Actions to Restore Remnant Wetland Habitat ................... 6-20

 6.4.4 Effects of Management Actions to Restore Scrub/Shrub Habitat ............................ 6-20

 6.4.5 Effects of Management Actions on Coastal Strand/Dune Habitat............................ 6-21 

 6.4.6 Effects of Promoting Management-related Research and Scientific Assessments... 6-22
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

iv Table of Contents 

 6.4.5 Effects of Management Actions on Coastal Strand/Dune Habitat ............................ 6-21 

 6.4.6 Effects of Promoting Management-related Research and Scientific Assessments ... 6-22 

 6.4.7 Effects of Offering More Visitor Opportunities ....................................................... 6-22 

 6.4.8 Effects of Increasing Awareness, Protection, and Appreciation of Cultural and 

Historic Resources ................................................................................................... 6-24 

 6.4.9 Support Flood Damage Reduction Efforts for the Town of Kahuku ........................ 6-25 

 6.4.10 Economic Impacts ................................................................................................... 6-25 

 6.4.11 Environmental Justice ............................................................................................. 6-26 

 6.5 Global Climate Changes and Projections ........................................................................ 6-26 

 6.5.1 Climate Change in Hawai‘i ...................................................................................... 6-27 

 6.5.2 Sea Level Rise .......................................................................................................... 6-28 

 6.5.3 Climate Change Effects on Water Resources .......................................................... 6-29 

 6.5.4 Ecological Responses to Climate Change ................................................................ 6-30 

 6.6 Cumulative Effects Assessment ........................................................................................ 6-31 

Tables 

Table 2.1 Management Alternatives Summary .................................................................................. 2-8 

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 

Table 6.1 CCP Alternatives Summary of Effect to the Refuge ......................................................... 6-2 

Figures 

Figure 2-1a. Alternative A. Map (Ki‘i Unit) .................................................................................... 2-39 

Figure 2-1b. Alternative A. Map (Punamanō Unit) ........................................................................ 2-41 

Figure 2-2 Alternative B. Map ......................................................................................................... 2-43 

Figure 2-3 Alternative C. Map ......................................................................................................... 2-45 

Figure 3-1 The Main Hawaiian Islands .............................................................................................. 3-3 

Figure 3-2 Refuge Land Status and Unit Boundaries ........................................................................ 3-5

Figure 3-3 Soils .................................................................................................................................. 3-7 

Figure 3-4 Flood Zone/Hydrology ..................................................................................................... 3-9 

Figure 3-5 Historic Land Divisions ................................................................................................. 3-11 

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 

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

Appendix G: Statement of Compliance ............................................................................................ G-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, western missionaries standardized a written version of the Hawaiian language that features 8

consonants and 5 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 

Draft Comprehensive Conservation Plan and Environmental Assessment
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

USFWS

James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment

vi Readers ’ Guide 
‘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 

Draft Comprehensive Conservation Plan and Environmental Assessment

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 

Draft Comprehensive Conservation Plan and Environmental Assessment
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

Native Animals

Laura Beauregard

NOAA

Tom DeGuiar

Tom Dove

Mike Yamamoto

Readers ’ Guide ix

James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment
‘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 

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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 

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James Campbell National Wildlife Refuge 

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xii Readers ’ Guide
James Campbell National Wildlife Refuge 

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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

James Campbell National Wildlife Refuge (NWR or Refuge) is located in the Kahuku ahupua„a of 

the Ko„olauloa district on the north shore of O„ahu. Drawn to the area by the rich ocean waters and 

fertile lands dotted with natural springs, Native Hawaiians settled in Ko„olauloa around 1100 CE. 

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. 

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 „īlio-holo-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. 

IMPORTANT NOTE TO READERS

The U.S. Fish and Wildlife Service currently has an agreement with the James Campbell 

Company to purchase land from the company to expand the James Campbell NWR. At the time 

of this draft Comprehensive Conservation Plan (CCP) for the Refuge, 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 2011 or 2012, the expansion 

lands have been incorporated into this plan. All alternatives and 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.
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1.1 Proposed Action

We, the U.S. Fish and Wildlife Service (Service), manage the James Campbell NWR as part of the 

National Wildlife Refuge System (Refuge System). We propose to adopt and implement a 

Comprehensive Conservation Plan (CCP) for the Refuge. This document is the Refuge‟s Draft 

Comprehensive Conservation Plan and Environmental Assessment (CCP/EA) and includes all lands 

within the approved boundary. A CCP sets forth management guidance for a refuge for a period of 

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

668dd et seq.) as amended by the National Wildlife Refuge System Improvement Act of 1997 (Pub. 

Law 105-57) (Administration Act). The Administration Act requires CCPs to identify and describe: 

The purposes of the refuge; 

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

values found on the refuge; 

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

correct or mitigate those problems; 

Areas suitable for administrative sites or visitor facilities; and 

Opportunities for fish and wildlife-dependent recreation. 

The Refuge System planning policy (Service Manual 602 FW 3, June 21, 2000) states that the 

purpose of CCPs is to: “describe the desired future conditions of a refuge and provide long-range 

guidance and management direction to achieve refuge purposes; help fulfill the National Wildlife 

Refuge System mission; maintain and, where appropriate, restore the ecological integrity of each 

refuge and the Refuge System; . . . and meet other mandates.” 

The Service has developed and examined alternatives for managing James Campbell NWR through 

the CCP planning process. The various alternatives address the major issues and relevant mandates 

identified in the CCP process and are consistent with principles of sound fish and wildlife 

management. The Service has consolidated management options into three alternatives for James 

Campbell NWR and has identified Alternative C as the preferred alternative. The draft preferred 

alternative appears to represent the best balanced approach for achieving the Refuge‟s purposes, 

vision, and goals; contributing to the Refuge System mission; and addressing the relevant issues and 

mandates consistent with sound principles of fish and wildlife management. However, the preferred 

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

received from the public or other agencies and organizations. The Regional Director for the Service‟s 

Pacific Region will be the final decisionmaker regarding the alternative that will be adopted for 

implementation. For details on the specific components and actions comprising the range of 

alternatives, see Chapter 2. 

1.2 Purpose and Need for the CCP 

The purpose of the CCP is to provide the 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. An approved CCP will help ensure that the Service manages 

James Campbell NWR to achieve its purpose, vision, goals, and objectives, and to help fulfill the 

Refuge System mission. 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 will identify 
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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 will also evaluate priority wildlife-dependent recreational uses on the Refuge. 

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 (EE) and interpretive 

opportunities and volunteer programs, and recover endangered species populations. 

1.3 Content and Scope of the CCP 

This CCP provides guidance for managing Refuge habitats and wildlife, and administering public 

uses on Refuge lands. The James Campbell NWR Draft CCP/EA is intended to comply with the 

requirements set forth in the Administration Act and the National Environmental Policy Act (NEPA). 

Information included in the CCP includes: 

An overall vision for the Refuge, its establishment history and purpose, and its role in the 

local ecosystem (Chapter 1); 

Management alternatives, goals, and objectives for specific conservation targets and visitor 

programs, as well as strategies for achieving the objectives (Chapter 2); 

A description of the Refuge‟s physical environment (Chapter 3); 

A description of conservation targets, condition, and trends on the Refuge and within the 

local ecosystem; a presentation of the key desired ecological conditions for sustaining the 

targets; and a short analysis of the threats to each conservation target (Chapter 4); 

An overview of the Refuge‟s visitor programs and facilities, a list of desired future conditions 

for each program, and other management considerations (Chapter 5); 

An analysis of the environmental effects associated with implementing the various 

management actions prescribed under the alternatives described in Chapter 2 (Chapter 6); 

A comprehensive list of species known to occur on the Refuge or mentioned in the CCP/EA 

(Appendix A); 

Evaluations of existing and proposed appropriate public and economic uses for compatibility 

with the Refuge‟s purposes (Appendix B); 

An Implementation Plan needed to support the alternatives considered (Appendix C); 

Wilderness Review (Appendix D); 

Integrated Pest Management (Appendix E); and 

Literature Cited (Appendix F). 
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1.4 Planning and Management Guidance 

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

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

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

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

designated 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 Administration Act, the Refuge 

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

Regulations (CFR), and the Fish and Wildlife Service Manual. The Administration Act is 

implemented through regulations covering the Refuge System, published in Title 50, subchapter C of 

the Code of Federal Regulations. These regulations govern general administration of units of the 

Refuge System. 

1.4.1 U.S. Fish and Wildlife Service Mission 

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

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

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

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

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

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

programs, and helps other countries develop wildlife conservation programs. 

1.4.2 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 EE and 

interpretive activities on national wildlife refuges. 

1.4.3 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” (Administration Act). 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; 
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Develop and maintain a network of habitats for migratory birds, anadromous and 

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

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

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

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

underrepresented in existing protection efforts; 

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

(hunting, fishing, wildlife observation and photography, and EE and interpretation); and 

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

wildlife, and plants and their habitats. 

1.4.4 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 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.” 

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

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

trends of fish, wildlife, and plants on every refuge. Additionally, six wildlife-dependent recreational 

uses are granted special consideration in the 

planning, management, establishment, and expansion 

of units of the Refuge System: hunting, fishing, 

wildlife observation and photography, and EE and 

interpretation. When determined compatible on a 

refuge-specific basis, these six uses assume priority 

status among all public uses of the refuge in 

question. The overarching goal is to enhance 

wildlife-dependent recreation opportunities and 

access to quality visitor experiences on refuges, 

while managing refuges to conserve fish, wildlife, 

plants, and their habitats. The Service is directed to 

make extra efforts to facilitate wildlife-dependent 

Ae visitor opportunities. ‘o chick tests the water Laura Beauregard/USFWS
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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 purposes 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. 

1.5 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. 

1.5.1 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). 

1.5.2 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 therefore be developed for individual program areas, as needed, following 

completion of the CCP. Stepdown plans require appropriate NEPA compliance. Several stepdown 

plans (including the Visitor Services Plan, Transportation Plan, Land Protection Plan, and Inventory 

and Monitoring Plan) are appropriate to develop and/or update following CCP completion. 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 available in Appendix C. 
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1.6 Refuge Establishment and Purposes 

1.6.1 General 

The Administration Act directs the Service to manage each refuge to fulfill the mission of the Refuge 

System, as well as the specific purposes for which that refuge was established. Refuge purposes are 

the driving force in developing refuge vision statements, goals, objectives, and strategies in the CCP. 

Refuge purposes are also critical to determining the compatibility of all existing and proposed refuge 

uses. 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.

1.6.2 James Campbell NWR Establishment 

The earliest document identifying areas for 

protection and management within the James 

Campbell NWR boundary is Hawai„i‟s Endangered 

Waterbirds (U.S. Bureau of Sport Fisheries and 

Wildlife 1970*). 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” 

(U.S. Bureau of Sport Fisheries and Wildlife 1971*). 

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 

acquire and 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. 

‘Alae ‘ula Mike Silbernagle/USFWS
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1-8 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 EE 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. 

1.6.3 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 ...”. 

1.7 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. 
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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 control measures for the Town of Kahuku.
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1.8 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 
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Chapter 1. Introduction 1-11

techniques to meet the needs of resident and migratory species. Education and public outreach are 

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

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

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

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

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 
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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 

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. 

1.9 Planning and Issue Identification 

1.9.1 Issues to be Addressed in the Draft CCP

The following issues are being 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; 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. 

1.9.2 Issues Outside the Scope of the Draft 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 Refuge‟s jurisdiction, and will not be addressed in the 

CCP. 
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Chapter 2. Alternatives, Goals, Objectives, and Strategies 2-1

Chapter 2. Alternatives, Goals, Objectives, and Strategies

2.1 Introduction

The Service proposes to adopt and implement a 15-year CCP to guide the management and 

administration of the Refuge throughout the life of the CCP. This chapter presents and compares a 

range of reasonable alternatives for this proposed action, including a preferred alternative. It also 

includes information on the development of the alternatives, alternatives or components considered 

but dropped from further analysis, and elements or actions common to all alternatives. Table 1 

summarizes, compares, and contrasts the alternatives. 

2.2 Development of Alternatives

Initial alternatives were developed between fall 2009 and spring 2010 after initial scoping and public 

involvement. These alternatives are: A. Continue Current Management (no action); B. Partial 

Restoration and Management of Refuge Expansion Lands; and C. Full Restoration and Management 

of Refuge Expansion Lands (preferred alternative). The three alternatives are described in detail in 

Section 2.5. Under all alternatives, the wetlands at the Ki„i and Punamanō units are managed as core 

management areas as identified in the Recovery Plan for Hawaiian Waterbirds (USFWS 2005). 

2.3 Alternative Components Not Considered for Detailed Analysis

During scoping, public involvement, and the development of the objectives and strategies that make 

up each alternative, a variety of ideas and solutions were presented, explored, and debated. The 

following alternative components were considered but not selected for further analysis in this Draft 

CCP/EA for the reason(s) described. 

2.3.1 Kahuku Airfield Restoration for Private Aircraft

We received a suggestion that the Service should 

preserve and reopen an old asphalt runway located 

in the approved acquisition area. The commenter 

recommended the runway be made available for: 

1) an emergency landing site; 2) an auxiliary 

landing field for short-field practice; and 3) a 

recreation site for picnicking (accessible by air 

only). 

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. Refuge management plans 

Eroded runway Laura Beauregard/ USFWS
James Campbell National Wildlife Refuge 

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2-2 Chapter 2. Alternatives, Goals, Objectives, and Strategies 

include removing existing encroaching pest 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 kolea. 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. 

2.3.2 Nonlethal Techniques to Remove Mammalian Predators 

In accordance with policy 569 FW 1 (Integrated Pest Management), the Service chooses pest 

management methods by considering the following four factors (listed in their order of importance): 

human safety, environmental integrity, effectiveness, and cost. Live trapping and release of predators 

to other locations on O„ahu or the State is not a sound biological strategy. Transporting predators and 

releasing them is not cost effective and has the potential to exacerbate resource management issues at 

other Federal, State, County, and private lands. 

2.3.3 Public Trapping and Hunting to Remove Nonnative Mammalian 

Predators 

These actions are dismissed from consideration for this CCP for the following reasons: potential 

disturbance to endangered species, lower effectiveness for removal of mammals, safety of and 

potential conflicts with other Refuge users, potential conflicts with Refuge staff implementing onthe-ground management actions, and the primary mammalian predators present (mongooses and rats) 

are generally not sought after species by the general hunting public. Pigs may occur on the Refuge in 

low numbers but will be controlled by staff or contractors to avoid the conflicts described above 

associated with public hunting. 

2.4 Elements Common to All Alternatives

2.4.1 Implementation Subject to Funding Availability 

Under each alternative, actions will be implemented over a period of 15 years as funding becomes 

available. Routine maintenance, repair, replacement, and improvement of existing facilities will 

continue, also dependent on funding. 

2.4.2 Interagency Coordination and Collaboration 

Ecosystem planning efforts discussed in Chapter 1, Section 1.8 involve collaboration among Federal, 

State, and local agencies toward mutual goals. 

2.4.3 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 
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Chapter 2. Alternatives, Goals, Objectives, and Strategies 2-3

Endangered Species Act of 1973. Section 7 of the Act, 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. Consultations are either 

completed or will be conducted, as needed, concurrent with development of the CCP. The resulting 

Section 7 documents will be included as an appendix in the final CCP. 

2.4.4 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 

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. 
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2-4 Chapter 2. Alternatives, Goals, Objectives, and Strategies 

2.4.5 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/EA. 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). 

2.4.6 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. 

2.4.7 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 Department of 

the Interior (DOI) Adaptive Management Technical Guide also defines adaptive management as a 

decision process that “promotes flexible decision making that can be adjusted in the face of 

uncertainties as outcomes from management actions and other events become better understood.” 

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

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

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

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

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

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

evaluation of the CCP. 

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

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

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

working closely with partners; and engaging the public. 
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2.4.8 Integrated Pest Management 

In accordance with Department of the Interior 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 (e.g., mosquito-borne disease). For more information on 

strategies related to control of pests, see Appendix E. 

2.4.9 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 

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2-6 Chapter 2. Alternatives, Goals, Objectives, and Strategies 

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 Hawai‘i 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. 

2.5 Alternative Descriptions

These alternatives represent broad, thematic approaches to management of the Refuge, recognizing 

the latitude managers have within the framework of Refuge System laws and policy (Table 2-1). The 

alternatives reflect direction in the Administration Act, Service policy for administration and 

management of refuges, and a host of ongoing conservation initiatives affecting the Hawaiian 

Islands. The alternatives were developed to address a suite of issues, and indeed are structured to 

track the issues, challenges, and opportunities presented in Chapter 1. 

As an integrated CCP and EA, the details of the alternatives are described in terms of the main 

components of a CCP, namely measurable objectives and strategies to achieve those objectives. Most 

importantly, these alternatives are designed to help James Campbell NWR contribute to the mission 

of the Refuge System; meet the purpose for which the Refuge was established, and help achieve the 

Refuge vision, goals, and objectives. Stepdown plans for Visitor Services, Transportation, and 

Climate Change would be developed under Alternatives B and C. Except for scheduled docent tours 

by special use permits, EE program activities, and year-round access along the shoreline; the Refuge 

will be closed to general public entry until new visitor facilities are constructed and additional staff 

members are acquired to manage them. 

2.5.1 Alternative A: Continue Current Management 

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

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

part of the Statewide effort to implement the Hawaiian Waterbird Recovery Plan. Public use 

programs would remain virtually unchanged. Units would remain closed to the public except by SUP 
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Chapter 2. Alternatives, Goals, Objectives, and Strategies 2-7

issued for EE, research, wildlife observation, and wildlife photography on a case-by-case basis. 

Newly acquired expansion lands would receive custodial oversight only, no habitat restoration and 

no additional visitor services. Both current aquaculture leases will remain in effect until 2023 at 

which time, by prior agreement, they will expire. 

2.5.2 Alternative B: Partial Restoration and Management of Refuge 

Expansion Lands 

In addition to waterbird management actions identified in Alternative A, highest priority wetlands 

and coastal dunes on expansion lands would be restored and fenced to exclude large predators. By 

2016, a Visitor Services Plan (VSP) would be developed to address a variety of wildlife-related 

public use activities. This plan will identify, evaluate, and carefully select sites and locations for 

infrastructure needed to fully implement a safe and meaningful program for the public. Infrastructure 

needs identified by the plan would include safe and compatible roads, parking areas, trails, overlook, 

etc. The VSP will identify new special regulations that may be needed to protect sensitive wildlife 

resources, the fragile coastline, and the visiting public. Other considerations include: 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 while enhancing or protecting 

valuable natural resources on the Refuge; and both current aquaculture leases will remain in effect 

until 2023 at which time, by prior agreement, they will expire. 

2.5.3 Alternative C: Full Restoration and Management of Refuge Expansion 

Lands 

In addition to all of the management actions identified in Alternatives A and B, all wetlands, coastal 

dunes/strand and scrub/shrub habitats would be restored and managed. Trial use of predator-proof 

fencing would be initiated on selected dune or wetland sites to protect nesting seabirds and 

waterbirds. Abandoned aquaculture facilities would be cleaned up and remnant wetland habitat 

would be restored to natural conditions or other approved uses. 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. 

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. The Refuge is 

considered by many to be one of the best areas in Hawai„i to view endangered waterbirds. Highquality wildlife viewing will continue and be expanded on the Refuge through the development and 

maintenance of trails, boardwalks, and observation sites. 
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2-8 Chapter 2. Alternatives, Goals, Objectives, and Strategies 

Table 2.1 

James Campbell NWR Management Alternatives Summary

Key Themes Objectives Alt A Alt B Alt C HABITATS

Intensively 

Managed

Wetland 

Habitat

1.1 Ae„o loafing 

& foraging

50-75 ac 50-75 ac 90-115 ac

1.2 Ae„o breeding 20 ac 20 ac 20 ac

1.3 „Alae 

ke„oke„o & „alae 

„ula loafing & 

foraging

30-40 ac 30-40 ac <59 ac

1.4 „Alae 

ke„oke„o & „alae 

„ula breeding

15-20 ac 15-20 ac <30 ac

Natural

Wetland 

Habitat

1.5 „Alae 

ke„oke„o & „alae 

„ula life-history

18-25 ac 25-32 ac 32-51 ac

Remnant

Wetland

Habitat

1.6 Waterbirds & 

migratory birds

0 ac 10-25 ac 25-67 ac

Coastal 

Strand

Dune 

Habitat 

3.1 Restore, 

protect, and 

manage 

 

0 ac

 

50-100 ac

 

100-185 ac

3.2 Improve 

seabird nesting 

site on runway

0 ac <10 ac 20-28 ac

Scrub / 

Shrub 

Habitat

2.3 Restore 

scrub/shrub

0 ac <20 ac <312 ac

Expansion 

Lands

2.1 Complete 

Land Acquisition

✓ ✓ ✓

2.2 Plan & 

Construct Refuge 

Facilities

Develop site 

plans; 

Design/build new 

HQ/VC/EE

facility

Design/build new 

HQ/VC/EE facility, 

maintenance shop, 

bunkhouse & 

greenhouse 
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Chapter 2. Alternatives, Goals, Objectives, and Strategies 2-9

Management Alternatives Summary (continued)

Key Themes Objectives Alt A Alt B Alt C

Scientific 

Data

4.1 Conduct 

inventory and 

monitoring

Monitor 

impacts of pest 

plants &

animals; and 

movements of

endangered 

waterbirds

Track nesting 

success; impacts 

of pest plants &

animals; and 

movements of 

endangered 

waterbirds

Track nesting success; 

impacts of pest plants & 

animals; and 

movements of 

endangered waterbirds

with GIS data layer

development.

Initiate data collection 

volunteer program (i.e.,

bird surveys)

4.2 Facilitate 

research & 

scientific 

assessments

Establish research 

partnerships

Form research 

partnerships; and 

develop climate change 

assessment protocols

Visitor 

Services

5.1 Provide EE EE is provided 

by SUP for 

1,500 students 

3,000 students

or up to 6,000 

students with 

construction & 

staffing of EE 

facility

Up to 6,000 students

with construction &

staffing of EE facility

5.2 Offer new 

visitor 

opportunities, 

primarily wildlife 

observation and 

photography

Maintain 

current level; 

500-800

visitors 

annually

5,000 visitors 

annually along 

coastline and 

Ki„i; and up to 

210,000 w/ 

construction & 

staffing of VC

5,000 visitors annually 

along coastline and 

Ki„i; and 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

Consult Native 

Hawaiian & 

historical 

societies to 

develop 

interpretive 

materials; 

NAGPRA 

training for staff

Consult Native 

Hawaiian & historical 

societies to develop 

interpretive materials; 

NAGPRA training for 

staff; 

Develop GIS layer for 

avoidance of known 

sites

Flood 

Damage 

Reduction

for the Town 

of Kahuku

7.1 Support 

feasible flood 

reduction efforts 

for Kahuku

Cooperate in 

planning 

process

Cooperate in 

planning process; 

maintain 

Walkerville Unit 

as potential flood 

reduction project 

area

Cooperate in planning 

process; maintain 

Walkerville Unit as 

potential flood 

reduction project area
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2.6 Goals, Objectives, Strategies, and Rationale

Goals and objectives are the unifying elements for successful, adaptive refuge management. They 

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

and the Refuge System mission. 

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

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

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

by objectives that direct effort into incremental and measurable steps toward achieving those goals. 

Finally, strategies identify specific tools and actions to accomplish objectives. Unless specifically 

stated, all objectives are applicable throughout the life of this plan. 

In the development of this Draft CCP, the Service has prepared an effects analysis (Chapter 6) for 

each of the alternative sets of management actions derived from management goals, objectives, and 

implementation strategies. The goals for the James Campbell NWR are presented on the following 

pages. Each goal is followed by one or more objectives that pertain to it. The goal order does not 

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

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

for clarity these strategies are listed under each relevant objective. Following the goals, objectives, 

and strategies, a brief rationale is provided. This rationale generally describes how management 

strategies will be implemented to achieve the intended objectives. The rationale may also, where 

necessary, discuss means to minimize potential impacts to nontarget species and habitats. It also 

provides further background information pertaining to the importance of an objective relative to 

legal mandates for managing units of the Refuge System, including refuge purpose, trust resource 

responsibilities (federally listed threatened and endangered species and migratory birds), and 

maintaining/restoring biological integrity, diversity, and environmental health. 

A honu hatchling scoots its way to the sea Mike Silbernagle/USFWS
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2.6.1 Goal 1. Protect and manage seasonal wetland habitats to meet the lifehistory 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„iUnit 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, California 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 Alt A Alt B Alt C

Total acreage meeting objective characteristics 50-75 50-75 90-115

Drawdown in specified impoundments from approximately MarchJuly (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 Monthly Monthly 3 X

Monthly

Eliminate pest roost trees for cattle egrets ✓

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 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 
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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.

For more information on strategies related to control of pests, see Appendix E.

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„iUnit 

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 5 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 Alt A Alt B Alt C

Total acreage meeting objective characteristics 20 20 20

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)

✓ ✓ ✓

Pulsing water to promote invertebrates for broods Twice 

Monthly

Twice 

Monthly Weekly

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

stations 

✓ ✓ ✓

Control pest plants using: herbicide application, prescribed fire, 

mowing, rototilling, 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 ✓
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Rationale: Breeding ae„o require dry to unsaturated mudflat habitat for building nests. Pre-breeding 

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„owith 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.

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

mongooses, bullfrogs, dogs, cats, cattle egrets, and „auku„u. It is critical to control predators during 

the nesting season, thereby increasing nesting and fledging success. 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 1.3. 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„iwith 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 5 individual „alae ke„oke„o and 1 „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.
James Campbell National Wildlife Refuge 

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2-14 Chapter 2. Alternatives, Goals, Objectives, and Strategies 

Strategies Applied to Achieve Objective Alt A Alt B Alt C

Total acreage meeting objective characteristics 30-40 30-40 <59

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) ✓ ✓ ✓

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

Monitor predator abundance to evaluate effectiveness of predator 

control efforts

✓

Control pest plants using: herbicide application, prescribed fire, 

mowing, rototilling, disking, and brush cutting ✓ ✓ ✓

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.

On the Ki„iUnit, grass covered dikes are important habitat for „alae ke„oke„o and „alae „ula, as well 

as other species such as kioea. One wide dike is utilized by many species and is known as the C/F 

Dike. Mowing of this dike to maintain a grass height of less than 4 inches provides foraging areas 

where „alae ke„oke„o and „alae „ula can graze on short grass and feed on associated invertebrates. 
James Campbell National Wildlife Refuge 

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Chapter 2. Alternatives, Goals, Objectives, and Strategies 2-15

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„iwith 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 5 individual „alae ke„oke„o and 1 „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 Alt A Alt B Alt C

Total acreage meeting objective characteristics 15-20 15-20 <30

Extended hydro-period to promote epiphytic invertebrates ✓ ✓ ✓

Flood to sufficiently inundate emergent vegetation ✓ ✓ ✓

Slow drawdown rate (control fish and promote invertebrates/algal 

growth, plant response) ✓ ✓ ✓

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.
James Campbell National Wildlife Refuge 

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2-16 Chapter 2. Alternatives, Goals, Objectives, and Strategies 

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. Botulism is a concern so evidence of botulism 

poisoning is closely monitored for during decomposition.

„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.

Habitat manipulation Mike Silbernagle/USFWS
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 2. Alternatives, Goals, Objectives, and Strategies 2-17

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 5 individual „alae ke„oke„o and 1 „alae „ula per year.

Strategies Applied to Achieve Objective Alt A Alt B Alt C

Total acreage meeting objective characteristics 18-25 25-32 32-51

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 

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. 
James Campbell National Wildlife Refuge 

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2-18 Chapter 2. Alternatives, Goals, Objectives, and Strategies 

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 5 ae„o per year; and

Limited/controlled public use to minimize disturbance.

Strategies Applied to Achieve Objective Alt A Alt B Alt C

Total acreage meeting objective characteristics 0 10-25 25-67

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 ✓

Rationale: Unmanaged semi-permanent and temporary wetlands within the approved acquisition 

boundary provide habitat for a variety of species. Natural weather patterns, subsurface ground water 

movement, and small surface ditches control the hydrology of the unit. No active water management 

or water management facilities (e.g., pumps and water control structures) currently exist for the 

purpose of managing these wetlands. Once acquired, Service management will mostly involve 
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 2. Alternatives, Goals, Objectives, and Strategies 2-19

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.

Water levels, timing, and duration cannot be controlled as on Ki„i; where water control structures; 

dedicated water supply; bottom topography; and confined impoundments allow detailed and specific 

water regimes to be established and maintained. 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. Many areas will not be enhanced 

because of the inaccessibility to equipment.

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.

There will be less of a mosaic of open water and vegetation to provide thermoregulation during 

inclement weather. Mowing, prescribed fire, herbicide application, disking, and rototilling to open 

Batis, California grass, marsh fleabane, Christmas berry, and koa haole dominated areas to create the 

mosaic of vegetation, open water, and mudflats will be retained as management tools, but suitable 

areas for implementing one or more of these techniques will be greatly reduced under this objective 

because of access restrictions and the inability to effectively manage water.

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. 

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

Draft Comprehensive Conservation Plan and Environmental Assessment 

2-20 Chapter 2. Alternatives, Goals, Objectives, and Strategies 

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 Alt A Alt B Alt C

Total acreage meeting objective characteristics 0 <242 <242

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 using: herbicide application, prescribed fire, 

mowing, rototilling, disking, and brush cutting ✓ ✓

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 they 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.
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Chapter 2. Alternatives, Goals, Objectives, and Strategies 2-21

Objective 1.8. Provide wetland habitats to meet the life-history needs of koloa maoli.

Enhance, protect and manage up to 50 ac. 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;

Protected near water nest sites;

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 Alt A Alt B Alt C

Total acreage meeting objective characteristics 0-5 10-15 15-25

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 Monthly Monthly 3x 

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, 3 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; 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).
James Campbell National Wildlife Refuge 

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2-22 Chapter 2. Alternatives, Goals, Objectives, and Strategies 

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 Alt A Alt B Alt C

Continue coordination with Regional Office and Washington Office

staff for logistical support to land acquisition

✓ ✓ ✓

Continue close coordination/cooperation with James Campbell 

Company to complete terms of purchase agreement

✓ ✓ ✓

Closely monitor transfer of State Water Use Permit to meet time 

restrictions for administrative transfer

✓ ✓ ✓

Continue to 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 ensure compatibility of uses

✓

Rationale: The James Campbell National Wildlife Refuge Expansion Act of 2005 authorizes the 

expansion of the existing Refuge by 800 ac for a total of 1,100 ac within the approved Refuge 

boundary. 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 April 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 Refuge purposes and ensure 

compatibility of uses. 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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 2. Alternatives, Goals, Objectives, and Strategies 2-23

In addition to lands currently planned for acquisition under the purchase agreement with James 

Campbell Company, 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 Alt A Alt B Alt C

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 ✓

Continue discussion with NOAA / non-government organizations 

about potential „īlio-holo-i-ka-uaua rehabilitation facility ✓

Rationale: Acquisition of the expansion lands will provide new opportunities to develop major new 

Refuge facilities that will benefit the public and staff. Sites on these lands may be suitable for 

construction of a headquarters, visitor center, and EE facility (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, the 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 new 

HQ/VC/EE constructed on the James Campbell 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.
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

2-24 Chapter 2. Alternatives, Goals, Objectives, and Strategies 

The current location of the Complex maintenance facility is undersized and is exposed to harsh 

marine coastal winds that are highly corrosive to equipment and buildings due to salt spray. When 

fully acquired, sites on the Refuge 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. 

Leadership in Energy & Environmental Design is an internationally recognized green building 

certification system, providing third-party verification that a building or community was designed 

and built using strategies intended 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.

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 ac. of terrestrial habitat consisting of 

approximately 140 ac. of coastal dune/strand, up to 60 ac. of adjacent coastal scrub/shrub and 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 Alt A Alt B Alt C

Total acreage meeting objective characteristics 0 50-100 100-185

Remove marine debris ✓ ✓ ✓

Periodic mowing and brush-cutting to allow for breeze flow and 

pathways from the beach or dune crest where seabirds like to launch 

to nest sites further inland 

✓ ✓
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Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 2. Alternatives, Goals, Objectives, and Strategies 2-25

Strategies Applied to Achieve Objective Alt A Alt B Alt C

Propagation and planting of native plant species ✓

Control pest plants using IPM appropriate techniques, including 

herbicide application, prescribed fire, mechanical removal, brush 

cutting, and hand pulling 

✓ ✓

Predator control methods for pigs, cats, and dogs include trapping, 

fencing, and shooting ✓ ✓

Support volunteers and organizations such as Malama na 

Honu (Protect the Turtles) and O„ahu Monk Seal Response Team 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 the 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-holoi-ka-uaua

✓ ✓

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 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 seabirds 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 
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

2-26 Chapter 2. Alternatives, Goals, Objectives, and Strategies 

crustaceans. Beach clean-ups at the Refuge are scheduled 2 to 4 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.

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.

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.

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 

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.
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 2. Alternatives, Goals, Objectives, and Strategies 2-27

Objective 3.2. Improve potential seabird nesting site on abandoned Kahuku airfield 

runway.

Restore, manage, and protect approximately 28 ac. 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 Alt A Alt B Alt C

Total acreage meeting objective characteristics 0 <10 20-28

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 the 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 

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 
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

2-28 Chapter 2. Alternatives, Goals, Objectives, and Strategies 

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. 

Objective 3.3. Restore scrub/shrub habitat within expanded boundary.

Develop restoration plans for up to 312 ac. 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 Alt A Alt B Alt C

Total acreage meeting objective characteristics 0 <20 <312

Conduct surveys and studies to determine desirable native vegetation 

community based on local site conditions including soil type, 

elevation, ground water table and proximity to shore

✓ ✓

Use IPM techniques to control/eradicate pest plants ✓ ✓

Mōlī pair watches over chick USFWS
James Campbell National Wildlife Refuge 

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Chapter 2. Alternatives, Goals, Objectives, and Strategies 2-29

Strategies Applied to Achieve Objective Alt A Alt B Alt C

Work with the Bishop Museum and other potential 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 a 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. Specifically, they can be used to evaluate 

achievement of resource management objectives identified in this CCP. These surveys have the 

following attributes: 

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

to minimal habitat destruction;

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

macroinvertebrates, vertebrates) to meet statistical analysis requirements for identification and/or 

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

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

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

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

applicable.
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2-30 Chapter 2. Alternatives, Goals, Objectives, and Strategies 

Strategies Applied to Achieve Objective Alt A Alt B Alt C

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 

(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 ✓ ✓ ✓

Investigate movements of endangered waterbirds (e.g., inter- and intraisland 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 

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, 
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 2. Alternatives, Goals, Objectives, and Strategies 2-31

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.

During the period 2018 to 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 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 Alt A Alt B Alt C

Annual Student Participation 1,500 2000-

4,000

<6,000

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

✓ ✓

Continue current seasonal program (October 15-February 28) at Ki„i 

Unit 

✓ ✓
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Strategies Applied to Achieve Objective Alt A Alt B Alt C

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„iUnit) 

✓ ✓

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 decisionmaking skills. Environmental education 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;

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 

year-round 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. Construction 

of a HQ/VC/EE facility is proposed in the vicinity of Marconi Road and Kamehameha Highway.

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
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Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 2. Alternatives, Goals, Objectives, and Strategies 2-33

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 HQ/VC/EE facility is funded and 

constructed. 

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 Alt A Alt B Alt C

Total Annual Refuge Visitors 800 <210,000 <210,000

All Refuge units remain closed to the general public ✓

Maintain existing signs and interpretive material ✓

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 „īlioholo-i-ka-uaua and honu closure information in cooperation with 

other agencies (NOAA and State)

✓ ✓

Increase law enforcement presence ✓ ✓

Develop new interpretative materials (brochures, kiosk panels, 

species lists) ✓ ✓

Ki‘i kiosk Laura Beauregard/USFWS
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

2-34 Chapter 2. Alternatives, Goals, Objectives, and Strategies 

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). The up to 210,000 visitors estimate is based on having a visitor center with associated 

staffing. 

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„iwetlands are conducted only during the ae„o 

nonbreeding season (October to 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. 
James Campbell National Wildlife Refuge 

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Chapter 2. Alternatives, Goals, Objectives, and Strategies 2-35

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 Alt A Alt B Alt C

Comply with Section 106 of the National Historic Preservation Act 

(NHPA) when conducting ground-disturbing 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 Native American cultural items (human remains, funerary 

objects, sacred objects, and objects of cultural patrimony) removed from Federal lands to lineal 

descendants, Indian tribes, and 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 
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

2-36 Chapter 2. Alternatives, Goals, Objectives, and Strategies 

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 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 2. Alternatives, Goals, Objectives, and Strategies 2-37

2.6.7 Goal 7. Assist partner agencies and local community with planning and 

implementing flood damage control 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 control projects.

Strategies Applied to Achieve Objective Alt A Alt B Alt C

Cooperate in planning process for future proposed flood control 

project(s) that may utilize portions of Refuge expansion lands ✓ ✓ ✓

Maintain 73-ac. Walkerville Unit (when fully acquired) as potential 

flood damage reduction project area by:

Periodic disking or mowing to prevent further encroachment 

by woody vegetation and allow more free-flowing water; 

Removing existing encroaching woody vegetation, as feasible;

Participating in community and government planning efforts 

to reduce flood damages in Kahuku; and

Continuing to regularly maintain Refuge ditches.

✓ ✓

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 proposed Walkerville Unit is well suited for potential flood mitigation projects because of its 

proximity to Kahuku and major drainage ditches, its relatively low-lying elevation and lower 

overall potential wildlife value than other Refuge expansion lands. This area is comprised 

primarily of former agricultural lands that have been unused 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 is intended only as an interim measure until final 

decisions regarding such projects are made. Also, other adjoining Refuge expansion lands 

(primarily makai) may still also be considered in future flood mitigation projects and are not 

excluded. All potential projects would be subject to full engineering, environmental, and 

regulatory evaluations and compliance. 

[Note to readers: As of June 2011, the parcel of land containing this proposed unit has not been 

acquired by the Service.]
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Highway

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Figure 2-1a. James Campbell NWR

Alternative A 

Habitat Management

Ki'i Unit

Ae'o Loafing & Foraging

Ae'o, 'Alaeke'oke'o, & 'Alae'ula

Loafing & Foraging - Dikes

'Alaeke'oke'o & 'Alae'ula

Loafing & Foraging

'Alaeke'oke'o & 'Alae'ula

Breeding

Ae'o Breeding

Approved Acquisition

Boundary

Intensively Managed 

Wetland Boundary

0 100 200

Meters

0 400 800

Feet

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Figure

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21°42'0"N

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Figure 2-1b. James Campbell NWR

Alternative A 

Habitat Management

Punamano Unit

Ae'o & Alae'ula 

Foraging - Grasslands

'Alaeke'oke'o & 'Alae'ula 

Breeding & Foraging - 

Open Water

NAWCA Bullrush Removal

Area

Restoration Area -

Mowed Grassland

Approved Acquisition

Boundary

0 100 200

Meters

0 400 800

Feet

UTM 4

NAD 83

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Figure

2-1b

P a c i f i c O c e a n

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Figure 2-2. James Campbell NWR

Alternative B

Habitat Management

0 250 500

Meters

0 1,000 2,000

Feet

UTM 4

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Figure

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Intensively Managed 

Wetland

Ae'o, 'Alaeke'oke'o, & 'Alae'ula

Loafing & Foraging - Dikes

'Alaeke'oke'o & 'Alae'ula 

Life History

Restore & Manage Altered 

Wetlands

Restore, Protect, Manage 

Coastal Strand & Dunes

Improve Seabird Nesting on 

Kahuku WWII Runway

Restore Schrub / Shrub

Support Flood Damage 

Reduction Efforts

(Walkerville Unit)

Approved Acquisition

Boundary

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Figure 2-3. James Campbell NWR

Alternative C

Habitat Management

0 250 500

Meters

0 1,000 2,000

Feet

UTM 4

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Figure

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Intensively Managed 

Wetland

Ae'o, 'Alaeke'oke'o, & 'Alae'ula 

Loafing & Foraging - Dikes

'Alaeke'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

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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 (Figure 3-1). 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 March 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 to 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 to 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 to 80 percent of the time) and a greater chance of storms (Lau and 

Mink 2006). 

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 
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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 to April, to about 81°F 

between August and 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 to 80.8°F. Annual 

precipitation in James Campbell NWR is between 26 and 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 to 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
Hawaii

Kailua-Kona

Mauna Kea

Mauna Loa

A l e n u i h a h a C h a n n e l

Maui

Kahoolawe

Lanai

Molokai

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Honolulu

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Figure 3-1. Jame

Kahuku

Honolulu

Oahu Forest

NWR

James Campbell

NWR

Pearl Harbor

NWR

Oahu National Wildlife 

Refuge Complex 

Headquarters

Ewa

Laie

Waimea

Kahana

Haleiwa Waialua

Waianae

Kahaluu

Nanakuli

Waimanalo 

Beach

The M

Hawaiia

Island

of

Oahu

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Figure 3-2. Jame

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Figure 3-3. Jame

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Kaunala

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Paumalu

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Hanaka'oe

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Ulupehupehu

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Figure 3-5. Jame

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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 and encompasses 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 to 

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, referred to as 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). 

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). 
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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 

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 (FIRM) 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 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 3. Physical Environment 3-15

volcanic-rock aquifers into the overlying sedimentary deposits and eventually discharges to the 

ocean. Flow to the ocean is estimated from 2-4 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 3.6). Pond water levels generally 

average between 3-4.5 feet. The most seaward ponds (Ponds A and E) typically maintain lower water 

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 and 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 three 3-inch diameter artesian wells, which piped water into 

the seven 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 3-6. 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 PCB concentrations. A followup Level 1 Preacquisition Contaminant Survey was 

subsequently performed in 1998 to characterize the PCB contamination. 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 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 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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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. As previously described, copper and also zinc are naturally abundant in Hawaiian volcanic 

soils and the detected concentrations were similar to concentrations found in other areas of O„ahu 

(Hunt and De Carlo 2000). 

3.7 Land Use

This section presents an overview of land uses within and adjacent to James Campbell NWR that 

have the potential to influence Refuge conditions. Relevant local and regional land use policies 

affecting land use are also discussed. 

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. 
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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 ultimately 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), 

usually wedge-shaped and running from the mountain crest to shore. O„ahu was divided into six 

moku. Each moku was divided into smaller units known as ahupua„a. Shaped by 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 3-5). 

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 Gordon Hopkins purchased over 

8,000 acres of Hawaiian lands, some from Moffitt and some in Mālaekahana from A. Keohakalole, 

and founded Kahuku Ranch, a cattle and sheep ranch. 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 L. Richardson, and in 1876, Richardson sold the ranch to James 

Campbell (Wilcox 1975). 
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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 better facilitate the 

transport of 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. Irrigation for the crops was acquired through existing 

groundwater sources, streams, and pumped spring water; these sources eventually proved inadequate 

and artesian wells became the primary irrigation source. 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 provided O„ahu residents with a passenger train service 

that remained in operation for 58 years. The Kahuku Plantation Co. began leasing land to individual 

pineapple growers during the mid-1900s. Similarly, the O„ahu Railway & Land Co. leased land to 

individuals for pineapple cultivation. 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 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 

Kahuku Plantation Co. #1 c. 1946

Bishop Museum Collection
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Chapter 3. Physical Environment 3-21

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). 

The Kahuku Training Area is situated south 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. These pursuits are situated on previously 

cultivated cane lands and constitute expansive modifications. Hotel and golf course developments 

located on the coastal plain represent considerable land modifications of relatively large, contiguous 

areas. These large development activities combined with relatively smaller project 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. 

Romy's Kahuku Prawns & Shrimp 

Laura Beauregard/USFWS
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3-22 Chapter 3. Physical Environment 

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 base yard 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 one 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. 
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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. Background information includes a description, 

location, condition, and the trends associated with wildlife or habitats, key ecological attributes, and 

stresses and sources of stress (collectively, “threats”) to the target. 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 biological integrity, diversity, and environmental health. 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 
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4-2 Chapter 4. Refuge Biology and Habitat

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, below. 

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, 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 
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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, 

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, 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
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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
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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 historic 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 

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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. Interisland 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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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„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 year 

round 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 

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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 and 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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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 

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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 to 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

‘Auku‘u looks for prey Laura Beauregard/USFWS
James Campbell National Wildlife Refuge 

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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 to 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 

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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 

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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, 

although fossil evidence indicates that at least one other bat species 

was native to the islands. 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 a variety of night-flying insects, 

including moths, beetles, crickets, mosquitoes, and termites. They 

have been documented near the Refuge. Water courses and edges 

(e.g., coastlines and forest/pasture boundaries) appear to be 

important foraging areas; the species 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. Mating occurs 

in the spring and early summer. 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. Juveniles feed on a higher proportion of 

nocturnal fish species. 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. 

‘Ōpe‘ape‘a Dan Clark/USFWS

‘Īlio-holo-i-ka-uaua rests on beach 

© Jim Collin/ AP
James Campbell National Wildlife Refuge 

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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. 

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; 

Honu basking on the shore Laura Beauregard/USFWS
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Refuge Biology and Habitat 4-15

feeding primarily on select macroalgae and sea grasses. The common name “green sea turtle” is 

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 approximately100 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).

Conflicts and interactions with a variety of ocean and beach users are becoming more frequent and 

significant in the main Hawaiian Islands. Human disturbance to adults coming to shore to lay eggs 

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 by Refuge personnel did not occur. Some 

information gathered by NOAA indicates historic use of the area. 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 insuitable 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). 
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4-16 Chapter 4. Refuge Biology and Habitat

‘Ilima 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). 

Flowers and fruit of naupaka kahakai 

Laura Beauregard/USFWS
James Campbell National Wildlife Refuge 

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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 (Pattison et al. 1998, Ikuma et al. 2002, Middleton 2006). 

Hala grove Laura Beauregard/USFWS
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-18 Chapter 4. Refuge Biology and Habitat

4.13.1 Mammals 

4.13.1.1 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. 

4.13.1.2 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, 

mammals, amphibians, crabs, plants, and birds. In Hawai„i, mongooses are diurnal predators that 

Mongoose on the prowl © Chuck Babbitt

Black rat © Jack Jeffrey
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Refuge Biology and Habitat 4-19

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. 

4.13.1.3 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). 

4.13.1.4 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 

environments 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) 

Neutered and released cat with ‘alae ‘ula 

© Michael Walther

Pigs at Punamanō Mike Sibernagle/USFWS
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-20 Chapter 4. Refuge Biology and Habitat

4.13.1.5 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 would be implemented (Brisbin et al. 2002, Engilis et al. 2002, Hawaii Audubon Society 2005). 

Dogs running through Ki‘i Unit 

Mike Silbernagle/USFWS

Cattle egret © Michael Walther
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Refuge Biology and Habitat 4-21

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. 

4.13.3.1 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). 

4.13.3.2 North American bullfrog (Rana catesbeiana) 

North American bullfrogs were brought to Hawai„i in the late 1800s. They now occur on six of the 

main Hawaiian Islands, including the Refuge, where they have been identified as a major predator of 

ae„o chicks. They also prey on chicks of other endangered waterbirds. Nocturnal predators, they will 

ambush and eat just about anything they can fit in their ample mouths, including 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 hind feet 

are completely webbed except for the last joint of 

the largest toe. The bullfrog‟s call is a deep “jug-orum” or “br-wum” 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). 

Cane toad Laura Beauregard/USFWS

North American bullfrog Mike Silbernagle/USFWS
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-22 Chapter 4. Refuge Biology and Habitat

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). 

4.13.4.1 Apple snails (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 for their potential human food resource. All four species 

have a similar appearance making the species difficult to distinguish. The Pomacea species in 

Hawai„i are 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. Plant 

consumption causes shifts in ecosystem conditions and function. During feeding, P. canaliculata

may consume most of the plant or make cuts, causing damaged plants to be highly susceptible to 

disease. It is unknown to what extent apple snails impact natural wetland vegetation in Hawai„i. 

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). 

4.13.4.2 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 
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Refuge Biology and Habitat 4-23

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: 

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. 

4.13.5.1 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). 

California grass Mike Silbernagle/USFWS
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

4-24 Chapter 4. Refuge Biology and Habitat

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 (Appendix F). 

4.13.5.2 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). 

4.13.5.3 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). 

Khaki weed Mike Silbernagle/USFWS

Pluchea indica Mike Silbernagle/USFWS
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Refuge Biology and Habitat 4-25

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. 

4.13.5.4 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. 

4.13.5.5 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 (Appendix 

E).

Silverhead pest plant Mike Silbernagle/USFWS

California bulrush at Punamanō Mike Silbernagle/USFWS
James Campbell National Wildlife Refuge 

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4-26 Chapter 4. Refuge Biology and Habitat

4.13.6 Diseases 

4.13.6.1 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). 

4.13.6.2 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. 

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. 
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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 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 

Beach strand Laura Beauregard/USFWS
James Campbell National Wildlife Refuge 

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4-28 Chapter 4. Refuge Biology and Habitat

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. 

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). 

Punamanō wetland George Fisher/USFWS
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 4. Refuge Biology and Habitat 4-29

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. 

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). 

Exposed coral shelf Mike Silbernagle/USFWS
James Campbell National Wildlife Refuge 

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4-30 Chapter 4. Refuge Biology and Habitat

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, other flightless birds (now 

extinct). Hawaiian dry forests have been reduced by 90 percent. Land utilization by the early 

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. 

Scrub/shrub habitat Mike Silbernagle/USFWS
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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). 
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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. 

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 
James Campbell National Wildlife Refuge 

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Chapter 5. Outdoor Recreation, Social, and Economic Factors 5-3 

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 Refuge Manager or by 

participating in scheduled tours. Guided tours by volunteer docents or knowledgeable birders occur 

on Thursdays and Saturdays by reservation only. 

Rough north shore surf Laura Beauregard/USFWS

Wildlife viewing at the Refuge © ucdavis.edu
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

5-4 Chapter 5. Outdoor Recreation, Social, and Economic Factors 

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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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). 
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5.2.3 Economy 

Hawai„i ‟s economy grew at an annual rate of 4.1percent between 2001 and 2006. Including the 

economic recession of 2008 and 2009, the economic growth rate in Hawai„i between 2000 and 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 United States (U.S.); 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 grantsin-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 
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Chapter 5. Outdoor Recreation, Social, and Economic Factors 5-7 

the year 2011. The jump in production expenditures is being driven by ten motion pictures as well as 

the final season of TV‟s “Lost” and the start of two network shows, “Hawai„i Five-0” and “Off the 

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 United States via the Panama Canal, and others from 

western Pacific ports. Around-the-world passenger ships carry visitors through Honolulu, and there is 

an interisland 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. 
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James Campbell National Wildlife Refuge 

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Chapter 6. Environmental Effects Analysis 6-1 

Chapter 6. Environmental Effects Analysis 

6.1 Overview of Effects Analysis

This effects analysis was developed by identifying resources associated with the physical, biological, 

and human environment identified in Chapters 3-5 of the Draft CCP/EA that may be impacted by the 

various alternative strategies presented in Chapter 2. The potential effects to those resources as a 

result of implementing the strategies described under each alternative were then assessed. This 

includes a brief discussion on potential impacts of climate change to Refuge resources. 

The information used in this Draft CCP/EA was obtained from relevant scientific literature, existing 

databases and inventories, consultations with other professionals, professional knowledge of 

resources based on field visits, and personal experience. Subheadings have been included to guide 

the reader in understanding which types of management strategies are likely to affect each resource 

as not all management strategies affect each resource. 

Cumulative impacts, including impacts to Refuge resources from reasonably foreseeable events and 

impacts resulting from interaction of Refuge actions with actions taking place outside the Refuge, are 

addressed in the final section of this chapter. 

6.2 Terminology

Effects were assessed for scope, scale, and intensity of impacts to resources. Effects may be 

identified further as beneficial or negative, as well as long-term or short-term. 

Negligible. Resources would not be affected, or the effects would be at or near the lowest 

level of detection. Resource conditions would not change or would be so slight no 

measurable or perceptible consequence to a population, wildlife or plant community, 

recreation opportunity, visitor experience, or cultural resource would occur. 

Minor. Effects would be detectable but localized, small, and of little consequence to a 

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

cultural resource. Mitigation, if needed to offset adverse effects, would be easily 

implemented and successful. 

Intermediate. Effects would be readily detectable and localized, with measurable 

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

experience, or cultural resource. Mitigation measures would be needed to offset adverse 

effects and would be extensive, moderately complicated to implement, and probably 

successful. 

Major. Effects would be obvious and would result in substantial consequences to a 

population, wildlife, or plant community; recreation opportunity, visitor experience, or 

cultural resource within the local area and region. Extensive mitigating measures may be 

needed to offset adverse effects and would be large scale in nature, very complicated to 
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

6-2 Chapter 6. Environmental Effects Analysis

implement, and may not have a guaranteed probability of success. In some instances, major 

effects would include the irretrievable loss of the resource. 

Time and duration of effects have been defined as follows. 

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

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

or season. 

6.3 Summary of Management Action Effects at James Campbell

NWR

A summary of the effects analysis is presented in Table 6-1. Current management (Alternative A) 

does benefit wildlife and habitats; however, effects are described in terms of the change from current 

conditions. Therefore, Alternative A generally has negligible, if any, effects because little or no 

change to management programs occurs under this alternative. Effects from Alternatives B and C are 

summarized in the table using the above definitions to describe the magnitude of change from the 

current condition. 

Table 6-1 CCP Alternatives Summary of Effects to the Refuge 

Alternative A Alternative B Alternative C

EFFECTS TO SPECIES AND HABITAT

Effects to 

endangered 

ae‘o, ‘alae

‘ula, and 

‘alae 

ke‘oke‘o

Negligible. No 

change from current 

management. Refuge

continues to provide 

high-quality wetlands 

at current level 

supporting loafing, 

foraging, nesting, and 

chick rearing 

appropriate to lifehistory needs. 

Minor long-term positive 

effect. Increased predator 

control efficiency through 

expanding predator control 

area should decrease 

predation on young and 

adult birds yielding a greater 

number of young fledged.

Increased foraging and 

loafing area will become 

available as greater acreage 

is restored to suitable, highquality wetlands thereby 

increasing the carrying 

capacity of the Refuge.

Intermediate long-term 

positive effect. Increased 

predator control efficiency 

through increased control 

activities on more acreage, 

particularly in areas of higher 

concentrations of this species, 

will result in decreased 

predation on young and adult 

birds yielding a greater 

number of young fledged.

Increased frequency of water 

manipulation will result in 

increased production of 

suitable food throughout the 

year resulting in healthier birds 

and increasing the carrying 

capacity of the Refuge.

Suitable, quality foraging and 

loafing areas will be 

maximized as wetland 

restoration expands potential 

habitat.
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 6. Environmental Effects Analysis 6-3 

Alternative A Alternative B Alternative C

Effects to 

migratory 

waterbirds

Negligible. No 

change from current 

management.

Greater water level 

manipulation, including 

pulsing water, will have 

minor short-term positive 

effects by stimulating 

production of invertebrates 

and seeds, thereby 

increasing foraging area and 

food abundance for 

shorebirds and waterfowl.

Restored acreage of quality 

suitable wintering habitat 

will increase carrying 

capacity for migrant 

waterbirds.

Intermediate long-term 

positive benefits are expected. 

Acreage of suitable wintering 

waterbird habitat will be 

maximized with increased 

control of invasive plants 

coupled with water 

management. Increased 

predator control efficiency 

through increased control 

activities on more acreage will 

result in decreased predation.

Effects to 

seabirds

Negligible. No 

change from current 

management.

Minor long-term positive 

effect. Active vegetation 

management will increase 

suitable nesting habitat. 

Public use closures in 

previously unmanaged 

sensitive coastal dune

nesting areas, pest plant 

removal, and predator 

controls should protect 

nesting seabirds and their 

chicks, increasing fledgling 

success and contribute to 

colony growth. 

Intermediate long-term 

positive effect. Active 

vegetation management will 

increase suitable nesting 

habitat. Public use closures in

previously unmanaged

sensitive coastal dune nesting 

areas, pest plant removal, 

predator-proof fencing, and 

predator control should protect 

nesting seabirds and their 

chicks increasing fledgling 

success and contribute to 

colony growth. 

Effects to 

threatened

honu

Negligible. Not 

currently managed.

Minor long-term positive 

effect. Protection of 

sensitive dune nesting areas 

and predator control should 

protect nests, increasing 

hatching success and 

contributing to species 

recovery. 

Minor long-term positive 

effect. Additional law 

enforcement, EE and 

interpretation, protection of 

sensitive dune nesting areas 

and predator control should 

protect nests, increasing 

hatching success and 

contributing to species 

recovery. 
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

6-4 Chapter 6. Environmental Effects Analysis

Alternative A Alternative B Alternative C

Effects to 

endangered 

‘īlio-holo-ika-uaua

Negligible. Not 

currently managed.

Minor long-term positive 

effect. Protection of 

sensitive dune pupping areas 

and terrestrial predator 

controls should contribute to 

species recovery and less 

disturbance. 

Minor long-term positive 

effect. Additional law 

enforcement, EE, protection of 

sensitive dune pupping areas 

and terrestrial predator 

controls should contribute to 

species recovery and less 

disturbance. 

Effects to 

wetland 

habitats and 

associated 

resident 

wildlife

Negligible. No 

change from current 

management. Quality 

habitat supporting 

endangered and other 

waterbirds will be 

managed and 

maintained at current 

levels.

Minor long-term positive 

benefits to resident wetland 

bird species due to reduction 

of waterbird predation 

within Refuge. An increase 

in wetland acreage will 

provide additional habitat. 

Pulsing water will have 

minor positive effect by 

stimulating germination of 

native plants, thereby 

increasing plant diversity 

and foraging habitat.

Intermediate long-term 

positive benefits to resident 

wetland bird species due to 

reduction in predation within 

Refuge over a greater area. 

Quality yearlong wetlands and 

associated habitat will result 

from increasing the acres to be 

managed. Maximized 

diversity of wetland types and 

plant communities will support 

larger populations of 

waterbirds.

Effects to 

scrub/shrub 

habitat

No effect. Not 

currently managed.

Minor long-term positive 

effect. Limited acreage will 

be restored. Native plants 

will be outplanted and the 

habitat will become more 

suitable for a variety of 

seabirds, including the mōlī. 

Wintering birds may also 

benefit.

Intermediate long-term 

positive effect. Maximum 

acreage will be restored under 

this alternative. Native plants 

will be outplanted and a 

greater effort made to control 

pest plants and maintain highquality habitat. A greater area 

for seabird nesting will be

provided, primarily for mōlī. 

Wintering birds may also 

benefit. Intermediate longterm positive effect on habitat 

restoration efforts with on-site 

greenhouse with increased 

ability to propagate native 

plants acclimated to the 

Refuge.
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 6. Environmental Effects Analysis 6-5 

Alternative A Alternative B Alternative C

Effects to 

coastal 

strand/dune 

habitat

Negligible. Currently, 

removal of marine 

debris from shoreline 

occurs once a year. 

Larger shrubs and 

trees are maintained 

to provide shade for 

potential „u„au kani, 

Christmas 

shearwaters, and 

koa„e„ula underneath 

and higher nest sites 

for „ā. 

Minor long-term positive 

effect. Marine debris 

removal will continue at the 

same rate. More active 

management of vegetation 

will occur, increasing 

suitable nesting habitat for 

potential „ua„u kani, 

Christmas shearwaters, and 

koa„e„ula underneath and

higher nest sites for „ā. Pest 

plant and predator control 

should protect nesting 

seabirds, honu, and „īlioholo-i-ka-uaua.

Intermediate long-term 

positive effect. Marine debris 

removal will continue at the 

same rate. More active 

management of vegetation will 

occur, increasing suitable 

nesting habitat for potential 

„ua„u kani, Christmas 

shearwaters, and koa„e „ula 

underneath and higher nest 

sites for „ā. Pest plant and 

predator control should protect 

nesting seabirds, honu, and 

„īlio-holo-i-ka-uaua.

Intermediate long-term 

positive effect on habitat 

restoration efforts with on-site 

greenhouse with increased 

ability to propagate native 

plants acclimated to the 

Refuge. 

‘Īlio-holo-i-ka-uaua rests on shore Dave Ellis/USFWS
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

6-6 Chapter 6. Environmental Effects Analysis

Alternative A Alternative B Alternative C

PHYSICAL ENVIRONMENTAL EFFECTS

Effects to 

air quality

Negligible. No 

change from current 

management.

Short-term minor negative 

effects from a slight increase 

in infrequent prescribed fires 

and pile burning. Fence 

installation results in a shortterm disturbance to air 

quality due to the use of 

heavy equipment to clear a 

path for the fence.

Short-term minor negative 

effects from a slight increase in 

infrequent prescribed fires and 

pile burning. Fence installation 

results in a short-term 

disturbance to air quality due to 

the use of heavy equipment to 

clear a path for the fence.

Effects to 

water 

quality

Negligible. No 

change from current 

management.

Minor long-term positive 

effects resulting from 

removal of woody 

vegetation, thereby favoring 

grasses and other more 

desirable vegetation 

supporting longer, more 

efficient water table recharge 

and reduction of silt-laden 

runoff to the nearshore 

environment. Increased 

frequency of water level 

manipulation will seasonally 

result in additional water 

being released to channels 

draining to the ocean. This is 

not expected to increase silt 

levels because of the low 

volume and slow release 

rates from wetland 

impoundments. Use of best 

management practices 

(BMPs) during construction 

projects will minimize 

effects on water quality 

during site preparation and 

ground disturbance portions 

of project.

Minor long-term positive 

effects resulting from removal 

of woody vegetation, thereby 

favoring grasses and other more 

desirable vegetation supporting 

longer more efficient water 

table recharge and reduction of 

silt-laden runoff to the 

nearshore environment. 

Increased frequency of water 

level manipulation will 

seasonally result in additional 

water being released to 

channels draining to the ocean. 

This is not expected to increase 

silt levels because of the low 

volume and slow release rates 

from wetland impoundments. 

Increased pulsing and water 

level manipulation is expected 

to increase water use by a 

minor amount on a yearly basis, 

remaining well within our 

permitted use. Use of BMPs 

during construction projects 

will minimize effects on water 

quality during site preparation 

and ground disturbance portions 

of project.
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 6. Environmental Effects Analysis 6-7 

Alternative A Alternative B Alternative C

Effects to 

soils

Negligible. No 

change from current 

management.

Minor long-term positive 

effect anticipated as water is 

again introduced to once 

hydric soils that have 

become more xeric as a 

result of altered surface and 

subsurface hydrology related 

to manmade channels and 

ditches. Fence installation 

results in a short-term 

disturbance to soil due to the 

use of heavy equipment to 

clear a path for the fence and 

then construction of the 

fence.

Intermediate long-term positive 

effect anticipated as expanded 

wetlands restoration is 

undertaken and water is 

reintroduced to larger areas of 

once hydric soils that have 

become more xeric as a result 

of altered surface and 

subsurface hydrology related to 

manmade channels and ditches. 

Fence installation results in a 

short-term disturbance to soil 

due to the use of heavy 

equipment to clear a path for 

the fence and then construction 

of the fence.

SOCIAL EFFECTS

Prospects 

for wildlife 

photograpy

Negligible. No 

change from current 

management which 

allows for limited, 

seasonal 

opportunities in 

conjunction with 

public tours 

conducted 2 days a 

week on the Ki„i 

Unit. 

Minor long-term positive 

increase in opportunities and 

additional subjects 

associated with the coastal 

areas. The use in the Ki„i 

Unit will be reduced as new 

viewing areas are developed 

in expansion lands. 

Intermediate long-term positive 

increase in opportunities and 

additional subjects associated 

with the coastal areas. The use 

in the Ki„i Unit will be reduced 

as new viewing areas are 

developed in expansion lands.

Prospects 

for EE

Negligible. No 

change from current 

management. The 

Refuge hosts EE 

groups on a seasonal 

basis from October 

15-February 28.

Minor long-term positive 

effect. Additional resources 

may enable the Refuge to 

increase EE opportunities 

over a greater time period 

and accommodating 

increased number of 

students.

Intermediate long-term positive 

effect. More EE opportunities 

are expected resulting from 

additional resources and 

expanded areas suitable and 

compatible with Refuge 

operations.

Prospects 

for 

interpretation

Negligible. No 

change from current 

management.

Minor long-term positive 

effect. Some additional 

opportunities developed with 

new visitor center and 

stepdown VSP.

Intermediate long-term positive 

effect. Additional opportunities 

developed with new visitor 

center and stepdown VSP.
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

6-8 Chapter 6. Environmental Effects Analysis

Alternative A Alternative B Alternative C

FACILITIES

Office and 

Visitor 

Center

Negligible. No new 

Office and Visitor 

Center.

Intermediate long-term 

positive effect. Planning, 

design and construction of 

new office/visitor center, if 

funded. Short-term minor 

negative effects possible 

during construction phase

work days due to increased

construction traffic and 

activities, including 

increased noise. Use of 

BMPs during construction 

will minimize effects on 

water quality during site 

preparation and ground 

disturbance portions of 

project.

Intermediate long-term positive 

effect. Planning, design and 

construction, if funded. Shortterm minor negative effects 

possible during construction 

phase work days due to

increased construction traffic 

and construction activities, 

including increased noise. Use 

of BMPs during construction 

will minimize effects on water 

quality during site preparation 

and ground disturbance portions 

of project.

Maintenanc

e Facility, 

Bunkhouse,

and 

Greenhouse

Negligible. No new 

facilities 

constructed.

Existing shop 

subject to negative 

environmental 

conditions and 

increased 

maintenance needs.

Negligible. No new 

maintenance facilities 

constructed. Existing shop 

subject to negative 

environmental conditions

and increased maintenance 

needs. 

Intermediate long-term positive 

effect. A new maintenance 

facility would reduce

equipment maintenance and 

extend life of high-value heavy 

equipment, tractors, vehicles, 

etc. by providing protection 

from harsh coastal weather. A 

bunkhouse would provide 

onsite, affordable, temporary 

housing for volunteers, 

researchers, or interns thereby 

greatly enhancing their ability 

to work on the Refuge. Shortterm minor negative effects 

possible during construction 

phase work days due to

increased construction traffic 

and activities, including 

increased noise. Intermediate 

long-term positive effect with 

greenhouse to propagate native 

plants acclimated to the Refuge. 

BMPs during actual 

construction will minimize 

effects on water quality during 

site preparation and ground 

disturbance portions of project.
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 6. Environmental Effects Analysis 6-9 

Alternative A Alternative B Alternative C

EFFECTS TO NONNATIVE PREDATORS

Fencing Negligible. Minor 

localized reduction 

in dogs and pigs.

Negligible. Minor localized 

reduction in dogs and pigs.

Negligible. Minor localized 

reduction in dogs and pigs.

CONTROL METHODS

Live 

traps

Negligible. Minor 

localized reduction 

of mongooses and 

cats. Nontarget 

species are released 

unharmed at capture 

site. 

Minor localized reduction of 

mongooses, rats, mice, 

bullfrogs, pigs, dogs, and 

cats. Track tunnel 

monitoring may improve 

efficiency of live-trapping 

program. Nontarget species 

are released unharmed at 

capture site. 

Minor localized reduction of 

mongooses, rats, mice, 

bullfrogs, pigs, dogs, and cats. 

Track tunnel monitoring may 

improve efficiency of livetrapping program. Nontarget 

species are released unharmed 

at capture site. Corral traps 

considered for pigs and dogs.

Bait 

stations

Negligible. There 

have been no 

recorded incidents 

of nontarget species 

killed as a result of 

Refuge bait stations.

Minor long-term localized 

reduction of mongooses, 

rats, and mice. Track tunnel 

monitoring may improve 

efficiency of bait station 

program.

Minor long-term localized 

reduction of mongooses, rats, 

and mice over larger area. 

Track tunnel monitoring may 

improve efficiency of bait 

station program.

Predator

-proof 

fence

Not currently used. Intermediate long-term 

positive effect with

immediate exclusion of 

mongooses, dogs, cats, rats, 

and mice from specific 

highly sensitive areas. 

Potential to reduce the need 

for lethal predator control 

efforts.

Intermediate long-term positive 

effect with immediate exclusion 

of mongooses, dogs, cats, rats, 

and mice from specific highly 

sensitive areas. 

Potential to reduce the need for 

lethal predator control efforts.

Lethal 

traps

Not currently used. Potential for minor localized 

reduction of mongooses, 

cats, rats, and mice. 

Inadvertent nontarget 

species effects would be 

mitigated by trap design and 

program operation.

Potential for minor localized 

reduction of mongooses, cats, 

rats, and mice. Inadvertent 

nontarget species effects would 

be mitigated by trap design and 

program operation.

Shooting Negligible. Used 

intermittently for 

animals difficult to 

capture. It is a viable 

tool for individual 

predators that elude 

other control 

methods or pose an 

immediate danger to 

humans.

Negligible effects. Use of 

this tool may increase due to

increased acreage and 

opportunity.

Negligible effects. Use of this 

tool may increase due to

increased acreage and 

opportunity. 
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

6-10 Chapter 6. Environmental Effects Analysis

6.4 Effects Analysis

The following analysis describes the anticipated effects of implementing the Refuge management 

strategies described in Chapter 2 on the physical, biological, and social environment, the attributes of 

which were described in detail in Chapters 3, 4, and 5. 

6.4.1 Effects of Management Actions to Protect Endangered Waterbirds 

6.4.1.1 Fencing 

Currently a combination of barbed wire and hog wire fence is used both internally and along the 

perimeter of the Refuge as a deterrent to minimize mammalian predator and unauthorized human 

access to the Refuge. Round wooden 4-inch

diameter posts are used because of their ability to 

withstand the harsh coastal environment. Woven 

hog-wire (47-inch high) is made of weatherresistant material (Benonal). Although this material 

is relatively expensive, it provides long fence life 

and reduced maintenance. Two to three strands of 

barbed wire are strung above the top of the hogwire and both fencing materials are stapled to the 

wooden posts. The hog-wire is a series of 

rectangles woven into a single roll of fencing. 

Chain-link fence topped with strands of barbed 

wire is considered a viable preventive aid to deter 

predators and human trespass, but is currently not 

used because of the harsh, corrosive coastal 

environment. There is also the need to ensure that „ōpe„ape„a do not become entangled in barbed 

wire they cannot detect through echolocation. Small mammals such as mice, rats, and mongooses 

can move through most types of fence. Cats (and potentially dogs) can climb over some fences. 

Monitoring of fences for breaches (such as cuts made by humans; digging by animals; and damage 

from falling trees and limbs) is ongoing and time consuming. 

Trial use of predator-proof fences is recommended to protect highly sensitive sites on the Refuge, 

such as nesting and chick-rearing sites and sensitive, threatened, or endangered plant populations. 

These fences are very expensive, but have been proven to prevent entry by mammals as small as a 

mouse. They are designed to prevent digging under and climbing over by animals. They are not 

failproof because damage from human vandalism and natural causes, such as falling trees and 

branches, can result in failure. Predator-proof fences have been successfully used on a large scale in 

New Zealand. A current project to install the first predator-proof fence on the northwest tip of O„ahu 

has been initiated for the Ka„ena Point Natural Area Reserve for protection of coastal resources. This 

project should provide valuable information and experience that can be used in development of a 

similar fence on the Refuge. 

Fence installation results in a short-term disturbance to vegetation, soil, air quality, and noise level 

due to the use of heavy equipment to clear a path for the fence, construction of the fence, and cyclical 

replacement. These effects are negligible and short-term compared to the benefits gained over the 

long-term by protecting habitats and native wildlife dependent on them, especially endangered 

Pigs follow the Ki‘i Unit fence George Fisher/USFWS
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 6. Environmental Effects Analysis 6-11

species. Predator-proof fencing should reduce the need for lethal control methods and decrease use of 

other techniques in the long-term. This would also result in long-term financial savings. Predatorproof fencing might not be appropriate for all areas of the Refuge because of topographical features, 

waterways, and access points. 

Implementation of either Alternative B or C will have negligible impacts. These fences can only 

keep dogs and pigs out of enclosed areas. Standard hog/barbed-wire fences do not prevent access by 

smaller predators such as cats, mongooses, and rats. 

6.4.1.2 Live trapping 

Currently, Tomahawk® walk-in live traps are used, but other similar devices could be considered for 

use in the future, if deemed appropriate for target species. Traps are set and baited with dry pet food, 

canned foods, and sardines. Sometimes used cooking oils are used to create a different olfactory 

attractant in an attempt to capture trap-wary animals that might be avoiding certain baits. Trying 

different baits and rotating through various baits is a part of the program. Walk-in traps are checked 

daily when set. If traps cannot be checked at this frequency, they are closed. Under ESA Section 7 

compliance documents, the Refuge is required to check the traps at least once every 48 hours. 

A cover over each Tomahawk® trap provides shade along with an attached water bottle that allows a 

trapped animal to drink. When a target species is captured, it is euthanized by shooting with a small 

caliber weapon, generally a .22 caliber rifle or pistol. Carcasses are disposed of according to State 

and local requirements at an approved location. 

Nontarget species are occasionally caught in this type of trap. A small number are occasionally found 

dead, mostly the result of predation by mammalian predators attacking from outside the trap. These 

nontarget animals are primarily nonnative doves and cardinals that are released unharmed at the 

capture site. Effects to nontarget species are negligible because they are nonnative and widespread on 

O„ahu. The area of effect (Refuge) is infinitesimal compared to the range and numbers of nontargets 

affected. Effects to target species are also negligible because they are widespread on O„ahu and the 

area of effect is insignificant compared to the range and numbers of target species. 

 

Cage traps, including both large corral traps and portable drop-gate traps, are the most popular and 

effective trap methods for capturing pigs and dogs, but success varies seasonally with the availability 

of natural food sources. Cage or pen traps are based on a holding container with some type of a gate 

or door. In this situation, animals are lured either by a pathway and/or bait into an enclosure with a 

one-way entry point. Captured pigs would be euthanized on site using a small caliber weapon and 

disposed of according to applicable regulations. Captured dogs are usually turned over to the 

Hawaiian Humane Society. This type of trap allows release of nontarget species that may 

inadvertently be drawn into it. There are many variations in design for these traps and specific 

designs will be selected based on applicability on specific areas and conditions on the Refuge. An 

advantage of these designs is that many are constructed from readily available materials (woven wire, 

steel/wooden fence posts milled lumber). They are also relatively easy to assemble, disassemble, and 

transport for set-up at different locations. Control or eradication of pigs from the Refuge will 

positively affect the recovery of endangered waterbirds and enhance restoration activities aimed at 

reducing pest plants and animals and outplanting and/or fostering native plants. Removing pigs from 

the Refuge is also anticipated to have a positive effect on surrounding lands by reducing potential for 

damage at nearby golf courses and agricultural properties (Barrett & Birmingham 1994, Mapston 

1999). 
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

6-12 Chapter 6. Environmental Effects Analysis

Specialized cylindrical wire traps that look much like minnow traps are placed in wetland 

impoundments seasonally to capture bullfrogs. Placement is guided by location of ae„o nests. Traps 

are typically placed in March and maintained into July, the period when ae„o chicks hatch. Traps are 

moved as needed to maximize bullfrog reduction in areas where active nesting and chick rearing 

occurs. Other animals caught in these traps include Tilapia, apple snails, Pacific giant toads, and 

crayfish. These nonnative animals may be killed or released. Captured bullfrogs are killed and 

disposed of in accordance with applicable regulations. Prior to disposal, most carcasses are 

necropsied to gather information that adds to our knowledge of this species on the Refuge. 

Reduction of the bullfrog population has resulted in increased ae„o chick survival on the Refuge, 

helping fulfill one of the Refuge purposes. Control is in a limited area compared to the distribution of 

bullfrogs on O„ahu and throughout the main Hawaiian Islands. The effect on the overall population 

of this species is anticipated to be negligible. Although crayfish are not native to Hawai„i, they are an 

important food to endangered and migratory waterbirds, so reduction of bullfrogs maintains an ample 

food supply for these species. 

Implementation of either Alternative B or C will result in a minor localized reduction of mongooses, 

rats, mice, bullfrogs, pigs, dogs, and cats. Track tunnel monitoring may improve efficiency of livetrapping program. 

6.4.1.3 Lethal Trapping 

Currently, no lethal traps are being deployed on the Refuge. Under Alternatives B and C, however, 

this type of trap may be considered to protect endangered species and meet Refuge goals and 

objectives for management and recovery. Several designs are available that are intended to instantly 

dispatch animals in a humane manner. A design that has been explored in Hawai„i is the New 

Zealand Department of Conservation (DOC) series of lethal traps. The kill portion of the trap is 

enclosed in a sturdy box for safety and the entrance to the trap is designed to keep out nontarget 

species. These traps are intended for capturing and humanely killing small mammals up to the size of 

cats. Traps in the DOC series have passed stringent New Zealand National Animal Welfare Advisory 

Committee standards as a humane kill trap. 

We anticipate the implementation of lethal traps will further reduce the number of predators that prey 

on or otherwise impact endangered species recovery. Traps will be selected to capture the appropriate 

size animals at specific locations and will allow the targeting of difficult-to-capture individuals that 

might have developed “capture device” aversion to other capture mechanisms and techniques. Trap 

size and design will be selected to target predator species that are or have been implicated in taking 

native wildlife, particularly endangered and threatened species, and minimize the opportunity to 

capture nontarget species. When lethal traps are deployed, authorized entry points to the area of 

usage will be signed to alert the public that such devices are in use. Traps will be checked at least 

every 3 days to remove any captured animals and dispose of them according to applicable 

regulations. 

Implementation of either Alternative B or C will result in a minor localized reduction of mongooses, 

rats, mice, bullfrogs, pigs, dogs, and cats. Track tunnel monitoring may improve efficiency of livetrapping program. 
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Chapter 6. Environmental Effects Analysis 6-13

6.4.1.4 Bait Stations 

Diphacinone bait blocks are used in approved lockable bait boxes. Commonly used throughout the 

State, the size and design of these bait stations allows entry to animals up to the size of a mongoose. 

This includes mice and rats. Each bait station is labeled with a contact number and each Refuge entry 

area is signed with a warning notifying the public that bait stations are in use in the area. Bait is 

secured in each bait box according to regulations. Bait is checked once weekly, with new blocks 

placed in the box to replace eaten ones, and the data recorded. Small portions of blocks left in the bait 

box are disposed of according to label requirements. The diphacinone bait blocks are not water 

soluble, are secured within the weather-resistant bait station, and do not leach into surrounding 

water and soil. 

Exact numbers of target species affected by bait stations are difficult to ascertain from direct 

observations because target species are relatively small and head to cover after consuming bait. Very 

few animals are found after they consume the diphacinone bait. Presently, observation of target 

animals on the Refuge is the only method used to determine relative presence. Under Alternatives B 

and C, implementation of track tunnel monitoring will occur on a quarterly basis. Use of track 

tunnels devices will provide a more accurate numerical and trend assessment of mice, rats, and 

mongooses on the Refuge. The devices allow identification of tracks left by species that walk 

through a nontoxic ink. Track tunnel monitoring will help us determine the efficacy of ongoing 

predator control programs; target only pest species present/active in a particular area; and provide 

information needed to make modifications to improve the program using relative abundance 

information for targeted species. 

Presently, the use of track tunnels is intermittent. Under Alternatives B and C, implementation of a 

yearlong monitoring program is anticipated. Each cycle of monitoring encompasses a 4-day period. 

Under these alternatives, one tract tunnel monitoring cycle will be conducted quarterly during the 

year, initially. Refining of the number of monitoring efforts necessary to provide an appropriate level 

of data will be undertaken and this quarterly monitoring schedule may be revised, if appropriate. 

Bait stations are currently used on only a portion of the Refuge (Ki„i Unit). Since use of bait stations 

provides a safe and approved method of controlling rodents and mongooses in Hawai„i, they are 

considered for use on other areas of the Refuge under Alternative B with expanded use under 

Alternative C to reduce and maintain minimal small mammal predator numbers to protect native and 

endangered species of animals and plants. Under Alternatives B and C, additional acreage will be 

actively managed and restored to a more functional environmental community, supporting greater 

numbers and diversity of native plants and animals. To provide the optimal possible habitat 

supporting the greatest carrying capacity, predators will need to be controlled on areas not presently 

having a predator management program. The expansion to other parts of the Refuge will support 

endangered species recovery efforts by increasing nesting success and survival of young to fledgling 

age to be recruited into the population and contributing toward high quality habitat. Native plants are 

expected to benefit through increased seed survival and lower seedling predation by rodents, 

contributing to a more rapid recovery of restored native plant communities on the Refuge. Abundant 

native plant seed production would allow seeds to be banked for future outplanting on the Refuge or 

other locations within the plant‟s historic range where it might have been extirpated. 

The number of predators affected is anticipated to be negligible compared with the overall 

populations on O„ahu. Predators targeted by bait stations (mice, rats, and mongooses) have large, 

widespread populations throughout the main Hawaiian Islands and are known to be highly 
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reproductive. The result of using bait stations will be a reduction in target species in sensitive 

resource management areas for endangered and other native species. A positive intermediate effect is 

anticipated with fewer predators impinging on native animals and plants. 

Bait station design prevents entry of most nontarget species (for this control method) such as pigs, 

cats, and dogs. Introduced land snails, geckos, and Pacific giant toads have been observed in the 

stations, but there have been no incidents of death caused to these species. Implementation of either 

Alternative B or C will result in a minor long-term reduction of mongooses, rats, mice, bullfrogs, 

pigs, dogs, and cats. Track tunnel monitoring may improve efficiency of live-trapping program. 

6.4.1.5 Shooting 

Shooting with small–caliber rim fire and center fire firearms and shotguns by trained and qualified 

individuals is a viable tool for controlling difficult to trap individual animals or removal of predator 

species on an opportunistic basis. This tool is very selective and specific predators can be targeted for 

removal. Sound-suppressed firearms will be used when possible to minimize any disturbance to 

nearby neighbors. Dispatched animals will be removed from the site so as not to impact human 

health or adversely impact other wildlife. Predator control activities are confined to the Refuge, 

encompassing a maximum of 1,100 acres. Impacts to the islandwide predator population are 

considered negligible because of the high number, extensive range, and wide distribution of pigs, 

mongooses, mice, rats, bullfrogs, and cats occurring in the wild on O„ahu. 

Cattle egrets have been documented taking chicks of all endangered waterbirds species occurring on 

the Refuge and may be taken under a permit from the Service‟s Office of Migratory Birds. This 

species may be taken using either .22 caliber weapons or shotguns with slugs or nontoxic shot 

material. Limited numbers of this species are expected to be removed from the Refuge for the 

protection and recovery of endangered waterbirds. Compared to the large population and distribution 

of this species on O„ahu and throughout Hawai„i, the number anticipated to be removed will be 

minor and will not have an effect on birds outside the local geographic area. Intermediate positive 

benefits to endangered waterbird recovery are anticipated resulting from decreased chick predation 

and birds recruited into the population. Increased fledgling success will contribute to the overall 

population of each species on O„ahu and other islands as young birds disperse from the Refuge, 

thereby positively affecting recovery (Elepaio Vol. 46). 

The effects of reducing or eliminating predation by utilizing one or more of the above techniques 

provide intermediate positive benefits to endangered, other resident, and migratory waterbirds, as 

well as endangered „īlio-holo-i-ka-uaua and threatened honu. For endangered species, increased 

survival of young will move each species closer to the potential for recovery and delisting. 

Implementation of either Alternative B or C will result in negligible impacts as it is only used 

intermittently for animals difficult to capture. It is a viable tool for individual predators that elude 

other control methods or pose an immediate danger to humans. 

6.4.2 Effects of Management Actions to Intensively Manage Wetland Habitat 

6.4.2.1 Water level manipulation 

This management tool incorporates incremental raising and lowering of water levels (referred to as 

“pulsing”) coupled with the duration and seasonal timing of water held on a particular wetland 
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impoundment. The water level, timing, duration, and degree of pulsing affects plant germination and 

growth, invertebrate production, and food accessibility to foraging shorebirds and endangered 

waterbird chicks. Alteration of successional stages of wetland vegetation is also achieved using this 

tool. A variety of successional stages occurring simultaneously in wetlands contributes to increased 

wildlife and plant diversity. It also contributes to wetland conditions supporting a greater number of 

species and life-history needs of endangered and migrant waterbirds using the Refuge. Prolonged 

drying aids soil rejuvenation by oxygenating soil and reducing the number of fish, such as Tilapia, 

that compete with waterbirds for invertebrates. After such a treatment, a more aerobic wetland 

condition exists when water is reapplied to wetland impoundments. 

Pulsing just prior to chick hatching stimulates increased production of invertebrates consumed by the 

endangered waterbirds. This assists managers in providing ample food to help maximize fledglings 

and increase populations. Invertebrates range from small insects the size of midges to 

macroinvertebrates like crayfish. All are important food items for various life stages of Hawai„i‟s 

endangered waterbirds. Pulsing also creates suitable substrate, moisture, and temperature conditions 

to favor wetland plant germination. Many wetland plants provide food, cover, and/or nesting 

habitat/structure. 

Water level management is one of the primary endangered species management tools used on the 

Refuge. The frequency of pulsing is currently limited due to staffing shortage and workload. Under 

Alternative B, pulsing will be increased to enhance habitat and moderately improve endangered 

waterbird recovery potential on the Refuge. Under Alternative C, use of this tool will be increased to 

gain optimal benefits for enhancing habitat, increasing production, and rearing of young waterbirds. 

The effects of increased pulsing include potential increases in fledged waterbird chicks and 

additional suitable nesting and maintenance habitat. Throughout the summer, there is an increased 

risk of botulism. Maintaining a flow of water through water control structures helps keep water 

temperatures lower by circulating cooler ground water. Cooler water temperatures and higher oxygen 

levels reduce the potential for botulism outbreaks. This flow of water results in a moderate increase 

in water consumption seasonally. To offset this use, water usage is continually monitored and when 

rainfall levels permit, groundwater is reduced. This water-saving measure is utilized throughout the 

year. 

Vegetation can be controlled by rapidly raising water levels and holding several inches of water over 

the top of plants that are forming a monotypic stand or are undesirable in a particular wetland. This 

technique does not work on all plant species and is used only when it does not negatively affect 

endangered species. During the cooler fall and winter months, it is often not necessary to provide a 

continual flow of water through wetland impoundments. During this period, evapotranspiration 

(combination of environmental evaporation and plant transpiration) can be used to assist pulsing and 

maintaining desired water levels. 

The positive effects for endangered, resident, and migratory water-related species occur because the 

pulsing provides a sustainable food base, encourages invertebrate hatches which leads to increase 

food supply throughout the year for young and adult birds. Wetland plants require variable soil 

moisture, temperature, ambient temperature, and duration of wetting for successful germination of a 

variety of native plants beneficial to a host of vertebrate and invertebrate species found in the 

wetland community. The successful seed production resulting from pulsing and maintaining a 

healthy and diverse assemblage of wetland plants ensures future plant presence into the future. 
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Although they are not native, crayfish are an important food source to waterbirds especially during 

chick rearing periods. The migratory kioea also regularly feeds on this macroinvertebrate which is a 

source of protein and calcium. Since manipulating water levels is staggered among wetland 

impoundments, there is some habitat for a greater variety of water-dependent birds throughout the 

Refuge. This minimizes the potential for creating a system where all water is either too deep or too 

shallow for accommodating the life history needs of waterbirds seasonally and throughout the year. 

Lower levels also produce a protected environment for waterbirds to roost during the night with 

reduced chance of predators sneaking up on them. The periods of drying or lowering water levels 

where a moist mud substrate exists may actually assist in controlling bullfrogs, a known predator on 

endangered ae„o chicks, by drying areas where egg masses are attached resulting in their inability to 

hatch. 

Implementation of Alternative B will result in a minor long-term positive effect. Increased predator 

control efficiency through expanding predator control area should decrease predation on young and 

adult birds yielding a greater number of young fledged. Increased foraging and loafing area will 

become available as greater acreage is restored to suitable, high-quality wetlands thereby increasing 

the carrying capacity of the Refuge. 

Implementation of Alternative C will result in an intermediate long-term positive effect. Increased 

predator control efficiency through increased control activities on more acreage, particularly in areas 

of higher concentrations of this species, will result in decreased predation on young and adult birds 

yielding a greater number of young fledged. Increased frequency of water manipulation will result in 

increased production of suitable food throughout the year resulting in healthier birds and increasing 

the carrying capacity of the Refuge. Suitable, quality foraging and loafing areas will be maximized as 

wetland restoration expands potential habitat. 

6.4.2.2 Mechanical Treatment 

Mowing and tilling are currently used to maintain and improve habitat. These tools are used both on 

uplands, within seasonal wetlands, and within intensively managed wetlands to control vegetation 

height, composition, and interspersion. Manipulation of these vegetative components for resource 

management purposes positively affects wildlife and the overall landscape. Waterbirds utilize a 

variety of vegetative conditions. Endangered „alae ke„oke„o and „alae „ula feed on dikes and within 

wetlands where short grass and other plants (<4 in. tall) occur. Younger plants have less cellulose, 

more digestible nutrients, and are preferentially selected over older plants. This habitat condition is 

also utilized by ae„o and a variety of other waterbirds for loafing and foraging. Overgrown areas 

provide concealment cover for predators that prey on waterbirds and their young. Mechanical 

treatment is used as a follow-up to prescribed burning to complete some habitat enhancement 

projects on the Refuge. Tractors or other appropriate equipment pull the implements used to 

accomplish the mowing, and tilling. These tools will continue to be utilized under all alternatives 

with greater frequency, and over larger areas as active management expands under Alternatives B 

and C. 

When vegetation control is required in areas where water drawdowns are not attainable, feasible, or 

desirable, a floating aquatic weedcutter (a small gasoline-powered boat with an attached sickle-bar 

cutter on the front) is used. This equipment can operate in water up to 2-feet deep and cut vegetation 

at different depths depending on the outcome desired. Once cut, vegetation is either left to 

decompose in place or removed from the water and allowed to decompose on adjacent uplands. The 

aquatic weedcutter can be used to create desirable mosaics of open water to vegetation, which can 
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increase carrying capacity. Creating physical and visual barriers and interspersion increases 

territories that can be occupied by waterbirds. 

Disking has a potential to be used to break up accumulation of organic matter; destroy root systems 

of undesirable plants; and loosen soil for improved aeration. Controlled use of this tool is considered 

appropriate for improving habitat conditions. Shallow (1-6 in.) disking will be considered and used 

appropriately on areas where soil and soil moisture conditions warrant. 

Use of mechanical techniques entails the use of motorized equipment and therefore contributes to the 

greenhouse effect. To minimize the carbon foot print contributed by mechanical control, the Refuge 

will use these techniques with the most fuel-efficient equipment feasible. Under the preferred 

Alternative C, it is anticipated no more than five pieces of equipment will operate at the same time. 

This constitutes a negligible burden on the environment compared to the number of fuel-burning 

vehicles operating in the local area and on the Island of O„ahu. This effect will be far outweighed by 

the moderate positive effects to the natural landscape and natural resources, including recovery of 

endangered waterbirds. 

Implementation of Alternative B or C will result in minor long-term positive effects to water quality 

resulting from removal of woody vegetation, thereby favoring grasses and other more desirable 

vegetation supporting longer, more efficient water table recharge and reduction of silt-laden runoff to 

the nearshore environment.

6.4.2.3 Chemical Treatment 

Chemical treatment is another tool used to control vegetation. The presence of many perennial plant 

species, many of which are managed as part of a habitat management scheme, necessitates the use of 

herbicides. Only EPA-approved herbicides for wetlands are applied in and around water areas under 

the guidance of trained applicator(s). We strive to minimize the use of herbicides and apply them in 

compliance with label requirements, agency policy, Section 7 requirements of the ESA and other 

applicable regulations. The concentration used is only as high as necessary to control the targeted 

species. It is anticipated that Rodeo® (or other appropriate glyphosate-based herbicides) and Habitat®

will be the preferred and most-used herbicides in and adjacent to wetlands. These are both approved 

for use in wetlands. Adjuvant is added during application to maximize the effect of the herbicide on 

target species. Only appropriate adjuvant that is compatible with the herbicide is used. Additionally, 

a nontoxic color dye is used to visually detect the area where application has occurred. This helps 

achieve complete coverage of the treatment area and minimizes the quantity of herbicide used by 

reducing the potential for multiple spraying of the same area. Whenever possible, wetland 

impoundments are dewatered prior to the application of herbicides. Herbicide is not applied when 

wind conditions could carry it to an area where control is not intended. 

Other herbicides designed for controlling woody vegetation will likely be necessary during upland 

restoration projects. Many woody shrubs and trees have the ability to resprout after mechanical 

treatment, such as cutting. A technique of cutting followed almost immediately with herbicide 

application on the cut is required to prevent resprouting and repetitive treatment. Herbicides 

successfully used on this type of vegetation in Hawai„i include Garlon 3A® and Garlon 4®. The 

same precautions will be followed when using these or other herbicides. This type of treatment is a 

“spot” treatment as herbicide is applied to an individual plant and not broadcast over an area covered 

with plants. This minimizes the area affected and reduces the quantity of chemical used. 
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Under all alternatives, negligible short-term negative effects to nontarget plant species will be 

mitigated by training personnel to identify and avoid treatment of nontarget species. Negligible shortterm negative effects to nonnative birds may result from the reduction in nesting habitat. These 

effects are far off-set by the widespread distribution and large populations of species such as redvented bulbul and myna birds. We will use herbicides to augment other vegetation control techniques 

like water level manipulation, mechanical treatment, and prescribed fire. Application is overseen by a 

certified pesticide applicator, further reducing the potential for undesirable effects. In relation to 

pesticides used throughout the local area as part of agricultural and aquaculture operations, the 

quantity proposed for use on the Refuge for habitat management is anticipated to be negligible. 

6.4.2.4 Fire

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. 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 (USFWS 2003). 

Conducted under an Agricultural Burn Permit issued by the State Department of Health, Clean Air 

Branch, prescribed burning is used primarily to improve habitat and control undesirable vegetation 

on the Refuge. Burning removes aggressive pest species such as California grass without retention of 

large amounts of vegetated material (left during mechanical treatments) which can lead to botulism 

potential and decreased water quality. Decreased water quality occurs when biodegradation of plant 

material diminishes dissolved oxygen. 

Desirable wetland plants are stimulated by reducing competition with pest plants. The fire regime 

used (slow backing to flanking) produces moderate temperatures that do not adversely affect soils. 

Burning more rapidly returns nutrients tied up in undesirable pest vegetation back to the soil to be 

used by more beneficial species. Following burns, surveys have documented increased species 

diversity and numbers of both endangered and other water-dependent birds. Prior to expansion of the 

Refuge, approximately 8-15 ac of habitat was enhanced using prescribed fire annually. We expect to 

increase the acreage in the prescribed burn program with Refuge expansion to improve and maintain 

habitat quality on a larger scale. In addition, in the future, prescribed burning of piled brush could 

occur to reduce hazardous fuels along the northern and southern edge of the Refuge. 

The typical prescribed burning season to improve wetland habitat on the Refuge extends from 

approximately the beginning of September-October. Prescribed burns on the Refuge have been 

conducted for more than 10 years. Annually, about 10 acres are burned on the Ki„i Unit. The 

prescribed burning cycle varies from 2-3 years in a given impoundment. Prescribed burning on 

uplands on Refuge expansion lands could allow a larger burn window. As is currently done, all 

applicable local, State, and Federal regulations regarding the use of fire will be adhered to during 

burn operations. 

Other agricultural burning occurs in the local area and the infrequent burning conducted by the 

Refuge under all alternatives is anticipated to negatively affect air quality at a minor level on a shortterm basis. 
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6.4.2.5 Ditch maintenance/cleaning

This activity consists of removing vegetation from along ditch banks and within the ditches flowing 

through the Refuge. The major ditches involved in this process are Hospital, Ki„i, Punamanō (EastWest), and Outlet Ditches. Sand plug removal is also required periodically in the Outlet Ditch to 

maintain a water flow to the ocean. These ditches essentially drain that portion of the Ko„olau 

Mountain Range from Kahuku Point to the Town of Kahuku. This drainage system is manmade and 

was once associated with sugar cane production in the area. 

Rental or Service-owned equipment will be used to accomplish the cleaning, which will be done 

periodically on an as needed basis to reduce vegetation that might interfere with water flow to the 

ocean. Cleaning is anticipated to be accomplished on a rotational basis with not all ditches being 

cleaned in a single event or project. Vegetation growth rates related to weather, water salinity, and 

possibly other environmental factors will affect the cleaning frequency. 

Material removed during the project will be placed on top of the dike and left to biodegrade. Material 

removed during cleaning events will not be placed or disposed of in wetlands. Outlet Ditch cleaning 

is required to remove sand deposited associated with shoreline currents. The sand buildup impedes 

water flow to the ocean. Sand will be removed using heavy equipment such as tracked vehicles 

(small dozer, skidloader, etc.), backhoes, and other appropriate equipment. Sand that is removed will 

be redeposited onto the existing sand dunes, coastal strand, and ditch banks. These locations are 

essentially the origins of the sand as it is eroded and transported along the shoreline. Ditch clearing 

will be done with the necessary concurrence and/or permits from USACE. 

Under all alternatives, minor effects on the natural environment are anticipated with these activities. 

Low levels of turbidity can be expected during the actual vegetation removal process as vegetation is 

pulled from the ditch(s). The normally low flow rate of the ditches is expected to allow most 

loosened sediment to settle out in the ditch before water exits into the ocean. There are also 

mechanical devices such as one-way duck-bill check valves that also will assist settling of sediment. 

Since the majority of material removed and deposited on the ditch bank will be vegetative (little 

sediment will be redistributed) and this organic matter will decompose, it is not anticipated that more 

than a minor short-term height in the ditch bank will result. The height will be naturally decreased as 

decomposition occurs. This removal is expected to have a positive effect on allowing water to more 

freely flow and reduce, to some degree, potential impacts from flooding at the Town of Kahuku. The 

minor to moderate positive effects of the cleaning are not anticipated to negate flooding associated 

with major flood events. 

Minimizing vegetative decomposition in the water of the ditches and maintaining a flow that 

contributes to oxygenation of the ditch water will to a minor to moderate level reduce the potential 

for a form of botulism that can be deadly to water-related birds since this bacterium needs an 

anaerobic environment to thrive. Reducing endangered waterbird mortality from this disease will 

further add to recovery of these imperiled species. 

During the work there will be a minor short-term increase in noise and carbon footprint associated 

with the use of heavy equipment compared to normal Refuge operations when this event is not 

occurring. To offset minor noise impacts, cleaning will only occur during daylight hours. Compared 

with regularly occurring agricultural and maintenance activities occurring in the local area and other 

locations on the Island of O„ahu, this action is anticipated to have a negligible to minor cumulative 

impact to the environment. 
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6.4.3 Effects of Management Actions to Restore Remnant Wetland Habitat 

Major alteration of the landscape is not required to restore remnant wetlands capable of supporting 

waterbirds because in most areas soils and hydrology are still functioning in a relatively natural 

manner. Selected sites will be investigated for the feasibility of installing small water control 

structures to partially restore water level management in remnant wetlands. This limited management 

capability may improve the ability to control pest species and increase habitat diversity but overall 

management would remain less intensive under this objective as compared with the intensively 

managed wetlands on the Ki„i Unit. We expect long-term minor positive impacts to endangered 

waterbirds by restoring additional wetland acreage for loafing, foraging, and nesting. 

Aquaculture ponds are currently under lease with the Service for shrimp and prawn farming on 137 

acres of the Refuge. These leases are scheduled to expire in 2023, when they will revert to Refuge 

management. Lessees may relinquish their leases prior to 2023 on a voluntary basis, or if they fail to 

meet the conditions of the leases. Under current aquaculture operations, some of the ponds may be 

idle at times. This provides an opportunity for voluntary cooperative management strategies between 

the lessees and the Refuge to provide additional wetland habitat through water level management 

(raising and/or lowering water level). When ponds permanently revert to Refuge management, they 

will be assessed for reconfiguration, size modification, potential for providing a more diverse 

wetland type mosaic, and more active management strategies. A Comprehensive Water Resources 

Study is planned to initiate in 2018 to prepare for the transfer. 

Implementation of Alternative B will have negligible affects. There is expected to be a moderate 

affect under Alternative C resulting from modifying and intensifying management on these 137 

acres, which will expand and enhance endangered species recovery potential on the Refuge and allow 

for production and support of a greater number of endangered waterbirds. Larger numbers of 

migratory species, including waterfowl and shorebirds, should also be supported, which is important 

since Hawai„i is the major wintering area for some of these species. The kioea and kōlea are 

examples. Some of these species are exhibiting declining populations and providing protection and 

quality habitat (providing loafing, roosting, and foraging areas with ample food) for them is crucial to 

supporting their long flight back to Arctic breeding grounds. 

The lease expiration is anticipated to have a minor to moderate effect on aquaculture operators since 

existing leases will end in 2023 and full implementation of habitat improvement will not occur until 

near the end of the anticipated life of this CCP. At the time the leases expire, lessees will be relocated 

at government expense to equivalent land where they can continue their operations, if they choose. 

6.4.4 Effects of Management Actions to Restore Scrub/Shrub Habitat 

Abandoned aquaculture facilities would be cleaned up for an intermediate long-term positive effect 

allowing for restoration of the natural ecosystem. Native plants will be outplanted and a greater 

effort made to control pest plants and maintain high-quality habitat. A greater area for seabird nesting 

will be provided, primarily for mōlī. Wintering birds may also have positive benefits with additional 

cover and foraging areas. 

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 
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promote native plant propagation for use on the Refuge. If feasible, establishing new populations of 

the endangered „Ewa hinahina and „akoko plants will have long-term positive effects on species 

recovery. 

Implementation of Alternative B will result in a minor long-term positive effect. Limited acreage will 

be restored. Native plants will be outplanted and the habitat will become more suitable for a variety 

of seabirds, including the mōlī. 

Implementation of Alternative C will result in an intermediate long-term positive effect. Maximum 

acreage will be restored under this alternative. Native plants will be outplanted and a greater effort 

made to control pest plants and maintain high-quality habitat. A greater area for seabird nesting will 

be provided, primarily for mōlī. Wintering birds may also benefit. Intermediate long-term positive 

effect on habitat restoration efforts with on-site greenhouse with increased ability to propagate native 

plants acclimated to the Refuge. 

6.4.5 Effects of Management Actions on Coastal Strand/Dune Habitat 

Low intensity management on beach and dunes will include fencing, spot treatment of pest plants, 

and minimizing predator disturbances. Semi-annual beach clean-ups will be coordinated with 

volunteers. Removing marine debris from the coastal zone is an important step to prevent 

entanglement and ingestion by honu, marine mammals, and migratory birds. 

Seabird management on James Campbell NWR is associated with the expansion, since the James 

Campbell National Wildlife Refuge Expansion Act of 2005 specifically lists these and other species 

to become management priorities for which the expansion was approved by Congress. The 

information covering seabirds is based on field reconnaissance and literature reviews. Six seabird 

species are believed to be potential initial nesters in this habitat when it is actively managed. These 

species in order of feasibility of attraction are mōlī, „ua„u kani, koa„e „ula, „ā, ka„upu, and Christmas 

shearwater. Presently the first two species listed are known to occur in the immediate area. After 

colonization by these species, other species found in Hawai„i could be more attracted and possibly 

nest.

Recent failed nesting attempts have been noted in the area (mōlī, „ua„u kani). Anecdotal reports 

suggest that on rare occasion seabirds have fledged in the area. Predation by dogs has been 

documented on several occasions and has been noteworthy enough to make the incident newsworthy. 

Adults and nests are susceptible to mammalian predation by dogs, pigs, rats, cats, and small Indian 

mongooses. Rats and other rodents are known to result in failed seabird nesting in the NWHI, 

although rats have now been removed from all of the NWHI. Control of these predators on the 

Refuge will be necessary to effectively establish and maintain successful nesting seabird colony(s). 

Mōlī have attempted to breed at Kahuku Point since 1979 but were unsuccessful in establishing and 

maintaining colonies due to chick predation by dogs and crushing of nests by ORVs. The site was 

abandoned in 1996 but is still regularly visited (Young, et al. 2009). 

„Ua„u kani breed commonly on O„ahu and the largest colonies, apart from Lehua Island, are found on 

the offshore islets. With protection from mammalian predators, a thriving colony occurs at Ka„ena 

Point. Smaller colonies, with no protection from predators, occur at Black Point, Mōkapu Peninsula, 

Kahuku, and Mālaekahana (Pyle and Pyle 2009). 
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Removal of woody pest plants to maintain breeze flow is critical to aid in thermoregulation of 

nesting adults and prefledgling birds. 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. Fostering desirable vegetation capable of support nesting habitat for the aforementioned 

species will be beneficial to establishment of a seabird nesting colony on the Refuge. Effects are 

anticipated to be minor to moderate in Alternatives B and C. 

6.4.6 Effects of Promoting Management-related Research and Scientific 

Assessments 

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. Under all alternatives, effects of promoting management-related research and 

scientific assessment will have minor to moderate long-term positive impacts on the Service‟s ability 

to effectively manage the Refuge. 

6.4.7 Effects of Offering More Visitor Opportunities 

Four species of endangered Hawaiian waterbirds are present year-round at Ki„i, which provides 

visiting public with excellent viewing opportunities for these species. However, 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. Once self-guided tours are in place, docent-led tours will continue, but at a greatly 

reduced frequency. 

6.4.7.1 Expanded Visitor Services and Environmental Education Program 

Land acquisition will expand the land base of natural resources and facilities, providing greater 

opportunities for year-round programs at James Campbell NWR, subject to adequate funding and 

staff. The Refuge is in a unique position to offer local education entities, teachers, and students a 

place where learning about natural environments, endangered species, natural resource management, 

conservation issues, and cultural resources occurs in an outdoor setting. 

To meet student needs, the Refuge staff is committed to looking for ways to teach about wildlife and 

habitat conservation. These could be one-time activities such as planting native species, or long-term 

involvement including planning, design, and actual on the ground implementation of a study or 

ongoing restoration of a particular site. 

James Campbell NWR currently serves 1,500 students and teachers annually. It is estimated that the 

Refuge could accommodate up to 6,000 students onsite each year if: (1) an education staff were 

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. With more opportunities and a more structured program where teachers are trained to 

use the site and are provided with site-specific materials and tools, educators should be eager to use 

the Refuge year-round. Although the focus of the program would be outdoors, an indoor facility 
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would provide lab space and meeting space, particularly during inclement weather. Construction of a 

HQ/VC/EE complex is proposed for the new acquisition lands near the intersection of Marconi Road 

and Kamehameha Highway. 

Specific details of these activities, compatibility with Refuge purposes and management, locations, 

etc., will be addressed in a VSP to be completed by the Refuge. Generally speaking, EE is an 

important aspect of visitor services on refuges. When dealing with sensitive areas, including the 

presence of threatened and endangered species, opportunities are often limited. They are still 

important and when supervised and planned appropriately open a new world to youth. We anticipate 

enlisting students from local high schools and units of the University of Hawai„i system to participate 

in gaining firsthand knowledge of science and the scientific method by having them conduct 

monitoring and restoration projects. These activities will be closely monitored by Refuge and/or 

Refuge-approved leaders and teachers. 

Life history requirements of wildlife, particularly endangered species, and minimizing disturbance to 

natural resources will be a critical factor in selecting locations for public use programs. Negligible 

short-term effects are expected because of the small footprint of the participants on any given day 

and the onsite guidance they will be provided. Long-term beneficial effects will be exposing students 

to opportunities to experience the outdoors and contribute to the knowledge base of the Refuge. 

Through these experiences participants will gain a greater appreciation for nature, wild places, 

environmental processes, and potentially guide them into a science career. The Refuge will benefit 

from the information gained that will contribute to more effective management of the biotic and 

abiotic components of this rare coastal community. 

Despite the anticipated increased level of visitor services, including EE and interpretation, public 

tours, wildlife viewing opportunities, and nature photography, effects are expected to be negligible 

with implementation of either Alternative B or C. When compared to other areas on O„ahu available 

for these activities, the consequences to wildlife of increases in public use opportunities at this 

Refuge would not be noticeable. 

The effects of visitor services programs to natural resources, endangered and nonendangered wildlife 

and plants, and migratory bird species is expected to be negligible as a result of the timing, seasonal 

access limitations, and limited access and areas available for public use on the Refuge. 

6.4.7.2 Construction of Visitor Center, Office, Equipment Building, Bunkhouse, and 

Greenhouse 

Under Alternatives B and C there is a potential for developing a new Complex office, visitor center, 

bunkhouse, and maintenance buildings for the Refuge. No planning for these structures has been 

undertaken. If it is determined one or more of these will be built, construction would be timed to 

minimize effects to natural resources of the Refuge, including daylight work only, seasonal 

construction restrictions based on nesting endangered species, and minimizing disturbance to 

neighbors. Details of constructing and maintaining facilities such as these would be subject to a 

separate environmental compliance process. 

Additional traffic congestion along Kamehameha Highway that may result from construction of a 

new visitor center would be mitigated through highway turnoff redesign (to reduce hazards 

associated with the Marconi Road intersection). It is anticipated that the majority of visitors to the 

visitor center will be people already traveling along the highway visiting other popular north shore 
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destinations. Mitigation measures will be fully developed in a step-down Transportation Plan when 

funding for this project is available. 

6.4.7.3 Entrance and Boundary Sign Installation 

Presently there is one entry sign on the entire Refuge. It is located along the main entry to the Ki„i 

Unit of the Refuge. There is the potential for an additional one or two entry signs depending on 

locations of future access points to expanded portions of the Refuge. Boundary signs will be placed 

along the Refuge boundary in compliance with Service policy. The purpose of the aforementioned 

signage is to inform the public of the presence of the Refuge and delineate the boundary for legal 

purposes. 

Implementation of Alternative B or C will result in negligible short-term effects from use of either 

manual or mechanized posthole diggers. Disturbance to the ground will be limited to a small several 

square foot area. Long-term minor positive benefits will be to inform the public the area is a unit of 

the Refuge System. Installing signs has the potential to adversely affect cultural resources; however, 

no effects to cultural resources are anticipated from this activity or other management actions for the 

following reasons. 

6.4.8 Effects of Increasing Awareness, Protection, and Appreciation of 

Cultural and Historic Resources 

Cultural resources are physical remains, historic sites, objects, records, oral testimony, songs, stories, 

and traditional life-ways that connect people to past generations. They include archaeological and 

historic sites, structures, artifacts, landscapes, sacred locations, and oral histories. Cultural resources 

are integral components of the landscape that serve as anchors for individual and group identity. 

Protection, preservation, and respect for cultural resources are integral to management actions 

considered or planned on the Refuge. The Refuge contracted with the National Park Service to 

prepare an internal reference document providing an overview of cultural resources on the Refuge 

entitled “A Cultural Resource Overview Report for the Proposed Expansion of James Campbell 

National Wildlife Refuge, Kahuku, O„ahu, Hawai„i” in June 2005. This document is not available to 

the public due to sensitive details pertaining to cultural resources. It describes the environment, land, 

history, historic eras, previous research and documentation, and recommendations for Refuge 

management. A predictive model ranks and also identifies areas of potential cultural resources. 

Associated in this section are recommendations providing guidance to managers during planning and 

implementation of management actions to adequately address cultural resource issues and actions. 

This document will be used as a reference and guide during project planning on the Refuge. In 

addition, State and Federal guidelines will be followed to minimize the chance of harm to cultural 

resources on the Refuge. In the event of a discovery, any work in progress will cease and 

coordination with the proper cultural resource specialists will be initiated. 

Prior to implementing all ground disturbing projects, the applicable cultural resource compliance 

investigation would be undertaken. If cultural resources are found, appropriate procedures and 

protocols would be followed to protect the cultural resources. Whenever possible, resources would be 

avoided or mitigated. Mitigation options, in addition to site avoidance by relocating or redesigning 

facilities, would include data recovery, using either collection techniques or in-situ site stabilization 

protection. Through implementation and adherence to the above guidance and safeguards the effect 
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of implementing the CCP strategies to cultural resources under all alternatives is anticipated to be 

none to negligible. 

6.4.9 Support Flood Damage Reduction Efforts for Town of Kahuku 

The Town of Kahuku is within the lower portion of the Mālaekahana and „Ōhi„a Streams‟ 

watersheds. Portions of Kahuku and much of the Refuge lie within the 100-year flood zones of these 

streams and the coastal floodplain, thereby subject to flooding and associated flood damage during 

exceptionally heavy rainfall. In an attempt to identify means to reduce flood damages in Kahuku, 

USACE completed the Kahuku Watershed Feasibility Study in 2006. This study did not identify any 

comprehensive flood control or flood damage mitigation projects which would meet cost/benefit 

requirements for federal funding. Since that time, various community groups or organizations have 

continued to develop and propose ideas for potential flood mitigation projects. 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 

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/impact 

Refuge lands would be subject to a separate environmental review and regulatory process from this 

CCP. 

6.4.10 Economic Impacts 

National wildlife refuges provide many services to people. A complete economic analysis of the 

Refuge System includes not only the value of all the forms of recreation enjoyed but also the payrolls 

of Refuge employees and the values of maintaining endangered species, preserving wetlands, 

educating future generations, and adding stability to our ecosystem. All of these services are of value 

to society, whether or not they result in some form of market transaction. Some people gain value 

simply from knowing that wild places and unique species still exist. 

For the regional economy, the source of the spending matters. If the expenditure is from outside the 

region, it generates increased economic activity. If it is from within the region and would have 

occurred in the region anyway, it does not increase economic activity but is important for local 

businesses. Thus it is important to separate spending by people from outside the Refuge's economic 

region from spending by those who live locally. Local residents would probably have spent their 

recreation money in the local economy with or without the Refuge. In contrast, non-residents may 

have been attracted to the area by the Refuge. They would have gone elsewhere except for its 

presence, and their spending is a stimulus to the economy. Non-resident spending generates new 

income and new jobs (Carver and Caudill 2007). 

Implementation of either Alternative B or C would be expected to result in minor positive benefits in 

expenditures in the local economy due to construction spending and higher visitation levels. These 

visitors are likely to frequent local businesses for food and other amenities not provided at the 

Refuge. The Hawai„i DBEDT states, “Tourism is the activity most responsible for Hawai„i‟s current 

economic growth and standard of living.” Additional visitors are expected to have a minor positive 

benefit to the local Hale„iwa and Kahuku business communities and provide tourism companies 

throughout the island with an additional venue to bring their clientele. Major construction projects, if 

funded, could have short-term intermediate positive benefits if local contractors have successful bids 
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to do the work. There could also be short-term positive benefits if the contractors hire local labors 

for the projects. The 12 additional staff positions identified in this plan, if filled, would have a longterm minor positive benefit on local employment and personal expenditures. 

6.4.11 Environmental Justice 

The concept of environmental justice has been around since the early 1990s and arose from a need to 

ensure that negative environmental activities from industry or government projects would not 

endanger local communities. The EPA oversees environmental justice compliance and defines 

environmental justice as: “the fair treatment and meaningful involvement of all people regardless of 

race, color, national origin, or income with respect to the development, implementation, and 

enforcement of environmental laws, regulations, and policies” (USEPA 2010). 

In keeping with the Ko„olau Loa Sustainable Communities Plan, expansion of the Refuge to protect 

1,100 acres of open space along the island‟s north shore will preserve scenic open space and natural 

resources from encroachment of development, thereby protecting the rural character of the region. 

Restoration of the expansion lands to native vegetation and wetlands and the return of native species 

will enhance spectacular natural, scenic, and cultural qualities. 

Since CCP implementation of any of the alternatives is expected to result in generally positive effects 

on the human environment, there would be little risk of disproportionate negative effects to low 

income or minority groups. Therefore, negligible effects related to environmental justice are 

anticipated under all CCP alternatives. 

6.5 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 and 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).
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6.5.1 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 

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. 
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6.5.2 Sea Level Rise 

According to the IPCC, the oceans are now absorbing more than 80 percent of the heat added to the 

Earth‟s climate system. Since 1961, this absorption has caused average global ocean temperatures to 

increase and seawater to expand. Thermal expansion of the sea is the primary cause of global sea 

level changes. Melting ice-sheets, ice caps, and alpine glaciers also influence ocean levels. 

Worldwide, sea level changes have 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). 

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 in per 

year. Geological uplift contributes about 0.0016 in per year. The University of Hawai„i Sea Level 

Center has estimated that 1905-2006 mean sea level rose about 0.0417 inches per year. A similar 

estimate was derived from shallow core measurements of a fringing reef crest at Hanauma Bay, 

which concluded that the island is subsiding at a rate of 0.0394-0.0787 in 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 (Nakiboglu et al. 1983, Caccamise et al. 2005). 

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 ft (eustatic) and beyond. There are two 

major channels through which saline inundation will occur; Bacahan channel 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. 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. 
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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. 

6.5.3 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 

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 
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“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). 

6.5.4 Ecological Responses to Climate Change 

Evidence suggests that recent climatic changes have affected a broad range of individual species and 

populations in both the marine and terrestrial environment. Organisms have responded by changes in 

phenology (timing of seasonal activities) and physiology; range and distribution; community 

composition and interaction; and ecosystem structure and dynamics. The reproductive physiology 

and population dynamics of amphibians and reptiles are highly influenced by environmental 

conditions such as temperature and humidity. For example, sea turtle sex is determined by the 

temperature of the nest environment; thus, higher temperatures could result in a higher female to 

male ratio. In addition, increases in atmospheric temperatures during seabird nesting seasons will 

also have an effect on seabirds and 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. For 

example, warmer night temperatures can increase the rate of respiration for native vegetation, 

resulting in greater competition from pest plants. Furthermore, climate change may enhance existing 

pest species issues because alterations in the environment may increase the dispersal ability of flora 

or fauna. Species response to climate change will depend on the life-history, distribution, dispersal 

ability, and reproduction requirements of the species (DBEDT and DOH 1998, Middleton 2006, 

Giambelluca 2008). 
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6.6 Cumulative Effects Assessment

Cumulative impacts are the overall, net effects on a resource that arise from multiple actions. Impacts 

can “accumulate” spatially, when different actions affect different areas of the same resources. They 

can also accumulate over the course of time, from actions in the past, the present, and the future. 

Occasionally, different actions counterbalance one another, partially canceling out each other‟s effect 

on a resource. But more typically, multiple effects add up, with each additional action contributing an 

incremental impact on the resource. In addition, sometimes the overall effect is greater than merely 

the sum of the individual effects, such as when one more reduction in a population crosses a 

threshold of reproductive sustainability, and threatens to extinguish the population. 

A thorough analysis of impacts always considers their cumulative aspects, because actions do not 

take place in a vacuum; there are virtually always some other actions that have affected that resource 

in some way in the past, or are affecting it in the present, or will affect it in the reasonably 

foreseeable future. So any assessment of a specific action‟s effects must in fact be made with 

consideration of what else has happened to that resource, what else is happening, or what else will 

likely happen to it. 

The Refuge staff is not aware of any past, present, or planned actions within the next 15 years that 

would result in a significant cumulative impact when added to the Refuge‟s proposed actions, as 

outlined in the proposed alternatives. The actions proposed by the Refuge in this CCP are expected to 

contribute negligible or minor effects to cumulative impacts of any flood damage reduction project, 

resort and subdivision development, wind farms, and military projects. 
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Appendix A: Species List A-1 

Appendix A: James Campbell NWR Species Lists 

Common Name Scientific name Hawaiian Name

Mammals

Hawaiian monk seal Monachus schauinslandi ‘Īlio-holo-i-ka-uaua

Hawaiian hoary bat Lasiurus cinereus semotus ‘Ōpe‘ape‘a

Dog Canis familiaris ‘Īlio

Cat Felis catus Pōpoki

Indian mongoose Herpestes auropunctatus Manakuke

House mouse Mus musculus ‘Iole

Polynesian rat Rattus exulans ‘Iole

Norway rat Rattus norvegicus ‘Iole

Black rat Rattus rattus ‘Iole

Pig Sus scrofa Pua‘a

Marine Reptiles

Green sea turtle Chelonia mydas Honu

Fish

Western Mosquitofish Gambusia affinis I‘a makika

Milkfish Chanos chanos Awa

Cuban molly Limia vittata

Engel's mullet Moolgarda engeli

Mullet Mugil cephalus ‘Ama‘ama

Acute-jawed mullet Neomyxus leuciscus

Molly Poecilia hybrid sp.

Sailfin molly Poecilia latipinna

Shortfin molly Poecilia mexicana

Gracile lizardfish Saurida gracilis

Black chin tilapia Sarotherodon melanotheron

Tilapia Oreochromis mossambicus

Tipapia Tilapia zillii

Giant trevally (papio) Caranx Ignobilis Ulua au kea

Invertebrates, aquatic

Asian clam Corbicula fluminea

Clam Corbicula sp.

Anchialine snapping shrimp Metabetaeus lohena 

Hawaiian red shrimp Halocaradiana rubra ‘Ōpae‘ula

Feeble shrimp Palaemon debilis ‘Ōpae huna

Limpet Pyrgophorus coronatus ‘Opihi

Mud crab Scylla serreta

Crenate swimming crab Thalamita crenata

Thalamita edwardsi

Crayfish Procambarus clarkii ‘Ōpae pake

Freshwater prawn Macrobrachium rosenbergii

Invertebrates, terrestrial

Southern house mosquito Culex quinquefasciatus
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Asian tiger mosquito Aedes albopictus

Waterstrider Halobates hawaiiensis

Cane spider Heteropoda venatoria

Rambur’s forktail damselfly Ischnura ramburii

Lesser brown scorpion Isometrus maculatus Kopiana

Centipede Scolopendra subspinipes Kanapī

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

Red-eared slider Trachemys scripta elegans

Migratory shorebirds 

Plovers & Dotterels

 Black-bellied Plover Pluvialis squatarola

 Pacific Golden-Plover Pluvialis fulva Kōlea

 Semipalmated Plover Charadrius semipalmatus

 Killdeer Charadrius vociferus

Avocets & Stilts

 Hawaiian Stilt Himantopus mexicanus knudseni Ae‘o

Sandpipers & Phalaropes

 Greater Yellowlegs Tringa melanoleuca

 Lesser Yellowlegs Tringa flavipes

 Wandering Tattler Heteorscelus incanus ‘Ūlilī

 Spotted Sandpiper Actitis maclaria

 Black-tailed Godwit Limosa limosa

 Bar-tailed Godwit Limosa lapponica 

 Ruddy Turnstone Arenaria interpres ‘Akekeke

 Red Knot Calidris canutus

 Sanderling Calidris alba Hunakai

 Semipalmated Sandpiper Calidris pusilla

 Western Sandpiper Calidris mauri

 Least Sandpiper Calidris minutilla

 Pectoral Sandpiper Calidris melanotos

 Sharp-tailed Sandpiper Calidris acuminata

 Solitary Sandpiper Tringa solitaria

 Marsh Sandpiper Tringa stagnatilis 

 Dunlin Calidris alpina

 Stilt Sandpiper Calidris himantopus

 Ruff Philomachus pugnax

 Short-billed Dowitcher Limnodromus griseus

 Long-billed Dowitcher Limnodromus scolopaceus

 Common Snipe Gallinago gallinago
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix A: Species List A-3 

 Wilson’s Phalarope Phalaropus tricolor

Seabirds & Gulls

Laysan Albatross Phoebastria immutabilis Mōlī

Black-footed Albatross Phoebastria nigripes ‘Ka‘upu

Wedge-tailed Shearwater Puffinus pacificus ‘Ua‘u kani

White-tailed Tropicbird Phaethon lepturus dorotheae Koa‘e kea

Red-tailed Tropicbird Phaethon rubricauda Koa‘e‘ula

Red-footed Booby Sula sula rubripes ‘Ā

Great frigatebird Fregata minor ‘Iwa

Laughing gull Leucophaeus atricilla

Franklin's Gull Laris pipixcan

Bonaparte's gull Chroicocephalus philadelphia

Ring-billed gull Larus delawarensis

Herring gull Larus argentatus

Thayer’s Gull Larus thayeri

Western Gull Larus occidentalis

Glaucous-winged Gull Larus glaucescens

Gull-billed Tern Gelochelidon nilotica

Caspian Tern Hydroprogne caspia

Sandwich Tern Thalasseus sandvicensis

Common Tern Sterna hirundo

Arctic Tern Sterna paradisaea

Least Tern Sternula antillarum

White Tern, Fairy Tern Gygis alba Manu o Kū

Herons & Ibis

Great blue heron Ardea herodias

Snowy egret Egretta thula

Cattle egret Bubulcus ibis

Black-crowned night-heron Nycticorax nycticorax ‘Auku‘u

White-faced ibis Plegadis chihi

Geese & Ducks

Greater white-fronted goose Anser albifrons

Black brant Branta bernicla 

Cackling goose Branta hutchinsii

Canada goose Branta canadensis

Gadwall Anas strepera

Eurasian widgeon Anas penelope

American widgeon Anas americana

Mallard Anas platyrhynchos

Hawaiian duck Anas wyvilliana Koloa maoli

Blue-winged teal Anas discors

Cinnamon Teal Anas cyanoptera

Northern shoveler Anas clypeata Koloa mohā

Northern pintail Anas acuta Koloa māpu

Green-winged teal Anas carolinensis
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix A: Species List A-4 

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

Canvasback Aythya valisineria

Redhead Aythya americana

Ring-necked duck Aythya collaris

Tufted duck Aythya fuligula

Greater scaup Aythya marila

Lesser scaup Aythya affinis

Bufflehead Bucephala albeola

Common Merganser Mergus merganser

Diurnal Raptors

Osprey Pandion haliaetus

Northern harrier Circus cyaneus

Peregrine falcon Falco peregrinus

Upland Game Birds

Ring-necked pheasant Phasianus colchicus

Common peafowl Pavo cristatus Pīkake

Guinea fowl Numida meleagris

Gallinules & Coots

Hawaiian moorhen 

Gallinula chloropus 

sandvicensis ‘Alae ‘ula

Hawaiian coot Fulica alai ‘Alae ke‘oke‘o

Pigeons & Doves

Rock pigeon Columba livia

Spotted dove Streptopelia chinensis

Zebra dove Geopelia striata

Mourning dove Zenaida macroura

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
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix A: Species List A-5 

Sparrows

House sparrow Passer domesticus

Java sparrow Padda oryzivora

Waxbills & Mannikins

Common waxbill Estrilda astrild

Red avadavat Amandava amandava

Nutmeg mannikin Lonchura punctulata

Chestnut munia Lonchura atricapilla

Native Plant Species

Scientific Name Common Name Origin Hawaiian Name

Aizoaceae

Sesuvium portulacastrum Sea purslane Ind. ‘Ākulikuli

Astererace

Lipochaeta lobata Daisy End. Nehe

Boraginaceae

Heliotropium anomalum var. argenterum Hinahina Ind. Hinahina

Heliotropium curassavicum Seaside heliotrope Ind. Kīpūkai

Chenopodiaceae 

Chenopodium oahuense Aheahea End. ‘Āheahea

Convolvulaceae

Ipomoea imperati Beach morning glory Ind. Hunakai

Ipomoea indica Koali‘awa Ind. Koali‘awa

Ipomoea pes-carprae Beach morning glory Ind. Pōhuehue

Jaquemontia ovalifolia Oval-leafed clustervine Ind. Pā‘ūohi‘iaka

Cyperaceae

Bolboschoenus maritimus Kaluha Ind. Kaluhā

Mariscus javanicus Marsh cyprus Ind. ‘Ahu‘awa

Cyperus polystachyos Manyspike flatsedge Ind.

Schoenoplectus lacustris Great bulrush Ind. ‘Aka‘akai

Fimbristylis cymosa Sand Bulrush Ind. Mau‘u

Euphorbiaceae

Chamaesyce degeneri Beach sandmat End. ‘Akoko

Fabaceae

Erythrina sandwicensis Hawaiian coral tree End. Wiliwili

Vigna marina Beach pea Ind. Nanea

Malvaceae

Gossypium tomentosum Hawaiian cotton End. Mao

Sida fallax Yellow ilima Ind. ‘Ilima

Thespesia populnea Milo Ind. Milo

Menispermaceae

Cocculus trilobus Huehue Ind. Huehue

Nyctaginaceae

Boerhavia repens Alena Ind. Alena 

Onagraceae
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix A: Species List A-6 

Ludwigia octovalvis Primrose willow Ind. Kāmole

Plumbaginaceae

Plumbago zeylandica ‘Ilie‘e Ind. ‘Ilie‘e

Pandanaceace

Pandanus tectorius Screw pine Ind. Hala

Poaceae

Sporobolus virginicus Beach dropseed Ind. ‘Aki‘aki

Santalaceae

Santalum ellipticum Coastal sandalwood End. ‘Iliahialo‘e

Scrophulariaceae

Bacopa monnieri Water hyssop Ind. ‘Ae‘ae

Solanaceae 

Lycium sandwicense Hawaiian desert-thorn Ind. ‘Ohelo kai

Solanum americanum Popolo Ind. Popolo

Sterculiaceae

Waltheria indica ‘Uhaloa Ind. ‘Uhaloa

Verbanaceae

Vitex rotundifolia Beach vitex Ind. Pōhinahina

Scaevola taccada Beach naupaka Ind. 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
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix A: Species List A-7 

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

Cyperus difformis Variable flatsedge

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
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix A: Species List A-8 

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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

 

Appendix B: Appropriate Uses and Compatibility Determinations B-1 

Appendix B. Compatibility Determinations and Appropriate Use

Findings

B.1 Introduction

The compatibility determinations (CDs) developed during the CCP planning process evaluate uses 

projected to occur at the James Campbell NWR over the next 15 years. The evaluation of funds 

needed for management and implementation of each use also assumes implementation as described 

in Chapter 2. Chapter 6 of the Draft CCP/EA also contains analysis of the impacts of public uses to 

wildlife and habitats. 

B.1.1 Uses Evaluated At This Time 

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 
James Campbell National Wildlife Refuge 

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B-2 Appendix B: Appropriate Uses and Compatibility Determinations 

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. 

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 overflights, 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 
James Campbell National Wildlife Refuge 

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Appendix B: Appropriate Uses and Compatibility Determinations B-3 

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: 

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 

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B-4 Appendix B: Appropriate Uses and Compatibility Determinations 
James Campbell National Wildlife Refuge 

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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 
James Campbell National Wildlife Refuge 

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B-6 Appendix B: Appropriate Uses and Compatibility Determinations 

life histories of both endangered and migratory birds viewed along the tour route. Scheduled from 

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. 
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

 

Appendix B: Appropriate Uses and Compatibility Determinations B-7 

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 

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). 
James Campbell National Wildlife Refuge 

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B-8 Appendix B: Appropriate Uses and Compatibility Determinations 

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. 

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 
James Campbell National Wildlife Refuge 

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Appendix B: Appropriate Uses and Compatibility Determinations B-9 

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 (Code of Federal Regulations; 50 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 

National Wildlife 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 

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. 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 
James Campbell National Wildlife Refuge 

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B-10 Appendix B: Appropriate Uses and Compatibility Determinations 

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) 

June 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 

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Appendix B: Appropriate Uses and Compatibility Determinations B-11

Signatures: 

The Compatibility Determination for Wildlife Observation, Interpretation, and Photography is 

compatible with stipulations. 

 

Prepared by: 

Refuge Planner, 

Hawaiian and Pacific Islands NWRC 

 ___ 

 (Signature) (Date) 

Project Leader, 

O„ahu National Wildlife Refuge Complex 

Approval: 

 ___ 

 (Signature) (Date) 

Concurrence: 

Project Leader, 

Hawaiian and Pacific Islands NWRC 

 ___ 

 (Signature) (Date) 

Regional Chief, 

National Wildlife Refuge System: 

 ___ 

 (Signature) (Date) 
James Campbell National Wildlife Refuge 

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B-12 Appendix B: Appropriate Uses and Compatibility Determinations 
James Campbell National Wildlife Refuge 

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Appendix B: Appropriate Uses and Compatibility Determinations B-13

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 (EE) 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 non-profit 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. 
James Campbell National Wildlife Refuge 

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B-14 Appendix B: Appropriate Uses and Compatibility Determinations 

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 

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 Monday, Wednesdays, or Fridays with a maximum of 60 students being allowed along 

with teachers and chaperones and programs are conducted from 11:30 a.m.-1:30p.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. 

 
James Campbell National Wildlife Refuge 

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Appendix B: Appropriate Uses and Compatibility Determinations B-15

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 

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. 
James Campbell National Wildlife Refuge 

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B-16 Appendix B: Appropriate Uses and Compatibility Determinations 

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. 

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) 

June 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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

 

Appendix B: Appropriate Uses and Compatibility Determinations B-17

Signatures: 

The Compatibility Determination for Environmental Education is compatible with stipulations. 

Prepared by: 

Refuge Planner, 

Hawaiian and Pacific Islands NWRC 

 ___ 

 (Signature) (Date) 

Project Leader, 

O„ahu National Wildlife Refuge Complex 

Approval: 

 ___ 

 (Signature) (Date) 

Concurrence: 

Project Leader, 

Hawaiian and Pacific Islands NWRC 

 ___ 

 (Signature) (Date) 

Regional Chief, 

National Wildlife Refuge System: 

 ___ 

 (Signature) (Date) 
James Campbell National Wildlife Refuge 

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B-18 Appendix B: Appropriate Uses and Compatibility Determinations 
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

 

Appendix B: Appropriate Uses and Compatibility Determinations B-19

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 species-
James Campbell National Wildlife Refuge 

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B-20 Appendix B: Appropriate Uses and Compatibility Determinations 

specific, Refuge-specific, or evaluate the relative contribution of the Refuge lands to larger 

landscapes (e.g., ecoregion, region, flyway, national, international) issues and trends. 

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(s) to conduct research, scientific collecting, and surveys will generally provide 

information that would benefit fish, wildlife, plants, and their habitats. Scientific findings gained 

through these projects provide important information regarding life-history needs of species and 

species groups as well as identify or refine management actions to achieve resource management 
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

 

Appendix B: Appropriate Uses and Compatibility Determinations B-21

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. 

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 projects (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. 
James Campbell National Wildlife Refuge 

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B-22 Appendix B: Appropriate Uses and Compatibility Determinations 

At least 6 months before initiation of field work (unless an exception is made by prior approval of the 

Refuge Manager), project investigator(s) must submit a detailed proposal. Project proposals will be 

reviewed by Refuge staff and others, as needed, to assess the potential impacts (short-term, longterm, and cumulative) relative to benefits of the investigation to Refuge management issues and 

understanding of natural systems. This assessment will form the primary basis for allowing or 

denying a specific project. Projects that result in unacceptable Refuge impacts will not be found 

compatible. 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. 
James Campbell National Wildlife Refuge 

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Appendix B: Appropriate Uses and Compatibility Determinations B-23

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. 

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 

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B-24 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) 

June 2021Mandatory 10-year re-evaluation date (uses other than wildlife-dependent public uses) 

NEPA Compliance for Refuge Use Decision: (check one below)

 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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

 

Appendix B: Appropriate Uses and Compatibility Determinations B-25

Signatures: 

The Compatibility Determination for Research, Scientific Collecting, and Surveys is compatible with 

stipulations. 

Prepared by: 

Refuge Planner, 

Hawaiian and Pacific Islands NWRC 

 ___ 

 (Signature) (Date) 

Project Leader, 

O„ahu National Wildlife Refuge Complex 

Approval: 

 ___ 

 (Signature) (Date) 

Concurrence: 

Project Leader, 

Hawaiian and Pacific Islands NWRC 

 ___ 

 (Signature) (Date) 

Regional Chief, 

National Wildlife Refuge System: 

 ___ 

 (Signature) (Date) 
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

B-26 Appendix B: Appropriate Uses and Compatibility Determinations 
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

 

Appendix B: Appropriate Uses and Compatibility Determinations B-27

FINDING OF APPROPRIATENESS OF A REFUGE USE

Refuge Name: James Campbell National Wildlife Refuge 

Use: Research, Scientific Collecting, and Surveys 

 This form is not required for wildlife-dependent recreational uses; take regulated by the State, or uses already described in a 

refuge CCP or step-down management plan approved after October 9, 1997. 

Where we do not have jurisdiction over the use (“no” to (a)), there is no need to evaluate it further as we cannot control the 

use. Uses that are illegal, inconsistent with existing policy, or unsafe (“no” to (b), (c), or (d)) may not be found appropriate. If 

the answer is “no” to any of the other questions above, we will generally not allow the use. 

If indicated, the refuge manager has consulted with State fish and wildlife agencies. Yes _✔__ No __ 

When the refuge manager finds the use appropriate based on sound professional judgment, the refuge manager must justify 

the use in writing on an attached sheet and obtain the refuge supervisor’s concurrence. Based on an overall assessment of 

these factors, my summary conclusion is that the proposed use is: 

Not Appropriate_____ Appropriate_✔ 

Refuge Manager:________________________________________ Date:_____________________ 

If found to be Not Appropriate, the refuge supervisor does not need to sign concurrence if the use is a new use. If an existing 

use is found Not Appropriate outside the CCP process, the refuge supervisor must sign concurrence. If found to be 

Appropriate, the refuge supervisor must sign concurrence. 

Refuge Supervisor:_______________________________________ Date:_____________________ 

FWS Form 3-2319 

A compatibility determination is required before the use may be allowed. 02/06 

Decision Criteria: YES NO 

(a) Do we have jurisdiction over the use? ✔

(b) Does the use comply with applicable laws and regulations (Federal, State, tribal, and local)? ✔

(c) Is the use consistent with applicable Executive orders and Department and Service policies? ✔

(d) Is the use consistent with public safety? ✔

(e) Is the use consistent with goals and objectives in an approved management plan or other 

document? ✔

(f) Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? ✔

(g) Is the use manageable within available budget and staff? ✔

(h) Will this be manageable in the future within 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? ✔

(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? 

✔
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

B-28 Appendix B: Appropriate Uses and Compatibility Determinations 

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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

 

Appendix B: Appropriate Uses and Compatibility Determinations B-29

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 toted 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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

B-30 Appendix B: Appropriate Uses and Compatibility Determinations 

FINDING OF APPROPRIATENESS OF A REFUGE USE

Refuge Name: James Campbell National Wildlife Refuge 

Use: Commercial operation, sea asparagus farm

 This form is not required for wildlife-dependent recreational uses; take regulated by the State, or uses already described in a 

refuge CCP or step-down management plan approved after October 9, 1997.

Where we do not have jurisdiction over the use (“no” to (a)), there is no need to evaluate it further as we cannot 

control the use. Uses that are illegal, inconsistent with existing policy, or unsafe (“no” to (b), (c), or (d)) may not be 

found appropriate. If the answer is “no” to any of the other questions above, we will generally not allow the use. 

If indicated, the Refuge manager has consulted with State fish and wildlife agencies. Yes ✔ No __ 

When the refuge manager finds the use appropriate based on sound professional judgment, the refuge manager 

must justify the use in writing on an attached sheet and obtain the refuge supervisor’s concurrence. Based on an 

overall assessment of these factors, my summary conclusion is that the proposed use is: 

Not Appropriate ✔ Appropriate____ 

Refuge Manager:____________________________________________ Date:_____________________ 

If found to be Not Appropriate, the Refuge supervisor does not need to sign concurrence if the use is a new use. If 

an existing use is found Not Appropriate outside the CCP process, the Refuge supervisor must sign concurrence. If 

found to be Appropriate, the Refuge supervisor must sign concurrence. 

Refuge Supervisor:___________________________________________ Date:_____________________ 

FWS Form 3-2319 

A compatibility determination is required before the use may be allowed. 02/06 

Decision Criteria: YES NO 

(a) Do we have jurisdiction over the use? ✔

(b) Does the use comply with applicable laws and regulations (Federal, State, tribal, and local)? ✔

(c) Is the use consistent with applicable Executive orders and Department and Service policies? ✔

(d) Is the use consistent with public safety? ✔

(e) Is the use consistent with goals and objectives in an approved management plan or other 

document? ✔

(f) Has an earlier documented analysis not denied the use or is this the first time the use has been 

proposed? ✔

(g) Is the use manageable within available budget and staff? ✔

(h) Will this be manageable in the future within 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? ✔

(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? 

✔
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

 

Appendix B: Appropriate Uses and Compatibility Determinations B-31

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.

f. Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? 
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

B-32 Appendix B: Appropriate Uses and Compatibility Determinations 

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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

 

Appendix B: Appropriate Uses and Compatibility Determinations B-33

FINDING OF APPROPRIATENESS OF A REFUGE USE

Refuge Name: James Campbell National Wildlife Refuge 

Use: Private Aircraft Operation of abandoned runway (former Kahuku Army Airfield)

 This form is not required for wildlife-dependent recreational uses; take regulated by the State, or uses already described in a 

refuge CCP or step-down management plan approved after October 9, 1997.

Where we do not have jurisdiction over the use (“no” to (a)), there is no need to evaluate it further as we cannot 

control the use. Uses that are illegal, inconsistent with existing policy, or unsafe (“no” to (b), (c), or (d)) may not be 

found appropriate. If the answer is “no” to any of the other questions above, we will generally not allow the use. 

If indicated, the Refuge manager has consulted with State fish and wildlife agencies. Yes ✔ No __ 

When the refuge manager finds the use appropriate based on sound professional judgment, the refuge manager 

must justify the use in writing on an attached sheet and obtain the refuge supervisor’s concurrence. Based on an 

overall assessment of these factors, my summary conclusion is that the proposed use is: 

Not Appropriate ✔ Appropriate____ 

Refuge Manager:____________________________________________ Date:_____________________ 

If found to be Not Appropriate, the Refuge supervisor does not need to sign concurrence if the use is a new use. If 

an existing use is found Not Appropriate outside the CCP process, the Refuge supervisor must sign concurrence. If 

found to be Appropriate, the Refuge supervisor must sign concurrence. 

Refuge Supervisor:___________________________________________ Date:_____________________

FWS Form 3-2319 

A compatibility determination is required before the use may be allowed. 02/06 

Decision Criteria: YES NO 

(a) Do we have jurisdiction over the use? ✔

(b) Does the use comply with applicable laws and regulations (Federal, State, tribal, and local)? ✔

(c) Is the use consistent with applicable Executive orders and Department and Service policies? ✔

(d) Is the use consistent with public safety? ✔

(e) Is the use consistent with goals and objectives in an approved management plan or other 

document? ✔

(f) Has an earlier documented analysis not denied the use or is this the first time the use has been 

proposed? ✔

(g) Is the use manageable within available budget and staff? ✔

(h) Will this be manageable in the future within 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? ✔

(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? 

✔
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

B-34 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: 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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

 

Appendix B: Appropriate Uses and Compatibility Determinations B-35

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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

B-36 Appendix B: Appropriate Uses and Compatibility Determinations 
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix C: Plan Implementation and Costs C-1 

Appendix C. Plan Implementation and Costs 

C.1 Administration

James Campbell National Wildlife Refuge is administered as part of the O‘ahu National Wildlife 

Refuge Complex. The Complex also includes the Pearl Harbor NWR, comprised of three separate 

units scattered along the south of O‘ahu and also 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 refuges in the entire 

Complex are located on the Ki‘i Unit. This site is located about 40 miles from the Pearl Harbor NWR 

units. A new O‘ahu NWR Complex headquarters/visitor center/environmental education facility is 

being 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, 

12 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). 

C.2.1 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 210,000 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 list below. 
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

C-2 Appendix C: Plan Implementation and Costs 

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 Manager 

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 in the CCP. 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. 

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 as 

seabird nesting habitat 

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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

C-4 Appendix C: Plan Implementation and Costs 
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix D: Wilderness Review D-1 

Appendix D: Wilderness Review for James Campbell 

National Wildlife Refuge

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. 
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

D-2 Appendix D: Wilderness Review 

The following section summarizes the inventory phase of the wilderness review for James 

Campbell NWR. 

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 
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Appendix D: Wilderness Review D-3 

impacts and activities outside the boundary of the unit. The cumulative effects of these factors were 

considered in the evaluation of naturalness for each wilderness inventory unit. 

In the wilderness inventory, specific 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). 
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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.
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Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix E: Integrated Pest Management Program E-1 

Appendix E: Integrated Pest Management (IPM) Program 

1.0 Background 

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, sitespecific management of pest species to achieve desired outcomes. In accordance with 43 CFR 

46.145, adaptive management would be particularly relevant where long-term impacts may be 

uncertain and future monitoring would be needed to make adjustments in subsequent implementation 

decisions. After a tolerable pest population (threshold) is determined considering achievement of 

Refuge resource objectives and the ecology of pest species, one or more methods, or combinations 

thereof, 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 in accordance with effects analyses presented in 

Chapter 6 of this CCP. Only pesticide uses that likely would cause minor, temporary, or localized 

effects to Refuge biological resources and environmental quality with appropriate best management 

practices (BMPs), where necessary, would be allowed for use on the Refuge. 

This Appendix does not describe the more detailed process to evaluate potential effects associated 

with aerial applications of pesticides. 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. 
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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; 
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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 
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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: 
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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) 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 
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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. 
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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. 
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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 
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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 
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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 
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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. 
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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 
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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. 
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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 
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only be approved where there would likely be minor, temporary, or localized effects to fish and 

wildlife species as well as minimal potential to degrade environmental quality. Potential effects to 

listed and nonlisted species would be evaluated with quantitative ecological risk assessments and 

other screening measures. Potential effects to environmental quality would be based upon pesticide 

characteristics of environmental fate (water solubility, soil mobility, soil persistence, and 

volatilization) and other quantitative screening tools. Ecological risk assessments as well as 

characteristics of environmental fate and potential to degrade environmental quality for pesticides 

would be documented in Chemical Profiles (see Section 7.5). These profiles would include threshold 

values for quantitative measures of ecological risk assessments and screening tools for environmental 

fate that represent minimal potential effects to species and environmental quality. In general, only 

pesticide uses with appropriate BMPs (see Section 4.0) for habitat management and facilities 

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 6.2.3. 

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 7.5. 
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Table E-1. Ecotoxicity tests used to evaluate potential effects to birds, fish, and mammals to 

establish toxicity endpoints for risk quotient calculations. 

Species Group Exposure Measurement endpoint 

Bird

Acute Median Lethal Concentration (LC50) 

Chronic No Observed Effect Concentration (NOEC) or

No Observed Adverse Effect Concentration (NOAEC)1

Fish 

Acute Median Lethal Concentration (LC50) 

Chronic No Observed Effect Concentration (NOEC) or

No Observed Adverse Effect Concentration (NOAEC)2

Mammal Acute Oral Lethal Dose (LD50) 

Chronic No Observed Effect Concentration (NOEC) or

No Observed Adverse Effect Concentration (NOAEC)3

1Measurement endpoints typically include a variety of reproductive parameters (e.g., number of 

eggs, number of offspring, eggshell thickness, and number of cracked eggs). 

2Measurement endpoints for early life stage/life cycle typically include embryo hatch rates, time 

to hatch, growth, and time to swim-up. 

3Measurement endpoints include maternal toxicity, teratogenic effects or developmental 

anomalies, evidence of mutagenicity or genotoxicity, and interference with cellular mechanisms 

such as DNA synthesis and DNA repair. 

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 
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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 E-2. Presumption of unacceptable risk for birds, fish, and mammals (US EPA 1998). 

Risk Presumption Level of Concern

Listed Species Nonlisted Species

Acute Birds 0.1 0.5

Fish 0.05 0.5

Mammals 0.1 0.5

Chronic Birds 1.0 1.0

Fish 1.0 1.0

Mammals 1.0 1.0

7.2.1 Environmental exposure 

Following release into the environment through application, pesticides would experience several 

different routes of environmental fate. Pesticides which would be sprayed can move through the air 

(e.g., particle or vapor drift) and may eventually end up in other parts of the environment such as 

nontarget vegetation, soil, or water. Pesticides applied directly to the soil may be washed off the soil 

into nearby bodies of surface water (e.g., surface runoff) or may percolate through the soil to lower 

soil layers and groundwater (e.g., leaching) (Baker and Miller 1999, Pope et. al. 1999, Butler et. al. 

1998, Ramsay et. al. 1995, EXTOXNET 1993a). Pesticides which would be injected into the soil 

may also be subject to the latter two fates. The aforementioned possibilities are by no means 

complete, but it does indicate movement of pesticides in the environment is very complex with 

transfers occurring continually among different environmental compartments. In some cases, these 

exchanges occur not only between areas that are close together, but it also may involve transportation 

of pesticides over long distances (Barry 2004, Woods 2004). 

7.2.1.1 Terrestrial exposure 

The estimated environmental concentration (ECC) for exposure to terrestrial wildlife would be 

quantified using an 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. 
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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 
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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 

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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). 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

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. 
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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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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 
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Draft Comprehensive Conservation Plan and Environmental Assessment 

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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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 

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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). 
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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. 
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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. 
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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). 
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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 
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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. 
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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). 
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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. 
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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 
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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. 
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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 

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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 >85oF.

Use the lowest spray height possible above target canopy. 

Where identified on the pesticide label, soil incorporate pesticide as soon as possible during or 

after application. 

Octanol-Water Partition Coefficient (Kow): The octanol-water partition coefficient (Kow) is the 

concentration of a pesticide in octanol and water at equilibrium at a specific temperature. Because 

octanol is an organic solvent, it is considered a surrogate for natural organic matter. Therefore, Kow

would be used to assess potential for a pesticide to bioaccumulate in tissues of aquatic species (e.g., 

fish). If Kow >1000 or Sw<1 mg/L AND soil t1⁄2>30 days, then there would be high potential for a 

pesticide to bioaccumulate in aquatic species such as fish (US Geological Survey 2000). 

Threshold for Approving PUPs: 

If there is not a high potential for a pesticide to bioaccumulate in aquatic species, then the PUP 

would be approved. 

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. 
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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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

E-46 Appendix E: Integrated Pest Management Program 

Habitat Management Treatments: 

Presumption of Unacceptable Risk Risk Quotient (RQ)

Listed (T&E) 

Species

Nonlisted Species

Acute Birds [0.1] [0.5]

Mammals [0.1] [0.5]

Fish [0.05] [0.5]

Chronic Birds [1] [1]

Mammals [1] [1]

Fish [1] [1]

Cropland/Facilities Maintenance Treatments: 

Presumption of Unacceptable Risk Risk Quotient (RQ)

Listed (T&E) 

Species Nonlisted Species

Acute Birds [0.1] [0.5]

Mammals [0.1] [0.5]

Fish [0.05] [0.5]

Chronic Birds [1] [1]

Mammals [1] [1]

Fish [1] [1]

Justification for Use:

Specific Best 

Management Practices 

(BMPs):

References:

Table CP.1 Pesticide Name 

Trade 

Namea

Treatment 

Typeb

Max Product 

Rate – Single 

Application 

(lbs/acre or 

gal/acre)

Max Product

Rate -Single 

Application 

(lbs/acre - AI 

on acid equiv 

basis)

Max Number 

of 

Applications 

Per Season

Max Product 

Rate Per Season 

(lbs/acre/season 

or 

gal/acre/season)

Minimum 

Time 

Between 

Applications 

(Days)

a

From each label for a pesticide identified in pesticide use proposals (PUPs), Service personnel 

would record application information associated with possible/known uses on Service lands.

bTreatment type: H – habitat management or CF – cropland/facilities maintenance. If a pesticide is 

labeled for both types of treatments (uses), then record separate data for H and CF applications. 
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

Appendix E: Integrated Pest Management Program E-47

7.0 References 

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Appendix F: Literature Cited F-1 

Appendix F: Literature Cited 

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(Kalaeloa Airport) O ̳ahu, Hawai ̳i. Naval Facilities Engineering Command, Pacific Division, Pearl 

Harbor, Hawai ̳i. 

U.S. Census Bureau. 2010. Population Division. Available at: 

http://www.census.gov/popest/estimates.php. 

U.S. Department of Agriculture (USDA), ARS, National Genetic Resources Program. Germplasm 

Resources Information Network -(GRIN) [Online Database]. National Germplasm Resources 

Laboratory, Beltsville, Maryland. 

U.S. Department of the Interior, Fish and Wildlife Service, and U.S. Department of Commerce, U.S. 

Census Bureau. 2006 National Survey of Fishing, Hunting, and Wildlife-Associated Recreation: 

Hawai ̳i. Washington, D.C. 

USFWS (U.S. Fish and Wildlife Service). 1996. Pacific Islands Ecoregion Coastal Ecosystem 

Program Proposal. Pacific Islands Ecoregion. Honolulu, HI. 

USFWS 1999. Recovery Plan for Multi-Island Plants. U.S. Fish and Wildlife Service, Portland, 

Oregon. 

USFWS 2003. James Campbell NWR Fire Management Plan. U.S. Fish and Wildlife Service, 

Portland, Oregon. 

USFWS. 2004. James Campbell National Wildlife Refuge: Land Protection Planning Study. 

Honolulu, HI. 

USFWS 2005. Draft revised recovery plan for Hawaiian waterbirds, second draft of second revision. 

U.S. Fish and Wildlife Service, Portland, OR. 

University of Hawai ̳i (UH), Sea Grant College Program. 2006. Natural Hazard Considerations for 

Purchasing Coastal Real Estate in Hawai ̳i: A Practical Guide of Common Questions and Answers. 

University of Hawai ̳i (UH), Sea Grant Extension Service and County of Maui Planning Department. 

1997. Beach Management Plan for Maui. 

Uyehara, K. J., A. Engilis, Jr., and M. Reynolds. 2007. Hawaiian duck‘s future threatened by feral 

Mallards. U.S. Geological Survey Fact Sheet 2007-3047. 

Uyehara, K. J., A. Engilis, Jr., and B. Duggar. 2008. Wetland Features That Influence Occupancy by 

the Endangered Hawaiian Duck. The Wilson Journal of Ornithology 120(2):311–319. 

Vitousek, Peter M. 1994. Beyond Global Warming: Ecology and Global Change. Ecology 75(7): 

1861–1876. 

Wagner, Warren L. and Herbst, Derral R. 1995. Contributions to the Flora of Hawai ̳i. IV. Bishop 

Museum Occasional Papers. 42:13-27. Honolulu, HI. 
James Campbell National Wildlife Refuge 

Draft Comprehensive Conservation Plan and Environmental Assessment 

F-12 Appendix F: Literature Cited 

Wagner, W.L., D.R. Herbst, and S.H. Sohmer. 1999. Manual of the flowering plants of Hawai ̳i , 

Revised edition. 2 vols, Bishop Museum Special Publication 97. University of Hawai ̳i Press and 

Bishop Museum Press: Honolulu, HI. 

Walker, R. 2010. Stealing with Tools. `Elepaio 70:44-47. 

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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

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. 

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 

Draft Comprehensive Conservation Plan and Environmental Assessment 

G-2 Appendix G. Statement of Compliance 

Endangered Species Act of 1973. The Service will conduct consultations under Section 7 of 

the ESA for any refuge management program actions that have the potential to affect listed 

species. 

Coastal Zone Management Act, Section 307. Section 307(c)(1) of the Coastal Zone 

Management Act of 1972, as amended, requires each Federal agency conducting or supporting 

activities directly affecting the coastal zone, to conduct or support those activities in a manner 

which is, to the maximum extent practicable, consistent with approved state coastal management 

programs. The CCP is consistent with Coastal Zone Management Act because CCP 

implementation would protect the coastal zone from adverse impacts as a result of modification 

or destruction. 

Executive Order 11990. Protection of Wetlands. The CCP is consistent with Executive Order 

11990 because CCP implementation would protect and enhance existing wetlands. 

Executive Order 11988. Floodplain Management. Under this order Federal agencies "shall 

take action to reduce the risk of flood loss, to minimize the impact of floods on human safety, 

health and welfare, and to restore and preserve the natural and beneficial values served by flood 

plains." The CCP is consistent with Executive Order 11988 because CCP implementation would 

protect floodplains from adverse impacts as a result of modification or destruction. 

Integrated Pest Management (IPM), 517 DM 1 and 569 FW 1. In accordance with 517 DM 

1, and 569 FW1, an integrated pest management (IPM) approach has been adopted to eradicate, 

control, or contain pest and invasive species on the Refuge. In accordance with 517 DM 1, 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. 

 _______________________________ _________________________ 

 Chief, Division of Planning, Date 

Visitor Services, and Transportation 
U.S. Department of the Interior

U.S. Fish & Wildlife Service

O‘ahu National Wildlife Refuge Complex

James Campbell National Wildlife Refuge

66-590 Kamehameha Highway, Room 2C

Hale‘iwa, Hawai‘i 96712

Phone: 808/637-6330

Fax: 808/637-3578

June 2011

Front Cover Photos

Main: ‘Alae ‘ula

©Michael Walther

Inset: ‘Ua‘u kani

©Michael Walther

Ae‘o

©Michael Walther

Honu hatchling

Mike Silbernagle, USFWS

Spring-fed Punamano ̄ wetland/George Fisher, USFWS

Ki‘i wetland and coastline/George Fisher, USFWS